ML20114B736

Applicant Response to Intervenor Third Set of Interrogatories & Request for Production of Documents Re Pipe Cracks.Related Correspondence

ML20114B736
Person / Time
Site:	Hope Creek
Issue date:	01/21/1985
From:	Rippe R Public Service Enterprise Group
To:
Shared Package
ML20114B730	List: ML20114B729 ML20114B736
References
OL, NUDOCS 8501290460
Download: ML20114B736 (138)

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UNITED STATES OF AMERICA *3' NUCLEAR REGULATORY COMMISSION . ,

Before the Atomic Safety and Licensing Board *2P In the Matter of  :

Public Service Electric  : Docket No. 50-354 OL and Gas Company  :

(Hope Creek Generating Station  :

APPLICANT'S RESPONSE TO INTERVENOR'S THIRD SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO APPLICANTS 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.

If the intervenor desires to review documents listed herein as proprietary and protected pursuant to 10 CFR 2.790 of the Commission's Regulations, it will be necessary to enter into an appropriate protective agreement with the designated company.

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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 hereint that he has read the foregoing Applicant's Response to Intervenor's Third 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.

(Mt. L'--jY Richard D. Rippe Assistant General Manager - Engineering Subscribed and sworn to before me this S/ day I of January, 1985.

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O i NOTARY PUCUC Of ."t/! J;r.yv My Commi:Sloa Egirn .',;.;; la j , ,;

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PUBIJC ADVOCATE THIRD SET OF INTERROGATORIES PARTI PIPE CRACE5

1. List and identify each instance in which intergranular stress corrosion oracking (IGSCC) has been identified in roeirculation piping bested at the Hope Creek Generating Station site. For each such instance, state (a) the date of detoetion; (b) the type and dimension of piping involved; (c) the system of which it is a part; (d) the size of the crack, including its depth and length; (e) the technique and method of detection; (f) your determination of the cause of the crack; (g) all treatment the cracked piping received following discovery of the crack; and (h) the ultimate disposition of the piping involved, including whether that specific piece of piping is currently in use at the Hope Creek Generating Station.

ANSWER:

The summary report addressing the shop discovery of intergranular attack in two (2) Hope Creek Generating Station No.1 Unit and one (1) Hope Creek Generating Station No. 2 Unit recirculation piping system elbow closure pieces during fabrication processes was provided to the Public Advocate in response to the Intervenor's First Set of Interrogatories and Request for Production of Documents. This report is contained in General Electric's letter GB-83-210, dated October 12,1983, to Bechtel Power.

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O PUBLIC ADVOCATE THIRD SET OF INTERROGATORIES PARTI PIPE CRACKS

2. For each instance of IGSCC identified in response to Interrogatory I.1, state whether the NRC was informed in any way of the occurrence. If so, identify all writings related to the NRC's notification. If not, explain why the NRC was not notif!ed.

ANSWER:

No. This matter was not reportable.

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O PUBLIC ADVOCATE THIRD SET OF INTERROGATORIES PART I PIPE CRACKS

3. State the length of time each piece of recirculation piping was stored on Artificial Island prior to its installation in the Hope Creek generating station.

ANSWER:

Approximately six years.

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l PUBLIC ADVOCATE THIRD SET OF INTERROGATORIES PART I PIPE CRACKS

4. State whether exposure to weather conditions experienced at Artificial Island could cause cracking in the recirculation piping to be used at Hope Creek.

ANSWER:

No evaluation of this hypothetical condition has been undertaken.

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PUBLIC ADVOCATE THIRD SET OF INTERROGATORIES PART I PIPE CRACKS

5. State whether all recirculation piping is inspected for cracking prior to installation at Hope Creek. If so, identify (a) the specific personnel responsible for that inspection; (b) the techniques and methods used; ,

(c) the dates of the inspection for each piece of recirculation piping; (d) the length of time elapsed between the final inspection and installation; and (e) all reports or other writings produced as a result of such inspections. If not, explain why such inspection are not conducted.

. ANSWER:

Yes.

(a). Personnel are under the employ of General

• Electric and Bechtel Power.

(b)~ Visual and liquid penetrant methods 2

(20, 22 and 28 inch diameter) ,-

UT (12 inch diameter).

(c) During late 1982 through mid 1983.

(d) Spool pieces were installed in. position upon receipt from the piping contractor.

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! (e) General Electric's Ultrasonic Examination of Hope Creek Recirculation System Welds submitted with response to request for production of documents. PT Reports are available-for review at General Electric offices, San Jors, California upon request and arrangements male by. counsel.

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PUBLIC ADVOCATE THIRD SET OF INTERROGATORIES PART I PIPE CRACKS

6. State whether any pieces of recirculation piping were returned to vendors or otherwise rejected for having failed to meet PSE&G standards. If so, identify each such piece of piping, the system of which it was to be a part, and the reasons for its rejection.

ANSWER:

One (1) 28" Recirculation Piping Closure Elbow, Pc.MarkRS-2-Al from No.2 Unit at Hope Creek, planned as a replacement section for No.1 Unit, was rejected because of intergranular cracking.

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PUBLIC ADVOCATE THIRD SET OF INTERROGATORIES PARTI PIPE CRACES

7. State whether the Hope Creek Generating Station as currently designed is compatible with the application of hydrogen water chemistry. If not, list and identify all modifications or other measures that would be required at Hope Creek prior to the initiation of hydrogen water chemistry.

ANSWER:

No. Since detailed engineering studies have not been performed, all necessary plant modifications have not been determined. However, at least

. the following modifications would be necessary:

1. Feedwater piping system

2. Bulk hydrogen storage

3. Additional fire protection

4. Instruments and controls l

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PUBLIC ADVOCATE THIRD SET OF INTERROGATORIES PART I PIPE CRACKS

8. State whether hydrogen water chemistry was ever considered for use at Hope Creek. If so, state (a) the decision (s) reached after such consideration; (b) the grounds for each decision; (c) the individuals who made ,each decision; and (d) the date each decision was made.

ANSWER:

No; it has not been considered.

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1 THIRD SET OF INTERROGATORIES PIPE CRACK INTERROGATORIES SECTION I, ITEM 9 DESCRIPTION:

Identify how water chemistry controls at Hope Creek will minimize IGSCC. Specify (1) how the levels of ionic species entering the primary coolant will be reduced: (2) whether and how oxygen levels will be controlled; and (3) whether and how you will tighten the controls and limits on intrusion of impurities from the domineralizers.

RES7QNSEs The MCGS Chemistry Control Program is a systematic approach designed to minimize the_ introduction of impurities into the reactor. The Chemistry Control Program is based on an integrated effort of careful operation of installed plant water treatment systems. While water quality limits for operation are specified

• in the plant Technical Specifications, normal ope .

qualitygoalsarebasedontheguidelinesofEPRI{atingwater .

Nope Creek Water Chemistry Control Program establishs the chemistry sampling frequency and specifications.

1. As previously stated, impurity levels (ionic species) will be*

controlled through careful operation of installed water treatment systems and strict chemical impurity controls.

2. Oxygen will be controlled in the reactor feedwater within the range as recommended by EPRIl. The control will be accomplished through the monitoring of condenser air inleakage and the measurement of dissolved oxygen values in the reactor feedwater.

3.- The condensate polishing domineraliter effluent impurity

. guidelines. are addressed in the Chemistry Control Program.

Guidelines for the mixed effluent are a factor of 2-5 lower than typical SWR limits. By maintenance of these guidelines, impurity input from the domineraliser will be minimal.

REFERENCES :

1. 'EPRI, SWR Water Chemistry Guidelines Final Recort, Proceedings of the Internationa., Water Conference, Oct. 1984, Pittsburgh, PA (To be published)

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PUBIJC ADVOCATE THIRD SET OF D(TERROGATORIES PARTI PIPE CRACRS

10. State whether you have considered replacement of all 304SS recirculation piping with IGSCC-resistant piping. If so, state (a) what decision (s) was made; (b) the ground for each decision; (c) the individuals who made each decision; and (d) the date of each decision.

ANSWER:

The response to this interrogatory is addressed in PSE&G's letter dated January 25, 1979, from the Chief Mechanical Engineer to the General Manager - Engineering, which was provided to the Public Aavocate in response to the First Set of Interrogatories and Request for Production of Documents.

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PUBIJC ADVOCATE THIRD SET OF INTERROGATORIES PARTI PIPE CRACES

11. State whether you have considered the likelihood of the incidence of IGSCC in recirculation piping at Hope Creek after the application of "IGSCC remedies applied in accordance with NUREG 0313 and 0313 rev.1," as referred to in your responses to Interrogatories I.2 and I.3. If so, state your estimate of the incidence rate of IGSCC in recirculation piping over the life of the Hope Creek Generating Station.

i ANSWER:

Not specifically; NUREG 0313 and 0313 rev. I remedies have proved to resist IGSCC initiation.

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PUBLIC ADVOCATE THIRD SET OF INTERROGATORIES PARTI PIPE CRACES

12. State whether you have information regarding the incidence of IGSCC in other BWRs that have had IGSCC remedies applied to recirculation piping in accordance with NUREG 0313 and 0313 rev.1. If so, state the average incidence rate of IGSCC in recircolation piping at such plants.

ANSWER:

There has been no incidence of IGSCC after applying remedies in accordance with the NUREG 0313 and 0313 rev.1.

O PUBLIC ADVOCATE THIRD SET OF INTERROGATORIES PART I PIPE CRACKS l

13. Identify each instance in which IGSCC has been identified in BNRs that have had IGSCC remedies applied in accordance l with NUREG 0313 and 0313 rev. 1.

ANSWER:

None; see interrogatory 12.

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PUBLIC ADVOCATE TEIRD SET OF INTERROGATORIES PART I PIPE CRACKS

14. State the estimated frequency over the life of Hope Creek of IGSCC in field weld butt weld ends for which corrosion-resistant cladding (CRC) was utilized.

ANSWER:

No estimate undertaken. See Interrogatories 11, 12 and 13.

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INTFRVFNOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES f 15. List and identify each brand, size, type and frequency of UT transducer provided by Southwest Research F .

Institute as referred to in your response to f^ 7, interrogatory I.7.

