ML20101P944
ML20101P944 | |
Person / Time | |
---|---|
Site: | Hope Creek ![]() |
Issue date: | 12/31/1984 |
From: | Public Service Enterprise Group |
To: | |
References | |
CON-#185-921 OL, NUDOCS 8501070318 | |
Download: ML20101P944 (187) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board In the Matter of :
Public Service Electric : Docket No. 50-354 OL and Gas Company a s
(Hope Creek Generating Station) :
APPLICANT'S RESPONSE TO INTERVENOR'S SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to the rules of practice of the Nuclear Regulatory Commission
("NRC"),10 C.F.R. Section 2.740(b), and the Order of the Atomic Safety and Licensing Board of December 21, 1983 and the special prehearing conferences of November 22, 1983 and December 17, 1984, Applicant, Public Service Electric and Gas Company ("PSE&G"), hereby responds to the interrogatories propounded by the Intervenor, The Public Advocate of New Jersey, Joseph H. Rodriguez.
Several documents listed herein are proprietary and protected pursuant to 10 CFR 2.790 of the Commission's Regulations. If the intervenor desires to review these documents, it will be necessary to enter into an appropriate protective agreement with the designated company.
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PS G Cornoany E'ectnc and Gas 80 Park Plaza, Newark, NJ 07101/ 20' 433-6468 MAILING ADDRESS / P.O. Box 570, Newark, NJ 07101 Richard Fryling, Jr. Associate General Solicitor . TSE December 28,1984 Rienard E. Shapiro, Esq.
Director ,
Division of Public Interest Advocacy Department of the Public Advocate CN 850 Trenton, NJ 08625 Re: Applicant's Response to Intervenor's Second Set of Interrogatories and Request for Production of Documents Hope Creek Generating Station Docket No. 50-354 OL
Dear Mr. Shapiro:
Transmitted herewith is Applicant's Response to Intervenor's Second Set of Interrogatories as modified by Mrs. Laverty's December 20, 1984 letter to you.
Documents referenced in these answers will be made available with the documents provided in response to your request for documents. Mr. Thurber has tentatively scheduled January 2,1985 for this purpose.
Very o Os
- I Richard Fryling r RF:mbb Enclosures The Enerp. Pe:.rs
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O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board Public Service Electric and )
Gas Company )
) Docket No. 50-354-OL (Hope. Creek Generating )
Station) )
CERTIFICATE OF SERVICE I hereby certify . that copies of " Applicants' Response to Intervenor's Second Set of Interrogatories" in the captioned matter have been _ served upon the following by deposit in the United States mail on this 28th day of December, 1984:
Marshall E. Miller, Esq. Atomic Safety and Chairman Licensing Appeal Panel Atomic Safety and U.S. Nuclear Regulatory Licensing Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Dr. Peter A. Morris U.S. Nuclear Regulatory Atomic Safety and Commission.
Licensing Board Panel Washington, D.C. 20555 3 U.S. Nuclear Regulatory Commission Docketing and Service i
l Washington, D.C. 20555 Section Office of the Secretary Dr. David R. Schink U.S. Nuclear Regulatory Atomic Safety and Commission Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l J
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O Lee Scott Dewey, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Richard E. Shapiro, Esq.
Susan C. Remis, Esq.
State of New Jersey Department of the Public Advocate CN 850 Hughes Justice Complex Trenton, New Jersey 08625 Carol Delaney, Esq.
Deputy Attorney General Department of Justice State Office Building 8th Floor 820 N. French Street Wilmington, DE 19810
/-
Richard yAing, Jr.
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- Hand Delivered with service upon John P. Thurber, Esq.
O STATE OF NEW JERSEY )
- SS.
COUNTY OF ESSEX )
RICHARD D. RIPPE, being first sworn, deposes and states:
That he is the Assistant General Manager - Engineering of Public Service Electric and Gas Company, the Applicant herein; that he has read the ;
foregoing Applicant's Response' to Intervenor's Second Set of Interrogatories and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
sk Richard D. Rippe Assistant General Manager - Engineering Subscribed and sworn to before me this 28th day of December,1984.
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MAR RET M. NN fl0TARY PUBLIC OF NE'.'l JERSEY My Commission Expires March 23,1939
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PUBLIC ADVOCATE SECOND SET OF INTERROGATORIES PART I PIPE CRACKS
- 1. For each of the following types of piping, list and identify all piping of that type that has been or is planned to be used in safety-related systems in the construction of the Bope Creek Generating Station. For each such piping, list the chemical composition, diameter, wall thickness, operating pressure and temperature, design pressure and temperature, and identify the system of which it is a part:
ANSWER:
(a) type 304 stainless steel piping; Chemical Composition Percentage Carbon 0.08 (max.)
Manganese 2.00 (max.)
Phosphorus 0.045 (max.)
4 Sulfur 0.03 (max.)
Silicon 1.00 (max.)
Chromium 18.00 - 20.00 Nickel 8.00 - 12.00 Diameters Nominal Wall Thicknesses Part of System 4" .337" Reactor Water Clean-Up 12" .711" RER Return 12" .711" Risers 20" .966" RER Suction 22" 1.134" Loops 28" 1.200" Suction 28" 1.41" Discharge
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PUBLIC ADVOCATE SECOND SET OF INTERROGATORIES PART I -
PIPE CRACES
- 1. (a) Continued DESIGN: (Recirc. Suct.) Pressure 1250 psig Temperature 575'F DESIGN: (Recirc. Disch.) Pressure 1500 psig Temperature 575'F OPERATING: Pressure 1050 psig Temperature 550*F (b)
(c)
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(f) APPLICABLE (g)
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PUBLIC ADVOCATE SECOND SET OF INTERROGATORIES PART I -
PIPE CRACKS
- 2. Provide a listing of all piping walds on all type 304SS or 316SS piping. Identify each weld by serial number or other weld identification number; state whether the weld is a .
field weld or a shop weld and identify any and all IGSCC-countermeasures used or applied; and provide the quanti-fication of the stress rule index value for each of the welds.
ANSWER:
Reference attached G.E. Drawing 796E916 Rev. 2 for listing of recirculation piping system (Loops MB) weld numbering and IGSCC remedy application.
The recirculation piping system has had IGSCC remedies applied in accordance with NUREG 0313 and 0313 Rev. 1; hence, the stress rules index, for the selection of weld-ments to receive IGSCC remedies, is not applicable.
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PUBLIC ADVOCATE SECOND SET OF INTERROGATORIES PART I - PIPE CRACKS
- 3. -Identify and describe all plans and procedures to mitigate intergranular stress corrosion cracking (IGSCC) by means of hydrogen water chemistry at the Hope Creek Generating Station.
If hydrogen water chemistry is not to be utilized as a countermeasure to IGSCC, explain why it is not to be so used.
ANSWER:
Hydrogen water chemistry is not planned for the Hope Creek Generating Station. The recirculation piping system has had IGSCC remedies applied in accordance with NURBG 0313 and 0313 Rev. 1.
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O PUBLIC ADVOCATE SECOND SET OF INTERROGATORIES PART I- PIPE CRACKS
- 4. Identify and describe all plans and procedures to mitigate IGSCC in safety-related systems by means of reducing the tensile residual stress levelin the heat-effected zones of susceptible piping. In responding to this interrogatory, include the following information.
ANSWER:
(a) None (b) None (c) each instance in which corrosionnasistant eladding (CRC) of field welds was utilized at the Hope Creek Generating Station. For each
' such instance, identify the piping on which the weld was performed -
by its size and type and the system of which the piping is a part.
Answer.
CRC was shop applied to all field butt weld ends. See G.E.
Drawing 796E916 Rev. 2 submitted as part of question No. 2.
(d) None J
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INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION-t I.. PIPE CRACK INTERROGATORIES 5 IDENTIFY AND DESCRIBE THE INSPECTION TECHNtQUES, '
METHODS, PLANS AND PROCEDURES THAT WILL BE UTILIZED AT ,,
1 THE HOPE CREEK GENERATING STATION To DETECT IGSCC.3.FOR EACH SUCH INSPECTION TECHNtGUE, METHOD, PLAN OR ~.~) ,
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PROCEDURE, IDENTIFY OR DESCRIBE: y, .
A. THE PLANNED FREQUENCY OF THE INSPECTIONJ B. THE RELIABILITY OF THE TECHNIQUE, METHOD, PLAN AND PROCEDURE IN MEASURIN3 THE LENGTH AND DEPTH OF PtPE .
CRACKSJ ,
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D. THE PERSONNEL THAT WILL CONDUCT THE INSPECTIONJ E. THE SPECIFIC PROCEDURES TO BE FOLLOWEDJ AND :
F. THE REPORTS THAT WILL BE PREPARED FOLLOWING THE *t.
INSPECTION. e
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RESPONSE
A. PUBLIC SERYtCE ELECTRIC AND GAS COMPANY WILL SCHEDULE-EXAMINATIONS -IN ACCORDANCE WITH THE ASME SECTION XI EDITION THAT IS IN EFFECT FOR THE FIRST 10-YEAR 151 INTERVAL AT THE HOPE CREEK GENERATING STATION. .: ,
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INTERVENORS SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION L PIPE CRACK INTERROGATORIES B. THE RELIABILITY OF CURRENTLY AVAILABLE SIZING TECHNIQUES TO MEASURE LENGTH AND DEPTH OF PIPE CRACKS 5 QUANTIFIED IN EPRI PRESENTATION " STATUS OF IGSCC DEPTH SIZING," PRESENTED BY DR.
GARY DAU TO THE BWR OWNERS GROUP, OCTOBER 5,1984.
C. SIZING OF INDICATIONS WILL BE PERFORMED USING COMMERCIALLY AVAILABLE STANDARD ULTRASONIC INSTRUMENTS AND TRANSDUCERS, AS WELL AS THE RECENTLY DEVELOPED SOUTHWEST RESEARCH INSTITUTE (SWRI) SLIC-40 TRANSDUCER WHICH E USED AS PART OF THE EPRIIGSCC SIZING QUALIFICATION PROGRAM.
PERSONNEL THAT WILL BE CONDUCTING UT INSPECTIONS AT HOPE CREEK GENERATING STATION WILL BE QUALIFIED IN ACCORDANCE WITH THE APPLICABLE EPRI TRAINING PROGRAMS FOR IGSCC DETECTION AND/OR SIZING.
D. ALL PERSONNEL PERFORMING UT ON IGSCC SENSITIVE AREAS AT HOPE CREEK GENERATING STATION WILL BE TRAINED AND QUALIFIED WITH THE EPRI QUALIFICATION PROGRAM FOR IGSCC DETECTION AND l CERTIFIED AS LEVEL U EXAMINERS IN ACCORDANCE WITH SNT-TC-IA.
IN ADDITION, EACH INDIVIDUAL WILL HAVE SUCCESSFULLY PASSED AN SWRI TRAINING PROGRAM THAT INCLUDES CLANROOM AS WELL AS PRACTICAL TRAINING AND COMPETENCY TESTS. THE EXAMINERS WILL HAVE SUCCESSFULLY DEMONSTRATED THEIR EXPERIENCE AND KNOWLEDGE AS SPECIFIED BY SNT-TC-IA. THE PERSONNEL TO PERFORM THESE EXAMINATIONS HAVE NOT YET BEEN IDENTIFIED.
O INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION l
L PIPE CRACK INTERROGATORIES E. SOUTHWEST RESEARCH INSTITUTE PROCEDURES SWRI-NDT-600-31 and SWRI-NDT-800-100 WILL BE USRD FOR IOSCC DETECTION AT HOPE CREEK UNLESS SUPERSEDED BY LATER TECHNIQUES DURING ISL .
F. UT DATA SHEETS WILL BE COMPLETED AT THE TIME OF THE EXAMINATION. RESOLUTION SHEETS WILL BE PREPARED TO DOCUMENT THE DISPOSITION OF ALL DIDICATIONS. DATA WILL BE SUMMARIZED ON SITE AND KEPT ON FILE DURING ALL ON-8ITE ACTIVITIES. A REPORT WILL BE PREPARED AT THE COMPLETION OF PRESERVICE EXAMINATION ACTIVITIES.
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INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION
. I. PIPE CRACK INTERROGATORIES 6 DESCRtsE ANY AND ALL PLANS DESIGNED TO MINIMIZE OR ELIMINATE VARIAstLITY IN OPERATOR PROCEDURE IN 16 SCC DETECTION.
RESPONSE
SEE ITEM 5-D.
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. INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION 1
I. PIPE CRACK INTERROGATORIES 7 DESCRIBE ANY AND ALL PLANS DESIGNED TO MINIMtZE OR ELIMINATE VARIABILITY IN EQUIPMENT PERFORMANCE IN IG5CC DETECTION.
RESPONSE
SWRt HAS ITS OWN FActLITIES To CERTIFY ALL OF THE EQUIP- -
MENT NORMALLY USED FOR AN ISI. MAINTENANCE PROCEDURES ARE IMPLEMENTED TO ASSURE INSTRUMENT ACCURACY, UNIFORMITY, AND RELIABILITY EVEN SEYOND FACTORY SPECIFICATIONS. THE CERTIFICATION PROGRAM IS PERFORMED ',
IN ACCORDANCE WITH SWRt's OPERATING PROCEDURES. ULTRA-SONIC INSTRUMENTS AND TRANSDUCERS ARE RECERTIFIED EVERY SIX MONTHS OR MORE FREQUENTLY IF NECESSARY. ~
4 VARIOUS BRANDS, SIZE, TYPES, AND FREQUENCIES OF UT TRANSDUCERS (SEARCH UNITS) ARE PROVIDED BY SWRt. EACH TRANSDUCER IS TESTED FOR FREQUENCY AND BEAM PROFILE AND IS CERTIFIED IN ACCORDANCE WITH THE APPROPRIATE PROCEDURE.
EXAMINATIONS. THESE INSTRUMENTS ARE ALSD USED AS l NECESSARY FOR THICKNESS GAUGING OF MATERIALS AND AS'AN
- AID.IN DETERMINING THE ACQUSTIC CHARACTERISTICS /
PROPERTIES THROUGH MEASUREMENT OF THE TRANSMISSION AND I
ATTENTUAT10N otr ULTRASOUND IN MATERIALS. THESE INSTRUMENTS ARE ALIGNED AND CERTIFIED PRIOR TO THEIR USE i
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INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES 8 STATE:
A. WHETHER THE CALIBRAT!aN BLOCKS FOR ULTRASONIC TESTING (UT) WILL CONTAIN WELDS!
3 WHERE ON THE CALIBRATION BLOCKS THE CALIBR4710M' REFLECTORS WILL BE LOCATEDJ AND C. WHETHER NOTCHES OR SIDE-DRILLED HOLES WILL BE USED AS CAttBRATION REFLECTORS ON THE CALIBRATION BLOCKS.
RESPONSE ,
j A. CALIBRATION BLOCKS FOR UT EXAMINATION OF WELDS IN i CORROSION-REstSTANT CLAD MATERIAL WILL HAVE WELDS.
CALIBRATION BLOCKS FOR UT EXAMINATION OF WELDS IN i STANDARD PtPING MATERIAL WILL HAVE No WELDS IN THEM.
B. CALfBRATION ALOCKS 70 BE USED FOR THE PRESERVICE EXAMINATION AT HOPE CREEK GENERATING STATION WILL HAVE CALIBRATION REFLECTORS LOCATED IN THE BASE METAL.
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C. STANDARD SHEAR-WAVE TECHNIQUES To BE UTILfZED FOR
- RECIRCULATION PIPING UT EXAMINATIONS AT NOPE CREEK GENERATING STATION WILL UTILIZE SIDE-DRILLED HOLES FOR CALIBRATION SECAUSE THESE REFLECTORS OFFER THE MOST-SENSITIVE CALIBRATION. HOWEVER, REFRACTED .
LONGITUDINAL (RL) TECHNIGUES TO BE USED FOR THE' EXAMINATION OF CORR 05t0N-REstSTANT CLAD PIPtNG MATERIALS WILL UTILfZE THE NOTCH REFLECTORS.
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9 $ TATE WHETHER 60* SHEAR WAVE UT EXAMINATION WILL BE PERFORMED.
RESPONSE
SIXTY-DEGREE SHEAR-WAVE UT EXAMINATION WILL BE PERFORMED AS REQUIRED BY THE JotNT CONFIGURATION OF THE INDIVIDUAL WELD TO BE DETERMINED BY THE "AS BUILT" CONDITION. IT MAY BE USED,FOR EVALUATION OF INDICATIONS OR To CHARACTERIZE FLAWS IF REQUIRED.
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'I. PIPE CRACK INTERROGATORIES 10 STATE WHETHER A SKEWED SCAN UT ExAntNArt0N WILL sE PERFORMED ON WELDS To DETECT DEFECTS ORIENTED OTHER THAN PARALLEL OR PERPENDICULAR To THE WELD.
RESPONSE .
A SKEWED SCAN UI EXAMINATION WILL BE PERFORMED ON RECTRCULAT1oM PIPING WELDS TO DETECT DEFECTS ORIENTED OTHER THAN PARALLEL OR PERPENDICULAR TO THE WELD.
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INTERVENOR'S SECOND SET OF INTERROGATORIES
. HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES
! 11 STATE WHETHER THE 501 DAC METHOD OF CRACK LENGTH StItNG WILL BE REVISED FOR USE AT THE HOPE CREEK GENERATING STATION TO REQUIRE THAT END PotNTS OF A FLAW BE DETERMINED BY LOSS OF SIGNAL AMPLITUDE TO THE BACKGROUND NOISE LEVEL.
RESPONSE
FIFTY, PERCENT DAC StZING OF CRACK LENGTH AT NOPE CREEK GENERATING STATION WILL BE RECORDED DURING ALL ULTRASONIC EXAMINAT10NS. IN ADDITION, 20 PERCENT DAC l
LENGTHS WILL BE RECORDED DURING EXAMINATIONS.
INDICATIONS WHICH ARE SUSPECTED To SE OTHER THAN GEOMETRY MAY BE SIZED USING OTHER AVAILABLE ULTRASONIC TECHNtGUES AS REGutRED To DETERMINE THE NATURE AND LOCATION OF THE INDICATION. SUCH TECHNIQUES MAY INCLUDE, BUT NOT BE LIMITED TG, EXTRA ANGLES, MODES OF PROPAGATION, MULTIPLE BEAM AND SATELLITE PULSE CRACK TIP
- DIFFRACTION TECHNIGUES. FIFTY PERCENT DAC METHOD OF CRACK LENGTH SIZING WILL BE CONSIDERED A FIRST STEP IN THE LONG PROCESS OF EVALUATIN3 FLAW TYPE INDICATIONS AT HOPE CREEK GENERATING STATION.
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INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION ,
I. PIPE CRACK INTERROGATORIES 12 STATE WHETHER CONSID,ERATION WAS OR IS NOW BEING GIVEN IN THE PLANNING, DESIGN, OR CONSTRUCTION OF HOPE CREEK ,
TO THE NEED FOR ADEQUATE ACCESS FOR UT WELD.INSPECTtDN '
IF SD, DESCRIBE IN PtPE J01NT DESIGN AND INSTALLATION.
IN FULL ALL CHANGES IN DESIGN OR INSTALLATION THAT HAVE RESULTED OR WILL RESULT FROM THIS CONSIDERAT10N.
RESPONSE f DURING THE DESIGN OF THE HOPE CREEK GENERATING STATION, SOUTHWEST RESEARCH INSTITUTE CONDUCTED AN ACCESS ENGINEERING PROGRAM IN ACCORDANCE WITH THE REQUIREMENTS OF SUBARTICLE IWA-1500 OF ASME SECTION XI. THIS PROGRAM j
WAS DEVELOPED BY SWRt WORKING DIRECTLY WITH THE ^
ARCHITECT-ENGINEER, BECHTEL POWER CORPORATION.
EARLY IN THE DESIGN STAGES, REQUIREMENTS FOR PRESERVICE AND INSERVICE INSPECTION WERE IDENTIFIED, AND EFFORTS BY SWRt AND BECHTEL WERE DIRECTED TOWARD EN3URING THAT THE PLANT WOULD BE INSPECTABLE. INITIALLY, THE ACCESS ENGINEERING PROGRAM WAS PERFORMED UNDER THE INSPECTION REQUIREMENTS CONTAINED IN THE 1974 EDITION OF SECTION XI WITH ADDENDA THROUGH SUMMER 1975 THtS EDITt0N IS THE PRESERVICE INSPECTION REQUIREMENT AND WAS THE LATEST APPROVED CODE AT THAT TIME. AS MORE RECENT EDITIONS AND i
GAINST HE ME ER REQU EMENTS a WERE CONS ANTLY EVAL ATED '
TO ENSURE INSPECTABILITY UNDER LATER CODES.
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($) INTERVENOR'S SECOND SET OF INTERROGATORIES 1
HOPE CREEK GENERATING STATION
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I. PIPE CRACK INTERROGATORIES 12 . STATE WHETHER CONSIDERATION WAS OR IS NOW BEING GIVEN
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IN THE PLANNING, DEStGN, OR CONSTRUCTION OF HOPE CREEK TO THE NEED FOR ADEQUATE ACCESS FOR UT WELD INSPECTinN IN PIPE JotNT DEStGN AND INSTALLATION. IF So, DESCRIBE IN FULL ALL CHANGES IN DESIGN OR INSTALLATION THAT HAVE RESULTED OR WILL RESULT FROM THis CONSIDERATION.
RESPONSE (CONTINUED) .
IN GENERAL, VERY FEW DEstGN CHANGES HAD TO BE MADE }i BECAUSE OF THE EARLY AND CONSTANT INVOLVEMENT OF SWRt. .
TWO SPECIFIC CASES WHERE DESIGN CHANGES WERE MADE TO ENSURE SUFFICIENT ACCESS WERE (1) MODIFICATION TO '
BIOLOGICAL SHIELD DOORS, AND (2) INSTALLATION OF FLOW DIVERTERS ON THE REclRCULATION OUTLET N0ZZLES. IN SEVERAL CASES, THE ORIGINAL BIOLOGICAL SHIELD DOOR DEstGN DID NOT OPEN SUFFICIENTLY TO ALLOW COMPLETE ,
ACCESS TO ALL THE PIPING AND VESSEL WELDS. BECHTEL REDEstGNED THE DOORS TO ALLOW COMPLETE ACCESS.
SEVERAL YEARS AGO, FLOW DIVERTERS WERE PLACED AROUND THE RECtRCULATION OUTLET N0ZZLES. INITIAL DESIGNS OF THE FLOW DIVERTER RESTRICTED ACCESS TO THE SAFE END WELDSJ l HOWEVER, AFTER REVIEW AND REDEstGN OF THE FLOW DIVERTER, A DESIGN WAS ACCEPTED AND EVENTUALLY CONSTRUCTED WHICH ALLOWED ACCESS AND THE INSTALLATION OF AN ISI TRACK FOR INSPECTIONS OF THE WELD.
l DURING THE FINAL STAGES OF CONSTRUCTION, ACCESS AND INSPECTABILITY ARE CONTINUING To BE REVIEWED AND MODIFICATIONS MADE WHERE NECESSARY.
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INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION
- 1. PIPE CRACK INTERROGATORIES
- 12. STATE WHETHER CONSIDERATION WAS OR IS NOW BEING GIVEN IN THE FLANNING, DESIGN, OR CONSTRUCTION OF HOPE CREEK TO THE NEED FOR ADEQUATE ACCESS FOR UT WELD INSPECTION IN PIPE JOINT DESIGN AND INSTALLATION. IF SO, DESCRIBE IN FULL ALL CHANGES IN DESIGN OR INSTALLATION THAT HAVE RESULTED OR WILL RESULT FROM THIS CONSIDERATION.
RESPONSE
ACCESS TO PERFORM ULTRASONIC PIPING INSPECTION WAS PROVIDED IN SEVERAL WAYS. FIRST, PIPING ISOMETRIC DRAWINGS WERE REVIEWED TO ENSURE THAT FITTING-TO-FITTING WELDS WERE MINIMlZED. SECONDLY, CRITERIA FOR SURFACE PREPARATION,ID COUNTERBORE, AND WELD CONTOUR WERE PROVIDED TO BECHTEL FOR INCLUSION IN THEIR PIPING SPECIFICATIONS. THIRDLY, CLEARANCE DIMENSIONS FOR WELDS REQUIRING UT WERE I FURNISHED TO BECHTEL FOR THEIR USE IN ENSURING THAT l
SUPPORTS AND OTHER STRUCTURES DID NOT INTERFERE WITH WELD INSPECTION.
THROUGHOUT THE ENGINEERING PHASE OF HOPE CREEK, SWRI,IN ADDITION TO OTHER PROCEDURES, WORKED ON THE HOPE CREEK MODEL AT THE BECHTEL OFFICE AND CONDUCTED A DETAILED REVIEW ON THE MODEL ON A WELD-BY-WELD AND LINE-BY-LINE BASIS TO ENSURE THAT ACCESS WAS MAINTAINED. WELD LOCATIONS WERE VERIFIED AND ROUTES TRACED TO ENSURE THAT EACH WELD COULD BE REACHED AND INSPECTED.
