ML17157B881

Initial SALP Repts 50-387/90-99 & 50-388/90-99 for 901201-920408

ML17157B881
Person / Time
Site:	Susquehanna
Issue date:	06/03/1992
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17157B882	List: ML17157B881
References
50-387-90-99, 50-388-90-99, NUDOCS 9207070028
Download: ML17157B881 (27)

See also: IR 05000387/1990099

Text

ENCLOSURE

INITIALSALP REPORT

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

=

. INITIALSYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

REPORT NOS. 50-387/90-99; 50-388/90-99

1

r

PENNSYLVANIAPOWER &LIGHT COMPANY

SUSQUEHANNA STEAM ELECTRIC STATION

UNITS 1 AND 2

ASSESSMENT PERIOD:

December

1, 1990 - April 18, 1992

BOARD MEETING DATE: June 3, 1992

9207070028

92070i

PDR

ADOCK 05000387

PDR

TABLE

F

I.

INTRODUCTION

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SUh&iARYOF RESULTS..............

II.A

Overview

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II.B

Facility Performance Analysis Summary ..

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3

PERFORMANCE ANALYSIS.........

III.A Plant Operations

III.B Radiological Controls ..........

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

III.D Emergency Preparedness

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

Reactor Scrams and Unplanned Shutdowns

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Attachment

1 - SALP Criteria

I.

INTRODVCTION

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 June 3, 1992 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)

Members

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

J. Durr, (Acting) Deputy Director, Division of Radiation Safety & Safeguards

(DRSS)

C. Miller, Director, Projects Directorate I-2, NRR

J. White, Chief, Reactor Projects Section 2A

G. Barber, Senior Resident Inspector, Susquehanna

J. Raleigh, Licensing Project Manager, NRR

Other Attendees

E. Wenzinger, Chief, Projects Branch No. 2, DRP

D. Mannai, Resident Inspector, Susquehanna

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

W. Pasciak, Chief, Facilities Radiation Protection Section, 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

H.

SUMMARYOF RESULTS

II.A

Overview

Overall, both units were operated with a demonstrated high regard for nuclear safety.

The

licensee undertook many initiatives aimed at improving safety.

The new programs were

implemented with good initial results.

Many internal and external assessments

were executed

in a thorough and complete manner.

Both units operated well with high reliability.

Licensee managers,

supervisors,

and workers communicated well among themselves,

and with

the NRC, as issues arose.

The licensee used press releases prudently to keep the media

informed of plant events and public interest items.

Frequent management

meetings between

the licensee and the NRC were viewed as a positive licensee initiative. Licensee

communications were considered a significant strength.

Operations performance remained strong.

Effective management involvement was evident in

day-to-day operations.

Operator staffing, morale, and professionalism were outstanding.

There were few personnel errors'and operators maximized the availability of safety system

equipment.

Procedure use was excellent.

Some weaknesses

were noted in operator skills in

maintaining reactor level and pressure following the Unit '1 scram that resulted in main steam

isolation valve closure.

Similar performance weaknesses

were also noted following a Unit 2

scram and during a requalification program review.

The eventual corrective actions

implemented for these weaknesses

were comprehensive;

however, the tardy response to this

problem contributed to the assignment of a declining trend to this area.

The radiological controls program was effectively administered.

While some deficiencies

existed, the licensee continues to accrue low annual exposures.

Radiological concerns were

identified in ensuring adequate postings and instructions to workers in the drywell, and

effective use of Radiation Work Permits and temporary shielding.

Effluent and

environmental monitoring, transportation and radwaste programs were very effective.

Overall, performance in this area was good.

Strong performance continued in maintenance/surveillance,

emergency preparedness,

security,

and engineering/technical

support areas.

Excellent performance was noted in the Safety Assessment/Quality Verification area.

All

levels of management

were conservatively focused on safe operations and outages.

Deficiency management

was exemplary.

The licensee's extremely effective closeout of

deficiencies resulted in establishing a low backlog of outstanding nonconformances,

engineering discrepancies

and event resolutions.

Improvements were seen in the licensee's

identification and reporting of these deficiencies.

However, concern still exists regarding the

licensee's ability to plan and implement timely corrective actions for some recurring

.problems.

Overall, the licensee emphasized

safety and quality in their conduct of nuclear

activities.

H.B

Facility Performance Analysis Sunnnary

Functional

Area

Rating, Trend

Last Period

Rating, Trend

This Period

Plant Operations

Radiological Controls

Maintenance/Surveillance

Emergency Preparedness

Security and Safeguards

1, declining

Engineering/Technical

Support

Safety Assessment/

Quality Verification

Previous Assessment

Period:

Present Assessment

Period:

August 1, 1989 to November 30, 1990

December

1, 1990 to April 18, 1992

III.

PERFORlNANCE ANALYSIS

HI.A Plant Operations

4

The previous SALP rated licensee performance in operations as Category 1. That assessment

concluded that licensee management continued to emphasize

safe and effective operations.

Operator training programs were very good and operational problems were resolved in a

prompt, effective manner.

Operations was a significant licensee strength.

Overall, operations performance continued to be strong during the current period.

Unit

availability and capacity factors reached record setting levels.

Operators were attentive to

their duties and effectively controlled planned evolutions.

Procedures were effectively used.

Corporate management provided effective oversight and was heavily involved in operational

decision making.

Operator morale was excellent.

Twelve hour shift rotations continued during the current assessment

period.

This shift

schedule has significantly reduced the need for unplanned overtime.

As evidenced by

minimal personnel errors, the switch to 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts has not adversely affected operator

performance.

Shift turnover was conducted promptly and efficiently. Operators

communicated well and system status was kept up-to-date.

Operator staffing was excellent.

Allcontrol room activities, including access control, were performed in a professional

manner.

The day-to-day performance of control room personnel was excellent.

Safety system availability received significant management attention.

Operations and plant

scheduling ensured that work planning efforts minimized emergency core cooling system

(ECCS) out-of-service time during maintenance periods.

