IR 05000272/1989099
| ML18095A625 | |
| Person / Time | |
|---|---|
| Site: | Salem |
| Issue date: | 11/29/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18095A623 | List: |
| References | |
| 50-272-89-99-01, 50-272-89-99-1, 50-311-89-99, NUDOCS 9012060180 | |
| Download: ML18095A625 (41) | |
Text
ENCLOSURE FINAL SALP REPORT U.S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT NOS. 50-272/89-99 50-311/89-99 PUBLIC SERVICE ELECTRIC AND GAS COMP ANY SALEM GENERATING STATION UNITS 1AND2 ASSESSMENT PERIOD: MAY 1, 1989 - JULY 31, 1990 BOARD MEETING DATE: SEPTEMBER 20, 1990 9012060180 901129 PDR ADOCK 05000272 I}
F'DC
SUMMARY OF RESULTS II.A Overview PSE&G was successful in improving performance in the functional areas of plant operations and emergency preparedness during the assessment perio Good management involvement, supervisory oversight, and individual per-formance resulted in a reduced reactor trip and personnel error rat The emergency preparedness functional area achieved a superior level of per-formanc An effective, performance based security program resulted in maintaining a superior. level of performance in the security/safeguards functional are Very good performance by corporate engineering was noted, while mixed per-formance of the onsite system engineering group was observe As a result, the engineering and technical support functional area did not achieve the high level of performance that was predicted in the last assessmen Although a large number of maintenance and surveillance activities were successfully completed during this assessment period, there were signifi-cant performance weaknesses note These weaknesses included a large maintenance backlog, recurring missed surveillaMce tests, inservice test-ing program deficiencies and poor material condition of the plant An overall rating of Category 2 was assigned, however, the SALP Board gave serious consideration to a lower rating. The licensee's prior recognition of the identified problems and the achievement of small but measurable progress toward resolution of these weaknesses were critical factors in the Board's determinatio However, as a plant ages the challenges of maintaining equipment reliability and readiness increas The declining trend in this area reflects the gravity of the Board's concern over per-formance in this area and the need for marked progress in correcting the identified weaknesse Some improvements in the safety assessment/quality verification functional area were noted such as better supervisory involvement and oversight, development of significant event response teams, and effective review by the independent safety review groups. Weaknesses were identified in the effectiveness of licensee corrective action program In particular, there was a lack of effective interim measures to address continuing.pro-cedural inadequacies and degrading material conditions notwithstanding the long term significant remedial initiatives which were in proces Although the licensee has achieved discernible improvement in some aspects of each functional area, the overall performance in maintenance and sur-veillance, engineering/technical support, and safety assessment/quality verification has not improve Continued management attention and aggressive prosecution of remedial initiatives is *needed to attain a uniform, high level of performanc II.B Facility Performance Analysis Summary Functional Area Plant Operations Radiological Controls Maintenance/Surveillance Emergency Preparedness Security and Safeguards Engineering/Technical Support Safety Assessment/
Quality Verification Rating, Trend Last Period
2
2
2, Improving
Rating, Trend This Period
2 2, Declining
1
2 Previous Assessment Period:
January 1, 1988 thr~ugh April 30, 1989 Present Assessment Period:
May 1, 1989 through July 31, 1990
II PERFORMANCE ANALYSIS II Operations III. Analysis The previous SALP rated Salem operations as Category 3. That assess-ment identified weaknesses in the.area of supervisory oversight of routine day to day operation The number of plant trips and fre-
~uency of personnel errors had increase Operations management did not always provide adequate guidance to the operators for non-routine evolutions, however, operator response to plant transients was very goo Procedure establishment, use and compliance required continued
- station management attentio Some root cause analyses and correc-tive action determinations lacked aggressiveness and thoroughness, especially in cas~s related to possible ope~ator error The licen-see had instituted actions to. improve performance in these areas with mixed.results. The planning and work control processes were noted as strengths as was the fire protection progra During this assessment period, both reactors were generally operated in a conservative and safety conscious manne Examples of conserva-tive licensee operations include extension of shutdowns for both units to fully evaluate emergency core cooling system (ECCS) con-cerns, and the shutdown of one unit when a potential main steam iso-lation valve (MSIV) fast closure concern was identifie Operator response to reactor trips and* plant transients was goo In several instances prompt actions by operators prevented transients or reactor trips due to feedwater problems, loss of circulators, and steam dump system failures. Specific exceptions include an operations initiated loss of residual heat removal (RHR) event while shutdown due to operator error and an inadequate procedure, poor initial Station Operations Review Committee (SORC) response to an engineering iden-tified single failure vulnerability associated with the low pressure safety injection system, and non conservative interpretation and use of Technical Specification 3. The licensee has been successful in reducing the frequency of auto-matic reactor trip During the current assessment there were a total of 6 trips (4 at power.. and 2 while shutdown) for both unit This compares to 16 trips last _assessmen During the assessment period, Unit 1 did not experience a reactor trip for over 10 months and Unit 2 for over one yea One of the six reactor trips during this assessment period was attributed to a personnel error by a licensed operato An effective licensee trip reduction program included 11 scram-a-gram 11 information notices, warning signs for reactor trip sensitive areas, a new troubleshooting procedure and independent verification of trip sensitive procedural step.,
PSE&G has committed resources to upgrade pl ant operation; A second operating engineer, a dedicated radwaste engineer, and an emergency operating procedure cciordi nator were added to the operations staf In addition to the three senior reactor operators (SROs) required for each shift, a number of replacement candidates were hired to pursue a goal _of five SROs for each shift cre Two additional SR0-1 i censed individuals now supervise the work control group during regular main-tenance hour Operations.-
maintenance interface for equipment tagging is satisfactory. There are a total of 45 licensed operators, including 38 on-shift and seven in staff and training position Plant operations were generally well supported by the Training Departmen One exception was the response to the loss of RHR event, where both the station and the training department were not aggress-ive in obtaining training assistance following the potentially sig-nificant plant even Simulator refresher training before each unit restart continues to be given to the reactor operators (ROs) and SROs immed*iately before taking their shift and is considered a strengt The station instituted improved procedures to control the training process, and also established a master training matrix to track individual qualifications and to facilitate the maintenance of train-
- ng record Six of six SRO license candidates an
- :! six of seven RO candidates passed their initial license examination The RO/SRO requalifica-tion program was excellent with seven of seven ROs and six of six SROs tested passing an NRC administered requalification exa Direct involvement of operations management personnel has had a positive effect on the requalification program.succes Licensed operators* plant awareness, safety perspective, and profess-ional control room demeanor were consistently eviden Shift turn-overs were formal and included thorough briefings of the relief cre Control room access was controlled, and activities were limited to those directly related to plant operation Good performance non-licensed equipment operators was noted during NRC observations made on plant tours, and during."licensee equip_ment testing and oper-atio However, operator overtime was at times not properly control-1 ed in that proper management approva 1 for exceeding admi ni strati ve guidelines was not obtained. *The licensee has increased the number of licensed operators to reduce* the amount of overtime and hqs iriitiated corrective actions to ensure appropriate approval is obtaine Overall, there has been a reduction_ in the personnel error rate.