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INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES
- 13. IDENTIFY ALL EMPLOYEES OF PSE&G AND OF ITS CONTRACTORS AND SUBCONTRACTORS THAT HAVE PERFORMED EASELINE UT INSPECTIONS DURING THE CONSTRUCTION STAGE OF THE HOPE CREEK GENERATING STATION. FOR EACH INDIVIDUAL WHO PERFORMED SUCH BASLINE UT INSPECTIONS, STATE THE INDIVIDUAL'S NAME, AGE, JOB DESCRIPTION, QUALIFICATIONS, EDUCATIONAL LEVEL, TRAINING AND EXPERIENCE. ALSO IDENTIFY WHETHER EACH SUCH INDIVIDUAL WILL CONTINUE TO BE UTILIZED TO PERFORM PERIODIC UT INSPECTIONS DURING THE LIFE OF THE PLANT.
RESPONSE
SEE RESPONSE TO QUESTION 5.D NO BASELINE UT INSPECTIONS HAVE BEEN COMPLETED FOR THE RECIRCULATION PIPING SYSTEM TO DATE.
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- I. PIPE CRACK INTERROGATORIES l 14 STATE WHETHER PASSING THE EPRt/NDE CENT 30 DNE-WEEK TRAINING COURSE ON IGSCC CRACK DETECTION (EPRt/NDE TRAINING COURSE) WILL BE A JOB REQUIREMENT FOR HOPE CREEK UT OPERATORS. IDENTIFY ALL OTHER TRAINING THAT WILL BE REQUIRED OF OR PROYtDED TO SUCH GPERATORS.
RESPONSE
YES. IN ADDITION, OTHER TRAINING PROGRAMS WILL BE USED. SEE INTERROGATORY 5-D.
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I. PIPE CRACKS 15.. List and describe the ways in which the requirements of IEB 83-02 and IEB83-03 have been or will be complied with at Hope Creek.
RESPONSE
IEB 83-02 was issued to Hope Creek for information only.
IEB 83-03 pertains to check valves, outside the scope of the contention.
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INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION.
i I. PLPE_ CRACK INTERROGATORIES 16 STATE WHETHER THE CRACK-TIP DIFFRACTION SIZING APPROACH WILL BE UTILIZED IN CRACK DETECTION AT NOPE CREEK. IF So, DESCRIBE THIS APPROACH, ESTIMATE ITS ACCURACY, IDENTIFY THE OPERATORS THAT WILL BE UTILIZING THIS APROACH AND STATE THE PLANNED FREQUENCY OF SUCH .
INSPECTIONS.
RESPONSE
PSEsG PRESENTLY INTENDS TO USE,'IF NECESSARY, THE CRACK TIP DIFFRACTION APPROACH FOR CRACK SIZING BUT NOT FOR CRACK DETECTION. CRACK DETECTION WILL PROBABLY BE ACHIEVED BY MEANS OF SIGNAL AMPLITUDE FROM A 45' REFRACTED LONGITUDINAL WAVE DUAL TRANSDUCER (SEND-RECEIVE) SYSTEM. HOWEVER, CRACK SIZING, AS WELL AS CRACK DETECTION, TECHNIQUES ARE STILL BEING INVESTIGATED. BECAUSE OF THE RAPIDLY CHANGING STATE-OF-THE-ART IN IGSCC CRACK DETECTION AND SIZING, PSEsG WILL NOT DECIDE ON A SPECIFIC SYSTEM OR TECHNIQUE UNTIL THE ACTUAL NEED ARISES.
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INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION L PIPE CRACK INTERROGATORIES
- 17. STATE WHETHER AUTOMATED UT DATA COLLECTION BY y
\ MECHANICAL SCANNERS WILL BE UTILIZED AT THE HOPE CREEK .
GENERATING STATION. IF SO, DESCRIBE THE PROCEDURES AND EQUIPMENT TO BE UTILIZED, AND IDENTIFY THE SYSTEMS TO BE INSPECTED USING THIS MEANS.
RESPONSE
h, REMOTE SCANNING EQUIPMENT WILL BE UTILIZED FOR EXAMINATION OF THE NQZZLE-TO-SAFE END AND SAFE END-TO-l PIPING WELDS. THESS DZVICES DkRIVE POSITION INFORMATION PROM THE CHAIN OR' GEAR TEETH ON THE TRACKS WHICH ARE FIXED PERMANENTLY OR TEMPORARILY TO THE VESSEL NOZZLES AND PIPING. DIGITAL ENCODERS ARE GEARED DIRECTLY TO THE DRIVING MECHANISM TO PROVIDE POSITION INFORMATION.
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MOVEMENT OF THE DEVICES IS BY MEANS OF VARIABLE-SPEED DC MOTORS. THE OPERATOR HAS DIRECT CONTROL OF "STOP",
" START", AND " JOG" MODES OF OPERATION. THE SCANNING l
! 3 DEVICES CAN BE HANI> CARRIED THROUGH THE PERSONNEL HATCH IN THE CONTAINMENT, CONNECTED, AND INSTALLED AFTER AN INITI'AL CONNECTION AND CHECKOUT JUST OUTSIDE
- OF CONTAINMENT.
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- 18. STATE WHETHER AUTOMATED UT DATA RECORDING TECHNIQUES WILL BE UTILIZED AT THE HOPE CREEK GENERATING STATION. IF SO, DESCRIBE THE TECHNIQUES AND EQUIPMENT TO BE UTILIZED.
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RESPONSE
AUTOMATED UT DATA COLLECTION WILL BE UTILIZED DURING MECHANIZED SCANNING. THE SWRI STANDARD DATA ACQUISITION SYSTEM (SDAS) IS A MAN-PORTABLE, COMPACT, MODULAR SYSTEM DESIGNED FOR RAPID AND ACCURATE RECORDING OF
. CONVENTIONAL ULTRASONIC INFORMATION OBTAINED DURING A REMOTE-CONTROLLED MECHANIZED INSPECTION. SDAS IS
! COMPOSED OF FOUR ULTRASONIC INSTRUMENTS WITH
- CONVENTIONAL PEAK DETECTION GATES, A TIME-CORRECTED- .
GAIN (TCG) SYSTEM, A DIRECT VIDEO CONVERSION MODULE, A l
VIDEO RECORDING SYSTEM, AND A MULTI 4HANNEL STRIP-CHART RECORDER. SDAS INTERFACES WITH THE SWRI ATTACHMENT POSITIONING SYSTEM. THE SYSTEM RECORDS ULTRASONIC SIGNAL DATA AND POSITION LOCATION INFORMATION ON VIDEO TAPE AND ON A MULTI-CHANNEL STRIP-CHART RECORDER. THE NORMAL SYSTEM B CAPABLE OF SUPPORTING UP TO FOUR CHANNELS OF PULSE-ECHO ULTRASONIC DATA, BUT THE SYSTEM CAN BE INCREASED TO NINE CHANNELS.
SDAS STORES DATA IN TWO FORMS: VIDEO TAPE AND STRIP CHART. THE VIDEO TAPE IS A RECORDING OF THE CRT DISPLAY FOR EACH OF THE ULTRASONIC INSTRUMENTS. A CAMERA IS FOCUSED ON EACH DISPLAY SCREEN AND ITS OUTPUT IS SENT TO A VIDEO MIXER FOR FORMATTING ONTO A SIGNAL DISPLAY.
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L PIPE CRACK INTERROGATORIES
- 18. STATE WHETHER AUTOMATED UT DATA RECORDING TECHNIQUES WILL BE UTILIZED AT THE HOPE CREEK GENERATING STATION. IF l SO, DESCRIBE THE TECHNIQUES AND EQUIPMENT TO BE UTILIZED.
RESPONSE (Continued)
IN ADDITION, THE PEAK SIGNAL AMPLITUDE AND TIME VALUES AS WELL AS THE TRANSDUCER MODULE LOCATION ARE SENT TO A DIRECT-VIDEO-CONVERSION MODULE WHERE THESE ANALOG AND BINARY-CODED DECIMAL VALUES ARE CONVERTED TO CHARACTERS AND SENT TO THE VIDEO MIXER TO ADD DIGITAL INFORMATION TO THE DISPLAY. THE VIDEO RECORDING CONSISTS OF THE INSTRUMENT A-SCAN DISPLAYS, THE DIGITAL VALUES
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CORRESPONDING TO PEAK SIGNAL AMPLITUDE AND TIME, AND THE DIGITAL LOCATION COORDINATES OF THE TRANSDUCER MODULE.
WITH THIS INFORMATION, IT IS POSSIBLE TO REVIEW THE DATA IN THE SAME SEQUENCE THAT THE OPERATOR CBSERVED IT DURING THE INSPECTION. THE VIDEO RECORD PRESERVES THE A-SCAN SHAPE AS WELL AS THE DYNAMICS ' ASSOCIATED WITH TRANSDUCER MOVEMENT WHICH ARE ESSENTIAL TO THOROUGH DATA EVALUATION.
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A HARIKOPY RECORD OF THE INSPECTION IS PROVIDED BY THE STRIP-CHART RECORDER. IN THIS RECORD, PEAK SIGNAL AMPLITUDE AND TIME VALUES FOR EACH OF THE ULTRASONIC CHANNELS ARE TRACED AS A FUNCTION OF TRANSDUCER LOCATION. SIGNAL AMPLITUDE AND TIME ARE APPROPRIATELY
- - - - - .,-~,-..,_.,,-w,-.,,m._-y.,.y_-c_.-y,.,_.,%m-,--.w,~ ..,.r_,...,_.mm...-
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l INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION L PIPE CRACK INTERROGATORIES
- 18. STATE WHETHER AUTOMATED UT DATA RECORDING TECHNIQUES '
WILL BE UTILIZED AT THE HOPE CREEK GENERATING STATION. IF SO, DESCRIBE THE TECHNIQUES AND EQUIPMENT TO BE UTILIZED.
RESPONSE (CONTINUED)
SCALED AND TRACED OVER THE CHART-PAPER GRID SO THAT VALUES CAN BE INTERPOLATED AT A LATER TIME. TRANSDUCER MODULE LOCATION B RECORDED BY MEANS OF AN EVENT-MARKER CHANNEL. ACTUAL POSITION DATA ARE SENT TO AN ELECTRONIC CIRCUIT WHERE EVENT SIGNALS ARE GENERATED FOR THE STRIP CHART AS A FUNCTION OF OPERATOR-SELECTED DEVICE MOVEMENT INTERVALS. FOR EXAMPLE, AN EVENT MARK CAN BE GENERATED FOR EVERY 1, 5, 10, 100, ETC. UNITS OF DEVICE MOVEMENT. AN EVENT MARK IS MADE ON A CHANNEL ON THE STRIP CHART FOR EVERY SIGNAL GENERATED BY THE l
ELECTRONIC CIRCUIT. THE OPERATOR E THEN ABLE -TO DETERMINE THE LOCATION OF THE TRANSDUCER MODULE BY KNOWING THE START LOCATION AND THE EVENT INTERVAL AND BY COUNTING THE EVENT MARKERS.
THE VIDEO-TAPE RECORDINGS AND THE STRIP CHART PROVIDE COMPLETE DOCUMENTATION OF THE UI.TRASONIC INSPECTION.
THE STRIP-CHART DATA ARE CORRELATED WITH THE VIDEO-TAPE RECORDING THROU,GH POSTION LOCATION INFORMATION.
ADDITIONAL DATA THAT ARE NOT AUTOMATICALLY RECORDED ARE WRITTEN ON THE STRIP CHART OR SPOKEN INTO A MICROPHONE SO THEY ARE RECORDED ON THE AUDIO TRACK OF THE VIDEO-TAPE.
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INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I i
I. ' PIPE CRACK INTERROGATORIES 19 STATE WHETHER AUTOMATED UT DATA INTERPRETATION SYSTEM OR SYSTEMS WILL BE UTILIZED AT THE HOPE CREEK IF So, DESCRISE THE EQUIPMENT AND GENERATING STATION. .
PROCEDURES To BE UTILIZED, AND IDENTIFY THE INTERPRETATION ALGORITHM TO BE USED.
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RESPONSE
AUTOMATED UT DATA INTERPRETATION IS NOT PRESENTLY
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SCHEDULED FOR USE AT HOPE CREEK GENERATING STATION.
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.O INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES
- 20. DESCRIBE THE PROCESSES THAT WILL BE USED FOR CONDUCTING s " BLIND TEST" PERFORMANCE DEMONSTRATIONS TO QUANTIFY THE t
FLAW DETECTION PROBABILITY AND CHARACTERIZATION ACCURACY FOR CANDIDATE ULTRASONIC INSERVICE INSPECTION SYSTEMS (UT/ISI).
RESPONSE
BLIND TEST PERFORMANCE DEMONSTRATIONS ARE INCLUDES AS PART OF THE EPRI TRAINING PROGRAMS REQUIRED OF ALL EXAMINERS THAT V'lLL PERFORM EXAMINATIONS ON RECIRCULATION PIPING AT HOPE CREEK GENERATING STATION. THE PROBABILITY OF DETECTION HAS BEEN DETERMINED TO BE APPROXIMATELY 72% (55% FOR THE ISOLATED CRACK CASE). THESE FIGURES HAVE BEEN DETERMINED BY EPRI AND WERE PRESENTED TO THE PVRC NDE SUBCOMMITTEE BY DR. GARY DAU ON OCTOBER 16, 1984.
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O INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES 21 SPEC 1FY THE FLAW DETkCTION PROSAB1L1TY AND CHARACTERIZATION ACCURACY STANDARDS THAT WILL BE IMPLEMENTED AT HOPE CREEK AS A QUALIFIATION FOR :
PERFORMING UT/ISt.
RESPONSE
FLAW DETECTION PROBABILITY AND CHARACTERIZATION ACCURACY .
STANDARDS WILL BE THOSE DETERMINED BY EPRI (SEE ITEM . ...
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INTERVENOR'S SECOND SET OF INTERROGATORIES
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HOPE CREEK GENERATING STATION ;
I. PIPE CRACK INTERROGATORIES
- 22. STATE WHETHER YOU WILL MEET THE MINIMUM REQUIREMENTS DEVELOPED BY THE AD HOC COMMITTEE FOR DEVELOPEMENT OF QUALIFICATION REQUIREMENTS FOR NUCLEAR UTILITY EXAMINATION PERSONNEL IN SEPTEMBER 1983 (NUR-MR-IA). IF SO, PROVIDE A COPY OF YOUR " WRITTEN PRACTICE" AS REQUIRED NUR-MR-IA SPECIFYING HOW YOU WILL COMPELY WITH THOSE MINIMUM REQUIREMENTS.
RESPONSE
MINIMUM REQUIREMENTS BY THE AD HOC COMMITTEE FOR DEVELOPMENT OF QUALIFICATION REQUIREMENTS FOR NUCLEAR UTILITY EXAMINATION PERSONNEL, DOCUMENT NUR-MR-lA, ARE NOT RECOGNIZED AS A REQUIREMENT FOR HOPE CREEK GENERATING STATION. NUR-MR-1A REPRESENTS A COMPILATION OF VARIOUS STANDARDS.
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O INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES
- 23. STATE WHETHER YOU WILL INTEND TO MEET THE PROCEDURE AND PERSONNEL QUALIFICATION REJUIREMENTS CODE CASE BEING DEVELOPED BY THE ASME SECTION XI WORKING GROUP DN NONDESTRUCTIVE EXAMINATION.
RESPONSE
THE CODE CASE DESCRIBED IN THis INTERROGATORY IS ,
PRESUMED To BE N-409 WHICH HAS NOT YET BEEN APPROVED BY ASME OR THE NRC. NO DECISION WILL BE MADE BY PSEa6'ON ADOPTION OF THIS CODE CASE UNTIL A FINAL VERSION HAS BEEN APPROVED AND PUBLISHED.
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INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I.' PIPE CRACK INTERROGATORIES l 1
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24 STATE WHETHER YOU WILL MEET THE REQUIREMENTS OF T!iE LATEST VERSION OF CODE CASE N-335 RESP 0tlSE i WHILE THE PROCEDURE REQUIREMENTS OF N-335 ARE IN MOST CASES ACCEPTABLE To PSEEG, THE ANGLE BEAM CALtBRATION REQUIREMENTS OF SECTION 3 2 2(D) ARE NOT ACCEPTABLE.
NORMALIZATION OF THE SHEAR WAVE DAC SENSITIVITY To THE NOTCH RESPONSE YtELDS A LESS SENSITIVE CALIBRATION THAN THE SIDE-DRILLED HOLE RESPONSE AND AS SUCH IS CONSIDERED UNACCEPTABLE FOR THE EXAMil4ATION OF IGSCC SENSITIVE o MATERIALS.
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O PUBLIC ADVOCATE SECOND SET OF INTERROGATORIES PART I - PIPE CRACKS l
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- 25. State whether the Hope Creek Generating Station will utilize an acoustic leak detection system. If so, describe the system that will be utilized at, Hope Creek and identify l i
where and how it will be used.
i ANSWER:
Acoustic leak detection is not utilized at the Bope Creek Generating Station.
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O INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK 6ENERATING STATION I. PIPE CRACK INTERROGATORIES l
l 26 STATE WHETHER THE HOPE CREEK GENERATING STATION WILL UTILIZE A MotSTURE-SENSITIVE TAPE LEAK DETECTION SYSTEM. IF So, DESCRIBE THE SYSTEM THAT WILL BE UTILIZED AT HOPE CREEK AND IDENTIFY WHERE AND HOW IT WILL BE USED.
RESPONSE
i A MotSTURE SENSITIVE TAPE LEAK DETECTION SYSTEM IS NOT PRESENTLY PROPOSED FOR USE AT THE HOPE CREEK GENERATING STATION.
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INTERROGATORIES SECTION I ITEM 27 DESCRIPTION:
State whether the Hope Creek Generating Station will utilize a sump pump monitoring system to detect pipe cracks and leaks. If so, describe the system that will be utilized at Hope Creek and identify where and how it will be used. Also identify the surveillance and limits on unidentified leakage to be utilized.
RESPONSE / COMMENTS:
Hope Creek Generating Station design incorporates a sump pump monitoring system as stated in FSAR 1.8.1.45. The sump pump monitoring system is described in FSAR 5.2.5.1. a and b. The surveillance requirements for the sump pump monitoring system as stated in Technical Specifications 4.4.3.1.b.
The surveillance requirements for reactor coolant sytem feakage are stated in Technical Specifications 4.4.3.2. The limits on unidentified leakage are stated in Technical Specification 3.4.3.2.
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O PART I- PIPE CRACKS A
- 28. Identify all recirculation piping withing the Hope Creek Generating Station f
that you have determined are very unlikely to be susceptible to IGSCC.
Explain the reasons for this determination.
ANSWER:
All. Remedies have been applied in accordanca with NUREG 0313 and 0313 Rev.1.
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O PART I- PIPE CRACKS
- 29. Identify all recirculation piping within the Hope Creek Generating Station that you have determined are likely to be susceptible to IGSCC. Explain the reasons for this determination.
ANSWER:
See Answer to Interrogatory 1/28.
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O INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION
- 1. PIPE CRACK INTERROGATORIES
- 30. PROVIDE YOUR FLAW EVALUATION CRITERIA FOR IGSCC.
RESPONSE
INITIAL SCREEING OF INDICATIONS WILL BE IN ACCORDANCE WITH SECTION XI('77-78 EDITION). EVALUATION CRITERIA OF IGSCC WILL BE DETERMINED IN ACCORDANCE WITH THAT CODE, FURTHER ENGINEERING EVALUATION WILL BE PERFORMED IN ACCORDANCE WITH ACCEPTED PRACTICES AND NRC SPECIFICATIONS AT THE TIME OF OCCURRENCE.
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- 31. Identify allinstances in which continued operation without repair will be permitted where crack length exceeds 27% of pipe circumference.
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- 32. For each of the following categories, state whether you willinspect pipe welds according to the following minimum schedule:
(a) 25% of the welds of each pipe size in ten years, with one-third of these inspected every three and one-third years or the nearest ref ueling outage: for welds on stainless steel type 304L,386L, 316K,304NG,316NG,347NG and 308L piping; low-strength carbon
! steel piping; NRC-approved nickel-based piping; cast low- .
carbon /high ferritte austenic stainless steels; and welds solution heat-treated after fabrication and welding:
,b) 30% of the welds of each pipe size in ten years, with at least one-i third of these inspected every three and one-third years of the nearest refuelina outages for welds on piping to which IH5I, M5W or LPH59 has been applied, where hydrogen water chemistry has been continuously implemented.
i (c) 100% in six years, with at least one-half of these to be inspected every three and one-third years or the nearest refueling outate:
, for all other welds.
RESPONSE
(a) Welds in the recirculation piping system, including shop welds which have been solution heat treated after fabrication and welding, will be inspected in accordance with Table IWB 2500-1 of the applicable Edition of -
ASME Sec. XI which presently calls for 25%
of the welds every ten years.
(b) Not applicable.
l (c) See Response 5A and (a) above. ,
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- 33. Estimate the total cost, including the cost of purchasing replacement power during shut-down, of IGSCC-related damage to the Hope Creek Generating Station during the life of the plant. List separately each category of estimated expenses for each expected incident and the statistical source for all such estimates.
RESPONSE
The interrogatory is irrelevant because costs to implement necessary safety i requirements or modifications are irrelevant.
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- 34. List your estimate of the current cost of replacing all type 304 stainless steel piping with IGSCC-resistant piping for each system within the Hope Creek Generating Station that utilizes type 304 piping. Identify the statistical sources for all such estimates.
RESPONSE
See Answer to1/33.
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INTERVENOR'S SECOND SET OF INTERROGATORIES HOPE CREEK GENERATING STATION
- *I. PIPE CRACK INTERROGATORIES
- 35. -LtST AND IDENTIFY ALL WELDS THAT WILL REQUIRE MANUAL RATHER THAN AUTOMATED UT INSPECTION, AS STATED AT PAGE l
10 0F APPLICANTS' ANSWER To PROPOSED CONTENTIONS OF THE PUBLIC ADVOCATE OF THE STATE OF NEW JERSEY DATED NOVEMBER 18, 1983 FOR EACM SUCH WELD, IDENTIFY THE DIMENSIONS OF THE PIPING INVOLVED, ITS TYPE AND THE .
l SYSTEM OF WHICH IT IS A PART.
RESPONSE .
RECtRCULATION SYSTEM WELDS CURRENTLY SCHEDULED TO BE EXAMINED BY MANUAL TECHNtQUE ARE IDENTIFIED IN ATTACHMENT 1 ADDITIONAL INFORMATION ON WELD DIMENSIONS AND ISOMETRIC SKETCHES IS FOUND IN THE HOPE CREEK PRESERVICE EXAMINATION PLAN, PREPARED BY SWRt IN COLLABORATION WITH THE PSEsG ISI'6R00P.
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ATTACHMENT 1 TO INTERROGATORY l-35 RECIRCULATIONSY5TEMWELDS-MANUALEXAMINATION j A-LOOP 1-BB-28VCA-012-ILD SUCTION 1-BB-28VCA-012-2, 2LU, 2LDI, 4 2LD0 SUCTION .
1-BB-28VCA-012-3, 3LUI, 3LUO, 3LD SUCTION
- 1-BB-28VCA-012-4, 4LU, 4LD SUCTION 1-BB-28VCA-012-5, SLU, SLD SUCTION .
' ~
! 1-BB-28VCA-012-6, 6LU, 6LD SUCTION 1-BB-28vCA-012-7, 7LU, 7LDI, 7LDO SUCTION 1-BB-28VCA-012-8, 8LUI, 8LUO SUCTION 1-BB-28VCA-012-9, 9LD, 9BC1, 9BC2 SUCTION 1-BB-28VCA-012-10, 10LU, 10LDI, 10LD0 SUCTION .
1-BB-28VCA-012-11, 11LUI, 11LUO SUCTION 1-BB-28vCA-013-1, 1BCl, 1BC2 DISCH.
1-BB-4VCA-013-1 DISCH.
1-BB-28VCA-013-2, 2LU DISCH.
1-BB-2BVCA-013-3, 3LDI, 3LD0 DISCH.
1-BB-28VCA-013-4, 4LUI, 4LUO, 4LD DISCH.
1-BB-28vCA-013-5, SLU, SLD DISCH.
1-BB-28VCA-013-6, 6LU, 6LD DISCH.
- 1-BB-28VCA-013-7, 7LU DISCH.
