IR 05000272/1988099

Final SALP Repts 50-272/88-99 & 50-311/88-99 for Jan 1988 - Apr 1989

ML18094A714
Person / Time
Site:	Salem
Issue date:	09/25/1989
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18094A713	List: IR 05000272/1988099 IR 05000354/1988099
References
50-272-88-99-01, 50-272-88-99-1, 50-311-88-99, NUDOCS 8910020201
Download: ML18094A714 (33)

Text

FINAL SALP REPORT U. S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT NO. 50-272/88-99; 50-311/88-99 PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM GENERATING STt.TION DPR-70 AND DPR-75 Enclosure 2 ASSESSMENT PERIOD:

JANUARY 1, 1988 - APRIL 30, 1989

SUMMARY OF RESULTS III.A Overview The Salem units continued to operate in a safe manner during the assessment period, however a notable decline in overall licensee performance occurred when compared with the previous assessmen This was exhibited by an increase in the number of reactor trips and safety system challenges. Specifically, personnel errors, procedure implementation deficiencies, and inadequate supervisory oversight resulted in weaker performance in several functional area In contrast, excellent performance continued in the security are In Operations, plant transients caused by personnel and procedural errors were more frequen Weaknesses in supervisory oversight and procedure control were note Root cause determinations were sometimes weak with regard to potential operator error A decline in ear~y in the procedure performance r~diation protection and industrial safety SALP period, despite a significant upgrade Enhanced training and management oversight at the end of the assessment perio performance occurr~d in radiation control resulted in improved Maintenance performance also declined early in the period due to lapses in oversiyht and procedural control Licensee corrective actions during the SALP period resulted in a substantial improvement tren Personnel errors and program deficiencies persisted in the Surveillance area despite significant licensee efforts to resolve these weaknesse Although the program was basically sound, the inability to promptly resolve these weaknesses was noted as a concer In Emergency Preparedness, a strongly supported program was also note However, performance in the annual exercis~ declined and correction of a long standing deficiency in the Salem Technical Support Center was not aggressively pursued to resolutio Licensee initiatives to improve the quality of Engineering and Technical* Support

.were effective but implementation problems persisted during the transition to*

new program A significant decline in Quality Verification efforts was note Inconsistent performance and reduced expectations.resulted from a lack of management focus and supervisory oversight in some area The effectiveness of corrective action programs was inconsisten Overall, the licensee identified these declining performance trends and took corrective actions to resolve most of the concerns during the perio The Salem station appears to be in a pivotal period in the licensee's attempt to upgrade the programs and standards at the unit The NRC encourages the licensee's initiatives to review and self-identify program weaknesses and supports the pursuit of excellence throughout Artificial Islan It appears, however, that continued management focus and attention is warranted to insure that these standards have been accepted and implemented at all levels throughout the Salem organizatio,*

-5-II Facility Performance Analysis Summary Functional Area Plant Operations Radiological Controls Maintenance/Surveillance Emergency Preparedness Security Engineering/Technical Support Safety Assessment/

Quality Verification Last Period (10/1/86-12/31/88)

,

2 1/2*

1

1/2**

Rated as separate fun~tional area This Period (1/1/88-4/30/89)

• 3

2

l

2 Trend Improving

Similar areas (Assurance of Quality, Category 1 and Licensing Activities, Category 2) were assessed last perio III.C Reactor Trips and Unplanned Shutdowns Unit 1 Event Description Power Date Level Root Cause Functional Area The reactor tripped automatically on high flux while adjusting a nuclear instrument detecto A technician performed procedur~ steps out of sequence and failed to bypass the output trip signal before pulling the channel fuse *

2/24/88 4%

Personnel Error Survei 11 ance - The reactor was tripped manually after the turbine governor valves began to drift shut due to loss of control oil pressur Operators failed to properly diagnose a previously annunciated turbine control oil reservoir low level alarm, which resulted in the loss of both control oil pump /30/88 100%

Personnel Error Operations A 15-day unplanned shutdown commenced following the 3/30/88 trip to replace 1eaking (about 110 gpd) steam generator (SG) tube plug /30/88 0%

Component Failure NA The reactor tripped automatically on turbine trip during on-line surveill~nce testing of the turbine trip mechanis /31/88 100%

Unknown NA The reactor tripped automatically on low SG level due to operator failure to select an alternate controlling steam pressure channel during surveillance testin /6/89 100%

Personnel Error Operations An unplanned shutdown was made due to a component cooling water leak in the supply line* to a reactor cool ant pum /15/89 100%

Component Failure NA The reactor tripped automatically on turbine trip because a technician failed to follow the surveillance test procedur The initial conditions for performance of a turbine impulse pressure functional test were not met prior to proceeding with the surveillance activit /18/89 0%

Personnel Error Surveillance An unplanned shutdown was made due to high combustible gas concentrations in the main power transformer oi Confirmed transformer degradation caused an early start of the refueling outage scheduled for 4/15/8 /23/89 100%

Component Failure NA

Event Description Power Date Level-7-Unit 2 Root Cause Functional Area _The reactor tr.ipped automatically on low loop flow because a technician did not follow the procedure for restoring a reactor coolant loop flow transmitter to servic The transmitter valving manipulations were performed out of sequenc /21/88 100%

Personnel Error

• Surveil 1 ance The reactor tripped automatically on turbine trip due to high SG water.

leve Turbine control equipment problems and/or inappropriate operator response contributed.to the high SG leve /22/88 18%

Unknown NA The reactor tripped automatically on high power range negative flux rat One control rod dropped into the reactor core while inserting rods to reduce power for a surveillance test, 5/13/88 97%

Unknown NA The reactor tripped automatically and safety injection actuated due to spurious initiating signals generated when the 11 C 11 vital instrumer.t bus inverter faile The non-redundant engineered safety features sensor power supply design contributed to the even /22/88 100%

Component Failure Engineering The reactor tripped automatically due to a spurious trip signal caused by the loss of vital instrument bus inverter 11C 11 *

7/30/88 80%

Component Failure Engineering The reactor tripped automatically on high SG level due to a failed open feedwater control valv The control valve positioner had become disconnected, due to vibration in combination with a poorly designed lockwashe /31/88" 72%

Component Failure NA The reactor tripped automatically on low SG leve Inadequate procedural guidance resulted in improperly setting the control air regulator for a feedwater control valve positione The resultant SG level oscillations caused the tri /28/88 25%

Defective Procedure Maintenance

Event Description Power Date Level Root Cause-8-Functional Area An unplanned shutdown was made due to high combustible gas concentrations in the main power transformer oi /9/88 100%

Component Failure NA The reactor tripped automatically on low SG water level due to loss of feedwate Inadequate procedures for operat1on with reduced circulating water capacity and only one heater drain pump caused the loss of both feed pumps due to low suction pressur /5/89 60%

Defective Procedure Operatio.ns 1 The reactor tripped automatically on low SG water level following the loss of vital instrument bus inverter 110 11 *

