IR 05000272/1999003

Insp Repts 50-272/99-03 & 50-311/99-03 on 990315-19.No Violations Identified.Major Areas Inspected:Operations,Maint & Corrective Actions

ML18107A277
Person / Time
Site:	Salem
Issue date:	05/03/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18107A276	List: IR 05000272/1999003 ML18107A275
References
50-272-99-03, 50-272-99-3, 50-311-99-03, 50-311-99-3, NUDOCS 9905120022
Download: ML18107A277 (19)

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Docket Nos:

License Nos:

Report N Licensee:

Facility:

Location:

Dates:

Inspectors:

Approved by:

U. S. NUCLEAR REGULATORY COMMISSION 50-272, 50-311 DPR-70, DPR-75

REGION I

50-272/99-03, 50-311/99-03 Public Service Electric and Gas Company Salem Nuclear Generating Station, Units 1 & 2 P.O. Box 236 Hancocks Bridge, New Jersey 08038 March 15-19, 1999 Paul Kaufman, Senior Reactor Engineer Douglas Dempsey, Reactor Engineer William Maier, Emergency Preparedness Specialist Lawrence T. Doerflein, Chief Engineering Programs Branch Division of Reactor Safety 9905120022 990503 PDR ADOCK 05000272 G

PDR

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• SUMMARY Salem Nuclear Generating Station _

NRC Inspection Report No. 50-272, 311/99-03 During this inspection the Salem Units 1 and 2 remained at power, with the exception of both units experiencing unscheduled power reductions caused by high grass intake at the circulating water structure. The team directly observed operations and maintenance activities. The inspectors used selected sections of Nuclear Regulatory Commission (NRC) Inspection Procedure 93802, "Operational Safety Team Inspection (OSTI)," to conduct this inspection activit Overall Conclusions PSE&G had recognized the declining performance in the area of human performance errors, work control activities, and the slow reduction of corrective action backlogs. As a result of these concerns, PSE&G implemented a number of recent initiatives, such as corrective action backlog reduction plans in various departments, continuous control room observations by Quality Assurance, initiation of a common cause analysis of operations breakthrough events from 1996-1998, and implemented field oversight supervision of work control activities to try and resolve these problems. The recent corrective actions appear reasonable; however, additional time is necessary to validate the effectiveness of the implemented initiative Operations Operations were conducted in a safe and controlled manner in accordance with plant procedures. Operations personnel consistently adhered to management standards and expectations regarding communications, overhead annunciator response and control board awareness. Three-way communications, peer-checking and self-checking were routinely used by the operators. The observed shift turnover was professional and effective in ensuring that the operators were well informed of plant conditions, and that important plant status information was conveyed to the oncoming shift. Shift supervision demonstrated a conspicuous oversight during complex field activitie Operators were conducting tagging operations with due consideration to plant safety and material cleanliness. Shift supervision exercised appropriate conservatism when authorizing maintenance for safety-significant equipment. The Operations Superintendent showed appropriate concern for the conduct of maintenance activities that impacted safety-related equipment. Control room crews were informed of the maintenance activities affecting their particular plant and exercised appropriate control over such activitie Operators, in the control room and plant, were proficient in the performance of their assigned tasks. They were knowledgeable of the conditions, operation and status of the work station to which they were assigned and the procedures they were usin The Station Operations Review Committee (SORC) conducted a safety-focused meeting and did not compromise quality for expedienc iii

