ML17157A549

SALP Repts 50-387/89-99 & 50-388/89-99 for 890801-901130. Overall Control of Radiological Activities Effective,But Weaknesses in Contractor & Contamination Controls Noted

ML17157A549
Person / Time
Site:	Susquehanna
Issue date:	01/22/1991
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17157A548	List: ML17157A547 ML17157A549
References
50-387-89-99, 50-388-89-99, NUDOCS 9102110090
Download: ML17157A549 (57)

See also: IR 05000387/1989099

Text

ENCLOSURE

INITIALSALP REPORT

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

REPORT NOS. 50-387/89-99; 50-388/89-99

PENNSYLVANIAPOWER & LIGHTCOMPANY

SUSQUEHANNA STEAM ELECTRIC STATION

UNITS 1 AND 2

ASSESSMENT PERIOD:

August 1, 1989 - November 30, 1990

BOARD MEETING DATE: January 22, 1991

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TABLE

F

ONTENT

I.

INTRODUCTION .....................................:

1

II.

SUMMARYOF RESULTS............

II.A

Overview

II.B

Facility Performance Analysis Summary

2

2

3

PERFORMANCE ANALYSIS..........

III.A Plant Operations

III.B

Radiological Controls ......:....

III.C Maintenance/Surveillance.........

III.D Emergency Preparedness

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III.E

Security and Safeguards..........

III.F

Engineering/Technical Support

III.G

Safety Assessment/Quality

Verification

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IV.

SUPPORTING DATAAND SUMMARY ...

IV.A Licensee Activities.............

IV.B

NRC Inspection and Review Activities .

IV.C

Significant Licensee Meetings ......

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IV.D Reactor Trips and Unplanned Shutdowns........................

24

TABLE 1 - Inspection Hour Summary

TABLE2 - Enforcement Summary

TABLE 3 - License Event Report Summary

Attachment

1 - SALP Criteria

I.

INTROD

TI N

The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff

effort to collect observations,

data and to periodically evaluate licensee performance on the

basis of this information.

The SALP process is supplemental to normal regulatory processes

used to ensure compliance with NRC rules and regulations.

SALP is intended to be

sufficiently diagnostic to provide a rational basis for allocating NRC resources

and to provide

meaningful feedback to the licensee's

management to improve the quality and safety of plant

operations.

An NRC SALP Board, composed of the staff members listed below, met on January 22,

1991 to review the collection of performance observations and data, and to assess

the

licensee's performance at the Susquehanna

Steam Electric Station.

This assessment

was

conducted in accordance with the guidance in NRC Manual Chapter 0516, "Systematic

Assessment of Licensee Performance".

The SALP Board for the Susquehanna

Steam Electric Station assessment

consisted of the

following individuals:

chairman

Charles W. Hehl, Director, Division of Reactor Projects (DRP)

~Mem er

W. Hodges, Director, Division of Reactor Safety (DRS)

M. Knapp, Director, Division of Radition Safety & Safeguards

(DRSS)

W. Butler, Director, Projects Directorate I-2, NRR

A. Blough, Chief, Projects Branch No. 2, DRP

G. Barber, Senior Resident Inspector, Susquehanna

M. Thadani, Licensing Project Manager, NRR

eh

d

P. Swetland, Chief, Reactor Projects Section 2A

J. Stair, Resident Inspector, Susquehanna

B. Westreich, Reactor Engineer, DRP

J. Durr, Chief, Engineering Branch, DRS

P. Eapen, Chief, Special Test Programs Section, DRS

W. Pasciak, Chief, Facilities Radiation Protection Section, DRSS

J, White, Chief, Nuclear Material Safety, Section C, DRSS

R. Keimig, Chief, Safeguards

Section, DRSS

J. Kottan, Laboratory Specialist, DRSS

J. Noggle, Radiation Specialist, DRSS

C. Gordon,

Sr. Emer Prep Specialist, DRSS

R. Albert, Physical Security Inspector, DRSS

K. Green, NRR

K. Brockman, Region I Coordinator, EDO

P. Ray, Performance Evaluation Branch, NRR

Q /

,2

MARY

F R

T

ILA

QWrview

Overall licensee performance was very good.

Strong management

support and oversight were

evident, and facility operations were conducted in a conservative,

safety conscious manner.

There was a continuation of superior performance in plant operations,

maintenance,

surveillance and security.

Noteworthy in these areas was the high quality of individual

performance,

and self assessment.

The overall quality of training programs also contributed

to strong performance,

even though some weaknesses

in program administration were noted.

Radiological controls performance was good.

While overall control of radiological activities

was effective, there were weaknesses

in contractor and contamination controls.

Emergency preparedness

improved significantly during this period.

The full implementation

of position specific emergency response procedures,

and the excellent performance during the

annual exercise were noteworthy in the achievement of a superior rating.

Engineering and technical support activities were generally conducted in a high quality

manner.

However, slow evaluation and resolution of some recent and long standing technical

issues detracted from an otherwise strong standard of performance.

Strong safety assessment

and quality verification performance was marked by effective

strategic planning and follow through, and superior self assessment

programs.

3-

II.B

Facilit

Performance Anal

is Summa

~Fane i nal

Ratin

Trend

Last Period

Ratin

Trend

This Period

Plant Operations

Radiological Controls

Maintenance/Surveillance

Emergency Preparedness

Security and Safeguards

2, Improving

Engineering/Technical

Support

2

Safety Assessment/

Quality Verification

1, Declining

Previous Assessment

Period:

Present Assessment

Period:

February

1, 1988 to July 31, 1989

August 1, 1989 to November 30, 1990

III.

PERF

RMAN E ANALYSIS

III.A

P~l

The previous SALP report rated performance in operations as Category 1.

That assessment

concluded that the operating staff continued to display strong management involvement and

was aggressive in dealing with plant problems.

Operators'onservative

approach to nuclear

safety was a significant strength.

Good training and staffing levels were in place, as

evidenced by the fact that there were very few operator-induced. events.

During this assessment

period, operators continued to maintain a strong safety perspective and

were well-trained and qualified.

Professionalism

was apparent in everyday activities.

Procedural adherence is mandated and receives significant management

emphasis.

Operators

were effective at monitor'ing and controlling plant activities and evolutions.

They also

exhibited thorough knowledge of the plant by identifying and responding to plant problems

and transients correctly and expeditiously.

For example, operator response to an uncontrolled

heatup transient during a Unit 1 outage in February 1990 was very thorough and focused on

termination of the heatup.

In addition, operators rapidly identified and terminated an

unanticipated actuation of the Reactor Core Isolation Cooling System at Unit 2 in May 1990,

thus limiting the power excursion.

In July 1990, the operators'otating

shift schedule was changed from an 8-hour shift to a 12-

hour shift to improve long-term operator performance on shift. The licensee conducted a

survey of industry experience with the use of 12-hour shifts and hired a consultant to educate

employees and their spouses

on the effects of 12-hour shift work.

Operator feedback on the

new shift schedule has been very positive.

The change has eliminated the use of,split shifts

to fillin for unplanned absences

and has reduced overtime use by operations.

Changes occurred in the licensee's upper level management

organization during the period.

The plant superintendent

was promoted to Vice President, Nuclear Operations,

and the

Assistant Superintendent for Outages was promoted to Plant Superintendent.