The inverter control power fuse fell out of its fuse holde A safety injection resulted from spurious actuation signals caused by the loss of inverter powe /12/89 Unknown Engineering 1 The reactor tripped aut0matically during surveillance testing on low SG water level when plant operators did not prevent SG level from reaching the low setpoint with a coincident steam flow channel bistable inoperable and trippe /29/89 0%

Personnel Error Operations 1 The reactor tripped automatically on low SG water level. A latching relay malfunctioned during a main steam bypass valve surveillance test, causing inadvertent closure of a main steam isolation valve and the consequent SG level oscillation /11/89 100%

Component Failure NA

I PERFORMANCE ANALYSIS I IV... Operations Analysis-9-(1437 hours0.0166 days <br />0.399 hours <br />0.00238 weeks <br />5.467785e-4 months <br />, 41%)

Plant Operations was rated as a SALP Category 2 during the previous assessment perio Licensee str~ngths included a strong management team and an improved trip frequenc Personnel error due to inattention to detail and poor interface communications was noted as an area in need of improvemen During the current SALP period there were 16 reactor trips between the two units (five on Unit 1, 11 oq Unit 2), including six trips directly or indirectly attributable to the operations functional are The 16 reactor trips.were m6re than twice as many as during the previous assessment (seven).

The number of trips two SALP cycles ago was 1 The licensee's trip reduction efforts appear to have been ineffective since the last SAL The root causes of the reactor trips were consistent with overall performance concerns at Salem including personnel errors and procedure implementation deficiencie Personnel errors resvlting from failure to follow procedures and inattention to detail ~esulted in six reactor trips during the assessment.perio Three of these -involvea operations personne Three Technical Specification (TS)

surveillances were missed or late due to personnel error by operations personnel and inadequate supervisory revie On two occasions operators failed to enter TS Action Statements as require Two additiQnal examples of operations p~rsonnel errors included failure to follow a survei.1lance procedure, which resulted in blackout loading on a vital bus, and poor communication between operations supervisors, which resulted in fuel handlin with the fuel building ventilation inoperabl In response to these issues, the licensee has placed additional supervisors on shift during outages and has counseled Operations Department supervisors concerning better o~ersight and responsibilit However, since personnel errors have continued to occur, further management attention is needed in this are Operations management did not always provide adequate guidance to the operators relative to non~routine situation Inadequate direction for operations support of maintenance activities resulted in a diesel generator

~ay tank being overfilled and an NRC identified misalignment.of a service -

water header chloride inlet valv In addition, prompt actions were not

• implemented by operations management relative to a Station Operations Review Committee (SORC) directed action for a non-seismic diesel generator fire protection relay, and the tracking of steam flow channels which were drifting non-conservativel NRC and station management involvement was needed to ensure correction of these deficiencie In order to address the shortcomings in the conduct of day ~o day rciutine plant evolutions, increased management oversight is needed in the operations area to ensure that adequate procedural guidance is established when appropriaie, arid procedures are followe Deficient procedures contributed to two reactor trips, one in the operations are One TS surveillance was missed due to an inadequate operations

-10-procedur The licensee has instituted a procedure upgrade program and a work standards improvement program in response to NRC concerns relative to personnel error and procedure problem However, the programs appeared to have been focused mainly on maintenance and surveillance activitie Administrative control of proceduras and documents in the control room.needs improvement, in that examples of wrong Technical Specjfication pages, misfiled*

documents, missing procedures, an incorrect procedure revision, and inaccurate reference material were identified during the SALP perio Each of these deficiencies was corrected and QA revie~s of control room files, procedures, and materials were periodically performed to identify additional deficiencie Additional management action is needed in this a~ea because deficiencies in the control of documents in the control room continued to be identifi.e Staffing in the Operati6ns Department was adequate and programs ~er~ in place to maintain and enhance staffing levels for both licensed and non-licensed operator A five shift operator rotation is in effect at each uni Control room professionalism was generally goo Although numerous ex~mples of perso~nel. error and inattention to detail occurred during routine operation, immediate operator response to reactor trips and implementation of emergency operating procedures was very goo Reactor startups and shutdowns were generally well controll~d and superv4se Licensee event and pi*vblem evaluation and response was usually prompt and

.comprehensiv However, the root cause of four reactor trips was not determined by the license Certain self assessments and root cause jnvestigations have been weak, {n that the level of aggressiveness with whic iisues were pur~ued decreased when a concl~sive root cause for a trip or equipment problem was not determined within a short period of tim In some cases, root.cause investigations were incomplete because operations management was reluctant to accept responsibility for possible operator errors, and this aspect was not pursued as aggressively as possible equipment deficiencie On several occasions* unit restart was authorized based on the replacement of suspect components or the completion of actions based on supposed problems, without substantive evidence that. all possible causes had been identified or would be resolve Examples include a turbine electro-hydraulic control (EHC)

rate amplifier card which was replaced even though it tested satisfactorily, and a separate occasion where actions were taken to clean and monitor pressure in the turbine auto stop oil system in response to a supposed, one-time momentary clog in the syste Further instances of slow or weak root cause evaluation, related to two reactor trips and loss of a safety-related 4 KV electrical bus late in the period, prompted a violation and an NRC request for further information from the licensee regarding circumstances surrounding the event Continued management focus on root cause determinations is neede Initial license exams were administered to two SRO and three RO candidates

~uring the SALP pefio Of this group, one SRO faile Requalification exams were taken by eight SROs and four RO Of this group, one RO faile EDP usage weaknesses identified during the requalification program evaluation were promptly correcte The licensee's operator requalification program was upgraded to a satisfactory rating during the SALP perio The licensee has begun control room human factors modifications which are

-11-planned to be installed over a three refueling outage period for each uni The licensee has taken a conservative approach to minimize the chance of operator error due to control room differences by assigning licensed reactor operators to specific unit In response to an NRC concern, operations management took action to develop a written plan to define the actions necessary to indoctrinate licensed operators on the opposite unit if a need fqr reassignment should aris Daily status and planning meetings were well structured, thorough and concis Meaningful exchanges of unit status, identified problems and scheduled evolutions took plac The operations department prioritized work based on plant needs and the planning and maintenance organizations responded accordingl The work control center coordinated activities between the support groups and operations department to facilitate removal and return of systems and equipment to servic Toward the end of the assessment period, equipment outage duration and operational priorities were discussed and emphasized at planning meetings to ensure proper coordination between departments and timely return of equipment to servic The quality of housekeeping in the station was inconsistent during the SALP period and was directly related to the level of management attention and emphasis on housekeeping matter The licensee's Fire ~rut8ction Program was well staffed and maintaine The persons in charge of the program were competent and received considerable corporate management backing in their effort to improve the progra Evidence of the-management support was the recent purchase of state of the art firefighting equipmen The licensee has addressed NRC concerns in the safe shutdown and fire protection areas, for example the work to upgrade fire barriers is proceeding expeditiousl Limited examples of late firewatch patrols and missed fire protection surveillances due to inadequate administrative controls or communication within or between the operations and fire protection departments occurred during the perio Increased fire protection management attentio~ has been effective in preventing similar occurrences in the latter part of the assessment perio In summary, weaknesses were identified in operations in the areas of supervisory oversight of routine day to day operation The number of plant trips and frequency of personnel errors have increased since the previous SALP

£ycl Operations management did not always provide adequate guidance to the operators for non-routine evolution Procedure establishment, use and compliance require continued station management attentio Some root cause analyses and corrective action determinations lacked aggressiveness and thoroughness especially in cases relating to possible operator error The licensee has instituted actions to improve performance in these areas with mixed result Operator response to plant transients was very goo The planning and work control processes were noted as strengths as was the fire protection progra IV. *Performance Rating Category 3

..