- 1-BB-22VCA-013-1, ILD, 1BC1, 1BC2 DIST. HDR 1-BB-22VCA-013-2, 2LU DIST. HDR 1-BB-22VCA-013-3, 3LD, 3BC1, 3BC2 DIST. HDR 1-BB-22VCA-013-4, 4LU DIST. HDR '
1-BB-12VCA-013F-1, ILD RISERS l
1-BB-12VCA-013F-2,'2LU, 2LD RISERS 1-BB-12VCA-013F-3, 3LU, 3LDI, 3LD0 RISERS 1-8B-12VCA-013F-4, 4LUI, 4LUO, 4LD R!SERS .
f PAGE 1 0F 4 ,
($)' i I ATTACNMENT 1 TO INTERROGATORY I-35 i
- 1-BB-12VCA-0136-l', ILD RISERS 1-BB-12VCA-0136-2, 2LU, 2LD RISERS 1-BB-12VCA-0136-3, 3LU, 3LDI, 3LDO RISERS
- 1-BB-12VCA-0136-4, 4LUI, 4LUO, 4LD RISERS
,i 1-BB-12VCA-013H-1, ILD RISERS f
! 1-BB-12VCA-013H-2, 2LU, 2LD RI.SERS r 1-BB-12VCA-013H-3, 3LU, 3LDI, 3LDO RISERS
, 1-BB-12VCA-013H-4, 4LUI, 4LU0, 4LD RISERS.
! 1-88-12VCA-013J-1, ILD RISERS -
1-BB-12VCA-013J-2, 2LU, 2LD RISERS t
1-BB-12VCA-013J-3, 3LU, 3LDI, 3LDO RISERS 1-88-12VCA-013J-4, 4LUI, 4LUO, 4LD RISERS 1-8B-12VCA-013K-1, ILD RISERS .
l 1-BB-12VCA-013K-2, 2LU, 2LD RISERS 1-88-12VCA-013K-3, 3LU, 3LDI, 3LD0 RISERS 1-BB-12VCA-013K-4, 4LUI, 4LUO, 4LD RISERS i 1-BC-12CCA-116-5, SLU RHR RETURN 1-BC-12CCA-116-4, 4LD, 4LUI, 4LUO RHR RETURN i
1-BC-12CCA-116-3, 3LDI, 3LDO, 3LU RHR RETURN
- 1-BC-12CCA-116-2, 2LD, 2LUI, 2LUO -
RHR RETURN 1-BC-12CCA-116-1, ILU, ILDI, ILD0 RHR RETURN 1-86-4CCA-012-1 RWCU
- 1-86-4CCA-012-2 RWCU i
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ATTACHMENT 1 TO INTERN 0GATORY I-35 B-LOOP 1-BB-28VCA-011-1,*ILD SUCTION ;
1-BB-28VCA-011-2., 2LU, 2LDI, 2LD0 SUCTION 1-BB-28VCA-011-3, 3LUI, 3LUU, 3LD SUCTION l 1-BB-28VCA-011-4, 4LU SUCTION I
1-BB-28VCA-011-5, SLD SUCTION 1
1-BB-28VCA-011-6, 6LU, 6LD SUCTION 1-BB-28VCA-011-7, 7LU, 7LDI, 7LD0 SUCTION i 1-BB-28vCA-011-8, 8LUI, 8LU0 ,
SUCTION '
l 1-BB-28VCA-011-9, 9LD, 9BC1 SUCTION .
1-BB-28vCA-011-10, 10LU, 10LDI, 10LD0 SUCTION .
1-BB-28VCA-011-11, 11LUI, 11 LUG SUCTION . l 1-BB-28VCA-014-1, ILD, 1BCl, 18C2 SUCTION ;
1-BB-4VCA-014-1 DISCH. ,
1-BB-28VCA-014-2, 2LU DISCH.
- 1-BB-28VCA-014-3, 3LDI, 3LD0 DISCH. -
1-BB-28VCA-014-4, 4Lul, 4LUO, 4LD DISCH. ;
1-BB-28vCA-014-5, SLU, SLD DISCH.
1-BB-28VCA-014-6, 6LU, 6LD DISCH.
1-BB-28VCA-014-7, 7LU DISCH.
1-BB-22VCA-014-1, ILD, 18C1, 1BC2 DIST. HDR 1-BB-22VCA-014-2, 2LU DIST. HDR 1-BB-22VCA-014-3, 3LD, 3BCl, 3BC2 DIST. HDR 1-BB-22VCA-014-4, 4LU DIST. HDR 1-BB-12VCA-014A-1, ILD RISERS 1-BB-12VCA-014A-2, 2LU, 2LD RISERS 1-88-12VCA-014A-3, 3LU, 3LDI, 3LD0 RISENS 1-BB-12VCA-014A-4, 4LUI, 4LUO, 4LD HISERS .
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O ATTACHMENT 1 TO INTERRUGATURY I-35 I
1-BB-12VCA-bl48-1,ILD RISERS ,
1-BB-12VCA-0148-2, 2LU, 2LD RISERS 1-BB-12VCA-0148-3, 3LU, 3LDI, 3LD0 RISERS 1-BB-12VCA-0148-4, 4LUI, 4LUO, 4LD RISERS 1-BB-12VCA-014C-1, ILD RISERS i
1-BB-12VCA-014C-2, 2LU, 2LD RISERS .
i 1-BB-12VCA-014C-3, 3LU, 3LDI, 3LDO RISERS .
1-BB-12VCA-014C-4, 4LUI, 4LUO, 4LD RISERS .
i 1-BB-12VCA-014D-1, ILD RISERS 1-BB-12VCA-014D-2, 2LU, 2LD RISERS 1-BB-12VCA-014D-3, 3LU, 3LDI, 3LD0 RISERS 1-BB-12VCA-0140-4, 4LUI, 4LUO, 4LD RISERS ,
l - 1-BB-12VCA-014E-1, ILD RISERS 1-BB-12VCA-014E-2, 2LU, 2LD RISERS 1-BB-12VCA-014E-3,.iLU, 3LDI, 3LD0 RISERS l 1-BB-12VCA-014E-4, 4LUI, 4LUO, 4LD RISERS i 1-BC-12CCA-115-5, SLU RHR RETURN i 1-BC-12CCA-115-4, 4LD, 4LUI, 4LUO RNR RETURN j 1-BC-12CCA-115-3, 3LDI, 3LDO, 3LU RHR RETURN 1-BC-12CCA-115-2, 2LD, 2LUI, 2LUO RHR RETURN l
L 1-BC-12CCA-115-1, ILDI, ILDO, ILU RHR RETURN 4 1-BC-20CCA-114-1, ILD RHR SUCTION 1-BC-20CCA-114-2, 2LU, 2LDI, 2LDO RHR SUCTION 1-BC-20CCA-114-3, 3LUI, 3LUO, 3LD RHR SUCTION 1-BC-20CCA-114-4, 4LU, 4LDI, 4LDO RHR SUCTION 1-BC-20CCA-114-5, SLUI, SLU0, SLD '
RHR SUCTION
~
1-BC-20CCA-114-6,6LU RHR SUCTION 1-86-4CCA-011 2 WELDS RWCU 1
PAGE 4 UF 4
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M O
PUBLIC ADVOCATE SECOND SET OF INTERROGATORIES PART I PIPE CRACKS
- 36. Identify each person whom you expect to call as an expert witness with respect to contention 1 relating to pipe cracks. For each such person, state
' the subject matter on which he or she is expected to testify, the substance of the facts and opinions to which he or she is expected to testify, and a summary of the grounds for each such' opinion. Also describe the educational and professional qualification of each such person, the publications, if any, of the person, and identify any previous proceeding in which that person has testified.
. PSE&G Employees
- 3. E. Rogozenski 4
R. F. Brandt L. Lake G. 3. Schnabel G. L. Duncan General Electric Company .
G. M. Gordon J
SWRI Employees W. T. Flach W. A. Weis j
S. W. Richter E. H. Reuscher 7
G. 3. Gruber 4
e 4
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O -
III. MANAGEMENT COMPETENCE: INTERROGATORIES
- 1. Identify and describe all steps PSE&G has taken or plans to take to meet the " character" requirement of Section 182(a) of the Atomic Energy Act, 42 U.S.C. Sections 2232(a), to operate the Hope Creek Generating Station.
RESPONSE
See Application, FSAR Sec.13 and remainder at responses to management competence interrogatories submitted herewith and documents provided in response to management competence request for documents.
4 N
.- - ----..,----.,-.-------,,,.-------..n -- .,.-----,.c ..,.-,--,-,---,-,---,.-n-,- - , , . - - -, , - - - - . - . - - . -, ,
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i III. MANAGEMENT COMPETENCE:' INTERROGATORIES
- 2. Identify and describe all steps PSE&G has taken or plans to take to ensure its " technical qualification" within the meaning of 10 CFR Part 30, Sec.
50.56 and 50.57(aX4), to operate the Hope Creek Generating Station.
RESPONSE
See response to Interrogatory 111/l.
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f III. MANAGEMENT COMPETENCE: INTERROGATORIES I INTERROGATORY #3: Identify and describe what PSE&G has learned regarding !
- - its management practices from the failures and problems experienced at the Salem Generating Station.
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RESPONSE
I Detajled evaluations of the Salem Generating Station reactor trip breaker events by PSE&G, the Nuclear Regulatory Commission and outside consultants identified specific short term and longer term actions to improve management practices of the Salem station. Insplementation of these actions is now eittw complete or progressing toward a scheduled completion.
See also response to Interrogatories 3,4 of the Public Advocate's First Set of
. Interrogatories dated Februaryb 14,1984 and the attached list of referenced meetings and documents.
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RESPONSE
Meetings between PSEEG and the NRC were held on:
- 1. February 28, 1983, as documented in the NRC Meeting Summary, dated March 14, 1983;
- 2. March 5 and 10, 1883, as documented in the NRC's Salem Restart Status Report, dated March 14, 1983;
- 3. March 15, 1983, as documented in the official Transcript of Proceedings before the NRC, dated March 15, 1983, and NRC Summary of Meeting, dated April 18, 1983,
- 4. March 24, 1983, as documented in Brihfing of the Nuclear Regulatory Commission on Salem Post-Trip '
Report, dated March 24, 1983
- 5. March 31, 1983, as documented in a letter from R. A. Uderitz to D. G. Eisenhut, dated April 4, 1983
- 6. April 7, 1983, as documented in the draft Salem
- Restart Authorization (SECY-83-98E), dated April 11, 1983
- 7. April 20, 1983, as documented in Briefing on Salem Public Meeting, dated April 20, 1983 These documents and all other documents and other writing discussed or produced as a result and L additional information regarding the NRC's concerns or recommendations and PSE&G's response to these concerns have been provided to the Department of the Public Advocate In the Matter of the Motion of Public Service Electric and Gas Company to Reduce the Level ,
of the Levelized Energy Adjustment Clause before the State of New Jersey Board of Public Utilities, Docket No. 831-25. (See response to Interrogatory 2 of Contention 2, dated February 14, 1984).
- 8. March 18, 1983, Management Meeting held to discuss initial findings of Management Analysis Company (MAC) diagnostic of PSEEG, as documented in Combined. -
Meeting Report No. 50-272/83-21 and 50-311/83-21,
. dated July 20, 1983; i.
O I'
- 9. August 9, 1983, Management Meeting held to discuss PSEEG's progress toward completion of long-term corrective actions from the May 6, 1983 ordar, as documented in Combined Meeting Repott No.
50-272/83-26 and 50-311/83-27, dated September 7, !
. 1983 *
- 10. October 11, 1983, Management Meeting held to discuss the PSE&G Action Plan for improvement of Nuclear Department operations, as documented in Combined Meeting Report No. 50-272/83-31 and 50-311/83-32, dated October 26, 1983;
, 11. November 18, 1983, Management Meeting held to discuss the status and details of the PSE&G Action Plan for imptovement of Nuclear Department operat' ions, as dccumented in Combined Meeting Report No.
50-272/83-34 and 50-311/83-34, dated November 30, .
1983;
- 12. December 1, 1983, meeting to discuss the Systematic ~
. Assessment of Licensee Performance (SALP) Board i Report for the period October 1, 1982 through Septsaber 30, 1983, as documented in NRC letters ,
dated November 22, 1983, and January 19, 1984; .
- 13. January 5, 1984, Management Meeting held to discuss l the status and details of the PSEEG Action Plan for improvement of Nuclear Department operations, as documented in Combined Meeting Report No.
' 50-272/84-01 and 50-311/84-01, dated January 10,
' 1984;
- 14. March 6, 1984, Management Meeting held to discuss the status and details of the PSE&G Action Plan for improvement of Nuclear Department operations, as documented in Combined Meeting Report No.
50-272/84-12 and 50-311/84-12,- dated March 22, 1984r j 15. May 18, 1984, Management Meeting held to discuss the
- status and details of the PSEEG Action Plan for improvement of Nuclear Department operations, as
. documented in Combined Meeting Report 50-272/84-20
' and 50-311/84-20, dated June 21, 1984; i
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- 16. July 19, 1984, Management Meeting held to discuss the status of the PSE&G Action Plan for improvement of Nuclear Department operations, as documented in Combined Meeting Report No. 50-272/84-30 and 50-311/84-29, dated July 30 and August 2, 1984; l l
- 17. November 15, 1984, meeting to discuss the SALP Board Report No. 50-272/84-37 and 50-311/84-36, dated November 5,1984, for the period October 1,1983 l l through August 31, 1984. The NRC meeting report has i not yet been made availabler
- 18. November 16, 1984, Management Meeting held to discuss the status of the PSEEG Action Plan for improvement I
of Nuclear Department operations, as documented in Combined Meeting Report No. 50-272/84-30 and I 50-311/84-29, dated December 17, 1984; .
The documents listed above in items 8 through 18 will be provided as part of the response to Request for Documents III Request No. 2 i
f 19. July 23 - 25, 1984, meeting to review the proposed organization for the operation of the Hope Creek ,
Generating Station from the level of senior corporate l officer down to and including the proposed operating i
staff.
i (Ref. Section 13.1.1.1, Hope Creek SER, NUREG-1048) l l
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SEGON IE. MANAGEMENT COMPETENCE: INTERROGATORIES INTERROGATORY M Identify and describe all of the management related causes, identified by Public Service Electric and Gas Company and consultants, of the ATWS incident that occurred February 22-25,1983 at the Salem Generating Station.
RESPONSE: None, but see response to Interrogatory III/3.
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SECTION III. MANAGEMENT COMPETENCE: INTERROGATORIES INTERROGATORY 45: Identify and describe each of the changes la management structure, practice, staffing, philosophy or training suggested by any and all consultants retained by PSEEG related to PSEEG's Nuclear Department or the operation of the Hope Greek generating stations.
RESPONSE: Changes in PSE&G Nuclear Department management structure, management practice, management staffing, management philosophy or management training suggested by consultants retained by PSE&G are identified and described in the Management Assessment and Action Plan for Improvement of Salem Stations 1 and 2 Operations,
- d'ated. June 24, 1983 (Management Analysis Company);
- and the Hope Creek Management Review Update dated April 1984 (Theodore Barry & Associates)
! See, also, response to Interrogatory III/3.
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O III. MANAGEMENT COMPETENCE: INTERROGATORIES
- 6. Identify and describe each of the changes in P8EEG l management structure, practice, staffing, philosophy' or training suggested by the NRC or its staff.
RESPONSE
Any changes in PSEEG management structure, practica, staffing, philosophy or training were developed as a result of PSE&G's interpretation of the evaluation of the ATWS or through or by consultants who were contracted to provide guidance in the areas described
,in our response to Interrogatory 5 of section III or -
through informed discussions with NRC or its staff.
See, also, response to Interrogatory III/3.
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O PUBLIC ADVOCATE SECOND SET OF INTERROGATORIES PART III - MANAGEMENT COMPETENCE
- 7. Identify each instance in which PSEEG has been fined or cited for any deficiency by the NRC. For each such instance, identify (a) the reason for the NRC's action; (b) PSE&G's response to the notice of violation involved; (c) PSE&G's response to the proposed fine; and (d) any and all corrective measures undertaken by PSEEG in response to thp NRC's action.
Response: No civil penalties proposed by the NRC for Hope Creek ~ Generating Station. Documents related to r
deficiencies identified during NRC inspections will
' be made available in response to the request for documents.
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O V
III. MANAGEMENT COMPETENCE: INTERROGATORIES _
- 8. State the reasons why PSEEG found it necessary or appropriate to reorganize its Nuclear Department in 1984; identify and describe each of the changes in the structure and staffing of the Nuclear Department that resulted from this reorganizations and for each such change, identify and describe in full the specific reason therefor.
RESPONSE , .
see response to Interrogatory III/3 and III/5. .
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't IN TE R R O G AT b RIE S SECTION EL ITEN 9 DESC RIPTION:
Identify how PJ.E. & G. wS1 ensure that the management and staff of the Hope Creek Generating Station wfIlbe aware of and 3 earn from the experiences of the management and staff of the Sa3ea Generating Station. Identify aILdocuments that in any way discuss this issue.
RESPO ESE As a result of the P.S.E. & G. Action Plan to perfora an indepth ana3ysis of the roles of the Vice President- Nuc3 ear and his Direct Reports, senior management organizationalchanges were made to establish the most effective organizational ,
structure WMa As part of this organizationalstructure, the Assistant Vice President- Nuclear Operations and his staff provide fulltime senior management oversight of the operating functions of both Sales and Hope Creek Generating Stations. This reporting structure wD1 encourage com munication between the I stations as wellas other Nuclear Department groups. The operating activities of both stations are administrative 3y contro33ed by progra ms and procedures which stem from and comply with the Vice President Nuclear Procedures (VPNs) as a com non base. . The experience of both stations, as wellas the nuclear industry, willbe continuously factored into improvements of these com non programs. The Hope Creek Generating Station has implemented an operating experience assessment program which provides for the evaluation of Hope Creek, Sale a and other nuc3 ear industry operating events. The programs of both stations wf31be coordinated through coa non Nuclear Departaent support groups to provide effective transfer of infer nation. Additionally, operating events and proceduralchanges affecting safety wj21be independently reviewed by the aoa aon Nuclear Safety Review Departaent.
See, also, response to Interrogatory III/3.
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1 III. MANAGEMENT COMPETENCE: INTERROGATORIES i
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- 10. Identify and describe all changes to the Hope Creek FSAR that resulted from the Director's Order of May 6, 1983, as referred to in Applicants' Answer to Proposed Contentions of the Public Advocate of the State of New Jersey at 23 n. 48.
RESPONSE
No changes to the Hope Creek FSAR have been made as a direct result of the May 6, 1983 Order; however, numerous changes have been made as a result of the internal programs and evaluations that have been conducted. See, specifically Chapter 13, Conduct of Operations.
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- III. MANAGEMENT COMPETENCE: INTERROGATORIES
- 11. Identify each instance in which NRC staff met with PSE&G personnel after February 25, 1983, to discuss issues related to' management-related causes of the ATWS events or the management of Hope Creek, including but not limited to PSE&G administration, quality assurance, personnel matters, staffing levels, training, philosophy of management, . staff or management experience, management failures or human error.
For each such instance, identify:
(a) the date of the meeting; (b) the individuals in attendancer
- i. (c) whether a transcipt, recording, notes, memos, or j minutes exist from the meeting (d) the subject matter of the discussion; (e) all documents or other writings discussed; ,
(f) all documents or other writings produced as a result; (h) the NRC's concerns or recommendations in their discussions; (i) PSEEG's response in these discussion to the NRC's concerns or recommendations; (j) any modifications or change in management practices or procedures implemented as a result of the discussionst
. (k) any concerns or recommendations of the NRC not acted l upon by PSEEGr and (1) the reasons PSEEG did not act upon any of the recommendations or concerns listed in ll(k)
- l 1
Response: See response to Interrogatory III/3.
,- - - - ,---,-e-- - . - - - - -
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- III. MANAGEMENT COMPETENCE: INTERROGATORIES
- 12. Identify all documents or other writings in your possession regarding or i relating to:
}
- a) management turnover in the Nuclear Department; Monthly Retention Analysis Report Monthly Personnel Change Report Out-of-Service File Exit Interview Reports Personnel Change Authorization Forms b) management turnover at the Salem Generating Station; Same reports identified in Interrogatory 12(a).
c) management turnover at the Hope Creek Generating Station; i
Same reports identified in Interrogatory 12(a).
, d) Management turnover at the Engineering and Construction Department.
I Management turnover for the period February 25,1983, through December 31, 1984, has been 0.
e) problems, in management liasion or coordination with Bechtel and otner Hope Creek contractors and subcontractors.
None, f) allegations or reports of records falsification at Hope Creek.
The following documents were identified as relating to an allegation of records falsification by a soils testing tecnnician employed by GEO Construction Testing Inc.:
a) GEO Construction Testing Inc. letter to Bechtel CLB-204, dated October 10, 1984. Subject is " Technician Termination and Quality Evaluation."
b) Bechtel letter to GEO Construction Testing Inc., BLC-331, dated October 15,1984. Subject is ' Technician Testing Deviation."
c) GEO Construction Testing Inc. letter to Bechtel CLB-205, <
dated October 18,1984. Subject is " Technician Testing Deviation."
v- ===v,v---,---n, ,,,.-_.,a,_,_ _ , , _
O Ill. MANAGEMENT COMPETENCE: INTERROGATORIES g) allegations or reports of drug or alcohol use at the Hope Creek Generating Station; WITHDRAWN h) management absenteeism at the Hope Creek Generating Station; Report of Employee Absence or Tardiness Report of Absence Due to Illness Excessive Unavailability Report Report of Absence of Permanent Employees Due to ll! ness - Quarterly
- 1) allegations or reports of management inadequacy, ineffectiveness or incompetence at the Hope Creek Generating Station; 1
None.
j) allegations or reports of inadequate, inaccurate, improper or poor planning by the Nuclear Department.
None k) allegations regarding the substandard management performance of the l Engineering and Construction Department.
None 4
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O III. MANAGEMENT COMPETENCE: INTERROGATORIES l
1
. SUGGESTED RESPONSE l 1
.TO HOPE CREEK INTERROGATORIES ,
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. 413 l l
l Identify and describe all procedures and methods instituted by PSE&G to monitor and evaluate the performance of its man-i agerial, employees in the Nuclear Department.
Management Personnel Performance Appraisal Program
- Corporate Personnel Practices Manual Section 12.1 I ,
3
- Guide to Personnel Performance Appraisal Program The PSE4G Manigement Personnel Performance Appraisal Program has been implemented for the following reasons: ,
- 1. To systematically and objectively appraise each individual's -
performance. ;
- 2. To create, establish and implement an incentive tool facili-tating personal growth, career development, and oppcrtunities for advancement consistent with and in support of department-(
l al objectives.
- 3. To provide a basis for establishing and understanding between the individual and his/her superior pertaining to the expecta-tions of both as they relate to the duties and responsibili-ties of the job and the departmental goals and objectives.
- 4. To provide the basic performance data necessary for an equit-able merit salary program.
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l The Guide to Personnel Performance Appraisal Program was designed to assist management employees in the implementation of the pro- ,
cess. ;
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CONTENTION 2: MANAGEMENT COMPETENCE s
I 14. Identify each person whom you expect to call as an expert witness with respect to contention 2 relating to Management competence. For each such person, state the l I subject matter on which he or she is expected to testify, the substance of the facts and opinions to which he or she 4
is expected to testify, and a summary of the grounds for I
each such opinion. Also describe the educational and professional qualifications of each such person, the
{ publications. if any, of the person, and identify any previous proceedings in which that person has testified.
Response - The following personnel may testify on behalf of Public Service Electric & Gas Company relative to the PSE&G l
l senior Management competence to safely operate the Hope Creek Nuclear Generating Facility.
PSt&G Co.
R. M. Eckert, Sr. Vice President - Nuclear & Engineering R. A. Uderitz, Vice President - Nuclear ,
, J. T. Boettger, Asst. Vice President = Nuclear Operations Support i R. A. Burricelli, General Manager - Nuclear Engineering S. LaBruna, Asst. General Manager - Hope Creek Operations L. A. Reiter, Asst. General Manager - Hope Creek Transition M. D. Hanson, Manager - Nuclear Training I
1 O
contention 2 t I I The educational and professional qualifications of PSEEG personnel J
j are contained in chapter 13 of the Hope Creek FSAR.
I t
i Manacement Analysis Comoany g
R. C. Traylor, Sr. Vice President
- s.
John E. Ward, Vice President I
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- we,--e.-,---__ _ - _ , ,__ _ _ ________,
O 4
III. MANAGEMENT COMPETENCE: INTERROGATORIES
- 15. State what programs, policies or other mechanism have ;
been established to ensure commitment by upper level corporate management to take all stepa necessary to ensure the safe and efficient operation of its nuclear power plants.
RESPONSE
I -
Commitment by upper level corporate management to take 4
all steps necessary to ensure the safe and efficient operation of its nuclear power plants is addressed in the
- following programs, policies or other mechanisms:
Nuclear Department Policy Manual approved by'the vice President - Nuclear provides overall guidance and direction for the Nuclear Department. It addresses how corporate level policies are
- implemented in the Nuclear Department.
The CEO, Senior Vice President and Vice President =
,~ '
Nuclear have committed to frequent meetings and communications to maintain a high level of awareness and readiness to respond.
