ML18082A534
| ML18082A534 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 06/03/1980 |
| From: | Schneider F Public Service Enterprise Group |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8006110231 | |
| Download: ML18082A534 (8) | |
Text
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rick W. Schneider Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201/430-7373 Production June 3, 1980 Mr. Boyce H. Grier, Director Off ice of Inspection and Enforcement USNRC Region 1 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Grier:
NRC INSPECTIONS 50-272/80-04 AND 50-311/80-01 UNIT NOS. 1 AND 2 SALEM GENERATING STATION We have reviewed the report of your* inspections conducted on January 28-31 and February l, 4-7, and 11-13, 1980.
Our response to those items of non-compliance identified in Appendix A of your Inspection Report are as follows:
The infraction in your Appendix A, Item A states:
A.
10 CFR 50, Appendix B, Criterion V, states in part, "Ac-tivities affecting quality shall be prescribed by documented instructions, procedures *** of a type appropriate to the circumstances ** ~**"
Listed below are two examples of failure to develop/estab-lish appropriate instructions/procedures:
FSAR Amendment 43, Section D.2 states in part, "Engi-neering Department *** (3} Is responsible for identi-fying structures, systems and components covered by the QA Program *** " Station Procedure. AP-17, The Electric Production Department Quality Assurance Program at Salem Generating Station, Revision 5, Paragraph 2. 4.* 1 states in part, "The General Manager - Engineering is responsible for: a) Maintaining and Updating the Master Equipment List (MEL) *** "
Contrary to the above, as of February 13, 1980, the licensee had not developed MEL's for either unit.
FSAR Amendment 43, Section D.2 states in part, "These activities shall be performed in compliance with..* (8)
Regulatory Guide 1. 64 *** " which endorses ANSI N45. 2.11-July 1973, Quality Assurance Requirements for the De-sign of Nuclear Power Plants.
Paragraph 4.3 of the standard states in part, "Procedures shail be estab-
Boyce H. Grier, Director 6-3-80 lished for the preparation and control of drawings.
Typical subjects to be covered by such procedures are: *** (10) As-Built Drawings.** "
Contrary to the above, as of rebruary 13, 1980, the licensee had not established procedures tha,t: addressed how users of con-trolled drawings from the station Technical Document Room would be alerted that a given drawing was affected by a recent modifi-cation; nor how Control Room operators are alerted to and receive as-built information on recent modifications that affect those drawings utilized for plant operation.
Reply to Item A:
- 1.
Master Equiprne*nt List The Master Equipment List which is in the process of development for ea,ch Salem Unit will expand existing methods of compliance with the requirements for identi-fication of systems and components subject to the QA program.
This requirement had been met previously with proper equipment identification in source documents such as the FSAR, specifications and system descrip-tions.
A document which is the predecessor of the MEL identified the classification of equipment during the pre-operational stages of Salem Units 1 and 2.
This document was known as Project Directive #7 (PD-7).
Since PD-7 *is not totally effective for use in an operating plant, a new listing (MEL) is being developed which will better serve the needs of the operating units.
Until the MEL is finalized, proper identification of safety-related equipment is achieved by station per-sonnel query of the Enginee*ring Department through use of a "Request for Item Classification" form whenever the proper identification is not known.
This system is used primarily for procurement of spare parts.
The existing procedures used to properly identify equipment meet the intent of the QA program requirements.
It is expected that the MEL for Salem #2 will be issued by September 30, 1980 and that the Salem #1 MEL will be issued by June 30, 1981.
- 2.
As-Built Drawings Control As identified by the inspector, there is a period of time from the implementation of a design change to the distribution of revised as-built drawings, where s'tation controlled drawings may not depict as-built conditions.
Administrative Procedure No. 12 (AP-12) will be modified
Boyce H. Grier, Director 6-3-80 to provide *prompt notification to the station Technical Document Room of any issuance, for implementation, of a Design Change.
The notification will be made by the Station Planning_IDlginee_r_.____The-Techni-ca-l.-Dc:::>e-wnen~oom>-------:
~will then provide notification to all holders of con-trolled drawings affected by each newly issued Design Change Package; Departments receiving this notifi-cation will, in turn, mark or annotate the affected drawings to alert any person using them of changes being implemented.
Additionally ~he Electric Production Training Center has developed a format and is presently implementing a program whereby operations personnel are briefed on all design changes affecting operations.
This will complement the modifications to AP-12 speci-fically for control room operators.