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e Corrective Actions Corrective action activities associated with significance level 1 corrective actions are not being completed within established procedural goals. Based on a sample review of the SL 1 corrective action backlog items in the design engineering area no safety significant technical issues were identified. It appears that your staff efforts to support Salem restart activities may have adversely affected your progress in reducing the corrective action backlog. The recent corrective actions to address these problems appear reasonable; however, additional time is necessary to validate the effectiveness of the implemented initiative Maintenance PSE&G has established an aggressive non-outage corrective maintenance backlog reduction goal that challenges a not yet fully effective twelve-week work management system. Efforts to reduce the corrective maintenance backlog in 1999 have not been fully successful, but plans and processes designed to reduce the backlog over two operating cycles are in place. A review of two risk-significant systems' maintenance backlog and performance indicators indicated appropriate prioritization of open work orders, no preventive maintenance backlog, and no operability concerns. Planned and completed work order packages were documented properly and post-maintenance tests were appropriat Maintenance activities were conducted with acceptable documentation, procedure adherence, sensitivity to housekeeping and foreign material exclusion controls, and appropriate supervisory oversight. Maintenance department human error and rework rates were trended by the corrective action group. The Maintenance department human error and rework rate goals were met at the end of 199 Plant material condition was acceptable, with deficiencies properly tagged and entered into the maintenance planning system. Particular licensee attention to housekeeping in areas undergoing maintenance was evident. The program for identifying and correcting operator work-arounds was properly manage The maintenance and quality assurance departments performed critical self-assessments and audits of maintenance activities. Identified problems were addressed appropriately and within the time limits established in the corrective actions progra iv

• Report Details I. Operations

Conduct of Operations 0 Control Room Observations Inspection Scope The inspector observed control room activities to determine if operators were following management expectations regarding communications, alarm response and supervisory oversight. Control room activities were observed during high and low maintenance activity, shift change, and an unscheduled operational transient caused by high grass intake at the circulating water structure which resulted in a significant power chang Observations and Findings Communications Operations personnel demonstrated good communications practices. Three-way communications were routinely and consistently used during periods of both low and high control room activity. Communications did not degrade during response to alarms/annunciators nor during the grass i_ntake transient. Operators performed peer checking when performing significant reactivity manipulations. Operators also demonstrated good self-checking techniques when performing less critical operation Shift Turnovers Nuclear control operators conducted very detailed watch turnovers. Sufficient turnover time was allocated to ensure that plant status information was transferred to the oncoming shift. The off going operators maintained current plant status on shift relief checklists and the oncoming operators used these checklists to facilitate a comprehensive discussion of plant status. In addition to noting equipment status and performing log reviews, the operators also conducted detailed control board walkdowns and reviewed alarm printout Oncoming Shift Briefing The oncoming shift briefing was very detailed in its discussion of watch station statu Shift supervision, nuclear control operators, nuclear equipment operators, site fire protection personnel, shift maintenance personnel, shift chemists and shift radiation protection technicians presented the status of their areas of responsibility and the planned upcoming activities for the shift. Shift supervision gave safety and operating practice refresher training during the briefings.

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Overhead Annunciator Response Nuclear control operators consistently announced all overhead annunciator alarms received to the control room supervisors. They also stated whether the alarms were expected and what the cause was. Control room supervisors acknowledged the announced alarms and three-way communications were routinely used in the acknowledgments. These announcements and acknowledgments were also evident, in nearly all cases, during the grass intake transien Supervisory Oversight I

