ML18095A524
| ML18095A524 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 10/09/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18095A523 | List: |
| References | |
| 50-354-89-99, NUDOCS 9010180103 | |
| Download: ML18095A524 (75) | |
See also: IR 05000354/1989099
Text
ENCLOSURE
INITIAL SALP REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
REPORT NO. 50-354/89-99
PUBLIC SERVICE ELECTRIC AND GAS COMPANY
HOPE CREEK GENERATING STATION
ASSESSMENT PERIOD:
MAY 1, 1989 - JULY 31, 1990
BOARD MEETING DATE:
SEPTEMBER 19, 1990
9010180103 901009
~DR
ADOCK b5000272
Q
I.
INTRODUCTION . . .
II.
SUMMARY OF RESULTS
A.
Overview ...
TABLE OF CONTENTS
B.
Facility Performance Analysis Summary
III. PERFORMANCE ANALYSIS ...
1
3
3
4
5
A.
Plant Operations .. *.
5
B.
Radiological Controls
8
C.
Maintenance and Surveillance. . . .
.
.
.
.
10
D.
Emergency Preparedness (Common With Salem) ...... 15
E.
Security and Safeguards (Common With Salem)
17
F.
Engineering and Technical Support . . . . .
19
G.
Safety Assessment and Quality Verification.
22
IV.
SUPPORTING DATA AND SUMMARIES .....
A.
B. c.
D.
Licensee Activities.
. .....
Inspection and Review Activities.
Significant Licensee Meetings ..
Plant Trips and Unplanned Shutdowns
Table 1 - Inspection Hours Summary
Table 2 - Enforcement Summary
Table 3 - Licensee Event Reports Summary
Attachment 1:
SALP Evaluation Criteria
25
25
25
26
26
I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) is an integrated
NRC staff effort to collect observations and data to periodically evaluate
licensee performance on the basis of this information.
The SALP process
is supplemental to normal regulatory processes used to ensure compliance
with NRC rules and regulations.
SALP is .intended to be sufficiently
diagnostic to provide a rational basis for allocating NRC resources and to
provide meaningful feedback to the 1 icensee 1 s management to improve the
quality and safety of plant operations.
An
NRC SALP Boa rd, composed of the staff members 1 i sted be 1 ow, met on
September 19, 1990 to review the collection of performance observations
and data and to assess the 1 icensee 1 s performance at the Hope Creek
Generating Station. This assessment was conducted in accordance with the
guidance in NRC Manual Chapter 0516,
11Systematic Assessment of Licensee
Performance
11 *
This report is the NRC 1s assessment of Public Service Electric and Gas
(PSE&G) Co. 1 s safety performance at the Hope Creek Generating Station for
the period May l, 1989 through July 31, 1990.
The SALP Board for the Hope Creek Generating Station assessment consisted
of the following individuals:
Chairman:
C. Hehl, Director, Division of Reactor Projects (DRP)
Members:
R. Blough, Chief, Projects Branch 2, DRP
P. Swetland, Chief, Reactor Projects Section 2A, DRP
T. Johnson, Senior Resident Inspector, DRP
W. Butler, Director, Project Directorate I-2, Office of Nuclear Reactor
Regulation (NRR)
C. Shiraki, Project Manager, NRR
M. Knapp, Director, Division of Radiation Safety and Safeguards (DRSS)
J. Durr,
Chief,
Engineering Branch, Division of Reactor Safety (DRS)
Others in Attendance:
J. Stone, Project Manager, NRR
S. Dembek, Project Manager, NRR
S. Barr, Resident Inspector, DRP
S. Pindale, Resident Inspector, DRP
K. Lathrop, Resident Inspector, DRP
C. Anderson, Chief, Plant Systems Section, DRS
J. Jang, Senior Radiation Specialist, DRSS
2
Others in Attendance (Continued)
R. Nimitz, Senior Radiation Specialist, DRSS
J. Joyner, Division Project Manager, DRSS
W. Pasciak, Chief, Facilities Radiation Protection Section, DRSS
J. Noggle, Radiation Specialist, DRSS
C. Conklin, Senior Emergency Preparedness Specialist, DRSS
C. Amato, Emergency Preparedness Specialist, DRSS
R. Keimig, Chief, Safeguards Section, DRSS
R. Albert, Physical Security Inspector, DRSS
P. Ray, Operations Engineer, Performance Evaluation Branch, NRR
A. Almond, General Engineer, Director's Office, NRR
3
II
SUMMARY OF RESULTS
II.A Overview
PSE&G successfully operated the Hope Creek reactor in a safety conscious
manner, effectively completed their second refueling and maintenance out-
age, and exhibited excellent performance by support groups.
Strong licen-
see management involvement and oversight were evident in a 11 fun ct i ona l
areas, as was excellent performance at the worker and supervisory levels.
Strong and effective self-assessment by supervision, management and inde-
pendent assessment groups was noted.
Critical, technically sound problem
i dent if i cation, root cause analysis and corrective action programs were
also evident in all functional areas.
As a result, the plant operations,
radiological controls, and security/safeguards functional areas maintained
a superior level of performance.
In addition, the emergency preparedness,
engi neeri ng/techn i cal support and safety assessment/quality veri fi cation
functional areas achieved this high level of performance during this
period.
However, some isolated personnel errors persisted in most func-
tional areas.
The maintenance/surveillance functional area received the same SALP per-
formance rating noted during the last assessment period.
Improvements are
needed in worker attention to detail and procedural compliance, in the
spare parts procurement and material control programs, and in reactor trip
rate reduction.
Significant licensee corrective measures in this area
were evidenced and an
improving trend in this area at the end of the'
period was noted.
In summary, the licensee achieved an overall superior level of perform-
ance.
It is important that the licensee recognize the challenge to mai~
tain this performance level by continuing the aggressive, safety conscious
attitude and approach to nuclear, radiological and personnel safety, from
the worker level through corporate management.
II. B
4
Facility Performance Analysis Summary
Functional
Rating, Trend
Rating, Trend
Area
Last Period
This Period
Plant Operations
1
1
Radiological Controls
1
1
Maintenance/Surveillance
2, Improving
2, Improving
2
1
Security and Safeguards
1
1
Engineering/Technical
Support
2, Improving
1
Safety Assessment/
Quality Verification
2, Improving
1
Previous Assessment Period:
January 16, 1988 through April 30,
1989
Present Assessment Period:
May 1, 1989 through July 31, 1990
III
III.A
III.A.1
5
PERFORMANCE ANALYSIS
Plant Operations
Analysis
The previous SALP rated Hope Creek operations as Category 1.
That
assessment concluded that the operating staff continued to display a
conservative and safety conscious approach to plant operation.
There
was
an
excellent operating
record with
no
operationally caused
reactor scrams.
The operators were ski 11 ful and kn owl edgeab 1 e, and
properly responded to transients.
PSE&G
improved the support of
operations with increased staffing in both onshift and support roles.
The need for reduction in personnel errors rep.resented the primary
area for improvement.
During this assessment period, the reactor was operated in a conser-
vative and safety conscious manner.
Operators ski 11 fully performed
their duties during unit startups, shutdowns and transients.
There
were four reactor scrams during the period and none were caused by
operators.
However, two of these scrams occurred during main turbine
testing from the contro 1 room, and a reactor operator error contri b-
uted to one of these scrams.
Operator response to reactor scrams and
plant transients was exemplary.
In
sev~ral instances, prompt actions
by operators prevented plant transients and possible reactor scrams
due to *a feedwater heater isolation, a loss of instrument air event
and reactor feedwater pump trips.
PSE&G
has
committed resources to upgrade p 1 ant operations.
Each
operating shift continues to have three Senior Reactor Operator (SRO)
licensed individuals
(one
above Technical
Specification
require-
ments).
The operations staffing includes a pipeline into licensed
operator status to recover losses from attrition.
A separate SRO
1 i censed i ndi vi dua 1 supervises the work control group during regular
maintenance hours.
There are a
to ta 1 of 36
1 i cen sed operators,
including 25 onshift and 11 in staff and training positions.
Plant operations were adequately supported by the Training Depart-
ment.
Simulator refresher training on reactor startups continues to
be given to the ROs and SROs immediately before taking their shift.
Three of five SRO license candidates and four of four Reactor Oper-
ator (RO) candidates passed their initial license examinations.
The
RO/SRO requalification program was determined to be satisfactory with
four of four ROs and eight of ten SROs passing an NRC administered
exam.
The failure rate for these initial and requalification SRO
exams indicates weaknesses in licensee and candidate preparation.
6
Deficiencies also existed in methods for simulator evaluations, in
exam grading and in poor quality of licensee submitted exam material.
Licensed operators' plant awareness, safety perspective, and profess-.
ional control
room
demeanor w.ere
consistently evident.
However,
mi nor weaknesses were noted in the routine performance of periodic
contra l boa rd wa l kd.own s and with the procedures that establish the
requirements such as the a 11 owed contra l room mobility for the RO/
SRO.
For example, the SRO was a 11 owed to enter the computer room
where he would be out of sight of.control room alarms/indications.
The licensee was responsive to these NRC .concerns and adequately
addressed these mi nor weaknesses.
Pl ant opera ti ans were wel 1 sup-
ported by detailed procedures, and procedura 1 adherence was good.
Shift turnovers: were formal and inc 1 uded thorough briefings of the
relief crew.
Control room access was controlledi and activities were
limited to those directly related to plant operations.
A high number
cif lit annunciator alarms was noted upon
~he completion of a~d prior
to startup from the second refueling outage.
Aggressive management
attention resulted in significant reductions in these lit annuncia-
tors.
The use of overtime was properly controlled.
Good performance
of non-licensed equipment operators was noted during observations
made
on
pl ant tours, and *during eqlii pment testing and operation.
The licensee has implemented
revision~ to the emergency procedure
guidelines in their emergency operating procedures (EOPs).
The oper-
- ators effectively used the EOPs as evidenced by
observations of
actual plant transients and scrams, and *during simulator training.
Overa 11, the EOPs continued to be fully capable of performing their
intended purpose.
Strong plant management oversight and a.ttention to operations was
evident on a daily basis.
An operational perspective of plant prob-
lems and work prioritization was well understood and was enhanced by
daily meetings.
The licensee has been effective in ensuring good
interdepartmental
communication
and
in
resolving
problems.
The*
senior
nuclear
shift
supervisor
has
direct
access
to
plant
management.
Instances of personnel errors in Operations continued. *The- errors
were of minor safety significance, occurred during operational, main-
tenance
and
testing activities and were
committed by different
peop 1 e.
The errors were . most preva 1 ent during the outage peri ad
early in the SALP period.
Acceptable, appropriate corrective actions
were taken for each error.
Management meetings with each shift dur-
ing the refueling outage were held to ensure operators understood
III.A.2
III.A.3
7
expectations.
All operations related outage activities were stopped
during these meetings.
Safety, procedure compliance, proper brief-
ings and communications, and reversing the short term negative trend
in personnel errors were demonstrated to be more important to manage-
ment than meeting the outage schedule.
There were fewer errors in
the latter portion of this assessment period, and the frequency of
significant personnel
errors has decreased compared
to
previous
assessment periods.
PSE&G's aggressive approach has continued to
reevaluate previous corrective actions and the potential for addi-
tional corrective actions.
Plant housekeeping has improved during the period.
Plant area paint-
ing is nearing completion.
This activity has reduced the contamin-
ated floor space, particularly in the high pressure coolant injection
and reactor core isolation cooling rooms.
Equipment operators can
make their rounds with only minimal contamination protective cloth-
ing.
The assignment of housekeeping area responsibilities has been
effective in providing
11 ownership
11 of specific plant areas.
The overall fire protection program was effective.
Dedicated fire
protection personnel performed we 11
and were kn owl edgeab le, which
demonstrated an effective training program.
The fire brigade was
staffed by the Site Protection group personnel, which minimized the
reliance on operators to respond to fir~ and first aid related emerg-
encies.
Appropriate operator involvement in emergencies was pro-
vided.
The preventive maintenance and surveillances of fire protec-
tion equipment were effective.
Fire protection equipment upgrades
included a new ambulance, incident command vehicle, and other items.
Overa 11, pl ant and site management aggressively supported the fire
protection area.
In summary, the Hope Creek reactor was operated skillfully and in a
conservative and safety conscious manner.
Reactor operator error
contributed to one of four reactor scrams that occurred during the
period.
Strong management and supervisory oversight and involvement
occurred at all levels from the senior reactor operator through the
station general manager.
An aggressive approach by management has
been effective in reducing the number of personnel errors.
Senior
reactor operator failure rate during licensing and requalification
exams was higher than normal.
Performance Rating
Category:
1
Trend:
NA
Board Comments
None
-- ---- ---------------------------------,
III.B
III.B.1
8
Radiological Controls
Analysis
The previous SALP rated the functional area of radiological controls
as Category 1 and concluded that PSE&G maintained and implemented an
effective radiological controls program.
No significant weaknesses
were identified during the last assessment period.
During the current assessment period, the radiological controls pro-
gram continued to be effective and well managed.
NRC observations
throughout the period, which included the second refueling outage,
continued to indicate a good level of management involvement and con-
trol of the radiological controls program.
PSE&G supervisors and
managers actively observed ongoing work activities and plant condi-
tions through formal
review processes.
The
licensee's internal
review processes such as quality assurance audits and surveillances
and internal self-assessments provided effective oversight of program
activities.
The review processes were generally performance based
and used technical experts where appropriate.
The licensee's approach to the resolution of technical issues was
good as evidenced by the licensee's response to and resolution of
technical
problems associated with two
operational
events.
For
example, the licensee's response to a higher than expected crud burst
during refueling was appropriate and well managed.
In addition, late
in the assessment period the liquid radwaste processing system backed
up, causing overflows of several tanks into in-plant dikes.
The
licensee's technical review of the overflow event was extensive and
continuing at the end of the assessment period.
The overflows did
not result in any onsite or offsite radiological concerns.
This was
an isolated event, and the licensee's response to this event was
determined to be appropriate.
The licensee's enforcement history during the period was good.
No
NRC violations were cited.
The licensee effectively detected an
isolated problem with a High Radiation Area door being left open and
implemented
appropriate corrective actions.
PSE&G's
ability
to
self-identify and implement appropriate corrective actions remains a
strength.
Staffing throughout the period continued to be good, both for routine
operat1ons and outage periods. Well qualified personnel continued to
fill key positions within the organization.
Reliance on contractor
support was minimized by use of temporary support from the Salem
station and the corporate radiological controls group.
The staff,
including contractors, received appropriate training and qualifica-
tion testing to perform assigned tasks.
9
There were no unplanned external whole body radiation exposures dur-
ing the assessment period.
Engineering controls were effectively
used to control airborne radioactivity, and no significant intakes of
airborne radioactivity occurred during the assessment period.
Over-
all external and internal exposure controls were effective.
The licensee instituted several engineering changes to reduce ISI
personnel radiation exposure.
These changes are:
(1) the replace-
ment of cont rci l blade pins and ro 11 ers with others made of non-
ste l lite materials prior to startup; (2) the use of zinc injection to
reduce cobalt plate-out; and (3) the reduction of feedwater iron from
approximately 11.8 parts per billion (ppb) during the first fuel
cycle to 3-5 ppb during the second cycle.
The
station ALARA
(As
Low As
Reasonably Achievable) organization
effectively planned for outage radiological work activities.
Expos-
ure goals were reasonable.
initiatives,
such
as
use
of
robotics and video cameras were evident throughout the outage.
The
use of the computerized radiation work permit system in conjunction
with the automated dosimetry access contra l system was effective in
tracking and controlling exposure.
The licensee aggressively pur~ued
power reductions to minimize occupational exposure during steam plant
maintenance activities.
