IR 05000272/1991017

Safety Insp Repts 50-272/91-17 & 50-311/91-17 on 910610-14. No Violations Noted.Major Areas Inspected:Review of Control of Station Procedures,Licensee Procedure Upgrade Project & Newly Issued Nuclear Administrative Procedures

ML18096A135
Person / Time
Site:	Salem
Issue date:	06/27/1991
From:	Baunack W, Blumberg N, Taylor D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18096A132	List: IR 05000272/1991017
References
50-272-91-17, 50-311-91-17, NUDOCS 9107170043
Download: ML18096A135 (9)

Text

Report No License N Licensee:

Facility Name:

Inspection.At:

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

50-272/91-17; 50~311/91-17 DPR 70; DPR 75 Public Service Gas and Electric Company P.O. Box 236 Hancocks Bridge, New Jer~ey 08038 Salem Units 1 & 2 Hancocks Bridge, New Jersey Inspection Conducted:

June 10 - 14, 1991 Inspectors:

W. Baunack,USr. Reactor Engineer D. Taylor,,;eactor Engineer Approved by:

N. Blumber 1 Date Inspection Summary:

Inspection on June 10 - 14, 1991 (Inspection Report No /91-17 and 50-311/91-17)

Areas Inspected:

Routine unannounced safety inspection by two region-based inspectors to review the control of station procedures, the licensee's Procedure Upgrade Project and the newly issued Nuclear Administrative Procedure Results:

The licensee's control of station procedures was found to be adequat Improvement has been noted in the Procedure Upgrade Projec Some concern was noted with the issuance of several Nuclear Administrative Procedure PDR ADOC~~ 05000272 _

G PDR

DETAILS Persons Contacted Attachment 1 provides a listing of pe~son~ contacted during the inspectio.0 Review of.Facility Procedures (42700) Verification of the Licensee 1 s Review and Approval Pro~ess Various procedures were selected at random and reviewed to verify that technical specification requireme~ts for review and approval of procedures are being complied wit (Documents re~iewed during the inspection are identified in Attachment 2).

Since the lice~see is currently implementing a Procedure Upgrade Project (PUP), all procedures selected for review were selected from new procedures issued as part of the PU A PUP manual specifies the process for the development, review, and control of procedures which fall under the scope of PU The PUP manual describes a review process which is significantly expanded over that which is required by the technical specifications.

. The revie~ of complete packages from PUP procedures, which have been issued, verified that adequate reviews had been performe Typical documents associated with review included in a procedure package

• are:

a procedure review signoff sheet (which includes verification by a Station Qualified Reviewer (SQR) review), a Procedure Review and Comment Form, a Discrepancy Evaluation Form, 10 CFR 50.59 Review and Safety Evaluation, an Implementing Department Review, and various checklists associated with review Overall, the review of procedures issued as part of the PUP included the reviews required by technical specification Technical Specifi-cations require a review by an SQR independent of the procedure prepare Administrative procedures were verified to have received Station Operations Review Committee (SORC) reviews as require.2 Verification that Procedure Changes were made to Reflect Technical Specification Revisions The procedure changes required by thr~e recently issued Technical Specification Amendments (Amendment Nos. 101, 102, and 103) were verified to have been incorporated into Station Procedure In addition, the licensee's process for assuring that license amendmerits are incorporated into appropriate documents was reviewe Station

.

Administrative Procedure AP-12, 11Technical Specification Surveillance Program, 11 describes the responsibilities of the station licensing engineer and the technical specification administrator as they pertain to the verification that license changes are incorporated

into appropriate document The records associated with the three amendments selected were complete and demonstrated that procedural requireme~ts had been adhered to in the processing of these amendment.3 Verification that Procedure Changes were made in Accordance with 50.59 Requirements Licensee Procedures NC~NA-AP.ZZ-0032(0), Preparation, Review and Approval of Procedures," and NC.NA-AP.ZZ-0059(Q),

11 10 CFR 50.59 Reviews and Safety Evaluation," provide the instructions necessary to assure that new or revised procedures are reviewed to assure that the requirements of 10 CFR 50.59 are evaluate For the newly-issued PUP procedures discussed in Paragraph 2.1, the 10 CFR 50.59 reviews and safety evaluations were verified to hav~ been performed in accordance with procedural requirements and were observed to be detailed and comprehensiv.4 Verification that On-The-Spot Changes to Procedures were Adequately Controlled The technical specificati-0n requirements as well as additional requirements related to the preparation of the on-the-spot changes (OTSCs) to procedures are described in Licensee Procedure NC.NA-A ZZ-0032(0) (NAP-32), "Preparation Review and Approval of Procedures.

