ML20050E243
| ML20050E243 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/01/1982 |
| From: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| Shared Package | |
| ML20050E242 | List: |
| References | |
| NUDOCS 8204130137 | |
| Download: ML20050E243 (10) | |
Text
.
co r tog Io UNITED STATES g
NUCLEAR REGULATORY COMMISSION y ), eq, g REGION IV
,; {y., _. j 611 RY AN PLAZA DRIVE, SulTE 1000 0,%, ' U,$g ARLINGTON TEXAS 76011 April 1,1982 In Reply Refer To:
Dockets: 50-445/81-20 50-446/81-20 Texas Utilities Generating Company ATTN:
R. J. Gary, Executive Vice President and General Manager 2001 Bryan Tower Dallas, Texas 75201 Gentlemen:
This refers to the Systematic Assessment of Licensee Performance (SALP) Board Report of the Comanche Peak Facility, Units 1 and 2, Construction Permits CPPR-126 and CPPR-127. The SALP Board met on September 1,1981, to evaluate the performance of tne subject facility for the period July 1,1980, through June 30, 1981. The performance analyses and resulting evaluation are documented in the enclosed SALP Board Report. These analyses and eval-uation were discussed with you at your office in Dallas, Texas, on October 9, 1981.
The performance of your facility was evaluated in the following functional Piping Systems and Supports; Safety-Related Components; Support Systems; areas:
Electrical Power Supply and Distribution; Instrumentation and Control Systems; and Licensing Activities.
The SALP Board evaluation process consists of categorizing perfonnance in each functional area. The categories which we have used to evaluate the performance of your facility are defined in Section II of the enclosed SALP Board Report.
As you are aware, the NRC has changed the policy for the conduct of the SALP program based on our experiences and the recently implemented reorganization which emphasizes the regionalization of the NRC staff. This report is the product of the revised policy.
Any comments which you may have concerning our evaluation of the performance of your facility should be submitted to this office within 20 days of the date of this letter. Your connents, if any, and the SALP Board Report, will both appear as enclosures to the Region IV Administrator's letter which issues _
the SALP Report as an NRC Report.
In addition to the issuance of the report, this letter will, if appropriate, state the NRC position on matters relating to the status of your safety program.
8204130137 820409 PDR ADOCK 05000445 G
f Texas Utilities Generating Company April 1,1982 Comments which you may submit at your option, are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this letter, we will be glad to discuss them with you.
Sincerely,
)$$lu&
'G. L. Madsen, Chief Reactor Project Branch 1 (SALP Board Chairman)
Enclosure:
Appendix - NRC Report 50-445/81-20 50-446/81-20 cc:
Texas Utilities Generating Company ATTN:
H. C. Schmidt, Project Manager 2001 Bryan Tower Dallas, Texas 75201 l
O e
APPENDIX U. S. NUCLEAR REGULATORY COMMISSION REGION IV SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Report:
50-445/81-20 50-446/81-20 Dockets: 50-445 & 50-446 Category A2 Licensee:
Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201 Facility Name: Comanche Peak, Units 1 and 2 Appraisal Period:
July 1, 1980, to June 30, 1981 Appraisal Completion Date:
September 1,1981 Licensee Meeting:
October 9, 1981 SALP Board:
G. L. Madsen, Chief, Reactor Project Branch 1 W. A. Crossman, Chief, Reactor Project Section B S. B. Burwell, NRR Project Manager R. G. Taylor, Senior Resident Inspector R. C. Stewart, Reactor Inspector Reviewed By:
37/8L W. A. Crossman, Chief, Reactor Project Section B
~ Date
/
6 MW f L Approved By:
t
'G.L. tiadsen, Chief, Reactor Project Branch 1 Date (SALP Board Chairmian)
1
)
I i
i l
I.
Introduction i
Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect available observations and data on an annual i
basis and evaluate licensee perfomance utilizing these data and observations as a basis.
The integrated systematic assessment is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to licensee management.
{
II. Criteria i
The assessment of licensee perfomance is implemented through the use of seven evaluation criteria. These criteria are applied to each functional area that is applicable to the facility activities (construction, pre-operation or operation) for the categorization of licensee performance in these areas.
One or more of the following evaluation criteria are used to assess each applicable functional area.
1.
Management involvement in assuring quality i
2.
Approach to resolution of technical issues from safety standpoint i
3.
Responsiveness to NRC initiatives 4.
Enforcement history
)
5.
Reporting and analysis of reportable events 6.
Staffing (including management) 3 7.
Training effectiveness and qualification Attributes associated with the above evaluation criteria fom the guidance for the SALP Board for categorization of each functional area in one of three categories.
Performance categories are defined as follows:
j Category 1.
A combination of attributes which demonstrates achievement of superior safety performance; i.e., 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 perfor-mance with respect to operational safety or construction is being achieved.
Reduced NRC attention may be appropriate.
Category 2.
A combination of attributes which demonstrates achievement of satisfactory safety perfomance; 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 safety or construction is being achieved.