Also, an in-depth post-outage ALARA report
was developed to document strengths and weaknesses encountered during
the outage.
Areas for improvement were tracked to ensure resolution
prior to the next outage.
The licensee performed ALARA reviews for
outage work that accounted for about 90% of the aggregate exposure
sustained during the outage.
Overa 11, the licensee's efforts to
maintain
occupational
radiation
exposure
have
been
very
effective.
The radiological liquid and gaseous effluent monitoring and control
programs were effective.
Liquid
and
gaseous
effluent
sampling,
analysis, and reporting were good.
Air cleaning and effluent/process
radiation monitoring systems were well maintained, tested, and cali-
brated.
The
licensee's
effluent
control
training
program
for
technicians was very good.
An effective Radiological Environmental Monitoring Program was imple-
mented.
Sampling and ana lyt i cal procedures were upgraded, and an
effective QC program was in pl ace to assure the quality of sample
analysis.
The meteorological monitoring system was properly cali-
brated* and maintained.
Audi ts performed by the Quality Assurance
Division were thorough, and audit-identified deficiency items were
adequately resolved in a timely manner by the licensee.
III.8.2
III .8.3
III. C
III.C.1
10
The solid radwaste/transportation program continues to be very good.
The unique radwaste processing system (asphalt solidification and
dewatering system) has been effectively operated, with no incidents,
violations or problems at the disposal sites.
The quality assurance
(QA) program for radwaste was determined to be excellent with notable
strength in the area of QA surveillances.
The licensee 1 s training
program, especially for the Radwaste Operators, was excellent.
The
l icensee 1 s
performance with respect to NRC
standard chemical
measurements was good.
In addition, the results of the radiological
sample measurements comparisons indicated that all the measurements
were in agreement under the NRC criteria used for comparing results.
Disagreements initially encountered in the measurement of an air
particulate filter and
a
charcoal
cartridge
~ere resolved.
The
licensee's QA program for chemical and radiological measurements is a
noted strength.
In summary,
PSE&G continued to maintain and implement an effective
radio l ogi cal contra ls program.
Management support and oversight of
the
program were
good.
Overall
radiological controls, including
staffing, to support routine and outage work activities were good.
The licensee's initiatives in the ALARA area continue to indicate a
proactive approach to reducing aggregate exposure over the life of
the
plant.
Programs
such
as
radwa~te processing and
shipping,
effluent monitoring and control and environmental monitoring continue
to be well managed.
Performance Rating
Category:
1
Trend:
NA
Board Comments
None
Maintenance/Surveillance
Analysis
The last SALP rated the Hope Creek maintenance/surveillance func-
tional area as a Category 2, Improving.
That assessment concluded
that the maintenance organization effectively managed preventive and
corrective maintenance and was staffed with technically knowledgeable
and experienced personnel.
Strengths noted included an improvement
11
in the control of maintenance work as evidenced by the decrease. in
the number of maintenance-related reactor trips, and the adequacy and
detail of the plant 1 s surveillance test procedures.
The SALP noted
the reduction of the number of personnel errors and missed surveil-
lances as the areas requiring improvement.
Maintenance:
The Hope Creek maintenance program is well organized, and the licen-
see has demonstrated good performance in this area including overall
adherence to procedures in maintenance work, and appropriate over-
sight of maintenance activities.
Both unit and individual systems
availability have been maintained at a high level. Senior management
was noted to be directly and intimately involved *in plant maintenance
activities.
Management oversight has been effective through the
di re ct use of maintenance performance i ndi ca tors and a maintenance
tracking system.
Daily planning meetings demonstrated the ability of
plant management to adjust maintenance priorities and to review and
correct adverse trends. Additionally in this area, the licensee has
been acquiring risk assessment data to be used for prioritizing main-
tenance activities. This activity has only recently been in it i c;ited
at Hope Creek and is a positive indication of management 1 s safety-
conscious control of maintenance work at the plant.
The most significant strength of the maintenance organization is its
stab 1 e and we 11-tra i ned staff.
The maintenance work force operates
under the direction of good supervision, and utilizes proven mainten-
ance procedures.
The maintenance training program was effective and
demonstrated very well-defined qualification criteria for personnel.
However,
not a 11 maintenance personne 1 had comp 1 eted this forma 1
training program.
The training center continued to provide extensive
electrical and mechanical training facilities. Overall, the mainten-
ance staff was highly knowledgeable in their respective areas of
responsibility.
For times when the Hope Creek maintenance staff
needs to be supplemented, the licensee has established an effective
control for contracted maintenance personnel by using the Contractor
Control Sheet to track contractor personnel and their training,
indoctrination and qualification.
Maintenance faci 1 it i es were generally we 11 contro 11 ed, equipped and
maintained. The layout and utilization of these facilities were well
planned, organized and controlled throughout the plant to accommodate
the maintenance activities and the movement of materials and equip-
ment.
The administrative controls over procurement, receipt, inspec-
tion, storage and issuance of materials were generally adequate for
ensuring that maintenance materials were available when needed and
..
12
are issued properly for their intended use.
A weakness in ma i nten-
ante support activities was noted, however, concerning the availabil-
ity of replacement parts.
A slow requisition process resulted in a
large number of -routine maintenance requests being delayed because
they were awaiting parts.
At the end of the assessment period, the
licensee
had
recently dedicated additional
resources
with
sole
responsibility for material control to. improve performance in this
area.
The l icensee
1 s routine management oversight and feedback system has
worked well to assure safe and reliable plant operations.
A strength
of the system is the Managed Maintenance Information System (MMIS).
MMIS riot only provides a wide range of information, such as equipment
history, recurring task scheduling, real time job status and parts
inventory, but is widely used* by pl ant personnel , is easily access-
ible~ and usable.
During the assessment period, Hope Creek completed o_ne refueling and
several forced outages.
The maintenance planning and outage organ-
izations functioned well in scheduling all required tasks and coor-
dinating the team work required of the different work groups to
a~complish those tasks.
The unit uhderwent its second refueling out-
age during September through November 1989, with a 11 major efforts
successfully completed and without the ,occurrence of any maintenance
related safet~ system actuations br other significant incident~.
The
maintenance organization functioned effectively during a two week.
forced outage following
the March 19, 1990
reactor
With
little notice or preparation time, the maintenance department per.;..
formed successful repairs on a feedwater drain cooler that had been
isolated and had been preventing. the unit from operating at full
power.
S~veral events occurred during the period related to improper system
restoration following maintenance on the system.
One event occurred
in September 1989 and resulted in a core spray pump being operated
for 45 minutes with both the minimum fl ow and full fl ow test lines
isolated.
A second event occurred in June 1990 when a Reactor Water
Cleanup (RWCU) isolation was caused by an RWCU pump being started
with two discharge drain valves open, which resulted in a high rlif-
ferential
flow
signal.
Additional
examples
of
improper
system
restoration included the failure to reconnect the air supply to the
air operated drain valves, which contributed to the January 6, 1990
turbine and reactor trip, and a faulty ci rcul at i ng
water system
a 1 i gnment which resulted in
a
1 arge amount of salt water being
rel eased to and contaminating the 1 i quid effluent radwaste system.
The licensee received one maintenance-related violation during the
assessment period, resulting from several instances of maintenance
work*procedures not being properly followed.
Notwithstanding the weaknesse~ identified in this area, the licensee
has managed and performed a high number of maintenan~e acti~ities in
a commendable manner.
13
Surveillance:
The Hope Creek survei 11 ance program was conservatively and effec-
tively managed and
implemented throughout the assessment period.
Surveillance tests were scheduled and tracked effectively through the
MMIS, which provided good coordination of the Operations, Mai nten-
ance, Radiation Protection, Chemistry and Site Protection Departments
for the performance of the surveillance program.
This inter-depart-
ment coordination and cooperation were strengths of the Hope Creek
program.
Another asset of the surveillance program was the surveillance test
procedures themse 1 ves, which continued to be well written, accurate
and complete.
The procedure revision backlog noted in the previous
SALP report was eliminated during this SALP period, and the licensee
is now ~head of schedule in the required review of surveillance pro-
cedures.
An additional positive aspect of the surveillance program
is the implementation by the licensee of a policy whereby_ all _sur-
veillance procedures which affect safety system redundancy or initia~
tion -are performed on the night shift.
The policy* results in the
surveillances being performed in a more controlled atmosphere, with
fewer distractions for the test performer.sand the onshift plant
operators.
However, the policy is implemented only between May and.
September, primarily to reduce the risk of a plant scram during the
day when the electrical distribution grid is more strained.
Although the nu~ber of surveillance rel~ted incidents decreased from
- the pri'or SALP cycle, the predominant cause of the incidents con-
tinued to be personnel error; including inadequate admi.nistrative
contra ls.
Three survei 11 ance t_ests were missed during this SALP _
period, one* due to a computer malfuncti.on and two due to personnel
error.
Personnel error was also the attributable cause of the three
calibration* errors which occurred over the course of the assessment
period.
One calibration error resulted in an
engineered safety
feature actuation, whi 1 e another resulted , in a licensee i dent i fi ed,
Technical Specificatton violation.
The licensee took effective and
timely corrective action fo-r all six of these incidents, but atten-
tion to detail remained the primary area for improvement in the rou-
tine ~urveillance program.
Two rea.ctor scrams* occurred at Hope Creek during the SALP cycle dur-
ing surveillance testing.
In December 1989 and again in January
1990, the reactor scrammed due to a main t_urbine trip.
The first
scram was due to a main turbine thrust bearing wear detector failure,
and the second was ca!Jsed by a high water l eve 1 trip of a moisture
III.C.2
III.C.3
14
separator.
The root cause of the first event was management's fail-
ure to implement a modification recommended as a result of a previous
similar event.
The root cause of the second event included poor
calibration of the normal and emergency separator drain path controls
combined with an operator procedural noncompliance while the surveil-
lance test was being performed.
The licensee ultimately implemented
adequate corrective actions, yet this is another example of the need
for better attention to detail in the surveillance area.
The inservice inspection (ISI) program at Hope Creek was well admin-
istered and effectively implemented.
Staffing levels, including the
use of ISI contractors were good.
The licensee exhibited good con-
trol over ISI vendors, part of which was the performance of multiple
quality assurance surveillances of vendor activities.
A notable
strength existed in the licensee's ISI personnel and contractors who
were well qualified to perform ultrasonic testing of intragranular
stress cracking corrosion (IGSCC) susceptible piping.
Hope Creek has
been effectively operating plant equipment in a manner which achieves
optimum primary water chemistry which in turn is part of an overall
effort to reduce the susceptibility of austenitic stainless steel
piping systems to IGSCC.
Licensee management has also demonstrq.ted
an
active concern and sensitivity to efforts regarding personnel
exposure during ISI and surveillance activities.
ISI results have
been well documented, complete, easily retrievable, and able to be
trended by comparison with previous data.
In summary, the Hope Creek station has carried out successful main-
tenance and surveillance programs.
The programs have been adequately
scheduled, planned and implemented.
The strengths of the program lie
in management, a well-trained and experienced staff and good proced-
ures.
Weaknesses in the area continued to be found in the procure-
ment process, post-maintenance system restoration, and in the per-
sonnel errors which have contributed to the noted pl ant events and
Hope Creek's maintenance and surveillance program is a good
one, but improvements need to continue to resolve these weaknesses.
Performance Rating
Category
2
Trend:
Improving
Board Comments
None
III.D
III.D.l
15
Analysis
The Emergency Pl an for Art ifi ci al Is 1 and covers both Hope Creek and
Salem Nuclear Generating Stations, therefore the assessment of emerg-
ency preparedness is a combined evaluation of both facilities* emerg-
ency response capabilities.
During the previous SALP period, this area was rated Category 2.
This rating was based on weaknesses identified during a Salem based
full-participation exercise, some actual event classification prob-
lems, and delays in ensuring that the Salem Technical Support Center
could meet NRC design requirements.
Strengths noted included a high
level of management involvement in emergency preparedness activities,
responsiveness to NRC concerns, and an overall effective emergency
preparedness training program.
Management involvement in emergency preparedness was effective and
extensive.
Executives and plant managers maintain emergency response
organization position qualification, review and approve plan and pro-
cedure changes, participate in drills and exercises, resolve audit
noncompliance issues, exercise oversight functions, and interface
with Delaware and New Jersey State and County government personne 1.
Management oversight includes a review of call-in test results and
emergency preparedness training rescheduling.
The licensee successfully completed a partial-participation emergency
preparedness exercise conducted at the Salem facility during this
assessment period.
PSE&G 1 s emergency response actions were success-
ful in providing for the health and safety of the public.
Overall,
licensee performance was excellent and noted to be improved since the
last period.
Resolution of technical issues continues to be very good and demon-
strates a commitment to quality.
For example, as a result of an NRC
concern, the licensee completed a review of default iodine to noble
gas ratios as a function of release pathway, and determined the
values were consistent with accident data and emergency off-gas sys-
tem design and specifications. A four hour, default release duration
time has been developed and accepted by the States.
User friendly
personal computer software has been developed for the back-up dose
assessment program.
Relating to deficiencies in the previous assess-
ment,
the Technical
Support Center ventilation
system
has
been
16
upgraded to meet NRC design requirements.
Innovative program activ-
ities in-progress include development of site Emergency Action Levels
(EALs) for natural phenomena and security events to replace individ-
ual station EALs, a single Event Class-ification Guide for all three
units, and a simplified EAL description for use in the initial con-
tact message sent to the States.* Another example of resolving iden-
tified concerns was apparent in review of the licensee 1 s corrective
actions following loss of the NRC Emergency Notification System (ENS)
when it was accidentally disconnected from an uni nterruptab le power
supply (UPS) in May 1990.
The licensee 1 s communications staff has
aggressively
pursued
upgrading
the
Salem
Telephone
Switch
Room
(location of the ENS UPS connection).
Staffing in the emergency preparedness area is stable with a well-
qualified staff_ available to maintain an effective emergency pre-
paredness program.
Personnel
with operations backgrounds -are on
staff who develop demanding operations based scenarios for drills and
exercises.
Management* s attention t6 qua-1 ity was effective as demonstrated by
the following items.
Effective licensee audits and reviews for ~ach
unit were completed by independent audit groups.
Among other things,
drills were observed and the State/County/licensee interface was
determined to be adequate.
There were no significant findings and
the licensee/off-site interface was proactive.
Emergency Department
-p~rsonnel with licensee _e~ecutives and managers attended almost 100
meetings with State and County personnel.
The public alerting system
is tested daily, and is well maintained with availability at 99.5%, a
value which exceeds Federal Emergency Management Agency standards.
Independent and redundant siren activating systems are installed and
maintained in each State ..
The licensee has an effective emergency preparedness training pro-
gram.
Responsibility for emergency preparedness training has been
assigned to *the Emergency Preparedness Department.
Two qualified
emergency
preparedness trainers
have
been
transferred
from
the
Nuclear Training Center to the Emergency Preparedness Department to
support this effort.
Weekly, on-the-job, mini training drills for
each site have resumed and nine day-long drills are.also scheduled.
Over
1,000
licensee
personnel
have
been
trained
for
Emergency
Response Organization (ERO) positions. There are at least three per-
sonnel qualified for each key
ERO decision-making and management
position.
A dedicated emergency preparedness training facility has
been placed in service.
Engineers assigned to the Technical Support
- Center and the Emergency Operations Facility are given an overview
of Emergency Plan Implementing Procedures and Core Damage Assessment
Procedures.
III.0.2
III.D.3
III. E
IILE.1
17
The effectiveness of the training program was al so demonstrated !:Sy
response to twelve actual conditions requiring classification, and
the strong exercise performance.
This re so 1 ves the previous SALP
concern regarding event classification.
