ML20141E789

SALP Rept 50-354/85-99 for Nov 1984 - Dec 1985

ML20141E789
Person / Time
Site:	Hope Creek
Issue date:	02/19/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20141E777	List: IR 05000354/1985099 ML20141E771 ML20141E789
References
50-354-85-99, NUDOCS 8602250376
Download: ML20141E789 (44)

See also: IR 05000354/1985099

Text

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U.S. NUCLEAR REGULATORY COMMISSION

l REGION I

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

j. INSPECTION REPORT NO. 50-354/85-99

l PUBLIC SERVICE ELECTRIC AND GAS CORPORATION

HOPE CREEK GENERATING STATION

ASSESSMENT PERIOD: NOVEMBER 1, 1984 TO OCTOBER 31,~1985

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BOARD MEETING DATE: JANUARY 16, 1986

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TABLE OF CONTENTS

Page

I. Introduction . . ... ...... .............. 1

A. Purpose and Overview .................. 1

B. SALP Board Members ...... ............. 1

C. Background ... ...... .............. 1

II. CRITERIA . . . . . . . . . . ...... ......... 3

III. SUMMARY OF RESULTS . . . . . . . . . . . . . . . . . . . . . . 5

A. Overall Facility Evaluation . .............. 5

B. Facility Performance .................. 6

IV PERFORMANCE ANALYSIS . ...... ............. 7

A. Construction Activities . . . .............. 7

B. Electrical and I&C Construction . . ........... 11

C. Quality Assurance . . . . . . . . . . . . . . . . . . . . 14

D. Preoperational Testing. . . . . . . . . . . . . . . . . . 16

E. Operational Readiness . . . . . . ............ 19

F. Maintenance . . . . ....... ............ 22

G. Radiological Controls . .. .............. 25

H. Security and Safeguards . . ............... 28

I. Emergency Preparedness. . . . . ............. 30

J. Licensing Activities .................. 32

V. SUPPORTING DATA ................ ....... 34

A. Construction Deficiency Reports . . . . . . . . . . . . . 34

B. Investigation Activities. . . .............. 34

C. Escalated Enforcement . . .. ...... .... 34

D. Management Conferences ................. 34

TABLES

Table 1 Inspection Hours Summary. .............. 35

Table 2 Inspection Report Activities. . ........... 36

Table 3 Enforcement Data ..... ............ 40 .

Table 4 Tabular Listing of Construction Deficiency Reports . 42

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I. Introduction

A. Purpose and Overview

The Systematic Assessment'of Licensee Performance (SALP) is an inte-

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grated NRC staff effort to collect available observations and data on

a periodic basis, and to evaluate licensee performance based upon

this informhtion. SALP is supplemental to normal regulatory process-

es used to ensure compliance with NRC rules and' regulations. It is

intended to be sufficiently diagnostic to provide a rational basis

for allocating NRC resources, and to provide meaningful guidance to

licensee management to promote quality and safety of plant operation.

An NRC SALP Board, composed of the staff members listed below, met on

January 16, 1986 to review the collection of performance observations

and data to assess the licensee performance in accordance with the

guidance in NRC Manual Chapter 0516, " Systematic Assessment of

Licensee Performance." A summary of the guidance and evaluation cri-

l teria is provided in Section II of this report.

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This report is the SALP Board's assessment of the licensee's safety

performance at Hope Creek Generating Station for the period November

1, 1984 through October 31, 1985.

B. SAlp Board

Chairman:

R. W. Starostecki, Director, Division of Reactor Projects (DRP)

Members:

' H. Kister, Chief, Projects Branch No. 1, DRP  !

L. Bettenhausen, Chief, Operations Branch, DRS

R. Bellamy, Chief, Emergency Preparedness and Radiological Protection

Branch, DRSS (Part time) l

J. Joyner, Chief, Nuclear Materials Safety and Safeguards 1

Branch, DRSS  !

E. Adensam, Director, BWR Project Directorate #3

J. Strosnider, Chief, Reactor Projects Section IB, DRP

R. Blough, Chief, Reactor Projects Section IA, DRP

D. Wagner, Licensing Project Manager, NRR

C. Background

1. Licensee Activities

At the beginning of the SALP Assessment period the facility construc-

tion was approximately 92% complete. Preliminary and preoperational

testing were in progress. Preliminary testing culminated in the In-

tegrated System Flush in February and the Reactor Pressure Vessel

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Hydrostatic Test in early March. At the end of the period facility

construction was essentially complete with the exception of the plant

radiation monitoring system, radwaste systems, and some HVAC systems,

and completion of miscellaneous construction activities and clean up.

Preoperational testing was estimated 32% complete.

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Significant activities that occurred during this assessment period

include an Independent Design Verification Program conducted during-

April through June, initial cold license operator exams conducted in

July, receipt of new fuel on site during September and October, and

an initial Hope Creek Emergency Plan exercise on October 29, 1985.

A reorganization of the PSE&G Nuclear Department was implemented-on

July 1, 1985. This reorganization was in accordance with the appli-

cant's Transition Plan for switching from Construction Phase to

Operations. -

2. Inspection Activities

An operations senior resident inspector was assigned to the Hope

Creek Generating Station for the entire assessment period, and a con-

struction senior resident inspector was assigned until Mid-September.

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The total NRC inspection effort for the period was 5462 hours0.0632 days <br />1.517 hours <br />0.00903 weeks <br />0.00208 months <br /> (resi-

dent and region-based), with a distribution in the appraisal func-

i tional areas as shown in Table 1. A resident-inspector-in-training

i was assigned to the site beginning in April. During the assessment

period, NRC team inspections were conducted to examine the following -

areas:

a. Radiation Protection Program ,

b. Chemistry Program

c. Radi active Waste Disposal Program

d. Reat;or Coolant System Hydrostatic Test

e. Emergency Lighting and Safe Shutdown Capability in the event of

a fire

f. Independent Design Verification Program followup by IE

Headquarters

9 Emergency Preparedness Program

h. Readiness to Receive Fuel

Tabulations of Inspection Activities and Violations are presented in

Tables 2 and 3, respectively.

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II. Criteria

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Licensee performance has been assessed in selected functional areas. Each

functional area is significant to nuclear safety and the environment, and

is a normal programmatic area.

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One c. more of the following evaluation criteria were used to assess each

functional area.

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1. Management involvement and control in assuring quality

2. Approach to resolution of technical issues from a safety standpoint

f 3. Responsiveness to NRC initiatives

j 4. Enforcement history

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5. Reporting and analysis of reportable events

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6. Staffing (including management)

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7. Training and qualification effectiveness

! Based upon the SALP Board assessment each functional area evaluated

has been classified into one of three performance categories. The

definitions of these performance categories are:

Category 1. Reduced NRC attention may be appropriate. Licensee manage-

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ment attention and involvement are aggressive and oriented toward nuclear

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safety; licensee resources are ample and effectively used so that a high

level of performance with4 respect to operational safety 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 reasonably effective

so that satisfactory performance with respect to operational safety is-

l 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 effectively used so that minimally satisfactory perfor-

mance with respect to operational safety is being achieved.

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The SALP Board also assessed each functional area to compare the

licensee's performance during the last quarter of the assessment period to

a that during the entire period in order to determine the recent trend for

each functional area. The trend categories used by the SALP Board are as

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follows:

f Improving: Licensee performance has generally improved over the last

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quarter of the current SALP assessment period.

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Consistent: Licensee performance has remained essentially constant over

the last quarter of the current SALP assessment period.

Declining: Licensee performance has generally declined over the last

quarter of the current SALP assessment period.

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-III. Summary of Results

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A. Overall Facility Evaluation

The applicant's performance was satisfactory in all areas. Project

personnel displayed a positive attitude towards assuring quality con--

struction by the crafts. Use of quality assurance oversight and

. o feedback to management has resulted in ' quality construction. There

, was good management involvement in all areas, and areas requiring

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improvement were generally aggressively pursued.

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Construction management maintained a positive attitude, was appropri-

ately involved in resolving issues, and used a variety of approaches

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to maintaining quality awareness among workers. Areas needing im-

provement include (1) housekeeping, which has generally lagged other

areas of progress, and (2) communications and interfaces among vari-

ous groups having responsibilities for electrical and I&C activities.

