IR 05000458/1981015
| ML20054M544 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 04/27/1982 |
| From: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | William Cahill GULF STATES UTILITIES CO. |
| Shared Package | |
| ML20054M538 | List: |
| References | |
| NUDOCS 8207130566 | |
| Download: ML20054M544 (18) | |
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B 7 APF 1932 Docket:
50 -b8/81-15 Gulf States Utilities ATTN:
Mr. Williae J. Cahill, Jr.
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Senior Vice President -
River Bend Nuclear Group P. O. Box 2951 Beaumont,.TX 77040
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Gentlemen:
This refers to the Systematic Assessment of Licensee Performance (SALP) Board Report of the River Bend Facility, Unit 1, Construction Permit CPPR-145.
The SALP Board met on October 6, 1981, to evaluate the performance of the subject facility for the period July 1,1980, through June 30, 1981.
The performance analyses and resulting evaluation are documented in the enclosed SALP Board Report.
These analyses and evaluation were discussed with you at our office in Arlington, Texas, on November 19, 1981.
The performance of your facility was evaluated in the following functional areas: Soils and Foundations; Containment and other Safety-Related Struc-tures;. Piping Systems and Supports; Electrical Power Supply and Distribution; Licensing Activities; and Corrective Action and Reporting.
The SALP Board evaluation process consists of categorizing performance in each functional area.
The categories which we have used to evaluate the performance of your facility are defined in Section II of the enclosed SALP Board Report. As you are aware, the NRC has changed the policy for the conduct of the SALP program based on our experiences and the recently implemented reorganization which emphasizes the regionalization of the NRC staff. This report is consistent with the revised policy.
Any comments which you may have concerning our evaluation of the performance of your facility should be submitted to this office within 20 days of the date of this letter.
Your comments, if any, and the SALP Board Report, will both appear as enclosures to the Region IV Administrator's letter which issues the SALP Report as an NRC Report.
In addition to the issuance of the report, this letter will, if appropriate, state the NRC position on matters relating to the status of your safety program.
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8207130566 820621 PDR ADOCK 05000458 G
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Gulf States Utilities I332
Comments which you may submit at your option, are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork
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Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this inspection, we will be pleased i
to discuss them with you.
Sincerely, i sisnod by
,,origina g,g, MADSEN"'
G. L. Madsen, Chief Reactor Project Branch 1-l (SALP Board Chairman)
Enclosure:
i Appendix - NRC Report 50-458/81-15
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REGION IV==
System Assessment of Licensee Performance Report:
50-458/81-15 Docket:
50-458 Licensee: Gulf States Utilities P. O. Box 2951 Beaumont, Texas 77040 Facility Name:
River Bend, Unit 1 Appraisal Period:
July 1, 1980-June 30, 1981 Appraisal Completion Date:
October 6, 1981 Licensee Meeting:
November 19, 1981 SALP Board:
G. L. Madsen, Chief, Reactor Project Branch 1 W. A. Crossman, Chief, Reactor Project Section B R. L. Perch, NRR Project Manager
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A. B. Beach, Senior Resident Inspector R. C. Stewart, Reactor Inspector Reviewed by:
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Crossp6n, Chief Dite/
Reactor Prpject Section B Approved by:,, / /3I6[e
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G. L. Madsen, Chief Date Reactor Project Branch 1 (SALP Board Chairman)
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I.
Introduction
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Systematic Assessment of. Licensee Performance (SALP) tis'an integrated NRC staff effort to collect-available observations and data annually and to J
evaluate licensee performance utilizing 'these data and observations as a basis.
The integrated systematic assessment ~ is intended to be sufficient-ly diagnostic to provide a rational basis.for allocating NRC resources and to provide meaningful guidance to licensee management.
II.
Criteria The assessment of licensee performance is implemented through the use'of seven evaluation criteria.
These criteria are applied to each functional area that is applicable to the facility activities (construction, pre-operation, or operation) for the categorization of licensee performance in these areas.
One or more.of the following evaluation criteria are used to assess each applicable functional area.
1.
Management involvement in assuring quality 2.
Approach to resolution of technical issues from safety standpoint 3.
Responsiveness to NRC initiatives 4.
Enforcement history 5.
Reporting and analysis of reportable events 6.
Staffing (including management)
7.
Training effectiveness and qualification Attributes associated with the above evaluation criteria form the guidance for the SALP Board for categorization of each functional area in one of three categories.
Performance categories are defined as follows:
Category'1:
A combination of attributes which demonstrates achievement of superior safety performance; i.e., licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieved.
