ML18093A874

Forwards Response to SALP Repts,Per Request Made During 880414 Meeting.Sys Engineer Function & Responsibilities Should Be Clarified & Detailed Plan for Improvement of Lab Qa/Qc Prepared

ML18093A874
Person / Time
Site:	Salem, Hope Creek, 05000000
Issue date:	05/25/1988
From:	Miltenberger S Public Service Enterprise Group
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML18093A872	List: ML18093A874
References
NLR-N88080, NUDOCS 8806130080
Download: ML18093A874 (86)

Text

' .

Public Service Electric and Gas Company

. .te*en E. Mmenbe*ge, Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 Vice President and Chief Nuclea: Officer May 25, 1988 NLR-N88080 United States Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Attention: Mr. William T. Russell Region I Administrator RESPONSES TO THE HOPE CREEK AND SALEM GENERATING STATIONS SALP REPORTS Enclosed are our responses to the Hope Creek and Salem Station recent SALP Reports. These responses are being submitted per your request made during a meeting at Hope Creek Station on April 14, 1988. Responses to the Hope Creek SALP report are enclosed in Attachment 1 and Salem responses are enclosed in Attachment 2.

Should you have any questions in this regard, please do not hesitate to contact us.

Sincerely, Attachments 8806130080 880602

~DR Afi6t~ 05000272 DCD

Mr. w. T. Russell 2 5/25/88

• C Mr. G. w. Rivenbark USNRC Licensing Project Manager - Hope Creek Mr. G. w. Meyer USNRC Senior Resident Inspector - Hope Creek Mr. D. C. Fischer USNRC Licensing Project Manager - Salem Mr. R. W. Borchardt USNRC Senior Resident Inspector - Salem Mr. D. M. Scott, Chief Bureau of Nuclear Engineering Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628 Document Control Desk Washington, DC 20555

ATTACHMENT l HOPE CREEK SALP REPORT RESPONSE A. Plant Operations

1. Analysis The analysis described Hope *creek plant *operations to be conducted in a conservative and safety conscious manner.

A number of. areas of improvement were noted. A need for increased non-licensed operator attention to detail and overall plant knowledge was described. This weakness contributed to one reactor scram and a number of equipment availability problems. Investigations have determined that many of these problems could have been precluded' by increasing the level of detail in logs and procedures available to operators. Revisions to the applicable documents have been completed. *To prevent other equipment control problems all local switches that control Technical Specification equipment have been identified with "Operator Aids" signs requiring them to be maintained in the correct position. Further, a program to instruct and evaluate non-licensed operators in the field will be instituted during 1988. This program will consist of selected surveillance tests being performed in the field by the responsible non-licensed operator and acccompanied by a Senior Reactor Operator (SRO). Feedback from the SRO will provide non-licensed operators with detailed guidance on how to increase the effectiveness of surveillance activities to preclude further equipment availability problems. This feedback process should also increase the quality of the procedure being performed.

A need for improvement in housekeeping was also identified. Associated with this was a concern with improperly erected or stored scaffolding. To address this concern, Station AP-023, Scaffolding Program, has been revised to provide improved direction on the erection and control of scaffold within the plant.

Scaffold installations are monitored and included in a management report which is reviewed weekly by station department managers and the station General Manager. The Maintenance Department has issued a department directive which clearly identifies the areas approved for scaffold storage by the Engineering Department. The areas are identified by the use of floor markings and lamacoid tags. These actions should preclude further concern in this area

• e e Another housekeeping issue was evidence of eating and smoking in radiological controlled areas. To address this issue the Hope Creek Radiation Protection Department will continue mandatory supervisory tours of the radiological controlled area to identify areas and personnel that show evidence of eating, drinking or smoking to station department management.

2. Board Recommendations RECOMMENDATION: Evaluate future licensed operator manning requirements to ensure adequate staffing levels are maintained.

RESPONSE: A licensed operator "Pipeline" program has been established to ensure future operator staffing requirements are met. This program will provide an additional eight training positions to current Hope Creek manning levels.

These positions will be used as required to maintain adequate shift coverage with minimal overtime.

B. Chemistry and Radiological Controls

1. Analysis Overall, the SALP analysis concluded that Hope Creek is implementing an effective radiological control program.

Most of the concerns noted in the analysis were observed early in the SALP period, and have since been corrected.

The following actions are underway for those not yet corrected:

1. A dose budgeting system is currently under development that will enhance the ALARA goals program and will facilitate ALARA reviews of work in progress. Implementation is expected in July, 1988.

2. Alignment has been reached between Radiation Protection/Chemistry Services and Quality Assurance for increasing the technical depth of audits and assessments allowing them to be more performance oriented.

3. The Radiological Occurrence Report System is currently under review and recommendations for its improvement are being developed. Hope Creek is evaluating inclusion of significant radiological oc~urrences in its Incident Reporting Program.

4. An NRC inspection conducted during the week of 4/18 -

4/22 indicated that effective preventative actions have been taken in response to earlier NRC identified problems in the radioactive waste shipping program.

In general, as we noted during the SALP review meeting at Hope Creek on April 14, 1988, most areas of concern were successfully addressed during the SALP period.

2. Board Recommendations None.

c. Maintenance and Outage Management

1. Analysis The SALP analysis characterized the maintenance, planning and outage organizations as well trained and experienced organizations. No unaddressed concerns were identified in the analysis.

2. Board Recommendations None.

D. Surveillance

1. Analysis Overall, the surveillance program was found to be an effective program using procedures of high quality.

A few areas needing improvement were noted.

The surveillance analysis identified a need for improvement in recognizing the need for and accomplishing situational type tests and sample analyses. This concern was specifically related to radiation and protection areas where five failures to have required systems operable, compensating samples analyzed, or surveillance tests completed were identified. Corrective actions taken in response to these failures include revision of applicable procedures, additional training emphasizing the importance of sampling for out of service equipment, and a detailed site wide program providing increased control of rad waste shipments.

A concern regarding occasional breakdowns in the level of attention to detail and strict procedural compliance was also identified. At the time of the incidents, the appropriate department manager emphasized the department policy of procedure adherence during group sessions with personnel. Responsibilities of independent verification and licensed responsibilities were also addressed.

Furthermore, a working group composed of multi-discipline members was established to identify and correct possible contributing factors dealing with procedure adherence.

... I '

A lack of timeliness in incorporating technician recommended refinements to surveillance procedures was identified as leading to complancy toward strict procedural compliance. Recently, control of plant

• procedures was centralized within the Hope Creek Technical Department. This will provide a direct focus and dedicated effort to optimize procedural revisions.

While the procedures are a proven technical product, technicians have provided a number of enhancements as recognized in the SALP analysis. The formation of a centralized procedures group combined with the scheduled two-year review will provide the opportunity to incorporate the refinements which have been identified.

2. Board Recommendations None.

E. Emergency Preparedness

1. Analysis We are in agreement with the analysis ~nd have no further comment.

2. Board Recommendations None.

F. Security and Safeguards

1. Analysis Overall, the SALP analysis found the site wide security program to be highly effective. No unaddressed concerns were identified.

2. Board Recommendations None.

G. Engineerin~ Support

1. Analysis In response to previous SALP reports identifying the need for improved engineering support, a comprehensive reorganization of the Engineering and Plant Betterment (E&PB) Department was implemented in December 1987.

Since much of the assessment period was consumed by defining and establishing this new organization, there

was not a sufficient basis on which to make a performance evaluation. The analysis states that this area will be closely monitored during the next assessment period *

• 2. Board Recommendations RECOMMENDATION: Clarify the system engineers' function and responsibilities.

RESPONSE: In early 1988, the System Engineering Group within the Technical Department was reorganized from two to four functional groups to help provide prioritization and planning of work. Job descriptions and system engineering responsibilities were issued in department procedures and will be updated as necessary. In addition, a "Living Engineering Plan" is being established to provide for long term prioritization and work load control.

Other factors contributed to difficulties in filling the system engineer's role in 1987. First, a significant number of paperwork items dating from the Startup and Power Ascension program were closed out by the system engineers in 1987. This was in addition to their normal workload. Also, many system engineers attended a comprehensive plant operations training program during the first half of 1987. While this program provided system engineers with broad operational training, it also decreased their availability at the plant. Third, the reorganization of E&PB during the period impacted the level and timeliness of their support. With the completion of these activities, the system engineers workload will decrease and be more focused on daily plant operation. Also, the E&PB Department reorganization has resulted in improved engineering support to identified problems. This has and should continue to reduce the system engineers' workload.

H. Licensing Activities

1. Analysis Concerns with scheduling of submittals and completeness of information were identified and are addressed below.

2. Board Recommendation RECOMMENDATION: Provide additional effort to assure the quality of all submittals; and submit requests requiring NRC action earlier with respect to the required action date

• I

• RESPONSE: Increased attention is being given to submittals to ensure that they provide adequate information to substantiate the requests. Also, previous industry correspondence pertaining to a submittal is being reviewed when necessary to ensure that the level of detail is adequate to preclude the need for additional requests for information.

The licensing staff is working more closely with station and engineering management to identify license change requests needed for refueling outages earlier. This should result in*

more timely submittal of requests.

I. Training and Qualification Effectiveness

1. Analysis The identified concern in the analysis is addressed below.

2. Board Recommendation RECOMMENDATION: Resolve personnel error/inattention to detail problems.

RESPONSE: The analysis noted that a number of the personnel errors resulting in reportable events were caused by lapses of attentiveness or attention to detail rather than a lack of specific knowledge.

Since attention to detail is an inherent part of training, continued quality training should help preclude personnel errors in the future. Training review groups and the Nuclear Training Oversight Committee will address this topic at their next respective meetings to identify additional actions the Nuclear Training Department should take to increase personnel attentiveness to detail.

J. Assurance of Quality

1. Analysis Continued improvement in quality is being aggressively pursued with emphasis placed on improving the effectiveness of quality verification functions performed by both line organizations and independent assessment groups. This will ensure that quality is achieved and problems are avoided.

In reference to the concern regarding Engineering and Plant Betterment (E&PB) Departments' response to QA

• findings, E&PB has implemented a Correction Action Request Management System which has improved E&PB performance. The system centralizes responsibility in

e e the Nuclear Engineering Standards Section for receipt, response, corrective action implementation, and closeout of all QA action requests issued to E&PB. As of March 31, i988, all fifteen (15) action requests received during 1988 and processed with this system have been

.responded to on time.

2. Board Recommendations None

• ATTACHMENT 2

• RESPONSE TO SALEM SALP REPORT A. Plant Operations

1. Analysis While finding the plant operations organization to be competent, responsive, and highly motivated toward safe plant operations, the analysis did note some areas in need of improvement. In regards to instances of poor communications, a Conduct of Shift Operations Program is being developed which will formally address this issue.

In reference to the wrong unit equipment error, a Human Performance Evaluation is being reviewed to prevent reoccurrence. It was noted that in some instances, operators were not wearing monitoring devices in the correct manner. All personnel have been reminded as to the proper location for wearing personnel monitoring devices.

2. Board Recommendation None.

B. Chemistry and Radiological Controls

1. Analysis While the analysis noted continuing strong performance in a variety of areas, several concerns were identified.

These are addressed below and in the response to the Board Recommendations.

The Radiation Protectiori organization responsibilities were recently expanded to include chemistry. This .

organization change impacts the technician level in that a technician "pool" will perform both chemistry and

.health physics (HP) functions. A concern was raised that previous experience has shown this type of organization to be detrimental to effective performance of HP duties.

However, the intent of this change is to combine only specific functions at the technician level within the Radiation Protection and Chemistry Departments. Specific functions to be combined are basic tasks, such as using a frisker or determining the pH of a liquid. Paragraph 3.2.4 of ANSI 3.1, 1981, allows performance of such tasks provided that qualification of these tasks has been demonstrated, whether or not the t~chnician performing them meets the full experience requirements for his or her specialty. This enables nuclear power facilities to train and qualify otherwise inexperienced new hires.

2. Board Recommendation

• RECOMMENDATION: Provide and complete a schedule of radiation protection program procedure upgrades.

RESPONSE: A schedule for procedure upgrades has been prepared by Salem Radiation Protection. Revised and upgraded procedures will be fully implemented by May, 1988.

RECOMMENDATION: Re-evaluate the dual assignment of HP and chemistry technicians in light of HP appraisal findings in this area.

RESPONSE: A re-evaluation of the dual assignment of HP and chemistry technicians has been performed. This re-evaluation will be presented to the NRC at a future date.

RECOMMENDATION: Improve radiological and nonradiological laboratory QA/QC and followup NRC and licensee audit identified weaknesses in these areas.

RESPONSE: Salem management has prepared a detailed plan for improvement of laboratory QA/QC and f ollowup on identified weaknesses in these areas. The Radiation Protection/

Chemistry Services Department will provide coordination and

• c.

oversight for this plan and will assist the station as requested.

Maintenance

1. Analysis We are in agreement with the analysis and have no further comment.

2. Board Recommendation None.

D. Surveillance

1. Analysis While the analysis found the surveillance program to be sound, a need for increased licensee oversight and attention to detail in the implementation of surveillances was identified. The Quality Assurance Department is performing an evaluation of the administrative control on recurring surveillance tasks and Equipment Qualification tasks. This evaluation will compare the computer based work order system with the Technical Specifications, and applicable Engineering Field Directives. Improvements to the surveillance program will be made based on the results of this review.

~ .

2. Board Recommendation None.

E. Emergency Preparedness

1. Analysis We are in agreement with the analysis and have no further comment.

2. Board Recommendation None.

F. Security and Safeguards

1. Analysis We are in agreement with the analysis. No unaddressed concerns were identified.

2. Board Recommendations

• G.

None.

Refueling, Outage Management

1. Analysis We are in agreement with the analysis and have no further comment.

2. Board Recommendations None.

H. Engineering Support

1. Analysis The analysis stated that previously identified weaknesses within the off-site engineering department continued, but to a lesser extent. The analysis also stated that long term corrective action programs are in place. Two specific occurrences were discussed. The first occurrence dealt with the design evaluation and documentation of piping and support systems. Our response has been as follows:

". I*

0 The concerns expressed during NRC inspections on the approach and criteria for design and evaluation of piping and support systems have been addressed via issuance of Stress Directives that clearly interpret and provide technical direction on the performance of the related activities.

0 Verified documentation for safety related piping stress calculations and support evaluations are being maintained in compliance with 10CFR50 Appendix B requirements.

0 The technical reports generated by the vendor are reviewed in accordance with Engineering and Plant Betterment (E&PB) procedures. The error identified in the contractor's report related to U-Bolt Anchors-has since been corrected and the design information reviewed in accordance with procedures.

