ML20058D075
| ML20058D075 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/20/1982 |
| From: | Madsen G Office of Nuclear Reactor Regulation |
| To: | Aswell D LOUISIANA POWER & LIGHT CO. |
| Shared Package | |
| ML20058D052 | List: |
| References | |
| NUDOCS 8207270022 | |
| Download: ML20058D075 (14) | |
Text
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In Reply Refer To:
l'N I932 Docket:
50-382/Rpt. 81-32 Louisiana Power and Light Company ATTN:
Mr. D. L. Aswell Vice President Power Production 142 Delaronde Street New Orleans, Louisiana 70174 Gentlemen:
This refers to the Systematic Assessment of Licensee Performance (SALP)
Board Report of the Waterford Facility, Unit 3, Construction Permit CPPR-103.
The SALP Board met on September 24, 1981, to evaluate the performance of the 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 evaluation were discussed with you at your office in New Orleans, Louisiana, on October 30, 1981.
The performance of your facility was evaluated in the following functional areas:
Piping Systems and Supports; Safety-Related Components; Support Systems; Electrical Power Supply and Distribution; Instrumentation and Control Systems; and Lic'ensing Activities.
The SALP Board evaluation process consists of categorizing performance 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 consistent with the revised pol ky.
Any comments which you may have concerning our evaluation of the performance l
of your facility should be submitted to this office within 20 days of the date of this letter.
Your comments, 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.
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RPS-Bfa RPB1 DRRP DRA RA/ IV f
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8207270022 820701 PDR ADOCK 05000382 A
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Louisiana Power and Light 2
Company 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 1
discuss them with you.
Singey,g]y,,noany, g,e,MADsEW8 G. L. Madsen, Chief Reactor Project Branch 1 (SALP Board Chairman)
Enclosure:
Appendix - NRC Report 50-382/81-32 cc:
Louisiana Power and Light Company Waterford-3 ATTN:
D. B. Lester, Plant Manager P. O. Box B - Killona Taft, LA 70066 Louisiana Power and Light Company ATTN:
F. J. Drummond, Project Support Manager 142 Delaronde Street New Orleans, LA 70174 Mr. T. F. Gerrets, QA Manager (same address) bcc distrib. by RIV:
W. Crossman G. Constable J. Cummins W. Seidel S. Black R. Stewart TPB RPB2 INFO SYSTEMS J. Collins RIV File C. Wisner
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APPENDIX
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U.S. NUCLEAR REGULATORY COMMISSION j.
REGION AV
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE,e t ', '
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Report:
50-382/81-32
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Dockets:
50-382 Category A2
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i Licensee:
Louisiana Power and Light Company i
142 Delaronde Street
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New Orleans, Louisiana 70174 Facility Naine: Waterford, Unit 3 e
Appraisal Period: July 1, 1980, to June 30, 1981
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i Appraisal Completion Date:
September. 24,1981 i
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October.30, 1981 i
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G. L. Madsen, C4f e'f, Reactor [Woject Branch J, f W. C. Seidle, Chitf, Reactor {froject. Branch 2 '
W. A. Crossmaa, Chief, Reactor Project Section B c
S. C. Black,- NRR Project Manager
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G. L. Constable, Senior Resident Inspector R.
C.' Stewart, Reactor Inspector
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[Mg-6~!/2 W. A. Crossman, Chief, Reactor Project Section B Date 1
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Approved By:
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G. L. Madsen, Chier, Reactor Project Branch 1[',/ Date,
(SALP Board Chairman) i e '
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2 I.
Introduction Systematic Assessment of Licensee Performance (SALP) is an integrated
- NRC staff effort to collect available observations and data on an annual basis and evaluate licensee performance utilizing these data and i
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 The assessment of licensee performance 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 s
applicable functional area.
1.
Management involvement in assuring quality c' i 2.
Approach to resolution of technical issues from 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 i).'
Attributes associated with the above evaluation criteria form the guidance for the SALP Board for categorization of each functional area in one of three categories.
Performance categories are defined as follows:
~1 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 performance with respect to operational safety or construction is being achieved.