Shift supervision maintained a strong presence in the field, accompanying nuclear equipment operators for complex evolutions that affected large plant components or important processes. The work control center supervisor accompanied an operator in the restoration of the normal letdown pressure control valve and maintained communications with the control room to coordinate the activity. The Operations Superintendent was present for the swapping of charging pumps so that a surveillance test could be performed on the running pum The shift supervision also conducted detailed briefings of operators prior to complex or seldom-performed evolutions such as the return of the letdown pressure control valve to service and several surveillance activitie Conclusions Operations were conducted in a safe and controlled manner in accordance with plant procedures. Operations personnel consistently adhered to management standards and expectations regarding communications, overhead annunciator response and control board awareness. Three-way communications, peer-checking and self-checking were routinely used by the operators. The observed shift turnover was professional and effective in ensuring that the operators were well informed of plant conditions, and that important plant status information was conveyed to the oncoming shift. Shift supervision demonstrated a conspicuous oversight during field complex activitie Operational Status of Facilities and Equipment Inspection Scope The inspector reviewed the work control process and verified adherence to tagging procedures. Two equipment tagging evolutions of risk significant systems; one tagging application and one tagging release were inspected. Shift supervision discussions concerning upcoming maintenance activities and their impact on plant safety and safety system operability were observed. The impact of maintenance activities on the control room crews was evaluated. A plan of the day meeting chaired by the Operations Superintendent was assesse '. Observations and Findings Equipment Safety Tagging The inspector noted no errors in the risk-significant system tagging request. Likewise, the tagging release was properly executed, valve locking mechanisms were properly reapplied, drain lines were capped and area cleanliness restore Operability Status of Safety-Related Equipment The inspector observed conservative decision making in entering Technical Specifications (TS) Limiting Conditions for Operations (LCOs) when taking equipment out-of-service. For example, the Unit 2 Control Room Supervisor, in consultation with the Operations Superintendent, deferred planned maintenance on the 28 emergency diesel generator after the nuclear equipment operator reported an out-of-specification oil temperature with the 2A diesel generator. The Control Room Supervisor initiated prompt action to generate an action request to resolve the problem with the 2A diesel generato The Operations Superintendent (OS) assumed a leadership role in guiding the efforts of the station departments in promptly returning safety-related equipment to service. In one example of this, he announced at the plan of the day meeting that a replacement pump motor for a safety-related chiller was not properly evaluated for use in the plant,

• impacting the chiller's return to service and the ability to meet its limiting condition for operation. The OS discussed the need for the responsible department to be accountable for the error. He held a follow-up discussion with a representative of the Work Management Center to ensure that the problem was accurately characterized for corrective actio Control of Maintenance Activities The nuclear control operators were aware of ongoing activities in the plant that could affect plant equipment and control room indications. They asked appropriate questions to technicians about the work as it was commencing. During off-normal conditions and testing evolutions, shift management provided briefings to the operating crew. These observed briefings were informative and solicited feedback from all attendees. During discussions and pre-job briefs, the operators were attentive and actively participate The inspector noted times when the scope of maintenance activities in progress, coupled with issues arising from plant operation, created a stressful environment in a portion of the control room. One example occurred when a stator cooling water high temperature alarm occurred while surveillance testing and other maintenance activities were in progress. The control room crew responded appropriately and halted the non-critical activities to devote their full attention to the developing problem. Activities were resumed only after the problem with stator cooling water temperature was resolve *

• Conclusions Based on the tagging activities observed and reviewed, the operators were conducting tagging operations with due consideration to plant safety and material cleanliness. Shift su.pervision exercised appropriate conservatism when authorizing maintenance for safety-significant equipment. The Operations Superintendent showed appropriate concern for the conduct of maintenance activities that impacted safety-related equipment. Control room crews stayed informed of the maintenance activities affecting their particular plant and exercised appropriate control over such activitie Operator Knowledge and Performance Inspection Scope The inspector interviewed control room supervisors and nuclear control operators to determine their knowledge of plant conditions. The inspector observed and interviewed nuclear equipment operators in the plant to appraise their knowledge of assigned tasks and their understanding of management expectations for their performanc Observations and Findings Nuclear control operators were able to explain the reason for all illuminated overhead annunciators on their panels. The Unit 2 control room supervisor was also knowledgeable about a radiation monitor channel deficiency the inspector noted in the field. The Operations Superintendent was knowledgeable about and interested in the status of ongoing maintenance activities as demonstrated by his conduct of the plan of the day meetin Nuclear equipment operators were proficient in the tasks the inspector observed them perform in the plant. Procedures or approved written instructions were followed when performing complex evolutions. The interviewed operators stated that operations *

procedures quality had been improved. They indicated the level of administrative and management support they were receiving was adequate to assist them in performing their tasks correctl * Conclusions Operators, both in the plant and in the control room, were proficient in the performance of their assigned tasks. They were knowledgeable of the conditions, operation and status of the work station to which they were assigned and the procedures they were usin~.