0 The concerns related to the Inservice Inspection of the U-Bolt Anchor assemblies were resolved by issuance of a Field Directive that requires torque verification of U-Bolt Anchors during subsequent outages.

The second occurrence identified a programmatic weakness in design interfaces during the process of design modifications. Our response has been as follows:

0 Since December, 1987, an improved process of design change control has been initiated which emphasizes design interfaces, peer review, specialty review and (when required) verification. An all-day training class is required of all engineers and designers which concludes with an exam requiring 80% to pass.

Over two hundred personnel have successfully passed the course and exam.

0 In a broader perspective, E&PB is developing a formal training program to address the attainment of enhanced skills in all areas of Engineering (including management skills). This program allows for two to four weeks of training per engineer *per year to meet his or her position requirements (the latter being determined by performing a job analysis). The present training program will continue until the enhanced program is in place.

2. Board Recommendation None.

l.

UNITED ST ATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406

&9 MAR 1988 Do:ket Nos. 50-272 50-311 50-354 Public Service Electric & Gas Company ATTN: Mr. Steven E. Miltenberger Vice President - Nuclear Post Of~~ce Box 236 Hancocks Bridge, New Jersey 08038 Gentlemen:

Subject:

Systematic Assessment of Licensee Performance (SALP)

The NRC Region I SALP Board has reviewed and evaluated the performance of activities at the Salem and Hope Creek Generating Stations for the period of October 1, 1986 - December 31, 1987 and December 1, 1986 - January 15, 1988, respectively. The results of the assessment are documented in the enclosed SALP Board reports dated February 5 and March 4, 1988. A meeting to discuss this assessment will be scheduled for a mutually acceptable date.

At the SALP meeting, you should be prepared to discuss our assessments and your plans to improve performance. This meeting is intended to be a dialogue wherein any comments you may have regarding our report may be discussed.

Additionally, you may provide written comments within 30 days after the meeting.

Your cooperation is appreciated.

Sincerely,

~William T. Russell Regional Administrator

Enclosure:

SALP Report Nos. 50-272/86-99 and 50-311/86-99 SALP Report No. 50-354/86-99

• I ..

Public Service Electric &

Gas Company 2 2 9 MAR 1988 cc w/encl:

J. Zupko, General Manager, Salem Operations S. LaBruna, General Manager, Hope Creek Operati~ns B. A. Preston, Manager - Licensing and Regulation W. H. Hirst, Manager, Joint Generation Projects Department, Atlantic Electric Jack Urban, General Manager, Fuels Department, Delmarva Power and Light Rebecca A. Green, Bureau of Radiation Protection M. J. Wetterhahn, Esquire R. Fryling, Jr., Esquire Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector K. Abraham, PAO (11)

State of New Jersey Chairman Zech Commissioner Roberts Commissioner Bernthal Commissioner Carr Commissioner Rogers bee w/encl:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

DRP Section Chief George Rivenbark, NRR Project Manager B. Clayton, EDO Board Members

I. Licensing Activities

1. Analysis The analysis noted that while most submittals allowed for adequate NRC review time, several were not tendered in a timely manner. The licensing staff is working more closely with station and engineering management to identify license change requests needed for refueling outages earlier. This should result in more timely submittal of requests.

2. Board Recommendation None.

J. Training and Qualification Effectiveness

1. Analysis The analysis noted that an increasing proportion of personnel errors indicated a need to increase attention to detail. A review of personnel error ineident reports has been included in the Licensed Operator training received concerning the differences between the Unit 1 and Unit 2 Technical Specifications as a concern.

Training on the Technical Specification differences took place in Segment 1 of the 1987/88 Licensed Operator Requalification Cycle, and is reinforced in regular classroom and simulator training sessions.

In reference to the June 1987 requalif ication examination, the following actions have been taken:

0 All individual exam failures were remediated in accordance with procedures.

0 The Operations Department revised Operations Directive OD~lS to describe the proper use of Operations Department procedures.

0 The dropped rod abnormal operating procedure was reviewed with all shifts during Segment I of Licensed Operator Requalif ication.

0 The station Operations Department has issued a letter to all station SROs detailing their responsibilities and the proper standards of performance of their duties.

0 Radiation monitoring equipment was reviewed in Segment I of Licensed Operator Requalif ication.

0

~he Unit 2 RMS system was covered in Segment III of Licensed Operator Requalification

• 0 The Operations Department management has participated in the Licensed Operator Requalif ication Program as simulator evaluators during the annual operating test, and has, an occasion, reviewed the conduct of simulator training.

2. Board Recommendation None.

K. Assurance of Quality

1. Analysis Continued improvement in quality is being aggressively pursued with emphasis placed on improving the effectiveness of quality verification functions performed by both line organizations and independent assessment groups. This will ensure that quality is achieved and problems are avoided.

2. Board Recommendation None.*

U. S. NUCLEAR REGULATORY COMMISSION REGION I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NO. 50-272/86-99; 50-311/86-99 PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM GENERATING STATION ASSESSMENT PERIOD: October l, 1986 - December 31, 1987 SALP BOARD FEBRUARY 5, 1988

TABLE OF CONTENTS I. INTRODUCTION . . . . ,.. 1 A. Purpose and Overview; 1 B. SALP Board Members: 1 I I . CRITERIA . . . 3 III.

SUMMARY

OF RESULTS 5 A. Overall Summary 5 B. Background. . . 6 C. Facility Performance Analysis Summary 11 D. Unplanned Shutdowns, Plant Trips, and Forced Outages 12 IV. PERFORMANCE ANALYSI$ . . ... 15 A. Plant Operations. . . . . 15

• B.

C.

D.

E.

F.

G.

Chemistry and Radiological Controls Maintenance Surveillance. .

Emergency Preparedness . . . .

Security and Safeguards . .

Refueling, Outage Management.

18.

24 27 30 32 36 H. Engineering Support . . 38 I. Licensing Activities. . 43 J. Training and Qualification Effectiveness. 45 K. "Assurance of Quality .. 47 V. SUPPORTING DATA AND SUMMARIES. . . . 50 A. Investigations and Allegations . . . . . . . . . . . . . 50 B. Escalated Enforcement Actions SO C. Management Conferences. . . . SO D. Licensee Event Reports. . . . Sl TABLE 1 - INSPECTION REPORT ACTIVITIES. S2 TABLE 2 - INSPECTION HOUR

SUMMARY

S6 TABLE 3 - ENFORCEMENT ACTIVITY .. S7 TABLE 4 - LICENSEE EVENT REPORTS. 61 TABLE S -

SUMMARY

OF LICENSING ACTIVITIES 66

• I. INTRODUCTION A. Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an iritegrated NRC staff effort to collect the available observations and data on a periodic basis and to evaluate licensee performance based upon this information. The SALP program is supplemental to the normal regulatory processes used to ensure compliance to NRC rules and regulations . . The SALP program is intended to-be sufficiently * =-

diagnostic to provide a rational basis for allbcating NRC resources and to provide meaningful guidance to the licensee's man~gement to promote quality and safety of plant operation.

The NRC SALP Board, composed of the staff members listed bel-0w, met on February 5, 1988 to review the collection of performance obser-vations and data .and to assess licensee performance in accordance with the guidance in NRC Manual Chapter 0516, 11 Systematic Assessment of Licensee Performance 11

• A summary of the guidance and evaluation criteria is provided in Section II of this report.

This report is the SALP Board's assessment of the licensee's safety

• performance at the Salem Generating Station for the period October 1, 1986 through December 31, 1987. It is noted that the summary findings and totals reflect a 15 month assessment period.

The SALP Board was comprised of the following:

Chairman S. J. Collins, Deputy Director, Division of Reactor Projects (DRP)

Members W. F. Kane, Director, Division of Reactor Projects (DRP) (part-time)

W. R. Butler, Project Director, PDI-2 (NRR) (part-time)

J. E. Richardson, Acting Deputy Director (DRS)

E. C. Wenzinger, Sr., Chief, Reactor ProjBcts Branch 2 (DRP)

R. M. Gallo, Chief, Operations Branch (DRS)

R. R. Bellamy*, Chief, Facilities Radiological Safety and Safeguards Branch (DRSS) (part-time)

P. D. Swetland, Chief, Reactor Projects Branch 2B (DRP)

T. J. Kenny, Senior Resident Inspector, Salem (DRP)

2 Other Attendees (non-voting)

R. R. Keimig, Chief, Safeguarcis Section (DRSS) (part-time)

W. J. Lazarus, Chief, Emergency Preparedness Section (DRSS)

(part-time)

W. J. Pasciak, Chief, Effluents Radiation Protection Section (DRSS)

(part-time)

M. M. Shanbaky, Chief, Facilities Radiation Protection Section (DRSS)

(part-time)

R. J. Summers, Project Engineer, Branch 2B (DRP) (part-time)*

M. J. Cioffi, Radiation Specialist (DRSS) (part-time)

D. T. Wallace, Operations Engineer (DRS)

3

• II. CRITERIA Licensee performance is asse~sed in selected functional areas. Functional areas normally represent areas significant to nuclear safety and the environment.

One or more of the following evaluation criteria were used to assess each area.

1. *Management involvement and control in assuring quality.

2. Approach to resolution of technical issues from a safety standpoint.

3. Responsiveness to NRC initiatives.

4. Enforcement hi story.

5. Operational events (including response to, analysis of, and corrective actions for).

6. Staffing (including management) .

• 7. Training and qualification have been used where appropriate.

eff~ctiveness.

However, the SALP Board is not limited to these criteria and others may Based upon the SALP Board assessment each functional area evaluated is classified into one of three performance categories. The definitions of these performance categories are:

Category 1: Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety is being achieved.

Category 2: NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and concerned with nuclear safety; licensee resources are adequate and reasonably effective so that satisfactory performance with respect to operational safety is being achieved.

Category 3: Both NRC and licensee attention should be increased. Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear strained or not effectively used such that minimally sat i sfa.ctory performance with respect to operational safety is being achieved.

4

• The SALP Board may determine to include an appraisal of the performance trend of a functional area. Normally, this performance trend is only used where both a definite trend of performance is discernible to the Board and the Board believes that continuation of the trend may result in a change of performance level. Improving (declining) trend is defined as:

Licensee performance was determined to be improving (declining) near the close of the assessment period .

5

• III.

SUMMARY

OF RESULTS A. Overall Summary The Salem facilities continue to operate in a safe, competent manner.

The leadership of site and corporate management in setting high goals with respect to plant safety and reliability is evident.by the commit-ment of resources to identify and solve problems, the establishment of ownership and accountability for facility performance, and the prompt conservative approach* to safety issues, particularly when continued plant operation was affected. The licensee's handling of service water corrosion/erosion problems, electrical coordination discrepancies and reactor vessel head leaks exemplfy this element of performance.

Operator performance during routine and abnormal conditions has been good: Some insta.nces. of inattention to detail and inadequate communications/interface with other departments have resulted in plant trips or other events. While.the frequency of trips has been reduced, particularly for Unit 1; th~ number of trips for Unit 2 can be improved. Problems identified in the operator requalification program also require further licensee attention.

The surveillance program satisfactorily implements a large number of test requirements to assure reliable equipment operation. Weaknesses in attention to detail and inter-department interface continue to result in a small, but growing number of missed or late surveillances.

There is an effective radiation protection program onsite, with cha 11 engi ng ALARA goa 1s and adequate resources and management comm,; t-ment to successfully achieve them. Not withstanding, recurrent weaknesses in the quality of radiation protection procedures and the implementation of laboratory quality controls need to be addressed.

Noteworthy good performance was recognized in the maintenance, security, emergency planning, outages and assurance of quality areas. In each case, the licensee's aggressive approach to excellence, quality of training, and commitment of resources were exemplary.

In the engineering area, older plant problems such as inadequate implementation of new regulatory requirements and poor documentation of the design basis for the plants continue to affect overall performance .. Recent licensee initiatives appear to be effective in identifying and correcting these problems. Nevertheless, the assess-ment of licensee performance in this area reflects the continuing c0ncern over previous performance weaknesses .

• The strength* 6f the management team and the positive worker attitude contribute to the improving trend in licensee performance overall.

Recurring lapses in individual attention ~o detail particularly in the surveillance area, longstanding problems with radiation protection procedures and quality control in the chemistry area, and continuing design and engineering support discrepancies indicate that further licensee emphasis in these areas is warranted.

6

• B. Background

1. Licensee Activities Unit 1 Unit 1 began this assessment period at 83% due to loading restrictions within the electri~al plant. The restrictions were self imposed due to station transformer loading problems identified after the August 26, 1986 false loss of offsite power. Following manipulation of electrical loads between Unit 1 and 2, which conformed to licensee commitments to the NRC, the Unit operated at various power levels up to 100% ~ntil March 1, 1987, when a tanker struck and destroyed a 500 KV line from Hope Creek to Keeney, Delaware. The loss of this line restricted*

electrical output from Salem and Hope Creek because of the potential for off-site electrical line instability if another 500 KV line was lost with all three plants operating at full power.

On March 8, 1987, the unit was removed from se:r;::,v1ce for planned maintenance and the replacement of No. 1 Auxiliary Power Transformer. The unit was returned to service on March 15, after completion of this maintenance. Unit output was restricted to 71% due to the loss of the 500 KV Keeney line.

On March 27, 1987, a new plant tripping device was energized allowing the units to return to 100% power. This device was installed to trip one operating unit, if another off-site high voltage line would be lost. The unit selected by the trip-a-unit device would trip, thus restricting output power from the Artificial Island (location of Hope Creek and Salem Generating Stations). To prevent undesired trips, the

• trip-a-unit device was disarmed and unit output reduced anytime electrical storms in the area threatened high voltage line reliability.

On April 6, 1987, Steven Miltenberger was appointed to the position of Vice President - Nuclear Operations and Corbin McNeill was promoted to Senior Vice President - Nuclear.

On June 2, 1987, the unit tripped due to a lightning strike on the line that had the trip-a-unit in service. The trip-a-unit had not been disarmed because the electrical storm intensity was below the criteria necessary to disarm. This forced the licensee to reevaluate the criteria for removing the trip-a-unit. It was determined that such a lightning strike was not common and the criteria was not changed.

)

/

7

• On October 2, 1987, the unit was removed from service for a refueling outage and plant modifications. The licensee per-formed the following major changes to the facility: (1) removal of the RTD bypass loop; (2) installation of bottom mounted core exit thermocouples and the elimination of th~ instrument pene-trations on the reactor head; (3) removal of the boron injection tank, as well as other modifications. The unit remained in the refueling outage (Mode 5) at the end of this report peribd .. The startup from the outage was delayed by a service water flooding event and the discovery of cracks in three spare contro1 rod drive mechanism penetrations.

