IR 05000354/1991013

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Insp Rept 50-354/91-13 on 910520-24.No Violations Noted. Major Areas Inspected:Review of Several Open Items Remaining from Maint Team Insp 50-354/89-80 & Surveillance Test & Implementation
ML20198C912
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 06/21/1991
From: Baunack W, Blumberg N, Oliveira W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20198C890 List:
References
50-354-91-13, NUDOCS 9107030201
Download: ML20198C912 (14)


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JUN 211991 U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.

91-13 Docket No.

50-354 License No.

NPF-57 Licensee:

Public Service Electric and Gas Company 80 Park Plaza - 17C Newark, New Jersey Facility Name:

Hope Creek Generating Station

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Inspection At:

Hancocks Bridge, New Jersey Inspectior, Conducted:

May 20 - 24, 1991

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Inspectors:

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W. Baunaci, Sr. Reactor Engineer Date k /

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W. OMveira, Reactor Engineer Date Approved by:

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g gt N. Blumberg, Chief

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Date Performance Programs Wettion Operations Branch, DRS InsFction Summary:

heas Inspected:

Routine unannot.nced safety inspection by two region-based inspe: tors to review several open items remaining from the Maintenance Team Inspection (MTI)

Report No. 50-354/89-80. A follow-up to other issues identified during the MTI was also conducted.

The surveillance test program and its implementation were also reviewed.

Results:

The open items from the MTI were adequately addressed.

No deficiencies were noted during the review of other issues identified in the MTI.

The surveillance test program was found to be adequately documented and implemented.

No violations or deviations were identified.

9107030201 910621 PDR ADOCK 05000354 O

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I DETAILS 1.0 Persons Contacted

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Attachment 1 provides a listing of persons contacted during the inspection.

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2.0 Maintenance Team Ins _pection (MTI) Follow-up

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An MTI was conducted at the Hope Creek Generating Station f rom October 2 to October 13, 1989.

During that inspection, one violation dealing with failure to fellow procedures with ten examples was identified, as were-several unresolved items and a weakness.

The licensee provided a written response to the violation by letter dated March 9,1990.

A written response to the unresolved items and the weakness was provided by letter

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dated April 12, 1990. A number of these items had been closed during previous NRC inspections.

During this inspection, the remaining open items were closed.

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Also, during the MTI, issues were noted which were not categorized as violations, unresolved items or weaknesses.

These issues included deficiencies noted by the team or areas in which the licensee was in the process of making improvements which the team considered in making their findings.

Progress made by the licensee in these areas was also reviewed during this inspection.

2.1 Licensee Actions on MTI Identified Violations (92702)

(Closed) Violation 50-354/89-80-01: Contrary to requirements of station procedures, scaffolding components were found leaning against safety-related instrument lines.

To prevent recurrence, permanent warning signs have

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been installed in two locations in the reactor building where materials could be stored against instrument lines. The warning signs were installed in accordan:e with Station Procedura SA-AP.22-044(Q), " Station Aics and Labeling Practices." This procedure requires an index and copy of all station aids to be maintained in a Station Aids Book.

Also, metal protective enclosures have been erected protecting the safety-related instrument tubing.

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(Closed) Violation 50-354/89-80-05:

Contrary to the requirements of station procedures, a valve (identified as damaged) with a work order

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The licensee's corrective action to prevent recurrence was to make the involved procedure less demanding by changing the requirement from "All personnel shall..." to "All personnel should attach an EMIS tag to or near malfunctioning components or systems." A review of Station Procedure NC.NA-AP.ZZ-0009(Q), " Work Control 7 cess" by the inspector indicated that the procedure does L

clearly kentify in Attachment 1 the appropriate use of the EMIS tag, particularly for those items considered to be visible malfunctions.

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Inspector observations during tours of the facility show EMis tags are being used.

The use of EMIS tags was discussed in detail with senior maintenance and operations personnel.

These managers, who essentially set the standards and are most involved in the use of EMIS tags, indicated that they were satisfied that EMis tags were being applied in accordance with the intent of the procedure.

Based on this information, the inspector considers this item closed.

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{ Closed) Violation 50-354/89-80-06:

Contrary to requirements of station procedures, a number of floor drains were plugged without the preparation of a Temporary Modification Request.

To prevent recurrence, Administrative Procedure NC.NA-AP.ZZ-0013(Q) " Control of Temporary Modifications" was t

revised to include Attachment 6, " Controlling Temporary Floor Drain Plugs."