This* is reflected in root causes for LERs and licensee incident report This can be attributed to increased accountability of per-sonnel, effective management oversight of activities, and implemen-tation of worker performance standard,-'
Procedural inadequacy continues to be a leading root cause for events, including the loss of RHR event during the Unit 1 refueling outag A procedural upgrade.project (PUP)
continues to be an important initiative; however, program implementation has encountered problems as discussed in Section II Operators effectively used Emergency Operating Procedures (EOPs) as evidenced during simulator observat-ions, and actual unit transients and trips; as well as during the NRC EOP team inspectio EOPs were well written, usable by operators and well maintaine However, a concern was identified regarding excessive responsibilities placed on the one RO who operates the controls while the other RO reads the EOP The licensee plans to resolve this issue by modifying RO/SRO command and control responsibilitie Weaknesses were also noted with respect to abnormal operating procedures (AOPs) and some alarm response procedures. The lack of a good procedure verification pro-gram resulted in AOPs containing many longstanding errors including labeling problems and missing informatio Consequently, successful performance of these procedures relies heavily upon operator kn ow-ledge and experienc Licensee Operations Department event and problem
~valuation and response were usually prompt and comprehensiv Improve~ents in root cause analysis and self-assessment were note Management attention and the root cause training program have been effectiv Also, implementation of the Significa~t Event Response Team initiative has been effective in providing timely, independent; detailed, and thorough root cause analyses. However, there were isolated instances where i nterna 1 incident reports were not written when required by.
station procedures. Examples include boric acid transfer pump fail-ures and a spurious steam dump system actuation, which nearly resulted in a reactor trip. Also, early in the period, there were several instances where the licensee failed to make timely 10 CFR 50.72 report Improvements were noted later in the perio Strong plant management oversight and attention to operations were evident *on a daily basi There was an operational perspective of plant problems, and work prioritization was well understood and enhanced by daily meeting The licensee has been effective in ensuring good interdepartmental communication and in resolving prob-lem The senior nuclear shift supervisor has direct access to plant managemen Pl ant housekeeping has shown some improvement during the perio Plant area decontamination activities have reduced the contaminated floor space, particularly in the ECCS room Equipment operators can make their rounds with only minimal contamination protective cloth-in Overall, however, material condition of* the plant was weak (Section III.C).
Licensee initiatives in progress to improve the degraded conditions were not sufficient to display significant improvement II. III. The overall fire protection program was satisfactor Dedicated fire protection personnel performed well and were knowledgeable, which demonstrated an effective training progra The.fire brigade was staffed by site protection personnel, which minimized the reliance on operators to respond to emergencie Appropriate operator involve-ment in emergencies was provide The preventive maintenance and surveillances of fire protection equipment were effectiv Fire protection equipment upgrades included a new ambulance, incident com-mand vehicle, and other item However, the fire protection program experienced implementation problems at Sale For example, a weak-ness was identified in the apparent-tolerance for and the lack of timely resolution for a long term condition at Salem where some fire doors did not always close securel This condition was due to imbalances in the plant's ventilation syste Some interim compen-satory measures were taken by the plant to monitor these doors during the rounds of roving fire watches; ho_wever, doors that were not part of the route for the watches often went unmonitore In response to NRC concerns, a task group was formed to investigate the root cause of this problem and to formulate corrective actions.. A second weak-ness was related to improper control of combustible material in safety related area The licensee was aggressive in addressing.and correcting this concer In summary, improvement in - management involvement and supervisory oversight, in reduced reactor trip and personnel error rate, and in root cause analysis initiatives were note Em~rgency operating pro-cedures are considered a strength; however, weaknesses were noted relative to abnormal operating procedure Good operations manage-ment and training department irivolvement has resulted in a successful operator requalification progra The licensee has committed resources to improving plant operation Performance Rating Category:
Trend:
NA Board Comments None
II Radiological Controls III. Analysis The previous SALP rated the functional area of *radiological controls as Category The NRC 1 s review during the 1 ast assessment period *
identified that performance for inplant radiation protection activ-ities had declined early in the per~od and that the licensee's cor-rective actions and self-assessments were initially ineffective in improving overall performanc NRC observations toward the end of the last assessment period found that management attention had resulted in signific*ant performance improvemen The radiological controls organization was reorganized and a new ALARA group was established during the last perio The licensee's performance in the areas of radwaste transportation, effluent monitoring and control were adequate, and radiological confirmatory measurements was goo During the current assessment period, direct NRC observations of Unit 2 refueling activities indicated that outage activities were well planned and effectively controlle The licensee established and implemented an effective outage radiological controls organization which minimized the use of contractor personnel acting in supervisory role All major radiological work activities performed during the outage (e.g., steam generator work activities) were directly super-vised by a licensee radiological controls superviso In addition, the staffing levels to support outage and non-outage work activities, including the training of personnel, were good and the new ALARA organization continued to provide aggressive oversight of outage radiological wor~ activitie During the Unit 2 outage, the licensee experienced operational prob-lems with emergency core cooling systems at Unit 1, necessitating a concurrent mini-outa*ge at Unit 1. The licensee established a special organization to review and plan the Unit 1 work activities in order to prevent distraction of personnel supporting the Unit 2 outag This indicated a good level of management involvement in outage activitie No degradation of radiological controls was identifie The licensee also experienced an operational event at Unit 1 which resulted in generation of High Radiation. Areas in various port.ions of the Auxiliary Building. The event, which caused a high crud burst during full-flow testing of emergency core cooling systems, was well responded to by the 1 icense No unplanned exposures occurred and the crud was quickly cleaned u Corrective actions were taken to prevent recurrenc However, the event did indicate test planning process weaknesses that failed to predict and prevent occurrence of the crud burs NRC observations during the current assessment period found that the licensee's oversight of radiological program activities has improved relative to the last assessment perio For example, an independent radiological assessor was reporting findings to management during the Unit 2 outage and QA was active in identifying concern The 1 i cen see' s enforcement hi story during the assessment period has generally been goo However, ther-e were two NRC identified prob-1 em One involved 1 ack of performance of an audit of radwaste activities and one involved two examples of failure to adhere to radiation protection procedure The problems we~e properly addressed by the license In addition, the licensee identified a number of problems that included a worker leaving the site with a contaminated shoe, identification of contaminated tools in a storage area located outside the radiological controlled area (RCA), radio-active material stored in offsite warehouses, and one individual who exceeded admi n i strati ve externa 1 exposure guide 1 i nes through per-sonnel error in use of exposure control computer Review of the NRC and licensee identified problems indicated the problems were attributable to inattention to detail by the *licensee and weaknesses in procedure The radioactive and contaminated material control problems did not result in any unplanned or unmon-itored exposures of personnel and th~ licensee's response to the events was timely, comprehensive, and effectiv Good support and involvement in resolving the event by the corporate radiological con-trols group were eviden The licensee had not yet implemented all long term corrective actions at the end of the assessment period for the radioactive material control problem The problems with release, control and handling of radioactive mate-rial outside formally defined RCAs indicated the need to provide enhanced procedure The 1 i censee has been attempting to imp rove procedures, but this effort was progressing slowl The licensee has initiated action to improve these effort The licensee's radiological *occurrence program exhibited a number of significant weaknesses which minimized the effectiveness of this pro-gram for identifying, tracking, and resolving self identified radio-logical problem NRC review**found that root cause analysis of.the problems was weak, problems were not always categorized properly, and corrective actions for problems were not always identifie Examples of this weakness included the contamination control problem With the exception of the previously mentioned administrative limit prob 1 em, there were no unp 1 anned externa 1 who 1 e body or i nterna 1 exposures resulting from work activitie Access controls to HRAs were effective and enhanced through the use of 11 talking signs 11 which automatically inform personnel of access control requirements to HRA The licensee has installed digital sig*ns at the entrance to the RCA to inform workers of important informatio NRC observations indicated improvement in industrial safety, but housekeeping con-tinues to be in need of attention.* Observations of numerous candy wrappings in the RCA continue to indicate lack of worker sensitivity to the potential of ingestion of radioactive materia The licensee's controls for steam generator work, a significant radiological work activity, were commendabl Of particular note was the use of multiple, redundant monitoring methods to monitor and control the exposure* of personnel working on steam generator Performance in the ALARA area was very good and improved over pr~*
vi ous assessment period Exposure of station and contractor per-sonnel was closely tracked, monitored and reported by use of the computerized radiation work permit and automated dosimetry access control syste Potential emergent work was anticipated and planned (e.g. possible extended work scope for steam generator inspection and maintenance).