Observations of training
drills indicated active involvement
from licensed .senior reactor
operators dedicated to drill scenario deve 1 opment.
Ope rat i ans Sup-
port Center ~nd Technical Support Center personnel were observed to
implement effective problem identification and resolution.
The licensee successf~lly used the Hope Creek and Salem simulators to
enhance training effectiveness during emergency drills.
To enhance
the training effectiveness of these facilities, emergency communica-
tion systems duplicating those in the control rooms were installed in
each simulator.
In summary, the licensee maintains a strong and effective emergency
preparedness
program.
Management
remains
involved with. a demon-
strated
commitment to* quality.
Technical
issues
are
generally
promptly resolved and appropriate response is given to NRC initia-
tives.
The Emergency Preparedne~s Program staff is stable and well
quali,fied
to
maintain
an
effective
program.
Training *is well
developed and is effective as demonstrated by exercise' performance
and. response to actual conditions requiring classifiCation.
A good
working relationship is maintained with ,the States and Counties_ wi_th
regular meetings, and frequent drills.
Performance Rating
Category:
1
Trend:
NA
Board Comments
None
Securtty and Safeguards
Analysis
.The Security Plan for Artificial Island covers both Hope Creek and
Salem Generating Stations, therefore the assessment a*f security and
safeguards is a combined evaluation.
During the previous assessment period, the licensee's performance was
rated as Category 1.
Noted were an excellent enforcement history,
the continued implementation of an effective and performance-based
program, kn owl edgeab 1 e and experienced security. supervisory person-
ne 1,
and management
1 s. i nvo 1 vement in and support for the program.
18
During this assessment period, the licensee continued to implement a
high quality and very effective program, and management's attention
to and
involvement
in
the
program
remained
evident.
The
site
security supervisor and his staff are well-trained and qualified
professi ona 1 s who have been vested wi.th the necessary authority to
ensure that the security program is carried out effectively and in
conformance with NRC regulations.
The site security manager and his
staff continued to actively participate in
the Region I
Nuclear
Security Association and other groups
engaged
in
nuclear
plant
security matters.
They also maintained excellent rapport and effec-
tive communication channels with the plant staff who exhibit respect
and a good attitude toward the program.
Staffing of the contract security force was consistent with program
needs.
Early in this assessment period, the security force attrition
rate was high (24 percent).
Licensee and contractor efforts through
personal incentives were
successful
in
reducing this rate to
9
percent by the end of this period.
The licensee was responsive to identified concerns.
This was evident
by the approach to several potential weaknesses during the period
which primarily involved system and equipment aging.
As a result,
the licensee promptly initiated a comprehensive evaluation of all
systems and equipment and developed appropriate plans and a timely
schedule for upgrading and/or replacing the affected equipment.
In
addition, the licensee implemented a well managed fitness-for-duty
program in response to new NRC requirements during the period.
The
licensee's policy has been clearly stated and widely disseminated
among both emp 1 oyees and contractors.
It was found to be aggress-
ively implemented by knowledgeable personnel, and processing facil-
ities and procedures were exce 11 ent.
These efforts represented a
proactive management approach that continually seeks to improve the
effectiveness of the entire security program.
The
security force training and requalification program is well-
developed and administered by an experienced staff of two full-time
and five part-time instructors, and a supervisor.
Facilities are
provided on-site for training and requalifications and were well-
equipped and well-maintained.
During this
period,
the
licensee
established additional oversight of the contractor's training and
requalification program by providing a full-time licensee represen-
tative to administer the program.
III.E.2
III.E.3
I I I. F
III.F.1
19
The licensee 1s event report procedures were found to be clear and
consistent with the NRC 1 s reporting requirements.
Only one report-
able safeguards event was identified during the assessment period.
This event involved the loss of power to the security system and was
properly compensated for by the security force.
The licensee
1 s
report was cl ear and concise, and indicated an appropriate response
to the event.
During the assessment period, the licensee submitted three rev1s1ons
to the security program plans under
the
prov1s1ons
of
10
CFR
50.54(p).
These revisions were of high quality and technically
sound, and reflected well-developed policies and procedures.
The
licensee
also
updated
all
Physical
Security
Plan
implementing
procedures.
In summary, the licensee continued to maintain a very effective and
performance-based security program that exceeds regulatory re qui re-
ments.
The licensee's ongoing program to identify and correct poten-
tial weaknesses
in systems and equipment during this period are
commendable and demonstrated the licensee's commitment to maintain an
effective and high quality program.
Performance Rating
Category:
1
Trend:
NA
Board Comments:
None
Engineering/Technical Support
Analysis
The previous SALP rated Engineering and Technical support as Category
2, Improving.
The previous assessment indicated significant changes
within the corporate engineering department ( Engineering and Pl ant
Betterment, E&PB).
These changes were intended to improve engineer-
ing interaction with the plant staff. These changes included: estab-
lishment of Project Matrix Organization,
rev1s1on of the Design
Change Process, implementation of an Engineering Work Request System,
use of a Project Management System, and improved responsiveness of
E&PB to site needs.
Inconsistencies iri the quality of engineering
work from E&PB were noted to remain and a concern was
i dent i fi ed
early in the assessment period regarding reduced experience levels
within the systems engineering group.
20
During this SALP period, evidence of improved performance was noted
in the E&PB.
The Project Matrix Organization and the new design
change control process worked well.
The other changes appeared to
function properly.
Communication between E&PB and the plants also
improved through daily morning meetings,
and
regular weekly and
monthly meetings.
An improvement in the consistency of the quality
of work from E&PB and improvements in the performance of the systems
engineering group were observed.
The E&PB was mainly involved in the design process and less involved
i n d a il y p 1 a n t act i v i t i e s .
The o v e r a 11 de s i g n p r o c e s s with i n E& PB
was well controlled and contained appropriate checks and balances.
There was an emphasis on nuclear safety as evidenced by discussions
with E&PB personnel related to upgrading of procedures and implemen-
tation of new initiatives, such as the Configuration Baseline Docu-
mentation project, which is intended to reconstitute the design basis
for many of the major plant systems.
The design change process pro-
cedures were observed to be clear and detailed.
The procedures ade-
quately addressed design interface, design process and corrective
action process requirements with appropriate 1eve1 s of review and
verification specified.
Satisfactory performance and documentation
of cross discipline reviews were noted.
Calculations contained in
the modification packages were technically correct and performed in
accordance with applicable procedures .* A new workbook procedure has
been developed to improve the existing design change package process
and to improve configuration management control.
The workbook was sufficiently detailed to control the design process
and post-modification testing.
The drawings affected by modifica-
tions were accurate and appropriately reviewed and approved.
A new
prioritization program is under development to
improve
workload
prioritization and resource allocation.
The E&PB organization support of plant problems is noteworthy.
For
example, engineering support following a reactor scram and electrical
was
thorough
and aggressive.
This
included
immediate
response,
root cause analysis
and investigations,
and corrective
actions.
Also,
metallurgical
evaluations for plant defects were
noted as being satisfactory, as was Hope Creek 1 s implementation of
the guide 1 in es of Generic Letter 90-05,
11 Gui dance for Performing
Temporary Non-Code Repair of ASME Code 1, 2, and 3 Piping,t' in affec-
ting repairs to the service water system.
The
E&PB organization
works well with Onsite System Engineering.
However, one example of a
poor design change package was associated with the core spray system
flow instrumentation not meeting the ASME Section XI instrument range
requirements.
The
licensee is properly addressing this concern.
21
The onsite system engineering group is staffed with experienced and
knowledgeable personnel.
Evidence of good system engineering support
for station activities includes:
(1) location of a packing leak in
the drywell and its prompt isolation; (2) maintenance trending, dis-
position for degraded equipment, and procedure generation; (3) active
participation in a scram reduction program by review of Hope Creek
and other plant events and near misses; and (4) thorough root cause
determination and incident report fo 11 owup.
The 1 i censee has been
aggressive in identifying and following
up
on engineering related
deficiencies.
10
CFR Part 21 evaluations and associated notifica-
tions such as HPCI/RCIC drain pot level switch qualification were
appropriately executed.
System engineering aggressively pursued cor-
rective actions associated with Rosemount transmitters.
The licen-
see* s operating experience. feedback (OEF) program has been effec-
tively implemented.
For example, vendor information regarding design
problems with Terry Turbine overspeed trip devices was reviewed and
addressed by the station in a timely and adequate manner.
Also, the
station is conducting weekly meetings to discuss current industry OEF
information.
Early in the period, a high turnover rate was noted for system e~gi
neers.
This had the potential for reducing the overall experience
level.
The licensee continued to implement their pipeline program to
train new system engineers.
Improvements in system engineering site
experience and the addition of new system engineers were noted to
reduce the turnover rate later in the assessment period.
These
individuals provided good day-to-day support of plant operations.
Engineering analyses in support of proposed licensing amendments were
technically viable and sound from a safety standpoint and on only a
few
occasions,
required
additional
information.
The
licensee 1 s
responses to Generic Letters and Bulletins usually addressed al 1
required aspects of the issues with little or no prompting.
The
engineering
staff
1 s
performance
indicated
good
interdepartmental
communications.
The licensee aggressively pursued solutions to a high failure rate
for the Bailey Solid State Logic Modules.
The licensee has been able
to
reduce
the
failure
rate
of these modules.
The statistical
analyses of failure rates for the modules were conservative.
The inservice inspection (IS!) program is generally well administered
and showed a high degree of licensee control over its IS! vendors.
An example is the diversified QA surveillances performed on a number
of vendor activities.
IILF.2
III.F.3
III.G
III.G.l
22
In summary, corporate engineering (E&PB), de'sign change control, com-
munications between E&PB and the plant have all improved.
The engi-
neering support was excellent for license amendments and replies to
generic correspondence.
The engineering staff possesses good tech-
nical knowledge and competence and closely monitors areas that have
been problems in the past.
They are responsive to the daily needs of
the station and prompt to respond with sufficient support.
Performance Rating
Category:
1
Trend:
NA
Board Comments
None
Safety Assessment/Quality Ver1ficatiori
Analysis
The previous SALP rated Safety Assessment/Quality Verification as
Category 2, Improving.
The safety conscious approach *instilled. by
plant management and exercised by Hope Creek personnel was commend-
able.
Problem
identification
was
excellent,
and
problems
were
promptly addressed and corre.cted.
PSE&G licensing activities were
generally
complete
and
timely.
Numerous
personnel
errors
had
occurred in all functional areas, and continued management attention
was deemed necessary.
Overall during this SALP period, individual performanc;:e was excel-
1 ent.
First and second 1 i ne supervisors were di re ct ly involved in
the field.
However, early in the period, isolated personnel errors
continued in all functional areas which resulted in further manage-
ment attention.
The errors were of low safety significance, and were
promptly reported and corrected.
During the refue 1 i ng outage, *the
operations department concluded that the rapid pace of outage activ-
ity was
contributing to the personne 1 errors and stopped outage
activities to couhsel the department to take the time required to do
the job right.
In addition to being willing to halt work to empha-
size the importance of quality work, it is to management's credit
that undue
schedular pressures are not exerted bn
the workers.
Another tool being utilized to emphasize the importance that manage-
ment places on quality output is a training session on attention to
detail, which "includes an effective video tape presentation.
Fewer
- personne 1 errors occurred during the second ha 1 f of the assessment
period.
23
Station management,
including department managers and the general
manager, was di-rectly involved in providing effective station over-
sight on a daily basis.
The Senior Nuclear Shift Supervisors were
held accountable for plant operations, and they had direct access to
station management.
Effective daily meetings gave an operational
perspective to plant problem/work prioritization, and to tracking and
trending of information.
When a high number of 1 it contro 1 room
alarms were present,
station management aggressively
dedicated resources and* successfully reduced the number.
Corporate management was also involved in station activitie~. Their
presence was observed onsite and in the plant during normal and off-
normal working hours.
Nuclear services,
engineering and quality
assurance (QA) management were also in'volved in their departments'
activities.
Corporate, plant, QA, and nuclear services management
personnel
responded
to
the site when
several
unplanned
occurred during evening hours.
The licensee has an effective program for problem identification.
Incident Reports continued to be used to identify and resolve these
p 1 ant prob 1 ems
and off-norma 1 events and for tracking corrective
actions to completion.
PSE&G continued to analyze a:nd trend the
. Incident Reports and LERs; their analyses* demonstrated a steadily
decreas.i ng .frequency.
The s*tation Operations Review Committee (SORC) provided consistent,
effective
review' of significant plant
issues,
including design.
changes, post-scram reviews, and reportp.b 1 e events.
After the off-
s i te marsh fire* on
March 19, 1990
and
the *resultant* 'electrical
transient and scram, the SORC met severa.l times to review the root
causes, corrective actions arid course .of action bE;!fore implementa-:-
tion, a good indication of the SORC's ~roactive role.
PSE&G has instituted an event review process .entitled "Significant
Event Response Team (SERT)".
A SERT 1s initiated by* the
gener~l
manager and is a real time,
independent review. of any unplanned
reactor* scram
or
other
major
plant
event.
SERTs
effectively
developed the sequence of events, determined root cause(s) and recom-
mended corrective actions for the four reactor scrams that occurred
during the reporting period.
The Human Performance Eva 1 uati on Sys-
tem; a detailed*analysis method for dete~mining root causes in inci-
dents involving personnel errors is also utilized by the licensee.
24
The Quality Assurance Department, the Onsite Safety Review Group
(SRG), and the Offsite Safety Review Group provided effective, inde-
pendent review of plant activities.
These groups also participated
in SERT activities and root cause training.
The station QA organiza-
tion provided effective day-to-day review of station activities,
including resolution of problems, and was well integrated into the
station 1 s organization.
The QA organization has developed and used
performance based surveillances for several station activities.
involvement in the area of radwaste processing was
considered a
strength.
The
SRG
has been aggressive in reviewing and assessing
plant performance.
This included a twenty-four hour coverage of con-
trol room activities for a two week period.
Two of four scrams during the period were attributed to this func-
tional area.
A December 30, 1989 main turbine trip and reactor scram
were caused by failure of the thrust bearing wear detector trip by-
pass linkage during testing.
The root cause analysis determined that
plant management failed to aggressively implement modifications that
were recommended after a similar failure and scram in 1986.
Also the
March 19, 1990 scram which resulted from an offsite marsh fire, had
previously been identified by the licensee as a potential problem,
yet appropriate actions or contingency plans were not developed to
cope with them.
.
Twenty-seven licensing actions were processed.
The quality of the
technical evaluations was good, indicating that PSE&G
has a good
understanding of the technical issues, is aware of and participates
in industry groups, and uses acceptable approaches to problem solu-
tions.
The licensee 1 s response to Generic Letter 88-01 regarding
stainless steel piping was timely and adequately addressed the issues
in the letter.
PSE&G
has developed
and effectively implemented
Hydrogen Water Chemistry in the plant as a result of their review and
followup to the generic letter.
During the assessment period, a small leak was detected in the Hope
Creek service water piping, and plant management proposed to perform
a non-code repair in accordance with the
newly
re 1 eased Generic
Letter 90-05.
This was the first application of the provisions of
and
numerous discussions were
required to
arrive at a satisfactory resolution.
Although the licensee and the
NRC staff had differing views as to the best technical approach for
effecting the temporary non-code repair, PSE&G 1 s decision to adopt
the provisions of the Generic Letter was a positive action that
allowed the issue to be satisfactorily resolved.
III.G.2
III.G.3
25
In summary, Hope Creek, continues to be a well run, safety conscious
organization.
Management is heavily involved on a daily basis, and
makes its safety conscious attitude known throughout the plant.
The
review teams are candid and effectively determine root cause of
events.
