ML18094A619
| ML18094A619 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Salem |
| Issue date: | 04/30/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18094A618 | List: |
| References | |
| 50-272-88-99, NUDOCS 8908180014 | |
| Download: ML18094A619 (31) | |
See also: IR 05000272/1988099
Text
I~.---
INITIAL SALP REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
REPORT NO. 50-272/88-99; 50-311/88-99
-*PUBLIC SERVICE ELECTRIC* AND GAS COMPANY
SALEM GENERATING STATION
Enclosure 1
A$SESSMENT PERIOD:
JANUARY 1, 1988 - APRIL 30, 1989 .
TABLE OF CONTENTS
Page
I.
INTRODUCTION
II.
BACKGROUND .
2
3
3
3
II.A Licensee Activities . . . . . .
. .
II.B Direct Inspection and Review Activities
- ' .
III. SUMMARY OF RESULTS ............ .
4
4
6
6
III.A Overview ....... *.
. .... .
III.8 Facility Performance Analysis Summary.
III.C Reactor Trips and Unplanned Shutdowns
IV.
PERFORMANCE ANALYSIS ...
9
A.
B. c.
IV.A Operations.*. . . . .
9
IV.ff Radiological Controls . .
12
IV.C Maintenance/Surveillance. . . . . . . . . . . .
14
IV.D Emergency*Preparedness (Common With Hope Creek) .
17
IV.E Security (Common With Hope Creek) . . .
19
IV.F Engineering/Technical Support . . . . . .
21
IV. G.. Safety Assessment/Qua 1 i ty Veri fi ca ti on. .
24
SUPPORTING DATA AND SUMMARIES
Enforcement Activity;
~ .
. ..... .
In spec.ti on Hour Summary . . .
. . . .
Licensee Event Repor~ Causal Analysis.
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27
27
28
Attachment 1:
SALP Criteria
'* ... * ...
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I.
INTRODUCTION
The Systematic Assessment of Licensee Performance*(SALP) is an integrated NRC
staff effort to collect available observations and data on a periodic basis**
and to evaluate licensee performance on the basis of this information.
The
SALP program is supplemental to normal regulatory processes used to ensure
compliance with NRC rules and regulations. It is intended to be sufficiently
diagnostic to provide a rational basis for allocating NRC resources and to
provide meaningful feedback to the licensee's management regarding the NRC's
assessment of their facility's performance in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on
June 28, 1989, to review the observations and data on performance, and to
assess licensee performance in accordance with the guidance in NRC Manual
Chapter 0516,
11Systematic Assessment of Licensee Performance".
The guidance
and evaluation criteria are summarized in Attachment 1 of this report.
The
Board's findings and recommendations were forwarded to the NRC Regional
Administrator for approval and issuance.
Thi.s report is the NRC's assessment of the licensee.*s safety performance at
the Salem Generating* Station, Units 1 and 2 for the period January 1, 1988
through April 30, 1989.
The SALP Board was composed of:
Board Chairman
S. J. Collins, Deputy Director, Division of Reactor Projects (DRP)
Board Members
B. Boger, Acting Director, Division of Reactor Safety (DRS)
M. Knapp, (Part-Time), Director~ Division of Radiation Safety and Safeguards
(DRSS) *
J. Joyner, (Part-Ti.me), Division Project Manager, DRSS
W. Butl.er, Director, Project Directorate I-:-2,. Office* of Nuclear Re-actor
Regulation (NRR)
- *
K. Halvey Gibson, Senior Resident Inspector, Salem
P. Swetland, Chief, Reactor Projects Section No. 2B, DRP
. . . . -
.
.
- .
Attendees
J. Linville, Acting Chief, Reactor Projects Branch No. 2, DRP
R. Nimitz, Senior Radiation Specialist, DRSS
S. Chaudary, Senior Reactor Engineer, DRS
S. Pindale, Resident Inspector, Salem
W. Lazarus, Chief, Emergency .. Preparedness Section, DRSS
R. Bores, Chief, Effluents Radiation Protection Section, DRSS
R. Keimig, Chief, Safeguards Section, DRSS
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- , .:* .*
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-3-
II.
BACKGROUND
II.A Licensee Activities
Unit 1 entered the assessment period at the end of the seventh refueling
outage with the startup being delayed due to leakage identif.ied at the lower
canopy seal welds of some spare control rod drive mechanism (CROM)
penetrations. Unit 2 began the assessment period operating at full power in
the midst of the fourth fuel cycle.
Unit 1 was restarted following the refueling outage on February 2, 1988.
The
unit experienced five reactor trips and three unplanned shutdowns during the
16 month assessment period. Additionally, there were several power reductions
during the assessment period due to various causes, including Technical
Specification Action Statement requirements and balance of plant maintenance.
Unit 1 shutdown for the eighth refueling/maintenance outage on March 28, 1989,
about two *weeks before the originally scheduled April 15 start date, due
to a degraded main power transformer.
Major outage activities included steam
generator tube eddy current testing and tube plugging, main steam safety valve
and inverter replacements, control room human factors design changes, reactor
protection system modifications, and main power transformer replacements.
During the SALP period, there were eleven reactor trips and two unplanned
shutdowns at.Unit 2.
There were also several power reductions due to various
causes.
Unit 2 shutdown for the fourth refueling outage on August 31, 1988,
and was returned to service on November 26, 1988.
Major outage activities
included steam generator tube eddy current testing and p*.ugging, control room*
human factors design changes, reactor protection system modifications, RTD
bypass ma[ii~old removal, and bottom mounted thermocouple installation.
At the end.o.f.the.assessmentperiod, the Unitl eighth refueling outage was
continuing and Unit 2 w~s operating at full power.
Section III.C summarizes
all reactor trips and unplanned shutdowns that occurred for both units d~ring
the* SALP* period: ..
During the ass~ssment period, Steven E. Miltenberger replaced Corbin A.
McNeill as Vice President and Chief Nuclear Officer, and later, Stanley
LaBruna was ~ppointed Vice President - Nuclear Operations.
Other licensee
personnel changes* were implemented at the following positions: General
Manager*- Salem O~erations, Mai~ten~nce Man~ger, .Technical Manager and
Radiological Protection/Chemistry Manager.
II.B Direct Inspection and Review Activities
During the assessment period there were two NRC resident inspectors assigned
to the site, except for a si~ month ~eriod when one inspector was assigned.
Several NRC team/special inspections were conducted at Salem, including a Unit
1 readiness assessment team following the seventh refueling outage (January
4-8, 1988), a review of the December 22, 1987 Unit 1 service water system
flooding event (January 4-7, 1988), a review of the circumstances associated
with two personnel contamination events*(November 30, 1988 - January 20,
1989), and a Unit 2 outage team inspection (October 17-28, 1988).
An NRC
Emergency Preparedness Inspection Team observed the annual, full
participation, emergency exercise on November 29 - December 2, 1988.
.-. .-.* *:**.**.*;.
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A total of 3531 inspection hours (2353 annualized) were expended utilizing
resident and region-based inspectors.
Ill. SUMMARY OF RESULTS
III .A Overview
The Salem units continued to operate in a safe manner during the assessment
period, however a notable decline in overall licensee performance occurred
when compared with the previous assessment. This was exhibited by an increase
in the number of reactor trips and safety system challenges. Specifically,
personnel errors, procedure implementation deficiencies, and inadequate
supervisory oversight resulted in weaker performance in several functional areas.
In contrast, excellent performance continued in the security area.
In Operations, plant transients caused by personnel and procedural errors were
more frequent.
Weaknesses in supervisory oversight and procedure control were
noted.
Root cause determinations were sometimes weak with regard to potential
operator errors.
A decline in radiation protection and industrial safety performance occurred
early in the SALP period, despite a sign~ficant upgrade in radiation control
procedures.
Enhanced training and management oversight resulted in improved
performance ~~ the end of the* assessment period.
Maintenanc~ performance also declined early in the period due to lapses in
oversight and procedural controls.
License~ corrective actions during the SALP
period resulted in a substantial improvement trend.
