ML20028G101
| ML20028G101 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 11/08/1982 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20028G093 | List: |
| References | |
| NUDOCS 8302070396 | |
| Download: ML20028G101 (29) | |
Text
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ENCLOSURE 2 i
i U.S. NUCLEAR REGULATORY COMMISSION REGION I 1
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE PUBLIC SERVICE ELECTRIC AND GAS COMPANY HOPE CREEK GENERATING STATION UNIT 1 (Construction Phase) l November 8, 1982 l
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i 6302070396 83020g
[M ADOCK 05000354 PDR
TABLE OF CONTENTS Page I. INTRODUCTION....
2 1
1.1 Purpose and Overview 2
1.2 SALP Board and Attendees 2
1.3 Background
2 II.
SUMMARY
OF RESULTS..............
5 III. CRITERIA..................
6 IV. PERFORMANCE ANALYSIS 4.1 Soils and Foundation 7
4.2 Containment and Other Safety Related Structures.
9 12 4.3 Piping Systems and Supports.
4.4 Safety Related Components.
14 4.5 Support Systems..
16 4.6 Electrical Power Supply and Distribution 18 4.7 Instrumentation and Control Systems.
19 4.8 Licensing Activities 20 V. SUPPORTING DATA AND SUMMARIES 5.1 Cor.struction Deficiency Reports (CDRs) 21 5.2 Investigation Activities 21 5.3 Escalated Enforcement Actions.
21 5.4 Management Conferences 21 TAB L_E_S TABLE 1 - CONSTRUCTION DEFICIENCY REPORTS.
22 TABLE 2 - VIOLATIONS 23 i
TABLE 3 - INSPECTION HOURS
SUMMARY
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TABLE 4 - INSPECTION ACTIVITIES 25 ATTACHMENT ATTACHMENT 1 - ENFORCEMENT DATA.
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-I.
INTRODUCTION 1.
Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect the available observations on an annual basis and evaluate licensee performance based on those observations with the objectives of improving the NRC Regulatory Program and licensee performance.
The assessment period is September 1, 1981 through August 31, 1982.
i The prior assessment period was July 1,1980 tnrough June.30,1981.
i The two month gap between assessment periods does not impair the current evaluation as no significant findings were identified during that time frame.
Significant findings from the prior assessment are discussed in the applicable Performance Analysis (Section IV) functional areas.
Evaluation criteria used during this assessment are discussed in Section III below.
Each criterion was applied using the " Attributes for Assessment of Licensee Performance," contained in NRC Manual Chapter 0516.
2.
.SALP Board and Attendees:
i Review Board Members R. W. Starostecki, Director, Division of Project and Resident Programs (DPRP)
T. T. Martin, Director, Division of Engineering and Technical Programs (DETP)
R. R. Keimig, Chief, Reactor Projects Branch No. 2, DPRP i
E. J. Brunner, Acting Chief, Reactor Projects Branch No.1, DPRP S. D. Ebneter, Chief, Engineering Programs Branch, DETP J. H. Joyner, Chief, Technical Programs Branch, DETP L. E. Tripp, Chief, Reactor Projects Section No. 2A, DPRP W. H. Bateman, Senior Resident Inspector, Hope Creek Generating Station A. Schwencer, Chief, Licensing Branch No. 2, NRR j
Attendees W. J. Lazarus, Project Engineer, Reactor Projects Section 2A, DPRP l
===3.
Background===
Public Service Electric and Gas Company was issued Construction Permits (CPPR-120 and 121) to build Hope Creek 1 and 2 (DN's 50-354 and 50-355) on November 4, 1974. On December 23, 1981, Public Ser-vice announced cancellation of Unit 2 based on the economic situation and lower than anticipated load growth.
The Unit 1 NSSS is a 3293 MWt General Electric BWR Class 4 housed in a Mark I containment.
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i (1) Licensee Activities Activity on' Unit 1 increased throughout the assessment period and Unit 2 was cancelled four months.into the assessment period.
The craft work force increased from approximately 3000 to 4000 during the period. At the end of the period, consideration was-bei'g given to different methods to accomplish a ten hour per day, seven day work week.
The licensee committed to the New Jersey Board of Public Utilities to setting a ceiling on the cost of Unit 1 at $3.79 billion.