The licensee successfully

maximized safety system availability.

There was one scram on Unit 1 and two scrams on Unit 2 during the SALP period (see

Section IV.D). None of the scrams was attributable to operator error. Operator performance

during all three scrams was sufficient to maintain the safety of the plant.

Emergency

Operating Procedures were used in all cases to bring the plant to a safe, stable state.

Some

weaknesses

were noted in operator skills needed to control reactor level and pressure during

two of the three scrams.

On January

18, 1992, a worker was mildly burned and contaminated to low levels when he

began grinding on an open-ended pipe that normally supplies the common unit offgas

hydrogen recombiner.

A leaky valve allowed the slow buildup of hydrogen which ignited

when grinding began.

The licensee's failure to recognize high offgas pressure alarms as a

symptom of an earlier hydrogen ignition, and the premature closeout of a work authorization

package which resulted in incomplete repair to a leaking maintenance boundary valve were

causal factors to this event.

The event also indicated that the licensee's implementation of

corrective actions from their early industry experience review program was not effective,

their response to the situation was extremely prompt and effective. A sixteen person team

was on-site within four hours of the initial event.

This Event Review Team (ERT) promptly

identified root causes,

causal factors, and proposed comprehensive corrective actions.

The

actions were completed in a timely manner and effectively addressed

the earlier deficiencies

which contributed to this situation.

In general, operator performance on. license examinations was very good.

Two NRC

requalifiication examinations and one initial examination involving 37 individuals were given

in the assessment

period.

The pass rate on the initial examination and the first set of

requalifiication examinations was 100%.

The pass rate on the second set of requalification

examinations was only 75%, and one of three crews did not demonstrate satisfactory

performance.

During these examinations,

weaknesses

were also observed in the

operators'bility

to manually control reactor pressure vessel (RPV) level and pressure.

These

weaknesses

were similar to those observed during the first set of requalification examinations

and during 2 of the 3 actual scrams.

Although the licensee has scheduled additional simulator

training in 1992 to improve this skills weakness,

the slowness in addressing this issue was of

concern to the NRC.

The licensed operator requalification program was determined to be satisfactory for both

requalifiication program evaluations.

However, a programmatic weakness was identified in

the evaluation techniques

used by the facility training staff during dynamic simulator

evaluations for the second program evaluation.

Once the licensee fully understood the

weaknesses,

a strong corrective action plan was developed and implemented.

The licensee did a thorough, comprehensive job during this period in resolving numerous

discrepancies identified by the NRC in an inspection (in the previous period) of the

Emergency Operating Procedures

(EOPs).

The EOP program controls are now effective for

developing and maintaining procedures of high quality.

The process for tracking EOP open

items was well organized and has ensured that identified problems were resolved.

In general,

the EOPs were found to be technically adequate,

though some deviations from the BWR

Owners Group Emergency Procedure Guidelines and the licensee's methodology for

determining area radiation action levels remain to be reviewed by the NRC.

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The site fire protection program, including procedures and training, was maintained in

accordance with industry standards.

Fire protection equipment was in good operating

condition and combustible materials were identified and stored properly.

The licensee has

made excellent progress resolving previous concerns with fire barrier penetration seals.

The

licensee's corrective actions have fully addressed

these concertos and demonstrated

a strong

commitment to effective fire barrier penetration sealing.

In fact, the average number of fire

zones requiring hourly fire watches in 1990 has decreased

from about 190 per month to about

40 per month.

The average number of these fire zones remained low at about 42 per month

in 1991 and has dropped to about 26 per month, thus far, in 1992.

The reduction in affected

fire zones reflected excellent progress toward recovering from previous weaknesses

in the fire

protection program.

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t

Plant housekeeping

was excellent.

Plant spaces were well kept.

Debris and unnecessary

clutter were not allowed to accumulate.

The licensee implemented a new administrative

procedure to improve control of transient tools and equipment.'he program described by

the procedure was very thorou'gh and detailed.

Spot checks during initial implementation

. indicated some compliance problems.

However, increased management attention has resulted

in significantly better and more consistent implementation of the procedure, resulting in

significantly better control of transient tools and equipment.

The plant painting and labeling program was a continuing success.

The licensee has

dedicated significant resources to both programs.

Painting and labeling of both unit's turbine

decks are complete and have improved the aesthetic appearance.

Similarly,

based on

discussions with plant personnel, attitudes have been positively influenced by the upgraded

appearance of the Unit'1 Radiological Control Access (RCA) point.

In summary, the licensee continues to operate both Susquehanna

units with an outstanding

regard for operational safety.

Management involvement continued to be strongly evident in

day to day operations.

Operational problems were conservatively resolved.

The operator

requalification program was generally strong, though some weaknesses

were noted.

Operator

control of reactor pressure and level during scrams reflected some inexperience with these

types of events.

Skills training is underway to improve operator responses.

Operator

staffing, morale and professionalism were outstanding.

Overall, strong, conservative plant

operations was a licensee strength.

Performance Rating:

,Board Comment:

1, Declining

An early requalification program evaluation and 2 of 3

scrams showed weaknesses

in operator skills for post

scram reactor level and pressure control. This

performance issue was the basis for the assignment of a

declining trend in this area. The additional training to

cope with this weakness while adequate,

was not

conducted in a timely manner.

III.B Radiological Controls

The radiological controls program was assessed

as Category 2.during the previous SALP

period.

Strengths included the development of various inter-departmental interface positions,

the separation of the chemistry function from the radiation protection group, and strong

management

response to radiological events.

The internal and external exposure controls

programs, including ALARAefforts, were of good quality and effectively implemented.

The

effluent monitoring and control program was effective.

Weaknesses

were noted in

management control of contractors that led to an unplanned exposure and in the sampling

methods used to classify radioactive waste.

Radiation Protection

In the current SALP period, a well-defined and staffed radiation protection (RP) organization

was maintained.

Management effectiveness of this organization was enhanced by transferring

radioactive waste (radwaste) functions to a newly formed Effluents Management Section.