Personnel errors and
program deficiencies persisted in the Surveillance area despite significant
licensee efforts to resolve these weaknesses.
Although the program was basically
sound, the inability to promptly* resolve these weaknesses was noted as a concern.
In Emergency Preparedness, a strongly supported program was also noted.
However,
performan~e in the annual exercise declined and correction of a long standing
deficiency in the Salem* Technical Support Center was not aggressively pursued
to re solution ..
Licensee initiatives to improve the quality of Engineering and Technical Support
were effecti.ve but. implementation problems persisted during the transition to
new programs.
A significant decline in Quality Verification efforts was noted.
Inconsistent
performance and reduced expectations resulted from a lack of management focus
and supervisory oversight in some areas.
The effectiveness of corrective action
programs was inconsistent.
Overall, the licensee identified these declining performance trends and took
corrective actions to resolve most of the concerns during the period.
The
Salem station appears to be in a pivotal period in the licensee's attempt to
upgrade the programs and standards at the units.
The NRC encourages the
licensee's initiatives to review and self-identify program weaknesses and
supports the pursuit of excellence throughout Artificial Island. It appears,
however, that continued management focus and attention is warranted to insure
that these standards have been accepted and implemented at'all levels
throughout the Salem organization.
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-5=
III .8
Facility Performance Analysis Summary
Functional Area
Pl~nt Operati6ns
Radiological Controls
Maintenance/Surveillance
Security
Engineering/Technical
Support
Safety Assessment/
Quality Verification
Last Period
(10/1/86-12/31/88)
2
2
112"'
1
1
2
1/2**
Rated a~ separate functional areas.
This Period
Trend
(1/1/88-4/30/89)
3
2
2
2
1
2
Improving
2
Si~ilar areas (Assurance of Quality, Category 1 and Licensing Activities,
Categ*ory 2) were assessed last period .
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III.C Reactor Trips and Unplanned Shutdowns
Unit 1
Event Description
Power
Date
Level
Root Cause
Functional Area
1.
The reactor tripped automatically on high flux while adjusting a nuclear
instrument detector. A technician performed procedure steps out of
sequence and failed to bypass the output trip signal before pulling the
channel fuses.
.2/24/88
4%
Personnel Error
Surveillance
2.
The reactor was tripped manually after the turbine governor valves began
to drift shut due to loss of control oil pressure.
Operators failed to
properly diagnose a previously annunciated turbine control oil reservoir
low level alarm, which resulted in the loss of both control oil pumps.
3/30/88
100%
Personnel Error
Operations
3.
A 15-day unplanned shutdown commenced following the 3/30/88 trip to
replace leaking (about 110 gpd) steam generator (SG) tube plugs.
3/30/88 .
0%
Component Failure
NA
4.
The reactor tripped automatically on turbine trip during on-line
surveillance testing of the turbine trip mechanism.
8/31/88
-100%
Unknown
NA
5.
The reactor tripped automatically on low SG level due to operator failure
to select an alternate controlling steam pressure channel during
surveillance testing.
2/6/89
100%
Personnel Error
Operations
6.
An unplanned shutdown was made due to a component cooling water leak in
the supply line to a reactor coolant pump *.
2/15/89
100%
Component Failure
NA
7.
The reactor tripped automatically on turbine trip because a technician
failed to follow the surveillance test procedure.
The initial conditions
for performan~e of a turbine impulse pressure functional test were not
met prior to. proceeding with* the surveillance activity.
2/18/89
0%
Personnel Error
Surveillance
8.
An unplanned shutdown was made due.to high combustible gas concentrations
in the main power transformer oil. Confirmed transformer degradation
caused an early start of the refueling outage scheduled for 4/15/89.
3/23/89
100%
Component Failure
NA
Event Description
Power
Unit 2
Date*
Level
Root.Cause
Fi.met i ona L Area
l.
The reactor tripped automatically on low loop flow because a technician
did not follow the procedure for restoring a reactor coolant loop flow
transmitter to service. The transmitter valving manipulations were
performed out of sequence.
4/21/88
100%
. Personnel Error
Surveillance
2.
The reactor tripped automatically on turbine trip d~e to high SG water
level. Turbine control equipment problems and/or inappropriate operator
response contributed to the high SG level.
4/22/88
18%
Unknown
NA
3.
The reactor tripped automatically on high power range negative flux rate.
One control rod dropped i*nto the reactor core while inserting rods to
reduce power for a surveillance test.
5/13/88
97%"
Uri known
NA
4.
The reactor tripped automatically and safety injection actuated due to
spurious initiating signals generated when the
11C" vital instrument bus
inverter failed.
The non-redundant engineered safety features sensor
power supply design contributed to the event.
-
6/22/88
100%
Component* Failure
Engineering
5.
The reactor tripped automatically due to a spurious trip signal caused by
the loss of vital instrument bus inverter "C".
7/30/88
. 80%
Component Failure
Engineering
6.
The r~~~t~~ trip~ed automatically'o~ high SG level due to a failed open
feedwater control valve.
The control valve positioner had become
disconnected> due to vibrat.ion in combination with a poorly designed
l ockwasher.
. . .
. . .
8/31/88
72%
Component Failure
NA
7.
The reactor tripped automatically on low SG level.
Inadequate procedural
guidance resulted in improperly setting the control air regulator for a
feedwater control valve positfoner.
The resultant SG level oscillations
caused the trip.
11/28/88
25%
Defective Procedure
Maintenance
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Event Description
Power
'Date
Level
Root Cause
=8~
Functional Area
8.
An unplanned shutdown- was made due to high combustible gas concentrations
in the main power transformer oil.
12/9/88
100%
Component Failure
NA
9.
The reactor tripped automatically on low SG water level due to loss of
Inadequate procedures for operation with reduced circulating
water capacity and only one heater drain pump caused the loss of both
feed pumps due to low suction pressure.
2/5/89
60%
Defective Procedure
Operations
10.
The reactor tripped automatically on low SG water level following the
loss of vital instrument bus inverter "D".
The inverter control power
fuse fell out of its fuse holder. A safety injection resulted from
spurious. actuation s i gna 1 s caused by the 1 oss of inverter power.
3/12/89
100%
Unknown
Engineering
11.
The reactor tripped automatically during surveillance testing on low SG
water level when plant operators did not prevent SG level from reaching
the low setpoint with a coincident steam flow chanriel bistable inoperable
and t-ri pped.
3/29}89
-0%
Personnel Error
Operations
12.
The_ reactor tripped automatically on low-SG water level. A latching
relay malfunctioned during a main steam bypass valve surveillance test,
causing inadvertent closure of a main steam isolation valve and the
consequent-SG level oscill~ti-0ns.
4/11/89
100%
_Component Failure
- ... :; .. * .
_NA
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I
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IV.
PERFORMANCE ANALYSIS
IV.A
IV .A.1
Operations
Analysis
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(1437 hours0.0166 days <br />0.399 hours <br />0.00238 weeks <br />5.467785e-4 months <br />, 41%)
Plant Operations was rated as a SALP Category 2 during the previous assessment
period.
Licensee strengths included a strong management team and an improved
trip frequency.
Personnel error due to inattention to detail and poor
interface communications was noted as an area in need of improvement.
During the current SALP period there were 16 reactor trips between the two
units (five on Unit 1, 11 on Unit 2), including six trips directly or.
indirectly attributable to the operations functional area.
The 16 reactor
trips were more than twice as many as during the previous assessment (seven).
The number of trips two SALP cycles ago was 18.
The licensee's trip reduction
efforts appear to have been ineffective since the last SALP.
The root causes
of the reactor trips were consistent with overall performance concerns at
Salem including personnel errors and procedure implementation deficiencies.
Personnel errors resulting from failure to follow procedures and inattention
to detail resulted in six reactor trips during the assessment period.
Three
of these involved operat*ions personnel. Three Technical Specification (lS)
surveillances were missed or late due to personnel error by operations
personnel a.nd inadequate supervisory review.
