ML18087A785

Evaluation of Salem Generating Station

ML18087A785
Person / Time
Site:	Salem
Issue date:	01/31/1983
From:	INSTITUTE OF NUCLEAR POWER OPERATIONS
To:
References
NUDOCS 8303280331
Download: ML18087A785 (36)

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EVALUATION of SALEM GENERATING STATION

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Public Service Electric and Gas Company 1

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THE ATTACHED FILES ARE OFFICIAL RECORDS OF THE DIVISION Of DOCUMENT CONTROL. THEY HAVE BEEN CHARGED TO YOU FOR A LIMITED TIME PERIOD AND MUST BE RETURNED TO THE RECORDS FACILITY BRANCH 016.

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DEADLINE RETURN DATE

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SUMMARY

INTRODUCTION SALEM (1982)

Page 1 The Institute of Nuclear Power Operations (INPO) conducted an evaluation of Public Service Electric and Gas Company's (PSE&G) Salem Generating Station during the weeks of October 4 and 11, 1982. The station is located on the eastern shore of the Delaware River, about eight miles southwest of Salem, New Jersey. Salem Unit 1 (1090 MWe) and.Salem Unit 2 (1115 MWe) began commercial operation in June 1977 and August 1981, respectively.

PURPOSE AND SCOPE INPO conducted an evaluation of site activities to make an overall determination of plant safety, to evaluate management systems and controls, and to identify areas needing improvement. Information was assembled from discussions, interviews, obser-vations, and reviews of documentation.

The INPO evaluation team examined station organization and administration, oper-ations, maintenance, technical support, training and qualification, radiological pro-tection, and chemistry. The team also observed the actual performance of selected evolutions and surveillance testing. Corporate activities were not included in the scope of the eyaluation, except as an incidental part of the station evaluation. As a basis for the evaluation, INPO used performance objectives and criteria relevant to each of the areas examined; these were applied and evaluated in light of the.experience of team members, INPO's observations, and good practices within the industry.

INPO's goal is to assist member utilities in achieving the highest standards of exce.llence in nuclel:l.r plant operation. The recommendations in each area are based on best practices, rather than m.inimum accept.able standards or requirements. Accord-*

ingly, areas where improvements are recommended are not necessarily indicative of unsatisfactory performance.

DETERMINATION Within the scope of this evaluation, the team determined that the plant is being safely operated.by qualified personnel.

The following beneficial pra~tices and accomplishments were noted:

• The capacity factor and availability of Unit 2, since the beginning of commercial operation, is impressive.

A strong commitment to training is evident.

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SALEM (1982)

Page 2 Improvements were recommended in a number of* areas. The following _are considered to be among the most important:

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Additional emphasis is required to reduce the backlog of work orders, drawing revisions, and plant modifications.

Material and housekeeping conditions in the auxiliary building and the intake structures need to be improved.

In each of the areas evaluated, INPO has established PERFORMANCE OBJECTIVES and supporting criteria. All PERFORMANCE OBJECTIVES reviewed during the course of this evaluation are listed in APPENDIX II.

Findings and recommendations are listed under the PERFORMANCE OBJECTIVES to which they pertain.

Particularly noteworthy conditions that contribute to meeting PERFORMANCE OBJECTIVES are identified as Good Practices.

Other findings describe conditions that detract from meeting the PERFORMANCE OBJECTIVES. It would not be productive to list as Good Practices those things that are commonly done properly in the industry since this would be of no benefit to PSE&G or to INPO's other member utilities.

As a result, most of the findings highlight conditions that need improvement

• The recommendations following each finding are intended to assist the utility in ongoing efforts to improve all aspects of its nuclear programs. In addressing these findings and recommendations, the utility should,* in addition to correcting or improving specific conditions, pursue underlying causes and issues.

As a part of the second and succeeding evaluations of each station, the evaluation team will follow up on responses to findings in previous reports.

Findings with response actions scheduled for future completion have been carried forward in APPENDIX I to this report. In areas where additional improvements were needed, a new finding that.

stands cin its o"Wn merit has beeri written. Tht.1s, this report stands alone, and ref er.ence.

to previous evaluation reports should not be necessary.

The findings listed herein were presented to PSE&G management at an exit meeting on October 14, 1982.

Findings, recommendations, and responses were reviewed with PSE&G management on December 22, 1983. Responses are considered satisfactory.

To follow the timely completion of the improvements included in the responses, INPO requests a written status by July 15, 1983.

Additionally, a final update will be requested. six weeks prior to the next evaluation.

The evaluation staff appreciates the cooperation received from all levels of PSE&G.

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PUBLIC SERVICE ELECTRIC AND GAS COMP ANY.

Response Summary SALEM (1982)

Page 3 Public* Service Electric and Gas Company is pleased to have had INPO perform an

~valuation of the Salem Generating Station. INPO's evaluation has identified various areas in need of improvement, some of which we were cognizant. Recommendations made by INPO will be considered in providing the direction for improving overall

• performance in our nuclear operation.

The positive comments with respect to the performance record of Unit 2 and the strong commitment to training is appreciated: It is apparent that experience with operation of Unit 1 and improvements in design have resulted in a more reliable operating plant.

The training commitment is supported by the successful hiring program, which has increased the number of personnel in the reactor operator training program.

A vigorous effort is being made by the nuclear department to improve the processing of plant modifications and drawings. to assure that the station has the current information in a timely manner. The maintenance department is embarking on a program by the maintenance planners to reduce the backlog of work orders.

A number of INPO findings relating to radiation protection concern lack of adherence to policies and procedures. It is believed that by improving personnel understanding of the need for such policies and procedures, performance in this area will be improved.

Management has taken positive steps to improve the material and housekeeping conditions by performing weekly tours of different areas.

All personnel will be reminded. in radiation worker review training to maintain cleanliness in his/her work areas.