During this rating period Unit 1 participated in an IAEA sponsored program to monitor plant activities to prevent diversion of special materials. The staff and management enthusiastically supported these safeguards activities and performed in an exemplary manner.

Unit 2

• • Unit 2 began this report period operating at 65% power with No.

21 feed pump out of service. On October 2, 1986, the unit was removed from service for a refueling outage. While taking the unit off the line, the licensee successfully demonstrated a partial unit shutdown from outside the control room. Outage activities included: (1) An intrusion of resin into the Refueling Water Storage Water Storage Tank and eventually into the refueling cavity; (2) A complete assessment of all of the welds in the service water system related to the containment fan cooler units; (3) replacement of No. 21 component cooling water heat exchanger tubes; and other design changes and maintenance.

On December 23, 1986, during the restart from refueling, the unit tripped from 8% power while troubleshooting an electro-hydraulic control (EHC) system failure. Repairs were made and the unit was brought on line on December 24, 1986. (The unit operation was restricted due to the same condition of the electrical plant that was delineated above for Unit 1.)

On December 28, 1986, the unit tripped from 77% power due to loss of level in No. 23 steam generator. The cause was a control system failure of the feedwater regulating control valve, which caused the valve to shut. On December 29, 1986, the unit was returned to service.

On January 18, 1987, the unit was being taken off the line due

• to a main generator exciter ground fault alarm when at. 3%, the unit tripped due to a high neutron flux signal which was

8

• inadvertently initiated by an instrument technician performing a surveillance on the nuclear instrument channels. The unit was returned to service on January 19*, 1987.

On March 12, 1987, the unit tripped from 96% power due to a main generator loss of field. The event was caused by operating the generator in an over excited condition. This was a new opera-ting condition necessitated by the electrical problems on the off-site electrical system with newly generated excitation curves and excitation metering that was not calibrated with the tolerances desired. The licensee reissued the curves, recali-brated the instrumentation, and restarted the unit on March 14, 1987.

On April 7, 1987, the unit tripped from 85% due to loss of electro-hydraulic control system O.C. power. The problem was traced to a failed servo card which was replaced. The unit was cooled down to repair a non-isolable valve in the reactor coolant system not caused by the trip. The licensee also identified a main generator stator water leak which was also repaired. The unit was returned to service on April 17, 1987.

On June 25, 1987, the unit was removed from service to investigate the reasons for a high vibration on No. 6 t~rbine bearing, and an unusual noise in the vicinity of No. 22 moisture separator reheater (MSR). The licensee performed a visual inspection of low pressure turbines, piping, and MSR 1 s with no identified problems. A vibration analysis contractor was brought to the site, and on June 30, 1987 the unit was restarted and brought to 62% power (the point where vibration and noise1 began to accelerate). The source of the noise was pin-pointed and the unit was once again removed from service. A transition piece diaphragm gasket in a low pressure turbine had failed. It was replaced and the unit was placed in service on July 13, 1987.

On August 6, 1987, the unit tripped from 100% power when No. 24 steam generator experienced a high-high level. The reason for the high level was the operator's inattention to the feedwater control system which had been placed in manual beca~se of an ongoing surveillance test. The operator was counseled and retrained, and the unit was returned to service on August 7, 1987 *.

On August 7, 1987, the licensee removed the unit from service after main output transformer oil samples indicated insulation breakdown in one of three inservice transformers. During this plant outage, the licensee also identified a small leak on the seal weld for #5 reactor vessel head instrument (conoseal)

• '_ ~ ..

9 penetratioh. The transformer was replaced with an on site spare, and the conoseal leak was repaired. The unit was returned to service on August 27, 1987.

On October 24, 1987, the licensee removed the unit from service when it could not be determined, through analysis and records search, that Class lE electrical breaker coordination existed.

The licensee brought the unit to Mode 5 and performed analyses

. and electrical modifications to the unit. On December 17, 1987, it was certified that breaker coordination ex1sted. The Keeney 500 KV electrical line was also returned to service in December 1987, thereby removing the need for the trip-a-unit protection.

The trip-a-unit equipment was de-activated for both units, Unit 2 was restarted and remained at 100% power through the end of this report period.

2. Inspection Activities -

Two NRC resident inspectors were assigned during the inspection period. The total of 4288 hours0.0496 days <br />1.191 hours <br />0.00709 weeks <br />0.00163 months <br /> (3430.4 annualized) was expended utilizing resident and region based inspectors.

During the period, NRC team inspections were conducted as follows:

a. Balance of Plant special inspection on the feedwater and condensate systems (Inspection Report 272/87-18, 311/87-20).

b. Appendix 11 R11 Fire Protection Team (Inspection Report 311/87-29).

c. Electric Breaker Coordination Team (Inspection Report 272/87-35, 311/87-35).

Inspection Activities and the distribution of hours are shown in Tables 1 and 2. Enforcement activities are summarized in Table 3.

This report also discusses "Training and Qualification Effec-tiveness" and "Assurance of Quality" as separate functional areas. Although these topics, in themselves, are assessed in the other functional areas through their use as criteria, the two areas provide a synopsis. For example, quality assurance effectiveness has been assessed on a day-to-day basis by resident inspectors and as an integral aspect of specialist inspection. Although quality work is the responsibility of every employee, one of the management tools to measure this effectiveness is the use of quality assurance inspections and

10

• audits. Other major factors that influence quality, such as involvement of first-line supervision, safety committees, and work attitudes, are discussed in each area.

11

c. Facility Performance Analysis Summary Category Category Last Period This Period

• Functional Area 10/1/85-09/30/86 10/1/86-12/31/87 Trend

1. Plant Operations 2 2

2. Chemistry and Radiological Controls 1 2

3. Maintenance 1 1

4. Surveillance 2 2

5. Emergency Preparedness 1 1

6. Security and Safeguards 1 1

7. Refueling, Outage Management 2* 1

8. Engineering Support 2* 2

9. Licensing Activities 2 2

10. Training and Qua 1ifi cat ion Effectiveness 2 2

11. Assurance of Quality 2 1

• These functional areas were combined in the last SALP.

12 D. Unplanned Shutdowns, Plant Trips, and Forced Outages Root Functional Date & Power Level Description Cause Area_

UNIT 1 3/8/87 - 100% The unit was removed from

• Equipment service to replace No, 1 failure/

Auxiliary Power Transformer design Restart: 3/15/87 6/2/87 - 100% Unit trip from trip-a-unit Lightning protection system due to a valid trip sensor actuation.

Restart: 6/4/87 UNIT 2.

12/23/86 - 8% Unit trip on turbine trip Personnel Operations due to loss of turbine error/poor control while reducing judgement main turbine load with the EHC in a degraded operating condition. Failure to maintain turbine load below the low power setpoint Restart: 12/24/86 12/28/86 - 77% Unit trip on No. 23 low Equipment steam generator level due failure/random to a failed shut feed regulation valve. Circuit card in the feed control system fa i1 ed.

Restart: 12/29/86 1/18/87 - 3% Reactor trip on spurious Personnel Maintenance High Neutron flux signal error:

when a technician pulled Training a fuse while trouble- deficiency.

shooting a rod block signal on the intermedi-ate range instrument.

This action was inapprop-riate for the existing plant: condition.

Restart: 1/19/87

13 D. Unplanned Shutdowns, Plant Trips, and forced Outages (Cont.)

Root Functional Date & Power Level Description Cause Area_

3/12/87 - 96% Unit trip on turbine trip Design Engineering due to main generator loss Error Support of field. Excitation metering was insufficient for operation in the over excited condition.

Restart: 3/14/87 4/7/87 - 85% Unit trip on turbine trip Equipment due to loss of DC power failure/random to the .EHC system. EHC circuit card failed.

Restart: 4/17/87 6/25/87 - 62% Controlled shutdown to Equipment investigate high vibration anomaly:

and noise associated with Cause was not

. the main turbine. determined.

Restart: 6/30/87 7/3/87 - 62% Controlled shutdown to Equipment correct main turbine failure/random vibration caused by a gasket failure at the low pressure turbine inlet transition piece.

Restart: 7/13/87 8/6/87 - 100% Unit trip on high steam Personnel Operations generator level in #24 error:

steam generator with Operator the feed system inattention to in manual control. detail.

Restart: 8/7/87

14 D. Unplanned Shutdowns, Plant Trips, and Forced Outages (Cont.)

Root Functional Date & Power Level Description Cause Area 8/7/87 Controlled shutdown due to

• E;qui pment impending failure of a main failure/random output transformer b~cause of insulation breakdown due to aging.

This.outage included the identification and repair of*

1. 5 conoseal leak on the reactor-head.

Restart: 8/27/87 10/24/87 Controlled shutdown due to Inadequate Engineering

• design documentation documentation Support problems related to of design basis.

electric breaker

• coordination.

Restart: 12/17/87 NOTE: The root cause in thi~ Tabl~ is the op1n1on of the SALP Bdard based on the inspector(s) description of the event; and may, in certain instances, differ from the LER.

15 IV. PERFORMANCE ANALYSIS A. Plant Operations (32.3%, 1385 Hours)

1. Analysis Licensee performance in this area was rated as Category 2, and improving at the.end of the previous SALP period. Weaknesses in the last pe~iod included an above average number of reactor trips (18), numerous fire protection deficiencies, and a number of operator errors.

Th~ licensee ~ontinues to have a strong management team committed to plant betterment, and which clearly recognizes safety issues and understands NRC policies and regulations.

There is consistent evidence of prior planning and the assign-ment of priorities by the licensee when dealing with plant

• operations. Rev~ews, decisions and corrective actions are clear, timely and in keeping with NRC and industry standards.

Often the corrective actions for identified concerns such as the RWST resin intrusion, conose~l leak and transformer problems exceed requirements.

Licensee management at the corporate and station levels have been conservative and responsive regarding the operation of the Units. The licensee has shutdown'and cooled down the units on four occasions (listed on pages 6-9) during this assessment period to install, repair or modify systems, and to address safety related problems. Startup following these shutdowns and refueling outages was approved by the .licensee only after all the identified concerns were fully resolved.

During this assessment period the licensee has exhibited their commitment to safety and the regulatory process by their prompt and thorough followup on: strike preparations, identification and followup corrective action on a resin intrusion into the refueling water storage tank, reactor vessel head leaks and the service water flooding event. The professionalism of the operators in the control room has been evident in the conduct of ope\'.'ations. How.ever, during the cpnduct of licensed operator examinations, isolated instances of informality of operations were observed. These instances have included operators leaning against contr61 board rails, control panel indications being obscured by procedures, and operators not wearing personnel monitoring devices as directed by licensee policy. Operator performance during plant trips and abnormal -Operating conditions remains prompt and competent. The housekeeping at the facility has been rated above average by NRC inspectors and management.

16 Licensee weaknesses in this functional area manifest themselves principally in the area o~ personnel error and inattention to detail. Two of seven trips resulted from inadequate operator attention to abnormal operating conditions. Human error was also noted in events related to isolating a component on the wrong unit for maintenance and omission of post mainten~nce testing on a diesel generator prior to its return to service.

This ina~tention to'the operations interface with other departments also resulted in missed su~vefllance tests as described in Section D of this assessment. Also, there-were instances of fire watches not posted and sleeping fire watches identified by the licensee. These problems indicate room for improvement in shift communication, interface with other depart-ments and more consistent attention to detail in operational activities.

The number of reactor trips has been reduced from 18 in the previous SALP peribd to 7 in this assessment period, which ~as three months longer. As a result of the licensee's trip reduction efforts, there was only one trip on*Unit 1 and the remainder were on Unit 2. Four trips were caused by equipment breakdowns~ one as a result of a lightning strike, and two trips were related to human error.

The staffing of the facility remains at a full complement and staff turnover is low. During this assessment period the Vice President of Nuclear was elevated to a Senior Vice President of Nuclear (a new position)* and a new Vice President of Nuclear was hired. The Engineering and Plant Betterment Department was reorganized to provide more responsive support to the plant operating staff. These changes are detailed in Section H of this report. The stability of the staff contributes to the consistency in implementation of operational programs.

The Station Operations Review Committee (SORC) meets frequently but not excessively. The Committee was observed to be thorough and complete with their reviews of safety related issues and their tracking of issues that have not been concluded. The SORC committee reviews and assesses all unit trips and shutdowns for root cause and correction prior to unit restart.

The Nuclear Safety Review (NSR) group which cons~sts of onsite and offsite safety review groups is a full time dedicated organization, consisting of managers and eight full-time engineers. This organization provided effective oversight of the routine activities specified in technical specifications and applicable industry standards. In additi..on, they provided independent assessment to management regarding the causes of significant operational occurrences and the incorrect certification of breaker coordinatio~.

17 In summary, the operations organization is competent, responsive and highly motivated toward safe plant operations.

The licensee has an aggressive approach to resolve problems encountered in the operation of the units. In particular, a strong management team is evident, which fosters a safety conscious attitude and an accountability for performance.

Operator response to events has been good, and trip frequency has decreased. However, human error due to inattention to detail or poor interface communications continues to be a contributor to plant trips and other events. --SORC and the safety review groups continue to be effective.

2. Conclusion Rating: 2 Trend: None

3. Board Recommendation Licensee: None NRC: None

18 B. Chemistry and* Radiological Controls (12.1%, 525 Hours)

1. Analysis This area was rated Category 1 last assessment per*iod. Licensee strengths in the last assessment were noted in a strpng commit-ment to minimize personnel exposures and reduca radwaste volume.

Program improvements were also noted with *renovations to the RCA access control point. This included new computerized access

~ontrols, the installation of sensitive p~rs6hnel friskers to enhance the radioactive material control program, and additional office space for the radiation protection staff .. -Weaknesses in the quality of radiation protection procedures and the need for improvement in the chemistry laboratory QA/QC program were identified.

During this review period, there were eight routine and reactive inspections in the radiological controls area. Routine inspection reviews included organization and staffing, training and qua*lifications, procedures, internal and external exposure cont'."Ols, the ALARA program, radiological and non-radiological chemistry, eff.luent controls and monitoring, and.solid radioactive waste management and transportatiun. One reactive inspection was conducted to review the circumstances of a primary water spill, hot particle contamination, and repetitive defeating of a locked high radiation door. Principal problems identified during this assessment period wher-e failure to adhere to procedures, failure to establish procedures, and failure to maintain positive controls over locked high radiation areas. :

i Weaknesses in the radiation protection procedures, highlighted in the two previous SALPs were not fully resolved in this assess-me~t period, in spite of licensee commitments to complete implementation of the new procedures prior to the beginning of the 1987 refueling outages. Further, problems were again identified both in the radiological and non-radiological chemistry laboratory QA/QC areas. These continued unresolved issues indicate a weakness in licensee.implementation of effective-corrective action to NRC identified weaknesses.