RESPONSE

The ult.rasonic t.ransducers presently being used by SURI are identified as follows:

BRAND SIZE TYPE FREOUEr!CY SURI .250 IN. Round Single Element. 1.50 MHz SURI .250 IN. Round Single Element. 2.25 f1Hz Aerot.ech .250 IN. Round Single Element 2.25 f1Hz SilRI .250 IN. Round Single Element. 5.00 f1Hz SWRI .375 IN. Round Single Element 1.50 f1Hz SWRI .375 IN. Round Single Element. 2.25 MHz SWRI .375 IN. Round Single Element. 5.00 MHz SURI .500 IN. Round Single Element 1.50 f1Hz SURI .500 IN. Round Single Element. 2.25 MHz

[, Aerot.ech .500 IN. Round Single Element. 2.25 MHz P,

Sonic- .500 IN. Round Single Element. 5.00 r1Hz SWRI .500 IN. Round Single Element. 5.00 P1Hz SURI .750 IN. Round Single Element 1.50 MHz SWRI .750 IN. Round Single Element 2.25 MHz Aut.omat. ion 750 IN. Round Single Element. 2.25 MHz Aerot.ech 750 IN. Round Single Element. 2.25 f1Hz flat.erials Assurance . 750 IN. Round Single Element 2.25 f1Hz

. SWRI .750 IN. Round Single Element. 5.00 f1Hz I^E SURI 1.000 IN. Round Single Element. . 2.25 P1Hz Aerotech 1.000 IN. Round Single Element 2.25 MHz I~

SURI 1.000 IN. Round Single Element 5.00 MHz

[ Dual Element 2.25 MHz l

Aerotech .250 IN. x .250 IN.

- SWRI .250 IN. X .250 IN. Dual Element 2.25 MHz SURI .375 IN. X .375 IN. Dual Element 1.50 f1Hz SWRI .375 IN. X .375 IN. Dual Element 2.25 MHz SURI .500 IN. X .500 IN. Dual Element 2.25 MHz I Branson .500 IN. X .500 IN. Dual Element. 2.25 MHz Aerot.ech .500 IN. X .500 IN. Dual Element. 2.25 P1Hz l

Aerotech .500 IN. X 1.00 IN. Dual Element 2.25 MHz Automat. ion .500 IN. X 1.00 IN. Dual Element 2.25 MHz SURI .500 IN. X 1.00 IN. Dual Element 2.25 MHz Dual Element 2.25 MHz l SWRI. 1.00 IN_. X 1.00 IN. 2.25 MHz Automat. ion - 1.00 IN. X 1.00 IN. Dual Element.

l Aerotech 1.00 IN. X 1.00 IN. Dual Element. 2.25 F1Hz I

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b INTERVENOR'S THIRD SET OF INTERROGATORIES ,

HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES

16. List and identify all " commercially available standard ultrasonic instruments" that will be utilized at Hope Creek, as referred to in your response to interrogatory I.S.

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RESPONSE

The commercially available ultrasonic instrunents presently scheduled to be used at Hope Creek Generating Station are identified as follows:

Sonic Instruments - Sonic t1KI Krautkramer - USIP 11 A

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O INTERVENOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES l

17. Identify and describe each of the " classroom as well as practical training and competency tests" that are included in the SwRI training program referred to in your response to interrogatory I.5. Specify how the SwRI course differs from the EPRI course, and list the standards for certification by SwRI.

RESPONSE

Level I and Level II Course Outlines are shown on the following pages 17a through 17d.

Practical training consists of a minimum of the specified experience hours perforning NDE examinations. Experience requirements are provided in

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Response 18.

Competency tests are also discussed in Response 18.

The SwRI course provides more general background than the EPRI course which focuses solely on the detection of IGSCC.

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INTERVENOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES ATTACHMENT TO RESPONSE 17 LEVEL I UT TRAINING COURSE OUTLINE A. INTRODUCTION B. BASIC ULTRASONICS - I

1. Definitions and Terns

2. Fundamental Properties

3. Have Behavior C. P1ATH REVIEU

l. ftath in Ultrasonics

2. Snell's Law D. BASIC ULTPASOt!ICS - II

1. Inpedance/ Reflection and Transnission of Sound

2. Snell's Law

3. Uavelength and Frequency as Related to Flaw Detection 4 Attenuation E. GENERATION OF ULTRASONIC WAVES - I

1. Piezoelectricity

2. Transducers F. ULTRASONIC TEST EOUIPMENT AND TESTING TECHNIOUES - I

1. UT Instrument

-2. UT Instrument Familiarization

3. Laboratory (Test Equipment Familiarization)

G. GENERATION OF ULTRASONIC WAVES - II .

1. Sound Bean Characteristics

a. Bean Spread Freznel and Fraunhofer Effects

b. Bean Profiles

c. Schlieren Techniques (Film)

d. Couplant and Interface Effects

e. Types of Reflect)rs

2. Laboratory (Couplants and Bean fiaintenance) 17a

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INTERVENOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES ATTACHMENT TO RESPONSE 17 LEVEL I UT TRAINING H. ULTRASONIC TEST EOUIPMENT AND TEST TECHNIOUES - II

1. Ultrasonic Flaw Detectors

2. Longitudinal Have Testing

3. Shear Uave Testing

4. Scanning Systems

5. Angle Bean Principle

6. Calibration Techniques and IIW Hlock Usage I. EXAt1INATION PROCEDURES (Laboratory)

1. Calibration

a. Distance Calibration

b. Amplitude Calibration

c. Responsibilities

2. Codes

3. Standards

4. UDT Procedures

5. Appendix IX, Article 5 and Appendix I

6. Reactors

7. Data Recording and Mapping

a. "L" !!easurements

b. "U" Measurements

c. Map Measurements

d. Recording Indications

e. Plotting Indications .

J. SPECIAL TOPICS

- 1. Effects of Equipment Variations

2. Metallurgical Conditions

3. Conparison of Ultrasonics to Other NDT Techniques K. REVIEU (Lab Techniques)

L. REVIEW

l. General Exan

2. Specific Exam

3. Practical Exam 176

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INTERVENOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES ATTACHMENT TO RESPONSE 17 LEVEL II UT TRAINING COURSR OUTLINE A. INTRODUCTION B. ULTRASONICS CHARACTERISTICS

1. Wavelength

2. Velocity

3. Frequency 4 Inpedence

5. Beam Spread

6. Near Field 7 Far Field R. Piezioelectricity C. FORflULAS USED IN ULTRASONIC TESTING

1. Snell's Law

2. Beam Spread

3. Wavelength

4. Reflection and Transnission Coefficient D. ULTRASONIC INSTRUf1ENTS

1. Components of Rasic Ultrasonic Instruments

2. Sonic tiark I

3. Nortec

4. Certification of Ultrasonic Instruments E. ULTRASONIC SEARCH-UNITS

1. Components of a Search Unit 2.. Types of Transducer riaterials

3. Angle Beam Search Units

4. Dual Element Search Units

5. Search Unit Certification F. SwRI PROCEDURES AND TECHNIOUES

1. Piping Procedures

2. Vessel Procedures

3. Special Procedures

4. Operating Procedures for Determining L and Indication Recording 17c

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Y INTERVENOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES ATTACHMENT TO RESPONSE 17 LEVEL II UT TRAINING G. LABORATORY

1. Calibrations and Data Recording H. LABORATORY

1. Data Review I. INDICATION ANALYSIS

1. In'dication Plotting and Sizing

2. Types of Geometric Indications

3. Types of Flaw Indications

4. Indication Terminology

5. Indication Resolution J. LABORATORY

1. Indications Plotting and Resolution Report Writing K. ASME CODES, REGULATORY GUIDES AND TECHNICAL SPECIFICATIONS

1.Section III

2.Section IX

3.Section V d.. SOClion XI

5. B-31-1

6. B-31-7 L. REVIEW M. EXAMINATIONS

1. General Exam

2. Specific Exam

3. Practical Exam 17d

N INTERVENOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES

18. state the total hours of (a) classroom training (b) practical trainings and (c) testing that will be

-included in the SwRI training program referred to abowe.

RESPONSE

Minimum training and experience levels included in the SwRI training program are as follows:

Training (Hours)

UT Educational Backcround Level I Level II .

Completion with a passing grade of at least two years of engineering or science study at a university, college, or technical school. 24 40 High school graduation, 40 dipolma or equivalent, 40 Grammer school graduation,

' or demonstrated proficiency or additional training. 40 80 Work Time Experience 3 months 9 months All educationL1 levels are (525 Hours) (1575 Hours) listed above NOTES: For Level II certification, the experience shall consist of time at Level I. If a person is being qualified directly to Level II with no time at Level I, the required experience shall consist of the sum

.- of the time required for Level I and Level II as a trainee and the hours of training required for Level l I and Level II in total shall apply.

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V INTERVENOR'S THIRD SET OF INTERROGATORIES MpPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES -

18 (continued)

SwRI Guidelines for Testing of Level I and Level II Examiners are as follows:

1. General (written) (for Levels I and II). The general examination shall cover the basic principles relative to the ultrasonic method.

2. specific (written) (for Levels I and II). The i specific examination shall :over the equipment, operating procedures, and ultrasonic examination that the applicant may encounter in his specific assignment.

The specific examination shall also cover the specifications or codes and acceptance criteria used in the applicable SwAI nondestructivo-examination procedures as applicable for the responsibilities of the level for which the examination is being taken.

3. Practical (for tevels I and II). The applicant shall demonstrate to the satisfaction of the examiner that he is familiar with and can operate the necessary examination equipment and analyze the resultant information to the degree required.

Minimum testing hours are not specified as part of SwRI's training program. The following table lists the minimum number of test questions for each Level and examiner types

General Specific Examination Examination Level I UT 40 20 Level II UT 40 20 Page 2 of 3

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INTERVENOR'S THIRD SET OF INTERROGATORIES 1(OPE CREEK GENERATING STATION I. PIPE CRACK INTERROCATORIES 18 (Continued)

Weight factors are applied to the percentage grades of the General, Specific, and Practical examinations as follows:

1) General 0.3

2) Specific 0.3

3) Practical 04 b

The composite grade is determined by multiplying each examination grade by its weight factor and adding the three products together.