It was a pleasure to have the INPO evaluation team return to Salem Generating Station, giving us their perspective and assistance in evaluating our management performance.

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ll ORGANIZATION AND ADMINISTRATION INDUSTRIAL SAFETY SALEM (1982)

Page 4 PERFORMANCE OBJECTIVE: Station industrial safety programs shol,tld achieve a high degree of personnel safety.

Finding (OA.5-1)

Recommendation

Response

Some industrial safety conditions and practices need additional attention. Examples include the following:

a.

the hot and humid environment of the penetration areas in the auxiliary buildings

b.

inconsistent implementation and interpretation of the station policy for head protection

c.

repeated injuries involving muscular strains, minor lacera-tions, and foreign objects in the eye Improve the environment in the penetration areas so that personnel access can be gained without undue hazard.

During industrial safety training, emphasize the head protection policy and unfavor-able trends in injury reports. Stress supervisory responsibility and accountability for day-to-day industrial safety performance.

The status of corrective actions is as follows:

a.

The system leaks and ins1=1la tion deficiencies in the auxil-iary building have been corrected for Unit 1. Unit 2 will be corrected during the January 1983 outage. The modifi-cations to improve the ventilation system* in the penetra-tion areas of the auxiliary building are approximately 10 percent complete. Priority will be given to completion of this project during 1983 outages. In addition, guidelines requiring the use of "hot environment" protective suits by employees working in these areas are being considered.

b.

A revised policy statement, regarding the use of hard hats by all employees and visitors at the Salem Generating Station, will be issued by the nuclear department by February 1983.

c.

During the monthly safety meetings, supervisors have reviewed.the company's safety guidelines on items b. and

c. of.this finding with all employees.

The Monthly Summary of Accident Experience will be reviewed and analyzed monthly by the safety supervisor to determine if any significant changes are being experienced in the work-related* injury history.

Based on this review and analysis, specific information will be provided to station

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SALEM (1982)

Page 5 supervisors for use during monthly safety meetings so that effort can be concentrated on correcting potential prob-lem areas.

J OPERATIONS CONDUCT OF OPERATIONS SALEM (1982)

Page 6 PERFORMANCE OBJECTIVE: Operational activities should be condu~ted in a manner that achieves safe and reliable plant operation.

Finding (OP.2-1)

Recommendation Resporne Access to the control room console area is not routinely restricted.

As a re.sult, personnel without official functions are allowed to approach control boards without approval Enforce the existing policy that requires granting of permission for entry to the control room console area, and restrict entry to only those that have a need.

The existing policy has been re-enforced through the Information Directive Distribution Notice System to the licensed opera tors, indicating the responsibilities for controlling access to the console area.

PLANT ST ATOS CONTROLS PERFORMANCE OBJECTIVE: Operational personnel should be cognizant of the status of plant systems and equipment under their control, and should ensure that systems and equipment are ~ntrolled in a manner that supports safe and reliable operation.

Finding (OP.3-1)

Improvemen~ are. need~. in the imple~entatiori of. the. blocking tag system. The following specific problems were noted:

a.

b.

c.

d.

Many tagging requests and tags are not filled out com-pletely.

Some tags have nomenclature that is different from that on the tagged component.

The periodic review of tagouts does not include checks for unauthorized tags and is generally ineffective in correct-ing deficiencies.

Some temporary tagout releases for testing remain in effect longer than allowed by administrative procedures.

Recommendation Emphasize adherence to station tagging procedures.

Increase supervisory involvement to ensure that tags are properly prepared and that temporary releases are restored in a timely manner.

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• .Response Finding (OP.3-2)

Rec om mendatioo

Response

Finding (OP.3-3)

SALEM (1982)

Page 7 Revise the existing requirements for the periodic reyiew of block-ing tags to include a check for u~authorized tags.

Operations personnel will be personally counseled on the impor-tance of adherence to administrative procedures by the operations manager. _ The existing requirements for the periodic audit of outstanding tagging requests and tags will be revised to include provisions to check for unauthorized tags.

The administrative policy concerning the length of time temporary tagging releases may remain in effect will be reviewed, finalized, and incorporated into the documents that describe and control the safety tagging program. The requirements of temporary tagging operations will then be re:-emphasized to all personnel who interface with the safety tagging system during safety tagging rules training that is scheduled for completion by June 1983.

Turnover practices by control rooin desk operators do not always provide for a complete transfer of information and are not in accordance with Operations Directives.

Enforce current directives governing shift turnover. Supervisors should periodically check the quality of information transfer during turnovers.

Operations department personnel will be personally counseled by the operations manager on the importance of adherence to the administrative procedures that govern shift turnover and the requirements of supervision to periodically verify the quality of.

information transferred during shift turnc:rver~ The policy will also be reiterated to the operators through the Information Directive Distribution Notice System by March 1983.

Information provided by the computerized Tagging Request<<and Inquiry System (TRIS) is sometimes not 'reliable.

Although the potential effectiveness of the system and the ongoing efforts to improve TRIS are recognized, the following deficiencies were noted:

a.

A formal method has not been developed to ensure that

_completed design modifications to systems are reflected in standard tagging requests.

b.

Current computer software provides no self-auditing method.

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Recommendation Response.

Finding (OP.3-4)

Recommendation

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SALEM (1982)

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Effective reviews are not conducted frequently enough to

c.

d.

identify all personnel and computer-generated errors.

Periodic training in the operation and capabilities of TRIS is not conducted for operators and supervisory personnel.

As part of the continuing effort to improve the reliability and capability of TRIS,_ include measures to correct the above-noted deficiencies.

The status of corrective actions is as follows:

a.

Administrative Procedure AP-8, "Station Design Changes, Tests, and Experiments," will be revised to ensure that TRIS is updated and the updating is documented upon the completion of all station design changes. The target date for completion is June 1983.

b.

Administrative procedures will be developed and imple-.

mented to perform TRIS software audits. This will ensure the program is functioning as designed by September 1983.

c.