Radiation Protection During this assessment period, the radiation protection organi-zation responsibilities were expanded to include chemistry. The planned change to the organization specifically impacts the technician level, in that, a technician 11 pool 11 will perform both chemistry and health physics functions. This was the status of

19 the radiation protection organization in 1980, during the HP appraisal. A significant appraisal finding was a lack of tech-nical depth within the technician pool for health physics

• activities. The concept of combining HP ~nd chemistry functions was identified as a generic industry weakness which was corrected as a result of the NRC's HP appraisals of 1980. The appraisal cited insufficient time and experience given to HP tasks which were necessary to appreciate -a-nd develop the technical skills necessary to perform in an effective manner.

The licensee's subsequent actions to correct-this deficiency were separation and dedication of technicians to health physics and chemistry.* The proposal of the technician 11 pool 11 suggests a return to a.n organization which has already been shown to be detrimental for effective program performance throughout the industry. The impact of the technician 11 pool 11 on program performance, and the effectiveness of the training and qualifications program to support the 11 pool 11 will be evaluated in the future.

An NRC identified concern for the previous two assessment periods regarding the consolidation, quality and consistency of radiation protection procedures was not resolved during this assessment period. Further, the lack of well established, clearly defined procedures resulted in two examples of failure to adhere to the requirements of existing procedures. There was also one example of failure to establish procedures for the calibration and use of airborne radioactivity monitors. These violations, along with the delay over resolving this issue indicates a weakness in management implementation of effective corrective actions.

• The external exposure control program is well defined and effectively implemented. The scheduling and execution of routine radiation surveys were thorough and well controlled.

Posting of radiologically controlled areas was effective, but there were repetitive instances of personnel defeating locked high radiation area doors. The licensee's initial corrective actions in this case were not effective in identifying and correcting the root cause of this problem. Subsequent actions appear to have been more effective.

The licensee maintains and implements a generally adequate and w~ll defined internal exposure control program. Engineering controls are effectively used to maintain airborne radioactivity levels well below those requiring respiratory protection.

However, violations were identified in the use and calibration of air sampling equipment, proper analytical methods, documenta-tion and adherence to procedural requirements which relate to the status of radiation protec~ion procedures already discussed.

20

• The licensee's ALARA program exhibited effective performance during the current period. Realistic annual and outage exposure goals were developed. A significant scope of work activities was undertaken during the Unit 1 1987 outage, including refueling, 10 year ISI, RTD bypass removal, steam generator activities, reactor coolant pump seal replacements and pressurizer and reactor vessel instrumentation modifications.

Pre-work ALARA planning was initiated early and ALARA reviews were comprehensive and well documented. The licensee used audio and video equipment extensively, for .monitortng work in-high exposure areas, shielding, and mock-up training. Work evolutions and exposure tracking were closely monitored by HP technicians assigned to ~pecific work packages.

Unanticipated work activities, such as the secondary side steam generator 11 J 11 nozzle replacements, conoseal head leak repair, pressurizer .spray va 1ve rep 1acement, and CRD vent fan change-out during 1987 increased the -original 1987 ALARA goal of 560 person-rem by 20%. In spite of this, licensee exposure for this assessment period was 635 person-rem for 1986, and about 675 person-rem for 1987. These exposure values (i.e., 2 units) compare favorably with industry PWR annual averages (approxi-mately 400 person-rem/year/unit).

Radiological Effluent Control and Monitoring Durfng the assessmen£ period, one inspection was conducted in this area. The licensee is implementing an adequate program for liquid and gaseous radioactive effluent control. Radioactive effluent releases were made in accordance with procedures and:

technical specification requirements. Semi-annual Radioactive Effluent Release R~ports were comprehensive. However, licensee responsiveness to concerns identified during an NRC inspection in this area during the previous assessment period, regarding a programmatic upgrade in the radio-chemistry laboratory QA/QC program, indicated a lack of thoroughness and management over-sight .. Improvements in the interlaboratory QC program and laboratory QC procedures were not impiemented from t.he initial commitment date of April 14, 1986 to the time of the inspection, March, 1987. The licensee's commitment to upgrade the electrical power supply to the counting room has similarly been prolonged.

A1so'* the 1ack of management oversight was noted by the fa i 1ure to resolve a licensee audit finding regarding the timeliness of radiochemistry procedure review because of the inability to escalate the audit finding to a management level sufficient for resolution. Within the chemistry organization, positions are identified and responsibilities defined .

21

• In* the area of air cleaning ~ystems testing, weaknesses were identified with respect to the thoroughness of management oversight and QA review. Time spans of eleven months in one instance and one.year in another had elapsed before final management and QA review were completed for the test results, indicating a lack of adequate attention to followup on potential problems.

• No onsite inspections of the licensee's environmental mon1toring program were conducted during this assessment-period. However,

. routine surveillance and event reports were revi~wed. These reviews indicated that a generally effective Radiological Environmental Monitoring Program was conducted by the licensee.

Sampling frequencies, types of measurements, analytical sensi-tivities.and reporting schedules generally complied with technical specification requirements.

Two LERs were submitted in this area during the assessment period. Both were related to technical specification surveillance requirements not being completed within the required time due to personnel error.

Solid Radioactive Waste Management and Transportation During the assessment period, one inspection was conducted in this area. The licensee is implementing an effective program for solid radioactive waste management and transportation. The licensee's organization in this area is defined in position descriptions and responsibilities are clearly delineated. The staff is e~perienced and only minor use is made of consultants to upgrade the computer program used to classify radioactive waste. Licensee response to an NRC identi.fied concern regarding training of all personnel with involvement in the radwaste area was timely and thorough. Both Quality Assurance and Quality Control programs were thoroughly and comprehensively implemented. Procedures and check lists were well defined.

Records were complete, well maintained and available.

Water Chemistry Controls Late in the assessment period, two inspections in the water chemistry controls area were conducted. Twelve out of 45 Brookhaven National Laboratory non-radiological chemistry standard results comparisons were in disagreement. The disagreements were generally due to poor calibration techniques

22 /

and procedures. These weaknesses are sim1lar to those identi-fied in this area during the previous assessment period. This is an indication of a lack of attention to detail, as well as a weakness in management response to NRC 1dentified concerns. In addition, some of the problems were the result of the licensee 1 s re 1i ance upon -contractor support personne 1 in the chemistry area rather th~n in-house staff expertise.

In the area of plant systems, the licensee has implemented a generally adequate water chemistry control program. Weaknesses in control of in-line instrumentation suggest a need for further emphasis in quality control of chemical measurements. Licensee initiated special task forces and contracted vendor audits have identified suggestions for program improvements, indicating licensee site management recognition of the need for improvement in water chemistry controls. Additional corporate support may be warranted to augment site initiatives in this area. Operating procedures were generally conservative, resulting in few corrosion-related problems with primary and secondary water systems.

In summary, the licensee 1 s radiation protection program is generally acceptable. Strong performance continues to be noted in the contra) of personnel exposures through the implementation of an effective ALARA program, and in effluent controls, envi-ronmental monitoring, and solid radioactive waste management and tnansportation. In contrast, weaknesses persist regarding the quality of radiation protection procedures and in the chemistry laboratory QA/QC area .. The licensee 1 s failure to resolve these long standing NRC concerns indicates an inability to focus management attention to affect timely corrective action.

2. Conclusion Rating: 2 Trend: None

3. Board Recommendation Licensee: 1. Provide and complete a schedule of radiation protection program procedure upgrades.

2. Re-evaluate the dual assignment of HP and chemistry technicians in light of HP appraisal findings in this area.

23

• 3. Improve radiological and nonradiological laboratory QA/QC and followup NRC and licensee audit identified weaknesses in these areas.

NRC: None

24

• c. Maintenance

1. Analysis (9.7%, 421 Hours)

The last SALP assessment rated this area a Category 1 and highlighted the new work order control system that had been incorporated into a computer system called the Managed

• Maintenance Information System (MMIS).

During this assessment period, the resident iftSpectors observed maintenance routinely. Two region-based inspections reviewed the maintenance, modification and retest programs, No viola-tions or concerns were identified.

The planning for the maintenance department (mechanical, elec-trical and I&C) is performed by the planning department who also controls the MMIS. After the planning department determines.

when the work orders will be accomplished, a complete *package including parts, proGedures and tag out is turned over to the maintenance department for performance of the maintenance. The planning department, upon completion of the work, then returns the system or systems to operational status. This system tends to eliminate duplication of work orders and ~ives more coordi-nation between departments when performing work on specific systems.

The maintenance department routinely performs the maintenance in a timely, effective manner. Isolated problems have been iden-tified such as, troubleshooting of the EHC system ar.d nuclear.

instrumentation system causing two reactor t~ips, recurrent r packing leakage on feedwater isolation valves, and failure to perform PM 1 s on warehouse stored rotating machinery. The licensee 1 s actions in response to these issues were prompt and effective.

Non-safety related transformer problems were reviewed by region based inspectors during this assessment period. Preventive measures .instituted by the licensee include obtaining equipment for monitoring and tracking transformer oil status. This action is aimed at preventing future occurrences, such as the failure of a Generator Main Transformer at Hope Creek in 1987. The licensee has taken positive steps in designing a continuous monitoring system that will provide a readily available status of transformer parameters. The implementation of these systems will allow the licensee to predict the optimum time for preventive maintenance of the Station and Main Generator Transformers, and will aid in identifying further actions necessary to prevent future transformer failures.

25 The licensee catalogs maintenance work requests into categories depending on parts availability, engineering input, plant conditions, 11 in planning stageu, and 11 scheduled to be worked 11

• The ratio of the number of work orders ready to work in conjunction with the plant conditions in which the work may be performed is manageable (about an eight day b~ck log). Techni ca 1 Specifications and 11 necessary for plant operation 11 work orders are usually perfoY'med within twenty four hours.

• The maintenance department works closely with-the systems

.engineers in identifying and correcting equipment deficiencies*

to return a unit to service, and installing minor design changes. Management encourages problem identification from any source. The identification of calibration deficiencies for lead-lag controllers by training and vendor pe~sonnel, and the prompt corrective measures exemplify licensee performance in this area.

One. inspection reviewed the inservice inspection, water chemistry controls, and radiological records for steam generator No. 13. Water chemistry has been well controlled throughout the life of the plant in order to provide extended life for the steam generators. The effectiveness of these controls is evidenced by the extremely small number of tubes that have required plugging or repair. Steam generator 13 has only 16 tubes that have been plugged. Of these 16, 10 were plugged prior to service as a precaution against erosion. The licensee's preventive actions have resulted in a high level of effectiveness in the area of steam generator maintenance.

The licensee's continued application of a live loaded valve packing program (which is now in effect on most of the valves within both units) is beginning to show positive results on ALARA and plant shutdowns. There are fewer primary *and secondary valve* leaks, and less contaminated leakage in the sumps. The smaller time necessary to repack highly radioactive valves is helping keep radiation doses ALARA.

The 1i censee se 1ected a manager, ma i ntena*nce engineer and a . ~-*

staff engineer, and assignt!d them to a. full time prevenlive ---=-~,..i?.;.:;..

maintenance project for six .months. The team utilized working groups ranging from 6 to 12 people from Vice Presidents down to engineers to develop a program that will ultimately establish a reliability centered maintenance program for Artificial Island.

The program will include predictive maintenance, enhanced preventative maintenance and a more structured root cause analysis feed back irito the maintenance program. The program

• pilot system is scheduled to go into effect in 1988 with full scale development in 1989.

/ 26

• During outages, maintenance related tasks were performed professionally and on time. The maintenance department utilized contract personnel to enhance and expand the maintenance force in order to complete the larger outage workload. Also, the licensee is currently utilizing.individuals from the QC department in the day to day work assignments in the maintenance area. The licensee hopes to make the individual worker and their peers res~onsible for QC of all work performed. The on loan QC personnel is the beginning of the p~o~ram to meet this goal. *

• In summary, the maintenance department management is aggressive and proactive. There is a consistent and structured approach to maintenance, utilizing well written procedures and technical manuals. The department resolves identified problems in a timely manner. The maintenance department is adequately staffed and competently trained.

2. Con~lusion Rating: 1

• 3.

Trend: None Board Recommendation Licensee: None NRC: None

27 D. Surveillance (11.1%, 479 Hours)

1. Analysis During the last assessment period, surveillance was rated a Category 2. There were several missed or late surveillances which were caused by personnel error and lack of attention to detail.

• buring this assessment period, a Containment-Integrated-Leak Rate Test (CILRT) for each Unit was witnessed by NRC specialists.

The resident inspectors reviewed routine surveillance activities regularly.

The test procedure and conduct of the CILRTs were consistent with the requirements specified in the technical specifications and station administrative procedures. The staff assigned to the performance of the tests were experienced in the evolution, uti.lized technically adequate procedures, and were supported by management. Implementation of the procedures was error fr~e, as a result of step-by-step rehearsals prior to each major activity.

QA/QC involvement in these activities was thorough, and included . '

surveillance tours, and the performance of surveillances and '

audits by QC personnel that evidenced a high degree of knowledge in the tests.

During the ass~ssment period, the post modification test program was reviewed noting that test procedures were properly approved, and technically adequate. Post modification testing was observed to be conducted in an orderly fashion by knowledgeabole personnel.

One inspection was directed toward the Cycle 4 Startup Physics Testing Program for Unit 2. This review indicated that the testing program has been implemented in an adequate manner. All surveillance tests and I&C Work Orders that supported the cycle 4 startup were noted to be adequately preplanned and were properly executed. Management involvement in the program*was evidenced by the high quality of the R~fueling Test Sequence Procedure. In addition, test results were noted to have been adequately evaluated and documented.

At Salem surveillances are tracked by computer. The system tracks about 2500 safety related surveillance tests per year, as well as all non safety related surveillances. The program is sound and a written schedule is produced on a daily basis. Some scheduling problems were identified because of the difference in scheduling surveillances during plant shutdowns and outages.

28

• During these periods, the scheduling is manually accomplished by schedulers. The licensee has recognized this problem and is developing a program to account for schedular differences during Unit shutdowns.

During this assessment. period, there were an increased number of personnel .errors related to missed or late surveillances.