Reduced NRC attention may be appropriate.
Category 2.
A combination of attributes which demonstratss
'evement of satisfactory safety performance; i.e., licensee management a tr.cion and L+
involvement are evident and are concerned with nuclear safety; licensee l'
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 mimically satisfactory safety performance; i.e., licensee manage-ment attention or involvement acceptable and considers nuclear safety, but
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3 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 (Construction)
Category 1.
Soil and Foundations NA 2.
Containment and other Safety-Related Structures 1
3.
Piping Systems and Supports 2
4.
Safety-Related Components 2
5.
Support Systems NA 6.
Electrical Power Supply and Distribution 2
7.
Instrumentation and Control Systems 2
8.
Licensing Activities 3
9.
Corrective Actions and Reporting 1
Functional Areas (Preoperational) l l
1.
Plant Operations Preparation 3
2.
Security & Safeguards 2
3.
Surveillance & Preoperational Testing 2
4.
Audits, Review & Committee Activities 3
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 Waterford Steam Electric Station (WSES) was tabulated and analyzed and a per-formance analysis was developed for each of seven functional areas.
The SALP Board met on September 24, 1981, to review the performance analyses and supporting data and to develop the SALP Board Report.
4 1.
Functional Area Analysis (Construction) a.
Soils and Foundations Work in this functional area has been completed and no assessment was made by the Board.
b.
Containment and Other Safety-Related Structures The functional area of containment is essentially complete with the exception of the dome and equipment handling hatch. Work completed during the appraisal period did not result in any violations and was concluded to be of exceptional quality based on 48 inspector-hours for the period.
Work activities in this functional area of other safety-related structures was minimal during the appraisal period.
No construc-tion deficiencies were identified, nor did any enforcement action result from inspection effort by the NRC.
The Board assessed the licensee's performance to be Category 1 in this functional area.
c.
Piping Systems and Supports Significant construction piping installation activities were a major portion of site construction during the appraisal period and, consequently, a significant portion of the expended onsite NRC inspector-hours.
Two of the three items of noncompliance were identified in this functional area.
However, they were not of a substantive nature to reflect a matter of concern.
The Board assessed the licensee's performance to be Category 2 in this functional area, d.
Safety-Related Components, Including Vessels, Internals, and Pumps One deviation was identified in this functional area - care and maintenance of containment penetrations.
Six construction deficiencies were identified during this appraisal period.
Three previously identified construction deficiencies were closed out.
5 Nuclear Installation Services Company (NISCO) recommended work on reactor vessel internals after an LP&L Stop Work Order and an NRC Immediate Action Letter were issued on May 9, 1980.
The Board assessed the licensee's performance to be Category 2 in this functional area.
e.
Support Systems, Including Radwaste and Fire Protection The activities accomplished during this appraisal period have been incorporated into the other functional areas.
Therefore, this area will not be categorized separately, f.
Electrical Power Supply and Distribution The licensee recognized a significant construction schedule slippage early on during this appraisal period and an accelerated construction installation program for cable installation and termination was initiated.
Despite accelerated work activity, the licensee continued to demonstrate a positive QA/QC management control over the work activity. There were no items of noncompliance identified in this functional area.
The Board assessed the licensee's performance to be Category 2 in this functional area.
g.
Instrumentation and Control Systems A major portion of the overall NRC onsite inspector-hours were expended in this functional area.
One item of noncompliance was cited in this area.
The item was related to a lack of protective taping of open-ended valves and tubing ends during installation.
This matter was promptly corrected by the licensee.
The Board assessed the licensee's performance to be Category 2 in this functional area.
h.
Licensing Activities The licensee is very cooperative in furthering the licensing review process.
Their responses to requests for information are generally of good quality and usually timely. They are cooperative in arranging meetings, which are well organized and very productive.
They are willing to compromise rather than allow issues to remain in controversy for long periods of time.
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6 The licensee relies heavily on consultants, which is not unusual for a small utility with no previous nuclear experience.
However, NRR reviewers have remarked that the licensee has very little working knowledge of plant systems.