The hard copy file of tagging requests that is compared with TRIS reports to verify computer accuracy on a semi-annual basis will now be compared on a monthly basis.

d.

A TRIS training manual is in the,process of development.

It will be issued to all users of TRIS, and should improve their ability ~o use the capabilities of the system.

A formal indoctrination training program for new TRIS

. users has been developed and implemented.

Administrative controls governing the use of caution tags are not effective. As a result, these tags are sometimes incorrectly used, not always authorized by appropriate personnel, and often remain installed for extended periods of time.

t1 Expand current procedures for the use of caution tags to include the following:

a.

specific direction on the proper use of caution tags

b.

an index of active caution tags

c.

periodic review to verify that existing caution tags are applicable, needed, and legible

d.

periodic review to ensure caution tags are maintained in accordance with procedures

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Response

Finding (OP.3-5)

Recommendation

Response

SALEM (1982)

Page 9 The administrative procedures that govern the use of caution tags will be reviewed and expanded to include specific direction in the use and control of caution tags.

TRIS will be evaluated for capability to include the processing of caution tagging operations.

TRIS would then provide the indexing and tracking functions required for caution tags. Auoit procedures will B;lso be developed and implemented to ensure the requirements for caution tagging operations are complied with. The target date for completion is June 1983.

Instrumentation outside the control room is riot included in the existing plant program for identification of degraded instrumenta-tion. Defective meters, gauges, and annunciators are identified by a variety of informal methods.

Expand the current system used in the control room, or develop another system to ensure that degraded instrumentation throughout the plant is effectively identified.

The current system used in the control room to identify and track degraded instrumentation will be expanded and modified as *re-quired to include instrumentation outside the control room by June 1983.

OPERATIONS FACILITIF.S AND EQUIPMENT PERFORMANCE OBJECTIVE: Operational facilities and equipment should effectively support plant operation.

Finding (OP.6-1)

The following Good Practice was noted: A mimic bm arrangement depicting the logic diagrams for reactor protection and safety injection actuation and for the saf eguarm loading sequence is displayed in the control room.

This ready reference contains indication of the following:

a.

valve p~itions

b.

coincidence and status of trips

c.

condition of blocks

d.

coincidence and status of safety injection signals

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circuit breaker positions

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operation of safety-related components

g.

status of containment isolation

h.

safeguards equipment loading sequence SALEM {1982)

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MAINTENANCE PLANT MATERIAL CONDITION SALEM (1982)

Page 11 PERFORMANCE OBJECTIVE: The material condition of the pla.nt. should be main-

. tained to support safe and reliable plant operation.

.Finding*-

(MA.2-1)

The work control system is not utilized to full effectiveness to improve the material condition of the plant. A number of material deficiencie,~ observed during the evaluation were not documented in the work control system.

Recommendation Ensure that material deficiencies are documented. Emphasize to plant personnel the need to identify and report material deficien-cies on a routine basis.

Response.

Plant personnel are making a greater effort to identify and report all material deficiencies not previously identified.

The operations department will implement, a.S applicable, a plant material deficiency identification program similar to that recom-mended. by INPO Good Practice MA-301, "Plant Material Deficiency Identification."

The target date for completion is November 1983.

W:ORfr. CONTROL SYSTEM.

PERFORMANCE OBJECTIVE: The control of* work should ell.5Ul"e that identified maintenance actions are properly completed in a safe, timely, and efficient manner. :

Finding (MA.3-1)

Recommendation Implementation of activities associated with the work control syste.m need'i improvement in the following areas:

a.

A large backlog of non-outage corrective maintenance exists.

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A system for planning and scheduling of maintenance activities has been recently implemented; however, only about 10 percent of.the jobs are currently included.

c. *. A method for plant identification of reported deficiencies does not exist.

Expand the use of the recently implemented planning and schedul-ing system to assist in reducing the large backlog of work.

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Response

SALEM (1982)

Page 12 control procedures should be modified to include plant identi-fication of reported deficiencies.

INPO Good Practice MA-301, "Plant Material Deficiency Identification," could be of assistance in this area.

The backl9g of non-outage corrective maintenanc~ work orders will be reduced by increasing the percentage of the daily workload that is preplanned and scheduled for accomplishment. Based upon work that can be scheduled, this percentage will be increased in accord-ance with the following schedule:

30 percent by June 1983 50 percent by January 1984 80 percent by June 1984 100 _percent by December 1984 In addition, a plant material deficiency identification program similar to that recommended by INPO Good Practice MA-301, "Plant Material Deficiency Identification," will be implemented by November 1983.

PREVENTIVE MAINTENANCE PERFORMANCE OBJECTIVE: The preventive maintenance programs should contribute to optimum performance and reliability of plant equipment.

Finding.

(MA;5-l).

Recommendation Respo~

. The preventive maintenance (PM) program for mechanical and

• electrical equipment needs to be expanded.

• The* current program consists principally of equipment lubrication and equipment.checks

• that are required by technical specifications.

Review plant mechanical and electrical equipment to identify what should be covered in a comprehensive PM program, and determine and implement necessary PM actions to be included for each component.

• A review of items such as licensee event reports, deficiency reports, work orders, vendor recommendations, and operating ex-

. perience will be performed to determine what equipment will be included in the maintenance PM program.

The target date for completion is Fet;>ruary 1983.

Inspection order cards for the items identified* above will be issued, and the maintenance department will implement an upgraded PM program by December 1983.

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TECHNICAL SUPPORT OPERATING EXPERIENCE REVIEW PROGRAM SALEM (1982)

Page 13 PERFORMANCE OBJECTIVE: Industrywide and in-bouse operating ~riences should be evaluated and appropriate actions undertaken to improve plant safety and reliability.