Attachment 6 provides mandatory instructions relating to the installation of floor drain plugs.

The. inspector verified a floor drain plug log is being maintained and that monthly reviews of installed plugs are being performed as required by the procedure. During this inspection, three active tagging requests were being contro'. led. Also, floor drain plugs installed in the-plant were observed to be tagged as required. A part of the licensee's response of March 9, 1990, to this item was the statement,

"A closing document notation was included in the revision to the procedure

[NC.NA-AP.ZZ-0013(Q)] to ensure continued compliance." Closing documents are part of the station commitment management program and are part of the process established for maintaining commitments.

The inspector noted that the closing O cument notation for the procedure change resulting from this i

commitment was un INP0 SOER dealing with flooding as opposed to the above

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licensee's response letter to the NRC which referenced the procedure change.

The licensee indicated the letter to the NRC would be added to the closing document.

2.2 Licensee Action on an MTI Identified Unresolved Item (92701)

Glosed) Unresolved Item 50-354/89_-80-11: - Emergency diesel generator oil sample analysis can provide meaningful information.

To be most meaning-ful, the oil sample must be taken from a running engine before any filtration. -The MTI noted lube oil samples were being taken from a stopped engine downstream of the oil filters.

The licensee committed to revising the procedure to take lube oil samples from a running engine upstream of the filters.

The inspector verified the Monthly Emergency Operability Test Procedure HC.0P-ST.KJ-0001(Q) was revised to provide for taking a lube oil sample upstream of the filters following a loaded engine run of at least 15 minutes.

Also, a design change request is scheduled to be implemented which will install a permanent lube oil sample connection.

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2.3 Licensee Action on an MTI Identified Weakness (92701)

{ Closed) Weakness 50-354/89-80-121 During the MTI, the team identified a notable weakness concerning the lack of effective parts support for routine maintenance activities.

The licensee has taken a number of steps to improve the availability of parts to support routine maintenance activities.

A; reorganization of the procurement and material control i

group was completed and a new general manager installed.

A project team was formed to work on improvements and staffing has been increased.

Additional steps taken by the procurement group are the monthly publication of a series of performance indicators.

The number of work orders on hold for parts is one of these indicators.

Statistics are provided for work orders scheduled to start in 7 days, 30 days and 90 days. A goal of less than 10'e of work orders waiting for parts scheduled to-start in 7 days has been established.

The March report showed 11*J of the work orders scheduled to start within 7 days were waiting for parts.

Significant improvement has been made in-the parts availability for work orders scheduled to start in 7 days.

For example, in December 1989, 45*4_of these were on hold awaiting parts.

Planning publishes their performance indicators weekly.

Good communications between planning and procurement have been established.

These communications consist of both formally scheduled meetings and informal daily contacts.

Three additional material coordinators have been permanently assigned to

_the procurement and material control staff, Also, to allow for more i

efficient purchasing and expediting of required materials, a requisition

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consolidation program has been made a part of the purchasing computer program.

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Another area in which significant improvement has been made is in the

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reduction of "open" procurement related documents.

This backlog of-l

"open" documents has been reduced from 4200 documents to a current 991.

The goal for the end of 1991 is 400 documents. Along with this goal, i

goals for requisition processing times have also been established.

Records indicating the number of tasks rescheduled due to a lack of parts are not maintained. However, discussions with plar.ning personnel incicate fewer tasks are now being rescheduled due to a lack of parts than was the case during the MTI.

Other improvements in the area of procurement and spare parts are being implemented which should further enhance the process.

These include the-establishment of.a warehouse automated management system-and the construction of a new onsite warehouse to consolidate activities now conducted at several locations.

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Although further improvements are still needed, this item is considered closed based on the implementation of aP corrective action commitments.

Also, the issue of spare parts is the suvject of another NRC outstanding inspection activity.

2.4 Licensee Actions on Other Issues Noted in the MTI (92701)

2.4.1 The team noted that several areas of the turbine building, screen house, and asphalt boiler house did not receive the same housekeeping attention as other areas of the plant.

The team also indicated management should provide guidance for the care of insulation and I

lagging. Tours of the facility by the inspector noted increased attention had been given to housekeeping on the 54 foot elevation of the turbine building, the screen house and the asphalt boiler house.

