ML20050C351
| ML20050C351 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 03/24/1982 |
| From: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Martin T Public Service Enterprise Group |
| References | |
| NUDOCS 8204080426 | |
| Download: ML20050C351 (32) | |
Text
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MAR 2 41982 Bocket Hos. 50-354
/C \\
50-355
/
/
Public Service Electric & Grs Company C;
p.~,_
ATTH: V. T. J. Martin D
Vice President 2
Arn r
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6-t Engineering and Construction lf[/
80 Park Plaza - 17C tiewark, New Jersey 07101 D
M Gentlemen:
[\\
Subject:
Systematic Assessment of Licensee Perfonnance (SALP)
This refers to the SALP performed by,this office on October 20, 1981 regarding the Hope Creek Generating Station and to the discussions of our findings held with your staff on November 12, 1981. That SALP covers the period of July 1, 1980 through June 30, 1981.
The attached SALP report for your facility is being issued and distributed in accordance with recently established NRC policy. Although this report was prepared under previous criteria, the results have been reclassified under present guidance.
No reply to this letter is required. Your cooperation is appreciated.
Sincerely, Original Signed By:
Ronald C. Ilaynes Regional Administrator
Enclosure:
SALP - Evaluation Report cc w/ enc 1:
J. Boettger, General Manag)er, Corporate QA Public Document Room (PDR Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of tiew Jersey A. Schwencer, NRR bec w/ encl:
Region I Docket Room (w/ concurrences)
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I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Public Service Electric and Gas Company Hope Creek Generating Station Units 1 and 2 (Construction Phase)
Region I PERFORMANCE EVALUATION Evaluation Period:
7/1/80 - 6/30/81 Board Date: October 20, 1981 s
t (Note: Public Service Electric and Gas Company announced cancellation of the Hope Creek Unit 2 Project effective December 23,1981.)
1 LS _:
- _O,-
e FOREWARD The Region I SALP Board performed this assessment prior to the decision of the Nuclear Regulatory Commission to revise the NRC's program of Systematic
- Assessroent of Licensee Performance. An important change in this revision was to retitle and redefine the performance categories.
This change affords better characterization of the staff's evaluations of licensee performance.
These revised perfonlance categories were used for this report. Thi SALP Board formally evaluated the licensee's performance before the revised guidance was available. These initial rankings were subsequently equated with and converted to the new performance categories without fornally reconvening the Board.
The performance categories are to be printed in the Federal Register within a few weeks.
Each functional area evaluated is characteri7ed as being in one of the following categories:
a.
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 per-formance with respect to operational safety or construction is being achieved.
b.
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 effective such that satisfactory performance with respect to operational i
(_,
!~
l' safety or construction is being achieved.
!~
c.
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 construc-tion is being achieved.
s E
In characterizing the licensee's performance in a functional ' area as being in one of the Categories, performance is evaluated against the following criteria:
a.
Management involvement in assuring quality, b.
Approach to resolution of technical issues from safety standpoint, c.
Responsiveness to NRC initiatives, d.
Enforcement history, e..
Reporting and analysis of reportable events, f.
Staffing-(including management), and g.
Training effectiveness and qualification.