SOER STATUS The status of Significant Operating Experience Report (SOER) recommendations is as follows:

Number of Recommendations Action Taken Satisfactory Not applicable Pending 63 39 48 The following recommendations are pending action:

SOER Number 80-2 81-2 81-3 81-14 81 81-16 82-1 82-3 82-4

~2-7 82-8 82-9 Recommendation Number 2

1, 2;3, 4, 5, 6 2, 3 1, 2 2a, 2b, 2c, 3 1, 2, 3 2a, 2b, 2c, 2d, 3 1

6 I, 2, 3, 4a, 4b, 4c, 4d, 4e, 4f, 5 1, 2~ 3; 4 1,*2, 3, 4, 5, 6, 7, 8, 9 An update on the status of each recommendation listed in the npending action" category shown above is requested in the six-month follow-on response to this report.

In addition, the status of each immediate action (red tab) SOER recommendation received subsequent to this evaluation should be included 1n the six-month follow-on response. A tabular summary, similar to that above, is requested.

Finding (TS.3-1)

Recommendation Salem does not actively participate in the Nuclear Plant Reliability Data System (NPRDS). Failure reports have not been submitted for Salem Unit 1 since the second quarter of 1981, and engineering data sheets and failure reports have not been submitted for Salem Unit 2.

Resume submittal of failure reports for Salem Unit 1. Commence submittal of failure reports and engineering data sheets for Salem Unit 2.

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Response

SALEM (1982)

Page 14 Computer software modifications have been implemented to pro-vide inputting of engineering data and failure reports.. Data is now included in the data base and submitted to INPO on a quarterly basis.

PLANT MODIFICATIONS PERFORMANCE OBJECTIVE: Plant modification programs should en.5Ul"e proper re-view, control, implementation, and completion of plant design changes in a safe and timely manner.

Finding (TS.4-1)

A large backlog of plant modifications exists. Approximately 1,500 modification8 are presently outstanding, some dating back to 1976.

Recommendation Implement corrective measures, as appropriate, to reduce the

• backlog of plant modifications.

In.addition, periodically review established priorities for plant modifications, canceling modifi-cations that are no longer warranted.

Response

A review will be made of outstanding modifications to reassess _the need and priority for these changes.

Modifications that are no longer warranted will be canceled by December 1983.

Design change requests are now reviewed more closely in establishing need and priority prior to preparing a modification package for future Finding (TS.4-2)

Recommendation

Response

. accomplishment.

A large backlog of document revisions exists for completed modifi-cations.

Continue efforts to reduce the backlog of design documents associated with completed modifications.

Provide the necessary

• emphasis and priority to ensure that final design documents are completed in a timely manner.

"'.1 An improved tracking system will be instituted, and increased emphasis will be placed on documentation updates to close out completed design change request packages. The target date for instituting this tracking system is April 1983.

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Response*

SALEM (1982)

Page 15 Temporary jumpers and lifted leads do not receive an independent technical design review prior to or promptly after installation.

Perform an independent technical design review of jumpers and

• lifted leads currently installed.

In the future, this review of jumpers and lifted leads should be conducted prior to or promptly after installation.

Administrative Procedure AP-13 will be modified to incorporate selected technical review criteria as guidelines to individuals involved in requesting and authorizing jumpers and lifted leads by April 1983. This technical review will be conducted either prior to or promptly after installation of temporary jumpers and lifted leads.

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TRAINING AND QUALIFICATION SALEM (1982)

Page 16 TRAINING ORGANIZATION AND ADMINISTRATION PERFORMANCE OBJECTIVE: The training organization and administrative systems should ensure effective control and implementation of training activities.

Finding (TQ.l~l)

Recommendation

Response

Technical helpe~ utility mechanics, and utility operators are not provided with initial training related to their knowledge and skill requirements, including industrial safety practices.

Provide an initial training and qualification program to develop the knowledge and skills necessary for entry level personnel to perform their assigned duties.

Existing programs (Phase I) could be modified to address this need. Qualification requirements should be completed prior to assigning workers to their dtities.

INPO documents "Nuclear Power Plant Non-Licensed Operators -

Guidelines for Qualification Programs" (GPG-04), "Guidelines for Instrument and Control Technician Qualification" (GPG-08),

"Guidelines for Mechanical Maintenance Personnel Qualification" (GPG-05), and "Guidelines for "Electrical Maintenance Personnel Qualification" (GPG-07) could be of assistance in this effort.

At present all technical helpers, utility mechanics, and utility operators attend a nuclear indoctrination course, which is an 11-day training program.

This is conducted shortly after they are employed, and typica.V-y it is presented once each quarter. Super-visors will ensure that technical helpers and utility mechanics are appropriately trained prior to assignment of specific work.

All utility operators attend a seven-week training program annually.

Personnel assignment practices will be modified, such that newly hired utility operators wiff attend the utility operator training with the next shift to be assigned to the training center after employment.

SALEM {1982)

Page 17 MAINTENANCE PERSONNEL TRAINING AND QUALIFICATION PERFORMANCE OBJECTIVE: The maintenance personnel training and qualification

.... pr()grarn~ ~hould develop and improve the knowledge and skills necessary to perform

• assigned job functions.

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Finding

(TQ.5-1)..

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Recommendation

Response

A continuing training program for maintenance and instrument and control.personnel is not currently provided.

Develop and implement a continuing training program *for the station and utility mechanic,. machinist, electrician, boiler repair technician, technical helper, instrumentation and control assistant, and instrumentation and control technicjan positions. INPO docu-ments "Guidelines for Mechanical Maintenance Personnel Qualifi-cation" (GPG-05); "Guidelines for Electrical Maintenance Personnel Qualification" (GPG-o7), and "Guidelines for Instrument and Con-trol Technician Qualification" (GPG-08), could be of assistance in this effort.

The current training programs for the identified employees are extensive and include an indoctrination program *upon hiring, an apprentice program that develops intermediate level skills as they gain experience, and an advanced program that brings an individual to journeyman level. Continuing training programs associated with the above disciplines will be evaluated and developed for personnel who do not advance to higher training levels on schedule and for personnel after achieving the journeyman level.