Discussions with personnel identified that a staff engineer has been assigned responsibility for care _and repair of damaged lagging, that significant effort has been spent on lagging repair since the MTI,

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and that the care of lagging and plant cleanliness are routinely

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discussed with managers and the staff.

I 2.4.2 The team noted a deficiency in the conduct of weekly housekeeping inspections.

The licensee indicated the housekeeping inspection procedure would.be revised to clearly reflect the manner in which

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housekeeping inspections were to be performed.

The inspector verified that Nuclear Administrative Procedure NC.NA-AP.22-0031(Q)

" Artificial Island Inspection / Housekeeping Program" has been revised to provide a means to assure that material deficiencies, cleanli-ness, housekeeping deficiencies, fire protection, and radiological deficiencies are identi fied.

The procedure provides for inspection schedules, documentation and resolution of inspection findings, and a -

i semi-annual review to identify repetitive problems and to trend progress.

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f Also, Station Directive SA-SD.ZZ-22, " Fixed Housekeeping Area Assignment" has been issued to provide area inspection responsibi-lities to Hope Creek personnel.

These procedures appear to clearly reflect the manner in which housekeeping inspections are to be performed.

The inspector performed walkdowns of various areas of the plant including the reactor, turbine, and auxiliary buildings, screen house, and the diesel generator rooms.

Overall, the housekeeping and material condition of the facility was very good.

Some specific observations were identified to the licensee.

These were:

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damaged or deteriorated flex conduit jackets; (2) a loose grounding

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strap on a service water strainer motor, and (3) numerous instances in which the clamps which secure terminal box covers were missing or loose.

The licensee had reviewed the damaged flex conduit jacket

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matter and will further look into the other issues.

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Another item identified during the walkdown dealt with the Unit 1 and Unit 2 interface. A pressurized fire line which protects Unit 2 spaces was identified running through a Unit 1 and Unit 2 common area.

This line was not indicated on any drawing available to Unit 1 Control Room personnel. Also, not all v61ves associated with this fire line were identified on the Unit 1 valve position indication system.

Several other lines were also identified in the common area between-Unit 1 and Unit 2 whose function was not known.

One was believed to be a chflied water line used during construction.

These interfacing lines and the possibility of other lines than those noted which interface between units were discussed with the licensee.

This discussion related to the potential for these interfacing lines to

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pose a future problem due to them possibly not being fully identified or controlled by station personnel.

The licensee stated this matter would be reviewed.

Also, as part of the walkdown work sites for three recently completed maintenance activities were inspected. The results of

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this inspection were as follows:

Work Order No. 901210088, repair leak on suction of 1B-P-114.

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This repair appeared to be properly completed.

However, the work-site was left in an extremely untidy condition.

Although the job site was left in an untidy condition, maintenance personnel did, however, write a work request to repair damaged insulation in the area.

Work Order 910514257, 1 APV-046 broken shaft, repair shaft.

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This repair appeared to be properly completed.

The repair was to a locked testable check valve.

The repaired valve was locked.

However, a similar valve close by also required to be locked was observed to be unlocked.

Increased vigilance during restoration of this work site should have identified this similar valve being enlocked. The licensee immediately locked the valve.

These valves are required to be administrative 1y locked and are not required to be locked by regulation.

Work Order 910512114, pump 1A-P-168 failed, will not pump

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water.

This repair to two adjacent sump pumps was improperly completed in that one pump was noted to have two grounding straps attached while the other pump had none.

Likewise, the grounding straos to both motors were lef t unattached. Also, the area was not cleaned up to the satisfaction of the maintenance supervisor.

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i The inspector indicated, based on the above observations, more attention should be paid to completed work activities to assure they are satisfactorily completed. The licensee acknowledged the inspectors comment.

2.4.3 The maintenance team noted that failure to follow procedures individually do not pose a significant safety concern.

However, collectively the number identified by the team represented a problem which warranted management's attention. Management indicated to the inspector that to address this issue two station directives (50) have

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been issued which are aimed at assuring personnel attention to detail and compliance with station procedures.

One of these directives 50-16 "Self Assessment Management Practices" directs plant managers ind department engineers to witness selected activities and through a checksheet and comments feedback form incorporate lessons learned into appropriate procedures and/or

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training. A second initiative has been the issuance to all station personnel of 50-14 " Work Practices and Written Instruction Use Guidelines." This directive provides specific guidance regarding the

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use of various cate;. ries of procedures.