The
licensee effectively identifies
problem
areas
and
ensures prompt and effective corrective actions.
How_ever, isolated
personne 1 errors continue to be an area meriting addi ti ona 1 manage-
ment attention.
Performance Rating
Category:
1
Trend:
NA
Board Comments
None
IV
SUPPORTING DATA AND SUMMARY
IV.A LICENSEE ACTIVITIES
BACKGROUND
The assessment period began May 1, 1989, with the Hope Creek reactor at
ful 1 power.
Automatic reactor scrams occurred on August 30, 1989, on
December 30, 1989, on January 6, 1990 and on March 19, 1990.
These scrams
are further described in Section III.C.
Other than these four scrams,
there were
no
unplanned shutdowns during the assessment period.
On
September 16, 1989, the Unit shutdown for its second refueling outage.
The Unit restarted on November 16, 1989.
At the end of the period, the
Unit had operated continuously for 124 days.
IV.B NRC Inspection and Review Activities
Two
NRC resident inspectors were assigned to the site throughout the
assessment period.
Regional
inspectors performed
routine
inspections
throughout the period, with added inspection emphasis during the schedule
outage.
In addition, a special inspection of the Maintenance Program was
performed in October 1989, and a Fitness For Duty inspection was performed
in March 1990.
Also, a team inspection was conducted to review perform-
ance
during
the
annual
emergency
preparedness
exercise
on
October 14, 1989.
NRC performed a to ta 1 of 3165 hours0.0366 days <br />0.879 hours <br />0.00523 weeks <br />0.0012 months <br /> of inspection dur-
ing the period, which equates to 2453 hours0.0284 days <br />0.681 hours <br />0.00406 weeks <br />9.333665e-4 months <br /> on an annualized basis.
26
IV.C Significant Licensee Meetings
A meeting was held on February 28, 1990, at Hope Creek Generating Station
to conduct a mid-SALP review and evaluation of licensee performance.
IV.D Reactor Scrams and Unplanned Shutdowns
Event Description
Date
Power
Root Cause
Functional Area
1.
The reactor was manually scrammed when half of the control rods inserted
due to a failed solder joint in the scram air header connection to one
control rod drive.
The solder joint had been inadequately installed dur-
ing plant construction.
8/30/89
81%
Component failure,
inadequate installation
NA
2.
The reactor automatically scrammed due to a turbine trip caused by the
failure of the main turbine thrust bearing wear detector trip bypass link-
age during surveillance testing.
Management had not aggressively imple-
mented modifications that were recommended after a similar failure and
scram in 1986.
12/30/89
100%
Component failure,
inadequate corrective
actions
Safety Assessment/
Quality Verification
3.
The reactor automatically scrammed due to a main turbine trip caused by a
high level in the A moisture separator during surveillance testing.
Al-
though calibrated per the vendor's recommendation, the normal and emerg-
ency drain systems were poorly tuned.
This, when combined with an oper-
ating error, caused the moisture separator level to rise uncontrollably.
1/6/90
96%
Inadequate level
contra 1 system
maintenance, operating
error
Maintenance/
Surveillance
4.
The reactor automatically scrammed on low reactor level due to loss of the
condensate and feedwater pumps when an offsite marsh fire caused an elec-
trical bus transient.
Although an electrical transient was predictable
from previous marsh fire events, the licensee did not implement effective
measures to prevent recurrence.
3/19/90
100%
Marsh Fire,
electrical system
transient; inadequate
corrective actions
Safety Assessment/
Quality Verification
TABLE 1
Inspection Hours Summary
Hope Creek Generating Station
May 1, 1989 - July 31, 1990
Annualized
Functional Area
Hours*
Hours
% of Time
A. Plant Operations
1375
1066
43
B.
Radiological Controls
283
219
9
c.
Maintenance/Surveillance
964
747
30
0.
80
62
3
E.
Security and Safeguards
144
112
5
F.
Engineering/Technical
Support
191
148
6
G.
Safety Assessment/
Quality Verification
128
99
4
TOTALS
3165
2453
100
- Does not include operator licensing hours.
TABLE 2
Enforcement Summary
Hope Creek Generating Station
May 1, 1989 - July 31, 1990
Functional Area
A.
Plant Operations
B.
Radiological Controls
C.
Maintenance/Surveillance
0.
E.
Security
F.
Engineering/Technical
Support
G.
Safety Assessment/
Quality Verification
TOTALS
Number/Severity of Violations
Level IV
1
1
TABLE 3
Licensee Event Re2ort
Hope Creek Generating Station
May 1, 1989 - July 31, 1990
Number by Cause
Functional Area
A
B c
D
E x
Subtotal
-
-
-
-
-
A.
Operations
2
1
1
1
B.
Radiological Controls
1
1
c.
Maintenance/Surveillance
4
2
2
3
0.
E.
Security and Safeguards
F.
Engineering/Technical
2
3
1
Support
G.
Safety Assessment/
1
Quality Verification
TOTALS
10
2
1
4
7
1
This analysis includes LERs 89-12 through 89-26, and 90-01 through
90-11.
Cause Codes:
A.
B. c.
0.
E. x.
Personnel Error
Design, manufacturing or installation
Unknown or external cause
Procedure inadequacy
Component failure
Other
5
2
11
6
1
25
Root causes assessed by the SALP Board may differ from those listed in
the LER.
Table 3 (Continued)
2
Cl early, the above causal analysis shows that personnel errors remained the
major contributor to reportable events.
PSE&G's analysis also showed personnel
errors to be the major contributor, but to a lesser extent than last period.
These errors involved six violations of Technical Specifications (all PSE&G
identified).
PSE&G analyses, including the Human Performance Evaluation System
(HPES), have not identified any common root causes for the personnel errors.
Personnel at various working levels were involved, from technicians to proced-
ure writers to engineers to supervisory licensed operators.
The next significant causal factor was component failure.
Review of these
failures did not determine any shortcomings in the preventive maintenance
program.
ATTACHMENT 1
SALP Criteria
Licensee performance is assessed in selected functional areas, depen'ding on
whether the facility is in a construction or operational phase.
Functional
areas normally represent areas significant to nuclear safety and the environ-
ment.
Some functional areas may not be assessed because of little or no
licensee activities or lack of meaningful observations in that area.
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.
Enforcement h1story;
4.
Operational and construction events (including response to, analyses of,
reporting of, and corrective actions for);
5.
- Staffing (including management); a~d
6*.
Effectiveness of training and qualification program.
Ori the basis of the _SALP Board assessment, each functi9nal area evaluated is
rated according to three performance categories. The definitions of these per-
formance categories are gi~en below~
Category 1 .
. Licensee management attention to and involvement in nuclear safety or
safeguards activities resulted in a superior level of performance.
NRC*
will consider reduced levels of inspection effort.
Category 2.
Licensee management attention to and involvement in nuclear safety or
safeguards activities resulted in a good level of performance.
NRC will
- consider maintaining normal levels of inspection effort.
Attachment 1
2
Category 3.
Licensee management attention to and involvement in nuclear safety or
safeguards activities resulted in an acceptable level of performance; how-
ever, because of the NRC 1 s concern that a decrease in performance may
approach or reach
an unacceptable level,
NRC will consider increased
levels of inspection effort._
Category N:
Insufficient information exists to support an assessment of 'licens~e per-
formance.
These cases would include instances in which a rating could not
be developed because of insufficient licensee activity or insufficient NRC
inspection.
The SALP Board may assess a functional area to compare the 'licen.see's perform-
ance during a portion of the assessment period to that during an* entire period
in order to determine a performance trend.
Gene.rally, performance in the
latter part of a SALP period is- compared to the performance of' the entire
period.
Trends in performance from one period to the next may ~lso be noted.
_The tren~ categories used by t~e SALP Board are as 'follows:
- Improving:
Licensee performance wa~ determined to be improving._
.
Declining:
Licensee performance was - determined to be dee H n i ng
and the -
licensee had not satisfactorily addressed this pattern.
A trend is assigned only when, in the opinion of the SALP Board, the tre_nd is
significant enough to be. considered_ indicative- of a likely change in the per-
formance
category in the near .future.
For example,
a classification of
ncategory 2, Improving" indicates the cl ear potent i a 1 for "Category 1" perform-
ance in the next SALP period.
It should be noted that Category 3 performance, the lowest category, represents
acceptable, although minimally adequate, safety performance.
If at any time
the NRC toncluded that a licensee was not achieving an adequate leve1 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 1 t *with independently from, and on a more urgent schedule than, the SALP
process.
ENCLOSURE
INITIAL SALP REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
REPORT NOS. 50-272/89-99
50-311/89-99
PUBLIC SERVICE ELECTRIC AND GAS COMPANY
SALEM GENERATING STATION
UNITS 1 AND 2
.
ASSESSMENT PERIOD:
MAY 1, 1989 - JULY 31, 1990
BOARD MEETING DATE:
SEPTEMBER 20, 1990
901018014~ 901009
F
- [-1R
ADOCK
h~ru)Q?7 2
. '** - - PDC
0.
..
I.
INTRODUCTION . . .
II.
SUMMARY OF RESULTS
A.
Overview ...
TABLE OF CONTENTS
B.
Facility Performance Analysis Summary
III. PERFORMANCE ANALYSIS ...
1
3
3
4
5
A.
Plant Operations. . .
5
- B.
RadiOlogical Controls
-9
C.
Maintenance and Survei 11 ance. .
.
. . . . .
13
D.
Emergency Preparedness (Common With Hope Creek) .
17
E.
Security and Safeguards (Common With Hope. Creek).
20
F.
Engineering and Technical Support . . . . . .
22
G.
Safety Assessment and Quality Verification.
25
IV .. SUPPORTING DATA AND SUMMARIES ......*
A.
Licensee Activities.
. .....
8.
Inspection and Review Activities.
C.
Significant Licensee Meetings ..
D.
Reactor Trips and Unplanned Shutdowns
Table 1 - Inspection Hours Summary
Table 2 - Enforcement Summary
Table 3 - Licensee Event Reports Summary
Attach~ent 1~
SALP Evaluation Criteria
.*
29
29
30
31
31
I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) is an integrated
Nuclear Regulatory Commission (NRC) staff effort to collect observations
and data to periodically evaluate licensee performance on the basis of
this information.
The SALP process is supplemental to normal regulatory
processes used to ensure compliance with NRC rules and regulations.
is intended to be sufficiently diagnostic to provide a rational basis for
allocating NRC resources and to provide meaningful feedback to the licen-
see's management to improve the quality and safety of plant operations.
An
NRC SALP Board, composed of the staff members listed below, met on
September 20, 1990, to review the collection of performance observations
and data and to assess the licensee's performance at the Salem Generating
Station.
This assessment was conducted in accordance with the guidance
in
NRC
Manual
Chapter
0516,
11Systematic
Assessment
of
Licensee
Performance.
11
This report is the NRC 1 s assessment of the licensee's safety performance
at the Salem Generating Station, Units 1 and 2 for the period May 1, 1989
through July 31, 1990.
The SALP Board for the Salem Generating Station assessment consisted of
the following individuals:
Chairman:
C. Hehl, Director, Division of Reactor Projects (DRP)
Members:
R. Blough, Chief Projects Branch 2, DRP
P. Swetland, Chief, Reactor Projects Section 2A, DRP
T. Johnson, Senior Resident Inspector, DRP
W. Butler, Director, Project Directorate I-2, Office of Nuclear Reactor
Regulation (NRR)
J. Stone, Project Manager, NRR
M. Knapp, Director, Division of Radiation Safety and Safeguards (DRSS)
J. Durr, Chief, Engineering Branch, Division of Reactor Safety (DRS)
Others in Attendance:
S. Pindale, Resident Inspector, DRP
S. Barr, Resident Inspector, DRP
A. Lopez, Reactor Engineer, DRS
C. Anderson, Chief, Plant Systems Section, DRS
D. Bessette, Acting Chief, Operational Programs Section, DRS
2
Others in Attendance (Continued)
J. Jang, Senior Radiation Specialist, DRSS
R. Nimitz, Senior Radiation Specialist, DRSS
J. Joyner, Division Project Manager, DRSS
C. Conklin, Senior Emergency Preparedness Specialist, DRSS
C. Amato, Emergency Preparedness Specialist, DRSS
R. Keimig, Chief, Safeguards Section, DRSS
R. Albert, Physical Security Inspector, DRSS
P. Ray, Operations Engineer, Performance Evaluation Branch, NRR
J. Caldwell, Regional Coordinator, Office of the Executive Director for
Operations
C. Woodard, Reactor Engineer, DRS
A. Almond, General Engineer, Director's Office, NRR
3
II.
SUMMARY OF RESULTS
II.A Overview
PSE&G was successful in improving performance in the functional areas of
plant operations and emergency preparedness during the assessment period.
Good management involvement, supervisory oversight, and individual per-
formance resulted in a reduced reactor trip and personnel error rate.
The
emergency preparedness functional area achieved a superior level of per-
formance.
An effective, performance based security program resulted in
maintaining a superior level of performance in the security/safeguards
functional area.
Very good performance by corporate engineering was noted, while mixed per-
formance of the onsite
system engineering group was observed.
As
a
result, the engineering and technical support functional area did not
a chi eve the high level of performance that was predicted in the last
assessment.
Although a large number of maintenance and surveillance activities were
successfully completed during this assessment period, there were signifi-
cant performance weaknesses noted.
These weaknesses included a
large
maintenance backlog, recurring missed surveillance tests, inservice test-
ing program deficiencies and poor material condition of the plants.
An
overall rating of Category 2 was assigned, however, the SALP Board gave
serious consideration to a lower rating.
The licerisee 1 s prior recognition
of the i dent i fi ed problems and the achievement of sma 11 but measurable
progress toward resolution of these weaknesses were critical factors in
the Board's determination.
However, as a plant ages the challenges of
maintaining equipment reliability and readiness increase.
The declining
trend in this area reflects the gravity of the Board's concern over per-
formance in this area and the need for marked progress in correcting the
identified weaknesses.
Some improvements in the safety assessment/quality verification functional
area were noted such as better supervisory involvement and oversight,
development of significant event response teams, and effective review by
the independent safety review groups.
Weaknesses were identified in the
effectiveness of licensee corrective action
programs.
In particular,
there was a lack of effective interim measures to address continuing pro-
cedural inadequacies and degrading material conditions notwithstanding the
long term significant remedial initiatives which were in process.
Although the licensee has achieved discernible improvement in some aspects
of each fun ct i ona l area, the overa 11 performance in maintenance and sur-
vei 11 ance, engineering/technical support, and safety assessment/quality
verification
has
not
improved.
Continued
management
attention
and
aggressive prosecution of remedial initiatives is needed to attain
a
uniform, high level of performance.
4
II.B Facility Performance Analysis Summary
Functional
Area
Plant Operations
Radiological Controls
Maintenance/Surveillance
Security and Safeguards
Engineering/Technical
Support
Safety Assessment/
Quality Verification
Previous Assessment Period:
Present Assessment Period:
Rating, Trend
Rating, Trend
Last Period
This Period
3
2
2
2
2
2, Declining
2
1
1
1
2, Improving
2
2
2
January 1, 1988 thr~ugh April 30, 1989
May 1, 1989 through July 31, 1990
I I I.
III.A
III.A.I
5
PERFORMANCE ANALYSIS
Operations
Analysis
The previous SALP rated Salem operations as Category 3.
That assess-
ment identified weaknesses in the area of supervisory oversight of
routine day to day operations.
The number of plant trips and fre-
quency of personnel errors had increased.
Operations management did
not always provide adequate guidance to the operators for non-routine
evolutions, however, operator response to plant transients was very
good.
Procedure establishment, use and compliance required continued
station management attention.
