IR 05000272/1991030

Insp Repts 50-272/91-30,50-311/91-30 & 50-354/91-23 on 911202-13.Three Noncited Violations Noted.Major Areas Inspected:Adequacy of Engineering & Technical Support for Plant Operation,Training & Engineering Performance

ML18096A537
Person / Time
Site:	Salem, Hope Creek
Issue date:	02/04/1992
From:	Anderson C, Koch G, Paolino R, Woodard C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18096A535	List: IR 05000272/1991030 ML18096A534
References
50-272-91-30, 50-311-91-30, 50-354-91-23, NUDOCS 9202280043
Download: ML18096A537 (24)

Text

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report Nos. 50-272/91-30 50-311/91-30 50-354/91-23.

Docket Nos. 50-272 50-311 50-354 License Nos. DPR-70 DPR-75 NPF-57

.Licensee:.

Public Service Electric & Gas Company 80 Park Plaza -17C Newark. New Jersey Facility:

Salem 1&2 and Hope Creek Generating Stations I~spection at: * Hancocks Bridge. New Jersey Inspection Conducted:

December 2-13. 1991 Inspectors:

<::luL)t.I' ~-

Carl H. Woodard, Reactor Engineer, Electrical Section, EB, DRS R~

Pa<>iiilO,Sr: Reactor Engineer, Electrical Section, EB, DRS Ma~.rialjs Seen~ EB, DRS Approved by: __ v_* ___ (AJ/u_

__ -=-----------

c. J. lnderson, Chief, Electrical _

Section, Engineering Branch, DRS 9202280043 920214 PDR ADOCK 05000272 G

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PDR Date

Date *

Date

Inspection Summary:

Area Inspected:* An announced inspection was performed to assess the adequacy of the licensee's engineering and technical support for the operation of the Salem and Hope Creek plants. This inspection reviewed the engineering organization, staffing, communications, training, management support, and engineering performanc *

Results: The licensee has made improvements in several areas including procurement engineering, configuration baseline documentation, planning and scheduling of engineering work activities, and in the implementation and routine use of performance indicators in key engineering areas. Several non cited violations were identified regarding engineering procedures and a non-cited violation was identified in which a decision affecting a temporary modification was made by a system engirieer without consulting with the appropriate engineering organizatio Overall, the licensee's engineering and technical support were considered to be adequate.

3 Purpose This inspection was conducted to assess the adequacy of the licensee's engineering and technical support for the operation of Salem 1, Salem 2 and -Hope Creek nuclear generating stations. It also included an assessment of corporate goals, commitments to provide adequate engineering and technical support resources and an evaluation of how well these resources are use.0 Corporate Support Corporate support to the Nuclear Department portion of the corporation was assessed by:

• A review of the 1989 and 1990 Annual Reports to Shareholders in which commitments to the Salem and Hope Creek plants are enumerate *

A review of the Nuclear Department Capital Budget Report, September 1991, in which capital projects and their status are reporte *

A review of the Nuclear Department Business Plan, November 1991,*in which the status of planned and ongoing projects is reported.

Interviews with the Nuclear Department Strategic Planning Manager in which the current, short range and long range planning for engineeririg support are discusse This inspection revealed corporate commitment with a stated.goal to become the

"premier electric company in the Northeast with national recognition". Both the budget and business plan reflect this commitment by the funding of required project. 0 Engineering Organizations Engineering and technical support for the Salem and Hope Creek plants are provided by three organizations; Technical Support Systems Engineering, Nuclear Fuel, and Engineering and Plant Betterment (E&PB). Each of these organizations is a part of a matrix type organization and reports through its own management to the Vice President and Chief Nuclear Officer of the Company.

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System Engineering Each plant has a technic8.I support system engineering department that is lOca.ted within the protected area, and reports directly to the operations station manager. * The department consists of six* groups: reactor and plant*

performance, electrical engineering, instrumentation and control, nuclear steam supply systems,.balance of plant systems, and administration and plannin This department is resp0nsible for engineering small scale plant modifications, including temporary modifications, plant system' specific engineering, day to day operations technical support, and support of each plant's maintenance department. A system engineer is assigned to each plant syste Engineering and Plant Betterment Engineering and Plant Betterment (E&PB) is responsible for engineering

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support of plant operations not performed by System Engineering. This includes supporting operations such as: licensing, specialized technical

• . expertise, configuration management control, management and engineering for

• major projects at each plant and for projects common to all plants and the sit E&PB is under the direction of the Vice President of Nuclear Engineerin The E&PB organization is divided into functional areas. These areas include:

Engineering Design, Licen.sing and Regulation, Nuclear Engineering and Projects Service, Salem Material Condition Revitalization, Nuclear Engineering Projects and Performance Enhancement. These departments provide engineering support to the Hope Creek and Salem plant.2.1 Nuclear Engineering Projects This department consists of three functional areas responsible for

• providing project management for planned modifications at each of the plants and for engineering activities common to all plants and the sit A project manager is assigned to each modificatio *

3.2.2 Nuclear Engineering Design This department is responsible to provide support for nuclear engineering projects in the areas of engineering and design standards, engineering procedures, mechanical, civil and electrical engineering, instrumentation and control, material, seismic and stress analyses, fire protection and engineering assessment. In addition, highly specialized technical consultants provide services to the E&PB through this departmen **

• .2.3 Nuclear Licensing and Regulation This department.consists of four functional areas namely, Hope Creek Station Licensing, Environmental Licensing, Salem Licensing, and Nuclear Licensin *

3.2.4 Salem Material Condition Revitalization This department is responsible for re-establishing and upgrading the material condition of the Salem plants by improving the equipment, systems and facilitie.2.5 Performance Enhancement This is a staff group which is responsible for establishing performance indicators (PI), evaluating PI's and assisting management in the implementation of performance enhancement projects for the plant Nuclear Fuel This. department is located within the E&PB facilities and it reports directly to the Vice President of Nuclear Operations. The Nuclear Fuel Department consists of three functional areas which are responsible for providing for nuclear fuel planning and procurement, engineering analysis, and safety evaluation and licensing activities for the Hope Creek and Salem plants..