It is expected to have fully developed the'se_.programs by August 1, 1980, and to implement them by September 30, 1980.
The Infraction in your Appendix A, Item B states:
B.
10 CFR 50, Appendix B, Criterion V, states in part, "Ac-tivities affecting quality shall be prescribed by documented instructions, procedures *** and shall be accomplished in accordance ~ith these instructions, procedures *.* "
Listed below are three examples of failure to accomplish ac-tivities in accordance with *established instructions/procedures:
Station procedure AP-8, Station Design Changes, Tests and Experiments, Revision 4, requires that the design change package (DCP) forwarded from the corporate offices to the station for implementation have attached or include: the written safety evaluation which pro-vided the bases for the determination that the modif i-cations/tests did not involve unreviewed safety questions; material lists; applicable specifications; the mode of operation, priority and implementation request date entered on the "Design Change -Request Form"; and, all required ADCN's (detailed instructions from appropriate engineers)
- Contrary to the above, six DCP's did not include or have attached in one instance or another all of the
- r'equired information {_this example applies to Unit* 1 only).
FSAR Amendment 43 establishes a commitment to ANSI NlB.7-1976, Administrative Controls and Quality As-surance for the Operational Phase of Nuclear Power Plants.
Paragraph 5.2.7 of that standard states that the *guidance of ANSI N45.2.8, Supplementary Quality
Boyce H. Grier, Director 6-3-80 Assurance Requirements for Installation, Inspection and Testing *** of Nuclear Power Plants, shall be applied to operating plants.
ANSI N45.2.8 requires that a system
~~~~~~~~~~-o-£--controts-be-~~~ab--il.snea.-to assure that as-built information is being processed.
Station procedure AP-17, paragraph 5.4 states in part, "The General Manager-Engineering is responsible for: *** Ensuring the copies of these documents (e.g., drawings) at the station are kept current by incorporation of imple-mented design changes."
Contrary to the above, five controlled drawings in the Control Room and eight controlled drawings in the station Technical Document Room did not depict the latest as-built conditions, were not annotated in some fashion attesting to this fact, nor was there a method by which a user could determine the as-built condition (this applies to Unit 1 only).
The "Introduction" to the Engineering Department Oper-ating and Design Procedures (EDODP) Manual establishes a requirement that all department procedures be re-viewed on an annual cycle and revised as necessary if the review so indicates.
Contrary to the above,* the Controls, Design, Electrical and Mechanical Divisions of the Engineering Department did not review on an annual cycle fifteen procedures (five ea_ch) that were sampled.
Reply to Item B:
- 1.
Design Change :Packa:ges Six (6) "issued for installation" DCR packages were cited in the subject audit report as being incomplete by nature of not containing one or more of the follow-ing items:
- a.
written safety evaluation
- b.
material lists
- c.
applicable "specifications
- d.
mode of operation
- e.
priority
~.
implementation request date The subject audit report stated that Station Procedure AP-8 require~ inclusion of all of the above items in every DCP.
AP-S's only requirements concerning the above items which are applicable to all DCR packages are that (l) each DCR contain a written safety evalu-
Boyce H. Grier, Director 5 -
6-3-80 ation (10CFR50.59l and (2) that the design change be presented in sufficient detail, in a format determined
-1 by the Engineering Department, to correctly instali_the~~~~~
~~~~~~~~~~,a-esign change.
Item *a:
Writteh Safety" Evaluation All six referenced packages were examined by the En-gineering Department and found to contain safety evalu-ations in compliance with AP-8.
Items b & c:
Material Llsts and Applicable Specifications The inclusion of items b and c, material lists and applicable specifications, in DCR packages is governed by Engineering Department Directive No. 1 (EDD-1}, not AP-8.
EDD-1 states that inclusion 0£ Material Lists and Engineering Instructions (the portion of the DCR where "applicable specifications" would be found} are not mandatory, but rather discretionary on the part of the engineer in keeping with an adequate presentation of the design.
Specifically, lED-0183 concerned only reinstallaion of presently installed pump components after shop coating and hardfacing.
Instructions furnished in the package to the field forces were adequate for the intended application.
IEC-0379 did include a list of materials, although it was annotated "none", as the only materials required were small pieces of structural steel shapes from stock.
Specification of the steel to be used, welding procedures and installation procedures were not included because the drawing revised by the ODCN con-tained all necessary reference information.
lEC-0479 did have a full set of piping diagrams, weld spreadout sheets and instructions upon issue.
