IR 05000483/1982004
| ML20058H908 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/19/1982 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Schnell D UNION ELECTRIC CO. |
| References | |
| NUDOCS 8208090107 | |
| Download: ML20058H908 (22) | |
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-July 19, 1982 Docket No.' 50-483 Union Electric Company ATTN:
Mr. Donald F. Schnell Vice President - Nuclear Post Office Box 149 - Mail Code 400 St. Louis, MO 63166 Gentlemen:
This refers to the management meeting held by Mr. A. B. Davis and other NRC representatives with you and other representatives of Union Electric Company on April 14, 1982, to review the results of the NRC's assessment of the utility's regulatory performance at the Callaway Plant in connec-tion with NRC Manual Chapter 0516 - Systematic Assessment of Licensee Performance (SALP) covering the period July 1, 1980 to September 30, 1981.
A preliminary copy of the SALP Report was'provided for your review in advance of our meeting. The final SALP Report including the SALP Board Chairman's letter to you and your written response and comments of May 4, 1982 is enclosed.
In addition to the assessments and recommendations made by the SALP Board contained in the enclosed SALP Report, I wish to give you my overall observa-tions and assessment relative to the utility's regulatory performance during the assessment period:
1.
With respect to the SALP ratings, the Regional SALP Board views the Category 2 rating as the rating which it anticipates most licensees will achieve. A Category 1 rating is given only for superior per-formance and there is reasonable expectation that it will continue.
A Category 3 rating is given when the licensee's performance is considered minimally acceptable and identified weaknesses warrant special licensee management and NRC attention.
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Union Electric Company
July 19, 1982 2.
It is my view that the overall regulatory performance of Union Electric Company at the Callaway Plant was satisfactory during this SALP period and there appears to be a good balance of management attention and involvement for the' work activities undertaken. One area that does concern me was the level of Quality Assurance support in the electrical area.
As we have discussed previously the number of problems that have-surfaced at other facilities in the electrical area is a major concern to us.
It is in this context and the fact your noncompliance history in the electrical area indicated a potential for similar problems that I am concerned. Therefore, I was pleased with your response of May 4,1982, indicating that you are taking steps to strengthen your resources in Quality Assurance. 'While we have no particular problem with the use of consultants to supplement and train your staff, our concern is in the integration of<these various resources into an effective effort to ensure a high level of quality activities. We will continue to follow your efforts to strengthen your Quality Assurance program.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the SALP Report will be placed in the NRC's Public Document Room.
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No reply to this letter is required; however, should you have any questions concerning these matters, we will be pleased to discuss them with you.
Sincerely, Orfginst signed by James G. Keppler James G. Keppler Regional Administrator
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Enclosure:
SALP Report
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l No. 50-483/82-04 l
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REGION III==
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SYSTEMATICASSESSMENTOFLICENSEEPfRf.0RMANCE'
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Docket No. Sj-483
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Report No. 50-483/82-04 -
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j 3 (Assessm'ent' Period '
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July I/19b0, to September 30, 1981 j
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CONTENTS Page 1.
SALP Board Chairman Letter to Licensee.................... iii 2.
Licensee Comments......................................... vi I.
Introduction..............................................
II.
Criteria..................................................
III. Summary of Results
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IV.
Performance Analyses.....................................
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Supporting Data and Summaries
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A.
Noncompliance Data.................................
B.
Licensee Report Data...............................
C.
Licensee Activities................................
D.
Inspection Activities..............................
E.
Escalated Enforcement Actions
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F.
Management Conferences
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Docket No. 50-483 Union Electric Company ATTN:
Mr. Donald F. Schnell Vice President - Nuclear Post Office Box 149 - Mail Code 400 St. Louis, MO 63166 Gentlemen:
This is to confirm the conversation between Mr. R. L. Powers and Mr. J. Neisler of the Region III staff, scheduling April 14, 1982, at 9:30 a.m. as the date and time to discuss the Systematic Assessment of Licensee Performance (SALP)
for the Callaway Plant. This meeting is to be held at Union Electric Company offices in St. Louis.