A PSE4G Nuclear Oversight Committee has been established to provide Company management and the Eoard of Directors an independent basis for evaluating the effectiveness of the Company's nuclear plant operations. Specific atttntion is to be provided to evcluating overall management attention to nuclear safety and evaluating progress in resolving open evaluations of Company nuclear operations.
All of the above items are designed to ensure an
, appropriate degree of involvement at all levels of management that provides timely decision making authority
, to enhance the safe and efficient operation of the PSE&G Nuclear Power Plants.
See response to Interrogatory III/3.
O.
III. MANAGEMENT COMPETENCE: INTERROGATORIES
- 16. Identify all individuals and departments within P.S.E.tG. and all individuals and organization outside PSE&G .that have evaluated in writing PSEEG's Nuclear Department or its management of the operations of either the Salem or Hope Creek generating stations.
1 The individuals and departments within PSE&G and i RESPONSE: PSE&G that have all individuals and organization outside }
or its ovaluated in writing PSE&G's Nuclear Department l' management of the operations of Hope Creek Generating Station are listed below:
INTERNAL PUBLIC SERVICE ORGANITATIONS Safety Deview Group ( SRG)
/
PSE&G P. O. Box 236 Hancocks Bridge, NJ 08038 The f ollowinC individuals may be contacted at the PSE&G Nuclear Depertment address listed above: .
B. E. Hall .
Safety Review Engineer - Group Head J. A. Fest Safety Revtew Engineer A. Carolyn Taylor Safety Review Engineer P. E. Steinhauer
[
Safety Review Engineer R. J. Atkisson Safety Review Engineer .
L. Fink Safety Review Engineer i
Atlantic Electric Co.
J C. Littleton Saf ety Review Engineer i
l Nuclear p, view Board 'NP31-PSE&G Nuclear Department P. O. 3;x 236 Hanec:ks Bridge, NJ F. M. Krishna
':uelear F.eview Scard Manager J T. Boettger Ass 2stant " ice Precident - Operations Support
^ -. .- -.
I R. S. Salvesen General Nanager - Hope Creek 1
J. M. Zupko General Nanager - Salem Operations R. P. Douglas :
Manager - Licensing and Analysis i i
N. J. Nidura General Manager - Nuclear Services R. L. Mitti General Manager - Nuclear Assurance & Regulation .
A. Nassman Assistant to General Manager - Nuclear Engineering
[,','
R. D. Rippe Assistant General Manager - Engineering & .'.
Construction C. P Johnson General Manager - Nuclear Quality Assurance W. T. Ullrick r
Superintendent Nuclear Services 2301 Market Street P. O. Box 8699 .-
Philadelphia, PA 19101 T. R. Robbins Consultant Pickerard, Lowe & Garrick Inc.
1200 18th Street North West Suite 612 Washington, D. C. 20036 Nuclear Assurance and Regulation PSE&G 80 Park Plaza Newark, NJ 07101 R. L. Mitti General Manager Nuclear Assurance and Regulation Nuclear Safety Assurance PSE&G P. O. Box 236
.Han:ocks Bridge, NJ 08038 J. C. Cueller Manager Suelear Safety Assurance
- . _ _ . . . _ . . _ _ . . _ . _ . . _ _ . _ _ _ _ _ _ _ _ . . _ . . , _ _ _ _ . . _ _ . - _ , _ _ . . _ _ _ _ _ . . . _ _ ~ - ~ _
O J. J. Wang Lead Engineer Nuclear Safety Assurance F. P. Omohundro
- Manager Corporate Quality Assurance
' R. D. Evans Assistant Manager Corporate Quality Assurance
MEMBERSHIP: .
Dr. M. B. Gottlieb. Chairman t Director - Emeritus Princeton Plasma Physics Lab l*
P. O. Box 451' Princeton, NJ 08544
- Dr. S. Levy President - S. Levy.Inc.
1999 South Bacom Ave.
7th Floor i Campbells, Calif. 95008 t
D r. E. C. Rogers
- l President l Stevens Institute of Technology l
' Castle Point Station Hoboken. NJ 07030 Dr. W. F. Witzig Nuclear Engineering Department Head Penn State University 231 S=ckett BLDG University Park. PA 16802 i
Admiral E. P. Wilkinson l
President -
j Institute Nuclear Powere Operations -
1100 Circle 75 Parkway Atlanta, GA 30339 l
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Nuclear Denartment Quality Assurance PSELG P. o. Box 236 Hancocks Bridge, NJ 08038 The following individuals may be contacted at the PSE&G Nuclear Department address listed above:
C. P. Johnson General Manager Nuclear Quality Assurance E. Witkin Quality Assurance Controls Engineer R. P. Bivona Principal Staf f Engineer Reports ;
, L.
H. Gross Senior Engineer - Trending [
J. R. Franks Senior Engineer
- Commitment Verification ,
M. Maraded Lead Engineer Commitment Verification ':
M. Rosenzweig Engineering and Procurement Engineer E. Rozovsky Principal Engineer l
QA Engineering W. Blasek Lead Engineer QA Engineering Mechanical W. Reuther Principal Engineer QA Supplier Control D. Hauth .
Lead Engineer QA Supplier Control Planning V. 3. Keeffe renier Staff Engineer C; fupplier Control E 'tiustion
L R. E. Tierney Senior Engineer i QA Supplier Control Fuels QA A. Robinson Principal Staff Engineer i
QA Recieving Control .
H. Fistel Lead Engineer QA Recieving Control W. R. Schults Programs and Audits Engineer .
W. R. Hunsinger ~
Senior Engineer - Programs Evaluation i t
W. Nevias Principal Staff Engineer Training and Certification P. A. Benini Principal Engineer - Audits H. S. Lowe Senior Engineer - Audits Evaluation {
R. A. Jorgenson i
Lead Engineer - QA Recieving Control D. A. Perkins
' Station Q. A. Engineer l
T. Cocco Lead Engineer - Operations A. E. Siebert Lead Engineer - Operations R. Dules Principal Engineer - Services
~
R. J.'Skibinski ,
Senior Engineer - Services J. M. DeStefano Senior Staf f Engineer - Services W. Den 11nger Lead Engineer - Services .
D. J. Tauber Principal Engineer - Quality Control
O S. Skabicki Senior Engineer - Quality Control Internal Auditint
- 80* Park Plaza Newark, NJ 07101 s The following individuals may be contacted at the above ;
listed address:
W. J. Smith General Manager Internal Auditing .
R. J. Lipschuts ,
Manager - Operation Auditing ~
t Nuclear Department - Internal Auditing [.
r PSE&G P. O. Box 236 i
Hancocks Bridge, NJ 08038 l The following individuals may be contacted at the above
- listed address:
F. H. Zaksevski Principal Auditor E. N. Demarest Senior Auditor G. Mori Staff Auditor J. J. Lengyel Staff Auditor l
PSE&G Action Plan Task Forces PSE&G P. O. Box 236 Hancocks Bridge, NJ 08038 W. C. Bibb -
Action Plan Director Management Analysis Company ( MAC)
The following people can be contacted at the PSE&G address listed above unless noted otherwise:
2.1.1 - Functional Analysis of CP - Nuclear R. A. Burricelli General Manager Nuclear Engineering Sponsor
O .
R. A. Uderitz Vice President Nuclear .
. J. M. Zupko i General Manager l Salem Operations J. T. Boettger J Assistant Vice President
- Nuclear Support .
C. P. Johnson General Manager .
Nuclear Quality Assurance H. E. Lamb ( MAC) . p.
,i S. R. Lamb ( MAC) 2.1.2 - Nuclear and Corporate Matrix Relationships R. A. Burricelli .
General Manager Nuclear Engineering Sponsor 2.1.3 - Nuclear Department policy Manual s.
R. E. Gehret Manager Methods and Systems Sponsor I' 2.1.4 - Nuclear and Corporate Communications i
R. A. Burricelli I
General Manager ,
Nucle.ar Engineering i
Sponsor t
Managemen I-l: 2.1.5 - Nuclear Department Transition
- t I
R. A. Burricelli l
General Manager t
I Nuclear Engineering i
Sponser I. J. M. ;upko f Gener:1 Hanager l
' Sale *.Cperations '
I H. J. Madura General Manager Nuclear Support i
. _ _ . _ _ _ _ . . . _ . _ . . , . . . , . . . . . , . . . _ - . . _ . . . . _ . _ . . _ _ _ _ _ . - . _ . _ _ . ~ . _ . . _ . , . _ .
R. S. Salvesen General Manager
' Hope Creek Operations J. T..Boettger Assitant Vice President Nuclear Support 2.1.6 - Hope Creek Transition Plan L. A. Reiter -
Assitant General Manager Hope Creek Transition Sponsor .
S. Labruna-
' Assistant General Manager .
. Hope Creek Operations i R. D. Rippe p Assistant General Manager Engineering 80 Park Place ,
Newark, DE R. P. Douglass Manager Licensing and Analysis ,
80 Park Place Newark, DE A. C. Smith Assistant Project Manager Hope Creek i
E. G. Towhley Manager Employement and Placement 2.1.7 - New Employee Recruiting and Hiring r
l S. M. Rosierowski Personnel Affairs Manager Nuclear ,
l Sponsor .
2.2.1 - Safety Review Management P. M. Krishna l
Manager Nuclear Review Board f
Sponsor 2.2.2 - Commitment Tracking E. A. Liden Manager Nuclear Licensing and Regulation Sponsor .
__ _ __ _ _.. __ __ _.. _.._,._ _,_. _ ___.- __ ~-_. _ .._ .~..._. .__..__ _ . . ___ _.__....___. . _.
O R. E. Gehret Manager Methods and Systems J. G.. Jackson .
Technical Engineer t ,
Salem
}
?
J. A. Nicols I Technical Manager Hope Creek
~
E. Witkin QA Controls Engineer .
2.3.1/2.3.2 - Configuration Control Management / Change
~
i.
D. J. Jagt II Assistant General Manager 4
Muclear Engineerin6 Sponsor M. Rosensweig Engi ne er .
QA Engineering and Procurement L. E. Miller Assistant General Manager Salem Operations F. Meyer 4
Manager Nuclear Site Maintenance t
J. M. Rucki Maintenance Engineer Hope Creek t
2.4.1 - Plant cleanliness L. M. Fry Operations Manager Salem Sponsor 2'.4.2 - Technical and' Equipment Specifications L. E. Miller .
Assitant General Manager Salem Operations Sponsor R. Hallmark Interfacs Inc.
t._. _ - _ _ . . . _ _ _ _ _ . , , _ _ . . _ _ _ _ _ _ _ _ _ _ . _ . _ _ . _ _ _ _ _ . . . . - _ _ _ . _ _ _ ______2______..______. . _ _ _ .
O 2.4.3 - Post Modification / Post Repair Testing F. Meyer Manager Nuclear Site Maintenance 2.4.4 - Site Protection and Emergency Preparedness P. A. Moeller Manager '
Nuclear Site Protection Sponsor i 2.4.5 - Engineering and Operations Coordination l
I R. A. Burricelli General Manager l Nuclear Engineering .
i &
2.5.1/2.5.2/2.5.3 - QA Organization /Norking Relations / Procedures C. P. Johnson General Manager -
j Nuclear QA Sponsor i
2.6.1 - Maintenance Organization '
f H. J. Midura General Manager Nuclear Services Sponsor i 2.6.2 - Maintenance Planning E. W. Barradale Manager Nuclear Contruction Support Sponsor J. E. Gallagher Maintenance Manager, Salem V. C. Gadzinski Senior Maintenance Planning Supervisor 2.6.3 - Maintenance Work order Backlog i
J. E. Gallagher.
l Maintenance Manager. Salem Sponsor V. C. Gadzinski Senior Maintenance Planning Supervisor i
l
O-2.6.4 - Measuring and Test Equipment F. Meyer Manager .
Site Maintenance i Sponsor D. W. Lyona Operational Test Engineer l R. W. Vanderdecker -Sr.
Supervisor I & C Planning, Salem s
' D. A. Ward Station Planning Engineer, Salem t
l' ' .
. )..
/ W.(l.5 - Outage Management '
,r J. M. Zupko 6, General Manager i Salem Operations Sponsor D. A. Ward -
Station Planning Engineer E. P. Czuchni c ki Senior Staff Engineer l '
R. P. Surman i Principal Staff Engineer s
T. McCorkell MAC l
2.7.1/2.7.2 -
Records Management / Document Control I
R. E. Gehret Manager Methods and Systems Sponsor M. J. Murphy Senior' Methods Analyst J. G. Jackson
(
Technical Engineer, Salem A. J. Ameo Document Scheduling Adm*t;4trator L. F. Lake ISI Engineer l'
- ' 1
(:)
D. Bhavani Senior Staff Engineer M. A. Pardeds Administration Staff Assistant W. R. Hunsinger Engineer i
R. A. Ritsman Group Supervisor TDR, Hope Creek 2.7.3 - Information Systems R. E. Gehret Manager Methods and Systems -
2.7.4 - Nuclear Department Training H. D. Hanson Manager Nuclear Training Sponsor S. Labruna Assistant General Manager Hope Creek Operations L. E. Miller Assistant General Manager Salem Operations S. Jelenevsky Assistant Manager Management Resource Division 2.7.5 - Cost and Schedule Control I
V. g. McNamara Manager Cost and Scheduling EITERN AL ORG ANIZ ATIONS Basic Enterry Technolorv Associates. Inc. (BETA)
Arlinton, Virginia R. N. Bass R. 5. Brodsky
O M. E. Miles W. Wegner J. C. Grigg
- Independent consultant to BETA Nanaaement Analysis Corporation ( NAC) .
San Diego, California
' R. J. Ascherl R. J. Campbell R. B. Kelley L. J. Kube H. E. Lamb t S. R. Lamb K. T. Perkins
- R. J. Robinson F. L. Thompson A. J. Tudury LIST OF NRC PERSONNEL The following may be reached at:
Salem Nuclear Generating Station USNRC, Drawer I Hancocks Bridge, NJ 08038 l
J. C. Linville l Senior Resident Inspector, Salem R. J. Summers Resident Inspector, Salem i
The f ollewing rnay be reached at:
U. S. Nuclear Regulatory Commission Washington, DC 20555
(
t F. . C. te*ioung l
Dire-ter, Office of Inspection l
and Inf crcement (I L E)
I e
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O D. G. Eisenhut Director, Division of Licensing, Of fice of Nuclear Reactor Regulation ( NRR)
H. R. Denton
NRR ,
S. L. Israel f NRR W. G. Kennedy NRR G. Lanik I & E W. D. Lanning C Office for Analysis and Evaluation of Operational Data ( AEOD)
' J. G. Partlow I& E l
C. E. Rossi NRR P. C. Shemanski i NRR H. Silver NRR N.. Ernst.
l Office of Nuclear Regulatory Research C. J. Heltemes AEOD E. Jordan I & E G. Klangler Enforcement Specialist I & E
- 5. A. Targa Chief, Operating Reactors Branch (ORB) 1 Division
, of Licensing, NRR :
1, D. C. Pischer {
Licensing Project Nanager, ORB 1, NRR i
j H. R. Booher Chief, Licensee Qualifications Branch, ..
NRR E. M. Podolak ,
Chief. Program and Administrative 4
Service Branch l <. ,
T. Gilinsky Commissioner l' W. J. Dircks Executive Director for Operations The following may be reached at:
U. 5. Nuclear Regulatory Commission Region I .
631 Park Avenue i
King of Prussia, PA 19406 T. E. Nurley Regional Administrator J. N. Allan l
Deputy Regional Administrator R. C. Haynes Regional Administrator T. T. Martin Director, Division of Engineering and Technical Programs ( DETP) ,
R. W. Starostecki
[ Director, Division of Project and Resident Programs ( DPRP)
- 5. D. Ebneter ,
Chief. Engineering Programs l Branch, DETP I
H. B. Kaster l Chief. Projects Branch No. 2 J DPRP ;
)
I
(:) l l
L. J. Norrholm Chief, Reactor Project Section 28, DPRP
'l D. F. Lidroth ;
Project Engineer, Projects -
Branch 2 DPRP R. - R. Bellamy {g Chief, Radiological ,
Protection Branch, DETF /
J. H. Joyner .
Chief, Nuclear Materials and Safeguards Branch, DETP L. E. Tripp Chief, Reactor Projects -
(?
Section 3A, DPRP 9 i
R. R. Reinig Chief. Projects Branch 3. DPRP D. L. Caphton -
Chief. Management Programs Section. DETP W. J. Lazarus Project Engineer. DPRP 1 I
i W. J. Raymond Region i f C. J. Anderson - .
Region 1 l
N. J. Blumberg '
Region 1 H. Eichenholts Region 1 L. Plisco Region 1 -
R. Jacobs Project Engineer, DPRP D. Holody a
Enforcement Specialist, Region 1 T. Shaub Region 1 i
O The following may be reached at: t U. S. Nuclear Regulatory Commission 3 Region II j 101 Marietta Street i Saite 3100 Atlanta, GA 30303 i,
J. 01shinski <
Region II j The following may be reached at: .I Hope Creek Generating Station 3 USNRC, P. O. Box B !~
Hancocks Eridge, NJ 08038 W. H. Bateman Resident Inspector, Hope Creek A. R. Bloug$
- f' Resident Inspector. Hope Creek LEgg Institute of Nuclear Power Onerations 1820 Water Place Atlanta, GA . 30339 4
(
(404) 953-3600 $
l Mr. Zack T. Pate President Institute of Nuclear Power Operations 1100 circle 75 Parkway Suite 1500 Atlanta, GA 30339 Mr. Thomas McHenrey 6 Assistant to President Institute of Nuclear Power Operations 1100 Circle 75 Parkway l
Suite 1500 Atlanta, GA 30339 .
1 It is against INPO Corporate policy to divulge' NOTE:
l the names of member utility individuals who l comprise the audit teams. For further information please contact the two individuals listed above.
O . !
I Aaency Federal Emerzenev Naragement Federal Plaza New Yor,k, NY 10278 The followind individuals may be contacted at the address listed above: ,
Frank P. Petrone Regional Director R. Iowieski
- 8. Marking R. Carolik L. Dillon B. Houston R. Rodriguez M. Wu P. Cammarata Pennsv1vania Public Utilities Commision P. O. Box 3265 Commonweath and North Street
' Harrisburg, PA 17120 The Honorable:
Linda C. Taliaferro, Chairman Nichael Johnson, Commisioner James Cawley, Commisioner William R. Shane, Commisioner Frank Fischl, Commisioner New Jersey Board of Public Utilities 1100 Raymond Boulevard .
Newark..NJ 07101 e
Barbara A. Curran, President George A. Barbour New Jersey Denartment of the Public Advocate Department of the Public Advocate CN850 Trento. NJ 08025 Joseph H. Rodreiguez, Public Advocate Richard E. Shapiro, Director Division of Pub 2tc -
Interest Advocacy
-- **v"'<c -~~=v--,.,-_ . , , _ ____
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! American Nuclear Insurers ( ANI)
The Exchange suite-245
- 270 Yarmington Ave.
Farmington, CT 06032 l The following individuals may be contacted at the above listed address: .
]
Mr. Ted Banasiewicz Facility Engineer ii Mr. Leo P. Mariani Vice President Muclear Engineering Nuclear Mutual Li mi t e d (NHL)
Mr. Quentin Jackson General Manager Nuclear Mutual Limited P. O. Box 2025 Hamilton 5 ,
Bermuda .
M&M Protection Consultants 22 South Riverside Plaza Chicago, IL 60606 Consultant for NHL The following individuals may be contacted at the above listed address:
Mr. Quentin Jackson General Manager
~
Mr. Daniel E. Brown
' Loss Prevention Supervisor Mr. George Luer Loss Prevention Inspector Mr. Robin Wilson Boiler & Machinery Inspector 13moer Authorized Insnector Agency Lumbermans Mutual Casulty Co.
' Kemper Group 1020 Plain Street Marr hfield, MA 02050 The following individuals may be contacted at the above lisced address: .
R. D. Norris Regional Manager Special Inspection Se.-. ice
D. A. DeBacker Authorized Nuclear Inspector Supervisor Theodore Barry & Associates 50 Rockefellpr Plaza
e 4-t e
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4 SECTION 15. MANAGEMENT COMPETENCE: INTERROGATORIES INTERROGATORY #17: Identify and describe all corrective action or changes implemented by PSE&G in response to the following suggestions made by the Management Analysis Company (MAC) at page 11 of its June 24, 1983 l
" Management Assessment and Action Plan for Improvement of Salem Stations
' I and 2 Operations" (MAC I report):
Clarification of jurisdictional scopes and individual role responsibilities to enhance site management's capability to manage and to improve accountability throughout the Nuclear Department.
RESPONSE: The documents identified below describe in detail the corrective action or changes implemented by PSE&G relative to the clarification of jurisdictional scopes and individual role responsibilities to enhance site management's capability to manage and to improve accountability throughout the Nuclear Department.
REFERENCE:
PSE&G Plan for Improvement on Nuclear Department Operations, submitted to the U.S.
l Nuclear Regulatory Commission on August 26, i 1984.
Seetion 2.0, Actions Plans ,
Action Plan numbers; 2.1J, 2.1.2, 2.1.3 and 2.1.4 j
Action Plan 2.1.1- Functional Analysis of the VPN position and all Direct Reports.
OBJECTIVE - Perform a comprehensive functional analysis of the Vice President - Nuclear position and all direct report positions to determine priority functions. Recommend viable structural and/or procedural strategies for maintaining centralized and effective management control of the Nuclear Department NFATUS -The objectives were met, activities completed and verified by PSE&G, Nuclear - Quality Assurance on September 28, i
1984.
REFERENCE:
PSE&G Action Plan Close-out Document, Action Plan 2.1.1.
Action Plan 2.1.2 - Improve the Effectiveness of Working Relationships between Nuclear Department and Corporate Public j . Relations, Human Resources and Purchasing.
OBJECTIVE - Improve the effectiveness of the working relationships between the Nuclear - Department and Corporate Public Relations, Human Resources and Purchasing Departments; assess the feasibility of retaining these functions as matrix agreements; elarify and formalize all working agreements, including agreements about employee performance evaluatoins
O l between administrative and functional managers, and concerns related to personnel acquisition and procurement procedures.
NFATUS - The objectives were met, activities complete and verified by PSE&G, Nuclear - Quality Assurance on October 17, 1984.
REFERENCE - PSE&G Action Pl&n Close-out Document, Action Plan 2.1.2.
Action Plan 2.1.3 - Completion and Implementation of the Nuclear l
Department Policy Manual, VPN-1, and Supporting Departmental Procedures.
OBJECTIVE - Complets the ongoing development and control of implementing procedures and directives.
- STATUS - This Action Plan is still in progress. Present status on corrective action or changes implemented are described in the following referenced documents.
REFERENCE:
PSE&G Action Plan Sponsors Weekly Status Reports.
PSE&G Action Plan Weekly Status Reports.
PSE&G Action Plan Monthly Status Reports.
PSE&G (partially complete) Action Plan Close-out Documents, Action Plan 2.1.3.
Action Plan 2.1.4 -Improve Communications Between the Nuclear Department and Corporate.
OBJECTIVE - Assess formal and informal communication systems between Corporate and the Nuclear Department to recommend improved information flow processes. Although the focus of this effort is to increase each organization's understanding of the other's operational realities and the efficiency of their interactions, the accomplishment of this objective will also have a positive impact on improving external relations between PSE&G and regulatory agencies, the media and the public.
NPATUS - The objectives were met, activities completed and verified by PSE&G, Nuclear - Quality Assurance on September 26, 1984.
REFERENCE:
PSE&G Action Plan Close-out Document, Action Plan 2.1.4.
- O h
l INTERROGATORY #17: Development and implementation of an effective ,
transition management process.
RESPONSE: The document identified below describes in detail the corrective action or changes implemented by PSE&G relative to the development and implementation of an effective transition management process.
REFERENCE:
PSE&G Plan for Improvement of Nuclear >
Department Operations, submitted to the U.S. Nuclear Regulatory l Commision on August 26,1984.
Section 2.0, Action Plans Action Plan number; 2.1.5 l Action Plan 2.1.5 - Development and Implementation of an i Effective Transition Management Process.
OBJECTIVE - Develop and implement an organizational transition management process which will assist management to:
! 1. Identify and address any remaining adverse effects of the recent Nuclear Department reorganization and relocation in terms of employee perceptions and attitudes (e.g., perceived barriers between the plant organization and other
- . departments which relocated from Newark; confusion about responsibilities and resulting lack of ownership).
- 2. Clarify (and/or develop as necessary) organizational procedures, including departmental interface agreements, and functional responsibilities for the implementation of i management control systems, i- 3. Identify and resolve intra- and inter-departmental communication problems.
- 4. Address facilities planning as this relates to problems with geographic fragmentation of work functions or adequate housing of staff resources.
- 5. Develop realistic plans and implementation schedules for the management of future organization transitions.