The fillingof

the previously vacant Vice President position has increased management's

interaction at all

levels and is viewed as a positive action.

These changes have continued an emphasis on high

quality operations.

Direct involvement by middle management

and upper management

was

frequently observed in the plant.

Corporate management visited the site frequently and was

found to be very involved with emerging plant issues.

5

There was one automatic scram on Unit 1 and two automatic scrams on Unit 2 during the

SALP period (see Section IV.D). None of the scrams was attributed to operator error.

One

scram on each Unit was attributable to unrelated problems in the offsite switchyards and the

other Unit 2 scram was due to a failed feedwater level controller transmitter.

Operator

response following these scrams was excellent.

In each case, the emergency operating

procedures

(EOPs) were used to effectively stabilize the plant in hot shutdown.

Licensee

corrective actions have improved control of activities in the offsite switchyards.

The operator training programs were well designed, implemented,

and strongly supported by

both training management

and line management.

However, some weaknesses

were noted.

The most significant program weakness allowed two operators who failed requalification

examinations to return to licensed activities prior to retraining and successful retesting.

This

weakness was subsequently corrected by the licensee.

The NRC administered requalification

examination in January

1990 resulted in eight of the ten reactor operators (ROs) and all of the

ten senior reactor operators (SROs) passing the examination.

(The two ROs who failed

subsequently

passed

an NRC administered requalification examination in April 1990).

The

requalification program was determined to be satisfactory.

Allsix ROs passed

the initial

examination administered in April 1990, as did two of the three SROs.

The Susquehanna

EOPs were generally acceptable,

although some weaknesses

were noted.

Suppression

chamber pressure indication was not available in the control room and was

difficultto interpret for use as a decision point in the EOPs.

The licensee took prompt action-

to assure that operators were aware of this safety significant issue and subsequently performed

short- and long-term corrective actions regarding suppression

chamber pressure indication.

Another noted weakness

was slow implementation of several actions directed by the primary

containment control EOP.

Continued simulator fidelity problems were also a particular-

concern.

However, the licensee has initiated action to place a new state-of-the-art simulator

in service by September

1992, in parallel with certifying the current simulator.

Notwithstanding these items, the EOPs can be performed successfully in the plant.

An

identified strength was the success of the licensee's training program in training the operators

to use the EOPs in the control room and the plant.

The licensee's initial response to the EOP

inspection did not include prompt corrective action, for some short term items and therefore

required an additional response.

Housekeeping of the plant was excellent.

The licensee continued to expend significant

resources to maintain a clean and well kept plant.

On every shift, two or three people

cleaned the plant on a full time basis.

The licensee continued to implement a vigorous

painting program to upgrade the permanent appearance of the plant. A new labeling program

for equipment and flowpaths provided a marked improvement in identification of system

components and flow directions.

During the period, the licensee's control of transient

equipment and material continued to be a problem.

Unsecured equipment and material were

occasionally observed in the plant.

Although corrective actions are in progress,

implementation has been slow.

Overall, howevder, housekeeping

was a licensee strength.

During the previous SALP period, the number of outstanding fire watches needed to

compensate for degraded or ineffective fire protection barriers, seals and equipment was a

noted weakness.

During the current period, the licensee expended significant efforts to

resolve these equipment deficiencies and to reduce the number of fire watches.

During 1990,

the number of fire zones requiring hourly fire watches was improved from about 190 to about

40.

This reduction in affected fire zones reflects good progress toward recovering from

previous weaknesses

in fire protection performance.

Overall, the licensee's fire protection

program was found to be well-managed and adequately staffed with experienced

and

knowledgeable personnel.

In summary, the licensee has demonstrated

continued strong performance in the area of plant

operations.

Aggressive management involvement in operational activities was noted at both

the corporate office and the site.

The plant continues to operate safely and effectively.

The

licensee's training programs are very good and operator staffing is excellent.

There were no

scrams due to operator error.

Operational problems did'ccur, but the operators dealt with

them in a prompt and effective manner.

Overall, plant operations is a significant licensee

strength.

Perform nce Ratin:

1

~d'

III.B

~Rdh

I

The radiological controls program was assessed

as Category 2, with an improving trend

during the previous SALP period.

The program was considered to be effective. A good

level of management involvement and support for resolving previously identified problems

was noted.

The internal and external exposure controls programs, including ALARAefforts,

were of good quality and effectively implemented.

The effluent monitoring and control

'rogram was effective.

There was a need for continued management attention to the control

of contaminated material.

A well defined and staffed radiation protection organization was in place.

The organization

was effectively augmented during the outages with properly trained and qualified contracted

personnel.

An appropriate level of supervisory oversight of the augmented organization was

maintained.

The radiation protection organization has remained stable and several inter-

departmental interface positions (e.g. Maintenance Drywell Coordinator, Outage Scheduler,

and Radiological Controls Consultant) have been added.

The addition of these positions has

improved communications between the radiological control groups and the station's other

functional groups.

Added management oversight has been achieved by dividing the Radiation

Protection/Chemistry Group into separate radiation protection and chemistry groups.

The licensee's overall training and qualification program for radiation protection personnel

and radiation workers was found to be of good quality. No deficiencies were identified

which reflected inadequacies in the training and qualification program.

Special control point

instructions were developed to provide additional guidance for controlling access to

radiologically significant work activity areas.

Late in this assessment

period, NRC review

found that there were only limited administrative controls over the duties performed by

radiation protection technicians to ensure the assignment of only qualified personnel.

Also,

there was no clear guidance as to what constitutes acceptable "equivalent" experience for

commercial nuclear power experience when qualifiying contractor radiation protection

personnel.

The licensee initiated a review of these issues.

1

During the previous assessment

period, the licensee experienced continued problems with the

control of radioactive material.

Since then, the licensee has essentially eliminated any

inadvertent release of contaminated material from the radiological controlled area (RCA). A

computerized tool accountability program has been implemented along with many procedural

modifications.

An isolated event involving the improper release of a tool was quickly

identified by the accountability program and rectified.

Overall, the licensee has implemented an effective external and internal exposure control

program.

The licensee was sensitive to industry events. For example, as a result of a spent

fuel pool personnel exposure event at another station, the licensee required the use of

alarming dosimeters around the spent fuel pools.

The licensee also used alarming dosimeters

for personnel radiation exposure control in the Drywell. Personnel exposure reports were

published at least daily providing good control over the accumulation of personnel exposure.

The licensee demonstrated

good overall control of airborne radioactivity.

Radiation

protection work practices were generally well performed and controlled.

Some isolated

problems (e.g., lack of documentation of surveys and a worker not adhering to radiation

protection and confined space postings) were immediately evaluated and corrected by the

licensee.

There were weaknesses

with contamination control practices (e.g., the potential for cross

contamination of personnel;

and hoses and lines extending from posted contaminated

areas

into clean areas).

Contamination events were of minor significance but indicated lack of

I

worker attention to proper contamination control practices.

The licensee was pursuing

improvements.

A significant, isolated external exposure event occurred early in the period and involved an

unplanned radiation exposure to a small area of the chest of a contractor chemistry technician.

The contractor technician carried an unsurveyed, highly radioactive reactor coolant filter

sample in his shirt pocket for a short period of time.

Although no overexposure occurred,

the event revealed significant weaknesses

in the licensee's control of contractor work

activities.

