ML20129D863
| ML20129D863 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/21/1985 |
| From: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Opeka J NORTHEAST NUCLEAR ENERGY CO. |
| Shared Package | |
| ML20129D868 | List: |
| References | |
| NUDOCS 8506060249 | |
| Download: ML20129D863 (10) | |
See also: IR 05000219/2003001
Text
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UMTED STATES
. NUCLEAR REGULATORY COMMISSION
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WASHING TON, D. C. 20555
-....... May 21, 1985
-Docket No. 50-423
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LNortheas'tfNuclearEnergyCompany
ATTN: -Mr.' John F.-Opeka
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Senior Vice President - Nuclear
. Engineering and Operations Group
P.O.' Box 270 .'
' Hartford,'CT - 06141-0270
-Gentlemen:
, -
. SUBJECT:
CONSTRUCTION APPRAISAL TEAM INSPECTION 50-423/85-04
Enclosed is the report of the Construction Appraisal Team (CAT) inspection
conducted by the Office of Inspection and Enforcement on February 19-March 1
and March 11-22 1985'at-the Millstone Unit 3 site.
Team was compose,d of members of IE, NRC Region I and a number of consulta
The inspection cevered construction activities authorized by NRC Construction
Permit CPPR-113.
This inspection is .the eleventh of a planned series of construction appraisal
' : inspections by the Office of Inspection and Enforcement. The results of these
inspections are being used to evaluate the management control of construction
activities and the quality of construction at nuclear plants.
The enclosed report identifies the areas examined during the inspection.
Within these areas, the effort consisted primarily of detailed inspection of
selected hardware subsequent to quality control inspections, a review of
selected portions of your Quality Assurance Program, examination of procedures
and records, and observation of work activities.
Appendix A to this letter is an Executive Summary of the results of this
inspection and of conclusions reached by this office. The NRC CAT noted no
pervasive breakdown in meeting construction requirements in the samples of
installed hardware inspected by the team or in the licensee's project
p construction controls for managing the Millstone Unit 3 project.
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However, deficiencies noted by the NRC CAT indicate that a number of construc--
tion program weaknesses exist which warrant additional management attention.
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The major areas of concern to the NRC CAT are: (1) ineffective implementation
and contro1~of work on systems ~and components subsequent to turnover from
! construction to the testing organization and (2) need to improve interface
actions and communications among the design, construction, and inspection
! organizations.
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s Copy to RCPBt1E
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. Northeast Nuclear Energy Company -2- May 21, 1985
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Appendix'B to this letter contains a list of potential enforcement actions
based on the.NRC CAT inspection observations. These are being reviewed by the
Office of Inspection and Enforcement and the NRC Region I Office for
appropriate action. In addition, Region I will be following your corrective
action for deficiencies identified during this inspection.
In accordance with.10 CFR 2.790(a), a copy of this letter and the enclosures
will be placed in the NRC Public Document Room. No reply to this letter is
required at this time. You will be required to respond to these findings
after a decision is made regarding appropriate enforcement action.
Should you have any questions concerning this inspection, please contact us or
the Region I Office.
Sincerely, ,
/3/
James M. Taylor, Director
Office of Inspection and Enforcement
Enclosures:
1. Appendix A - Executive Summary
2. Appendix B - Potential Enforcement Actions
'3. Inspection Report
cc w/ enclosures: See next page
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IE:RCPB IE:RCPB IE:D W DI IE:D/DIR
HWong RHeishman JGPartlow RHVollmer JMi a lor
05/7 /85 05/ /85 05/ /85 05/ /85 05 p /85
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Northeast Nuclear Energy Company -3- May 21, 1985
cc w/ enclosures:
Northeast Utilities Service Company Robert W. Bishop, Esq.