Some root cause analyses and correc-
tive action determinations lacked aggressiveness and thoroughness,
especially in cases related to possible operator errors.
The licen-
see had instituted actions to improve performance in these areas with
mixed results.
The planning and work control processes were noted as
strengths as was the fire protection program.
During this assessment period, both reactors were generally oper~ted
in a conservative and safety conscious manner.
Examples of conserva-
tive licensee operations include extension of shutdowns for both
units to fully evaluate emergency core cooling system (ECCS)
con-
cerns, and the shutdown of one unit when a potential main steam iso-
lation valve (MSIV) fast closure concern was identified.
Operator
response to reactor trips and plant transients was good.
In several
instances prompt actions by operators prevented transients or reactor
trips due to feedwater problems, loss of circulators, and steam dump
system failures.
Specific exceptions include an operations initiated
loss of residual heat removal
(RHR)
event while shutdown due to
operator error and an inadequate procedure, poor initial Station
Operations Review Committee (SORC) response to an engineering iden-
tified single failure vulnerability associated with the low pressure
safety injection system, and non conservative interpretation and use
of Technical Specification 3.0.3.
The licensee has been successful in reducing the frequency of auto-
matic reactor trips.
During the current assessment there were a
total of 6 trips (4 at power and 2 while shutdown) for both units.
This compares to 16 trips last assessment.
During the assessment
period, Unit 1 did not experience a reactor trip for over 10 months
and Unit 2 for over one year.
One of the six reactor trips during
this assessment period was attributed to a personnel error by a
licensed operator.
An
effective licensee trip reduction program
included
11 scram-a-gram
11
information
notices,
warning
signs
for
reactor trip sensitive areas,
a new troubleshooting procedure and
independent verification of trip sensitive procedural steps.
6
PSE&G has committed resources to upgrade pl ant operation.
A second
operating engineer, a dedicated radwaste engineer, and an emergency
operating procedure coordinator were added to the operations staff.
In addition to the three senior reactor operators (SROs) required for
each shift, a number of replacement candidates were hired to pursue a
goal of five SROs for each shift crew.
Two additional SRO-licensed
individuals now supervise the work control group during regular main-
tenance
hours.
Operations -
maintenance interface for equipment
tagging is satisfactory.
There are a total of 45 licensed operators,
including 38 on-shift and seven in staff and training positions.
Plant operations were generally well
supported
by
the
Training
Department.
One exception was the response to the loss of RHR event,
where both the station and the training department were not aggress-
ive in obtaining training assistance following the potentially sig-
nificant plant event.
Simulator refresher training before each unit
restart continues to be given to the reactor operators (ROs) and SROs
immediately before taking their shift and is considered a strength.
The station instituted improved procedures to control the training
process,
and also established a master training matrix to track
individual qualifications and to facilitate the maintenance of train-
ing records.
Six of six SRO license candidates anq six of seven RO candidates
passed their initial license examinations.
The RO/SRO requalifica-
tion program was excel lent with seven of seven ROs and six of six
SROs tested passing an NRC administered requalification exam.
Direct
involvement of operations management personnel
has had a positive
effect on the requalification program success.
Licensed operators 1 plant awareness, safety perspective, and profess-
ional control room demeanor were consistently evident.
Shift turn-
overs were formal and included thorough briefings of the relief crew.
Control room access was controlled, and activities were limited to
those di re ct ly related to pl ant operations.
Good performance of
non-licensed equipment operators was noted during NRC observations
made on plant tours, and during licensee equipment testing and oper-
ation.
However, operator overtime was at times not properly control-
led in that proper management approval for exceeding administrative
guidelines was not obtained.
The licensee has increased the number
of licensed operators to reduce the amount of overtime and has
initiated corrective actions
to ensure
appropriate
approval
is
obtained.
Overal 1, there has been a reduction in the personnel error rate.
This is reflected in root causes for LERs
and licensee incident
reports.
This can be attributed to increased accountability of per-
sonnel, effective management oversight of activities, and implemen-
tation of worker performance standards.
7
Procedural
inadequacy continues to
be
a
leading root cause for
events, including the loss of RHR event during the Unit 1 refueling
outage.
A procedural
upgrade project (PUP)
continues to be
an
important initiative; however, program implementation has encountered
problems as discussed in Section III.G.
Operators effectively used Emergency Operating Procedures (EOPs) as
evidenced during simulator observations, and actual unit transients
and trips; as well as during the NRC EDP team inspection.
EOPs were
well written, usable by operators and well maintained.
However, a
concern was identified regarding excessive responsibilities placed
on the one RO who operates the controls while the other RO reads the
EOPs.
The licensee plans to resolve this issue by modifying RO/SRO
command and control responsibilities.
Weaknesses were also noted
with respect to abnormal operating procedures (AOPs) and some alarm
response procedures.
The lack of a good procedure verification pro-
gram resulted in AOPs con ta i ni ng many 1 ongstandi ng errors including
labeling problems and missing information.
Consequently, successful
performance of these procedures relies heavily upon operator know-
1 edge and experience.
Licensee
Operations
Department event
and
problem evaluation
and
response were usually prompt and comprehensive.
Improvements in root
cause analysis and self-assessment were noted.
Management attention
and the root cause training
program have been effective.
Also,
implementation of the Significant Event Response Team initiative has
been
effective
in
providing
timely,
independent,
detailed,
and
thorough root cause analyses.
However, there were isolated instances
where
i nterna 1 incident reports were not written when re qui red by
station procedures.
Examples include boric acid transfer pump fail-
ures
and
a
spurious
steam dump
system actuation,
which nearly
resulted in a reactor trip.
Also, early in the period, there were
several instances where the licensee failed to make timely 10 CFR
50.72 reports.
Improvements were noted later in the period.
Strong plant management oversight and attention to operations were
evident on a daily basis.
There was an operational perspective of
plant problems,
and work prioritization was well
understood
and
enhanced by daily meetings.
The licensee has been effective in
ensuring good interdepartmental communication and in resolving prob-
lems.
The senior nuclear shift supervisor has direct access to plant
management.
Pl ant housekeeping
has shown
some
improvement during the period.
Plant area decontamination activities have reduced the contaminated
floor space, particularly in the ECCS rooms.
Equipment operators can
make their rounds with only minimal contamination protective cloth-
ing.
Overall, however, material condition of* the plant was weak
(Section III.C).
Licensee initiatives in progress to improve the
degraded
conditions
were
not
sufficient
to
display significant
improvements.
II .A.2
III.A.3
8
The overall fire protection program was satisfactory.
Dedicated fire
protection personnel
performed well
and were knowledgeable, which
demonstrated an effective training program.
The fire brigade was
staffed by site protection personnel, which minimized the reliance on
operators to respond to emergencies.
Appropriate operator involve-
ment in emergencies was provided.
The preventive maintenance and
surveillances of fire protection
equipment were effective.
Fire
protection equipment upgrades included a new ambulance, incident com-
mand vehicle, and other items.
However, the fire protection program
experienced implementation problems at Sal em.
For example, a weak-
ness was identified in the apparent tolerance for and the lack of
timely resolution for a long term condition at Salem where some fire
doors did not always close securely.
This condition was due to
imbalances in the plant 1 s ventilation system.
Some interim compen-
satory measures were taken by the plant to monitor these doors during
the rounds of roving fire watches; however, doors that were not part
of the route for the watches often went unmonitored.
In response to
NRC concerns, a task group was formed to investigate the root cause
of this problem and to formulate corrective actions.
A second weak-
ness was related to improper control of combustible material
in
safety related areas.
The licensee was aggressive in addressing.and
correcting this concern.
In
summary,
improvement in management involvement and supervisory
oversight, in reduced reactor trip and personnel error rate, and in
root cause analysis initiatives were noted.
Emergency operating pro-
cedures are considered a strength; however, weaknesses were noted
relative to abnormal operating procedures.
Good operations manage-
ment and training department involvement has resulted in a successful
operator
requalification
program.
The
licensee
has
committed
resources to improving plant operations.
Performance Rating
Category:
2
Trend:
NA
Board Comments
None
III. B
III.B.1
9
Radiological Controls
Analysis
The previous SALP rated the functional area of radiological controls
as Category 2.
The NRC 1 s review during the last assessment period
identified that performance for inplant radiation protection activ-
ities had declined early in the period and that the licensee's cor-
rective actions and self-assessments were initially ineffective in
improving overal 1 performance.
NRC observations toward the end of
the
last assessment
period found that management attention
had
resulted in significant performance improvement.
The radiological
controls organization was
reorganized and a new ALARA group was
established during the last period.
The licensee's performance in
the areas of radwaste transportation, effluent monitoring and control
were adequate, and radiological confirmatory measurements was good.
During the current assessment period, direct NRC observations of Unit
2 refueling activities indicated that outage activities were well
planned and effectively controlled.
The licensee established and
implemented an effective outage radiological controls organization
which minimized the use of contractor personnel acting in supervisory
roles.
All major radiological work activities performed during the
outage (e.g., steam generator work activities) were directly super-
vised by a licensee radiological controls supervisor.
In addition,
the staffing levels to support outage and non-outage work activities,
including the training of personnel, were good and the new ALARA
organization continued to provide aggressive oversight of outage
radiological work activities.
During the Unit 2 outage, the licensee experienced operational prob-
lems with emergency ~ore cooling systems at Unit 1, necessitating a
concurrent mini-outage at Unit 1.
The licensee established a special
organization to review and plan the Unit 1 work activities in order
to prevent distraction of personnel supporting the Unit 2 outage.
This indicated a good level of management
involvement in outage
activities.
No degradation of radiological controls was identified.
The licensee also experienced an operational event at Unit 1 which
resulted in generation of High Radiation Areas in various portions
of the Auxiliary Building.
The event, which caused a high crud burst
during full-flow testing of emergency core cooling systems, was well
responded to by the licensee.
No unplanned exposures occurred and
the crud was quickly cleaned up.
Corrective actions were taken to
prevent recurrence.
However, the event did indicate test planning
process weaknesses that failed to predict and prevent occurrence of
the crud burst.
10
NRC observations during the current assessment period found that the
licensee 1 s oversight of radiological program activities has improved
relative to the last assessment period.
For example, an independent
radiological assessor was reporting findings to management during the
Unit 2 outage and QA was active in identifying concerns.
The 1icensee 1 s enforcement hi story during the assessment period has
generally been good.
However, there were two NRC i dent i fi ed prob-
1 ems.
One
involved lack of performance of an audit of radwaste
activities and one involved two examples of failure to adhere to
radiation
protection
procedures.
The
problems
were
properly
addressed by the licensee.
In addition, the licensee identified a
number of problems that included a worker leaving the site with a
contaminated shoe, identification of contaminated tools in a storage
area located outside the radiological controlled area (RCA), radio-
active material stored in offsite warehouses, and one individual who
exceeded administrative external exposure guidelines through per-
sonnel error in use of exposure control computers.
Review of the
NRC
and licensee identified problems indicated the
problems were attributable to inattention to detail by the *licensee
and
weaknesses
in
procedures.
The
radioactive and contaminated
material control problems did not result in any unplanned or unmon-
itored exposures of personnel
and thi; licensee 1 s response to the
events was timely, comprehensive, and effective.
Good support and
involvement in resolving the event by the corporate radiological con-
trols group were evident.
The licensee had not yet implemented all
long term corrective actions at the end of the assessment period for
the radioactive material control problems.
The problems with release, control and handling of radioactive mate-
rial outside formally defined RCAs
indicated the need to provide
enhanced procedures.
The 1 icensee has been attempting to improve
procedures, but this effort was progressing slowly.
The licensee has
initiated action to improve these efforts.
The licensee 1 s radiological occurrence program exhibited a number of
significant weaknesses which minimized the effectiveness of this pro-
gram for identifying, tracking, and resolving self identified radio-
logical problems.
NRC review found that root cause analysis of the
problems was weak, problems were not always categorized properly, and
corrective actions for problems were not always identified.
Examples
of this weakness included the contamination control problems.
11
With the exception of the previously mentioned administrative limit
problem, there were no
unplanned externa 1 who 1 e
body or i nterna 1
exposures resulting from work activities.
Access controls to HRAs
were effective and enhanced through the use of
11 ta 1 king si gns
11 which
automatically inform personnel of access control
requirements to
HRAs.
The licensee has installed digital signs at the entrance to
the RCA to inform workers of important information.
NRC observations
indicated improvement in industrial safety, but housekeeping con-
tinues to be in need of attention.
Observations of numerous candy
wrappings in the RCA continue to indicate lack of worker sensitivity
to the potential of ingestion of radioactive material.
The
licensee's controls for
steam generator work, a significant
radiological work activity, were commendable.
Of particular note was
the use of multiple, redundant monitoring methods to monitor and
control the exposure of personnel working on steam generators.
Performance in the ALARA area was very good and improved over pre-
vious assessment periods.
Exposure of station and contractor per-
sonnel
was closely tracked, monitored and reported by use of the
computerized radiation work permit and automated dosimetry acc;:ess
control system.
Potential emergent work was anticipated and planned
(e.g. possible extended work scope for steam generator inspection and
maintenance).
The licensee performed A LARA
reviews for work that
accounted for about 95% of the aggregate exposure sustained during
the outage.
A LARA goals were reasonable and effectively used to
monitor ongoing work but person hour estimating could be improved.
Overall performance in the ALARA area has been effective.
The licensee has an effective solid radwaste/transportation program.
The training provided to radiological controls personnel involved in
the radwaste program continues to make a positive contribution to the
effectiveness of the program.
NRC reviews of the radiological effluent monitoring and control pro-
gram indicated calibration of effluent and process monitors was per-
formed acceptably during the assessment period.
However, there were
about 32 Emergency Safety Feature ( ESF) actuations due to spurious
Radiation Monitoring Systems (RMS) signals.
The licensee had estab-
1 i shed short and 1 ong term projects to upgrade the RMS during the
previous assessment period.
The projects are on schedule with the
installation of a central process unit in 1990 and replacement of ESF
RMS in .1991.
III.B.2
III.8.3
12
NRC reviews performed during this assessment period indicated weak-
nesses in the licensee's maintenance of safety related ventilation
systems particularly charcoal filter systems.
For example, the NRC
identified that the licensee did not take measurements to verify the
relative humidity of the Auxiliary
Building
Ventilation
System.
Other systems,
such as the Control
Room ventilation systems, were
found to have failed inplace surveillance testing with no explanation
as to possible causes.
Also,
the licensee 1 s response to an
NRC
identified issue related to testing of the air cleaning systems,
including humidity measurements, identified early in the assessment
period remained open, ~ith the licensee not anticipating closeout of
the issue before the end of 1990.
An effective Radiological Environmental Monitoring Program (REMP) was
implemented.
Sampling and analytical procedures were upgraded and an
effective QC program was in place to assure the quality of sample
analysis.
One problem was identified in the area of an unmonitored
liquid radwaste release, but there was no impact on the public health
and safety or environment and the licensee took effective corrective
actions for the occurrence.
The meteorological monitoring system was
properly calibrated and maintained.
Audits of these areas performed
by the Quality Assurance Division were thorough and audit identified
deficiency items were adequately resolved in a timely manner by the
licensee.
In
summary,
the licensee implemented a good radiological controls
program with a good 1eve1 of management i nvo 1 vement in the program.
Efforts in organization, staffing, training and qualification have
improved performance.
The
licensee
1 s
ALARA activities were very
good.
Weaknesses exist in the radiological occurrence report program
and personne 1 attention to deta i 1 is in need of improvement.
A 1 so,
problems
with
radioactive material
control
indicated a
need to
improve procedural controls.
The radwaste handling, transportation,
and environmental monitoring programs were effective.
The licensee
has performed adequately in the area 6f liquid and gaseous effluent
controls.