Conclusions The licensee's engineering organization is capable of providing effective engineering services to the plants. The use of project managers assures that one individual is responsible for the. correct design and installation of major modifications, and that the individuals responsible are knowledgeable of the specific plant configuration and

• requirements. The use of a systems engineering concept provides a technical presence in the day to day operation and maintenance of the major systems.

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6 Engineering Resources The inspectors reviewed. the licensee's engineering resources (facilities, equipment,

• and personnel) to assess their adequacy in supporting the needs. of the operating plan These resources should l?e organized and* managed to identify,. schedule, *and complete tasks in an effective and timely manner. As a oonsequence of previously identified and on-going needs, the licensee has established engineering resources within the operating plants and immediately adjacent to the plants. In the past these resources have been considered adequate to support plant operations. However, through experience, industry initiatives, and audits, the licensee has identified needs for.

additional resources and for the better utilization of certain resource.1.3 Facilities Physical facilities consists of office areas within the operating plants and a large engineering office building immediately adjacent to the plant. Mobile office units provide additional facilities for engineering personnel. Inspection of these facilities revealed that they were fully-utilized, and are considered.

adequate to provide for the offices, services, and equipment required by the engineering.supi>ort personnel.* A review of the corporate long range business

. plan revealed plans to provide additional-permanent engineering facilities in the E&PB area with engineering design for these facilities to begin during 199 Equipment Engineering equipment consists of all those devices and machines which enable personnel to perform their functions. The inspectors found that engineering personnel are provided with strategically located computer terminals. These

. terminals provide the }>enefit of the timely acquisition of historical and current engineering and maintenance information. Engineering personnel are provided with support equipment and software which enables them to process this information in a timely and efficient manner into outputs which provide good support to plant operation Personnel Engineering and Technical Support and Nuclear Fuels Engineering staff located in the E&PB facilities include 409 authorized positions of which 398 were filled at the time of this inspection. Of the 409 positions, approximately 340 are engineers, designers, supervisors and managers, and the remainder are drafters, clerks and secretaries. The Station Technical Engineering staff consists of 85 engineers. Approximately 55 % work at the Salem plants. In addition, there are approximately 200 in-:-house contract engineering staff personnel. Contractors from architect engineering companies perform

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approximately 50% of the E&PB Design Change Package (DCP) work in their own offsite facilities. The engineering organizations are staffed in all technical disciplines. The licensee informed the inspectors that by use of contract engineering personnel to provide for periods of high engineering demand~ they are able tO maintain a stable permanent staff of experienced engineers 'with low personnel turnover. Contract personnel are* directed by licensee staff and are trained in the licensee's procedure In general, all engineers and management personnel have degrees in the appropriate disciplines. In addition, there are approximately 100 individuals

• holding advanced degrees, including 12 individuals who have doctorate degrees. There are 120 memberships in professional and technical societies and more than IO individuals represent the licensee on various owner group The average experience of the staff is about 12 years in the nuclear industr Turnover rate is approximately 3.6% per year, most of which is due to retirement. Based upon a review of the licensee's staffing of the engineering, organizations, the inspectors concluded that the licensee has achieved staffing objectives and personnel positions have been adequately matched to education and experienc The inspectors concluded that. the licensee's resources were adequate to support *their engineering and technical support objective Engineering Performance The inspectors assessed engineering performance by conducting:

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Reviews of the engineering responsibilities and organizations for coverage of operations requirements and interface Reviews of applicable procedures for adequacy and compliance with codes, standards and regulation Interviews with selected engineering, operations and maintenance personnel to evaluate their understanding and roles in accomplishing engineering activitie Reviews of selected engineering modifications and temporary modification packages to evaluate their quality and acceptability in* meeting their intended function *

Reviews of self assessments.

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Engineering Responsibilities. Organization and Procedures Engineering responsibilities and support for activities of the Salem and Hope