-12-IV. Recommendations Licensee: Present to NRC Region I, the license~ assessment of corrective actions needed to reduce challenges to safety systems and improve the analysis of plant event NRC:

Conduct an Independent Performance Assessment Team Inspectio I IV. Radiological Controls Analysis (503 hours0.00582 days <br />0.14 hours <br />8.316799e-4 weeks <br />1.913915e-4 months <br />, 14%)

This area was rated Category 2 during the previous assessment perio Identified weaknesses included procedure quality and implementation, the adequacy of the chemistry QA/QC program and*the corrective action syste Strengths included ALARA planning and relationships between radiation protection personnel and other department There were two_outages which challenged the radiological controls program this assessment perio NRC observations during the first outage, the Fall 1988 outage at Unit 2, identified a number of significant problems which prompted enhanced NRC a~t~ntion to this functional are OVer~ll licensee response to the identified problems was aggressive and timel Specifics regarding the problems identified. and licensee actions taken to improve performance during the Spring 1989 outage at Unit 1 are discussed in this assessmen During the current assessment period, the licensee addressed procedure quality by revising 44 existing procedures and w~iting 20 new one This initiative addresses a long-standing concern relative to procedure adequac The new procedures were improved in quality and usefulness and resolved NRC's major concerns with procedure adequacy prior to beginning the Unit 2 refueling outag Implementation of these procedures was weak during the Unit 2 outage (September 1988 to November 1988).

This problem was attributed to ineffective training in the new pro~edures, weak communications, and inattention to detail by both supervisors and technician In response to the concer~s identified during the Unit 2 outage, management ensured that both licensee personnel and contractors were properly trained in the new procedures prior to the scheduled Unit 1 outage in March 1989. The licensee augmented its ~6utine radiological controls training and qualification program with a special six week training program, which enhanced the routine progra In addition, management stressed the need to adhere to the new procedure These efforts resulted in significant improvements in procedure implementation during the Unit 1 outag NRC inspection of Unit 2 outage activities identified weaknesses in th adequacy of corrective actions for radiological occurrences, a problem previously identified by the station QA grou An example of a weakness that was identified by the licensee and not effectively resolved involved problems in High Radiation Area access controls. Further, there was little evidence that major weaknesses identified in the field by the Radiological Assessor during the Unit 2 outage were being acted upo The NRC inspection also

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-13-identified that supervisory oversight of on-going Unit 2 outage activities was weak as evidenced by radiation protection technician and radiation worker performance problem To address these concerns in preparation for the Unit 1 outage, radiological protection management personnel changes were made and the in-plant radiological controls group was reorganized following completion of the Unit 2 outag In addition, plant management initiated weekly meetings to discuss radiological occurrences, Radiological Assessor findings, Industrial Safety concerns and Quality Assurance finding NRC observations during the Unit 1 outage indicated the licensee's actions were effective in improving the supervisory and management oversight of outage radiological controls activities and the management and resolution of radiological occurrences and Radiological Assessor finding No significant external radiological controls concerns were identified during the Unit 1 outage, including during steam generator work-.

The program to minimize airborne radioactivity for generator work was particularly noteworth Control and minimization of contaminated areas and contamination was good and allowed personnel to perform work on the steam generator platforms without the need to wear respirijtory protection equipmen Problems continu~d to exist during the SALP period in the area of worker practices relative to housekeepin For example, candy wrappers were observed in the radiological controlled areas indicating a lack of worker and supervisory sensitivity to potential ingestion of radioactive materia Housekeepiny was considered poor throughout the radiological controlled areas of the facility due to inattention to and lack of accountability for housekeepin Observations toward the end of the period indicated some improvement in the areas that have received management attention such as containment, but problems continued to exist in the auxiliary and fuel handling building NRC review during the Unit 2. outage identified significant industrial safety concerns involving prevention of heat stress and work control measures for high elevations, and prompted a special review by the.Occupational Safety and Health Administration (OSHA).

OSHA subsequently took enforcement actions for the observed problem NRC review during the Unit 1 outage indicated-improvement in the areas of concer In general, over the assessment period it appears that the quality of audits, surveillances and assessments was improvin The licensee has initiated a performance based surveillance progra The licensee has also begun to use outside technical specialists to enhance audit performanc The audits, in conjunction with self-assessments by the Radiological Assessor, are now considered effective in identifying problem A number of problems were identified relative to the maintenance of the post-accident sampling system, indicating lack of attention to this important syste Repeated NRC involvement was needed to focus licensee attention on this concer Consistent with the last assessment period, a generally effective ALARA program is maintained and implemente Station aggregate exposure compares

• favorably with industry average Performance is close to industry best percentiles. Aggressi¥e oversight and control of major exposure tasks was note A number of actions were taken to improve long term ALARA performanc Special shielding was used during steam generator maintenance which reduced exposure dose rates by about a factor of Dose reduction actions that could reduce aggregate exposure over the life of the facility are aggressively pursue Fuel performance has'been goo Radiological controls personnel were recently assigned to the planning and scheduling department to evaluate work packages and interface.between work groups ahd the radiological -controls grou A new ALARA group was recently establishe This has provided for *

improved ALARA plannin Isolated problems were noted in individual work group perfqrmance. *For example personnel were observed sianding in about a 100 mR/hr field waiting for tools to disassemble the reactor vessel head shrou The problem indicates potential concerns with some supervisors and workers regarding sensitivity to ALARA and a need for more attention to ALARA trainin Radiologiral confirmatory measurements inspections indicated good per*form;ince by the licensee in this are~. The review of the radiological environmenial monitor~ng program (REMP) indicated ah adequate program was in plac Performance during the last assessment period in the area of solid radioactive waste and transportation was considered effective.* Two violations involving failure to perform an audit and failure to properly survey a truck cab were i~entified during this SALP perio These violations were considered to be isolated and were not iridicative of a programmatic proble In summary, early in the assessment period licensee performance declined from that noted iri the previous SAL Licensee corrective actions and self-assessment processes were initially ineffective in improving overall performance which prompted NRC involvement to stress the need to initiate effective program improvemen Subsequent management attention has resulted in significant performance improvement, as noted during the Unit 1 outage late in the perio Performance was adequate in the areas of radioactive effluent controls and monitoring, radwaste transportation, and good in the area of radiological confirmatory measurements. *

IV. IV. I IV. Performance Rating Category 2 Recommendations None Maintenance/Surveillance ( 648 hours0.0075 days <br />0.18 hours <br />0.00107 weeks <br />2.46564e-4 months <br />, 18%)