T 4
11
i PUBLIC SERVICE ELECTRIC AND GAS COMPANY HOPE CREEK GENERATING STATION Units 1 and 2 LICENSEE PERFORMANCE EVALUATION Region I Facility: Hope Creek Generating Station, Unit Nos. I and 2 Licensee: Public Service Electric and Gas Company Facility Information Unit 1 Unit 2 Docket No:
50-354 50-355 Licens,e No:
CPPR-120 CPPR-121 Date of Issuance:
November 4, 1974 November 4, 1974 l
NSSS:
General Electric General Electric l
l MWt:
3293 3293 Assessment Period:
July 1, 1980 to June 30, 1981 Assessment Date:
October 20, 1981-Review Board Members:
G. H. Smith, Director of Emergency Preparedness l
and Operational Support - SALP Board Chairman R. A. Starostecki, Director, Division of Resident l
and Project Inspection j
T. T. Martin, Director, Division of Engineering and Technical Inspection R. A. Gilbert, Licensing Project Manager - NRR R. R. Keimig, Chief, Projects Branch #2, ORPI l
W.- H. Bateman, Senior Resident Inspector, Hope j
Creek Generating Station l
Attendees:
L. E. Briggs, Project Inspector, RPS 2A, DRPI E. Brunner, Chief, Projects Branch #1, DRPI E. G. Greenman, Chief, Projects Section 2A, DRPI W. Hill', Resident Inspector, Salem Ger.erating Station E. McCabe, Chief, Projects Section 2B, DRPI L. S. Norrholm, Senior Resident Inspector, Salem Generating Station tz j
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8.
Number and Nature of Construction Deficiency Reports (CDR)
There were ten Construction Deficiencies reported.
Later four of these were determined to be not reportable and cancelled.
Six reports are common to Unit Nos. I and 2.
CDR's 80-00-02, 80-00-03, 80-00-04 and 80-00-05 were also included in the Cycle 1 evaluation.
Type of Event:
a.
Personnel Error 3
b(1). Design / Fabrication Error 1
b(2). Construction Error 1
c.
External Cause 1
d.
Defective Procedure 0
e.
Component Failure 0
f.
Other 0
Total 6
Causally Linked Events: None C.
Escalated Enforcement Actions Civil Penalties None Orders:
None Immediate Action Letters:
None D.
Management Conterences Held Meeting No. 80-11, August 5, 1980, to acquaint corporate management with the resident inspector and the resident inspection program.
Other topics discussed were: (a) Hope Creek project status, (b) status of FSAR, (c) NRC independent measurements program, (d) NRC programs underway to evaluate licensee performance, (e) 10 CFR 50.55(e) reporting, and (f) enforcement policy.
Meeting No. 81-03, February 5, 1981: an enforcement conference to discuss licensee and subcontractor performance and to review recent licensee responses to enforcement action.
Meeting No. 81-06, April 30, 1981: a management meeting to discuss the results of the Cycle 1 Regional SALP with the licensee.
Meeting requested by the licensee and held onsite February 24, 1981, to discuss qualification of QC personnel (discussed in Inspection Report 81-02).
E.
Licensee Activities Activity on both units increased steadily throughout the evaluation period. The beginning of the evaluation period was marked by settlement of a pipe-fitter strike and a low ebb in site manpower (approximately 200 craft personnel). After the strike was settled, site manpower loading started to increase and continued to increase throughout the assessment period.
(As of October 1981 there were approximately 3100 craft personnel on site.)
Safety related activity on Unit I was primarily in the areas of concrete placement, pipe installation, structural steel erection, bioshield installa-tion, reactor vessel installation, reactor internals installation, backfill, cable tray and conduit installation. Unit 2 activities were not as intense as Unit l's and included concrete placement, structural steel erection, and containment erection.
Milestones accomplished during the evaluation period included setting of the Unit I reactor vessel, restart of Unit 2 containment erection, and restart of service water intake structure excavation.
Licensee efforts to install emergency notification systems has been aggressive. System hardware is in place and will be functional by mid-November.
Unit I and common area (common area denotes systems common to Units 1 and 2 that are necessary to support Unit 1 operation) were estimated at 37%
complete and Unit 2 at 18% complete.
F.
Inspection Activities Resident inspector activities involved accomplishment of assigned inspection requirements including observation of work in progress, followup of licensee events, pursuit of allegations, reactive inspection, ar.d evaluation of licensee responses to identified concerns.
Of twenty inspections performed at Hope Creek during the evaluation period, seven were performed by the senior resident inspector, five were performed jointly by the senior resident inspector and regional based specialist inspectors, and eight were performed by regional based specialist inspectors. The inspections sampled all the work activity in progress (see paragraph E) and also included inspections of.the QA/QC programs.
l G.