For qualification, a composite grade of 80 percent or greater is required. In addition, each grade for the General, Specific, and Practical examinations must be 70 percent or greater. For the Practical examination, at least 90 percent of the required test indications must be found l for qualification.

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%J INTERVENOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES

19. Describe the SwRI facilities which will be used "to certify all of the equipment normally used for an ISI" as referred to in your response to interrogatory I.7.

Specify (a) the location of these facilities; (b) the equipment to be used in the certification; (c) the personnel involved in the certification process; (d) the qualifications of each of these personnel; and (e) the specific steps by which this certification is performed.

RESPONSE

(a) SwRI facilities for equipment certification are located at SWRI in San Antonio, Texas.

(b) and (e)

Standard Electronic test equipment such as Oscilloscopes, Digital Voltmeters, Function Generators and Reference Standards are used to certify the equipment. All test equipment is calibrated according to reference standards having certified traceability to the national bureau of standards.- Calibrations are performed in accordance with approved operating procedures as required by the NOAPfl.

(c) and (d)

The qualification of personnel performing calibrations, adjustments, and repairs of test and inspection equipment shall be evaluated by the Department Director. He thall consider such factors of skill required and shall provide for additional training if necessary. A list of qualified personnel is maintained along with the type of equipment that they may calibrate, adjust, or repair.

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INTERVENOR'S THIRD SET OF INTERROGATORIES H< OPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES

20. State whether the calibration reflectors in the calibration blocks to be used at Hope Creek will be located either in the weld or on both sides of the weld.

RESPONSR Calibration reflectors in the calibration blocks to be used at Hope Creek will not be located in the weld.

See response 8a, B and C to Intervenor's Second Set of Interrogatories.

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(G INTERVENOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES

21. State whether the calibration blocks to be used at Hope Creek will have the same nominal microstructure as the piping being examined. .

RESPONSE

The calibration blocks to be used at Hope Creek for the ultrasonic examination of Recirculation piping will have the same nominal microstructure as the piping being examined.

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INTERVENOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES

22. State how you will compensate for the sensitivity differences between notches and side-drilled holes when notches are used as calibration reflectors, as you indicated in your response to interrogatory I.8.

RESPONSE

Notches will be used as calibration reflectors only for the Refracted Longitudinal (RL) Ultrasonic examination of CRC welds. For RL waves, notch reflectors provide a more sensitive calibration than side drilledtherefore, hole reflectors, as stated previously in I.R C, no " compensation" is required.

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'd INTERVENOR'S THIRD SET OF, INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES

23. Stat.e whet.her beam spread corrections will be made at Hope Creek as permitt.ed by the ASME Code. If so, state whet.her flat calibration reflectors will be used for the correct. ions to crack and lack-of-fusion-type indications.

RESPONSE

Beam Spread Measurements will be made as required by ASME Section XI. Such measurements are made using side drilled hole calibration reflectors.

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l INTERVENOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES

24. state whether the end poir.ts of a flew will be determined at Hope Creek by loss.of signal amplit'#A.to.

I the background noise level where the 50% DAC method of I crack length sizing is utilized.

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l RESPONSE i 50% DAC and points will be utilized for indications I

which exceed DAC. In addition, 1/2 maximum response l end points will be utilized for indications suspected i

of being other than geometry, but do not exceed DAC.

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e i INTERVENOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES

25. Identify the " clearance dimensions for welds requiring UT , . .

furnished to Bechtel for their use in ensuring that supports and other structures did not interfere with weld inspection," as referred to in your response to interrogatory I.12.

RESPO!?SF Clearance dinensions for welds requiring t1T are that a nininun distance of 2T + 2 inches, where T is the weld thickness, shall be naintained between the edges of two adjacent welds. No other obstructions such as hangers of insulation are allowed within this area.

V INTERVENOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES

26. Identify the " criteria for surface preparation, ID counterbore, and weld contour" provided by PSEEG to Bechtel for inclusion in their piping specifications, as referred to in your response to interrogatory I.12.

RESPONSE

The criteria for the preparation of the surface shall be 250 microinches or less. The ID counterbore shall be 2T where T is $he weld thickness. The weld is essentially flat-topped with a maximum height of 1/32 inch and the edges blended snoothly into the adjacent base metal ensuring that no undercutting takes place.

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INTERVENOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES

27. State when you presently intend to perform baseline UT inspections on the Hope Creek recirculation piping system, as referred to in your response to interrogatory I. 13.

RESPOUSE Recirculation system piping circumferential welds are scheduled to be exanined in April 1985. We are presently performing baseline UT exaninations on longitudinal welds within this system.

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INTERVENOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES

28. Identify the remote scanning equipment to be used at Hope Creek referred to in your response to interrogatory I.17. Specify the manufacturers and model numbers of each such piece of equipment.

RESPor1SR Remote scanning of recirculation piping welds at Hope Creek will be accomplished with the SwRI Hutt lleld Inspection Device. This device is designed to inspect piping butt welds. The device operates on a track that is clanped to t.he pipe . The device positions a module, which typically contains three ultrasonic search units, on'the area to be inspected. The devices are designed and fabricated'by SwRI.

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v PUBLIC ADVOCATE THIRD SET OF INTERROGATORIES PARTI PIPE CRACKS

30. State whether you have considered utilizing an acoustic leak detection system at Hope Creek. If so, explain the reasons why such a system will not be utilized.

ANSWER:

No.

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PUBLIC ADVOCATE T511RD SET OF INTERROGATORIES PART I PIPE CRACKS

31. State whether the Hope Creek Generating Station as currently designed is compatible with the introduction of an acoustic leak detection r/ stem. If not, list and identify all modifications or other measures that would be required at Hope Creek before such a system could be introduced.

ANSWER:

Detailed engineering studies have not been performed; therefore, necessary plant modifications have not been determined.

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V PUBLIC ADVOCATE THIRD SET OF INTERROGATORIES PART I PIPE CRACKS

32. State whether you have considered utilizing a moisture sensitive tape leak detection system at Hope Creek. If so, explain the reasons why such a system will not be utilized.

RESPONSE

Use of a moisture sensitive tape leak detection system has been considered for Hope Creek Generating Station but is not presently proposed because the need for such a system is not needed at this time in view of IGSCC countermeasures employed at Hope Creek (see response to Interrogatory I-26 in the Second Set of Interrogatories). Information available to PSE&G at this time has indicated some proolems with this method, including spurious signals from non-relevant sources of moisture and inconsistent reporting when moisture is present.

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l INTERVENOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES

33. State whether the Hope Creek Generating Station, as currently designed, is compatible with the introduction of a moisture-sensitive tape leak detection system. If not, list and identify all modifications and other measures that would be required at Hope Creek before such a system could be introduced.

RPSPONSF To the best of our knowledge, Hope Creek Generating Station, as presently designed, is compatible with the introduction of a noisture-sensitive tape leak detection systen.

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PUBLIC ADVOCATE THIRD SET OF INTERROGATORIES PARTI PIPE CRACKS

34. State whether you have reviewed IE Information Notice No. 84-89. If so, list and identify all steps you have taken as a result.

ANSWER:

Yes. We have applied the corrective action recommended in NUREG 0313 Rev.1, Article III A.2.

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G INTERVENOR'S THIRD SET OF INTERROGATORIES HOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES

35. State whether your PSI program will be revised to include volumetric examination of a representative sample of welds in the RHR, ECCS and CHR systems. If so, specify (a) your present intentions as to when your program will be thus revised; (b) which welds will be selected for the volumetric examination; and (c) how these welds will be examined. ,

RESPONSF The only welds in the RHR, ECCS and CHR systems associated with the Recirculation piping are three welds in the RHR systen which already have been incorporated into the Hope Creek Exanination Plan.

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}IOPE CREEK GENERATING STATION I. PIPE CRACK INTERROGATORIES

36. State whether you will obtain a CRC test block with ICSCC for qual.ification of the new UT techniques to be utilized at Hope Creek. If so, specify how you will obtain this test block and estimate when it will be available.

RESPONSE

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PSE&G currently has committed to obtaining a CRC mockup, containing machined reflectors, for each size of CRC weld at the Hope Creek Generating Station. CRC j test blocks with TGSCC are not available at this time since IGSCC has not occurred in CRC piping. PSE&G has and will continue the pursuit of representative clad overlay crack samples for UT technique demonstration and qualification as directed by NRC. The samples were chosen because they were considered the most acceptable alternative test piece due to the unavailability of CRC test samples with IGSCC. In an informal, but " blind" test, the SwRI technique detected 80% of the IGSCC in the test piece.

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37. Describe how the special pitch catch unit designed for the transducer developed by SwRI for PSEEG is able to alleviate the particular acoustic problems presented by the UT examination of CRC.

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RESPONSE

The SwRI approach to the problems associated with UT l

examination through CRC was to develop a transducer l

which improved the signal-to-noise ratio while minimiz-ing the effects caused by the reflective cladding interfaces. Refracted longitudinal waves were speci-fied to minimize the interface reflections while the tra'nsducer is designed to minimize the effect spurious signals and improve the signal-to-noise ratio. These design goals are accomplished by highly damping the transducer while using acoustic impedence matching plates for the transducer element with electronic impedence and frequency matching networks on the input side of the unit.

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SECTION III. MANAGEMENT COMPETENCE - INTERROGATORIE3 INTERROGATORY ll: Identify and describe the " specific short term and longer term actions to improve management practices" re ferred to in your response to interrogatory III.3.

RESPONSE: The " specific short term and longer term actions to improve management practices" referred to in our response to interrogatory III.3 are identified and described in the following documents:

Supplement to Corrective Action Program; 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, Salen Generating Station Units No. I and 2, submitted to the Nuclear Regulatory Commission April 28, 1983.

PSE&G Plan for the Improvement of Nuclear Department Operations, dated August 26, 1983.

All of these documents were previously provided in response to the December 14, 1984 Request For Documents IV.5.

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'\~s Y THIRD SET OF INTERROGATORIES MANAGEMENT COMPETENCE INTERROGATORIES SECTION III, ITEM 2 '

DESCRIPTION:

Describe in detail the " programs and procedures which stem from and comply with the Vice President Nuclear Procedures (VPNs) as a common base" as referred to in your response to interrogatory III . 9.