ATTN: Mr. V. Papadopoli, Supervisor Corporate Secretary
Construction Quality Assurance Northeast Utilities
Millstone Unit 3 P. O. Box 170
P. O. Box 328 Hartford, CT 06141
Waterford, CT 06385
Northeast Utilities Service Company Mr. Kevin McCarthy
ATTN: Mr. Edward J. Mroczka, Director
Vice President, Nuclear Operations Radiation Control Unit
P. O. Box 270 Department of Environmental
He.rtford, CT 06141 Protection
State Office Building
Northeast Utilities Service Company 165 Capital Avenue
ATTN: Mr. E. R. Foster, Director Hartford, CT 06106
Generation Construction
P. O. Box 270 Mr. T. Rebelowski
Hartford, CT 06141 Senior Resident Inspector Office
U.S. Nuclear Regulatory Commission
Northeast Utilities Service Company Millstone III
ATTN: Mr. R. T. Laudenat, Manager . P. O. Box 615
Generation Facilities Licensing Waterford, CT 06385
P. O. Box 270
Hartford, CT 06141
Northeast Nuclear Energy Company
ATTN: Mr. D. O. Nordquist, Manager of
Quality Assurance
P. O. Box 270
Hartford, CT 06141
Mr. Michael L. Jones, Manager
ProjectManagementDepartment
Massachusetts Municipal Wholesale
- Electric Company
Post Office Box 425
Ludlow, Massachusetts 01056
Gerald Garfield, Esq.
Day, Berry & Howard
City Place
Hartford, CT 06103-3499
Mr. Maurice R. Scully, Executive Director
Connecticut Municipal Electric
Energy Cooperative
268 Thomas Road
I Groton, CT 06340
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, .' Northeast Nuclear Energy Company -4. May 21, 1985
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DISTRIBUTION:
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Regional Division Directors
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Resident Inspector
_ _ _ - _ _ . _ _ _ _ _ _ - _ _ _ . . _ - _ _ - _ .___-___--_-___ _ ___- - ______-__ _ _ _ _ _ _ _ . _ __ _ __ _ -
APPENDIX A
EXECUTIVE SUMMARY
An announced NRC Construction Appraisal Team (CAT) inspection was conducted
at Northeast Nuclear Energy Company's Millstone Unit 3 during the period
February 19-March 1 and March 11-22, 1985.
Overall Conclusions
Hardware and documentation for construction activities were generally in
accordance with requirements and licensee commitments. However, the NRC
CAT did identify a number of construction program weaknesses that require
additional management attention. These include:
1. Control of work on systems and components subsequent to turnover from
Construction to the testing organization requires improvement. This is
indicated by the deficiencies found in the control of wiring changes, and
preventive maintenance deficiencies found in the mechanical and electrical
areas subsequent to turnover to the startup organization. Additional
attention is needed to ensure that missed maintenance activities are
evaluated as to the potential damaging effects on the components. These
findings indicate the need to reevaluate the controls applied to activi-
ties subsequent to system turnover from Construction to Operations.
2. A number of hardware deficiencies were identified which appear to have
been caused by a lack of effective communications between the design,
construction, and inspection groups. Design parameters were in some
cases not properly translated into inspection criteria. For example, pipe
supports had been installed and accepted by QC with dimensional tolerances
not in accordance with the design calculations. In addition, a lack of
thoroughness on the part of the design organization was identified.
Examples identified include: omission of the Residual Heat Removal System
from the pipe support " lugs-in-contact" review; wiring termination changes
made to drawings without the issuance of the necessary documents to
control the actual construction work; inadequate technical justification
for the acceptance of unmarked fasteners in certain motor control centers;
and conflicting details for a structural steel end connection.
3. A significant number of document control errors were found at both the
Quality Control and Construction drawings stations. This is of particular
concern in that the deficiencies in document control had been identified
previously, and the number of audits increased to monitor the situation.
In fact, a 100% audit of all drawing stations had been performed just
prior to the start of the NRC CAT inspection. The corrective actions
taken had not been effective, however.
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4. A number of findings indicate that the effectiveness of Quality Control
inspection activities needs to be improved. These findings include the
area of piping as-built drawings, mechanical equipment foundation anchorage,
i structural steel connections (welded and bolted), piping support welding
(pipe straps and skewed fillet welds), and pipe support miscellaneous
i hardware (lock nut tightness, cotter pin installations, etc.). Also,
vendor deficiencies were identified in the areas of tank and heat
exchanger fillet welds (pressure boundary and supports), performance
of load indicating washers, and marking of fasteners.
The foregoing identified weaknesses require additional management attention
to assure that completed installations meet design requirements.