Mr. A. B. Davis, the Deputy Regional Administrator, and members of the NRC staff will present the observations and findings of the SALP Board.
Since this meeting is intended to be a forum for the mutual understanding of the issues and findings, you are encouraged to have appropriate representation at the meeting. As a minimum we would suggest Mr. D. F. Schnell, Mr. R. J. Schukai, Mr. F. D. Field, and managers for the various functional areas where problems have been identified.
The enclosed SALP Report which documents the findings of the SALP Board is for your review prior to the meeting.
Subsequent to the meeting the SALP Report will be issued by the Regional Administrator.
Enclosure 1 to this letter summarizes the more significant findings identi-fled in the SALP Board's evaluation of the Callaway Plant for the period of July 1, 1980 to September 30, 1981. Since these findings indicate a need l
for increased resources in the quality assurance function in the area of electrical activities, you are requested to respond in twenty days following
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our April 14, 1982, meeting as to your evaluation of the SALP Board recommenda-tions contained in Enclosure 1 and any actions you plan to take.
If you desire to make other comments concerning our evaluation of your facility,
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j they should be submitted with your response, i
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e Union Electric Company
In accordance with section 2.790 of the NRC's " Rules of Practice" Part 2, Title 10, Code of Federal Regulations,.a copy of this letter, the SALP Report, and your response and commitments, and your comments, if any, will be placed in the NRC's Public Document Room when the SALP Report is issued.
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The. response requested by this letter is not subject to the clearance i
procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980 PL 96-5111.
If you have any questions concerning the SALP Report for the Callaway l
Plant, we will be happy to discuss them with you.
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Sincerely,
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J. A. Hind, Director
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Division of Emergency Preparedness and Operational Support
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l Enclosures:
l 1 Summary of Significant Findings 2.
Callaway SALP Report (5 copies)
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Resident Inspector, RIII i
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ENCLOSURE 1 Summary of Significant SALP Report Findings for the Callaway Unit 1 Plant Functional Area: Electrical Power Supply and Distribution
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Based upon the findings in this area, the SALP Board recommends greater licensee attention to ensure that adequate resources are available to identify and correct problems.
It appears that the minimal quality assurance staffing in this area is not adequate to identify and assure timely correction of problems as evidenced by the thirteen noncompliances identified in NRC inspections.
The Board recommends that the licensee make an independent assessment of licensee performance in this area, and consider additional technical staff to ensure adequate and timely audits and increased inspection of work activities.
Functional Area:
Instrumentation and Control Systems Although the licensee was not rated in this area, the SALP Board recommends that the licensee also include this area in the assessment for increased quality assurance resources, i
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UNION ELecTnic COMPANY tool onATeoT eTREET ST. Louis, Missouma
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May 4, 1982
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Mr. J. A. Hind, Director Division of Emergency Preparedness and Operational Support U. S.
Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 ULNRC-556
Dear Mr. Hind:
SALP REPORT APRIL 14, 1982 MANAGEMENT MEETING This letter is in response to your April 8, 1982 draft Systematic Assessment of Licensing Performance (SALP) report for the Callaway Plant and our joint April 14, 1982 neeting to discuss the findings and observation of the SALP Board.
Our comments on the draft report and meeting presentation are directed to three areas as explained herein.
The first area of comment addresses the overall conclusion to be drawn from the report.
The NRC's rating system was explained in some detail by your personnel, and our overall conclusion from the discussion is that Union Electric management attention and involve-ment are evident at Callaway and are properly directed towards meeting the necessary requirements for a quality project.
Union Electric management is dedicated to assuring that necessary quality objectives are achieved and we will continue to address areas requiring increased strength.
Our second comment area is in reference to Enclosure #1 of the draft report entitled:
" Summary of Significant SALP Report Findings for the Callaway Unit 1 Plant".
You recommend that an independent assessment of our performance be made in the area of electrical power supply and distribution, and that additional technical staff be con-sidered for this area as well as the area of instrumentation and control systems.
As noted in our meeting, we are taking steps to acquire additional technical staff for increased coverage in these areas.
