IR 05000311/1979004
| ML18078B048 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 02/05/1979 |
| From: | Baunack W, Conte R, Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18078B047 | List: |
| References | |
| 50-311-79-04, 50-311-79-4, NUDOCS 7903210013 | |
| Download: ML18078B048 (14) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report N /79-04 Docket N License N CPPR-53 Priority ----------
Category -----=::B...:..l ___ _
Licensee:
Public Service Electric and Gas Company 80 Park Place Newark, New Jersey 07101 Facility Name:
Salem Nuclear Generating Station, Unit 2 Inspection at:
Hancocks Bridge, New Jersey Inspection conducted: January 8-12, 1979 Inspectors: &J. U. ~~k-r..,,,l Approved by:
W. H. B~~ack, Reactor Inspector (JI V. v:
w f__
R. J. Conte, Reactor Inspectq accompanied by N. J. Blumberg, Reactor Inspector
~~.
llf::R"fs~Nuclear Support Section No. 2, RO&NS Branch Inspection Summary:
. 'date signed
~ /!:,-):>c;
" date signed Inspection on January 8-12, 1979 (Report No. 50-311/79-04)
Areas Inspected:
Routine, unannounced inspection by regional based inspectors *Of established administrative controls in the following areas:
owner organization; assignment of authority and responsibility; onsite operating organization; rules of practice; responsibility and authority of operating personnel; equipment control; maintenance and modifications maintenance programs; procedure adherence;
operating/special orders and temporary procedures; review, approval and control of procedures; procedure scope and content; and a facility tou The inspection involved 80 inspector hours onsite by 2 regional based NRC inspectors and 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> onsite by one NRC superviso Results:
No items of noncompliance were observe Region I Form 12 (Rev. April 77)
- DETAILS Persons Contacted Public Service Electric and Gas Company
- A. Desanctis, Office Administrator L. Fry, Senior Performance Department Supervisor (Instrument and Control)
- R. Griffith, Senior Staff Engineer Quality Assurance (QA) Unit 2
- S. LaBruna, Maintenance Engineer
- B. Leap, QA Supervisor
- D. Lyons, QA Specialist R. MacWalters, Shift Supervisor
- H. Midura, Manager Salem Generating Station
- L. Miller, Station Performance Engineer
- M. Murphy, Associate Engineer - Operations E. Roscioli, Senior Reactor Staff Supervisor
- E. Rozovsky, Electric Production Department - QA Engineer
- J. Stillman, Station QA Engineer J. Zupko, Chief Engineer NRC
- L. Norrholm, USNRC Resident Inspector Other members of the operations and quality assurance staffs were also interviewe * denotes those present at the exit intervie.
Genera 1 The licensee's administrative controls established for the operation of Salem Unit 2 were reviewed in detai The review was conducted to verify provisions exist to implement selected requirements of ANSI NlS.7-1976, 11Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants
, in facility administrative procedures. Areas and documents reviewed, and findings are discussed in the following detail.
Facility Owner Organization, Onsite Operating Organizations Program, and Policies In accordance with Paragraph 2, the following areas of ANSI Nl8.7*1976 were.reviewed:
Owner Organ.ization Assignment of Authority and Responsibility Onsite Operating Organization Rules of Practice Responsibilities and Authorities of Operating Personnel Equipment Control Maintenance and Modifications Maintenance Programs The below listed documents were reviewe AP-1, Administrative Procedure Program, Revision 9, Draf AP-2, Organization and Responsibility, Revision 1, June 1, l 97 AP-5, Operating Practices, Revision 8, August 24, 197 AP-8, Station Design Changes, Tests and Experiments, Revision 4, May 20, 197 AP-9, Work Order System, Revision 4, December 4, 197 AP-6, Operational Incidents: Report Initiation, Investigation and Follow-up, Revision 5, November 20, 197 AP-10, Inspection Order System, Revision 2, November 17, 197 *
AP-13, Control of Lifted Leads and Jumpers, Revision 2, April l 0, 1978 *
. AP-15, Tagging Rules, Revision O, April 13, 197 AP-25, Control of Station Maintenance and Repair, Draft Revision Operating Department Memo Operations Directive Manua Results of the above review are as follows:
(l} AP-2, Organization and Responsibility, Revision l, June l, 1977, does not specify the current lines of authority, responsibility, and corranunication for members of the organization as required by ANSI NlS.7-1976, Section The licensee stated AP-2 would be revised to include the requirements of ANSI NlS.7-197 This item remains open pending completion of licensee action as stated above and
, subsequent NRC:RI review (311/79-04-01).
