ML18086A854

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IE Insp Repts 50-272/81-03 & 50-311/81-04 on 810209-13 & 18. Noncompliance Noted:Untimely,Inadequate & Ineffective Corrective Actions Re Nonconformances Covering Design Change Notice & Missed Plant Surveillances
ML18086A854
Person / Time
Site: Salem  
Issue date: 07/05/1981
From: Caphton D, Napuda G, Norrholm L, Shaub E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18086A852 List:
References
50-272-81-03, 50-272-81-3, 50-311-81-04, 50-311-81-4, NUDOCS 8108100179
Download: ML18086A854 (10)


See also: IR 05000272/1981003

Text

U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

Report No.

50-272/81-03

50-311/81-04

Docket No.

50-272

50-311

Region I

c

DPR-70

License No. DPR-75

  • Priority -----

Category ___ c __ _

Licensee:

Public Service Electric and Gas

80 Park Plaza - 15A

Newark, New Jersey 07101

Facility Name:

Inspection at:

Salem Nuclear Generating Station, Units 1 & 2

Hancocks Bridge ;-and Newark,; New Jersey

-

'**

-

-

Inspection conducted:

February 9-18, 1981

A.,,/~

Inspectors: ?(~~ _ ,, _)

G *{feua' Reactor Inspector

Approved by:

Inspection Summary:

Inspector

, Management

DE&TI

da

{lgrred

tle

6~

datsigl1ed

Ins ection on February 9-13 and 18, 1981 (Combined Ins ection Re ort No.

50-272/81-03; 50-311/81-04

Areas Inspected:

Routine unannounced inspection by two region-based inspectors of

QA Program implementation including QA Program Annual Review; QA/QC Administration

Program; Qualification o.f Personnel; Design change and Modifications; Audits; Corrective

Action; and, licensee action on previously identified inspection findings.

The

inspection involved 64 inspector-hours onsite by two region-based inspectors and 34

inspector-hours at the corporate offices by two NRC region-based inspectors and the

Resident Inspector .

Results:

Of the seven areas inspected, no items of noncompliance were identified

in four areas and one item (three examples} of noncompliance was identified in three

areas (Violation-- untimelyj ,fnadequat~ ~~d tneffectiv~ corrective actions,

____ Paragraphs 4. c and 7).

.

.

- s1oe1oo-1798io724~

PDR ADOCK 05000272

G

PDR

DETAILS

1.

Persons Contacted

  • J. Boettger, General Manager-QA Engineering and Construction
  • F. Christiana, Chief Controls Engineer
  • N. Dyck, QAD Engineer
  • C. Hug, Lead Engineer
  • J. Krauth, Chief Desi:gn Engineer
      • L. LaVecchia, QA Co6rdinator

B. Leap, QAD Engineer

    • H. Lowe, QAD Engineer
    • F. Meyer, Manager-QA Operations and Maintenance
    • H. Midura, Station Manager
  • A. Nassman, Manager - QA Engineering and Construction
  • M. Rosenzweig, QAD Engineer
  • G. Schneider, QAD Engineer
    • J. Stillman, Station QA Engineer
  • R. Underitz, General Manager - Nuclear Production
  • W. Valaika, QAD Audit Division Head

NRC Personnel

W. Hill, Resident Inspector

    • L. Norrholm, Senior Resident Inspector
  • denotes those present at the exit interview conducted at the Newark, New

Jersey corporate offices on February 13, 1981.

    • denotes those present at the exit interview conducted at the Salem

Station on February 18, 1981.

      • denotes those present at both exit interviews.

2.

Licensee Action on Previous Inspection Findings

(Closed) Unresolved Item (50-272/79-28-04):

Review effectiveness of corrective

action.

Based on the inspection findings discussed in Paragraph 7 this

item is closed.

(Closed) Infraction (50-311/80-01-02):

Failure to establish appropriate

procedures.

Based on the inspection and findings discussed in Paragraph 7

this item is closed .

3

(Open) Infraction (50-272/80-04-02):

Failure to establish appropriate

procedures.

Based on the inspection and findings discussed in

Paragraph 7 this item remains open pending verifications that the

Unit No. 1 MEL is issued by June 30, 1981.