This, in part, is a symptom of the shortfall in staffing the plant.
Corporate management has been found to be lacking in nuclear experience and in its recognition and response to staffing and management problems.
The state of staffing, as far as numbers of vacant positions as well as the lack of commercial nuclear experience of the present staff, has led NRR to reserve judg-ment regarding LP&L's qualifications.
The highest levels of utility management have become cognizant of the problem and have committed to do anything necessary to solve this problem.
The Board assessed the licensee's performance to be Category 3 in this functional area.
i.
Corrective Actions and Reporting There were 112 inspector-hours expended by the NRC inspectors in this functional area.
There were no items of noncompliance or deviations identified which is indicative of a generally positive QA management control in corrective actions and reporting.
The Board assessed the licensee's performance to be Category 1 in this functional area.
2.
Functional Area Analysis (Preoperational) a.
Plant Operations Preparation Beginning with the first preoperational inspection conducted by NRC's Office of Inspection and Enforcement (79-15, dated l
October 25, 1979), weaknesses in the licensee's preparation for operation have been identified to LP&L management.
The details of the weaknesses were forwarded by IE to NRR and are included as open items in the SER.
The Resident Inspector has spent approximately 118 hours0.00137 days <br />0.0328 hours <br />1.951058e-4 weeks <br />4.4899e-5 months <br /> inspecting this area.
No l
noncompliance was identified in this area due to the early stage of development.
a
7 Major areas of concern are:
a lack of nuclear utility experience of the permanent staff; turnover problems; difficulties in hiring; and the excessive use of contractors resulting in little involvement of the permanent plant staff in the preparation of plant procedures or the conduct of preopera-tional tests.
Each of the identified weaknesses have been discussed extensively with the licensee in various formal and informal meetings.
To date, the licensee has had great difficulty in resolving these problem areas.
The Board assessed the licensee's perforsence to be Category 3 in this functional area.
b.
Security and Safeguards Waterford-3 security is not in place.
The physical security plan is now in second revision and a final revision is expected by late 1981 or early 1982. A review of the security plan was made in June 1981 by IE, NRR, and NMSS personnel.
The Board assessed the licensee's performance to be Category 2 in this functional area.
c.
Preeperational Testing The NRC inspector has conducted periodic reviews of the licensee's preparation for preoperational testing. This 4
involved 332 manhours of inspection effort.
No violations or deviations were reported during the evaluation period.
In general, the licensee's startup group is well organized with an experienced staff consisting primarily of consultants.
The startup organization has been hurt by turnover and does not interface well with the operating organization.
This appears to be related to the overall organization and training problems identified in Section IV.2.a (Plant Operations Preparation).
The licensee has begun one preoperational test with none completed.
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Principal effort thus far has been procedure development, planning, and scheduling.
The Board assessed the licensee's performance to be Category 2 in this functional area.
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8 d.
Audits, Reviews and Committee Activities The licensee's Plant Operations Review Committee (PORC) was established February 1, 1980.
Meetings to date have principally involved the review of plant operating procedures and system integrated test (SIT) procedures.
The onsite QA organization for operations /startup has not been established. An onsite operations QC group is functioning presently without the benefit of operational experience.
The licensee has had considerable difficulty coordinating document control and procedure development activities between the operating organization and the startup group.
These difficulties appear to be related to the lack of preoperational overview by the QA/QC organization and to an initial lack of appreciation by the PORC committee of the depth of their over-all responsibilities.
The inspector conducted 13 manhours of inspection during this evaluation period.
No items of noncompliance were identified to the licensee during this period.
The Board assessed the licensee's performance to be Category 3 in this functional area.
3.
Conclusion The SALP Board concluded that, notwithstanding the Category 2 rating in the construction functional areas, the following summaries of the negative characteristics substantiate an overall rating of Category 3.
Two of the three areas evaluated in the preoperational functions, preparation for operation and review, and audit activities, were rated Category 3.
The third area, preoperational testing, was rated Category 2.