Safety related activity on Unit I was primarily in the areas of concrete placement, structural steel installation, pipe and support installation, reactor internals installation, cable tray and conduit installation, purchase of electrical cable, and installation of permanent plant equipment.
Installation of HVAC ductwork and supports and setting of electrical panels and instrumentation racks commenced this period. The first reactor coolant pressure boundary piping connection was made to the reactor pressure vessel.
Construction progress was marked by a 17% increase in the over-all plant completion status from 37% to 54%. The licensee submitted a letter to NRC requesting cancellation of the Construction Permit for Unit 2 which was approximately 18%
complete. An evaluation is in progress to determine the i
physical effects of the cancellation of Unit 2 on Unit 1.
E The licensee increased manpower in their site QA, construction, i
plant startup, and electric production groups. The number of i
Bechtel non-manual personnel also increased substantially, s
PSE&G commenced construction of their nuclear department facili-ties on the Hope Creek site and started activities to improve the access to and egress from both the Hope Creek and Salem sites.
s (2) Inspection Activities f
Resident inspector activities involved accomplishment of assigned inspection requirements including observation of sork in progress, followup of licensee events, pursuit of allegations, reactive inspection, and evaluation of licensee responses to identified concerns.
I Thirteen inspection reports were issued during the evaluation period: 7 independently by the senior resident inspector, five jointly by the senior resident inspector and one regionally based specialist inspector, and one by a regionally based specialist inspector.
The specialist inspection activity in four of the five joint reports was limited to civil activities l
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primarily in regards to preparation for and placement of the service water intake structure foundation.
The fifth joint report involved the resident inspector assisting in an in depth QA inspection. The single inspection by a regionally based specialist inspector examined the procedures controlling performance of the Unit 2 structural integrity test.
(3) Licensing Activities No major licensing activities occurred during this assessment period. The licensee intends to submit the FSAR and Environmental Report in March of 1983.
l Licensing activities that did take place during this assessment period include:
Resolution of ASME III Subsection NF jurisdictional boundary question; Resolution of modification to shape of Vincentown excavation
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supporting the Service Water Intake Structure; Progress toward resolution of deviation from 10 CFR 50 paragraph 50.55(a) - Codes and Standards Rule; and 1
Response to NRR Generic Letter 81-01 requiring implementation of USNRC Regulatory Guide 1.58 which endorsed ANSI Standard N45.2.6 - 1978 concerning qualification of QC personnel.
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II.
SUMMARY
OF RESULTS HOPE CREEK GENERATING STATION Category Category Category Functional Areas 1
2 3
1.
Soils and Foundation X
2.
Containment and Other Safety Related Structures X
3.
Piping Systems and Support _s X
4.
Safety Related Components X
5.
Support Systems X
6.
Electrical Power Supply and Distribution No Basis for Assessment 7.
Instrumentation and Control Systems No Basis for Assessment 8.
Licensing Activities Insufficient Basis for Assessment 5
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III. CRITERIA ~
The following criteria were used as applicable in evaluation of each functional area:
1.
-Management involvement in assuring quality.
2.
Approach to resolution of technical issues from a 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.
To provide consistent evaluation of licensee performance, attributes associated with each criterion and describing the characteristics appli-cable to Category 1, 2, and 3 performance were applied ~as discussed in NRC Manual Chapter 0516, Part II and Table 1.
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The SALP Board conclusions were categorized as follows:
Category _1:
Reduced NRC attention may be appropriate.
Licensee manage-ment attention and involvement are aggressive and oriented toward nuclear j
safety; licensee resources are ample and effectively used such that a 3
high level of performance with respect to operational safety or construc-i tion is being achieved, i
j Category _2:
NRC attention should be maintained at normal levels.
Licensee 1
management attention and involvement are evident and are concerned with I
nuclear safety; licensee resources are adequate and are reasonably effective
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such that satisfactory performance with respect to operational safety or construction is being achieved.
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Category _3:
Both NRC and licensee attention should be increased.
Licensee
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management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appeared strained or not effectively used such that minimally satisfactory performance with respect to operational safety or construction is being achieved.
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IV. PERFORMANCE ANALYSES j
1.
Soils and Foundation (18%)
Analysis Onsite excavation and backfill activities continued throughout the evaluation period. The majority of the safety related activity in this area was associated with burying of the Service Water piping.