RESPONSE

Hope Creek Station Administrative Procedures stem from and will comply with Vice President - Nuclear Procedures. These Station SA-AP's have been previously supplied and provide the detail requested.

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, _ THIRD SET OF INTERROGATORIES MANAGEMENT COMPETENCE INTERROGATORIES SECTION III, ITEM 3 DESCRIPTION:

Describe in detail the " operating experience assessment program" referred to in your response to interrogatory III. 9.

RESPONSE

A detailed description of the " Operating Experience Assessment" program is provided in Station Administrative Procedure SA-AP.ZZ-047(O " Operating Experience Evaluation". Station Administration Procedures have been previously supplied. ,-

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V THIRD SET OF INTERROGATORIES MANAGEMENT COMPETENCE INTERROGATORIES SECTION III, ITEM 4 DESCRIPTION:

Identify and describe in detail the " common Nuclear Department support groups" referred to in your response to interrogatory III. 9.

RESPONSE

The " common Nuclear Department support groups" referred to in the response to Interrogatory III.9 are those departments parti-cipating in the operating experience assessment program in addition to Salem and Hope Creek Operations. These groups are Engineering Control, Licensing and Regulation, Reliability and Assessment and Training. A description of these departments is provided in HCGS FSAR Chapter 13.1.

A description of the program is in FSAR Section 1.10.2.I.C.5.

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~- III. . MANAGEMENT COMPETENCE INTERROGATORIES b 5. List and identify each of the " numerous changes" that have been made in the Hope Creek FSAR" as a result of internal prcgrams and evaluations that have been conducted," as referred to in your response to Interrogatory III. 10. For each such change to the FSAR, identify and describe the internal program or evaluation that resulted in the change.

RESPONSE

The changes made in the Hope Creek FSAR are those identified as Amendment 8 in Chapter 13, Conduct of Operations and those identified as Amendments 1 through 8 in Chapter 17, Quality Assurance. These changes resulted from internal programs and evaluations conducted as part of the "PSE&G Plan for the Improvement of Nuclear Department Operations", submitted to the NRC on August 26, 1983. See also, response to Interrogatory III. 17 (Second Set).

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8. Identify and describe each of the criteria used in the PSE&G Management Personnel Performance Appraisal Program to " systematically and objectively appraise each individual's performance", as referred to in your response to Interrogatory III.13.

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RESPONSE

PSE&G's Management Personnel Performance Appraisal Program utilizes a form which identifies the evaluation factors used in the program. See response to Second Set of Request for Production of Documents,III.25.

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9. Identify and describe each c~ .:.. incentives available for use in the PSE&G Management Personnel Performance Appraisal Program as referred to in your response to Interrogatory III. 13.

RESPONSE

PSE&G's Management Personnel Performance Appraisal Program in itself is an incentive tool established to facilitate personal growth, career development, and opportunities for advancement consistent with and in support of the departmental goals and objectives.

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IH. MANAGEMENT COMPETENCE: INTERROGATORIES INTERROGATORY 10: List and identify each of the meetings between the CEO, Senior Vice President and Vice President - Nuclear dating after January 1,1982, referred to in your response to Interrogatory 111.15. For each, (a) state the date of the meeting; (b) list all persons in attendance; (c) identify the subject matter discussed; and (d) identify all minutes or other writings that were prepared as a result.

RESPONSE

(a) Meetings between the CEO, Senior Vice President and Vice President - Nuclear are scheduled every Wednesday and others as needed.

(b) The CEO, Senior Vice President and Vice President -

Nuclear attend these meetings along with others as needed (records of attendance are not maintained).

(c) Nuclear Department activities are discussed.

(d) None.

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IH. MANAGEMENT COMPETENCE: INTERROGATORIES INTERROGATORY 11: Describe the nature of the " readiness to respond" referred to in your response to Interrogatory III.15. Identify and describe (a) each of the potential' responses' for which the CEO and Senior Vice President are ' ready'; and (b) each instance since January 1,1932 in which the CEO and Senior Vice President i

have in fact responded within the meaning of your answer to this Interrogatory.

l l RESPONSE:

The weekly meetings referred to in Interrogatory IIL10 are for the purpose of maintaining the CEO and Senior Vice President at a high level of awareness. They have responded where necessary to provide company resources to support the nuclear operation.

O SECTION III. MANAGEMENT COMPETENCE: INTERROGATORIES INTERROGATORY #12: Identify the status of your efforts to fill the position of Assistant Vice President - Nuclear Operations.

Describe all steps you have taken to date and all steps you presently intend to take in the future to fill this position.

Also, state how long this position has remained open.

RES PONSE: Approximately fifty potential candidates were reviewed.

Thirty-one of these were interviewed either by phone or in person. Three individuals have been selected as final candidates and are under consideration at this time.

The position became open when the Nuclear Department was reorganized in August, 1984.

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\J SECTION III. MANAGEMENT COMPETENCE: INTERROGATORIES INTERRORATORY #13: Identify the status of your efforts to fill the position of Manager - Reliability and Assessment.

Describe all steps you have taken to date and all steps you presently intend Also to take state how in the long future this to has position fill this remained position.

open. .

RESPONSE: In excess of 100 resumes have been reviewed relative to this position, with 12 candidates interviewed to date. Four individuals have been selected as final candidates and are under consideration at this time.

This position has been open since August, 1984.

O SECTION III. MANAGEMENT COMPETENCE: INTERROGATORIES l

l INTERROGATORY #14: Identify and describe each of the " demands" that where previously "placed on the Vice President - Nuclear" that are no longer thus placed as a result of the implementation of the "Public Service Electric and Gas Company Plan for the Improvement of the Nuclear Department Operations" referred to in your response to interrogatory III.19. Specify each change in job description or definition of job responsibilities that resulted from the implementation of this plan and estimate the resultant time savings per week for the Vice President - Nuclear.

RESPONSE: The docuuents' identified below describe in detail the "deman.ls" previously "placed on the Vice President -

Nuclear". Each change in job description has been i documented in Chapter 13, Hope Creek FSAR. It is estimated that moving from eight (8) direct functional i

reports to four (4) direct functional reports, the I establishment of a senior management team concept, i together with other reorganization objectives, all l detailed in the documents identified below, allows the i

Vice President - Nuclear to redirect one-quarter of his time per week to matters requiring additional senior management focus.

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REFERENCE:

PSE&G Plan for Improvement on Nuclear l Department Operations, submitted to the U. S. Nuclear Regulatory Commission on August 26, 1983.

Section 2.0, Action Plans Action Plan number 2.1.1 l

Action Plan 2.1.1 - Functional Analysis of the VPN position and all Direct Reports.

l PSE&G Action Plan Close-out Document,

! Action Plan 2.1.1.

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IH. MANAGEMENT COMPETENCE: INTERROGATORIES Interrogatory 15: Identify and describe each meeting between the Senior Vice President - Nuclear and Engineering, the CEO and the Vice President - Nuclear referred to in your response to Interrogatory III.20. For each such meeting identify (a) the date it occurred; (b) all persons in attendance; (c) the subject matter discussed and all decisions reached; and (d) all minutes or other writings that were prepared thereafter.

RESPONSE

(a) Review meetings of Action Plan progress are scheduled every Wednesday. Bi-monthly review meetings of the Action Plan are held with the NRC.

(b) The CEO, Senior Vice Precident - Nuclear and Engineering, and the Vice President - Nuclear attend these meetings.

(c) Progress on the Action Plan is discussed at these meetings.

(d) None.

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15. MANAGEMENT COMPETENCE: INTERROGATORIES INTERROGATORY 16: Identify and describe each visit to Artificial Island by the CEO, the Senior Vice President - Nuclear and Engineering, the Vice Presidents and the General Managers involved in matrixed functions, and other corporate personnel as referred to in your response to Interrogatory III.20. For each such visit, identify (a) the date it occurred; (b) the persons making the visit; (c) the specific purpose of the visit; (d) all facilities and activities observed; (e) all decisions, observations or conclusions resulting from the visit; and (f) all minutes, reports or other writings that were produced as a result of the visit.

RESPONSE

(a) Visits to ArtificialIsland are made as needed and about once every two weeks by the CEO.

(b) About two days each week by the Senior Vice President - Nuclear and Engineering. Vice President - Nuclear is permanently located at ArtificialIsland. All General Managers attend meetings as needed.

(c) The purpose of the visits are to discuss the activities of the Nuclear Department.

(d) The facilities and activities observed vary with the reason for the meeting. .

(e) The decisions resulting from these meetings vary with the reason for the

. meeting. ,

l (f) None.

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O SECTION III. MANAGEMENT COMPETENCE: INTERROGATORIES INTERROGATORY 917: Identify, define and describe the recently established " focal points for Corporate information requests" referred to in your response to Interrogatory III.20. , Identify when such focal points were established, their purpose and all the personnel involved.

RESPONSE: Identification, definition and descriptions of recently established focal points for Corporate information requests are contained in PSE&G Action Plan Close-Out Document, Action Plan 2.1.4 documentation previously submitted. Personnel involved in the focal points are identified in Chapter 13 HCGS FSAR, previously submitted.

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b SECTION III. MANAGEMENT COMPETENCE: INTERROGATORIES INTERROGATORY 018: Identify and describe how communications between " Corporate and Nuclear Department managers involved in the matrixed functions" has been "substantially increased," as referred to in your response to Interrogatory III.20.

t RESPONSE: The report of "substantially increased communications" is based on the perceptions of relevant managers involved in the matrixed functions informally collected by organization development consultants. Resulting clarifications of matrix agreements; an increase in the daily phone communications between Corporate and Nuclear Department managers involved in the matrixed functions; the increased knowledge and understanding demonstrated by both corporate and site managers about each other's concerns re matrixed functions; and the increase in visits by corporate managers to Artificial

' Island are all substantiating evidence of substantially increased communications.

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22. State whether you agree with the NRC's conclusion as stated in the 1984 Salem SALP that, during the assessment period of October 1, 1983 through August 31, 1984, PSE&G's " decision making was not at a level sufficient to ensure adequate management review." If you disagree, state the reasons why this conclusion is inaccurate. If you agree, explain why. Identify and describe all steps that you have taken or presently intend to take in the future in response to this conclusion by the NRC.

