IR 05000423/1985067

Initial OL Review Insp Rept 50-423/85-67.Major Areas Inspected:Const,Preoperational Testing,Preparations for Operation,Allegations & SALP

ML20138J049
Person / Time
Site:	Millstone
Issue date:	11/25/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20138J038	List: IR 05000423/1985067 ML20138J035
References
50-423-85-67, NUDOCS 8512170420
Download: ML20138J049 (24)

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November 25, 1985 NRC REGION I INITIAL OPERATING LICENSE REVIEW REPORT MILLSTONE POINT UNIT 3 REPORT 50-423/85-67

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8512170420 851210 PDR ADOCK 05000423 G PDR

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SUMMARY AND CONCLUSIONS

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The facility _has been constructed substantially in accordance with an approved quality program, and the Region has no significant outstand-ing construction concerns which are not being recommended as potential license condition The applicant!s preoperational test program has been rigorous and effectiv The applicant's procedures to support startup and operations are late. Special attention to resolution of_this problem is being provided by Region I.

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ENCLOSURE 1

- NRC INSPECTION SUMMARY AT MILLSTONE UNIT 3 1973 Two inspections (582 hours0.00674 days <br />0.162 hours <br />9.623016e-4 weeks <br />2.21451e-4 months <br />) of construction.Q Three inspections (120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />) of structural foundation wor Eight inspections (310 hours0.00359 days <br />0.0861 hours <br />5.125661e-4 weeks <br />1.17955e-4 months <br />) of construction and QA/Q Nine inspections.(341 hours0.00395 days <br />0.0947 hours <br />5.638227e-4 weeks <br />1.297505e-4 months <br />) of construction and-QA/QC, 1977 Twelve inspections (330 hours0.00382 days <br />0.0917 hours <br />5.456349e-4 weeks <br />1.25565e-4 months <br />) of construction and QA/Q ,

1978 Six inspections (116 hours0.00134 days <br />0.0322 hours <br />1.917989e-4 weeks <br />4.4138e-5 months <br />) of' cons'truction and QA/Q Twelve inspections (257 hours0.00297 days <br />0.0714 hours <br />4.249339e-4 weeks <br />9.77885e-5 months <br />) of construction and QA/QC, including special inspection of design documentation for safety-related pipin Eight inspections (323 hours0.00374 days <br />0.0897 hours <br />5.340608e-4 weeks <br />1.229015e-4 months <br />) of construction and QA/QC, including a special inspection of poor work practices and QC by a subcontrac-tor (Graver Tank' Company) at both Millstone 3 and Beaver Valley '1981 Thirteen inspections (1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br />) of construction and QA/QC activi-ties (including the initial CTI).

1982 Fifteen inspections (1421 hours0.0164 days <br />0.395 hours <br />0.00235 weeks <br />5.406905e-4 months <br />) of construction and QA/QC, includ-ing one special inspection of construction deficiencies in rock anchors and a special inspection of the Prompt Public Notification Syste Twenty-two inspections (1868 hours0.0216 days <br />0.519 hours <br />0.00309 weeks <br />7.10774e-4 months <br />) of construction and QA/QC, in-cluding one inspection by the NRC Mobile NDE Laborator Twenty-three inspections (2832 hours0.0328 days <br />0.787 hours <br />0.00468 weeks <br />0.00108 months <br />) of construction, preopera-tional testing, and QA/QC including a team inspection focused on management, design control, QA, and construction contro Sixty-five inspections (8572 hours0.0992 days <br />2.381 hours <br />0.0142 weeks <br />0.00326 months <br />) as of early November 1985. These-focused on construction completion, testing and test results review, and preparations 1for operations. There were four inspections by the Office of Inspection and Enforcement (CAT and Engineering Assurance Program reviews), one as-built team inspection using an NRC consultant, and one.as-built team in-spection using NRC. Region I. personne r- _ ,

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ENCLOSURE 2 SPECIAL ASSESSMENT OF THE QUALITY OF CONSTRUCTION OF MILLSTONE UNIT 3* .~0ver 18,000 man-hours of NRC field inspection h' ave.been expended on Mill-stone 3. The inspections have.addre_ssed the applicable inspection-programs and specific concerns raised during Unit-3 constructio B.: 'Special ' inspections conducted by the ' Region inc:lude:

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. Regional CAT (1981) - There was a tot'al of 25 findings; 8 violations, 17 unresolved. The majority of the findings were administrativ NDE Van (1983) - There were 2 violations; one for penetrameters across weld areas of. interest, and the other for film densities exceeding code

. requirement HVAC (1984) - Special audit.-regarding Bahnson Company (HVAC equipment-supplier).. There were 3 findings; 2 of which had been.previously iden-tified by SWEC Field Quality Control: Self tapping screws used in place of high strength bolts (identified by SWEC). Stove bolts and wing. nuts 'used instead of high strength b'olts (identified by SWEC).

