ML20058G322
| ML20058G322 | |
| Person / Time | |
|---|---|
| Site: | Marble Hill |
| Issue date: | 03/17/1982 |
| From: | Shields S PSI ENERGY, INC. A/K/A PUBLIC SERVICE CO. OF INDIANA |
| To: | Hind J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20058G309 | List: |
| References | |
| NUDOCS 8208030282 | |
| Download: ML20058G322 (16) | |
Text
.
~.
7'7
./
I.
I f
i i,i PUBLIC SERVICE IbdE)l Skid /\\
March 17, 1982 S. W. Shields Senior Vice President -
Nuclear Division Mr. J. A. lif nd, Director Docket Nos.: STN 50-546 Division of Emergency Preparedness STN 50-547 and Operational Support Construction Permit Nos.:
Chairman, Region III SALP Board CPPR - 170 U. S. Nuclear Regulatory Commission CPPR - 171 Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Marble 11111 Nuc1 car Generating Station - Units 1 and 2
Dear Mr. Ilind:
This is in response to the Systematic Assessment of Licensee Performance (SALP) Report sent to Public Service Company of Indiana, Inc. (PSI) on March 2, 1982.
Mr. Menscer, merobr of my staff and I met with Region III and SALP Board personnel on March 10, 1982, at the Marble 11111 site to discuss the SALP report and the. conclusions contained in it.
The discussion was constructive and the meeting worthwhile.
We are in general agreement with the report, but wish to take exception to one specific and three general areas in the report.
I I
PSI's specific exception and major concern lies with the language used in the opening paragraph of Enclosure 1 to the SALP report.
That paragraph says that there remains a question regarding the ability of the restructured project management and Quality Assurance controls I
to adequately control the project during the return to " normal l
levels of construction." As you know, we have been performing Safety Category I construction for almost a year and now have a su site force of more than 3,000 personnel. We are at full construction in the civil / structural' area and are ramping up the piping / mechanical and electrical areas. PSI's performance to date should leave no j
doubts as to its ability to manage the project at elevated levels of construction; this view is strongly supported by language contained in both the SALP report and in the NRC's Inspection Report 81-18.
If the intent of the language in SALP Enclosure I was to note that the I
8208030282 820720 vi PDR ADOCK 03000546 A
PDR l
l P. O. Box 190. New Washington. Indiana 47162 812. 289.1000 i
L
1' e
7
.- c
[
p PUBUC SERVICE
)
Nr. J. A. Hind March 17, 1982 mRNANA J
NRC feels it necessary to maintain an increased level of surveillance-as Marble Hill moves more heavily into piping and electrical work,
.the Report should be so corrected.
The general exception which PSI takes is to the assignment of performance categories in the areas of " Containment and Other Safety-Related Structures," " Quality Assurance," and " Support Systems." As we understand the ranking criteria contained in the SALP report and in NRC Manual 0516, the SALP report and Inspection Report 81-18 do not contradict Category 1 rating in those areas noted above. The j
SALP Report notes:
"These (concrete placement) activities, as inspected, were properly controlled with evidence that emphasis was being placed on quality, producing an end product of high quality.
Any problems that were encountered were properly identified, in accordance with the established quality program, and dispositioned (corrective action taken, identified problems repaired, action to prevent recurrence taken, and actions properly documented)."
The Inspection Report 81-18 also notes:
"The program's further success is exemplified by the quality of work being accomplished in the construction areas. That is, quality awareness has become a vital w.,rk controlling element.
A good example of this is demonstrated in the concrete placed since the resumption of construction in the civil areas.
This concrete has been of high quality, free'of voids and unsound' material, with an excellent surface finish."
The SALP Report further states:
"The Region III staff notes that the cooperation, responsiveness-to NRC concerns, effectiveness, and attitude of the licensee's personnel and orgcnization meets or exceeds requirements, and are indicatire of a concerted effort toward quality... as evidenced by:... prompt resolution of differences, emphasis on training, massive restaffing with qualified individuals, planned management
\\
audits, additional audits by outside firms..."