Because excavated soil is not suitable for backfill, backfill material had to be trucked onsite. The sources of backfill material were approved prior to their use and the suitability of the backfill material was continuously monitored by the onsite soils and concrete testing laboratory and Bechtel QC. Observations by the resident inspector of in process activities, such as excavation to required depth, deposit of backfill in limited thickness layers, compaction to required density, and testing of compacted backfill resulted in no adverse findings.
Major progress was made on construction of the Service Water Intake Structure (SWIS).
This progress included excavation within a sheet pile cofferdam to the Vincentown geologic formation (Vincentown) and underwater placement of approximately 17,700 cubic yards of concrete on top of the Vincentown to form a basemat for further SWIS construc-tion.
The excavation to Vincentown encountered one significant problem.
In particular, the Vincentown was not at the elevation expected based on core samples taken several years earlier. Additionally, coring determined that further excavation was necessary but that modifications to the original bottom profile of the SWIS basemat could be made to minimize the impact.
The licensee obtained NRC approval prior to implementing their modifications.
Upon completion of the SWIS excavation and prior to underwater concrete placement, Dames and Moore and Bechtel diver geologists inspected the bottom for shape and cleanliness.
Based on their experience, the workmanship and cleanliness of the excavation were considered exceptional.
Underwater concrete placement followed the inspection.
This tremie placement challenged the concrete produc-tion facility and the construction and QC personnel involved for a five day period, twenty-four hours a day.
Placement was completed early and rates reached 200 cubic yards per hour. NRC resident and i
regional inspector surveillance, as well as licensee and Bechtel QA surveillance, identified no significant problems. The pre planning, personnel training, and coordination was exceptional, as was the day to day implementation of the controlling procedures.
Prior to commencement of safety related activities by J. Rich Steers (JRS), the SWIS contractor, the JRS QA/QC manual was reviewed and found deficient by NRC.
However, upon identification of the problem areas, JRS, Bechtel, and the licensee undertook to correct the i
deficiencies.
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The cancellation of Unit 2 caused foundation concerns relating to site weight loading which are under investigation by the licensee.
Heave / settlement monitoring activities for both units were reviewed and found to be in effect and up to date.
It appears from the results that settlements are leveling off with.i acceptable limits.
No construction deficiency reports were issued in this functional area.
The licensee demonstrated a clear understanding of the important issues that arose in this area and approached these issues in a technically sound, thorough, and timely manner.
The routine activities were consistently performed to meet quality requirements.
. Conclusion Category 1 Board Recommendation None 8
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I 2.
Containment and Oth'er Safety Related Structures (34%)
Analysis The prior assessment discussed an unresolved item where the licensee took issue with an NRR position requiring testing of rebar splicing crews.
During this assessment period, the licensee commenced testing rebar splicing crews in accordance with the NRR position.
Concrete continued to be placed throughout the period.
The reactor building cylindrical wall was completed to the springline, concrete panel wall placement commenced, the spent fuel pool bottom was placed, high density concrete was pumped into the upper biological shield, the drywell shield wall was placed, and SWIS structural concrete placements commenced.
Concrete was placed under both hot and cold weather conditions.
The inspector raised questions regarding Cadweld identification, concrete consolidation, plumbness of formwork, use of Lorrelation data, and hot weather mass concreting practices. All were adequately addressed by the licensee. QC involvement in all activities was evident and effective. A review of QC inspector quali-fication records indicated that an active training program was in effect and that all personnel were properly qualified.
No violations or construction deficiency reports involving concrete and rebar were identified.
Structural steel continued to be erected inside the drywell and at most elevations of other safety related structures. Many bolted 4
connections, both inside and outside the drywell were welded because of design changes, misalignm(nt caused by steel fabrication errors, misalignment caused by out of plumb concrete walls, and mislocated beam seats. Welding was an appropriate engineering resolution for these alignment problems.
Several NCR's were written to identify these problems.
The site NCR trending system identified a trend in this area and corrective action was initiated.
Part of-the corrective action involved the use of steel columns (eventually to be embedded) to support formwork in lieu of guy wires.
Structural welding was found to be in conformance with AWS D1.1 Code require-
- ments, i.e., procedures were qualified, weld quality was acceptabla, preheat was used when required, filler metal issue was controlled, and the inspection status was thoroughly documented in Quality Control Inspection Reports (QCIR's).
Bechtel administered onsite training i
courses to prepare field engineering and QC personnel for the AWS Qualified Welding Inspector examination.