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The preoperational testing function is well-staffed with experienced

, personnel. The Code Hydrostatic Test was especially well-controlled.

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Nonetheless, some problems have been noted in procedure scope and ,

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review. Procedureal adherence and test control have been generally

very good, but have varied depending on personnel involved. .In pre-

, paring for fuel load and testing there needs to be adequate attention

given by management to reviewing test results and identifying and -

correcting potential problems that could affect power ascension

operations.

The applicant's planning for plant transition from construction to

operations has been generally thorough and effective. The plant or-

ganization's involvement in construction completion, turnover, and

testing has been noteworthy. Some transition problems that occurred

in the preventive maintenance area have been corrected. The appli-

cant has a good management philosophy regarding safe operation and

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strong administrative controls. Plant staffing, personnel qualifi-

cations, and training are generally quite good. However, vacancies

and transfers occurred in the radiological controls area and may have

contributed to a lack of attention to technical detail in the

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programs.

i The assessments presented in this report are based largely on review

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of program plans; not implementation. Implementation of these pro-

grams will be carefully monitored in future inspections. .Due to the

state of transition from construction to testing and operational

readiness near the end of this assessment period performance trends

were not assigned in most functional areas.

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j B. Facility Performance

Catego ry Category Recent

4 Functional Area last Period This Period Trend

Construction Activities 1/2* 1 Consistent

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1 Electrical and I&C

l Construction 2 2 NA**

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( Quality Assurance 1 1 Consistent

j Preoperational Testing 2 2 NA**

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Operational Readiness Not evaluated 1 NA**

Maintenance Not evaluated 2 NA**-

, Radiological Controls Not evaluated 2 NA**

Security and Safeguards Not evaluated 1 NA**

Emergency Preparedness Not evaluated 2 NA**

Licensing Activities 2 2 NA**

j *This Functional area includes four areas addressed separately in

the last SALP. In that SALP three areas were Category I and one

was Category 2.

j **No trend is assigned in these areas since applicant effort during the

period focused primarily on program development and there was

i insufficient opportunity for observation and evaluation of implementation

! to determine performance trend.

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IV PERFORMANCE ANALYSIS

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A. Construction Activities (24.4%, 1522 hours0.0176 days <br />0.423 hours <br />0.00252 weeks <br />5.79121e-4 months <br />)*

1. Analysis

j Construction activity decreased during this assessment period as

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the project neared completion. Therefore, to provide a meaning-

) ful assessment, some areas addressed separately.in previous

SALPs are addressed collectively here. This SALP area covers

overall construction project management and control, as well as

i most individual construction disciplines. Electrical and I&C

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construction is addressed in a separate functional areas because

it was the area of greatest construction activity and was an

1 area of poorer performance.

1 Overall construction management continued to be strong during

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this assessment period. The utility and architect engineer's

staff were knowledgeable of plant status and were appropriately

1 involved in resolving technical issues and in ensuring quality.

! Senior utility and architect-engineer management were frequently

j cbserved on-site and in the plant.

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Construction management maintained a positive, quality conscious

attitude and a policy and practice of being generally receptive

to quality concerns. In this regard, the applicant formed an

independent group, SAFETEAM, to encourage and draw out expres-

sions of any quality concerns among project personnel. This

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organization did not operate in a passive mode but rather ac-

tively solicited concern from present and past employees. This-

was accomplished through periodic interviews with current non-

manual employees, group exits for manual employees, required

interviews for leaving non-manual employees, and letters sent

i to previous employees not interviewed.

l Communication of overall project status information from manage-

ment was generally strong and effective; previous initiatives in

this area, such as newsletters, posters, bulletin boards, and

meetings, were continued during this assessment period.

1 Management and supervision were not fully successful in foster-

ing within the project a high degree of pride in plant appear-

ance and of attention to detail in protecting plant equipment

, from damage. Examples of problems were debris found in cable

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trays and the leaking of fire barrier sealant material onto

plant equipment. Housekeeping improved during the assessment

, period, but the progress was not consistent and generally lagged

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behind other aspects of plant completion and transition. Also,

• Numbers in parenthesis represent the percentage and absolute

- number, respectively, of inspection hours expended in each func-

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tional area.

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there were some cases, where preventive maintenance (PM) on in plant

equipment still under construction was not fully effective. These

problems were exceptions to a generally effective construction PM

program and, once identified, were properly addressed.

The applicant's QA group followed up on NRC open items, tracking

each item to resolution. The various technical groups have not al-

ways been timely in addressing the open issues, however, and some

items remained open longer than necessary. A few items required

repeated NRC re-inspection and additional licensee work to reach an

acceptable resolution. Some IE Bulletins, IE Circulars, and TMI

Action Plan items involving procedural controls were presented for

NRC review before they were actually ready, in that the associated

procedures were still in the applicant's review cycle.

Details of performance in individual construction disciplines are

discussed below.

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Piping Systems and Supports

! During this period NRC inspections in this area focused on welding

and pre-service and in-service inspection (PSI /ISI) activities.

An inspection using the NRC Mobile Nondestructive Examination Labora-

tory was conducted April 8 - May 3, 1985. This inspection involved

review of licensee data packages and independent radiographic, mag-

netic particle liquid penetrant, visual and ultrasonic examination of

selected welds in ASME Class 1, 2 and 3 systems. The results of this

inspection indicated that the licensee's programs for welding and

fabrication control were effective in assuring the quality of the

plant system installations.

Another inspection reviewed the areas of welding, design and fabrica-

tion of small pipe and pipe support attachments. The inspection found

that the licensee was actively involved in the resolution of materials

related problems and other activities to control quality while extra

efforts were being made to keep on schedule for turnover of systems

for pre-operational testing. The licensee showed engineering con-

servatism in the solution of ASME Code Class 1 materials problems re-

lated to pipe attachments.

Preservice Inspection (PSI) activities were reviewed during the NRC

NDE Van inspection and during five additicnal inspections. The in-

spections found that licensee management involvement and control was

amply evidenced by the almost constant QA surveillance of vendor PSI

activities.

Additionally, the licensee has been actively involved in the demon- i

stration of ultrasonic examination techniques for piping containing

corrosion resistant cladding (CRC). Potential problems with these l

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examinations were identified to the licensee by the NRC, and since

that time the licensee has been actively engaged in a research and

development program to design a viable method for performing a

meaningful examio tion of the material. Demonstrations on 12", 22"

and 28" diameter material were successfully performed.

The licensee's staff, and the PSI vendor's personnel have been found

competent and have shown evidence of effective training in this area.

Staffing at the plant has been adequate for the activities in pro- ,

gress. The licensee's Q.A. group has. reviewed records to assure that

the PSI vendor personnel involved with the mechanized ultrasonic RPV

weld examinations were trained and qualified in the set up and opera-

l tion of the mechanized equipment. Additionally, the QA staff per-

i formed periodic audit of the PSI vendor activities to assure that

those activities were performed in accordance with applicable

requirements.

One exception to the above favorable findings was the licensee's re-

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moval from the ISI program of two welds in the HPCI system. The

short distance between these welds prohibited effective PSI /ISI ul-

trasonic testing. Thus these welds were removed from PSI /ISI program

and replaced with two similar category welds. However, the licensee

did not provide a thorough technical evaluation of the actual piping

configuration to assure that the HPCI system reliability would not be

degraded over a period of extended use. This item required repeated

NRC attention to obtain an acceptable degree of evaluation.

Safety Related Components

Inspections were conducted in this functional area involving the re -

actor pressure vessel (RPV) and preventive maintenance during

construction.

The reactor vessel internals installation was performed and con-

trolled by General Electric Company. The GE construction personnel

were experienced, well trained, and effectively managed; the work was

planned and controlled with necessary instructions and procedures.

The end result was an RPV that has no weld draw beads in any of the

internals. The smooth assembly process provided evidence of good.

planning and management of this construction activity. One problem

was identified in this area, in that three of the RPV top flange

threaded stud holes were observed to be rusted, with resultant thread

metal loss.

However, in general, management involvement during work on reactor

vessel internals was adequate with considerable evidence of QC and QA

activity by the contractor (General Electric), the architect engineer

(Bechtel Construction) and the licensee.

