ML18086B297

Evaluation Rept:Salem Generating Station,Public Svc Electric & Gas Co of Nj.

ML18086B297
Person / Time
Site:	Salem
Issue date:	09/30/1981
From:	INSTITUTE OF NUCLEAR POWER OPERATIONS
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ML18086B296	List: ML18086B297
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NUDOCS 8202110305
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Text

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.... . J tJ Evaluation n

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• September 1981 Salem r*

L Generating Station Public Service Electric and Gas Company of New Jersey n

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1 Li EVALUATION of

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' *1 SALEM GENERATING STATION Public Service Electric and Gas Company September 1981 I' ~

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• SALEM (1981)

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SUMMARY

INTRODUCTION

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t..J The Institute of Nuclear Power Operations (INPO) conducted its first evaluation of Public Service Electric and Gas Company's (PSE&G) Salem Generating Station during the weeks of May 25 and June 1, 1981. The station, which is located on the Delaware River near Salem, New Jersey, utilizes Westinghouse pressurized water reactor plants. Net electrical output for Units 1 and 2 is 1090 and 1115 megawatts respectively. Unit 1 was placed in commercial operation in 1977.

Unit 2 has been licensed and is in startup testing for commercial operation.

PURPOSE AND SCOPE INPO conducted an evaluation of site activities to make an overall determination

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'l of plant operating safety, to evaluate management systems and controls and to u identify areas needing improvement. Information was assembled from discus-sions, interviews, observations and review of plant documents.

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'.. ...J The team examined station organization, training, operations, maintenance, radiological and chemistry activities and on-site technical support. Corporate f"! activities were not included in the scope of the evaluation, except as an j

.._.i l incidental part of the station evaluation. As a base for the evaluation, INPO used its experience on best practices within the industry and written evaluation criteria which were furnished to the station in advance. The evaluation standards are high, and the findings and recommendations are not limited to

._J " minimum safety concerns*

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DETERMINATION I Within the scope of this evaluation, the team determined that the station is being safely operated. The following beneficial practices and accomplishments were noted:

o Well-managed radiological protection programs exist in the areas of ALARA, solid waste reduction and technician training.

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1 L:J o A positive corporate commitment exists to support and upgrade training.

o A good training program exists for entry-level electrical, mechanical and instrumentation and control (I&C) craft *personnel.

o The station has a highly effective computerized system for scheduling and tracking tests, maintenance routines and action items from reports.

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Opportunities for improvement were identified as follows:

SALEM (1981)

Page 2 o The shortage of qualified personnel in several areas.

• .. _J o Industrial safety practices.

o Adherence to formal procedures.

o Management controls of important documents, procedure revisions and design modifications.

o Fragmented technical support activities.

o Operational practices in areas such as blocking of alarms, shift turnover, and tagout procedures.

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i o Formal goals and objectives for the station.

Specific evaluation findings and recommendations are contained in the accom-panying DETAILS, and information of an administrative nature is in the ADMNISTRATIVE APPENDIX. These findings were presented at an exit meeting at the plant on June 5, 1981.

Recommendations are intended to augment PSE&G's efforts to achieve the highest possible standards in its nuclear operations. Certain findings may reflect multiple deficiencies within a particular area. Therefore, in addressing these findings and recommendations, the company should look beyond correction of the specific findings and address corrective actions toward the underlying issues.

' ' To follow the timely completion of the improvements included in the responses,

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~ INPO requests written notification of status six months from the date of this report.

The evaluation staff appreciates the excellent cooperation received from all levels of the Public Service Electric and Gas Company.

E. P. Wilkinson President

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Page 3 PUBLIC SERVICE ELECTRIC AND GAS COMPANY

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_, Response Summary L...1 Public Service Electric and Gas Company is pleased to have had INPO perform an evaluation of the Salem Generating Station. INPO's review has confirmed areas we have previously identified or suspected as providing opportunities- for improvement. We readily accept the INPO recommendations which are directed toward achieving the highest standard of overall performance in our nuclear operation.

We appreciate the positive comments with respect to training, radiation protec-tion, and the computerized system for scheduling and tracking maintenance routine and action items. We are committed at all levels of management to support and improve our personnel training programs. A new training center, near the Salem site, is expected to be completed in 1982. This facility will provide a variety of classroom, laboratory and shop facilities, and two simulators duplicating the Salem and Hope Creek control rooms. The reorganization of the J

Training Department in December 1980 and additional training personnel will ensure a high standard of performance in the training area. We are encouraged with our progress regarding radiation protection programs and our commitment n

'l.J to maintain personnel exposure to radiation as low as reasonably achievable. The recent reorganization of the radiation protection group at Salem Station and the additional personnel will ensure our performance in this area will remain at a high level.

During the past several years we have continually evaluated the number and qualification of our personnel at Salem Station, particularly with respect to the changing regulatory climate. The post-TMI attitudes affecting personnel, training and licensed operators have created a number of vacancies in our Station organization. These vacancies, coupled with unexpected turbine main-tenance oh Unit No. 1, concurrent startup of Unit No. 2, and the new licensed operator training and requalification requirements have resulted in a number of areas identified by INPO as needing improvement. We are actively pursuing a vigorous hiring effort to fill the known vacancies at Salem Station and the anticipated vacancies that will result as Hope Creek Station is staffed.

We are presently reviewing our overall organization with renewed emphasis resulting from the INPO evaluation. Our goal is to establish an organizational structure _that will permit the highest possible standards of perfor!Ilance with

,...., respect to our nuclear operations.

d*- .J Regarding our specific responses to the findings, Public Service Electric and Gas Company will provide reports to INPO on a semi-annual basis as to the status of r,

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the proposed actions. We anticipate the first report will be submitted by February 15, 1982. It was a pleasure and rewarding experience to have the INPO LJ.

evaluation team at Salem Generating Station, giving us their perspective of our

,. ..., station as related to the "Standards of Excellence."

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DETAILS This portion of the report includes the detailed findings. It is composed of six sections, one for each of the major evaluation areas. Each section is headed by a

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] summary describing the scope of the evaluation and the overall finding in that area. The summary is followed by the specific findings, recommendations and utility responses related to each of INPO's evaluation procedures. Items which relate to criteria that have not been included in INPO procedures, but which are generally recognized as desirable and accepted techniques of industry and management, are referenced as "General Criterion." The evaluation procedures used are listed in the ADMINISTRATIVE APPENDIX.

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'. *..J ORGANIZATION AND ADMINISTRATION In this area, the organization_structure, personnel qualifications, administrative controls, and the programs for goals and objectives, quality assurance, industrial

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~-:.i safety and equipment surveillance were evaluated.

The equipment surveillance program is well managed. However, need for improvement exists in other areas as discussed below.

OBJECTIVF.S j (INPO Procedure OA-101, Revision 2)

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An evaluation was performed to determine how effectively goals and objectives are established and disseminated throughout all levels of the station and how

.... __ .. effective they are in conveying intended operational and maintenance directives

• Areas reviewed included station mission statements, supervisor accountability, availability of station mission documents, assessment programs, and measure-

• ... _J ment of goals and objectives attainment. Determinations were made as follows:

Finding (Reference Criteria A, B, C, D and E)

Management has not prepared a mission statement for the station nor have formal goals and objectives been established.

Recommendation Prepare and publish a mission statement that includes short-term as well as long-term goals and objectives for the station. A method of reporting goal achievement should be developed to note program success and to implement personnel accountabilities.

Response

PSE&G concurs with this finding and recommendation and will establish a program that identifies a mission statement that includes short-term as well as long-term goals and objectives for the Station by March 1982.

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SALEM (1981)

Page 5 ORGANIZATION STRUCTURE (INPO Procedure OA-102, Revision 2)

] An evaluation was performed to determine if the organizational structure provides the capability of managing a nuclear facility on a day-to-day basis in a sa:fe and efficient manner. Areas reviewed included the organizational structure 0 and reporting requirements, the establishment of written position descriptions based on job analysis, the use of position descriptions to periodically evaluate

• J\ each individual's performance, the span of control for station management positions, the backup capability for station management positions and the staff size.

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1. Finding (Reference Criterion A)

The station organization diagram dated December 30, 1980, and the organization diagram published in Administration Procedure 2, Rev. 2.

(! are not in full agreement and do not reflect the actual station organi-

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zation.

Recommendation Establish and maintain a station organization diagram that accurately

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• reflects the actual station organization. Ensure that documents and procedures affected by changes to the organization diagram are cor-

..-, rected in a timely manner .