On two occasions operators
failed to enter TS Action Statements as required.
Two additional examples of
operations.personnel errors included failure to follow a surveillanca
procedure, which resulted in blackout loading on a vital bus, and poor
communica.tiOn between operations supervisors, which resulted in fuel handling
with the fuel building ventilation inoperable.
In response to these issues,
thelicensee*has placed additional supervisors on shift during outages and has
counseled Operations Department supervisors concerning better oversight and
responsib.ility.
However, since personnel errors have continued to occur,
further management attention is needed in this area.
Operations managemen~ did not always provide adequate guidance to the
operaiors relative to non-routine situa~ions. * Inadequate direction for
operations support of maintenance activities resulted in a diesel generator
day tank._being overfilled and an NRC. identified misalignment of a service
water heade~ chlbride fnl~t valve.
I~ ~ddttion, prompt actions were not
implemented by operations management relative to a Station Operations Review
Committee (SORC) directed action for a non-seismic diesel. generator fire
protection relay, and the tracking of steam flow channels which were drifting
non-conservatively.
NRC and station management involvement was needed to
ensure correction of these deficiencies.
In order to address the shortcomings
in the conduct of day- to day routine plant evolutions, increased management
oversight is needed in the operations area to ensure that adequate procedural
guidance is established when appropriate, and procedures are followed.
Deficient procedures contributed to two reactor trips, one in the operations
area.
One TS surveillance was missed due to an inadequate operations
..
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procedure.
The licensee has instituted a procedure upgrade program and a work
standards improvement program in response to NRC concerns relative to
personnel error and procedure problems.
However, the programs appeared to
have been focused mainly on maintenance and surveillance activities.
Administrative control of procedures and documents in the control room needs
improvement, in that examples of wrong Technical Specification pages, misfiled
documents, missing procedures, an incorrect procedure revision, and inaccurate
reference material were identified during the SALP period.
Each of these
deficiencies was corrected and QA reviews of control room files, procedures,
and materials were periodically performed to identify additional deficiencies.
Additional management action is needed in this area because deficiencies in
the control of documents in the control room continued to be identified.
Staffing' in the Operations Department was adequate and programs were in place
to maintain and enhance staffing ievels for both licensed and non-licensed
operators. A five shift operator rotation is in effect at each unit.
Control
room professionalism was generally good.
Although numerous examples of
personnel error and inattention to detail occurred during routine operation,
immediate operator response to reactor trips and implementation of emergency
ope-rating procedures was very good.. Reactor startups and shutdowns were
generally well controlled and supervised.
Licensee event and problem evaluatio*1 and response was usually prompt and
comprehensive.
However, the root cause of four reactor trips was not
determined by the licensee.
Certain self assessments and root cause
investigations have been weak, in that the level of aggressiveness with which
issues were pursued decreased when a conclusive root cause for a trip or
equipment problem was not determined within a short period of time.
In some
cases, ro_ot cause investigations were incomplete because operations management
was reluctant to accept responsibility for possible operator errors, and this
aspect was not pursued. as aggressively a~ possible equipment deficiencies.
On
several occasions unit restart was authorized based on the replacement of
suspect components or the completion of actions based on supposed problems,
without substantive evidence that all possible causes had been identified or
would ba resolved .. Examples include a turbine electro-hydraulic control (EHC)
rate amplifier card which was replaced even though it tested satis*factorily,
and a separate occasion where actions were taken to clean and monitor pressure
in the turbine auto stop oil system in response to a supposed, one-time
momentary clog in the system.
Further instances of slow or weak root cause
evaluation, related to two reactor trips and loss of a safety-related 4 KV
electrical bus late in the period, prompted a violation and an NRC request for
further information from the licensee regarding circumstances surrounding the
events.
Continued management focus on root cause determinations is needed.
Initial license exams were administered to two SRO and thr-ee RO candidates
during the- SALP period.
Of this grou~, one- SRO failed.
Requalification exams
were taken PY eight SROs and four ROs.
Of this group, one RO failed.
EDP
usage weaknesses identified during the requalification program evaluation were
promptly corrected.
The licensee
1 s operator requalification program was
upgraded to a satisfactory rating during the SALP period.
The licensee has begun control room human factors modifications which are
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planned to be installed over a three refueling outage period for each unit.
The licensee has taken a conservative approach to minimize the chance of
operator error due to control room differences by assigning licensed reactor
operators to speciftc units.
In response to an NRC concern, operations
management took action to develop a written plan to define the actions
necessary to indoctrinate licensed ope~ators on the opposite unit if a need
for reassignment should arise.
Daily status and planning meetings were well structured, thorough and concise.
Meaningful exchanges of unit status, identified problems and scheduled
evolutions took place.
The operations department prioritized work. based on
plant needs and the planning and maintenance organizations responded
accordingly.
The work control center coordinated activities between the
support groups and operations department to facilitate removal and return of
systems and equipment to service.
Toward the end of the assessment period,
equipment outage duration and operational priorities were discussed and
emphasized at planning meetings to ensure proper coordination between
departments and timely return of equipment to service.
The quality of
housekeeping in the station was inconsistent during the SALP period and was
directly related to the level of management attention and emphasis on
housekeeping matters.
The licensee's Fire Protection Program was well 5taffed and maintai~ed. The
persons in* charge of th~ program were competent and received considerable
corporate management backing in their effort to improve the program.
Evidence
of the management support was the recent purchase of state of the art
firefighti~g equipment.
The licensee has addressed NRC concerns in the safe
shutdown and fire protection areas, for example the work to upgrade fire
barriers js proceeding expeditiously.
Limited examples of late firewatch
patrols and missed fire protection surveillances due to inadequate
administrative* controls or communication within or between the operations and
fire protection departme~ts occurred during the period.
Increased fire
protection management attention has been effective in preventing similar
occurrences in* the latter part of the assessment period.
In summary, weaknesses were identified in operations in the areas of
supervisory oversight of routine day to day operations.
The number of plant
trips and frequency of personnel errors have increased since the previous SALP
cycle.
Operations management did not always provide adequate guidance to the
operators for non-routine evolutions.
Procedure establishment, use and
compliance require continued station management attention.
Some root cause
analyses and corrective action determinations lacked aggressiveness and
thoroughness especially in cases relating to possible operator errors.
The
licensee has instituted actions to improve performance in these areas with
mixed results.
Operator response to plant transients was very good.
The
planning and work control processes were noted as strengths as was the fire
protection program.
IV.A.2
Performance Rating
Category 3
~i2-
IV.A.3
Recommendations
Licensee: Present to NRC Region I, the licensee assessment of corrective
actions needed to reduce challenges to safety systems and improve
the analysis of plant events.
NRC:
Conduct an Independent Performance Assessment Team Inspection.
IV.B
IV.8.1
Radiological Controls
Analysis
(503 hours0.00582 days <br />0.14 hours <br />8.316799e-4 weeks <br />1.913915e-4 months <br />, 14%)
This area was rated Category 2 during the previous assessment period.
Identified weaknesses included procedure quality and implementation, the
adequacy of the chemistry QA/QC program and the corrective action system.
Strengths included ALARA planning and relationships between radiation
protection personnel and other departments.
There were two outages which challenged the radiological controls program this
assessment period.
NRC observations during the first outage, the Fall 1988
outage at Unit 2, identified a number of significant problems which prompted
enhanced NRC ~ttention to* this functional area. Overall licensee response to
the identified problems was aggressive and timely.
Specifics regarding the
problems identified and licensee actions taken to improve performance during
the Sprin~ 1989 outage at Unit 1 are discussed in this assessment.
During the current assessment period, the licensee addressed procedure quality
by revisi_ng:44 existing procedures and writing 20 new ones.
This initiative
addresses a** Tong-standing concern relative to procedure adequacy.
The new
procedures were improved.in*quality and usefulness and resolved NRC 1s major
concerns with procedure adequacy prior to beginning the Unit 2 refueling
outage.
Implementation of these procedures was weak during the Unit 2 outage
(September 1988 to November 1988).