Specific examples are: shift supervisors not issuing the*

surveillance packages to be performed, correct surveillance performed but on the wrong unit, engineering~not providing valve numbers for expanded ASME Section XI valve tests, omission of tests on the fuel handling crane, and performance .of an inadequate post test procedure. Although the number of these events (missed or late surveillances) is small in relation to the total number of tests performed yearly, these occurrences have increased during this assessment period. This indicates that corrective measures for previous missed or late surveillances have not been effective and more licensee oversight and attention to detail in the implementation of surveillances is warranted.

The licensee's calibration program for gages and instrumentation was not consistently implemented to assure the accuracy of

• instruments used for plant operation. Technical specification required instrumentation was calibrated and recorded during each surveillance by procedure. Howeve~, in the balance of plant (BOP) there were calibration stickers on some gages and instru-ments and not on others. The inconsistency was confusing to operators and supervisors as to the validity of readings taken from unlabeled gages, and to management and auditors measuring the effectiveness of the calibration program. Toward the endf of this assessment period, the licensee had corrected the method for identifying calibrated gages and instrumentat"ion. Technical specification instruments remain as described above, instruments used,to operate the BOP are now divided into information only instruments and instruments necessary for operation. The instruments necessary for operation are now calibrated on a three or five year cycle depending on their application.

Operators were updated to the new method of calibration being performed.

In summary, no major discrepancies were identified in the sur-veillance area, and there appears to be a sound surveillance program in place. However, implementation problems related to the applicability and support of the surveillance programs are the most frequently identified problems at Salem. These discrepancies identified both by the NRC and the licensee indicate the need for better attention to detail.

29

2. Conclusion Rating: 2 Trend: None

• 3. Board Recommendation Licensee: None NRC: None

30

• E. Emergency Preparedness

1. Analysis (1.1%, 47 Hours)

There is a consolidated Emergency Plan for the Artificial Island complex, including the Salem and Hope Creek facilities. Conse-quently, the assessment of emergency preparedn~ss is a combined evaluation of both facilities' emergency response capabilities.

During the previous* assessment period, the ltcensee was-rated Catego*ry 1 in the area of Emergency Preparedness at Hope Creek and Salem. This assessment was based on strong management commitment to the hardware and programmatic requirements of this functional area, and the performance of the licensee's staff during exerci~es at both Salem and Hope Creek.

During this assessment period, there were three announced inspections ~f Emergency Preparedness at Artificial Island. One inspection was the observation of a Hope Creek full participa-tion exercise. There was no exercise at Salem. In addition, four actual unusual events were declared at Hope Creek and one at Salem. Implementing procedures were correctly followed for all but one of the unusual events. On July 30, 1987, Hope Creek made a one hour notification to the NRC per 50.72(b) instead of declaring an unusual event. The license~ detected the error within sixteen minutes and then declared the unusual event. The Hope Creek Event Classification Guide has been modified to avoid a recurrence of this misclassification.

Observations made during the routine safety inspections at Hope Creek and Salem indicate regulatory requirements were fully satisfied. A drill testing various aspects of the program is conducted at both Salem and Hope Creek on a weekly basis. The high degree of training and experience is reflected in the excellent performance noted during their annual exercise.

Emergency response training is current; 1,450 personnel are qualified fot one or more emergency response positions - 600 for each site and 250 for both sites. Operators received eight hours of emergency preparedness training. including response to one fast breaking scenario 11 run 11 on the Hope Creek simulator. Health Physicists demonstrated the ability to correctly use the four available dose projection systems. A dosimetry comparison was made involving three of the licensee's systems, systems for both States and the NRC. The results were within acceptable limits.

31 A review of communications and call-in test data also showed satisfactory results. Independent audits are current.

Executives and senior managers interface with State government officials. Safety parameter display systems (SPDS) are in place and functional at Hope Creek and Salem, a Post Implementation Appraisal for Salem has been conducted. No significant deficiencies have been identified to date.

PSE&G has put considerable effort. into working with off-site authorities to complete final review and approval of off-site plans. Results of the annual public* Alert and Notification system (sirens, etc.) test specified by FEMA were .submitted during December 1986. FEMA has not completed the review. The Delaware Emergency Plan was given contingent, favorable reviews and comments per 44 CFR 350.12, pending acceptance by FEMA of the siren test data. New Jersey has submitted its plan for similar review. The licensee has developed a computerized data base for special needs residents (hearing and mobility impaired) livin*g within the ten mile Emergency Planning Zone.

Additional licensee strengths in this area are noted as follows:

(1) Contracts are in place to provide for plume aerial surveillance; (2) ten diverse, redundant communfcations systems are in place; and (3) a full-time, 37 person site fire

• department is available for emergency support, with half of them qualified as Emerg_ency Medical Technicians. The staff is divided into shifts and work around-the-clock.

In summary, a strong management commitment to emergency preparedness is evident by the hardware and comprehensive training program achievements in this area, and by licensee cooperation with outside agencies toward approval of State Emergency Plans. Licensee effectiveness is demonstrated by the consistent high quality performance of the staff during emergency exercises.

2. Conclusion Rating: 1 Trend: None

3. Board Recommendations Licensee: None NRC: None

32

• F. Security and Safeguards

1. Analysis (4.3%, 187 Hours)

• There is a consolidated Security Plan for the Artificial Island complex, including the Salem and Hope Creek facilities. Conse-quently, the assessment of security and safeguards is a combined evaluation of both facilities' protection capabilities.

During the previous assessment periods, both-the Salem and Hope Creek security programs were assessed as Category 1. These ratings were influenced by a well-planned transition for the integration of the two security programs; a major upgrade of security systems to include the installation of an integrated security computer system and associated hardware, computerized access control devices, state-of-the-art assessment aids and new search equipment; and a strong security management staff.

Man~gement's attention to, and involvement in, assuring the implementation of an effective and quality security program remained evident during this assessment period. The licensee was very effective in maintaining good support for the security

• program from other functional gro*ups at both stations. Frequent organizational interfaces and good working relationships were apparent from the profe~sional attitude of all employees toward the security program, as well as the attention given by the maintenance groups to prevention and correction of problems with security systems and equipment.

As further evidence of management's interest in an effective and quality program, it was noted that all security shift supervisors, who provide around-the-clock oversight of the contract security force, attended a special 30-day training course on regulatory and security program requirements and objectives. In addition, security management continued to participate in nu cl ear industry groups engaged i.n security related matters.

The licensee also continued to implement a self-initjated appraisal program carried out by security management and supervisory personnel. Adverse findings were promptly resolved and factored into the training and qualification program in an effort to prevent their recurrence. The appraisal program is in addition to the NRC's required annual program audit that is conducted by experienced quality assurance personnel. The last annual audit was comprehensive in both scope and depth. Audit findings were distributed to appropriate management personnel for review, and corrective actions for deficiencies were prompt and effective. This also demonstrates the licensee's desire to implement an effective and quality security program.

33

• During this assessment period, the licensee engaged a new contractor to provide the administration, supervision, and training of the security force. The new contractor was able to retain most of the incumbent members of the force. The change in contractors went smoothly as a result of good planning on the part of the licensee.

Staffing of the security organization appears adequate, as evidenced by a controlled use of overtime. The installation and maintenance of state-of-the-art systems and equipment has significantly reduced the use of compensatory posts for systems and equipment failures and, thus, reduced the need for extensive overtime. Both the licensee's proprietary supervisors and the 1

co~tractor s supervisors are well trained and experienced, and exhibit a conservative and positive attitude toward security.

Security force personnel are also well-trained and exhibit high morale and professionalism in carrying out their duties. The licensee's efforts to establish and maintain such a professional image for the security force is another indicator of the licen-see's desire to implement an effective and quality security

• program. It is also reflected by the generally excellent state of cleanliness in all security facilities . . .

• The training and requalification program is well developed and

~arried out by a training administrator and two full-time instructors. In addition to initial and requalification train-ing, on-the-job performance evaluations are conducted which test the proficiency of individuals on general and specific security program requirements. The on-the-job performance evaluations.

have provided management the ability to review and enhance the performance and job knowledge of security personnel and to correct deficiencies as they are detected. This is another initiative that is indicative of the licensee's desire to implement an effective program.

During the assessment period, there were two events involving security guards who were discovered being unattentive to duties.

One (at Hope Creek) was discovered by the NRC Resident Inspector and the licensee was cited for the violation. The other (at Salem) security guard was discovered by the on duty security shift supervisor.

In each case, the licensee took prompt and effective corrective action. The associated security event reports submitted by the licensee pursuant to 10 CFR 73.7lc were complete and well writteni and required no further information from the licensee.

These events appear to be isolated cases of poor performance and do not indicate a programmatic problem. They occurred during the latter part of the assessment period and.until that time,

34 the licensee's overall good enforcement record during this period is attributed to management's involvement in the security program, the continuing self-appraisal program, comprehensive annual audits and the security training program.

During this assessment period, the licensee submitted three "temporary clianges 11 to the Plans. These changes included compensatory measures to be implemented during construction of a building addition inside the protected area and during the special ~upervisory training program. The changes were-clear and fully described the issues. Prior to submittal of these changes, the licensee discussed them with Region I safeguards personnel at a licensee-requested meeting on site and at the Region I office. The licensee also provided its response to the August 4, 1986 Miscellaneous Amendments to 10 CFR 73.55 codified by the NRC, and submitted the consolidations of the Salem and Hope Creek _Security Plans, Safeguards Contingency Plans, and Training and Qualification Plans into the Artificial _Island Secµrity Plan, Safeguards Contingency Plan, and Training and Qualification Plan.* The Artificial Island Plans were generally of high quality; however, several discrepancies were identified during the NRC review. A management meeting was held with the licensee during. which the licensee was able to fully explain each discrepancy _and provide acceptable resolutions. The licensee subsequently submitted amendments to the plans that resolved the discrepancies. Considering the magnitude of the effort involved in consolidating the Salem and Hope Creek plans into one, the discrepancies were considered by the NRC to be minor oversights that did. not materially effect the quality of the Artificial Island Plans. The safeguards licensing group ~s adequately staffed with experienced personnel who are knowledge-able of NRC security program objectives and committed to main-taining an effective and high quality security program. Management involvement, advance planning, and the expenditure of necessary capital and personnel resources was noteworthy and indicative of high level management support.

In summary, the licensee continued to implement a highly effective and quality .security program for Artificial Island.

Management interest in the program remained evident through its continued support and attention to program needs.

2. Conclusion Rating: I Trend: None

35

• 3. Board Recommendations Licensee: None NRC: None

-36 G. Refueling, Outage Management ( 7. 4%, 322 Hours)

1. Analysis The last SALP rated outages and engineering support as Category

2. With regard to outages, the assessment addressed generally effective outage planning, over~ight and im~lementation. The newly organized planning department was highlighted as an unproven refueling outage initiative.

During this assessment period there were two ~efueling outages and four plant shutdowns as discussed in Section III.B of this report.

Within the plarining department there are groups of personnel dedicated to outage planning as well as daily operational maintenance planning. The outage planners dedicated to either Unit 1 or 2 (2 groups) maintain a living schedule, which is computerized. When outages are forthcoming, little notice is required to have a comprehensive schedule ready for work to be performed. The management within this organization is aggressive in the planning of outages and the work planned is generally

• completed on time. The four outages, one on Unit 1 and three on Unit 2 were performed on schedule and the Units were returned to service within a day of the scheduled time, with all planned work and in some cases additional work being performed.

Management has not hesitated in removing the* Units from service and cooling them down, if necessary, in order to facilitate repairs in the interest of personnel and nuclear safety.

f Refueling outages are also preplanned. Design changes for the outage are identified far enough in advance that the design packages are deli~ered to prospective contractors for fixed price bidding in advance of the start of the outage. Management meetings, held three times daily during outages, address the issues and problem areas squarely, and determine responsible management to resolve the issues in a timely fashion. No instances were identified any area where safety was compromised for timel~ completion of a job or project.

When the refueling outages have been prolonged, the reasons were usually unplanned factors that were identified as the outage progressed. When confronted with a contingency, the scheduling department was aggressive in factoring the newly identified work into the schedule. Examples of this are: (1) Identification, during routine steam generator inspections, that the 11 J 11 tube feed nozzles were degraded to an unacceptable level. The result was replacement of all 11 J 11 tubes in all steam generators;

37 /

(2) flooding of the service water bay; (3) identification of cracks in the spare control rod drive mechanism penetrations; and (4) identification of degradation in the welds of the service water system inside containment, which resulted in all service water piping welds within the containment being examined and the .necessary repairs being performed.

The planning department expanded their department to i"nclude an operations group that reviews, scheduies and performs tag outs of equipment. This evolution is performed ;~-the annex -just outside of the control room. The group keeps the operations department informed of the work to be performed that day, either during an outage or when the unit is operating, by direct involvement with the operating shift. This arrangement reduces the traffic in the control room, thus minimizing disruptions in control room activities.

In summary, management and the planning department are aggres-sive in preplanning outages. During outages, they are equally aggressive in seeing that work is performed satisfactorily, on schedule and without impacting personnel safety or nuclear

$a.fety.

2. Conclusion Rating: 1 Trend: None

3. Board Recommendation Licensee: None NRC: None

38 H. Engineering Support* (22.0%, 922 Hours)

1. Analysis The last SALP assessment rated the combined outages and engi-neering support area as Category 2. That assessmen*t discussed the organizational weaknesses within the Engineering Department, as well as specific areas (10-CFR 50.59 reviews and environmen-tal qualification) where engineering support had bee~ weak. The last SALP also ~escribed new licensee initiafives planned to address these weaknesses.

The onsite system engineering group is directly involved in the day to day operation of the facility and are engineers that have complete cognizance of a particular assigned system or systems.

Whenever there is an identified concern within the facility, the engineer assigned to the faulted system is alerted. These engineers are extremely knowledgeable of their assigned systems and have demonstrated.this through clear identification of root causes for; 1) Unit trips, 2) chemistry anomalies, especially oxygen in the condensate system) and 3) system malfunctions.

When design changes are instituted such as, the installation of new undervoltage relays which involved a technical specification

• change and the upgrading of procedures, the system engineer conducted training sessions for operators and I&C technicians to explain the changes. The engineers have also provided safety analyses and engineering evaluations for plant malfunctions such as, the resin that was found in the refueling water storage tank, and the reactor head penetration leak on Unit 2. These/

evaluations were concise, thorough and technically sound:

The nuclear fuel engineering support provided for plant oper-ations- is timely, technically sound, and includes independent.

verifications for the assurance of quality. Procedures are technically adequate, and management support is evident by the quality of personnel and the level of staffing. Another positive indicator in this area is the willingness of management

- to provide technical assistance for audits of fuel vendors.

