ML20050C431
| ML20050C431 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/16/1982 |
| From: | Caphton D, Meyer G, Napuda G, Shaub E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20050C415 | List: |
| References | |
| 50-272-82-07, 50-272-82-7, 50-311-82-06, 50-311-82-6, NUDOCS 8204080496 | |
| Download: ML20050C431 (12) | |
See also: IR 05000272/1982007
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U.S. NUCLEAR REGULATORY COMMISSION
Region I
50-272/82-07
Report No.
50-311/82-06
50-272
Docket No.
50-311
C
License No. DPR-75
Priority
Category
C
Licensee:
Public Service Electric and Gas
80 Park Place
Newark, New Jersey 07107
Facility Name:
Salem Nuclear Generating Station, Units 1 & 2
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Inspection At: Hancock's Bridge, New Jersey and Corporate Office
Newark, New Jersey
Inspection Conducted:
February 8-11 and 17-18,1982
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Inspectors:
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. W. Meyer,
actor, Ins ector
date signed
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.3. /.S~. T ~2.__
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E. T. Shaub, Reactor Inspector
date signed
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G. Aapuda, Reactor Inspector
date signed
Approved by:
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D. L. Caphton, Chief, Management
date signed
Programs Section, DETP
Inspections Summary:
Inspection on February 8-11 and 17-18, 1982 (Combined Report Numbers
50-272/82-07 and 50-311/82-06)
Area Inspected:
Routine unannounced inspection by three region-based inspectors
of design changes and modifications; facility modifications; audit program and
licensee actions on previous inspection findings. The inspection involved 46
inspector hours onsite and 56 inspector hours at the corporate office.
Results: Noncompliance: None in three areas; one in one area [ violation -
failure to address program effectiveness in QA Audit reports, para. 4.c.(1)].
02040804 % 820322
PDR ADOCK 05000272
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DETAILS
1.
Persons Contacted
- J. Boettger, General Manager, Nuclear Department
- J. Driscoll, Assistant-General Manager, Salem Operations
- N. Dyck, Assistant Manager, Quality Assurance (QA) Programs
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R. Evans, Manager, QA Audits and Training
- G. Harbin, Station Planning Engineer
C. Hug, Lead Engineer
C. Johnson, Assistant Vice President, Nuclear
- W. Keeffe, Senior Engineer, QA Audits
L. LaVecchia, QA Coordinator
- B. Leap, Supervisor, Station QA
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E. Liden, Manager, Nuclear Licensing and Regulation
- R. Mitt 1, General Manager, Corporate QA
M. Ochs, Senior Clerk, Technical Document Room
- F. Omohundro, Manager, QA Services
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- R. Silverio, Assistant to Manager, Salem Station
- J. Stillman, Station QA Engineer
- R. Stanley, Principal Engineer, Salem Projects Division
- W. Valaika, Section Leader, QA Audits
- E. Witkin, Senior Engineer, QA Audits
- J. Wroblewski, Principal Engineer, Controls Division
J. Zupko, General Manager, Nuclear Services
NRC
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L. Norrholm, Senior Resident Inspector
R. Summers, Resident Inspector
- denotes those present at the exit interview conducted at the Newark,
New Jersey corporate office on February 18, 1982.
- denotes those present at the exit interview conducted at the Salem
Station on February 17, 1982.
- denotes those present at both exit interviews.
2.
Licensee Action on Previous Inspection Findings
(Closed) Violation (272/80-04-02).
Failure to issue the Unit 1 Master
Equipment List (MEL).
The inspection verified that the Unit 1 MEL was
issued on July 9, 1981. Additionally, the inspector reviewed the temporary
Quality Assurance Instruction (QAI) and the revised administrative procedure
Based upon these findings, the item is closed.
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(0 pen) Violation (272/81-03-01; 311/81-04-01)
Failure to provide timely
and adequate corrective action in that;
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the Unit No. 2 Master Equipment List (MEL) was issued af ter the
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commitment date.
the program to provide prompt as-built information to station personnel
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was not fully implemented until six months after commitment date.
multiple examples of missed surveillance as documented by Licensee
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Event Reports (LER's).
The inspector reviewed the revised procedures, temporary QA Instruction
TI-1, Revision 0, September 24, 1980 and AP-3,' Revision 10, February 19,
1981 which were issued to provide a mechanism for updating and controlling
the MEL.