RESPONSE

See attached letter in response to SALP Report (R. A. Uderitz to R. W. Starostecki, December 14, 1984).

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P O. Box 236 sanc:c<s Bre;e. NJ C8033 6C9 33943%

o.2,,; semce E'e::ric rc Gas Carr:any

, :e 8'escem - Nuc' ear Richard A. Udentz December 14, 1984 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 ,

Attention: Mr. Richard W. Starostecki, Director Division of Project and Resident Programs Gentlemen:

LICENSEE COMMENTS (SALP)

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE SALEM GENERATING STATION NO. 1 AND 2 UNITS DOCKET NOS. 50-272 AND 50-311 .

1984 SALP report We have reviewed the October 1983 to August 1984 and participated transmitted by your letter of November15,-1984. 5, While we note in the SALP meeting held on November that an improving trend has been identified in the areas of plant operations, radiological controls, maintenance and sur-veillance, we are not satisfied with the degree or speed of progress. In addition, we'are particularly troubled by the recent decline in fire protection and emergency preparedness. -

These areas, as well hs plant operations, will be vigorously pursued and given particular attention.

l While there may be some disagreement concerning the details of some aspects of the report, we agree with the overall assess-The findings of the report will be given the highest' ment.

priority. It is our intention to expeditiously take the steps necessary to improve our performance in all areas.

As you are aware', we have made signif[ cant progress in the de-velopment.and implementation of a number of Now programs havingtargeted the benefit to improve our performance in many areas. we have l

' of the SALP Board's findings in their recent report, initiated a review of these programs and our internal performance monitoring activities to assure that these programs will yield 6

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'*h.RichardW. Starostscki- - l the most timely and satisfactory results. Corrective actions in terms of additional programs (interim and permanent), or adjustments to existing programs, will be taken to assure that our performance improves significantly during the next appraisal period.

kh EAL:vmd C Mr. Donald C. Fischer Licensing Project Manager Mr. James Linville Senior Resident Inspector 1

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23. Identify and describe all steps that you have taken or presently intend to take in the future in response to the NRC's observation in the 1984 Salem SALP that you have "not been consistent" in your

" efforts to assure quality and to maintain a good operating safety perspective," and that "it is not clear that this remains foremost when the licensee is responding to events that have removed, or have the potential for removing, the unit (s) from' service."

RESPONSE

See response to Interrogatory III.22.

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O 95:CTION III. MANAGEMENT COMPETENCE: INTERROGATORIES INTERRORATORY $24: Identify and describe all steps you have taken and all steps you presently intend to take in response to the NRC's observation in the 1984 Salem SALP report, dated October 15, 1984, that a "[1]ack of aggressive management involvement in resolving long standing problems . . . is clearly evident."

RESPONSE: See response to Interrogatory III.22. . . .

III. MANAGEMENT COMPETENCE: INTERROGATORIES 3

25. Identify and describe all steps you have taken and all steps you presently intend to take in response to the NRC's observation in the 1984 Salem SALP that ' lack of direct licensee supervisory and quality assurance involvement in many outage activities seems to have led to extensive rework."

RESPONSE: See response to Interrogatory III.22.

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SECTION III. MANAGEMENT COMPETENCE: INTERROGATORIES INTERROGATORY #26: Identify and describe all steps that have been taken or which you presently intend to take in the future in response to the NRC's statement at the Management Meeting held November 16, 1984 which " cautioned that the Action Plans were not necessarily the cure for all problems that may be identified."

RESPONSE: Normal and prudent PSE&G management practices as set forth in Corporate and Nuclear Department policy and procedure documents.

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III. MANAGEMENT COMPETENCE: INTERROGATORIES

27. State whether you agree with the NRC's observation at the November 16, 198 4 Management Meeting that your then-current practice of authorizing "PSE&G licensing personnel to sign correspondence directed to the NRC" represents a " potential problem as it relates to the degree of (corporate] review given" to such submissions.

If you agree, explain why. If you disagree, explain why.

RESPONSE

We do not agree. The Manager - Nuclear Licensing and Regulation is a senior manager who is accountable to keep upper management informed on regulatory issues and assure the appropriate level of management review and approval on all regulatory issues. See also response to Interrogatory III.28.

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g III. MANAGEMENT COMPETENCE: INTERROGATORIES

28. Identity all PSE&G personnel who currently have authority to sign correspondence directed to the NRC of the nature referred to by the NRC at the November 16, 1984 Management Meeting. If licensing personnel currently have this authority, state whether you presently intend to withdraw this authority and when you intend to do so. (

If not, state the date when this authority was withdrawn. Also identify all memoranda and other documents relating to this issue.

RESPONSE

Vice President - Nuclear General Manager - Salem Operations General Manager - Hope Creek Operations Manager - Nuclear Licensing and Regulation There is no intention to change signatory authority.  !

Related documents: VPN procedures (previously submitted),

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. 29. Identify and descirbe all steps you have taken or that you presently intend to take in the future in response to the " attitude problem on the part of some staff" ebserved byu the NRC in the 1983 Salem SALP, including their " lack of inquisitiveness or lack of personal accountability.

RESPONSE

See attached letter in response to SALP Report (R. A. Uderitz to R. W. Starostecki, December 20, 1983) t

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L Richard A. Uderitz  %:nc Service E;ectnc and Gas Comcany P O Sox 236. Mancoes 3rv NJ C3033 E9 E CIO vice rr o.ni .

Nuclear December 20, 1983 U. S. Nuclear Regulatory Commission - Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention: Mr. Richard W. Starostecki, Director Division of Project and Resident Programs Gentlemen: ,

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)

SALEM GENERATING STATION, UNITS NO. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 As a result of our review of the November 7, 1983 SALP Board's report, we are concerned about many of the statements made regarding our performance in the area of plant operations. The SALP Board has rated our overall performance in the functional area of plant operations as category 3, requiring increased NRC and licensee attention. PSE&G believes this rating to be unwarranted for the reasons detailed below.

In their report the SALP Board has identified several weaknesses (Section IV.1); however, these weaknesses are essentially a reiteration of those identified during the NRC's investigation of the February 1983 reactor trip breaker f ailures and those identified by the PSE&G initiated management review conducted by Management Analysis Company (MAC). We believe such a low rating to be inappropriate, in that PSE&G has implemented a comprehensive corrective action program to eliminate those weaknesses. The decision to engage MAC to conduct such an .

extensive management review and to act on their findings, represented a major commitment to upgrade management attention f to all f acets of plant operations and support; yet, the SALP Report does not credit PSE&G for this effort and ,in fact, used k,, its findings to further support negative findings.

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A U.S. Nuclear Regulatory Commission 12/20/83 C

PSE&G has programs in place to address each of the concerns identified in Section IV.1 of the SALP report, and would like the opportunity to respond to each concern. Accordingly, we.

request an extension until January 25, 1984 for providing a detailed response to the SALP findings in the functional area of plant operations.

Sincerely, i

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III. MANAGEMENT COMPETENCE: INTERROGATORIES ,

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30. Identify and describe all steps you have .taken or that you presently intend to take in the future in response to the need "to provide an integrated philosophy of operations and safety inquisitiveness" identified by the NRC in the~1983 Salem SALP. If any such steps have been taken, identify and describe the " integrated philosophy '

of operations and safety inquisitiveness" that has been provided by PSE&G's management.

RESPONSE

See response to Interrogatory III.29.

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31. Identify and describe all steps you have taken or presently intend to take in the future in response to the NRC's statement in the findings of the 1983 Hope Creek SALP that " training and activity planning and overview (were) areas which merit increased management attention to upgrade performance."

RESPONSE

At the time of the 1983 Hope Creek SALP, Bechtel management was already investigating training activities as a result of previous audits. The results of this " Task Force" effort are being provided with the request for documents. Specific application of the recommendations are as specified in the applicable Specific Work Procedures.

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IH. MANAGEMENT COMPETENCE: INTERROGATORIES

32. DESCRIPTION:

Identify and describe all steps you have taken or presently intend to take in the future in response to the NRC's recommendation in the 1983 Hope Creek SALP that "your advance planning for the operations phase carefully assess BWR operating experience in your operating and corporate staff."

RESPONSE

The Company has carefully assessed the BWR operating experience requirements necessary for the operations phase of Hope Creek.

Subsequent to the 1983 NRC SALP for Hope Creek Generating Station the NRC staff has performed and published the Safety Evaluation Report related to the operation of Hope Creek Generating Station NUREG-1048 dated October,1984.

The NRC's findings relative to this matter are presented in the Hope Creek SER Section 13.1.

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33. Identify and describe all steps you have taken or presently intend to take in the future in response to the " concern" noted by the NRC in the 1983 Hope Creek SALP "for the ability of PSE&G to concurrently support Hope Creek licensing and give adequate attention to safe operation at Salem."

RESPONSE

See letters provided with request for documents.

. R. L. Mitti (PSE&G) to A. Schwencer (NRC), July 8,1983.

. R. L. Mitti (PSE&G) to A. Schwencer (NRC), October 28,1983.

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-34. Identify and describe all steps you have taken or presently intend to take in the future in response to the

" concern" noted by the NRC in the 1983 Hope Creek SALP "that the Hope Creek OL application did not reflect significant overall PSE&G management capability and performance changes made in response to the May 6, 1983 NRC Order addressing.the Salem experience."

RESPONSE:.

See Hope Creek FSAR, Cnapter 13.

See also response to Interrogatory III. 33.

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35. List and describe all NRC violations at the Salem or Hope Creek Generating Stations in 1983 and 1984. For each, include the date of the violation, the level of severity, and any penalty imposed.

RESPONSE

See response to Second Set III.7 and documents provided in response to request for documents.

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36. Identify and describe all steps you have taken in response to the NRC's concern, expressed in the May 16,1984 meeting, that "because of the changes occurring in the , Hope Creek. site organization, PSE&G's effort on site might be diluted," as referred to in the May 18,1984 memorandum from A. C.

et al. Specify each change in your site Smith to . C. referred organization W. Churchman, to by theHitC and describe how it has effected or will effect PSE&G's effort on site.