The evaluation portion of this effort will be completed by October 1983.

RADIOLOGICAL PROTECTION SALEM (1982)

Page 18 RADIOLOGICAL PROTECTION ORGANIZATION AND ADMINISTRATION PERFORMANCE OBJECTIVE: The organization and administrative systems should ensure effective control and implementation of the radiological protection program.

Finding *.. _:

(RP.1-:1). _-. *..

Recommendation

Response

Station* and contractor personnel do not always comply with requirements of Radiation Exposure Permits (REPs) and station radiological protection procedures.

Examples include the fol-lowing:

a.

failure to wear protective clothing required by REPs in posted c9ntaminated areas

b.

improper removal of protective clothing

c.

workers gaining access to and performing work in the controlled access area under the wrong REP

d.

improper wearing of personnel dosimetry devices All station supervisory personnel should enforce worker compliance with station rad_iological protection requirements.

Additional training should be provided to station and contractor personnel in protective clothing and dosimetry requirements.

All station supervisory personnel as well as radiation protection personnel will be instructed to observe for and enforce worker compliance with ratliological protection requirements by March 1983. Instructions in the form of drawings are being made and will be posted at strategic loeations to. assist personnel in the proper method of protective clothing removal.

The manager - nuclear training has included these items in the radiation worker review training.

RADIOLOGICAL PROTECTION PERSONNEL QUALIFICATION PERFORMANCE OBJECTIVE: The radiological protection qualification program should ensure that radiological protection personnel have the knowledge and practical abilities

. necessary _to effectively implement radiolOgical protection practices.

Finding (RP.2-1)

The fallowing Good Practice was noted: The initial training pro-gram for radiological protection and chemistry technicians is comprehensive and uses training facilities and equipment that

SALEM (1982)

Page 19 duplicate plant equipment.

Additionally, comprehensive written and oral qualification examinations are administered to trainees.

GENERAL EMPLOYEE TRAINING IN RADIOLOGICAL PROTECTION PERFORMANCE OBJECTIVE: General employee training should ensme that plant personnel, e<>ntractors, and visitors have the knowledge and practical abilities necessary to effectively implement radiological protection practices associated with their work.

Finding (RP.3-1)

Recommendation

Response

Improvements in radiological proteetion general employee training (GET) are needed. Examples of problems include the following: * *

a.

Individual workers are not required to demonstrate practi-cal radiological protection abilities such as frisking, use

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of step-off pads, donning and removal of protective clothing, and reading pocket ion chambers.

b.

Written examinations do not include questions that re-quire workers to apply basic radiological protection knowledge to situations that may be encountered in their work.*

Require each worker to demonstrate practical radiofogical protec-tion abilities during GET.

Expand the scope of written GET examinations to include questions that require the worker's appli-cation of radiological protection knowledge.

The nuclear training department is developing a comprehensive program that includes demonstration by each person of practicai radiological protection abilities including frisking, use of step-off

- pads, donning and removal of protective clothing, and reading of pocket ion chambers (dosimeters). The target date for completion is May 1983.

The written examinations used in the GET program have been revised to include questions that require workers to apply basic radiological protection knowledge to situations that may be en-countered in their work.

RADIOACTIVE EFFLUENTS SALEM (1982)

Page 20 PERFORMANCE OBJECTIVE: Radioactive effluent controls should minimize radio-active mat~rials released to the environment.

. Finding (RP.6-1}

Recommendation Respon.5e The volume and curie content of discharged liquid effluents can be reduced. Processed water is not reused. Additionally, plant water inventory losses need to be minimized.

The station should evaluate plant water inventory losses and the reuse of processed water.

Based on this evaluation, a program should be implemented to reduce the volume and curie content of water discharged to the environment.

An independent *liquid waste source study was conducted in 1980 to identify any unnecessary or excessive source of water being processed as liquid radioactive waste.

Since that time, the discharge volumes have shown a decreasing trend.

. A waste water management review will be made to determine if operational improvements can be made and to develop account-ability for waste generation. This will be completed by July 1983.

In addition, PSE&:G will review the design of the liquid radioactive waste system by October 1983 to determine if system effective-ness can be improved.

SOLID RADIOACTIVE WASTE PERFORMANCE OBJECTIVE: Solid radioactive waste controls should minimize the volume of radioactive waste and ell.5lire safe transportation of radioactive materiaL Finding (RP. 7-1)

The fallowing Good Practice was noted: Sorting of potentially contaminated trash has resulted in a reduction of compactible waste volume by approximately 50 percent. Several radiological

• protection technicians have been assigned to survey and sort this trash on a routine basis.

PERSONNEL DOSIMETRY SALEM (1982)

Page 21 PERFORMANCE OBJECTIVE: The personnel dosimetry program should ensure that radiation exi)osures are accurately determined and recorded.

Finding (RP.8-1)

ReeommendRtion

Response

The personnel dosimetry program needs strengthening as evidenced by the following examples:

a.

A policy has not been established that identifies the conditions requiring the use of extremity and multiple whole-body dosimetry.

b.

The accuracy and precision of results. obtained from the thermoluminescent dosimeter (TLD) processing system is not verified by exposing TLDs to known amounts of radia-tion and evaluating reported results.

Develop a station policy for use of extremity and multiple whole-

• body dosimetry, and incorporate this policy in training programs and station procedures.

To ensure. the quality of the dosimetry program, include TLDs with known exposures during normal TLD processing and compare the reported results with the known exposure values.

Investigate and determine the cause of any abnormal results.

RPE 3.021 has been changed to institute an upgraded program for the placement of extremity and multiple whole-body oosimetry.

An inspection order card is now issued periodically to ensure that the TLD processing system is verified by evaluating results of TLDs exposed to known amounts of radiation.