The RP organization was effectively augmented during the outages with properly trained and

qualified contracted personnel.

The licensee maintained sufficient supervisory attention to

contracted personnel during these periods.

The radiation protection organization staffing level

remained stable.

Emergency radiological response'to

the victim of a hydrogen burn in a

contaminated area was prompt and effective, and demonstrated

effective contingency

planning.

The licensee continued to accrue low annual exposures through an effective

ALARAprogram.

The licensee's overall training and qualification program for radiation

protection personnel and radiation workers was found to be of good quality.

Notwithstanding the above, in some cases,

the application of radiological controls in the work

place was deficient despite the existence of excellent procedures

and a well defined program.

For example, during the Unit 1 outage, several radiological postings in the drywell were

found devoid of radiation information and several workers demonstrated insufficient

knowledge of the actual radiological conditions in the area.

Such lack of knowledge was

largely attributable to lack of sufficient radiological information provided to workers.

Also,

although Radiation Work Permits (RWPs) were well written, they did not always adequately

convey information to the worker.

Further, the temporary shielding program, while well-

established and supported with sufficient resources,

lacked criteria and guidance to assure the

effective use and optimization of temporary shielding.

Consequently,

shielding of many

sources in the drywell was found to be insufficient to assure that personnel exposures were

maintained As Low As Reasonably Achievable.

Additionally, management

has not yet resolved a long-standing potential airborne

contamination concern as a result of positive containment pressure causing air flow out of the

drywell during maintenance periods.

Several strengths were identified in the radiological control program implementation in the

workplace.

For example, the licensee has implemented good external and internal exposure

control programs.

Personnel exposure data are tabulated, evaluated,

and published at least

daily, providing good controls over accumulation of personnel exposure.

Overall monitoring

of airborne radioactivity was good.

Radiation protection personnel training, qualification,

and ability to use radiation detection instruments appeared very good.

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

Various audit

perspectives

were obtained from such diverse groups as the corporate radiation protection

group, the station quality control department,

and 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.

The ALARAgroup was involved early in station outage planning activities and had

complete access to all scheduled work packages.

Emergent work received appropriate

ALARAreviews.

Exposure goals were developed for individual departments

and jobs, and

were considered challenging and'easonable.

The recurring 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.

Due to ALARAconsiderations, in part, the pumps

are scheduled to be replaced with seal-less pumps in 1992.

While some deficiencies existed,

as previously discussed,

the licensee continues to accrue low annual exposures.

Effluent Monitoring and Control and Environmental Monitoring

The licensee continues to implement a very effective radioactive liquid and gaseous effluent

controls program.

The air cleaning systems were tested and well maintained.

Excellent

calibration techniques were implemented for the gaseous

and liquid effluent radiation

monitors.

The radiological environmental monitoring program (REMP) was effectively implemented.

The instrumentation and equipment of the meteorological monitoring program were operable,

calibrated and well maintained. The licensee implemented an effective QA/QC program to

assure the quality of the REMP sample analysis.

An NRC review of the licensee's

Personnel Dosimetry Processing

revealed a strong

commitment to quality.

The licensee demonstrated

a good understanding of the technical

issues regarding thermoluminescent dosimeter (TLD) quality assurance/quality

control, TLD

calibrations, and methods for dose assessment.

Quality Assurance (QA) audits were thorough and of good technical depth and assessed

the

programmatic performance of all three programs.

Procedures

were detailed and well written

to effectively implement these programs.

The licensee implemented an effective program for

measuring radioactivity concentrations in process and effluent samples.

Transportation and Solid Radwaste

NRC review of QA audits.and surveillances of the solid radioactive waste and transportation

program found them to be of excellent scope and technical depth.

The quality assurance

program in the solid radwaste and transportation area was good with only isolated indications

of weaknesses

that were promptly resolved.

For example, initial QA involvement with the

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spent fuel pool clean-out project was marginal,

However, following NRC identification, QA

participation improved to an acceptable level during the project.

Another problem involved

the station practice of releasing waste oil based on effluent Lower Limitof Detection (LLD)

versus environmental LLD levels.

The licensee promptly stopped this practice following

NRC identification, and revised their procedures accordingly.

The staffing and training in the newly organized Effluents Management Section were

considered excellent.

Management response to industry issues was good.

For example, as a

result of a vendor communication, the licensee determined that'a certain resin (Marlex

CL200K) used to manufacture high integrity containers (HICs) was substandard.

In response

to this concern, a nonconformance report was generated,

and the licensee successfully

identified and dispositioned

10 HICs made from this resin.

The licensee's review of this

concern was complete, thorough, and comprehensive.

Overall this functional area appeared

to be managed very well.

Summary

Formal audits of the radiological controls area were of excellent quality.

Radiological

controls were strong relative to internal and external exposure tracking and control programs,

and supervisory oversight and staffing.

However, the implementation of the program in the

drywell during outages exhibited weaknesses

relative to radiological control postings,

effectiveness of RWP's, and resolution of a problem involving positive containment pressure.

The effluent monitoring and control, environmental monitoring, transportation and radwaste

programs were well implemented and maintained.

Response to an event involving a

potentially contaminated burn victim was very effective.

The licensee's overall training

program for permanent and contractor radiation protection personnel was well done.

Performance Rating:

Board Comment:

None

III.C Maintenance/Surveillance

During the previous SALP, the Maintenance/Surveillance

functional area was rated Category

1.

The maintenance and surveillance programs were scheduled,

planned, and implemented in

an effective manner.

A strong management commitment to both programs was evident.

Personnel errors and procedural deficiencies in the maintenance area were minor weaknesses.

Surveillance activities were generally performed well.

During the current period, the maintenance program continued to be effectively implemented.

Management involvement with plant maintenance activities was excellent throughout the

period.

Management was involved daily to schedule, coordinate and adjust work activities

for planned and corrective maintenance.

I&CForemen provided increased supervisory

oversight of field activities, spending approximately fiftypercent of their time in the field.

