ML18092A414
| ML18092A414 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 11/21/1984 |
| From: | Liden E Public Service Enterprise Group |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8411280175 | |
| Download: ML18092A414 (7) | |
Text
e PS~G Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Nuclear Department November 21, 1984 U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Licensing Washington, DC 20555 Attention:
Mr. Steven A. Varga, Chief Operating Reactors Branch, No. 1 NUCLEAR OVERSIGHT COMMITTEE RESPONSE TO QUARTERLY REPORT SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311 Gentlemen:
Enclosed for your information is a copy of our response to the October Quarterly Report of our Nuclear Oversight Committee.
Should you have any questions, do not hesitate to contact us.
Enclosure Sincerely, E. A. Liden Manager -
Nuclear Licensing and Regulation C
Mr. H. B. Kister, Chief Projects Branch No. 2, DPRP Region 1 Mr. Donald C. Fischer Licensing Project Manager Mr. James Linville Senior Resident Inspector The Energy People l
,---~*94 1 1*2-00175 a*41121 PDR ADOCK 05000272 R
PDR 95-21 68 (80 M) 11-82
GENERAL November 20, 1984 RESPONSE TO QUARTERLY REPORT NUCLEAR OVERSIGHT COMMITTEE OCTOBER 22, 1984 The Nuclear Department has reviewed and reflected upon the previous NOC meetings and reports.
The department has reviewed existing programs and taken steps to enhance these programs, to be responsive to the NOC concerns.
In particular, it has enhanced activities aimed at identifying and resolving problems and evaluating the root causes of trips and unplanned outages at the Salem facility.
It has also taken steps to reduce the backlog of DCRs.
Further, the department has reviewed the comments on reporting relationships of the safety review function and is imple-menting the arrangement found acceptable by NOC.
NUCLEAR OPERATIONS SUPPORT AND NUCLEAR ENGINEERING The following programs and organizational responses address the NOC's concern about Engineering support of the station in the areas of DCR/DCP backlog and identification of the generic or fundamental aspects of plant trips.
Problem Recognition An Availability and Capacity Factor Improvement Task Force, made up of senior level personnel, has been commissioned.
One of its important assignments is to identify ways in which we can improve our failure analysis and root cause analysis methodology.
The task force held its first meeting on October 25, 1984, and is charged with developing and delivering to the Vice President -
Nuclear an overall plan by January 1985.
In parallel with this task force activity, the Reliability and Assessment Group has initiated a systematic program that is structured to provide insights into the Salem reliability problems.
This program is in it's early phase of implemen-tation, but a high priority of the program is to assess reactor trips and equipment failures to determine if generic patterns exist.
The program is scheduled to provide the following in the first quarter of 1985:
a review and analysis of plant equipment historical data, a review and analysis of reactor trip histories, and the development of a first level reliability model for the plant.
-. ~ Backlog of DCRs and DCPs In the August 30, 1984 response to the Third NOC Quarterly Report, dated July 31, 1984, a discussion was provided on the "Engineering Backlog" related to the design change process.
This discussion included an outline of programs for reduction of the backlog, including implementation of the Change Control Board (CCB), evaluation of inactive projects, and use of con-tractors for completion of projects and closeout of documen-tation.
In the Fourth Quarterly Report, NOC identified con-cerns related to the development of a plan for these programs.
The backlog reduction program status and schedule are dis-cussed herein.
A CCB Charter has been developed and approved by the Vice President -
Nuclear.
Board members have been assigned and the first meeting was held on November 7, 1984, to address the backlog of inactive projects.
All inactive DCRs were returned to the initiating department for re-evaluation and those which are not cancelled by this re-evaluation will be presented to the CCB for disposition.
In parallel with this activity, PSE&G has iriitiated activities to develop an Integrated Living Schedule (ILS) that will aid in the allocation of resources and the long term scheduling of plant activities.
The first phase of the ILS implementation is structured to address the backlog issues.
DCRs awaiting implementation will be re-evaluated in a similar manner.
Those which are intended to be implemented will be incorporated into either the current Unit 2 outage schedule or allocated to a future outage through the exercising of the ILS process.
The program to reduce the backlog of DCRs awaiting final documentation closeout is underway.
Contract personnel have been retained to support this effort and are working in our facilities under the direction of the Manager -
Nuclear Engineering Control to ensure that all documents are updated and issued, and the DCRs are closed.
The anticipated com-pletion date for this effort is the end of December 1984.
At the present time approximately 115 DCRs have been closed out.
Root Cause The ongoing station activities, the Reliability and Assessment programs and the activities of the Availability and Capacity Factor Improvement Task Force, described previously in this document, are responsive to this area of concern.
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- ....... Engineering "Mother" In providing engineering support for Salem Generating Station, Nuclear Engineering utilizes a sponsor program which provides a focal point for system engineering support responsibility.
An engineer is designated as "sponsor" for a specific system(s).
A system responsibility list is maintained and distributed periodically.
The role of the "sponsor" engineer is under review as part of an overall review of the suitability of the existing Nuclear Engineering organizational structure and its ability to efficiently and effectively support plant operations.
"ZERO DEFECTS" The following discussion describes our programs and commitments to the actions indicated by NOC as being useful in achieving a "Zero Defect" Program at Salem Station.
It is the practice of the station to use qualified and well trained personnel to carry out all evolutions at the plant.