.' II Response

-' ....l A review of the present Station organization and methods to improve the effectiveness and utilization of personnel is currently in progress. We concur with your finding. Our objective is to establish and maintain a station organization diagram that clearly and accurately reflects the actual Station organization by December 1, 1981. Documents and procedures affected by any changes to the organization diagram will be corrected in a timely manner~

2. Finding (Reference Criterion B)

\....-1 Position descriptions that define responsibility, authority, accountability and qualification requirements have not been prepared for all positions at the station.

Recommendation

...* ..i Provide position descriptions based on job analyses that define authority,

,..., responsibility, accountability and qualification requirements for each position on the station staff.

.____, Response We concur with the finding and will establish position descriptions that

• i define responsibility, authority, accountability and qualification require-I I

,'__J ments for all positions at the station by June 1, 1982.

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Performance evaluations are conducted annually but are not based on position descriptions.

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Recommendation Revise the performance appraisal program to include performance evaluations based on position descriptions.

Response

The performance appraisal program will be revised to include perfor-mance evaluations based upon position descriptions by June 1982.

4. Finding (Reference Criterion D)

The span of control for the Station Quality Assurance Supervisor and the .

Yard Supervisor appears excessive.

Recommendation

-1. t Evaluate the span of control for the supervisors and adjust as needed *

__ j Continue efforts currently underway to obtain assistance for the Yard Supervisor.

Response

' The Corporate Quality Assurance (QA) Department is currently review-ing the Salem Station QA organization and responsibilities. Changes to the QA organization, which will address the present span of control for the QA Supervisor,. will be completed by September 30, 1981.

An additional Yard Supervisor has now been placed on the Station staff.

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5. Finding (Reference Criterion F)

Overtime for several supervisory groups appears high. The Yard Supervisor, Performance Supervisors and Radiation Program Supervisors all accumulated greater than 40 percent overtime by March 1, 1981.

Recommendation Evaluate the technical and administrative workload of those supervisors and implement corrective action to bring overtime to more reasonable levels.

Response

An additional Performance Supervisor was added to the Station staff on July 10, 1981. The vacancies associated with the Radiation Protection Supervisor and the Yard Supervisor have been filled. The current review of the present Station organization is addressing the manpower require-ments for each position. Requests for additional personnel, if required, will be processed in a timely manner and positions filled in a prudent u l fashion. Station efforts are in progress to review and reduce, wherever possible, excessive overtime.

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SALEM (1981)

Page 7 ADMINISTRATIVE CONTROLS (INPO Procedure OA-103, Revision 2)

An evaluation was performed to determine the effectiveness of the controls for administrative functions. Areas reviewed addressed the program of administra-

~ tive controls for purpose, scope, responsibilities,. flexibility, level of administra-u tive-actions and program dissemination.

l. Finding (Reference Criterion C)

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~ - Administrative functions are not always accomplished at the lowest appropriate level. This sometimes interferes with the primary role of I~

supervisory and management personnel.

l*.*i Recommendation*

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'\ ___-\} Delegate administrative duties to the lowest appropriate levels in order I

to reduce the administrative workload of supervisory personnel.

Response

The current review of the Station organization is addressing the respon-sibilities associated with each position. Administrative duties will be reviewed to ensure assignments of this nature occur at the lowest

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!_: i appropriate. levels in order to reduce the administrative workload of

,1..d supervisory personnel. We expect to c.omply with the recommendation of this section by March 1, 1982.

2. Finding (Reference Criterion D)

Interpretation and implementation of station administrative procedures are not always consistent between departments at the station. In addition, adherence to administrative procedures is not uniformly re-quired. During the evaluation period, several instances of non-confor-mance to written procedures were observed. Examples include industrial safety, tagout, frisking procedures, and shift turnover.

Recommendation Review station administrative procedures with respect to:

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o requiring station departments to interpret and implement proce-r-1 dures in a more consistent manner -

' o establishing and maintaining closer adherence to procedures.

Response

PSE&G concurs with the finding and will institute a review of the Station Administrative Procedures with respect to interpretation, implementa-tion and adherence on a uniform basis. We expect this review and implementation of any corrective actions to be completed by June 1, 1982.

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QUALITY PROGRAMS (INPO Procedure OA-104, Revision 5)

An evaluation was conducted to determine how effectively quality programs monitor and audit station activities to promote accomplishment of the station LJ

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Page 8 mission. Areas reviewed included management controls, accountability pro- -

grams, program cross checks, program effectiveness, programs for corrective actions and staffing.

1.. Finding (Reference Criterion A)

Management controls do not require regular observation of plant opera-

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. -- tion by station supervisors, particularly by senior management

• Recommendation Establish management- controls that require station supervisors and

- management to routinely get out into the plant and observe plant activities in progress to ensure the quality of operations, maintenance, and high standards of industrial safety and housekeeping.

Response

PSE&G concurs with the finding that present management controls do not require regular observation of plant operation by Station supervisors, r--

particularly senior management. The current review of the station

_,j u organization is addressing responsibilities associated with each position

• It is anticipated that the results of this review will identify a reorganiza-tion and reassignment of responsibilities that will permit supervisors, as Q well as senior management, to spend more time in the plant observing activities in progress. We expect to implement corrective actions resulting from this review by December 31, 1981. With the continued addition of supervisors to fill existing vacancies, improvements in this area are in progress.

2. Finding (Reference Criterion B)

An approved quality program is in place but is not functioning adequately in every aspect of the operation. Little emphasis is placed on non-safety-related aspects of operations. Only limited coverage is provided

,_, in some areas such as surveillance, in-service inspection and chemistry.

Recommendation Expand quality programs coverage to all aspects of station operation in a graduated manner, including non-safety as well as safety-related areas.

Response

The development of a formal balance-of-plant QA program has been initiated and is expected to be completed by April 1, 1982. The QA Department is currently reviewing the surveillance program for all station activities in conjunction with the examination of position respon-sibilities and organization structure. The results of this review will be incorporated into revised quality assurance instructions for specific surveillances. These instructions when combined with an increase in staffing levels will correct deficiencies in operations surveillance, in-101

,.: service inspection and chemistry. It is expected that these instructions will be issued by September 30, 1981.

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SALEM (1981)

Page 9 iNDUs'rRI.AL SAFETY (INPO Procedure OA-106, Revision 3)

An evaluation was performed to determine if a safe working environment was I I provided for station personnel. Areas reviewed included plant commitment to safety, attitude toward safety, employee involvement and cooperation in acci-dent prevention, and .work practices and safety considerations peculiar to the nu station.

1. Finding* (Reference Criterion B)

_Although an approved safety program exists, management emphasis and enforcement of industrial safety rules need improvement. As an example, monthly safety meetings by each department, as required by*

station directive, are frequently not held.

Recommendation Increase attention to and emphasis on industrial safety.

Response

i The Station Manager has re-emphasized to all station personnel the

~--J importance of adhering to the requirements of the existing safety program. Methods to ensure continued compliance with the safety program have been established.

2. Finding (Reference Criterion D)

A station safety guide has not been published for distribution to. each employee. Employee responsibilities within the safety program are described in a Station Safety Manual which is distributed only to supervisors.

Recommendation Prepare and distribute to all employees an industrial safety handbook applicable to the Salem Station.

Response

An industrial safety handbook, applicable to Salem Station, is being

,,~*** developed and will be distributed to all employees by November 1, 1981.

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SURVEILLANCE PROGRAM i : (INPO Procedure OA-107, Revision 3)

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u An evaluation was performed to determine if an effective program exists to accomplish surveillance inspection and testing. Areas reviewed included com-pleteness, depth, acceptance criteria, results review, notification and control of off-standard conditions, suitable scheduling and training in proper use of surveillance procedures.

\1 lJ Finding All criteria in this procedure were met.

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SALEM (1981)

Page 10 PERSONNEL QUALIFICATIONS (INPO Procedure OA-108, Revision 2)

An evaluation was performed to determine if a program exists for qualifying

• personnel to operate and maintain the station. Areas reviewed included the ru*** .

applicability of all job descriptions for each station position; the program for personnel promotion or selection and the program for periodic review of all job qualification requirements.

n u . Finding (Reference Criterion C)

Periodic review and revision of personnel qualification requirements are needed.

n. ' Recommendation

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I Establish a program to periodically review and revise, as needed, qualification requirements for all station positions.

Response

A program to periodically review and revise qualification requirements for all Station positions will be established by June 1, 1982 *

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Page 11 TRAINING AND QUALIFICATIONS

\_j i In this area, an evaluation of the training organization, administration and resources was conducted. In addition, training programs for licensed and non-('-""1 licensed operators, shift technical advisors and maintenance personnel were i"'j evaluated.

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As a general observation, training for Salem personnel is moving in a positive G '.

direction. Recent reorganization of training functions, addition of training management and acquisition of training facilities reflect management's aware-ness of past training deficiencies and commitment to address them.