. Low strength bolts used.in areas where high strength bolts were-specified (identified by NRC).

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CTI-(1984) - There were a total of-13 observations; 6 violations,4 un-resolved, and 3 IFI CAT (1985) - Enforcement actions:

-1.- Licensee's program for design contro . Programs for post turnover. test not effectively implemente . Design document. control.

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• Note: Much of the data in Sections E, F, and G of this enclosure was compiled-by the applicant's QA organization based on an informal request made by the Region I staff to'the applicant!s. Construction Quality-Assurance Superviso That-information is essentially as_ presented by the utility staff'without being verified correct by the NR ..

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Enclosure 2 2 NDE Van (1985) - 2 violations were noted for unacceptable radiographic

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indications and failure to control unique identification numbers on controlled drawing There were no Severity Level III or' higher violations and no Enforcement Meetings for the construction of Millstone Unit The quality control.and quality assurance organizations have adequately

controlled the quality of. work'at Millstone. . Northeast Utilities (NU)

Construction Quality Assurance retained review and approval rights for all

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contractors' inspections'and work procedures. These quality assurance reviews and approvals assisted in maintaining high quality for construction activities. The quality program at Millstone has identified quality problems early in the work process and has achieved timely and effective corrective actions and reinspection Throughout the years, Region I has received adequate responses from the applicant to inspector concerns. Further, it has been observed that the applicant has exercised strong control of the quality of the work by the major contractor,' Stone and Webster, and of subcontractor E. -The Millstone project has a three-level quality program concept as described belo The three-level construction verification program utilizes the defense-in-

. depth concept. The first level, QC inspection, is performed by Stone and Webster Field Quality Control, which is independent from the construction forces. Quality Control 'is responsible for verifying that the product meets the specified design requirements. The second level, QA auditing, is performed by Stone and Webster's Quality Assurance. Auditing Division, which is independent from the construction forces and Quality Contro The third level, Construction QA, is a section within the NU Quality Assurance Branch, which is entirely independent from all Stone and Webster organiz'ation Construction QA audits, performs surveillances, and makes in process veri-fications to assure that the quality programs of the first and second level organizations function as required. In addition, NU reviews specifications, site procedures, and other required documents furnished by Stone and Webster to assure that quality requirements have been incorporate The Quality Assurance organization is staffed with highly qualified per-sonnel. The staff consists of graduate engineers with several years of engineering or nuclear -industry experience, graduate technical scientists or technologists with several years of nuclear industry experience, and non-degreed technicians with. several years of nuclear experience. Several of the key individuals are additionally SNT-TC-1A certified, ASNI N45. inspectors, ASME VT 1 through 4 certified, or have been previously licensed at a nuclear facility. This quality organization is functionally and admin-istratively independent of the Millstone 3 project organizatio The organization remains in close contact with the NU engineering departments for consultation and technical assistance when neede .

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Enclosure 2 3

To date, Northeast Utilities Construction Quality Assurance personnel have, conducted over 450 audits. These have confirmed that the first two levels of the quality program are working effectivel Northeast Utilities Service Company also audits the corrective actions on problems identified by S&W Quality Assurance audit reports. Additionally, Nonconformance. Reports having a "Use-As-Is" or " Repair" disposition are sent to NUSCo Construction Quality Assurance for review and concurrenc If there are any questions about any item in the S&W reports, the NUSCo Construction Quality Assurance Organization-takes investigative actio This has been effective in assuring Northeast Utilities management that S&W corrective actions are satisfactor The quality ~ assurance'. program implementation at the Millstone 3 station is also subject to review and/or verification by five independent outside organizations:

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The American Society of Mechanical Engineers (ASME)