The inspectors verified that several recent revisions to Design Change
Packages (DCP's) and Operational Design Change Notices 00CN's) were
directly issued to the station Technical Document Room (10R) by the Salem
Projects Division field engineers. Direct issuance of DCP revisions to
the TOR maintains the station current with the necessary as-built information.
Additionally, the licensee plans to institute a Response Coordination
Team to be responsible for assuring the adequacy and timeliness of commitments
and responses. The inspector determined that the licensee has established
a station response coordinator.
However, the Response Coordination Team
and the implementing procedures have not been established.
The licensee's representative acknowledged the inspector's findings and
committed to establish and fully implement the Response Coordination Team
by July 1,1982.
This item will remain open pending licensee action and
subsequent NRC:RI review.
3.
Design Changes and Facility Modification
a.
Administrative Controls for Design Changes and
Facility Modification
Administrative controls governing the control and implementation of
Design Change Request (DCR's) and Design Change Packages (DCP's)
were inspected to determine their conformance with the requirements
of 10 CFR 50, Appendix B. " Quality Assurance Criteria for Nuclear
Power Plants and Fuel Processing Plants"; Technical Specification,
Section 6, " Administrative Controls"; ANSI 18.7-1976, " Administrative
Controls for the Operational Phase of Nuclear Power Plants" and
Regulatory Guide 1.33, Revision 2, 1978, " Quality Assurance Program
Requirements (Operation)".
The following procedures were reviewed:
AP-8, Design Change, Test and Experiment Program, Revision 5,
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January 8, 1982;
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Engineering Department Directive No. 1, Operational Design
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Change Control - Salem Nuclear Generating Station; Revision 3,
March 30, 1981;
Engineering Department Directive No. 4, Control of Design Input
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Analysis and Verification, Revision 1, May 19, 1981;
Engineering Department Organization and Design Procedure Manual,
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Section 11, Design Verification, Revision 3;
Mechanical Division (MD) Procedure 3.2, Design Control, Revision
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Mechanical Division Procedure 3.6, Design Verification, Revision
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Controls Division Procedure CP-83, Design Input and Verificatior.
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Requirements, Revision 0, August 3, 1981; and
Electrical Division Manual (EDS) Section 8, Design Input,
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Revision 2.
No violations were identified.
b.
Design Change and Modification Implementation
A selective sampling inspection was conducted of the Design Change
Packages listed below to verify, as applicable, that:
DCPs have been reviewed and approved in accordance with 10 CFR
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50.59, Technical Specification (TS) and the licensee's QA
Program;
Necessary TS revisions and FSAR admendments were completed and
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the NRC has approved the changes prior to implementation;
DCP's are controlled by established procedures;
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Code requirements and specifications were included;
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Acceptance tests, including acceptance criteria and evaluations
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were included;
Test deviations, resolution and retesting were included;
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Applicable procedures (i.e., operating, emergency, etc.) were
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modified and approved in accordance with Technical Specifications;
and,
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As-built prints and drawings were changed to reflect current
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modifications.
The DCPs reviewed were:
IEC-0538, Pressurizer Heater System
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1EC-0429, Steam Generator Pressure Sensor
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2EC-0640, Emergency Diesel Generator Jacket Water Heaters
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1EC-0641, High Density Fuel Racks Unit 1
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2EC-0642, High Density Fuel Racks Unit 2
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2EC-1062, Containment Isolation Pressure Setpoint
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2EC-0581, Liquid Rad Waste System
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2EC-0959, Safeguards Equipment Control (SEC)
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2EC-1267, Chemical and Volume Control - Valve 2CV5 Opening
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1EC-0424, Remote Shutdown Instrumentation
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c.
Findings
No violations were identified however the following unresolved item
was identified:
Technical Specification 6.5.2.7.a requires the Nuclear Review Board
(NRB) to review safety evaluations for changes to equipment or
systems completed under the provision of 10 CFR 50.59 "to verify
such actions did not constitute an unreviewed safety question." The
inspector determined that the NRB is adequately performing the .
reviews of unreviewed safety question for each design change package,
in that, all Station Operations Review Committee (SORC) meeting
minutes with attached DCPs and safety evaluations are individually
routed to each NRB member.