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TRAINING ORGANIZATION (INPO Procedure TQ-201, Revision 0)

An evaluation was performed to determine if the station has a clearly defined training organization, staffed with qualified personnel who are capable of accomplishing all assigned training tasks. Areas reviewed included the organiza-tional structure, training staff size and instructor qualifications.

l. Finding* {Reference Criterion A)

Although informal working relationships between the training staff and other departments have been established and are functioning, the training organization is not clearly defined. Administrative procedures

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, _ _j and training procedures do not accurately reflect current organizational or functional relationships to other departments.

Recommendation Revise those administrative and training procedures that define the current training organization to ensure their accuracy. The functional relationships between the station organization and training organization n should be included in these revisions or should be documented separately.

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! Response u Administrative procedures describing the training organization and its relationship with Salem Station have been drafted and distributed for review and comment. Final procedures are expected to be completed and implemented by October 1, 1981.

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LJ 2. Finding (Reference Criterion B)*

In the operations training area, the training organization is not of

~--:i I I sufficient size to perform all normally assigned responsibilities. This is

, I recognized by management. Currently, openings for five additional C.J people exist. Two of these openings are for people with boiling water reactor experience to prepare the training programs for Hope Creek.

Recommendation Bring the staff to authorized levels to permit timely development of needed instructional capabilities.

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Response

We concur with this finding and are in the process of filling the existing

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TRAINING ADMINISTRATION (INPO Procedure TQ-202, Revision 0)

An evaluation was performed to determine if the administrative functions necessary to initiate and control personnel qualification programs are accom-plished in a well-defined, coordinated and effective manner. Areas reviewed

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\ included training. goals and objectives and the programs for conducting trainee evaluations, conducting. training audits, measuring instructor performance and documenting qualification and requalification activities and results.

1. Finding (General Criterion) ,

Improvement is needed in the training manual. The description of

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. *l training* programs for station personnel is not current or fully

~-~j comprehensive. In some cases, training programs are provided that are not reflected in the training manual, while in others, programs are not conducted as they have been described and approved.

Recommendation u Deveiop and issue a revision to the current training manual describing the content of all training programs provided by the training organi-zation for station personnel.

Response

Training programs and procedures for all courses administered and conducted by the Training Department are reviewed prior to each class offering. A formal, written procedure for revising course contents with Station concurrence is in effect. A completely revised Training Manual

(") will be issued by January 1982.

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2. Finding (Reference Criterion A)

The training organization does not have established policies and procedures for accomplishing and monitoring some training functions, including evaluation of instructor performance, determination of trainee entry-level aptitudes, knowledge and skills, and the development of training programs.

Recommendation Develop and publish appropriate policies and/or procedures to describe i-"l,

~1 the conduct of training and the monitoring of training functions.

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A formalized evaluation of instructor performance will be included as a portion of the Instructor Development Program scheduled to be in effect.

by October 1981. Currently, trainee entry-level aptitudes, knowledge, and skills are measured by approved pre-employment test batteries. The

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Company is currently reviewing other types of tests for a variety of

.-, skilled worker positions to *determine a more effective method of

' . identifying individual aptitudes, knowledge and skills. Policies and

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\ procedure for implementing and monitoring training program develop-ment will be addressed by June 1982.

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'*.i lJ TRAINING RESOURCF.S (INPO Procedure TQ-205, Revision 0)

An evaluation was performed to determine if the plant has sufficient resources to support the delivery of high quality training for nuclear power plant personnel.

Areas of interest included review of facilities for suitable classrooms, labora-tories, workshops, office space, training materials, aids and equipment, lesson .

development and accommodations to support the trainers and trainees.

Finding All criteria in this procedure were met.

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I l LICENSED OPERATOR REQUALIFICATION TRAINING (INPO Procedure TQ-223, Revision 0)

An evaluation was performed to determine if adequate training exists to t__ ) maintain a high level of knowledge and skill in individuals licensed as reactor operators and senior reactor operators. Areas reviewed included development and use of training materials used to inform licensed operators of procedure changes, licensee event reports, plant modifications, changes in station licensing requirements and vendor information affecting operation. In addition, station

' .* policy on use of a training simulator, periodic program evaluation, and provisi9ns for delinquent operator identification and requalification were reviewed.

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1. Finding (Reference Criterion A)

Improvement is needed in the licensed operator requalification program.

1....:...J Requalification training has been impacted by Unit 2 licensing training and the availability of licensed personnel for training because of minimum operating staff levels.

Recommendation Upgrade the plan for licensed operator requalification and fully

.,., implement the program.

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Response

___:j The previous licensed operator requalification program was severely affected by post-TMI changes implemented by the NRC's Operator Licensing Branch and by a concurrent loss of some of our licensed

. _1 personnel to positions outside PSE&G. With NRC permission our requalification program was suspended after the TMI incident for ap-proximately 18 months. This allowed the Unit No. 1 licensed operators to attend classes and be re-examined by the NRC as a requirement prior

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'*- to the issuance of Unit No. 2 operating license. In January 1981 the licensed operator requalification program was re-established on an

. \ abbreviated schedule in order to minimize the significant overtime

\~.J burden on the available licensed operators. All licensed operators completed the selected retraining by June 1, 1981. Presently, there are 13 nuclear control operators in training for a reactor operator's license.

Our current efforts to hire additional candidates for the nuclear control operator's position and to sucessfully qualify these individuals as licensed.

reactor operators will increase the existing staff of licensed operators.

These additional operators will ensure training is properly attended and conducted without reducing the training schedule because of operator

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' I LJ 2~ ~inding (Reference Criterion F)

Oral examinations are not administered as part of the licensed operator

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Recommendation Conduct oral examinations annually as part of the licensed operator n

) I requalification program *.

u Response The revised Training Procedure 10 (TP-10), Licensed Operator Requalifi-r1

4 cation Program, which includes provisions for an oral examination, has I '.

u been implemented. *

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\ _ _j I The licensed operator requalification program is not evaluated for I l effectiveness in achieving program goals and improving job performance.

Recommendation *

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Perform an annual evaluation of the licensed operator requalification program to assess its effectiveness.

Response

The revised Training Procedure 10 (TP-10)Section IV.C, des~ribing the method by which the requalifica tion program will be reviewed and re-evaluated, has been implemented.

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SIDFT TECHNICAL ADVISOR TRAINING rJ. (INPO Procedure TQ-224, Revision 0)

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.~J An evaluation was performed to determine if an adequate program exists to provide the shift technical advisors (STAs) with initial and continuing training necessary to ensure safe and effective performance of assigned duties. Areas reviewed included the STA training program for college-level and site-specific requirements, retraining program including on-site and off-site event analysis,

• 1 simulator time and pertinent documentation of all training.

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Finding (Reference Criterion F)

Although shift technical advisors (STAs) have been included in the

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licensed operator requalification training, a requalification program,

,_j structured specifically for ST As has not been developed.

Recommendation

• Develop and implement a requalification program for shift technical

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. advisors.. An INPO document titled "Nuclear Power Plant Shift Technical Advisor, Recommendations for Position Description,

• Qualifications, Education and Training" (INPO #GPG-01),. provides guidance in this area.

Response*

Training programs and procedures for all courses administered and conducted by the Training Department will be included in the Training Manual to be issued by January 1, 1982. The current Shift Technical Advisor (ST A) Training Program has been reviewed and _approved by the NRC as part of Unit No. 2's licensing process. The INPO document

1. GPG-01 will be used in conjunction with the STA Training and Requali-fica tion Programs. The Training Manual will also address the ST A Requalification Program.

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u NON-LICENSED OPERATOR TRAINING r: (INPO Procedure TQ-242, Revision 2)

~,J An evaluation was performed to determine if an effective program exists to provide initial and continuing training for non-licensed operators to ensure that

["-! they are capable of performing their jobs safely and effectively. Areas reviewed

._J included the procedures for initial and continuing training of non-licensed operators, selection and promotion screening, utilization of classrooms and on-ri i the-job training.

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Finding (Reference Criterion D)

--. A continuing training program for non-licensed operators has not been developed. A plan to provide this training is under consideration.

Recommendation

---. Develop and implement a continuing training program for non-licensed operators. An INPO document titled "Nuclear Plant Non-Licensed L;j Operator Guidelines for Qualification" (INPO #GPG-04), provides guid-ance in this area.

r~1 Response

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A training/requalification program for equipment operators (non-licensed operators) utilizing the INPO document #GPG-04 for guidance is being

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the Training Manual and will be implemented by January 1, 1982.

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___ :..J" LICENSED OPERATOR TRAINING (INPO Procedure TQ-243, Revision 1)

I .l l .* ~,;.I. An evaluation was performed to determine if an effective program exists to provide training to candidates for operator and senior operator licenses. Areas reviewed included the licensed operator tl'.aining program for content, base level

• of knowledge, training materials, source input, systems and fundamentals, operating practices, and candidate and program evaluation.