RADIOACTIVE CONTAMINATION CONTROL PERFORMANCE OBJECTIVE: Radioactive contamination controls should minimize the contamination of area8, equipment, and personneL Finding (RP.9-1)

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The monitoring of station and contractor personnel for radioactive contamination needs to be improved.

Many personnel exiting contaminated areas do not correctly monitor themselves for radio-active contamination as required by station policy. In particular, personnel do not always monitor their whole bodies for contamina-tion at the nearest frisker when leaving a contaminated area.

Personnel frequently move the frisker probe too quickly over body

Recommendation

• Response Finding

.(RP.9-2)

Recommendation

Response

SALEM (1982)

Page 22 areas being monitored. Additionally, station portal monitors at the exits of the controlled area were found to alarm at contamination levels well above prescribed setpoints.

Ensure that personnel comply with the station's requirements for contamination monitoring.

Implement a program to frequently check the response of station portal monitors using radioactive.

sources.

Signs have been posted at both control points to remind personnel of.the need for and extent of personal monitoring to check for contamination. Nuclear training now includes the importance of frisking in all phases of radiation worker training.

Additionally, supervisors periodically observe for proper radiological monitoring techniques and enforce rules when necessary. The portal monitor setpoin ts are now checked on a periodic basis and reset to the correct values as required.

The teclmiques used to monitor vehicles do not ensure that alpha and beta-gamma contamination can be detected at the levels of the station contamination limits. Problems noted are as follows:

a.

scanning of surfa<;es for alpha contamination with a portable scintillation detector too rapidly to allow for proper meter response

b.

counting of large area cloth smears for beta-gamma contamination in a manner that does not minimize the self-absorption of beta radiation by the cloth Improve monitoring techniques such that contamination on vehicles can be detected at the levels of the station alpha and beta-gamma contamination limits.

The status of corrective actions is as follows:

a.

Personnel have been reinstructed in the proper use of the portable scintillation detector.

b.

Radiation protection personnel have been instructed to follow the proper steps in RPI 4.003, which specify a 100 cm2 smear be taken to minimize self-absorption.

Pro-cedures will be reviewed to determine if any changes or precautionary notes are necessary.

This will be com-pleted by February 1983.

-Finding (RP.9-3)

• Recommendation

Response

Finding (RP.9-4)

Reeommendation

Response

SALEM (1982)

Page 23 Large roll-up doors on the boundaries of the controlled area are frequently left open to the environment when not needed for entry or exit of equipment. Radioactive waste processing and shipping operations are routinely performed in areas adjacent to the clean facilities building roll-up door.

Keep large roll-up doors on the boundaries of the controlled area closed except when transporting materials or equipment through the doors.-

Ensure these doors are closed when work that might result in airborne radioactivity is performed inside the controlled area.

Motor failures on the roll-up door in the auxiliary building have necessitated manual operation.

A design change request is in process to improve operation reliability.

The target date for completion of this modification is *April 1983.

A department directive w_ill instruct all radiation protection supervisors that

• during eyolutions such as compacting and movement of demineralizers, the door shall be closed.

In addition, the same warnings shall be posted at this door and the fuel handling building roll-up door operating mechanisms. The target date for completion is March 1983.

Workers are not always aware of radiation and contamination levels when they are working in the controlled area..

Extended REPs, posted radiological survey maps, and radiological signs are

• not effectively used to provide this information to workers.

Ensure that workers are informed of or have ready access to information on radiation and contamination levels in their work areas.

PSE&::G recognizes that workers should be aware of the radiation and contamination levels in their work areas. All station personnel are apprised of both the requirements of the REP system and the posting of radiation areas and survey sheets in conjunction with the GET and radiation worker review classes. In order to evaluate the need. to improve current practices, personnel will be randomly questioned to determine their knowledge of radiation hazards in their work area. Improvements that are necessary will be imple-mented by April 1983.

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CHEMISTRY ORGANIZATION AND ADMINISTRATION SALEM {1982)

Page 24 PERFORMANCE OBJECTIVE: The organization and administrative ensure effective implementation and control of the chemistry program.

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Chemistry technicians do not always adhere to chemistry proce-dures. Examples include the following:

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failure to check reagent shelf lives

b.

use of glassware for silica analyses

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failure to keep procedures up to date

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Recommendation Chemistry procedure adherence should be stressed to the techni-cians. *Supervisory personnel should more closely monitor proce-dure adherence to improve sampling and analysis techniques of chemis~ personnel

Response

Four additional chemistry supervisory level positions are expected to be filled by March 1983. As these individuals gain experience at the supervisory level, procedure adherence will improve. These supervisors will counsel individuals on the importance of procedure adherence. *In addition, procedure adherence for chemistry techni-cians will be stressed during future training classes.

Finding (CY.1-2)

Recommendation

• Chemi.Stry parameters are not recorded in a fashion that facilitates trend review. The computer printout format currently in use does not readily relate associated analyses or reflect applicable plant conditions. Additionally, data is only entered into the computer monthly~ delaying trend reviews.

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Identify key chemistry parameters and record them in a timely manner*. in a format that reflects plant conditions and related chemistry parameters.

Trend these parameters on a frequent basis. ** ~.-.

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SALEM (1982)

Page 25 A new computer graphics. plotter that reflects associated plant conditions is now l,lSed to trend key chemistry parameters. Trend reviews are being performed daily and monthly plofs are forwarded to management.

CHEMISTRY CONTROL PERFORMANCE OBJECTIVE: Chemistry controls should ensure 0ptimum chemistry conditions during all phases of plant operation.

Finding (CY.3-1)

Recommendation

Response

Corrective measures ta.ken when chlorides and potassium chro-mates in the component cooling water systems are out of specifi-cation have not been adequate in some cases. A coordinated plan to correct these problems and to determine the long-term effects on components serviced by the component cooling water systems has not been developed.

