ML19350D485
| ML19350D485 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 01/05/1981 |
| From: | Martin T Public Service Enterprise Group |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19350D484 | List: |
| References | |
| NUDOCS 8104160005 | |
| Download: ML19350D485 (7) | |
Text
- -
Thomas J. Martin Public Service Electric and Gas, Company 80 Park Plaza Newark, N.J. 07101 201/4304316 Vice President Engineering and Construction i
January 5, 1981 Mr. Boyce H.
Grier, Director U. S.
Nuclear Regulatory Commission Office of Inspection and Enforcement Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 4
Dear Mr. Grier:
1 NRC INSPECTION REPORT 50-354/80-16 AND 50-355/80-16 NO. 1 AND 2 UNITS HOPE CREEK GENERATING STATION We have reviewed the report of your inspection conducted on October 6 - November 2, 1980 at the Hope Creek Generating Station.
The report was transmitted with your letter of November 18, 1980 and received on November 24, 1980.
This response due to the NRC on December 24, 1980, is a few days late due to the complexity of coordinating the response be-tween PSE&G, the architect engineer (Bechtel), their con-tractor and subcontractor.
The following actions have been initiated relative to the three infractions:
A.
Deficiency applicable to Docket No. 50-354 (16-01):
10 CPR 50, Appendix B, Criterion V, states, in part, that:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings...
and shall be accomplished in accordance with these in-structions, procedures, or drawings."
Section 16.4.5 of Chapter 16 of the PSAR states, in t
part, tha t:
quality related activities are docu-mented and controlled by written procedures and instructions."
Paragraph 1.9.2 of Chapter 1 of the PDM QA Manual, states, in part, that:
any modification... from the... drawing used for stress analysis, has been certi-fled... as having been satisfactorily reconciled with those calculations."
810.416 000S=.
.e Mr. Boyce H.
Grier, Director 1/5/81 PDM Letter No. CLB-152-2429 dated 10/3/80, which was written to clarify PDM drawing requirements, stated that the vertical component of the safety relief valve (SRV) piping supports will carry a proper amount of dead weight load.
Contrary to the.above, as of October 21, 1980,-
Schneider, Inc., a subcontractor to PDM, was not instal-ling the SRV piping an supports in accordance with PDM drawings and PDM Letter No. CLB-152-2429:
The SRV pip-ing was being cold sprung in a downward direction to establish a required slope, thus, resulting in the ver-tical component of the SRV piping support functioning in a condition opposite to that intended.
Additionally, SI was rigging the 10" diameter SRV piping into position by using the 6" diameter spray header piping as the pur-chase point for the rigging operation.
This rigging operation had not been evaluated and approved by exper-ienced personnel and demonstrates a lack of good engi-neering practice.
Reply to A:
1.
Comment:
The SRV lines in question were being installed in ac-cordance with the pertinent Schneider, Inc. (SI) erec-tion drawings and a set of installation guidelines pro-vided by PDM as a response to a noncompliance report submitted to PDM by SI.
These guidelines clarified the installation tolerance requirements for the nominal dimensions already on the erection drawings.
In an at-tempt to follow these guidelines, cold springing was used to establish a specified slope.
Since cold spring-ing is normally considered stande.rd practice for Schneider, Inc., no analysis of the ef fects of this was performed prior to its use.
2.
Corrective steps which have been taken:
Schneider, Inc. has issued N&D 520-F-101 and the cold springing loads were removed.
PDM then had the design-ers of the system (Nutech) analyze the system to see if cold springing could be used to achieve the specified slope without causing any detrimental affects.
Bechtel was also asked by PDM to evaluate whether or not the slope requirement could be reduced.
The final resolu-tion of the SRV installation problems, which will in-clude SRV piping support loading requirements, will be forwarded by PDM to SI by January 15, 1981 as a reply to their N&D.
Mr. Boyce H.
Grier, Director 1/5/81 An evaluation by SI of the rigging operation in question shows that the load imposed on the 6" diameter spray header by lifting a 10' length of 10" diameter pipe would not cause any appreciable stress on either the header or its support system regardless of the location of the rigging.