Subsequent NRC and licensee reviews of the unplanned exposure event identified

failures of multiple exposure control barriers (e.g., radiation work permit controls and

supervisory and management

reviews) which contributed to the occurrence of the event.

The

licensee took aggressive actions to assure the program deficiencies were corrected.

Control

of contractors has been 'significantly enhanced

since this event occurred.

The licensee

evaluated the management control of all contractors on site and issued a special procedure to

provide guidance for control of contractors.

Audits of the radiation protection program continued to be of very good quality. Various

audit perspectives

were obtained from such diverse groups as the corporate radiation

protection group, the station quality control department and from outside industry experts.

The audits were performance-based

and reflected good management involvement with the

radiation protection program.

A high degree of corporate and station management involvement in ALARAgoals was

evident.

Although the implementation of the ALARAprogram was good, there were

weaknesses

in the scope of ALARAtraining for maintenance personnel and in station wide

publicity of the ALARAprogram.

The ALARAgroup=had early involvement in,station

planning activities and complete access

to all scheduled work packages.

Emergent work

received appropriate ALARAreviews.

Exposure goals were developed for individual

departments

and jobs and were considered reasonable.

Repair of Reactor Water Clean-Up

(RWCU) pump seals in both units has accounted for a large percentage of the maintenance

personnel exposure for the last two years.

In part due to ALARArecommendations,

the

current pumps are scheduled to be replaced with seal-less pumps, but not until 1992.

The licensee had in place an effective program for the control of radioactive gaseous

and

liquid effluents.

In addition, the radiological environmental monitoring program (REMP)

was found to be effectively implemented.

Procedures for both the radioactive effluent

monitoring and control program and the REMP were detailed and well written and procedural

adherence

was excellent.

Expertise was available within the chemistry department management

and staff to effectively

conduct the radiological effluents program.

The reorganization of the radiation protection/

chemistry group, discussed earlier, appeared

to enhance the ability of the licensee to

effectively manage the program.

At the end of the assessment

period, the licensee was in the

process of qualifying an individual as the new Chemistry Supervisor.

QA audits of the effluent and environmental monitoring programs were thorough, of excellent

technical depth, and of sufficient scope to identify programmatic problems in these areas.

Overall licensee performance in these areas was considered to be excellent.

QA audits and surveillances of the solid radioactive waste and transportation program were of

excellent scope and technical depth.

The quality assurance program in the solid radwaste and

transportation area was a noted strength.

Also notable in this area was the licensee's

excellent training program for radwaste personnel.

'uring this assessment, period, the licensee identified an under-reporting of the quantity of

radioactivity in shipments of dewatered resins from 1984 to 1990.

This event demonstrated

an isolated, but significant lack of radwaste transportation program oversight and attention to

detail, but was not indicative of an overall programmatic breakdown.

The NRC has not yet

reviewed licensee long term corrective actions for the problem.

Overall, the licensee's

performance in this area was considered to be good.

In summary, management involvement and control in assuring quality was apparent.

With

the exception of the radwaste classification issue the licensee aggressively pursued the

resolution of technical issues,

and the resolution of previously identified problems was

excellent.

The enforcement history in this functional area has been acceptable with two

isolated problems detracting from an overall effectively implemented radiological controls

program.

No significant operational events,

attributable to poor performance in the area of

radiological controls, occurred this assessment

period.

Staffing in all radiological controls

areas was good.

The licensee's overall training program for permanent and contractor

radiation protection personnel was also good.

2~

2B:

2

B~d

The licensee maintained effective radiological controls programs.

This rating does not

reflect a decline in performance, but the trend of improvement during the last SALP

period was not sustained at the previous rate and performance did not achieve the

previous expectation.

10

III.C

Maintenance/

urveillan

'he previous SALP report rated the licensee's performance in the combined Maintenance/

Surveillance functional area as Category 1.

The maintenance

and surveillance programs were

properly established

and implemented.

Both organizations were staffed with well qualified

and skilled individuals.

Surveillance and maintenance of safety-related components and

systems were rigorous as evidenced by no automatic scrams from either activity.

The maintenance program is well organized, and the licensee has demonstrated

good

performance in this area.

Both unit and individual system availability have been maintained

at a high level.

Mid-level and,senior site management involvement with plant maintenance

activities was apparent throughout the period.

Foremen supervised daily maintenance

activities and problems to assure that they were properly tracked, prioritized and resolved.

Daily planning meetings demonstrated

the ability of plant management to adjust priorities and

to effectively coordinate ongoing woik activities with newly identified problems requiring

maintenance.

Interaction with plant operations occurred on a daily basis in order to schedule

work activities and assure that coordination with operations and other groups was established.

Preplanned

schedules were used whenever possible to control activities.

An evolving package

of preplanned maintenance

was kept up to date during power operations in case a forced

shutdown or automatic scram occurred.

The licensee emphasized

the importance of forced

outage maintenance by extending unplanned shutdowns for up to seven days to complete

preplanned forced outage activities.

Administrative controls over procurement, receipt,

inspection, storage and issuance nf materials were effective for 'ensuring the availability of

materials when needed for routine or emergency maintenance activities.

The licensee has established long term maintenance programs in order to preserve the life

extension option for Susquehanna.

Program enhancements

which were identified for the long

term include, better use of predictive maintenance;

continued efforts to integrate reliability

centered maintenance concepts into the maintenance process;

and the on-going implementation

of a preventive maintenance improvement program.

X

A significant strength of the maintenance organization was its stable and well trained staff.

Maintenance activities were generally found to be properly authorized and conducted in

accordance with written instructions/procedures.

The maintenance training program was

effective and demonstrated well defined qualification criteria for maintenance personnel.

The

tracking system used for qualification of personnel has been improved since the last SALP

period and the licensee has committed to accelerate completion of formal personnel training

and certification.

When a supplemental work force was necessary

during outages,

the

licensee had an effective program for control of contracted maintenance personnel.

Individual work groups were responsible for assuring that contractor personnel working with

11

their groups had appropriate training and qualifications for the jobs they performed.

Licensee

actions were found to be effective at processing a large contractor maintenance force for

outages.

During the assessment

period, Susquehanna

completed two refueling outages and

several'orced

outages.

The maintenance planning and outage organizations functioned exceptionally

well in scheduling all required tasks and coordinating the team work required of the different

work groups to accomplish those tasks.

Two engineered

safety system actuations resulted

from maintenance related activities during the Unit 2 refueling outage.

In addition, a scram

signal resulted from maintenance activities while shutdown during this outage.

No rod

motion occurred from the signal since all rods were fully inserted.

These events were caused

by personnel errors and procedural deficiencies that were promptly corrected.

Preliminary results from a maintenance

team inspection confirmed that the maintenance

program was well described and adequately implemented.

Good availability and equipment

operability indicate that the maintenance process was effective.

Corporate and station

management

support of the maintenance process was evident in five-year plan program goals;

in adequate fiscal allocations and trained manpower; and in maintenance facilities, equipment,

and spare parts availability.

Weaknesses

identified by the maintenance

team included

inadequacies in performing and documenting 50.59 reviews, delays in performing periodic

maintenance procedure review, poor preplanning of a HPCI turbine six year inspection, and a

failure to follow some work procedures.

Overall, the material condition of the plant was well

maintained.

Licensee management

is effectively using performance indicators to assess

maintenance

and to

address unacceptable

trends.