Regarding preventive maintenance during construction, a problem was

J noted regarding failure to protect diesel generator heat exchangers

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! from static water accumulation and potential corrosion. Applicant

response to this NRC identified problem was effective.

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Support Systems (Fire Protection, HVAC) l

t A special inspection was conducted on May 20-24, 1985, to assess the

! plants ability to safely shut down in the event of a fire. In this

area, the licensee has consistently exhibited evidence of prior plan-

ning by the presence of complete, timely and thorough audits, techni-

cally sound reviews and complete records of design. Further evidence .

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of management's involvement is the thorough safe shut down analysis

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which was included _in the licensee's FSAR. The licensee wcs respon-

sive to NRC concerns as indicated by its quick resolution of issues

identified during the team inspection.

i Inspection of safety related HVAC ductwork and support installations, .

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emphasized a review of hardware installation and review of technical

< and design documents. PSE&G management involvement was evident in -

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various aspects of HVAC installations. Surveillance programs of site

contractors were found to be timely and thorough. Bechtel site engi- '

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neering was found to be knowledgeable and technically sound in ad-

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dressing most of the concerns raised during the inspection. Some

, unresolved items were identified related to justification for, and

qualification of tolerances in Duct Standard Support Criteria. .How-

j ever there was no indication of e. recurrence of previous problems

with subcontractor QC and, in general, good control over-site activi-

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ties related to HVAC installations was observed.

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2. Conclusion

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} Rating: Category 1

! Trend: Consistent

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3. Board Recommendations

Licensee: Complete prompt closure of outstanding open items.

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B. Electrical and I&C Construction (8.7%, 542 hours0.00627 days <br />0.151 hours <br />8.96164e-4 weeks <br />2.06231e-4 months <br />) -

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1. Analysis

This area is addressed separately in the SALP because there was

extensive construction work activity in this area during the

period and also because applicant performance in this area was

! not as strong or as consistent as in other construction disci-

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plines. Eight inspections were conducted in this area, five

primarily in electrical, and three primarily in I&C.

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Major jobs appeared well planned and the major technical aspects

were accomplished properly. Cable runs and instrument tubing

, were generally neat and adequately supported. However, the de-

i gree of attention to detail was less than in other areas. As a

i consequence, lapses occurred in construction performance and in

j protection of in plant installed electrical equipment, instru-

j ments and instrument tubing. Some examples of these lapses in-

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clude two examples of improper cable installation (Inspection

84-21), uncapped instrument tube ends (Inspections 85-03 and

1 85-51) and trash and debris accumulation in cable trays (Inspec-

tion 85-10).

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problems were noted involving communications and interfaces

among the varicus groups having responsibilities for aspects of

equipment design, installation, maintenance, and inspection.

Examples of these problems include:

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Confusion over pH responsibility for equipment released for

test (RFT) resulted in removal of space heating from six-

teen electrical components (Inspection 84-21).

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There was confusion among construction and start-up person-

nel regarding QC involvement in the RFT program (Inspection

85-03).

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Systems were accepted by QC and released for test with in-

struments which the vendor had previously indicated would

need replacement. There was no apparent method of tracking

the item being replaced in the QC document or the turnover

package,

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Construction activities, access controls, and preventive

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maintenance were not well-coordinated in certain plant ar-

, eas having safety related electrical power supply and dis- l

tribution equipment (Inspection 85-17).

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Class IE Unit Substation logic design was not properly

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translated into drawings. Further, an opportunity to iden-

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tify the deficiency during testing was missed due to

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f insufficient involvement of engineering personnel (Inspec-

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tion 85-42).

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Cable tie-ups were not reinstalled or reinspected after

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removal to facil.itate fire seal installation (Inspection

85-45).

The above noted problems indicate that more effective direct

i supervision of in plant activities and better coordination among

various organizations could have-improved overall performance,

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i The licensee was generally aggressive and reasonably thorough'in

! addressing issues, both those identified by NRC and those self-

identified. Corrective actions typically included consideration.

I of potential for generic implications or more widespread exam-

! ples of a noted deficiency. Seven construction deficiencies  ;

were reported in this area. As indicated in Section A, construc-

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i tion deficiencies were evaluated appropriately and corrective '

i actions were usually thorough and technically sound. '

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Considerable management attention and technical resources were I

I focused on evaluation and correction of various design problems

l with the Bailey low voltage control system. Although it appears ,

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preliminarily that significant improvements have been made, NRC i

f review of the system is not yet complete. '

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j The applicant was very responsive to an NRC concern involving

control of instrument calibration data (ICD) and setpoint calcu-

i lations. The applicant established a program to verify all cal-

ibration and setpoint data and has also been active in an

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owner's group to refine setpoint methodology. Further, a com-

l puter based index was developed that can cross-reference any

! revision to a reference document to each potentially-affected

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ICD card, so that calibration data and setpoint information can  !

be kept up-to-date.

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l Although the licensee was generally thorough and aggressive in

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addressing problems in this area, particular emphasis should be

placed on identifying possible electrical and I&C problems dur- ,

ing test results review. '

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l 2. Conclusion

j Rating: Category 2  ;

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3. Board Recommendations

Licensee:

Increase attention to electrical and 1&C equipment during facil-

ity turnover and plant walkdowns.

Improve in plant supervision of ongoing activities to ensure

proper care and respect is being given to irstalled equipment.

Be particularly sensitive during test results review to identi-

fication of problems possibly resulting from electrical and I&C

areas.

NRC: -

Include discussion of the root causes of problems in this area

and possible future implications as part of the SALP Management

meeting.

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C. Quality Assurance (9.1%, 569 hours0.00659 days <br />0.158 hours <br />9.408069e-4 weeks <br />2.165045e-4 months <br />)

, 1. Analysis

Five inspections were conducted by NRC QA specialists to review

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preoperational and operational phase QA programs. Further, nu-

merous other NRC inspections involved review of QA/QC program

effectiveness as it relates to construction, turnover,

preoperational testing, operational readiness, security and

safeguards, radioactive controls, ' emergency planning, and other

fanctional areas. Because QA effectiveness influences all func-

tional areas, it is discussed in various other sections of the

} report, as well as being addressed separately here.

Both the applicant and the architect-engineer have maintained

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strong QA programs; this has had a beneficial impact on project

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quality. Project management has demonstrated a support of QA.

The various project communications mechanisms, (mentioned in

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Functional Area A, Construction) contain-frequent discussions,

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reminders, and features designed to promote quality goals.

In accordance with the applicant's approved transition plan, the

! QA organization evolved and functional responsibilities were

transferred between groups based on project activities and

3 needs. Staffing of the QA/QC groups was fully adequate through-

) out the period, as the applicant shifted retources appropriately

i from construction oversight to preoperational testing and opera-

l tional readiness activities. Transfer of functions went smoothly

with no apparent losses of effectiveness in transition. The

.

transition reflected well on the management's planning efforts

! and evaluations of the evolving needs of the QA program. QA au-

i dits and <urveillance were found to be comprehensive and

j well-scheduled. For example, audits of operational readiness

were especially comprehensive and timely. In contrast, however,

i the QA audit process was apparently not used to ensure the readi-

ness of the Emergency Preparedness area for NRC appraisal.

4

The applicant and architect engineer focussed management atten-

tion on correcting deficiency weaknesses noted in the past. Cas- ,

! es of unauthorized rework were dealt with forcefully, although L

the project was not able to entirely eliminate the problem. For

example, several cases of unauthorized rework of fire barrier

penetration seals were identified (by the architect-engineer QA

organization) early in 1985. Similarly, cases of bypassing of

QC hold points continued to trend downward, and individual in-

stances were thoroughly investigated.

1

The applicant was generally responsive and thorough in respond- '

ing to quality concerns and findings, regardless of the source.

l

,

4

I

_ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ . _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _

._ - - - - . -. - . . . . . _. . _ - . . - - . - ... .. - . _ - . _ . . -

-

, . .

+

.