Analysis

-15-The last SALP assessment rated the maintenance functional area a Category 1 and the surveillance functional area a Category Generally strong performance was noted in both areas, with missed surveillances due to personnel error and inconsistent implementation of the instrument and gauge calibration program identified as weaknesse Maintenance:

During this assessment period there was a reduced level of maintenance management involvement and supervisory oversight in day to day activitie This resulted in a laxness with respect to implementation of the maintenance progra Procedure implementation deficiencies were identified including the failure to establish adequate maintenance procedures for disassembly, cleaning and preparation for removal"of an emergency diesel generator, the failure to have safety related pump alignment procedures at the work location while the maintenance was being performed, and storage of transient equipment contrary to administrative procedure Poor maintenance practices such as use of information only drawings, work performed outside the scope of that specified on the work order, and deficient radiological controls and housekeeping related to mainter1~nce activities were observe Inadequate documentation of troubleshooting activities was identified as a weakness in the licensee 1 s program, in that as foun'i data was not recorded in some cases, and problem resolution was delayed due to activities being repeated since detailed documentation of previous work performed was not availabl Return of safety-related equipment was not aggressive in a)l cases, in that, equipment was not promptly returned to service following mcintenance unless the action statement would *soon expir Inattention to detail in the proper execution of maintenance activities resulted in failures of operational retests and maintenance rewor Examples include leads not reconnected, valve air supplies not restored, and valve limit switch settings not reverified following maintenance/surveillance activitie A new maintenance manager was assigned in November 198 A program to upgrade work practices and supervisory oversight has been institute Station and maintenance management has communicated their expectations relative to acceptable work standards to the engineers, supervisors, and planners during group meeting A continuation of these meetings at the worker level is planned in the near ter The work practices improvement plan consists of work practice standards and procedure use guidelines which include supervisor responsibilities; house-keeping, documentation and safety requirements; and guidance on procedure compliance and attention to detai The structure of daily planning meetings has enhanced communications between operations and maintenance supervisors relative to timely return of equipment to servic Daily planning meetings were effective in communicating management philosophy, including the priority of the operating unit over outage activitie The transfer of work and plant status information between departments, and the scheduling and coordination of activities were generally effectiv Planning

. -16-and prestaging for the refue]ing outage was aggressive during the SALP perio The use of outage shift managers and containment coordinators was a strength, in that this increased level of oversight of outage activities in the field assured that problems were-resolved in a timely manne Mairtenance planning and execution of several major un~chedul~d activities such as the repair of a service water piping pressure tap, replacement of _main power transformers, repair of a component cooling water leak in containment and replacement of containment spray piping were well coordinated and controlle Since the implementation of licensee actions was continuing at the end of the SALP period, full assessment of the effectiveness of these a~tions could not be mad However, an improvement in supervisory oversight and the administrative control and content of work packages has been note Inconsistencie~ with regard to.procedur~ establishment and use.continue to be observe Maintenance personnel are experienced and knowledgeabl Howevef,.

continued management effort in communication and implementation of the work practices improvement plan elementsincluding holding the work force accountable is neede*d. to ensure an improved level of performance in the maintenance are Surveillance:

In the surveillance area, personnel errors involving failure to follow procedures, inadequate supervisory oversight and poor communication continued to be a weaknes~.and resulted in a significa~t number of reactor trios and missed surveillances during the SALP perio Six reactor trips were caused by personnel failure to follow procedur:-es and inattention to detail during maintenan~e/survei.llance activities, three involving maintenanc~ perso~nel. There was an increase in the number of missed or late Technical Specification surveillance tests during the SALP period attributable to personnel errors or poor administrative control This is partly attributable to inaccurate or incomplete information inputs to the computerized maintenance and surveillance tracking system, Managed Maintenance Information System (MMIS).

Several missed TS surveillance tests were identified as a result of increased scrutiny of the surveillance program by the license Dne of these resulted in an emergency TS chang No missed surveillances resulted from maintenance personnel error Missed or late surveillances caused by other station groups such as operations and chemistry are discussed in the appropriate functional area sectio The licensee has initiated several programs to ~nhance surveillance scheduling and tracking and ensure surveillances are completed as require These include the Technical Specification (TS) coordination project instituted to validate the MMIS database and surveillance procedures relative to TS surveillance requirement Several discrepancies including TS surveillances not historically performed or performed at an improper frequency were identified* and corrected as a result of this project. A surveillance coordinator was assigned within the technical department to maintain the MMIS database, to develop, review and issue scheduling information and to monitor

. *

-17-the overdue list in an effort to prevent missed surveillance An upgrade of the gauge calibration program was completed at the end of the assessment perio Procedures to implement and control the Rrogram were being developed. As these corrective ~ctions are being developed and implemented, surveillances have continued to be missed indicating that corrective action implementation was not timely or fully effectiv Continued management attention is needed in this area to ensure timely, effective implementation of corrective actions including proper oversight, scheduling and coordination of surveillance activitie *

In summary, reduced management and supervisory oversight of maintenance activities resulted in a laxness in the implementation of the maintenance progra A new maintenance manager has been assigned and a work practices improvement plan was instituted which resulted in some improvement in execution of maintenance activities late in the perio O.utages were well planned and controlle Personnel errors in the surveillance area resulted in an increase in'the number of reactor trips. Although the missed or late surveillances did not result in safety significant problems, *the long-standing nature oft.he problem and the inability to promptly corv-ect the problem indicates a weakness in management attention to this issu Increased management action is needed to ensure proper 0* 1ersight, scheduling and coordination of survei1lance activitie *

IV. IV. I IV. Performance Rating

"category 2

'Recommendations

• None Emergency Preparedness Analysis (305 hours0.00353 days <br />0.0847 hours <br />5.042989e-4 weeks <br />1.160525e-4 months <br />, 9%)

There is a consolidated Emergency Plan for the Artificial Island complex, including the Salem and Hope creek facilitie Consequently, the assessment

..of emergency preparedness is a combined evaluation of both facilities'

emergency response capabilities.

The previous SALP rated Emergency Preparedness as Category The licensee had demonstrated strong emergency response capability during the Hope Creek-based exercis No exercise weaknesses or areas for improvement were identifie There was no Salem-based exercis The licensee had maintained a strong management*awareness of and commitment to emergency preparednes One weakness was identified regarding the adequacy of the Salem staff response to pager call-in test *

During this assessment period, a Salem based full-participation exercise took place which involved Delaware and New Jerse It included an ingestion pathway response in New Jerse There was no full-scale exercise for Hope Cree Two routine emergency preparedness inspections were conducted and the Resident Inspector observed several training drill :.