• Creek facilities are delineated in Procedure No. NC.VP-PO.ZZ-0006(Q). The activities include the typical engineering disciplines (mechanical, civil, electrical, instrumentation and control) that are involved in the management of specified projects, system.and program analysis, engineering and problem assessment and standards development. Engineering responsibilities and support for the station trending program are delineated in Procedure NC.NA-AP.ZZ-0048(Q). The trending program is appropriately administered in two plant procedures SE-AP.ZZ-048 at Hope Creek and TD-13 at Salem 1 & The Engineering and Plant Betterment (E&PB) department is the design authority of record for the nuclear group. Responsibilities include developing and maintaining configuration management and design control procedure Station technical managers provide the day-to-day engineering support of station operations utilizing a systems engineering approach with assistance -

from E&PB as require E&PB generally assumes long term, larger scope or more complex engineering responsibilities as requested by station management. Under the station system engineering concept, engineering responsibility for individual systems is assigned to specific system engineers who report to the station technical manager through group supervisors. System engineers interface directly with E&PB, maintenance, nuclear services and operations organizations as necessar System engineering responsibilities include:

monitoring of station equipment and trending

routine assessment of station equipment

review of design change, packages prior/post completion

temporary modifications design package development, implementation, closeout E&PB engineers perform: _

long term projects/tasks/studies/scope proposals

modification change package development, implementation, closeout

supplemental engineering support to stations

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• configuration management control E&PB work activities generally fall into two categories: Functional work, which involves a single discipline or is programmatic in nature; project work, which requires multiple discipline interface. An engineering work request (EWR) is used to solicit functional support from E&PB. Project work is pre-planned and entered on a work list for the year. Change Packages are processed and closed-out through Procedure No. NC-AP.ZZ-0008(Q). This procedure establishes a uniform method for-controlling the design -and configuration changes for Salem and Hope Creek generating stations. Change package documentation is specific to the type of change involved. A *

standardized table of contents may be constructed for each type of change package and used in controlling* package contents. Expedited Change Packages contain the minimum essential documentation, con_sisting of completed cover sheet, table of contents, lOCFR 50.59 review and safety evaluation, design verifications and any other documentation necessary for the reviewer to adequately confirm that the package meets the intent of the chang Preassembled standard engineering change package workbooks; along with additional forms and continuation sheets are available through the E&PB Nuclear Standards Engineering Manager and the Station Technical Department managers. * The workbooks provide guidance and uniformity in performing design calculations and analyses, identifying design input, replacement and configuration change package, identifying plant document discrepancies and as-built documentatio Engineering and Plant Betterment Performance E&PB performance was assessed by conducting a detailed review of seven design change packages: These packages were assessed for overall quality, timeliness, and conformance with all applicable requirements and procedure * -

DCR 4HC-0195, Hope Creek design change modification involving replacement of inboard/outboard containment isolation valves 1BB-SV4310 and 1BB-SV4311 with Valcor valves along with inlet/outlet spools. Package closeout dated May 2, 199 *

DCR 2SC-2032, Salem Unit 2 modification involving the vital &

essential UPS bus. Package closeout dated January U, 199 *

DCR lEC-2122, Salem Unit 1 design change package involving current and voltage traces for the containment fan eooling unit (No. l lCFCV)

motor (coupled/uncoupled). Package closeout dated October 2, 1989.

DCR 2SC-2165, Salem Unit 2 design change package involving service water pipe replacement. Package closeout dated January 4, 199 *

DCR 2SE2001, Salem Unit 2 design change package involving backup protection for electrical penetratio *

DCR lEC-3032, Salem Unit 1 design change package involving wiring changes. Package closeout dated January 9~ 199 *

DCR lSC-2272, Salem Unit 1 design change package involving control-circuitry modification for motor starting coil and monitoring lights for SJ49 valves. Package closeout dated January 24, 199 These design change packages were well organized, complete and _in accordance with the applicable procedures. Materials, process parts and equipment were properly identified. Potential safety hazards were addresse Independent reviews were performed by persons other than the original designer. lOCFR 50.59 applicability reviews and safety evaluatioQs were performed as required. Safety evaluations were descriptive and supported the conclusions. Modifications were reviewed and approved by the site operations review committee (SORC). The design drawings and operations procedures were revised as necessary for the completed work packages. The required reporting of modifications was done in accordance with established procedure The test results met the acceptance criteria described in the applicable test procedure. - The quality of these design change packages and their compliance*

with the established procedures and timeliness was goo.2.1 E&PB Performance Enhancement Department The inspectors reviewed the functions of the E&PB staff organization, the Performance Enhancement Department (PED) in order to assess its functions and effectiveness in improving engineering performanc This review disclosed that performance assessments are made by PED in most key engineering areas. In addition to the timeliness of -

engineering performance, assessments are made in the areas of quality, safety, productivity, effectiveness and efficiency. Engineering's performance is measured by established month to month goals which are projected to cover a full year of activity. For many areas the actual achievements and goals are compared to the industry experience to provide additional perspective to the measurement. PED provides each manager and the vi~e president of nuclear engineering a monthly update of their performance which includes the graphic charts to provide visibility of past and present performance against the established goals.

These performance indicator reports are a topic of scheduled monthly

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meetings of senior management and of individual and group meetings - *

of engineering management. The inspector reviewed performance indicators.reports and charts including those for the following activities:

• Overdue Items Action Tracking System. Goal - none overdue:

actual less than 1 %.

M<>9ification documents (DCP, etc.) returned for engineering changes. Goal - less than 13%; actual approximately 11 %.

Safety evaluations quality. Goal - 93 % ; actual approximately 95%.

Project status reports timeliness of performance. Goal - 95 % ;

actual approximately 91 %.