The licensee performed ALARA reviews for work that accounted for about 95~~ of the aggregate exposure sustained during the outag ALARA goals were reasonable and effectively used to monitor ongoing work but person hour estimating could be improve Overall performance in the ALARA area has been effectiv The licensee has an effective solid radwaste/transportation progra The training provided to radiological controls personnel involved in the radwaste program continues to make a positive contribution to the effectiveness of the progra NRC reviews of the radiological effluent monitoring and control pro-gram indicated calibration of effluent and process monitors was per-formed acceptably during ihe assessment perio However, there were about 32 Emergency Safety Feature (ESF) actuations due to spurious Radiation Monitoring Systems (RMS) signal The licensee had estab-1 i shed short and 1 ong term projects to upgrade the RMS during the previous assessment perio The projects are on schedule with the installation of a central process unit in 1990 and replacement of ESF RMS in 199 III. III. NRC reviews performed during this. assessment period indicated weak-nesses in the licensee 1s maintenance of safety related ventilation systems particularly charcoal filter system For example, the NRC identified that the licensee did not take measurements to verify the relative humidity of the Auxiliary Building Ventilation Syste Other* systems, such as the Control Room vent.ilation systems, were found to have failed inplace surveillance testing with no explanation as to possible cause Also, the licensee 1 s response to an NRC identified issue related tci testing of the air cleaning systems, including humidity measurements, identified early in the assessmen period remained open, with the licensee not anticipating closeout of
- the issue befor~ the end of 199 An effective Radiological Environmental Monitoring Program* (REMP) was implemente Sampling and analytical procedures were upgraded and an effective QC program was in place to assure the quality of sample analysi One problem was identified in the area of an unmonitored liquid radwaste release, but there was no impact on the public health and safety or environment and the licensee took effective corrective actions for the occurrence. The meteorological monitoring system was properly calibrated and maintaine Audits of these areas performed by the Quality Assurance Division were thorough and audit identified deficiency items were adequately resolved in a timely manner by the license In summary, the licensee implemented a good radiological controls program with a good level of management involvement in the progfa Efforts in organization, staffing, training and qualification have improved performanc The licensee 1 s ALARA activities were very goo Weaknesses exist in *the radiological occurrence report program and personnel attention* to detail is in need of improvemen Also, problems with radioactive material control indicated a need to improve procedural control The radwaste handling, transportation, and env i ronmenta 1 men i tori ng programs were effectiv The 1 i cen see has performed adequately in the area of liquid and gaseous effluent control P~rformance Rating Category:
Trend:
NA Board Comments None
I I I. C III. Maintenance and Surveillance Analysis The last SALP assessment rated the Maintenance and Surveillance func-tional area a Category Identified strengths included the initia-tive to develop work standards; maintenance planning, pre-staging and oversight during refueling outages; *and the assignment of additional resources to prevent missed surveillance Weaknesses included inconsistent use of procedures, insufficient documentation of trou-bleshooting activities, failure to follow procedures and inattention to detail resulting in several plant events, and.multiple missed
.surveillance Maintenance:
During this assessment period, the licensee implemented a satisfac-tory maintenance progra A large volume of maintenance activities was successfully implemented, however specific observations often indicated several
~reas for continued improvement and management attentio The goals and objectives of the maintenance program were we 11 define There was a good 1eve1 of maintenance management involvem~nt and supervisory oversight in daily activities. Some pro-cedure content and usage deficiencies continued to exist during this assessment perio The licensee has stressed procedure compliance and i dent ifi cation of procedure inadequacie Work in progress has occasionally been-stopped by workers and first line supervisors due to procedure problems, indicating that licensee management 1 s efforts to identify procedure weaknesses have been communicated to the staf Early in the SALP period, work standards were issued to employees for the purpose of improving work, procedural compliance and industrial safety practice Written planning standards were subsequently issued to enhance maintenance plannin Although the work standards improvement program is in its early stages, its development is con-sidered to be a good licensee inttiativ The turnover rate experienced by. the maintenance organization is 1 ow and is indicative of a stable staf Maintenance workers are com-petent, trained and qualifie Qualification criteria are well-defined and documented for both*licensee and contractor workers. The training center continues to provide extensive electrical and mech-anical training facilitie When the existing modular training pro-gram was initiated in 1987, many craft personnel were 11grandfathered 11 with the intent of eventually being formally traine However, reviews of training records did not support fulfillment of this pla Additionally, there was not an aggressive effort to satisfy yearly training requirements for mechanical maintenance, apparently due to increased work loads from unit outage Overall, however, the main-tenance staff was
~ighly knowledgeable in their areas of responsibilit Maintenance department staffing was adequate to properly support significant maintenance activitie Staffing additions during this SALP period included supervisors, planners and craft personne Also, each unit now has an outage manage However, the maintenance backlog of overdue corrective and preventive l)'laintenance was larg Initiatives taken to increase productivity, improve scheduling, up-grade work planning, and increase staffing were demonstrated to increase maintenance productivit However, the monthly work order production rate has increased prop'ortionally to the increased pro-ductivity. *The work order production increase was partly due to recent management goals to improve plant materiel condition deficiencies and worker sensitivity in identifying deficiencie The aging of any pl ant causes the cha 11 enge of material condition maintenance to increase over tim The number of deficient pl ant material and area conditions such as steam and water leaks, equipment corrosion, and service water pipe integrity was indicative of years of insufficient attention to facility and equipment statu Par-ticular concerns included inadequate maintenance of the watertight features of the service water valve galJeries and the steam and water leaks in the containment penetration rooms in both unit Recent NRC findings, such as main steam isolation valve detent problems and material condition deficiencies that are not identified by the licen-see staff indicate an apparent toleran~e of equipment deficiencies..
The licensee has shown 5ome recent improvement (e.g., Unit 2 service water valve rooms) in this area and has assigned a special task force to address material condition and equipment improvement Despite the existence of the~e prbblems, the plants have been maintained and operated in a safe manne Maintenance activities are at times impaired due to the control and availability of spare part The lic~nsee had previously recognized these parts problems and recently dedicated additional resources with sole responsibility.for material control* to improve performance in this are The spare parts problems represented a major contributor to a large maintenance backlo The licensee is developing a reliability centered maintenance (RCM)
progra Based on a licensee assessment that the existing number of preventive maintenance (PM) a.ctivities is excessive,.implementation of the * RCM program is expected. to adjust the PM program scope, schedule and workload accordingly. The licensee's self initiated RCM program has been in progress for about three year Significant increases in RCM program resources have been provided by licensee management in mid-198 The program is planned to be performed in two phases and is expected to cover about 30 system The RCM pro-gram is currently in its early stages of implementatio *.****t.::->..