Our exception with the area of " Support Systems" lies in the area of Housekeeping. While not addressed directly in NRC reports, it is our observation, based on personal experience with other projects, that Marble Hill is generally free of graffiti and above average in cicanliness and overall housekeeping.
e
~vii l-
9 1
PUBUC SERVICE REMANA Mr. J. A. Hind March 17, 1982 I would also like to make the point that the SALP report notes three items of non-compliance in the materials area after the evaluation period. PS1 does not minimize the importance of those items which were promptly and adequately addressed, but does believe that the many positive events which occurred in the same period should be given equal emphasis. Examples are the successful placement of several thousand cubic yards of Safety Category I concrete, as well as i
excellent results with the Concrete Evaluation and Repair Program.
I i
PSI does not contend that the 1cvel of inspection be reduced in the three areas cited above. PSI does contend that the SALP language should be in proper prespective with regard to project management and Quality Assurance controls and that proper due be given those areas where programs, personnel, qualifications and dedication have provided a product of very high quality.
This response is made in accordance with the provision noted within the SALP report. PS1 would appreciate your' consideration of the comments presented herein.
Sincerely,
//
S. W. Shields JUB/bak r
cc: Director of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.
20555 J. E. Konklin J. J. liarrison l
t-i i
viii
I.
INTRODUCTION The NRC has established a program for Systematic Assessment of Licensee Performance (SALP). The SALP is an integrated NRC Staff effort to collect available observations and data on a periodic basis and evaluate licensee performance based upon these observations and data.
SALP is supplemental to the normal regulatory processes used to ensure compliance to the rules and regulations.
SALP is intended to be sufficiently diagnostic to provide a rational basis:
(1) for allocating future NRC regulatory resources, and (2) for providing meaningful guidance to licensee management to promote quality and safety of plant construction and operation.
A NRC SALP Board composed of managers and inspectors who are know-ledgeable of Public Service of Indiana (PSI) activities at the Marble Hill Nuclear Generating Station met on February 12, 1982, to review the collection of performance observations and data and assess the performance of Public Service of Indiana (the licensee) in selected functional areas.
This SALP Report is the Board's assessment of licensee safety perform-ance at the Marble Hill Nuclear Generating Station during the period of July 1, 1980 to September 30, 1981. During this period construction activities were limited by the August 15, 1979, Confirmatory Order.
NRC inspection activities were accordingly focused upon evaluation of the restructuring of the PSI Quality Assurance Program and Management Controls of the project. The conditions of the order were gradually lifted in various areas of work as inspection results indicated that work would be of adequato quality. The Region III staff recommended lifting the order during the SALP period. The order was fully lifted in February of 1982.
The results of the SALP Board assessments in the selected functional areas were presented to the licensee at a meeting held on March 10, 1982.
l l
l l
l l
1
II.
CRITERIA The licensee performance is assessed in selected functional areas depending whether the facility is in a construction, pre-operational or operating phase. Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant. observation.
One or more of the following evaluation criteria were used to assess each functional area.
1.
Management involvement in assuring quality 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.
However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
Based upon the SALP Board assessment each functional area evaluated is classified into one of three performance categories. The definition of these performance categories is:
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 thct a high level of performance with respect to operational safety or construction is being achieved.
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 safety or construction is being achieved.
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 ef fectively used such that minimally satisfactory performance with respect to operational safety or construction is being t
achieved.
2
III.
SUMMARY
OF RESULTS Category 1 Category 2 Category 3 Functional Areas 1.
Soils and Foundations X
2.
Containment and other Safety-Related Structures X
3.
Piping Systems and Supports X
4.
Safety-Related Components X
5.
Support Systems X
6.
Electrical Power Supply and Distribution X
7.
Instrumentation and Control Systems Not evaluated 8.
Licensing Activities Not evaluated 9.
Quality Assurance X
l i
[
t 3
IV.
PERFORMANCE ANALYSES 1.
. Soils and Foundations a.
Analysis NRC examination of this functional area consisted of portions of one inspection to evaluate compliance with licensee committments in the Preliminary Safety Analysis Report, licensee and contractor manuals, standards and procedures. No items of noncompliance or deviations were identified.
Based upon the limited scope of ongoing soil activities in progress, performance appeared to be adequate.
b.