Accomplishment of key projeet milestones as scheduled. Goal -

at least 85 % of the time; actual approximately 95 %. *

The inspectors concluded that PED's contribution to engineering performance is a positive initiative. It provides the visible goals and tracking to enable management to address problems in a timely manne System Engineering Performance This inspection was made to ascertain the effectiveness of Systems Engineering in accomplishing its basic objective of improving station reliability and safety by providing the proper technical support and guidarice. To meet this end, managers. were interviewed to learn how plant reliability improvement is factored into departmental goals and determine their success in meeting these goals. Selected procedures were studied to determine their adequacy in controlling system engineer functions. Meetings were held with system engineers to understand the extent that plant and equipment variables were being monitored and learn what actions are taken to effect improvement *Selected temporary modifications (T-Mods)_ wete reviewed.* From these actions, conclusions were drawn concerning the competence station technical personnel, compliance to requirements, and trends.

5. 3.1 Temporary Modifications System engineers are responsible for administering the program which controls T-Mods. This program is delineated in station procedure

.NC.NA-AP.ZZ-0013(Q). It is defined for the individual plants through sy.stem engineering procedures T-21 for Salem and HC.SE-AP.ZZ-0013(Q) for Hope Creek. The procedures were reviewed to determine conformance to regulatory requirements and found to be satisfactor Appropriate procedural controls were found to insure that design and operability considerations were addressed prlor to installation, and that.

removal of T-Mods were completed at the earliest possibility. All T-Mods require a lOCFR 50.59 review by procedure. The adequacy of this and other portions of the package are controlled by multiple reviews beginning in the System Engineering Section and ending with the Station Operating Review Committee (SORC). Daily operations personnel are made aware of active T-Mods by requiring shift supervisor. review and approval, making them custodian of the active*

modification package, logging modifications and identifying the modification by a tag. Verification of tagging, logging, and shift supervisor custody of the paperwork was performed during the inspection.

Temporary modification packages were reviewed from each plant to verify the adequacy of the technical content and conformance to plant procedures. These packages were: *

T-Mod 91-022 (Salem) Temporary Enclosure of Valve 22AF22 to effect a temporary leak repai *

T-Mod 90-010 (Salem) Temporary Patch on Service Water Header

T-Mod 91-008 (HC) Temporary modification to install flange face insert between a CRD pump flange and mating piping

T-Mod 91-032 (HC) Temporary modification to jumper out Hi/Hi water level alarm in #4B Feedwater Heate.

This review revealed that the station procedure HC.SE-AP.ZZ-0013(Q)

was not followed in the preparation of T-Mod 91-008. Paragraphs 5.1.3 and 5.1.4 require the system engineer to consult with the Engineering and Plant Betterment Department when certain conditions are not met. The procedure requires the system engineer to *use a checkli~t as guidance to define these conditions and insure that

decisions are made by persons with the most knowledge of the subjec In this case, the system engineer documented his judgement but did not consult with the E&PB engineer. This is a non-cited violation of lOCFR 50, Appendix B, Criterion V, in that an activity affecting

. quaiity was not performed in accordance with established procedures (50-354/91-23-01). Subsequent review by system engineering management proved that this was an isolated instance and a review by the appropriate E&PB engineering group showed that the initial technical judgement was acceptable. All other T-Mod packages were judged to be acceptabl This violation will not be subject to enforcement action because the licensee's actions meet the criteria specified in Section V.G. of the Enforcement Polic The specific subjects of T-Mods were studied and showed that leak repairs, temporary lighting, temporary patches, temporary air ser\\rice, and temporary bypassing of electrical instrumentation comprised the majority of temporary modifications. These subjects are considered appropriate for T-Mods and no evidence surfaced to suggest that the standard design change system was being circumvented. The length of time that T-Mods are installed is controlled by requiring the system-engineer to estimate removal date and managing the T-Mod status against that date on a weekly basis. In addition system engineering managers are required to review the active T-Mods on a monthly basis and report to the SORC. This management is effective as the inspection of the T-Mods logs showed that they are being removed routinely rather than waiting to clear all T-Mods during outages. The inspectors concluded that the overall quality of the T-Mods, compliance with established procedures, and timeliness was goo.3.2 Equipment and Systems Performance and Reliability Individual system engineers are responsible for. trending performance of selected equipment within.their assigned systems. The criteria for selecting candidates for performance parameter trending is shown in the procedures and are consistent with the goal of improving plant safety and reliability.* The procedures indicate the use of trend charts and

.parameter alarm limits, and evidence of limits was seen during the inspection on the charts being used by the system engineers. Each engineer is responsible for determining where the alarm. limit is to be established when the alarm limits are not given in regulatory documents. The inspector reviewed trend charts for vibration

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monitoring in selected portions of the balance of plant as well as lubricating oil analysis which are not governed by regulatory documents. The limits were appropriate in all cases. However, the fact that the procedures cio not give the engineer guidance in *

establishing alarm limits is viewed as a weakne8s. Consistency in establishing alarms would assure that the level of performance desired by station management is maintaine By procedure, system engineering is also responsible for the routine

• assessment of station equipment performance. This is formally -

accc>mplished by system: engineering issuing reports to the plant general managers at both Salem and Hope Creek. A variety of performance characteristics are monitored for these reports including safety system and diesel availability with INPO recommended methods used for determining availability. Plant performance is compared to established plant goals and INPO medians.* Hope Creek plant goals for monthly diesel.and safety systems are 99% available. The plant's operating experience is nearly 99% for both characteristics during 1991. Similar reports are issued at the Salem units for auxiliary feedwater, diesels, and safety injection systems. Plant goals for availability are 98 % for all systems..