During the evaluation period, i
questions raised by the inspector regarding automatic stud welding j
and arc strikes were promptly resolved by the licensee.
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Two violations involving structural steel were identified.
The first concerned failure to follow AISC and drawing requirements for friction type connections inside the drywell. The response to the violation was adequate, however, the violation indicated an inadequacy in training l
of the first line craft supervision and QC inspection personnel as l
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related to structural steel.
The second violation involved failure 4
of a vendor supplying slab support beams to bend test shear connector studs in accordance with AWS DI.1 requirements.
This noncompliance identified a weakness in the training of both the supplier's_QC inspec-4 tion personnel and Bechtel's supplier quality personnel.
The upper biological shield, which came in.three segments, underwent a large amount of modification and welding due to manufacturing deft-ciencies. Bechtel onsite and home office efforts to resolve the problems were effective and-thorough. However, insufficient attention was paid to maintaining bioshield internal cleanliness 1
during field assembly operations. This.resulted in a large and difficult cleanup effort prior to pumping high density grout into the bioshield for radiation shielding.
Better preplanning by the constructor would have resulted in minimal internal cleanliness problems.
The Unit 2 containment structural integrity test was performed without problems. One construction deficiency was reported regarding weld burnthrough of a Unit 2 vent line bellows and j
allegations were received regarding Unit 2 containment NDE and welding deficiencies.
The allegations were investigated by an NRC Investigator and the Senior Resident Inspector and found to be without basis.
Installation of piping and electrical penetrations to the Unit 1 drywell commenced during this period.
The proposed NDE of the piping flued head penetrations was reviewed against the requirements of NRC Bulletin 80-08 and found to be in conformance.
A question was raised by the inspector regarding overpressure testing of the welds connecting the penetrations to the drywell. This is an apparent problem since the containment structural integrity test was performed prior to welding the penetrations to the drywell. An additional question was raised by the inspector regarding the classification of the flued head penetration support steel as part of the building structure.
These questions remain to be answered and engineering disposition is under active review. One violation was identified regarding contain-ment penetration installation:
an electrical penetration was tack l
welded into position using weld filler metal that was not properly i
issued. This violation again demonstrated a first level craf t super-vision training problem.
It also demonstrated a lack of coordination i
l between the trades involved in the work.
j The expansion anchor bolt (EAB) and core drilling programs were reviewed by the inspector in detail. A question was raised regarding EAB minimum edge distance limitations which is still under investiga-tion by the licensee.
EAB's are used in pipe support, cable tray, conduit, HVAC ductwork, and concrete panel wall installation. The Bechtel program controlling their installation is thorough but a minor breakdown in implementation of the program was identified as a violation. The violation involved failure to obtain excavation 10
permits to drill EAB holes to a depth equal to or greater than 6".
The purpose of this permit is to prevent damage to embedded pipe and conduit. This problem again illustrates that first line supervision is either not adequately trained or fails to implement established procedures.
Further investigation into this problem determined that other onsite contractors who are drilling into safety related concrete walls do not have programmatic controls similar to Bechtel's.
This failure to establish uniform controls for all installers of EAB's is considered a weakness in management control.
Efforts should be directed toward ensuring that first line craft supervisors are aware of the requirements contained in the implementing procedures and the necessity for implementing these requirements. Additionally, efforts should be increased to ensure all contractors performing safety related activities follow proce-dures that contain uniform requirements.
Conclusion Category 2 Board Recommendation None 11
3.
Piping Systems and Supports (20%)
Analysis The previous assessment identified a series of subcontractor problems that were corrected, in part, by increased surveillance over contractors and subcontractors by the constructor QC group and licensee QA.
It was anticipated this effort would strengthen the overall inspection program in all functional areas. This has not been entirely successful as evidenced by the analyses discussed in paragraphs 4 and 5.
Pipe, pipe support, and pipe whip restraint installation was a major activity during this evaluation period. The first reactor coolant pressure boundary piping connection was made to the reactor pressure vessel, installation of small bore piping commenced, and Reactor Controls, Inc. installed a portion of the control rod drive mechanism hydraulic piping.
Installation of underground piping included Service Water and Fire Protection runs.
Small bore pipe and pipe support activity increased at an offsite facility.
Pipe installation activities such as rigging, handling, maintenance of pipe internal cleanliness, preheat, and fitup were in accordance with good construction practices and site procedures. Welding acti-vities were in accordance with qualified procedures, were performed with qualified welders, and inspected by qualified QC personnel.