This problem was attributed to ineffective
training in the new procedures, weak communications, and inattention to detail
by both supervisors and techni.ci ans.
In response to the concerns identified during the Unit 2 outage, management
ensured that both licensee personnel and contractors were properly trained in
the new procedures prior to the scheduled Unit 1 outage in March 1989. The
licensee augmented its routine radiological controls training and
qualification program with a special six week training ~rogram, which enhanced
the routine program.
In addition, management stresse~ the need to adhere to
the new procedures.
These efforts resulted in significant improvements in
procedure implementation during the Unit 1 outage.
NRC inspection of Unit 2 outage activities identified weaknesses in the
adequacy of corrective actions for radiological occurrences, a problem
previously identified by the station QA group.
An example of a weakness that
was identified by the licensee and not effectively resolved involved problems
in High Radiation Area access controls. Further, there was little evidence
that major weaknesses identified in the field by the Radiological Assessor
during the Unit 2 outage were being acted upon.
The NRC i-nspection also
-13-
identified that supervisory oversight of on-going Unit 2 outage activities was
weak as evidenced by radiation protection technician and radiation worker
performance problems.
To address these concerns fn preparatfon for the Unit 1 outage, radiological
protection management personnel changes were made and the in-plant
radiological controls group was reorganized following comp*letion of the Unit 2
outage.
In addition, plant management initiated weekly meetings to discuss
radiological occurrences, Radiological Assessor findings, Industrial Safety
concerns and Quality Assurance findings.
NRC observations during the Unit 1 outage indicated the licensee 1.s actions
were effective in improving the supervisory and management oversight of outage
radiological controls activities and the management and resolution of
radiological occurrences and Radiological Assessor findings.
No significant
external radiological controls concerns were identified during the Unit 1
outage, including during steam generator work.
The program to minimize
airborne radioactivity for generator work was particularly noteworthy.
Control and minimization of contaminated areas and contamination was good and
allowed personnel to perform work on the steam generator platforms without the
need to wear respiratory protection equipment.
Problems continued to exist durfng the SALP period in the trea of worker
practices relative to housekeeping.
For example, candy wrappers were observed
in the radiological controlled areas indicating a lack of worker and
supervisory sensitivity to potential ingest.ion of radioactive material.
Housekeeping was considered poor throughout the radiological controlled areas
of the facility due to inattention to and lack of accountability for
housekeepjng.
Observations toward the end of the period indicated _some
improvement in the areas that have received management attention such as
containment, but problems: continued to exist in the* auxiliary and fuel
handling buildings.
NRC review. during* the Unit* 2* outage* identified significant industrial safety
concerns involving prevention of heat stress and work control measures for
high elevations, and prompted a special review by the Occupational Safety and
Health Administration (OSHA).
OSHA subsequently took enforcement actions for
the observed problems.
NRC review during the Unit 1 outage indicated
i mprovem_ent in the areas of concern.
In general, over the assessment period it appears that the quality of audits,
surveillances and assessments was improving.
The licensee has initiated a
performance based surveillance program.
The licensee has also begun to use
outside technical specialists to enhance audit performance.
The audits, in
conjunction with self-assessments by the Radiological Assessor, are now
considered effective in identifying problems.
A number of problems were identified relative to the maintenance of the
post-accident sampling system, indicating lack of attention to this important
system.
Repeated NRC involvement was needed to focus licensee attention on
this concern.
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-14-.
Consistent with the last assessment period, a generally effective AL.ARA
program is maintained and implemented.
Station aggregate exposure compares
favorably with industry averages.
Performance is close to industry best
percentiles. Aggressive oversight and control of major exposure tasks was
noted. A number of actions were taken to improve long term AL.ARA performance.
Special shielding was used during steam generator maintenance which reduced
exposure dose rates by about a factor of 5.
Dose reduction actions that could
reduce aggregate exposure over the life of the facility are aggressively
pursued.
Fuel performance has been good.
Radiological controls personnel
were recently assigned to the planning and scheduling department to evaluate
work packages and interface between work groups and the radiological controls
group.
A new AL.ARA group was recently established.
This has provided for
impr~ved Al.ARA planning.
Isolated problems were noted in individual work group performance.
For
example personnel were observed standing in about a 100 mR/hr field waiting
for tools to disassemble the reactor vessel head shroud.
The problem
indicates potential concerns with some supervisors and workers regarding
sensitivity to AL.ARA and a need for more attention to AL.ARA training.
Radiological confirmatory measurements inspections indicated good performance
by the licensee in.this area.
The review of the radiological environmental
monitoring program (REMP) indicated an adequate program was in place.
Performance during the last assessment period in the area of solid radioactive
waste and transportation was considered effective.
Two violations involving
failure to perform an audit and failure to properly survey a truck cab were
identified~during this SALP period. These violations were considered to be
isolated and were not indicative of a programmatic problem.
In summary, early in the assessment period licensee performance declined from
that. noted in .the previous SALP.
Licensee* co-rrective actions and
self-assessment processes were initially ineffective in improving overall
performance which prompted NRC involvement to stress the need to initiate
effective* program improvement.
Subsequent. management attention has resulted
in. significant performance improvement, as noted during the Unit 1 outage late
in the period.
Performance was adequate in the areas of radioactive effluent
controls and monitoring, radwaste transportation, and good in the area of
radiological confirmatory measurements.
IV.B.2
IV.8.3
IV.C
IV.C.l
Perf6rmanc~ Rating*
Category 2
Recommendations
None
Maintenance/Surveillance
(648 hours0.0075 days <br />0.18 hours <br />0.00107 weeks <br />2.46564e-4 months <br />, 18%)
Analysis
..
-15-
The last SALP assessment rated the maintenance functional area a Category 1
and the surveillance functional area a Category 2.
Generally strong
performance was noted in both areas, with missed surveillances due to
personnel error and inconsistent implementation of the instrument and gauge
ca li brat ion program i dent ifi ed as weaknesses.
Maintenance:
During this assessment period there was a reduced- level of maintenance
management involvement and supervisory oversight in day to day activities.
This resulted in a laxness with respect to implementation of the maintenance
program.
Procedure implementation deficiencies were identified including the
failure to establish adequate maintenance procedures for disassembly, cleaning
and preparation for removal of an emergency diesel generator, the failure to
have safety related pump alignment procedures at the work location while the
maintenance was being performed, and storage of transient equipment contrary
to administrative procedures.
Poor maintenance practices s~ch as use of information only drawings, work
performed outside the scope* of that specified on the work order, and deficient
radiologic~l controls and housekeeping related to maintenance activities were
observed.
Inadequate documentation of troubleshoot1ng activities was
identified as a weakness in the licensee's program, in that as found data was
not recorded in some cases, and problem resolution was delayed due to
activities being repeated since detailed documentation of previous work
performed was not available.
Return of safety-related equipment was not aggressive in all cases, in that,
equipmen"t! was not prompt.ly returned-to service following maintenance unless
the action statement would soon -expire.
Inattention to detail in the proper
execution* of maintenance activities resulted in failures of operational
retests and maintenance rework.
Examples include leads not reconnected, valve
air supplies not restored, and valve limit switch settings not reverified
following-maintenance/surveillance activities.
A new maintenance manager was assigned in November 1988.
A program to upgrade
work practices and supervisory oversight has been instituted. Station and
maintenance management has communicated their expectations relative to acceptable
work standa~ds to the engineers, supervisors, and planners during group meetings.
A continuation o*f these meetings at the worker level is p 1 anned in the near
term.
The work practices improvement plan consists of work practice standards
and procedure use guidelines which include supervisor responsibilities; house-
keeping, documentation and safety requirements; and guidance on procedure
compliance and attention to detail.
The structure of daily plannirig meetings
has enhanced communications between operations and maintenance supervisors
relative* to timely return of equipment to* service.
Daily planning meetings were effective in communicating management philosophy,
including the priority of the operating unit over outage activities.
The
transfer of work and plant status information between departments, and the
scheduling and coordination of activities were generally effective,
Planning
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-16-
and prestaging for the refueling outage was aggressive during the SALP period.