AREAS INSPECTED AND RESULTS
Electrical and Instrumentation Construction
The electrical and instrumentation samples inspected generally met the applicable
design requirements and installation specifications. Several discrepancies
were identified including some that will require additional management attention.
Numerous electrical separation discrepancies were identified in the Main
Control Board wiring installed by the vendor and as modified by design and
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construction activities. Several areas were noted in which redundant electrical
division wires were in contact with each other.
Electrical separaticn criteria detailed in the Millstone Unit 3 FSAR had not
been met in many raceway and cable installations. However, lesser separation
may be acceptable based on recent tests. This matter is considered open
pending NRR review and evaluation.
During examination of Class IE cable ends, a number of terminations were
identified that were not in accordance with current design drawings. One
group of discrepancies pertains to incomplete implementation of design changes.
The second group relates to inadequate documentation of post-turnover wiring
changes.
Mechanical Construction
HVAC restraints, concrete expansion anchor installations, pipe wall thickness
and piping hydrostatic test records were found to be in general conformance
to design and procedural requirements.
Numerous discrepancies were identified in pipe support / restraints and mechani-
cal equipment foundation installations. A number of discrepancies were
observed between as-built drawings and piping configurations. Greater atten-
tion to detail during QC inspections appears necessary.
A need for more thorough engineering review activities, and additional
reinspection and/or reanalysis was observed. This need was indicated by:
unclear inspection criteria and inadequate engineering interface for pipe
support / restraint attachment locations; inadequate review of attachment lug
contact criteria; and a number of drafting errors.
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The NNEC0 maintenance program and maintenance activities performed after
equipment turnover from Construction were considered to be inadequate. This
item had been previously identified, but corrective actions taken had not been
effective or timely.
Welding and Nondestructive Examination
Welding and nondestructive examination activities were gerorally found to be
conducted in accordance with the governing codes and specifi 3tions. However,
a number of examples were identified where completed structural telds in pipe
supports involving skewed welded connections did not have the weld sizes
specified by the Architect-Engineer. These undersized welds in skewed
connections should have been identified during the weld inspection process,
and their existence indicates a program weakness. The licensee has performed
an engineering evaluation concerning this problem and concluded that most of
these welds are adequate for the intended application. In the area of vendor
supplied tanks and heat exchangers a number of tanks were found to heve
undersized weld reinforcements in nozzle and manway welded jointt. In addition,
some tank supports were found to have deficient welds.
Civil and Structural Construction
In general, concrete quality, cadwelding and concrete material certification
were found to be acceptable. Rebar appeared to be placed in accordance with
the design drawings. However, the NRC CAT inspectors identified unauthorized
material in the building isolation joints (rattle spaces).
Structural steel member size and configuration were generally found to be
acceptable. A nember of steel connections in the Main Steam Valve Building
were found to be not in accordance with the design drawings. Based on testing
by the NRC CAT, problems were identified in the performance of load indicating
washers.
Material Traceability and Control ,
The licensee's material traceability and control program was found to be
acceptable, except for certain fastener hardware. Significant lack of
traceability was found for vendor fastener materials, including bolts for
mounting large pump motors, bolts for battery racks and bolts for inter-
connecting adjacent motor control center cabinets.
Design Change Control
Design change control was determined to be in accordance with site procedures
with the exception of timely updating of design documents with the latest
change information. A number of drawings were found to be overdue for updating
to include the latest design change requirements. In the area of design
document control, a significant number of document control errors were found at
site drawing stations used for construction work and QC acceptance. Weaknesses
were also identified in the use of yellow drawings and document control audits.
In addition, four cases of apparent inadequate corrective actions were noted
in both the document control and design change control areas.
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- Corrective Action Systems-
A weakness was:found in the corrective actions taken to control preventive
maintenance after components had been turned over for testing / operation. In'
addition, corrective actions applied to design change controls and document
control deficiencies had not been effective. Also, an-increasing number of
unresolved nonconformances was-found after turnover of system packages for.
. testing / operation. These matters require additional management attention.
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APPENDIX B
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POTENTIAL ENFORCEMENT ACTIONS-
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As' a _ result of' the NRC CAT inspection of February 19 - March 1 and March 11-22,
'1985 at the Millstone Unit 3: site, the following items are being referred to
Region Itas-Potential Enforcement Actions! Section references are to the detailed
portion of the inspection report.