NDE requirements were performed as required and all inspection acti-vities were thoroughly documented on QCIR's.
The reject rate was high for welds required by Code to be radiographed.
Field Engineering attempts to improve such welding met with minimal success.
One major issue regarding proper selection of the ASME III Subsection NF jurisdictional boundary for piping supports was resolved.
The licensee made a presentation of their program to NRR and received concurrence. Also, the licensee amended their PSAR to take advantage of current Code requirements for NDE of NF type supports. The licensee took this action after questions were raised by the inspector NRC inspections verified that embedded piping was pressure tested prior to embedment, acceptable purge dam material was in use, QC inspectors were adequately trained and properly qualified, material traceability was possible, and a program to address arc strikes was in effect.
No violations were identified and no construction defi-ciencies were reported in this area.
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l The licensee consistently demonstrated prior planning and assignment of priorities.
Decision making processes involved adequate management involvement and review.
Records were complete, well maintained, and available.
Timely resolution of questions and problems was consistently evident with good engineering effort apparent.
Contiusion Category 1 Board Recommendation None l
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4.
Safety Related Components (16*o)
Analysis The major activity in this area involved installation of reactor pressure vessel internals.
In addition, two diesel generator units and the reactor building polar crane were received onsite.
Compo-nents were stored and maintained in accordance with procedures both in place and in storage facilities located onsite and offsite.
Two construction deficiencies were reported; one, as a result of a 10 CFR 21 report. Both remain open but are under active review by engineering. Three violations were identified during the assessment period. A question arose regarding the responsibilities of General Electric Nuclear Energy Business Organization (GENEBO) and Bechtel at interfaces where Bechtel connects to GENEB0 supplied NSSS equipment. This question was ultimately resolved by issuance of a site procedure agreed to by both Bechtel and GENEB0.
The three violations related to General Electric Installation and Survices Engineering Division (GEI&SE) onsite activities.
The first violation involved failure of a welder to perform in accordance with procedure requirements which went undetected.
The second violation involved failure to take adequate corrective action to prevent recurrence of a violation regarding implementation of the weld filler metal issue procedure.
The third violation involved failure to implement procedural requirements to control measuring and test equipment. These violations indicated inadequate and ineffective involvement of onsite QC supervision in the areas of training and implementation of the quality program.
The eventual response to these weaknesses was to replace the onsite QC supervisor with a more experienced individual.
Corrective action, although effective, should have been more timely.
During the time period the three violations were identified, it was recognized by the licensee that the QC supervisor was weak.
Their attempt to correct the problem was encumbered by their inability to deal directly with the subcontractor because of contractural complications.
The two construction deficiencies involved HPCI/RCIC exhaust line check valve failures and diesel generator thermostatic control valve deficiencies. The licensee identified and reported these problems after review of an NRC Information Notice and a 10 CFR 21 report.
Licensee planned corrective action appears adequate.
Licensee initiative in identifying and resolving plant specific problems through review of various failure reports is considered a strength.
In general, RPV internals installation has been technically adequate.
A problem with unpredictable shroud movement caused by weld shrinkage when welding the shroud to the shroud support ledge caused a delay in internals installation.
The resident inspector followed resolution of this problem to a satisfactory conclusion.
RPV access and cleanliness control was good.
Licensee and Bechtel QA audits of GEI&SE were reviewed and found acceptable.
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t In summary, management generally recognizes and takes action to i
correct identified problems. Efforts should be made to streamline i
the process involved in dealing in a timely manner with subcontractor problems. Training and qualification contributed to an adequate understanding of work and fair adherence to procedures with a modest number of personnel errors.
Conclusion l
Category 2 I
Board Recommendation j
None i
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Support Systems (11%)
Analysis Installation of HVAC, radwaste, and fire protection systems are included in this area.
No inspections were performed of radwaste systems.
Inspection activity of fire protection systems included observation of underground piping installation including hydrostatic testing and protective wrapping of piping.
The major inspection effort was observation of HVAC work in progress.
HVAC activities commenced during this assessment period. W-H Constructors is the installer. Their QA/QC program was reviewed by the inspector and found to meet the criteria of 10 CFR 50 Appendix B.