To be effective in improving reliability and safety, actions must result from engineers witnessing adverse conditions. The inspector observed *

appropriate actions in both stations. At Salem, #11 steam generator feed pump was exhibiting random vibration levels and the system engineer arranged.for the placement of additional sensors to better define the condition. Also component cooling pump 2CCE3 exceeded the alarm level for vibration. *A work order was issued to repair the bearings and vibration levels were reduced to acceptable levels. At Hope Creek, trending revealed that battery capacity was being reduce * corrective actions were take System Engineering has access to other information that is used to monitor reliability and performanee of equipment and systems. The Nuclear Department Work Request system (NDRAP), is a computerized data base which includes engineering and maintenance work requests that can be used to reveal maintenance history of

• components or systems and is* available at both the Salem station Hope Creek has access to NDRAP and another system (CRIDS) which captures performance characteristics from selected plant equipmen All system engineers interviewed had computer terminals to access the information. They demonstrated proficiency in the use of these systems during the inspectio **

Tw~ management approaches to improving system engineering -

effectiveness were witnessed during the inspection. System engineenng management at Salem develops departmental goals such as reduction of the number of T-Mods, reduction in the number of overdue action items, and continued expansion of trending. These goals have been distributed to the individual engineers to insure that all know the department expectations and direction. Hope Creek system engineering management works to the plant goals -and relies upon the engineering staff to function in a manner that will support them. At this time, both approaches appear to be adequate since station operating goals are being me.3.3' Conclusion The system engineering sections at Salem and Hope Creek are effective in contributing towards plant reliability. System engineers are using the trending and other information programs to determine the condition of their respective systems and develop corrections before failures occur. This has resulted in plant performance that is either bettering or is approaching plant goals. Procurement Engineering

• The inspector reviewed the Engineering Procurement and Materials Control Department activities in order to assess the adequacy of their support to ensure proper materials, items and equipment for the plant Procurement is performed in accordance with Procedure 1XC.NA-AP.ZZ-0019(Q).

This procedure is complimented by other procedures including DE-AP.ZZ-0016(Q),

"Procurement Classification Guidelines" and*DE-AP.ZZ-0024(Q), "Commercial Grade Dedication Program". These procedures are adequat The Engineering Procurement Department has established an approved procurement description for all items in the plants for which procurement requirements have been identified. These descriptions include all of the physical, testing, and software requirements for each item including such things as industry code, quality assurance specification, testing and supporting documentation. The identification descriptions are in a computerized database and are maintained on hard copy in the procurement files. Orders for items are placed utilizing these descriptions as the approved requirements for the item. During 1989 and 1990 tlie licensee developed, trial tested,

_and then began the implementation of a computerized Warehouse Automated

Materials Management System (W AMMS) in October of 1990. This system replaces a manual material requisitioning/procurement system which required manual entries for each procurement with the potential for errors. -The W AMMS system is now

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fully loaded with all identified procurement items. Controls are in place to ensure security of the data by limited aecess and the redundant approvals which are required

. to make data entry changes. Each engineer is able to access the system at a computer

• terminal to review item descriptions and obtain a hard copy printout if desire Previously this would have* required retrieval of hard copies from files. The inspector witnessed engineering access into the system and obtained pnnt outs for _specific parts. This system is a positive procurement system initiativ A review was made of the licensees commercial grade item dedication program (CGDP). This review revealed that until 1990 the licensee had no formalized procedures for accomplishing this dedication. Licensee personnel had worked closely with EPRI in the development of the EPRI commercial dedication program guideline The licensee's program in Procedure DC-AP.ZZ-0024 is based upon the EPRI guidelines and is now fully implemented. One of the licensee personnel responsible for the development and implementation of the PSEG program had been on loan to EPRI during the preceding year assisting other utilities in developing and implementing their own commercial dedication program The inspector reviewed the commercial dedication of a compressor crankshaft and an electronic pin type connector and found that these dedications were accomplished in accordance with the licensee's procedures. Based upon this review.. the inspector found that the licensee's procurement activities and procedures provide good support to ensure the proper materials to the plant Prioritizing of Engineering Activities The licensee has established a Nuclear Department Resources Allocation Program

• (NDRAP) during the last half of 1990. According to the licensee, the NDRAP computerized program replaces a manual prioritizing system which required dozens of meetings and was subject to significant errors and much confusion in attempting to prioritize and re-prioritize several hundred work item each time a new work items was added or the emphasis changed on an existing work item. The NDRAP program is described in detail by Procedure NC.NA-AP.ZZ-0065(Z). The stated purpose of this program is "to assure that Nuclear Department Resources are properly applied to the programs, projects or tasks which are most important to the Nuclear Department".

The procedure is used to screen and prioritize each work item in accordance with a uniform, common, accepted prioritization and scoring system. Some of the benefits recognized by the licensee include the ability to focus resources on the most important items of work, improved planning of work, schedular and cost benefits. During 1991, the licensee had effectively implemented NDRAP by being able to priontize old and riew work on an on-going basis with each new work item entered into the computerized program with its appropriate weighting factors and then being ranked against all other work in the system such that it receives the proper priority. The licensee reports that their planning cycle has been improved by approximately six

• - months. The NDRAP program has been recognized by INPO as well as other licensee's as a significant program for improvement in work planning. Other licensee's had requested and obtained training in NDRAP from PSEG. The inspectors concluded that the licensee's prioritization program for engineering activities was good and that the NDRAP program is a positive initiativ Salem Revitalization Project The Salem Revitalization Project is discussed in the "Study of Material Condition of the Salem Plant's," dated September 7, 1990. The project objectives include improvements in the plant material condition by means of improvements in components, equipment, and systems to achieve significant increases in reliability that result in improved plant safety and availability..