Effective management involvement and oversight resulted in successful completion of two unit refueling outages and several forced outages during the assessment period. Core alterations, reactor vessel work, and other refueling a*ctivities were well supported by operation Reactor coolant system midloop operations *were well planned, pro-cedur-alized and implemente Periodic outage meetings were effec-tive in communicating priority activities and problem areas to all members of the dedicated outage team:
Maintenance procedure deficiencies continued during this assessmen The station's expanded procedure upgrade project (PUP) was initiated in mid-1989 to fully*address procedural deficiencies. Only two main-tenance procedures had been completely processed and issued at the end of the assessment period. The NRC identified examples where com-plex maintenance activities were conducted without complete, suf-ficiently detailed and approved procedures, including emergency diesel generator and main steam i sol at ion valve mechanical latching mechanism (detent) maintenanc Two reactor trips were attributed to maintenance activities conducted prior to this assessment period; one due to ineffective actions for a previous event, and the other due to an inadequate maintenance pro-cedure.. Examples of plant events caused by maintenance activities during the current assessment period in~lude the failure of an emerg-ency lighting invert~r due to inadequate maintenance and an inadver-tent safety injection signal, which occurred when a maintenance tech-nician used a drawing for the opposite safety train while performing maintenance wor At times, the licensee did not effectively control and supervise con-tractor maintenanc Several findings were identified during this assessment period relative to procedural noncompliance by contractors and indicated the need for increased management attentio Examples include work on a feedwater regulating valve without proper work authorization and the failure to implement administrative procedure requirements for temporary installation The licensee recently modified their contractor proced~res including enhanced work standard requirements and procedural familiarizatio Increased direct over-sight by PSE&G personnel was provided. Toward the end of the asses*s-ment period, improvements were_ noted relative to contractor contro However, continuing problems were ~ote Surveillance:
During this assessment period, s*urvei 11 ance testing was us.ua l ly con-ducted in a well controlled manner by knowledgeable personnel with usually appropriate supervisio A large nu~ber of surveillance testing activities were successfully complete The surveillance program administrative procedure was modified to clarify personnel responsibilities, to assign individual surveillance coordinators, and to formally assign a Technical Specification (TS) Administrator to c6ordinate related station activitie Surveillance test procedures continued to contain human factors and technical deficientie Weak-nesses were identified in the administration of the Inservice Testing Progra There were seven missed surveillances this period, predominantly due to past inadequate admi ni strati ve controls re 1 ated to TS amendment issuance. This compares with 12 missed surveillances during the last assessment peri a Missed survei 11 ances have been a 1 ong-standi ng problem at Salem for which numerous TS.surveillance reviews and audits have been performed, including a computer data base review arid a limited review of recent TS amendment Technical procedure reviews to identify additional missed TS requirements have not yet been complete The continued missed TS surveillances due to past inadequate administrative controls indicate that the previous licen-see actions taken to identify the problems have been too narrowly focused and tneffectiv Licensee management recently directed a more comprehensive review of TS surveillance requirements against existing surveillance procedures to resolve this issu Several surveillance procedures contained deficiencies, some of which resulted in plant event Human factors deficiencies contributed to the May 20, 1989 loss of residual heat removal (RHR) event and emerg-ency core cooling systems flow calculation error The licensee is addressing these types of procedural inadequacies in their ongoing
- PUP effort In an effort to reduce plant trips, early in the assessment period the licensee instituted an independent peer review of critical steps for reactor protection system and ESF testin This action appeared to have been effective in preventing trips during surveillance test-ing; no reactor trips occurred durtng surveillance testing. However, three engineered safety feature (ESF) actuations occurred during sur-veillance testing.. Two were due to inadequate procedures and one was due to personnel erro III. III. II III. There are indications that the Inservice Testing (!ST) program was not effectively administere Pump vibration testing was not repeat-able due to a combination of unmarked vibration reading points and unclear component drawings in test procedures, and weaknesses were evident relative to evaluation of questionable and unsatisfactory test results (e.g. auxiliary feedwater and boric acid transfer pumps).
Weaknesses were also identified concerning trending of sur-veillance test dat In summary, the maintenance organization implemented a satisfactory progra Work standards, management involvement, and the RCM initia-tive were licensee strength Maintenance weaknesses include the large maintenance backlog, the quality of some procedures, control of contractor maintenance, and control and availability of spare part A poor* overall material condition of the plant was a significant weakness sourced in a prolonged period of insufficient attention to maintaining the.plan Licensee efforts to improve this area have been slow; meanwhile, the challenge to the maintenance program increases with plant ag A large number of surveillance testin activities were conducted in a well controlled fashion by knowledge-able and experienced personne Some surveillance test procedl,Jres continue to contain deficiencie Although no reactor trips were caused by personnel errors, such errors resulted in other plant events. Weaknesses were identified in the administration of the IST progra Missed surveillances continued to be identified due to ineffective previous actions.-
Performance Rating Category:
Trend:
Declining Board Comments Although the overall assessment was that a Category 2 rating was appropriate, several weak: areas continue to exist without significantly effective measures to improve performanc Increase*d management attention is warrante Emergency Preparedness Analysis The Emergency Plan for Artificial Island covers both Hope Creek and Salem Nuclear Generating Stations, therefore the assessment of emerg-ency preparedness is a combined evaluation of both facilities' emerg-ency response capabilitie During the previous SALP period, this area was rated Category This rating was based on weaknesses identified during a Salem based full-participation exercise, some actual event classification prob-lems, and delays in ensuring that the Salem Technical Support Center could meet NRC design requirement Strengths.noted included a high level of management involvement in emergency preparedness activities, responsiveness to NRC concerns, and an overall effective emergency preparedness training progra~.
Management involvement in emergency. preparedness was effective and extensiv Executives and plant managers maintain emergency response organization position qualification, review and approve plan and pro-cedure changes, participate in drills and exercises, resolve audit noncompliance issues, exercise oversight functions, and interface with Delaware and New Jersey State and County government personnel.
Management oversight includes a review of call-in test results and emergency preparedness training reschedulin The licensee successfully completed a partial-participation emergency pre pa redness exercise conducted at the Sal em facility during this assessment perio PSE&G 1 s emergency response actions were succcess-ful in providing for the health and safety of the publi Overall, licensee performance was excellent and noted to be improved since the last perio Resolution of technical issues continues to be very good and demon-strates a commitment to qualit For example, as a result of an NRC concern, the licensee completed a review of default iodine to noble gas ratios as a function of release pathway, and determined the values were consistent with accident data and emergency off-gas sys-tem design and specifications. A four hour, default release duration time has been developed and accepted by the State User friendly personal computer software has been developed for the back-up dose assessment progra Relating to deficiencies in the previous assess-ment, the Technical Support Center ventilation system has been up-graded to meet NRC design requirement Innovative program activ-ities in-progress include development of site Emergency Action Levels (EALs) for natural phenomena and security events to replace individ-ual station EALs, a single Event Classification Guide for all three units, and a simplified EAL des-cription for use in the initial con-tact message sent to the States. Another example of resolving iden-tified concerns was apparent in review of the licensee's corrective actions following loss of the NRC Emergency Notification System (ENS)
when it was accidentally disconnected from an uni nterruptabl e power supply (UPS) in May 199 The licensee's communications staff tias aggressively pursued upgrading the Salem Telephone Switch Room (location of the ENS UPS connection).
The licensee successfully used the Hope Creek and Salem simulators to enhance training effectiveness during emergency dri 11 To enhance the training effectiveness of these facilities, emergency communica-tion systems duplicating those in the control rooms were installed in each simulato Staffing in the emergency preparedness area is stable with a well-qualified staff available to maintain an effective emergency preparedness progra Personnel with operations back-grounds are on staff who develop demanding operations based scenarios for drills and exercise Management 1 s attention to quality was effective as demonstrated by the following item Effective licensee audits and reviews for each unit were completed by independent audit group Among other things, drills were observed and the State/County/licensee interface was determined to be adequat There were no significant findings and the licensee/off-site interface was proactiv Emergency Department personnel with licensee executives and managers attended almost 100 meetings with State and County personnel. The public alerting system is tested daily, and is well maintained with availability at 99.5%, a va 1 ue which exceeds Federal Emergency Management Agency standard Independent and redundant siren activating systems are installed.and maintained in each Stat The 1 icensee has an effective emergency preparedness training pro-gra Responsibility for emergency preparedness training has been assigned to the Emergency Preparedness Departmen Two qualified emergency preparedness trainers have been tran~ferred from the Nuclear Training Center to the Emergency Preparedness Department to support this effor Weekly, on-the-job, mini training drills for each site have resumed and nine day-long drills are also schedule Over 1,000 licensee personnel. have been trained for Emergency Response Organization (ERO) positions. There are at least three per-sonnel qualified for each key ERO decision-making and management positio A dedicated emergency preparedness training facility has been placed in servic Engineers assigned to the Technical Support Center and the Emergency OperatiQns Facility are given an overview of Emergency Pl an Imp 1 ement i ng Procedures and Core Damage Assessment Procedure The effectiveness of the trafoing program was al so demonstrated by response to twelve actual conditions requiring classification, and the strong exercise performanc This re so 1 ves the previous SALP concern regarding event classificatio Observations of training drills indicated active involvement from licensed senior reactor operators dedicated to drill scenario developmen Operations Sup-port Center and Technical Support Center personnel were observed to implement effective problem identification and resolutio III. III. In summary, the licensee maintains a strong and effective emergency preparedness progra Management remains involved with a demon-strated commitment to quality..