We also have proposals under consideration for an independent review of specific areas of electrical construction; however, we have not yet concluded whether such a review is necessary.
We will keep the NRC Resident Inspector advised of our plans and progress in these areas.
The third area of comment deals with section 6, pages 10-11 of the draft report, which was discussed at length during our meeting.
Contrary to the inference in the last paragraph of section 6.a.,
we understand that NRC does not disfavor our reliance on consultant and vi MAT 7 b%
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Mr. J. May 4, 1982
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Page Two contractor quality assurance personnel.
Indeed it was agreed that employment of competent consultants under Union Electric Company direct supervision is a prudent decisibn.
Regarding section 6.c.,
Board Recommendations, we are endeavoring to hire additional competent permanent employees and intend to use experienced consultants to help train these people and supplement our staff, thereby increasing the effectiveness of our efforts.
Progress has been made since the last SALP evaluation, and the need for increased effort is being addressed.
Additionally, we noted in the subject meeting that Nuclear Construc-tion engineering personnel have been added directly into the contractor's construction staff to assist in problem identification and resolution.
A further increase in the staff of Nuclear Construction is underway.
We believe that our overall efforts in this area will provide satisfac-tory monitoring of the construction activities.
Again we will keep the NRC Resident Inspector informed of progress in this area.
In summary, Union Electric is fully committed to building and operating a safe, reliable plant.
We have endeavored to fulfill this commitment and will continue to be responsive to areas requiring increased effort.
Union Electric management attention and involvement will remain evident in meeting the necessary requirements for a quality project.
Should you have any further questions, please contact me.
Very truly yours, Donald F.
Schnell DFS/bjp cc:
J. E. Konklin, NRC Region III NRC Resident Inspector Callaway Plant Missouri Public Service Commission vii
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INTRODUCTION J
The NRC has established a program for Systematic Assessment of
Licensee Performance (SALP). The SALP is an integrated NRC Staff
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effort to collect available observations and data on a periodic j
basis and evaluate licensee performance based upon these observa-tions.
SALP is supplemental to normal regulatory processes used j
to insure compliance to the rules and regulations.
SALP is intended i
from a historical point to be sufficiently diagnostic to provide a i
rational basis:
(1) for allocating future NRC regulatory resources, and (2) to provide meaningful guidance to licensco management to
promote quality and safety of plant construction and operation.
A NRC SALP Board composed of managers and inspectors who are know-
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ledgeable of the licensee activities, met on February 17, 1982 to l
review the collection of performance observations and data to assess l
the licensee performance of Union Electric Company in selected functional areas.
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l This SALP Report is the Board's assessment of the licensee safety performance at the Callaway Unit i for the period July 1, 1980, to September 30, 1981.
l The results of the SALP Board assessments in the selected functional areas were presented to the licensee at a' meeting held April 14, 1982.
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CRITERIA The licensee performance is assessed in selected functional areas depending upon whether the facility is in a construction, pre-opera-tional or operating phase. Each functional area normally represents areas significant to nuc1 car safety and the environment, and are normal programmatic areas.
Some functional areas may not be assessed because of little or no licensee activitics or lack of meaningful observations.
Special areas may be added to highlight significant observation.
One or more of the following evaluation criteria were used to assess each functional area.
1.
Msnagement 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)
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Training effectiveness and qualification.
However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
Based upon the SALP Board assessment each functional area evaluated is classified into one of three performance categories. The definition of these performance categories is:
Category 1.
Reduced NRC attention may be appropriate.
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.
Category 2.
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effec-tive such that satisfactory performance with respect to operational safety or construction is being achieved.
Category 3.
Both NRC and licensee attention should be increased.
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 with respect to operational safety or construction is being achieved.
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III. SUMMARY OF RESULTS Functional Area / Assessment Category 1 Category 2 Category 3 1.
Soils and Foundations X
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Containment and other X
Safety-Related Structures 3.
Piping Systems and Supports X
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Safety-Related Components X
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Support Systems Not Rated 6.