The inspectors identified that the review requirements for temporary OTSCs were not as clear as the requirements for OTSCs which became permanent procedure change This was discussed with the license The licensee indicated that a major revision to the procedure is in the review process and is expected to be issued in Jul OTSCs are one area for which a clarification is planne The adherence to the requirements for OTSCs was verified by a random sampling of completed OTSC In all but one instance the changes were made in accordance with requirement One OTSC correcting a typographical error to Procedure SC.ND-CM.115-0001, 11 10 KVA Uninterruptible Power Supply Trouble Shooting and Repair, 11 prepared on March 7, 1991, was found not to have received the 14 day review and approval required by the technical specifications at the time of this inspectio When the licensee was informed of this matter, the required review was performed and a Plant Incident Report was prepare In addition, the licen~ee performed a 100% detailed review of all OTSCs made since 198 This review identified 684 OTSCs, Of these 684, three additional OTSCs were identified which did not receive the required 14 day revie None of the three additional OTSCs were made since the new Administrative Procedure, NAP-32 was issue Based on inspection findjngs as well as the review performed by the licensee; it is concluded that adequate measures are in place to assure OTSCs are reviewed as required and that the one identified since the new procedure was issued is an isolated instanc.5 Verification of Procedure Technical Content One system operation procedure and one maintenance procedure were reviewed for technical content, instruction compatibility with checklists, and appropriate technical informatio No deficien~ies were note To further evaluate the technical content of newly issued PUP procedures, discussions were held with operations and mai~tenance personnel who were users of these procedure Based on these discussions, it was determined that the newly issued PUP procedures are technically adequat.6 Verification That Procedures in Working Files are Current To verify that working files of procedures are current, a group o randomly selected operations and maintenance procedures were selected from the docket room computer listin The up-to-date listing of revisions for these procedures was compared to revisions contained in the control room and maintenance department working file In each instance, working files contained the latest revision of the procedur The inspectors noted that several OTSCs were still indicated on the computer for certain procedures for which the OTSC was no longer applicabl The licensee indicated this matter would be reviewe.0 Procedure Upgrade Project The status of the licensee's Procedure Upgrade Project (PUP) was reviewe Salem's PUP was developed in June of 1989 as an initiative to reduce the number of procedure related errors resulting, in part, from inadequate procedure During its onset, the project encountered significant problems which still affect it toda A number of these problems were reported in previous NRC Inspection Report No. 50-272/90-81; 50-311/90-81 and Salem's last SAL This inspection provides a current update of the project ahd an assessment of the quality of prbcedures being developed by the PU In addition, this inspection details the actions initiated by the licensee to overcome setbacks initially experienced with the projec In an attempt to enhance the project, the PUP was reorganized around September of 199 A new Project Manager and additional staff were assigne At that time, an adjustment to the project schedule was generated which more realistically reflected future goals for PUP progres As of June 9, 1991, 746 procedures had been issued and the upgrade project was estimated by the licensee to be about 33% complet The total scope of the project includes the issuance of about 3950 procedures and is scheduled to be finished by December 199 The inspectors review of the status as of May 31, 1991, indicates the project to be once again behind its projected sched~l However, a recovery schedule has been initiate A large part of the delays are attributed

to the last site outag Affected the most by the outage were the reviews and approvals conducted by plant personnel not directly involved with PU With the completion of the outage, increased progress in this area has been note A review of randomly selected appr.oved maintenance, I&C, and operations procedures was conducted to assess their qualit In general, the proced~res being approved for use are of good quality, and no technical errors were note However, the inspector 1 s review showed that PUP 1 s earli~r draft procedures issued for user review were poo This was evident by the numbers and types of comments being generated by the plant staf A similar review of more recently completed procedures indicated the quality of draft procedures to be much bette Although the newer procedures are of higher quality, there are still inconsistencies with format and conten Two years into the project, the licensee has still not developed a standard to manage such concern Examples noted by the inspectors included:

Drawings incorporated into procedures were inconsisten Some _

drawings were high quality computer generated while others were reproduced from manuals and of less qualit *

Wording of 11 standard paragraphs 11 varie *

Methods used to mark steps to point out certain requirements are ~nconsisten Some procedures mark a step number whereas others mark the enclosure which records the data required by the ste *

Several methods exist to mark steps requiring independent verificatio The inspectors noted that inconsistencies in procedures have been previously identified by the licensee and that actions have been taken or are planned to improve procedures in this are These and other improvements are discussed belo *

Considerable improvements in the PUP manual were made with the issuance of QA-PJ-ZZ-1013(0) in April 199 Additional improvements are in the process of being mad *

An administrative standard for format and content has been develope The standard is expected to be approved by mid-Jul *

Computer software used to develop procedures is in the process of being upgrade *

New graphics software has been purchased, and additional dedicated staff has been added for the purpose of enhancing drawing. 6

Human Factors training has been given to all the PUP staf *

A quality committee was organized in late 199 The committee has made recommendations on human factors and procedure consistenc *

A quality indicator was developed to track changes made to PUP approved procedure As more procedures are used in the field,*

the data generated by this indicator will become useful in determining PUP effectiveness and qualit Overall, improvements have been made by the licensee in the PUP projec The initial slow start achieved by PUP is being rectified by the many ongoing refinement The project continues to remain behind schedule; however, progress is being mad Although inconsistencies still appear to be a problem, the licensee is working to improve in this are The quality of procedures which have been issued appears to be goo * Nuclear Administrative Procedures During the review of PUP, the inspectors noted several deficiencies with governing administrative procedure Based on the perceived weakness, a limited review of Nuclear Administrative Procedures (NAPs) was performe The utility is in the process of upgrading and consolidating Hope Creek and S.alem administrative procedures into NAP NAPs are being developed to govern the administrative requirements for the entire site. Specifically, the inspectors reviewed NC.NA-AP.ZZ-32(Q), Rev. 0, 11 Preparation and Approval of Procedures, 11 and NC.NA-AP'.ZZ-OOOl(Q), Rev. 2, 11 Nuclear Department Procedure System.