'

4 15

'

.

j -The applicant responded quickly and effectively to NRC-identi-

fied QC concerns from late in the last SALP period involving

j clarification of QC inspection procedures and records,

i

Although a few exceptions were noted, the applicant's corrective i

i actions typically involve measures to determine the full scope

j' of the problem (i.e., to find out if there are additional defi-

ciencies similar to the ones cited) and to identify and correct

i the root causes.

i

-

Despite an overall strong QA program, during the early part of

). the assessment period the QA construction and preoperational QA

i program were not comprehensive enough to identify and correct ,

j concerns identified by the NRC and discussed in the correspond-

'

ing sections of this report in the electrical, I&C, and preven-

,

tive maintenance areas. NRC also identified repeated problems

! in documentation of preoperational test equipment accountability

J and usage. Recently, the licensee management and QA staff have

taken effective corrective actions to adequately address the  :

, NRC-identified deficiencies. Actions included procedure revi-  !

! sions, improved definition of interfaces, and associated inte'r- i

l' face meetings. This improvement in the applicant's programs was  !

l, verified during NRC Inspection 85-51.

r

! Inspections thus far of operational QA programs have indicated >

j proper planning, management involveinent, and commitment to QA.

i

i 2. Conclusion

!  !

l Rating: Category 1

Trend: Consistent

j 3. Board Recommendation

l

Licnesee: None '

j NRC: None

i

i -

-

i

I .

'

i

t

1

.

'

.

l

$

i

I i

,

y

I-

_. . ._ . . _ _ _ __ __ _ __

t

l ..

l

!

l' 16

.

.

D. Preoperational Testing (29.3%, 1822 hours0.0211 days <br />0.506 hours <br />0.00301 weeks <br />6.93271e-4 months <br />)

1. Analysis

i

During this assessment period twelve inspections of

preoperational testing activities, which included one initial

review of the applicant's startup program, were performed by

region-based inspectors. The resident inspectors also reviewed

the area extensively.

The licensee has developed a well-defined and administrative 1y

adequate preoperational test program. Based on inspector obser-

vations the applicant appears to be well staffed with qualified

system test engineers. Management personnel are involved in

program activities and appear to be vigorously pursuing an expe-

dited preoperational test program.

There have been weaknesses identified in the area of test proce-

dure scope content and level of review. During the early phase

of the preoperational test program only "Q" category procedures

received Preoperational Review Committee (PORC) review and ap-

proval. NRC review determined that numerous systems listed in

Regulatory Guide (RG) 1.68 were not classified as "Q" by the

applicant. The applicant has revised his program to include

review of all results of preoperational tests identified in RG

1.68 by PORC.

An additional weakness concerning the emergency diesel generator

preoperational test procedure scope was identified during a

February 1985 inspection. The PORC approved procedure did not

satisfy the intent of RG 1.108 concerning ECCS load sequencing

after the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> full load run. Several other minor instances

have been identified where FSAR commitments had been omitted from

preoperational test procedures. Also some of the early tests

required an excessive number of changes during test performance '

to make them workable. As a result of the above, the licensee

has taken positive steps to ensure that FSAR and Regulatory Guide

commitments are not overlooked by establishing the Test Review

Board (TRB) which performs an in-depth review of preoperational '

test procedures (PTP) prior to PORC review and approval. Although

this procedure reduced the number of NRC comments relating to

procedure review, NRC inspection in July 1985 found in three

instances where procedures did not eeet FSAR commitments. The .

deficiencies were relatively minor, however, and the general +

trend of procedure quality is improving.

A compressed work schedule has contributed to premature accep-

tance of plant systems early in the period by the startup group.

Many systems have been accepted from construction (201 of 210

plant systems as of October 16,1985) with too many open

l

1

,

'

..

.

17

deficiencies to allow testing (48 of 149 PTPs had been field

completed as of October 16,1985). One example of this problem

involved the diesel generators which were scheduled to begin

testing early in 1985. At that time, vendor testing had not

begun and diesel preoperational testing actually began in Octo-

ber 1985. Sequencing of many other tests was changed based on  !

equipment availability. Also in an attempt to support a com- '

pressed test schedule (1) FSAR test commitments were often

shifted from one test to another, and (2) some_ systems (e.g.,

HPCI, RCIC) were preoperationally tested with significant modi-

fications pending. These actions increase the potential for

either missing test requirements or invalidating completed

tests. Therefore, increased applicant attention is warranted in

the areas of test results review, modification sequencing, and

post-modification testing. This need for special applicant at-

tention is further underscored by the fact that a large number

of FSAR changes have been made during the preoperational phase,

due to (1) initially too general test commitments, and (2) de-

sign changes.

NRC inspection of the Local Leak Rate Testing (LLRT) program

indicated that the licensee had developed and implemented a well

planned and thorough program that will meet the requirements of

10 CFR 50 Appendix J if followed.

One special NRC inspection covered the ASME Code Hydrostatic

test of the reactor pressure vessel and associated piping. This

test was executed in an especially effective and satisfactory

manner. The applicant demonstrated complete involvement with

this test. The fact that management considered this test to be

an extremely important milestone in the plant's construction was

evident throughout the test. Management and staff personnel

exhibited high levels of technical competence, a cautious con-

servative approach, and systematic planning, training, and con-

trol of the event. Also, the documentation and records of these

tests were quite complete and well-organized.

Procedural adherence and test controls have been generally very

good, but have been somewhat dependent on the individual test

engineers. Most procedural adherence deficiencies noted have

been administrative in nature, such as improper handling of

changes or failure to fully review prerequisites. One area of

repeated problems is documentation of test equipment account

ability and usage. This problem was originally identified by

NRC, but repeated examples of lack of attention to detail were

subsequently noted by both the applicant's QA group and NRC.

Since the applicant's program provides multiple means of tr:cing

equipment usage, the adherence problems have not jeopardized

test validity.

- - ..

-

,

..

-

.

18

. Preparations for the startup test program are well underway.

l Planned staffing levels appear adequate. The startup

organization is drawing experienced personnel from various

sources and has been gathering information and lessons learned

from other recent BWR startup test programs. Because of the

limited opportunity for evaluation, thus far, startup testing is

not considered in determining the rating for this functional

area.

. Throughout this period QA/QC has been actively involved with the

preoperational testing program through both procedure review and

surveillance of activities. The QA manager has also assigned a

QA engineer to track and expedite closure of all NRC open items.

In summary, the dynamic test schedule, the shifting of commit-

,

ments among tests, and the tempo of design and FSAR changes dic-

tate an especially thorough final review of the tests to verify

they are valid, meet all commitments, and have gathered all the

necessary data. In addition, modifications in progress must be

carefully reviewed to make sure they don't negate previous test

results.

~

2. Conclusion

Rating: 2

Trend: NA

3. Board Recommendations

Licensee:

Be especially thorough in review of results of individual tests

and of the overall program.

i

Ensure that modifications and shifting of test commitments don't

negate completed test results.

NRC: None

i

l

..

-

.

l 19

l E. Operational Readiness (13.0*4, 809 hours0.00936 days <br />0.225 hours <br />0.00134 weeks <br />3.078245e-4 months <br />)

i 1. Analysis

A special team inspection reviewed the applicant's readiness to

receive, inspect, handle, and store new fuel. Also, operational

readiness in the areas of design control, records program, and

t measuring and test equipment (M&TE) control was reviewed in two

l inspections. Operator licensing examinations were conducted in

l July and October 1985. The resident inspectors also reviewed

various aspects of operational readiness.

The applicant developed a planned, methodical approach to the

transition from construction to operations. A. formal Transition

Plan was in effect throughout the period. As the preoperational

phase began, Hope Creek Operations developed an Operational

Peadiness Plan to identify and track to completion major opera-

i

tional readiness activities. Tracking systems and management

l information systems were used effectively in the areas of staff-

l ing, procedure development, procurement, and training.

l

The details and extent of planning for the transition from a

construction oriented to an operations organization indicated

that management exerted considerable analysis and effort to as-

l sure smooth transition and a high level of readiness to safely

l operate the plant.

The applicant has staffed the plant using experienced, well-

qualified personnel. Although many of these were previous

company employees, the applicant supplemented this talent by

hiring experienced personnel from throughout the nuclear indus-

try. Those hired were assigned to the staff sufficiently early

to be involved in preoperation phase activities and in opera-

,

tions phase program development. Thus, depth and scope of per-

l sonnel resources has been obtained. In terms of numbers of

l personnel, the applicant has been relatively successful in fill-

l ing technical, administrative, and craftsman positions on-site.