{2}
ANSI Nl8. 7-1976, Section 5. l, in relation to the quality assurance program description, states in part,
- A surranary document shall be complied by each owner organization to identify the sources, to index such source documents to the requirements of this standard and to provide a consolidated base for description of the progra This summary document has as yet not been prepare The licensee stated such a summary document will be prepare This item remains open pending completion of licensee action as stated above and subsequent NRC:RI review
'(311/79-04-02}.
(3)
ANSI Nl8.7-1976, Section 5.2.l, specifies the responsibilities and authorities of the plant operating personnel be delineated. It further lists six specific operator responsibilities which shall be delineated. Currently not all of these items are specifically addressed in facility administrative procedure The licensee stated appropriate procedures would be revised to include the items required by ANSI NlS.7-1976, Section 5.2.l. This item remains open pending completion of licensee action as stated above and subsequent NRC:RI review (311/79-04-03}.
(4)
(5)
(6)
(7)
AP-13, Control of Lifted Leads and Jumpers, Step 3.3, states, "The supervisor in charge of the work shall be responsible for verification that the correct leads were lifted and reconnected, and that temporary jumpers were placed where designated and remove Verification shall be documented on Form AP-13.1."
Form AP-13.1, requires documentation for verification of removal of jumpers but not for placement of jumper The licensee stated Form AP-13.l will be revised to include verification of place-ment of jumpers. This item remains open pending completion of licensee action as stated above and subsequent NRC:RI review (311/79-04-04).
Maintenance Manual Procedure A-5 in addressing jumpers indicates that only permanent jumpers will be installed in accordance with Station Administrative Procedure AP-13, Control of Lifted Leads and Jumper AP-13 is intended specifically for the installation of temporary jumpers, not permanent jumper The licensee stated A-5 would be revised to be consistent with AP-1 This item remains open pending completion of licensee action as stated above and subsequent NRC: RI review (311 /79-04-05).
The above item was noted, by the inspectors, to be an example of Departmental Procedure not being in agreement with a Station Administrative Procedure. * The licensee stated AP-1, Administrative Procedure Program, Revision 9,.would include a positive means of ass.uring that Depart-mental Manuals are consistent with Station Administrative Procedures and that Departmental Manuals are upgraded as*
Station Administrative Procedures are revised; This item remains open pending completion of licensee action as stated above and subsequent NRC:RI review (311/79-04-06).
The inspector noted that in some instances draft copies of procedures were used by the inspectors to verify compliance with the requirements of ANSI Nl8.7-197 The licensee acknowledged this statement, and indicated that every effort would be made to issue all Station Administra-tive Procedures, currently in need of revision, prior to the receipt of an operating license. It was further stated that draft procedu.res or issued procedures requiring revision which implement the requirements of ANSI 187 -
1976 will be revised and issued prior to receipt of the operating license. It was noted that these procedures will be identified upon completion of the summary document (index source documents to requirements of the standard)
addressed in paragraph 3.C(2).
This remains open pending completion of licensee action as stated above and subsequent NRC:RI review (311/79-04-07).
(8)
The inspectors discussed the preventive maintenance program required by ANSI Nl8.7-1976, Section 5.2.7.1 with the license The licensee stated the Unit 2 Preventive Maintenance Program would be fashioned after the Unit l program which is scheduled in accordance with the Inspection Order Syste The. licensee, further stated steps would be initiated to include Unit 2 Preventive Maintenance in the Inspection Order System prior to issuance of the operating licens This item remains open pending completion of licensee action. as stated above and subsequent NRC:RI review (311/79-04-08).