During their review, the inspectors noted several deficiencie Examples of the types of deficiencies found are described below:

The inspectors noted that procedures referenced by both NAP-1 and NAP-32 were not yet issue Both of these documents have been in effect for greater than eight months; however, referenced documents still do not exis *

Step 4.3.6 of NAP-1 governs maintaining a procedure writer 1 s guid Specifically, Step 4.3.6.a states that the procedure writer 1 s guides shall be maintained as controlled documents and shall reflect the requirements of this procedure and NAP-3 The procedure writer 1 s guides are not currently controlled document Further, the document number referenced as the implementing procedures writer 1 s guide does not exis Based on these and other errors, the inspectors were concerned that administrative procedures were being sent to SORC for review while containing known error The inspectors brought this to the attention of

.the procedures sponsoring organizatio The Department Manager responsible for the procedures stated that both of these items were covered by the

implementing requirements listed on the cover page to NAP-3 Further, SORC was made aware of th~ inaccuracies prior to their recommending the procedure for approva However, eight months after both procedures were approved, requirements and references listed in the procedures were still not being implemented or issue The inspectors noted that both pro~edures have drafts in the review proces These drafts significantly revise the procedures and comprise improvements in many area The difficulty of issuing procedures which impact such a wide range of station activities is recognize Nevertheless, the importance of providing accurate admini-strative procedures cannot be minimize The inspectors had concern for the quality of procedures going out for review; however, based on the limited scope of the review, no conclusions could be draw~.

5.0 Exit Meeting Licen~ee management was informed of the scope and purpose of the inspection at the entrance meeting conducted on June 10, 199 The findings of the inspection were discussed periodically with licensee representatives during the course of the inspectio An exit was conducted on June 14, 1991, at which time the findings of the inspectors were presente Attachments: Persons Contacted Documents Reviewed

.ATTACHMENT 1 PERSONS CONTACTED Public Service Electric and Gas Company

• G. Bachman, Principal Joint Owner Representative

• D. Budzik, Maintenance Engineer

• T. Cellmer, Radiation Protection and Chemistry Manager

• B. Connor, Technical Staff Engineer B. Cornman, Operations Procedure Writer

• P. Duca, Delmarva Power

N. Dyck, Principal Engineer, QA/NSA C. Fenton, Senior Staff Engineer, QA

• A. Giardino, Manager QA Programs and Audit E. Hemmila, Technical Assurance Supervisor, PUP W. Holmes, Nuclear Shift Supervisor

• E. Liden, Manager, Offsite Safety Review

• M. Morroni, Technical Department Manager

• J. Pantazes, Procedure Upgrade Project Manager

• E. Villar, Station Licensing Engineer

• C. Vondra, General Manager, Salem Operations F. Wiltsee, Operations Supervisor; PUP United States Nuclear Regulatory Commission S. Barr, Resident Inspector S. Pindale, Resident Inspector T. Johnson, Senior Resident Inspector During the course of this inspection, the inspectors contacted other members of the licensee 1 s technical and administrative staff *Denotes those present at the exit meeting held on June 14, 1991:

'.r.

SI/S2.0P-SO.RHR-0002(0),

SC.MD-PM.ZZ-0040(0), Re SI.OP-SO.. RHR(O), Rev. *o, SC.MD-CM.AF-OOOl(Q), Re OP-II-4.3.2, Rev. 10, SI.OP-ST.SJ-0012(0), Re SI.OP-SO.DG-0003(0), Re NC.NA-AP.ZZ-OOOl(Q), Re NC.NA-AP.ZZ-0032(Q), Re * OA-PJ.ZZ-1031(0), Rev. 0'

AP-12, Rev. 10, NC.NA-AP.ZZ-0059(0), Re Re,

0'

0, 2'

0, 0,

ATTACHMENT 2 DOCUMENTS REVIEWED 0,

and 23 Terminating RHR Disassemble, Inspect and Reassemble Mark A-116 Check Valves Filling and Venting the RHR System Auxiliary Feedwater Terry Turbine Tappet Replacement Filling and Venting the Safety Injection System Emergency Core Cooling - ECCS Throttle Valves IC Diesel Generator Operation Nuclear Department Procedure System Preparation, Review and Approval of Procedures Procedure Upgrade Project Manual Technical Specification Surveillance Program 10 CFR 50.59 Reviews and Safety Evaluations Nuclear Department Procedure System Transition Plan Technical Specification Amendments, 101, 102, and 103