Performance Rating
Category:
2
Trend:
NA
Board Comments
None
III. C
III.C.1
13
Maintenance and Surveillance
Analysis
The last SALP assessment rated the Maintenance and Surveillance func-
tional area a Category 2.
Identified strengths included the initia-
tive to develop work standards; maintenance planning, pre-staging and
oversight during refueling outages; and the assignment of additional
resources
to
prevent missed
surveillances.
Weaknesses
included
inconsistent use of procedures, insufficient documentation of trou-
bleshooting activities, failure to follow procedures and inattention
to detail resulting in severa 1 p 1 ant events, and multi p 1 e missed
surveillances.
Maintenance:
During this assessment period, the licensee implemented a satisfac-
tory maintenance program.
A large volume of maintenance activities
was
successfully implemented, however specific observations often
indicated several areas for continued improvement and management
attention.
The goals and objectives of the maintenance program were
we 11
defined.
There was a good l eve 1 of maintenance management
involvement and supervisory oversight in daily activities.
Some pro-
cedure content and usage deficiencies continued to exist during this
assessment period.
The licensee has stressed procedure compliance
and i dent i fi cation of procedure inadequacies.
Work in progress has
occasionally been stopped by workers and first line supervisors due
to procedure problems, indicating that licensee management's efforts
to identify procedure weaknesses have been communicated to the staff.
Early in the SALP period, work standards were issued to employees for
the purpose of improving work, procedural compliance and industrial
safety
practices.
Written
planning
standards were
subsequently
issued to enhance maintenance planning.
Although the work standards
improvement program is in its early stages, its development is con-
sidered to be a good licensee initiative.
The turnover rate experienced by the maintenance organization is low
and is indicative of a stable staff.
Maintenance workers are com-
petent, trained and qualified.
Qualification criteria are well-
defined and documented for both licensee and contractor workers.
The
training center continues to provide extensive electrical and mech-
anical training facilities.
When the existing modular training pro-
gram was initiated in 1987, many craft personnel were
11 grandfathered 11
with the intent of eventually being formally trained.
However,
reviews of training records did not support fulfillment of this plan.
Additionally, there was not an aggressive effort to satisfy yearly
training requirements for mechanical maintenance, apparently due to
increased work loads from unit outages.
Overall, however, the main-
tenance
staff
was
highly
knowledgeable
in
their
areas
of
responsibility.
14
Maintenance department staffing was
adequate to properly support
significant maintenance activities.
Staffing additions during this
SALP *period
included
supervisors,
planners
and craft personnel.
Also, each unit now has an outage manager.
However, the maintenance
backlog of overdue corrective and preventive maintenance was large.
Initiatives taken to increase productivity, improve scheduling, up-
grade work
planning,
and increase staffing were demonstrated to
increase maintenance productivity.
However, the monthly work order
production rate has increased proportionally to the increased pro-
ductivity.
The work order production increase was partly due to
recent
management
goals
to
improve
plant
materiel
condition
deficiencies and worker sensitivity in
identifying deficiencies.
The aging of any plant causes the challenge of material condition
maintenance to increase over time.
The number of deficient plant
material and area conditions such as steam and water leaks, equipment
corrosion, and service water pipe integrity was indicative of years
of insufficient attention to facility and equipment status.
Par-
ticular concerns included inadequate maintenance of the watertight
features of the service water valve galleries and the steam and water
leaks in the containment penetration rooms in both units.
Recent NRC
findings,
such as main
steam isolation valve detent problems and
material condition deficiencies that are not identified by the licen-
see staff indicate an apparent toler.an~e of equipment deficiencies.
The licensee has shown some recent improvement (e.g., Unit 2 service
water valve rooms) in this area and has assigned a special task force
to address material condition and equipment improvements.
Despite
the existence of these problems, the plants have been maintained and
operated in a safe manner.
Maintenance activities are at times impaired due to the control and
availability of spare parts.
The licensee had previously recognized
these parts problems and recently dedicated additional resources with
sole responsibility for material control to improve performance in
this area.
The spare parts problems represented a major contributor
to a large maintenance backlog.
The licensee is developing a reliability centered maintenance (RCM)
program.
Based on a licensee assessment that the existing number of
preventive maintenance (PM) activities is excessive, implementation
of the
program is expected to adjust the
program
scope,
schedule and workload accordingly.
The licensee's self initi~ted RCM
program has been in progress for about three years.
Significant
increases in
RCM program resources have been provided by licensee
management in mi d-1989.
The program is planned to be performed in
two phases and is expected to cover about 30 systems.
The RCM pro-
gram is currently in its early stages of implementation.
15
Effective management involvement and oversight resulted in successful
comp 1 et ion of two unit refue 1 i ng outages and severa 1 forced outages
during the assessment period.
Core alterations, reactor vessel work,
and other refueling activities were well supported by operations.
Reactor coolant system midloop operations were wel 1 planned, pro-
cedur-al ized and implemented.
Periodic outage meetings were effec-
tive in communicating priority activities and problem areas to all
members of the dedicated outage team.
Maintenance procedure deficiencies continued during this assessment.
The station's expanded procedure upgrade project (PUP) was initiated
in mid-1989 to fully address procedural deficiencies. Only two main-
tenance procedures had been completely processed and issued at the
end of the assessment period.
The NRC identified examples where com-
p 1 ex maintenance activities were conducted without comp 1 ete, suf-
ficiently detailed and
approved procedures,
including emergency
diesel generator and main steam isolation valve mechanical latching
mechanism (detent) maintenance.
Two reactor trips were attributed to maintenance activities conducted
prior to this assessment period; one due to ineffective actions for a
previous event, and the other due to an inadequate maintenance pro-
cedure.
Ex amp 1 es of p 1 ant events caused by maintenance activities
during the current assessment period in~lude the failure of an emerg-
ency lighting inverter due to inadequate maintenance and an inadver-
tent safety injection signal, which occurred when a maintenance tech-
nician used a drawing for the opposite safety train while performing
maintenance work.
At times, the licensee did not effectively control and supervise con-
tractor maintenance.
Severa 1 findings were identified during this
assessment period relative to procedural noncompliance by contractors
and indicated the need for increased management attention.
Examples
include work on a feedwater regulating valve without proper work
authorization and the failure to implement administrative procedure
requirements
for temporary installations.
The
licensee recently
modified their contractor procedures including enhanced work standard
requirements and procedural familiarization.
Increased direct over-
sight by PSE&G personnel was provided. Toward the end of the assess-
ment period, improvements were noted re 1 at i ve to contractor contro 1.
However, continuing problems were noted.
16
Surveillance:
During this assessment period, surveillance testing was usually con-
ducted in a well controlled manner by knowledgeable personnel with
usually appropriate supervision.
A large number of surveillance
testing activities were
successfully completed.
The surveillance
program administrative procedure was modified to clarify personnel
responsibilities, to assign indivi~ual surveillance coordinators, and
to formally assign a Technical Specification (TS) Administrator to
coordinate related station activities.
Surveillance test procedures
continued to contain human factors and technical deficiencies.
Weak-
nesses were identified in the administration of the Inservice Testing
Program.
There were seven missed surveillances this period, predominantly due
to past inadequate administrative controls related to TS amendment
issuance.
This compares with 12 missed surveillances during the last
assessment period.
Missed surveillances have been a long-standing
problem at Salem for which numerous TS
surveillance reviews and
audits have been performed, including a computer data base review and
a limited review of recent
TS
amendments.
Technical
procec;iure
reviews to identify additional missed TS requirements have not yet
been completed.
The continued missed TS survei 11 ances due to past
inadequate administrative controls indicate that the previous licen-
see actions taken to identify the problems have been too narrowly
focused and ineffective.
Licensee management recently directed a
more comprehensive review of TS surveillance requirements against
existing surveillance procedures to resolve this issue.
Several surveillance procedures contained deficiencies, some of which
resulted in plant events.
Human factors deficiencies contributed to
the May 20, 1989 loss of residual heat removal (RHR) event and emerg-
ency core cooling systems flow calculation errors.
The licensee is
addressing these types of procedural inadequacies in their ongoing
PUP efforts.
In an effort to reduce plant trips, early in the assessment period
the licensee instituted an independent peer review of critical steps
for reactor protection system and ESF testing.
This action appeared
to have been effective in preventing trips during surveillance test-
ing; no reactor trips occurred during surveillance testing.
However,
three engineered safety feature (ESF) actuations occurred during sur-
veillance testing.
Two were due to inadequate procedures and one was
due to personnel error.
III.C.2
III.C.3
III.D
III.D.1
17
There are indications that the Inservice Testing (IST) program was
not effectively. administered.
Pump vibration testing was not repeat-
able due to a combination of unmarked vibration reading points and
unclear component drawings in test procedures, and weaknesses were
evident relative to evaluation of questionable and unsatisfactory
test results (e.g. auxiliary feedwater and
boric acid transfer
pumps).
Weaknesses were also identified concerning trending of sur-
veillance test data.
In summary, the maintenance organization implemented a satisfactory
program.
Work standards, management involvement, and the RCM initia-
tive were licensee strengths.
Maintenance weaknesses include the
large maintenance backlog, the quality of some procedures, control of
contractor maintenance, and control and availability of spare parts.
A poor overall material condition of the plant was a significant
weakness sourced in a prolonged period of insufficient attention to
maintaining the plant.
Licensee efforts to improve this area have
been
slow;
meanwhile,
the challenge to
the maintenance
program
increases with plant age.
A large number of surveillance testing
activities were conducted in a well controlled fashion by knowledge-
able and experienced personnel.
Some surveillance test procedl)res
continue to contain deficiencies.
Although no reactor trips were
caused by
personnel errors, such errors resulted in other pl ant
events. Weaknesses were identified in the administration of the IST
program.
Missed surveillances continued to be identified due to
ineffective previous actions.
Performance Rating
Category:
2
Trend:
Declining
Board Comments
Although the overall assessment was that a Category 2 rating was
appropriate,
several
weak
areas
continue to exist without
significantly
effective
measures
to
improve
performance.
Increased management attention is warranted.
Analysis
The Emergency Plan for Artificial Island covers both Hope Creek and
Salem Nuclear Generating Stations, therefore the assessment of emerg-
ency preparedness is a combined evaluation of both facilities' emerg-
ency response capabilities.
18
During the previous SALP period, this area was rated Category 2.
This rating was based on weaknesses identified during a Salem based
full-participation exercise, some actual event classification prob-
lems, and delays in ensuring that the Salem Technical Support Center
could meet NRC design requirements.
Strengths noted included a high
level of management involvement in emergency preparedness activities,
responsiveness to NRC concerns, and an overa 11 effective emergency
preparedness training program.
Management involvement in emergency preparedness was effective and
extensive.
Executives and plant managers maintain emergency response
organization position qualification, review and approve plan and pro-
cedure changes, participate in drills and exercises, resolve audit
noncompliance issues, exercise oversight functions, and interface
with Delaware and New Jersey State and County government personnel .
Management oversight includes a review of call-in test results and
emergency preparedness training rescheduling.
The licensee successfully completed a partial-participation emergency
preparedness exercise conducted at the Salem facility during this
assessment period.
PSE&G 1 s emergency response actions were
succc~ss
ful in providing for the health and safety of the public.
Overall,
licensee performance was excellent and noted to be improved since the
last period.
Resolution of technical issues continues to be very good and demon-
strates a commitment to quality.
For example, as a result of an NRC
concern, the licensee completed a review of default iodine to noble
gas ratios as a function of release pathway, and determined the
values were consistent with accident data and emergency off-gas sys-
tem design and specifications. A four hour, default release duration
time has been developed and accepted by the States.
User friendly
personal computer software has been developed for the back-up dose
assessment program.
Relating to deficiencies in the previous assess-
ment, the Technical Support Center ventilation system has been up-
graded to meet NRC design requirements.
Innovative program activ-
ities in-progress include development of site Emergency Action Levels
(EALs) for natural phenomena and security events to replace individ-
ual station EALs, a single Event Classification Guide for all three
units, and a simplified EAL des-cription for use in the initial con-
tact message sent to the States.
Another example of resolving iden-
tified concerns was apparent in review of the licensee 1 s corrective
actions following loss of the NRC Emergency Notification System (ENS)
when it was accidentally disconnected from an uni nterruptab le power
supply (UPS) in May 1990.
The licensee
1 s communications staff ras
aggressively pursued
upgrading
the
Salem
Telephone
Switch
Room
(location of the ENS UPS connection).
19
The licensee successfully used the Hope Creek and Salem simulators to
enhance training effectiveness during emergency drills.
To enhance
the training effectiveness of these facilities, emergency communica-
tion systems duplicating those in the control rooms were installed in
each simulator.
Staffing in
the emergency preparedness area is
stable with a well-qualified staff available to maintain an effective
emergency preparedness program.
Personnel with
operations back-
grounds are on staff who develop demanding operations based scenarios
for drills and exercises.
Management's attention to quality was effective as demonstrated by
the following items.
Effective licensee audits and reviews for each
unit were completed by independent audit groups.
Among other things,
drills were observed and the
State/County/li~ensee interface was
determined to be adequate.
There were no significant findings and
the licensee/off-site interface was proactive.
Emergency Department
personnel with 1 icensee executives and managers attended almost 100
meetings with State and County personnel.
The public alerting system
is tested daily, and is well maintained with availability at 99.5%, a
va 1 ue which exceeds Federa 1 Emergency Management Agency standards.
Independent and redundant siren activating systems are installed.and
maintained in each State.
The licensee has an effective emergency preparedness training pro-
gram.
Responsibility for emergency preparedness training has been
assigned to the Emergency Preparedness Department.
Two qualified
emergency
preparedness trainers have
been
transferred
from
the
Nuclear Training Center to the Emergency Preparedness Department to
support this effort.
Weekly, on-the-job, mini training drills for
each site have resumed and nine day-long drills are also scheduled.
Over
1,000
licensee personnel
have
been
trained for
Emergency
Response Organization (ERO) positions. There are at least three per-
sonnel qualified for each key
ERO decision-making and management
position.
A dedicated emergency preparedness training facility has
been placed in service.
Engineers assigned to the Technical Support
Center and the Emergency Operations Facility are given an overview of
Emergency Plan Implementing Procedures and Core Damage Assessment
Procedures.
The effectiveness of the training program was also demonstrated by
response to twelve actual conditions requiring classification, and
the strong exercise performance.
This re so 1 ves the previous SALP
concern regarding event classification.
Observations of training
drills indicated active involvement from licensed senior reactor
operators dedicated to drill scenario development.
Operations Sup-
port Center and Technical Support Center personnel were observed to
implement effective problem identification and resolution.
III.0.2
III.D.3
III. E
III.E.l
20
In summary, the licensee maintains a strong and effective emergency
preparedness
program.
Management
remains
involved with a demon-
strated
commitment
to
quality.
Technical
issues
are
generally
promptly resolved and appropriate response is given to NRC in it i a-
t i ves.
The Emergency Preparedness Program staff is stable and well
qualified
to
maintain
an
effective
program.
Training
is well
developed and is effective as demonstrated by exercise performance
and response to actual conditions requiring classification.
A good
working relationship is maintained with the States and Counties with
regular meetings, and frequent drills.
Performance Rating
Category:
1
Trend:
NA
Board Comments
None
Security and Safeguards
Analysis
The Security Plan for Artificial Island covers both Hope Creek and
Salem Generating Stations, therefore the assessment of* security and
safeguards is a combined evaluation.
During the previous assessment period, the licensee's performance was
rated as Category 1.
Noted were an exce 11 ent enforcement hi story,
the continued implementation of an effective and performance-based
program, kn owl edgeab le and experienced security supervisory person-
nel ,
and management
1 s
involvement in and support for the program.