Conclusion The licensee is considered to be in performance Category 2.
c.
Board Recommendations It is recommended that careful attention be given to this area as activity increases.
2.
Containment and Other Safety-Related Structures a.
Analysis NRC examination of this functional area consisted of portions of twenty-two inspections to evaluate compliance with licensee committments in the Preliminary Safety Analysis Report, licensee and contractor manuals, standards and procedures.
No items of noncompliance or deviations were identified.
New concrete placement activities and concrete repair activities were initiated during April 1981. These activities, as inspected, were properly controlled with evidence that increased emphasis was being placed on quality, producing an end product of high quality. Any problems that were encountered were properly identified, in accordance with the established quality program, _and I
dispositioned (corrective action taken, identified problems repaired, action to prevent recurrence taken, and actions properly documented).
i b.
Conclusions The licensee is considered to be in performance Category 2.
Performance in this area is greatly improved since the previous SALP, as indicated by the resumption of work
activities, ad.quacy of controls, and high quality of civil construction.
In spite of the high quality of the work observed to date, additional observations are needed be' fore a Catagory 1 assignment could be made, c.
Board Recommentations The Board recognizes the improvements indicated by the results of inspections in th!s area.
It is also recognized that these results represent limited experience with the implementation of new management and quality assurance practices. Accordingly, an increased level of inspection in this area is recommended until full implementation can be demonstrated.
3.
Piping System and Supports and 4.
Safety Related Components a.
Analysis NRC examination of this functional area consisted of portions of eighteen inspections to evaluate compliance with licensee commitments in the Preliminary Safety Analysis Report, licensee and contractor manuals, standards and procedures. Three items of noncompliance were identified:
(1) Failure to follow procedures during the Construction and Materials Verification Program.
(50-546/80-23; 50-547/80-23)
(2) Failure to troat inert gas purge gauges as calibration equipment for equipment storage requirements.
(50-546/80-28; 50-547/80-28)
(3) Failure to take adequate Corrective Action related to the Material Verification Program.
(50-546/80-40; 50-547/80-40)
The above items of noncompliance were isolated cases involving the verification program and a minor storage problem.
Work activities in these areas that have been initiated since NRC auchorization to restart receipt inspection and construction activities have been adequate.
Activities inspected included receiving, receipt inspection, storage and maintenance, installation, and related Quality Assurance /
Quality Control Activities, b.
Conclusion The licensee is considered to be in performance Category 2.
Performance in this area is improved since the previous 5
~
g,
^
\\
q s
evaluatica period as evidenced by the lack of noncompliances since work activities resumed.
c.
Board Recommendations rhe Board. recommends continued increased Inspection ef fort 3
s
\\
in this arda' as described in the Board comments to Functional Area 2., " Containment and Other Safety Related Structures."
s 5.
Support Systems a.
Analysis NRC insp'ection of this functional area was consistent with nossal practice for the status of project completions and consisted of portions of twelve inspections to evaluate housekeeping practices and the fire protection program.
's No items of noncompliance or deviations were identified.
Performance appeared to be satisfactory with no specific
?
strengths or weaknesses identified.
3 b.
Conclusion
(
The licensee is considered to be in performance Category 2.
c.
Board Recommendations None.
6.
Electrical Power Supply and Distribution a.
Analysis s
t NRC examination of this functional area consisted of
,\\
portions of eighteen inspections to evaluate compliance 1'
with licensee commitments in the Preliminary Safety Analysis Report, licensee and contractor manuals, 4
standards and_ procedures. No items of nondempliance or deviations were identified.
Inspection activities during this period included procedure review, storage and maintenance activities, and,cabic tray hanger installation.
b.
Conclusion The licensee is considered to be in performance Cateogry 2.
l Installation activities in this area have been limited, and i
will increase as construction continues.
I c.
Bperd Reconmendations None.
I 6
1
4 1
7.
Instrumentation and Control Systems This functional area was not evaluated because there was no significant licensee activity.
8.
Licensing Activities 4
Licensing activities have been minimal as a result of the state of project completion, i.e.,
the construction permit stage is over and no significant operating licensing activity has begun. Accordingly, an evaluation in this I
area is not appropriate.