Stone and Webster Construction, Inc. has received and maintained its ASME

.. certification to install nuclear pressure retaining components. ASME teams audit every three years, with welding being one of the major areas covere National Board of Boiler and Pressure Vessel Inspectors Members of the Board participate in the ASME surveys and in the decision to grant the certificate. In addition, members of the National Board certify the Authorized Nuclear Inspectors who perform the ANI inspections described belo Hartford Steam Boiler Inspection and Insurance Company Hartford maintains a staff of Authorized Nuclear Inspectors (ANIS)

onsite as required by the ASME Code. These inspectors monitor ASME

, related activities and have the authority to assign construction hold points. In addition, Hartford supervision performs semi-annual audits of applicable-S&W activities associated with ASME Code weldin Joint Utility Management Audits (JUMA)

Northeast Utilities has been a participating member in a Joint Utility Management Audit Group since the early 1980s. This group manually audits-Northeast Utilities' activities. The JUMA audits of Northeast Utilities are conducted by senior supervisory quality assurance personnel from other utilitie . Institute of Nuclear Power Operations (INPO) - Construction Project Evaluation (CPE)

The INPO Construction Project Evaluation was developed as a standard method of evaluating Utilities' nuclear construction program ._ __

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Enclosure 2 4 Northeast Utilities supports the INPO CPE and has actively partici-pated in the development and trial of the Phase I evaluatio The above organizations evaluations, auditing, and verifications of the project have all been positive. The ASME audits have resulted in the extension of S&W ASME Certification of Authorization. The onsite Authori-zed Nuclear Inspector has verified the ASME work is done in accordance with the Code requirements. The semi-annual audits by Hartford have not identified a major problem. JUMA audits and INP0 evalu~ations have con-cluded that the Millstone 3 QA program is effective and is being effec-tively implemente INP0 evaluations and JUMA audits go beyond verifying conformance with established programs and make recommendations for improvements. Northeast Utilities has evaluated the INPO and JUMA recommendations and has adopted many of them. The results of these outside agencies' evaluations and audits have been beneficial. They have reported to the Company's manage-ment from a different perspective. This has further increased the con-fidence the company has in its quality assurance program which, in turn, leads to a higher degree of confidence in qualit The Northeast Utilities Quality Assurance Section has the. authority to stop work independent of the Construction organization and has not shown'a reluc-tance to do so when conditions warrant this action. The following summarizes stop work ~ actions. initiated by Northeast Utilities Construction Quality As-surance Organization:

Year Description Remarks 1974 Insufficient and un- NUSCo overall QA program evaluation re-approved QA program vealed that there was an insufficient-number of QA/QC procedures present to control Category I wor Drawing control Apparent lack of control of revised / changed or new drawing issued for construction use in the fiel Drawing. control Drawings and documents changing drawing were not properly maintained in the field station. This station not within program requirement Northeast Utilities Construction Quality Assurance has an onsite staff of Quality Assurance personnel which conducts routine onsite audits, in process-verifications (IPVs), and surveillance of Millstone 3 construction. A summary of the results of the documents are as follow .

Enclosure 2 -5 Number of Number of Number of Number of Year Audits Findings IPVs Findings 1974 3 8 0 0-1975' 41- 43 0 0 1976 24 38 0 0 1977 27 45 0 0 1978 18 24 0 0 1979 27 27 0 0 1980 9 13 3 14 1981 41 27 3 4

,1982' 43 100 19 18 1983 41 -135 19 29 1984 21 103 7 14 1985*- 11 62 5 18 306 625 56 97

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~ Year' Surveillance Reports Findings

'1975 90 4

~1976 116 7 1977 193 42 1978 307 44

~1979 196 2 JI981 404 .91 1982 379 197 1983 436 161 1984- 1126 372--

1985* 720 263 4081 1237

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-Enclosure 2 6 Additionally, Northeast Utilities Quality Assurance, Procurement Section, has performed audits of the NSSS supplier, Westinghouse, and Stone and Webster as follows:

Number o Number of Year Audits Findings

1974- 12 4 1975- 20 21

,1976 12 10 1977 9 5 1978 9 25 1979 17 33 1980 20 26 1981 28 65 1982 2 * -9 0 169 .244

• As of 8/10/8 ' Stone and Webster QA and QC have also issued nine stop work orders and conducted 221 audits and 1348 field monitoring 1nspections during the construction of Mill-stone 3.