(9)
During the review of A-3, Maintenance Department Training, it was noted that the experience level requirements for maintenance personnel specified in accordance with ANSI N.45.2.6, Qualification of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants, (applicable to the operation phase also)
and that experience is categorized into three levels. It was determined that a Level I individual (minimum experience level - one year) could be assigned certain safety related maintenance task The proposed Technical Specifications require that the facility staff be qualified to ANSI Nl8. 1-1971, Selection and Training of Nuclear Power Plant Personne For maintenance personnel (repairmen, per ANSI Nl8. 1-1971), the individual shall have three years experience in a craf The inspector stated that ANSI N45.2.6 generally applies to quality assurance/control personnel, i.e., NDT examiner, and that ANSI Nl8.l applies to the facility staff who perform routine operations, maintenance, sureveillance testing. This is based on guidance from the Office of Nuclear Reactor Regulation (NRR).
The licensee representative stated that this area will be reviewed furthe This is open pending completion of action as stated above and subsequent NRC: I review (311 /79-04-09).
4. * Ptocedate Control and Use In accordance with Paragraph 2, the following areas of ANSI NlB.7-1976 were reviewed:
__J
- Procedure Adherence; Operating/Special Orders and Temporary Procedures; Review, Approval and Control of Procedures; and, Procedure Scope and Conten The below listed documents were reviewed:
Administrative P.rocedure (AP-1), Administrative Procedure Program, Revision 9 (draft);
AP-2, Station Organization, Revision O, June 1, 1977; AP,..3, Station Documentation, Revision 9 (draft);
AP-5, Operating Practices, Revision 8, August 27, 1977; AP-11, Station Record, Revision 4 (draft);
AP-12~ Document Control, Revision 4 (draft);
Performance Department Manual, selected sections, Revision 8, May 24, 1978; Maintenance Department Manual (MOM) Administrative Procedure A-1, Maintenance Department Organization, Revision 1, January 27, 1976; (MOM) A-3, Maintenance Department Training, Revision 4,_
August 15, 1978; *
(MOM) A-11, Procedure Writing Guidelines, Revision 11, November 24, 1978;
- --
Operating Department Memos - all effective; Supervisor's Letters - all effective; Operations Directive Manual, Revision 3, March 1, 1978;
- Reactor Engineering Manual, Part i, Procedures for Making Changes, September 29, 1978; Station Plant Manual (SPM}, I-1, General Information, Revision 1 Results of the above review are as follows:
(1)
AP-3, Station Documentation, authorizes various documents (manual/procedures) for use at the station. The following documents which have been established, are not included in this administrative procedure: Operations Directive Manual, Operating Department Memos, Night Order Boo The inspector considered the above documents as Operating/
Special Orders as defined by ANSI 18.7-1976 Paragraphs 5. and 5.2.4. This was based on the information addressed in the subject document It was further noted that periodic review requirements for these types of documents were not addressed in the station administrative control The licensee representative acknowledged the above and stated that these documents would be incorporated into the next revision of AP- *
This is open pending completion of action as stated above and subsequent NRC:RI review (311/79-04-10}.
(2)
AP-5, Rules of Practice, addresses information to be specified in the 11 Night Order Book. 11 AP-5 indicates that temporary operating instructions not included in the scope of the Statibn Plant Manual (SPM} may be provided. This appeared to have authorized the use of the Night Order Book (NOB)
to promulgate Temporary Procedures as defined in ANSI 18.7-1976, Paragraph 5. The licensee representative indicated that it was not intended to use the NOB to promulgate Temporary Procedure Further it was stated that AP-5 is being revised and that this section on the NOB would be clarifie This is open pending completion of action as stated above and subsequent NRC:RI review (311/79-04-11}.