Finding All criteria in this. procedure were met.

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SALEM (1981)

Page 17 OPERATIONS Operations activities were eval.uated in the areas of organization and adminis-tration, tagout practices, conduct of shift operations, use and content of p~ocedures, plant status controls, facilities and equipment and shift turnover.

It should be noted that during. the first day of the evaluation Salem Unit 1 was placed in cold shutdown, following a main turbine failure. Salem Unit 2 was in D

l- start-up testing during the entire evaluation.

OPERATIONS ORGANIZATION AND ADMINISTRATION (INPO Procedure OP-301, Revision 3)

An evaluation was performed to determine the existence .of a clearly defined Y .* ;

i operations organization that provides for the assignment of responsibilities and delegation of adequate authority for accomplishment of required tasks. Areas reviewed included organizational structure, job descriptions, shift administrative Cl assignments, written and oral instructions and orders, and miscellaneous adminis-u trative programs.

Finding (Reference Criterion A)

The current staffing level of licensed reactor operators is not sufficient to operate the station and conduct comprehensive operator retraining.

This problem may be partially alleviated when the results of current licensing examinations are known; however, advance planning is necessary to ensure that a similar problem does not occur when the Hope Creek site is staffed.

Recommendation

~-: Provide sufficient licensed operators to permit simultaneous station operation and a comprehensive program of operator retraining. Review IT long-range planning to ensure Hope Creek can be adequately staffed without seriously impacting Salem staffing levels.

L.1

Response

We concur with your finding in this area. In August 1980, we identified the staffing deficiencies for both licensed and non-licensed operators and developed a program to increase these levels accordingly. We are actively involved in hiring qualified candidates for all vacancies in Salem Station and those projected for Hope Creek Station. Thirteen nuclear control operators are presently enrolled in our training program for reactor operators, which is expected to be completed in November 1981, followed by the NRC administering the licensed reactor operator exami-nation. The Training Department, in conjunction with Salem Station, has developed a long-range training program for all positions requiring specific and/or specialized training in order to ensure Salem and Hope

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Creek Stations will be adequately staffed.

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SALEM (1981)

[ Page 18

.. *' TAGOUT PRACTICES (INPO Procedure OP-302, Revision 2)

c. ..J An evaluation was performed to determine if established tagout practices ensure protection for personnel and station equipment. Areas reviewed included senior

~

reactor operator (SRO) approval of safety-related tagouts, double verification of

. tagged equipment for personnel safety, double verification of important manual

. valves. that are* repositioned during maintenance or' test, tag coloring and numbering, and review of the* clearance log.

1. Finding (Reference Criterion C)

The existing procedures for *independent verification of component position on safety-related systems do not require that the independent verification be* performed while in cold shutdown or refueling conditions.

Recommendation .

Expand the existing procedures to include the requirement to conduct an independent verification of applicable components while at cold shut-down and refueling conditions.

Response

An Operating Department Memorandum (OM-19) has been issued re-quiring independent verification of safety-related system components in all modes of operation including cold shutdown and refueling. A revision to Administrative Procedure No *. 15 (AP-15) Safety Tagging Program will be completed by December 31, 1981, requiring independent verification of safety-related components in all operating modes including cold shut-down and refueling.

2. Finding (Reference Criterion E)

The status of the tagouts is not always verified by persons responsible

\ j for work on the tagged equipment prior to the commencement of work as required by Administrative Procedure 15 (AP-15).

Recommendation Require that personnel comply with the tagout procedures as specified in AP-15.

,.,'.\

Response

The requirements of Administrative Procedure No. 15 (AP-15) Safety Tagging Program have been re-emphasized with all station supervisors by their respective department heads. Compliance with these requirements will be periodically reviewed.

3.. Finding (Reference Criterion G)

Although a periodic audit of tagouts is being performed, the full intent of an audit is not being accomplished in that it does not include a check of the adequacy of the tagouts, the position of tagged equipment and the presence of outdated or unauthorized tags.

Recommendation Revise current audit practices to include the above items.

r~ Response J

i A computerized tracking system associated with the Station's Safety Tagging System is currently being implemented. This system, along with procedures to check the adequacy of tagouts, the position of tagged equipment and the presence of outdated or unauthorized tags, will be in effect by January 1, 1982 .

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(, _J SALEM (1981)

• Page 19

,,. 4. Finding (General Criterion)

The existing tagging system dfffers from current industry practices and does not provide for control of a clearance from tag issue to final tag removal and restoration of the system to service. It is recognized that a project to review and revise the system is currently in progress.

Recommendation Continue the current review and revision project. Consider including the

• following items:

CJ t i lJ o sequential numbering of each clearance to be used as an identifier o logging clearances by the sequential number for quick and easy.

review of current clearances o providing for transfer of a clearance to eliminate release and rewrite o writing instructions to the person placing the clearance as to the position of the clearance point (e.g., valve open or closed)

\*.. ~ Response .

PSE&G has initiated a Tagging Rules Review Task Force to review the present Safety Tagging System. Corrective actions will be implemented by December 1, 1981.

CONDUCT OF SHIFT OPERATIONS (INPO Procedure OP-303, Revision 3)

An evaluation was performed to determine how effectively the conduct of shift operations maintains quality shift performance. Areas reviewed included opera-tor activities, station cleanliness and order, response to abnormal conditions, logkeeping practices,. reliability of control room instrumentation and operator awareness of plant conditions.

1. Finding (Reference Criterion B) f -. General housekeeping and cleanliness needed improvement in many areas

. *.. J of the station, particularly in the auxiliary building, elevation 84' of the turbine building and the service water intake structure. Improvements r*::; were noted during the evaluation period.

Recommendation L..J Reassess and enforce housekeeping responsibilities for PSE&G personnel and require that contractor personnel also support station housekeeping policies.

Response

PSE&G concurs with the finding in this area. Station management has addressed housekeeping requirements and responsibilities with all station and contractor personnel. Specific groups have been assigned the responsibility, on a daily basis, for housekeeping and cleanliness within the Station.

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SALEM (1981)

• . Page 20 il I  !

2. Finding (Reference Criterion D) l_J No established policy or procedure is in use to identify and mark inopera-tive or out-of-tolerance instrumentation.

Recommendation Establish a program or policy to readily indicate to operating personnel that a specific instrument is unreliable or inoperative*.

Response*

A procedure implementing this recommendation has been promulgated.

3~ Finding (Reference Criterion I)

Changes to significant procedures are sometimes issued without notifica-tion to the operators.

Recommendation Develop a program to notify the operator of new or revised procedures.

r--_... Response

.J .i; A method for notifying operators of changes to significant procedures

• ~  ;

has been implemented.

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f _:_j*1 USE OF PROCEDURES (INPO Procedure OP-304, Revision 2)

An evaluation was performed to determine proper use of procedures to conduct operations safely and reliably. Areas reviewed included management policy for use of procedures and changes to procedures (short-term and long-term). In addition, procedures were reviewed for clarity, continuity, identification of "sequence required" actions and suitable advisory information*.

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1. Finding (Reference Criterion A) l u The established management policy for use of procedures does not delineate the specific conditions for which procedures and check sheets are required to be "irl-hand." Also, the policy does not address the use of emergency instructions (Els) or specify those portions of Els that must be memorized by the operator.

r*-:*

Recommendation f i *:t Revise the existing policy for use of procedures to include the above I

items.

Response

In accordance with -existing programs, all operating procedures and emergency instructions are formally reviewed at least every two years.

During these reviews we will determine the need for the operators to use the procedure and/or check lists "in-hand" and appropriately identify this requirement. A requirement for licensed operators to memorize imme-diate actions associated with emergency instructions will be issued by December 1, 1981.

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SALEM (1981) f -.,

Page 21 i  !

2. Finding (Reference Criterion E)

On-the-spot changes to procedures in use by the operators do not indicate approval by the Station Operations Review Committee (SORC).

Further, a timely review and revision of procedures to incorporate these changes is not being performed.

('1 'J Recommendation

! l 1.Jl Replace the draft copy of the on-the-spot change with an approved copy as required in Administrative Procedure AP-3. Develop a program of review, and revision of procedures to agree with the two-year require-ment of Administrative Procedure AP-3 *.

Response

- A program to review and revise all operating and emergency instructions on a two-year cycle has been implemented. Special direction has been given to the Operating Department support staff to incorporate on-the-spot changes into the appropriate procedures in a more timely manner.