Many troubleshooting and surveillance activities are con-sidered critical and requiring special attention which is considered in the qualification process of operating personnel.
A review of the adequacy of qualifications and operating procedures is undertaken as a normal course for incidents with personnel error as a contributing cause.
A Nuclear Training Oversight Committee functions to assure that personnel completing the training programs meet the needs of station operations.
A supplemental review of these qualifi-cations and the adequacy of operating procedures will be conducted, as determined appropriate, as the results of the root cause evaluation programs become available.
A formal program has been implemented, whereby monthly inspections are conducted by a senior management inspection team consisting of a General Manager and at least three other managers.
These inspections cover physical structures and grounds and address the material condition, housekeeping and adherence to radiation protection procedures.
Inspection reports are prepared and distributed to senior management with corrective actions assigned to the cognizant General Manager.
These inspections supplement the recently revised station inspection programs by senior station managers.
Currently, the Salem Station Technical Department's Perform-ance and Reliability Group conducts periodic performance tests and evaluations on plant equipment in order to monitor equip-ment performance and identify problems prior to equipment failure and/or a forced unit shutdown.
A program utilizing equipment vibration signatures and analyses is presently under review for implementation in conjunction with the preventive maintenance program.
The evaluation of system designs to identify equipment which should be added or eliminated will be part of the systematic implementation of the reliability program by the Reliability and Assessment organization.
The Nuclear Quality Assurance organization currently conducts independent valve and circuit breaker lineups on balance of plant equipment as well as safety related equipment to assure proper lineups during power operation.
Since this program has been implemented, valve and breaker tagging errors have been virtually eliminated.
In addition, the information provided by the NQA valve surveillance reports has resulted in more accurate and complete lineup procedures and a much improved TRIS Data Base.
Reports are also utilized by Nuclear Engineering to verify "as built" conditions of the plant and to correct any deficiencies noted.
The Reliability and Assessment organization is implementing programs that are structured to accomplish the following objectives:
a)
Ensure continual enhancement of nuclear plant reliability through technical evaluations of plant operating history, operating experiences at other nuclear plants and maintenance and modification programs.
b)
Set reliability goals for the plant and allocate unavailability on a system and component basis to achieve these goals.
c)
Monitor and evaluate the reliability and maintenance experience of the plant on an ongoing basis to ensure the reliability goals are achieved.
d)
Review, develop and support activities which will enhance equipment reliability and plant availability.
UPPER MANAGEMENT INVOLVEMENT IN POST PLANT TRIP REVIEWS With the establishment of the Nuclear Department on site, senior management and engineering personnel are readily available to participate in post-trip reviews.
The Station Operations Review Committee (SORC) reviews all reactor trips to ensure root causes are identified and approved corrective actions are implemented to preclude recurrence.
Restart of a unit following a trip can be authorized only by the General Manager -
Salem Operations.
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'"',.... As a permanent member of SORC, the head of Safety Review Group is now in line with the post-trip review process.
Evaluation of reactor trips involves station department managers and engineers prior to and during the SORC review to ensure the highest level of management attention.
The post-trip review results are discussed in detail with the General Manager -
Salem Operations in order to provide him with a basis for authorizing restart of a unit following a trip.
Additionally, detailed discussions with the Vice President -
Nuclear take place prior to a reactor restart.
In summary, the highest level of station management is involved in the review of plant trips and decisions during post-trip evaluations prior to plant restart.
Corporate management is kept informed and other senior managers and specialists are involved as required.
The current level of management involve-ment with plant trips facilitates the decision-making process, encourages professional rigor and makes use of any and all available resources.
ACTION PLAN -
NRC MILESTONES AND FOLLOW-UP To assure NRC commitments are met, each Action Plan Sponsor submits close-out documents to the Program Director.
The documents are reviewed and any concerns are resolved with the Sponsor.
Following the initial review, the documents are submitted to the General Manager -
Nuclear Quality Assurance.
The Nuclear Quality Assurance staff then verifies the completeness of the documents and compares them to the Action Plan and MAC Management Diagnostic to assure completion of all NRC commitments.
Following the fourth meeting of the NOC, Action Plans 2.1.1, 2.1.2, 2.1.4, 2.2.1, 2.3.1, and 2.4.5 have been verified complete by Nuclear Quality Assurance and closed out in accordance with the close-out procedure described above.
Each completed Action Plan is presented at the NRC bi-monthly meetings.
These presentations provide assurance that there are no misunderstandings in the methodology used to close-out the Action Plans.
Action Plans 2.1.1, 2.1.2, 2.1.4, 2.1.5, 2.2.1, 2.3.l, 2.3.2, 2.4.3 and 2.4.5 were discussed in detail at the bi-monthly NRC meeting held on November 16, 1984.
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'*.. The Action Plan Follow-Up Program was presented to PSE&G senior management and Action Plan sponsors at the Managers' Dialogue Session held on October 16, 1984.
During the initial stages the Follow-Up Program will be administered by Program Director's staff.
If advisory groups or working groups were involved in program development, they will perform technical reviews of appropriate action plans during implementation and provide feedback to the sponsor to ensure that the plan accomplishes its purpose.
The Action Plan Close-out Procedure and Follow-Up Program were presented to the NRC at the bi-monthly meeting held on November 16, 1984.