A review was made of the Nuclear Engineering Departments portion of this projec In May 1991, the licensee established a separate matrix type engineering organization which reports to the Manager of Nuclear Engineering Design. This organization has its own management and dedicated staff which is supported by its own dedicated contractors. This project organization allows it to function in a manner which minimizes the impact of its*work on any of the other PSE&G engineering departments resources, The revitalization project initially identified approximately 109 material upgrade projects. Approximately 30 of the projects which were identified as high station priority and which require minimal engineering effort have progressed through preliminary design and have been approved for final design and construction. A cursory review was made of revitalization preliminary design packages for two of the projects. Most of the projects now in design are scheduled for construction during 1992 except those requiring an outage. The licensee has scheduled the longer term, larger scope projects which may require significant engineering effort for completion by the end of 199 *

The inspector concluded that Salem revitalization is a project to which the licensee is fully committed. It is considered to be a positive commitment by the licensee to improve plant r~eliability and safet * Regulatory Communications A review was made to assess engineering response to selected regulatory commission communications as follow *

_ Information Notice (IN) 90-51 alerted licen8ees_to the potential failure of voltage dropping resistors in the power supply circuits to the Model 2301 Woodward electronic governor. The licensee adequately addresse4 the Woodward governors in use at the plants including those in the emergency diesel generators, feedwater pump turbine controls and in the HPCI and RCIC turbine speed controls. The licensee's response to this IN is contained in Hope Creek internal memorandum HC 3675, da_ted October 23, 1990, and in Salem internal response, dated November 13, * 199 IN 91-20 alerted licensees to the potential for electrical wire* insulation degradation to cause failure in a safety related motor control center. The licensee conducted appropriate investigations and evaluations -to address this issue. The internal response to this IN is contained in licensee letter ELE-91-0519, dated September 20, 199 IN 90-43 alerted licensee's to mechanical interference with thermal trip functions in GE molded case circuit breakers types TED and THED. The licensee.conducted appropriate investigations and evaluations to address this issue. The internal responses to this IN is contained 1n Salem documentation, dated August 15, 1990 and in Hope Creek memorandum dated April 8, 199 IN 91-06 alerted licensee's to the potential for lock-up of emergency diesel generators starting and load sequencer control circuits thereby preventing restart of tripped EDG circuits. The licensee conducted appropnate investigations and evaluations to address this issue. The internal responses to this IN are contained in Salem and Hope Creek documentation, dated September 9, 199 The inspectors found that the licensee addresses regulatory communications that require action by means of their Action Request and Action Request Tracking Syste Responses to the INs reviewed were timely and of good qualit.0. Configuration Baseline Documentation Project CCBD)

The licensee's CBD was project in order to assess the current status. this.project was implemented during 1988 for Salem and in 1990 for Hope Creek. In the original project scope, 87 systems/structures for Salem and 146 for Hope Creek were identified for CBD. Currently, 37 systems for Salem and 24 Hope Creek have been complete The licensee implemented the computerized Document Information Management

,System (DIMS) to compliment the hard copy configuration baseline documentatio All of the 37 Salem CBD are now in the DIMS data base. Computer terminal work

• stations have been installed in the standards, electrical, mechanical, licensing, and sciences engineering locations in order to begin implementation of the use of DIM A training program for the users has been implemented. The hard copy CBD is now and will remain the official baseline document. As a part of the DIMS program,

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imaging capability now has been input into the data base for seven Salem systems in order to provide visibility of such documents as one-line diagrams and schematic The inspector reviewed portions of the CBD for selected systems by viewing them on a computer terminal. The capability to retrieve and view any portion of a system and to perform searches within the system around any desired key input was considered to be a positive factor in the capability of the licensee to effectively utilize the CBD information. DIMS imaging of selected schematics _and one-line diagrams was considered to be a positive factor particularly with the capability to scan a full size drawing or a very small segment of the drawin *

The inspector eoncluded that the licensee's CBD program was being implemented on a timely basis and iri such manner as to provide access for use by.engineering personne *

Quality Assurance Audits The quality assurance (QA) area was reviewed to evaluate their involvement in assessing and enhancing the quality of engineering services. Quality assurance audits.

of the Nuclear Engineering Department are performed by the Nuclear Quality Assurance Audit Group on a scheduled bi-yearly basis. In addition there are follow-up, compliance, requested and special audits that evaluate the Nuclear Engineering Departments performance. Procedure No. GM9-QAP.:.6-1 identifies the requirements deemed necessary to effectively prepare, perform, report and follow-up activities associated with QA audits. Since the audits of engineering involve highly complex activities, the inspectors examined the qualification of auditing personnel. Procedure GM9-QAP-6-1 provides for the proper qualification of permanent staff auditors. The qualifications of five of the auditors were reviewed by the inspectors and found to be adequate in the areas of inspection. However, technical specialist that sometimes perform as auditors normally do not undergo qualification. Rather they are assigned to specific task and they report directly to a qualified team leader who is responsible for their wor The inspectors conducted extensive reviews of QA Audit Nos.91-100, 91-101, and 91-102. The review included the QA Action Requests to engineering, corrective actions \\Jy engineering, and follow-up audits by QA to assure the implementation of acceptable corrective actions. In addition, reviews were made of the prior year and current year audits to assure that the corrective actions made in prior years were effectiv QA Audit 91-100 of the Nuclear Engineering Department was conducted during March 1991. This audit report concluded that the engineering design control portion of their QA program had been effectively implemented. However, the audit disclosed some instances of programmatic deficiencies as follows.