Investigation Activities
.There were two informal investigations performed in conjunction with resident inspections. The first investigation, IE Report 81-04, dealt with an allegacion related to an ASME III Class 2 pipe weld undergoing repair. The resident inspector immediately notified the licensee of this allegation thus averting any physical problem.
Followup investigation sho,ted that the joint required radiography.
The potential weld problem would be apparent on the radiograph.
The second investigation, IE Report 81-01, dealt with an allegation from an individual about the design of the primary containment vacuum relief valves.
Followup investigation resulted in the licensee reporting this design question as potentially reportable per requirements of 10 CFR 50.55(e). This item was subsequently withdrawn as not reportable.
H.
Cycle 1 and Cycle 2 SALP Statistical Data Overlap Cycle 2 overlaps the last four months of Cycle 1.
The evaluation period for Cycle 1 was November 1, 1979 to October 31, 1980.
Cycle 2 began on July 1, 1980. The fellowing data is reviewed in both Cycle 1 and 2:
Noncompliances 354/80-14-01, 80-14-02, 80-14-03, 80-14-04; 80-16-01, 80-16-02, 80-16-03, and 50-355/80-14-01 CDR's 00-02, 80-00-03, 80-00-04, and 80-00-05
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INSPECTION HOURS
SUMMARY
Inspection Hours
-Functional Area (Unit I and 2 Combined) 1.
Quality Assurance 80 (8*s) *
- 2.
Site Preparation and Foundations 16 (2%)
3.
Containment Structures 221 (24%)**
4.
Safety-Related Structures 128 (14%)**
5.
Piping and Hangers 133 (15%)**
6.
. Safety-Related Components 181 (19%)
.7.
Electrical 23 (2%)
8.
Instrumentation 0'
(0's) 9.
= Fire Protection 0
(0's)
- 10. Preservice Inspection 0
(0*4)
- 11. Corrective Actions and Reporting 109 (12%)**
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- 12. Procurement 0
(0%).
- 13. Design and Design Changes 20*
(2%)
- 14. Training 20*
(2%)
931
- Estimated hours, not'766 data
- These hours reflect 766 data plus time. spent performing independent inspection.
k'
1 i
HOPE ~ CREEK GENERATING STATION Unit Nos. I and 2 PERFORMANCE ANALYSIS
SUMMARY
Category Category Category Functional Area 1
2 3
1.
Quality Assurance X
2.
Site Preparation and No Basis Foundations 3.
Containment Structures X
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14.
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i 5.
Piping and Hangers X
6.
Safety Related Components X
7.
Electrical (Equipment, X
Tray, Wire) 8.
Instrumentation and Wire No Basis 9.
Fire Protection No Basis 10.
Preservice Inspection No Basis 11.
Corrective Actions and Reporting X
- 12. Procurement No Basis l
13.
Design and Design. Changes X
- 14. Training X
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- 81-04c
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'ra ilure to incorporate nonessentia s B-IX NC6-EJ D' 6-
-variables into ASME IX weld proceduro g
and incorrect thickness qualification.
81-04-02 Failure to radiograph in accordance -
B-V
-NCS EEB 6-with procedure requi rements.
81-05-01~
4/6-5/3' 2* ACME embeds contained the following B-VII NC4 ESA
' 4; fillet weld defects: undersize, unde r-cut, surface & subsurface porosity.
81-10-03L 6/18, 19,
- No documented vertrication that B-V NC6 EEB 6-
.22-26 specified maintenance inspections were performed.
- Common to both units.
4 5
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y NONCOMPLIANCE DATA Unit No. 2 July 1,.1980 - June 30,.1981
. Cycle 2 '
Noncompliance.
d Number
- Period.of Inspection'
. Subject Req.