RESPONSE

As cited in the referenced memo dated May 18, 1984, the NRC Resident Inspector did express some concern about a possible diluting of the Public Service site organization effort regarding; (1) the recent transfer of the system completion group from Construction to Startup responsibility; and (2) the recent transfer of several Construction Engineers to Site Engineering.

PSE&G did not concur that this was a valid concern for the following reasons: .

The first change (Item No.- 1 above) was appropriately made to effect a smoother and more efficient turnover process as the jobsite effort was moving more from a bulk construction mode to a system / facility turnover and testing mode. Accordingly, the years of actual Hope Creek jobsite experience associated with these construction completion personnel have bolstered the capabilities of the Public Service Startup team to date to more effectively carry out their turnover related requirements.

The second change (Item No. 2 above) was similarly made as the Public 4

Service engineering role was shifting from a plant design mode to a system F testing and pre-operational support mode. The transfer of construction engineers to Site Engineering strengthened the overall support required for startup activities.

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l III. MANAGEMENT COMPETENCE: INTERROGATORIES RESPONSE TO QUESTION NUMBER 37 OF INTERVENOR' S THIRD SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO APPLICANTS DATED J ANUARY 4, 1985 .

37. Identify and describe all steps you have taken and which you presently intend to take to reduce personnel errors reportable as a Licensee Event Report. Explain why reportable LER personnel errors increaseo 7% from 1982 to 1983 while the total number of LER's in the same period decreased 42%.

RESPONSE

Each incident is thoroughly reviewed and corrective actions implemented as necessary based on the results of tne review.

In reviewing past incidents involving personnel error, there has been no common cause. Personnel errors are handled on a case-by-case basis. Some events have resulted in upgrading training programs and some have resulted in disciplinary action.

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III. MANAGEMENT COMPETENCE: INTERROGATORIES

38. State whether a system of tracking / trending using Incident Reports (IR's) instead of LER's has been instituted. If so, list all incident reports by Equipment Identification Industry Standard (EIIS) codes for all ' rears for which data has been entered. Also, describe how personnel errors will be classified by the EIIS code.

RESPONSE

The Hope Creek trend analysis program which includes incident reports, is instituted on systems after they complete preoperational testing and are turned over to Hope Creek Operations. Due to the small number of systems released to Hope Creek Operations and the short operational history of those systems, no recurring failures or problems have been identified.

Personnel errors are not classified by the EIIS code, o

INTERROGATORIES

\v) III. MANAGEMENT COMPETENCE:

39. State whether you have ccerelated " personnel error incidents with availability", as referred to in the minutes of the Nuclear Review Board (NRB) meeting of March 6, 1984. If so, describe the relationship so identified and all corrective actions you have taken or presently intend to take in the future as a result.

Also, identify all documents relating to this correlation.

RESPONSE

We have not.

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1 III. MANAGEMENT COMPETENCE: INTERRGGATORIES

40. List the total number of personnel errors identified in Salem Generating Station Licensee Event Reports (LER's) for each of the years: 1980, 1982, 1983 and 1984. State whether the 1984 statistics can be correlated to the statistics from previous years. If not, correct the previous years statistics to compensate for any changes in reporting requirements.

RESPONSE

The total number of LER's attributed to personnel error was eleven (11) in 1980, twenty-one (21) in 1981, twenty-seven (27) in 198 2, twenty-nine (29) in 1983 and sixteen (16) in 1984. Yes, they can be correlated.

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III. MANAGEMENT COMPETENCE: INTERROGATORIES

41. Identify and describe all audits of either Hope Creek or Salem staff performance. For each such audit, identify (a) the date it was performed; (b) all persons performing the audit and their job titles; (c) all persons audited and their job titles; (d) all deficiencies found, and (e) all reports and documents prepared as a result of the audit.

RESPONSE

Audits are conducted of program activities and organizations to assess compliance with requirements and effectiveness of program controls. The audits, by their nature, do assess overall staff performance of organizations relative to their scope of responsibilities. See audit reports for 1983 and 1984 submitted in response to Document Production Request IV.ll.

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42. Identify and describe all steps you have taken in response to the Nuclear Review Board's " longstanding concerns with the DCR process," including the problems of " inadequate safety evaluations" and " tunnel vision" on the part 1 of the engineering staff,"(sje.) as referred to in the June 5,1984 meeting of the NRB.

RESPONSE

The steps that are being taken are described in the close out documentation for Action Plans which have been previously submitted. See responso to Second Set III.3.

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43. Describe the causes of the event of October 14, 1984 at the Salem Generating Station, when By-Pass Breaker A and Reactor Trip Breaker B would not close after manual actuation during performance of I & C testing.

Identify the date on which the console trip switch involved in this event had

-last been replaced, and the dates on which each item of equipment involved had undergone preventative maintenance.

RESPONSE

The event of October 14, 1984 occurred during the performance of an I & C test on Unit I while the unit was in Mode 3 and reactor power level was 0. A maintenance inspection found pitting on one of the contacts on the console trip switch. During this entire event the redundant trip switch remained in an operable condition.

1 The console trip switch identified in this event was installed on April 25, 1983. Periodic inspection was scheduled to be performed every three refuelings. Based on this frequency, no inspection nor maintenance was required or performed since the switch was installed in 1983. As a result of the October 14, 1984 event, this inspection is now being scheduled for every refueling outage (approx. every eighteen ..anths).

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III. MANAGEMENT COMPETENCE: INTERROGATORIES

44. Identify and describe each of the current "open items" of the Nuclear Review Board. For each, state (a) all steps that have been taken to close the open item; (b) each date the item was reviewed by the Board; (c) all steps that you presently intend to take in the future to close the item; and (d) the date by which you expect each such item to be closed.

RESPONSE

No Open Items exist at this time.

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IH. MANAGEMENT COMPETENCE: INTERROGATORIES

45. Identify and describe what is meant by the " span of control" of the Nuclear Department's senior management, as referred to in your response to

- Interrogatory ID.27. Explain how the August 28,1984 reorganization "better defined" this span of control.

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RESPONSE

" Span of control", as used in this question, is the description of the organizational and managerial demands made on members of the Nuclear Department senior management team. On August 28, 1984, the Nuclear Department was reorganized.

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In the revised management structure, the Vice President - Nuclear will have the assistance of two senior managers to establish Department plans, make; decisions about program activities, and address interface problems from a Department-wide perspective.

Each Assistant Vice President has _a more reasonable span of contrcl, in terms of the number and focus of functions reporting to him. All operations and maintenance functions are grouped under the Assistant Vice President -

Nuclear Operations; all technical and administrative support functions ,

report to the Assistant Vice President - Nuclear Operations Support. Each Assistant- Vice President is responsible not only for ensuring effective functional management on the part of the line managers reporting to him, but also for ensuring timely coordination and responsiveness between operations and operations _ support work groups, and for resolving all interface concerns in support of effective Department-wide programs.

The key function of Quality Assurance and Nuclear Safety Review will report directly to the Vice President - Nuclear to provide independent authority in the execution of Department-wide quality assurance and safety review activities and to ensure on-going senior management awareness and support of these programs.

The revised Nuclear Department organizational structure will provide for-more effective management control and improved functioning as an integrated department.

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%d INTERROGATORIES SECTION III'. MANAGEMENT COMPETENCE:

List and identify the " periodic Nuclear INTERROGATORY #46:

Department management dialogue meetings" referred to in your For each such meeting, identify resonse to Interrogatory III.27.

(a) the date of the meeting; (b) the persons in attendence; (c) the subject matters discussed and any decisions reached; and (d) all writings produced as a result.

RESPONSE: The previously submitted documents identified below answer in detail the questions concerned with the Nuclear Department managenent dialogue meetings.

REFERENCE:

PSE&G Action Plan Close-out Document, Action Plan 2.1.5.

Management Dialogue Sessions S

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4 III. MANAGEMENT COMPETENCE: INTERROGATORIES

47. -Identity tne Otganizational Development specialist referred to in your response to Interrogatory III. 27.

State this individual's responsibilities within the

( Nuclear Department, and describe what, if anything, this specialist has done.to correct the management - related deficiencies identified by the NRC.

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RESPONSE

S. Poston was hired effective December 17, 1984, to fill the position of Principal Organizational Development Consultant. His duties include:

o Strategic planning and problem-solving with the senior management team; facilitating weekly meetings of this group; o Planning and facilitating the Manager's Dialogue Sessions; o Working with Department managers on organizational problems related to jurisdictional accountabilities, information flow, administrative control systems, etc.; ,

o _ Designing and managing conflict resolution strategies

- to resolve. Department interface problems.

o Providing " third party" facilitation of managerial working relaionships with peers or subordinates, o Designing and managing department and organizational unit team building activities, o Consulting with individual managers on issues such as leadership style, work analysis, time management, employee performance problems, planning and implementing change, etc.;

o Planning and chairing special departmental task forces or work groups focused on interorganizational l Concerns.

l Because of the recent employment of this individual, his efforts in corrective action of deficiencies cannot yet be measured.

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SECTION III. MANAGEMENT COMPETENCE: INTERROGATORIES l INTERROGATORY #48: List and identify each " team building" meeting between " departmental members at various levels" as referred to in your response to Interrogatory III.27. For each identify (a) the date of the meeting; (b) all persons in attendance; (c) the subject matter of the meeting and any decisions reached; (d) all documents produced as a result.

RESPONSE: Team building meetings referred to in response to Interrogatory III.27 are described and documented in PSE&G Action Plan Close-Out Document, Action Plan 2.4.5 previously submitted.

w III. MANAGEMENT COMPETENCE: INTERROGATORIES

51. List and describe all " areas . . . regarding efforts to correct deficiencies" identified by the self-evaluative performance indicators referred to in your response to Interrogatory III. 32. For each, describe all steps you have taken or present.ly intend to take in the future to address it.

RESPONSE

The performance indicators are used to identify trends, to allow comparison with other plants, and to compare progress and performance relative to established targets of performance.

The current set of performance indicators are identified and defined in the VPN Procedures and Nuclear Department Monthly Reports, previously submitted.

Activities initiated by the information obtained by trending these indicators includes:

a. The initiation of a Capacity Factor Improvement Task Force;

b. The initiation of a scram evaluation and reduction program.