The use of outage shift managers and containment coordinators was a strength,
in that this increased level of oversight of outage activities in the field
assured that problems were resolved in a timely _manner.
Maintenance planning and execution of several major unscheduled activities
such as the repair of a service water piping pressure tap, replacement of main
power transformers, repair of a component cooling water leak in containment
and replacement of containment spray piping were well coordinated and
controlled.
Since the implementation of licensee actions was continuing at the end of the
SALP period, full assessment of the effectiveness of these actions could not
be made.
However, an improvement in supervisory oversight and the
administrative control and content of work packages has been noted.
Inconsistencies with regard to procedure establishment and use continue to be
observed.
Maintenance personnel are experienced and knowledgeable.
However,
continued management effort in communication and implementation of the work
practices improvement plan elements including holding the work force
accountable is needed to* ensure an improved level of performance in the
maintenance area.
Surveillance:
In the surveillance area, personnel errors involving failure to follow
procedures, inadequate supervisory oversight and poor communication continued
to be a weakness and resulted in a significant number of reactor trips and
missed surveillances during the SALP period.
-
Six reactor trips were caused by personnel failure to follow procedures and
inattention to detail during maintenance/surveillance activities, three
involving maintenance personnel.
There was an increase in the number of
missed or late Technical Specification surveillance tests during the SALP
period attributable to personnel errors or poor administrative controls. This
is partly attributable to inaccurate or incomplete information inputs to the
computerized maintenance and surveillance tracking system, Managed Maintenance
Information System (MMIS).
Several missed TS surveillance tests were identified
as a result of increased scrutiny of the surveillance program by the licensee.
One of these resulted in an emergency TS change.
resulted.from maintenance personnel errors. Missed or late surveillances
caused by other station groups such as operations and chemistry are discussed
in the appropriate functional area section.
The licensee has initiated several programs to enhance surveillance scheduling
and tracking and ensure surveillances are completed as required.
These
include the Technical Specification* (TS) coordination project instituted to
validate the MMIS database and surveillance procedu~~s relative to TS
surveillance requirements.
Several discrepancies including TS surveillances
not historically performed or performed at an improper frequency were
identified and corrected as a result of this project. A surveillance
.
coordinator was assigned within the technical department to maintain the MMIS
database, to develop, review and issue scheduling information and to monitor
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-17-
the. overdue list in an effort to prevent missed surveillances.
An upgrade of
the gauge calibration program was completed at the end of the assessment period.
Procedures to implement and control the program were being developed. As these
corrective actions are being developed and implemented, surveillances have
continued to be missed indicating*that corrective action implementation was
not timely or fully effective. Continued management attention* is needed in
this area to ensure timely, effective implementation of corrective actions
including proper oversight, scheduling and coordination of surveillance
activities.
In summary, reduced management and supervisory oversight of maintenance
activities resulted in a laxness in the implementation of the maintenance
program.
A new maintenance manager has been assigned and a work practices
improvement plan was instituted which resulted in some improvement in
execution of maintenance activities late in the period.
Outages were well
planned and controlled.
Personnel errors in the surveillance area resulted in
an increase in the number of reactor trips. Although the missed or late
surveillances did not result in safety significant problems, the long-standing
nature of the problem and the inability to promptly correct the problem
indicates a weakness in management attention to this issue.
Increased
management. action is needed to ensure proper oversight, scheduling and
coordination of surveillance activities.
IV.C.2
IV.C.3
IV.D
IV.D.1
Performance Rating
Category 2
Recommendations
None
(305 hours0.00353 days <br />0.0847 hours <br />5.042989e-4 weeks <br />1.160525e-4 months <br />, 9%)
Analysis
There is a consolidated Emergency Plan for the Artificial Island complex,
including the Salem and Hope creek facilities.
Consequently, the assessment
of emergency preparedness is a combined evaluation of both facilities'
. emergency response capabilities.
. . .
.
.
The previous SALP rated Emergency Preparedness as Category 1.
The licensee
had demonstrated strong emergency response capability during the Hope Creek-
based exercise.
No exercise weaknesses or areas for improvement were
identified.
There was no Salem-based exercise.
The licensee had maintained a
strong management awareness of and commitment to emergency preparedness.
One
weakness was identified regarding the adequacy of the Salem staff res~unse to
pager call-in tests.
During this assessment period, a Salem based full-participation exercise took
place which involved Delaware and New Jersey. It included an ingestion
pathway response in New Jersey.
There was no full-scale exercise for Hope
Creek.
Two routine emergency preparedness inspections were conducted and the
Resident Inspector observed several training drills .
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i
-18-
During the full-participation exercise two weaknesses were identified by the
NRC.
One weakness involved the fact that the Control Room and Technical
Support Center staffs did not recognize postulated containment failure for an
hour and forty minutes.
The other weakness involved a communication problem;
the Emergency Response Manager did not inform the Emergency Operations
Facility staff that recovery conditions had been attained;
In addition,
several other areas of lesser significance were identified.
Remedial drills
demonstrated effective corrective action for all identified exercise
weaknesses with one exception, recognition of containment failure, which will
be evaluated in a future exercise.
In other areas, corrective actions have been completed regarding pager call-in
response.
Management also responded to NRC concerns and took steps to improve
the quality of dose projection calculations and field monitoring techniques.
Sixteen Unusual Events (UEs) were declared during this assessment period.
Licensee response to the events was generally in accordance with procedures;
however, some areas for improvement were identified.
Two similar events at
Salem were classified differently (one as a LIE and one not classified),
indicating inconsistent interpretation and use of EAL classification
procedures by the operators.
The procedures have been revised to provide
clarification.
On two other occa~ions, inaccurate or incomplete information
was provided to the NRC Headquarters Operations Offiter. A Hope Creek UE was
declared 45 minutes after the event had begun.
Management recognized the need
for corrective action in these cases and reemphasized to the Senior Reactor
Operators the importance of prompt, accurate declarations.
A reorganization placed the Emergency Preparedness Department in the Nuclear
Services Department, which is intended to enhance corporate involvement in
this area as the Nuclear Services Department General Manager (GM) has an
operations and emergency .response background. and has maintained close contact
with the emergency preparedness program (EPP).
Corporate management involvement*
and interest in this area was evident by the considerable amount of effort by
the on site Vice. Presidents devoted to emergency preparedness issues, including
off-site interface~. Support of and cooperation with the states remained at a
high level.
One new staff position, requiring a radiation protection
background, was added to emergency preparedness.
Two senior reactor operators
are to be assigned full time to the EPP staff.
Emergency P'reparedness Training* (EPT) was a collaborative effort between EPP
and the Training Department (TD).
The TD was changing its approach to EPT:
additional trainers are being qualified; a modular methodology based on Job .
Task Analysis will be used to ensure trainers have an adequate understanding
of emergency response organization staff needs; and the frequency of weekly
training drills has been revised to one for each site ever;1 two weeks (on a
trial basis). At least three persons were qualified for each position in the
Emergency Response Organization.
The licensee recently affirmed that the Salem Technical Support Center (TSC),
an interim TSC per the Salem Unit 2 License, has not met NRC design require-
ments regarding ventilation. This is a condition which has existed for eight
years.
The licensee committed to resolve the deficiencies by October 1989.
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-19-
Under the current situation, in the event TSC evacuation is required due to
uninhabitability, the Salem TSC staff will relocate to the Hope Creek TSC.
In most areas the licensee demonstrated a high level of interest and
involvement in maintaining emergency response capability:
the licensee had an
excellent Rumor Control organization, which could be manned by about 300
people on two shifts;
an upgraded route alerting mechanism was developed; and
a VHS tape was developed to train offsite workers in radiological
self-protection. Siren ava.ilability was 98.5%.
Ten independent, redundant
and diverse offsite communication systems were in place.
The Emergency News
Center (ENC) was located about 7.5 miles from the site. Although it was not
required, an alternate Emergency News Center has been identified and logistics
arranged to support activation, if necessary.