Sev.
Co'e Area
,' 80-14-01:
9/2-10/5
. *Fallure of Bechtel to follow bolt B-V'
. i n f.
EEB 4
tensioning procedures resulted in-improperly tensioned bolted connections the extent of which was not known.
81-05-01
. 4/6-5/3
- ACME embeds contained the following B-Vill NC4 ESA 4
fillet weld defects:. undersize, under-cut, surface & subsurface porosity,
'81-10-02
- 6/18, 19,
' *No documented. verification that B-V NC6 EEB 6
22-26
'specified maintenance inspections were performed.
- Common'to both units i
4 i
_s t'
CONSTRUCTION DEFICIENCY REPORTS CDR Report Cause No.
Date Subject Area
- 80-00-02 7/1/80 Missing NDE records for lower A
biological shield welds 80-00-03 8/12/80 Con Chem epoxy surfacer falsified C
records
- 80-00-04 10/9/80 Pipe purchased with longitudinal A
weld seams not radiographed 80-00-05 10/10/80 Pipe weld buildup repairs made but A
no inspections performed
- 80-00-06 12/4/80 Westinghouse circuit breakers C
derated 80-00-07 12/17/80 Inadequate design of bracket B(1) stiffener plates 81-00-01 3/5/81 Deformation of drywell bottom A
caused by concrete placement
- 81-00-02 4/22/81 Nonconforming fillet welds in ACME A
embeds 81-00-03 4/22/81 Safety relief valve discharge piping A
improperly cold pulled into position 81-00-04 6/19/81 Limitorque valve operator equipment B(2) deficiencies
- CDR evaluated and withdrawn as not reportable.
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I FUNCTIONAL AREAS PERFORMANCE ANALYSIS P
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Quality Assurance-a.
Cycle 1 The Cycle 1 analysis discussed 3 items of noncompliance in this area.
One of the three related to licensee surveillance of contractor and subcontractor activities. The licensee committed to implement an improved contractor / subcontractor surve'11ance program.
b.
Cycle 2 (80 hrs., 8*s)
Five inspections in areas of quality assurance and quality control of licensee, contractor, and subcontractor activities resulted in three items of noncompliance, two of which were during Cycle 1 and Cycle 2 overlap. The one noncompliance in Cycle 2 involved an isolated case of an unqualified QC inspector performing concrete inspections.
Licensee followup of this concern resulted in an improved program for QC personnel qualification.
The concern for effective contractor and subcontractor surveillance inspection identified in Cycle 1 was resolved during Cycle 2 as evidenced by satisfactory performance of surveillance inspection by all involved in this activity.
Inspector concerns regarding the vendor / supplier quality program were raised and pursued. These were.specifically discussed in Inspection Report 81-07.
Problems not identified by Bechtel supplier quality control personnel have resulted in major efforts both onsite and in Bechtel's San Francisco home office to either repair or justify the use of these items, e.g., ACME embeds. Licensee corrective actions have resulted in some improvement in this area, however, more improvement is required, c.
Conclusion Category 2 s.. v
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Site Preparation and Foundations a.
Cycle 1
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Work in this area was essentially complete.
b.
Cycle 2 (16 hrs., 2*.)
Work in this area was essentially complete excluding the service water intake structure.
Preliminary excavation with sheet pilings was underway. None of the excavation work is considered safety related until the Vincetown geologic formation is reached.
Safety related work is scheduled to start in November 1981.
c.
Conclusion No basis.
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3.
Containment Structures a.
Cycle 1 This functional area consisted of two functional areas in Cycle 1 -
Concrete and Steel Containment. Cycle 1 Concrete : analysis described three noncompliances, all were satisfactorily ri. solved.
Cyc's 1 Steel Containment and analysis explained that Unit 2 containtant i
erection had been temporarily suspended.
b.
Cycle 2 (221 hrs.,24%)
Concrete continued to be placed in substantial volumes in both units.