During the full-participation exercise two weaknesses were identified by the-NR One weakness involved the fact that the Control Room and Technical Support Center staf~s did not recognize postulated contain~ent failure for an hour and forty minute The other weakness involved a communication problem the Emergency Response Manager did not inform the Emergency Operations Facility staff-that recovery conditions had been attaine In addition, several other areas of lesser significance were identified. *Remedial dr. lls demonstrated effective corrective action for all identified exercise weaknesses with one exception, recognition of containment fail~re, w ch will be evaluated in a future exercis In other areas, corrective attions have been. completed regarding ager call-in respons Managemen~ also responded to NRC concerns and took eps to improve the quality of dose projection calculations and field monitor g technique Sixteen Unusual Events ~UEs) were declared during this ass ssment p~riod:

Licensee response to the events was generally in accor e with proced~res; how~ver; some areas for improvement were identifie Tw similar events at Salem were classified differently (one as a UE and ne n t classified),

indicating inconsistent interpretation and use of ~ assification procedures by the operator The procedures hav ee revised to provide clarificatio On two other occa~ions, inaccur. ~

incomplete information was *provided to the NRC Headquarters Operatic~ Of icer.. A Hope Creek UE was declared 45 minutes after the event had beg

.

nagement recognized the need for corrective action in these cases and r sized to the Senior Reactor Operators the importance of prompt,

~ccur, claration A reorganization placed the Emergency Services Department, which is intend edness Department in the Nuc1ear to nhance corporate involvement in this area as the Nuclear Servi~es ent General Manager (GM) has an operations and emergency responsen..,~1r* ound and has maintained close contact with the emergency preparedness m (EPP).

Corporate management involvement and interest in this area was by the considerable amount of effort by the onsite Vice Presidents d to emergency preparedness issues, including off-site interfaces. Suppo nd cooperation with the states remained at a high leve One new stiff ion, requiring a radiation p~otection background, was added to r

ncy preparednes Two senior reactor operators are to be assigned full It' m to the EPP staf Emergency Preparedness~ ining (EPT) was a co.llaborative effort between EPP and the Training Dep"'tm~nt (TD).

The TD was changing its approach to EPT:

additional trainers are being qualified; a modular methodology based on Job Task Analysis will e used to ensure trainers have an adequate understanding of emergency res nse organization staff needs; and the frequency of weekly:

training drills as been revised to one for each site every two weeks (on a trial basis).

At least three persons were qualified for each position in the Emergency Re ponse Organizatio ee recently affirmed that the Salem Technical Support Center {TSC)~

m TSC per the Salem Unit 2 License, has not met NRC design require-:

egarding ventilatio This is a condition which has existed for eight The licensee committed to resolve the deficiencies by October 198 A During the full-participation exercise two weaknesses were identified by the NR One weakness involved the fact that the Technical Support Center staff did not recognize postulated containment failure for an hour and forty minute The other weakness involved a. communication problem; the Emergency Response*

Manager did not inform the Emergency Operations Facility staff that recovery conditions had been attaine In addition, several other areas of lesser significance were identifie Remedial drills demonstrated effective corrective action for all identified exercise weaknesses with one exception, recognition of containment failure, which will be evaluated in a future exercise.

. In other areas, corrective actions have been comp1eted regarding pager call-in respon~e~ *Management also responded to NRC concerns and took steps to i~prove

• the quality of dose projection calculations and field monitoring technique Sixteen Unusual Events (UEs) were declared during this assessment perio Licensee response to the events was generally in accordance with procedures; howe~er, some areas for improvement were identifie Two similar events at Sa.lem were classified differently (one as a UE and one not classifie_d),

indicating inconsistent interpretation and use of EAL classification procedures by the operator The procedures have been revised to provide clarificatio On two other occasions, inaccurate or incomplete information was provided to the NRC Headquarters Operations Officer:

A Hope Creek UE was declared 45 minutes after the ev~~t had begun.. Management recognized the need for corrective action in these cases and reemphasized to the Senirir Reactor Operators the importance of prompt, accurate declaration *A reorganization placed the lmergency Preparedness Department in the Nuclear Services Department, which is intended to enhance corporate involvement-in this area as the Nuclear Services Department General Manager (GM) has an operations and emergency response background and ha~ maintained close contact with the emergency preparedness program (EPP).

Corporate management involvement and interest in this area was evident by the considerable amount of effort by the onsite Vice Presidents devoted to emergency preparedness issues, including off-site interface Support of and cooperation with the states remained at a high leve One new staff position, requiring a. radiation protection background, was added to emergency preparednes Two senior reactor operators are to be assigned full time to the EPP staf Emergency Preparedness Training (EPT) was a collaborative effort between EPP and the Training Department (TD).

The TD was changing its approach to EPT:

additional trainers are being qualified; a modular methodology based on Job Task Analysis will be used to ensure trainers have an adequate understanding of emergency response organization staff needs; and the freq.uency of weekly training drills has been revised to one for each site every two weeks (on a trial basis).

At least three persons were qualified for each position in the Emergency Response Organizatio The licensee recently affirmed that the Salem Technical Support Center (TSC},

an interim TSC per the Salem Unit 2 License, has not met NRC design require-ments regarding ventilatio This is a condition which has existed for eight year The licensee committed to resolve the deficiencies by October 198 Under the current situation, in the event TSC evacuation is required due to uninhabitability, the Salem TSC staff will relocate to the Hope Creek TS In most areas the licens~e demonstrated a high level of interest and 1nvo-1vement in maintaining emergency response capability:

the licensee had an excellent Rumor Control organization, which could be manned by.about 300 people on two shifts;

~n upgraded route alerting mechanism was develop~d; and a VHS tape was developed to train offsite workers in radiological self-protectio Siren availability was 98.5%.

Ten independent, redundant and diverse offsite communication systems were in plac The Emergency News Center (ENC) was located about 7.5 miles from the site. Although it was not required, an alternate Emergency News Center has been identified and logistics arranged to support activation, if necessar In summary, the licensee.maintained *a good Emergency Preparedness Progra Management remained involved, was reasonably responsive to NRC concerns, and maintained an adequate staff for the Emergency Response Organizatio An effective training program has been maintaine Salem staff performa~c~

during the annual exercise was not at the sa~e high level as that noted in the previous Hope Creek exercise; however, it was acceptabl There were isolated event classification problem Th~ _licPnsee's corrective actions with regard to resolving Salem TSC operability concerns are scheduled to be completed by*

October 198 IV. Performance Rating Rating:

Category 2 IV. Recommendations None I Security

. (209 hours0.00242 days <br />0.0581 hours <br />3.455688e-4 weeks <br />7.95245e-5 months <br />, 6%)

IV. Analysis One security program covers Salem and Hope Creek, and the protected areas and security staffs overla Accordingly, this assessment of security.app 1 i es to both site The previous SALP rated the Salem and Hope Creek security program as Category This rating was largely influenced by management's attention to and involvement in the program, an effective_ self-appraisal program, a clear understanding of NRC security objectives and a good enforcement histor Management's attention to, and involvement in, assuring the implementation of an effective security program remained eviden The licensee was very effective in maintaining good support for the security program from other functional groups at both station Frequent organization i~teractions and good working relationships were apparent from the professional attitude of employees toward the security program, as well as the attention given by the maintenance group to. the prevention and correction of problems with security systems and equipmen As further evidence of management's interest in an effective and quality program, it was -noted that all security shift supervisors, who provide around-the-clock oversight of the contract security force, attended a yearly training course given by the licensee on regulatory and security program requirements and objective In addition, security-management continued to part'icipate in the Region I Nuclear Security Organization and in other nuclear industry groups engaged in nuclear security related matter The licensee also continued to implement a self-initiated appraisal program carried out by security management and supervisory personne Adverse findings ~ere promptly resolved and provided to t~aining personnel to factor into the training program to prevent their recurrenc The appraisal program is in addition to the NRC 1 s,,required annual program audit that is conducted by quality assurance personnel:

The last annual audit was very comprehensive in both scope and dept Audtt findings w~re di~tributed to appropriate management personnel for review, and corrective actions for deficiencies were prompt and effectiv This also demonstrated the li~ensee's desire to implement an effective and quality security progra During this assessment period, the licensee appointed a new site security manager. The new secur1ty manager was promoted from within the existing organization, and the transition ~ent smoothly which was indicative of good planning and effective managemen *

The security force contractor had effective management as was evidenced by continuousonsite contractor management, steps taken to improve the security program (e.g., employee benefits, training aids, and better equipment), and the low turnover of personnel (about 7%).