NRC attention should be maintained at normal levels.
Category 3.
A combination of attributes which demonstrates achievement of only minimally satisfactory safety performance; licensee management i
attention or involvement is acceptable and considers nuclear safety, but 2
1
i 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.
Both NRC and licensee attention should be increased.
III. Summary of Results Functional Areas Category 1.
Soils and Foundations NA 2.
Containment and other NA Safety-Related Structures 3.
Piping Systems and Supports 1
4.
Safety-Related Components 1
5.
Support Systems 2
6.
Electrical Power Supply and Distribution 1
7.
Instrumentation and Control Systems 1
8.
Licensing Activities 2
IV.
Performance Analyses The SALP Board obtained assessment data applicable to the appraisal period of July 1, 1980, to June 30, 1981.
The data for the Comanche Peak Steam Electric Station (CPSES) was tabulated and analyzed and a performance analysis was developed for each of six functional areas.
The SALP Board met on September 1, 1981, to review the performance analyses and supporting data and develop the SALP Board Report.
Functional Area Analysis 1.
Soils and Foundations All activities completed.
j 2.
Containment and Other Safety-Related Structures Very limited activities during assessment period.
]
]
3.
Piping Systems and Supports l
l Three violations issued to the licensee in the review period were concerned with malfunction in this general area.
Two of three involved vendor furnished support / restraint components.
The first 3
e l
+
was based on an allegation to the effect that a group of moment restraints could not have been properly examined in the vendor's facility by the vendor.
Our examination at the site substantiated the allegation and the components were sent back to the vendor
\\
for rework and reinspection.
The second was by the same vendor regarding a group of seismic restraints that did not receive full penetration welding as specified.
These components were reworked onsite by the vendor to satisfy the engineering criteria.
Both instances, which occurred within an approximate 2-month period, indicated problems in the vendor component inspection program which have been rectified.
The thir involved a finding that due to the removal of temporary i
- supports,
.ctain piping and in-line components were in effect un-supported.
The licensee reponded to the noncompliance by installing so called 'hard supports' of a temporary nature until such time as the permanent supports are installed.
Hard supports are supports that are difficult to remove inadvertently by being bolted to the building, the pipe, or both.
The licensee / contractor ASME Code based installation and quality control program is relatively simple, straightforward and is generally well implemented.
The major weakness has been, and to a degree continues to be, an inability to hire /or retain the services of competent (as distinguished from Code qualification) pipe welders.
The licensee has responded to this problem by radiographing certain welds in some essential piping systems that he is not required to radiograph under the Code or NRC regulations.
He also has a relatively strong welder training program aimed at improving the competence of the welders he hires.
The licensee's management controls have been demonstrated to be effective in this area and are assigned to Category 1.
4.
Safety-Related Comoonents, including Vessels, Internals, and Pumas During the appraisal period, the major activity in this area was the maintenance and preservation of installed, nonoperational components.
Limited work was also accomplished on the Unit 1 Reactor Vessel Internals.
The maintenance and preservation activities in all ar.eas have been diligently pursued by a group of construction and quality personnel 1pecifically assigned to the activity controlled by central di.ipatchers and easy-to-follow procedures.
NRC inspections in this area have revealed no substantive problems.
No NRC inspections were made of installation work on the vessel internals during the period due to the limited work involved.
The licensee's management controls have been demonstrated to be effective in this area and are assigned to the Category 1 level.
i 4
5.
Support Systems including HVAC, Radwaste and Fire Protection The licensee's application of suppert systems, other than those involving concrete or piping systems (areas 2 and 3 above), are essentially limited to HVAC, radwaste, and the fire protection system.
During the appraisal period, NRC inspections were directed toward review of the licensee's audit program for u nitoring the subcontractors installing HVAC and fire protection systems.
The subcontractor programs had been evaluated in an early appraisal period and found adequate for the work involved.
The licensee's audit program was also found to be effective in monitoring these activities.
Supports for the radwasta piping system are included with the licensee's Class 5 support program which has been evaluated as it relates to other Class efforts and found to be effective.
The licensee's management controls in this area cre considered to be at the Category 2 level.
6.
Electrical Power Supoly and Distribution The NRC inspections in this functional area have not identified any substantive problems.
The licensee procedures for installation and quality control are relatively simple and straightforward.
The licensee currently has a competent force of adequately trained and motivated personnel to carry out the procedural requirements.
Performance analysis in this area is determined to be Category 1.
7.
Instrumentation and Control Systems Although much effort has been expended in this area by the licensee's labor force, relatively few instruments are fully installed.
The licensee's program for installation and quality control in this area is simple, straightforward, and effective.
The assigned personnel appear to have been adequately trained and competent to carry out their assigned responsibilities.
NRC inspections have not identified any substantive problems in this functional area during the appraisal period.
Assessment of the licensee's attributes in this area revealed a Category 1 level.
8.
LicensinhActivities The applicant's ability to respond on schedule is slower than
]
average.