Electrical Power Supply X
and Distribution 7.
Instrumentation and Not Rated Control Systems 8.
Licensing Activities X
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IV.
PERFORMANCE ANALYSES 1.
Soils and Foundations
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Analysis
l No major construction activities were underway during the assesument period and work in this area is virtually complete.
One inspection was conducted to review licensee audits relative to soll placement and compaction activities and followup on previous unresolved items.
Based upon further review, two previous unresolved items were reclassified as items of non-l compliance, as follows:
(1) Infraction for failure to identify the rip-rap on the ultimate heat sink as a safety-related installation.
(2) Infraction for failure to perform soil tests necessary
to ensure quality of granular fill material used in the ultimate heat sink pond.
t These items of noncompliance resulted from a difference in
engineering judgement rather than a programmatic deficiency.
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The licensee reclassified the rip-rap as safety-related and committed to rework portions of the rip-rap. These noncompli-ances involved the method of inspection and testing to ensure the quality of the granular fill material but they did not have a significant impact on the quality of construction.
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b.
Conclusion The licensee is rated Category 2 in this area. No trends were identified that would indicate significant strengths or weaknesses, s
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Board Recommendations i
i None. The Board notes that subsequent to the assessment period, the licensee corrective action was verified.
2.
Containment and other Safety-Related Structures
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Analysis
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Portions of thirteen inspections were performed to examine the licensee's organization for control of activities,
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adequacy of procedures, corrective action system, qualifica-l tion and training of personnel, observation of work activities and investigation of concrete defects. The inspections were performed by both the resident inspector and regional based
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inspectors and included an assessment of the overall effective-ness of the Quality Assurance Program at the site.
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One noncompliance (Infraction) was identified related to inadequate indoctrination and training of concrete vibrator operators. Operators were observed using techniques contrary to written requirements. This finding is considered an isolated occurrence; retraining of the operators produced acceptable results.
Two of the inspections in this area were reactive, and con-cerned the discovery and reporting of concrete imperfections in the reactor building dome.
It was concluded that the licensee had reacted responsibly and had reported the problems in accordance with requirements.
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Conclusion The licensee is rated Category 2 in this area. No significant strengths or weaknesses were l'lentified.
c.
Board Recommendations None.
3.
Piping Systems and Supports a.
Analysis Inspection of piping systems and supports was included in portions of fourteen inspections during this appraisal period.
The inspections examined the licensee's organization for
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control of piping activities, including the adequacy of implementing procedures; corrective actions; installation activities; welding, including welder qualifications and welding material controls; receipt inspection, storage, and preservation of materials; personnel qualification and training; inspection and nondestructive examination; and investigation of alleged welding defects. The inspections
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were performed by both the resident inspector and region-based personnel. As a result of these fourteen inspections, Region III inspectors identified four items of noncompliance.
The items of noncompliance.dentified were as follows:
(1)
Infraction for failure to control welding materials.
(2) Deficiency for failure to identify tools (brushes, grinders, files) according to the procedure for con-trolling tools used on stainless steel pipe, plate, and shapes.
(3)
Infraction for failure to have controlled welding procedure specifications with associated technique sheets at the work location during welding activities, as required by the ASME Code.
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(4) Severity Level V noncompliance for failure to judge pipe pieces unacceptable after the radiographic film indicated apparent-incomplete fusion and excessive reinforcement in the weldment.
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b.
Conclusion
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The Ifcensee is rated Category 2 in this area. Although
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there were four items of noncompliance identified in this area, the number, severity and type of noncompliances do not indicate a breakdown in the Quality Assurance in this area.
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Board Recommendations None.
4.
Safety-Related Components a.
Analysis
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Safety-related components were included in portions of
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fourteen inspections during the uppraisal period. The inspections examined the licensee's organization for control of activities affecting-safety-rclated components, storage and preservation, installation of reactor pressure vessel j
internal CRDM insta11ction activities, documentation and records on pumps and valves, installation and inspection
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packages, receipt inspection activities, welding, installa-
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tion and grouting of safety-related tanks. The inspections were performed by both the resident inspector and region-based'
inspectors. No items of noncompliance were identified.