(3)
During the review of administrative controls for temporary changes (defined as On-The-Spot Changes by the licensee (4)
in AP-3), it was noted that procedures have not been established to review a change on one unit (which warrants a permanent procedure revision) for applicability to the other uni The inspector was informed by the licensee representative that many Unit 2 procedures would be similar to Unit The licensee representative acknowledged the above and stated that measures to address dual unit applicability for on-the-spot changes are planne This is open pending completion of action as stated above and subsequent NRC:RI review (311/39-04-12).
During a review of administrative controls established in the Operations Directive Manual,Section III, for the performance of valve line-ups, it was not clear on how temporary changes of a permanent nature (warranting a procedure revision) or of a temporary nature (due to unique plant changes) were to be controlled. A review of selected Unit l completed valve line-ups indicated the following:
Temporary changes of a permanent nature were controlled through the use of the on-the-spot change syste However, in certain instances, valves that cycle positions due to automatic operation had a required position of 11closed 11 with actual position recorded as 11open
, with no indication of an on-the-spot change or procedure revisio The licensee representative stated that a revision should have been generated to clarify this type of situatio Changes to valve positions due to maintenance work or special plant conditions are documented; but, in certain instances, the return to normal position was not documented after the work was complete The licensee representative stated that the area will be reviewed further to determine if existing controls are adequat This is open pending completion of action as stated above and subsequent NRC:RI review (311/79-04-13).
(5)
Within the Performance Department, the Chemistry and Radiation Protection Groups have several controlled (by distribution list) copies of in-use procedures such as laboratory instructions. The Performance Department Manual (PDM) does not address.the updating of these controlled copies for on-the-spot changes. This does not apply to the I&C Group procedures because only one set of procedures (the Master) are used for the generation of copies to be used in the plant and on-the-spot changes are incorporated into that maste The licensee representative stated that the PDM will be revised to address updating distributed Chemistry and Radiation Protection procedures for on-the-spot change This is open pending completion of action as stated above and subsequent review by NRC:RI (311/79-04-14).
(6) The documents reviewed in Paragraph 4.b do not reflect the procedure adherence requirements of ANSI NlB.7-1976, Paragraph 5.2.2 in the areas of procedure use, data taking, and emergencies not covered by approved procedur (With respect to this area of ANSI Nl8.7, temporary changes are adequately controlled per AP-3 which provide instructions for on-the-spot cha.nges.)
The licensee representative acknowledged the above and stated that this area would be reviewed to assure coverage of the above topic *
This remains open pending completion of action as stated above and subsequent NRC:RI review (311-79-04-15).
(7) The below listed items were noted in the area of periodic review of facility procedure Licensee action for resolution of these items is listed with each ite (a)
The method of documentation of periodic review of Station Administrative Procedures (AP's) is not addresse The station AP's recognize that a revision constitutes a revie However, the inspector stated that some procedures may not get revised within the prescribed frequency (2 years) of revie The licensee representative stated that the task of periodic reivew of station AP 1 s will be incorporated into the* Inspection Order Syste The Inspection Order System is a computerized schedule for action items that are required on a periodic basis such as a survei 11 ance testing ( 311/78-04~16).
(b) * AP-3 requires the periodic review of the Performance Department Manual (PDM).
Procedures, generated by the three groups (Instrument and Control (I&C},
Chemistry, and Radiation Protection} within this department, implement the surveillance/calibration requirements of Technical Specifications. These procedures (unlike the Maintenance Department Manual}
are not a part of the PDM *. The PDM does not address periodic review requirements for procedures not in PD Discussions with the licensee representative revealed an intent to take credit for a review of a procedure through the use of the procedur The inspector concurred that this method of review would confirm*
adequacy of procedural implementation on a step by step basis; but this would not meet the intent of periodic revie That intent is to assure the procedure had been updated to changing conditions since the time the procedure was written, e.g.,
Technical Specification Limit changes due to core reloa The licensee representative acknowledged the above and stated that controls for periodic review of department procedures wi 11 be incorporated into the PDM (311/79-04-17}.