{ -, We will continue to review the philosophy and use of on-the-spot changes

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., _: to procedures in order to improve their use and effectiveness

• PLANT STATUS-CONTROLS (INPO Procedure OP-305, Revision 2)

An evaluation was performed to determine- if plant status controls are provided

... _: to ensure adequate equipment and system availability. Areas reviewed included

• management programs and policies that provide guidance, actual practices, i - responsibilities of senior licensed operators assigned to monitor and review I

status control, and provisions for special conditions (e.g., outages, accident recovery, or refueling).

Finding (Reference Criterion A)

Alarms are sometimes blocked and made inoperative without formal authority or recording to ensure that others are aware of the blockage.

Recommendation Develop a procedure to more closely control the blocking of alarms.

Response

A procedure has been implemented to permit and readily identify the blocking of alarms when properly authorized.

OPERATIONS FACILITIES AND EQUIPMENT (INPO Procedure OP-306, Revision 2)

An evaluation was performed to determine if station facilities and equipment are r-1 I

' l ' operated and maintained in a manner that ensures safe and efficient operation.

I I Areas reviewed included equipment service needs, effect of the working environ-ment on safe and efficient station operation and adequacy of communications equipment.

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SALEM (1981)

• . Page 22 i

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1. Finding (Reference Criterion A)

Access to some station equipment and controls, such as electrical switchgear and emergency diesel engines, is obstructed by temporary scaffolding and temporary storage of loose items.

Recommendation Initiate a policy to ensure free access to all operating and standby equipment,. including electrical switchgear.

Response

i "'g This finding was immediately corrected by Station personnel following

*] identification *. Operations personnel have been instructed to ensure free

\:..._.

access is maintained *to all operating and standby equipment including electrical switchgear~ Obstacles and/or* debris impacting free access to

] equipment are to be reported immediately in order to facilitate- correc-

! tive action. The recommendation has been included in the monthly area inspections conducted by the Safety Supervisor.

I:~;

2.. Finding (Reference Criterion B)

Improvements are needed in the logsheets and procedures in use by equipment operators and utility operators to ensure operating equipment, standby equipment and general station conditions are properly moni-tored.

• '-:)

\._.*., Rf?commendation _

[j Provide additional guidance to operators on how to perform checks of operating and standby equipment. Guidance could be in the form of check-off sheets, modified log sheets or a procedure. Provisions should i' :

i 1._* .:;

be included to also check station conditions such as fire and industrial safety hazards, cleanliness conditions, equipment accessibility and I --::~

system leakage.

I I Response PSE&G concurs with the finding and will implement the recommendation by October 1, 1981.

SHIFT TURNOVER (INPO Procedure OP-307, Revision 1)

.__; An evaluation was performed to determine if continuous, correct understanding of station conditions is maintained at all shift positions. Areas reviewed included programs and policies controlling shift turnover practices for watch stations, checklists, operating panel review and station activities in progress or planned.

1. Finding (Reference Criterion A)

The procedures for shift turnover do not include turnover requirements I,

for the shift technical advisor or the senior reactor operator in charge of fuel handling.

Recommendation Revise station procedures to include shift relief requirements for the ST A and the SRO in charge of fuel handling.

SALEM (1981)

I Page 23

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Response

PSE&G concurs with the finding and will* implement the recommendation by October 1, 1981.

._ 2~ Finding (Reference Criterion B)

J ..

A shift turnover checklist is not used for shift positions other than for the senior shift supervisor.

Recommendation

'1 . Develop shift relief checklists for each shift position.

J Response-PSE&G concurs with the finding and will implement the recommendation by October 1, 1981.

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SALEM (1981)

Page 24 MAINTENANCE The Maintenance Department and Instrumentation and Control (I&C) Group were evaluated in the areas of organization and administration, preventive mainte-nance, procedures, work control systems, maintenance history, facilities and equipment, special processes and control of test equipment. Several positive programs and practices were noted in the maintenance and I&C areas. The overall size, arrangement and allocation of facilities aid performance of the mai*ntenance function. The Inspection Order System is an effective method for identifying, scheduling and tracking repetitive tasks. The scheduling system in use in the I&C Group allows efficient use of technicians, includes timely attention to work orders and provides feedback to supervisors. Specific areas where improvements could be made are noted in the following discussions.

MAINTENANCE ORGANIZATION AND ADMINISTRATION (INPO Procedure MA-401, Revision 3)

An evaluation was performed to determine how effectively the maintenance and I&C organizations and administrative programs function to enhance performance of maintenance tasks. Areas reviewed included organizational structure, report-ing requirements and practices, staff size, training and certain administrative programs.

1. Finding (Reference Criterion B)

An insufficient number of I&C technicians have achieved qualification levels needed to perform all assigned tasks. As a result, overtime for qualified technicians and supervisors is high.

Recommendation Initiate an aggressive program to increase the number of qualified I&C technicians. The training should be designed to eliminate dependence on a few specialized technicians.

Response

PSE&G is currently reviewing the I&C personnel with respect to qualifi-cations, training and availability. Appropriate corrective action will be implemented by January 1, 1981 to increase the number of qualified I&C technicians and to eliminate dependence on a few specialized techni-cians.

2. Finding (Reference Criterion B)

An increase is needed in the number of qualified maintenance supervisors to provide more direct supervision of work and increased coverage for backshifts and weekends.

Recommendation Increase the number of maintenance supervisors to the authorized level.

Response .

As of July 3, 1981 two maintenance supervisors have been added to the Maintenance Department and have completed the appropriate training for new supervisors. We are actively involved in filling all vacancies

SALEM (1981)

Page 25 identified on the Station staff. We are reviewing alternate means of achieving adequate maintenance supervision in the event routine back-shift and weekend work continues.

PREVENTIVE MAINTENANCE (INPO Procedure MA-402, Revision 2)

An evaluation was performed to determine the effectiveness of maintenance and I&C efforts to optimize equipment reliability and performance*. Areas of review included governing procedures, equipment included in the program, type and frequency of preventive maintenance (PM), and effectiveness of program coordi-nation and control.

Finding (Reference Criteria A, C, F, and I)

A program exists for scheduling and tracking preventive maintenance tasks; however, an approved procedure or guideline is needed to describe the objectives, scope and administrative controls for implementing the preventive maintenance program.

Recommendation Formalize the existing preventive maintenance program. Consider including:

o specific criteria for determining what equipment will be included o assignment of responsibilities for program development, implemen-tation and review o establishment of inspection or maintenance frequencies and appropriate types of PM activities o development of individual PM procedures for safety-related equip-ment and inspection guidelines for other equipment as appropriate.

Response

PSE&G concurs with. the finding and will formalize the existing preven-tive maintenance program as recommended by November 1, 1981.

MAINTENANCE PROCEDURES (INPO Procedure MA-403, Revision 3)

An evaluation was performed to determine if use of existing procedures enhances the quality and effectiveness of maintenance and I&C activities. Areas reviewed include an assessment of activities governed by procedures, methods of proce-dure development and revision, and content of procedures.

Finding (Reference Criterion C)

Vendor instruction manuals used for guidance in performing some main-tenance and I&C work are not sufficiently detailed, up-to-date or verified to be applicable to installed equipment.

Recommendation Where maintenance and I&C tasks involve the use of vendor manuals to control work, these manuals should be reviewed and approved in a manner equivalent to that provided for station procedures. The review should consider applicability of manuals to the work to be performed,

SALEM (1981)

'- Page 26 accuracy and suitability for controlling work. These manuals should be maintained up-to-date as changes to equipment or manufacturers' rec-ommendations occur. *

Response

Vendor ma~uals existing at the Station are indexed under the Engineering Department's foreign print control system. The Engineering and Produc-tion Departments are currently reviewing a comprehensive program to ensure all manuals are current, properly indexed and maintained on a 1--, controlled-revision basis. This effort is expected to be completed in 18 I

months.

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WORK CONTROL SYSTEM I***- (INPO Procedure MA-404, Revision 3)

' . An evaluation was performed to determine the effectiveness of the work control system in use at the station. The system functions were checked to see if they define and authorize work to be performed by maintenance groups; provide for planning, scheduling and control of actual work; and provide a suitable record of work performed for future reference.

1. Finding (Reference Criterion D)

A formal method is not employed for planning non-outage maintenance work. The lack of planning support increases the administrative burden on maintenance supervisors and affects. efficient performance of work.

The corporate "Repair and Maintenance Procedure System" (RAMPS) is under development to fulfill planning needs, but this system is not yet fully implemented.

Recommendation Utilize the RAMPS system or a similar work planning system for both outage and non-outage work. Planning efforts should include determi-nation of spare parts availability, needed tools and manpower, quality and radiological controls requirements, coordination with other groups and activities, and other administrative tasks.

Response

We concur with the finding. Staffing deficiencies in the maintenance and planning areas have contributed to this finding. As the vacancies are filled, efforts to implement the recommendations will be made. This finding is expected to be resolved within one year.