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06 Operations Organization and Adminosfration 0 Station Operations Review Committee Inspection Scope The inspector attended a meeting of the Station Operations Review Committee (SORG)

and observed several presentations before the committe Observations and Findings The SORG chairman held presenters accountable for meeting committee expectations for presentations. He discussed the need to ensure high quality, timely presentations were made for the committee members to be able to make informed safety decision Presenters were counseled when their presentations were not of the expected qualit SORC did not give final approval to any presentation that did not meet these expectation The chairman also ensured that detailed meeting minutes were kept so that SORC activities were easily reconstructed. He occasionally had the secretary read back the minutes to ensure that they were clear. There was candid and pointed discussions between the committee members and the presenters to investigate any possible unanalyzed aspects of the presented topic Conclusions The Station Operations Review Committee (SORC) conducted a safety-focused meeting and did not compromise its expectations of quality in the name of expedienc Quality Assurance in Operations 07.1 General Observations Inspection Scope The inspector observed quality assurance (QA) oversight of control room activities and interviewed QA assessment personnel to determine the standards to which QA was assessing plant operation Observations and Findings QA personnel were performing continuous control room observations during the week of this inspection in response to a request from station management. Their observations were consistent with the observations noted in this inspection report. Based on QA assessment findings, management concluded that the recent human performance incidents were not indicative of a generic performance proble The inspector also noted that the QA organization closely followed operations activities on a daily basis, reviewing operating logs and action requests generated during the previous day. The QA personnel factored these insights into the upcoming plans for operations audits and surveillance QA personnel interviewed had a high expectation of quality from the operations department. They expressed an intention to hold operations accountable for recent performance issues that impacted the maintenance schedule. QA has developed a master audit plan that assesses operations in areas noted to be sources of recent issues such as configuration managemen Conclusions The QA organization was exercising an appropriate amount of oversight of operation Assessment initiatives were based on actual and perceived concerns for safet.2 Corrective Actions Inspection Scope The inspection focused on corrective action activities associated with the highest.

significance level and classified as significance level 1 (SL 1).c<>rrective action Timeliness of corrective actions was assessed by reviewing the following corrective action program items: condition reports; corrective action evaluations; corrective action backlogs; corrective action program performance indicators; the corrective action program procedure; and, quality assurance audits. The inspector also attended a Corrective Action Review Board meeting and conducted interviews of the corrective action program staf Observations and Findings Based upon reviews of corrective action program documentation, the inspector determined that corrective actions associated with the highest significance level (SL 1)

corrective actions are not being completed within established procedural goal Specifically, initial evaluations related to corrective action evaluations (CREVs) were not being performed within the 30 day goal established in procedure Nuclear Administrative Procedure NC.NA-AP.ZZ-0006, "Corrective Action Program," Revision 16, (NAP-6). Of the approximate 58 SL 1 CREVs performed in 1998, 33 exceeded the 30 day goal and some corrective action evaluations were over due by one year or more. In addition, the Corrective Action Review Board is not conducting reviews of SL 1 condition report evaluations within the one month goal stated in procedure NAP-6 and corrective action effectiveness reviews are also not being accomplished in accordance with licensee established timeliness goals. Corrective action due dates for condition report corrective actions (CRCAs) are not being met and due date extensions were granted for a large number of corrective actions in the design engineering area. Corrective action due dates were extended by approximately one year because design engineering efforts were devoted to supporting Salem restart activities. NRC reviewed these deferred engineering corrective actions prior to Salem restart activities and concluded that the justifications for deferral were appropriat The number of SL-1 corrective action backlog associated with Salem has decreased from 210 to 116 during 1998. However, the design engineering corrective action backlog is still quite large. Approximately 728 Salem corrective actions assigned to design engineering, including 28 SL 1 corrective actions, were deferred from May 1998 to April 1999. It appears that efforts to support Salem restart activities may have impacted your progress in reducing the corrective action backlog Over the past year, QA audits provided meaningful insights to management in the area of corrective actions. QA had identified that the corrective action backlog was large and provic;:led objective assessments of station performance to management in various area Management has been responsive to the QA findings and had recognized the decline in performance associated with human performance errors, corrective action backlogs, and work controls. To address these problems management implemented a number of initiatives, such as development of corrective action backlog reduction plans by various station departments, continuous control room observations by Quality Assurance, conducting a common cause analysis of operations breakthrough events from 1996-1998, and field oversight supervision of work control activities. These recent initiatives appear reasonabl Conclusions Corrective action activities associated with highest significance level (level 1) corrective actions are not being completed within established procedural goals. Based on a sample review of the SL 1 corrective action backlog items in the design engineering area no safety significant technical issues were identified. It appears that your staff efforts to support Salem restart activities may have adversely affected your progress in reducing the corrective action backlog. The recent corrective actions to address these problems appear reasonable; however, additional time is necessary to validate the effectiveness of the implemented initiative II. Maintenance M1 Conduct of Maintenance M 1. 1 Planning and Scheduling Inspection Scope The inspector assessed the process for planning, scheduling, and implementing maintenance and surveillance activities by attending routine work management meetings and reviewing recent maintenance department performance indicators, and through discussions with cognizant PSE&G personnel. The inspector reviewed the extent and