The licensee uses PRA techniques to assess

and modify plant

design and operations.

Although a comprehensive

risk-based maintenance prioritization

system is not yet in place, the licensee is proceeding toward this goal.

QA surveillance of mainten'ance activities was adequate

and effective in identifying program

implementation deficiencies.

QA audits were found to be thorough as evidenced by the,

quality of audit findings and observations documented in audit reports.

The'QA/QC groups

were active in maintenance activities, including the work authorization process.

In contrast,

the licensee's correction of some nonconformances

and deficient conditions was slow, and in

some cases, took years (See section III.G for details).

The licensee's electrical maintenance program was adequately staffed with experienced

and

knowledgeable personnel.

The effectiveness of the electrical maintenance program was

evidenced by few circuit breaker failures.

However, the licensee's maintenance

management

was not always aggressive in resolving issues promptly. For example, it was previously

12

identified that the licensee did not have adequate breaker testing program for 480 volt

breakers.

Actions to resolve this concern included only a tentative schedule to complete a

breaker testing program by the end of third quarter 1991.

In general, supervisory oversight and procedural control of maintenance activities was very

good.

However, a noted lapse in this performance was evident when sandblast material was

introduced into the air intakes of two diesel generators.

Although this appeared to be an

isolated case, it was considered to be significant because of its common mode failure

potential.

In addition, procedures

used for a six year inspection of the HPCI turbine lacked

detail commensurate with the evolution's safety significance.

The HPCI inspection was

completed satisfactorily.

The surveillance program was effectively managed

and implemented throughout the

assessment

period.

A computer-based

system scheduled the necessary

surveillance tests

and tracked them effectively. This system assured good coordination between Operations,

Maintenance, Radiation Protection, Chemistry, and Instrumentation and Control personnel for

the performance of the surveillance program.

The successful implementation of this program

and the cooperation of the departments involved were strengths of the surveillance program.

No automatic scrams or transient events occurred as a result of surveillance related activities

during the period.

However, three safety system actuations of minor consequence

and one

Reactor Core Isolation Cooling (RCIC) initiation occurred during the performance of

surveillances.

Three of these actuations were directly attributable to personnel errors, and

one was due to a procedural deficiency.

The licensee took action to assure that appropriate

corrective actions were taken.

Considering the large number of surveillances performed in 16

months of two unit operation and refueling outages,

these cases represent a very small

fraction of the total number of surveillances performed.

Overall, conduct of the surveillance

program was excellent.

In-service testing /ST) performance was good.

The IST program successfully monitored the

performance of pumps and valves throughout the plant and adequately documented

age-'elated

degradation.

During the assessment

period, the licensee's in-service inspection gSI)

program was well planned and implemented.

One weakness was noted in the ISI area.

The

licensee failed to provide adequate ISI contractor and procedural controls, which led to a

plant start-up with a potentially unacceptable

ultrasonic indication in the reactor vessel.

The

indication was subsequently

evaluated and found to be insignificant.

The licensee took

appropriate corrective actions to prevent the recurrence of this problem.

The examination

program for the detection of intergranular stress corrosion cracking also exhibited some

4

13

weaknesses;

however, prompt action by the licensee resolved these deficiencies. Staffing

levels, including the use of ISI contractors were good.

Overall, licensee ISI personnel and

contractors were found to be well-qualified in performing ultrasonic testing.

In summary, the licensee has carried out successful maintenance and surveillance programs,

although some weaknesses

were identified.

These programs were adequately scheduled,

planned, and implemented.

A strong management commitment was evident in conduct of

maintenance

and surveillance activities.

Minor weaknesses

in the maintenance

area were due

to personnel errors and procedural deficiencies.

The surveillance program was generally very

good.

Perf rmance Ratin

1

ar

mment'one

III.D Emer enc

Pre aredne

During the last SALP period, Emergency Preparedness

(EP) was rated Category 2, a decline

from the previous assessment.

Strengths were noted in the areas of coordination with offsite

authorities and in the use of the simulator to stage the control room portion of the 1989

exercise.

Weaknesses

were identified during this exercise, particularly with regard to the

formulation and issuance of timely protective action recommendations,

and an incomplete

update of Emergency Plan Implementing Procedures

(EPIPs).

An additional concern

involved the lack of distribution of independent audit reports to the state and local agencies.

In this SALP period, the licensee performed well during the annual partial participation

exercise.

Changes in plant conditions were readily observed by the shift staff and were used

to properly classify emergency conditions. The licensee completed development of new

Position Specific Procedures

(PSPs) for each designated emergency response position so that

a separate procedure can be used by each emergency response organization (ERO) staff

member.

The PSP's received both peer and management review before implementation.

Personnel effectively used PSP's to execute response actions.

No performance weaknesses

were identified during the exercise and only minor improvement areas were noted.

Emergency response facilities were maintained in an excellent state of readiness.

The ERO

was fully staffed and trained in key response functions.

EP staffing has remained stable

throughout the period to effectively maintain major program functions.

Management was

supportive of EP activities and demonstrated

a clear understanding of relevant issues affecting

the program.

Senior managers are kept apprised of EP program activities through formal

14

meetings with the EP staff.

Key management

and technical staff at the site and corporate

office are assigned emergency response functions and have maintained ERO. qualification.

Emergency response training has been effective in general employee training as well as

'ualifying

individual members of the ERO to perform response functions,

Course

requirements

necessary

to satisfy each emergency position are subject to management

involvement and approval.

Lesson plans for ERO training were adequate but not completely

updated to correspond to the PSP's.

Independent quality assurance

audits were performed using a detailed audit plan and were

=

found to be adequate in scope and provided a thorough review of EP activities.

Results of

audits were reviewed by corporate and plant management who ensured that audit results were

properly addressed

and that significant deficiencies were given priority. The audit reports

were properly distributed.

Corrective actions on recommendations

identified during audits

and self-assessinents

were timely.

During this period, the licensee responded well to an actual plant challenge requiring

activation of the Emergency Plan'.

In February 1990, the licensee properly classified an Alert

due to a loss of shutdown cooling which resulted in reactor coolant temperatures

exceeding

200 degrees F.

Activation of the Technical Support Center (TSC) was prompt and was

completed prior to exceeding the Alert initiating condition.

Operators demonstrated

good

knowledge of Abnormal Operating Procedures

used to provide an alternate means of decay

heat removal and with EPIPs used to carry out event response.

The licensee's self-critique of

the response identified a significant concern regarding their ability to promptly activate the

Media Operations Center (MOC) to provide timely transmission of plant status information to

the public. A task force was formed to evaluate and address this concern and propose

corrective action to prevent recurrence.

Overall implementation of the Emergency Plan

during the Alert was effective and well coordinated.

In summary, performance has improved since the previous assessment

and an effective EP

program was implemented throughout this period.

Involvement of management in the quality

of both onsite and offsite program activities was evident.

Actions taken for previous

weaknesses

were effective. The training program is well defined and organized and ERO

personnel were well qualified.

Implementation of the recently developed PSPs has

significantly enhanced

response capability.

ERO performance in the annual exercise was

excellent.

Response activities during an Alert were effective, with the exception of timely

activation of the MOC.

~fR

~d:

N

15

III.E

ecuri

and

afe uard

During the previous assessment

period, the licensee's performance was rated as Category 1,

as it has been for all previous assessment

periods in this functional area.