Electrical and mechanical maintenance foremen also spent increased time in the field. The

licensee has corrected the majority of the previously identified weaknesses

and deficiencies in

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their maintenance'program.

However, some minor deficiencies still exist in the maintenance

procedures,

and the self-assessment

processes for mechanical and electrical maintenance are

not well established.

The maintenance staff was well trained and the turnover rate was low. The training program

was effective and qualification elements were well defined.

The level of experience of

maintenance personnel was high.

This strength contributed significantly to the maintenance

program as evidenced by relatively few performance errors.

Maintenance program performance was very effective as evidenced by high capacity factors

and excellent individual system availability being maintained throughout the period.

However, some weaknesses

were noted.

Control of maintenance activities on the off-gas

recombiner was weak.

Premature closeout of a previous work authorization package to repair

.

a leaking boundary valve and maintenance work documents not containing adequate

instructions relative to purging and monitoring for hydrogen were primary contributors to the

hydrogen recombiner event.

Additionally, early in the period, an unplanned ESF actuation

occurred during the performance of a maintenance activity due to personnel error.

Specifically, a Loss of Shutdown Cooling occurred during replacement of a pressure switch in

the Residual Heat Removal (RHR) pressure permissive circuitry. The cause of the event was

due to an I&Cwork planner not referencing proper electrical drawings when developing the

instructions for pressure switch replacement.

Notwithstanding these isolated deficiencies, the

overall performance of maintenance

was excellent.

During the assessment

period, a Unit 2 refueling outage was completed and a Unit 1

refueling outage was in progress at the end of the period.

Station maintenance and outage

organizations performed well in scheduling, coordinating, and accomplishing work.

Overall,

plant and system performance following the Unit 2 outage was good.

The licensee

aggressively pursued and resolved two unusual problems during the Unit 2 refueling outage.

Unidentified material was found in the reactor vessel and excessive leakage from a control

rod drive occurred during mechanism changeout.

Both problems were handled in a planned

and systematic manner and successfully resolved.

I

Several maintenance program initiatives matured during the assessment

period.

The licensee

continued tracking equipment availability and performance history to trend and assess

maintenance effectiveness.

Maintenance was prioritized according to probabilistic risk

- assessment

and reliability. The maintenance organization interacted well with operations in

the planning, scheduling, authorization and performance of maintenance activities.

The

licensee increased efforts in the use of predictive maintenance.

A supervisor, assistant

foreman, and several mechanics were assigned full time to this area.

The predictive

maintenance program was effective as demonstrated by the identification of combustible gas

in the Unit 2 "C" phase main transformer oil and bearing problems with two Unit 1 turbine.

building fans prior to component failure. The licensee's initiative in the use of predictive

maintenance

was considered

a strength.

11

The surveillance program was effective and well-managed as evidenced by no inadvertent

automatic scrams and few errors.

Scheduling and coordination were strengths of the

program.

Effective interaction with operations during performance of surveillance activities

was a significant contributor to program success.

During the assessment

period, there were no automatic scrams attributable to surveillance

activities.

Surveillance program performance was highly effective.

However, some

personnel errors and procedural deficiencies were identified. For example, an unplanned

reactor water cleanup isolation occurred due to personnel communication error when a

thermocouple calibrator was connected to the wrong test block.

Procedural deficiencies

affecting both units included:

(1) failure to include 18 manual containment isolation valves

associated with each unit in the monthly containment integrity surveillance inspection

procedures;

and, (2) failure to include a required 10 millisecond (msec) trip sensor response

time in the applicable surveillance inspection procedures relative to Turbine Stop Valve

(TSV) and Main Steam Isolation Valve (MSIV) response time verification,

These licensee

'dentified

deficiencies were promptly corrected.

Notwithstanding isolated deficiencies, the

overall conduct of the surveillance program was excellent.

The in-service inspection (ISI) program was effectively implemented.

Personnel responsible

for performing nondestructive examinations in the plant were properly qualified.

In-service

test (IST) results were well organized, trended, and thoroughly reviewed; however, the

licensee did not include check valves in the containment instrument gas (CIG) system in the

IST program as required.

The program for testing and surveillance of motor-operated valves

(MOVs) was thorough, well managed,

and on schedule.

Summary

In summary, the Susquehanna

maintenance and surveillance programs continued to be a

licensee strength. Some isolated minor weaknesses

were noted in both programs involving

personnel errors and procedural deficiencies.

Management was effectively involved and

strongly committed to the maintenance and surveillance programs.

Overall, performance was

outstanding.

Performance Rating:

Board Comment:

None

12

IH.D Emergency Preparedness

Analysis

During the last SALP period, this area improved to a Category

1 rating.

Strengths included

effective response to an Alert caused by a loss of shutdown cooling, development of Position

Specific Procedures

(PSPs), effective use of PSPs during the annual exercise, excellent

Emergency Response Facility (ERF) readiness,

ample and stable staffing, and effective

training.

Slow Media Operations Center (MOC) information dissemination was noted as a

weakness.

During the current SALP period, one Unusual Event occurred. It involved a localized

hydrogen ignition in the offgas hydrogen recombiner system and the consequent transport of a

contaminated, injured individual off-site. Timely and effective licensee response

was evident

in prompt evaluation and declaration of the Unusual Event.

MOC activation was notably

prompt.

Accurate and complete information was provided to the state, local officials, and the

public.

During the October 16, 1991, annual emergency exercise, the licensee demonstrated

excellent

on-site analysis and response capability, provided timely classifications and notifications,

appropriately prioritized tasks, exhibited a strong emphasis on personnel safety, established

effective communications between ERFs, provided excellent and frequent media briefings,

effectively tracked the progress of in-plant repair teams, developed Protective Action-

Recommendations

(PARs), and effectively interfaced with the Commonwealth of

Pennsylvania,

and Luzerne and Columbia counties.

The February 19, 1992 annual emergency exercise was characterized by excellent on-site

event analysis and response,

timely notifications, and appropriately determined PARs.

Overall; the licensee demonstrated effective performance.