2. Finding (General Criterion)

The Maintenance Department's ability to perform identified work in a timely manner needs improvement. Lack of maintenance response to lower prioritiy work orders sometimes leads to misuse of the established priority system.

Recommendation Evaluate department resources and practices to determine the causes of lack of response to lower priority work* orders. This evaluation should be directed toward identifying and correcting problems associated with staff size, personnel qualifications, productivity, administrative proce-dures, management methods, work order screening or other factors affecting department activities.

SALEM (1981) .

IJ Page 27

Response

• • • --* PSE&G concurs with the finding. The backlog of work orders has deteriorated over the past several months due to two forced turbine outages on No. 1 Unit and the concurrent initial startup of No. 2 Unit.

We have initiated a program to account for each outstanding work order and to purge the files of invalid requests. We are currently reviewing

• the priority assignments of work orders relating tc:> safety, security and fire protection in order to improve our response to indicated defi-ciencies. We will conduct an evaluation of department resources, as recommended, by December 1, 1981, implementing in a timely manner any corrective actions identified.

• MAINTENANCE HISTORY (INPO Procedure MA-405, Revision 3) f --~

An evaluation was performed to determine if maintenance history records are I **

retained and used to improve equipment reliability and performance. Areas reviewed included assessment of equipment included in the program, content and accessibility of records, history review and evaluation methods and procedures for program implementation.

Finding (Reference Criterion D)

Machinery maintenance histories are not systematically reviewed to evaluate and improve equipment performance.

Recommendation Develop a system for evaluating and trending major equipment perfor-mance. Systematic maintenance history review results should be used to adjust the PM program and operating practices as appropriate.

Response

PSE&G concurs with the finding and will develop a system to implement the recommendation by January 1, 1982.

CONTROL AND CALIBRATION OF TEST EQUIPMENT AND INSTRUMENTATION I

\

(INPO Procedure MA-406, Revision 2)

I An evaluation was performed to determine the adequacy and effectiveness of methods used for calibration and control of test equipment and instrumentation.

Areas reviewed included identification, calibration, storage, issuance, use, shipment and documentation.

Finding All criteria in this procedure were met.

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SALEM (1981)

Page 28 CONTROL OF SPECIAL PROCESSES (INPO Procedure MA-407, Revision 1)

An evaluation was performed to determine if adequate controls exist for performance of special processes. Areas of review included training and qualification of personnel, administrative controls and control of equipment and materials.

Finding All criteria in this procedure were met.

MAINTENANCE FACllJTIES AND EQUIPMENT (INPO Procedure MA-408, Revision 2)

An evaluation was performed to determine if available facilities and equipment contribute to the performance of maintenance activities. Areas reviewed included number, type, and condition of tools and equipment; size and location of tool storage areas; adequacy of office and work areas; and the cleanliness and

,, . orderliness of maintenance facilities.

1. Finding (Reference Criterion C)

Housekeeping practices in the Maintenance and I&:C Shops need improve-ment. Excessive quantities of parts, equipment, materials, scrap, etc.,

are located in shop areas.

Recommendation Establish and enforce a policy that requires Maintenance and I&:C Shops be maintained in a clean, orderly manner. The responsibility for r . continued shop housekeeping should be specifically assigned.

Response

Both the Maintenance and I&C Shops have been cleaned. All supervisory personnel have been re-instructed regarding the importance of main-taining good housekeeping practices. Specific shop areas have been assigned to specific personnel for the purpose of implementing house-keeping requirements. Station management will continue to monitor plant areas regarding proper housekeeping and unobstructed access to

,_ equipment.

2. Finding (General Criterion)

Spare parts and material used for safety-related systems are stored in common storage areas with non-safety-related material and are not identified in a positive manner as safety-related.

Recommendation Segregate the spare parts used in safety-related systems from those used in other systems to help prevent using a non-quality part in a safety system.

Response

• SALEM (1981)

Page 29 The safety-related material found improperly segregated in the store-room will be corrected by September 1, 1981. The spare parts stored in warehouse # 2 and the "B" building have now been verified to be properly tagged and stored.

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Page 30

• ---* RADIATION PROTECTION AND CHEMISTRY Radiation protection and chemistry were evaluated by reviewing the perfor-mance of radiological protection training, personnel dosimetry, external and internal radiation exposure, radioactive effluents, solid radioactive waste con-trol, radioactive contamination control and chemistry. It was concluded that the station's radiological protection and chemistry programs were adequate to protect the public, station workers and the environment.

I A number of good practices were observed in the radiological protection program. These included a good ALARA program, a well defined training program for general employees and radiological protection technicians and a station commitment for reducing solid and liquid radioactive waste. It is evident that the radiological protection program is being effectively managed.

The most significant problem areas in radiological protection were in monitoring workers for contamination and work practices in contaminated areas. In the chemistry area, problems existed in the calibration of laboratory instruments,

\ ..

• sampling of clean station systems for radioactivity and management training for supervisors. It appears that the underlying cause for the problems in the chemistry area is an insufficient number of personnel.

RADIATION PROTECTION AND CHEMISTRY ORGANIZATION AND ADMINISTRATION (INPO Procedure RC-501, Revision 1)

An evaluation was performed to determine the effectiveness of the management of the radiological protection and chemistry programs and to ensure that station staff members have the knowledge and practical abilities necessary to imple-ment radiological protection practices associated with their work.

Finding (Reference Criterion C)

Several functions of the chemistry organization currently are not being accomplished. These include calibration of laboratory instruments, management training for supervisors and sampling normally clean station systems for radioactivity. Also, a high overtime rate for chemistry supervisors and technicians was noted. It appears that these problems result from an insufficient number of personnel for assigned responsibilities.

Recom menpation Review current responsibilities assigned to the chemistry organization and balance requirements with the proper number of personnel.

Response

PSE&G concurs with the finding. The Senior Performance Supervisor-Chemistry (licensed SRO) presently satisfying a license requirement on shift will be reassigned to. the Chemistry Group as soon as an appropriately licensed supervisor is available as a replacement. A vacancy for a Technical Supervisor was filled in July 1981. These

SALEM (1981)

Page 31 additions to the chemistry staff will correct the deficiencies identified .

The Performance Engineer is currently reviewing the findings to determine short- and long-term solutions to the problems identified.

Corrective actions will be implemented by November 1, 1981.

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PERSONNEL DOSIMETRY (INPO Procedure RC-503, Revision 2)

An evaluation was performed to determine if personnel radiation exposures were accurately measured and recorded.

Finding All criteria in this procedure were met.

RADIATION SURVEILLANCE AND CONTROL (INPO Procedure RC-504, Revision 2)

An evaluation was performed to determine the effectiveness of the station's radiological surveillance program and the effectiveness of controls that identify and minimize radiological risks to station personnel.

1. Finding (General Criterion)

Contamination controls need improvement in some areas of the auxiliary building. Used anti-contamination clothing is not being placed in waste containers following work in contaminated areas; it is being left on the floor in an uncontrolled manner. There are also indications that plastic anti-contamination booties are being used for non-radiological jobs in the turbine building.

Recommendation Improve the enforcement of radiological work practices at the station.

Response

All station and contractor personnel have been apprised of this finding.

A recent inspection by Station management indicates positive action has been implemented. The Station will continue to monitor progress in this area to ensure the deficiencies identified do not recur.

2. Finding (General Criterion)

Whole body contamination surveys are not qeing done by personnel after exiting contaminated areas in the auxiliary building. HP-210/RM14 frisking instruments are provided, but workers are required to only monitor their hands and feet prior to proceeding to the portal monitor.

Neither of these methods provides sufficient personnel monitoring for contamination.

SALEM (1981)

Page 32

• --* Recommendation Establish a program to require whole body monitoring for contamination following work in contaminated areas and prior to exit from the auxiliary building.

Response

Procedures have been implemented which require a whole body frisk* of any individual who exits a contaminated area.

WASTE AND DISCHARGE CONTROL (INPO Procedure RC-505, Revision 2)

An evaluation was performed to determine if releases of radioactive effluents to the environment were minimized and if solid radioactive waste volumes were minimized.

Finding (Reference Criterion D)

\ -**

A program is needed for sampling the demineralizer water system or the potable water system for radioactivity. The station does sample some systems which are normally uncontaminated; however, the demineralizer and potable water systems are not included.

Recommendation Include these systems in the station program for sampling clean systems for radioactivity.

Response

We concur with the finding and will implement the recommendation by October 1, 1981.