Each NRB member reviews the 50RC minutes
and then signs the attached routing slip (memo to NRB) indicating
either concurrence or disagreement with the unreviewed safety question
disposition.
50RC minutes are then placed on the NRB agenda and
discussed at the next scheduled NRB meeting.
Nuclear Review Board Administrative Procedure, NRBP-2, Review Practices,
Section D.4 requires that "if the NRB review verifies no unreviewed
safety question was involved, the meeting minutes will document that
fact, closing out the issue." The inspector reviewed NRB meeting
minutes and determined that the only documentation of this verification
was the numeric listing of SORC meeting minutes that the NRB reviewed
and closed out at that meeting.
The inspector questioned the adequacy of the documentation for close
out of the unreviewed safety question verifications in the NRB
meeting minutes.
The licensee's representative acknowledged the inspector's concerns
and stated that they would take the necessary steps to clarify the
documentation of these verifications in conjunction with the ongoing
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NRB reevaluation and reorganization. This item is unresolved pending
licensee action and subsequent NRC:RI review (279/82-07-01; 311/82-02-01).
4.
Quality Assurance Audits
a.
Requirements
The requirements governing _the performance of quality assurance
audits of safety-related areas are specified in 10 CFR 50, Appendix
B, " Quality Assurance Criteria for Nuclear Power Plants" and Technical
Specifications, Section 6, " Administrative Controls".
In addition,
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the PSE&G Quality Assurance Manual require compliance with the
requirements of ANSI N18.7-1976, " Administrative Controls for Nuclear
Power Plants", and ANSI N45.2.12-1977, " Requirements for Auditing of
Quality Assurance Programs for Nuclear Power Plants."
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Specifically, the above requirements specify that the audits achieve
the following:
The content of audit reports clearly defines the scope of the
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audit and the results.
Audits are conducted by trained personnel .,ot having direct
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responsibility in the area being' audited.
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Frequency of audits are in conformance with Technical Specifications
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and the QA program.
Appropriate followup actions (including reaudit, if necessary)
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are being taken, are in progress or are being initiated.
The audited organization's response to the audit findings is in
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writing. is timely, and adequately addresses the findings and
recommendations.
b.
Review
The inspector reviewed the following procedures to verify that the
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licensee maintains an administrative system to meet the above require-
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ments:
Quality Assurance Instruction (QAI) 18-1, " Audits by the Quality
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Assurance Department", Rev. 8, September 4, 1981.
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Quality Assurance Instruction (QAI) 18-3, " Audit of PSE&G OA
Program by Outside Agents / Auditors", Rev. 6, January 23, 1979.
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Nuclear Review Board (NRB) Procedure NRBP-3, " Procedure for
Administration of Audit Program", Rev. 2, February 2, 1980.
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Administrative Procedure (AP)-17, "The EPD Quality Assurance
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Program at the Salem Generating Station", Rev. 5, April 26,
1979.
In addition the inspector reviewed the following areas to verify
compliance with the requirements:
1982 audit schedule;
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1981 log of audits and audit reports;
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selective sample of six 1981 Salem audit reports;
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qualification records for three auditors; and
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Cooperative Management Audit Program (CMAP) 1981 Audit of
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PSE&G, November 23, 1981
c.
Findings
(1) Auditing of Effectiveness
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The inspector found that the PSE&G audit reports did not address
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the effectiveness of the program audited. ANSI N45.2.12-1977,
paragraph 4.4.4 and QAI 18-1, Attachment 1, Revision 2, paragraph
4 both require that the summary of results section include "an
evaluation statement regarding the effectiveness of the quality
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assurance program elements which were audited." The inspector
checked six audit reports issued within the last twelve months;
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none of the reports contained an evaluation statement regarding
ef fectiveness in the summary of results section.
This is a
violation (272/82-07-02; 311/82-06-02).
The licensee's representative acknowledged the inspector's
concern, but did not agree with the classification of it as a
violation.
(2) Audit Coverage and Frequency
(a) Operational Quality Assurance (QA) Program
Technical Specification 6.5.2.8(d) requires auditing of
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the " activities required by the Operational Quality Assurance
(QA) Program to meet the criteria of Appendix B, 10 CFR
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50, at least once per 24 months."