(Closed) Infraction (50-272/80-04-03; 50-272/80-01-03):

Failure to

implement/follow established procedures.

The inspectors reviewed

objective evidence and interviewed engineering personnel to determine

that the implementing procedures in the manuals of the four divisions

of the Engineering Department have been reviewed and revised as

necessary.

Based on the findings of IE Inspection Reports 50-

272/80-19 and 50-311/80-14, and the findings discussed in Paragraphs

4 and 7 of this report~ this "item ts c*1 osed.

(Closed) Unresolved Item (50-272/80-04-04; 50-311/80-01-04):

Drawing 207522 depicted local pressure indicator PL1047 at a different

location in Auxiliary Feedwater System than as-built condition is

indicated on Drawing 20523.

The inspector reviewed Revision 13

dated June 19, 1980 to drawing 207522 and verified it depicted the

correct location of pressure indicator, PL1047.

(Closed) Deficiency (50-272/80-04-05):

Completed single copy

Design Change Packages ED 0173, 0174, 0183, 0227 and 0268 were

transmitted from Station to the corporate offices:and _stored in non-

fire rated steel cabinets.

The inspector verified that.the subject

design change packages were also recorded on m1crof1lm 1n the Station

Technical Document Room.

(Closed) Unresolved Item (50-272/80-19-01; 50-311/80-14-01):

Corrective action associated with audits of document control area.

The inspector reviewed documented results of followup action with

respect to Licensee Audits 79-3-G.l-3(R) and S0-80-05.

With the

exception of a chemistry procedure yet to be issued all required

corrective actions on these audit findings had been verified as

accomplished.

The inspector noted that another audit of this area

was scheduled for February 23, 1981.

Based on the foregoing and

the findings discussed in Paragraph::5, thi~ item is closed.

(Closed) Deficiency (50-272/80-19-02; 50-311/80-14-02):

Unsatisfactory

warehouse hold area conditions and discrepancies with respect to

warehouse housekeeping inspections.

The inspector verified that

the subject inspection records ~enerated since the initial finding

were *s; gned* by the i nspectthg official and tpen transmitted ,

..

to the Technical Document Room for microfilming.

The inspectors

also toured the warehouse and noted that though conditions were

4

somewhat crowded the hold areas were clearly marked.

A recent

Boric Acid shipment that was in a hold status was securely roped in

with several hold tags displayed in easily seen locations.

The

inspectors al so noted that a quantity of previously aq:epted material,

turned over from the constructor, was being re-reviewed/inspected

for incorporation into the licensee's warehouse stock.

The licensee

representative stated that management consideration is being given

to enlarging warehousing capability.

Based on the foregoing this

item is closed.

(Closed) Deficiency (50-272/80-19-03; 50-311/80-14-03):

Failure to

provide objective evidence that proper environmental conditions

were met during calibration of test equipment used in safety related

maintenance (John Fluke Multimeter Nos. PD-003, 004 and 187).

The

inspector verified that the Temp-Humidity recorder was installed in

the calibration lab and reviewed the subsequent recalibration data

for the three multimeters.

All three meters were within specifications,

therefore no other licensee followup action was necessary.

3.

QA Program

a.

References

FSAR Admendment 43, Appendix D - Quality Assurance

Quality Assurance Manual Volumes 1, Policies and Procedures

and 2, Salem QA Instructions.

Implementing procedures referenced in subsequent paragraphs

of this report.

b.

Program Review

The inspectors reviewed the changes made to the QA Manual,

organization and implementing procedures in order to ascertain

that they were consistent with the QA Programs as described in

the FSAR Appendix D.

c.

QA/QC Administration

The inspectors reviewed the referenced documents to verify

that:

The scope and applicability of the QA Program were

defined.

Appropriate controls were established to prepare, review

and approve QA Program procedures, including changes

thereto.

A mechanism has been established to review and evaluate

the QA Program.

d.

Findings

The licensee has recently reorganized the QA organization to

have the onsite QA functions (QA/QC and Audits) be the responsibility

of the Corporate QA Department.

QA Procedure 1, Organization, Revision 10, 12/1/80; and QA

Instruction 1-1, PSE&G Corporate QA Department, Revision 3,

12/1/80; have been revised to reflect the new organization and

delegate the authorities and responsibilities necessary to

implement the QA program.