Reduced NRC attention may be appropriate.
Category 2:
A combination of attributes which demonstrates achievement of satisfactory safety performance; i.e., licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that
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satisfactory performance with respect to operational safety or construction is being achieved.
NRC attention should be maintained at normal levels.
Category 3:
A combination of attributes which demonstrates achievement of only minimally satisfactory safety performance; i.e., licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance it.h respect to operational safety or' construction is being achieved.
Both NRC and licensee attention should be increased.
III. Summary of Results
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Functional Areas Category 1.
Soils and Foundations
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Containment and other Safety-Related
Structures 3.
Piping Systems and Supports
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Safety-Related Components NA 5.
Support Systems NA 6.
Electrical Power Supply and
Distribution 7.
Instrumentation and Control Systems NA 8.
Licensing Activities
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Corrective Action and Reporting
IV.
Performance Analyses The SALP Board obtained assessment data applicable to the appraisal period of July 1,1980, to June 30, 1981.
The data for the River Bend Station (RBS) was tabulated and analyzed and a performance analysis was developed for each of six functional areas.
The SALP Board met on October 6, 1981, to review the performance analyses and supporting data and to develop the SALP Board Repor O o.
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Functional Area Analysis 1.
Soils and Foundations Reviews in this functional area have not identified any major problems.
The major work performed in this area during the evaluation period involved backfilling operations.
One violation (Severity Level V) was identified in this area; however, had the SRI been given all the information obtained in the response to the citation, the concern would have been satisfied.
The average relative density for backfill (Category I) at the site was calculated as 9^ percent.
The soils program is now complete, and
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all observations and records reviewed indicate that the program met or exceeded the Safety Analysis Report (SAR) requirements.
Assessment of the licensee's attributes in this area revealed a Category 1 level.
2.
Containment and Other Safety-Related Structures The licensee's QA organization has been very perceptive and aggressive in problem identification, but has been deficient in timely corrective action.
Problems involving concrete placement activities were continuously identified-since April 1980, but it was not until April and May 1981, that these problams involving consistency of concrete were sufficiently solved.
Numerous problems were reviewed on a " case-by-case" basis, rather than a review of the
" programmatic" aspect relative to concrete consistency of placement.
Problems continued to plague concrete placement activities through-out most of the evaluation period.
Four violations (infractions),
three deviations, and one deficiency were identified by NRC inspectors.
Many actions to improve concreting placement have been initiated, and as a result, concrete placement has improved.
The programs for both concrete placement and concrete testing are now being implemented in accordance with adequate procedural requirements.
However, 22 Nonconformance and Disposition Reports were written from Cctober 1980 until July 1,1981, involving improper consolidation of concrete resulting in voids and/or honeycombs.
Five of these involved voids completely through wall areas.
However, as documented in IE Inspection Report 50-458/81-07, these voids were not of a significant size and were appropriately documented and repaired to adequate procedures and in accordance with quality control requirements. Thus, the importance of consistency of concrete placements must continue to be emphasized to preclude previous placement problems, especially.in the more difficult areas in the higher elevations of the shield and drywell wall area.
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No significant problems have been ide'ntified in the construction of the containment liner. by Graver. Engineering during the evaluation period.
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The Board considered manage' ment: cont'r61 in this functional area to be Category 2 le' vel.
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3.
Piping Systems and: Supports
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Very early in the program, the SRI has, on several occasions, expressed concern regarding a high weld reject rate (greater than 50 percent of the welds made).
The licensee is evaluating methods to correct this problem, such as radiography of weld qualification coupons (not required by the Code), and a review of the training program to seek improvements.
ll Since less than 2 percent of the safety-related welds have been completed, it is difficult to assess the program at this time.
However, the weld rate must be monitored to ensure that quality welds are being made in accordance with the licensee's commitments.
Assessment of the licensee's attributes in this functional area revealed a Category 2 level.
4.
Safety-Related Components, Including Vessels, Internals and Pumps Since there was very limited activity performed in this functional area during the evaluation period, this area was not inspected.
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5.
Support Systems Including HVAC, Radwaste and Fire Protection There was very limited activity in this functional area during the
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assessment period and this area was not assessed.
6.
Electrical Power Supply and Distribution t '
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Although no real electrical installation has been started, the licensee remains dedicated to assurance that the electrical equipment qualifications meet the requirements of IEEE 323-1974.
Much attention has been focused in this area as a result of the petition from the Union of Concerned Scientists requesting construction work at the River Bend site be halted.
This petition was subsequently dismissed by'the NRC during this evaluation period.