STATUS -The objectives were met, activities completed and verified by PSE&G, Nuclear - Quality Assurance on September 7, 1984.
j
- - - ' ' ' * - ' ' ' - - ~ .mm _ . - - , , , , , . . . _ _ _ _ _ _ , _ _ _ . _ , __ , . _ __ _ __ _
. . ,-_ ~. . -. . -. - - - . . . ~ - - _ _ - _ - - . - _ - - . -
O I i
REFERENCE:
PSE&G Action Plan Close-Out Document, 4
Action Plan 2.1.5.
i INTERROGATORY #17: Timely staffing of open supervisory and mapport j positions required to perform the work of the Neelear Department effectively.
l RESPONSE:The document identified below describes in detail the corrective action or changes implemented by PSE&G relative to the timely staffing of open supervisory and support positions required to !
perform the work of the Nuclear Department effectively. i
REFERENCE:
PSE&G Plan for Improvement of Nuclear i Department Operations, submitted to the U.S.
Nuclear Regulatory Commission on Atgust 26,1984.
Section 2.0, Action Plans Action Plan number,2.4.5 li Action Plan 2.4.5 - Strengthen Nuclear Engineering and Coordination Between Nuclear Engineering and Operations.
OBJECTIVE - Strengthen the Nuclear Engineering organization and improve coordination between Engineering and Operations.
i STATUS - The objectives were met, activities completed and
! verified by PSE&G, Nuclear - Quality Assurance on October 31,
! 1984.
i
REFERENCE:
PSE&G Action Plan Close-Out Document, i
! Action Plan 2.4.5.
INTERROGATORY #17: Consolidation of the safety review process and an improved system for commitment treeking.
RESPONSE:The documents identified below describe in detail the corrective i
action or changes implemented by PSE&G relative to the ,
i consolidation of the safety review process and an improved system for commitment tracking.
( '
REFERENCE:
PSE&G Plan for Improvement of Nuclear
' Department Operations, submitted to the U.S.
Nuclear Regulatory Commission on August 26, 1984. '
l
! Section 2.0, Action Plans Action Plan numbers; 2.2.1 and 2.2.2 Action Plan 2.2.1 - Improve Safety Review Management Activities. i l
.,.,,.--,v,--c,.. , ~ . . ~ , . , - ~ - - , , - _ . _ _ _
-___.___.-_,____,_-_--_______________.____.______-,1.__ -
O i OBJECTIVE - Evaluate the existing safety review management activities to address improvements that would maximize the effective use of resources in a manner consistent with the need to assure safe, reliable operation of the plants.
STATUS - The objectives were met, activities completed and verified by PSE&G, Nuclear - Quality Assurance on October 30, ,
1984.
REFERENCE:
PSE&G Action Plan Close-Out Document, Action Plan 2.2.1 Action Plan 2.2.2 -Improve Commitment Identification, Tracking and Close-out.
OBJECTIVE - Identify and implement changes to consolidate and improve PSE&G commitment tracking systems to assure that established commitments are acceptably closed-out in reasonable time frames. An additional objective is to clearly define the ,
authority to make commitments within the Nuclear Department. .
NFATUS - This Action Plan is still in progress. Present status on corrective action or changes implemented are described in the following referenced documents.
REFERENCE:
PSE&G Action Plan Sponsors Weekly Status Reports.
PSE&G Action Plan Weekly Status Reports.
PSE&G Action Plan Monthly Status Reports. ,
j PSE&G (partially completed) Action Plan Close-out Document, Action Plan 2.2.2.
INTERROGATORY #17: Development and implementation of a more "w configuration management program, including improved design l
-:-:9; 2 l ehange procoms, document control and records management. .
RESPONSE: The documents identified below describe in detail the corrective action or changes implemented by PSE&G relative to the i
development and implementation of a more -comprehensive configuration management program, including improved design l
i change process, document control and records management.
t
O
REFERENCE:
PSE&G Plan for Improvement of Nuclear Department Operations, submitted to the U.S.
Nuclear Regulatory Commission on August 26, 1984.
Section 2.0, Action Plans Action Plan numbers; 2.3.1, 2.3.2, 2.7.1 and 2.7.2.
Action Plan 2.3.1 - Implement a Fully Integrated Configuration Management Program.
OBJEC11VE - Ensure that the Nuclear Department has an integrated program which will effectively control the .
configuration of the nuclear stations.
Configuration management is a program comprised of many individual elements within the areas of configuration identification, configuration control, configuration status and configuration verification. Most, if not all, of the individual elements currently exist within the Nuclear Department. The
- goal of this action plan is to ensure that all elements of a configuration management program are fully integrated and l
implemented.
l
- RA'IUS - The objectives were met, activities completed and
- verified by PSE&G, Nuclear - Quality Assurance on September 7, 1984.
REFERENCE:
PSE&G Action Plan Close-Out documents, Action Plan 2.3.1.
Action Plan 2.3.2 -Improve Change Control Process OBJECTIVE - Make the design change process more efficient and more effective. Give particular consideration to screening potential changes, streamlining the Design Change Request / Design Change Package process and incorporating completed changes into appropriate key design documents.
MATUS - The objectives were met, activities completed and verified by PSE&G, Nuclear Quality Assurance on September 21, 1984.
REFERENCE:
PSE&G Action Plan Close-out Document, Action Plan 2.3.2.
Action Plan 2.7.1 - Establish an Effective Records Management Program OBJECTIVE - Establish an effective, centralized records management program within the Nuclear Department.
l 1
O i
_7 l
STATUS - This Action Plan is still in progress. Present status on corrective action or changes implemented are described in the following referenced documents.
REFERENCE:
PSE&G Action Plan Sponsors Weekly Status Reports.
PSE&G Action Plan Weekly Status Reports.
PSE&G Action Plan Monthly Status Reports.
PSE&G (partially complete) Action Plan Close-out Document, Action Plan 2.7.1.
' Action Plan 2.7.2 -Integrate the Document Control Function OBJECTIVE -Integrate document control functions performed by all PSE&G organizations that support the Nuclear Department.
This applies to both safety and non-safety related documents which support and control the design basis for the plant including drawings, specifications, design criteria, procedures, etc.
STATUS - This Action Plan is still in progress. Present status on corrective action or changes implemented are described in the i
following referenced documents.
REFERENCE:
PSE&G Action Plan Sponsors Weekly Status Reports.
PSE&G Action Plan Weekly Status Reports.
PSE&G Action Plan Monthly Status Reports.
PSE&G (partially complete) Action Plan Close-out l Documents, Action Plan 2.7.2.
INTERROGATORY #17: Coordination of reanagement systems, procedures and interdepartmental communientions to enhamee the empeelty of all
! organisations to provide oo+;--J - "ve technical and administrative support to Operations.
i i RESPONSE: The documents identitled below describe in detail the corrective action or changes implemented by PSE&G relative to the coordination of management systems, procedures and interdepartmental communications to enhance the capacity of all organizations to provide comprehensive technical and administrative support to Operations.
l
O l
REFERENCE:
PSE&G Plan for Improvement of Nuclear ,
I Department Operations, submitted to the U.S.
Nuclear Regulatory Commission on August 26, 1984.
l Section 2.0, Action Plans Action Plan numbers; 2.4.5 and 2.7.3 Action Plan 2.4.5 - Strengthen Nuclear Engineering and l Coordination Between Nuclear Engineering and Operations OBJECTIVE - Strengthen the Nuclear Engineerir.g organization and improve coordination between Engineering and Operations.
STATUS - The objectives were met, activities completed and verified by PSE&G, Nuclear - Quality Assurance on October 31, 1984.
REFERENCE:
PSE&G Action Plan Close-out Document, l; Action Plan 2.4.5
~
l Action Plan 2.7.3 -Information Systems OBJECTIVE - Determine the management information needs of the Nuclear Department, evaluate how these needs can be met via a common data base management system and construct a plan to implement an integrated system.
STATUS - This Action Plan is stillin progress. Present status on corrective action or changes implemented are described in the
- following referenced documents.
REPERENCE: PSE&G Action Plan Sponsors Weekly Status Reports PSE&G Action Plan Weekly Status Reports
! PSE&G Action Plan Monthly Status Reports INTERROGATORY M7: Clarifloation of program priorities and the eoordination of interdepartmental procedures and eommunientions to improve the effectiveness of the quality programs.
RESPONSE:The documents identified below describe in detail the corrective action or changes implemented by PSE&G relative clarification of 4
program priorities and the coordination of interdepartmental procedures and communleations to improve the effectiveness of the quality programs.
4
)
O REFERENC 3&G Plan for Improvement on Nuclear partment Operations, submitted to the U.S.
h.. lear Regulatory Commission on August 26, 1984.
Section 2.0, Action Plans Action Plan numbers; 2.5J, f.5.2, and 2.5.3 Action Plan 2.5.1 - Improve the Quality Assurance Department Organization OBJECTIVE - Improve the internal capability of the Quality Assurance Department (QAD) to mange the salem Quality Assurance (QA) program through enhanced communications.
STATUS - The objectives were met, activities completed and verified by PSE&G, Corporate Quality Assurance on June 21,1984.
REFERENCE:
PSE&G Action Plan Close-out Document,-
Action Plan 2.5.1 Action Plan 2.5.2 - Improved Interdepartmental Relationships Between the Quality Assurance and Other Nuclear Department Organizations OBJECTIVE - Improve coordination procedures and working relationships between the Quality Assurance (QA) and other Nuclear Department organizations.
tit'ATUS - The objectives were met, activities completed and verified by PSE&G, Corporate Quality Assurance on November 19, 1984.
REFERENCE:
PSE&G Action Plan Close-out Document, Action Plan 2.5.2 Action Plan 2.5.3 - Improve the Quality Assurance Department Procedures and Work Activities OBJECTIVE - Improve Quality Assurance peccedures and work activities as these relate to auditing, monitoring and Quality Control inspection functions. Improve quality engineering review during the procurement cycle. Improve QA nonconformance control activity. !
I STATUS - The Sponsor has met the objectives and completed all activities. The Action Plan Close-out Documents are being verified by Corporate Qua'.ity Assurance. The following referenced documents describe in detail the corrective actions or changes implemented. ,
I
O 1
REFERENCE:
PSE&G Action Plan Sponsors Weekly Status Reports 1 PSE&G Action Plan Status Reports PSE&G Action Plan Monthly Status Reports PSE&G (partially complete) Action Plan Close-out Document, Action Plan 2.5.3 INTERROGATORY #17: Organisational and systems improvements for more effective planning and coordination of maintenance and plant betterment activities.
RESPONSE: The Documents identified bebw describe in detail the corrective actions or changes imploraented by PSE&G relative to the organizational and systems improvements for more effective planning and coordination of maintenance and plant betterment activities.
REFERENCE:
PSE&G Plan for Improvement of Nuclear Department Operations, submitted to the U.S.
Nuclear Regulatory Commission on August 26, 1984.
Section 2.0, Action Plans Action Plan numbers, 2.6.1, 2.6.2, 2.6.3, 2.6.4 and 2.6.5 l
Action Plan 2.6.1 - Clarify Organizational Responsibility and Interfaces in the Maintenance Area OBJECTIVE -
Clarify organizational responsibilities and accountabilities associated with the Maintenance function and establish a maintenance management structure that effectively and efficiently meets the needs of the Nuclear Department.
l NTATUS - The objectives were met, activities complete and l verified by PSE&G, Nuclear - Quality Assurance on April 16,1984.
l t
REFERENCE:
PSE&G Action Plan Close-out Document, Action Plan 2.6.1.
Action Plan 2.6.2 - Enhance Maintenance Planning, Monitoring and Control l OBJECTIVE - Provide a managed maintenance progro.a to l
facilitate the planning, scheduling and analysis of maintenance I work activities, i
O STATUS -This Action Plan is stillin progress. Present status on corrective actions or changes implemented are described in the following referenced documents.
REFERENCE:
PSE&G Action Plan Sponsors Weekly Status Reports PSE&G Action Plan Weekly Status Reports PSE&G Action Plan Monthly Status Reports Action Plan 2.6.3 - Reduce the Number of Backlogged Maintenance Work Items OBJEC11VE - Reduce the non-outage work order backlog to permit current maintenance activities to be completed in a timely, well planned manner.
NATUS - This Action Plan is still in progress. Present status on .
corrective actions or changes implemented are described in the following referenced documents.
REFERENCE:
PSE&G Action Plan Sponsors Weekly Status Reports PSE&G Action Plan Weekly Status Reports PSE&G Action Plan Monthly Status Reports Action Plan 2.6.4 -Improve Maintenance, Calibration and Control of Measuring and Test Equipment OBJECTIVE - Ensure that calibration and control of measuring and test equipment is maintained at a high level of performance.
NATUS - The objectives were met, activities completed and verified by PSE&G, Nuclear-Quality Assurance on May 10,1984.
REFERENCE:
PSE&G Action Plan Close-out Document, Action Plan 2.6.4 Action Plan 2.6.5 - Organisation for Outage Management and Improving Planning, Monitoring and Control of Outages OBJECTIVE - Review and strengthen the outage function including management systems and procedures which will aid in the planning, monitoring and controlling (including costs) of outages.
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l STATUS - This Action Plan is still in progress. Present status on corrective actions or changes implemented are described in the following referenced documents.
REFERENCE:
PSE&G Action Plan Sponsors Weekly Status Reports PSE&G Action Plan Weekly Status Reports PSE&G Action Plan Monthly Status Reports 9
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O SUGGESTED RESPONSE INTERROGATORY NO. 18 Identify management positions in the Nuclear Department that are open or unfilled as of the date you answer these interrogatories.
At this time, the following management positions remain open:
Assistant Vice President - Nuclear Operations Manager - Reliability and Assessment
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SECTION III. NANAGENENT COMPETENCE: INTERROGARIES l INTERROGATORY 919 Describe how the " excessive demands placed upon the Vice President - Nuclear" identified at page 3-2 of .the ,
Nanagement Analysis Company (NAC) I Report has been corrected or mitigated.
RESPONSE: The issue " excessive demands placed upon the Vice.
President - Nuclear" was addressed by the plan -
"Public Service Electric and Gas Company Plan for the Improvement of Nuclear Department Operations," August 26, 1983, Section 2.1.1, Functional Analysis of the VPN and Direct Reports.
Implementation of this plan was completed in Septembe r, 198 4. Results are presented in the close-out documents for Action Plan 2.1.1, Functional Analysis of the VPN and Direct Reports.
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SECTION III. NANAGEMENT COMPETENCE: INTERROGATORIES
[
INTERROGATORY 920 Deecribe how the probleme resulting from the '
" geographical distance between Corporate and the Nuclear Department" identified at page 3-2 of the Management Analysie Company I report have been corrected or mitigated.
i RESPONCE: The entire paragraph on page 3-2 of the referenced Management Analysis Company document reads as follows:
"The geographic distance between Corporate and the Nuclear Department and the resulting lack of informal daily communications contribute to misunderstandings and misperceptions. The -
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potential thus exists for Corporate to respond too quickly and simply to complex problems in the
{ Nuclear Department. Improved and more frequent communications would minimi.se this potential."
l As part of Action Plan 2.1.4 PSEEG implemented a l process for improving communicatiens between the Nuclear Department and Corporate. Attached is a list of improved and more frequent communications which r
have corrected or mitigated the problems resulting from the " geographical distance between Corporate and the Nuclear Department."
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AND THE MUCLEAR DEPARTMENT 1' i
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i o The Senior Vice President - Nuclear and Engineering i meet weekly to discuss Nuclear Department concerns and Action Plan Program Status. :
i i o The are alsoChief keptExecutive Officer updated through andweekly written the Senior Vice President Action Plan ,
Status Reports.
j o Visits to Artificial Island by the Chief Executive Officer, the Senior Vice President - Nuclear and Engineering, the l Vice Presidents a,nd the General Managers involved in
- matrixed functions, and other Corporate personnel have
- increased substantially. .
o Establishment of definite focal points for Corporateinform l
coordination of Department responses.
Establishment of a full-time management position ( Assistant o General Manager - Nuclear Joint Owners and Regulatory to coordinate information gathering, Activities) preparation of testimony and other activities related to co-owner and fiscal regulation concerns. ,
o streamlining of the Department staf fing authorization process by the Senior Vice President - Nuclear and Engineering.
o, substantially increased communications between Corporate and Nuclear Department managers involved in the m working relationships in the areas of s
. Human Resources Services Purchasing Services Computer Systems Development .and Applications Office Automation l
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INTERROGATORIES III. MANAGEBENT COMPETENCE:
4 III #21 Identify, and describe all corrective actions or steps.taken to implement the suggestions and :
recommendations contained in the "Assessasnt of the i Public Service Electric & Gas Company Operations l Quality Assurance Program for Salem Generating Stations Units 1 and 2* prepared by Management l Analysis Company and dated July 27, 1983 (MAC II report).
Response PSEEG Plan for the Improvement of Nuclear Department Operations August 26, 1983, identifies and describes the corrective actions to be taken which address the subject (MAC II) report. The associated close-out -
documents describe the actions taken or to to be taken for each recommendation. See response Interrogatory III/3.
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h III. MANAGEMENT COMPETENCE: INTERROGATORIES 2 2.' Identify which division or office within PSE&G is "specifically responsible for verification of status and completion of all commitment items" as stated at page 2-4 of the MAC II report. Identify the organizational document or manual that establishes this responsibility. ,
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RESPONSE
The specific responsibilities of the General Manager -
Nuclear Quality Assurance, the Manager - Nuclear -
Licensing and Regulation, and the Managers of departments i providing data are provided in VPN-LEP-03.
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.. o MANAGEMENT COMPETENCE: INTERROGATORIES III.
III #23 State whether the PSE&G Quality Assurance Department (QAD) makes regularly scheduled audits to assure is that the verification program described above working effectively. If so, identify the frequency of such audits and provide the dates and results of )
the audits since February 25, 1983.
Responses PSE&G Nuclear Quality Assurance implements a documented program of independent verification of n
selected regulatory commitments including NRC
,l ' commitments and completion of the Plan for Improvement of Nuclear Department Operations. In addition to independent verification conducted by Nuclear Quality Assurance a planned QA Audit program.
of the commitment management and corrective action .
4 processes is conducted regularly. These audits are conducted semi-annually. Since February 25, 1983, Ihl3
, three audits have been conducted:
, .T Audit No. Date of Audit .
S-83-12 August 15 through September 9, 1983 S-84-1 February 13 through March 8, 1984 c
l e S-84-13 July 30 through August 17, 1984 l
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III. MANAGEMENT COMPETENCE: INTERROGATORIES III #24 State whether a " formal trend analysis program" has been established as recommended at page 2-7 of the MAC II report. If so, describe this program.
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l Responses A " Formal trend analysis program" has been established in the Nuclear Department as recommended on page 2-7 of the MAC report. This program is i detailed in the PSEEG Nuclear Quality Assurance Department Manual, ' Volume GM9-1, Quality Assurance Procedure (QAP) 7-3, " Trend Analysis", that became effective 10/16/84, and which is implemented by the Quality Assurance Controls Group. It includes the trending of NQA Action Requests, NRC Violations, INPO Findings, Incident Reports / Licensee Event Reports, DCP Reviews, Valve / Breaker Surveillances, and Status of Deficiency Reports.
During Hope Creek Construction, a formal trend analysis program was established to identify recurring deficiencies and to initiate corrective action (s). The program encompasses construction jobsite activities and activities of jobsite subcontractors.
Nonconformance Report (NCRh trend analysis is a documented activity performed by Bechtel Quality Assurance Engineers assigned to the project jobsite.
A trend analysis log is maintained in which all validated NCRs are entered. The trend analysis log is periodically reviewed and at such time that sufficient occurrences of the same nonconformance have been recorded as to indicate a potential trend exists, a trend analysis worksheet is initiated to give visibility to the monitoring and action taken for that group of nonconformances. The potential trend is then investigated to determine whether the fundamental cause(s) of the repetitive nonconformance are similar and thereby indicate a trend.
When evaluation of the basic cause(s) of the repetitive nonconformances indicate that a trend exists, a request for corrective action is issued to the responsible organization. _ Resultant corrective action requests are evaluated, initiated, reported,
, closed and documentation of these actions is retained.
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.. . III. MANAGEMENT COMPETENCE: INTERROGATORIES III.25 Describe all steps taken to implement the recommendations l and suggestions, as they apply to Hope Creek, contained in "A Review of Public Service Electric & Gas Company Corrective Action Program Related to Reactor Trip Breaker Failures at Salem !
Generating Station, Unit 1" dated May 27, 1983 and submitted by Basic Energy Technology Associates, Inc. (BETA).
Response
The referenced BETA report included several recommendations
- related to management issues. These topic areas, which are listed below, are all being addressed in other Public Advocate Interrogatories and/or PSE&G Action Plans.
Topic Comments 1), Nuclear Oversight Committee See response to Inter-(BETA Report IV.C.2.e) rogatory 26.
Revised Nuclear Review Board This is being addressed in 2) membership (BETA Report IV.C.2.e) PSEEG Action Plan 2.2.1 which was to improve Safety Review Management.
Specifically, the Nuclear Review Board function will be replaced by a full-time offsite review organization reporting to the General Manager -
Nuclear Safety Review.
! 3) Evaluating Nuclear Department See response to Inter-Organizational Functioning rogatory 27.
l (BETA Report IV.C.3.a)
- 4) Safety Related Component Testing See response to Inter-(BETA Report IV.C.3.b) rogatory 28.
- 5) Enhance SORC (BETA Report This is being addressed in PSE&G Action Plan 2.2.1 IV.C.3.c) which was to improve Safety Review Management.
Specifically the SORC review process is being redefined to utilize qualified reviewers to support the SORC process and will allow SORC to concentrate on consideration of safe and reliable operation of the station.
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- 6) Reduction of Unplanned Trips See response to Inter-(BETA Report IV.C.3.d) rogatory 29.
Machinery History Date Base This is being addressed in <
- 7) '
(BETA Report IV,C,3,e) Action Plan 2.6.2 which is to develop a Maintenance i Management Information system. This system will integrate various aspects of maintenance planning and management including utilization of equipment history data bases for analysis.
- 8) Strengthen Incident Report Hope Creek Administrative System (BETA IV.C.3.f) Procedure No. 6 regarding the Incident Report System will require that each
- Incident Report include a narrative. This fulfills the BETA recommendation.
- 9) Nuclear Engineering Integration See response to Inter-with plant operations. rogatory 30.
(BETA IV.C.3.g) l l
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III. MANAGEMENT COMPETENCE: INTERROGATORIES
- 26. State whether PSE&G has established a Nuclear Oversight Committee (NOC). If so, described how the concerns raised in the May 27, 1983 BETA report at p. 12-13 have been resolved. If not, described how the proposed objectives of the NOC have been otherwise accomplished.
RESPONSE
A Nuclear Oversight Committee (NOC) has been established.
The concerns raised in the May 27, 1983 BETA report were considered in development of Action Plan 2.2.1 which establishes a revised nuclear safety review organization.
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e w e III. MANAGEMENT COMPETENCE: INTERROGATORIES III.27 Describe how PSE&G senior management has developed a "better capability to determine how well their new organizational plan is functioning, particularly at the lower levels", as recommended by BETA at page 14 of its May 27, 1983 report.
Response
In the August 26, 1983 letter to the Director of Nuclear Regulation, PSEEG included a response to the May 27, 1983 BETA Report. As indicated on page 5 of that response, this particular BETA recommendation was to be addressed by the following PSE&G Action Plan sections:
l 2.1.1 Functional analysis of Vice President - Nuclear and all
- direct reports.
2.1.4 Communications between the Nuclear Department and Corporate.
2.1.5 Detailed Transition Management process.
2.4.5 Coordination between Engineering and Operations.
The key steps accomplished by these - Action Plans that directly respond to the BETA recommendation are as follows:
- 1. The Nuclear Department reorganization of August 28, 1984, which better defined the span of control of Nuclear Department senior management.
- 2. Improved communications between Nuclear Department senior management and PSE&G Corporate senior management.
l 3. Establishment of periodic Nuclear Department management i
dialogue meetings which provide for an open exchange of
- information and discussion of topics between the members of the Nuclear Department management team.
- 4. The addition of an Organizational Development specialist 4
to the Nuclear Department staff. -
- 5. The holding of team building meetings between departmental members at various levels to improve communication and identify difficulties that require resolution.
These key steps demonstrate that senior management has taken positive steps to evaluate -and improve the functioning of the Nuclear Department and fulfill the recommendation made by BETA.
1 INTERROGATORIES
- SECTION III, ITEM 28 l
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DESCRIPTION:
State whether P.S.E. T G. has " review (ed) existing pre-start test requirements at Hope Creek to determine if additional testing of safety related components or systems is desirable,"
as recommneded by BETA at page 15 of its May 27, 1983 report.
- If so, describe what changes at Hope Creek have been implemented as a result of such a review.
RESPONSE
Hope Creek Operations has developed its pre-startup procedure using as a reference, the Salem procedure, which was revised as a result of the breaker failure incident. In addition, the INPO Good Practice on Post Trip Review was evaluated and used as a reference in the Hope Creek prestart procedure.