• nature of the corrective and preventive maintenance backlogs and evaluated the.

effectiveness of backlog reduction efforts. The maintenance backlogs of-two risk-significant systems were evaluated for potential impact on equipment operability. Finally, the inspector examined a sample of planned and completed work orders for completeness and qualit Observations and Findings Twelve Week Planning Process From a review of work planning performance indicators for late 1998 and the first quarter of 1999, the inspector discerned that weekly schedule adherence (work orders completed versus planned) has met PSE&G's goal of at least 70% despite a large amount of unscheduled emergent work. The current average is approximately 85%.

The Work-It-Now (WIN) team and a round-the-clock coverage of high priority work by multi-disciplined crews were important contributors to this effort. The licensee indicated, however, that a considerable amount of work is deleted from the schedule due to incomplete planning, such as failure to perform adequate pre-job walkdown or to anticipate and pre-stage replacement parts, or higher priority emergent work. Technical Specification surveillance test performance and preventive maintenance schedule adherence remained high.

During the inspection week, few departments met.the daily 70% completion goal. This condition results in deferral of some jobs, and unplanned overtime and weekend work to meet the weekly goal. In an effort to identify and resolve problems and inefficiencies in the planning and scheduling process, PSE&G has begun to focus on daily department performance. *

Administrative procedure NC.PL-AP.ZZ-0009(Z), 'Work Management Manual,"

establishes a process in which future work is planned systematically over a twelve week period before the scheduled execution date. The process establishes milestones for completion of work support tasks such as performance of risk assessments,

. establishment of safety tagging boundaries, work package assembly, resource allocation, and pre-job walkdowns. Inadequate pre-job walkdowns early in the planning process have contributed to major delays during the work weeks and adversely affected subsequent schedules and plant operations. For example, during the inspection, correction of a high vibration condition on the #22 Chiller compressor motor was delayed several days when maintenance personnel identified that the replacement motor nameplate data did not match the original motor. This resulted in changing the work scope to refurbish the original motor. PSE&G entered the occurrence into its corrective action program for resolutio *