Technical issues are generally promptly resolved and appropriate response is given to NRC initia-tive The Emergency Preparedness Program staff is stable and well qualified to maintain an effective progra Training is well deve 1 oped and is effective as *demonstrated by exercise performance and response to actual conditions r.equiring classificatio A good working relationship is maintained with the States and Counties with regular meetings, and frequent drill Performance Rating Category:
Trend:
NA Board Comments None II Security and Safeguards III. Analysis The Security Pl an for Art ifi ci a 1 Is 1 and covers both Hope Creek and Salem Generating Stations, therefore the assessment of* security and safeguards is a combined evaluatio During the previous assessment period, the licensee's performance was rated as Category Noted were an excellent enforcement history, the continued imp 1 ementat ion of an effective and performance-based program, kn owl edgeab 1 e and experienced security supervisory person-ne 1,
and management's i nvo 1 vement in and support for the progra During this assessment period, the licensee continued to implement a high quality and very effective.* program, and management's attention to and involvement in the program remained eviden The site secur-ity supervisor and his staff are well-trained and qualified profess-ionals who have been vested with the necessary authority to ensure that the security program is carried out effectively and in co~pli ance with NRC regulation The site security manager and his staff continued to actively participate in the Region I Nuclear Security Association and other groups engaged in nuclear plant security mat-ter They also maintained excellent rapport and effective communi-cation channels with the plant staff who exhibit respect and a good attitude toward the progra Staffing of the contract security force was consistent with program need Early in this assessment period, the security force attrition rate was high (24 percent).
Licensee and contractor efforts through personal incentives were successful in reducing this rate to 9 per-cent by the end of this perio The licensee continued to demonstrate responsiveness to several potential weaknesses during.the per:io These weaknesses primarily i~volved system and equipment agin As a result, the licensee promptly initiated a comprehensive evaluation of all systems and equipment and developed appropriate plans and a timely schedule for upgrading and/or replacing the affected equipmen In addition, the licensee implemented a well managed fitness-for-duty program in response to new NRC requirements during the perio The licensee's policy has been clearly stated and widely disseminated among both employees and contractor It was found to be aggressively imple-mented by knowledgeable personnel, and processing facilities and procedures were excel len These efforts represented a proactive management approach that continually seeks to improve the effective-ness of the entire security progra The security force training and requalification program is well-developed and administered by an experienced staff of two full-time and five part-time instructors, and a, superviso Facilities are provided on-site for training and requalifications and were well-equipped and well-maintaine During this period, the licensee established additional oversight of the contractor's training and requalification program by providing a full-time licensee representa-tive to administer the progra The 1 i censee' s event report procedures were found to be cl ear and consistent with the NRC's reporting requirement Only one report-able safeguards event was submitted to the NRC during the assessment period. This report involved the loss of power to the security sys-tem and was properly compensated for by the *security forc The licensee's report was clear and concise, and indicated an appropriate response to the even During the assessment period, the licensee submitted three revisions to the security program plans under the prov1s1ons of
CFR 50.54(p).
These revisions were.of high quality and technically sound, and reflected well-developed policies and procedure The licensee also updated all Physical. Security Plan implementing procedure III. III. III. F III. In summary, the licensee continued to maintain a very effective and performance-based security program that exceeds regulatory require-ment The licensee 1 s ongoing program to identify and correct poten-tial weaknesses in systems and equipment during this period are com-mendable and demonstrated the licensee 1 s commi'tment to maintain an effective and high quality progra Performance Rating Category:
Trend:
NA Board Comments None Engineering/Technical Support Analysis The previous SALP rated Engineering and Technical Support as Category 2, improvin The previous assessment noted significant changes within the corporate engineering department established to improve engineering 1 s interaction with the station staf Improvements were noted in corporate/station engineering communication System engi-neering was a strength. Weaknesses included implementation problems associated with station modifications and inadequate safety evaluation *
During this SALP period, evidence of good performance was noted in E&P The Project Matrix Organization and the new design change con-trol process worked wel The other changes appeared to function properl Communications between E&PB and the pl ants a 1 so improved through daily morning, regular weekly and monthly meeting Several new concerns were identified regarding the consistency of the quality of work performed by the systems-" engineers and instances of inappro-priate implementation of the temporary modification progra The design change process is effective in plant modification imple-mentatio Design change process procedures were observed to be clear and detaile The procedures adequately addressed design interface, design process and corrective action process requirements with appropriate levels of review and verification specified. Satis-factory performance and documentation of cross di sci pl ine reviews were note Calculations contained in modification packages were technically correct and performed in accordance with applicable
procedure A new workbook procedure has been developed to improve the existing design change package process and to improve configura-tion management contro The workbook was sufficiently detailed to control the design process and post-modification testin The draw-ings affected by modifications were mostly accurate and appropriately reviewed and approve In addition, a new prioritization program is under development to improve workload prioritization and resource allocatio The E&PB organization. works well with onsite system engineerin Thi~ was evidenced during the followup of the Emergency Core Cooling System (ECCS) flow problem The on site system engineering group supports operational, mainten-ance, testing and design change activitie Inconsistencies were observed in the quality of work performed by the systems engineer For example, system engineer troubleshooting and corrective action plans for radiation monitoring system deficiencies, main power trans-former problems, main steam line isolation valve (MSIV) modification errors, reactor cool ant system check valve leakage, and feedwater system and regulating valve timing problems were thorough and compre-hensiv However, system engineer followup of boric acid pump low flow problems, initial MSIV drifting indications, and initial analysis of the RHR overpressurization event were poor. System engi-neers are used as station qualified reviewers (SQRs).
The SQR pro-cess, at times, was noted as a weaknes~.