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INTERROGATORIES SECTION III, ITEM 29
- 29. Describe what efforts have been undertaken by PSE&G to reduce the number of unplanned reactor trips at Hope Creek recommended by BETA with regard to Salem Generating Station at page 16 of its May 27,1983 report.
RESPONSE
PSE&G management is committed to minimizing the number of unplanned trips caused by equipment failure and personnel error. This scram minimization program is' based on INPO and NRC guidance and will include the following elements:
- 1) Thorough review of plant incident reports to determine the root cause of the event, determination of necessary corrective actions and tracking of implementation to completion.
- 2) Trend analysis of periodic preventive maintenance, corrective maintenance and surveillance testing activities to identify reoccurring failures or problems.
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- 3) Industry operating experience, including Salem Ge rerating Station, is evaluated for potential applicability to Hope Creek. Corrective actions are identified and tracked to completion.
- 4) Performance monitoring of selected components is used to identif y degrading conditions, and provide input for maintenance planning and scheduling in a predictive mode.
- 5) Administrative programs which control planning, authorization, coordination and conduct of testing or maintenance activities through validated procedures.
! 6) Personnel training programs which assure understanding of job responsibilities, as well as an attitude of quality awareness.
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-III. MANAGEMENT COMPETENCE: INTERROGATORIES
- 30. Describe all steps taken to " integrate more fully at Hope Creek the nuclear engineering organization into plant 1
operations" as recommended at page 18 of the BETA report of-May 27, 1983.
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RESPONSE
4 Integrating nuclear engineering organization in Hope i creek plant operations is not an applicable process at i the present time. Engineering support of Hope Creek-Operations is presently being provided by the Engineering and Construction Department through its Site Engineering 9 -
organization. The integration of the Hope Creek Site Engineering organization into the Nuclear Engineering organization is addressed in the Hope Creek Transition Plan.
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SECT' ION III. MANAGENENT CONPETENCE: INTERROGATORIES INTERROGATORY 931: List and describe all short and long term items in the PSE&G Corrective Action Plan. For each itent (1) describe specifically all steps taken pursuant thereto (2) describe any steps remaining to be takent and (3) state the expected or actual completion date.
RESPONSE: Table III-31 provides a listing of the short and long term items in the PSEsG Corrective Action Plan and the expected or actual completion date. More detailed -
descriptions of these activities are described in th.e following documents.
Supplement to Corrective Action Progrant Reactor Trip Breaker Failures, No.1 and 2 Unit Salem Generating Station, submitted to the Nuclear -
Regulatory Commission April 8, 1983.
Corrective Action Summary Reactor Trip Breaker Failures, Salem Generating Station Units No. 1 and 2 submitted to the Nuclear Regulatory Commission April 28, 1983 i
Vendor Manual Review Programt Salem Generating Station Units No. I and 2 submitted to the Nuclear Regulatory, Commission February 22, 1984.-
The only open items on this list are activities l
i C.6.b.i and C.6.b.j which are due January 1,1985 and ,
activities C.10.a.1 and C.10.a.2 which are ongoing.
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l TABLE III-31 O PSEEG CORRECTIVE ACTION PLAN STATUS ITEM SUBJECT EXPECTED OR ACTUAL .,
DESIG (Brief Desc.) COMPLETION DATE A.1 Determination of shfety April 1983 classification of breakers A.2 Identification cause of failure !
a.1 Confirm u/v Trip Att. Inc. all April 1983 design changes o.2 Measure force required to trip April 1983 breaker b.1 Submit test program life cycle, etc. May 1983 b.2 Est.~ proc. periodically measure April 1983 force 4
b.2a Complete _ breaker test program and December 1984 analysis and ji OG plant data evalua-tion program .
A.3 Verification testing program a.1 Mfgr. to test u/v trip attachment April 1983 j on test c/b 25 times
- a.2 After inctallation test 10 times April 1983 c.3 Response time test April 1983 c.4 Test within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to re- ~ April 1983 start l
lA.4 Maintenance and surveillance proc.
I j c.1 Cleaning deficiency April 1983 1.
i a.2 Revise maintenance proc. to test April 1983 25 cycles i
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.m PAGE 2 ITEM SUBJECT EXPECTED OR ACTUAL DESIG (Brief Desc.) COMPLETION DATE o.3 Provide acceptance criteria - no- April 1983 failures n.4 Modify maintenance proc. M30-2 April 1983 (3 timing tests) c.5 Modify maintenance proc. M30-2 April 1983 (apply sealant)
- c.6 Add to M30-2 range of dropout April 1983 voltage c.7 Lubricate breakers April 1983 c.8 Trip force measurement April 1983 o.9 Mod. maintenance proc. (6 month April 1983 test) c.10 Provide functional test proc. April 1983 0.11 Perform monthly breaker timing test April 1983 ,
b.1 Tech spec. change Table 1 req. June 1983 A.S.1 Detailed report July 1983 1.a Auto. initiation turbine trip July 1983 1.b Diversity in activating reactor July 1983 scram breakers 2.a Complete generic design July 1984 2.b Develop plant specific design October 1984 B.1 Operating proc. for ATWS --- ---
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PAGE 3 ITEM SUBJECT EXPECTED OR ACTUAL DESIG (Brief Desc.) COMPLETION DATE a.1 Identify indications in control room April 1983 a.2 Review' basis. for ATWS proc. etc. April 1983 b.1 Proc.'to ensure operability of April 1983 SSPS indicators b.2 Schedule upgrade program for emerg, April 1983 oper. proc.
B.2 Operator training o.1 Conduct training on revised proc. April 1983 c.2 Conduct practical exercise April 1983 o.3 Conduct walkthrough on alarms, etc. April 1983 c.4 Training for aux. operators April 1983 a.S Evaluate trainee's performance April 1983 c.6 Review training material April 1983 B.3 operator response c.1 Use of J handle control April 1983 b.1 Replace trip switch with secure April 1983 handles b.2 Modifications to annunciators April 1983 C.1 MEL
~
a.1 Verify MEL is complete accurate etc. April 1983 c.2 Instruct purpose an6 use of MEL April 1983 i
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PAGE 4 IYEM SUBJECT EXPECTED OR ACTUAL DESIG (Brief Desc.) COMPLETION DATE b.1 Re-issue MEL as controlled doc. June 1983 C.2 Procurement proc.
c.1 Revie'w of past procurement docs. April 1983 b.1 Classify items important to safety July 1983 b.2a Procurement procedures January 1984 b.2b OA procedures January 1984 C.2 b.2c AP-19 January 1984 -
b.3 Interim instruct to verify MO/IC's November 1983 b.4 Prog. s sched. for shelf-life January 1984 .
b.5 Develop attributes check list January 1984 b.6 Tag components in warehouse January 1984 C.3 Work order proc.
1 l 0.1 OA review all non SR work orders April 1983 l
l n.2 Training program classification April 1983 l work order t
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. ITEM SUBJECT EXPECTED OR ACTUAL
- DESIG (Brief Desc.) COMPLETION DATE 0.3 Evaluate safety consequences of April 1983 improper class of work orders
'C.4 Post-trip review -
c.1 Post-trip review procedure AD-16 April 1983 6 c.5 Timeliness of event notification a.1 Assign dedicated communicator April 1983 0.2 Review importance of reporting April 1983 requirements C.6 Updating vendor-supplier information c.1 Update existing document control system a.lo) Audit station files April 19E2 b) Audit Nuclear Engineering files April 1983 ,.
c) Compare Station & Nuclear Engg. April 1983 i
d) Contact vendors-confirm manuals April 1983 Request updated copies April 1983 j a.2 Review W tech. bul.eti's and data April 1983 i letters
- b. Long-term actions a) Audit station for manuals, etc. July 1983 b) Audit Nuc. Engg. for manuals, etc. July 1983 I
PAGE 6 ITEM SUBJECT EXPECTED OR ACTUAL DESIG (Brief Desc.) COMPLETION DATE c) Compare Station & Nuclear Engg. August 1983 d) Confirm manuals technically current, December 1983 etc. '
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e) Revise station procedures July 1983 f) Control of new/ revised manuals December 1983 j
[ g) Develop proc. to control vendor May 1983 l manuals h) Vendor manuals in TDR; & revise July 1984 procedures '
i) Review vendor manuals January 1, 1985 -
j) Incorporate findings from h & i January 1, 1985 k) Clear direction on use of un- January 1984 .
controlled vendor manuals
'C.7 Involvement of OA with other depts.
a.1 Retain outside consultant April 1983 c.2 Modify QA organization policy to April 1983 l more fully integrate b.1 Training on work orders September 1983 C.8 Post-maintenance operability testing c.la Revise AP-9 July 1983 o
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1 g PAGE 7 l ITEM SUBJECT EXPECTED OR ACTUAL IDESIG (Brief Desc.) COMPLETION DATE i
l s.lb Rev. 2 of AP-9 & A-21 0.2 Complete review of vendor and engg. January 1984 ;
recommendations and incorporate I necessary changes into departmental l documents I a.3 Incorporate items into insp. order August 1983 systems -
l c.4 Complete managed maintenance prog. June 1984 ;
- a. Complete for 15 systems February 1984
- b. Complete for critical components February 1984
- c. Complete for all safety-related June 1984 systems C.9 overall mgt. capability &
performance
- 1. Complete staffing of N.A.&R. dept. January 1984
- 2. Independent assessment of OA July 1984
- 3. Training program for 1st level September 1984 supervisors (TSSP-1)
- 4. Training program for senior October 1983 supervisors level (TSS P-2 )
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PAGE 8 I' FEM SUBJECT EXPECTED OR ACTUAL DESIG (Brief Desc.) COMPLETION DATE 4.a Commence training for (TSSP-2) February 1984
- 5. Reg. ,trng. prog. for supervisory March 1984 and management personnel (TSSP-3)
- 6. Dev. tech. trng. for non-station April 1984 personnel (TSSP-4)
- 7. MAC management diagnostic final June 1983 report C.10 Management reports 0.1 NOC reports to Sr. V.P. (ES&E) & ongoing Director of NRR -
c.2 Provide Dir.-NRR with responses to ongoing report 0.3 Prelim. report to include N.O.C. January 1983 charter ,
l b.1 MAC rept.-full analysis & sched. August 1983 for implementation to NRR c.1 Submit to NRR copy of BETA rev. April 1983 D. Initial start-up after 2/25 event. May 1983 Verification of total operability i
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j III. MANAGEMENT COMPETENCE: _INTERROCATORIES IN T E R R O G A T O RIE S SECTION EL ITEN 32 0 ESC RIPTION Identify and describe any and a21 steps that have been taken or willbe taken by )
P.S.E. & G. to ens.tre that its management displays "the expected aggressive effort '
to self evaluate and redirect efforts to correct internally identified probla as" found to be lacking by the N RC staff at page 37 of the Sa2sa Restart SER. Identify all docu'ments relating to any such steps.
mEsPoEE3 J
The Public Service Electric and Gas Company has
, implemented a system of performance indicators (described in the VPN procedures) to monitor our performance trends relative to those of the industry on an ongoing basis. Areas, identified by this self-evaluation, requiring efforts to correct de-ficiencies will be addressed on a. case by case basis.
An example of self initiated efforts to resolve
- problems in this way is the task force on capacity
' factor improvement.
The Puh11C Service Electric and Gas Company ' Plan for Improvement of Nuclear Department Operations"is a result of a comprehensive reviaw of Nuclear I Departaent progr as and activities. PSE & G engaged Manage aent Analysis Coapany (N AC) to perfora an independent assessment of PSE& G's Nuc2 ear Department to make recom sendations for improvemonts in organisation structures, manage ment syste ma, and quality assurance progra ms. The results of the M A C diagnostic studies were documented in reports given to the Nuclear Reg'ulatory Co a misanon (N RC).
The PJ.E. & G. " Plan forInproveaent of Nuclear Departaent Coerations"
' incorporates responses to both N AC assessments, by establishing. specific oldectives for improvement and developing Action Plans to accomplish these objectives.
O INTERROGATORIES l
SECTION E. ITEM 33
- 33. Identify and describe any and all steps that have been or will be taken at Hope Creek by PSE&G to prevent the " poor communication among the various departments (that) has hindered the development of a sensitivity with the (Salem) station staff to identify and resolve problems that are outside their direct sphere of influence," as noted by the NRC staff at page 38 of the Salem Restart SER. Identify all documents relating to any such steps.
RESPONSE
PSE&G has implemented a program entitled," Action Plan to strengthen the Nuclear Engineering Organization and improve Coordination Between Nuclear Engineering and Operations." This program is a continuing series of team building meetings between a!! departments and all management levels.
Good communications exist at Hope Creek Station due to the interaction of senior level people from each Department at key site meetings. Examples are:
. Daily Action Meetings run by the Operations Department Managers are attended by key Startup and Engineering representatives.
. Plan of the Day Meeting run by Startup Managers are attended by key Operations Supervisors.
. Weekly Engineering Interface Meeting run by Engineering and attended by key Operations representatives. *
- Periodic Management Dialogue Sessions are attended by key management personnel.
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III. MANAGEMENT COMPETENCE: INTERROGATORIE_5-
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j 34. Identify and describe any and all steps that have been or will be taken by PSE6G to remedy the " parochialism" that the NRC staff found, at page 38 of the Salem Restart SER to be the result of the isolation of support groups, and inparticular, of maintenance and engineering,
. from.one another. Identify all documents relating to -
any such steps.
RESPONSB The engineering support for Hope Creek during its Prooper-ational Testing Program will be satisfied by personnel from P5EEG's Engineering and Construction Department who have i been reassigned to' Artificial Island. This organization works hand-in-hand with the Hope Creek Operations Depart-
- ment and plays a major role in the construction completion and startup of the project. To insure that goed communi-cations exist, both departments attend key site meetings '
as indicated in response to interrogatory 2-33. At the point in time when construction and startup activities are completed this Engineering o~rganisation as an operable unit, will be transitioned into the Nuclear Department to.
, provide ongoing engineering support for Hope Creek during its operating life. This combination of good project com-l munications and continuity of personnel will preclude the
" parochialism" that was identified in the Salem Restart SER.
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! III. MANAGEMENT COMPETENCE: INTERROGATORIES
- 35. Identify and describe any and all steps that have been or will be taken to PSE&G 'to remedy the " problem.....of l high level station management and first line station supervision failing to adequately assess the performance
- of their subordinates, especially with respect to adherence to procedures," as noted by the NRC staff on page 38 of the salem Restart SER. Identify all documents relating to any such steps. ,
masPousE .
!. A Technical Supervisory skills Program (TSSP) has been developed and implemented to promote intellectual curiosities and technical competence to ensure a high caliber of supervisory personnel is developed and main-~ t j tained at both the Hope Creek and Salem Generating Station.
l TSSP (as app 1'icable to station personnel) is comprised l of three separate courses, each having its own unique / specific objectives, scope, and criteria.
l TSSP-1 is approximately eight weeks in duration and is tailored specifically for first-level supervisors.
TSSP-2 is approximately five weeks in duration and is tailored specifically for senior supervisory level personnel.
TSSP-3 serves as a refresher course and is periodically offered to both first-line supervisors and senior super-visory level personnel.
TSSP includes, but is not limited to, the following subject areas:
Stress Management Performance Appraisal Progressive Discipline
- communications Group Dynamics
{thics *
- ~~
Time Management Motivation Planning The Vice President - Nuclear uses regularly scheduled management dialogue meeting to motivate and remind higher level management personnel to become more involved in station activities and to raise their expectations of acceptable response. These topicsmanagers plant are futher staff disseminated meetings.to middle management through
, See respcnse to Interrogatory III/3.
- - - - - , - , , - . , ,. _ _ , . _ _ _ , , _ . , _,m_. _ _,, _ _ _ _ _ , , _ , _ _ _ _ , _ _ , _ , _ _ ,
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III. MANAGEMENT COMPETENCE: INTERROGATORIES
- 36. Identify and describe any and all steps that have been or will be taken by PSEEG to remedy the problem identified by the NkC staff on page 38 of the Salem Restart SER that "First line supervisors appear to refrain from raising issues out-side of their defined scope of responsibility..." Identify all documents relating to any such steps, i
RESPONSE
See response to Interrogatory 35.
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l III. MANAGEMEIrf COMPETENCE: INTERROGATORIES III #37 Identify and describe any and all steps that have or will be taken by PSEEG to remedy the problems that suggested to the NRC staf f that there had been "a major. breakdown in management and quality assurance program implementation at the Salem Nuclear Generating Station". Salem Restart SER at 38.
Identify all documents relating to any such steps.
Responses Actions and associp.e,d docuggjs have been provided l
in response to: Interrogatories III/3,17 and 21.
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III. MANAGEMENT COMPETENCE: INTERROGATORIES
- 38. Identify and describe all steps taken by PSE&G to correct or remedy the " lack of resolve on the part of, PSE&G managers and supervisors in enforcing adherence to procedures" perceived by the NRC staff identified by the NRC on page 39 of the Salem Restart SER as one of the principal causes of the February 22 and 25, 1983 events at Salem Unit 1.
Identify all documents relating to any such steps.
RESPONSE
See response to Interrogatory III/35 .
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s i MANAGEMENT COMPETENCE: INTERROGATORIES III.
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Interrogatory 39,Section III. .
i~
- Identify and describe all steps taken by PSE&G to improve "the safety perspective displayed by the corporate management" identified by the NRC staff at Page 39 of the Salem Restart SER as one of the principal causes Identify for all thedocuments February 22relating and 25, E 1983 events at Salem Unit 1. l'
,S to any such steps.
A
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RESPONSE. .
The following steps were taken to improve the safety perspective displayed by the corporate management. *
- 1. Strengthened Nuclear Review Board with .
participation by persons from outside ~
organizations.
1
- 2. Assignment of a member of the Safety Review Group to serve on the Station Operations Review Committee.
- 3. Establishment of the Nuclear Assurance and Regulation Department reporting to the Senior Vice President - Nuclear (
and Engineering. <
Datuils of items 1, 2, and 3 above are discussed in a letter dated March 18, 1983 from R. A. Uderits to R. W. Starostocki on Docket No. 50-272. (Copy attached).
- 4. A Nuclear Oversight Committee consisting of nationally recognized experts has been established by the Company's Board of Directors i i
' to oversee safety aspects of the company's nuclear operations. Details regarding the Oversight committee are covered in responses to Interrogatories 26 and 44.
- 5. Pursuant to'the recommendations resulting from Action Plan on Safety Review Management, a management decision has been made to establish a Nuclear Safety Review Department headed by a General Manager and a non-Technical Specifi-cation Nuclear Safety Advisory Board, both reporting to the Vice President - Nuclear.
Details of the subject Action Plan are included in response to Request for Documents #3,Section IV.
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The corporate policy stating that " Nuclear i 6.
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safety is of the highest priority and shall i take pre,cedence over matters concerning power l production" is included in the Nuclear De-This policy is constantlyj partment Manual. emphasized by the Vice President - Nuclear l and other corporate officials. 1 il, 1
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i III. MANAGEMENT COMPETENCE: INTERROGATORIES
- 40. Identify and describe all steps taken by PSE&G to become i "proactive".rather than " reactive" in its approach to the
- kinds of problems resulting in the February 22 and 25, 1983 events at Salem Unit 1, as suggested by Region I Administrator Thomas Murley at a meeting with PSEEG officials on April 10, 1984. Identify all documents relating to any such steps.
RESPONSE
The Management of Public Service Electric and Gas Company is aggressive and proactive in pursuing appropriate solutions '
to problems that occur, not only at the present time but also in the past. Our management style has always been aggressive in areas where we believe aggressiveness was required. Por example, in the design and engineering of the Salem Plants we displayed initiative and a capacity j
for innovation, such as the control room design, which we believe produced a superior plant design. We built one, of the finest Nuclear Training Centers without any pressure from outside sources because we believed it was the right i thing to do. This aggressive attitude continued when we l took a major step in 1981 and organized a. separate Nuclear Department and began relocation of the entire department, including the Vice President responsible for its operation, to Artificial Island. As a result of this mover we now have several hundred relocated people on site, and we are l
actively working to coordinate the activities of our Engineering and Administrative people with the operating people who were originally at the plant. This allows the Engineering people who are responsible for the design of the plant to be located at the work location and not 150 miles away, another aggressive action.
Prior to the Salem events, we had been talking to Management-Analysis Company (MAC) about an overall assessment of our Quality Assurance (QA) Program, where we ourselves believed t there were opportunities for improvement. Subsequent to the evant, MAC was engaged to perform an independent assessment.
of PSE&G's Nuclear ~ Department.to make. recommendations for improvements in organization structures, management systems and quality assurance programs. PSE&G created a " Plan for Improvement of Nuclear Department Operations" which incorporated responses to MAC assessments, and created Action Plans to meet identified objectives. A.special PSE&G management task force developed 29. Action Plans with an integrated schedule for their implementation. These Action Plans are grouped into seven topical areas, which are as follows:
l Organization Management, Safety and Compliance Management, configuration Management, Operations l
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III. MANAGEMENT COMPETENCE: INTERROGATORIES
- 40. (Continued) and Operations Support, Quality Assurance, Maintenance and Plant Betterment,
/ and Nuclear Department Services. This extensive effort by PSE&G reaffirms the Company's long-standing commitment to achieve excellence in the management and operation of the nuclear f acilities at ArtificialIsland.
PSE&G has established an abnormal occurrence review program. All events,
~
whether reportable to Regulatory Agenc es or not, are reviewed by the Systems 5
Analysis Group in the Nuclear Engineering Department. Each event is analyzed to
- determine reportability. In addition, ine program has been beneficial in establishing better engineering involvement in plant operations. This program, which takes action on abnormal occurrences and not just events which are j~ determined to be reportable, demonstrates PSE&G's agressiveness in solving immediate problems and preventing potent!al problems.
i Additional significant actions that we consider to be self-initiated, positive, aggressiwr actions on the part of our Nuclear effort is the formation of the Nuclear
! ,~ l 4 S > Quality Assurance Department, the Nuclear Assurance and Regulation Department and the Nuclear Safety Review Department as well as input from the Institute of Nuclear Power Operations. Development otthe Preventive Maintenance Program and implementation of the computerized safety tagging system will reduce operator errors, improve safety, comp!irct. to tech specs and decreased operator drudgery. The cambined efforts and benefits from these organizations and programs willimprove the overall operations and reliability of our facility.
l@ Other specific steps have been taken with respect to Hope Creek to identify potential problems and resolve them in,an expeditious manner. Examples of this
- g. proactive approach are:
. Action plan item 2.2.1 (ref. !),Igprovement of Safety Review Activities.
a
. Implementation of a Feedba-k of Operating Experience Program which includes review of nine years of historical data.
y .
Conducted self-evaluation of operational readiness in INPC format.
." . Implementation of the Safe Team Program which encourages the
- identification of alleged problems by all site personnel.
b . Weekly station cleanliness walkdowns by plant management.
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O III. MANAGEMENT COMPETENCE: INTERROGATORIES 4
- 41. . Identify and describe all ways in which PSE&G's top corporate leaders have increased their involvement with i the daily. operation of PSE&G's nuclear plants, as stated by Harold Sonn on April 10, 1984. ' Identify all documents '
i relating to any such steps.
l .
RESPONSE
o At the briefing on the status of Salem, presented to the NRC Commissioners on April 10, 1984, Mr. Sonn stated the following:
~
"In fulfilling my responsibility, I involve myself on a daily basis with plant activities through reports on our-operations. I also have scheduled weekly meetings with Dick Eckert and Dick Uderitz to review activities A Weekly Report as well as progress on our improvement program.
is discussed which assesses our accomplishments to date -
and addresses our concerns and their resolution.
In addition, I receive Monthly Performance Reports which address all aspects of our nuclear operations. Details are included in the form of descriptions, assessments and graphic displays on subject such as operating events, safety system status, personnel radiation exposure, industrial safety, radioactive waste generation and disposal, staffing, and unit equipment performance.
My overall efforts are in addition to multiple levels of more-detailed review and are in place at several stages
- in our operations.
By frequent visits to the plant site, I seek to communicate to Nuclear' Department personnel, through meetings with employees at various levels, the importance
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the company places on their work and to familiarize myself with.as many activities as possible.
l l Our company Board of. Directors'is equally concerned with l' the safe. operation of.our nuclear facilities. .At each Board meeting, nuc19ar operations are discussed. Formal t_
presentations on various aspects of the operations are made periodically."
o Daily discussions' occur between the Senior Vice President
- Nuclear and Engineering (Sr. VP-N&E) and the Vice President - Nuclear (VPN) regarding plant status and operation for the Salem facility.
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III. MANAGEMENT COMPETENCE: INTERROGATORIES ,
- 41. (Continued)
. Periodic visits by the Sr. VP-N&E on at least a monthly basis provide an opportunity for discussion between the VPN and his staff regarding plant operation.
. The VPN meets on a weekly basis with the President and Sr. VP-N&E following Operating Committee meetings to
- discuss nuclear operation and pertinent activities.
