LR-N970102, Forwards TS Surveillance Improvement Program Overview Per Verbal Request
| ML18102A866 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 02/14/1997 |
| From: | Dawn Powell Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LR-N970102, NUDOCS 9702210080 | |
| Download: ML18102A866 (8) | |
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~ PSIOCI Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 FEB 141997 LR-N970102 SALEM TECHNICAL SPECIFICATION SURVEILLANCE IMPROVEMENT PROGRAM DOCKET 50-272 AND 50-311 Gentlemen:
In accordance with your verbal request, attached is the Technical Specification Surveillance Improvement Program Overview.
If you have any questions concerning this matter please contact me.
, Attachment Sincerely, David R. Powell Manager-Licensing and Regulation I
f AODI /1 210006 9702210080 970214 PDR ADOCK 05000272 P
PDR The power is in your hands.95-216S REV_ 6/94 I
.J, Document Control Desk LR-N970102 2
c Mr. Hubert J. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. N. Olshan, Licensing Project Manager - Salem U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. C. Marschall (X24)
USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 FEB 141997
,,11 Executive Summary PSE&G initiated the Salem Technical Specification Surveillance Improvement Program (TSSIP) to evaluate the quality of the Technical Specification surveillance program.
TSSIP is designed to review the surveillance testing program to enhance administrative controls, assure proper scheduling and tracking of surveillances, and validate the implementing procedures, with certain exceptions, for Technical Specification surveillance testing requirements.
TSSIP is being performed in two phases. Phase 1, which will be completed for each unit prior to the respective unit's restart, involves a general review of the Technical Specification surveillance requirements and implementation procedures, along with an evaluation of scheduling controls. PSE&G is confident that completion of Phase 1, coupled with related restart efforts, ensures that Technical Specification surveillance requirements at Salem are effectively translated into procedures and program requirements and that the Technical Specification surveillance testing program is adequate to support restart and power operation at Salem.
TSSIP phase 2 will validate the adequacy of those procedures. Based on results achieved at Hope Creek, as well as other utility initiatives, PSE&G is confident that discrepancies, if found, will be minor in nature and can be corrected within the allowed outage times specified by the Technical Specifications.
Initiatives In early 1996, Salem management approved the TSSIP to evaluate the quality of the surveillance testing program. The first phase of TSSIP was implemented for each unit during 1996 and will be completed prior to unit restart. TSSIP addresses certain Performance Improvement Requests (PIRs) related to the surveillance testing program.
The historical surveillance testing problems have generally concerned scheduling (e.g.,
missed surveillances), technical deficiencies (e.g., inadequate scope of programs, Technical Specification interpretation problems), and human performance errors.
Overall, TSSIP is designed to review the Salem surveillance testing program to verify that adequate administrative controls and procedures are in place to ensure appropriate implementation and maintenance of Technical Specification surveillance testing requirements; that appropriate scheduling mechanisms and processes are in place; and that a comprehensive cross reference matrix exists that relates each Technical Specification surveillance requirement to its associated implementing procedure(s) and initiating and scheduling mechanism(s). Prior to completion of TSSIP, the matrix will be a living reference document and is expected to be controlled and updated as specified by plant procedures.
Phase I TSSIP is being performed in two phases. Phase 1 will be completed at each unit prior to unit restart. To carry out Phase 1, the Technical Specification surveillance requirements (including conditional requirements and the associated trigger mechanisms, but excluding Section 6.0 Administrative Controls) were identified and placed into the Technical Specification Cross Reference Matrix. Use of the matrix format indicates the appropriate implementing procedure/surveillance requirement relationship. Approximately 1000 Technical Specification surveillance requirements were identified and reviewed during the Unit 2 Phase 1 process to ensure the matrix was complete, that recurring tasks were in place for each Technical Specification surveillance testing line item, and that the correct mode was referenced for each line item.
A general review was performed of the associated implementing procedures. This review involved a comparison of the Technical Specification surveillance requirements against the procedure and its purpose statement and acceptance criteria. This review was designed to validate that the implementing procedure accurately reflects and references the surveillance requirement, and that the stated acceptance criteria are consistent with the associated Technical Specification.