Problems evolved during the assessment period with implementation of the QA/QC program, however, and resulted in a stop work order and eventual assumption of all onsite QC inspection of HVAC activities by Bechtel.
The W-H problems started at the outset of their onsite work when Bechtel issued a stop work order due to a lack of confidence in W-H's ability to perform to meet quality requirements.
Problems continued and W-H QC inspectors on one occasion were allegedly intimidated by the crafts whose work they were rejecting. The licensee initially did not inform the NRC of the intimidation I
incident indicating an apparent lack of openness on their part.
However, after the licensee became aware of the incident, there were no further instances of intimidation indicating their corrective action was effective in precluding recurrences. Approximately one i
month after the intimidation incident, a W-H QC inspector was fired.
Subsequent to his being fired, the W-H inspector made potentially serious allegations to Bechtel and the licensee regarding the quality of HVAC ductwork installation and W-H management practices.
Just after the allegations were made, the licensee informed the NRC of the particulars of the firing and the previous intimidation incident.
As a result of the W-H in house problems, more NRC inspection effort was spent reviewing their work in progress, licensee and Bechtel I
followup to the above allegations, and documentation. These efforts resulted in the identification of two unresolved items and three violations. One of the unresolved items concerned the lack of involvement of QC in verifying torque applied to bolts / nuts used in assembly of ductwork supports.
Had the licensee promptly investigated and resolved this item, they probably would have avoided the first violation involving failure to maintain an inspection status of ductwork support expansion anchor bolt torquing.
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The second violation involved failure of W-il to follow their contract specification requirements to obtain design approval prior to deviating from approved design drawings.
This resulted in as-built conditions dif fering from design conditions with no one aware of the differencos.
The third violation involved failuro of W-il to qualify and cortify QC inspectors to the requirements of ANSI N45.2.6 and their QA manual. -Immediately after this finding was idontified, a socor,d stop work ordor was issued. All W-il work came to a stop while QC personnel were trained, reevaluated and in one caso downgraded to meet requirements. At this point in time, the Itconsco decided that j
a major step was required to avoid further problems wtth W-il.
The decision was mado and eventually implemented to dolote onsito QC i
responsibilities from W-II's scopo of work.
llechtel QC took over the j
onsite QC activitios and W-il retained QC responsibilitlos for shop work.
l The three W-il violations indicated inadequato QC and craf t training, poor Internal communication, and lack of W-il management involvement in assuring quality.
lho licensee's inability to take prompt corrective action to correct a known problem with W-ll evidenced itself in the sequence of events.
Final correctivo action, however, was effectivo.
No construction or 10 CFR 21 deficiencies were reported.
l In conclusion, licensee and subcontractor training and qualtftcation effectiveness is evidenced by dofined programs that are implemented l
for most of the personnel.
Staffing 15 generally adequato but the licensee's system for correcting occasional subcontractor staf fing i
i problems is cumbersome and requires streamlining.
. Conclusion i
Category 2 j
lloard Jlecommefula t iqn Nono i
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6.
Electrical Powei Supply and Distribution (1?;)
Analysis Cable tray and conduit continued to be installed throughout the evaluation period. Additionally, electrical panels and equipment items were installed, protected, and maintained.
No permanent plant cable was pulled.
No construction or 10 CFR 21 deficiencies were reported.
Inspection activity of this area was minimal with no violations identified.
Conclusion No basis for assessment Board Recommendation None l
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7.
Instrumentation and Control Systems (0%)
Analysis Activity during this assessment period included mounting of instrument racks and control system cabinets.
The instrument racks and cabinets were protected from damage by erection of protective enclosures.
No construction or 10 CFR 21 deficiencies were reported.
There was no inspection activity in this area.
Conclusion No basis for assessment Board Recommendation None 19
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i 8.
Licensing Activities Hope Creek is a " post-CP" facility' for which Public' Service Electric and Gas Company (PSE&G) is not expected to file the OL application until March of 1983. Only limited licensing activities were conducted during the assessment period, which were:
i Use of supplementary steel in pipe supports Resolution of new base for intake structure January 7, 1982 meeting to solicit staff guidance towards PSE&G's j
efforts to write ER/0L documents.
NRR finds that PSE&G's management has demonstrated involvement in assuring they conform to NRC requirements.
This is demonstrated by the fact that they are, during this post-CP stage, seeking guidance on how they can be assured that their application, when submitted j
next spring, will be acceptable as to content and format.