Stabilization of work week scope early in the planning process is a key element in meeting established goals. PSE&G has been less successful in meeting its 70% goal during planning week T-5", when the work schedule is intended to be fixed ( "frozen"). The 1999 average for T-5 stability was approximately 64%. Major challenges identified by the licensee in its self-assessments were parts availability and scheduling of emergent work. Corrective steps have been taken to introduce more discipline into the process to reduce the amount of unplanned emergent work added to the work week to a minimu The inspector reviewed several post-work week critiques conducted by the work planning managers. The assessments were self-critical and provided insights into the strengths and weaknesses of current performanc Work Order Backlog Review The backlog of non-outage corrective maintenance work orders consisted of 1432 items at Unit 1 and 1173 items at Unit 2. PSE&G's ultimate goal is to reduce the backlog to 400 items per unit in the next two operating cycles. The goals for 1999 are 900 and 700 items at Unit 1 and 2, respectively. The licensee's backlog reduction plan consisted of validating all outstanding work orders, developing performance indicators for the reduction effort, and assigning plan ownership to the Maintenance Superintenden These items were complete. The work management center and work week managers have been attempting to prioritize work to control the backlog by providing input to the 12-week rolling schedule. However, recent performance indicators showed that the corrective maintenance backlog has been relatively constant during the first quarter of 1999, with a slight increase at Unit 1. The condition has been attributed to emergent work. PSE&G is placing considerable reliance on the WIN team to limit the amount of new work entering the work week process, and an indicator has been developed to monitor the efficacy of the WIN team's efforts in this are The inspector reviewed the maintenance backlogs for two risk-significant systems (control air and station blackout gas turbine generators) to assess the significance of typical backlogged work items. The inspector examined individual work orders and system health reports, walked down the systems, and discussed system status with responsible engineers. The inspector noted no operability concerns or adverse cumulative impacts due to the backlogged items, and no preventive maintenance items were overdue. The system health reports evidenced an effort to maximize system availability and reliability and the work orders were prioritized and tracked appropriatel Work Order Package Review From a sample of about 30 closed work order packages in records storage, the inspector performed a detailed review of eight safety-related corrective maintenance work orders performed in 1998. In each case, the problems and corrective actions were documented clearly, and component operability was demonstrated adequately by post-maintenance test *

• The inspector also examined ten planned corrective maintenance work orders that had been reviewed by maintenance supervisors and approved as "task ready." Except for some minor administrative errors that were promptly noted for correction, the work packages were adequate to support the projected maintenance wor Conclusions PSE&G has established an aggressive non-outage corrective maintenance backlog reduction goal that challenges a not fully effective twelve-week work management system. Efforts to reduce the corrective maintenance backlog in 1999 have not been fully effective, but plans and processes designed to reduce the backlog over two operating cycles are in place. A review of two risk-significant systems' maintenance backlog and performance indicators indicated appropriate prioritization of open work orders, no preventive maintenance backlog, and no operability concerns. Planned and completed work order packages were documented properly and post-maintenance tests were appropriat M1.2 Observation of Maintenance Activities Inspection Scope The inspector observed corrective maintenance performed on the safety-related #22 chiller compressor motor during the on-site inspection period to verify that the activities were controlled, and performed consistent with Salem procedures and NRC requirements. The inspector also reviewed PSE&G's tracking of maintenance performance errors and rewor Observations and Findings Work order 981027232 called for replacing the original #22 chiller compressor motor with a new equivalent replacement motor. The work scope subsequently was changed when the job supervisor identified differences in the motor nameplate data. Since the work was being performed under a technical specification limiting condition for operation, PSE&G decided to refurbish the original motor. The work order changes were processed properly in accordance with Salem procedures. The work order package contained all of the procedures and documentation needed to support the job. Good housekeeping practices were followed in the work areas, and the maintenance crew demonstrated sensitivity to foreign materials exclusion considerations while the motor end bells were removed for bearing replacement and motor cleaning. Procedures were followed closely, and engineering support was solicited when nonconforming or questionable conditions were identified. The inspector verified through review of training records that the maintenance personnel were qualified for the assigned work, and attention to detail and self-checking were evident. Frequent first line supervision at the job was noted.

• The maintenance department corrective actions group developed and maintains performance indicators to track human errors and repeat maintenance. The human error metric (number of errors per 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> worked) showed an improving trend, with the goal of less than 0.5 being met at the end of 1998. The errors are binned by organizational and process failure codes in order to focus corrective actions. Repeat work is defined as any maintenance required on the same component 18 months after previous maintenance that can be attributed to errors of omission or commission during the first activity. The cumulative data for 1998 indicated that department goals for this indicator were me Conclusions Maintenance activities were conducted properly, with acceptable documentation, procedure adherence, and sensitivity to housekeeping and foreign material exclusion controls, and appropriate supervisory oversight. Maintenance department human error and rework rates were trended by the corrective action group. The Maintenance department human error and rework rate goals were met at the end of 199 M2 Maintenance and Material Condition of Facilities and Equipment M Plant Material Condition and Operator Work-arounds a.