As of December 1996, the TSSIP reviews resulted in approximately 55 Action Requests for potential conditions adverse to quality, and approximately 620 revision requests for procedure enhancements. TSSIP also reviewed surveillance procedure revisions and Technical Specification amendments for potential impacts on surveillance requirement implementation. For conditional surveillance requirements, the TSSIP review focused on ensuring that the appropriate initiation (trigger) mechanism is in place such that each conditional (or event-driven) surveillance requirement is recognized and implemented.
Phase 1 also included a scheduling review. This involves a comparison of each surveillance-related Managed Maintenance Information System (MMIS) Recurring Task against the Technical Specification requirements and a detailed evaluation of mode transition controls and verifications. This provides assurance that surveillance requirements are scheduled at the appropriate periodicity and performed in the correct modes or conditions.
Phase 2 Phase 2 of TSSIP will involve longer-term initiatives including a detailed review of the technical adequacy of the specified surveillance procedures and development of a basis for compliance with each surveillance requirement. Further Phase 2 actions may include evaluation of testing requirements identified in the Updated Final Safety Analysis Report (UFSAR) as well as evaluation of a methodology to ensure continued
technical accuracy of Technical Specification implementing procedures following TSSIP. Phase 2 is scheduled to be completed by the end of 1997.
Related Actions PSE&G has initiated restart required surveillance procedure reviews, in addition to the TSSIP Phase 1 efforts, in areas that were deemed to need more thorough evaluation to ensure readiness for restart. Such efforts have included the Master Time Response procedure, ventilation system test procedures, and in-service test procedures.
Additionally, upgrades of the Emergency Operating Procedures and Operations Logs have been performed. As a part of these upgrades, the Technical Specifications were reviewed to ensure technical requirements were met.
Salem FSAR Project PSE&G has also undertaken restart efforts that help provide assurance that plant
~ystems/equipment are properly tested. The UFSAR "vertical slice" inspections of seven safety significant systems have evaluated the implementation of applicable testing requirements through a review and comparison of the licensing basis documents to the associated design documents and operating and test procedures.
These vertical-slice reviews were undertaken as part of the Salem FSAR Project which was conducted from June to September 1996 to provide reasonable assurance of plant operation within its licensing and design basis.
Another feature of the FSAR Project was a review and validation of system related input and assumptions of the UFSAR Chapter 15 safety analyses. Input and assumptions were validated against various plant documents including the technical specifications, surveillance test procedures, design calculations, and vendor documents. Where surveillance testing was used to periodically confirm the particular input or assumption value or parameter, the FSAR Project confirmed consistency between the test procedure and the analysis input or assumption. The input or assumption was found acceptable where the testing acceptance criteria bounded the Chapter 15 input or assumption parameter.
Hope Creek TSSIP A similar TSSIP effort was undertaken for the Hope Creek station. Hope Creek completed Phase 1 and entered Phase 2 in the first quartet of 1996. Phase 2 began just prior to plant startup and is now complete. Prior to startup, all identified problem areas were resolved. Throughout the year, TSSIP identified various missed, incomplete or incorrect surveillances which resulted in writing 70 Action Requests (ARs). Of the 70 ARs, there were four instances where Operations personnel entered Technical Specification 4.0.3 which allowed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to complete the required testing.
In all cases, satisfactory tests were completed within the 24-hour time restraint.
There was a brief period between Phase 1 and 2 where the TSSIP team was requested by Hope Creek to review various Technical Specification-related startup issues.
Although outside the scope of the project, the TSSIP team performed a detailed review of conditional surveillances required after maintenance and a review of the requirements of Technical Specification Section 6.0, Administrative Controls.
The level of detail of the Hope Creek TSSIP review and the low significance and consequences of the issues found has given the station a high level of confidence in the surveillance program. Although the more detailed Hope Creek TSSIP reviews were conducted while the plant was operating, corrective actions were accomplished successfully for all the problems identified within the allowable Technical Specification action times.
Results Achieved The Phase 1 TSSIP review for Salem identified about 1000 Unit 2 Technical Specification surveillance requirements. This resulted in a Phase 1 review of over 900 Unit 2 and common Technical Specification implementing procedures. TSSIP has also reviewed approximately 1,300 Unit 2 MMIS Recurring Tasks, as well as all departmental mode transition procedures and Technical Specification conditional surveillance trigger mechanisms (approximately 250 of the line item Technical Specification surveillance requirements are conditional). This review included verification of the following:
The purpose statement of each procedure accurately reflects the applicable surveillance requirement, or a procedure revision or Action Request was initiated.
