ML20141E789
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: |
References | |
50-354-85-99, NUDOCS 8602250376 | |
Download: ML20141E789 (44) | |
See also: IR 05000354/1985099
Text
-- .. . ._. . . . .- . _ , . _ ._..
.
,,
' '~
-
.
l
}
,
l
'
'
U.S. NUCLEAR REGULATORY COMMISSION
l REGION I
,
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
1
1
BOARD MEETING DATE: JANUARY 16, 1986
,
<
.
i
e602250376 860219
PDR- ADOCK 05000354
'
Q- PM
4
u___.___ _.-_m__.____._m._____
l
-
.
-
.
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
1
l
l
.
. _ _ .
-
.
1
1
.
I. Introduction
A. Purpose and Overview
The Systematic Assessment'of Licensee Performance (SALP) is an inte-
'
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.
i
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
,
- . - . . - . - .
~
.
J
-
.
g
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.
.
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.
.
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.
I
- . . - .-_ .
-
.
-
.
3
II. Criteria
,
^
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.
'
One c. more of the following evaluation criteria were used to assess each
functional area.
,
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
1
5. Reporting and analysis of reportable events
1 +
"
- 6. Staffing (including management)
4
- 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-
i
ment attention and involvement are aggressive and oriented toward nuclear
,
'
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.
'
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
!
follows:
f Improving: Licensee performance has generally improved over the last
4
quarter of the current SALP assessment period.
I
!
.
4
, - . - , _ ~e ,- - --,wn--,- ,+e-- , p----,---,,,-.s n, y c-w., -,,-r,- - ~ ,
aw--e . .
m-e
.
-
,
4
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.
.
l
l
.
!
l
.- - -.
-
-
f
-
.
5
-III. Summary of Results
2
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
.t
improvement were generally aggressively pursued.
.
Construction management maintained a positive attitude, was appropri-
ately involved in resolving issues, and used a variety of approaches
,
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.
.
The preoperational testing function is well-staffed with experienced
, personnel. The Code Hydrostatic Test was especially well-controlled.
- ,
'
Nonetheless, some problems have been noted in procedure scope and ,
J
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
a
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
>
programs.
i The assessments presented in this report are based largely on review
I.
'
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.
2
.- . - -. .
.. ... - - . . - . . .
,
..
-
.
3 6
1
j B. Facility Performance
Catego ry Category Recent
4 Functional Area last Period This Period Trend
Construction Activities 1/2* 1 Consistent
1
1 Electrical and I&C
l Construction 2 2 NA**
1
( Quality Assurance 1 1 Consistent
j Preoperational Testing 2 2 NA**
i
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.
i
4
I
.t
3
i
!
!
I
,
. . - . . -- . . ..
'
~
. .+
. 7
IV PERFORMANCE ANALYSIS
l
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
4
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
i
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
'
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.
!
- 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
,
'
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
!
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
i
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-
!
tional area.
,
,-, . - . - - , , -n s -m.-, . - - - - ,
-
,
-
.
8
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.
I
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
l
l
- _ ~ - . . - - - -. -_ . ... - -. .. - - __
l4
l
'
9
1
,
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-
l
'
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
l
l
l
__ _ _ _ _ _ _ _ _ ___ _ _ _ - _ _ - _ __ _ _ _ _ _ __ _ _ _ - _ _ _ -
. _ . . _ . . _. _ .
_ _ . _ _ . _ _ _ _ _
-
~
i
4
.
'
!
10
,
! from static water accumulation and potential corrosion. Applicant
response to this NRC identified problem was effective.
.
.
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 .
.
of management's involvement is the thorough safe shut down analysis
!
'
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, .
'
!
emphasized a review of hardware installation and review of technical
< and design documents. PSE&G management involvement was evident in -
,
various aspects of HVAC installations. Surveillance programs of site
contractors were found to be timely and thorough. Bechtel site engi- '
<
neering was found to be knowledgeable and technically sound in ad-
>
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-
4
ties related to HVAC installations was observed.
.;
2. Conclusion
l
} Rating: Category 1
! Trend: Consistent
i
3. Board Recommendations
Licensee: Complete prompt closure of outstanding open items.
-
NRC: None -
l
1
) i
i
4
/
r
_ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ . . . _ _ _ . . _ . _ _ . _ _ _ _ _ . _ _ _ . _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
_ _ - . - - - ._ _ _ _ _ _ _ _ . _ _ . _ __ _ .
,M
-
.
11
'
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 />) -
4
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-
I
plines. Eight inspections were conducted in this area, five
primarily in electrical, and three primarily in I&C.
i
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-
!'
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).
1
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:
--
Confusion over pH responsibility for equipment released for
- test (RFT) resulted in removal of space heating from six-
teen electrical components (Inspection 84-21).
--
There was confusion among construction and start-up person-
nel regarding QC involvement in the RFT program (Inspection
85-03).
'
--
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,
f
--
Construction activities, access controls, and preventive
-
maintenance were not well-coordinated in certain plant ar-
, eas having safety related electrical power supply and dis- l
tribution equipment (Inspection 85-17).
i --
Class IE Unit Substation logic design was not properly
.
'
translated into drawings. Further, an opportunity to iden-
J
tify the deficiency during testing was missed due to
!
,
-- - .-.g ,.--g---.w.e .--,-,w- , , , , - , - - - -----~a-----,r ,,..m,vr--,-,- - ,v--- m ----,,~e---- -r,,*y,se. - - - g -r- --e,v- - - - n- - , ~ w +-,-w -m,
- . - . . _ . - - . - . - . - . -._- - _ .. . .-
-
-
!. -
<
12
j
f insufficient involvement of engineering personnel (Inspec-
!
tion 85-42).
,
! --
Cable tie-ups were not reinstalled or reinspected after
,
'
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,
l
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-
'
I
i tion deficiencies were evaluated appropriately and corrective '
i actions were usually thorough and technically sound. '
-
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 ,
1
preliminarily that significant improvements have been made, NRC i
f review of the system is not yet complete. '
!
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
,
i
!
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
'
ICD card, so that calibration data and setpoint information can !
be kept up-to-date.
e
l Although the licensee was generally thorough and aggressive in
i
addressing problems in this area, particular emphasis should be
placed on identifying possible electrical and I&C problems dur- ,
ing test results review. '
4
l 2. Conclusion
j Rating: Category 2 ;
i
I Trend: NA >
l
l
- 6
i
.
'
13
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.
- - . .- -- -- .. .- - - - . _ - - . _ _ - ..
~
.
l'
-
.
-14
i
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
1
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
4
strong QA programs; this has had a beneficial impact on project
3
quality. Project management has demonstrated a support of QA.
The various project communications mechanisms, (mentioned in
!
'
Functional Area A, Construction) contain-frequent discussions,
4
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
,
_ _ _ _ __ _ . - - _ _ _
_ _ _ _ _ _ _ _ _ _
.
-
,. )
'
> _ ,
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
!
_ _ . _ _ _ _ _ . _
'
, ,cp . .n
-
.
, . 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
'
!
-
s
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
.
!
l -
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.
85-34 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
1
I
!
l
i
!
'
.
.
40
TABLE 3
ENFORCEMENT DATA
(11/1/84 - 10/31/85)
Number and Severity Level of Violations
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
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
- - _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ - _ _ _ _ - - - _ _ _ _ _ - _ _ _ _ - .