Another effort taken has been the making of changes to administrative procedures in order to make them more clear and, consequently, easier to follow. Also, station Quality Assurance (QA) has begun a program to monitor performance of station procedures.

A trending of QA-surveillances of maintenance activities was reviewed by the inspector.

This report for the period of July 1990 thru December 1990_ indicated

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that lack of procedure compliance was still a factor in 71.4 percent of the unsatisfactory QA surveillances of maintenance activities.. To assist in making further improvements, QA meets with station manogement monthly to discuss quality trends and make recommendations.

Overall, efforts have been made by manacement to improve procedure adherence. Additional ef forts in this area appear to be warranted.

The continued monitoring by QA of the performance of station procedures is an initiative which will indicate continued improvement if the actions taken by management are successful.

2.4.4 TI,e team could find no formal or documented policy or program directive which _ specifies management policies regarding the maintenance program and industry initiatives for improving the-program.

Since the MTI the licensee has issued Nuclear Administrative

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Procedure NC.NA-AP.ZZ-0054(Q), " Operating Experience Feedback Program."

This procedure defines authorities, responsibilities, and_ department interfaces in the review process of both internal and external

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operating experience information to assure that lessons learned are being effectively utilized to prevent recurrence of events and improve plant safety and reliability.

2.4.5 The team expressed a concern regarding the documentation associated with the torque wrenches used in the diesel engine overhaul procedure..The licensee indicated the procedure would be revised.

The procedure was not revised.

Hawever, the implementation of a new electronic work order has eliminated the problem since now all measuring and test equipment, which includes torque wrenches, are now recorded on the electronic work order.

Conclusion I

The licensee has satisfactorily implemented all actions committed to in

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letters to the NRC to resolse the violation, unresolved items, and weaknesses identified-in the MTI.

Station housekeeping and material condition appear-to be very good.

However, numerous instances were noted i

where terminal box clamps were missing or were. loose. Also, the inspection of three recently completed job sites all showed some deficiencies, improvements have been made in the timely procurement of spare parts to

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support maintenance.

Further improvement in this area are still being made.

Steps have been taken to-improve procedure adherence by station i

personnel.

However, QA findings show further actions in this area are warranted.

In general, the licensee appears committed to improving all i

aspects of facility operation. However, certain findings show a lack of attention to detail exists.

3.0 Surveillance Test Program (61700, and 61725)

i 3.1 Purpose i

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Determine the status'of the licensee s program for the control and implementation of the Surveillance Test Program.

3.2 Procram Review The Surveillance Test Program (STP) is described in Station Procedure HC.SA-AP.ZZ-012(Q), " Technical Specification Surveillance Requirements,"

Revision 9.

The description includes responsibilities fo planning, scheduling, maintaining the Technical Specification (TS) Matrix, implementing TS Amendments, and direction regarding overdue survei1-i lances.

Individual-surveillance tess procedures reviewed by the inspector conformed to procedure HC.SA.AP.ZZ-012(Q) requirements and included prerequisites, precautions, preparations, instructions for the l

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conduct of testing, acceptance criteria, restoration actions, signoffs such as the Maintenance Management Information System (MMIS), and are in

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place to prevent missed or overdue surveillances.

MMIS schedules routine surveillances with a frequency of 7 days or greater.

Routine surveillances with a frequency of less than 7 days are scheduled by the responsible department.

Deficiencies identified by surveillances are addressed by pro:edurt NC.NA-AP.ZZ-0006(Q). " Incident Report / Reportable Event Program and Quality Safety Concern Reporting System," Revision 2.

Tracking of deficiencies that result in Incident Reports (irs) or Licensee Event Reports (LERs)- is addressed in NC.NA. AP.ZZ-0057(Q), " Action Tracking Program,"

Revision I.

Station procedure HC SA-AP.ZZ-027(0), " Station Inservice Inspection and Testing Program," Revision 5, describes Inservice Inspection (ISI) and Inservice Test (IST) programs and their respective pregram manuals.

The General Manager of Nuclear Services through the Manager of Site Services has the overall responsibility for the ISI program.

The General Manager

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of Hope Creek Operations is responsible for assuring that ISI and IST activities required by the Station TS are identified and responsibilities assigned. -The General Manager of Hope Creek Operations has overall responsibility for implementation of the program, including the preparation of all required procedures and assigning responsibilities to the Station Technical Manager, Station Operations Manager, and Station Maintenance Manager.