Design verification of ~Important to Safety" applications was not performed as required by Procedure DE-AP.ZZ-OOlO(Q).

• Inability to determine* whether design verification was performed* for equivalent replacement items in "Important to Safety" application. ANSI N45.2.11, Section 6.2 requires that design *verification be adequately documented and referenced in subsequent design change *

Inability to determine from review of the DCP and supporting documentation if walkdowns required by procedure DE-AP.ZZ-0003(Q) were performe *

Nuclear Engineering initiated code job package did not comply with ASME Code and Nuclear Department Procedure NAP-2R requirements. In addition, measures were not established to control ASME Code revisions and statu For each of the above deficiencies QA issued appropriate Action Requests to the

• Manager of Nuclear Design. The inspectors determined that the licensee had taken actions to assure that plant safety was not compromised as a consequence of these deficiencies. Appropriate actions had been taken to correcf the deficiencies and to prevent their recurrence. These violations will not be subject to enforcement action because the licensee's efforts in identifying* and correcting the violations meet the criteria specified in Section V.G. of the Enforcement Polic QA Audit 91-101 of Salem's environmental qualification program was conducted in July 1991. The audit team identified 39 containment isolation valve position switches in Salem Unit 1 and in Salem Unit 2, that were not in Salem's environmental qualification master list (EQML). The list of these switches was documented in a memorandum from A. E. Giardino to M. L. Bursztein, dated October 11, 1991. The location code of these switches indicated that they were located in harsh environment areas. Regulatory Guide 1.97, *Revision 3,.classified the containment isolation valve position as a type B, Category 1 variable; Regulatory Guide 1.97, Revision 3, Table 1, Item 1 specified qualification requirements for category 1 instruments. The licensee was unable to demonstrate qualifiability of these position switches (mpstly Masoneilan position switches) before the conclusion of this inspection. However, the licensee was able to demonstrate that the control room operators could respond properly and safely should the position switches malfunction following a postulated acciden *

.

Following the inspection on January 3, 1992, the licensee's program analysis group

• and Salem instrumentation and control group jointly issued a memorandum to the licensing group. This memorandum indicated that 28 of the 39 affected valves did not receive automatic containment isolation signals. The licensee considered these valves to be non-containment-isolatio11-valves. The licensee could not provide documented evidence that this criterion (definition of containment isolation valves)

i

had been reviewed and accepted by the NRG. The only justification they provided was that these valves were not listed in Technical Speeifications Table 3.6-1, Updated Final Safety Analysis Report Table 6.2-10, or procedure EOP-TRIP-1. The environmental conditions of the location* of the other 11 * valve position switches were reevaluated by the licensee and were determined to be mild environment. Therefore, EQ is not required for these switches. The EQ issue of the 28 valve position switches (for each of the Salem Units) is an unresolved item pending NRC review of the licensee's actions regarding the classification and qualification of the switches (50-

. 272/91-30-01; 50-311/91-30-01).

QA Audit 91-102 of the Nuclear Engineering Department Configuration Baseline Documentation (CBD) program was performed during June 1991. During the audit, a review and comparison of MMIS component classjfications with those assigned in other PSE&G documents (i.e., specifications, drawings and the FSAR). revealed

. inconsistencies in the areas of safety related/non safety related, quality group classification and seismic classification.. These component classifications in the CBD revealed classifications changes made that included both upgrades and downgrade According to the licensee's audit, the following classification deficiencies were observed:

a)

No engineering validations as required by technical standard procedure DE-TS.ZZ-5416 for classification downgrades

b)

No Deficiency Evaluation Forms were initiated for nuclear classification upgrades as required by Procedure DE-AP.ZZ-0018(Q).

c)

No change packages were issued as required by procedure DE-AP.ZZ-001 QA issued the initial Action Request to the Manager of Nuclear Engineering on June 27 with a response due date of July 10, 1991. A response was issued on Juiy 26, in which downgrades were re-installed. Subsequent QA action requests were used* following the engineering responses until the root causes of the improper reclassification were determined, evaluations were made to assure that the safety of the plant was not compromised during the period of time when proper classification

• was not assured, and corrective actions were taken to prevent recurrence of classification errors. These self-identified violations of licensee procedures are

• considered to be a non-cited violation of lOCFR 50, Appendix B, Criterion III, Design Contro *

• *

.*.