Examples include:
proced-ure changes involving safety significant issues being processed by*
the SQR; not maintaining the required SQR independence; and, not implementing SQR training that was committe There have been several examples of inappropriate implementation of the temporary modification progra Some installed temporary changes should have been processed as permanent modifications, some temporary modifications were found to have been in place for excessive time periods, and a required periodic review of temporary modifications by the Station Operations Review Committee was misse A new control procedure for temporary modifications (T-MOD) had been developed and approved for use at Sale The training for the use of this new pro-cedure was just completed at th~ end of the SALP period and the con-trol of T-MODs at Salem is in a.transition period for using the new procedur The purpose of the new procedure is to pro vi de c 1 ea rer guidance than the old on Engineering problem evaluations are generally adequate. However, the licensee's response to discrepant system flow measurement devices was initially too narrowly focuse CFR Part 21 reviews and notifica-tions are appropriately execute Technical support for refueling and maintenance outage periods and for post outage recovery activities was noted as being effectiv Both E&PB and onsite system engineering participated in and inter-faced with the outage organization on a daily basi Reactor engi-neering was noted as pro vi ding strong support during fuel movement activities, and during reactor startup and power ascension testin The licensee established project task forces led by E&PB managers to address specific technical is*sues ana problem area These included ECCS pump and flow problems and MSIV circuitry desig These task forces effectively integrated offsite, onsite and contractor engi-neering group The licensee 1 s site and corporate management were actively involved in the resolution of these technical issue The technical justification for amendment requests was mostly satis-factory and exhibited good responsiveness to NRC issues and concern However, the technical justification that accompanied requests for emergency changes to the Technical Specifications was not of the same qualit Examples included main steam isolation valve timing and charging pump excess flow submittal These changes required the licensee to augment its application with significant amounts of addi-tional informatio The technical information included in licensee responses to NRC Bulletins, Generic Letters, and other licensee requests was generally timely and adequate with sufficient detail to allow a determination concerning the acceptability of the licensee's actio One exception was the response to Bulletin 88-04, Potential Safety Related Pump Los ln that response the licensee did not recognize that the existing system alignment made the Salem Unit 1 RHR pumps potentially susceptible to the strong pump/weak pump interactio The licensee has maintained adequate control over the inservice inspection (ISI) Program, and has completed required inspections and examinations for the first interval without undue recourse to exten-sion and deferral request The licensee has performed inspections in excess of the technical specification requirements in all steam generators to determine the_ operating condition of the generators, and to assure safety and reliability of the NSSS syste Also, recognizing the importance of the* 11ALARA 11 concept, the licensee pro-vided adequate training, controls, and maximum effective automation for these inspections and examt~ation Forty-eight of 87 licensee event reports (LERs) were attributable to this functional are The majority of these were due to radiation monitoring system initiated actuations caused by design flaw PSE&G is adequately addressing this are There were other LERs that were identified by the licensee during their Configuration Baseline Docu-mentation (CBD)
projec This design basis *reconstitution is a
III. III. positive licensee initiative (Section III.G).
Two of the six auto-matic reactor trips during the period were attributed to the engi-neeri ng/techn i ca 1 support area.. The causes of these trips were a personnel error leading to an unauthorized modification, and untimely corrective actions for a previously identified inadequate modifica-tion desig *
In summary, the corporate. engineering (E&PB) performance, design change control, communications between E&PB and the plants have been very goo Inconsistencies were observed in the quality of work per-formed by the systems engineer There have been several examples of misuse of the temporary modification progra The requests for license amendments were adequately supported with the exception being those requests made under. emergency circumstance Other 1 i censee submittals and responses to generic correspondence have been timely and provided the requested informatio These exhibited adequate
- management support, attention to detail and interdepartmental communication Performance Rating Category:
Trend:
NA Board Comments None II Safety Assessment/Quality Verification III. Analysis This area assesses the effectiveness of the licensee's programs pro-vided to assure the safety and quality of plant operations and activ-itie During the previous period the licensee was evaluated as Category 2 in this functional are The last assessment noted that 1 icensee management generally displayed an adequate safety perspec-tive, however, continued management attention to assure consistency in the quality and timelines~ in licensee submittals was neede To correct a 1 i censee recognized need for improved qua 1 i ty performance and personne 1 accountability, enhanced management communi ca ti on and corrective action programs had been develope Implementation of these programs had begun, but completion of the programs and con-tinued management oversight was necessar At the beginning of this assessment period, a number of new programs were instituted by the licensee to correct the noted concerns. Cor-porate and station management continue to be involved in the conduct of operations and in the resolution of unplanned occurrence Sta-tion management is directly involved in the daily oversight of unit operation Corporate management was observed onsite and in the plant during normal and off-normal working hour Senior Nuclear Shift Supervisors were held.accountable for unit operations and had direct access to station managemen Daily meetings were held to provide an operational perspective to unit problems *and for work prioritizatio First and second line supervisors were directly involved in field activities. Worker performance during the period was adequat Other than for routine material condition problems, (see Section III.C.), the licensee had* a generally effective program for problem identification. Plant deficiencies and events were documented using incident reports. These reports were discussed at shift turnover and at the daily morning status and management meeting There were several instances of late or poor 10 CFR 50.72 and 50.73 report Examples include engineering safeguards feature actuations caused by radiation monitoring systems and a residual heat removal (RHR) over-pressurization everit:
Root cause determination and corrective actions were generally adequate. The ltcensee has implemented a root cause training progra There were several instances where initial corrective actions were either incomplete or ineffectiv Examples include emergency core cooling system (ECCS)
pump surveillance deficiencies, ove.rdue biennial procedure reviews, and late station qualified reviewer trainin At the beginning of the period, management promulgated worker stand-ards and provided training which has improved worker performance and procedure complianc PSE&G has been successful in reducing the number of personnel errors and reactor trip An effective trip reduction program included 11 scram-a-gram 11 notices, reactor trip warn-ing signs on sensitive equipment, and independent verification of trip sensitive surveillance procedure Two reactor trips (both while shutdown) were caused by personnel error One was caused by an operations error during atmospheric steam dump operation and the other by an engineering and technical support error resulting from a 1987 plant modificatio *
Management has been aggressive in disseminating and instilling a safety conscious attitude among station personne There have been effective results as evidenced by the following conservative opera-tions:
a voluntary unit shutdown because of main steam isolation valve (MSIV) operability concerns; extending shutdowns for both units to resolve ECCS concerns; successful reactor coolant system midloop opera_tion with detailed procedures and training; and voluntary unit
power reductions to avoid transient However, at times management appeared to tolerate deficient condition Examples of this toler-ance include MSIVs drifting off the1r open latch; open fire doors; and continuing degraded material condition of both unit Also, worker overtime was, at times, not properly control led by station managemen Station Operations Review Committee (SORC) review of reactor trips, design changes, significant* technical issues, and reportable events were usually thorough and timel However, there were several occasions where SORC reviews were weak, such as (1) the fai 1 ure to identify an RHR system single failure vulnerability, (2) an MSIV closure circuit failure to "seal in", with a subsequent modification pro vi ding an uncontro 11 ed steam generator vent path to the environ-ment, and (3) a non-conservative interpretation of Technical Specifi-cation 3. *
At Salem, personnel designated as Station Qualified Reviewers (SQRs)
are used to decide whether a safety evaluation and subsequent SORC *
review is necessar Because of incomplete screening criteria and a misunderstanding on the part of SQRs and station management, some issues that sho!Jld have been reviewed by SORC were no Included were both procedure changes and faci 1 i ty change This was a pro-grammatic control problem, but no safety issues were identifie Licensee safety evaluations, when completed, were found to be ~f high qualit *
The Quality Assurance (QA) Department, the Onsite Safety Review Group (SRG) and the Otfsite Safety Review Group provided effective, inde-pendent review of plant activitie The QA organization has developed and used performance based surveillance of station activ-itie QA involvement in radwaste processing is considered a
strengt Post trip reviews and other investigations by the SRG were effective in determining root cause and providing good corrective action recommendation In addition, PSE&G has instituted an even review process entitled "Significant Event Response Team" (SERT).