(One exception is the radiological controls area, discussed in

Section G.)

l During the appraisal period staffing appeared adequate. After

l the transition to operations, certain areas; such as I&C, reac-

l tor engineering, and shift administrative support; will have to

i be monitored closely during initial operation to determine if

l staffing matches the workload.

Hope Creek Operations has been appropriately involved in con-

l struction completion, turnover, and preoperational test activi-

l ties. The operating shifts have been manned for two years, and

l shif t supervision displays good control over operations and

l maintenance of turned over equipment. Plant management is

l

- - - - .__ . ._ -_ .

-

.

-

.

20

knowledgeable and fully involved; managers and supervisors ap-

pear to spend an appropriate amount of time in the plant.

i

Licensed operator and senior operator selection and training

, appears quite effective. On-shift personnel have shown a good

attitude, a good safety perspective and a high level of motiva-

tion and initiative. Further, the operator training program was

well-organized and made good use of the plant-specific simulator  :

and the symptom-based emergency operating procedures. License

candidates showed very good plant knowledge during

NRC-administered license examinations. Nineteen of 24 senior

reactor operator candidates and 14 of 16 reactor operator candi-

dates were successful in their NRC cold license exams during

this assessment period. This-is a relatively high success rate

, and reflects well on the applicant's selection and training

.

program.

l

In the area of administrative and procedural controls, signifi-

cant NRC review remains to be done, so there is not a strong

basis for evaluation. Preliminarily, it appears that the appli-

cant has a good philosophy of providing strong controls. Sig-

nificant management involvement and technical evaluation has

been evident relative to establishing strong administrative con-

a trols that enforce good engineering and operating practice. Some

i

administrative procedures appear somewhat unwieldy, however, and

some inconsistencies among procedures were found. For example,

procedures were inconsistent regarding scope of independent ver-

ifications under TMI Action Plan Item I.C.6. Regarding emergen-

cy operating procedures (EOPs), very extensive technical and

, human factors effort, which included significant operations man-

agement input, was expended in developing, verifying and refin-

ing the procedures. This shows management recognition of the

'

importance of the E0Ps and proper attention to their adequacy.

Other operating and test procedures were somewhat _ late, relative

, to FSAR commitments, in being reviewed and approved. When the

!

procedure review process fell behind, management attention was

j focused on recovering and ensuring procedures would be ready in

i time to allow for training and familiarization.

'

Although additional inspection is needed to fully verify the

j adequacy of the operational phase QA program, initial indica-

>

tions are favorable. Specifically, the operations phase pro-

grams for procurement control, receiving, storage and handling

l of materials and equipment, document control, maintenance, in-

jl strumentation and control and surveillance test programs was

found acceptable. This is further evidence of proper planning,

!

management involvement, and project commitment to QA. One area

I

of development requiring management attention is the safety re-

view process. The offsite groups had not been. fully staffed,

3 and the onsite safety review process was not fully operational

as of the time of the NRC QA inspection in July 1985. Safety

f

.

-

.

-

.

21

review processes need to be in place, well-understood, and func-

tioning smoothly and effectively for the operational phase.

During an inspection of readiness for fuel receipt, several mi-

nor discrepancies were noted with fire protection procedures.

Licensee management took immediate action during a scheduled

site Operations Review Committee (SORC) meeting to review, dis-

cuss and correct the deficiencies. NRC review of other operat-

l ing and test procedures is pending.

The applicant has a good program for reviewing, evaluating and

tracking industry experience information from various sources,

including NRC, INP0, and vendors. The review program has a

full-time coordinator and provides for multi-discipline review.

Although the reviews are usually thorough, there has been some

tendency to rely too heavily on the vendor's or architect engi-

neer's resolution, which is usually hardware-oriented and might

not include appropriate procedural or administrative control

features. Examples include IE Bulletins 79-24 (Freeze Protec-

tion) and 80-16 (Rosemount Transmitter Over-ranging).

During the readiness to receive fuel inspection, the inspectors

found that the licensee was well prepared with a fully developed

program for fuel receipt. However, the licensee's experiences

during this program also indicated an example of possible sched-

ule pressure, in that fuel was to be stored dry because all sys-

tems required for wet storage were not ready.

2. Conclusion

Category: 1

Trend: NA

l 3. Board Recommendations

! Licensee:

l

Prepare an operational readiness presentation, based on self

j appraisal, for NRC Region I management approximately two weeks

l prior to projectd fuel load.

NRC:

Monitor adequacy of staffing in I&C, reactor engineering, and

shift administrative support.

1

l

!

. .

.

-

.

22

F. Maintenance (2.35, 143 hours0.00166 days <br />0.0397 hours <br />2.364418e-4 weeks <br />5.44115e-5 months <br />)

1. Analysis

The applicant's maintenance organization was extensively in-

volved in preventive and corrective maintenance of in plant

,

equipment throughout the assessment period. Maintenance respon-

sibility shifted to the Hope Creek Operations (HCO) maintenance

group on a system-by-system basis at Time of System Turnover

from construction to Start-up. Four specialist inspections ob-

served licensee activities related to preventive maintenance

(PM); also resident inspections and pre-operational test spe-

cialist inspections frequently spot-checked maintenance activi-

ties. Additional programmatic inspections are planned before

licensing.

l The HC0 Maintenance Department is well-staffed with experienced

supervisors and managers. Many of the supervisors have 15 or

,

more years of applicable experience. The department manager was

the project Construction Manager for several years before join-

ing the plant operations staff. A conscientious and

quality-conscious attitude exists throughout the staff, includ-

ing the craftsmen.

Exterior resources, including an impressive training facility,

are devoted to craftsmen training program. Also, a documented

on-site job qualification program is in place. . The training of

maintenance personnel involved in fuel receipt was very effec-

tive. Further, the applicant has been alert during the

preoperational phase to optimize the training benefit of correc-

,

tive maintenance activities that occurred. As a result of the

j experience gained, some operations phase maintenance will proba-

bly be done more efficiently, and therefore, with less radiation

exposure.

Despite the generally impressive personnel resources and train-

ing program, a number of maintenance-related problems have oc-

curred, most of which involved turnover and transition. Examples

follow:

--

Some electrical equipment was without required space heat

temporarily (see functional area B, Electrical and I&C);

--

A backlog of preventive maintenance requests (PMs) on re-

cently turned-on equipment developed;

--

Some Hope Creek maintenance craftsmen appeared unfamiliar

with Bechtel PM procedures, which they were required to

perform during PM program transitions;

-, _ _._ _ ._ _ - _

, , , --. . ,_, _-.- .

_.

.

.

23

--

Many Limitorque motor operated valve actuators were greased

with the wrong grease, resulting in a Construction Deft-

ciency Report and extensive rework.

The above noted problems indicate that:

(1) There were lapses in interface and coord.ination between the

construction and operations organizations, as related to

the specfics of equipment maintenance during the transition

phase,

(2) Some job-specific training and on the job supervision was

not fully effective, and

(3) The HC0 PM program may not have been adequately prepared

for some system turnovers.

Most of the above listed problems occurred early in the assess-

ment period. The applicant was aggressive in correcting identi-

fied problems and using lessons learned. For example, the PM

backlog was reduced to minimum later in the assessment period.

The applicant has shown a strong commitment to PM. Although

some problems appear to have been related to unique aspects of

transition, similar interface and coordination problems can oc-

~ . cur during modification work in the operations phase; therefore

the applicant should make sure any such problems have been fully

resolved.

One activity occurring late in the assessment period was per-

formed in an especially safe and professional manner. This was

the receipt, handling, inspection, and storage of new fuel, con-

ducted by maintenance personnel. This job went smoothly and was

very well supervised. Supervisors and craftsmen were knowl-

edgeable, alert, and meticulous.

,

Maintenance facilities are generally good and were functional

before needed. One exception is the CRD rebuild facilities

which are not well designed.from an ALARA viewpoint.

Maintenance procedures have not been reviewed extensively by

NRC. Of a sampling reviewed thus far, some were found to be

very good, whereas others appeared in need of additional detail.

2. Conclusion:

Rating: 2

Trend: NA

.

V

N

s

b

,

_ _ _ _ __ _ . - - _ _ _

_ _ _ _ _ _ _ _ _ _

.