However, for much of the

exercise, interim Emergency Operations Facility (EOF) management

was in charge, of the off-

site response.

Because of the consequent additional workload, the Interim Recovery Manager

was overloaded.

It was not until the corporate based Recovery Manager assumed

his position

(about three hours into the exercise) that sufficient staffing was available to effectively

manage the activities in the EOF.

The licensee has undertaken a study to determine the best

long-term means of resolving this staffing issue.

Subsequent to the end of this SALP period,

the licensee developed an interim corrective action plan of training site managers

as Recovery

Managers.

That plan was temporarily interrupted in order to pursue other possible interim

and long-term corrective actions,

However, training of TSC Emergency Directors on EOF

related response activities was completed.

The interim action plan willbe implemented upon

additional training and procedural revisions and is scheduled for completion in September,

1992.

13

NRC review noted that the October 1991 exercise scenario was challenging and provided a

good environment for self-assessment.

NRC review also noted that the February 1992-

exercise scenario was carefully tailored by the licensee to challenge the Emergency'Response

Organization (ERO) in aspects not clearly demonstrated during previous exercises and

program reviews, and that this self-challenging aspect was instrumental in revealing whether

suspect areas were problems.

Such critical self-examination'y the licensee was considered a

major strength.

Administration of the drill and exercise program was excellent.

Six station drills were

conducted in 1991 in addition to other, smaller scale drills required by the emergency plan.

Rotation of players for drills and exercises was notable.

Though ERO members -were

required to participate in drills and exercises at least once every four years to maintain

certification, the licensee established

a goal of ERO member participation once every two

years.

During this period, that goal was met by key ERO members.

Station and corporate management effectively maintained emergency response qualifications,

reviewed and approved the emergency plan and procedure changes,

participated in drills and

exercises,

and interfaced with state and local agencies.

EP training quality was excellent.

AllERO positions had sufficient numbers (3 to 5) of

trained and qualified personnel.

Classroom training was conducted throughout the year and

was well-defined.

Lesson plans were properly controlled, accurate and well detailed.

An

initiative to change from classroom-based

to performance-based

training was in progress.

Performance during the emergency exercises demonstrated

that emergency response facilities,

equipment, and supplies were very well maintained.

Emergency response procedures were

generally well-maintained, but there were weaknesses

in PSP provisions for turn-over of

functions from the Technical Support Center (TSC) to the EOF.

Administrative procedures

were well-stated.

The licensee's

1991 audit was appropriate in scope and content, and combined the Technical

Specification audit with the 10 CFR 50.54 (t) review.

Off-site interface results were

provided to state and county officials. Audit reports received wide management distribution.

To provide better visibilityand tracking of EP items, Nuclear Emergency Planning (NEP)

was in the process of transitioning to the station commitment tracking system.

NRC review

concluded that this transition was a good initiative.

EP program administration was effective.

The EP program was effectively administered by

the Supervisor, Nuclear Emergency Planning.

EP staffing was stable and had a good

discipline mix. The licensee met regularly with state and local officials to assure

coordination of emergency preparedness

activities.

14

Su~mary

In summary, the licensee has implemented an effective EP program.

Management was

effectively involved.

Response to actual events was appropriate and timely. The quality of

the drill and exercise program, the audits and reviews, and the depth of the ERO were

considered strengths.

A need for more timely full staffing of the EOF was evident, as was a

need for more specific provisions for turn-over of functions from the TSC to the EOF.

Performance Rating:

Board Comment:

None

III.E Security and Safeguards

, During the previous assessment

period the licensee's performance was rated as Category

1.

That rating was based on implementation of a highly effective and performance-oriented

security program.

Management attention and support were evident in all aspects of the

program.

Resources

were allocated to ensure necessary program upgrades and staffing, an

aggressive audit program, and an effective training program.

During this, period, the licensee continued to sustain a superior level of performance.

Upgrades and enhancements

to security systems and equipment were continued and included

the installation of state-of-the-art intrusion detection equipment on portions of the protected

area perimeter and new security computer software to provide more rapid and varied data

processing,

diagnostics and programming ease.

The upgrade of the perimeter intrusion

detection system is an ongoing project and is scheduled to be completed during the next

assessment

period.

The expenditure of resources for these capital improvements was

indicative of management's

continuing commitment to maintain an effective security program.

The security staff maintained effective communications with other station departments

and

met daily with maintenance to review security maintenance requirements and to discuss

potential interface problems.

The licensee continued effective implementation of the Fitness

for Duty (FFD) Program.

The station-supplied corrective and preventive maintenance

support for security equipment was very aggressive and resulted in excellent on-line

availability for security equipment, thus reducing the need for compensatory

measures

and

attendant overtime.

This support further reflected management's

commitment to an effective

prograIll.

Security supervisors were well trained.

These qualified security professionals closely

monitored the program and ensured that it was carried out effectively and in compliance with

NRC regulations,

as evidenced by an excellent enforcement history.

The supervisory staff

was actively supported by a very knowledgeable and effective corporate staff in making

program plan changes,

self-assessment,

upgrades,

and enhancements.

Corporate and station

15

security personnel continued to actively participate in groups engaged in nuclear plant security

matters and also maintained excellent rapport and liaison with Commonwealth and local law

enforcement agencies.

Security force staffing was consistent with program needs as

evidenced by the minimal use of overtime.

The security officers demonstrated

a very

professional demeanor and a thorough and comprehensive knowledge of their duties, the

station and its systems.

This resulted in a very positive attitude toward the program by other

station staff.

The turnover rate in the security force remained very low. The continuing-

strong demonstration of these attributes reflected the licensee's resolve to implement an

effective and high quality program.

The training and requalifiication program was well developed and administered by full time,-

highly qualified instructors.

Lesson plans were kept current and accurately reflected the

commitments in the licensee's program plans.

Facilities were provided within the owner-

controlled area for personnel training and firearms requalifiication.

They were well-equipped,

well-maintained, and made good use of instructional aids.

The training program was very

effective as evidenced by a minimum number of personnel errors.