The licensee is further into its qualification program than are many of the utilities participating in the BWR Owner's Group who are, likewise, committed to the newer IEEE 323-1974 requirements.
He is aggressively seeking a viable program, both with General Electric
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and his vendors to ensure his commitments are satisfied.
Considering the status of construction, it is encouraging to view the progress made in the equipment qualification area.
The Board's assessment of the licensee's attributes in this functional area is considered to be Category 2.
7.
Instrumentation and Control Systems This functional area was not inspected during the evaluation period due to limited activity.
8.
Licensing Activities The plant was in the post-CP period for the majority of this appraisal period.
As such, correspondence has been very limited.
Principal act'ivity was related to:
(1) requests for amendments for additional plant ownership by Cajun Electric; and (2) agreements regarding modifications to a transmission line corridor through the Port Hudson National Battlefield.
In both cases, the information provided by the applicant was of high quality.
A high degree of cooperation by the applicant was.shown on both matters which significantly reduced the time and effort needed to achieve acceptable resolution of the issues.
In response to st'aff requests, the utility consistently meets schedules and takes the initiative in communicating with the staff to solve problems.
The applicant has been keeping up to date on NRC needs through generic letters and developments on other plants.
The applicant is highly knowledgeable regarding these matters and new requirements.
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'This is Gulf States Utilities first nuclear power plant.
The applicant's level of experience is most visible in its construction schedule estimates which are very optimistic based on the evaluation of the Caseload Forecast Panel' conducted during this evaluation period.
The licensee compensates for his lack of corporate experience by the hiring of knowledgeable key staff and by his utilization of his A/E contractor, Stone and Webster.
The Board assessed the licensee's performance in this functional area to be Category 1, 9.
Corrective Action and Reporting Correctiveaction'isalsobiscussed'underFunctionalArea2.
As for reporting, there appears'to be a reluctance on the part of the licensee relative to the reportability of license identified problems in accordance with 10 CFR 50.55(e).
Three licensee deficiency reports were reported to the Region IV office during the evaluation
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period. Although there may be some misunderstanding of reporting requirements, this is rather unlikely in that a management meeting was held in late 1979 tc discuss.reportability-requirements in response to several identified problems relative to reporting.
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One example of a possible deficiency that should have been reported involves structural steel.
On December 9, 1979, a GSU QA Finding Report (79-11-35-D) was initiated indicating that certain of the welds c'o not meet the AWS criteria. On December 18, 1979, a memorandum was issued by a GSU QA engineer that these welds "may constitute a situation sufficiently grave to require reporting to the USNRC under the guidelines set forth in 10 CFR 50.55(e).
Stone and Webster responded to the December 18, 1979, memorandum in a separate letter dated April 14, 1980.
They stated that the nonconforming welds were not reportable under 10 CFR 50.55(e)
because:
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No significant breakdown in the River Bend Quality Assurance Program occurred.
b.
No deficiencies exist in the final design released for construction.
c.
No significant deficienies were noted... no extensive evaluation was required... no extensive repair was required.
However, a review of several N&Ds, of some 40 to 50 pages each, indicated considerable evaluation had been performed.
In addition, 100 percent field inspection, after acceptance of the steel and prior to erection, was initiated by Stone and Webster to detect these nonconformances.
A selected review by the RRI of two nonconformance reports on approximately 60 pieces of steel revealed approximately 75 percent of the welds were repaired to meet the AWS requirements, and 25 percent of the welds were accepted "as-is" and re-evaluated to reflect the shear and connection capacity of the
"as-is" weld.
Thus, there appears to be extensive evaluation performed, as well as a possible breakdown in the vendor quality control program.
In addition, another example involves the use of ASTM A-500 Grade B structural tubing.
On May 23, 1981, N&D A-001 was initiated indicating that A-500 Grade B tubing was procured from Marmon-Keystone who was not qualified in accordance with the Bergen-Paterson Quality Assurance (QA) program in violation of the ASME III QA program. Additionally, the vendor did not perform any confirmatory tests on the material prior to acceptanc.
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This disposition to the N&D allowed acceptance of the A-500 Grade B tubing procured from the supplier and allowed shipment of the material to the River Bend site upon completion of a confirmatory testing program.
Subsequently, on July 9,1981, _ N&D A008 was written documenting that I
two of the seven referenced heat numbers of material tested as part of the confirmatory testing program did"not meet the minimum specified elongation requirements., Retests from the same material also failed.
Five heat numbers of material'were documented as meeting the' specification. requirements; the remaining material was dispositioned for.us,e in_ Class 4 supports'.