Based on a concern of the resident inspector about the selection of the NF jurisdictional boundary as related to supplemental steel used in pipe supports, PSE&G requested a meeting with NRR during which they presented the issue and provided a sound technical basis for i
their approach on this problem. Although NRR had some problems with their approach, it was considered acceptable with certain limitations.
Although there has been very little licensing activity during this assessment period, based on ?SE&G's responses, responsiveness to NRR l
initiatives has been adequate.
Conclusion Limited activity provides insufficient basis for conclusion.
Board Recommendation None I
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4 V.
SUPPORTING DATA AND SUMMARIES i
1.
Construction Deficiency Reports (CDRs)
I Ten CDRs were submitted by the licensee during the assessment period.
After evaluation, seven were determined to be not reportable and one was cancelled with the cancellation of Unit 2.
All deficiencies are listed in Table 1 and were analyzed for causal links.
They were individually evaluated as part of the functional area that they re-presented.
No causally linked CDRs were identified.
2.
Investigation Activities Two inquiries into allegations / concerns were conducted.
In the 1
first case, none of the allegations were substantiated.
In the second case, the conditions under which the allegations were made 3
j have since been changed with no potential remaining for substantive i
negative findings.
i 3.
Escalated Enforcement Actions j
None.
4.
Management Conferences a.
September 25, 1981 - a special, announced management meeting at PSE&G's request to discuss their reorganization plans.
b.
November 12, 1981 - a special, announced management meeting at NRC request to discuss the results of the Region I SALP board i
convened to evaluate licensee performance from July 1,1980 to June 30, 1981.
(Combined Meeting Report 354/81-17 and 355/81-18).
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TABLE 1 CONSTRUCTION DEFICIENCY REPORTS 4
(9/1/81 - 8731/82)
HOPE CREEK GENERATING STATION CDR No.
DEFICIENCY CAUSE CODE
- 81-00-06 Fabrication defects in Unit 2 lower B
biological shield supplied by PX Engineering
- 81-00-07 Torus seismic concern B
- 81-00-08 Auxiliary Building seismic response B
81-00-09 Burnthrough of Unit 2 ventline bellows F
81-00-10 HPCI/RCIC exhaust line check valve failures E
- 81-00-11 Potential overstress problems with B-line E
electrical tray support hardware
- 82-00-01 Deflected main steam line bellows F
- 82-00-02 Diesel generator spider bolt torquing B
- 82-00-03 Method of staking diesel generator B
Robertshaw thermostatic control valve adjustment nut
- 82-00-04 Solder used to stake diesel generator B
Robertshaw thermostatic control valve adjustment nut
- Reported as Potential Deficiency and subsequently cancelled.
- Also reported under 10 CFR 21.
- Reported as Potential Deficiency and subsequently cancelled. Also reported under 10 CFR 21.
Cause Codes A
Personnel Error B
Design / Fabrication Error C
External Cause D
Defective Procedures E
Component Failure F
Site Construction Error 22
TABLE 2 V!0LATIONS (9/1781 - 8731/82)
^
00PE CREEK GENERATING STATION A.
Number and Severity level of Violations 1.
Severity Lev.el Severity Level !
Total 10 B.
Violations vs. Functional Area Severity _ Level Functional Area IV V
1.
Soils and Foundation 0
0 2.
Containment and Other Safety Related Structures 2
1 3.
Piping Systems and Supports 0
0 4.
Safety Related Components (RPV) 0 3
5.
Support Systems (llVAC) 3 0
6.
Electrical Power Supply and Distribution 0
1 7.
Instrumentation and Control Systems 0
0 Note:
The NRC Enforcement Policy was revised during the assessment period.
This resulted in upgrading Severity Level V citations under the old policy to Severity Level IV citations under the revised policy. All ten violations are substantially the same Severity Level.
23
TABLE 3 INSPECTION HOURS
SUMMARY
(9/1/81 - 8/31/82)
HOPE CREEK GENERATING STATION Functional Area Hours
% of Time 1.
Soils and Foundation 233 18 2.
Containment and Other Safety Related Structures 441 34 3.
Piping Systems and Supports 258 20 4.
Safety Related Components 206 16 5.
Support Systems 155 11 6.
Electrical Power Supply and Distribution 19 1
7.
Instrumentation and Control Systems 8.