The contractor also implemented -

changes to its superviso1y structure,- which eliminated duplicate supervisory positions between the licensee and the contracto Staffing of the security organization appeared adequate, as evidenced by a limited use of overtime and a low backlog of wor The installation and maintenance of some state-of-the-art systems and equipment during this period significantly reduced the use of compensatory posts for systems and equipment-failure and, thus, reduced the need for extensive overtim Both the licensee's proprietary supervisors and the contractor's supervisors were well trained and experienced, and exhibited a conservative and positive attitude

-

.toward securit Security force personnel were also well-trained and exhibited high morale and professionalism in carrying out their dutie The lic~nsee's efforts to establish and mai~tain such a professional image for the security force was another indi-cator of the licensee's desire to implement a -

quality security progra It was also reflected by the generally excellent state of cleanliness in all security facilitie The training and requalification program was well developed and carried out by a Training Administrator and two full-time instructor In addition to initial and requalification training, on-the-job performance evaluations were conducted which test the proficiency of individuals on _general and specific security program requirement The on-the-job performance evaluations provided management the ability to review and enhance the performance and job knowledge of security personnel and to correct deficiencies as they were

-21-detecte This was another initiative that was indicative of the licensee's desire to implement an effective progra Several minor deficiencies were identified that were promptly and effectively correcte The licensee's good enforcement record during this period is attributed to management's involvement in the security program, the continuing self-appraisal program, comprehensive annual audits, and the security training progra The licensee submitted three security event reports pursuant to 10 CFR 73.71(c) during the assessment perio One report involved an inadvertent tailgating incident and the other two reports involved security guards who were inattentive to dut The licensee's actions were prompt and effective in each cas During this period, the licensee also developed a program to minimize the recurrence of inattentive guards; the program includes limiting overtime and conducting organized discussions on topics such as proper n u tr i t i o n a n d p hy s i ca 1 f i t n e s s.

'

An NRC Safeguards Regulatory Effectiveness Review (RER) of the Island reviewed the protected area boundary and identified several potential weaknesses associated.~ith the Salem facility due to older equipment that the license~

had planned to replac The licensee was responsive to the RER findinr.s and imp 1 emented short-terr. corrective measures where necessar However, s~vera 1 of the potential weaknesses were readily apparent to members of the RER team and should have been identified and corrected by the security organizatio The licensee submitted one change to the contingency plan under 10 CFR 50.54(p). *This change was made to provide clarification to certain areas in the pla This was indicative of the licensee desire to provide its security force with unambiguous instructio The change was clear and fully described the issue Prior to the submittal of this change, the licensee discussed the change with Region I safeguards personnel at a licensee requested meetin In summary, the licensee continued to implement a highly effective and quality security program for Art ifi ci a 1 Is 1 an Management interest in the program remained evident through its continued support and attention to program need IV. IV. I IV. Performance Rating *

Category 1 Recommendations None Engineering/Technical Support Analysis (274 hours0.00317 days <br />0.0761 hours <br />4.530423e-4 weeks <br />1.04257e-4 months <br />, 8%)

The last SALP rated the engineering support area as Category The assessment identified NRC concerns in management support and overall quality

-22-in the engineering and technical support are The last SALP also indicated that the licensee had initiated some long term corrective actions to address these concern During this SALP period, significant changes within the.engineering department have been effecte These changes are intended to improve engineering's interaction with the station staf They included a project matrix organiza-tion, a new design change control process, and establishing a new relationship between the engineering organization and the plant staf The newly _defined performance based relationship between the engineering (service provider)

organization and the plant staff (client) appeared to work well and increased the effectiveness of engineering support by better prioritization of wor Senior engineers, designated as Project Managers, coordinated and were responsible for design changes and.modifications from inception to completio This concept resulted in enhanced personnel accountability, in improved design change control, and in better project development and implementatio The implementation of the organization and project management concept in the engineering department allowed the licensee to effectively schedule large r.;*Jltid.isciplinary project This approach also allowed the staff to be avail-able through the unit supervisors to work on smaller ;>reject This flexibility combined wi~h the system engineers provided better coverage fur the ent*ire plan The µlant staff involvement in projects was assured by the system engineers and QA personnel on the project tea Examples of tne effectiveness of the changes described above include; recovery from a service water bay flooding event, resolution and prevention of reactor heid penetration leaks in both units, and resoluti-0n of cracks in the bodies of containment spray test isolation valve The licensee's actions in addressing and resolving these issues were well planned and organized, engineering evaluations and root cause analyses were technically sound, and implementation of corrective actions were timely and well controlle A pre-established workbook approach to design change package (DCP) development was initiate The new design change procedures and checklists provided better configuration management control The supporting information within these packages appeared to be effective in providing appropriate aid to jnstallation in the fiel This initiative was an improvement over the old, less formal proces Early in the SALP period, the NRC's outage team inspection of the Unit 2 refueling outage identified implementation problems in the new design change proces Poor implementation resulted in numerous comments generated during QA review of DCPs, rejection of some DCPs by SORC, and concerns identified in NRC inspections regarding outage DCP Problems included inadequate or incomplete safety evaluations, inconsistencies between checklists, and missing review and approval signature The licensee's handling of safety evaluations (10 CFR 50.59 reviews) exhibited a lack of preciseness and attention to detai Design analyses for potential consequences of system or component failures were also noted to exhibit weaknesse For example, during the Unit 2 outage team inspection, NRC identified that the design change which moved the low power trip bypass set-point (P-9) from 10% to 50% power failed to examine potential consequences of system or component failure During th~ transition, the problems noted above were largely the rasult of'

confusion due to the dual systems of design control (old procedure and new procedure) ~nd a lack of training and experience in the new syste A majority of modifications and other design changes had been processed through the old procedures, but were being implemented under the new syste Also, the requirements of new procedures were not very well disseminated to affected personnel. Although these problems may be attributed to growirig pains, the number of problems identified and the lack of prompt action by management t identify and*resolve the root cause of these problems was of concer Subsequently, enhanced training was provided to engineering personnel regarding the new design change procedures, and the importance of attention to detail. A pre-SORC review of completed DCPs by a board composed of engineering*