It should be noted, however, that the licensee has been cooperative and responsive.
l 9.
Quality Assurance Progra_m a.
Analysis NRC examination of this functional area consisted of portions of twelve inspections to evaluate overall program effectivo-nesss and compliance to commitments in the Preliminary Safety 4
Analysis Report, the Projecc Quality Assurance Manual, the
{
American Society of Mechanical Engineers (ASME) Quality Control Manual, and other standards and procedures. As a result of the August 15, 1979, Confirmatory Order the Region III staff conducted special evaluations of licensee changes to project management practices, and restructuring of PSI and contractor Quality Assurance programs and practices.
l The requirements of the order were lifted following acceptable results of inspections of controls for specific types of work g
affected:
PSI Receipt Inspection Activitics authorized 7/7/80.
{
Document Control System Review and Acceptance by NRC 10/80.
Receipt Inspection Activities authorized 11/13/80, for two contractors (Cherne and Commonwealth-Lord JV).
Construction Activities authorized 12/5/80 for two contractors (Cherne and Commonwealth-Lord JV).
Construction and Receipt Inspection Activities authorized for Newberg-Marble Hill, 3/27/81.
x Additionally, the fo11 ewing Quality Assurance program elements were inspected by the NRC:
Overall licensee program assessment for effectiveness, content, and implementation Overall contractors program assessment for effectiveness, content and implementation Corrective Action program Audit Program Construction and Materials Verification Program Design change control program Training Program ASME Survey 7
The qualification and training of personnel during this period was adequate. The document control systems were found to be adequate.
Management controls for the overall program were assessed as adequate. No items of noncompliance or deviations were identified.
NRC reports and inspection results indicate that success and effectiveness of the Quality Assurance Program has improved greatly, and that overall management control of the program is adequate.
The Region III Staff notes that the cooperation, respon-siveness to NRC concerns, effectiveness, and attitude of the licensee's personnel and organization meets or exceeds requirements, and are indicative of a concerted effort toward quality.
Licensee manage.nent has been fully suppor-tive of the Quality Assurance program, as evidenced by:
Involvement in meetings conducted on a routine and scheduled basis Prompt resolution of differences Emphasis on training Massive restaffing with qualified individuals Planned management audits Additional audits by outside firms Prompt action to correct and prevent the recurrence of audit findings b.
Conclusion The licensee is considered to be in performance Catagory 2.
Performance in this area has been vastly improved since last evaluated.
c.
Board Recommendations 1.
The Board recommends continued increased inspection effort in this area as described in the Board comments to Functional Area 2., " Containment and Other Safety Related Structures."
l 2.
Although not reported during the evaluation period the Board is concerned with the three items of noncompliance identified in Inspection Report No. 81-22 (inspection period November 16 through December 4, 1981), and the l
resulting management meeting conducted to discuss NRC l
concerns in regard to the overall effectiveness of the l
Material Control Program management.
In regard to the findings the Board emphasizes the importance of avoiding a breakdown of the controls in any area of the project.
Considering the 1979 Confirmatory Order, and the resultant 8
l w
g
-a
e focus upon the Marble 11111 Project, it is crucial that the implementation of the Quality Assurance Program in all areas be beyond question. An effective system of checks and balances, including your internal audit program, surveillances, a corrective action program, and other QA methods can prevent the breakdown of project controls and enhance the success of the project.
9
V.
SUPPORTING DATA AND SUS 1MARIES A.
Noncompliance Data Facility Name: Marble Hill Units:
1 and 2 Docket Nos. 546/547 Inspections No. 80-26 through No. 80-46 No. 81-01 through No. 81-18 Noncompliance and Deviations Severity Levels Categories Functional Areas I
II III IV V VI Viol.
Infr.
Def.
Dev.
- 1. Soils & Foundations
- 2. Containment & Other Safety-Related Structures
- 3. Piping System &
Supports
- 4. Safety Related Components (1)
(2)
- 5. Support System
- 6. Electrical Power Supply /Dist.
7.
Instrumentation &
Control System
- 8. Licensing Activities 9.