The syitems engineers and their management have provided assessments and information for NRC regulatory issues. These responses have been timely, thorough and have provided information in excess of what was requested. The inspectors were able to assess and close out regulatory issues with confidence that the safety issues were thoroughly addressed .

39

• One incident occurred, where a steam generator (SG) was not fully drained which caused a reactor coolant spill when the SG was opened. The cause was attributed to changes made with regard to the operation of the Residual Heat Removal (RHR) System during a drained condition. To protect the RHR pump from vortexing, a higher minimum reactor vessel level was specified. However, engineers failed to recognize that the new high level specifi-cation. would not allow the reactor coolant system loops to fully drain. Following the spill, the licensee's actions to correct the anomaly were prompt and effective.

In previous SALPs the off-site engineering department has been identified as having weaknesses in design review interfaces, procedural development and the adequacy of the technical review process. These weaknesses continued to be identified, but to a lesser extent during this assessment period. The implementation of site-based system engineers has improved the responsiveness to operational concerns, but interface problems with the offsite design organizations are still evident. Other NRC findings in this area were largely the result of the previous practices and do not necessarily reflect the current organization. Never-theless, for illustration these types of findings are discussed in the next two paragraphs.

Review of the approach and criteria for design and evaluation of piping and support systems revealed several technical con-siderations which were either ignored or poorly addressed in the governing design documents. This conclusion is further supported by the lack cf d2:~~2ntation of piping stress analyses. Th2 identification of an error in a contractor's technical report/

for U-bolt piping anchor assemblies and several concerns related to !SI of these anchor assemblies supports the conclusion of technical inadequacies in the mechanical engineering organization.

Though the licensee agreed to address these concerns, it was apparent that past reviews and approvals of documents and pro-cedures in these areas were lacking in depth and technical adequacy.

Weaknesses in management's effectiveness were also noted in the review of design interfaces during the process of design modification. Though the topic of interface between various engineering disciplines was included in the procedures for design modification, this guidance was vague and ineffective.

Two modifications initiated by the mechanical group, and involving the addition of load attachments to a building structure were completed without the interface or knowledge of the Civil/Structural discipline. These findings led to several problems and indicated that a programmatic weakness existed

40 in the design interface area. The engineering department also failed to provide valve number changes for Section XI code modifications resulting in a missed surveillance.

Significant deficiencies were identified by NRC and the licensee in the implementation of Appendix R fire protection requirements

~t Unit 2. These problems include lack of separation and protection for redundant systems needed for safe 'shutdown of the plant, and inadequate breaker coordination for associated electrical circuits. Potential violations are pending in these matters. The importance of these fire protection issues is emphasized because similar problems were identified at Unit 1 in 1983, The licensee hired a consultant to review the fire protection program well after the date when compliance* was required. Some of the deficiencies were identified by the licensee and reported to NRC prior to our inspection. Other problems such as the breaker coordination issue had not been focused on by licensee management. Compensatory measures were implemented by the licensee upon identification of individual problems. The tardiness of licensee verification of satisfactory fire protection measures and the unfamiliarity of licensee personnel with the requirements in this area indicated a lack of management emphasis and attention in the fire protection area.

Following NRC review of this area, the licensee reviewed the details of the identified problem areas. In most cases, accept-able compensatory measures were identified to justify continued operation of the facilities until modifications could be implemented.

However, uncertainties regarding electric breaker coordination result2d in the: voluntai'y shut.down of Unit 2 pending verification of as-built and design parameters, and modifications to sever~l breaker coordination relays. These actions were completed on both units and verified by NRC prior to plant restart.

In a letter to the NRC, the licensee made an tncorrect statement regarding the existence of electric breaker coordination. The NRC and the licensee performed special investigations which identified informality in communication between staff and management personnel, inadequate measures for defjciency repo_rting within the engineering organization, and inadequate management of commitment tracking as causes for the mis-statement. This is another example of inadequate interface and communications between organizations and departments. Licensee management is presently implementing corrective actions for these concerns.

/ 41

• • During this assessment period a wrong assumption led to a delay in placing the fuel back into the vessel after the thermo-couple guide tube modification had been performed. The engi-neering department took advantage of a shutdown on Unit 2 to take measurements for the modification and assumed that the measurements on Unit 1 were the same. The result was some of the guide tubes were too long to allow the fuel to rest firmly on the core support plate. The licensee performed an investigation into the reason for the interference and identified the problem. The licensee has take-n correcti-ve measures to prevent recurrence.

At the end of this SALP period, the licensee implemented further reorganization within the Engineering and Plant Betterment Department to institutionalize a project matrix organization which successfully handled service water, and electrical system problem recovery projects. The new matrix organization also managed the Design Modification Packages (DCPs) for Units 1 and 2 for the "Second Level of Undervoltage Protection for the Vital Bus 11 system which were well defined. The engineering study and calculations that established these modifications were complex, and required extensive calculations from the system to the component level. During the review of the DCPs, it was clear that Quality Control played an important role in verifying that installation and test results reflected the requirements in the DCPs. A review of engineering documentation indicated that the reports were detailed, and considered parameters such as cable and transformer losses that were not part of the original study.

All aspects cf the program were well controlled and documented.

A review of as-built drawings verified that the drawings reflected the present configuration of the plant undervoltage installation. An additional inspection found modification packages for the Unit 1 outage to be accurate, well organized and complete, with QA/QC involvement characterized by appropri-ate hold points and well defined acc~ptance criteria.

In September of 1987, the NRC became aware of a potential problem with breaker coordination at the Salem Units. In October of 1987, the licensee determined that the degree of breaker coordination for the electrical distributiori system affecting safety related equipment was not sufficiently established and documented to warrant continued operation of Unit 2. Site management subsequently shut down Unit 2.

Results of the NRC review of the breaker coordination issue indicated that the cause of the problem was primarily the inadequate maintenance of design basis documents for the units .

The licensee's corrective actions were sufficiently comprehensive to address the problem. In particular, the

42 licensee 1 s review included not only safety related circuit breakers, but also the potential impact of breaker coordination for non-safety related circuits. The licensee 1 s technical reviews were generally thorough and based on sound technical judgement. In addition, site staff's responses to NRC questions resulted in a satisfactory resolution for each of the problems identified. The licensee has also initiated efforts to improve the quality and retrieval capability for design basis documents.

In conclusion, NRC inspections identified mari~gement support and overall quality in the engineering and technical support areas.

NRC review of site events and breaker coordination problems indicate that site management responded in a thordugh and effective manner. Continued deficiencies in the fire protection program indicate that further attention to this area is warranted.

Long standing design basis problems and interface issues with operations and the off-site engineering organization are being addressed by ongoing long term corrective action programs. The eff~ctiveness of these initiatives will be assessed by future NRC review.

2. Conclusion Rating: 2 Trend: None

3. Board Recommendation Licensee: None NRC: None

43

• I. Licensing Activities

1. Analysis During the previous SALP period, the licensee was rated as Category 2 with a consistent trend in this functional area. The previous SALP report noted good management overview in the area as evidenced by timely submittals, when changes to the technical specifications were needed to coalesce with the units* operations.

The previous SALP also noted certain weaknesses in the quality of the technical justifications for licensing actions that were submitted.

At the beginning of the current SALP period, the licensing backlog for Salem, Units 1 and 2 were 44 and 45, respectively.

These items represented a mixture of licensee and NRC staff initiatives. During the SALP period, 16 licensing items were completed for Unit 1 and 13 for Unit 2. Nine new items were added for Unit 1 and 10 for Unit 2. This left a backlog of 37 items for Unit 1 and 42 items for Unit 2 at the end of the SALP period.

The licensee 1 s activities in this functional area are conducted by a well trained group, generally efficient in operation. The licensing group exhibited a high degree of cooperation with the NRC. The good communications between the licensing group and the NRC has been helpful in processing licensing actions.

The licensee continues to be active in industry groups, most notably the Westinghouse Owners Group.

With regard to NRC initiatives, the licensee 1 s responses to NRC 1 s requests for additional information have generally been responsive and technically accurate, though sometimes not timely with respect to the need for completing the review. During the current SALP period, the NRC initiated its Safety Issues Management System to improve its tracking of implementation schedules associated with safety issues. The licensee was responsive to this initiative and provided updated information on two occasions, the most recent in September, 1987.

During the current SALP period, the licensee 1 s effectiveness relating to licensing activities appeared to decline. Weak-nesses were noted in schedular planning which resulted in late licensee submittals and responses. As an example, in mid-May the licensee submitted a proposed change requesting replacement of the existing RTD by-pass system with a newly designed system.

The request should have been submitted in February or March 1987.*

Very early discussion between the licensee and the NRC had

44

• made the licensee aware that NRC review would be lengthy (6 months) because of the complexity of the issue. The licensee intended to implement the modification on Unit 1 during the next refueling outage scheduled late in September 1987. As a result of the late submittal, an expedited NRC review was necessary in order for the amendment to be issued in November, barely in time to permit implementation of the new design on Unit 1.

Other ~xamples of submittals which were not tendered in a timely manner included the second 10-year interval ISI program and corrected analyses in support of Appendix R ~xemptions. - Increased licensee emphasis on planning and completing license action mile-stones appears to be needed to improve performance in this area.

Other than the shortcomings with the timeliness of some submittals, the licensee maintains .good technical capability to resolve the problem areas which arise during the NRC review process. In addition, the licensee utilizes the services of other outside nuclear support groups who may be required to assist in problem resolution or to utilize new and proven techniques to enhance the operation and safety of the plant.

In summary, the licensee continues to provide excellent *

• cooperation with the NRC and maintains a knowledgeable licensing staff. License change requests are prioritized so that license amendments may be processed and issued on dates that coalesce with the plants' operational schedules. This process has been generally successful; the exceptions usually resulted from a lack of effective planning. Licensee submittals during the SALP period exhibited improved technical justifications.

2. Conclusion Rating: 2 Trend: None

3. Board Recommendation Licensee: None NRC: None

/

45

• J. Training and Qualification Effectiveness

1. Analysis This area was rated.Category 2 in the last SALP assessment. A strong commitment to training was noted with weaknesses identified in the success of initial license candidates; and, inadequate training leading to sev~ral reactor trips.

During this assessment period, management involvement and control in assuring a high quality of' training continued, as evidenced by improvements in the Nuclear Training *Department laboratories such as, the addition of Nuclear Instrumentation and rod control unit facilities to be used for maintenance training; and offering six month System Engineer's training courses to QA personnel.

A common weakness which was noted in many functional areas involves attention to detail by licensee employees. The .

increasing proportion of personnel errors is indicative of a need to improve awareness and performance in this area. In addition, one plant trip was related to inadequate technician training. Overall, however, th~ satisfactory completion of the majority of activities conducted onsite reflects positively on the quality of the INPO accredited training progr~ms. In particular, the strong licensee performance in the maintenance, emergency planning and security areas was due, in part, to the training and qualification effectiveness in these areas.

The QA/QC involvement with the non-licensed training program is characterized by thorough and comprehensive audits. These audits routinely address the qualifications and training of non-licensed personnel and timely corrective actions for those activities which are not adequate.

Three operator licensing examinations were administered during the reporting period. One reactor operator candidate and eight senior reactor operator candidates were examined; seven of these candidates received their license. During the simulator portion of initial licensing examinations, it was observed that the operators were generally familiar with their responsibilities; and with the required actions during emergencies, both indivi-dually and as a team. The operator candidates also demonstrated a familiarity with the use of EOPs, specifically in the application of prerequisites, precautions, initial conditions and transitions.

The February 1987 examination resulted in a concern directed toward the level of training received by operators regarding the differences between the Unit 1 and Unit 2 Technical Specifications (T.S.). Insufficient understanding of these differences led to an unsatisfactory ~ating for an individual being examined for Unit 2. The lack of understanding by this candidate and other operators in the control room indicates that

46

• other licensed personnel may need additional training on the unique requirements of the Unit 2 Technical Specifications.

The NRC administered requalification written and operating examinations to seven senior reactor operators (SROs) and.five reactor operators (ROs) in June 1987. Two SROs and three ROs passed all portions of the examinations. The requalification

.program evaluation resulted in an unsatisfactory rating for the program. This determination was based on the low pass rate of operators being administered the exams. Som~-of the areas of weakness identified during the review consisted of: operator informality during the simulator scenarios which was demonstrated in several ways, among them, lack of supervision during certain safety significant evolutions including bistable tripping; and the performance of a procedure out of sequence.

In addition, several operators demonstrated a lack of knowledge of radiation monitoring equipment, and an inability to operate the Unit 2 Radiation Monitoring System computer.

In response to the unsat.i sfactory rating of the re qua 1ifi cation program, site management organized an Examtnat~on Review Team to determine the root cause of the examination failures. Short and long term corrective actions were devised by the licensee, and included in part: remedial tr~ining and reexamination, Operations Directive revisions that standardize the use of procedures, an increased emphasis on the understanding of the bases for procedural steps, incorporation into the requalification program of specific topics that require further training, and increased management attention toward simulator training and control room conduct.

Overall, training programs are characterized by a strong commit-ment and responsiveness to the needs of site personnel. Security, maintenance and emergency training were noted as particularly effective. However, some general weaknesses were identified in the effectiveness of training programs as indicated by the licensee operator requalification program results; operator informality; and the overall training program effectiveness in reducing the frequency of personnel errors.

2. Conclusion Rating: 2 Trend: None

3. Board Recommendation Licensee: None NRC: None

47

• K. Assurance of Quality

1. Analysis Assurance of Quality is a summary assessment of management oversight and effectiveness in implementation of the quality assurance program, and administrative controls affecting quality.

Activities affecting the assurance of quality as they apply specifically to a functional area are addressed under each of the separate functional areas. Consequently;-this functional area is not an assessment of the quality assurance department alone, but is an overall evaluation of the effectiveness of management's initiatives, programs, and policies which affect* or assure quality.

Corporate and station managers remain visible and actively involved in station activities commensurate with their level of responsibility. Station management meets daily to discuss the problem areas within the plant. These meetings are also attended by corporate managers on occasion. Operational direction and day to day operational activities are the outcome of these meetings. Corporate and station management make plant walkthroughs frequently and are sensitive to plant cleanliness and safety. Management is sensitive to safety issues, and NRC and INPO identified concerns.