Licensing Activities TOTALS 1312 100%
l 24
TABLE 4 INSPECTION ACTIVITIES t
HOPE CREEK GENERAiING STATION Report Number Inspector Areas Inspected 81-14 Resident RPV internals, training, excavation, QA manual review 4
i 81-15 Resident Concrete activities, documentation review, pipe & hanger installation, NDE 81-16 Resident Rebar, welding, allegations, excavation,
{
Specialist pipe installation, fire protection 1
81-17 Cycle 2 SALP 81-18 Resident Structural steel, cable tray, rebar, con-Specialist crete, RPV internals, hangers and supports 82-01 Resident RPV internals, Bulletin review, concrete, Specialist structural steel i
82-02 Specialist QA, RPV internals, HVAC ductwork 82-03 Resident Storage and maintenance, structural steel, i
concrete, NDE, RPV internals, pipe and support installation, material traceability 82-04 Resident Containment penetrations, NDE, HVAC duct-Specialist work, concrete, storage, RPV internals, pipe and supports 82-05 Resident Expansion anchor bolts, NCR trending, HVAC 82-06 Resident RPV internals, diesel generator installation, Specialist pipe welding, pipe support installation, qualification of QC personnel, concrete placement I
82-07 Resident Structural welding, qualification of QC personnel, concrete, RPV internals, pipe supports and restraints, arc strikes i
i 25
Report Number Inspector Areas Inspected 82-08 Resident Excavation, welding, pipe and supports, RPV internals, structural steel, NDE 82-09 Resident FCN program, housekeeping, EAB installation, stud welding, structural steel, pipe supports 26
4 0
ATTACHMENT 1 ENFORCEMENT DATA SEV.
FUNC.
REPORT SUBJECT LEVEL AREA 354/81-14 Failure of GEI&SE to add filler n:etal while V
4 welding plugs into core support plate using GTAW process.
354/81-18 Failure of GEI&SE to take adequate ccerective V
4 action to prevent recurrence of fallt.ro to implement weld filler metal iscue procedure.
354/81-18 Failure of Bechtel to implement drawing V
2 s
requirements for friction type connections used in erection of structural steel.
354/82-01 Failure of GEI&SE to implement procedural V
4 requirements to control measuring and test equipment.
354/82-04 Failure to implement weld metal issue V
2 procedure when welding containment electrical penetration.
354/82-05 Failure of W-H to maintain an inspection IV 5
status of ductwork support expansion, anchor bolt torquing.
354/82-05 Failure of W-H to follow their contract IV 5
specification requirements to obtain design approval prior to deviating from approved design drawings.
354/82-07 Failure to bend test floor beam shear IV 2
connectors in accordance with AWS D1.1 requirements.
354/82-07 Failure of W-H to qualify and certify QC IV 5
inspectors to requirements of ANSI N45.2.6 and their QA Manual.
354/82-07 Failure of Bechtel to implement procedure IV 2
to obtain excavation permit prior to drilling expansion anchor bolt holes to a depth of 6" or more.
27
.. o ENCLOSURE 3
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NOV 2 21982 Docket / License:
50-354/CPPR-120 Public Service Electric and Gas Company ATTN:
Mr. T. J. Martin Vice President - Engineering and Construction 80 Park Plaza - 17C Newark, New Jersey 07101 Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP)
The NRC Region I SALP Board conducted a review on November 8, 1982 and evaluated the performance of activities associated with the Hope Creek Generating Station, Unit 1.
The results of this assessment are documented in the enclosed SALP Board Report.
A meeting has been scheduled for December 7, 1982 at the site to discuss this a.sessment.
This meeting is intended to provide a forum for candid discussions relating to this performance.
At the meeting, you should be prepared to discuss our assessment and your plans to improve performance.
Any comments you may have regarding our report may be discussed at the meeting.
Additionally, you may provide written comments within 20 days after the meeting.
Following our meeting and receipt of your response, the enclosed report, your response, and a summary of our findings and planned actions will be placed in the NRC Public Document Room.
Your cooperation is appreciated.
Sincerely,
\\
1
\\
n
>b Richard W. Starostecki, SALP Board Chairman Director, Division of Project and
Enclosure:
As Stated Resident Programs cc w/ encl:
R. Eckert, Senior Vice President, Energy Supply and Engineering R. L. Mittl, General Manager, Corporate QA A. Schwencer, Chief, LB #2, NRR
.