3.
Corrective steps which have been taken to avoid further items of noncompliance.
Bechtel made both PDM and SI site organizations aware of the requirement for stress analysis of cold springing.
Cold springing will therefore no longer be considered accepted practice without prior engineering involvement.
SI has also been instructed to use the suppression chamber monorail in lieu of the spray header to perform i
rigging activities in the future.
4.
Date when full compliance will be achieved:
Disposition of Schneider, Inc. N&D will be completed by January 15, 1981.
Implementation of remedial action for the pipe supports will be dependent upon the nature of this disposition.
B.
Deficiency applicable to Docket No. 50-354 (16-02):
10 CFR 50, Appendix B, Criterion XIII states, in part, that:
" Measures shall be established to control the storage... and preservation of material... in accordance with work and inspection instructions to pre-vent damage or deterioration."
Section 16.4.13 of Chapter 16 of the PSAR states, in part, that:
"For... subcontractor work, special...
and preservation requirements are identified storage in technical specification... "
Paragraph 18.3.3 of Bechtel Design Specification C-152(Q), Rev. 14, " Design Specification for Fut.tishing, Designing, Detailing, Fabrication Delivery, and Erection of Primary Containment" states, in part, that:
"... all pipe ends shall be capped with metal or plywood caps to protect the surfaces and to prevent entry of foreign materials or moisture.
Caps will remain in place during storage, shipment, and handling."
- r. Boyce H.
Grier, Director 1/5/81 Contrary to the above, as of October 21, 1980, pipe ends were not capped to protect surfaces and prevent entry of foreign materials or moisture in the area of work being performed by Schneider, Inc.
Reply to B:
1.
Comment:
This item was identified as an item of noncompliance by the NRC in February, 1980 (Inspection Report 80-02).
SI developed and implemented a housekeeping procedure (SICP 14.1) and a surveillance plan (S520-1) to correct the problem and prevent recurrence.
The last documented SI surveillance was 10/1/80 (Date of noncompliance was 10/21/80).
Corrective Action defined in the response to Inspection Report 80-02 was adequate, however, Schneider, Inc., failed to continue to implement the original actions.
2.
Corrective steps which have been taken:
Pipe caps have been replaced.
Debris snd wood scaffold-ing have been removed.
3.
Corrective steps which have been taken to avoid further items of noncompliance:
Schneider, Inc. has revised their procedure to provide more detailed housekeeping requirements.
SI has rein-stated the weekly (minimum) surveillance of the house-keeping activities.
PDM will monitor the SI surveil-lance as part of overall increased sucveillance.
l Bechtel will increase its surve'.11ance of its contrac-l tors and subcontractors.
C.
Deficiency applicable to Docket No. 50-354 (16-03):
10 CFR 50, Appendix B, Criterion V, states, in part, that:
" Activities af fecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these in-structions, procedures or drawings."
Section 16.4.5 of Chapter 16 of the PSAR states, in part, that:
"Bechtel quality related activitiec are documented and controlled by written procedures and instructions."
Paragraph 3.6.1 of Section IX, Rev. 1, of the Bechtel Construction Quality Control Manual states:
"Each con-tractor and subcontractor is responsible for controlling
Mr. Boyce H. Grier, Director 1/5/81 the quality of work performed by his subtier contrac-tors."
Paragraph 3.3.1 of this same document goes on to explain that Becht:1 nas a surveillance inspection re-quirement to ensure contractor and subcontractor activ-ity is in accordance with contract documents.
Contrary to the above, as of October 21, 1980, PDM and Bechtel surveillance inspection programs failed to iden-tify and correct serious installation errors involving Schneider, Inc. installation of the SRV piping supports and failed to identify the recurrent problem of Schneider, Inc.'s failure to ensure piping internal cleanliness.
Reply to C:
1.
Comment:
a.