The licensee stresses doing jobs correctly the first time and first line supervisors are frequently found at the job site. To emphasize and assess ti1.:: iiiip~.::,;1cr1ta.ti0n of this philosophy thi;:

licensee uses the following: Banners, signs, and slogans are displayed throughout the plant that address management's approach to Assurance of Quality. These signs are updated frequently with different QA/QC type messages. Quality control personnel have been assigned to the maintenance department to oversee quality assurance on a day to day basis. These assigned individuals are independent of maint~nance, however they do assessments and evaluations to improve or enhance maintenance activities. The Employee Involvement Program (EIP) instituted last year is still in full force at the station. This is a program that facilitates management/worker interfaces and rewards*

good performance. There is also a Quality Awareness Committee comprised of nuclear department volunteers who periodically issue a "Quality Gram 11 to promote improvements in quality performance, and finally a Quality Concerns Reporting Program

• that enables plant personnel to confidentially express quality concerns to be investigated by licensee QA personnel. The above programs are generally effective, however, the large proportion

48

• of personnel error related events identified by the licensee points to weakness in the attention to detail at the worker and first line supervisory levels.

There were two region based inspections performed within the QA/QC organization. Warehouse storage conditions, records of item locations, and original equipment manufacturer (OEM) storage requirements were observed to be adequate. The identification by NRC personnel of incomplete preventive maintenance for various motors in storage foe-used add it i.ona l licensee attention toward the preventive maintenance of these items. The licensee acknowledged this problem, and has established a Site Service Group to develop a program to streamline the processing of documents necessary for the performance of preventive maintenance activities for stored components.

The Nuclear QA Audit Group is well organized and managed: The licensee utilizes the Offsite Safety Review Committee and consultants as a team approach to review the site audit program on a regular basis. These reviews are effective in identifying quality concerns as evidenced by in-depth and comprehensive annual reports issued by the teams. The QA organization performs quarterly surveillance overviews on all plant departments which provide plant management with a useful assessment of the department performance. These overviews are keyed to SALP identified or INPO identified concerns .. QA also monitors contractor activities during outages, and has issued work stoppages when working conditions have become degraded.

These are considered strengths, however weaknesses were identified in 10 CFR Appendix B violations, mainly in the engineering of certain systems discussed in the engineering section of this report, and the wrong gasket used when replacing a hand hole gasket on No. 23 steam generator. Both of these issues have been resolved.

As discussed in the chemistry and radiological controls analysis, weaknesses were observed in the control of radio-chemistry J~q~atory QA/QC program and should be addressed.

-- - - -:-~rP~~ .

As discussed in the engineering section, design basis retention and document control has been a main contributor to NRC concerns during this assessment period; specifically with regard to breaker coordination, followup on hangers installed in the 1979 and 1980 period, concrete walls and improper breaker settings of Unit 2 diesel generators. The licensee _is aware of this issue and is beginning to address the methods for recovery of such

• records in the future.

49

• In summary, the sensitivity to Assurance of Quality is evident at all worker levels and throughout management at the Salem.

Station. When safety issues are identified the licensee responds in a prompt thorough and effective manner in order to

. provide NRC management with an accurate assessment of the concern, and a prompt conservative approach to resolution.

2. Conclusion Rating: 1 Trend: None

3. Board Recommendation Licensee: None NRC: None

50 V. SUPPORTING DATA AND

SUMMARY

A. Investigations and Allegations Review Six allegations were received, followed up and closed during this assessment period. The allegations involved: (1) contractor labor supervisor extorting money from laborers and using illegal drugs; (2)

Inadequate repai~ of service water piping; (3) Improper use of weld overlay and procedures; (4) Improper surveillance testing of service water pumps; (5) Guards being overworked; and (6)-Equipment damaged to discredit contractors and get them removed from the site.

All six allegations were found to be unsubstantiated.

B. Escalated Enforcement Actions

1. Civil Penalties None

2. Ord~rs None

3. Confirmatory Action Letters None C. Management Conferences I

November 11, 1986 - Meeting in Region I office to discuss licensee' 1 s corrective actions taken to prevent events similar to the false loss of offsite power event that occurred on August 26, 1986.

February 24, March 10, and March 17, 1987 - Meetings at Salem to discuss the Salem electrical distribution system.

July 16; 1987 - Meeting in Region I office to discuss the

~onsolidated Artificial Island Emergency Plan.

September 29, 1987 - Meeting in Region I to discuss Unit 2 reactor vessel head leak and proposed schedule for replacement of service water piping.

November 3, 1987 - Meeting in Region I to discuss the electrical distribution system and breaker coordination as related to Appendix 11R11

• 51 D. Licensee Event Reports Forty-five LERs were submitted by the two Salem units during this period. The LERs are listed in Table 4. The causal analyses of the LERs are as follows: (1) Eighteen LERs were attributed to personnel error (three plant trips); (2) Twelve LERs were a result of licensee identified plant conditions discovered during plant walkdowns and

~nginee~ing evaluations; (3) Six LERs were attributed to procedural errors and were a product of omission of key information necessary to perform the operations for which they were written-(one plant trip);

(4) Five LERs were attributed to equipment failure (two plant trips).

52 Table 1 INSPECTION REPORT ACTIVITIES REPORT NUMBERS TYPE TOTAL INSPECTION DATES INSPECTION HOURS DESCRIPTION 86-28 86-28 RESIDENT 94 ROUTINE RESIDENT INSPECTION 10/01/86 10/27/86 86-30 86-32 SPECIALIST 44 INSPECTION OF CONTINGENCY PLAN EVENTS AND 10/15/86 10/16/86 GUIDANCE FOR OPERATIONAL INTERFACES 86-31 86-34 RESIDENT 131 ROUTINE RESIDENT INSPECTION 10/28/86 11/24/86 86-32 86-36 RESIDENT 155 ROUTINE RESIDENT INSPECTION 11/25/86 12/31/86 86 ... 33 SPECIALIST 33 INSPECTION OF THE RADIOLOGICAL SAFETY 11/04/86 11/07/86 PROGRAM 86-35 SPECIALIST 73 INSPECTIO~ OF TEST WITNESSING AND 11/19/86 11/27 /86 PRELIMINARY EVALUATION OF CONTAINMENT INTEGRATED LEAK RATE TEST AND TOURS OF THE FACILITY 87-01 87-01 RESIDENT 106 ROUTINE RESIDENT INSPECTION 01/01/87 01/26/87 87-02 87-02 SPECIALIST 47 INSPECTION OF LICENSEE ACTIVITIES IN 01/12/87 01/16/87 RESPONSE TO OPEN ITEMS RELATING TO IE BULLETINS 79-02 AND 79-14 87-03 87-04 RESIDENT 130 ROUTINE RESIDENT INSPECTION 01/27/87 02/23/87 87-03 RESIDENT 24 SPECIAL INSPECTION OF OPERATION OUTSIDE 01/12/87 01/23/87 THE DESIGN BASIS ANALYSIS AS DESCRIBED IN IE INFORMATION NOTICE 87-01 87-04 87-10 SPECIALIST 34 INSPECTION OF THE LICENSEE 1 S RADIOLOGICAL 03/16/87 03/20/87 EFFLUENTS CONTROL PROGRAM 87-05 SPECIALIST 31 CYCLE 4 STARTUP PHYSICS TESTING PROGRAM 02/03/87 02/06/87

• 87-05 87-07 SPECIALIST 02/24/87 02/27/87 36 ROUTINE INSPECTION OF THE RADIATION PROTECTION PROGRAM

53 Table 1 (cont.)

INSPECTION REPORT ACTIVITIES REPORT NUMBERS . TYPE TOTAL INSPECTION DATES INSPECTION - HOURS

- DESCRIPTION 87-06" 87-11 RESIDENT 89 ROUTINE RESIDENT INSPECTION 03/24/87 04/20/87 87-07 87-08 RESIDENT 140 ROUTINE RESIDENT INSPECTION 02/24/87 03/23/87 87-08 87-09 SPECIALIST 110 INSPECTION OF LICENSEE'S ENGINEERING 04/07/87 04/10/87 OFFICE AND SALEM 1 AND 2 PLANT SITES 87-09 87-12 SPECIALIST 42 ROUTINE INSPECTION OF THE LICENSEE'S 04/13/87 04/16/87 EMERGENCY PREPAREDNESS PROGRAM CONDUCTED APRIL 13-16, 1987 87-10 87-13 SPECIALIST 39 INSPECTION OF STAFF TRAINING AND LICENSEE 04/16/87 04/16/87 ACTION ON PREVIOUS INSPECTION FINDINGS 87-11 87-14 SPECIALIST 17 EFFECTIVENESS OF QUALITY CONTROL &

04/15/87 04/20/87 QUALITY ASSURANCE ACTIVITIES IN PROCUREMENT & PREVENTATIVE MAINTENANCE FOR STORED ITEMS 87-12 87-15 RESIDENT . 190 ROUTINE RESIDENT INSPECTION 04/21/87 05/18/87 87-13 87-16 SPECIALIST 88 NUCLEAR ENGINEERING INCLUDING IN-PLANT 05/18/87 05/22/87 REACTOR ENGINEERING AND, QA/QC INTERFACES, INVOLVEMENT AND OVERVIEW 87-14 87-17 SPECIALIST 62 ROUTINE PHYSICAL SECURITY INSPECTION 05/18/87 05/21/87 87 87-18 RESIDENT 112 ROUTINE RESIDENT INSPECTION 05/19/87 06/15/87 87-16 87-19 SPECIALIST 33 INSPECTION OF LICENSEE'S ANALYSIS, VITAL 06/01/87 06/05/87 BUS RECORD LEVEL PROTECTION SYSTEMS, QA INTERFACE, SURVEILLANCE PROCEDURES &

ELECTRICAL DISTRIBUTION SYSTEM 87-17 CANCELLED

• 87-18 87-20 *RESIDENT 06/15/87 06/19/87 192 SPECIAL TEAM INSPECTION ON FEEDWATER AND CONDENSATE SYSTEMS

54 Table 1 (cont.)

INSPECTION REPORT ACTIVITIES REPORT NUMBERS TYPE TOTAL INSPECTION DATES INSPECTION - HOURS

- DESCRIPTION 87-19 87-21. RESIDENT 138 ROUTINE RESIDENT INSPECT!ON 06/16/87 07/20/87 87-20 87-22 SPECIALIST 34 INSPECTION OF LICENSEE'S RADIOACTIVE 06/29/87 07/02/87 WASTE PREPARATION, PACKAGING AND SHIPPING PROGRAM 87-21 87-26 SPECIALIST 0 OPERATORS EXAMINATIONS GIVEN 06/15/87 06/19/87

. 87-22 87-23 SPECIALIST 5 A MEETING BETWEEN PSE&G AND- NRC REGION I 07/16/87 07/16/87 . TO DISCUSS CONSOLIDATED EMERGENCY PLAN 87-23 87-24 SPECIALIST 76 INSPECTION OF THE LICENSEE'S RADIATION 07127/87 07/31/87 PROTECTION PROGRAM 87-24 87-25 RESIDENT 223 ROUTINE RESIDENT INSPECTION 07/21/87 08/24/87 87-25 87-27 RESIDENT 204 ROUTINE RESIDENT INSPECTION 08/25/87 09/28/87 87-26 SPECIALIST 0 WRITTEN AND OPERATING EXAMINATIONS 09/15/87 09/17/87 ADMINISTERED TO FOUR SENIOR REACTOR OPERATOR CANDIDATES 87-27 SPECIALIST 38 POST MODIFICATION TEST PROGRAM FOR 09/21/87 09/25/87 REFUELING OUTAGE 87-28 87-30 RESIDENT 226 ROUTINE RESIDENT INSPECTION 09/29/87 11/02/87 87-29 SPECIALIST 37 STEAM GENERATOR INSERVICE INSPECTION 10/26/87 10/30/87 87-29 SPECIALIST 258 FIRE PROTECTION/APPENDIX 11 R11 09/14/87 09/18/87 87-30 87-31 SPECIALIST 107 INSPECTION OF RADIOLOGICAL CONTROLS 10/19/87 10/23/87 P~OGRAM

• 87-:31 87-32 SPECIALIST 10/26/87 10/30/87 115 INSPECTION OF LICENSEE'S ACTIONS ON PREVIOUS NRC FINDINGS

55 Table 1 (cont.)

INSPECTION REPORT ACTIVITIES REPORT NUMBERS TYPE TOTAL INSPECTION DATES INSPECTION HOURS DESCRIPTION 87-32 87-33 RESIDENT 183 ROUTINE RESIDENT INSPECTION 11/03/87 11/30/87 87-33 87-34 SPECIALIST 68 INSPECTION OF THE NON RADIOLOGICAL 11/16/87 11/20/87 CHEMISTRY PROGRAM 87-34 SPECIALIST 38 OUTAGE MODIFICATIONS FOLLOWUP 11/16/87 11/20/87 87-35 87-35 SPECIALIST 320 FOLLOWUP ON APPENDIX 11 R11 BREAKER 11/30/87 12/04/87 COORDINATION ISSUE 87-36 87-36 RESIDENT 97 ROUTINE RESIDENT INSPECTION 12/01/87 12/31/87 87-37 87-37 SPECIALIST 41 INSPECTION OF RADIOLOGICAL SAFETY 12/14/87 12/18/87. PROGRAM

. 87-38 . SPECIALIST 28 ILRT.ASSESSMENT 12/20/87 12/23/87

56 /

Table 2 SALEM 1&2 INSPECTION HOUR

SUMMARY

AREA HOURS HOURS ANNUALIZED PERCENT OPERATIONS 1385 1107. 3 32.3 RADCON/CHEMISTRY 525 420.0 .12 .1 MAINTENANCE 421 336.9 9.7 SURVEILLANCE 479 383.4 11.1 EMERGENCY PREP. 47 37.7 1.1 SEC/SAFEGUARDS 187 149.7 4.3

. OUTAGES 322 257.8 7.4 ENGINEERING 922 737.6 22.0 TOTALS: 4288 > 3430.4 100.0

57 Table 3 SALEM 1&2 ENFORCEMENT ACTIVITY A. Violations versus FunctionaLArea by Severity Level FUNCTIONAL No. of Violations in Each Severity.Level AREA 1 2 3 4 5 DEV TOTAL OPERATIONS 1 3 4 RADCON/CHEMISTRY 3 3 MAINTENANCE 1 1 SURVEILLANCE 0 EMERGENCY PREP. 0 SEC/SAFEGUARDS 0 OUTAGES 0 ENGINEERING SUPPORT 5 5 LICENSING 0 ASSURANCE OF QUALITY 0 TRAINING & QUALIFICATION 0 TOTALS: 1 7 5 I3 Note: Four other violations pending from NRC Fire Protection Team Inspection 50-311/87-29.