The Manager of Licensing and Regulation ensures that regulatory requirements related to the ISI and IST programs are met, and the General Manager of Quality Assurance (QA)/ Nuclear Safety Review audits and reviews the ISI and'IST programs.

QA also certifies personnel performing visual examinations and conductsSection XI preservice visual examinations.

Conclusion The Surveillance Test Program is well documented.

Approved surveillance test procedures are detailed and clearly written.

Automated control /

tracking systems and QA coverage ensure the program conforms with TS requirements.

3.3' Inspection Review The-inspector observed an IST surveillance of the Reactor Core Isolation CoLling (RCIC) Pump 203 conducted by Operations and monitored by QA and Radiation Protection personnel. Also observed were two functional test surveillances conducted by Instrument and Controls (I&C)

personnel in Maintenance, and a weekly surveillance conducted by a Reactor Engineer and an I&C technician.

The surveillances listed in Attachment 2 were conducted satisfactorily in accordance with approved surveillance test procedures.

In preparation for the functional test of Drywell Pressure Channel C71-N6500, an on-the-spot (OTS) change was made to the surveillance test procedure IC-FT-BB-022(Q).

The change allowed the use of the test jacks permanently installed by Design Change Package

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(DCP) 204 for convenience and safety in performing surveillances and troubleshooting.

The licensee uses several means to change or revise a I

procedure depending on the safety significance or the urgency of the

change or revision.

In this case, the surveillance could have been performed satisfactorily without the OTS change and the procedure would have been revised during the close out process of the DCP.

I&C supervision chose to implement the OTS change to take advantage of the test jacks.

The inspector had no questions regarding the course of action taken.

The inspector reviewed the records of completed surveillances and verified that the records are properly filed, readily accessible and complete.

Records reviewed include:

Off-Normal Response Forms, Attachment 2 to procedure HC-CH-TI-ZZ.0012(Q), " Chemistry Sampling Frequencies, Specifications-and Surveillance," Revision 14; ISTs, and Battery Surve111ances.

In keeping with procedure SE-AP.ZZ-048(Z),

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" System Engineering Station Performance Monitoring," Revision 2, records for battery surveillances not only include test results but also trends.

The system engineer is able to determine when specific cells in a battery bank should be replaced.

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Program effectiveness is measured through the efforts of Onsite Safety Reviews; Scram and Power Reduction Elimination (SPRE) results; Human Performance Enhancement System (HPES); Significant Events Response Teams (SERT) results; QA Audits and Surveillances; as well as the analyses of Incident Reports and Licensee Event Reports (LERs). The inspector was provided examples of these efforts.

The inspector reviewed the training and qualifications related to the Surveillance Test Program through the use of the Action Tracking System (ATS) program.

The personnel observed conducting surveillances were determined to be qualified. _ Management also requires that members of SPRE, SERT, the LER Coordinator, as well as Station and Engineering managers

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receive investigative interviewing and root cause and decision making analysis training.

By 1995, the licensee expects all their technical staff personnel to receive this training.

The inspector reviewed a QA Audit No.90-170, " Surveillance Testing,"

issued on September 13, 1990.

The audit was conducted in accordance with Procedure GM-9 QAP 6-1, " Quality Assurance Audits," Revision 8.

All items have-been corrected.

QA Audit No.- 91-142, " Maintenance," issued on May 21, 1991, addressed minor surveillances concerns.

Also reviewed were

- twelve.1991 QA Surveillance Reports and the inspector noted no discrep-ancies were reported.

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1 Conclusion The Surveillance Test Program is satisfactorily implemented, and the licensee is further improving the program's performance to ensure safe operation of the facility.

4.0 Exit Meeting Licensee management was informed of the scope and purpose of the inspection at the entrance meeting conducted on May 20, 1991.

The findings of the inspection were discussed periodically with licensee representatives during the course of the inspection. An exit was conducted on May 24, 1991, at which time the findings of the inspectors were presented.

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Attachments:

1.

Persons Contacted 2.

Documents Reviewed

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ATTACHMENT __1 PERSONS CONTACTED Public Service Electric and Gas Company

'A. Barnabei, Principle Engineer, Nuclear QA J. Buchanan, Senior Operations Supervisor - Pad Waste

  • J. Clancy, Radiation Protection / Chemistry Manager C. Fuhrmeister, Senior Staff Engineer
  • S. Funsten, Maintenance Manager
  • J. Hagan, General Manager - Hope Creek Operations F. Hughes, Senior haclear Shift Supervisor J. Morrison, Project Manager
  • W. O'Malley, Operating Engineer P. Opsal, Technica: Engineer
  • 0. Pease, Safety Review Engineer J. Rucki, Electrical and Instrument and Control Engineer R. Ritzman, Engineer - Technical Staff
  • J. Samson, P&MC Inventory Control W. Schell, Technical Engineer
  • W.