. Special meetings, either in Newark at the Corporate Headquarters or at ArtificialIsland take place with any and alllevels of management as the need dictates.
. Monthly meetings occur with the Sr. VP-N&E and General Manager - Nuclear Assurance & Regulation (GM-NA&R) along the VPN and his staff to review and discuss issues i associated with the operation of the nuclear facilities.
. As a result of the recent reorganization of the Nuclear Department which initiated the Senior Management Team concept, daily meetings between the VPN, the Assistant Vice President - Operations Support (AVP-OS), General Manager - Nuclear Safety Review (GM-NSR), and General Manager - Nuclear Quality Assurance (GM-NQA), occur following a briefing on the status of nuclear operations.
. The development and implementation of numerous performance indicators in the Nuclear Department Monthly Report receives Corporate Management level attention.
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O 111. MANAGEMENT COMPETENCE: INTERROGATORIES
- 42. Identify and list each of the approximately thirty outside groups that have assessed PSE&G's nuclear operations, as stated by PSE&G officials on April 10,1984. Summarize the conclusions and recommendations of each such assessment.
RESPONSE: Oversight, review and audit of PSE&G's Nuclear Operations is conducted by many internal and external organizations. The attached listing identifies many of these organizations and their primary functions or nature of oversight, review or audit.
These groups provide periodic reports dependent upon their charter and the nature or function which they perform. In 1984, more than 300 individual reports have been issued relative to Salem Operations.
Some of these reports are provided directly to the State of New Jersey by the originating organization. Summary reports are not normally provided and time constraints prevent a summarization of all of the detailed reports. Report summaries or the individual report indicated below will be made available in response to Management Competence l
Request for Documents.
.i NRC Inspection Reports - Provided directly to the State of N.J.
NRC SALP Reports - Section IV Item 21 Nuclear Review Board - Section IV Item 24 Safety Review Group - Section lY Item 37 Nuclear Oversight Committee - Section IV Item 3 f
Training Reports - Section IV Item 8, 28, and 33 Pre-Operational Review Committee - Section IV Item 16 Institute of Nuclear Power Operations - Section IV Item 22 ,
Nuclear Mutual Limited - Section IV Item 30 and 32 Basic Energy Technology Associates - Section IV Item 38 QA Audit Reports l
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O INTERROGATORIES SECTION IH, ITEM 43 DESCRIPTION:
Identify and describe all steps taken by PSE&G to become more aggressive in solving its own problems before being pushed by the NRC, as suggested by Region I Administrator Thomas Murley on April 10,1984. Identify all documents relating to any such steps.
RESPONSE
See response to Interrogatory III/40.
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\v III. MANAGEMENT COMPETENCE: INTERROGATORIES
- 44. Identify the oversight committee formed in October 1983 to advise PSE&G. List each of the dates this committee has met and provide copies of the summaries or minutes of these meetings.
RESPONSE
Meetings were held October 27,1983, December 13,1983, March 12 and 13,1984, June 11 and 12,1984, September 6 and 7,1984, and December 6 and 7,1984. Summaries of these meeetings are in the form of the NOC Quarterly Report. The report for the last quarter of 1984 has not yet been issued.
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MANAGEMENT COMPETENCE: INTERROGATORIES III.
Section III ,
f Identify the dates of each observation of an operating 3 Question 45: BWR or PWR which took place pursuant to your structured , ,
j PWR/BWR observation program referred to at p. 13-10 of the SER. For each such observation, identify p.,
J the names of all personnel participating in the obser- 1 vation and the license for which they were being ;
trained, the name and location of the reactor observed, ;
j l
the specific systems and procedures observed, and '
whether the reactor observed was a BWR or PWR.
Name/ Location Plant Type ,,
Lic Dates Namel Susquehanna B'WR*2 02/13/84 - 08/06/84 Lou Aversa SRO Berwick, PA 1.
(1048 hours0.0121 days <br />0.291 hours <br />0.00173 weeks <br />3.98764e-4 months <br />) - .
9 Susquehanna BWR*2 ['
Frank Hughes SRO. 02/13/84 - 08/21/84 Berwick, PA i
(1060 hours0.0123 days <br />0.294 hours <br />0.00175 weeks <br />4.0333e-4 months <br />)
Susquehanna BWR*2 Tcm Russell SRO 04/04/84 - 09/06/84 Berwick, PA (1092 hours0.0126 days <br />0.303 hours <br />0.00181 weeks <br />4.15506e-4 months <br />) .
Susquehanna BWR*2 Bob Stamato SRO .05/16/84 - 01/29/85 Berwick, PA Susquehanna BWR*2
, Marty Trum, SRO ' " 02/13/84 - 07/31/84 Berwick, PA jg
- (1078 hours0.0125 days <br />0.299 hours <br />0.00178 weeks <br />4.10179e-4 months <br />) ,
Salem PWR*1 Mark Azzaro SRO 10/21/83 - 11/22/83 Salem, NJ (60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />)
Peach Bottom BWR*3 06/30/84 - 08/26/84 Delta, PA (248 hours0.00287 days <br />0.0689 hours <br />4.100529e-4 weeks <br />9.4364e-5 months <br />)
Salem PWR*1 Jeff Johnson SRO 05/14/84 - 05/25/84 Salem, NJ (80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />)
- Peach Bottom BWR*3 07/08/84 - 08/25/84 Delta, PA (272 hours0.00315 days <br />0.0756 hours <br />4.497354e-4 weeks <br />1.03496e-4 months <br />)
Salem PWR*1 Gary Nayler , SRO 01/02/84 - 01/27/84 Salem,. NJ
- '(160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br />)
Peach Bottom BWR*3
- 06/28/84'- 08/20/84 Delta, PA (248 hours0.00287 days <br />0.0689 hours <br />4.100529e-4 weeks <br />9.4364e-5 months <br />)
Peach Bottom BWR*3 Jim O'Brien SRO 06/26/84 - 08/29/84 Delta, PA (280 hours0.00324 days <br />0.0778 hours <br />4.62963e-4 weeks <br />1.0654e-4 months <br />)
Salem PWR*1 Bill O'Malley SRO 10/24/83 - 11/18/83 Salem, NJ (160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br />)
Peach Bottom BWR*3 06/25/84 - 08/08/84 Delta, PA (256 hours0.00296 days <br />0.0711 hours <br />4.232804e-4 weeks <br />9.7408e-5 months <br />)
Page 1/5
O 1 S;etion III Question 45 Plant Type Dates Name/ Location Name Lie Salem PWR*1 Rtndy Ebright SRO*- 01/03/84 - 01/13/84 Salem, NJ
. (80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />)
Peach Bottom BWR*3 .
09/01/84 - 11/12/84 Delta, PA Salem PWR*1 Frank Higgins SRO 03/12/84 - 03/23/84 Salem, ,tET (80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />) .
Peach Bottom BWR*3
. 10/05/84 - 12/22/84 Delta, PA Salem PWR*1 Larry Newman SRO 03/12/84 - 03/23/84 Salem, NJ )
(80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />) . !.
Peach Bottom BWR*3 i 08/26/84 - 11/01/84 Delta, PA 4
Salem PWR*1 Dave Powell SRO 01/03/84 - 01/13/84 Salem, NJ (80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />) '
Peach Bott.om BWR*3 10/01/84 - 12/22/84 Delta, PA Susquehanna BWR*2
. Steve Saunders SRO 02/13/84 - 05/03/84 Berwick, PA . .
j (452 hours0.00523 days <br />0.126 hours <br />7.473545e-4 weeks <br />1.71986e-4 months <br />) ,
Peach Bottosi BWR*3 Randy Thorsen SRO 09/01/84 - 12/22/84 Delta, PA
- 1 Procedures observed include Tagging Request Information System
- (TRIS), Station Safety Tagging, Security, Firs Protection, Emergency Response, Shift Relief and Turnover. Other procedures and systems observed or participated in were consistent with I the day-to-day operation of the plant.
A minimum of 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> was spent on-shift. Numbers in parentheses indicate actual hours worked. .
- 2 The systems and procedures that were observed or that Eere actively participated in were This consistent time with participation.in included the day-to-day E
' operation of the plant.
the daily operation of the Unit i reactor at power.and the initial fuel loading, pre-operational testing, initial criticality and power accession testing of the Unit 2 reactor plant.
A minimum of 1040 hours0.012 days <br />0.289 hours <br />0.00172 weeks <br />3.9572e-4 months <br /> was spent on-shift. Numbers in parentheses indicate actual hours wor.:ed.
- 3 The systems and procedures observed or that were actively participat in were consistent with the day-to-day operation of the' plant.
A minimum of 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> were spent on-shift. Number in parentheses W.bgGnJ@ ABO 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. work.ed..._.-.___ ._._ _ _ _,_
O 5;ction III Qucation 45: .
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Y Name/ Location Plant Tvoa ,
Lic Dates Name PWR*1 .
Salem Paul Bonnett RO 07/11/83 - 07/21/83 Salem, NJ . ,
i BWR*2 I-Susquehanna 1-
- 4 01/21/85 - 02/02/85 Berwick, PA i
Salem PWR*1 Bill Chausse RO ~07/11/83 - 07/22/83 Salem, NJ
- Susquehanna BWR*2
- 4 02/04/85 - 02/16/85 .
Berwick, PA Sa'lem NWR*1 ,
07/05/83 - 07/22/83 ^
John DeDominico RO
- Salem', NJ Susquehanna BWR*2
- 4 01/21/85 - 02/02/85 Berwick, PA Salem ' PWR*1 Ted Easlick RO 07/11/83 - 07/22/83 $alem, NJ Susquehanna BWR*2
- 4 02/18/85 - 03/02/85 Berwick, PA r Salem PWR*1 Joe Edwards RO 07/25/83 - 08/12/83 Salem, NJ Susquehanna BWR*2
Susquehanna BWR*2
- 4 02/18/85 - 03/02/85 Berwick, PA Salem PWR*1 Steve Geary RO 07/25/83 - 08/05/83 Salem, NJ Susquehanna BWR*2
- 4 01/07/85 - 01/19/85 Berwick, PA Page 3/5
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S:ction III .
Question 45: -
. P.
- Plant Type -j Dates Name/ Location !
Nage Lic
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Sales PWR*1 Sam Hansell RO 07/11/83 - 07/22/83 Salem, NJ !!
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Susquehanna BWR*2
- 4 02/04/85 - 02/16/85 Berwick, PA I
Salem PWR*1 Sam Jones RO 07/25/83 - 08/05/83 Salem, NJ ,'
Susquehanna 'BWR*2 j
- 4 02/,18/85 - 03/02/85 Berwick, PA 1
Salem. PWR*l-Erad Lewis RO 07/25/83 - 08/05/83 Salem, NJ Susquehanna BWR*2
- 4 02/04/85 - 02/16/85 Berwick, PA Salem -
'PWR*1 Robert Rudy RO 07/05/SQ - 07/22/83 Sal,em, NJ Susquehanna BWR*2
Susquehanna BWR*2
- 4 01/07/85 - 01/19/85 Berwick, PA Salem PWR*1 Tom Williams RO 08/01/83 - 08/12/83 Salem, NJ Susquehanna BWR*2
- 4 01/21/85 - 02/02/85 Berwick, PA,, ,
$alem PMt* 1~
-Paul Wilson RO 07/05/83 - 0'8/12/83 Salem, NJ Susquehanna BWR*2
- 4 01/21/85 - 02/02/85 Berwick, PA Susquehanna BWR*2<3 Rich Myers RO 01/07/85 - 01/19/85 Berwick, PA Susquehanna BWR*2,3 Tom Kirwin RO 02/04/85 - 02/16/85 Berwick, PA
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Sectio'n III s
. 9 Question 45 ' -
=
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- 1 Procedures observed include the Tagging Request & Inform Other procedures System (TRIS), :
3 Emergency Response, Shift Relief and Turnover.and system 4 the day-to-day operation of the plant. - 1 A minimum of 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> were spent on shift. 1
- 2 The procedures and systems that are to be observed are to be consistent with the day-to-day operation of the plant
- A minimum of 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> is to be spent on shift. .
- 3 RO Licensed at Salem Generating Station.
- 4 Scheduled .
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l MANAGEMENT COMPETENCE:
INTERROGATORIES III.
Section III Describe in detail how you will meet the requirements Questi.on 46: of Generic Letter 84-10 in response to the concerns "l
- )
cf the NRC staff as indicated in p. 13-11 of the y SER. 311 '
1 Appendix 13K of the FSAR describes the observation / experience train- 4 l
ing program developed to satisfy the requirements of Generic Letter ;
84-10. This observation / ofexperience training includes a minimum on-shift observation / participation f of six weeks (240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br />) I at a comparable BWR plan for all Senior Reactor Operator candidates !
l who are not previously BWR licensed or do not have actual operating !'
- experience at a comparable BWR plant.
' The observation / experience training program also provides for a minimum of two weeks (80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />) on-shift observation at the Salem Generating Station, a 1000 MWe PWR, and two weeks (80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />) on-shift observation at a comparable operating BWR facility for all Reactor Operator candidates who are not previously BWR licensed or dQ not have actual operating experience at a comparable BWR plant.
Each license operator candidate (RO, SRO) will also participate ,
in the Operator In-plant Training described in Appendix 13I of the FSAR. This training provides for a structured and documented .
a program of plant specific system checkouts, preoperational work
- assignments and testing to give each' operator a thorough knowledge
.This train-of Hope Creek plant equipment,and operating procedures.
ing is documented by individual In-plant Training' Guidelines for
- the RO and SRO candidates. r i
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i O INTERROGATORIES i III. MANAGEMENT COMPETENCE:
Section 3 Item 47 Identify and describe all specific TSSP and other training courses for each Hope Creek management and staff position identified in the FSAR, as suggested by the NRC staff at P. 13-17 of3 ,. p SER..
RESPONSE
, Appropriate technical courses are provided to several positions in addition to the management training identified below. Those eligible for the Executive Development and Advanced Management
- Programs also attend periodic Management Dialogue Sessions.
Position Program Eligibility Vice President - helear: Executive Development Programs l Assistant Vice President - Nuclear Operations: Executive Development Programs 1 Assistant Vice President - Nuclear Operations Support: Executive Development Programs General Manager - Nuclear Quality Assurance: Executive Development Programs General Manager - Nuclear Safety Review: Executive Development Programs General Manager - Nuclear Engineering: Executive Development Programa Manager - Nuclear Licensing and Reliability: PSE46 Advanced Management Program
! General Manager - Hope Creek Operations: Executive Development Programs General Manager - Nuclear Services: Executive Development Program Manager - Methods and Systems: PSE44 Advanced Management Program ',
Public Affairs Manager - Nuclear: PSE86 Advanced Management Program Personnel Affairs Manager - Nuclear: PSE44 Advanced Management Program Manager - Outage Services: PSEAG Advanced Management Program Nuclear Industrial Relations Manager: PSE4G Advanced Management Program Assistant General Manager - Joint Ouners and Regulatory Affairs: Executive Development Programs i
special Projects Administrator: PSE&G Advanced Management Program Manager - Nuclear Maintenance Services: PSE46 Advanced Management Program g
- Manager - Nuclear Site Protection
- PSE&G Advanced Management Program Manager - Nuclear Training: PSE&G Advanced Menagement Program Manager - Radiation Protection Services: PSE46 Advanced Management Program Manager - Nuclear Licensing and Regulation: '
PSEAG Advanced Management. Program l Manager - Nuclear Fuel: PSE&G Advanced Management Program l Manager - Netta6111ty and Assessment:
- PSEAG Advanced Management Program Assistant General Manager - Nuclear Engineering: PSE46 Advanced Management Progr,as Manager - Hope Creek Systems Engineering: PSE4G Advanced Management Program i Manager - Mechanical / Civil (!&C/ Electrical) - I Engineering: PSE&G Advanced Management Program I Manager - Nuclear Engineering Design: PSEAG Advanced Management Program Manager - Nuclear Engineering Control: PSE&G Advanced Management Program i Shift Supervisor: Technical Supervisory Skill,s Program -1 i Senior Nuclear Shift Supervisor: Technical Supervisory Skills Program - 2; Management Training Program ,
Chemistry Engineer: Management Training Program
- !&C Engineer
- Management Training Program -
l Technical Engineer: - Management Training Program l . Principal Startup Engineer: Management Training Program
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il MANAGEMENT COMP m Is m MAMRM III. )
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,4 8.
List and identify each and every person who provided information for use in "An overview of PSEEG Technical Qualifications and Management capability in Support of the Operation of Hope Creek Generating Station" dated j July 1984 (Management overview Report). 7 1
Response 2 Identified below are each and everf person who provided '
4 information or in any way participated in the drafting,
- editing or review of the Management overview Report.
PSEEG EMPLOYEES C. Johnson D. Parks .. ,
R. Bast- .
J. Boettger S. Ketcham L. Reiter R. Rippe R. Burricalii S. Kosierowski D. Ruyter T. Busch P. Krishna R. Salvesen .
L. Codey P. Kudless .
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- S. LaBruna R. Schaffer C. Connor P. Landrieu E. Selover -
j R. Cowles -
R. Leach R. Silverio F. Delany R. Eckert E. Liden R. Uderitz P. Walzer
)'
R. Edmonde R. Lovell
- E. Yochhies l
S. Funston T. Martin M. Sapolski A. Garrison J. Meredith J. Supko W. Gott E. Midura ,
D. Hanson J. Nichols .
W. Eleczpiel MANAGEMENT ANALYSIS COMPANY EMPLOYEES W. Bibb E. Lamb ,
S. Lamb A. J. Tudury ENERGY CONSULTING SERVICES EMPLOYEES C. Allen E. Miles
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. l INTERROGATORIES
. III. MANAGEMENT COMPETENCE:
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- 49. List and identify each and every person who in any way participated in the drafting, editing or review of the Management Overview Report.
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Response
See response to Interrogatory 48. .
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III. MANAGEMENT COMPETENCE: INTERROGATORIES 1 i 4
- 50. Describe all procedures that will be used to " coordinate on a routine basis concerning ' lessons learned' and to address operating problems from a shared experience data base for all three units" as referred to at p. 2-1 of the Management Overview Report. Also identify all personnel that will participate in such procedures. l I RESPONSE l
The procedures that will be employed to " coordinate on a i
routine basis concerning ' lessons learned' and to address operating problems from a shared experience data base for
) all three units", are those associated with the conduct j of operations and the organization of the Nuclear Department j
at Artificial Island. These procedures have been described in the FSAR in the sections describing conduct of operations l and organization for the Nuclear Department. The execution of these procedures will involve all personnel within the i
Nuclear Department.
The process, philosophy, and structure to achieve this corrdination on a routine basis is that associated with consolidating che responsibilities and authority to support, ,
operate and administer the activities of the three nuclear ]
' facilities under one organization in one location. ;
J It is the day to day management activities brought about l l by the organisational structure, the close physical l accessibility of personnel and the consolidation of re-1 ;
sponsibilities and authority which leads to routine communication and coordination of " lessons learned" and i l
operating problem solutions. The functional organizational structure facilitates the application of the shared experience data base since the department with the technical expertise
. in a particular area is charged with supporting each of the three facilities in that functional area.
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! close coordination and communication of lessons learned and operating problems is accomplished through formal i periodic and informal meetings conducted throughout the management chain. In addition, the Licensing and Reliability organisation is structured to provide a coordinated review, evaluation, and communication of outside lessons learned to the appropriate personnel within each of the nuclear i facilities.
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O QUESTION V-1.
" List and identify all safety-related electrical and mechanical equipment, components and subcomponents that you intend to include in your environ-mental qualification program. For each such item of safety-related electrical and mechanica1 equipment, component or subcomponent, list and '
identify any and all documentation establishing its qualification, and identify whether it has been or will be qualified in accordance with the i '
- criteria and guidelines delineated in IEEE-323-1g71. IEEE-323-1974, NUREG 0588 category II or NUREG 0588 category I. Also identify whether I
qustification for each such item of equipment has been established by test, analysis, a combination of test and analysis or by other specified methods."
I Response:
The safety-related electrical equipment in the harsh environment that is i
included in the HCGS environmental qualification program is listed in j Table 3.11-5 of the Hope Creek FSAR. This table is also included in Section VII of the Hope Creek Generating Station Environmental Qualifica-tion Summary lleport. ,
l Table 1A (Document Package V-1) lists the completed documentation that establishes the environmental qualification of the electrical equipment described above. The list is for components having completed the qualiff-cation process. Equipment that is missing from the list is still in the qualification process and documentation is not complete.
The safety-related mechanical equipment in the harsh environment that is included in the HCGS environmental qualification program is listed in l
! Table 3.11-4 of the HCGS FSAR. This table is also included in Section VII of the Hope Creek Generating Station Environmental Qualification Summary l
Report.
PSESG has not included any list of documentation of mechanical equipment in this response since all of the equipment is currently in the qualifi-cation review process and final documentation is not complete. Mechanical l
! equipment qualification is accomplished by a combination of test and/or .
} analyses.
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Response (Cont'd)
- All of the electrical equipment in the harsh environment 'in the equipment qualification program is qualified to the criteria and guidelines of IEEE-323-1974 and NUREG 0588, category I. The qualification of the electrical components has been established by test and analysis.
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1 QUESTION V-2.
" List and describe all testing, analysis or review that has been done on safety-related equipment at the Hope Creek generating station in
. response to each of the following:
(a) The 1983 Sandia National Laboratories report of a number of anomalies in its testing program; Resoonse:
This item refers to industry tests conducted by Sandia National Labs as i outlined in "Inside NRC." of 10/31/83, and reflected in Infomation Notice 84-47, of 6/15/84. The deficiencies / anomalies reported have been l addressed for Hope Creek. Our position is that:
! (a) No teminal blocks have been purchased for inside cont-inment i
j (drywell) use at Hope Creek.
i (b) For outside containment applications, Buchanan teminal blocks
! " models NQB 104, NQ8108, and NQ8112 are being used. These i
teminal blocks are qualified for their application as supported j by FRC qualification report number F-C5143, dated 7/17/80.
QUESTION V-2.
)
(b) The August 31, 1983, and October 6,1983, Board Notifications 4 (83-128 and 83-128A) transmitting a sumary of a staff investigation -
into Franklin Research Center tests on ASCO solenoid valves; f
Resoonse:
The Board Notifications in question (83-128, 83-128A) concern an NRC letter dated 9/28/83, from R. Vollmer to D. G. Eisenhut. The issue is ,
i ability of ASCO solenoid valves model nos. NP8344 and NP8346 to sustain LOCA temperatures in excess of 340*F. PSE&G has reviewed the applica- ,
tions of these solenoid valves at Hope Creek and has concluded that these models are used in areas where maximum temperatures reach only 148'F. Our review is documented and attached as Document Package fV-2b & V-2c.
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l0 QUESTION V-2.
(c) The NRC Infomation Notices of September 24, 1981 and December 21, 1982(IN81-29 and 82-52) revealing that Viton Elastomer Seals in MP 8300 series Solenoid Valves broke down when exposed to gamma radia-tion exposures in excess of 20 megarads;
Response
PSE&G has responded to this problem by reviewing all ASCO solenoids at Hope Creek. To correct the problem identified in the Infomation Notices.
PSE&G is refurbishing any affected solenoids with Ethyhene Propolene Document Package V-2b & V-2c delineates our review and action plan.
QUESTION V-2.
(d) The NRC Infomation Notice of October 28,1983 (IN 83-72) revealing that during tests simulating LOCA conditions at Sandia National Laboratories. Barksdale pressure switches experienced " blown" seals that allowed water to acew:ulate in the switch housing, resulting in the equipment exhibitirg electrical shorts across the micro-switches;
Response
This notice reports that dring high temperature steam environmental testing Barksdale p'ressure switches. Models 82T and D2H. failed. We have detemined that there are no cases where these switches are installed in HCGS safety-related systems subject to the environmental conditions described in this notice.
QUESTION V-2.
(e) The NRC Infomation Notice of October 28.1983 (IN 83-72) revealing that during LOCA simulation tests at Sandia. Static-0-Ring pressure switches failed at 2 to 5 minutes into the LOCA transient; ,
Response
This notice reports that during high temperature steam environmental test-ing Static-0-Ring pressure switches. Model 5N and 12N. failed. We have detemined that there are no cases where these switches are installed in HCGS safety-related systems subject to the environmental conditions described in this notice.
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QUESTION V-2.
(f) NRC Infomation Notice 83-72. revealing that during environmental qualification testing, an ITT-Barton suppressed zero model 763 '
j transmitter demonstrated a negative shift in output during initial
- exposure to operating pressure; Response: '
4 We have detemined that none of these particular instruments are installed in safety-related systems at NCGS.
- 00ESTION V-2.
(g) The NRC Infomation Notice of October 28.1983 (IN 83-72) revealing that under performance tests by ITT on ITT-Barton electronic trans-mitters Models M-763 and M-764. ITT detected a leakage current path through the shafts of the zero and span potentiometers to the mount-ing bracket, resulting in non-repeatability at 320*F;
Response
' We have detemined that these pressure transmitters are not used in
- safety-related systems at HCGS.