Bechtel responsibility:
Bechtel Construction Quality Control is responsible for performing surveillance inspection of the receiv-ing, storage, handling, maintenance, fabrication, in-stallation, welding, heat treating, inspection, exam-ination, testing, documentation and other on-site con-struction activities performed by Bechtel's contrac-tors and their subcontractors.
Construction surveil-lance inspeccion consists of a review, observation or inspection of contractor or subcontractor activities related to material, equipment, processes and test re-sults performed by a Construction Quality Control Engineer at random or selected stages of construc-tion.
The purpose of the activity is to determine if there is suf ficient assurance that actions have been i
accomplished in accordance with established require-l
- ments, and that supporting documentation has been l
prepared in accordance with selected requirements of the contract documents.
i l
Based on the above, it becomes evident that Bechtel QC cannot identify every minor deficiency generated during l
the construction phase by a contractor or subcontractor.
Bechtel QC could not have had performed surveillance on this item of non-conformance since Bechtel QC and Schneider had not been made aware of the contents of the referenced PDM letter CLB-152-2429.
In addition, the fact remains that Bechtel QC found the installation to be in accordance with the existing installation drawing.
i
Mr. Boyce H. Grier, Director 1/5/81 Recognizing that any contractors may develop repetitive problems during the execution of the work, an overall evaluation of Section IX of Bechtel's CQCM was made by PSE&G and Bechtel.
The purpose was for redressing contract work which develops serious or repetitive deficiencies.
The results of this evaluation are as follows:
(1)
Immediate steps were taken to increase the magni-tude of surveillance inspection being performed on the PDM contract.
Particular attention was given to hardware installation and housekeeping.
This increased level of effort will be maintained until an acceptable overall confidence level has been re-established.
(2)
Administrative Quality Control Instruction No.
AQCI-X1, Rev. 1, has been prepared and approved.
This AQCI revision specifically addresses addi-tional action to be taken when a contractor's per-formance is repeatedly failing to meet the contract requirements.
(3)
The Project Construction QC Engineer has held numerous training sessions with the QC supervisors on the subject of contractor surveillance.
Key points stressed during these training sessions were the qualitative method of performing surveillance inspection, the level of effort required, and insistence on compliance with Section IX of the CQCM.
Corrective steps which have been taken or will be taken to avoid further items of noncompliance have been ad-dressed in items 1, 2 and 3 above.
Full compliance will be achieved with the issue of AQCI-IX-1, Rev. 1 on January 5, 1981.
b.
PDM /Schneider responsibility:
Infractions 1 & 2 involved the following items:
(a)
Cold springing SRV piping to obtain a required slope.
(b)
Rigging a portion of the 10" diameter SRV piping off of the 6" spray header.
(c)
Uncapped pipe ends in suppression chamber area.
Mr. Boyce H. Grier, Director 1/5/81 I tems (a) and (b) are generally considered normal indus-trial practice and item (c) represented a recent minor breakdown (from 10/1/80 to 10/21/80) in housekeeping, as a result of Schneider's lack of continued implementa-tion of previously committed corrective action.
There-fore, we do not consider that these were " serious" installation errors.
2.
Corrective steps which have been taken or will be taken to prevent recurrence of the repetitive housekeeping problem:
(a)
SI is generating and upgrading inspection plans, reevaluating inspection personnel requirements, and conducting additional training.
They have estab-lished January 15, 1981 as a target date for com-pleting this activity.
(b)
PDM has assigned a full-time inspector to perform surveillance of SI activities.
The surveillance will be monitored by PDM's Site QA Manager who will inform the PDM Division QA Manager of the progress.
3.
Date when full compliance will be achieved:
(a)
Bach.el's action will be achieved by January 5, 1981.
(b)
January 15, 1981 is the date Schneider, Inc., has targeted for completion.
If you require additional information, we will be pleased to j
discuss it with you.
Very truly yours,
-('
/
'j
/
CC:
Office of Inspection and Enforcement l
Division of Reactor Construction and Inspection i
Washington, D.C.
M P80 153 11/7
.