Schmick, Senior Maintenance Supervisor

  • M.

Sesok, Site Representative of Atlantic Electric

  • D.

Smith, Station Licensing Engineer C. Smith, Principal Engineer Planning and Scheduling C. Taylor, Human Performance Enhancement Systen Engineer

  • J. Thompson, Technical Engineer Hope Creek Operations T. Wysocki, Senior Nuclear Maintenance Supervisor U.S. Nuclqa r Regul a_ tory Commi s_sion
  • K. Lathrop, Resident inspector
  • N. Blumberg, Chief, Performance Programs Section
  • M. Carey, Engineering Assistant (CD-OP)

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' Denotes those presert at the exit meeting held on May 24, 1991 The inspectors also contacted other administrative and technical personnel during the inspection.

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ATTACHMENT 2 DOCUMENTS REVIEWED PROCEDURES NC.NA-AP..ZZ-0006(Q), Rev. 2 Incident Report / Reportable Event Program and Quality Safety. Concerns Reporting System i

NC.NA-AP.ZZ-0057(Q), Rev. 5, Action Tracking System l

NC.NA-AP.ZZ-0061(Q), Rev. 1, Significant Event Response Team Management l

HC.SA.AP.ZZ-012(Q),_ Rev. 9, Technical Specification Surveillance Requirements HC.SA. AP.ZZ-027(Q),

Rev. 5, Station Inservice Inspection and Testir g Program I

HC-0P-IS.80-0001(Q), Rev.10, Reactor Core lillation Cooling Pump OP203 IST HC-CH-TI.ZZ-0012(Q), Rev.16, Chemistry Frequencies, Specifications, and Surveillances HC-CH-TI.ZZ-0013(Q), Rev. 3, Chemistry Logs and Data Handling Program

SE-AP.ZZ-048(Z),

Rev. 2, System Engineering Station Performance Monitoring I

IC-FT.FD-007 (Q),

Rev. 1, Functional Test HPCI DIV 1 Channel E41-N656A IC-FT.BB-022(Q),

Rev. 3, Functional Test NucBir DIV 4 Channel C71-N6500 NC.NA-AP.ZZ-0054(Q), Rev. O, Operating Experience Feedback Program NC.NA-AP.ZZ-0031(Q), Rev. O, Artificial Island Inspection / Housekeeping Program SA-SD.ZZ-22, Rev. 2, Fixed Housekeeping Area Assignment HC.0P-ST.KJ-0001(Q), Rev.14, Emergency Diesel Generator' AG400 Operability Te c -

Monthly NC.NA-AP.ZZ-0013(Q), Rev. O, Control of Temporary Modifications NC.NA-AP.ZZ-0009(Q), Rev. 2, Work Control Process SA-AP.ZZ-044(Q),

Rev. 1, Station Aids and Labeling Practices

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Attachment 2 Cont'd

Documents

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Licensee letter to NRC of February 4, 1991, regarding "D" EDG Failure to~5 tart Incident Report 91-074, "0" EDG Failure to Start, Issued May 22, 191 Chemistry Log for Off-Normal Responses91-012(CRD), 066(CST), 245(Dearator)

Effluent Monitoring Action Statements91-122, 123, 124, 127 and 531

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Licensee Event Reports 90-11, 15, 16, 22, 24, 26, 27, 28, 31, 32, 91-01, and 03 Technical Specification Surveillance Responsibilities Matrix ISI Tests Work Order Nos. 910418037, 920817014, 91050617, 90206011, 90409067, and 910413043

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IST Work Order Nos. 901206039, 91011019, 91011037, 910223028, 910317040 QA Surveillance Reports90-093, 103, 105, 113, 151,_476, and 511,91-029, 102, 112, and 113 QA Audit 90-170, Surveillance Testing, issued September 13, 1990 QA Audit 91-142, Maintenance, issued May 21, 1991 Procurement and Material' Control, Monthly Performance Indicator Report -

March 1991 Station Aid Log Form, Serial Number ICA-089-11 i

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