In summary, the licensee maintained a good Emergency Preparedness Program.
Management remained involved, was reasonably responsive to NRC concerns, and
maintained an adequate staff for the Emergency Response Organization.
An
effective training program has been maintained.
Salem staff performance
during the annual exercise was not at the same high level as that noted in the
previous Hope Creek exercise; however, it was acceptable.
There were isolated
event classification problems.
The licensee's corrective actions with regard
to resolving Salem TSC operability concerns are scheduled to be completed by
October 1989.
IV.D.2
Performance Rating
Rating:
Category 2
IV.D.3.
Recommendations
None
IV.E
Securitl'.
(2Q9, hours, 6%) .*
IV.E.1
Analysis
One security program covers Salem and Hope Creek, and the protected areas and
security sta-ffs overlap. Accordingly, this assessment of security applies to
both
sites~,**
- *
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The previous SALP rated the Salem and Hope Creek security program as
Category 1.
This rating was largely influenced by management's attention to
and involvement in the program, an effective self-appraisal program, a clear
understanding of NRC security objectives and a good enforcement history.
Management's attention to, and involvement in, assuring the implementation of
an effective security program remained evident*.
The licensee was very
effective in maintaining good support for the security program from other
functional groups at both stations.
Frequent organization interactions and
good working relationships were apparent from the professional* attitude of
employees toward the security program, as well as the attention given by the
maintenance group to the prevention and correction of problems with security
systems and equipment.
.. . **.**.' .: *.;** .-**.*-;**.
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-20-
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 yearly
training course given by the licensee on regulatory and security program
requirements and objectives.
In addition, security management continued to
participate in- the Region I Nuclear Security Organization and in other nuclear
industry groups engaged in nuclear security related matters.
The licensee also continued to implement a self-initiated appraisal program
carried out by security management and supervisory personnel.
Adverse
findings were promptly resolved and provided to training personnel to factor
into the training program to prevent their recurrence.
The appraisal program
is in addition to the NRC's required annual program audit that is conducted by
quality assurance personnel.
The last annual audit was very 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 demonstrated the licensee's desire to
implement an effective and quality security program.
During this assessment period, the licensee appointed a new site security
manager. The new security manager was promoted from within the existing
organization, and the tran$ition went smoothly which was indicative of good
planning and effective management.
,
The security force contractor had effective management as was evidenced by
continuous_ onsite contractor management, steps taken to improve the security
program (e.g., employee benefits, training aids, and better equipment), and
the low turnover of personnel (about 7%).
The contractor also implemented
changes to its supervisory structure, which eliminated duplicate supervisory
positions between the licensee and the contractor.
Staffing of the security organization appeared adequate, as evidenced by a
limited use of overtime and a low backlog of work.
The installation and
maintenance of some state-of.;.the-art systems and equipment during this period
significantly reduced .the use of compensatory posts for systems and equipment
failure and~ thus, reduced the need for extensive overtime.
Both the
licensee's proprietary supervisors and the contractor's supervisors were well
trained and experienced, and exhibited a conservative and positive attitude
toward security. Sec;uri ty force personne 1 were also we 11-tra i ned and"'
exhibited 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 was another indicator of the licensee's desire to implement a
quality security program.
It was also reflected by the generally excellent
state of cleanliness in all security facilities.
The- training and requalification program was well developed and carried out by
a Training Administrator and two full-time instructors.
In addition to
initial and requalification training, on-the-job performance evaluations were
conducted which test the proficiency of individuals on general and specific
security program requirements.
The on-the-job performance evaluations
provided management the ability to review and enhance the performance and job
knowledge of security personnel and to correct deficiencies as they were
-21-
detected.
This was another- initiative that was indicative of the licensee's
desire to implement an effective program.
Several minor deficiencies were identified that were promptly and effectively
corrected.
The licensee's good enforcement record during this period is
attributed to management's involvement in the security program, the continuing
self-appra.isal program, comprehensive annual audits, and the security training
program.
The licensee submitted three security event reports pursuant to 10 CFR
73.71(c) during the assessment period.
One report involved an inadvertent
tailgating incident and the other two reports involved security guards who
were i nat.tent i ve to duty.
The 1 i cen see 1 s actions were prompt and effective in
each case.
During this period, the licensee also developed a program to
minimize the recurrence of inattentive guards; the program includes limiting
overtime and conducting organized discussions on topics such as proper
nutrition and physical fitness.
An NRC Safeguards Regulatory Effectiveness Review (RER) of the Island reviewed
the protected area boundary and identified several potentia-1 weaknesses
associated with the Salem facility due to older equipment that the licensee,
had planned to replace.
The licensee was responsive to the RER findings and
implemented short-term corrective measures where necessary.
However, several
of the potential weaknesses were readily apparent to members of the RER team
and should have been identified and corrected by the security organization.
The licensee submitted one change to the contingency plan under 10 CFR
50.54(~). This change was made to provide clarification to certain areas in
the plan. __ This was indicative of the licensee desire to provide its security
force with unambiguous instruction;
The change was clear and fully described
the issues.;* Prfor to.the*submitta-1 of this change, the licensee discussed the
change with Region I safeguards personnel at a licensee requested meeting.
In summary, the licensee continued to imp*lement 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.
IV.E.2
IV.E.3
Performance Rating
Category 1
Recommendations
None
IV.F
Eng*int!ering/Technical Support
(274 hours0.00317 days <br />0.0761 hours <br />4.530423e-4 weeks <br />1.04257e-4 months <br />, 8%)
IV.F.l
Analysis
The last SALP rated the engineering support area as Category 2.
The
assessment identified NRC concerns in management support and overall quality
,* *C*"*".*
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-22-
in the engineering and technical support area.
The last SALP also indicated
that the licensee had initiated some long term corrective actions to address
these concerns.
During this SALP period, significant changes within the engineering department
have been effected.
These changes are intended to improve engineering's
interaction with the station staff. They included a project matrix organiza-
tion, a new design change control process, and establishing a new relationship
between the engineering organization and the plant staff. The newly defined
performance based relationship between the engineering (service provider)
organization and the plant staff (client) appeared to work well and increased
the effectiveness of engineering support by better prioritization of work.
Senior engineers, designated as Project Managers, coordinated and were
responsible for design changes and modifications from inception to completion.
This concept resulted in enhanced personnel accountability, in improved
design change control, and in better project development and implementation.
The implementation of the organization and project management concept in the
engineering department allowed the licensee to effectively schedule large
multidisciplinary projects. This approach also allowed the staff to be avail-
able through the ur.it supervisors to work on smaller projects. This flexibility
combined with the system ~ngineers provided better coverage for the entire plant.
The plant staff involvement in projects was assured by the system engineers and
QA personnel on the project team.
Examples of the effectiveness of the changes described above include; recovery
from a service water bay flooding event, resolution and prevention of reactor
head pen~tration leaks in both units, and resolution of cracks in the bodies
of containment spray test isolation valves.
The licensee's actions in
addressing and resolving these issues were well planned and organized,
engineering evaluations and root cause analyses were technically sound, and
implementation of corrective actions were timely and well controlled.
A pre-established workbook approach to design change package (DCP) development
was initiated.
The new design change procedures and checklists provided
b~tter configuration management controls.
The supporting information within
these packages appeared to be effective in providing appropriate aid to
installation in the field.
T-his initiative was an improvement over the old,
- less formal process;
Early in the SALP period, the NRC's outage team
inspection of the Unit 2 refueling outage identified implementation problems
in th~ new design change process.
Poor implementation resulted in numerous
comments generated during QA review of DCPs, rejection of some DCPs by SORC,
and concerns identified in NRC inspections regarding outage DCPs.
Problems
included inadequate or incomplete safety evaluations, inconsistencies between
checklists, and missing review and approval signatures.
The licensee's
handling of safety evalu<:1Hons (10 CFR 50.59 reviews) exhibited a lack of
preciseness and attention to detail.
Design analyses for potential
consequences of system or component failures were also noted to exhibit
weaknesses.