QUESTION V-2.
l (h) The NRC Information Notice of October 28,1983 (IN 83-72) revealing l
that Bechtel had found numerous defects in Limitorque valve operators
' at Midland; i
l Response:
This notice discusses problems with environmental qualification of Limi-j torque stor actuators found by Bechtel at the Midland plants. We have ,
determined that no problems exist other than verification of teminal t blocks used in the operators. This verification is being pursued. see Package V-2h.
l GUESTION V-2.
i (1) The NRC Information Notice of October 28,1983 (IN 83-72) revealing that Anaconda flexible conduits, which provide protection for cables, failed environmental qualification testing by Wyle Laboratories.
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Response
This notice reports that the polyethlene copolymer jacket of Anaconda flexible conduit failed when exposed to LOCA conditions. HCGS does not use the type _of conduit described in this notice.
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i* QUESTI0lt V-3.
If testing, analysis or review was not performed on safety-related equip-ment at the Hope Creek generating station in response to the items listed in 2(a)-(i), state the reasons with respect to each item why testing, analysis or review was not perfomed.
Response
PSEM actively reviews and responds to NRC or industry data which becomes l available and has a potential for affecting the safe operation of the >
i Hope Creek Generating Station. With respect to the cases specifically
! identified in 2(a-1), our position has been provided as part of the response to that item.
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O QUESTION V-4.
List and describe any and all testing review or analysis that has been performed on safety-related equipment at the Hope Creek generating station i
to establish that such equipment is qualified to withstand such fire con-ditions as high humidity, burning. corrosive gases and smoke. Identify 4 all safety-related equipment not so tested.
'f 4 Response:
Safety-Related equipment in the harsh environment is qualified for humidity and/or steam environment. Safety-Related cables are qualified for steam environment and also flame tested per requirements of IEEE 383-1974.
Use of combustible material in the plant is minimized so that the cor-rosive gases and smoke produced by the material will not adversely impact the qualification of the safety-related equipment. Alto the redundant safety-related equipment is physica11'y separated,.
Following is the list of Safety-Related Equipment with its qualificationu >>catus on this topics e
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l 1 I I i l l HIGH l CDRRDSIVEl l SAFETE REZATED EUIPfENf llEJMIDITY BtRNItGl GASES l SMOKE l REMARKS i l I
(
l l l 1 1 4.16 kV Switchgear l -
l -
l - -
l Mild hvironment l.SAs Mocors l ms l -
l - -
l 1 SVc Mater Pump Motor - - -
l - Mild Dwironment
. 480V Switchgear - - , - Mild Ehvironment l 480V M.c.c. '
Yes l - ,
- Mild myironment l 125Vdc Panels l -
l l l l 125Vdc Switchgear ,
l -
l -
l -
l Mild Environment
.; 250 Vdc M.c.c. l Tes l -
l l -
l
- ' Elec. Aux. ceb. - - -
l - Mild Ehvironment Penetrations Des - -
l Battery & Battery Chargers l - -
l -
l - Mild Ehvironment Distribution Panels l -
l -
l - - Mild Dwironment l , UPS Sptas l -
l -
l - - Mild Ehvironment l l Power, Chtri, Instr. Cables l Yes l Yes l -
l l Flame Testad Per j
l l IEEE-383-1974.
e l l
} l control Room Devices l - - -
l - , Mild Ehvironment l l SACS Rosete Cbntrol Panel l Yes -
l l -
l l Remote Shutdown Panels l - - - -
l Mild Ehvironment Transmitters l 1es - ,
!~ Radiation Monitoring System l Yes -
l -
l -
1 l ,
l '
- control Switches l Des - - -
l l-i t
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- . . . . . ~ . - _ - . . . l O l l
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, l nIaB l l CORROSIVE. l REMARKS l
l SAFETY RELATED IQUIPfENT lHJMIDITYlBtEtNINGl GASES l SMOKE l l l '
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, l l '
RTD & Thermoccuples Das - -
Solenoid Valves Ems -
l Butterfly Valves ins PrCasure Regulator - - - - Seismic only Excesa Flow Check Val w - - - - Seismic only l Nuclear Nrv. Inst. Valve l - - -
l Seismic only Baergency toad Sequencer - - - -
l Mild Erwironment ERFDA System .
l Mild Bwironment Dicael Generator l - -
l - -
l Mild Dwironment
, TRVLG Matar S:reen - - - - Mild Dwironment Hy& ogen Recombiner . Das -
l l Inst. Gas omepressor l Des ,
.- - - l
,' Polar Orane - - - - Seismic only SACS Heat acchanger -
- - Seianic only ,
i Safety Aux. (bol Pump l Ens l -
l -
l -
l l Fuel Pool Heat Btch. l - -
l -
l - I Seismic only
> Self-cicaning Stra. l - -
l -
l - Seismic only Mild Dwironment l SVC Noter Pumps - -
l l Horiz. Centrifugni Pump . Yes - -
i l Nuclear SVC Ref. Valves l Des .
l ,
Y Strainer l -
l -
l -
l Seismic only l
R.B. Mc. Breaker l - - - - Seismic only Pump Roca Blowout Panel Seimnic only
, Accinaulator Mnks i - - - - Mild Swironment
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l Air Handling Units - - - - Mild Bwironment ,
l Centrifugal Fans Yes - - - l Seismic only Dessars he Axial Fans - - - - Mild Dwironment Meter Chillers . - - - - Mild Dwironment l HVAC Instrumentations Yes - -
Seismic only Air Filtration System -
l - -
l l -
Nuc. Grade Valves Yes l - -
l Globe Valves Yes - -
i Butterfly Valves yes - -
l -
- m non-antal parts Snubbers -
Enrainal ELock Yes - -
Flexible (bnduit ses - - ,
Raychem Splice Kits Ens - -
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O QUESTION V-5.
State whether any safety-related equipment at the Hope Creek Generating Station contains or relies on Viton parts. If so, identify each and every such item of safety-related equipment.
Response
i ,
Viton is used for many applicances in safety-related ;
. l-j / equipment. A complete list showing each specific
,g application is not available at this time, since
! final qualification documents are not complete.
i However, a partial listing of documents which are known to purchase components containing Viton parts and a partial listing of specific applications is
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provided on the attached table.
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l TABLE V-5A General Listing of Safety-Related Equipment Containing Viton (BOP-Partial)
- 1. J-605(O) Va:,ves
- 2. P-301(O)
- 3. P-302(O)
- 4. P-303A(0)
- 5. P-305(O)
- 6. P-366(O)
- 7. M-047A(0) Hydrogen Roccabiner (Blower Motor)
- 9. C-152(O) Primary Containment (Personnel Access Airlock)
- 10. M-711(O) ITT Series NH-90 Damper Actuator
- 11. M-713(O) [New Replaement Recommendation Viton Parts to replace EPR Parts]
- 12. M-717(O)
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TABLE V-5B Listing of Safety-Related Equipment That May Contain Viton (NSSS-Partial)
MPL-NUMBER COMPONENT Gould Levl Xmtr. PPD 163C1973 P002 (E41-N062)
Barksdale Pressure PPD 163C1090 P001 (C71-N005)
Switch (C11-Nol3)
Magnetrol/ Levi PPD 159C4361 P005 Switch- P003 (E41-N014)
P006 (E51-N010)
PPD 163C1560 (Ell-N013,NO26,NO28
- Rosemount Pressure N053,N057,NO60, Xmtrs. PPD 163C1563 PPD 163C1564 E21-N003,E41-NOl3, N052,E51-N007,N052)
PPD 163C1303 P001 (C71-NOD 6)
NAMCO Limit Switch (Ell-N008 )
- Barton Level Switch PPD 145C3156 P002 Valve Assembly PPD 136B1302 G002 (C51-J004)
- (E51-C002)
RCIC Turbine SPEC 21A9526 I HCU Pilot Solenoid PPD 922D138 P001 (Cll-D001)
- *MSIV (B21-F022/F028)
- Testable Check Viv 283X301ADG001, ACGF001 (Ell-PO41, F050,E21-F006)
- Definitely utilize 'Viton The above is the NSSS safety-related electrical equipment in the Hope Creek EQ Program that may utilize Viton (asterisked items definitely use Viton; EO-scope items not listed definitely do not use Viton.
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QUESTION V-6 List and identify all information relating to Environmental Qualification or the Equipment Qualification Program for Hope Creek that has yet to be submitted to the NRC staff but which you presently intend to submit in the future, as referred to by the NRC staff at page 3-30 of the Hope Creek SER. For each such item, identify the earliest date s
by which you estimate the information wi!! be so submitted.
(f .
- Response:
The information which PSE&G intends to submit, or has already submitted, to the USNRC st'aff as referred to in the staff SER is as follows:
- 1. Request for additional ir. formation in letter dated August 10,1983. This information has e
been submitted as the response to Question 270.2
- in FSAR Amendment 2.
- 2. Additional information to supplement the response a
[/ , to Question 270.2. The Hope Creek Environmental Qualification Summary Report was originally scheduled to be submitted in the first quarter of 1985. A first draf t of this report was issued to the NRC Staff in August 1984. A revised report
,/. is currently scheduled for submittal during Q April 1985.
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- 3. Request for additional information in letter
' 's dated November 21,1984. This information is being submitted to the NRC Staff. The majority of NRC questions are answered. Those questions
>o not answered at this time will be answered t( prior to February 1,1985.
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QUESTION V-7 .
List and identify all documentation upon which you relied in determining which particular pieces of electrical and mechanical equipment and which electrical and mechanical systems would be included in the Hope Creek Generating Station's environment qualification program.
RESPONSE
The significant documents used to determine the equipment which would be included in the Hope Creek environmental qualification program have been identified in Section VII of the Hope Creek Environmental Qualification Summary Report. Specifically, for the mechanical program, the scope was defined at a J meeting with the NRC on Environmental Qualification of November 28,1983.
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O i OUESTION V-8.
List and identify all category I and 11 equipment items in Regulatory Guide 1.97, Revision 2 at the Hope Creek Generating Station, and all equipment to be installed at the Hope Creek Generating Station in response to those Regulatory Guide items. Also, identify the environmental qualification status of all such equipment items, and list each of the Regulatory Guide 1.97 equipment that you do !)o_t, intend to install.
Responsa ,
Category I and 11 equipment items in Regulatory Guide 1.97 which are installed or will be installed in the Hope Creek Generating Station are listed in Table 7.5-1 of the Hope Creek FSAR. Every category I and !! item of Regulatory Guide 1.97 that is installed in the Hope Creek Generating Station is in the environmental qualification program.
Exceptions and interpretations of the Regulatory Guide as it pertains to Hope Creek are identified and justified in Section 1.8.1.97 of the FSAR.
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OUESTION V-9.
State whether you will seek to environmentally qualify any equipment after the fuel load. If so, identify each equipment item to be thus quellfled and provide copies of all justifications for interim qualification (310) that has or will be submitted to the NRC. If justifications have not yet been w . bmitted, state the estimated date of such submissions.
Response
PSE&G's Environmental Qualification Program is on a schedule which will support the fuelload date. At this time, we anticipate that all equipment identified in the program scope will be fully qualified prior to scheduled fuel load.
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O QUESTION V-10 State whether you have any information that any of the safety-related electrical or mechanical equipment to be used in the Hope Creek Generating Station has ever been identified by the NRC as having experienced a failure under normal or harsh !
operating conditions at any plant. If so, identify each such item or items of i equipment and describe in detail the nature of the failure. l l
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RESPONSE
PSE&G makes use of the established federal system of NRC I&E Bulletins, Inf ormation Notices, etc., which identify generic problems with specific components. Each of these documents is evaluated for applicability to the Hope Creek Generating Station requirements ud action is taken as necessary to assure that the problem does not compromise reactor safety, eg., control rod drive scram solenoid.
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O QUESTION V-11 With respect to any equipment identified in response to Interrogatory No.10, state the steps that have been taken or will be taken to prevent such a f ailure at Hope Creek and the dates or estimated dates of such steps. If applicable, stata the reasons why no such steps have been taken regarding any of the equipment identified in response to Interrogatory No.10.
RESPONSE
The example cited in V-10 resulted from the sticking of a urethane disc due to an air temperature of 140 degrees F. PSE&G has addressed this concern by refurbishing the valves' disc.
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O QUESTION V-12 Identify the dates of each and every audit by PSE&G, or any other auditor of the Hope Creek environmental qualification program. For each, also identify the .
personnel that took part in the audit, the portion or portions of the program !
audited, and any and all deficiencies observed or noted.
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RESPONSE
A. NSSS Items A PSE&G audit limited to the Environmental Qualification Program has not been conducted. General Electric standard design practices and procedures for conducting the GE EQ Program. PSE&G participated in a Bechtel Power Corporation audit on November 15,1983 and November 13,1984.
The NRC conducted audits of the GE EQ effort on February 7, April 18, and September 19,1983 and on January 17, March 30 and August 27,1984. Reports for these audits are available on Docket 99900911.
B. BOP Items Information regarding audits of Hope Creek Qualification Program by PSE&G are listed below. For further detailed iniormation and deficiencies, if any, refer to respective i audit reports.
No. and Date of Audit Participants Title j
l In the week W. R. Cole Audit Team Leader, Bechtel of Nov. 13, 1984 E. Bowlby Auditor, Bechtel l
G. E. Penfield Auditor, Bechtel W. F. Valeika Auditor, PSEEG In the week W. R. Cole Audit Team Leader-of Nov. 14, 1983 W. Gobel Auditor, Bechtel R. A. Koschak Auditor, Bechtel S. Chawaga Auditor, PSE&G t
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V-12 (Continued)
No. and~
p Date of- Participants Title E.Q. Item Audited Audit H-84-8 A. Sternberg Audit Team Leader Verifiestion of R. T. Griffith, Sr. Lead Auditor completion of the in the week of Oct. 29, R. E. Jackson Lead Auditor open items related 1984 R. D. Savage Lead Auditor to E. Q. from Audit J. Jelinek Tech. Consultant No. H-84-1 H-84-1 A. Sternberg Audit Team Leader o Dits 7.5 -
in the week R. Jackson Lead Auditor Temperature Calc.
of March 26, D. Whitmer Lead Auditor o AKR.-30 Ckt. Bk 1 t
1984 T. K. Ram Lead Auditor o Control of E.Q. .
Pro.
i H-82-3 A. Sternberg Audit Team Leader H-82-3 in the week W. R. Hunsinger Lead Auditor of Aug. 9, W. J. Reuther Lead Auditor 1982 W. B. Keeffe Lead Auditor H-82-1 M. Rosenzweig Audit Team Leader o Envi. Qual. of E. P. Gilewicz Auditor Safety Related in the week Elec. Equipment L of April 19, R. C. Robinson Lead Auditor W. R. Schultz Lead Auditor o Follow up on 1982 I
R. C. Kirk Tech. Consultant Audit No. H-81-2
- H-81-2 W. F. Valeika Audit Team Leader Environmental I in the week P. A. Benini Lead Auditor Qualification of Sept. 28, S. C. Misuraca Lead Auditor Program
- 1981 M. Rosensweig Lead Auditor l^
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O OUESTION V-13.
Describe the " audit of the environmental design and accident analysis" referred to on page V-1 of the Hope Creek " Environmental Qualificaticn Summary Report" (HCEQ R6; port) . Identify who completed this audit and the date or dates it was undertaken. Also identify each and every person that has " independently verified" that the correct conditions and calculations were utilized, as stated on page V-1 of the HCEQ Report.
$ Response The pertinent infor.ation is listed below. For further details refer to respective aud,it reports.
Auditor Audit No. (Indepe ndent Item and Date verifier) Audited .
T. K . Ram o Environmental Design H-84-1 i in the week of criteria o Environmental Design i i
March 26, 1984 '
Calculation i
J. J. Jelinek o Followup-
" H-84-8 :
it in the week of
- October 29, 1984 (Item 1 of H-84-1) .
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V. ENVIRONMENTAL QUALIFICATION: INTERROGATORIES OUEST10N V-14.
Identify each and every site visit to vendors or subcontractors "to review the in-house EQ QA/QC program and evaluate the objective evidence of the vendor's ability to meet his QA/QC commitments" referred to at p. V-1 of the HCEQ report. For each such site visit, also identify the date of the visit, the vendor or subcontractor visited, the ;
personnel thtt participated in the visit, and any reports, evaluations, memoranda, or other docume sts prepared after the site visit.
Responses A. NSSS Items There have been no EQ or Hope Creek specific audits of GE vendors and subcontractors.
A generic QA audit program is in place to audit vendor QA/QC programs on a regular basis at vendor shops.
Audits of Hope Creek EQ equipment vendors conducted during 1982,1983, and 1984 are as follows:
Vendor Date Auditor Pyco June 83 R.B. Ehle Magnetrol March 83 A.3. Rzeszotarski Rosemount Oct. 84 3.M. Bricken GE Motor (53) Aug.82 G.A. Berry Terry Turbine Sept.83 C. Lewis Target Rock May 82 M.A. Ball Barksdale April 84 A.3. Rzeszotarski NAMCO May 83 R.L. Bragg Valcor Feb.83 3.M. Bricken Yarway July 84 C.B. Skov Gould July 82 C.B. Skov Fisher Controls Nov.t3 C. Hunter
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General Electric considers audit reports to be proprietary. The reports will be provided for inspection upon completion of a mutually acceptable proprietary agreement between GE and the Public Advocate.
B. BOP ltems Vendor audits performed by Bechtel Project Quality Assurance are listed below:
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Vcndar Date of Audit Personnel that Participated Reports - Date Issued Croaro, Inc. 6/23-25/81 Creare Bechtel Project Audit Report No. 3 o
Hnnovar, and J. Black L. Anderson 30.12 Phase I and Phase N3w Hrapshire 9/16-17/81 S. Sellow G. Judd II. 7/1/81 & 10/7/81 5
- P. Dolan J. Goldsmith g-P. Rothe g o.
3/17-18/82 Nutech Bechtel Project Audit Report No.
,Nutsch Engineering 30.12-2 April 1, 1982
- Inc. San Jose, CA D. Gerber G. Penefield ,
I W. Booth J. Bonner R. Sanchez l
! Bechtel Project Audit Report No.
,Nutsch Engineering 5/19/83 ,
Nutech
- Inc. SEn Jose, CA
- P. Reeves L. Whitson 30.12-3 5/20/83 I R. Smith Y. Yiu
! R. Lehnert l
lGE San Jose, CA 5/31/83 GE Bechtel Project Audit Report No.
i N. Belich E. Bowby 30.12-4 6/8/83
! P. Kachel R. Valencia P. Novak i
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Question V-15.
Identify each and every site visit to " testing laboratories used to perform EQ analysis and/or testing" referred to at p. V-1 of the HCEQ report. For each such site visit, also identify the date of the visit, the laboratory visited, the personnel that participated in the visit, arid any reports, evaluations, memoranda, or other documents prepared after the visit.
Responses l
A. NSSS Items Both GE and the NRC routinely audit the testing labs used for the GE EQ program. The GE audit dates during 1982,1983, and 1984 are as follows:
Lab GE Audit Date Auditor Viking Lab Aug.1984 C.B. Skov Wyle (CA) Nov.1982 K.S. Manrao Wyle (Huntsville) Aug.1982 W.E. Widener ,
l NTS Aug.1982 K. Manrao SWRI May 1984 3.M. Bricken t
NRC audit reports can be obtained through the Public Doc. ament Room. For example:
Lab Date NRC Docket #
Southwest Research Inst. Sept.82 99900909 Wyle Labs (Huntsville) Aug.82 99900902 National Technical Sycs. Jan.83 99900907 General Electric considers audit reports to be proprietary. The reports will be provided for inspection upon completion of a mutually acceptable proprietary agreement between GE and the Public Advocate.
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O Y. ENVIRONMENTAL QUALIFICATION: INTERROGATORIES QUESTION V-15. (Cont'd)
- 8. 80P Items v
Following is a list of visits made to witness EQ test and analysis performed for the Hope Creek Project.
I l l l PEIUDi@lEL IABORA20W l DATE l VISITED l VISITED l REMARKS l REPORT VISITED I I l l
Ravi Goel Farwell & Herdricks 5/5/84 1 Witnessed 480V M.C.C. Bechtal V/P No.
Thakur Harang .
Stanidity Test & Analysis l10855-118(Q)-207-2 I i l
i l Ravi Goel Famil & Herdricks l6/13/84 l Witnessed 480V M.C.C. lBechtel V/P Ho.
Inna Ostrcusky l l Humidity Test & Analysis l10855-E118(Q)-207-2 I
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Ravi Goel l Actor Bwironmental 7/19/84 & Witnessed LOCA Test &
1"esting Corporation l7/20/84 Analysis of control 10855-M-780A(Q)-199-l Panel Devices 1085 %7-201(Q)-66-1 I I I .
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l OUEST10N V-16.
Identify all personnel that participated in the " verification of proper procedures ~and practices for the shipment, storage, and mounting of safety-related equipment" referred to at p. V-2 of the HCEQ report. For each such personnel, identify the dates of their participation and what each person did as part of the verification process described above.
Response
The information is incorporated in the following standard reports:
- Quality Surveillance Reports for Shipment of Safey-Related Equipment.
- Quality ControlInspection Reports for Storage and Mounting of Safety-Related Equipment.
Quality Surveillance Reports and Quality Control Inspection Reports are available for review at the HCGS jobsite.
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- QUESTION V-17 Identify the date or dates of the audit of the EQ file referred to at page V-2 of the HCEQ report. Also identify the personnel that participated in the audit, l any deficiencies noted, and any reports, memoranda or other documents relating to the audit.
RESPONSE
Quality Assurance - Engineering and Construction will
- conduct.an audit of the EQ files referred to on page V-2 of the HCEQ report prior to April 1985. QA-E&C will perform this audit assisted by Mr. T. K. Ram of the Hope Creek Site Engineering Department.
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i QUESTION V-18_
Identify the date or dates of the audits "to ensure proper review and signoff of vendor qualification plans, test procedures, and analysis documentation" referred to at page V-2 of the HCEO report. Also identify the
- personnel that participated in each such audit or audits and any reports, documents or memorandam relating to the audits.
RESPONSE
Quality Assurance - Engineering and Construction will conduct an audit "to ensure proper review and signoff of vendor qualification plans, test procedures, and documen-tation" referred to on page V-2 of the HCEO report.
QA-EEC will perform this audit prior to to April 1985, assisted by Mr. T. K. Ram of the Hope Creek Site Engi-neerinag Department.
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t OUESTION V-19 Identify the date or dates of the audits "of plant surveillance and maintenance program procedures" referred to at page V-2 of the HCEQ report. Also, identify the personnel that participated in each such audit and any reports, docments or memoranda relating to the audits.
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RESPONSE
Quality Assurance Audits of " Plant Surveillance and Main-tenance Program Procedures" are an integral part of the Operational QA Program which will be implemented on the Hope Creek Generating Station. Implementation of the Operational QA Program for Hope Creek is targeted for mid 1985, consistant with the schedule for loading fuel.
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O QUESTION v-20 State whether a " documented process for QA identified deficiency resolution" as referred to at page V-2 of the HCEO report has been established. If so, describe.all QA identified deficiencies which are part of this process and identify those that have not been resolved. If not, provide the estimated date when it will be established.
RESPONSE
The Operational QA Program includes documented processes for identification and resolution of QA identified deficiencies. These processes are described in the Nuclear Quality Assurance Department Manual. Implementa -
tion of the operational QA Program is targeted for mid j 1985 at which time these documented processes will be implemented.
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QUESTION V-21 Identify the date or dates on which the " program to procure qualified spare parts and/or replacement equip-ment from approved vendors" as referred to on page V-2 of the HCEO report was verified. Also, idenfity all person-nel who participated in this verification process. If not yet verified, provide the estimated date when this program will be verified.
-RESPONSE:
Applicable procureAent program procedures were reviewed and verified by Nuclear Quality Assurance to assure adequate processes were established to procure qualified spare parts and/or replacement equipment from approved vendors for the Hope Creek Generating Station. These processes were reviewed and implemented during September 1984, by the following Nuclear Quality Assurance persoanel:
C. P. Johnson - General Manager - Nuclear QA M. Rosenzweig - QA Engineering and Procurement Engineer W. R. Schultz - Programs and Audits Engineer i
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O OUESTION V-22.
Identify each person whom you expect to call as an expert witness with respect to contention 3 relating to environmental qualification. For each such person, state the '
subject matter on which he or she is expected to testify, the substance of the facts and opinions to which he or she is expected to testify, and a summary of the grounds for each such opinion. Also describe the educational and professional qualifications of each such person, the publications, if any, of each such person, and Identify any previous proceeding in which that person has testified.
Response
PSE&G Company J.J. Wroblewski W. Galley R. D'Orazio Bechtel Power Corp.
G.N. Kapandritis D. Sullivan ,
G.E. Company N. Luria Proto-Power M. Annon D. Hallahan i
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