That rating was

based on a highly effective and performance-oriented

security program, an excellent

enforcement history, experienced security supervisory personnel and a high degree of

management involvement, in and support for the program.

The licensee's high level of performance during the previous assessment

periods was also

sustained during this period.

Upgrading and enhancement of systems and equipment

continued., In particular, some aging package and personnel search equipment and security

vehicles were replaced with state of the art equipment.

Additionally, the licensee continued

to maintain (1) a well planned and integrated security program utilizing well-trained

personnel;

(2) an effective and well-supported testing and maintenance program as evidenced

by a short turn-around time for equipment maintenance,

an excellent on-line availability

record for security equipment, even for some aging equipment, and the absence of equipment

related events requiring reports to the NRC; and (3) an excellent working environment for

security personnel

as evidenced by, in particular, the clean and well maintained access control

centers, security office areas, security training center, alarm stations and security vehicles.

Plant and corporate management continued to be actively involved in security matters as

evidenced by excellent support for and cooperation with security program implementation,

upgrade enhancements,

security personnel training and participation in industry groups

involved with nuclear security matters.

Site security management

and staff are well-trained

and highly qualified professionals who have been vested with the necessary authority and

discretion.,and who ensure that the security program is implemented effectively and in

compliance with NRC regulations.

Corporate security management continued to be actively

involved in all site security program activities and continued to conduct various surveillances

and reviews of on-site security readiness

to ensure that a high quality and effective program

was being implemented.

Site and corporate security management

also continued to actively

participate in industry groups engaged in nuclear plant security matters.

They also.

maintained excellent rapport and effective communication channels with the plant staff who

exhibited an excellent attitude toward the program.

Staffing of the security force was consistent with program needs as evidenced by the minimal

amount of overtime required to support the program and the adequate off-shift time available

to provide the security force members with effective training.

The allocation of adequate

resources to provide for an effective security force has resulted in a minimal number of

personnel errors and an excellent enforcement history.

1

Audits of the security program conducted by the licensee's QA Group, and surveillance

conducted by the Corporate Security Staff, were found to be comprehensive

and

thorough.'indings

of the audits and surveillance were directed toward refining and enhancing the

16

program and no major deficiencies were noted.

Corr'ective actions were always prompt and

effective with aggressive follow-up to insure proper implementation.

A review of the licensee's security event reports and reporting procedures found them to be

well understood by security supervisors and consistent with NRC regulations.

There wei'e no

events requiring a prompt reporting during this period.

Other events were found to be

promptly logged, appropriately tracked, with corrective action specified, as necessary.

The licensee security training program was administered by four full-time and highly

qualified instructors with full-time administrative support.

The program as administered was

well-structured, maintained current and exceeded

the requirements of the NRC-approved

Security Force Training and Qualification Plan.

The security training facilities were well

maintained and training was conducted utilizing excellent lesson plans and state-of-the-art

training aids for hands-on-training.

Security management

also instituted a tactical training

program for the armed security force members during this assessment

period.

The licensee's

training program is aggressive and has resulted in security force members being very

knowledgeable of their duties, contents of procedures

and overall responsibilities.

During this assessment

period the licensee implemented a Fitness-for-Duty (FFD) program in

response to new NRC requirements.

The licensee's FFD program development and

implementation were found to be responsive to both the spirit and intent of the NRC's FFD

rule.

The licensee also submitted three changes to the security plan under the provisions of 10 CFR 50.54(p) during this assessment

period.

These revisions were of high quality, technically

sound and reflected well-,developed policies indicating a comprehensive

and thorough

understanding of the NRC's performance objective for nuclear power plant security.

In summary, the licensee continued to maintain a highly effective and performance-oriented

program.

Management, attention to and support for the program are clearly evident in all

aspects of program implementation.

The efforts to upgrade some security systems and

aggressively maintain other aging equipment were commendable,

and demonstrated

the

licensee's commitment to a very effective and high quality program.

The security training

program was dynamic and very well administered.

In addition, the licensee's FFD program

met the spirit and intent of the FFD rule.

B~d'

17

III.F

En ineerin /Technical

In the previous SALP report, Engineering and Technical Support was rated as Category 1,

with an overall conclusion that the licensee demonstrated

a high quality engineering program.

No significant deficiencies had been identified in this functional area.

Positive factors were

noted in the following areas:

system engineering/technical

support, management involvement

in the plant modification process,

assessment

and development of probabilistic risk concepts,

and a motivated and highly,qualified engineering staff.

During the current SALP assessment

period, the licensee's engineering organization provided

sound technical resolution of many safety significant issues.

For example, engineering

review of a suppression pool-to-drywell vacuum breaker modification already installed on

Vnit 1 identified that a flow limiting orifice had been omitted during the original design

change.

When analyses indicated that potential damage could result during vacuum breaker

operation without the orifices, a prompt shutdown and repairs were completed.

In another

case, prompt and effective evaluation of extensive corrosion in one RHR pump motor cooler

resulted in timely and conservative replacement of all these coolers on both units.

Licensee

identification of and timely response

to these safety concerns indicated thorough engineering

involvement and a conservative approach to plant problems.

Effective engineering was also evident in support of other plant problems.

For example,

when a control rod could not be inserted during a weekly control rod surveillance, the

licensee developed a special test with the vendor's concurrence that was able to free the

'ontrol

rod.

In another case, low flow to ce'rtain emergency service water (ESW) coolers

was noted.

A licensee evaluation with significant involvement of the system engineers,

identified that the flow reduction was due to silt buildup in the lines.

Good engineering

direction and technical competency were displayed in support of the silt flushing, and in the

ESW flow balance performed.

The frequency of silt flushing was temporarily increased in

order to prevent blockage from silt buildup.

Subsequently,

modifications were made which

allowed various valves to be fully opened while other valves were left throttled to prevent the

potential for silt buildup.

These licensee actions were prudent.

Management involvement in the mo'dification process continued to be evident.

Administrative

procedures which control the modification process and plant configuration control were

thorough and effective.

Both Resident Engineering and Corporate Nuclear Engineering

departments were involved in planning and prioritization of plant modifications.

Modification

packages were well organized and included detailed design descriptions which contributed to

successful installations with little or no followup work required.

Good communications were

maintained between corporate engineering and all other plant support organizations during

modification planning.

Review of nuclear plant engineering work practices indicated that the

engineering work activities were being prioritized and executed according to appropriate

procedures

to support the plant and licensee needs.

l

'

18

During this assessment

period, the NRC conducted an electrical distribution system functional

inspection (EDSFI) to determine ifthe electrical distribution system would be capable of

performing its intended'afety function as expected,

and to assess

the licensee's engineering

and technical support of the electrical distribution system.

The licensee mounted a significant

engineering effort to prepare for the EDSrI, and as a result, was well prepared and provided

significant assistance

to the NRC team during the inspection.

A strong resource commitment

was evident.

The licensee had aggressive self assessment/audit

programs which have

identified many technical and programmatic concerns regarding the electrical system.

However, some of the concerns had not been fully evaluated or corrected in a timely manner.

In addition, several instances were identified where operability/reportability reviews had not

been completed in accordance w'ith the applicable procedures.

Although engineering support was generally good, some errors in design changes occurred.