managers was also institute The improved quality of Unit 1 refueling outage DCPs reviewed at the end of th~ SALP period indicated th~t these corrective acti6ns were effectiv The Engineering ~nd Pl~nt Betterment (E&PB) staffing w~s generally adequat The plant staff managed approximately 65% of the present workload, and contractor personnel were used for the balance of the wor The staff was competent and knowledgeable in their areas of responsibilit The licensee s~ron9ly supported participation 'in industry, owners' groups, and professional societies in order to evaluate and develop program enhancemer.t In addition, licensee in~*tiative.s 1n performing safety system functional reviews and reconstitution of £he design baiis documentation indicated a co~mitment to self improvement in these area Va~ious meetings provide adequate communications for mandgement control of the many projects and tasks in E&P Individual communications between project tean members and the Project Managers appeared satisfactory for accomplishin the major project However, equipment failures (vital inverters) and system design problems (reactor protection system and feedwater regulating valves)

have contributed to reactor trips. Modifications and upgrades for these problems which were in progress during the assessment period were iri some cases not implemehted in time to prevent recurrent trip The strong support provided by the on-site system eng~neers in support of day-to~day activities was noted during the last SALP period. Aggressive involvement and technical guidance with respect to troubleshooting and resolution of identified problems by the systems engineers was also noted during this SALP perio Examples include; the development of a comprehensive test procedure to verify operability* of the diesel generator that had been synchronized out-of-phase with the grid, providing conservative technic~l guidante to operators regarding a reactor coolant pump seal leak, investiga-tion of various MSIV diicrepancies, and prompt identification and resolution of a transformer combustible gas proble A noted exception, however, is the steam generator steam flow indication discrepancies, a long-standing issue that has not received adequate management or engineering attentio The continued effective interface between reactor engineering and the operations staff was evideni during startup testing from refuelin The control room operators were kept informed by the reactor engineer as to the intent, direction, and the overall status of the ongoing test The Nuclear Fuels Group of the E&PB organization provided strong support throughout the testing by providing personnel and analytical test criteri The licensee's program to control the performance of inservice inspection (ISI) in accordance with ASME Section XI is a strength, in that; program changes are documented after review and approval by appropriate personnel, and

~lant modifications are reviewed for ISI program requirement The appropriate level of management is involved in the evaluation and resolution of examination result In summary, the engineering support organization~ design change control, and communications between plant and corporate engineering have improve System engineering continued to be a noteworthy strengt However, there were *

implementation problems with inconsistent or missing information in DCPs and inadequate safety evaluations during this SALP perio These problems were evaluated by the licensee and are in the process of resolutio Th~se licensee initiatives appear to be well directed and capable of enhancing engineering support to the.plan *

IV. IV. I IV. Performance Rating Category 2; Improving Recommendations None Safety Assessment/Quality Verification ( 155. hours, 4%)

Analysis This new functional area. combines the previous functional areas of Licensing Activities and Assurance of Quality. This area assesses the effectiveness*of the licensee's programs provided to assure the safety and quality of plant operations and activitie During the previous SALP period, the licensee was evaluated as Category 2 in Licensin The SALP noted a weakness in schedular planning which resulted in*

late submittals and response Ljcensing staff technical capability and the thorough and effective manner in which the licensee responded to safety issues were noted as strengths in the licensing area. *The licensee was evaluated as Category 1 in the Assurance of Quality functional area during the previous SALP perio In general, licensee initiatives and programs to assure quality

.were comprehensive and effective~

How~ver, the SALP concluded that improvements in chemistry laboratory QA/QC and the quality of licensee engineering processes were neede During thi~ assessment-period, the licensee generally approached technical issues from a safety perspective* and were responsive to NRC initiative However, delays in licensee recognition of the impact of planned activities such as the CROM clamp installation and steam generator tube plugging on regulatory requirements resulted in untimely submittal More than occasional expedited NRC review and approval was neede Licensee responsiveness to requests for information such as TMI Action Plan status was very goo Thirty-eight licensing actions were processed during this.assessment perio In addition, considerable effort was made by the licensee to reduce the backlog of pending license amendment request Although staffing levels appear adequate, the quality of new licensee submittals was_ inconsistent, both from an administrative and technical perspe~tive. For example, Appendix R exemption requests and the CROM clamp submittal were comprehensive and technically adequate, while others required communication with the licensee to resolve questions and concerns that were not addressed adequately in the submittal For example, one amendment request was rejected because the content deviated significantly from NRC published guidance and adequate justification for the deviations was not provided~ Numerous inaccuracies in proposed Technical Specification revision submittals were observed and correcte The licensee was cooperative and very respons*ive in resolving each of the administrative and technical concern At the end of the assessment period, improvement in the quality of some new licensee submittals was note Continued managemen~ attention is required ~o assure sustained improvement in the technical and administrative quality, as well as the timeliness of submittal The presence of Corporate VPs and the station general manager on site was,

observabl They were generally involved in site activi~ies. The station staff was experienced and adequately traine However, assessments in operations, surveillance and radiological controls inuicated that management did not hold the-work force accountable for the expected level of performance and that some programs were not effectively implemente Manaqement 1 s recognition and acceptance of these problems later in the assessment period led to the development and implementation of programs to cummunicate management expectations; review and correct programs, procedures and ~olicies; and improve personnel performanc These programs included a Technicai Specification surveillance verification project, work practices improvement program, procedures upgrade program, safety system functional reviews, and a third party assessment of the 10 CFR 50.59 safety evaluation proces In addition, the station QA group instituted a performance-based surveillance program including backshift activities which provided station management with a method to evaluate the effectiveness of program implementatio During the development and implementation of those initiatives, recurrent examples of inattention to detail, procedure noncompliance and deficient work

~ractices were exhibited, and indicated a continuing need for management attention and action in assuring quality performanc There were inconsistencies in the level of station management attention and control relative to planning and implementation of corrective actions in response to plant events or problem Examples of well controlled and executed activities accomplished during the assessment period include the station's investigation of the service water bay flooding event and the containment spray piping replacemen In contrast, activities associated with the auxiliary building ventilation charcoal replacement and testing; and steam generator steam flow indication discrepancies exhibited a reduced level of management attention, control and effectivenes ~26-Station Operations Review Committee (SORC) reviews of reactor trips, plant e~ents, and engineering design change packages were generally thorough and usually displayed an acceptable level of understanding of technical issue However, on several occasions the SORC and station management authorized unit restart based on the replacement of suspect components or the completion of actions based on.supposed problems without substantive evidence that all possible causes had been identified or would be resolve Onsite Safety Review Group (SRG) post-trip reviews and other investigations of these and.

other instances were of high quality and made good findings and recommendation Station responsiveness to these findings was not particularly effective early in the SALP period, but was observed to be

. improving late The onsite safety review group also performed safety system functional reviews, problemuarea revie~s, and root cause investigations which provided thorbugh and meanirlgful information for management actio In addition, the licensee has instituted a Human Performance Evaluation System to enhance root cause analysis of personnel error Continued management focus on root cause determinations is needed.*