Inspection Scope The inspector assessed the general material condition of the plant, including review of a sample of equipment deficiency tags. The inspector also reviewed the program for identifying, tracking, and correcting operator work-arounds and deficient/out-of-service control room and field indicators to verify that the program was implemented properly, and that the conditions did not affect safe plant operatio Observations and Findings The inspector conducted several plant walkdowns to assess housekeeping practices and the general material condition of both Salem units. Housekeeping was found to be acceptable, particularly in areas in which maintenance was in progress. Deficient conditions that were observed were tagged properly for repair, and no significant items

~ere identified. Two minor deficiencies involving oil leakage from the #22 service water pump strainer motor gearbox and an Appendix R emergency light in #2 service water bay were observed during the walkdowns, and turned over to the operating crew for dispositio..

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!* Procedure SC.OP,;,AP.ZZ-0030(Q), "OperatorDeficiency Program;" defines the pfogf~:im for managing operator work-arounds (OWAs) and control room/field indicator deficiencies. The program is administrated by the Operations Manager and requires a monthly assessment of the aggregate impact of the conditions on plant operation and operator capabilities. Non-outage related deficiencies are assigned the highest work priority with a correction goal of thirty days. Compensatory measures are entered into the shift turnover log to heighten operator awareness, and the impact of the measures on the operators' daily routine is assessed. During this inspection there were 15 OWAs at Unit 1 and 13 OWAs at Unit 2. Resolution of these current operator work-arounds will require an outage. The status of each deficiency was tracked in a computerized database, and performance indicators were used to track program effectiveness. The inspector assessed the individual and cumulative effect of the work-arounds and found no adverse impact on operators' ability to operate the plant safel Conclusions Plant material condition was acceptable, with deficiencies properly tagged and entered into the maintenance planning system. Particular licensee attention to housekeeping in areas undergoing maintenance was evident. The program for identifying and correcting operator work-arounds was properly manage M7 Quality Assurance in Maintenance Activities M7.1 Maintenance Self-Assessments and Quality Assurance Audits Inspection Scope The inspector examined the effectiveness of the maintenance department self-assessment program and the independent oversight of maintenance activities exercised by the quality assurance organization. The inspection consisted of review of self-assessment and audit reports and discussions with the maintenance department corrective actions group and the quality assurance manage Observations and Findings Standardized field observation (MAP) cards are the primary data gathering tools used in the maintenance department self-assessment program. The cards are formatted to comprehensively evaluate the major activities associated with job startup, implementation, and completion, and are used by managers and first line supervisors during periodic walkdowns. In addition, detailed checklists are used to assess specific subject areas such as housekeeping, material storage, post-maintenance testing, and the maintenance and test equipment program. The results recorded on the cards are collated and evaluated by the department corrective action group for periodic management reports and feedback to the field. Problem areas and adverse observations are documented in action requests that are entered into the corrective action program. During the last quarter of 1998, 606 observations were performed by first line supervisors at a rate of about 45 per week. Problems in the areas of work

package quality and work scope changes were identified for corrective aqtion, and 75 action requests were generated. The action requests sampled by the inspector were addressed acceptably and within the assigned time frames. The inspector also noted that the maintenance self-assessment program was audited by the quality assurance department, which concluded that the program is effective in identifying adverse trends and problem area The inspector reviewed several recent quality assurance department audits that were performed in the maintenance*area. A June 12, 1998 audit (No. 98-0059) of the work management program identified problems in the area of on-line LCO (technical specification limiting condition for operation) maintenance, and an audit of the effectiveness of the corrective maintenance backlog reduction plan (No. 98-0101)

resulted in several action requests. The inspector found the action requests to have been resolved acceptably and within the licensee's time limits. The quality assurance manager indicated that he viewed maintenance department management and staff as responsive to his department's findings and recommendations. The inspector found the observation to be consistent with the relevant corrective action program performance indicator Conclusions