-

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'

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l

l

.=

l

24 l

1

g5 l

. -

3. Board Recommendations:

{

i

Applicant:

)

Ensure that interface and coordination problems identified in

the maintenance area are fully resolved and will not causs

problems during the operations phase. '

NRC: None

1

I.

l

l

w

s

T

T t

X

\

.

1

t

!

4

I

!

_ _ . _ _ _ _ _ . _

'

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-

.

, . 25

.

4

G. Radiological Controls (4.7%, 295 hours0.00341 days <br />0.0819 hours <br />4.877645e-4 weeks <br />1.122475e-4 months <br />)

1. Analysis

During this assessment period, initial reviews of the appli-

' cant's developing radiation protection and radioactive waste

management programs were completed and the implementation of the

segments of the radiation protection program needed to support

fuel receipt was reviewed. No significant problems or devia-

tions from previous commitments were noted during the reviews.

Radiation Protection

,

Four inspections in the radiation protection area were conducted

by Region I Radiation Specialists. The inspections reviewed the

development of the radiation protection program and its imple-

mentation during fuel receipt activities. Although a number of

problems and weaknesses was identified, overall program develop-

ment is considered adequate.

Early in the appraisal period reviews of the radiation protec-

tion organization and staffing indicated development of a gener-

ally adequate radiation protection organization. As a result of

reorganization and inerger of the chemistry and radiation protec-

i

tion organizations, the incumbent Radiation Protection Manager

became the Chemistry / Radiation Protection Department Manager.

Supervisory oversight and attention to technical detail in

radiation protection program development was weakened during the

preoperational period by the vacancy in the Radiation Protection

Engineer position created by the reorganization. Staffing with-

in the radiation protection function of the reorganized depart-

ment was generally adequate. However, late in the' assessment

period, transfers and vacancies in radiation protection and ra-

diological engineering supervision weakened supervisory over-

sight of operational radiation protection and radiological

engineering.

The development of radiation protection procedures was generally

adequate. Weaknesses and the need for. technical improvement

were noted in station administrative procedures describing the

radiation protection program, providing control of access to

radiologically controlled areas and the radiation work permit

system. The applicant was resocnsive in addressing and correct-

ing the weaknesses noted.

An inspection after the end of the assessment period confirmed a

significant need for increased supervisory oversight and atten-

tion to technical detail in program and procedure development.

(This inspection, having been completed after the end of the

P

assessment period, is not considered in the SALP rating or in-

cluded in statistical data and tables.)

m

_ . _ _ _ _ _ _ _ _ . - - - . . . - _ _ . _ _ _ . _ - _ - - - - _ - _ _ _ . _ . - - _ . - _ _ . - _ _ _ - - - _ - - - - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ . _ - . - . . . - - _ . _ _ . _ - . _ - _ _ - - _ _

-

.

..

26

Radioactive Waste Management / Effluent Monitoring

Two inspections of the radioactive waste management and effluent

monitoring program were conducted by Regional Radiation Special-

ists during this assessment period. The inspections reviewed

the development of the program area including planned organiza-

tion and staffing, installation and testing of radioactive waste

systems and monitors and development of test and operating

procedures.

A generally adequate radioactive waste management organization

was being developed. Positions were adequately identified but

vacancies in supervisory positions were noted. Authorities and

responsibilities were identified in administrative procedures

but key responsibilities were divided between the Operations and

Chemistry / Radiation Protection Departments. The procedures de-

fining these interfaces were under development but incomplete

during the assessment period. Operating personnel were being

trained but had not been qualified on the systems which they

were to operate.

This area appears to require more management attention and

inter-departmental coordination to ensure (i) interfaces are

properly defined ar.d well-understood and (ii) training is com-

pleted and effective. As an example, an inappropriate Field

Change resulted in the last valve in the gaseous radwaste system

having an incorrect failure mode. This change was not ques-

tioned during the various, multi-discipline reviews during turn-

over. Improvements in both the areas mentioned above are needed

in an appropriate time frame to support radwaste system

operations.

Late in the assessment period, the applicant requested deferral

beyond fuel load for installation and operability of certain

process radiation monitors. The analysis provided to support

the deferral request did not fully address potential situations

and sources that could require monitoring. Technical issues

associated with the deferral request remained unresolved at.the

close of the assessment period.

Defined procedures for tests of radioactive waste systems were

being developed showing prior planning and assignment of priori-

ties in that portion of the apolicant's test program.

Acceptance criteria for the tests generally met previous commit-

ments suggesting reviews were generally thorough and technically

sound.

.

2. Conclusion

Rating: Category 2

-

.

-

..

27

Trend: NA

3. Board Recommendation

Applicant:

Complete staffing of supervisory positions within the radiation

protection organization (especially the Radiation Protection

Engineer position) and the radioactive waste management

organization.

Ensure through well coordinated test procedures and plans that

installation of deferred systems does not interfere with the

performance and results of plant startup testing.

NRC: None

.

-

._

'

-y

__ . ._ _ _ - _ _ .. ._ _ _. . .

7__.

-

.

-

..

,

,

28

H. Security and Safeguards (1.0*,;, 59 hours6.828704e-4 days <br />0.0164 hours <br />9.755291e-5 weeks <br />2.24495e-5 months <br />)

I. 1. Analysis

i

4

This assessment covers the licensee's performance in (1) devel-

oping and implementing a program for the receipt, on-site stor-

age, control and accountability of special nuclear material

(SNM) of low strategic significance, and (2) development of an

<

operations phase physical protection program for Hope Creek.

Two preoperational security program reviews, including one in-

spection of implementation of security and other storage license-

i requirements for new fuel, and one inspection of the licensee's

program for control and accountability of SNM, were performed by

i

regional-based physical security inspections. Routine review of

program development was also conducted by the NRC inspectors.

. During this assessment period, the licensee was highly effective

1

'

in the development of the physical security program and its in-

tegration into the existing security program for Salem Units 1

and 2. Experienced gained through the licensee's security pro-

gram at Salem Units 1 and 2 has been beneficial in establishing

the Hope Creek security program. The licensee was engaged in

.

1 '

4

modifying the' existing security management staff, redesigning

security procedures and orders and conducting complex acceptance.

i testing of new security related systems. These modifications

and testing of new systems were aggressively pursued and have

j had minimal impact on the operation of the Salem security

prog am.

l

j

~

NRC review of the Hope Creek physical security plan and the plan

for Receipt of Special Nuclear Material of Low Strategic Signif-

i icant identified only a few issues which required rework by.the t

j

licensee, which is indicative of management's attention to the

preparation of the plans. Additionally, the licensee was found

l

'

to be aggressive in pursuing' resolution of outstanding issues

identified during Region I preoperational program reviews. This

1 is further evidence of management's commitment to develop and

implement an effective program. At the end of the period the

i licensee was reviewing its Training and Qualification and Safe-

guards Contingency plans to identify necessary changes to those

j documents at an early stage. It is anticipated that only minor

operational and administrative changes will be necessary. The

NRC has found all security program plans to be professionally

i prepared, well organized and submitted in a timely manner. - '

! Changes necessitated as a result of NRC review were accomplished

in a timely, professional, and cooperative manner, demonstrating

i the licensee's continued attention and responsiveness to regula-

] tory requirements.

i

'

I

i .

i

.!

. . . . . . . . __ .

-

.

-

.

29

i

!

, Appropriate involvement of both quality assurance and project

j personnel was evidence of management's interest in a quality.

.

program. Auditors were aggressive and conducted prompt followup

on identified issues. Project engineers, responsible for the ,

systems and equipment, and on-site security management personnel .

were found to be very knowledgeable of program status, testing

'

schedules, turnover dates and NRC performance criteria.

Preoperational security program reviews conducted by NRC indi-

cated that the licensee's integrated security resources were

i ample, effective and well-defined, with attention to practical

'

applications and lessons learned. This-further demonstrated

management attention to program needs at an early stage.

Security force personnel were found to be receiving adequate

specialized training on the Hope Creek security equipment and

systems. The training was being given by qualified personnel

'

i and was consistent with the requirements of the licensee's cur-

rent NRC-approved Training and Qualification Plan. Security.