1 *

Master Audit Plans (MAP) and two consecutive audits of the Nuclear Engineering group and two consecutive audits of the System Engineering groups were reviewe The purpose was to determine the adequacy of the audit scope and content and look for repeat findings* that would indicate any departmental weakness that had not been addressed properly. The inspeetion revealed that the scope as defined by the MAP was comprehensive and was adequate to enable conclu"sions to be drawn about departments being audited. As required by QAP 6-1, audit checklists _had been prepared and the requirements of the MAP were met. The inspection revealed that the audits of engineering were effective. Issues needing correction were identified, were prioritized and reported to departmental management for corrective actio Action items were assigned and.entered into a system for-tracking them to completion. Typical problems are procedure violations, timely updating of drawings, and disputes over specification interpretation. The inspection showed that previous audit findings were revisited to verify that corrective actions taken were effectiv Items needing upper management attention were added into the monthly Q.A. letter to the Corporate Vice President and Chief Nuclear Office Conclusion The comprehensive QA involvement in monitoring engineering performance to ensure compliance with established programs, procedures, commitment and guidelines is a positive factor for engineering in providing for performance enhancements and improvements in the safety and reliability of the plant Technical Training Training for engineering personnel was reviewed in order to assess its adequacy in several key areas to provide the education required for proper performance of their assigned functions. The inspectors visited the licensee Technical Training Center located in Salem, New Jersey. This center has twenty seven (27) classrooms and five (5) laboratories which are well equipped for electrical, instrumentation and control,

• chemical, mechanical, radiological and radiation measurement counting. The emergency response center and the simulators for Salem and Hope Creek are also located in the same complex. This training center provides the required classroom instructions and on-the-job training for various engineering discipline The licensee has an extensive seven month training program for engineering and technical support personnel. This training is comparable to that provided to senior reactor operator candidates. The program provides technical training in BWR and PWR technology. The seven month training program is provided primarily to the -

system engineers on both sites. All newly hired system engineers receive this training prior to obtaining qualification for their work in their hired positions. The licensee stated that this program is mandatory for system engineers and is available to E&PB and Nuclear Fuels engineers. The program consists of two weeks of introductory

entry level BWR/PWR technology, eight weeks of engineering fundamentals and six.teen weeks of system engineering and administrative type of work. It also includes courses in root cause analysis and the design change process. The program is offered once a year (six months for PWR and.six months for BWR) for the licensee's engineers. Alw, basic level training is given to all engineers in the areas of administrative procedures, QA/QC, station qualified reviewer GET, and plant acces training. The licensee indicated that their training programs were in compliance with NUREG 1122 and 1123 and ANS 3.1-1981 and ANSI 18.1-1971 standard The licensee indicated that each engineer is budgeted to attend one seminar or symposium a year besides their training. They are encouraged to participate in IEEE, ANS and other technical committees. In addition, the engineering* managers are given separate management training courses by both in-house and outside management firm The inspector found that the E&PB Performance Enhancement Department provides extensive training to the engineering organizations in how to*achieve improvements in their organizations and their output products. Personnel are trained in how to achieve improvements in quality, safety, innovations, productivity, quality of working life, financial performance, efficiency, and effectiveness. Methods of identifying potential for enhancements, implementing changes, and measuring their effectiveness are included in the training. The inspectors reviewed many of engineering performance iildicators trending charts which were posted in the E&PB offices and discussed this program with engineering personnel who demonstrated a good knowledge of the progra The inspectors concluded that the training facilities and program provided to engineering personnel is good in supplying the education required for proper performance of their function.0 Management Meetings The licensee management was informed of the scope and purpose of the inspection at the entrance meeting on December 2, 1991. The findings of this inspection were discussed with the licensee representatives during the course of the inspectio~ and.

presented to licensee management during the exit meeting on December 13, 1991. A list of attendees is presented in Attachment *

ATTACHMENT 1

- Public Service Electric and Gas Company J. Bailey, Nuclear Engineering Sciences Supervisor

• R. Beckwith, Station Licensing Engineer

• P. Benini, Quality Assurance Auditing Principal Engineer A. Blum, Program Analysis Supervisor R. Brown, Station Licensing Principal Engineer M. Bumstien, Nuclear Electrical Engineering Manager B. Connor, Technical Department Engineer, Salem D. Cooley, Safety Review Engineer G. Englert, Nuclear Engineering Standards Manager A. Giardino, Quality Assurance Manager. -

B. Hall, Hope Creek Technical Manager

• J. Hann, Nuclear Fuel Engineering Supervisor D. Jagt, Nuclear Engineering Design Manager C. Lambert, Nuclear Engineering Senrice Manager M. Metcalf, Nuclear Engineering Projects Manager M. Morroni,.Salem Technical Manager

• P. Opsal, Technical Department. Supervisor - Hope Creek M. Pastva, Nuclear Licensing Engineer D. Pease, Safety Review Engineer

• J. Ranalli, Nuclear Mechanical Engineering Manager

• L. Reiter, Quality Assurance and Safety Review General Manager

• R. Schaffer, Nuclear Training Supervisor

• R. Swanson, Engineering and Plant Betterment General Manager

• . F. Thompson, Licensing and Regulations Manager

• B. Thomas, Licensing Engineer

• H. Trenka, Salem Revitalization Manager

• P. Walzer, Training Supervisor

• P. White, Engineering and Plant Betterment Projects Manager D. Wray, Senior Hope Creek Staff Engineer Atlantic Electric Company E. Krufka, Salem Site Representative M. Sesok, Hope Creek Site Representative U.S. Nuclear Regulatory Commission L. Cheung, Senior Reactor Engineer

. G. Koch, Reactor Engineer T. Johnson, SeniOr Resident Inspector C. Woodard, Reactor Inspector

• Denotes those not present at the exit meeting on December 13, 1991.