Excellent technical

training continued, as well as training in non-security related areas such as supervisory skills

and station systems.

The training program contributed-very positively to the overall success

of the security program.

Audits of the security program conducted by the licensee's Quality Assurance Group were

found to be comprehensive

and thorough.

Findings from audits and surveillances were

directed toward improving the effectiveness of the program as opposed to being compliance-

oriented.

Corrective actions were prompt and thorough with aggressive follow-up to ensure

implementation.

The aggressive audit and surveillance program further enhanced

the quality

of the security program.

The licensee's event reporting procedures were clear, consistent with the NRC's reporting

requirements,

and well understood by the supervisory staff.

There was one event requiring a

prompt report during the period. It involved a computer failure.

Corrective actions were

prompt and appropriate.

Loggable events were appropriately tracked and, where required,

corrective action was initiated to preclude adverse trends.

The licensee submitted four security program plan changes during this period.

The revisions

were technically sound and demonstrated

a thorough knowledge and understanding of NRC

requirements

and security objectives, not only by station staff but also by corporate staff who

are responsible for this activity.

16,

Summary

In summary, the licensee continued to maintain a very effective, high quality and

performance-oriented

program.

Management attention and support were clearly evident in all

aspects of the program implementation and resources were appropriately allocated to continue

system and equipment upgrades.

In addition, a well-trained, professional staff was retained

and performance-based

audits and self-assessments

were conducted to monitor program

implementation.

These efforts reflected the licensee's commitment to a high quality and

effective security program.

Performance Rating:

Board Comments:

None

III.F Engineering/Technical Support

In the previous SALP report, Engineering and Technical Support was rated as Category 2.

Sound technical resolution of safety significant issues, plant support, an aggressive self

assessment

program in the electrical distribution area, an effective modification process,

and a

highly qualified staff were noted as positive attributes.

However, the SALP noted

weaknesses

in addressing

causal factors and the implementation of timely corrective actions

for recurring electrical bus trips due to poor design of electrical insulators, emergency diesel

generator crankcase overpressurizations,

and reactor water cleanup system pump seal failures.

The timeliness of dispositioning of engineering discrepancies

was also cited as a weakness.

During the period, the engineering and technical support organizations were reorganized to

address

these weaknesses

and to provide better support to the plant. At the end of the period,

the licensee was making good progress in resolving outstanding engineering discrepancies.

During the current SALP period, the engineering organization underwent an additional

organizational change.

As a consequence of the Organizational Effectiveness Review (OER),

the licensee re-aligned the classical engineering disciplines into Modifications, Technology,

Fuels, and Systems Engineering to provide increased focus and a unified approach for

engineering support.

Systems Engineering now reports to the engineering manager instead of

the plant superintendent.

The Modifications and Nuclear Technology organizations were

formed to recognize the diversity of roles that each performs.

Modifications focuses on the

development of design changes, while Nuclear Technology works to resolve long-term plant

and system problems.

The new organization was implemented in November 1991 and was

viewed as a positive licensee initiative. However, because of long lead times of many

engineering issues,

the effectiveness of the new organization has yet to be fully demonstrated.

17

During this period, the licensee's efforts to provide timely closeout of plant deficiencies

continued to be a high priority for the engineering organization.

The licensee's deficiency

management

strategy effectively lowered the thresholds for operability and reportability

reviews.

As a result, licensee event reports were developed for two previously identified

design weaknesses.

The first involved reactor building ventilation system performance during

an accident, and the second involved the capabilities of the 250v DC batteries to meet the

four-hour rating.

The licensee's evaluation and recent reporting of these, and other

conditions that were reevaluated and determined to be outside the design basis, were

excellent.

Corporate engineering support to the site has been very good.

Nuclear Technology

performed thorough and comprehensive evaluations of such issues as the potential pressure

locking of residual heat removal (RHR) and core spray (CS) injection valves, electrical design

deficiencies, and elevated drywell (DW) temperatures

that resulted from a loss of drywell

cooling.

The final evaluations of these issues were found to be complete, comprehensive,

'nd

of excellent quality.

One weakness

was noted in the otherwise strong performance in this

area.

This involved an incomplete initial evaluation of a drywell (DW) temperature excursion

following the loss of drywell cooling.

The licensee's initial evaluation did not consider all

the potential effects of elevated temperatures

on system, structures, and components in the

drywell. This appeared to be primarily due to a lack of effective guidance for the initiation

of detailed engineering evaluations.

The Nuclear Engineering Department design change packages continue to be 'thorough and

technically sound.

The high quality of the modification packages is evident by the small

number of changes made to the modification packages during installation.

The design and

installation kickoffmeetings are useful efforts to enhance cooperation between the Nuclear

Plant Engineering and the responsible station groups.

The system engineers are involved in

the design and installation kickoffmeetings, and provide effective overview for the

installation and closeout of,plant modifications.

The motor-operated valve (MOV) program was'horough,

'well managed,

and on schedule.

Personnel responsible for the development and implementation of the motor-operated valve

program were knowledgeable of the applicable technical and regulatory aspects of MOV

reliability determination.

Design basis reviews and motor-operated valve switch settings

calculations were thorough and technically sound.

A significant effort has been made in

conjunction with industry groups regarding motor-operated valve diagnostic test equipment,

and testing of grease for motor-operated valves under the NRC Generic Letter 89-10 MOV

program.

The engineering organization has demonstrated

an excellent safety perspective by continually

reassessing

the basis of the original design for adequacy.

The licensee has been proactive in

implementing their design basis reconstitution and has aggressively resolved discrepancies

identified by the process.

This design basis reconstitution initiative is a significant licensee

strength.

18

Systems Engineering provided effective and visible support in resolving day-to-day

engineering problems.

The licensee increased the number of system engineers by combining

the plant technical staff and the resident engineering staff. The resultant organization reduced

, the maximum number of systems assigned to an engineer from six to two. This allowed the

system engineers to develop the necessary

system expertise to effectively address day-to-day

issues.