] force personnel were observed by the NRC staff to' have progres-

i sively improved their capabilities during this assessment peri-

i od. Management involvement was evident by a relatively

j troublefree transition, to-date.

j 2. Conclusion

i, Rating: Category 1

, Trend: NA

3. Board Recommendation i

Applicant:

i Fully implement operations phase security in sufficient time in

1

advance of fuel load to identify and resolve any weaknesses.

l

NRC: None

!

i

.

l

I .

i

'

f

i  ;

! ,

!

i .'

i  !

4

.- - - - ._ -. - -. . - -. -- -

.

n

-

.,

30

i-

.

t

i I. Emergency Preparedness (7.5%, 467 hours0.00541 days <br />0.13 hours <br />7.721561e-4 weeks <br />1.776935e-4 months <br />)

'

1. Analysis

,

i This assessment is based on the results of the Emergency Pre-

paredness Implementation Appraisal (EPIA) performed on August '

i 12-16, 1985 and on the NRC team. inspection of the first Hope

j Creek emergency exercise on October 29, 1985.

1

i An EPIA was performed at Hope Creek on August'12-16, 1985 to

1 evaluate the overall adequacy and effectiveness of the emergency

i preparedness program. The appraisal findings indicate that the

l framework for the emergency planning (EP) program including ad-

i

ministrative and organizational setup, training, procedures, and

facility locations is established and appears to be adequate.

l However, several critical program areas were found to be incom-

i'

plete. These inclede organization, communications, training, i

and physical facilities. Therefore, the NRC appraisal team was '

4

'

unable to make determination as to the adequacy of the program.

These findings indicate that management attention was temporar-

i fly diverted from the development Hope Creek EP capabilities due

, to the focus on (i) upgrading Salem EP provisions, and (ii) cor-

porate reorganization.

! The applicant performed quite well during the October 29, 1985

i

emergency exercise with only minor deficiencies noted by the NRC

1

inspection team. The applicant was not able, however, to demon-

>

strate the effectiveness of certain program areas due to their

incompleteness. In particular, personnel accountability and

! automatic transfer of Radiation Monitoring System (RMS) informa-

1

'

tion to the dose assessment facilities were not demonstrated

during the exercise. Nonetheless, significant progress in over-

, all EP capabilities was made between mid-August and last October

as evidenced by completion of the control room, technical sup-

.

port center, and off-site EP facilities; consolidation of the EP

. training program; and installation of a new telecommunications

system. The applicant is aggressively pursuing resolution of

these and the other program deficiencies noted by the EPIA ap-

,

praisal team and the NRC exercise observation team. The impres-

, sive emergency exercise, combined with the aggressive approach

to open items, indicate that management effectiveness is improv-

,

ing. Thus, while the above noted diversion of attention away

from plant-specific program developeent delayed implementation

of some Hope Creek EP features, the applicant's generic upgrad-

>

ing of his organizational capabilities has improved the Hope

-

Creek EP performance ability.

'

The applicant is keeping NRC Region I informed of progress made

,

in those program areas which are to be completed and future in-

i spections will not be conducted until the licensee has indicated

4

that the EP program is substantially completed.

,

.

.

-

.

,. 31

2. Conclusion

Rating: Category 2

Trend: NA

3. Board Recommendations

Applicant:

Consider performing a self appraisal of the Emergency Planning

area.

Consolidate Emergency Planning efforts at Hope Creek and Salem.

NRC:

Defer future inspections in this area until the EP program is

substantially completed.

1

P

J

r

.

. . -, . . -. - - - -_ - .

. -

.

I

-

32

J. Licensing Activities

. 1. Analysis

!

l During the present rating period, the licensee's management dem-

onstrated active participation in licensing activities and kept

, abreast of current and anticipated licensing actions. Manage-

ment involvement is evident in the applicant's responses to

'

staff concerns as most responses indicate awareness of policy,

design and operational considerations.

!

I During this rating period, the NRC staff performed numerous au-

dits at the Hope Creek site, PSE&G corporate headquarters, and

the Architect / Engineer's offices. In most instances, the appro-

l priate level of PSE&G management was present at these audits to

i

assure a smooth running review. The information provided by

PSE&G at these audits was generally complete and thorough. One

item the staff feels that PSE&G management should have been more

involved in providing responses to is SER open Item I,

"Riverborne Missiles." Responses to this issue did not fully

address the staff's concerns and some of the assumptions used in

<

the analyses were not adequately stated. The staff feels PSE&G ,

'

management should have exhibited more control over his consul- '

tants on this item to ensure responses addressed the pertinent

issues.

'

The applicant responded to numerous SER open and confirmatory

items. Generally, PSE&G provided technically sound responses

and displayed an adequate understanding of the technical issues

i to be resolved. The applicant has been quick to identify and

i propose resolution for technical issues of safety concerns which

have been discovered in pre-operational testing. An example in

this case is the applicant's identification of induced voltage

problems with Bailey Solid State Control Modules. In this case

the applicant identified and detailed the concern and discussed

'

their proposed fix at an onsite neeting attended by Region I and

NRR personnel. Similar aggressiveness has also been experienced

i in the applicant's resolution of preservice inspection of corro-

i sion resistant clad piping.

i The applicant has been responsive to NRC initiatives. Responses

l to NRC Generic Letters, where required, have been timely, gener-

ally sound and thorough. However, ir this late stage of licens-

ing, PSE&G owes the staff a significant amount of information to

resolve all of the outstanding issues in support of a February

15, 1986 fuel load date,

'

j a

'

In April 1985, PSE&G underwent a corporate reorganization. The

i staff reviewed this new organization during a two-day audit in' i

1 July, 1985. The corporate organization is well defined on pa-

'

per, positons are described in detail and authorities and

!

\

. i

.

.

33

responsibilities are well defined. Key Management positions

remain open and have been an SER Open Item for over a year now.

The staff cannot resolve this issue until the positions are

filled. The applicant should have been more aggressive in the

filling of those positions.

In summary, a substantial licensing staff has been maintained to

assure quality responses to NRC concerns. PSE&G management has

exhibited involvement and control in Hope Creek licensing activ-

ities. PSE&G has provided technically sound and timely respons-

es to SER open items and has displayed an adequate understanding

of the technical issues to be resolved. The applicant has ra-

sponded to NRC initiatives in a timely fashion; however, in

light of the announced fuel load date of December 1, 1985, 11-

~

censing issues were not being resolved at a satisfactory rate

(for example, identification of system deferrals was sent in by

letter dated November 29, 1985). PSE&G management has undergone

a staff reorganization which resulted in positions with authori-

ty and responsibilities well defined. Still, key management

positions have remained open for over a year. Management ap-

,

pears to be taking a more active role in licensing concerns.

2. Conclusion

Rating: 2

Trend: Improving

3. Board Recommendations

f

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34

, V. SUPPORTING DATA AND SUMMARIES

l

A. Construction Deficiency Reports

Thirteen construction deficiency reports (CDRs) were reported during

this period. Table 4 presents the deficiencies according to type

(i.e personnel error, design error, component failure, etc.) and as a

function of SALP functional areas. As indicated in the table seven

of the thirteen CDRs were related to electrical and instrumentation

and controls construction activities. Performance in this functional

area is aiscussed in Section IV.8.

B. Investigations

! The NRC Office of Investigation completed two investigation during

this SALP assessment period. One was related to an allegation that

'

certain pipe spools supplied by Dravo were not properly inspected.

The second involved an allegation that certain calibration records

were falsified. Neither investigation resulted in any adverse find-

ings with regard to Hope Creek,

j C. Escalated Enforcement

i

l

'

There has never been any escalated enforcement actions associated

with Hope Creek.

.

D. Management Conferences

l

l The following management conferences were held during the assessment

period:

l

DATE SUBJECT

. October 22, 1984 NRC Inspection Program for the

Transition from Construction to

Operation

February 11, 1985 The System Turnover Process

l February 15, 1985 SALP for the Period August 1, 1983 -

l October 31, 1984

August 1, 1985 Simulator Response During the First

l Operator Cold Licensing Exams

l

l

!

- - _ - - _ _ _ _ _ - _ _ - - - _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ - _ . _ - . _ _ _ _ _ . - _ - . . - _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ - _ - _ - _ _ _ _ . - _ - - _ _ _ - _ _ _ _

. - . - . . .. .-

.