In addition to the omission of flow orifices during the Unit 1 vacuum breaker modification, a

modification to the full flow test valve for RCIC and HPCI flow surveillances prevented

achieving adequate flow in the test line at a reactor pressure of 150 psig.

This modification

permitted full flow at 920 psig, but due to an engineering oversight, the higher head loss

effects during the 150 psig surveillance test were not considered.

This modification did not

affect the flow path for actual injection.

There were instances where engineering failed to address causal factors and implement timely

corrective actions.

For example, in February,

1990, a loss of shutdown cooling with reactor

coolant temperatures

exceeding 200 degrees F was caused by a recurring power failure

problem from a poorly designed electrical insulator.

Two Emergency Diesel Generator (DG)

crankcase overpressurizations

occurred in September and October 1990 due to an assortment

of conditions associated with DG operating and test conditions, as well as design.and

maintenance factors, the collective impact of which were not clearly understood.

The

licensee committed significant resources to ensure long lasting corrective action for both the

problems.

In addition, reactor water cleanup (RWCU) pump seal failures have been a

- continuing problem.

Accordingly, resources are also being allocated for the RWCU pump

seal problem.

The licensee's approach to these and other engineering problems emphasized

a

prolonged, methodical identification of the root cause without promptly addressing potential

causal factors in parallel.

The net result of this approach was untimely resolution of

engineering problems in some cases.

However, once management

focuses support on

resolving a problem, it gets prompt attention and comprehensive resolution.

Licensee review of conditions that were potentially outside the plant design basis was a

significant NRC concern during the period.

A number of these conditions identified by the

licensee were not fully analyzed, compensated for and/or reported to the NRC in a timely

" manner.

These include the potential inadequacy of electrical distribution design calculations,

potential electrical distribution system single failures that could overload DGs, and design

deficiencies in the leak detection system and the inboard main steam isolation valves.

Resolution of some problems was not always managed effectively, and corrective actions

19

were often slow in implementation.

In response to the need to address reportability and

correction of engineering problems, an engineering deficiency reporting (EDR)'ystem was

developed and implemented.

The EDR program was intended to capture these and other

deficiencies and to provide prompt operability/reportability evaluations as well as a focused

approach to resolution.

Many significant issues were reviewed under the EDR program with

inconsistent results.

In response,

the licensee made several significant changes to the EDR

. process which appear to have resolved the earlier problems.

The licensee made good

progress in implementing the EDR program which has improved their timeliness in reviewing

engineering issues.

There were concerns with the licensee's resolution of environmental qualification (EQ)

deficiencies such as the polyurethane damper seals in the standby gas treatment and direct

expansion cooling units.

In addition, EQ "related nonconformance reports including 64 motor-

operated valves in the reactor building were not adequately dispositioned, and many of the

qualification issues existed for several years.

Although management

attention to EQ was a

weakness identified in the 1986-1988 SALP, the effectiveness of corrective actions had

apparently not been long-lasting.

However, improvement has been noted in the licensee's

recent resolution of these engineering issues.

The lack of prompt disposition and correction of some of these issues appeared

to result from

the misclassification of the safety significance of these matters.

The licensee placed heavy

emphasis on the perceived small probability of occurrence of some events or the expected

satisfactory outcome of incomplete reanalyses to justify interim operation with the existing

discrepancy.

There was less focus on the potential adverse consequences

should the event

occur.

On this basis, concerns perceived to be of low safety significance received low

priority on completion of reanalyses

and corrective action, and on final operability/

reportability determinations.

During the latter half of the period, the licensee has taken

action to effect positive changes in their approach to safety significant issues.

Currently the

licensee has redefined safety significance to better focus on the potential adverse

consequences

of failures, even those of very low probability.

The licensee is supportive of industry standards groups, BWR owners group 'efforts, and

professional society participation.

In addition, the licensee

s engineering groups were well

trained, and staffed with sufficient personnel of all engineering disciplines.

About a third of

all the licensee's engineering work is normally performed by contractors and consultants.

Contractor involvement is currently higher than normal due to support for the EDSFI, design

basis reconstitution efforts and a future power uprate request,

The licensee's Operational

Effectiveness Review determined that the efficiency of engineering support could be improved

by reducing the number of separate support groups which currently exist.

In summary, the quality of engineering support provided by onsite and offsite engineering

groups was good.

The licensee's

management

and engineering staff were knowledgeable and

technically competent and the engineering effort was directed toward plant safety.

Design

20

problem issues were self-identified by the licensee and corrective actions were taken to

address them.

Timeliness of evaluation, reporting and resolution of identifie'd problems was

an NRC concern during the period.

Engineering deficiency management

has been the focus

of increased licensee attention and improvement was noted.

Rmdd

This lower performance rating reflects the more comprehensive

focus during this

period on several engineering concerns,

and on weaknesses

in the management

controls which resulted in prolonged resolution of many long-standing technical issues.

III.G

afet

As e

ment/

u li

Verificati n

During the last assessment

period, this area was rated Category 1, with a declining trend.

Licensee strengths included a strong safety attitude, an effective strategic planning tool in the

Managing For Excellence program, and well-developed probabilistic risk methodologies

available to prioritize maintenance efforts and to quantify operational risks inherent with the

plant design.

Weaknesses

were also noted including inadequate contractor training on safety

concern programs, too many uncorrected fire protection deficiencies, coordination and

tracking of maintenance personnel through their training programs, and lack of full

participation by designated

security personnel at fire brigade drills.

During the current assessment

period, the licensee has effectively corrected the previously

identified weaknesses

in this area.

New procedures were written on safety concern resolution

and the licensee implemented special training for all employees to emphasize the proper way

to present and process safety concerns.

The licensee reduced the number of required fire

watches throughout the units by completing Appendix R modifications and correcting other

deficiencies.

In addition, maintenance personnel qualification was more visible. The licensee

displayed qualification status in a more prominent location to ensure that work willbe

performed by qualified personnel and also emphaiszed

the timely completion'of maintenance

worker qualification. Finally, a tracking process that assures that security personnel attend

the minimum required number of fire drills has been implemented.

This new tracking

program has assured full attendance by security personnel at drills and training.

Licensee management

continues to take an active role in assuring safe operation of the two

units.

Corporate management visits the site frequently and actively participates in plant

activities during these visits. During the current SALP period, the licensee conducted an

operational effectiveness review (OER) to review the structure of the organization and seek

changes to increase the productivity, eliminate redundant functions, and ensure functional

efficiency. The adoption of the OER program was indicative of the corporate focus on self-

21

assessment.

Station supervision also contributed to the high quality of plant activities through

routine day-to-day oversight at work sites, effective daily coordination meetings and

maintenance of high expectations regarding operational safety perspective.

The licensee continued to use its safety review committees as effective tools in assessing'and

improving plant operation.

During this assessment

period, the nuclear safety assessment

group- (NSAG) conducted thorough and extensive evaluations of plant operations,

maintenance

and outage safety.

The NSAG also performed a self-assessment

of previous plant

performance to ensure safety significant issues were being properly addressed.

These NSAG

activities have provided a significant contribution to the assurance of safety at Susquehanna.

The licensee's staff was generally well prepared and technically correct when discussing

emerging safety issues with NRC licensing.

NRC comments on licensee technical resolutions

were given due consideration before providing licensing submittals.

The licensee has an

actions tracking system which effectively monitored the progress of resolution of all pending

safety issues.