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The inspector'found no objective evidence that the licensee
had a system to ensure the necessary audit coverage. The
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licensee's representative stated that due to the magnitude
of the Operational QA Program, it is most practical to
audit the activities to the criteria of Appendix B,10 CFR
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50, as part of the audits of the functional areas in which
there is an interface, e.g., contractors, Engineering
Department, Training Department, etc.
However, the inspector.
found no current plan to show how the coverage of the 18
criteria of 10 CFR 50, Appendix B would be achieved by
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this method.
T,his item is unresolved pending licensee action and subsequent-
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NRC:RI review.
It represents the first of three examples
of unresolved item (272/82-07-03; 311/82-06-03).
(b) Actions Taken to Correct Deficiencies
Technical Specification 6.5.2.8(c) requires auditing at
-1 cast every 6 months of.the "results of actions taken'to
correct deficiencies occurring in facility equipment,
structures, systems, or method of operation that af fect
nuclear safety". As described in paragraph (a.) above,
the licensee stated that due to the magnitude of this
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area, it is most practical to audit corrective actions in
the various functional areas as part of the audits of
those functional areas; therefore, no single audit covers
solely corrective action.
The inspector found that the licensee had no plan to
eveloate or show how the various components of their
corrective action system (e.g., Corrective Action Request
(CAR), Licensee Event Reports (LER), Deficiency Reports
-(DR), operator feedback, etc.) would be covered within the
planned audits.
Further, the inspector found no evidence
of auditing of Deficiency Reports (DR's) within the-last
12 months, although DR's are part of the PSE&G corrective
action system and, as such, should be audited at least
every 6 months.
Based on this example, it is not clear
that auditing of corrective actions is being done in a
planned, comprehensive manner.
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This item is unresolved pending licensee action.and subsequent
.NRC:RI review.
It represents the second of three examples
ofiunresolved. item (272/82-07-03; 311/82-06-03).
(c). Fire Protection
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Technical Specification paragraphs 6.5.2.8 (h, i, and j)
require two types of audits:
((1))
"The Facility Fire Protection Program
and implementing procedures at least once per 24
months."; and
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"An independent fire protection and loss prevention
program inspection and audit ,. at least once-
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In addition, the Technical Specifications further require
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that the independent inspection / audit of ((2)) above be
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personnel or an outside' fire protection firm", and that at
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least once per 36 months the outside audit must be performed.
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The inspector'found the following:
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There is no. documented rathod to satisfy the required
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independent. inspection /a'udit of fire protection. NRB
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procedure NRBP-3 lists the other Technical Specification
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required audits,,but it omits fire protection audits.
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QAI 18-1 addresses only the audit of the. administrative
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procedures of the Fire Protection Program.
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Althoui;h-tiTere-Ti, 6iiFr%t.*a #ss prevention, there
a pr'ogram of outside
audits of fire protection an
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is no documentation that the.auc ts are performed by
auditors qualified technically to
spect fire protection,
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1.e., meeting the qualification req #,rements of
Branch Technical Position 9.5-1.
The audits are
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performed under the direction of Nuclesr Mutual
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Limited and are administratively contro led by,the
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Insurance Department. There is no evider.ge of any QA
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Departmentoverviewofthisoutsideauditgrogram.
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Findings of the outside audit do not become\\ Mart of
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the formal corrective action system. Therea) pears
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to be no use of the corrective action system thtilized
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by the QA Department, including issuing of Corh?ctive
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Action Requests, tracking of open commitments,
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tion of actions, etc. The findings are issued t the
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Vice President - Production with no~ apparent foll
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by the Insurance Department or the QA Department. i
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Thisitemisunresolvedpendinglicenseeactionand*k
subsequent NRC:RI review.
It represents the third o
three examples of the unresolved item concerning the g
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coverage and frequency of audits (272/82-0/-03;
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311/82-06-03).
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Thelicensee'srehr'esentativeacknowledgedtheunresolved
item concerning the coverage and frequency of audits.
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(3) Administrative Procedure (AP) 17
Technical Specification paragraph 6.8.1 states " Written procedures
shall be established, implemented, and maintained." The inspector
found that AP-17, the administrative procedure for station QA
personnel is incorrect due to the organizational change of
December 1, 1980. At that time the station QA personnel became
the responsibility of the corporate QA Department and no longer
reported organizationally to the Station Manager.