Preparation for operation was rated Category 3 principally because of a lack of nuclear utility experience, staff turnover problems, and insufficient involvement of permanent plant l
staff in turnover problems, and insufficient involvement of permanent plant staff in the preparation of plant operating and l
testing procedures.
Review and audit activities were rated Category 3 due to a lack of onsite preoperational QA function and l
difficulties in implementing an effective document control program capable of adequately supporting plant activities.
Pre-operational testing was rated Category 2 based on a perceived
9 problem of interfacing and coordinating activities with the operating organization.
It was noted that the startup group's activities were well planned and organized and were being implemented by an experienced staff of consultants.
In the functional area of licensing review, the licensee has been cooperative in licensing activities during the review period.
However, we feel that their management and staffing problems require a Category 3 rating.
The fact that their staffing fell so far behind that it will take an enormous effort to recover in time for fuel loading in October 1982 shows a lack of management attention which reflects poorly on management capabilities.
4.
Board Recommendations The SALP Board concluded that augmented inspections should be maintained throughout the preoperational testing phase or until the licensee demonstrates improvement in control in this area.
Construction inspection will be completed utilizing an extended program already in place.
V.
Supporting Data and Summaries 1.
Report Data a.
LER Number Reviewed:
NA b.
Construction Deficiency Reports The licensee reported 15 during the appraisal period:
6/10/80 Base Metal Defects in Main Steam &
Feedwater Containment Penetration Anchors 8/1/80 Flex Liquid Tight Conduit Covering Failure 11/12/80 Target Rock Motor Op. Valves Bushing not Staked 11/25/80 Linear Indication in Electrical Cable Tray Seismic Support Clips 11/26/80 CEDM Lower Pressure Housing NDT Require-ment (CE Correction) l
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12/5/80 Inadequate Design Review of Instrumentation Seismic Support Drawings 2/6/81 Inadequate Electrical Insulation on Ex-Core Neutron Flux Detectors 2/18/81 Defective Valve Actuators (Fisher Controls) 2/20/81 Defective Valve Manual Operators (Fisher Controls) 2/20/81 Defective GE Circuit Breakers (AKR-30 & AKR-50) 3/13/81 Switchgear Breaker Position Switch Operator Defective 3/80/81 Feedwater Isolation Valves - Temperature Maintenance of Actuators (Anchor-Darling) 4/15/81 2" and Under Schedule 160 Socket Welds (Fillets under size) 4/28/81 Inadequate Clearance on Piping - Box Hanger Supports 4
6/11/81 Change out ASTM A193 Stainless Steel Bolts on Motor Control Center Bus Bars j
c.
Part 21 Reports The licensee identified one Part 21 report during the appraisal period.
This item is related to covering failure on liquid tight flexible conduit.
2.
Licensee Activities There were no significant licensee events during the appraisal period.
3.
Inspection Activities Region IV conducted 21 routine inspections related to the implementation of the "B" inspection program involving 733 inspector-hours.
The Senior Resident Inspector expended an additional 749 inspector-hours over the period performing preoperational and operational-type inspection activities.
An additional 85 inspector-hours were expended performing the investigations noted below.
11 4.
Investigations and Allegations Review Three separate investigations were performed during the appraisal period.
These matters are summarized as follows:
a.
Allegation by a former employee concerning five possible construction deficiencies noted by him while employed by Ebasco subcontractor.
The five allegations were either not substantiated or were partially substantiated, but were not detrimental to plant construction.
b.
Allegation by an onsite employee regarding six possible construction deficiencies noted by him while employed by an Ebasco subcontractor.
Of the six allegations investigated, two could not be sub-stantiated, and four were substantiated but were not safety-significant.
c.
Investigation of potential safety concern related to the arrest of eight onsite construction workers for drug-related criminal conduct.
Of the eight workmen arrested, only one, a welder, had been involved in safety-related work.
The investigation established that the limited safety-related work performed by the welder was of quality work and that no substandard safety-related work was performed by the arrested welder.
5.
Escalated Enforcement Action None.
i 6.
Management Conferences Held During Appraisal Period l
No management conferences were held with the licensee during the period, except as required by the SALP Program.
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