The licensee is proactive and plans its licensing activity to ensure that delays in

processing licensing actions are minimized, and that timely NRC reviews are facilitated.

The licensee has continued to demonstrate its capabilities in the field of risk assessment.

Its

individual plant evaluation (IPE) methodologies are frequently used to improve operating

procedures

and training, accident management

strategies,

and the prioritization of preventive

and corrective maintenance activities. Allof these activities were directed to minimizing the

risks to public health and safety.

The licensee is an industry leader in assessing

the risks

posed by nuclear facilities while in the shutdown mode.

Licensee event reports (LERs) were well written with clear descriptions of subject events.

Root cause analysis was adequate,

and recommended

corrective actions were technically

correct.

When in-depth engineering analysis and evaluation were required, the problem was

referred to corporate engineering for solution.

These solutions were generally very good.

Internally, the licensee uses three reporting systems to identify, document, and initiate action

on plant deficiencies including Significant Operating Occurrences Reports (SOORs), Non-

Conformance Reports (NCRs), and Engineering Discrepancy Reports (EDRs).

During this

period, Event Review Teams (ERTs) were formed to review Category

1 SOORs (the most

significant).

These ERTs were comprised of plant staff members who were the most

knowledgeable in the affected systems, equipment, or procedures.

ERTs provide a more

thorough and timely evaluation, and were found to.be very effective at identifying the

specific causal factors and broken barriers that led to these important events.

The NRC had concerns regarding the number and significance of outstanding open NCRs.

In

one case, the licensee failed to provide timely resolution of two 1988 NCRs involving

environmental qualification of limitorque motor operators for 64 containment isolation valves.

(See Section III.F) In another case,

an NCR concerning the qualification of HPCI system

22

instrumentation remained open for-a prolonged period.

Many conditionally released NCRs

existed and remained open for prolonged periods of time.

Due dates for conditionally

released NCRs were frequently extended with little or no additional justification.

As discussed in Section III.F, the lack of prompt disposition and correction of certain issues

resulted from the misclassification of safety significance.

However, later in the SALP

period, compensatory actions, operability/reportability determinations and final disposition for

safety significant issues were receiving more prompt attention.

The licensee implemented a new deficiency management

program to review all outstanding

NCRs, SOORS, and EDRs.

This program reevaluated

many old safety significant issues,

prioritized them according to safety significance, and appropriately dispositioned them.

By

the end of the SALP period, the licensee had reviewed and closed out 328 of 517 NCRs, and

271 out of 605 SOORs, and was making good progress on closing-open EDRs.

These

closure rates also included the new reports issued since the effort commenced.

The licensee

has committed significant resources

to reduce the number and age of outstanding deficiencies.

The licensee has set closure goals of 1992 for old issues and one fuel cycle for all newly

identified deficiencies.

Thus far, the licensee's progress in meeting. this goal has been

excellent.

In summary, the licensee's

management

continued to emphasize thorough self-assessment

and

organizational effectiveness.

The licensee's

technical staff was of high caliber and was

generally very thorough in resolving complex technical issues.

The use of the IPE

methodology to address normal and abnormal operational problems 'continued to be evident.

The licensee's nonconservative

approach in defining safety significant concerns resulted in

weaknesses

regarding timely discrepancy resolution and reportability determinations.

Management redefined a more conservative approach to safety significant issues and has made

significant progress in resolving outstanding discrepancies,

Perf rmance Ratin:

1

B ard

omment:

The licensee's conservative approach to nuclear activities and continued managem'ent

support of comprehensive

self-assessment

programs reflected a superior quality

program.

However, there were problems involving timely resolution of deficiencies

primarily in the area of Engineering and Technical Support.

Continued improvement

of this attribute in all appropriate functional areas should remain a management

priority.

0

,23

P RTIN

DATA AND

ARY

lVA

During the assessment

period, the Susquehanna

units operated safely and effectively. Unit 1

experienced four unplanned shutdowns, one of which was an automatic scram.

Unit 2

experienced two unplanned shutdowns, both of which were automatic scrams.

(See Section

IV.D - Reactor Trips and Unplanned Shutdowns).

Refueling outages were conducted on both units.

The Unit 2 third refueling outage took

place from September 9, 1989 through November 23, 1989 for a total of 76 days.

The Unit

1 fifth refueling outage took place from September

12, 1990 through November 17, 1990 for

a total of 66 days.

Major activities during these outages included refueling, replacement of

selected Control Rod Drives and LPRM strings, surveillance testing and inservice inspections.

Also, several major projects to address Heat Exchanger replacement,

Appendix "R", Loss of

Offsite Power, Emergency Service Water and Instrument Air upgrades were completed.

Significant events which occurred during the assessment

period included:

A significant

radiation exposure of a contractor individual in August 1989, when the individual placed a

contaminated millipore filter in his shirt pocket; two emergency diesel generator crankcase

overpressurizations

in September and October 1989 resulting in substantial damage to both

engines; an Alert was declared in Unit 1 on February 3, 1990 due to a loss of shutdown

cooling leading to reactor coolant temperatures

greater than 200 degrees F.

Temperature was

stabilized at approximately 250 degrees F and shutdown cooling was returned to service about

5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> later; in September

1990 two emergency diesel generators suffered extensive damage

when sandblast grit entered the combustion chambers from the intercoolers following

sandblast cleaning of the intercoolers.

IVAB NRC Ins ecti

n and Review Activities

During this assessment

period there were two NRC resident inspectors assigned to the site.

Several programmatic inspections were performed by regional inspectors in the areas of

Maintenance, Emergency Preparedness,

Security, Engineering, Quality Assurance,

and

Radiological Controls.

The NRC conducted the following team inspections during the period:

Electrical Distribution System Functional, Maintenance Team, Fitness For Duty, Emergency

Operating Procedures,

and Training.

There were a total of 6966 inspection hours, which

represents

5573 hours0.0645 days <br />1.548 hours <br />0.00921 weeks <br />0.00212 months <br /> on an annualized basis.

IV.C

i nificant Licen ee Meetin

A Management Meeting was held on September 6, 1989, in the NRC Region I office

to discuss licensee initiatives in the maintenance area.

24

An Enforcement Conference was held on October 3, 1989 in the NRC Region I office

to discuss the unplanned occupational exposure of a contractor employee at

Susquehanna

Unit 2.

An Enforcement Conference was held on November 21, 1989 in the NRC Region I

office to discuss a requalification program provision that allowed operators who failed

requalification to return to licensed duties prior to successful retraining and retesting.

A Management Meeting was held on December 19, 1989 in the NRC Region I office

to discuss reportability of engineering deficiencies.

A Management Meeting was held on May 23, 1990 in the NRC Region I office to

discuss the licensee's performance at the mid-SALP period.

A Management Meeting was held on July 10, 1990 in the NRC Region I office to

discuss various electrical distribution issues at Susquehanna

Units 1 and 2.

An Enforcement Conference was held on October 4, 1990 at the NRC Region I office

to discuss apparent violations regarding corrective action for environmental

qualification deficiencies and nonconformance report system concerns.

A Management Meeting was held on October 26, 1990 at the NRC Region I office to

discuss licensee initiatives in the area of discrepancy management.

A Management Meeting was held on November 15, 1990 at the PP&L Allentown

office to discuss licensee initiatives in the area of reportability.