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1 SECTION III. MANAGEMENT COMPETENCE: INTERROGATORIES INTERROGATORY 852: List and describe all " periodic management dialogue sessions" at Hope Creek as referred to in your response to Interrogartory III.33. For each, identify (a) the date of the meeting; (b) the persons in attendence; (c) the subject matter of the discussion; and (d) all documents produced as a result.

RESPONSE: Refer to Interrogatory response number 46 in this document.

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53. Describe how the Vice President - Nuclea,r "uses regularly scheduled management dialogue meeting (sic) to motivate and remind higher level management. personnel to become more involved in station activities and to raise their expectations of acceptable response" as referred to in your response to Interrogatory III. 35.

RESPONSE

The Manager's Dialogue Session agendas and meeting minutes previously submitted indicate how the Vice r President - Nuclear uses a 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.

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54. List and identify all " persons from outside organizations" added to the NRB following the February 22 and 25, 1983 ATWS at Salem as referred to in your response to Interrogatory III. 39.

RESPONSE

In January 1983, the NRB decided to add the following outside representatives to the Board:

Mr. T. R. Robbins - Pickard, Lowe and Garrick Messrs. W. T. Ullrich and G. A. Hunger, Jr. -

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55. Identify the. Safety Review Group member serving on the Station Operations Review Committee as referred to in your response'to Interrogatory III. 39.

RESPONSE

B. E. Hall, Safety Review Group Head.

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'N ,) III. MANAGEMENT COMPETENCE INTERROGATORIBS

56. Identify and describe each of the opportunities for improvement you believed existed in your QA program prior to the Salem events, as referred to in your response to Interrogatory III. 40. Identify all documents related to this issue.

RESPONSE

The areas which we believed we could strengthen included organizational structures, management systems and working, relationships. The results of the MAC OA assessment and subsequent PSE&G actions have been described and appropriate documents provided previously.

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57. Describe how development of the computerized safety tagging system will " reduce operator errors, improve safety, compliance to technical specifications and decrease operator drudgery" as referred to in your response to Interrogatory II. 40.

RESPONSE

A computerized Tagging Request and Inquiry System (TRIS) was developed almost 3 years ago to improve administrative control over the system used to apply safety blocking tags.

Since the TRIS has been placed in service, many improvements in control of tagging and equipment status have been realized. The system provides ready access to the location of a component so that an operator can quickly operate it when directed. The system prints out on a line printer all paperwork necessary to perform a tagging operation. This includes an operator worksheet which specifies tagged position, normal position for the mode that the plant is in, and any special instructions unique to that component, such as " locked" or

" throttled". The tags themselves are also printed, making the tag information consistent and legible.

Each manipulation is carefully recorded and tracked on the computer to assure that all steps in the tagging process are completed as required. These tagging evolutions create a file in the computer that gives the operators a readily accessible status of plant equipment. At the operator's request, the system provides hard copy of this status in a number of formats, all of which specify the position the component should be in for a given plant status. Available also is a history of tagging operations that allows the operators to look back over previous shifts if necessary.

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58. Describe the " Feedback'of Operating Experience Program which includes review of nine years historical data" referred to in your response to Interrogatory III. 40.

Response: A Response Coordinating Team is responsible for evaluating the following industry experience documents:

NRC Bulletins Information Notices Circulars Generic Letters GE SIL (Service Information Letter)

TIL (Technical Information Letter)

SAL (Service Advice Letter)

AID (Application Information Document)

INPO SOER (Significant Operating Experience Report)

SER (Significant Event Report)

O&MR (Operation and Maintenance Report) i c

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60. Identify and describe each of the " formal presentations on various aspects of the operations" of the Nuclear Department made to the PSE&G Board of Directors since February 25, 1984, referred to in Mr. Sonn's April 10, 1984 presentation to the NRC. Identify all documents relating to such presentations. .

RESPONSE

2/21/8 4 Status of construction and Economics of the Hope Creek Generating Station, Pierre Landrieu, R. M. Eckert.

No documentation.

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15. MANAGEMENT COMPETENCE: INTERROGATORIES

61. Identify each occasion on which an outside member of the PSE&G Board of Directots visited Artificial Island. For each such visit, identify (a) the date of the visit; (b) all persons that participated in the visit, including both Board members and others; (d) the purpose of the visit; and (d) all documents produced as a result.

Participants

! Date of Visit in Visit Purpose Documents November 16,1982 J. R. Cowan Inspection W. R. Davis M. S. Foster D. W. Hallstein I. Lerner W. E. Marfuggi M. M. Pfaltz J. C. Pitney K. C. Rogers W. E. Scott R. L Smith H. W. Sonn S. A. Mallard E. L. Morris t

J. B. Randel, Jr.

l M. F. Reynolds -

R. A. Uderitz i K. W. Hanson

! R. S. Smith i C. E. Johnson J. M. Zupko, Jr.

H. J. Midura August 2,1983 V. L. Roundtree, Inspection Director Ural Roundtree M. F. Reynolds

, R. A. Silverio P. J. Kudless April 26,1984 J. S. Weston, Inspection Director R. S. Smith

- R. A. Uderitz J. M. Zupko< M.

K. W. H'm o J.T.Boct 3ec R. S. Salwsen i

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SECTION III. MANAGEMENT COMDWTENCE: INTERROGATORIES INTERROGATORY 562: Identify each member of the Nuclear Oversight Comunittee that has resigned since October, 1983. Identify all documents that relate to these resignations.

RESPONSE: No member of the Nuclear Oversight Committee has resigned.

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INTERROGATORIES .

SECTION III. MANAGEMENT COMPETENCE:

List and identify alltoletters, any andmemoranda all members or of INTERROGATORY 463:

other documents received from or sent the Nuclear Oversight Committee.

of all letters, memoranda or RESPONSE: The following is a listother documents received by PSE&G f ro Nuclear Oversight Committee:

1.

Minutes of the Nuclear Oversight Committee meetings for October, 1983; December, 1983; March, 1984 June, 1984; September, 1984; and December, 14R4.

2.

Nuclear Oversight Committee Guarterly Reports dated January 23, 1484; April 24, 1984; July 31, 1984; and October 22, 1984.

3.

Letters transmitting the Nuclear Oversight Committee meetings and quarterly. reports.

of all letters, memoranda or The following is a listto all members of the Nuclear other documents sent Oversight Cormittee:

1. On a periodic basis the Nuclear Oversightthe following documents Committee members are sent

- Monthly Nuclear Department Reports l - Action Plan Monthly Reports i - Muskrat Line

- NRR Meeting Minutes

- INPO Reports

- SALP Reports

- Bi-monthly presentations to the NRC

- LERs ( f rom January,1983 to present)

- PSE4G response to NOC Ouarterly Reports l

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U Jcnunry 15, 1985 SECTION III, OUES . 63 2.

Besides those documents categorically listed above, the Nuclear Oversight Committee members the following documents by PSE&G:

have been sent Sent to NOC on October 12, 1983:

Management Analysis Company's (MAC) 1.

" Management Assessment and Action Plan for Improvement of Salem Stations 1 and 2 Operations".

2.

DSE&G's " Action Plan for Improvement of Nuclear Department Operations".

" Cross Reference

3. MAC/DSE&G Cross

Reference:

Document Between PSE&G Action Plan for Improvement of Nuclear Departmentand Operations Action and MAC's Management Assessment Plan for Improvement of Salem Stations 1 and 2 Ope' rations".

Basic Energy Te,chnology Associates.

4. BSTA:

Inc. , " Corrective Action Program Related to Reactor Trip Breaker Failures1". at Salem Generating Station Unit No.

5. PSE&G Response to BETA.

6 Corrective Action Program: Corrective Action Summary Reactor Trip Breaker Failures, Salem Generating Station Units 1 and 2.

7 Administrative Controls f or Salem Tech.

Spec's.

8. Charter of the Nuclear Review Board-Revision 6.

Rules of 4 NRC Enforcement Action 10CRF2:

Practice for Domestic Licensing Proceedings.

10 Nuclear Department Monthly Operating Report -

August 1983 (Eckert Report).

Sent to NOC on November 1, 1983:

1. Supplement to Corrective Action program.

Sent to NOC on November 3, 1983:

1. Transmittals Between PSE&G and the NRC Relating to the " Notice of Violations and Proposed Imposition of Civil Densities".

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SECTION _ III, OUES . 63 1983:

Sent to NOC on November 7, first regular NOC

1. Proposed agenda for the 13, 1483.

meeting to be held on December Send to NOC on December 16, 1983:

1. Expense letter form.

2.

Two Nuclear Review Board (NRR) meeting minutes and two Station Operations Review (SORC) meeting minutes.

3. Organizational Entities - Nuclear Safety with Managers identified by name.

Sent to NOC on December 21, 19R3:

1. Simplified Salem Plant Systems One Line Drawings.

Sent to Dr. Gottlieb (Chairman) only on December 30, I 1983:

1. List of PSE&G open commitments:

a. Output of the PSE&G Licensing Commitment Tracking used by the Nuclear Department.

b. Output of the Station Aesponse Tracking System used by Salem Operations.

types.

c. Key for identifying document Sent to NOC on February 28, 1984:

1. NRC combined inspection report 50-272/Al-20 i and 50-311/83-31.

! 2. Copy of PSE&G's response to above mentioned report.

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3. Proposed agenda for the second regular NOC 1984 meeting to be held on March 12 and 13, Sent to NOC on March 6, 19R4:

1. Performance Indicatorindicator Information Table and samples.

various performance l

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SECT G:1 2 1, OUES. 63 Sent to NOC on April 3, 1984:

1. Letter given to Lisa Salomon requesting that the NOC members be put on direct distribution of news releases of PSE&G's nuclear operations (Muskrat Info Line).

Sent to NOC on June 4, 1984:

1. Agenda for third regular NOC meeting to be held on June 11 and 12, 1984.,

Sent to E. D. Wilkinson on June 14, 1984:

1. Letter sent to E. P. Wilkinson from R. A.

Uderitz welcoming him as an active NOC member.

Sent to NOC on July 30, 1984:

1. Report of Unit 2's reactor trip / safety injection which occurred on July 25, 1984.

Sent to NOC on August 9, 19R4:

. 1. Proposed agenda for the fourth regular NOC meeting to be held on September 6 and 7, 1984.

