ML20028G102

Comments on SALP Rept for Sept 1981 - Aug 1982.Rept Provides Fair Assessment of Performance

ML20028G102
Person / Time
Site:	Hope Creek
Issue date:	12/27/1982
From:	Martin T Public Service Enterprise Group
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20028G093	List: ML20028G102
References
NUDOCS 8302070398
Download: ML20028G102 (2)

Text

ENCLOSURE 4

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Thomas J. Martin Public Service Electric and Gas Company 80 Park Plaza Newark, N.J. 07101 201/430 8316 Vice President Engineering and Constructfor December 27, 1982 Mr. Richard W. Starostecki Director, Division of Project and Resident Programs U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Starostecki:

HOPE CREEK GENERATING STATION (50-354)

, SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE I

i In response to the invitation in your letter dated November 22, 1982, transmitting the subject report, we have elected to underscore some of the topics addressed at the on-site SALP meeting, particularly the steps we have planned for further improving our OA Program in the area of training. .

Section two (2) of the SALP Report includes a discussion concerning testing of rebar splices in accordance with an NRR position. Since this could be construed to indicate our testing program did not meet current regulatory require-ments, we wish to reference our letter dated September 17, 1981, which pointed out our compliance with Regulatory Guide 1.94. The NRR position required additional testing in ac-cordance with former Regulatory Guide 1.10, which had been withdrawn by the NRC.

Section five (5) of the SALP Report stated that we were un-able to "take prompt corrective action" with regard to known subcontractor problems. In this area, we wish to point out that increasingly severe actions were being taken from the initiation of our investigation into the improvement of W-H Constructors OC Program. These actions included letters, management meetings, formal corrective action requests, stop work, and finally removal of OC inspection and testing responsibility from the contractor. The escalation of activities, management approval and implementation of this drastic and unprecedented step was accomplished in less than eleven (11) weeks. We feel that prudent steps must be taken to encourage contractors to upgrade their performance before the more drastic steps are undertaken. In this particular case, we lost confidence in the contractor's ability to manage their OC program and relieved them of this q\

responsibility. - "

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PDR

Richard W. Starostocki 12/27/82 Your report also pointed out where better training in the area of construction supervision would have led to improved performance. In response to this concern, our Architect Engineer and Constructor, Bechtel Power Corporation, has initiated a task-force effort to review the jobsite training programs of craft and non-manual personnel. Planned steps include:

1. Review of available data for indicators of training weakness (Nonconformance Reports, audit findings, independent evaluations, etc.),

2. Review of Hope Creek training programs,

3. Comparison with training programs in use within the industry and at other Bechtel projects, and

4. Compilation of recommendations for improvements in

the areas of program content, methods, and training organization.

We anticipate receipt of the review team findings and recom-mendations by April 1, 1983. Firm dates for implementation of the training program improvements will be established by May 1, 1983.

We feel that the on-site meeting was mutually beneficial and we appreciate the spirit of openness and professionalism that prevailed. The meeting afforded us ample opportunity to discuss the wording of the SALP Report. In general, we consider this report a fair assessment of performance.

Very truly youra,

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