A SERT is initiated by the static~ general manager and is a real time, independent review of any unplanned reactor trips or other major station even The SERTs effectively developed the sequence of events, determined root cause(s) and recommended corrective action In one instance, shortcomings.. associated with a SERT evaluation were identified by PSE&G management and correcte The Human Performance Evaluation System, a detailed analysis method for determining root cause of incidents involving personnel error is also utilized by the license Direct inspection of station activities through inspection hold points by Quality Control (QC) has been significantly reduced over the past several year Additi'onally, the administrative processes to identify, document, and resolve adverse conditions were at times not aggressively applie Examples include the reassembly of a main steam drain valve with an unacceptable seating surface, and the fail-ure to install the required washer kit and properly tighten flange fasteners on service water system repair Management attention in this area is needed for assurance that those conditions are properly evaluate PSE&G has revised their guidance for QC inspection and hold points, and increased QA surveillance of maintenance activitie The overall design process was well controlled and contained appro-priate checks and balance There was an emphasis on nuclear safety as evidenced by discussions with personnel related to upgrading of procedures and implementation of new initiatives, such as the Con-figuration Baseline Documentation project, which is intended to reconstitute the design basis for many of the major plant system Inadequate station procedures continue to be a contributing root cause for both reportable and non-reportable event PSE&G initiated a procedure upgrade project (PUP) last assessment period and provided additional resources this perio The PUP was an important initia-tive; however, the program has encount,ered implementation problem These included program scope changes, a variable resource allocation, and re-definitions of an end produc Also, the required biennial reviews of existing procedures were not completed in a timely manne These items have resulted in significant setbacks in upgrading station procedure Licensee *performance in routine licensing activities, in most ins.tances, has been adequat Requests for additional information were necessary in over half the case PSE&G is usually very respon-sive to the requests for informatio Non-routine licensing activity (i.e.,
emergency requests, exigent requests)
in most instances required significant followup by the staff with PSE&G to obtain the requisite additional informatio PSE&G was responsive to these requests and provided the requested information in a timely manne PSE&G's response to generic NRC correspondence (Bulletins, Generic Letters) was generally timely and*with sufficient information that a judgement concerning the suitability of the position taken. by them could be mad In one instance PSE&G failed to recognize a possible strong pump/weak pump interaction in the RHR syste (See Section III.F.)
PSE&G has shown inconsistent performance in resolving the open TM! Action Plan item For example, PSE&G was responsive in adding the upgrade to the subcooling margin monitor to the Unit 2 refueling outage work list at a late dat However, the post acci-dent sampling system was to be upgraded by the end of March 199 While it was in a licensee tracking system it had not been properly flagged and the due date was misse III. III.G. 3
In summary, corporate and station management involvement in station activities have improve Management continued to be involved in problem resolution and the assurance of nuclear safety. Initiatives taken by management such as the SERT formation and their efforts in instilling a safety conscious attitude among.station personnel are particularly noteworth The two safety review groups, Onsi te and Offsite, have provided effective, independent review of plant activ-itie SORC reviews, in some case~, have failed to identify safety issues that required additional consideratio The use of SQRs, in some cases, have raised the threshold for SORC review beyond the expected threshol QC involvement in station activities has not been sufficient to assure that adequate independent review is being maintaine The material condition of the plants is poor and needs management attentio Inadequate procedures are a frequent contrib-utor to plant events and the implementation of the PUP was delaye Effective and timely implementation of the PUP is important to the continued safe operation of the Salem unit Closer attention should be paid to the details provided in responses to generic correspond-ence and to other licensing submittal Performance Rating Category:
Trend:
NA Board Comments Licensee initiatives such as the PUP and materiel condition improvement program require increased and more aggressive management attention to ensure completio I SUPPORTING DATA AND SUMMARY IV.A LICENSEE ACTIVITIES BACKGROUND The assessment period began May 1, 1989, with Unit 1 in its eight refuel-ing outage and the Unit 2 reactor operating at full powe Unit 1 was restarted and placed on-line on July 18, 198 Automatic reactor trips occurred at Unit
on June 9, 1989, June 19, 1989, April 3, 1990 and April 9, 199 These trips and other unit unplanned shutdowns occurring during the assessment period are further detailed in Section III. Extended forced outages occurred April 11 -
June 7, 1990 (emergency core cooling system deficiencies) and July 22 - July 31, 1990 (main steam isolation valve concerns).
The unit remained shutdown at the end of the assessment perio..
A manual reactor trip was initiated at Unit 2 on June 10, 1989 and an automatic reactor trip occurred on June 28, 199 These trips and other
- Unit 2 unplanned shutdowns are further detailed in Section II On March 31, 1990, the unit shutdown for its fifth refueling outag The Unit restarted on June 24, 199 Extended forced outages occurred on October 13 -
November 5, *1989 (main power transformer replacement) and June 30 -
July 31, 1990 (main steam isolation valve concerns).
The Unit remained shutdown at the end of the assessment perio IV.8 NRC Inspection and Review Activities Two resident inspectors were assigned to the site throughout the assess-ment perio Regional inspectors performed routine inspections throughout the period, with added inspection emphasis during the scheduled refueling outage In addition to the routine inspections, the following NRC special and team inspections were conducted as follows:
May 22 through 26, 1989; Unit 1 Special Inspection to review the loss of the residual heat removal system event that occurred during sur-vei 11 ance testin May 27 through July 10, 1989; Special Inspection to review inadequate response time testing of main and bypass feedwater regulating control valve November 17 through 29, 1989; Special Inspection to review the iden-tification of a singie failure vulnerability in the emergency core cooling syste November 29. through December 1, 1989; Unit 1 Special Inspection to review circumstances surrounding an entry into Technical Specifica-tion 3.0.3 during a turbine volumetric flow tes January 10 through. 25, 1990;.Emergency Operating Procedures Team Inspectio March 12 through 15, 1990; Team* Inspection of the Artificial Island Fitness-for-Duty Progra April 9 through 13 and April* 23 through 27, 1990; Maintenance* Team
- Inspectio April 11 through 18, 1990; Special Inspection to review circumstances surrounding the miscalculation of safety injection pumps' flow rates in the associated flow balance.verification surveillance procedur May 14 through 25, 1990; Integrated Performance Assessment Team Inspectio IV.C Significant Licensee Meetings An Enforcement Conference was held on July 26, 1989 in the NRC Region I office to discuss potential violations associated with the inoperability of the feedwater isolation system at both Salem unit A Severity Level IV violation was subsequently issued on August 9, 198 An Enforcement Conference was held on December 11, 1989 in the NRC Region I office to discuss potential violations associated with the identification of a single failure vulnerability in the emergency core cooling system and related licensee activitie Circumstances surrounding entries into Technical Specification 3.0.3 were also discussed at the meetin Three Severity Level IV violations were subsequently issued on January 8, 199 A Management Meeting was held on F~bruary 26, 1990 in the NRC Region I office to conduct a mid-SALP cycle review and evaluation of licensee performanc An Enforcement Conference was held on May 18, 1990 in the NRC Region I office to discuss the circumstances related to the identi-fication of miscalculations of emergency core cooling system flow-rates during surveillance testin One Severity Level IV violation was subsequently issued on June 8, 199 IV.D Reactor Trips and Unplanned Shutdowns Unit 1 Event Description Date Power Root Cause Functional Area An automatic safety injection/reactor trip occurred while in Mode 3 (Hot Standby) due to a high steam line differential pressure condition created by internal steam line pressure oscillation A 1987 modification was determined to have been implemented which installed an unidentified valve (closed) in the common steam line drain header, which prevented draining saturated water that had accumulated in the steam line Neither the comp uteri zed tagging system nor the associated system drawings reflected the valve additio *
6/9/89 Shutdown Personnel error Engineering/Technical Support
..
Unit I (Continued)
-Event Description Date Power
. Root Cause Functional Area An unplanned shutdown occurred due to an inoperable safeguards equipment control (SEC) train I The SEC failed the surveillance test and was declared inoperabl Licensee troubleshooting replaced some component' Further testing proved operabilit /I8/89 20%
Component failure Not Applicable The reactor tripped automatically on low-low steam generator water level due to main steam isolation v*alve (MSIV) closure during a post-maintenance surveillance test of MSIV bypass valve A design deficiency was identi-fied in the MSIV continuity check circuitry,-. which allowed voltage to remain high for a sufficient time period and reset a latching relay, ca~s ing the MSIV inadvertent closur A Unit 2 reactor trip occurred from full power due to the failur~ of the same relay approximately two months
- earlier (previous SALP period).