The licensee stated that those implementing procedures that it

is necessary to change so as to reflect the present QA organization

authorities and responsibilities, are expected to be revised

during the next three months.

The licensee stated that the

current implementing procedures (QAI 1 s, AP-17 and OQI 1 s) will

be followed until revised.

The licensee is also evaluating the current QA Manual to

determine if the structure or content should be changed.

In

addition, the licensee is evaluating QA positions/personnel to

determine if changes in authorities, duties and responsibilities

are necessary.

The inspector stated this area will be reviewed during subsequent

routine inspections.

4.

Design Change/Modifications

a.

References

Engineering Department Directive No. 1, Operational

Design Change control - Salem Nuclear Generating Station,

Revision 1.

AP-8, Station Design Changes, Tests and Experiments,

Revision 4

b.

6

Review

The inspectors selected and reviewed the design changes listed

below to verify, as applicable, that:

they were accomplished

in accordance with 10 CFR 50.59 and the licensee's QA Program

requirements; code requirements and specifications were

included; acceptance tests including acceptance values and

standards were included; records of equipment performance were

reviewed and accepted; and, prints/drawings and operating

procedures were revised (a sample).

The Design Change Packages (DCPs) reviewed were:

1EC-0414A, Service Water System

lEC-0430, Solid State Protection System

lEC-0574, Emergency Diesel Generator Air Start

lEC-0973, Sampling System Containment Penetrations

lEC-1034, Main Steam Isolation Valve Remote Operating Switch

2EC-1035, Main Steam Isolation Valve Remote Operating Switch

c.

Findings

In their June 3, 1980, letter to RI describing corrective

actions for unacceptable conditions identified during IE

Combined Inspection 50-272/80-04; 50-311/80-01 the licensee

stated that the Technical Document Room (TOR) would receive

prompt notification via an Operational Design Change Notice

(ODCN) of any engineering drawings affected by a Design

Change and that this action would be implemented by September

30, 1980.

The inspectors noted that the corrective actions described in

the licensee's letter to RI dated June 3, 1980, had been

incorporated into each of the above DCPs with the exception

noted below.

The

inspectors identified that the implemented corrective

action was not adequate in that Revision 2 to DCP lEC-1034 had

been issued by site engineering but had not been received by

the TOR as of February 18, 1981.

The Design Change Document

Status List (a part of the DCP) indicated that revised ODCNs

C3/01, C4/01, C5/01 and C6/01 affected Drawing 231407-A-1403.

The inspector reviewed the latest as-built drawing and determined

that it did differ from the as-built information available in

the TOR for operating personnel.

The inspector also concluded

that no safety concern existed .

5.

7

In order to ascertain if the above was an isolated instance

the inspector selected three additional DCPs that had been

revised by site engineering with the following results:

lEC-0722, Revision 4 was the current DCP status and the

TOR had that revision;

lEC-0663, Revision 12 was the current DCP status while

the TOR had only Revision 8; and,

2EC-0550, Revision 2 was the current DCP status while the

TOR had Revision 1.

All four of the above DCP rev1s1ons had been issued by site

engineering during November-December, 1980.

The three instances identified above where the TOR did not

have current as-built information constitute an example of

inadequate corrective action that is included into the item of

noncompliance discussed in Paragraph 7 .

Audits

The inspectors reviewed the audits listed below.

These audits were

reviewed to verify that they were conducted as follows:

in accordance

with written checklists/procedures; by trained personnel not having

direct responsibility in the area(s) audited; with findings documented

and reviewed; with followup actions initiated/completed/closed out;

and, with audit frequencies and general audit conduct in accordance

with established standards.

S-80-9 Radwaste, Radiation Protection, SNM and Analytical

Measurements

Cooperative Management Audit, October 10-24, 1980.

The inspectors also reviewed the corporate and site audit/surveillance

schedules.

The inspectors noted that existing schedules are being

followed during the reorganization phase of the Quality Assurance

Department.

No unacceptable conditions were identified.

~-

6.

Review of Personnel Qualifications

The licensee has appointed individuals to fill the positions of

General Manager -Quality Assurance and Manager - QA Operations and

Maintenance.