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Stone and Webster representatives > indicated that these conditions had been evaluated for reportability~in a~ccordance with 10 CFR 21, but felt the condition was a "one-time-only" occurrence.
Further review into this matter re'vealed Regal Steel, another supplier of ASTM A-500 Grade B material, would no longer verify material procured under their existing Quality Assurance Program at the time of purchase after April 15, 1981.
After this date, all material must be procured to specification STN-50B (aluminum killed steel).
The supplier " believes that potential long term metallurgical problems might result from the use of ASTM A-500 Grade B material manufactured to commercially acceptable practice."
However, Regal Steel was required to comply with 10 CFR 21, as part of its existing Quality Assurance Program, and no evidence of reporting could be given to the NRC inspector in regard to.the metallurgical problems.
Additionally, an incident involving the possible use of unauthorized signatures of an individual on radiographs relating to safety-related piping was identified.
This problem was identified by Stone and Webster in early May 1981, but was not identified to the licensee until September 1981. This was subsequently reported-by the licensee as a potentially reportable construction deficiency.
However, the licensee is the responsible party for reportability in accordance vith 10 CFR 50.55(e), and must ensure he maintains adequate control to provide assurance that the contractor is performing in accordance with these requirements.
Under a new organization, the senior vice president will now be responsible for reporting significant deficiencies.
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The Board's assessment of the licensee's performance in this functional area was that it is minimally satisfactory and consequently of a Category 3 level.
10.
Conclusion The SALP Board concluded that the licensee had demonstrated characteristics having satisfactory qualities during the appraisal period. The consensus of the Board was that the licensee has performed in a Category 2 mode in regard to the licensee's ongoing construction activities.
Overall performance evaluation rating of Category 2 by the SALP Board was based on the licensee's satisfactory performance rating in five of the six functional areas reviewed.
Two functional areas were rated Category 1, and the functional area of corrective action and reportability was rated Category 3 which indicated that improvements were needed; In regard to the licensee's ongoing interactions with NRR, the consensus of the. Board was that the licensee has managed these activities in a Category 1 mode when compared to other. licensees involved in the same process. While the basis for judgments are somewhat limited during this period, observations do not give rise to any significant concerns. The licensee is rated Category 1 in the licensing process based on their attitude of cooperation and its initiative to resolve problems.
The licensee is also Category 1 in staying knowledgable of applicable licensing changes during this period.
11.
Board's Recommendation Based on the Category 2 assessment, the SALP Board recommended that NRC attention overall be maintained at a normal level.
Since the assessment of the functional area of corrective action and reportability was Category 3, the Board recommended that the licensee increase attention in this area.
V.
Supporting Data and Summaries 1.
Reports Data a.
LER numbers reviewed (Not appliable)
b.
Construction Deficiency Reports
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(1) Incorrect input in the calculations used to generate the amplified response spectra.
(2) Overturning of the primary shield wall.
(3) Crane boom falling on number one cooling tower.
c.
Part 21 Reports The licensee did not file any Part 21 reports, nor did any of his agents or vendors.
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Licensee Activities There were no especially significant licensee events during the appraisal period from a regulatory standpoint.
Construction work proceeded on a relatively routine basis during the period.
The evaluation period ended with construction work essentially 35 percent complete.
3.
Inspection Activities
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One " Construction Assessment Inspection" was performed during the evaluation period consuming 362 inspector-hours.
Region IV performed four routine inspections related to implementation of the
"B" level inspection program involving 225 inspector-hours. The SRI expended an additional 632 inspector-hours over the period performing the "C" program. An additional 56 inspector-hours were involved in the review of investigations and allegations reported below. Total inspector-hours expended during the period was 1275.
4.
Investigations and Allegations Review Six investigations were performed during the appraisal period.
These are summarized as follows:
a.
Investigations concerning material embedded in concrete.
During a labor relations meeting, an allegation was made that certain material was embedded in concrete with a product " Hold Tag" attached.
Stone and Webster investigation revealed that product number was actually a " Purchase Order Number" rather than a " Hold-Tag Number."
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Investigation of an allegation concerning lack of training of
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-personnel at'the River Bend site.
The Region IV office received a call from a former Stone and Webster employee who stated that the training of personnel at the River Bend site was not sufficient and was a safety defect.
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Two NRC Regional Reactor Inspectors interviewed the individual.
to obtain additional information concerning the. allegation.
The basic allegation referenced a large number of Stone and Webster personnel working onsite who had not received new hire orientation, " Job Safety and Work Rules."