Quality Assurance TOTALS (1)
(2)
B.
Licensee Report Data 1.
Construction Deficiency Reports (CDRs) j A total of seventeen Construction Deficiency Reports (CDRs) were made by the licensee. The Region III inspection staff reviewed licensee actions on a total of 22 CDRs during the report period, including several which were submitted prior to this period.
The 22 included nine which were retracted, ten were a result of the Construction Materials Verification program, two were Westinghourse (NSSS) supplier generic problems, and one was a supplier (limatorque operator) generic problem.
A review of backup documentation revealed that reporting was timely and adequate, as were retractions.
10
e 2.
Part 21 Reports No 10 CFR 21 items were reported during this evaluation period.
C.
Licensee Activities For the majority of,this evaluation period, the licensee was performing work under August 15, 1979, Order Confirming the Suspension of Construction. This work was authorized through graduated rescission of the Order as specified in letters dated July 7, 1980 (authorization for PSI to resume receipt inspection activities); November 13, 1980 (authorization for two firms, Cherne and Commonwealth-Lord JV, to resume receipt inspection activities); December 5, 1980 (authorization for two firms, Cherne and Commonwealth-Lord JV, to resume construction activities with certain conditions being specified); and March 27, 1981 (author-ization for Newberg-Marble Ilill to resume receipt inspection and construction activities with certain conditions being specified).
Included in activities which were authorized are:
1.
Receipt, S$orage, llandling and Preservation of Material.
2.
Construction and Material Verification Program.
3.
Receipt inspection Activities.
4.
Construction Activities limited to the following:
Civil - Concreto, concrete repair, structural steel.
Mechanical - Limited installation of piping systems and supports.
Electrical - Limited to cable tray hangers installation.
D.
Inspection Activities The IE Inspection program during this evaluation period was based on the requirements and restrictions of the Confirmatory Order dated August 15, 1979, and the Conditions of the graduated rescission of the Confirmatory Order dated May 15, 1980, rather than the normal inspection program, llowever, during this evalua-tion period a total of thirty-nine inspections vere conducted on the Marble 11111 project.
Included in these inspections were three special inspections to evaluate the licensee's document control system and the overall quality assurance programs for two major project contractors, the results of which were satisfactory.
E.
Investigations and Allegations Review No investigations were conducted. The Regional staff received one allegation of improper waterproofing practices, nicked re-i Inforcing steel and the dismissal of the alleger who identified I
the problem to a contractor. The Region III staf f interviewed the alleger and site personnel involved, reviewed records and 11 l
~ - -. -.
.=
-. -.. ~ -_ =. _ - -.
=
i observed the actual plant area involved, and concluded that the allegations were unfounded.
F.
Escalated Enforcement Action 1.
Civil Penalties None.
2.
Orders A confirmatory order has been in place at Marble Hill since August 15, 1979.
3.
Immediate Action Letters (IALs) 4 None.
G.
Management Conferences The following Management meetings were conducted during this period:
4 October 7, 1980 - Region III Management-subjects, Program Status, i
Construction and Material Verification Program and ASME Survey.
j October 31, 1980 - Region III Management-same subject as October 7, 1981.
December 9, 1980 - Region III Management-subject, SALP I.
1 June 3, 1981 - Region III DRPI Section Chief-subject, NRC concerns with QA Program.
June 11, 1981 - Region III Deputy Director-subjects, Regulation, Enforcement, and Project Status.
September 9, 1981 - Region III Management-subjects, QA Program Overview, Cemmitments to the NRC, Examination of Project Man-agement Personnel pursuant to the Confirmatory Order.
H.
Other l
No significant trends were noted during this evaluation period.
l Observations At this time no observations or data are available to assess the over-
{
all effectiveness of the restructured project management and Quality Assurance controls. The observations which serve as the basis for the majority of this report resulted from inspections of select portions of normal site construction activities as work was sequentially mobilized following the imposition of the August 15, 1979, Confirmatory Order.
The need for continued aggressive licensee management attention to 12 1
quality and increased NRC inspection effort are indicated to assure i
that early positive results continue as the construction effort returns to its normal level.
13
,...