RADIOLOGICAL SURVEY EQUIPMENT .CONTROL AND CALIBRATION (INPO Procedure RC-506, Revision 2)

Ap evaluation was performed to. determine if the control and calibration of radiological survey equipment is adequate *

..._ ~*:

Finding All criteria in this procedure were met.

lI SALEM (1981) I Page 33

-* PERSONNEL HEALTH PHYSICS INDOCTRINATION (INPO Procedure RC-507, Revision 2)

An evaluation was performed to determine the effectiveness of the station's health physics indoctrination program in informing personnel of the risks associated. with radiation exposure and the available methods for minimizing exposure.

'\_.:'

Finding All criteria in this procedure were met.

PROCESS WATER CONTROLS (INPO Procedure RC-508, Revision 2)

An evaluation was performed to ensure accurate measurement and comprehen-

", sive control of chemistry parameters.

\ __;

1. Finding (General Criterion)

Material deficiencies were found in the chemistry facilities that detract from efficient laboratory operations. Example include:

o equipment blocking evacuation doors in the analysis laboratory and the primary sample room o a need for improved housekeeping in the primary sample room o an inoperative dumbwaiter between the primary sample room and the analysis laboratory.

Recommendation Correct material deficiencies in chemistry facilities.

Response

We concur with the finding. Corrective action has been completed with the exception of the dumbwaiter. Parts are on order and repairs are expected to be completed by December 1, 1981.

2. Finding (General Criterion)

Many of the instruments in use for analysis in the chemistry laboratory are past due for calibration.

Recommendation

/ .._

Review the existing calibration program to ensure that all instruments i

\_.-I

requiring calibration are included in the Inspection Order System.

Accomplish calibrations as required.

Response

PSE&G has reviewed the existing calibration program to ensure that all instruments requiring calibration are included in the Inspection Order System. Revisions to procedures have been accomplished to ensure the meaning and use of the calibration tag is clearly understood.

I SALEM (1981)

!.* Page 34 I

I HEALTH PHYSICS FACILITIES AND EQUIPMENT

\  :

• (INPO Procedure RC-509, Revision 2)

An evaluation was performed to determine the effectiveness of the station's health physics equipment in satisfying station needs and in contributing to safe and efficient station operation.

Finding All criteria in this procedure were met.

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RESPIRATORY PROTECTION PROGRAM (INPO Procedure RC-511, Revision 2)

An evaluation was performed to determine if internal radiation exposure was minimized.

Finding All criteria in this procedure were met.

RADIATION EXPOSURE REDUCTION GOALS (INPO Procedure RC-538, Revision 0)

An evaluation was performed to determine if the station was minimizing personnel radiation exposures (ALARA program).

Finding (Reference Criterion B)

The station has not developed annual goals for total collective personnel exposure.

Recommendation Strengthen the existing ALARA program by providing annual station goals for total collective personnel exposure.

Response

As of July 9, 1981, annual station goals for total collective personnel exposure have been established.

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SALEM (1981)

Page 35 TECHNICAL SUPPORT The on-site engineering support was evaluated in the areas of organization and administration, engineering functions performed, nuclear operating experience

• , __\ evaluation, plant modifications and reactor engineering.

TECHNICAL SUPPORT ORGANIZATION AND ADMINISTRATION (INPO Procedure TS-701, Revision 1)

An evaluation was performed to determine if on-site technical support is effectively organized and adequately staffed. The capability to perform all

• assigned duties and responsibilities, along with a thorough knowledge of them and training to enhance engineering skills, were. examined.

1. Finding (Reference Criterion A)

A clearly defined on-site technical support organization has not been

\ established. An organizational structure is needed for overall

\ ~.l management control of the functions and responsibilities associated with an on-site technical support department.

Recommendation Establish a clearly defined on-site technical support organization with personnel assigned responsibilities and authority to accomplish assigned goals and objectives. The on-site technical support organization should provide management direction for areas such as plant performance monitoring, plant modifications, evaluation of nuclear operating expe-riences and on-site reactor engineering.

Response

PSE&G concurs with the finding. A review of the station organization is currently in progress. Changes to implement the recommendation will be completed by March 1, 1982.

2. Finding (Reference Criterion D)

A training program has not been established to provide continuing training and retraining for technical support personnel. Although some training is done for technicians and reactor engineers, there needs to be a commitment to an on-going training program to improve and develop

\ _- skills and keep personnel cognizant of the state-of-the-art changes and specific plant systems.

Recommendation Establish a training program for on-site technical support personnel. The training needs for on-site technical support personnel should be eval-uated in such areas as plant systems and components, specialized engineering knowledge or skills and effective management techniques.

On-site technical support personnel should be given the opportunity and should be encouraged to attend pertinent seminars and conferences within the areas of their expertise.

SALEM (1981)

Page 36

• • Response This area will be reviewed in conjunction with the previous finding with appropriate action implemented by March 1, 1982.

ENGINEERING SUPPORT (INPO Procedure TS-702, Revision 2)

An evaluation was performed to determine if on-site engineering support functions are provided in a clearly defined and effective manner. Areas examined included plant performance monitoring, communication with other support groups providing engineering assistance to the station, control of important documents and the adequacy of engineering support facilities.

1. Finding (Reference Criterion A)

Improvements are needed in the plant performance monitoring program to optimize plant thermal performance and maintain a high degree of reliability. A coordinated approach is not used in the assignment of personnel to monitor plant performance, collect and analyze data on a continuing basis and utilize the results to recommend plant improve-

!. ments.

Recommendation Develop a coordinated program to monitor plant performance on a routine basis to improve operating performance and reliability.

Response

We concur with this finding and will implement the recommendations by March 1, 1982.

2. Finding (Reference Criterion C)

Some important documents are not adequately controlled and kept up to date. No centralized document control system is used to track and follow up or to close out document changes and revisions. Although there are "controlled copy holder" distribution lists, tracking and follow-up of the status of the controlled documents need improvement.

Recommendation Establish a group responsible for the maintenance and control of important documents, which are identified by management. A master listing or copies of these documents should be updated with the latest revisions and changes. Use the master documents to establish a system to control the updating and accuracy of copies on a controlled copy listing. The system should include a timely feedback mechanism to facilitate status tracking and follow-up.

Response

We are reviewing the recommendations with respect to establishing a centralized document control system to effectively issue, track and follow up or to closeout document changes and revisions. We expect this action to be completed by March 1, 1982.

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Page 37 NUCLEAR OPERATING EXPERIENCE EVALUATION PROGRAM (INPO Procedure TS-703, Revision 1)

A review was made of the programs in place for evaluating in-house operating

, events as well as those occurring throughout the nuclear power industry.

Reporting, review and follow-up corrective actions for in-house events were examined, along with the method of disseminating the information to appropriate personnel and the industry. For industry events, examination was made of the sources of information reviewed, the screening process employed in surveying

' l events and the disposition of events having relevance to the station.

1. Finding (Reference Criterion A)

The responsibilities and functions required to review, evaluate and disseminate nuclear operating experiences are fragmented within the company organization, and the objectives of an effective nuclear operat-ing experience evaluation program are not fully met. Procedures are written relating to nuclear operating experiences; however, improvements are needed in event tracking, in feedback, and in eliminating duplication.

Recommendation Implement a written program with appropriate experienced technical personnel assigned to ensure in-house and industry nuclear operating experiences are reviewed and evaluated, and appropriate action taken in an efficient and timely manner.

Response

Procedure No. 16.8, Review of Significant Licensee Event Reports or Operating Incident Reports, Revision 1, issued on July 15, 1981 satisfies the INPO recommendations for this area. The' revised procedure distributes in-house and industry experience information to appropriate technical personnel for review, evaluation and appropriate recommendations in a timely manner. Also incorporated in this proce-dure is a feedback mechanism.

2. Finding (Reference Criterion C)

A periodic review of the nuclear operating experience evaluation program is needed to ensure the program is functioning as intended and to identify areas in which the program could be improved.

Recommendation

. Conduct a periodic independent evaluation bf the effectiveness of the

'---* nuclear operating experience evaluation program. This evaluation should ascertain if the operating experiences received are being properly reviewed and classified, appropriate personnel receive and understand the information and lessons learned, and corrective actions are being implemented.

Response

We have implemented a provision to conduct an independent evaluation of the nuclear operating experience evaluation program (NPDM 16.8 Revision 1) at least every two years.

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Page 38

3. Finding (Reference Criterion D)

The results of nuclear operating experience evaluations and lessons learned are not always disseminated to operations, maintenance, engineering or other plant personnel in a timely manner. Plant personnel receive nuclear operating experience information from more than one source, without statements of lessons learned, such as a need for special

'I ~

procedures, precautions and/or instructions. Duplication of the distri-bution of information has resulted in plant personnel receiving infor-mation that is unimportant, not applicable or of limited applicability.