A review of training records for May and June 1980 revealed-that the orientation and indoctrination classes were being held as required, and an effort was being made to give these classes to those employees already working at the site.
At that time, there was no effective method to determine an individual's training needs; thus, there may have been some employees who did not receive new hire orientation training.
However, since this training was not a requirement, no deficiency was found.
Even though this allegation was partially substantiated, it had no merit.
c.
Investigation of the Union of Concerned Scientists allegations.
As a result of a letter from the Union of Concerned Scientists (UCS), dated July 21, 1980, to three Commissioners of the U. S.
Nuclear Regulatory Commission, an NRC Inspector accompanied Mr. T. Crouse, Director of Quality Assurance for the River
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Bend facility, and Mr. C. Lundin, Project Quality Assurance Manager at the site for Stone and Webster, to the Stone and Webster Operations Center in Cherry Hill, New Jersey. Their purpose was to gather preliminary information, as available, relative to the GSU investigation of the allegations in the UCS letter of request submitted (pursuant to 10 CFR 2.206) to halt construction of River Bend, Unit 1.
In general, no Category 1 cable was delivered to the River Bend facility nor was fabrication for any of this cable initiated.
No safety-relate.d cable tray was installed.
All of the allegations speak to problems or deficiencies that were identifie~d by the 1icensee or the contractor in the fabrication area and thus, appeafed premature considering the status of construction.
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Document'a. tion provided by.the licensee verified that' all of the subjects discussed in the allegations had been identified by proper courses of action.- While some of the allegations spoke to current' problems which must be solved prior to the full-scale' installation of electric cable, the solutions to these problems cannot-be achieved until the manner in which the commitments are to be met is finally determined.
Another investigation' involving this subject was based on allegations from an anonymous source that was passed on through the Union of Concerned Scientists during a conference
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call on October 21, 1980.
The anonymous source alleged that Stone and Webster supervisors were creating schedules and applying pressures to-subordinate engineers to meet those schedules and thereby possibly compromising good engineering practices and creating improper specification requirements for buried cable for'the River Bend Nuclear Project.
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None of the allegations could be' substantiated.
d.
Allegation regarding welder examination.
The Region IV office received a telephone call in regard to welder examinations at the site. cThe caller was concerned in that he heard statements made by a Stone and Webster employee involving " help" given to an individual to pass his qualification tests.
The Stone and Webster employee who made the statement was interviewed by the RRI. The individual stated that he was not familiar with the imposed welding requirements, nor was he knowledgeable in this subject area.
He stated that the " help" he referenced in his statement was practice time given the welder prior to performing the qualification weld.
He knew of no actual assistance given the welder during the actual performance of the test.
The employee stated that a personality conflict existed between the welder and himself, and that he had made the statement in anger based on the welder's productivity.
Subsequent to the allegation, the welder was terminated due to absenteeism.
e.
Anonymous Allegations A caller to the NRC Headquarters Duty Officer alleged that
" things are going on there (River Bend) that are not being looked at, possibly." These " things" concerned document control, curing, embedded rebar, and performance of surveillances by the licensee.
In regard to the concern involving document control, the SRI could find no evidence of completed construction activities performed in accordance with drawings not reflecting the latest revision, and the allegation could not be suostantiated.
The allegation involving curing was substantiated; however, the licensee had identified these problems prior to the time at which the allegation was received.
Prompt and proper corrective action was taken in response to the problems identifie.
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position nor the lack of. performance of surveillances by the licensee could be substantiated.
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f.
- Investigation of an incorrect addition to water into a truckload of-concrete.
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j An investigation was conducted at River Bend Station regarding a possible. falsification of records by the National Mobile Concrete Corporation (NMCC) site.QA Manager concerning the actual amount of water added to a load of concrete mixed and placed on the afternoon of January 26, 1981. Witnesses were i
interviewed who confirmed that'12 gallons of water was added to the load, which~was 3. gallons in excess of'the maximum allowable water which could be added to the. load and which
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shouldlhave resulted in the load being rejected and the cost charged to NMCC.
Interview of one Stone-and Webster Engineering Corporation (S&W) Supervisor. disclosed ' iat-the
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site QA manager admitted not knowing the actual amount of water
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added to the concrete loa'd and that the associated
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documentation regarding the water added did not concur.
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site QA manager was interviewed and admitted that he incorrectly, but not knowingly, documented nine gallons of
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water was added to the load.
No evidence was found to indicate the information was knowingly falsified.
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Escalated Enforcement Actions None
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Management Conferences Held During Appraisal Period No management conferences were held with the licens~ee during the period except that required by the SALP program.
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