(c} * The instruction sections for the Stqtion Plant Manual (SPM) does not address periodic review require-ments for the.General Plqnt and System.*oper~ting *
Procedures, Erne_rgency Alarm Response, Surveill~nce* *
Test (operations} Procedure Based on discussions with the Operations Department personnel, questions remained outstanding on how to implement this require-ment due to numerous amounts of procedures involve *
The licensee representative stated that this area warrants further review (311/79-04-18).
The above three items remain open pending completion of action as stated above for each item and subsequent NRC:RI revie (8)
The below listed discrepancies were noted in the area of established administrative controls for procedure format and content (ANSI Nl8.7-1976, Paragraph 5.3.2). Licensee action for resolution of these items is listed with each ite (a)
Section III of the Operations Directive Manual states that format for Emergency Procedures and Operating Instructions will be in accordance with Section I-1 of the Station Plant Manual {SPM).
- Section I-1 of the SPM does not give format require-ments for these procedure The licensee representative stated that format
~equirements for these procedures will be specified in I-1 of the SPM (311/79-04-19).
(8)
The procedure format requirements in the Performance Department Manual (PDM) currently reflects the recommendations of ANSI N18.7~1972. The proposed Quality Assurance Program endorses ANSI Nl8.7-1976 and Regulatory Guide (RG) 1.33, Revision 2, February, 1978. This revision of RG 1.33 notes certain pro-cedural content recommendations (Title, Prerequisites, Precautions, Limitation/Actions) as significant and are to be considered requirement The licensee representative stated that the PDM would be revised to reflect the approved program commitments in this are The inspector noted that this applied to each section (Instrument and Control, Chemistry, Radiation Protection) of the PDM (311/79-04-20).
(c)
During discussions with the Operations Department personnel, the inspector noted many refueling instruc-tions in the Station Plant Manual (SPM) and general instructions for the SPM did not reflect an approval statu RG l..33, Revision 2 and ANSI NlB.7-1976, Paragraph 5.3.2(1) require that the procedure title have an approval status in addition to work, system, unit description and revision number or dat The licensee representative indicated that an approval status was intended to be indicated on these instruc-tions (311/79-04-21).
The above 3 items remain open pending completion of action as stated above for each item and subsequent NRC:RI revie (9)
During the inspection it was determined that a Unit 2 Reactor Engineering Manual remains to be issued and that the Operations Directive Manual needs revision for applicability to Unit This is open pending NRC:I review of these documents for consistency with respect to ANSI 18.7-1976 and Station Administrative Procedures (311/79-04-22). Facility Tours On several occasions during the inspection, tours of the facility were conducted of the control room, turbine building, primary auxiliary building, relay rooms, diesel generator room, and the containmen During the.tours the inspectors observed completed work, and observed work activities in-progress for obvious defects or noncompliance with regulatory requirement No items of noncompliance were identifie.
Open Items Open items are findings associated with documents/procedures-that the licensee intends to use for implementation of regulatory requirements upon receipt of the operating licens Licensee action to close these items are listed with each ite Further, target dates for completion of licensee actions are listed below as provided by licensee representative ~-.
Open i terns addressed in the fo 11 owing paragraphs are due for completion as noted:
Prior to Core Load - Paragraphs 3.c(l), 3.c(2), 3.c(3), 3.c(4),
3.c(6), 4~c(4), 4.c(7)(a), 4~c(4), 4.c(7)(a), 4.c(7)(c),
4.c(8)(a), 4.c(8)(c), 4.c(9);
Prior to Receipt of Operating License - Paragraphs 3.c(7) and 3.c(8);
Prior to March 1, 1979 - Paragraphs 3.c(5), 3.c(9), 4.c(2),
4. c(6), and, Prior to April 1, 1979 - Paragraphs 4.c(l), 4.c(3), 4.c(S),
4.c(7)(b), 4.c(8)(b). 'E~it Interview The inspectors met with licensee.representatives (denoted in Paragraph 1) at the conclusion of the inspection on January 12, 197 The purpose, scope and findings of the inspection were summarized.