IEC-0611A was initially issued and reviewed by SORC with Mechanical and Controls ODCN's, but without the Electrical ODCN's.
These ODCN's, issued later, only detailed cable pulls which where evident from the Controls ODCN's and hence did not represent a "major ch~nge" necessitating SORC re-review.
Corrective action has been taken, however, to preclude recurrence.
Item d :*
Mode of Operati*on AP-8 requires that a DCR initiator.indicate the plant mode of operation necessary to implement the change, if such information is known by the initiator.
A pro-cedural note states that if it is not known, it can be added by other involved organizations.
There is no requirement that the Engineering Department ensure
Boyce H. Grier, Director 6-3-80 identification of this information prior to issuance to the station for inst~llation. This information will, of necessity, be determined by responsible station personnel prior to OCR implementation.
- Item e: Priority AP-8 requires identification of a DCR priority for Station initiated DCR's, as does EDD-1 for Engineering Department DCR's.
The active use of a formal priority system was not in effect until just recently, and as such, identification of priorities on a formalized
- basis was not administratively enforced.
Priorities are an administrative restraint, and do not involve plant design or safety.
Item f:
Implementation *Request Date AP-8 only requires identification of an implementation request date for DCR's initiated by the station - i.e.,
the SC series.
For Engineering Department initiated.
DCR's, i.e., the EC series, EDD-1 regards identifi-cation of an implementation request date as discretionary.
All DCR's cited by the audit as missing this information were initiated by the Engineering Department, hence the information was not required.
Cor*recti ve Actions
- 1.
An administrative system, utilizing a form known as the "Construction Work Package Definition Record" is now in effect.
This system will ensure identification of all packages* to be issued on a DCR, and will preclude oversight of major job facets in the SORC review process.
- 2.
An active priority system will be in full effect by July 1, 1980.
All DCR's will be prioritized.
- 2.
As-Built Drawings Control Our response to Item A, Part 2, is applicable to this item with the additional comment that attached to each Design Change Package is an Operational Design Change Notice for each drawing that is affected by the design change.
The ODCN includes a sketch or diagram depicting the change to that specific controlled drawing.
A complete set of ODCNs for each Design Change is kept by the Station Planning Engineer and will also be made available by the program described in the response to Item A, Part 2.
Boyce H. Grier, Director 6-3-80
- 3.
Engineering Department Procedures
.The following action is being taken with respect to
_.....ng.ineer-ing-Depa-~"Gment---f);l;'eeedures---:
a)
All of the Divisions of the Engineering Department have been instructed to ensure that existing procedures are sufficiently accurate to assure proper control of safety-related activities as specified by the EDODP.
In some cases, procedures may have to be *revised to reflect minor differ-ences in organization and titles; the overall intent is to identify and correct any procedure which could result in improper control of safety-related activities.
b)
The overall design QA program is currently under review for possible modification.
This effort will include consideration of procedure review requirements.
c)
It is anticipated that the aforementioned activi-ties will be completed by September 1, 1980.
The Deficiency ;i..n Appendix A, Item C States:
- c.
10 CFR 50, Appendix B, Criterion XVII, states in part,
" *.* the ap~licant shall establish requirements con-cerning record retentions, such as duration, location, and assigned re~ponsibility."
FSAR Amendment 43, Section D.2.17 states in part, "Records *** shall be identified and maintained in accordance with Regulatory Guide 1.88 **. Design and Construction records are replicated via microfilm and stored in the record facility maintained at the gener-ating station and off-site locations."
Contrary to the above, original single copy records as-sociated with five Design Change Packages which were transmitted from the station to the corporate offices between July 1977 and January 1978, had not been micro-filmed and were stored at one location only (corporate engineering offices) in non-fire rated steel cabinets (this applies to Unit 1 only).
Reply to Item C:
Copies of the five referenced Design Change Packages (DCPs) that were transmitted to the corporate offices were *1ocated on site subsequent to the completion of NRC Inspection 80-04.
A program has been initiated to
,i.
Boyce H. Grier, Director 6-3-80 assure that copies of all DCPs are available at the station at all times; this program includes review of Design Changes currently in progress.
If you have any further questions with regard to this matter, we will be pleased to discuss theni with you.
Sincerely,
~LJ.
CC Director, Office of Inspection and Enforcement NRC Washington, DC 20555 l