1. 1 CMBG 2009 PSEG Nuclear Vendor Technical Document Program Deficiencies, Successes, and Cost Savings Presented By: Paul Davis PSEG Nuclear, Engineering Services – Configuration Management

2. 2 CMBG 2009 PSEG Nuclear Salem Unit 1 PWR 1,228 MWe Salem Unit 2 PWR 1,216 MWe Hope Creek BWR 1,268 MWe

3. 3 CMBG 2009 Background As a result of the Feb 1983 Salem Anticipated Transient Without Scram (ATWS) event, PSEG Nuclear was committed, via response to NRC Generic Letter 90-03 and Salem/Hope Creek UFSARs, to the maintenance of Vendor Technical Documents (VTDs) associated with certain key safety-related equipment. The PSEG Nuclear VTD Program consists of two elements: Recontact program and “Daily” program. –The Recontact program maintains the requirements of GL 90-03 (periodically contact vendors of key safety related equipment and a program with Nuclear Steam Supply System (NSSS) vendor to cover all safety-related components within the NSSS scope of supply). –The Daily program maintains the safety related documents not required in GL 90-03 and non safety- related documents (everything else).

4. 4 CMBG 2009 History Feb 22, 1983 – Salem ATWS event July 8, 1983 – Generic Letter 83-28 Mar 20, 1990 – Generic Letter 90-03 May 14, 1990 – Generic Letter 90-03 Supplement 1 Oct 7, 1992 – Generic Letter 83-28 Supplement 1 Mar 1996 – PSEG formed a Vendor Engineering Group Nov 2005 – Elimination of Vendor Engineering Group IAW the Exelon OEM Aug 2008 – Nuclear Oversight (NOS) audits program – finds three areas of concern

5. 5 CMBG 2009 What Happened As a result of the implementation of the Exelon model, starting in 2005, the Vendor Engineering Group was eliminated and its functions were not turned over to Vendor Document Coordinators (VDCs), SMEs, and System Managers. NOS identified the VTD Program as an Area Requiring Management Attention (ARMA) based on the aggregate of three issues.

6. 6 CMBG 2009 Issues 1.Vendor recontact documents have not been updated in a timely manner when Subject Matter Expert (SME) reviews are required. 2.Several vendor recontact documents were closed in SAP with “no action required” when they actually required SME reviews to satisfy procedural requirements and GL 90-03 requirements. 3.The Engineering Services Director has not assessed Vendor Information Services (VIS), the vendor that performs the recontact program activities, every two years to ensure program compliance in accordance with VTD procedure.

7. 7 CMBG 2009 Upon Further Investigation… 1.The Salem FSAR still stated we would interface with vendors for EVERY safety-related component. 2.Review (again) of key-safety related documents showed not all documents are required to be in the program. 3.The Vendor Engineering Group had been updating “Daily” VTDs with parts lists, Bills of Material, catalog information, Certificates of Conformance, and other material not related to vendor instructions. 4.One vendor publication may be part of multiple VTDs. For example, pub XYZ is part of multiple VTDs and therefore, every pub revision would require multiple VTD revisions.

8. 8 CMBG 2009 Fixes Revised Procedure Created “Desk Guides” on how to administer and evaluate documents in the VTD Program Updated the Salem UFSAR to state Key vs. All Station Management ownership Eliminated unnecessary document updates Reviewed all documents in the Recontact program and eliminated documents that are not required Created department PIs Audited recontact vendor Changed vendor audit frequency from two to three years (to align with contract) Added VTD Program to Corporate Self Assessment schedule

9. 9 CMBG 2009 Benchmarking October 2008, a VTD benchmarking questionnaire was sent to the CMBG contacts database list While the questionnaire was geared towards staffing, basic VTD “demographics” was asked 17 Utilities, 21 sites responded 7 sites had 1 FTE administering the program, 5 sites had a VTD group The number of documents in recontact program varied between 35 and 4,400 (average of 538)

10. 10 CMBG 2009 Cost Savings Do a Self Assessment of your program –Prevents any findings from INPO, NRC or your QA Department Review document updates for unnecessary updates –PSEG Nuclear eliminated 65% of the items sent to the document coordinator Review documents in your recontact program –PSEG Nuclear eliminated ~ 15,000 documents from the program in 2003. This resulted in a $375,000 annual savings. –PSEG Nuclear eliminated an additional 10 documents from the program in 2008. This resulted in a $850 savings. If possible, maintain only one publication in one Vendor Document –Reduces updated time and administrative processing and time

11. 11 CMBG 2009 Cost Savings (continued) Compare your program to the generic letter and your companies response to the NRC. –PSEG Nuclear was just removing any document from vendors that went out of business or were unresponsive – now have to review 145 documents that were removed. Utilize a vendor to do your recontacting. –Vendors charge a flat fee (between $85-$100 per document) and supply a comparison report. –Vendors have all of the equipment manufactures contact information –Vendors know who bought who –Vendors have a rapport with equipment manufactures Update your recontact documents in a timely manner –If you use a vendor to do your recontacting, they may recontact the same document if not updated within three years.

12. 12 CMBG 2009 OE As a result of numerous company buyouts and mergers, it is now recommended to re-re-contact vendors of documents whose policies may have changed. Specifically, those vendors who stated that their publications: –are not subject to revision and should be used for the life of equipment OR –may be revised but revision provided with equipment at time of purchase should be used for the life of equipment

13. 13 CMBG 2009

14. 14 CMBG 2009 Advertisement CM Café 1 Vendor Technical Information Library Room 13:00-16:30 (1:00-4:30)

15. 15 CMBG 2009 Questions Questions? Paul Davis PSEG Nuclear 856-339-1689 paul.davis@pseg.com