System Engineering resolution of certain recurring deficiencies has been occasionally

ineffective or untimely. For example, spurious Electrical Protection Assembly (EPA) breaker

tripping has been a problem since 1982, but little progress has been made in establishing a

permanent solution.

Past reliability problems included inadvertent tripping of EPA breakers

due to large motor starts, poor breaker design, and high ambient temperature surrounding the

EPA logic cards.

Although the licensee has been historically slow to resolve this problem,

management

has initiated action to improve or replace the affected equipment.

In summary, the licensee has made excellent progress in reducing the number of outstanding

engineering deficiencies,

Actions in response to the OER provide increased efficiency and

focus in the engineering organization.

The new organization is effectively involved with the

understanding

and assessment of the design basis.

Systems Engineering was strengthened

significantly by the OER, and continues to resolve day-to-day problems in an effective

manner.

However, certain long-standing and recurrent problems, such as EPA breakers,

continue to require management attention to assure an-effective and timely resolution.

The

engineering organization has changed significantly during this assessment

period.

These

changes have resulted in improved focus'in many areas, while in other areas, the new

organization remains untested.

Performance Rating:

Board Comment:

None

HI.G Safety Assessment/Quality Verification

During the previous assessment

period, this area was rated Category 1.

Licensee staff was of

high caliber and capable of resolving complex technical issues.

Licensee management

emphasized

thorough self-assessment

and organizational effectiveness.

The licensee's

use of

PRA in evaluating the relative risk of various engineering and,operational deficiencies was a

noteworthy strength.

Weaknesses

were noted in resolving certain safety significant concerns,

especially postulated conditions outside the plants design basis.. In addition, in the early part

of the last SALP, the licensee allowed the backlog of open Significant Operating Occurrence

Reports (SOORs); Non Conformance Reports (NCRs) and Engineering Discrepancy Reports

(EDRs) to grow significantly. However, later in the period a backlog reduction program was

h

19

begun.

Good progress was made throughout the period in reducing the backlog.

The

licensee instituted a policy that required the closeout of all backlog items by the end of each

refueling outage.

During the current SALP period, licensee performance in this area continued to be strong.

Corporate management

continued to show a strong on-site presence and remained actively

involved with decision-making.

The integrated planning effort to ensure that all operational

and outage activities were scheduled to minimize safety impact continued as a licensee

strength.

Operational and outage safety were top priority when planning and conducting

operational evolutions, maintenance and surveillance activities.

The plant scheduling group

played an important role in ensuring that planned activities were conducted to result in a net

safety benefit.

The licensee's planning activities were conducted in a safety conscious

manner.

The licensee continues to incorporate Probabilistic Risk Assessment

(PRA) findings and

insights when planning these various types of activities.'mprovements

made to the operating

p'rocedures and training, accident management

strategies,

and the prioritization of preventive

and corrective maintenance activities are frequently the result of the individual plant

evaluation (IPE) methodologies being applied to the respective programs.

Furthermore, the

licensee.has

continued to be an industry leader in assessing

and planning for the risks nuclear

- facilities are subjected to while in shutdown conditions.

The licensee completed and fully implemented their Organizational Effectiveness Review

(OER) during this assessment

period.

The goal of the OER was to solicit and implement

grass roots level comments on how to make the organization more effective.

The new

organization increases the Nuclear Department's

span of control, while reducing the layers of

management

between the workers and senior management.

The OER dissolved certain

historical alignments and shifted the organization to be more responsive to plant needs.

The

OER was viewed as a positive licensee initiative.

The licensee continued to use the nuclear safety assessment

group (NSAG) effectively.

During the assessment

period, NSAG conducted thorough evaluations of plant operations,

maintenance and outage safety, and remained involved with performing self-assessments

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 technicaHy correct when discussing

emerging safety issues and open licensing actions with NRC staff. In general, 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.

There have been isolated

instances where responses

to licensing submittal commitments and requests for additional

information (RAIs) have been less than timely.

20

The licensee did not recognize the extent and significance of the operator performance

weaknesses

related to reactor level and pressure control identified during the first

requalification program evaluation and in a previous reactor scram event.

Therefore, they did,

not correct the weaknesses prior to the second requalifiicatio'n program evaluation.

Following

.

the second licensed operator requalifiication program evaluation, the licensee took prompt. and

comprehensive actions to address the operator performance and programmatic weaknesses:

They performed a thorough root cause analysis.

Their proposed corrective actions

appropriately addressed

the identified root causes.

I

The reductio'n of the backlog of identified deficiencies remained a licensee priority. The

licensee made significant progress in reducing the overall number of deficiencies..

When the

licensee began their deficiency reduction in August 1990, there were 277 NCRs and 378

SOORs in the backlog.

Of these, 23 NCRs and 13 SOORs remain as of April 1992.

In

addition, the licensee had identified the remaining deficiencies to be closed out in the Unit 1

Cycle. 6 refueling outage.

They have made excellent progress and their goal continues to be

zero deficiencies at the end of the outage.

The control and management of deficiencies is a

significant licensee strength.

The Susquehanna

Review Committee (SRC) and the Plant Operations Review Committee.

(PORC) continue to perform their respective off-site and on-site safety reviews.

responsibilities in an effective manner.

The SRC utilizes outside contract and utility

personnel, that bring a diverse and unique safety perspective to the committee.

The licensee

also utilized Event Review Teams (ERTs) to perform in-depth reviews of safety-related

events.

The results of their reviews were broad, comprehensive,

and demonstrated

the

licensee's strong commitment to formal root cause analysis techniques.

These investigations

were found to be extremely thorough at the plant and system level, but showed some

weakness in two specific areas.

The first w'eakness involved component level root cause investigation, specifically for high

temperature effects on electronic components.

Accelerated aging was seen in capacitors used

for the main steam line radiation monitors and for logic cards used for the reactor protection

system (RPS) EPA breakers.

The licensee's root cause analysis did not fully investigate these

component level degradations.

The second root cause investigation weakness involved the

identification of past similar industry events for the january 18, 1992 hydrogen recombiner

event.