The inspector reviewed the qualifications of and interviewed these

individuals to verify that their qualifications were consistent

with the Quality Assurance Program requirements and ANSI 18.1.

No unacceptable conditions were identified.

7.

Corrective Action

The inspectors reviewed corrective actions associated with previously

identified findings (reference Paragraph 2), control of design

changes/ modifications (reference Paragraph 4) and occurrences that

usually require Licensee Event Reports (LERs - Reference Paragraph

5 and 6.b in IE Report 50-272/79-28).

This review was made to

determine that corrective action in these various areas was:

Timely, i.e., accomplished within a required/specified time

frame as conditions or commitments dictate;

Adequate, f;e., corrected all of the causes of identified conditions

adverse to quality; and,

Effective, f~e., prev~nt recurrent or similar conditions adverse

to quality.

The two examples discussed below and the example in Paragraph 4.c

constitute an item of noncompliance for untimely, ineffective and

inadequate corrective action (50-272/81-03-01; 50-311/81-04-01).

(a)

The Senior Resident Inspector had documented his concern about

the effectiveness of licensee corrective action in IE Report

272/79-28 with respect to recurring instances of missed plant

surveillances (Paragraph 5 of that report) and the collapse of

a CVCS Holdup Tank that was similar to events detailed in IE

Circular 77-10.

The Senior Resident Inspector identified that surveillances

continue to be missed as evidenced by the following LERs.

,, ,

9

80-42/03L, Missed 24 volt Battery surveillance

80-52/03L, Missed inservice inspection of valves

80-66/03L, Missed Fire Detection instruments surveillance

The above, LERs 78-14, 78-15, 78-25, 78-34, 79-15, 79-17, 79-

22, 79-23, 79-25 and 79-30 (Referenced in the subject IE

Report), and the CVCS Holdup Tank collapse are instances of an

example of ineffective corrective action.

This example is

included in the item of noncompliance discussed below.

The Senior Resident Inspector informed the licensee of this

example of an item of noncompliance during a meeting on March

2' 1981.

(b)

In a response (dated June 3, 1980) to IE Inspection Reports

50-272/80-04 and 50-311/80-01, dated May 6, 1980, the licensee

stated that corrective actions in the following areas would be

accomplished by the specified dates.

Engineering Department Procedures by September 1, 1980

Incorporation of five Design Change Packages into the

records system prior to the licensee's response letter

An administrative system established for overall control

of the content and information of a Design Change Package.

Material Equipment List (MEL) for Unit No. 1 issued by June

30' 1981.

A Training Program whereby operations personnel are briefed

on all design changes affecting operations fully implemented by

September 30, 1980.

Material Equipment List (MEL) for Unit No. 2 issued by

September 30, 1980.

Revision and issuance of a station procedure addressing

as-built drawings/information and the proper use thereof

by September 30p 1980.

The issuance of the Unit No. 1 MEL by June 30, 1981 will be

verified during a subsequent inspection.

Also, verification

that the Electric Production Training Center has developed a

format and is implementing a program for briefing operations

personnel on modifications affecting operations will be followed

up in conjunction with Infraction 50-272/80-14-01.

10

The inspector identified untimely corrective action in that: The

Unit No. 2 MEL was not issued until November 3, 1980; and, Procedure

AP-3, designated by licensee management as the one to address as-

built information and its proper use, was not issued as of February

18, 1981.

Further, RI had not been notified of the non accomplishment

of this corrective action or the reasons therefore.

The licensee stated during the exit interview on February 18,

1981, that AP-3 had been reviewed and approved by SORC that

. day and would be issued the next day.

8.

Exit Interview

Licensee management was periodically informed of inspection findings

as follows:

Date

2/9/81

2/11/81

2/13/81

2/18/81

3/2/81

Report Paragraph

Entrance Interview, 2,

2, 3,_4 and 6

2, 3, 4, 5, 6 and 7

2, 3, . 4, 5, 6 and 7

7

A summary of inspection findings was provided to the senior licensee

representatives at the corporate offices on February 13 and at the

station at the conclusion of the inspection (denoted in Paragraph

1).

The results of the inspection were also discussed between the

licensee and the Senior Resident Inspector during a meeting on

March 2, 1981.

The licensee acknowledged the inspectors' findings.