The Technical Specifications Cross Reference Matrix indicates the appropriate implementing procedure/ surveillance requirement relationship.
The acceptance criteria stated in each implementing procedure are consistent with the associated Technical Specification surveillance requirement, or a procedure revision or Action Request was initiated.
The appropriate initiation (trigger) mechanism is in place to ensure each conditional (or event-driven) surveillance requirement is recognized and implemented. This review focused in part on verifying that implementing procedures are in place. A procedure revision or Action Request was initiated for any identified deficiencies.
The appropriate initiation mechanism is in place to ensure each surveillance requirement is implemented prior to entering the required mode or condition. This review focused on the various mode transition procedures developed by each department to documenUverify readiness to enter each mode. As necessary,
procedural revisions and Action Requests were initiated to ensure implementation of the required surveillance requirements.
The appropriate scheduling mechanism is in place (e.g., MMIS Recurring Task) to ensure (1) that surveillance requirements are scheduled at the correct periodicity and performed in the correct modes or conditions; and (2) that other considerations, such as Staggered Test Basis and test performance limitations imposed by the Technical Specifications, are being adequately addressed. As necessary, changes to the scheduling mechanisms were initiated for identified deficiencies through a formal change request form.
The Phase 1 TSSIP review has resulted in identification of a number of surveillance testing discrepancies. These have included examples of surveillance requirements with no implementing procedure or with inadequate implementing procedures, scheduling and tracking mechanisms not assuring surveillance implementation, and procedural revisions inappropriately deleting referenced surveillance requirements.
Appropriate corrective actions were initiated for these items and mode change restraints were specified, as necessary, through the Action Request process to ensure the conditions adverse to quality are addressed prior to the appropriate point in the restart process.
As of early December 1996, the TSSIP team has written and submitted approximately 620 revision requests to clarify or modify surveillance procedures; approximately 1300 requests to update or revise Technical Specification information in MMIS; and approximately 55 Action Requests to document conditions adverse to quality. The issues identified to date have not had plant safety consequences, but those deficiencies identified that could have safety implications have been or will be thoroughly evaluated prior to restart.
Conclusion TSSIP is a comprehensive review of the surveillance testing program at Salem. It is designed to review the entire Salem surveillance testing program to verify that adequate administrative controls and procedures are in place to ensure appropriate implementation and maintenance of Technical Specification surveillance testing requirements; that appropriate scheduling mechanisms and processes are in place; and to develop a comprehensive cross-reference matrix that relates each Technical Specification surveillance requirement to its associated implementing procedure(s) and initiating and scheduling mechanism(s). As such, the scope of TSSIP reaches beyond the actions requested in NRC Generic Letter 96-01, "Testing of Safety-Related Logic Circuits," because it encompasses all surveillance testing requirements, not just surveillance procedures for the reactor protection system, Emergency Diesel Generator load shedding and sequencing, and actuation logic for the engineered safety features systems identified in the Generic Letter.
' ! t-Completion of Phase 1, coupled with related restart efforts (e.g., reviews of certain surveillance procedures and UFSAR vertical slice inspections of seven safety significant systems), provides confidence that the Salem Technical Specification surveillance testing program addresses all appropriate surveillance requirements. As expected, and previously demonstrated at Hope Creek, TSSIP reviews at Salem have effectively identified a number of surveillance testing discrepancies. Issues identified to date, however, generally have not had plant safety implications. In those few instances where there could have been safety implications, they will be appropriately evaluated and dispositioned prior to restart. This observation is consistent with that in Generic Letter 96-01 where the NRC Staff states that it is unaware of instances of specifically identified surveillance inadequacies that resulted in the unavailability of the safety system when called upon during an event.
PSE&G is confident that Phase 1 of TSSIP, coupled with other restart efforts, ensures that Technical Specification surveillance requirements at Salem are effectively captured in procedures and program requirements. TSSIP phase 2 will validate the adequacy of those procedures. Based on results achieved at Hope Creek, as well as other utility initiatives, PSE&G is confident that discrepancies, if found, will be minor in nature and can be corrected within the allowed outage times specified by the Technical Specifications