During this assessment period, the licensee continued to implement a
high quality and very effective program, and management* s attention
to and involvement in the program remained evident.
The site secur-
ity supervisor and his staff are well-trained and qualified profess-
ionals who have been vested with the necessary authority to ensure
that the security program is carried out effectively and in compli-
ance with NRC regulations.
The site security manager and hjs staff
continued to actively participate in the Region I Nuclear Security
Association and other groups engaged in nuclear plant security mat-
ters.
They also maintained excellent rapport and effective communi-
cation channels with the plant staff who exhibit respect and a good
attitude toward the program.
21
Staffing of the contract security force was consistent with program
needs.
Early in this assessment period, the security force attrition
.rate was high (24 percent).
Licensee and contractor efforts through
personal incentives were successful in reducing this rate to 9 per-
cent by the end of this period.
The
licensee
continued to demonstrate responsiveness to
several
potential weaknesses during the period.
These weaknesses primarily
i~volved system and
equipment aging.
As
a result, the licensee
promptly initiated a comprehensive evaluation of all
systems and
equipment and developed appropriate plans and a timely schedule for
upgrading and/or replacing the affected equipment.
In addition, the
licensee
implemented
a
well
managed fitness-for-duty program in
response to new NRC requirements during the per.iod.
The licensee's
policy has been clearly stated and widely disseminated among both
employees and contractors.
It was found to be aggressively imple-
mented
by
knowledgeable
personnel,
and processing facilities and
procedures were excellent.
These efforts represented a proactive
management approach that continually seeks to improve the effective-
ness of the entire security program.
The
security force training and requalification program is well-
developed and administered by an experienced staff of two full-time
and five part-time instructors, and a. supervisor.
Facilities are
provided on-site for training and requalifications and were well-
equipped
and well-maintained.
During this
period,
the
licensee
established additional oversight of the contractor's training and
requalification program by providing a full-time licensee representa-
tive to administer the program.
The licensee's event report procedures were found to be clear and
consistent with the NRC 1 s reporting requirements.
Only one report-
able safeguards event was submitted to the NRC during the assessment
period.
This report involved the loss of power to the security sys-
tem and was properly compensated for by the security force.
The
licensee's report was clear and concise, and indicated an appropriate
response to the event.
During the assessment period, the licensee submitted three revisions
to the security program plans under
the
prov1s1ons
of
10
CFR
50.54(p).
These revisions were of high quality and technically
sound, and reflected well-developed policies and procedurE;!s.
The
licensee
also
updated
all
Physical
Security
Plan
implementing
procedures.
III.E.2
III.E.3
III. F
III.F.1
22
In summary, the licensee continued to maintain a very effective and
performance-based security program that exceeds regulatory require-
ments.
The licensee's ongoing program to identify and correct poten-
tial weaknesses in systems and equipment during this period are com-
mendable and demonstrated the licensee's commitment to maintain an
effective and high quality program.
Performance Rating
Category:
1
Trend:
NA
Board Comments
None
Engineering/Technical Support
Analysis
The previous SALP rated Engineering and Technical Support as Category
2, improving.
The
previous assessment noted significant changes
within the corporate engineering department established to improve
engineering's interaction with the station staff.
Improvements were
noted in corporate/station engineering communications.
System engi-
neering was a strength.
Weaknesses included implementation problems
associated
with
station
modifications
and
inadequate
safety
evaluations.
During this SALP period, evidence of good performance was noted in
E&PB.
The Project Matrix Organization and the new design change con-
trol process worked well.
The other changes appeared to function
properly.
Communications between E&PB and the plants also improved
through daily morning, regular weekly and monthly meetings.
Several
new concerns were identified regarding the consistency of the quality
of work performed by the systems engineers and instances of inappro-
priate implementation of the temporary modification program.
The design change process is effective in plant modification imple-
mentation.
Design change process procedures were observed to be
clear and
detailed.
The
procedures adequately addressed design
interface, design process and corrective action process requirements
with appropriate levels of review and verification specified. Satis-
factory performance and documentation of cross discipline reviews
were noted.
Calculations contained in modification packages were
technically correct and
performed
in accordance
with applicable
23
procedures.
A new workbook
p~ocedure has been developed to improve
the existing design change package process and to improve configura-
tion management contra l.
The workbook was sufficiently detailed to
control the design process and post-modification testing.
The draw-
ings affected by modifications were mostly accurate and appropriately
reviewed and approved.
In addition, a new prioritization program is
under development to improve workload prioritization and resource
allocation.
The
E&PB organization works well with onsite system
engineering.
This* was evidenced during the followup of the Emergency
Core Cooling System (ECCS) flow problems.
The on site system engineering group supports operational, mainten-
ance, testing and design change activities.
Inconsistencies were
observed in the quality of work performed by the systems engineers.
For example, system engineer troubleshooting and corrective action
plans for radiation monitoring system deficiencies, main power trans-
former problems, main steam line isolation valve (MSIV) modification
errors, reactor coolant system check valve leakage, and feedwater
system and regulating valve timing problems were thorough and compre-
hensive.
However, system engineer followup of boric acid pump low
flow
problems,
initial
drifting
indications,
and
initial
analysis of the RHR overpressurization event were poor. System engi-
neers are used as station qualified reviewers (SQRs).
The SQR pro-
cess, at times, was noted as a weaknes~. Examples include:
proced-
ure changes involving safety significant issues being processed by
the SQR; not maintaining the required SQR independence; and, not
implementing SQR training that was committed.
There have been several examples of inappropriate implementation of
the temporary modification program.
Some installed temporary changes
should have been processed as permanent modifications, some temporary
modifications were found to have been in place for excessive time
periods, and a required periodic review of temporary modifications by
the Station Operations Review Committee was missed.
A new control
procedure for temporary modifications (T-MOD) had been developed and
approved for use at Salem.
The training for the use of this new pro-
cedure was just completed at the end of the SALP period and the con-
trol of T-MODs at Salem is in a transition period for using the new
procedure.
The purpose of the new procedure is to provide clearer
guidance than the old one.
Engineering problem evaluations are generally adequate.
However, the
licensee 1 s response to discrepant system flow measurement devices was
initially too narrowly focused.
10 CFR Part 21 reviews and notifica-
tions are appropriately executed.
..
24
Technical support for refueling and maintenance outage periods and
for post outage recovery activities was noted as being effective.
Both E&PB and onsite system engineering participated in and inter-
faced with the outage organization on a daily basis.
Reactor engi-
neering was noted as providing strong support during fuel movement
activities, and during reactor startup and power ascension testing.
The licensee established project task forces led by E&PB managers to
address specific technical issues and problem areas.
These included
ECCS pump and flow problems and MSIV circuitry design.
These task
forces effectively integrated offsite, onsite and contractor engi-
neering groups.
The licensee 1 s site and corporate management were
actively involved in the resolution of these technical issues.
The technical justification for amendment requests was mostly satis-
factory and exhibited good responsiveness to NRC issues and concerns.
However, the technical justification that accompanied requests for
emergency changes to the Technical Specifications was not of the same
quality.
Examples included main steam isolation valve timing and
charging pump excess fl ow submittal s.
These changes required the
licensee to augment its application with significant amounts of addi-
tional information.
The technical information included in licensee
responses to NRC
Bulletins, Generic
Letters,
and other licensee
requests was generally timely and adequate with sufficient detail to
allow a determination concerning the acceptability of the licensee 1 s
action.
One exception was the response to Bulletin 88-04, Potential
Safety Related Pump Loss.
In that response the licensee did not
recognize that the existing system alignment made the Salem Unit 1
pumps
potentially susceptible to the
strong
pump/weak
pump
interaction.
The
licensee has maintained adequate control
over the inservice
inspection (ISI) Program, and has completed required inspections and
examinations for the first interval without undue recourse to exten-
sion and deferral requests.
The licensee has performed inspections
in excess of the technical specification requirements in all steam
generators to determine the operating condition of the generators,
and to assure safety and reliability of the NSSS
system.
Also,
recognizing the importance of the
11ALARA
11 concept, the licensee pro-
vided adequate training, controls, and maximum effective automation
for these inspections and examinations.
Forty-eight of 87 licensee event reports (LERs) were attributable to
this functional area.
The majority of these were due to radiation
monitoring system initiated actuations caused by design flaws.
PSE&G
is adequately addressing this area.
There were other LERs that were
identified by the licensee during their Configuration Baseline Docu-
mentation
(CBD)
project.
This design basis *reconstitution is a
III.F.2
III.F.3
III.G
III.G.1
25
positive licensee initiative (Section III.G).
Two of the six auto-
matic reactor trips during the period were attributed to the engi-
neering/technical support area.
The causes of these trips were a
personnel error leading to an unauthorized modification, and untimely
corrective actions for a previously identified inadequate modifica-
tion design.
In
summary,
the corporate engineering (E&PB)
performance, design
change control; communications between E&PB and the plants have been
very good.
Inconsistencies were observed in the quality of work per-
formed by the systems engineers.
There have been several examples
of misuse of the temporary modi fi cation program.
The requests for
license amendments were adequately supported with the exception being
those requests made under emergency circumstances.
Other licensee
submittals and responses to generic correspondence have been timely
and provided the requested information.
These exhibited adequate
management
support,
attention
to
detail
and
interdepartmental
communications.
Performance Rating
Category:
2
Trend:
NA
Board Comments
None
Safety Assessment/Quality Verification
Analysis
This area assesses the effectiveness of the licensee's programs pro-
vided to assure the safety and quality of plant operations and activ-
ities.
During the previous period the licensee was evaluated as
Category 2 in this functional area.
The last assessment noted that
licensee management generally displayed an adequate safety perspec-
tive, however, continued management attention to assure consistency
in the quality and timeliness in licensee submittals was needed.
To
correct a licensee recognized need for improved quality performance
and personnel accountability, enhanced management communication and
corrective action programs had been developed.
Implementation of
these programs had begun, but completion of the programs and con-
tinued management oversight was necessary.
26
At the beginning of this assessment period, a number of new programs
were instituted by the licensee to correct the noted concerns.
Cor-
porate and station management continue to be involved in the conduct
of operations and in the resolution of unplanned occurrences.
Sta-
tion management is directly involved in the daily oversight of unit
operations.
Corporate management was observed onsite and in the
plant during normal and off-normal working hours.
Senior Nuclear
Shift Supervisors were held accountable for unit operations and had
direct access to station management.
Daily meetings were held to
provide an operational perspective to unit problems and for work
prioritization.
First and
second line supervisors were directly
involved in field activities.
Worker performance during the period
was adequate.
Other than for routine material condition problems, (see Section
III.C.), the licensee had a generally effective program for problem
identification.
Plant deficiencies and events were documented using
incident reports.
These reports were discussed at shift turnover and
at the daily morning status and management meetings.
There were
several instances of late or poor 10 CFR 50.72 and 50.73 reports.
Examples include engineering safeguards feature actuations caused by
radiation monitoring systems and a residual heat removal (RHR) over-
pressurization
event.
Root
cause
determination
and
corrective
actions were generally adequate.
The ltcensee has implemented a root
cause training program.
There were several instances where initial
corrective actions were either incomplete or ineffective.
Examples
include
emergency
core
cooling
system
(ECCS)
pump
surveillance
deficiencies, overdue biennial procedure reviews, and late station
qualified reviewer training.
At the beginning of the period, management promulgated worker stand-
ards and provided training which has improved worker performance and
procedure compliance.
PSE&G has been successful in
reducing the
number of personnel errors and reactor trips.
An effective trip
reduction program included
11 scram-a-gram
11 notices, reactor trip warn-
ing signs on sensitive equipment, and independent verification of
trip sensitive surveillance procedures.
Two
reactor trips (both
while shutdown) were caused by personnel errors.
One was caused by
an operations error during atmospheric steam dump operation and the
other by an engineering and technical support error resulting from a
1987 plant modification.
Management
has been aggressive in disseminating and instilling a
safety conscious attitude among station personnel.
There have been
effective results as evidenced by the following conservative opera-
tions:
a voluntary unit shutdown because of main steam isolation
valve (MSIV) operability concerns; extending shutdowns for both units
to resolve ECCS concerns; successful reactor coolant system midloop
operation with detailed procedures and training; and voluntary unit
..
27
power reductions to avoid transients.
However, at times management
appeared to tolerate deficient conditions.
Examples of this toler-
ance include MSIVs drifting off their open latch; open fire doors;
and continuing degraded material condition of both
uni ts.
Al so,
worker overtime was, at times, not properly controlled by station
management.
Station Operations Review Committee (SORC) review of reactor trips,
design changes, significant technical issues, and reportable events
were usually thorough
and timely.
However,
there
were
several
occasions where SORC reviews were weak, such as (1) the failure to
identify an
system single failure vulnerability, (2) an
closure circuit failure to "seal in", with a subsequent modification
providing an uncontrolled steam generator vent path to the environ-
ment, and (3) a non-conservative interpretation of Technical Specifi-
cation 3.0.3.
At Salem, personnel designated as Station Qualified Reviewers (SQRs)
are used to decide whether a safety evaluation and subsequent SORC
review is necessary.
Because of incomplete screening criteria and a
misunderstanding on the part of SQRs and station management,
?Orne
issues that should have been reviewed by SORC were not.
Included
were both procedure changes and facility changes.
This was a pro-
grammatic control
problem, but no safety issues were identified.
Licensee safety evaluations, when completed, were found to be of high
quality.
The Quality Assurance (QA) Department, the Onsite Safety Review Group
(SRG) and the Offsite Safety Review Group provided effective, inde-
pendent
review
of
plant
activities.
The
organization
has
developed and used performance based surveillance of station activ-
ities.
involvement
in
radwaste
processing
is
considered
a
strength.
Post trip reviews and other investigations by the SRG were
effective in determining root cause and providing good corrective
action recommendations.
In addition, PSE&G has instituted an event
review process entitled "Significant Event Response Team" (SERT).
A
SERT is initiated by the station general manager and is a real time,
independent review of any
unplanned reactor trips or other major
station event.
The
SERTs effectively developed the
sequence of
events, determined root cause(s) and recommended corrective actions.
In one instance, shortcomings associated with a SERT evaluation were
identified by PSE&G management and corrected.
The Human Performance
Evaluation System, a detailed analysis method for determining root
cause of incidents involving personnel error is also utilized by the
licensee.
28
Direct inspection of station activities through inspection hold
points by Quality Control (QC) has been significantly reduced over
the past several years.
Additionally, the administrative processes
to identify, document, and resolve adverse conditions were at times
not aggressively applied.
Examples include the reassembly of a main
steam drain valve with an unacceptable seating surface, and the fail-
ure to install the required washer kit and properly tighten flange
fasteners on service water system repairs.
Management attention in
this area is needed for assurance that those conditions are properly
evaluated.
PSE&G has revised their guidance for QC inspection and
hold points, and increased QA surveillance of maintenance activities.
The overall design process was well controlled and contained appro-
priate checks and balances.
There was an emphasis on nuclear safety
as evidenced by discussions with personnel related to upgrading of
procedures and implementation of new initiatives, such as the Con-
figuration
Baseline Documentation project, which is intended to
reconstitute the design basis for many of the major plant systems.
Inadequate station procedures continue to be a contributing root
cause for both reportable and non-reportable events.
PSE&G initiated
a procedure upgrade project (PUP) last assessment period and provided
additional resources this period.
The PUP was an important initia-
tive; however, the program has encount.ered implementation problems.
These included program scope changes, a variable resource allocation,
and re-definitions of an end product.
Also, the required biennial
reviews of existing procedures were not completed in a timely manner.
These
items
have
resulted in significant setbacks in
upgrading
station procedures.
Licensee
performance
in
routine
licensing
activities,
in
most
instances, has been adequate.