Implement a program that outlines actions required to re-establish proper chemistry conditions in the component cooling water systems when specifications are exceeded.

Particular emphasis should be placed on controlling chemistry during heat exchanger leakage and following maintenance.

Additionally, eva"luate whether long-term deleterious effects exist in components serviced by the component cooling water systems and take corrective action as appropriate.

The procedure for taking corrective measures when chlorides and potassium chromates in the component cooling water systems are out of specification has been reviewed and revised. Plant manage-ment will ensure that timely corrective action is taken when out-of-specification conditions exist in the component cooling water systems.

An evaluation of the chemistry requirements for the component.

cooling water system will be made by March 1983.

This will evaluate the potential for long-term deleterious effects on com-ponents serviced by the system.

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Recommendation

Response

SALEM (1982)

Page 26 A program is needed to control cleaning agents, decontamination agents, and solvents to prevent these materials from-entering plant systems. Examples of uncontrolled cleaning agents and solvents that could be harmful to plant components were noted throughout the plant.

Establish a program to provide controls for the use, transfer, and disposal of cleaning agents, decontall}ination agents, and solvents.

A list of approved cleaning agents, decontamination agents, and solvents should be *established.

Administrative Procedure AP-21 will be revised to ensure that the above materials are handled in a controlled manner by June 1983.

LABORATORY ACTIVITIBS PERFORMANCE OBJECTIVE: Laboratory and counting room activities should ensure accurate measuring and reporting of chemistry parameters..

Finding (CY.4-1)

Recommendation Resp0nse Some chemistry reagents are being used with expired or unidenti-fied shelf lives. in addition, some reagents reportedly have been

. received from the storeroom with expired shelf lives.

Establish a program that provides guidance to technicians on reagent shelf lives.

In addition, the program should require periodic monitoring of the laboratory and the storeroom to ensure that reagents are not retained past the shelf life expiration date.

The program* for controlling chemistry reagents will be improved to better identify reagents with expired shelf lives.

The manager - nuclear procurement will review storeroom proce-dures and implement improvements where needed. The target date for completion of identified improvements is March 1983.

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Recommendation Response _

SALEM (1982)

Page 27

• The methods used for the analysis of iron, copper, and chloride do not accurately measure these parameters at the limits specified by vendor recommendations or station procedures. In addition, the station limits for copper and iron are not consistent with vendor recommendations.

Establish methods that will provide accurate measurement of iron, copper, and chloride at the levels required. After these methods have be~n* established, technicians should be trained in these techniques in. order to ensure that the required sensitivities are achieved.

Re-evaluate and compare station limits for iron and copper with vendor specifications to ensure. that a sound basis exists for variances from vendor recommendations.

A qualified analytical laboratory will be utilized to perform the analysis for iron and copper at the sensitivity called for in the vendor1s recommendations by March 1983. Chloride analysis is now conducted using the ion chromatograph method that allows accu-rate measurements of the concentrations normally encountered.

APPENDIX I SALEM (1982)

APPENDIX I Page 1 Summary of O_utstanding Resp?nse Action from Previous Evaluation (1981)

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

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.

Re5ponse 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 _

~taffing levels will correct deficiencies in operations surveillance, in-service inspection and chemistry. It is expected that these instructions will be issued by September 30, 1981.

Status PSE&G is currently applying selected quality program aspects to various balance-of-plant (BOP) components considered to be important to safety or reliability. These applications have been primarily related to plant modifications when special circumstances warranted this approach.

INPO is developing a Good Practice in this area that will offer additional guidance and alternative methods for application of quality programs to BOP components.

PSE&G will evaluate the Good Practice and will consider improvements to current methods at that time.

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

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

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APPENDIX I Page.2 engineering knowledge or skills and effective mana.gem_ent 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.

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

• Status This training program has been delayed due to the longer than antici-pated time to staff the training department and du~ to the impact of a recent labor strike.

The development of a program for training of station technical support personnel has been undertaken by the technical supervisory skill program (TSSP) Committee with members from the Training Center, Salem and Hope Creek Generating Stations, and consul-tant training specialists.

A comprehensive modular TSSP is being developed that includes information on plant systems and components, specialized engineering knowledge or skills and effective management techniques. PSE&G is planning to develop and implement this program by July 1983.

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

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 opera ting performance and reliability.

Response

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

Status

• A performance and reliability group has been established along with a performance and reliability program. A portion of the program has been implemented.

Total implementation is scheduled to be completed by October 1983.

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APPENDIX II Page 1 Performance Objectives Reviewed ORGANIZATION AND ADMINISTRATION o.A.i **. Station Organization and Administration

.

• Stati~n organization and administrative systems should ensure effective imple-mentation and control of station activities.

OA.2 Mission, Goals, and Objectives Station mission, goals, and objectives should be established and progress.

f!lOnitored through a formal program

• OA.3.1 Management Assessment Management should assess and monitor station activities to ensure effective performance of all aspects of nuclear plant operation.

OA.3.2 Quality Programs Quality programs should ensure the effective performance of activities im-portant to nuclear safety.

OA.4 Personnel Planning and Qualification Personnel programs should ensure that station positions are filled by individuals with proper job qualifications.

OA.5 Industrial Safety Station industrial safety programs should achieve a high degree of personnel safety.

OA.6 Document Control Document.control systems should provide correct, readily accessible infor-mation to support station requirements.

OA. 7 On-site Nuclear Safety Review Committee Review of station nuclear activities by a knowledgeable interdisciplinary group should ensure achievement of a high degree of nuclear safety.

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OP.1 OP.2 OP.3 OP.4 OPERATIONS Operations Organization and Administration SALEM (1982)

APPENDIX II.

Page 2 The operations organization and administrative systems should ensure effective control and implementation of department activities.

Conduct of Operations Operational activities should be conducted in a manner that achieves safe and reliable plant operation.