Sent to NOC on September 5, 1984:

1. Ag'e nda for the fourth regular NOC meeting to be held on September 6 and 7, 1984.

Sent on September 13, 1984:

1. Agenda and minutes of the June 12, 1984 Manager's Dialogue Session (reference Action Plan 2.1.5.)

2. An overview of PSEAG Technical Oualificatons and Management Capability in Support of the Operations of Hope Creek Generating Station.

3. Status Report - Resolution of itens of concern in Action Plan Activity 2.5.2.4.

4. PSEAG's Response to Recommendations from INPO's Corporate Assistance Visit - 1484.

Sent to NOC on netober 17, 1984:

1. Memo, dated August 21, 1984, from M. Lamh and S.R. Lamb to R. M. Eckert et al addressing resolution of Public Affairs matrix issues.

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Jcnuary 15, 1985 SECTION III, OUEG 63

2. PSE&G Nuclear Engineering Department System a and Activities Code Responsibilities List.

3. Memo, dated August 29, 1984, from P. M.

Krishna to the Vice President - Nuclear addressing Salem Generating Station Unit 2 Modification associated with the Pressurizer 4

Overpressure Protection System.

4. Draf t copy of the General Physicos report dated May 6, 1983, on Human Factor Review of equipment tagging at the Salem Generating Station. .

Memo, dated May 16', 19R4 from P. M. Krishna to 5.

J. M. Zupko addressing Salem 2 Reactor Trips.

6. List, dated June 19, 1984, of NRB Open Items.

Memo, dated Septembe? 21, 19R4, from P. M.

7 Krishna to distribution addressing Hope Creek FSAR Section 13.4 i.

Sent to NOC on November 23, 19R4:

1. Response to SORC open iteas ' ( 84-047R) - Steam Generator level control at low power operation.

2. An overview of how the Implementation Board for DCRs/DCPs will work.

3. Drawing depicting outline of 14 inch, 304_

Stainless Steel Holding Ring flow nozzles used in the feedwater piping.

in

4. Graph of DCRs and DCPs depicting their age the design change process.

Sent to NOC on November 28, 1984:

1. Action Plan 2.4.3 status report.

2. Action Plan 2.4.5 status report.

3. Action Plan 2.2.1 status report.

4. Action Plan 2.2.2 status report.

3. Letters transmitting the documents listed in items 1 and 2.

O SECTION III. MANAGEMENT COMPETENCE: INTERROGATORIBS INTERRORATORY 464: Identify and describe how the

" Licensing and Reliability organization is structured to provide a coordinated review, evaluation, and communication of outside lessons learned to appropriate personnel within each of the nuclear facilities." Identify all documents related to this process.

RESPONSE: See Hope Creek FSAR, Chapter 13 and VPN Procedures, previously submitted.

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INTERROGATORY 965: State whether PSEEG has " evaluate (d) the necessity to continue the (Nuclear Oversight) committee as part of the Company's nuclear safety review program,"- rs stated in the NOC Charter. If so, state the result of this evaluation and identify all related documents.

RESPONSE: PSE&G extended the term of the Nuclear Oversight Committee (NOC) to necember, 1985.

During 1985 PSE&G will evaluate the necessity to continue the NOC as part of the company's Nuclear Safety Review Program.

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O INTERROGATORIES SECTION III. NANAGEMENT COMPE"rENCE:

INTERROGATORY 866: State whether the " term" of the NOC has been extended beyond the one year minimum contained in the NOC Charter. Also, identity the end of the current term of the NOC, and list all presently scheduled future meetings.

RESPONSE: The term of the NOC is presently scheduled to terminate December 31, 1985. Meetings of the NOC are presently scheduled as follows:

March 11, 12 June 11, 12 September 9, 10 December 9, 10 I

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O SECTION III. MANAGEMENT COMPETENCE: INTERROGATORIES INTERROGATORY 471: State whether you have developed any plan concerning the tension between operational responsibilities and Action Plan responsibilities. If so, describe all such plans.

RESPONSE: Normal and prudent PSE&G management practices, including the allocation of adequate resources, have insured that any problems related to the tension between operational responsibilities and Action Plan responsibilities are addressed as they arise and on a case by case basis.

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72. State whether the Nuclear Department has developed "a set of safety-related items which are measureable periodically and which can be employed to evaluate overall plant safety by comparison with past experience and prescribed goals" as recommended by the NOC at its '

December 13, 198 4 meeting. If so, describe all such

" safety-related items" and identify all documents relating to their development and implementation.

RESPONSE

Yes. Refer to performance indicators identified in the VPN Procedures and Nuclear Department Monthly reports previously submitted.

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III. MANAGEMENT COMPETENCE: IF.'ERROGATORIES 73.

Description:

Identify each PSE&G employee currently assigned to or stationed at Hope Creek who was assigned to or stationed at Salem on February 22 or 25, 1983. For each such employee, identify (a) his or her current job title and responsibilities; (b) his or her job title and responsibilities on February 22 and 25, 1983; and (c) all job-related training he or she has received in the intervening period.

RESPONSE

The current job titles and responsibilities, job titles and responsibilities on February 22 and 25, 1983 and all job-related training received in the intervening period is supplied for each PSE&G employee currently assigned to or station at the Hope Creek Generating Station who was assigned to the Salem Generating Station on February 22 and 25, 1983 in the documentation provided in response to request.for documents. Job responsibilities are described in AP SA-AP.22-002 (Q) ,

which has been previously submitted and in the PSE&G Job Specifications Manual provided with response for production of documents.

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(_ / . l THIRD SET OF INTERROGATORIES MANAGEMENT COMPETENCE INTERROGATORIES SECTION III, ITEM 74 DESCRIPTION:

Identify each PSE&G employee currently assigned to or stationed at PSE&G's Nuclear Department Corporate Offices who was assigned to or stationed at the Salem Generating Station on February 22 or 25, 1983. For each, identify: (a) his or her current job title and responsibilities; (b) his or her job title and responsibilities on February 22 and 25, 1983; and (c) any job-related training he or she has received in the intervening period.

RESPONSE

The current job titles and responsibilities, job titles and responsibilities on February 22 and 25, 1983 and all job-related training received in the intervening period is supplied for each PSE&G employee currently assigned to or stationed at the Nuclear Department who was assigned to the Salem Generating Station on February 22 or 25, 1983 with the responses to the request for production of documents.

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\J III. MANAGEMENT COMPETENCE: INTERROGATORIES

75. Identify by name and job title all individuals who provided information for or participated in the drafting, editing or review of your responses to Intervenor's Second Set of Interrogatories and Request for Production of Documents.

RESPONSE

R. A. Burricelli General Manager - Nuclear Engineering C. P. Johnson General Manager - Nuclear Quality Assurance 5

J. H. MacKinnon General Manager - Nuclear Safety Review H. J. Midura General Manager - Nuclear Services R. S. Salvesen General Manager - Hope Creek Operations J. M. Zupko General Manager - Salem Operations J. D. Driscoll Assistant General Manager - Nuclear Joint Owners and Regulatory Affairs D. J. Jagt Assistant General Manager - Nuclear Engineering S. LaBruna Assistant General Manager - Hope Creek Operations L. A. Reiter Assistant General Manager - Hope Creek Transition R. E. Gehret Manager - Methods and Systems H. D. Hanson Manager - Nuclear Training L. L. Kammerzell Manager - Nuclear Licensing and Reliability E. A. Liden Manager - Nuclear Licensing and Regulation S. M. Kosierowski Personnel Affairs Manager - Nuclear

(~N, III. MANAGEMENT COMPETENCE: INTERROGATORIES

75. RESPONSE : (CONTINUED)

W. C. Bibb Program Director - Action Plan Implementation P. M. Krishna ,

Nuclear Review Board Manager A. J. Tudury Secretary - Nuclear Oversight Committee B. E. Hall Safety Review Group Head W. R. Schultz Programs and Audits Engineer M. Rosenzweig QA Engineering and Procurement Engineer E. Witkin QA Controls Engineer H. Gross Senior Engineer B. W. Smith Associate Engineer G. E. Lipscy Outage Coordinator u.

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L) 1 III. MANAGEMENT COMPETENCE: INTERROGATORIES

= 7 6. Identify by name and job title all individuals who provided information for or participated in the drafting, editing or review of your responses to Intervenor's Third Set of Interrogatories and Request for Production of Documents.

RESPONSE

R. A. Burricelli ,

General Manager - Nuclear Engineering C. P. Johnson General Manager - Nuclear Quality Assurance J. H. MacKinnon General Manager - Nuclear Safety Review H. J..Midura General Manager - Nuclear Services R. S. Salvesen i General Manager - Hope Creek Operations J. M. Zupko General Manager - Salem Operations S. LaBruna Assistant General Manager'- Hope Creek Operations L. A. Reiter Assistant General Manager - Hope Creek Transition L. L. Kammerzell Manager - Nuclear Licensing and Reliability I

E. A. Liden Manager - Nuclear Licensing and Regulation l

S. M. Kosierowski

. Personnel ~ Affairs Manager - Nuclear W. C. Bibb Program Director - Action Plan Implementation P. M. Krishna Nuclear Review Board Manager

, A. J..Tudury Secretary - Nuclear Oversight Committee B. E. Hall

Safety Review Group Head '

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III. MANAGEMENT COMPETENCE: INTERROGATORIES

76. RESPONSE: (CONTINUED) -

D. A. Perkins Station QA Engineer - Salem W. R. Schultz Programs and Audits Engineer B. W. Smith Associate Engineer A. M. Ervin Lead Engineer J. Rupp ,

LER Coordinator l

T. G. Busch l Technical Engineer - Hope Creek Operations E. D. Yochheim Chemistry Engineer - Hope Creek E. L. Meils Senior Engineer - Nuclear Energy Consultants J. A. Nichols Technical Engineer - Hope Creek R. B. Cowles

, Engineer - Hope Creek l

L. D. Vreeland Office Staff Assistant - Hope Creek R. Donnellon Lead Plant Engineer - Stone & Webster

. L. A. Byrne Action Plan Coordinator T. G. Hersum Action Plan Coordinator H. E. Lamb Organizational Development Consultant S. R. Lamb Organizational Development Consultant s