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Conclusion
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The licensee is rated Category 2 in this area. No significant strengths or weaknesses were identified
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Board Recommendations i
None.
5.
Support Systems The licensee is not rated in this area. No inspections were performed in this area.
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6.
E_loctrical Power Supply and Distribution
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a.
Analysis f
Portions of fifteen inspections, including a portion of an inspection to assess the overall effectiveness of the Quality
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Assurance Program, were performed to examine the licensee's control of activities, including program and procedure adequacy; qualification and training of personnel;_installa-i tion of cable trays and hangers; storage and preservation of materials and components; receipt inspections; switchgear and component installation, testing, and inspection; and
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design, installation and testing activities involving Seismic i
II over Seismic I structures and systems. The inspections l
were performed by the resident inspector and region-based personnel from NRC Regions III and IV.
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l Thirteen items of noncompliance were identified in the electrical area during the appraisal period. The noncom-l pliances identified were as follows:
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(1)
Infraction for failure to assure that applicable
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regulatory requirements and design bases were correctly j
translated into specifications, in that the specifica-l tions did not establish requirements for protecting I
the integrity of installed Class 1E battery racks and battery rack hardware by specifying the use of acid resistant paint after field installation.
(2)
Infraction for failure to assure that plug welds on
the battery racks and 4.16KV switchgear were performed in accordance with AWS D1.1-75.
(3)
Infraction for failure to assure that purchased material and equipment conformed to procurement documents in that welds on the main control panel were undersized and contained porosity and slag.
(4) Severity Level IV noncompliance for failure to assure that activities affecting quality were accomplished in i
accordance with procedures in that electrical craftsmen were working through mandatory " Hold Points" without Quality Control performing the required inspections or receiving documented consent for the continuation of work beyond the designated " Hold Point."
(5) Severity Level V for failure to assure that adequate corrective action was taken with regard to specific Surveillance Reports, NCRs, and Deficiency Reports, t
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material conformed to procurement documents in that l
receipt inspections were performed without written procedares and that material was accepted without the
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specified documentation.
(7) Severity Level V for failure to assure that conditions adverse to quality were promptly identified and corrected i
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In that improperly terminated wires in the Battery Charger Panel were not identified and corrected.
(8) Severity Level V for failure to assure that inspection activities were accomplished in accordance with documented procedures in that electrical cables were installed in raceway before the raceway had been inspected as required by site procedures.
(9)
Infraction for failure to include or reference the provisions of 10 CFR 21 in procurement documentation for safety-related electrical cable splice and termina-tion kits.
(10) Severity Level VI for inadequate design controls in that acceptance criteria for determining minimum bend radius for electrical cables were not in accordance with the cable manufacturer's instructions.
(11) Severity Level VI for failure to provide adequate procedures for the repair of damaged electrical cable jackets to assure cable jackets are returned to original design characteristics.
(12) Severity Level V for failure to provide adequate procedures for II/I raceway inspection.
(13) Severity Level V for failure to follow procedures for II/I raceway inspections and not performing II/I inspections.
Taken individually, the above noncompliances do not represent major programmatic weaknesses; however, collectively they are indicative of inadequate resources to ensure adequate attention and control of activities in this area. The licensee has con-tinued to operate with a minimal quality assurance staff with l
reliance on consultants and contractor quality assurance groups.
j In view of the fact that over sixty percent of the noncompliances l
identified were due to inadequate quality assurance controls, it appears the licensee is not providing adequate quality
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assurance resources and overview in this area.
b.
Conclusion The licensee is rated Category 3 in this area. This is based
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upon the number and nature of noncompliances that indicate l
inadequate management attention.
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Board Recommendations The Board notes that minimal quality assurance staffing was addressed in the previous SALP. At that time the licensee was
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taking steps to improve the quality assurance function through reorganization, reassignment, and hiring of consultants. That corrective action does not appear to have been effective in this area. The Board recommends that the licensee take necessary steps to assure the proper identification and cor-rection of problems.