. The maintenance and quality assurance departments performed critical self-assessments and audits of maintenance activities. Identified problems were addressed appropriately and within the time limits established in the corrective actions progra V. Management Meetings X1 Exit Meeting Summary On March 19, 1999, inspection findings and conclusions were presented by the inspectors to Mr. Bert Simpson and other members of PSE&G management. PSE&G management acknowledged the observations and findings, and did not contest the teams conclusions. None of the information reviewed during this inspection was considered proprietar *

INSPECTION PROCEDURES USED IP 93802:

Operations Safety Inspection Team PARTIAL LIST OF DOCUMENTS REVIEWED *

Quality Assurance and Self-Assessment Reports NQA-99-0001, "QNOnsite Independent Review Quarterly Report -

October/November/December 1998," dated January 15, 1999 Audit Report 98-060, "Procurement and Material Control Audit," dated August 3, 1998 QA Assessment Report 98-0179, "Forced Outage - 21 RCP Seal Replacement," dated December 16, 1998 QA Assessment Report 99-0004, 'Work Control - Technical Specification Scheduling," dated January 21, 1999 QA Assessment Surveillance Report 98-0091, "Salem Unit Two Mid-Cycle Outage," dated August 14, 1998 QA Assessment Surveillance Report 98-038, 'Work Management," dated April 20, 1998 QA Assessment Surveillance Report 98-059, 'Work Management," dated June 12, 1998 QA Assessment Surveillance Report 98-101, "Corrective Maintenance Backlog," dated September 16, 1998

"Comprehensive Self Evaluation Of The Maintenance Training Program," Revision 1, dated November 19, 1998 Maintenance Department Self Assessment Program, "Report of the Observation Card Results,"

February 26, 1999 Maintenance Department Assessment Program, "Periodic Report," dated March 1998 Maintenance Department Self Assessment Program, "Effectiveness Review," dated July 1998 Maintenance Department Performance Report, dated January 1999 Procedures NC.PL-AP.ZZ-0009(0), 'Work Management Manual," Revision 0, dated November 30, 1998 NC.NA-AP.ZZ-0069(0), "Work Control Coordination," Revision 0, dated July 13, 1992

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NC-NA-AP.ZZ-0050(Q), "Station Testing Program," Revision 6, dated September 24, 1997 *

NC.NA-AP.ZZ-0055(Q), "Outage Management Program," Revision 2, dated September 24, 1998 NC.NA-AP.ZZ-0082(0), "Integrated Planning and Prioritization," Revision 1, dated June 24, 1998 NC.NA-AP.ZZ-0009(Q), 'Work Control Process," Revision 14, dated November 30, 1998 SH.MD-AP.ZZ-0002(Q}, "Maintenance Department Troubleshooting and Repair," Revision 1, dated November 3, 1998 SH.OP-AP.ZZ-0008(Q), "Operations Troubleshooting and Evolutions Plan Development,"

Revision 0, dated January 19, 1999

SC.OP-APA.ZZ-0030(0), "Operator Deficiency Program," Revision 1, dated July 3, 1997 NC.NA-AP.ZZ-0016(Q), "Monitoring the Effectiveness of Maintenance," Revision 3, dated February 17, 1999 CR CREV CRCA ECCS LER NRC OWA PMT PSE&G QA RCS RHR RO SORC TS UFSAR LIST OF ACRONYMS USED Condition Report Condition Report Evaluation Condition Report Corrective Action Emergency Core Cooling System Licensee Event Report Nuclear Regulatory Commission Operator Workarounds Post-Maintenance Test Public Service Electric and Gas Quality Assurance Reactor Coolant System Residual Heat Removal Reactor Operator Station Operations Review Committee Technical Specification Updated Final Safety Analysis Report