!

'

35

i

} TABLE 1

INSPECTION HOURS SUMMARY

(11/1/84 - 10/31/85)

-

Summary by Fuctional Area

FUNCTIONAL AREA HOURS  % OF TIME

l

,

A. Construction activities 1522 24.4

B. Electrical /I&C Construction 542 8.7

C. Quality Assurance 569 9.1

2

D. Preoperational Testing 1822 29.3

E. Plant Operations / Operational Readiness 809 13.0

F. Maintenance 143 2.3

j

!

G. Radiological Controls 295 4.7

j H. Security 59 1.0

I. Emergency Preparedness 467 7.5

1 J. Licensing * *

l.

'

TOTAL 6228 100.0

* Hours expended in facility license activities and operator license activities

i

not included in direct inspection effort statistics.

i

)

i

i

i

_-_-_-__-____-_______-._-__--_--_-_______-___-_-__--_-____________-__<

.

36

TABLE 2

INSPECTION REPORT ACTIVITIES

(11/1/84 - 10/31/85)

REPORT NO HOURS TYPE INSPECTED AREAS

84-19 66 S Preoperational Quality Assurance program.

84-20 54 S Preoperational testing.

84-21 170 S Electrical power supply and distribution.

84-22 -

R Preoperational management meeting.

84-23 - -

(Covered in 1984 SALP)

84-24 110 R Work in progress, preoperational testing, open

items, prevention maintenance. and system

turnovers.

84-25 32+37 5 Preservice inspection of piping systems / supports.

84-26 -

R SALP

'

84-27 61 S 0A/0C turnover procedures.

84-28 56 S Preoperational testing.

84-29 171 R Work in progress, preoperational testing, open

items, transition from construction to operations.

85-01 117 S Mechanical components, piping systems / supports.

0A and PSI.

85-02 44 5 Radiation protection, chemistry, and rad waste.

85-03 36 S Instrument components and control systems.

85-04 -

S (Cancelled)

85-05 74 R Construction, testing, and procedure review.

85-06 75 S Review of pre-op tests, system flushes, as-built

comparison, supports, and QA/QC.

- - . .. - . - - _-

.

-

.

37

REPORT N0 HOURS TYPE INSPECTED AREAS

,

85-07 NA R Management meeting on system turnover and control

room design.

85-08 473+168 S Independent measurements of safety related piping.

85-09 -

S (Cancelled)

!

85-10 34 5 Electrical power supply and distribution.

J

85-11 114 S QA/QC for pre-ops and startup testing.

] 85-12 94 5 Hydrostatic testing of the reactor vessel and ,

l associated piping.

1

85-13 53 S preoperational test procedure review / verification.

85-14 191 R Work in progress, preoperational testing, open

items.

85-15 104+9 S Piping systems and supports, PSI.

i

85-16 39 S Preoperational radiation protection program.

85-17 112 S Safety related electrical systems.

85-18 53 S Preoperational test procedure review / verification.

85-19 71 S Class 1 small pipe and pipe supports.

85-20 71+8 S Piping systems and supports.

! 85-21 72 S QA propram, instrumentation and control.

85-22 41 5 Safety related components,

j 85-23 72 S Electrical supply and distribution.

) 85-24 180+60 5 Support systems.

!

85-25 41 S Security program,

i 85-26 39 5 Preoperational testing.

1 85-27 307 R Work in progress, preoperational testing, open

items.

,

85-28 38 S Preservice inspection.

! l

J

l

l

.

!

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g

38

i

l

REPORT NO HOURS TYPE INSPECTED AREAS

85-29 -

L Operator and senior operator cold license exams.

i

85-30 70 S Preoperational testing and QA.

85-31 36+8 S Soils and foundations.

l

l 85-32 -

H Review of Independent Design Verification Program.

85-33 176 S OPS QA program.

85-34 34 S Electrical power supply and distribution.

85-35 249 R Work in progress, preoperational testing, open

items.

85-36 118 S Preoperational testing.

85-37 33 S Preservice inspection.

85-38 88 5 Preoperational QA program, OPS.

I 85-39 59 5 Instrumentation and controls, support systems.

85-40 283 S Emergency preparedness program appraisal.

85-41 270 S New fuel storage in high density spent fuel racks.

85-42 176 R Work in progress, preoperational testing, open

l items. .

85-43 -

L Operator licening meeting on simulator

performance.

85-44 81 S Radiation protection, chemistry, and rad wa'te.

85-45 208 R Work in progress, preoperational testing, open

items. .

l 85-46 35 S Preservice inspection.

85-47 112 S Preoperational inspection.

85-48 -

L Operator license exams.

85-49 -

L Operator license exams.

85-50 -

5 (Cancelled)

85-51 79 5 QA and preventive maintenance.

l

!

___ .__

- _ - . . _ -

.

,

l 39

l REPORT N0 HOURS TYPE INSPECTED AREAS

l

85-52 100+31 S Radiation protection, chemistry, and rad waste.

85-53 160 S Observation of annual full scale emergency

exersize.

85-54 -

H Review of Independent Design Verification Program.

Note: Key for TYPE of inspection; R - Resident Inspector, S - Specialist

Inspector, L - Operator Licening Activity, and H - Headquarters Inspection.

l

l

!

l

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40

TABLE 3

ENFORCEMENT DATA

(11/1/84 - 10/31/85)

Number and Severity Level of Violations

Severity level I 0

Severity level II 0

Severity level III O

Severity level IV 10

Severity level V 4

i

TOTAL 14

'

Violations Correlated by Functional Area i

FUNTIONAL SEVERITY LEVEL

AREAS I II III TV V

A. Construction activities

B. Electrical /I&C Construction

,

5 3 l

C. Quality Assurance

l

D. Preoperational Testing 4 l

E. Plant Operations / Operational Readiness

F. Maintenance 1 1

.

G. Radiological Controls

l H. Security

I. Emergency Preparedness

J. Licensing

TOTAL 10 4

.

o

41

TABLE 3 (CONT)

Summary of Violations

REPORT SEVERITY AREA NATURE

84-21 V B Two examples of improper installation of

electrical cables.

84-29 IV D Failure to follow procedures for control of

measuring and testing equipment.

85-01 IV F Preventive maintenance not established to

prevent DG component cor*osion.

85-03 V B Instrumentation tubing not appropriately

capped during construction work.

V B Lack of inspection of equipment released for

testing.

85-05 IV D Flushing systems with pipe hangers pinned.

85-10 IV B Cable trays not physically protected.

85-17 V F Preventive maintenance activities not

performed as scheduled.

85-27 IV D Three examples of failure to follow

preoperational test procedures.

85-35 IV D Three examples of FSAR committed testing not

being performed.

85-42 IV B Design bases of electri al computer alarm

points not correctly translated into

specifications and drawings.

85-45 IV B Failure to tie cables to cable tray rung.

85-51 IV B Inadequate design control for disposition of

NCRs on instrumentation.

IV '

, B Reversed wire-to-terminal connections on

instrumentation.

4

_ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ - - _ _ _ - _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - - _ _ .

.

4

. -

42

TABLE 4

CONSTRUCTION DEFICIENCY REPORTS

4

(11/1/84 - 10/31/85)

Type of Deficienc_y

1

TYPE NUMBER

A. Personnel Error...................... 1

B. De s i g n E rro r. . . . . . . . . . . . . . . . . . . . . . . . . 3

C. External Cause....................... 1

0. Defective Procedures................. 2

E. Component Failure.................... 3

F. Fabri cati on Erro r. . . . . . . . . . . . . . . . . . . . 3

4

Correlated By Functional Area

FUNCTIONAL AREA CAUSE CODE TOTAL

i

'

A. Construction activities 18,1E,1F 3

B. Electrical /I&C Construction 38,1C,2E,1F 7

C. Quality Assurance ID 1

D. Preoperational Testing IF 1

E. Plant Operations / Operational Readiness 0 0

F. Maintenance 1A 1

G. Radiological Controls 0 0

H. Security 0 0

I. Emergency Preparedness 0 0

J. Licensing 0 0

T3

- - _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ - _ _ _ _ - - - _ _ _ _ _ - _ _ _ _ - .