For example, during the Unit 2 outage team inspection, NRC
identified that the design change which. moved the low power trip bypass set-
point (P-9) from 10% to 50% power failed to examine potential consequences of
system or component failures.
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-23-
During the transition, the problems noted above were largely the result of
confusion due to the dual systems of design control (old procedure and new
procedure) and a lack of training and experience in the new system.
A
majority of modifications and other design changes had been processed through
. the old procedures, but were being implemented under the new system.
Also,
the requirements of* new.procedures were not very well disseminated to affected
personne 1 . A 1 though these prob 1 ems may be a.ttri buted to growing pains, the
number of problems identified and the lack of prompt action by management to
identify and resolve the root cause of these problems was of concern.
Subsequently, enhanced training was provided to engineering personnel
regarding the new design change procedures, and the importance of attention to
detail. A pre-SORC review of completed DCPs by a board composed of engineering
managers was also instituted. The improved quality of Unit 1 refueling outage
DCPs reviewed at the end of the SALP period indicated that these corrective
actions were effective.
The Engineering and Plant Betterment (E&PB) staffing was generally adequate.
The plant staff managed approximately 65% of the present workload, and
contractor personnel were used for the balance of the work.
The staff was
competent and knowl edgeab 1 e in their areas of responsibility.
The licensee
strongly supported participation in industry, owners* groups, and professional
societies in order to evaluate and develop program enhancements.
In addition,
licensee initiatives in performing safety system functional reviews and
reconstitution of the design basis documentation indicated a commitment to self
improvement in these areas.
Various me~ting~ provide adequate communications for management control of the
many projects and tasks in E&PB.
Individual communications between project
team memb_ers and the Project Managers appeared satisfactory for accomp 1 i shi ng
the major projects.
However, equipment failures (.vital inverters) and system
design problems (reactor protection system and feedwater regulating valves)
have co~tributed to reactor trips. Modifications and upgrades for these
problems which were in progress during the assessment period were in some
cases not implemented* in- time to prevent recurrent trips.
The strong support provided by the on-site sy~tem engineers in support of
day-to~day activities was noted during the last SALP period. Aggressive
involvement and technical guidance with respect to troubleshooting and
resolution of identified problems by the systems engineers was also noted
during this SALP period.
Exa~ples incl~de; the development of a comprehensive
test procedure to verify.operability of the diesel generator that had been
synchronized out-of-phase with the grid, providing conservative technical
guidance to operators regarding a reactor coolant pump seal leak, investiga-
tion of various MSIV discrepancies, and prompt identification and resolution
of a transformer combustible gas problem.
A noted exception, however, is the
steam generator steam flow- indication discrepancies, a long-standing issue
that has not received adequate management o~engineering attention.
The continued effective interface between reactor engineering and the
operations staff was evident during startup testing from refueling.
The
control room operators were kept informed by the reactor engineer as to the
intent, direction, and the overall status of the ongoing tests.
The Nuclear
Fuels Group of the E&PB organization provided strong support throughout the
testing by providing personnel and analytical test criteria.
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-24-
The licensee's program to control the performance of-inservice inspection
(!SI) in accordance with ASME Section XI is a strength, in that; program
changes are documented after review and approval by appropriate personnel, and
plant modifications are reviewed for !SI program requirements.
The
appropriate level of mana~ement is involved i~ the eval.uation and resolution
of examination results.
In summary, the engineering support organization, design change control, and
communications between plant and corporate engineering have improved.
System
engineering continued to be a noteworthy strength.
However, there were
implementation problems with inconsistent or missing information in DCPs and
inadequate safety evaluations during this SALP period.
These problems were
evaluated by the licensee and are in the process of resolution.
These
licensee initiatives appear to be well directed and capable of enhancing
engineering support to the plant.
IV.F.2
Performance Rating
Category 2; Improving
IV.F.3
Recommendations
None
IV.G
Safety Assessment/Quality Verification
(155 hours0.00179 days <br />0.0431 hours <br />2.562831e-4 weeks <br />5.89775e-5 months <br />, 4%)
IV.G.l
Analysis
This new functional area combines the previous functional areas of Licensing
Activi.ties and Assurance of Quality-.. This area assesses the effectiveness of
the licensee's programs provided to assure the safety and quality of plant
operations and activities.
During the previous SALP period, the licensee was evaluated as Category 2 in
Licensing.
The SALP noted a weakness in schedular planning which resulted in
late submittals and responses.
Licensing staff technical capability and the
thorough and effective manner in which the licensee responded to safety issues
were noted as strengths in the licensing area.
The licensee was evaluated as
Category 1 in the Assurance of Quality functional area during the previous
SALP period.
In general, licensee initiatives and programs to assure quality
were comprehensive and effective.
However, the SALP concluded that
improvements in chemistry laboratory QA/QC and the quality of licensee
engineering processes were needed.
During thi~ assessment period, the licensee generally: approached technical
issues from a safety perspective and were responsive to NRC initiatives.
However, delays in licensee recognition of the impact of planned activities
such as the CROM clamp installation and steam generator tube plugging on
regulatory requirements resulted in untimely submittals.
More than occasional
expedited NRC review and approval was needed.
Licensee responsiveness to"
requests for information such as TM! Action Plan status was very good.
-
-25-
Thirty-eight licensing actions were processed during this assessment period.
In addition, considerable effort was made by the licensee to reduce the
backlog-of pending license amendment requests. Although staffing levels
appear adequate, the quality of new licensee submittals was inconsistent, both
from an administrative and technical perspective.
For example, Appendix R
exemption requests and the CRDM clamp submittal were comprehensive and
technically adequate, while others required communication with the licensee to
resolve questions and concerns that were not addressed adequately in the
submittals.
For example, one amendment request was rejected because the
content deviated significantly from NRC published guidance and adequate
justification for the deviations was not provided.
Numerous inaccuracies in
proposed Technical Specification revision submittals were observed and
corrected.
The licensee was cooperative and very responsive in resolving each
of the administrative and technical concerns.
At the end of the assessment
period, improvement in the quality of some new licensee submittals was noted.
Continued management attention is required to assure sustained improvement in
the technical and administrative quality, as well as the timeliness of
submittals.
The presence* of Corporate VPs andthe station general manager on site was
observable.
They were generally involved in site activities.
The station
staff was experienced and adequately trained.
However, assessments in
operations, surveillance and radiological controls indicated that management
did not hold the work force accountable for the expected level of performance
and that some programs were not effectively implemented.
Management.1 s recognition a~d acceptance of these problems later in the
assessment period led to the development and implementation of programs to
communica..te management expectations; review and correct programs, procedures
and policies;*and improve personnel* performance.
These programs included a
Technical Specification. surveillance v~rification project, work practices
improvement program, procedures upgrade program, safety system functional
reviews, and a third party assessment of the 10 CFR 50.59 safety evaluation
process.
In addition; the*station QA group instituted a performance-based
surveillance program* including backshift activities which provided station
management with a method to evaluate the effecti.veness of program implementation.
During the development and* implementation of ihose initiatives, recurrent
examples of inattention to detail, procedure noncompliance and deficient work
practices were exhibited, and indicated a continuing need for management*
attention and action in assuring quality performance.
There were inconsistencies in the level of station management attention and
control relative to planning and implementation of corrective actions in
response to plant events or problems.
Examples of well controlled and
executed activities accomplished during the assessment period include the
.station's investigation of the service water bay flooding event and the
containment spray piping replacement.
In contrast, activities associated.,wi.th
the auxiliary building ventilation charcoal replacement and testing; and steam
generator steam flow indication discrepancies exhibited a reduced level of
management attention, control and effectiveness.
-.
. .
~ .. -'. *.**** -. ,..
-26-
Station Operations Review Committee (SORC) reviews of reactor trips, plant
events, and engineering design change packages were generally thorough and
usually displayed an acceptable level of understanding of technical issues.
However, on several occasions the SORC and station management authorized unit
restart based dn the replacement of suspect components or the completion of
actions based on supposed problems without substantive *evidence that all
possible causes had been identified or would be resolved.