Quality Assurance department audits and surveillances were of sufficient depth to make meaningful evaluations of the activities audite The quality of the offsite safety review group's unresolved safety question revie~s was acceptabl The.lack of timeliness ~n responding to and resolving QA and safety review groups'_ findings and recommendo.t"ions by the station was a continuing concer In addition, a violation was issued for the failure to correct or prevent recurrence 6f QA identified material control nonconformance In general, Corporate and station management enhanced the attention and importance given to the resolution of action items, and some improvement was nrited toward the end of the. SALP *perio Licensee responsiveness to previously identified weaknesses in the chemistry laboratory QA/QC program resulted in the implementation of improved calibration techniques and procedures, and an overall satisfactory level of performance in this area during this SALP perio In summary, licensee management generally displayed an adequate safety per-specti11,e. Continued managem_ent attention is needed to assure consistency in the quality and timeliness of license submittals. A need for improved quality per-formance and personnel accountability was recognized by licensee management

_during the assessment perio Enhanced management communication and corrective action programs have been developed and were in various stages of implementa-ti~n at the end of the assessment perio Some improve~ents were noted as a result of management effort However, completion of the improvement programs and continued management oversight of program implementation is *necessary to resolve the deficiencies in qualit IV. Performance Rating Category 2 IV. Recommendations None

-27-SUPPORTING DATA AND SUMMARY Enforcement Activity Number of Violations by Severity Level Functional Area v

IV III II I

Plant Operations 5*

Radiological Controls

Maintenance/Surveillance 1*

Emergency Preparedness Security Engineering/Technical Support

Safety Assessment/Quality

Verifi'cation Totals

10

• Violation cited three examples, two were in operations and one in maintenance/surveill~nce functional area An enforcement conference was held ~ith the licensee on September 29, 1988 to discuss environmental qualification violation A civil penalty resulted from the violation Inspection Hour Summary Plant Operations Radiological Controls Maintenance/Surveillance Emergency Preparedness Security Engineering/Technical Support Safety Assessment/Quality Verification Totals Actual 1437 503 648 305 209 274 155 3531 Annualized Hours 958 335 432 203 139 183 103 2353

• • Does not include NRC licensing staff hour Percent

14

9

8

100%

-28-. Licensee Event Report Causal Analysis Functional Area Ope rat ions

'

~adiological Controls Maintenance/Surveillance Emergency Preparedness Security Engineering/Technical Support Safety Assessment/Quality

• Verification

. Totals.

Includes Unft 1 LERs 88-01 through LERs 88-01 through 88-26 and 89-01 through 88-03 Cause Codes*

Ty Ee of Events A. * Personne 1 Error...... Design/Man/Coristr./Install * Externa*. Cause... Defective Procedur Component Failur Oth~r......

Tota A B

4 1

3 2 6 30 7 c

D E x Total

8

32

6

6

1

3

~*

1

0 12 18 6 h 89-15 and Unit 2 rity events 88-01

• Root causes assessed LE may,differ from those listed in the The following nt~ were identified:

Sixteen LERs discusse r ctor trips, twelve discussed missed or late surveillance tests, n eported TS 3.0.3 entries for inoperable equipment (5 service water relat, 3 steam flow channel inoperable, 1 resulted in shutdown), nine di cussed missed TS action statement requirements (4 chemistry*

samples, 5 firew ch), eight reported radiation monitoring system equipment related proble and six discussed system design related deficiencie Licensee Event Report Causal Functional Area

• Operations

.Radiological Controls Maintenance/Surveillance Emergency Preparedness Security Engineering/Technical Support Safety Assessment/Quality Verification Totals Includes Unit 1 LERs 88-01 through LERs 88-01 through 88-26 and 89-01 Cause Codes*

iy~e r ". E. \\.

of Events

~*ersonne l Error......

Design/Man/Constr./Install External Cause.. :

Defective P~ocedur Component Failur Other......

Tota A Analysis A

B c D

E x Total

4

4

4 1

6

5

1

13

1 2 6

3

13 28 7 0 12 18 6

88-20 and 89-01 through 89-15 and through 89-~9, and one safeguards

7

. 0

18

71 Unit 2 LE *Root causes assessed by the SALP Board may differ from those listed in the LE The following common mode events were identifi~d:

Sixteen LERs discussed reactor trips, twelve discussed missed or late surveillance tests, ten reported TS 3.0.3 entries for inoperable equipment (5 service water related, 3 steam flow channel inoperable, 1 resulted in shutdown), nine discussed missed TS action statement requirements (4 chemistry samples, 5 firewatch), eight reported radiation monitoring system equipment related problems and six discussed system design ~elated deficiencie 'I

'I 1*!

I,

!

l,,

I

'!

!

, I

'I

!

'I'!

~* ;

i l l i

Atta~hment 1 SALP CRITERIA Licensee performance is assessed in selected functional areas, depending on whether the facility is in a construction, or operational phas Functional areas normally represent areas significant to nuclear safety and the environmen Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observation Special areas may be added to highlight significant observation The following evaluation criteria were used, as applicable, to assess each functional area: Assurance of quality, including management involvement and control; Approach to resolution of te~hnical issues from a safety standpoint; Responsiveness to NRC initiatives; Enforcement history; Operational and construction events (including response to, analyses of, re~orting of, and corrective actions for); Staffing (including management); and Effectiveness of training and qualification progra On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categorie The definitions of these performance categories are:

Category 1:

Licensee management attention and involvement are evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirement Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieve Reduced NRC attention may be appropriat Category 2:

Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities is goo The licensee has attained a level of performance above that needed to meet regulatory requirement Licensee resources are adequate and reasonably allocated so that good plant and personnel performance are being achieve NRC atte~tion should be maintained at normal level Attachment 1 -

-2-Category 3:

Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not sufficien The licensee 1 s perfprmance does not significantly exceed that needed to meet minimal regulatory requirement Licensee resources appear to be strained or not effectively use NRC attention should be increased above normal level The SALP Board may assess a functional area and compare the licensee 1 s performance during a portion of the assessment period to that during an entire period in order to determine a performance tren Generally, performance in the latter part of a SALP period is compared to the performance of the entire perio Trends in performance from period to the next may also be note The trend categories used by the SALP Board are as follows:

Improving:

Licensee performance was determined to be improving near the close of the assessment perio Declining:

Licensee performance was determined to be decl1ning near the close of the assessment period and the licensee had not satisfactorily addressed this patter A ~r~nd is assigned only when, in the op1n1on of the SALP Board, the tren~ is significant enough to be considered indicative of a likely change in the performance category in the near futur For example, a classification of 11Category 2, Improving 11 indicates the clear potential for 11 Category 1

performance in the next SALP perio It should be noted that Category 3 performance, the lowest category, represents acceptable, although minimally adequate, safety performanc If at any time the NRC concluded that a licensee was not achieving an adequate level of safety performance, it would then be incumbent upon NRC to take prompt appropriate action in the interest of public health and safet Such matters would be dealt with independently from, and on.a more urgent schedule than, the SALP proces *

It should be also noted that the industry continues to be subject to rising performance expectation NRC expects each licensee to actively use industry-wide and plant-spec1fic operating experience in order to effect

_performance improvemen Thus, a licensee 1s safety performance would be expected to show improvement over the years in order to maintain consistent SALP ratings.