Requests for additional information
were necessary in over half the cases.
PSE&G is usually very respon-
sive to the requests for information.
Non-routine licensing activity
(i.e.,
emergency
requests,
exigent requests)
in
most
instances
required significant followup by the staff with PSE&G to obtain the
requisite additional information.
PSE&G
was
responsive to these
requests and provided the requested information in a timely manner.
PSE&G 1 s response to generic NRC correspondence (Bulletins, Generic
Letters) was generally timely and with sufficient information that a
judgement concerning the suitabi 1 ity of the position taken. by them
could be made.
In one instance PSE&G failed to recognize a possible
strong pump/weak pump interaction in the RHR system.
(See Section
III.F.)
PSE&G has shown inconsistent performance in resolving the
open TMI Action Plan items.
For example, PSE&G was responsive in
adding the upgrade to the subcooling margin monitor to the Unit 2
refueling outage work list at a late date.
However, the post acci-
dent sampling system was to be upgraded by the end of March 1990.
While it was in a licensee tracking system it had not been properly
flagged and the due date was missed.
III.G.2
III.G.3
29
In summary, corporate and station management involvement in station
activities have improved.
Management continued to be involved in
problem resolution and the assurance of nuclear safety.
Initiatives
taken by management such as the SERT formation and their efforts in
instilling a safety conscious attitude among station personnel are
particularly noteworthy.
The two safety review groups, Onsite and
Offsite, have provided effective, independent review of plant activ-
ities.
SORC reviews, in some cases, have failed to identify safety
issues that required additional consideration.
The use of SQRs, in
some cases, have raised the threshold for SORC
review beyond the
expected threshold.
involvement in station activities has not
been sufficient to assure that adequate independent review is being
maintained.
The material condition of the plants is poor and needs
management attention.
Inadequate procedures ar~ a frequent contrib-
utor to plant events and the implementation of the PUP was delayed.
Effective and timely implementation of the PUP is important to the
continued safe operation of the Salem units.
Closer attention should
be paid to the details provided in responses to generic correspond-
ence and to other licensing submittals.
Performance Rating
Category:
2
Trend:
NA
Board Comments
Licensee initiatives such as the PUP
and materiel condition
improvement
program
require
increased
and
more
aggressive
management attention to ensure completion.
IV.
SUPPORTING DATA AND SUMMARY
IV.A LICENSEE ACTIVITIES
BACKGROUND
The assessment period began May 1, 1989, with Unit 1 in its eight refuel-
ing outage and the Unit 2 reactor operating at full power.
Unit
1 was restarted and placed on-line on July 18, 1989.
occurred
at
Unit
1
on
June 9, 1989,
June 19, 1989,
April 3, 1990 and April 9, 1990.
These trips and other unit unplanned
shutdowns occurring during the assessment period are further detailed in
Section III.C.
Extended forced outages occurred April 11 -
June 7, 1990
(emergency core cooling system deficiencies) and July 22 - July 31, 1990
(main steam isolation valve concerns).
The unit remained shutdown at the
end of the assessment period.
- -
30
A manual reactor trip was initiated at Unit 2 on June 10, 1989 and an
automatic reactor trip occurred on June 28, 1990.
These trips and other
Unit 2 unplanned shutdowns are further detailed in Section III.C.
On
March 31, 1990, the unit shutdown for its fifth refueling outage.
The
Unit restarted on June 24, 1990.
Extended forced outages occurred on
October 13 -
November 5, 1989 (main power transformer rep 1 acement) and
June 30 -
July 31, 1990 (main steam isolation valve concerns).
The Unit
remained shutdown at the end of the assessment period.
IV.B NRC Inspection and Review Activities
Two resident inspectors were assigned to the site throughout the assess-
ment period.
Regional inspectors performed routine inspections throughout
the period, with added inspection emphasis during the scheduled refueling
outages.
In
addition to the routine inspections,
the following
NRC
special and team inspections were conducted as follows:
May 22 through 26, 1989; Unit 1 Special Inspection to review the loss
of the residua 1 heat remova 1 system event that occurred during sur-
vei 11 ance testing.
May 27 through July 10, 1989; Special Inspection to review inadequate
response time testing of main and bypass feedwater regulating control
valves.
November 17 through 29, 1989; Special Inspection to review the iden-
tification of a single failure vulnerability in the emergency core
cooling system.
November 29 through December 1, 1989; Unit 1 Special Inspection to
review circumstances surrounding an entry into Technical Specifica-
tion 3.0.3 during a turbine volumetric flow test.
-
January 10
through 25, 1990;
Emergency Operating Procedures Team
Inspection.
March 12 through 15, 1990; Team Inspection of the Artificial Island
Fitness-for-Duty Program.
Apri 1 9 through 13 and Apri 1 23 through 27, 1990; Maintenance Team
Inspection.
31
April 11 through 18, 1990; Special Inspection to review circumstances
surrounding the m.iscalculation of safety injection pumps' flow rates
in the associated flow balance verification surveillance procedure.
~ay 14
through
25, 1990;
Integrated Performance Assessment
Team
Inspection.
IV.C Significant Licensee Meetings
An
Enforcement Conference was
held on July 26, 1989
in the NRC
Region I office to discuss potential violations associated with the
inoperability of the feedwater isolation system at both Salem units.
A
Severity
Level
IV
violation
was
subsequently
issued
on
August 9, 1989.
An Enforcement Conference was held on December 11, 1989 in the NRC
Region I office to discuss potential violations associated with the
i dent ifi cation of a sing 1 e failure vulnerability in the emergency
core cooling system and related licensee activities.
Circumstances
surrounding entries into Technical
Specification 3.0.3 were also
discussed at the meeting.
Three Severity Level
IV violations were
subsequently issued on January 8, 1990.
A Management
Meeting
was
held on
F~bruary 26, 1990
in the
NRC
Region I office to conduct a mid-SALP cycle review and evaluation of
licensee performance.
An
Enforcement Conference was
held on
May 18, 1990 in the
NRC
Region I office to discuss the circumstances related to the identi-
fication of miscalculations of emergency core cooling system flow-
rates during surveillance testing.
One Severity Level
IV violation
was subsequently issued on June 8, 1990.
IV.D Reactor Trips and Unplanned Shutdowns
Unit 1
Event Description
Date
Power
Root Cause
Functional Area
1.
An automatic safety injection/reactor trip occurred while in Mode 3 (Hot
Standby) due to a high steam line differential pressure condition. created
by internal steam line pressure oscillations.
A 1987 modification was
determined to have been implemented which installed an unidentified valve
(closed) in the common steam line drain header, which prevented draining
saturated water that had accumulated in the steam lines.
Neither the
comp uteri zed tagging system nor the associated system drawings reflected
the valve addition.
6/9/89
Shutdown
Personnel error
Engineering/Technical
Support
\\j_
32
Unit 1 (Continued)
Event Description
Date
Power
Root Cause
Functional Area
2.
An unplanned shutdown occurred due to an inoperable safeguards equipment
control (SEC) train lA.
The SEC failed the surveillance test and was
declared inoperable.
Licensee troubleshooting replaced some components.
Further testing proved operability.
6/18/89
20%
Component failure
Not Applicable
3.
The reactor tripped automatically on low-low steam generator water level
due to main steam isolation valve (MSIV) closure during a post-maintenance
surveillance test of MSIV bypass valves.
A design deficiency was identi-
fied in the MSIV continuity check circuitry, which al lowed voltage to
remain high for a sufficient time period and reset a latching relay, caus-
ing the MSIV inadvertent closure.
A Unit 2 reactor trip occurred from
full power due to the failure of the same relay approximately two months
earlier (previous SALP period). Subsequent to the reactor trip, an 8-day
unplanned shutdown commenced from Mode
3 on June 20, 1989 to repai.r a
leaking safety injection system check valve (No. SJ55).
6/19/89
45%
Untimely corrective
actions
Engineering/Technical
Support
4.
An unplanned shutdown was made due to the failure of the speed increaser
bearing on a safety injection charging pump.
The unit was cooled down
further to Mode 5 following the identification of a leaking safety injec-
tion system check valve (No. SJ56).
12/1/89
100%
Component failure
Not Applicable
5.
An unplanned shutdown was made due to an inoperable safeguards equipment
control (SEC) train lA.
The SEC actuated following testing and licensee
troubleshooting could not determine a specific cause.
The
licensee
declared the SEC
replaced the electrical chassis, tested
satisfactorily, and declared the SEC operable.
3/27/90
100%
Component failure
Not Applicable
6.
The reactor tripped automatically while in Mode 3 on low-low steam gener-
ator water level due to personnel error.
A licensed operator failed to
establish optimum operating conditions prior to transferring main steam
atmospheric dump control from one steam generator to another.
This was
aggravated due
to auxiliary feedwater flow indication abnormalities.
4/3/90
Shutdown
Personnel error, poor
supervisory oversight
Operations
f..
33
Unit 1 (Continued)
Event Description
Date
Power
Root Cause
Functional Area
7.
The reactor tripped automatically on low-low steam generator water level
due to the loss of one main feedwater pump.
The pump went to idle speed
due to the failure of the governor valve control linkage.
A pin bushing
in the linkage assembly was missing and an associated lock nut was found
installed backwards.
Subsequent to the reactor trip, an extended shutdown
commenced on April 11, 1990 due to emergency core cooling system fl ow
discrepancies.
4/9/90
90%
Inadequate procedure
Maintenance/Surveillance
8.
An unplanned shutdown was made to evaluate potential deficiencies asso-
ciated with the main steam isolation valves' ability to close under cer-
tain postulated conditions, and to resolve main
steam line isolation
circuitry deficiencies identified relative to the original circuit design.
7/22/90
100%
Event Description
Power
Date
Level
Inadequate design
Unit 2
Root Cause
Engineering/Technical
Support
Functional Area
1.
An
unplanned shutdown was made to resolve feedwater regulating -control
valve (FRV) response time testing inadequacies.
Inadequate surveillance
procedures prevented i dent i fi cation of design/performance problems with
the FRVs.
5/27/89
50%
Inadequate procedure
Maintenance/Surveillance
2.
The reactor was tripped manually after five of the six circulating pumps
had become inoperable due to high differential pressure across the asso-
ciated circulating water system screens.
A large accumulation of grass
and debris fo 11 owing a recent storm caused the high screen differential
pressure.
A periodic preventive maintenance activity to periodically
clean the lower portion of the intake trash racks was not established
following a similar event in 1983.
6/10/89
100%
Ineffective
corrective actions
Maintenance/Surveillance
-------
Event Description
Power
Date
Leve 1
34
Unit 2 (Continued)
Root Cause
Functional Area
3.
An unplanned shutdown was made to replace a degraded phase B main power
transformer.
Periodic monitoring identified an elevated total combustible
gas concentration, indicating the presence of an internal hot spot (700
degrees F).
10/13/89
90%
Component failure
Not Applicable
4.
An unplanned shutdown was made to repair a leak on a welded pipe cap on
the discharge side of the boron injection tank.
The cause of the leaking
joint was attributed to a defect in the root of the weld that occurred
during a modification.
1/17/90
100%
Modification
installation error
Maintenance/Surveillance
5.
The reactor tripped automatically on low steam generator level coincident
with steam/feed fl ow mismatch fo 11 owing a loss of feedwater caused by a
460 volt transformer failure.
A similar catastrophic transformer failure
occurred on Unit 1 about one week earlier,. however, significant opera-
tional problems were not experienced.
Subsequent to the reactor trip, an
extended unplanned shutdown was made to evaluate and resolve main steam
isolation valve fast closure circuitry deficiencies.
6/28/90
75%
Component failure
Not Applicable
- '
TABLE 1
Inspection Hours Summary
Salem Generating Station
May 1, 1989 - July 31, 1990
Annualized
Functional Area
Hours*
Hours
% of Time
A.
Plant Operations
2912
2257
44
B.
Radiological Controls
303
235
5
C.
Maintenance/Surveillance 1340
1039
21
0.
151
117
2
E.
Security and Safeguards
243
188
4
F.
Engineering/Technical
Support
594
460
9
G.
Safety Assessment/
Quality Verification
959
743
15
TOTALS
6502
5039
100
- Does not include NRC licensing staff hours.
.,
TABLE 2
Enforcement Summary
Salem Generating Station
May 1, 1989 - July 31, 1990
Number/Severity of Violations
Functional Area
Level IV
Deviation
A.
B.
C.
D.
E.
F.
G.
Plant Operations
4*
Radiological Controls
3*
Maintenance/Surveillance
7**
Security
Engineering/Technical
Support
1
Safety Assessment/
Quality Verification
5**
TOTALS
19
1
Violation cited two examples, one in operations and one in radiological
controls areas.
Violation cited two examples, one in maintenance/surveillance and one in
safety assessment/quality verification areas, and is therefore included
in both areas.
Functional Area
A.
Plant Operations
B.
Radiological Controls
TABLE 3
Licensee Event Reports
Salem Generating Station
May 1, 1989 - July 31, 1990
Number by Cause
A B
C D E
X
7
2
1
5
1
1
C.
Maintenance/Surveillance
8
4
7
2
1
D.
E.
Security
F.
Engineering/Technical
Support
G.
Safety Assessment/
Quality Verification
Tota 1 s
6
31
2
1 8
23
35
2
9 16
2
Subtotal
13
4
22
48
87
Includes Unit 1 LERs 89-18 through 89-37 and 90-01 through 90-20; and, Unit 2
LERs 89-10 through 89-27 and 90-01 through 90-30.
Cause Codes:
A.
Personnel Error
8. *oesign, manufacturing or installation
C.
Un known or externa 1 cause
D.
Procedure inadequacy
E.
Component failure
X.
Other
Root causes assessed by the SALP Board may differ from those listed in the
LER.
ATTACHMENT 1
Salp 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 environ-
ment.
Some functional areas may not be assessed because of little or no
licensee activities or lack of meaningful observations in that area.
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.
Enforcement hi story;
4.
Operational and construction events (including response to, analyses of,
reporting of, and corrective actions for);
5.
Staffing (including management); and
6.
Effectiveness of training and qualification program.
On the basis of the SALP Board assessment, each functional area evaluated is
rated according to three performance categories.
The definitions of these
performance categories are given below:
Category 1.
Licensee management attention to and involvement in nuclear safety or
safeguards activities resulted in a superior level of performance.
NRC
will consider reduced levels of inspection effort.
Category 2.
Licensee management attention to and involvement in nuclear safety or
safeguards activities resulted in a good level of performance.
NRC will
consider maintaining normal levels of inspection effort.
>.; '
' .**
Attachment 1 (Continued)
2
Category 3.
Licensee management attention to and involvement in nuclear safety or
safeguards activities resulted in an acceptable level of performance; how-
ever, because of the NRC' s concern that a decrease in performance may
approach or reach an unacceptable level,
NRC will consider increased
levels of inspection effort.
Category N.
Insufficient information exists to support an assessment of licensee per-
formance.
These cases would include instances in which a rating could not
be developed because of insufficient licensee activity or insufficient NRC
inspection.
The SALP Board may assess a functional area to compare the licensee's perform-
ance 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:
Declining:
Licensee performance was determined to be improving
Licensee performance was determined to be declining and the
licensee had not satisfactorily addressed this pattern.
A trend is assigned only when, in the opinion of the SALP Board, the trend is
significant enough to be considered indicative of a likely change in the per-
formance
category in the near future.
For example,
a classification of
"Category 2, Improvi ng
11 indicates the cl ear potential for "Category 111 perform-
ance in the next SALP period.
It should be noted that Category 3 performance, the lowest category, represents
acceptable, although minimally adequate, safety performance.
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
dealt with independently from, and on a more urgent schedule than, the SALP
process.