Plant Status Controls Operational personnel should be cognizant of the status of plant systems and equipment under *their.control, and should ensure that systems and equipment are controlled in a manner that supports safe and reliable operation.

Operations Knowledge and Performance

-* --o"'p-~r~tor~knowledge and performance should :support safe and reliable plant operation.

OP.5 OP.6 MA.1 MA.2 MA.3 Operations Procedures and Documentation Operational procedures and documents should provide appropriate direction and should be effectively used to support safe operation of the plant.

Operations Facilities and Equipment Operational facilities and equipment should effectively support plant operation.

MAINTENANCE Maintenance Organization and Administration The maintenance organization and administrative systems should ensure effec-tive control and implementation of department activities.

Plant Material Condition The material condition of the plant should be maintained to support safe and reliable plant operation.

Work Control System The control of work should ensure that identified maintenance actions are properly completed in a safe, timely, and efficient manner.

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SALEM (1982)

APPENDIX II Page 3 MA.4 Conduct of Maintenance

. MA.5 Maintenance should be conducted in a manner that ensures efficient and effective plant operation.

Preventive Maintenance

• The preventive maintenance programs should contribute to optimum perform-ance and reliability -of plant equipment.

MA.6 Maintenance Procedures and Documentation M~inten*ance procedures should provide appropriate directions for work and should be used to ensure that maintenance is performed safely and efficiently.

MA. 7 Maintenance History The maintenance history should be used to support maintenance activities and optimize equipment performance.

MA.8 Maintenance Facilities and Equipment Facilities and equipment should effectively support the performance of mainte-nance activities.

TECHNICAL SUPPORT TS.1 Technical Support Organization and Administration The technical support organization and administrative systems should ensure

. effective control and implementation of department activities.

TS.2 Surveillance Testing Program TS.3 TS.4 Surveillance inspection and testing activities should provide assurance that equipment important to safe and reliable plant operation will perform within required limits.

Operations Experience Review Program lndustrywide and in-house operating experiences should be evaluated and appro-priate actions undertaken to improve plant safety and reliability.

Plant Modifications Plant modification programs should ensure proper review, control, implementa-tion, and completion of plant design changes in a safe and timely manner.

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APPENDIX II Page 4 TS.5 Reactor Engineering TS.6 On-site reactor engineering activities should ensure optimum nuclear reactor 9peration without compromising design or safety limits.

Plant Efficiency and Reliability Monitoring Performance monitoring activities should optimize plant thermal performance

• and reliability.

TS.7.

• T~hnical Support Procedures and Documentation TQ.1 TQ.2 TQ.3 Technical support procedures and documents should provide appropriate direc-tion and should be effectively used to support safe operation of the plant.

TRAINING AND QUALIFICATION Training Organization and Administration The training organization and administrative systems should ensure effective control and implementation of training activities.

Non-Licensed Operator Training and Qualification The non-licensed operator training and qualification program should develop and improve the knowledge and skills necessary to*perform assigned job functions.

Licensed Operator Training and Qualification The licensed operator training and qualification program should develop and improve the knowledge and skills necessary to perform assigned job functions.

TQ.4 Shift Technical Advisor Training and Qualification The shift technical advisor training program should develop and improve the knowledge and skills to perform assigned job functions.

TQ.5 Maintenance Personnel Training and Qualification The maintenance personnel training and qualification progra}ll should develop and improve the knowledge and skills necessary to perform assigned job functions.

TQ.6 Technical Training for Managers and Engineers The technical training program for engineers and managers should broaden overall knowledge of plant processes and equipment as a supplement to position-specific education and training *

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TQ.'1 General Employee Training SALEM (1982)

APPENDIX II Page 5

. The general employee training program should develop a broad understanding of

• '~mployee responsibilities and safe work practices.

TQ.8.

Tr.aining Facilities and Equipment

• The training facilities, equipment, and materials should effectively support

• *training activities.

RADIOLOGICAL PROTECTION RP.1 Radiological Protection Organization and Administration The organization and administrative systems should ensure effective control and implementation of the radiological protection program.

RP.2 Radiological Protection Personnel Qualification The radiological protection qualification program should ensure that radiolog-ical protection personnel have the knowledge and practical abilities necessary to effectively implement radiological protection practices.

RP.3 General Employee Training In Radiological Protection General employee training should ensure that pllm:t personnel, contractors, and visitors have the knowledge and practical abilities necessary to effectively implement radiological protection practices associated with their work.

RP.4 External Radiation Exposure External radiation exposure controls should minimize personnel radiation ex-posure.

RP.5 Internal Radiation Exposure Internal radiation exposure controls should minimize internal exposures.

RP.6 Radioactive Effluents RP.7 Radioactive effluent controls should mjnimize radioactive materials released to the environment.

Solid Radioactive Waste Solid radioactive waste controls should minimize the volume of radioactive waste and ensure safe transportation of radioactive material.

G SALEM (1982)

APPENDIX II Page 6 RP.8 Personnel Dosimetry_

RP.9 CY.1 CY.2

• The personnel dosimetry program should ensure that radiation exposures are accurately qetermined and recorded.

Radioactive Contamination Control Radioactive contamination controls should minimize the contamination of areas, equipment, and personneL CHEMISTRY Chemistry Organization and Administration The organization and administrative systems should ensure effective imple-mentation and control of the chemistry program.

Chemistry Personnel Qualification The chemistry qualification program should ensure that chemistry personnel have the knowledge and practical abilities necessary to implement chemistry practices effectively.

CY.3 Chemistry Control Chemistry controls should ensure optimum chemistry conditions during all phases of plant operation.

CY.4 Laboratory Activities Laboratory and counting room activities should ensure accurate measuring and reporting of chemistry parameters.

CY.5 Chemical and Laboratory Safety Work practices associated with chemistry activities should ensure the safety of personneL 3:;:~~.... ~~.~--":'?!.~-....'?'-........ ~~--.--~~

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