The event review team's (ERT) initial review did not consider past industry events as

contributing to the root cause or identify other applicable similar events.

However, this

review did identify weakness in the industry experience revievy program (IERP).

The IERP's

primary focus was on the review process and did not ensure that long-lasting corrective

actions were generated.

The licensee is reevaluating their approach to these two identified

weaknesses.

Except for these two minor weaknesses,

the licensee's

safety review activities

were found to be strong and comprehensive,

with a balanced safety perspective evident.

21

.

Licensee event reports (LERs) and 10 CFR 50.72 Event Notifications (ENs) were well

written with clear descriptions of the subject events.

The root cause analyses presented in the

LERs was adequate,

and recommended corrective actions were'technically correct.

When in-

'epth

engineering analysis and evaluation were required, the problem was referred to

corporate engineering for solution.

These solutions were generally very good.

The licensee has continued their efforts to determine the root cause of the past emergency

diesel generator crankcase explosions at Susquehanna.

The quality and detail of the reports

=produced on this issue were considered to be outstanding.

In general, the documented

information and the presentations

given by the licensee were very informative and well

prepared.

Even though no single root cause for the crankcase explosions was identified, the

licensee performed corrective actions which addressed

all four major causal factors.

Overall,

the actions taken to assure the safe and reliable operation of the emergency diesel generators

are considered

a commendable effort on the part of the licensee.

The licensee was successful at resolving problems that arose on an individual occurrence basis

once they were clearly recognized.

However, there were some observations that indicated

weakness relative to the licensee's ability to recognize potentially significant problems and

effect timely corrective actions.

Examples include:

(1) operator skill weakness,

observed

early in the period in an operator requaMcation program review and, later, in actual

perfoimance involving two plant transients,

was not effectively resolved until again observed

during another operator requalification program review in January 1992; (2) operators'ailure

to recognize and fully evaluate an offgas high pressure alarm as a symptom of a probable

hydrogen ignition, two days prior to the January 18,1992 event; (3) and failure to effectively

correct a long-standing and recurring problem involving reactor protective system (RPS)

electrical protective assembly (EPA) breaker tripping events.

With these exceptions,

the

licensee has been effective in establishing and implementing good corrective measures to

resolve problems.

In summary, licensee management

demonstrated

a conservative safety perspective with a high

level of involvement with day-to-day activities and continues to emphasize thorough self-

assessment

and organizational effectiveness.

The OER has lead to increased departmental

effectiveness by emphasizing customer service.

Outstanding deficiencies received an

extraordinary amount of attention, and as a result, are at historically low levels.

Safety

review activities were conducted in an effective manner with few weaknesses

noted.

The

licensee continued to emphasize safety and quality during the conduct of nuclear activities.

Performance Rating:

Board Comment:

None

22

IV.

SUPPORTING DATAAND SUMMARY

IV.A Licensee Activities

During the assessment

period, both Susquehanna

units operated safely and effectively. Plant

availability and capacity factors reached record levels.

Unit 1 experienced one unplanned

shutdown, which was an automatic scram.

Unit 2 experienced three unplanned shutdowns;

an automatic scram, a manual scram and a manual shutdown.

(See Section IV.D - Reactor

Trips and Unplanned Shutdowns).

A refueling outage was completed on Unit 2 and a Unit 1 refueling outage was in progress at

the end of the period.

The Unit 2 fourth refueling outage took place from March 9, 1991

through May 9, 1991 for a total of 61 days.

The Unit 1 sixth refueling outage began on

March 9, 1992 and was in progress at the end of the assessment

period.

Major activities

during both outages included core refueling, main generator rotor disassembly

and inspection,

emergency core cooling system (ECCS) valve work and testing, surveillance testing and

inservice inspections.

IV.B NRC Inspection and Review Activities

During this assessment

period, there were two full-time NRC resident inspectors assigned to

the site.

They performed on-going safety inspections throughout the SALP period.

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

Maintenance, Emergency Preparedness,

Security, Engineering, and Radiological Controls.

The NRC conducted one inspection during the period involving Motor Operated Valve

Dynamic Performance (GL 89-10).

IV.C Reactor Scrams and Unplanned Shutdowns

Date

Power

Level

Root Cause

%unctional

Area

Event Description:

UNIT 1

1.

07/31/91

100%

Component Failure

N/A

AUTOMATICSCRAM due to a loss of one offsite power source with an existing half scram

condition.

The loss of power to Startup Transformer 10 (T-10) was due to a loss of the

Montour Mountain Line. The resultant undervoltage and underfrequency tripped the "A"

RPS Motor Generator Set.

This sequence completed a full scram logic signal since a half

scram signal had been previously inserted due to a failed power supply to the "B" Main

Steam Line Radiation Monitor.

23

1.

08/06/91

100%

Component Failure

N/A

AUTOMATICSCRAM due to turbine stop valve closure.

A fault in the electro-hydraulic

control system caused the ¹1, ¹3, and ¹4 turbine stop valves to close.

2.

08/21/91

100%

Component Failure

N/A

, MANUALSHUTDOWN to replace a defective main transformer.

The shutdown was based

upon high combustible gases found during analysis of transformer cooling oil.

3.

03/18/92

100%

N/A

Component Failure

MANUALSCRAM due to degraded plant conditions following 2C engineered

safeguards

'ystem

(ESS) bus lockout.

Operators manually scrammed the unit in anticipation of Main

Steam Isolation Valve Closure.

ATTACHIVlENT1

SALP WGTEMA

Licensee performance is assessed

in selected functional areas depending on whether the

facility is in a construction or 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;

4.

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

and corrective actions for);

5.

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:

Category 1:

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.

Category 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.

Category 3: 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.

Category N: Insufficient information exists to support an assessment of licensee

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 a

portion of the assessment

period to that 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 one period to the next

"

may also be noted.

The trend categories used by the SALP Board are as follows:

Improving: Licensee performance was determined to be improving

Dedining:

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.

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.