Subsequent to the reactor trip, an 8-day unplanned shutdown commenced from Mode 3 on June 20, I989 to repai.r a -
leaking safety injection system check valve (No. *sJSS). *
6/I9/89 45%
Untimely corrective actions *
Engineering/Technical Support * An unplanned shutdown was made due to the failure of the speed increaser bearing on a safety injection charging pum The unit was cooled down further to Mode 5 following the identification of a leaking safety injec-tion system ~heck valve (No. SJ56).
I2/l/89 100%
Component failure Not Applicable An unplanned shutdown was made due to an inoperable safeguards equipment control (SEC) train I The SEC actuated following testing and licensee troubleshooting could not determine a specific caus The licensee declared the *sEC inoperable, replaced the electrical chassis,. tested*
satisfactorily, and declared the SEC operabl.
3/27 /90 100%
Component failure Not Applicable The reactor tripped automatically while in Mode 3 on low-low steam gener-ator water level due to personnel erro A licensed operator failed to establish optimum operating conditions prior to transferring main steam atmospheric dump control from one steam generator to anothe This was aggravated due to auxiliary feedwater flow indication abno.rmalitie /3/90 Shutdown Personnel error, poor supervisory oversight Operations
Unit 1 (tontinued)
. Event Description Date Power Root Cause Functional Area The reactor tripped automatically on low-low steam generator water level due to the loss of one main feedwater pum The pump went to idle speed due to the fa i 1 ure of the governor va 1 v~ contra 1 1 i nkag A pin bushing in the linkage assembly was missing and an associated lock nut was found installed backwards. Subsequent to the reactor trip, an extended shutdown commenced on April 11, 1990 due to emergency core coo 1 i ng system fl ow discrepancie /9/90 90%
Inadequate procedure Maintenance/Surveillance An unplanned shutdown was made to evaluate potential deficiencies asso-ciated with the main steam isolation valves' ability to close under cer-tain postulated conditions, and to resolve main steam line isolation circuitry deficiencies identified relative to the original circuit desig Event Description Power Date Level Inadequate design Unit 2 Root Cause Engineering/Technical Support Functional Area An unplanned shutdown was made to re so 1 ve feedwater regulating contra 1 valve (FRV) response time testing inadequacie Inadequate surveillance procedures prevented identification of design/performance problems with the FRV /27/89 50%
Inadequate procedure Maintenance/Surveillance The reactor was tripped manually after five of the six circulating pumps had become inoperable due to high differential pressure across the asso-ciated ci rcul at i ng water system screen A 1 arge accumulation of grass and debris fo 11 owing a recent storm caused the high screen different i a 1 pressur A periodic preventive.maintenance activity to periodically clean the lower portion of the intake trash racks was not establ fshed following a similar event in 198 /10/89 100%
Ineffective corrective actions Maintenance/Surveillance
. Event Description Power Date Level
Unit 2 (Continued)
Root Cause Functional Area An unplanned shutdown was made to replace a degraded phase 8 main power transforme Periodic monitoring identified an elevated total combustible gas concentration, indicating the presence of an internal hot spot (700 degrees F).
- 10/13/89 90%.
Component failure Not Applicable An unplanned shutdown was made to repair a leak on a welded pipe cap on the discharge side of the boron injection tan The cause of the leaking joint was attributed to a defect in the root of the weld that occurred during a modificatio /17/90 Modification installation error Maintenance/Surveillance The reactor tripped automatically on low steam generator level coincident with steam/feed fl ow mismatch fo 11 owing a loss of feedwater caused by a 460 volt transformer failur A similar catastrophic transformer failure occurred on Unit 1 about one week earlier,, however, significant opera-tional problems were not experience Subsequent to the reactor trip, an extended unplanned shutdown was made to evaluate and resolve main steam isolati.on valve fast closure circuitry deficiencie /28/90 75~6 Component failure Not Applicable
TABLE 1 Inspection Hours Summary Salem Generating Station May 1, 1989 - July 31, 1990 Annualized Functional Area Hours*
Hours
% of Time Plant Operations 2912 2257 44 Radiological Controls 303 235 5 Maintenance/Surveillance 1340 1039 21 Emergency Preparedness 151 117 2 Security and Safeguards 243 188 4 Engineering/Technical Support 594 460 9 Safety Assessment/
Quality Verification 959 743
TOTALS 6502 5039 100
- Does not include NRC licensing staff hour TABLE 2 Enforcement Summary Salem Generating Station May 1, 1989 ~July 41, 1990 Number/Severity of Violations Functional Area Level IV Deviation *
Plant Operations 4*
Radiological Controls 3*
Maintenance/Surveillance 7**
Emergency Preparedness Security Engineering/Technical Support
Safety Assessment/
Quality Verification 5**
TOTALS
1 Violation cited two examples, one in operations and one in radiological controls area Violation cited two examples, one in maintenance/surveillance and one in safety assessment/quality verificatiQn areas, and is therefore included in both area.,
TABLE 3 Licensee Event Reports Salem Generating Station May l, 1989 -*July 31, 1990 Number by Cause Functional Area A
B C
D E
X Subtotal Plant Operations Radiological Controls Maintenance/Surveillance Emergency Preparedness E.. Security Engineering/Technical Support Safety Assessment/
Quality Verification Totals
-
-
-
5
1
8
7
1
31
1 8
35
9 16 2
4
48
Includes Unit 1 LERs 89-18 through 89-37 and 90-01 through 90-20; and, Unit 2 LERs 89-10 through 89-27 and 90-01 through 90-30..
Cause Codes: Personnel Error
- B..
Design, manufacturing or installation Unknown or external cause Procedure inadequacy Component failure Other Root causes assessed by the SALP Board may differ from those listed in the LER.
ATTACHMENT 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 environ-men Some functional areas may not be assessed because of little or no licensee* activities or lack of meaningful observations in that are 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 contra l; Approach to resolution of technical issues from a safety standpoint; Enforcement hi story; Operational and construction events (including response to, analyses of, reporting of, and corrective actions for);* Staffing (including management); and Effectiveness of training and qualification progra On the basis of the SALP Board assessment, each functional area evaluated is rated according to three performance. categorie The definitions of these performance categories are given below:
Category Licensee management attention to and involvement in nuclear safety or safeguards activities resulted in a superior level of performanc NRC will consider reduced levels of inspection effor Category Licensee management attention to and *involvement in nuclear safety or safeguards activities resulted in a good level of performanc NRC will consider maintaining normal levels of inspection effor Attachment 1 (Continued)
Category Licensee management attention to and involvement in nuclear safety or safeguards activities resulted in an acceptable level of performance; how-ever, because of the NRC' s concern that a decrease in performance may approach or reach an unacceptable level, NRC will consider increased levels of inspection effor Category Insufficient information.exists to support an assessment of licensee per-formanc These cases would include instances in which a rating could not be developed because of insufficient licensee activity or insufficient NRC inspectio The SALP Board may assess a functional area to compare the licensee's perform-ance 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 al so be noted. *The trend categories used.by the SALP Board are as follows~
Improving:
Declining:
Licensee performance was determined to be improving Licensee performance was determined to be declining and the licensee had not satisfactorily addressed this patter A trend is assigned only when, in the opinion of the SALP Board, the trend is significant enough to be considered indicative of a likely change in the per-formance category in the near futur For example, a classification of
"Category 2, Improving" indicates the clear potential for "Category 1 11 perform-ance 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 sche.dule than, the SALP process.