The earliest
commitment date for issuing a revised, correct AP-17 is December,
1982. The inspector stated that the planned use of an out-of-date,
incorrect procedure for two years: appeared to not comply with
the intent of assuring that conditions adverse to quality are
promptly corrected.
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The licensee's representative stated that the needed revision
of AP-17 would be issued by May 1,1982.
This item will be
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reviewed during a subsequent NRC:RI inspection (272/82-07-04;
311/82-06-04).
(4) Followup Action of Audits of the QA Audit Section
The inspector found the following concerning the PSE&G followup
action to the 1981 Cooperative-Management Audit of PSE&G:
The acceptability of a finding's resolution is frequently
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judged and accepted by the sub-ordinate of the manager
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responsible for the corrective action, and the resolution
is often that of not acknowledging the finding. Two of
the five 1981 findings were resolved in this manner and
appear to not be effective corrective action.
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The QA Department has not been addressing the audit findings
adequately, in that, the inspector findings identified in
paragraphs 4.c.(2)(b), 4.c.(2)(c), and 4.c.(3) of this
report were previously identified to PSE&G in the 1981
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audit, but were resolved either by not acknowledging the
finding or by projecting a distant completion date.
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The QA Manual, in QAI 18-3, specifies that the PSE&G audit
response shall be transmitted to the auditor. There
appears to be no record of any such response for the 1981
audit.
The licensee's representative ackncwledged the inspector's
findings concerning the effectiveness of follow-up action to
indeoendent audits of the QA audit section, but disagreed with
the inspector's concerns regarding their current program's
effectiveness.
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This item is unresol w d pending licensee action and subsequent
NRC:RI review (272/82-07-05; 311/82-06-05).
(5) Nuclear Review Board (NRB) Review of Audits
Technical Specifications paragraph 6.5.2.8 delegates the responsi-
bility for the auditing of certain safety related activities to
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the Nuclear Review Board (NRB), the offsite review committee.
The inspector found the following items with regard to NRB
review of audits:
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NRBP-3, paragraph 4hdelineatesthespecificauditareasthat
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must be covered per Technical Specification 6.5.2.8.
However,
there is no reference to auditing of fire protection, an NRB
responsibility.
NRBP-3, paragraph 6.3 states " Audit reports (of NRB responsible
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areas) shall be circulated to all NRB members ...". However,
as discussed in finding paragraph 4.c.(2)(a) and 4.c.(2)(b),
the method of auditing the Operational QA Program and the
actions taken to correct deficiencies is by covering those
areas as part of audits of the different functional areas.
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Therefore, all audit reports containing reference to the Operational '
QA program and/or to corrective actions should be distributed
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to NRB members.
This is not the current practice.
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As discussed in paragraph 4.c.(2)(c), the Insurance Department
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administratively controls outside fire protection audits,
some of which are used to satisfy Technical Specification
required NRB responsibilities. However, the NRB does not
receive direct distribution of the audit reports.
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Independent audits of the QA audit section, such as the
Cooperative Management audit, should be distributed to the
NRB members for information, as the audits often address
issues concerning NRB responsible audits. This is not
current practice.
The licensee's representative acknowledged the inspector's
findings. Th licensee stated that a task force is currently
reviewing the operation of the NRB and that these concerns
would be addressed as part of that review. Also, the licensee
noted that as part of this review, recent changes had been made
to the NRB to provide a full-time NRB Chairman and a full-time
NRB secretary.
This item is unresolved pending licensee action and subsequent
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NRC:RI review (272/82-07-06; 311/82-06-06).
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5.
Unresolved Items
Unresolved items are matters about which mere'information is required in
order to ascertain whether they are acceptable, deviations or violations.
four unresolved items were identified during. this inspection and are
detailed in paragraphs 3.c. , 4.c.(2), 4.c.(4) and 4.c.(5).
6.
Management Meetings
Licensee management was informed of the scope and purpose of the inspection
at an entrance interview conducted on February 8, 1982. The findings of-
the inspection were periodically discussed with licensee representatives
during the course of the inspection. Exit interviews were conducted on
February 17, 1982 at Salem Nuclear Generating Station and February 18,
1982 at the corporate office, Newark, New Jersey (See paragraph I for
attendees) at which time the findings of the inspection were presented.
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