Included in these steps should be an assessment of licensee performance in this area and considera-tion of the need for increased staffing of field engineers and quality assurance engineers to ensure adequate and timely audits and increased direct inspections of work activities.
7.
Instrumentation and Control Systems a.
Analysis No inspections were performed in this area and there is inadequate information available to provide an assessment of licensee performance.
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Conclusion o
The licensee is not rated in this area.
c.
Board Recommendations Based upon the findings in Electrical Power Supply and Distribution, Section 6, the Board recommends both NRC and licensee attention be increased in this area. The attention should be directed toward the adequacy of the quality assurance function in this area.
8.
Licensing Activities a.
Analysis The licensee generally has an understanding of' issues and exhibits a conservative approach to those issues. Their approach is generally sound with timely resolution of issues.
It should be noted that as a result of the new licensing review procedures a minimum number of requests for additional information has been transmitted to the licensee.
The licensee does not exhibit an extensive knowledge of the effects of system interactions from an overall risk / safety l
viewpoint. However, the assistance of the technically know -
ledgeable SNUPPS staff and technical interchange with the other SNUPPS utility has resulted in a significant improvement in
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this area.
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Vacant key positions are being filled promptly with quality staff.
Planned staffing appears to be adequate. The licensee has committed to adding additional advisory staff to assist
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the plant superintendent, to assist operators at startup and for one year after fuel load, and to serve as shift technical advisors. The SNUPPS staff which is committed.to assisting the licensee continues to strengthen itself technically. Responsi-bilities for licensing activities are well defined.
Licensee upper management appears to be aware of details of licensing activities and personally review various licensing submittals in a timely manner. Management controls of licensing activities are in place and functional. Responses for licensing issues are well prepared and submitted in a timely manner.
b.
Conclusion The licensee is rated Category 1 in this area.
c.
Board Recommendation None, t
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V.
SUPPORTING DATA AND SUMMARIES A.
Noncompliance Data
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Facility Name: Callaway, Unit 1 Docket No. 50-483
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Inspections No. 80-19 through 80-31 No. 81-01 through 81-20 Noncompliances and Deviations Severity Levels Categories Functional Area Assessment I II III IV V VI Viol.
Infr.
Def.
Dev.
l 1. Soils and Foundations
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2. Containment and other
Safety-Related Structures 3. Piping Systems and
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i Supports 4. Safety-Related
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Components i
5. Support Systems 6. Electrical Power
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Supply and Distribution 7. Instrumentation and Control Systems i
8. Licensing Activities TOTALS
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Licensee Report Data 1.
Construction Deficiency Reports (CDRs)
Sixteen CDRs were submitted by the licensee ~under the re-quirements of 10 CFR 50.55(e). Of the sixteen reports
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submitted, one report was retracted. Thirteen of the reports involved deficiencies at suppliers that were not under direct control of licensee personnel; however, six of those appear to be discrepancies which should have been found during source inspections. The licensee's corrective actions appear to be adequate.
2.
Part 21 Reports Six Part 21 Reports issued by suppliers or contractors were addressed in CDRs issued by the licensee.
C.
Licensee Activities Construction was reported as 76% complete at the end of the
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appraisal period. Safety-related civil work is virtually complete.
The reactor vessel is in place and 90% of tho'large bore pipe is installed. The major construction activities remaining are in the piping, electrical, instrumentation and testing areas.
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The licensee began preparations for preoperational testing during this appraisal period. The'preoperational testing staff is on site. Test procedures are being developed but no testing had been performed at the end of this appraisal period.
D.
Inspection Activities t
The construction resident inspector was transferred from Callaway in July 1981. A replacement has been selected to be onsite during April 1982. The NRC inspection program is being maintained by.
the project inspector and other region-btsed perr.onnel. There have been no team inspections during this appraisal period.
E.
Escalated Enforcement Actions a.
Civil Penalties None were issued.
b.
Orders None were issued.
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c.
Immediate Action Letters None were issued.
F.
Management Conferences On December 18, 1980, results of the previous SALP were presented to the licensee.
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