IV.D

eactor Tri

nd

n lanned

hutdown

Date

Power

Level

~R~~ue

Functional

korea

Event De cri ti n

1.

09/08/89

100%

Personnel Error

Engineering/Technical Support

MANUALSHUTDOWN due to questionable operability of wetwell to drywell vacuum

breakers.

A damping orifice was inadvertently omitted from modification of the vacuum

breakers during the previous Unit 1 refueling outage.

4

25

eactor Tri

and

n lanned

h td wns

nt.

Date

Power

~Lev I

Functional

~r

Even De cri ti

n'.

05/28/90

100%

Component Failure

NA

AUTOMATICSCRAM due to Feedwater Control System circuit failure. The "B" level

instrument failed downscale generating a false low level signal that caused the feedwater

pumps to overfeed the vessel resultin in an actual high level turbine trip and reactor scram.

3.

02/01/90

100%

Design Deficiency

Engineering/Technical Support

MANUALSHUTDOWN due to a leak in the EHC line to the number 4 Main Turbine

Control Valve.

The leak was due to engineering specifying incorrect 0-rings during initial

plant construction.

4.

06/07/90

100%

Component Failure

NA

MANUALSHUTDOWN to replace all 4 RHR pump motor oil coolers as a result of

extensive cooler corrosion initiallyfound in Unit 2.

1.

02/06/90

100%

Component Failure

NA

AUTOMATICSCRAM due to generator load rejection.

A loose states link generated

a high

resistance connection which tripped the backup differential current protection scheme for the

500KV switchyard.

2.

05/28/90

100%

Component Failure

NA

AUTOMATICSCRAM due to Feedwater Control System circuit failure. The "B" level

instrument failed downscale generating a false low level signal that caused the feedwater

pumps to overfeed the vessel resulting in an actual high level turbine trip and reactor scram.

TABLE 1

n

ti nH

r

mrna

Susquehanna

Steam Electric Station

August 1, 1989 - November 30, 1990

FUN TI NALAREA

PLANT OPERATIONS

RADIOLOGICALCONTROLS'285

467

ANNUALIZED

HQI36.

1028

374.

ER ENT

,19

MAINTENANCE/SURVEILLANCE

1133

906

16

EMERGENCY PREPAREDNESS

SECURITY/SAFEGUARDS

ENGINEERING SUPPORT

SAFETY ASSESSMENT/

QUALITYVERIFICATION

TOTALS:

219

186

2317

1359

6966

175

149

1854

1087

5573

19

100

• Does not include NRC licensing staff hours.

// Includes 1,197 hours0.00228 days <br />0.0547 hours <br />3.257275e-4 weeks <br />7.49585e-5 months <br /> for the EDSFI Inspection and 545 hours0.00631 days <br />0.151 hours <br />9.011243e-4 weeks <br />2.073725e-4 months <br /> for the Maintenance Team

Inspection.

l+

4

~ABLE2

Enf rcem n

umma

Susquehanna

Steam Electric Station

August 1, 1989 - November 30, 1990

m er f Violations b

everi

Level

F

TI NALAREA

H

+

IV, V

QEV

TOTAL

PLANT OPERATIONS

RADIOLOGICALCONTROLS

MAINTENANCE/SURVEILLANCE

EMERGENCY PREPAREDNESS

1

2

1

3

SECURITY/SAFEGUARDS

ENGINEERING SUPPORT

SAFETY ASSESSMENT/

QUALITYVERIFICATION

1

1

1

4

TOTALS:

2

10

1

1

14

Enforcement conferences were held with the Licensee on October 3, 1989, to discuss an

unplanned personnel explosure; on November 21, 1989, to discuss a provision in the

requalification program which allowed the assignment of licensed duties to personnel that had

failed a requalification examination; and on October 4, 1990, to discuss corrective action /

environmental qualification issues.

A $25,000 civilpenalty was imposed for the latter

violation,

N TI NALAREA

~TABLE

i

n eeEv

n Re

rt

umma

Susquehanna

Steam Electric Station

August 1, 1989 - November 30, 1990

Number of LERs by Cause Code

A

B

Q

Q

E

g

~TTAL

PLANT OPERATIONS

RADIOLOGICALCONTROLS

MAINTENANCE/SURVEILLANCE

1

1

7

2

4

1

14

9

1

16

EMERGENCY PREPAREDNESS

SECURITY/SAFEGUARDS

ENGINEEMNG SUPPORT

7

1

11

SAFETY ASSESSMENT/

QUALITYVERIFICATION

- TOTAL:

6

1

1

1

9

19

7

1

5

19

2

53

This analysis includes LERs88-022 through 90-024 for Unit 1 and 89-006 through 90-012

for Unit 2.

d

A.

Personnel Error

B.

Design/Man. Constr. /Install

C.

External Cause

D.

Defective Procedure

E.

Component Failure

X.

Other

• Root Causes

assessed

by the SALP Board may differ.from those

listed in the LERs.

SUKhh I,

ALP

RITERIA

Licensee performance is assessed

in selected functional areas depending on whether the

'acility

is in a construction'r operational phase.

Functional areas normally represent areas

significant to nuclear safety and the environment.

Some functional. areas may not be assessed

because of little or no licensee activities or lack of meaningful observations in that area.

Special areas may be added to highlight significant observations.

The following evaluation criteria were used, as applicable, to assess

each functional area:

1.

Assurance of quality, including management involvement and control;

2.

Approach to resolution of technical issues from a safety standpoint;

3.

Enforcement history;

Operational and construction events (including response to, analyses of, reporting of,

and corrective actions fo');

Staffing (including management);

6.

Effectiveness of training and qualification program.

On the basis of the SALP Board assessment,

each functional area evaluated is rated according

to three performance categories,

The definitions of these performance categories are given

below:

Qate~oi~l;

Licensee management

attention to and involvement in nuclear safety or

safeguards activities resulted in a superior level of performance.

NRC willconsider reduced

levels of inspection effort.

~ate~ory 2:

Licensee management

attention to'and involvement in nuclear safety or

safeguards activities resulted in a good level of performance.

NRC willconsider maintaining

normal levels of inspection effort.

~te g~:

Licensee management attention and involvement in nuclear safety or safeguards

activities resulted in an acceptable level of performance; however, because of the NRC's

concern that a decrease in performance may approach or reach an unacceptable

level, NRC

willconsider increased levels of inspection effort.

g~ate

i~rN: Insufficient information exists to support an assessment of licensee

~ g

performance.

These cases would include instances in which a rating could not be developed

because of insufficient licensee activity or insufficient NRC inspection.

The SALP Board may assess

a functional area to compare the licensee's performance during

an entire period in order to determine a performance trend.

Generally, performance in the

latter part of a SALP period is compared to the performance of the entire period.

Trends in

performance from period to the next may also be noted.

The trend categories used by the

SALP Board are as follows:

I~mrovin: Licensee performance was determined to be improving

~Declinin:

Licensee performance was determined

to be declining and the licensee had not

satisfactorily addressed

this pattern.

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 performance category in the near

, future.

For example, a classification of "Category 2, Improving" indicates the clear potential

for "Category 1" performance in the next SALP period.

I

It should be noted that Category 3 performance,

the lowest category, represents

acceptable,

although minimally adequate,

safety performance. Ifat 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

safety.

Such matters would be dealt with independently from, and on a more urgent schedule

than, the SALP process.