No items of noncompliance were identified.
One Construction Deficiency Report involved overpressurization of the closed volume i
under the Unit 2 drywell during a pumped concrete placement. This overpressurization resulted in deformation and subsequent replacement of a portion of the drywell shell. Perceptive planning, based on the unique conditions of this placement, could have prevented this overpressurization. A second Construction Deficiency Report involved vendor falsification of qualification records for a concrete epoxy surfacer used in Unit I safety related applications. As a result of 4
this issue the epoxy surfacer was removed from the concrete surfaces inside the Unit I drywell.
Initial PSAR commitments required separate test cycles for mechanical splices in horizontal, vertical, and diagonal rebar, for each bar size, and for each splicing crew.
However, subsequent internal licensee changes to the PSAR deleted the requirement for periodic i
testing of splicing crews.
As a result no periodic testing of splicing crews has been performed since the end of 1977. NRR review of this practice resulted in a letter to the licensee requiring testing of rebar splicers in accordance with initial PSAR l
commitments.- The licensee has taken issue with the NRR position and has not changed their testing requirements.
c.
Conclusion Category 2 y
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4.
Safety Related Structures a.
Cycle 1 The Cycle 1 analysis discussed a lack of understanding of the applicable construction code requirements that existed among a combination of construction, engineering design, and QC personnel. A problem involving poor performance of the upper and lower bioshield supplier was also reviewed.
b.
Cycle 2 (128 hrs.,4%)
Inspections in this area identified four items of noncompliance, three of which were part of Cycle 1.
Licensee activities included steel framing erection, installation and weldout of the lower and upper bioshield, erection of larga component supports, and installation of embedments in concrete.
The single noncompliance identified in Cycle 2 involved defective AWS D1.1 welds in embedments.
These same defective welds resulted in the licensee submitting a potential Construction Deficiency Report (CDR) because some of these embedments were embedded in concrete. The licensee submitted a second CDR involving inadequate design of bracket stiffener plates. A third CDR involving missing NDE records for the lower bioshield was submitted and subsequently withdrawn.
Better QC coverage has improved onsite work in this area since the Cycle 1 review.
c.
Conclusion Category 1 s
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5.
Piping and Hangers a.
Cycle 1 Ir.spection activities in this area included Unit I large bore piping.
Four items of noncompliance were identified all involving the same subcontractor.
A management conference was scheduled to discuss licensee performance. Three potential CDR's were reported.
b.
Cycle 2 (133 hrs.,15*;)
Inspection activities in this area included Unit 1 large bore piping and hangers and Unit 2 containment spray and safety relief valve piping and hangers.
The three items of noncompliance identified during Cycle 1.
An enforcement conference was held during Cycle 2 to discuss these noncompliances. The corrective action resulted in more emphasis on contractor and subcontractor surveillance inspection which has and should continue to strengthen the overall inspection program in all functional areas.
The storage and handling of large bore piping and hangers was found to be in accordance with the controlling procedures.
Sequence of installation was well managed, joint fitups were within tolerance, and welding was performed by qualified personnel using qualified procedures.
QC inspection during and after installation was 3
1 thorough.
Two of the three potential CDR's involved failure to perform required NDE and the third involved improper cold pull of piping. One of the potential CDR's was withdrawn during the assessment period.
c.
Conclusion Category 1 1
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l 6.
Safety Related Components a.
Cycle 1 The majority of safety related components were in controlled storage.
Two items of noncompliance were identified.
Two potential CDR's were reported.
Performance was graded average.
b.
Cycle 2 (181 hrs., 19%)
The majority of safety related components were in controlled storage.
The one major activity was setting the Unit I reactor pressure vessel which was well planned and executed. Many valves were removed from storage and installed in piping systems. Maintenance of equipment both in storage and in plant was effective. Handling of bulky and heavy equipment was controlled by written procedures and supervised by experienced personnel.