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ENCLOSURE 3 MILLSTONE UNIT 3 ALLEGATIONS (Closed) Improper construction practices and alcohol and drug abuse by craf Concerns were not substantiated; however, the applicant took additional meas-ures to ensure good construction practices (1983). (Closed)' Improper' design specifications in use. Concerns were not substan-tiated; alleger subsequently withdrew concerns (1983). (Closed) ' Improper changes to construction specifications and improper welding on HVAC; improper procurement practices; and craft drug abuse. The HVAC concern was substantiated. Adequate corrective and preventive actions were taken by the applicant. No safety significance was identified (1983). (Closed) Improper welding on non-safety-related pipe' support The concern was not. substantiated (1983). (Closed) Possible poor quality weld on safety-related pipe. The concern was not substantiated (1984). (Closed). Improper design and qualification of fire protection system for safety-related charcoal filter beds. .The concern was not substantiated (1984). (Closed) Improper QC documentation and poor welding of instrumentation pipe supports. The concern was.not substantiated (1984). (Closed) Improper enhancement of .QC signatures on drawings. The concern was substantiated. There is no safety significance since no technical changes were made. The applicant implemented appropriate administrative-controls to prevent the practice (1984).

9 .- (Closed) Improper supports (Hilti bolts undersized). The concern was reviewed by the applicant and Region I and was not substantiated (1984).

1 (0 pen) Improper' changes to cable pull tickets. The concern was substantiate There is no safety significance. The applicant took adequate corrective and preventive-actions. Closeout-documentation in progress (1985).

1 (0 pen)' Individuals were reassigned to prevent identification of problem The concern was not substantiated. Closecut documentation is in progress (1985).

1 (0 pen) Turnover of EA-180 limit switches was effected without adequate inspection. NRC followup confirmed that about 200 EA-180 limit switches on safety-related valves may have been assembled improperly. The appli-cant's corrective action is in progress as part of his environmental qualification program. The licensee reported this problem to.the NRC about a year before the allegation was received, and the allegation is being closed because it did not identify any unaddressed safety issu _

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Enclosure 3 2 1 (0 pen) Field changes approved without adequate research or checking. The concern was substantiated. No safety significance was identifie The applicant took adequate corrective actions. Closecut documentation is in progress (1985).

1 (0 pen) Electrical.FQC inspections and records are inadequate. Concern was not substantiated. Closecut documentation is in progress (1985).

1 (0 pen) FQC inspectors are not qualified. The concern was not substantiate Closeout documentation is in progress (1985).

1 (0 pen) I&C (electrical) inspection procedures are not established. The concern was not substantiated. Closeout documentation is in progress (1985).

1 (0 pen) Worker concerns are not responded to. The applicant's allegation response program adequacy was questioned by Region I and upgraded by the applicant. Closeout documentation is in progress (1985).

1 (0 pen) Electrical FQC inspectors require training (not qualified). The concern was not substantiate Closeout documentation is in progress (1985).

1 (0 pen) Improper floor coatings and painter qualifications. -The applicant investigated the issue and found no evidence of safety significance. NRC review identified no safety inadequacy. Closecut documentations in pro-cess (1985).

2 (Closed) Alteration to painter qualification test plate. OI investigation is complete; concern was substantiate The applicant has provided Region I with their QC. data confirming the adequacy of coatings in the fiel This information is being evaluated (1985).

2 (0 pen) Improper welding inspections. The applicant investigated these issues and found no substantiating evidence. NRC review is in process (1985).

2 (0 pen) Improper ASME paper review. Preliminary review by Region I is complete, with no safety significant findings. Referred to OI for inquiry. OI review is complete; report submission is in progress (1985).

2 (0 pen) Improper preparation of pipe prior to insulatin The applicant reviewed the concern and found no substantiating evidence. Region I reviewed the. issue and also found no substantiating evidence. Closecut documentation is in progress (1985).

2 (0 pen) Worker harassment following identifying of a safety concern to NR No safety concerns are presently involved. The individual was referred to 00L. Closecut of the allegation is in process (1985).

2 (0 pen) Pipe was improperly aligned to a pum The concern was not substan-tiated. Closecut documentation is in process (1985).

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Enclosure 3 3 2 (0 pen) Worker alleged he was included in a layoff because he identified safety concerns to the NRC. The individual was advised of the need to contact DOL. Preliminary checks did not identify any safety substance to the concerns. Further review is in progress. The layoff issue is being referred to the Offi.ce of Investigations for a preliminary inquir (1985)

ENCLOSURE 4 RECOMMENDED LICENSE CONDITIONS 1. Demonstrate operability of gaseous fire suppression system prior to initial criticalit . Adopt final approved procedure's for Operational Modes 1-4 one week prior to entering the mode for which the procedures are require l 3. Provide satisfactory engineering resolution for all significant construction deficiencies [10 CFR 50.55e(e) reports] prior to initial criticality.