In the work leading to the issuance of the SER, the applicant was not able to perform at a rate necessary to meet schedule demands.
(Granted, these schedule demands were heavy due to the shortened schedule.)
In overall quality of work sub-mitted, the applicant has performed slightly better than average i
l over this appraisal period.
The applicant is well supported by I
5
o Westinghouse and Gibbs & Hill.
The principal need for improvement is in an increased participation in the licensing process by the station operations staff.
We expect this to improve as the station approaches fuel loading.
Application of evaluation criteria in this area resulted in a Category 2 level.
Conclusion The SALP Board concluded that the licensee has demonstrated an overall combination of attributes exhibiting Category 1 performance during the appraisal period.
This evaluation was based upon the three primary areas where the construction efforts, and, therefore, the NRC inspection effort, were directed; i.e., piping, electrical, and instrumentation installations.
The Board noted that 1069 of the 1699 inspection-hours were devoted to these three basic areas.
In regard to the licensee's ongoing interactions with NRR, the consensus of the Board was that the licensee has managed these activities in a Category 2 mode.
Board Recommendations Although the SALP Board concluded that the overall licensee performance was Category 1, they did not recommend to the regional office that the inspection level for construction be changed.
Programmatic changes for construction inspection have been made that will effectively reduce inspection activities for all construction sites.
V.
Supoorting Data and Summaries 1.
Reoort Data a.
LER Numbers Reviewed (Not applicable) b.
Construction Deficiency Reports The licensee formally reported seven Significant Construction Deficiencies that he or his agents had identified during the appraisal period.
These are summarized as follows:
(1)
Engineering failure to consider the thickness of architec-l tural concrete on floors when specifying the embedment depth of anchor bolts.
6
(2) Vendor error in not furnishing supports for piping and
]
components on the Emergency Diesel Generator packages in
- accordance with the ASME Code.
(3) Concrete anchor bolts being shortened by the craft labor force prior to installation.
(4) Vendor identified problem with the closing time of certain motor operated valves when working against design pressure (Part 21).
(5) Engineer failure to provide adequate air conditioning to rooms housing the vital AC power supply inverters (Part 21).
(6) Failure of HVAC supplier engineer to stipulate embedment lengths of concrete anchor bolts used on supports for ducts and other components.
(7) Failure of subcontracted engineer to consider SSE loads in design of instrument tubing support devices.
c.
Part 21 Reports The licensee did not file any Part 21 reports himself, but rather filed certain 50.55(e) reports in response to vendor Part 21 reports as noted above.
2.
Licensee Activities There were no especially significant licensee events during the appraisal period from a regulatory standpoint.
Most construction work proceeded on a routine basis during the period.
3.
Inspection Activities There were no special team inspections performed during the appraisal period.
Region IV performed 12 routine inspections related to imple-mentation of the "B" level inspection program involving 498 inspector-hours.
The Senior Resident Inspector expended an additional 963 inspector-hours over the period performing the "C" program.
An additional 238 hours0.00275 days <br />0.0661 hours <br />3.935185e-4 weeks <br />9.0559e-5 months <br /> were expended performing the investigations noted below.
4.
Investiaations and Allegations Review Three separate investigations were performed during the appraisal period, each based on allegations received by Region IV personnel.
These are summarized below:
7
a.
Allegation that anchor bolts pull out of the wall; that there are hollows in certain concrete walls; and that a motor control center was not properly grounded.
The investigation could not establish that anchor bolts pulled out after being tightened to specified values but frequently did during the tightening process, which was expected.
The walls with hollow sounds based on tapping were located and excavated with no anomalies being identified by the SRI who observed most of the excavation process.
No explanation was developed by the licensee or the SRI for the occurrence.
The proper grounding of the motor control center was verified to have occurred as a part of the normal prc::ess of energizing the unit.
The allegations were thus partially substantiated but proved to have no technical merit from a safety standpoint.
b.
An investigation was conducted regarding an allegation made by a licensee / contractor employee who was engaged in vendor inspections and audits that the licensee was knowingly allowing the shipment of vendor components identified as being of sub-standard quality.
The investigation revealed that the components were in fact substandard and were the subject of a Notice of Violation which was discussed in IV.3 above.
The balance of the allegation was not substantiated, partly because the alleger himself maintained a low profile and used an improper document to identify the original quality problem so that the licensee /
contractor quality managers were apparently unaware of the substandard condition.
c.
An investigation was made regarding an allegation that the electrical QC section was supervised by personnel overly sympathetic to construction problems; were not conducting required inspections; and were using many unqualified personnel when performing other inspections.
The allegation also inferred that construction welding engineering was deliberately impeding the orderly review of documentation packages for safety class pipe hangers.
Based on an extensive number of interviews, reviews of records, and observations, the investigation con-cluded that the allegations were essentially without merit.
5.
Escalated Enforcement Action None 6.
Management Conference Held During Appraisal Period No management conferences were held with the licensee during the period, except as required by the SALP Program.
S
_ _