Four items of noncompliance were identified one of which was during Cycle 1.
The other three involved a poor quality welding prt.edure specification, failure to perfor;n radiography in accordance with an approved procedure, and failure to verify performance of several maintenance inspections. All the noncompliances were corrected in a timely and thorough manner.
c.
Conclusion Category 1
7.
Electrical (Equipment, Tray, Wire) a.
Cycle 1 Cycle 1 functional areas now included under this single area in Cych 2 included Electrical Equipment and Electrical (Tray and Wire). No
' electrical equipment inspections except one cable tray inspection was performed in Cycle 1.
b.
Cycle 2 (23 hrs., 2%)
Cable tray and conduit installation were in progress in Unit 1 only.
Some panels were set on their foundations in the power block but the majority of equipment remained in storage. Two inspections were made in this area with no items of noncompliance identified. Two potential CDR's were reported and one subsequently withdrawn. The remaining potential CDR involves Limitorque valve operator deficiencies.
c.
Conclusion Category 1 i
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Instrumentation and Wire a.
Cycle 1 No inspections were conducted in this area 20e to a lack of field activity.
b.
Cycle 2 (0 hrs., 0%)
No inspections conducted in this area due to a lack of field activity.
Procurement activities were in progress and some equipment was in storage.
c.
Conclusion No basis.
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Fire Protection a.
Cycle 1 No inspections were conducted in this area.
b.
Cycle 2 (0 hrs., 0*4)
The inspector, during routine tours of the facility, has observed that l-the licensee follows good housekeeping practices which minimizes the potential for fires.
Fire retardant wood is used in areas where required.
c.
. Conclusion No basis.
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10.
Preservice Inspection a.
Cycle 1 No inspections were conducted in this area.
b.
Cycle 2 (0 hrs.0's)
No inspections conducted.
c.
Conclusion No basis.
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- 11. Corrective Actions and Reporting a.
Cycle 1 The Cycle 1 review discussed a developing problem with licensee responses to items of noncompliance. 10 CFR 50.55(e) reporting was responsive.
b.
Cycle 2 (109 hrs.,12*4)
As part of an enforcement meeting, the subject of licensee responses to items of. noncompliance was discussed. The licensee lowered the threshold for 10 CFR 50.55(e) reporting resulting in a more responsive program. Corrective action was generally effective and timely. No j
items of noncompliance were identified during Cycle 2.
c.
Conclusion Category 1 i
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12.
Procurement a.
Cycle 1 This functional area was not evaluated as part of the Cycle 1 assessment.
b.
Cycle 2 (0 hrs.,0%)
Site procurement was very limited and no inspections were performed.
Storage of procured items was an area inspected with one item of noncompliance identified (discussed in paragraph 6).
c.
Conclusion No basis.
13.
Des'ign and Design Changes a.
Cycle l' This functional area was not evaluated as part of the Cycle 1 assessment.
b.
Cycle 2 (20 hrs. estimated, 2'4)
The original plant design efforts are conducted in San Francisco and no inspection of these activities was conducted. Design changes are initiated both at the site and at the home office. Inspections were made of onsite design change activities and included review of the change approval circuit, method of incorporation into as-built
. drawings, classification of design changes, and evaluation of these changes regarding seismic and environmental qualification.
No noncompliances were identif ied.
c.
Conclusion Category 1 L
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- 14. Training a.
Cycle 1 Training programs were in effect for various site personnel.
No enforcement items were issued.
b.
Cycle 2 (20 hrs. estimated, 2*J)
Training records for various site personnel, e.g., QC inspectors, 4
welders, and mechanical splicers were reviewed. A training session for new welders was attended by the resident inspector. Several items of noncompliance in other areas appeared related to inadequate training of personnel. Licensee corrective action was the retraining of those personnel. No items of noncompliance in this specific area were identified.
c.
Conclusion Category 1 r
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