Onsite Safety
Review Group (SRG) post-trip reviews and other investigations of these and
other instances were of high quality and made good findings and
recommendations.
Station responsiveness to these findings was not
particularly effective early in the SALP period, but was observed to be
improving later. The onsite safety review group also performed safety system
functional reviews, problem area reviews, and root cause investigations which
provided thorough and meaningful information for management action.
In
addition, the licensee has instituted a Human Performance Evaluation System to
enhance root cause analysis of personnel errors.
Continued management focus
on root cause determinations is needed.
Quality Assurance department audits and surveillances were of sufficient depth
to make meaningful evaluat.ions of the activities audited.
The quality of
the offsite safety review group's unresolved safety question reviews was
acceptable.
The lack of timeliness in responding to and resolving QA and
safety review groups' findings and recommendations by the station was a
continuing ~oncern. In addition, a violation was issued for the failure to
correct or prevent recurrence of QA identified material control nonconformances.
In general,. Corporate and station. management enhanced the attention and
importanc~ giv~n to the resolution of action items, and some improvement was
noted toward the end of the SALP period.
Licensee -responsiveness to previously identified weaknesses in the chemistry
laboratory QA/QC program resulted in the implementation of improved
calibration techniques and procedures, and an overall satisfactory level of
performance in this area during this SALP pe~iod.
In summary, licensee management generally displayed an adequate safety per-
spective. Continued management attention is needed to assure conststency. in the
quality and timeliness of license* submittals. A need for improved quality per-
formance and personnel accountability was recognized by licensee management
during the assessment period~ Enhanced management communication and corrective
action programs have been developed and were in various stages of implementa-
tion at the end of the assessment period.
Some improvements were noted as a
result of management efforts.
However, completion of the improvement programs
and continued management oversight of program implementation is necessary to
resolve the deficiencies in quality.
IV.G.2
Performance Rating
Category 2
IV.G.3
Recommendations
None
..
- -~----
- .-**:*
27
SUPPORTING DATA AND SUMMARY
A.
Enforcement Activity
Number of Violations by Severity Level
Functional Area
v
IV
III
II
I
Plant Operations
5*
Radiological Controls
4
Maintenance/Surveillance
1*
Security
Engineering/Technical Support
1
Safety Assessment/Quality
1
Verification
Totals
1
10
- Violation cited three examples, two were in operations and one in
maintenance/surveillance functionaT areas.
An enforcement conference was held with the licensee on September 29, 1988 to
discuss environmental qualification violations. A civil penalty resulted from
the violations.
B.
Inspection Hour Summary
Plant Operations
Radiological Controls
Maintenance/Surveillance
Security
Engineering/Technical Support
Safety Assessment/Quality
Verification
Totals
Actual
1437
503
648
305
209
274
155
3531
Annualized
Hours
958
335
432
203
139
183
103
2353
- Does not include NRC licensing staff hours.
Percent
- .,*.
41
14
18
9
6
8
4
100%
~28-
c.
Licensee Event ReEort Causal Analysis
Functional Area
A
B c
D
E x
Total
Operations
16
4
8
4
32
Radiological Controls
4* 1
1
6
12
Maintenance/Surveillance
5
6
1
1
13
Security
3
3
Engineering/Technical Support
2 6
1
3
1
13
Safety Assessment/Quality
Verification
Totals
30' 7
0 12
18 6
73
Includes Unit 1 LERs 88-01 through 88-20 and 89-01 through 89-15 and Unit 2
LERs 88-01 through 88-26 and 89-01 through 89-09, and security events 88-01
through 88-03
Cause Codes*
TyEe of Events
A.
Personnel Error ..... .
B.
Design/Man/Constr./Install .
C.
Exterha~ Cause ...
D.
Defective Procedure.
E.
Comp9nent Failure.
X.
Other~ .....
Total.
30
7
0
12
18
6
73
- Root causes assessed by the SALP* Board may* differ from those 1 i sted in the
LER.
The following common mod~ ~vents were identified:
Sixteen LERs discussed reactor trips, twelve discussed missed or late
surveillance tests, ten reported TS 3.0.3 entries for inoperable equipment (5
service water related, 3 steam flow channel inoperable, 1 resulted in
shutdown), nine discussed missed TS action statement requirements (4 chemistry
samples, 5 firewatch), eight reported radiation monitoring system equipment
related problems and six discussed system design related deficiencies.
- .-:. ..
_
Attachment 1
SAU> CRITERIA
Licensee performance is assessed in selected functional areas, depending on
whether the facility is in a construction, or operational phase.
Functional
areas normally represent areas significant to nuclear safety and the
environment.
Some functional areas may not be assessed because of little or
no licensee activities or lack of meaningful observations.
Special areas may
be added to highlight significant observations.
The following evaluation criteria were used, as applicable, to assess each
functional area:
1.
Assurance of quality, including management involvement and control;
2.
Approach to resolution of technical issues from a safety standpoint;
3.
Responsiveness to NRC initiatives;
4.
Enforcement history;
5.
Operational and construction events (including response to, analyses of,
reporting of, and corrective actions for);
6.
. Staffing (including management); and
7 .. Effectiveness of training*-and qualification program.
On the basis of the NRC assessment, each functional area evaluated is rated
according* to three performance categories.. The definitions of these
performance categories are:
Category 1:
Licensee management attention and involvement are evident and
place emphasis on superior* performance of nuclear safety or safeguards
activities, with the resulting performance substantially exceeding regulatory
requirements.
Licensee resources are ample and effectively used so that a
high level of plant and personnel performance is being achieved.
Reduced NRC
attention may be appropriate.
Category 2:
Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities is good.
The licensee
has*attained a level of performance above that needed to meet regulatory
requirements.
Li~ansee resources are adequate and reasonably allocated so
that good plant and personnel performance are being achieved.
NRC attention
should be maintained at normal levels.
_ .. * ... *.
. *'* **. . .
.*:*.;:* :** ..... *:
.. * . '
- .
- .* .* .. -*
..*, .-*.
'..I'
- ,
- , .
-- _.
---~ ~ -
.:______ * __ ,.:__c .___ ***
. ' i
- .' ..
1;J
Attachment 1
-2-
Category 3:
Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are not sufficient.
The licensee's performance does not significantly exceed that needed to meet
minimal regulatory requirements.
Licensee resources appear to be strained or
not effectively used.
NRC attention should be increased above normal levels.
The SALP Board may assess a functional area and compare the licensee's
performance during a portion of the assessment period to that during an entire
period in order to determine a performance trend.
Generally, performance in
the latter part of a SALP period is compared to the performance of the entire
period.
Trends in performance from period to the next may also be noted.
The
trend categories used by the SALP Board are as follows:
Improving:
Licensee performance was determined to be improving near the
close of the assessment period.
Declining:
Licensee performance was determined to be declining near the close
of th~ assessment period and the _licensee had not satisfactorily addressed
this pattern.
A trend is assigned only when, in the op1n1on of the SALP Board, the trend is
significant enough to be considered indicative of a likely change in the
performance category in the near future.
For example, a classification of
"Category 2, Improving" indicates the clear potential for "Category 1
11
performanc*e in the next SALP period.
It should. be noted that Category 3 performance, the lowest category,
represents acceptable, although minimally adequate, safety performanca.
If at
any time the NRC concluded that a licensee was not achieving an adequate level
of safety performance, it would then be incumbent upon NRC to take prompt
appropriate action in the interest of public health and safety.
Such matters
would be dea-lt" with independently from, and on a more urgent schedule than,
- the SALP proce.s s.
It should be also noted that the industry continues to be subject to rising
performance expectations.
NRC expects each licensee to actively use
industry-wide and plant-speci-fic operating experience in order to effect
performance improvement.
Thus, a licensee's safety performance would be
expected to show improvement over the years in order to maintain consistent
SALP rp.tings.
. . . . '
'" -*
- ... *;*_:-
- ..
.-.. _:
~.: ... _."*-~';:: ...