1. 10 CFR 50, Appendix B, Criterion III, as implemented by Northeast Utili-
ties Quality Assurance Program (NVQAP), QAP 3.0, requires that measures'
shall be established to assure that applicable' regulatory requirements are
correctly translated into specifications, drawings, procedures and -
' instructions.
Contrary to the above, at the time of this inspection, the licensee's =
! program for design control has not been adequate to assure that Class IE '
wiring configurations are in accordance with applicable design. As a
result of incomplete control'of electrical ' termination changes, a number
of existing installations may'not perfonn their intended function (Section
II.B.2.b.(6)).
2. 10 CFR 50, Appendix B, Criterion V, as implemented by NVQAP, QAP 5.0,
requires that activities affecting quality shall be prescribed by
documented instructions, procedures or drawings which include appropriate
quantitative or qualitative acceptance criteria.
Contrary to the above, the NRC CAT inspectors found, at the time of this
inspection, that the licensee's programs were not effectively implemented
-in that they:
a. Failed to adequately implement their post-turnover test and
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inspection program
accordance to assure
with applicable that wiringSection
procedures. (changes were documented in
II.B.2.b.(6)).
b. Failed to identify conflicting allowable acceptance criteria between
the design organization and the inspection organization for pipe
supports / restraints (Section III.B.2).
3. 10 CFR 50, Appendix B, Criterion VI, as implemented by NUQAP, QAP 6.0,
requires in part that measures be established to control issue and
distribution of document changes to the prescribed locations.
Contrary to the above, during this inspection, the SWEC design document
control procedures were not adequately implemented in that numerous errors
in distribution, filing and updating of document record cards, design
change documents, drawings and specifications were found to exist in site
- drawing stations used for plant construction and Quality Control inspec-
L tion (SectionVII.B.1).
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4. 10 CFR 50, Appendix B, Criterion VII, as implemented by NUQAP, QAP 7.0,
. requires that measures be established to assure that purchased material,
- equipment and services confonn to the procurement documents.
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Contrary to the above, at the time of this inspection, the implementation
of SWEC's procedures were found to be ineffective in that vendor procured
tanks and heat exchangers were accepted and installed with deficient
welds (Section IV.B.1).
5. 10 CFR 50, Appendix B, Criterion VIII, as implemented by ?!UQAP, QAP 8.0,
requires that measures be established for the control of materials, parts
and components to prevent the use of incorrect or defective items.
Contrary to the above, at the time of this i.nspection the material
traceability and control of some fasteners., includirg busts for mounting
large pump motors, have not been adequate u essure the us9 of currect
material s.
6. .10 CFR 50, Appendix B, Criterion X, as implemented by NUQAP, QAP 10.0,
requires tnat a program for inspection of activities affecting quality be
established and executed to verify conformance with design documents.
Contrary to the above, at the time of this inspection, it was found that
the licensee's programs were not effectively implemented in that they:
a. Failed to ensure that safety-related pipe supports / restraints were
constructed in accordance with design requirements in that support
attachment locations were not installed as shown on design drawings
(Section III.B.2),
b. Did not assure that equipment foundation bolting connections were
installed in accordance with specified acceptance criteria and
requirements (Section III.B.5).
c. Have not assured that the specified weld sizes in skewed structural
pipesupportconnectionshavetherequiredweldsizes(Section
IV.B.1).
7. 10 CFR 50, Appendix B, Criterion XVI, as implemented by NUQAP, QAP 16.0,
requires that measures be established to assure that conditions adverse
to quality are promptly identified and corrected, including action to
avoid repetition.
Contrary to the above, at the time of this inspection, the licensee's
program of Quality Control Inspection had not provided adequate
procedural controls in that there was:
a. Failure to promptly identify and correct numerous separation
deficiencies in vendor or modified vendor wiring installations
withinthemaincontrolboards(SectionII.B.2.b(2)).
b. Failure to promptly perform effective corrective action to prevent
recurrence of nonconformances (Section VIII.B.1.b(1)).
c. Inadequate control of preventive maintenance after turnover for
testing / operating (SectionVIII.B.1.b.(2)).
d. Failure to apply effective corrective actions for document control
deficiencies (SectionVIII.B.1.b.(4)).
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