Recommendation

\ [ Include a provision in the nuclear operating experience evaluation program to determine the relative importance of in-house and industry operating experiences and provide that information to the appropriate personnel in a timely manner. Provide a method to incorporate operating experiences into a training program and to provide immediate action on the more important ones.

Response

The revised procedure (NPDM 16.8, Revision 1) addressed in Finding 1 provides for the determination of the relative importance of in-house

~

and industry operating experiences and ensures distribution of that information to appropriate personnel in a timely manner. Appropriate information is distributed, in accordance with the requirements of the procedure, to the Training Department for inclusion into proper training programs. Items requiring immediate action are determined by the Nuclear Operations Support staff and disseminated in accordance with the requirements of NPDM 16.8, Revision 1.

4. Finding (Reference Criterion E)

Conflicting information is sometimes provided to operators and other station personnel from sources such as the nuclear operating experience evaluation program and the training program.

Recommendation Include a provision in the nuclear operating experience evaluation program to ensure that information received by plant personnel and the Training Department is controlled so they do not receive conflicting or contradictory information.

Response

The revised procedure (NPDM 16.8 Revision 1) includes a provision to ensure information received by plant personnel and the Training Depart-ment is controlled in order to prevent conflicting or contradictory information.

' -' 5. Finding (Reference Criteria F and G)

Follow-up of recommendations, implementation and corrective actions need improvement. An experience evaluation program does not exist to ensure that expeditious "closed-loop" feedback is provided, such as feedback from corporate personnel on actions taken, not taken or even required, and recommendations from the departments receiving the nuclear operating experience reports. It is not apparent that Significant Operating Experience Reports (SOERs) as listed below have been proper-ly reviewed and appropriate action taken: SOERs 80-1, 80-2, 80-3, 80-4, 80-5, and 81-1 through 81-11.

SALEM (1981)

I \* Page 39 Recommendation

-* Implement a provision in the nuclear operating experience evaluation program requiring timely responses from departments receiving operat-ing experience reports for evaluation and from the departments respon-sible for corrective actions. Review SOERs listed and take action as appropriate.

Response

The revised procedure (NPDM 16.8 Revision 1) includes a prov1s1on requiring timely responses from departments receiving operating experi-enc.e reports and from departments responsible for corrective action.

The listed SOERs have been or are in the process of review and evaluation. Corrective actions resulting from the review and evaluation of the SOERs has been or will be appropriately implemented.

PLANT MODIFICATIONS i ;

(INPO Procedure TS-704, Revision 2) .

\ ;

An evaiuation of the program for processing plant design changes was made to determine if changes are implemented in a timely manner while maintaining the quality of plant systems, structures and components. Review of proposed modifications, prioritization, tracking, testing, verification of installation and closeout of the design change package were examined.

1. Finding (Reference Criterion F)

The design change process does not provide for review and approval of temporary changes, appropriate to their significance to plant safety and reliability, for consideration as permanent @lant design changes (such as temporary electrical jumpers).

Recommendation Establish a schedule to review and consider temporary changes to plant systems or equipment as permanent plant design changes. The review should be conducted by an interdisciplinary group, considering length of time in use and significance to plant safety and reliability.

Response

A method to review outstanding jumpers and temporary changes with respect to incorporating them as permanent design changes will be implemented by January 1, 1982.

2. Finding (Reference Criterion I)

Required drawing revisions, procedure revisions and operator training are not always completed prior to placing a modified system in service.

Drawings sent to the corporate office for final revisions after a modified system is placed in service are not always issued to the station in a timely manner.

Recommendation Revise the present design change program to include the following provisions:

o ensure that affected drawings indicate the "as-built" status of the modified system or component, prior to placing it in service

SALEM (1981)

Page 40 o identify and ensure revisions are implemented in operating and

• maintenance procedures, prior to placing a modified system in service o ensure that appropriate training and information are provided to the operations personnel, prior to placing a modified system in service o drawings sent to corporate offices for final revisions after completion of a design change should be coordinated and tracked to ensure completion and issue to appropriate plant personnel in a timely manner.

Response

A task force has been established to completely review our design change process and document control system. Included in this review will be the findings and recommendations by INPO. We expect this review to be completed by October 1, 1981, with corrective actions being implemented in a timely manner.

3. Finding (Reference Criterion J)

Routine evaluation of the plant design change program is needed to ensure it is functioning as intended and to identify program improvements.

Recommendation Include a provision in the plant design change program to ensure that a periodic evaluation of the program for effectiveness is conducted and the results are utilized for program improvements.

Response

PSE&G concurs with your finding and has established a provision in the design change program to conduct a periodic review, not to exceed 12 months, in order to evaluate the program effectiveness and implement improvements.

ON-SITE REACTOR ENGINEERING (INPO Procedure TS-705, Revision 2)

An evaluation of reactor engineering was made to assess the use of appropriate I. * . .

procedures, computer programs and control of changes to them, and the support functions provided by the on-site reactor engineers during all modes of plant r*

operation. Additional areas discussed included communication with other groups I __- that coordinate with the site reactor engineers, the dedication to the mainte-nance of fuel cladding integrity and the involvement in refueling activities.

Determinations were made as follows:

Finding All criteria in this procedure were met.

SALEM (1981)

Appendix

- * w Page 1 ADMINISTRATIVE APPENDIX I. LISTING OF AREAS EVALUATED

• l -* ORGANIZATION AND ADMINISTRATION OA-101 Objectives

1) .*. OA-102 Organization Structure OA-103 Administrative Controls OA-104 Quality Programs OA-106 Industrial Safety OA-107 Surveillance Program OA-108 Personnel Qualifications TRAINING AND QUALIFICATIONS TQ-201 Tra~ning Organization TQ-202 Training Administration TQ-205 Training Resources TQ-223 Licensed Operator Requalification Training TQ-224 Shift Technical Advisor Training TQ-242 Non-Licensed Operator Training TQ-243 Licensed Operator Training OPERATIONS OP-301 Operations Organization and Administration OP-302 Tagout Practices OP-303 Conduct of Shift Operations OP-304 Use of Procedures OP-305 Plant Status Controls OP-306 Operations Facilities and Equipment OP-307 Shift Turnover MAINTENANCE MA-401 Maintenance Organization and Administration MA-402 Preventive Maintenance MA-403 Maintenance Procedures MA-404 Work Control System I*

MA-405 Maintenance History MA-406 Control and Calibration of Test Equipment and Instrumentation MA-407 Control of Special Processes MA-408 Maintenance Facilities and Equipment

r SALEM (1981)

Appendix Page 2 RADIATION PROTECTION AND CHEMISTRY RC-501 Radiation Protection and Chemistry Organization and Admini&tration RC-503 Personnel Dosimetry RC-504 Radiation Suryeillance and Control RC-505 Waste and Discharge Control RC-506 Radiological Survey Equipment Control and Calibration RC-507 Personnel Health Physics Indoctrination RC-508 Process Water Controls RC-509 Health Physics Facilities and Equipment RC-511 Respiratory Protection Program RC-538 Radiation Exposure Reduction Goals TECHNICAL SUPPORT TS-701 Technical Support Organization and Administration TS-702 Engineering Support TS-703 Nuclear Operating Experience Evaluation Program TS-704 Plant Modifications TS-705 On-Site Reactor Engineering

\ . *~

J

SALEM (1981)

"** ' ... Appendix Page 3 II. PUBLIC SERVICE ELECTRIC & GAS COMPANY PERSONNEL CONTACTED Chairman of the Board President Senior Vice President, Energy Supply & Engineering Vice President, Production General Manager, Nuclear Production i

• Manager, Nuclear Operations Support Vice President, Engineering Station Manager - Salem Station Manager - Hope Creek Assistant to Station Manager Maintenance Engineer Station Planning Engineer Office Administrator Performance Engineer Radiation Protection Engineer Chief Engineer Assistant Maintenance Engineer Safety Supervisor i ,._

Office Supervisor Store Keepers Senior Maintenance Supervisors Maintenance Supervisors Assistant Engineers Senior Performance Supervisors - Instrument and Control Performance Supervisor Engineer - Planning Department Assistant Manager (On-Site Salem Project Engineer)

Document Control Senior Clerk Manager (On-Site Safety Review Group)

Engineer (On-Site Safety Review Group)

Senior Shift Supervisor Shift Supervisors Reactor Engineer Operating Engineer Control Operators Equipment Operators Utility Operators Shift Technical Advisors Training Manager i

l._; Senior Nuclear Training Supervisor Senior Training Supervisor Nuclear Training Specialist Staff Instructors Station Quality Assurance Engineer Assistant Quality Assurance Supervisor Senior Radiation Protection Supervisor Radiation Protection Supervisors Senior Performance Supervisors - Chemistry Chemistry Supervisor j _.

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