58 Table 3 (cont.)

. B. Summary of Violations INSPECTION REPORTS REQUIREMENT SEVERITY FUNCTIONAL INSPECTION DATES_ VIOLATED_ LEVEL AREA_ DESCRIPTION 87-02 87-02 CRITERION *In 5 ENGINEERING NO PROCEDURES FOR 01/12/87-1/16/87 10CFRSO IMPLEMENTING APPENDIX. B -SYSTEM DESIGN INTERFACE MEASURES CRITERION V 5 ENGINEERING PIPING AND PIPE 10CFRSO SUPPORT DESIGN APPENDIX B ACTIVITIES WERE NOT PERFORMED IN

• ACCORDANCE WITH APPROVED PROCEDURES CRITERION VI 5 ENGINEERING DOCUMENTS FOR 10CFRSO DESIGN MODIFICA-APPENDIX B TIONS WERE NOT MAINTAINED IN ACCORDANCE WITH REQUIREMENTS 87-03 87-04 T.S. 4.6.1.1.a 4 OPERATIONS TESTING DID NOT 01/27/87 02/23/87 DOCUMENT CONTAINMENT INTEGRITY EVERY 31i DAYS 87-03 T.S. 3.5.2.d 3 OPERATIONS INOPERABI LITY OF 01/12/87 BOTH EMERGENCY CORE COOLING SYSTEM AND RESIDUAL HEAT REMOVAL SYSTEM. THE SYSTEM COULD ONLY INJECT WATER TO TWO VS FOUR LOOPS

59 Table 3 (cont.)

INSPECTION REPORTS REQUIREMENT SEVERITY FUNCTIONAL INSPECTION DATES_ VIOLATED_ LEVEL AREA_ DESCRIPTION 87-06 87-11 T.S. 4.9.7 4 OPERATIONS MISSED 03/24/87 04/20/87 SURVEILLANCE PERTAINING TO OVERLOAD CUTOFF ON

-A CRANE THAT CAN TRAVEL OVER SPENT FUEL_

87-08 87-09 CRITERION V 5 ENGINEERING WRITTEN PROCEDURES 04/07/87 04/10/87 10CFR50 PROVIDING THE APPENDIX B SCOPE AND ACCEPTANCE CRITERIA WAS NOT DOCUMENTED FOR 1980 SURVEY OF BLOCK WALLS CRITERION XVII 5 ENGINEERING NO RECORDED, 10CFR50 CONTROLLED APPENDIX B- CALCULATIONS WERE AVA! LAB LE FOR MASONRY WALLS MODI FI CATIONS 87-11 87-14 CRITERION XII I 4 MAINTENANCE NO COMPLETED DATA 04/15/87 04/20/87 10CFRSO SHEETS TO DOCUMENT i

APPENDIX B ROTATION OF CRITICAL EQUIPMENT IN STOREROOM 87-15 87-18 T. s. 4. 5. 2b 4 OPERATIONS OPERABILITY OF 05/19/87 06/15/87 EMERGENCY CORE COOLING SYSTEM NOT DEMONSTRATED WITHIN 31 DAYS 87-29 REPORT NOT ISSUED - 4 POTENTIAL VIOLATIONS 09/14/87 09/18/87

/ 60

• INSPECTION REPORTS REQUIREMENT INSPECTION DATES_ VIOLATED-=

Table 3 (cont.)

SEVERITY FUNCTIONAL LEVEL~ AREA__ DESCRIPTION 87-30 87-31 T.S. 6.12 4 RAD CON LOCKED HIGH 10/19/87 10/23/87 RADIATION DOORS WERE DEFECTED AND LEFT UNLOCKED T.S. 6.11 4 RAD CON PRE-JOB BRIEFINGS WERE NOT BEING CONDUCTED AND MPC-HOUR METERS WERE NOT USED T.S. 6.8 4 RAD CON FA! LURE TO ESTABLISH PROCEDURES FOR CALIBRATION USE AND DATA EVALUATION OF SL4 (MPC-HOUR METERS)

61

• Table 4 SALEM 1&2 LICENSEE EVENT REPORTS A. LER by Functional Area Number by Cause Cod~s n,_ -

FUNCTIONAL AREA A B c D E x TOTAL OPERATIONS 2 1 3 2 2 10 RADCON/CHEMISTRY 4 4 MAINTENANCE 2 2 1 2 7 SURVEILLANCE 10 1 1 12 EMERGENCY PREP.

SEC/SAFEGUARDS REFUELING, OUTAGE MANAGEMENT ENGINEERING SUPPORT 1 10 1 12 LICENSING ACTIVITIES TRAINING AND QUALIFICATION ASSURANCE OF QUALITY TOTALS: T9 10 1 6 4 5 45 Legend: A- Personnel Error B- Design Error C- External Cause 0 - Defective Procedure E- Equipment Failure X- Other

62 Table 4 (cont.)

B. LER Syno12sis SALEM 1 LER NUMBER EVENT DATE CAUSE CODE DESCRIPTION 86-019 10/01/86 8 T.S. 3.7.11 NON COMPLIANCE - FIRE BARRIER WALL IMPAIRMENT DISCOVERED 86-020 11/08/86 A T.S. SURVEILLANCE 4.7.7.lA -

SURVEILLANCE NOT COMPLETED WITHIN TIME - DUE TO PERSONNEL ERROR 86-021 11/12/86 A T.S. SURVEILLANCE 4.3.3.9 - DETECTOR 1R41C FUNCTIONAL TEST NOT IN TIME DUE TO PERSONNEL ERROR 87-001 01/30/87 A UNIT NO. 1 REFUELING WATER STORAGE BORON CONCENTRATION OUT OF SPECIFICATION DUE TO PERSONNEL ERROR 87-002 03/12/87 A LOSS OF CONTROL OF A HIGH RADIATION AREA LOCKED DOOR DUE TO PERSONNEL ERROR 87-003 03/26/87 D CONTAINMENT PRESSURE/VACUUM RELIEF VALVES OPEN BEYOND 1000 HOUR LIMIT DUE TO PROCEDURAL INADEQUACY 87-004 04/10/87 A DIESEL GENERATOR MISSED SURVEILLANCE DUE TO INADEQUATE POST MAINTENANCE TESTING CAUSED BY PERSONNEL ERROR 87-005 04/23/87 A lF GROUP BUS UNDERFREQUENCY PROTECTION INOPERABLE DUE TO MISPOSITIONED KNIFE SWITCH 87-006 , 05/25/87 x BOTH TRAINS OF HIGH HEAD SI DECLARED INOPERABLE - T.S. 3.0.5 ENTERED 87-007 Op/02/87 c TURBINE TRIP/TX. TRIP FROM 100% -

5021 DEANS LINE CROSS TRIP SCHEME -

LIGHTING STRIKE 87-008 06/03/87 A FAILURE TO IMPLEMENT PORTIONS* OF THE

• INSERVICE TESTING PROGRAM

0 63 Table 4 (cont.)

LER NUMBER EVENT DATE CAUSE CODE DESCRIPTION 87-009 06/04/87 x T.S. 3.7.11 NON COMPLIANCE - IMPAIRED FIRE BARRIER PENETRATIONS DISCOVERED 87-:0lO 06/10/87 B NON COMPLIANCE WITH 10CFRSO APPENDIX A CRITERIA FOR SEPARATION OF SAFETY RELATED COMP.87-011 09/17/87 B POTENTIALLY INADEQUATE BREAKER COORDINATION 87-012 09/30/87 D REACTOR TRIP SYSTEM INSTRUMENTATION NOT BEING PUT IN TRIP WITHIN THE REQUIRED TIME FRAME 87-013 10/02/87 E TRIP FROM SOURCE RANGES HIGH NEUTRON FLUX DUE TO WATER IN THE DETECTOR 87-014 10/08/87 A LOSS OF CONTROL OF A-LOCKED HIGH RADIATION AREA DOOR DUE TO PERSONNEL ERROR 87-015 10/23/87 A TECHNICAL SPECIFICATION 3.8.l.2B -

NON COMPLIANCE DUE TO PERSONNEL ERROR 87-016 11/02/87 B POWER OPERATED RELIEF STOP VALVE CABLING FOUND DEGRADED - INADEQUATE f DESIGN REVIEW I 87-017 11/13/87 B DISCOVERED LEAKAGE PATHS FROM 13 (23)

AFW PUMP COMPARTMENT

.87-018 12/09/87 D LEAD/LAG AND DERIVATIVE AMPLIFIERS IMPROPERLY CALIBRATED DUE TO PROCEDURAL INADEQUACY

-** *"'";,--:-: ...~

87-019 12/27/87 x WASTE GAS OXYGEN~~ATER THAN 2% FOR GREATER THAN 48 HOURS

64 Table 4 (cont.)

SALEM 2 LER NUMBER EVENT DATE CAUSE CODE DESCRIPTION 86-010 10/16/86 B T.S. 3.7.11 NON COMPLIANCE - FIRE BARRIER PENETRATION DISCOVERED IMPAIRED 86-011 11/17 /86 A T:S. SURVEILLANCE 4.9.7 - NOT PERFORMED WITHIN SPECIFIED TIME DUE TO PERSONNEL ERROR 86-012 11/21/86 E CONTAINMENT SYSTEM - TYPE B & C LEAK RATE OUT-OF-SPECIFICATION DUE TO VALVE 2PR25 EXCESSIVE LEAKAGE 86-013 12/23/86 A TURBINE REACTOR TRI~ FROM 8% ON P-7 INTERLOCK DUE TO TURBINE OVERSPEED 86-014 12/28/86 E REACTOR TRIP FROM 77% POWER ON STEAM FLOW/FEED FLOW MISMATCH & 23 SG LOW LEVEL DUE TO VALVE 23BF19 CONTROL PROBLEMS87-001 01/13/87 D LOSS OF RHR INJECTION CAPABILITY TO TWO COLD LEGS DUE TO TECHNICAL SPECIFICATION MISINTERPRETATION 87-002 01/18/87 A REACTOR TRIP FROM 3% POWER ON ERRONEOUS HIGH NEUTRON FLUX SIGNAL DUE TO PERSONNEL ERROR 87-003 02/26/87 A UNIT 2 FUEL HANDLING CRANE MISSED SURVEILLANCE DUE TO PERSONNEL ERROR 87-004 03/12/87 x GENERATOR-TURBINE/REACTOR TRIP DUE TO LOSS OF FIELD ON THE MAIN GENERATOR 87-005 04/07 /87. E TURBINE/REACTOR TRIP FROM 85% POWER DUE TO LOSS OF DC CONTROL POWER TO TURBINE ELECTRO HYDRAULIC CONTROL SYSTEM BY A FAILED SERVO CARD 87-006 05/06/87 *A T.S. 3.7.10.3 NON COMPLIANCE -

INADEQUATE FIRE WATCH DUE TO PERSONNEL ERROR

• 65 Table 4 (cont.)

LER NUMBER EVENT DATE CAUSE CODE DESCRIPTION 87-007 05/11/87 B T.S. 3.7.11 NON COMPLIANCE -

DISCOVERY OF FIRE BARRIER IMPAIRMENT 87-008 05/19/87 A MISSED T.S. SURVEILLANCE 4.5.2.B DUE TO PERSONNEL ERROR - T.S. 3.0.3 ENTERED 87-009 06/19/87 8 APPENDIX R CRITERIA NON-CONFORMANCE 87-010 06/23/87 A FIRE BARRIER IMPAIRMENT -

NON COMPLIANCE DUE TO PERSONNEL ERROR 87-011 08/06/87 A REACTOR TRIP - NO. 24 STEAM GENERATOR HIGH-HIGH LEVEL 87-012 09/30/87 x RHR PUMP ROOM FLOOD CURB MISSING DUE TO PERSONNEL ERROR

• 87-013 87-014 10/02/87 10/22/87 D

B T.S. SURVEILLANCE 4.8.1.3.A MISSED DUE TO INADEQUATE PROCEDURAL CONTROL INCORRECT DIESEL GENERATOR INFEED BREAKER SETPOINT DUE TO INADEQUATE DOCUMENTATION CONTROL 87-015 11/27 /87 B POTENTIAL FOR CERTAIN SW MCC CONTROL.

CIRCUITS TO PICK UP STARTER COIL 87-016 12/07/87 A 2A DIESEL GENERATOR SURVEILLANCE MISSED DUE TO PERSONNEL ERROR 87-017 12/08/87 D TECHNICAL SPECIFICATION NON COMPLIANCE DUE TO PROCEDURAL IN ADEQUACY 87-018 12/23/87 A LArE SURVEILLANCE ON FUNCTIONAL TEST OF WASTE GAS MONITORS

66 Table 5

SUMMARY

OF LICENSING ACTIVITIES A. NRR LICENSEE MEETINGS 1/ 6/87 AEOD Meeting on False Loss of Offsite Power Transient 5/21/87 Control Room Design Review Meeting 6/15/87 RTD Bypass Modification Meeting 71 9/87 RTD Bypass Modification Meeting 11/24/87 North Anna Steam Generator Event Meeting B. NRR SITE VISITS 10/22-28/86 LPM observation of refueling outage activities 2/18/87 Licensing actions scheduling 5/28/87 Site access training for LPM 9/ 2/87 SIMS Data review 9/28/87 SIMS Data and licensing actions schedule review C. COMMISSION BRIEFINGS None D. SCHEDU.LAR EXTENSIONS GRANTED None E. RELIEFS GRANTED 6/24/87 Interim Relief from certain ASME Code testing requirements - Unit 1 12/29/87 Extension of 6/24/87 Interim Relief F. EXEMPTIONS GRANTED 9/ 4/87 Exemption from 10 CFR 50, Appendix J, III.D.2(b)(ii)

• • ~*"**-*""'" ~--*--*** *-*.*->*- --* *.......... --* .:-~-- .

... t . j*** ~

67 Table 5 (Cont.)

SUMMARY

OF LICENSING ACTIVITIES G. LICENSEE AMENDMENTS ISSUED Date Unit 1 Unit 2 Title 2/26/87 76 50 Reduce No~_of Active Fuel Rods*

3/31/87 77 51 Operate Fuel Handling Crane 4/ 7/87 78 52 Delete Boron Injection Tank 4/10/87 79 53 Accident Monitoring 6/19/87 80 54 Delete Maximum Fuel Weight 8/24/87 81 Facility Attachment 9/23/87 82 Replace Fxy Limits 10/16/87 83 55 Change RWST_ Boron Concentration 11/16/87 84 56 RTD Bypass Modification H. EMERGENCY CHANGES TO TECHNICAL SPECIFICATIONS None I. ORDERS ISSUED None