ML18102B322
| ML18102B322 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 05/20/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18102B320 | List: |
| References | |
| 50-272-97-07, 50-272-97-7, 50-311-97-07, 50-311-97-7, NUDOCS 9705280116 | |
| Download: ML18102B322 (46) | |
See also: IR 05000272/1997007
Text
Docket Nos:
License Nos:
Report No.
Licensee:
Faciiity:
Location:
Dates:
Inspectors:
Approved by:
U. S. NUCLEAR REGULATORY COMMISSION
50-272, 50-311
REGION I
50-272/97-07, 50-311 /97-07
Public Service Electric and Gas Company
Salem Nuclear Generating Station, Units 1 & 2
P.O. Box 236
Hancocks Bridge, New Jersey 08038
March 16, 1997 - April 26, 1997
C. S. Marschall, Senior Resident Inspector
J. G. Schoppy, Resident Inspector
T. H. Fish, Resident Inspector
R. K. Lorson, Resident Inspector
L. N. Olshan, Project Manager
J. 0. Noggle, Radiation Protection Specialist
E. B. King, Physical Security Specialist
G. C. Smith, Physical Security Specialist
James C. Linville, Chief, Projects Branch 3
Division of Reactor Projects
9705280116 970520
ADOCK 05000272
Q
EXECUTIVE SUMMARY
Salem Nuclear Generating Station
NRC Inspection Report 50-272/97-07, 50-311 /97-07
This integrated inspection included aspects of licensee operations, engineering,
maintenance, and plant support. The report covers a 6-week period of resident inspection;
in addition, it included the *results of announced inspections by regional security and
radiation protection inspectors.
Operations
In general, operators continued to exercise conservative and deliberate control over outage
activities. For example, operators generally performed well during the draindown to mid
loop, while in mid-loop, and in restoration from the mid-loop condition. Station and
operations management promptly and appropriately identified and corrected the causes of
minor performance weaknesses that occurred during the evolution. (Section 01.2).
Infrequent lapses in operator performance continued, however, to occur. In this period,
less than adequate technical specification tracking, knowledge deficiencies concerning vital
instrument bus inverter operation, and poor operator turnover resulted in an NRC-identified
violation of technical specifications concerning electrical bus train operability. The
operators and plant management took prompt and appropriate action to restore the correct
electrical configuration, identify the cause, and prevent recurrence. (Section 02.1 ).
A lapse occurred in the attention to proper implementation of the operator workaround
program as a result of operations staff personnel changes. The existing operator
workarounds did not adversely impact plant safety, however, continued inattention to
underlying deficient conditions could adversely impact availability of plant equipment. The
Operations Work Control Superintendent initiated corrective actions to improve
performance in this area (Section 02.2). Operators continued to demonstrate greatly
improved ownership of plant equipment. The operators demonstrated ownership by
notifying plant management that an industry issue affecting emergency diesel generator air
start systems applied to Salem. As a result, support staff initiated corrective actions.
(Section 03.2).
Management oversight has improved the quality of equipment and personnel performance.
For example, inspectors concluded that the PSE&G staff significantly improved the tagging
program. The program changes, combined with improved operator procedure adherence,
sharply reduced the frequency of tagging errors and eliminated breakthrough events. The
tagging program is ready to support restart (Section 03.1 ). In addition, effective
implementation of the Salem Assessment Restart Action Plan resulted in establishment of a
new self assessment, development of procedures to improve the use and effectiveness of
self assessme-n:t;-conduct of comprehensive self assessments that documented
weaknesses, and an increased percentage of self-identified issues. The inspectors
concluded that the area of self assessment is ready for restart. (Section 07 .1)
Implementation of the Salem Human Performance Management Restart Action Plan
resulted in significant improvement in the quality of oversight, teamwork, and assessment
of worker performance. The inspectors concluded that it is too early to judge the
ii
effectiveness of the trending results of the human performance errors, and that
management/supervisory presence in the field needed improvement. However, on balance,
the inspectors concluded that the improvements in human performance management were
adequate to support restart. {Section 07.2)
Maintenance
The inspector concluded that PSE&G made significant improvements in the Foreign
Material Exclusion {FME) program since the shutdown of the Salem units in mid 1995. In
addition, management continues to respond to problems and to make progress in improving
overall FME compliance. Inspectors concluded that the FME program 1s sufficient to
support the restart of Salem Units 1 and 2. (Section M1 .2) The PSE&G staff has also
made significant improvement since the shutdown of the Salem units in mid 1995. In
addition, management continues to respond to problems and continues to make progress in
improving overall tagging compliance. This issue is no longer considered a restraint to the
restart of Salem Units 1 and 2. {Section M1 .3)
The ability to plan and schedule work, then accomplish the work according to the schedule
and plan has been a long-standing weakness at Salem. The Salem management and staff
made significant improvement in the effectiveness of planning and scheduling during the
current shut down. During the current inspection period, plant management implemented
the twelve week work schedule to further improve the effectiveness of planning and
scheduling, and to reduce distractions and potential challenges to control room staff.
{Section M7. 1 )
Engineering
Engineering did not adequately provide sufficient time for installation and testing of the
CFCU modification consistent with the outage plan. Design engineers, quality assurance
inspectors and senior nuclear shift supervisors provided frequent oversight of the
installation. {Section E2.1 ).
In a letter to th.e NRC dated April 10, 1997, PSE&G provided a basis for reasonable
assurance the Salem Technical Specification Surveillances and implementing procedures
are adequate to support restart. (Section E7. 1)
Plant Support
The licensee provided very effective exposure controls limiting individual exposures to only
necessary and expected values. Continued diligence is necessary to ensure accurate
postings reflect survey results and for the timely removal of unnecessary radiological
hazards. The internal exposure assessment program has begun improving, but continues
to exhibit weaknesses in staff training and procedure development. RP corrective action
assignment has improved, however, the guidance has yet to be captured in a station-
approved procedure. For several years, the RP services group has not provided ALARA
program and RP program assessments as required, which resulted in a violation .
iii
. '
The security program was determined to be adequate to protect public health and safety .
Appropriate corrective actions have been implemented to address previously identified
weaknesses in the program. The alarm station operators were knowledgeable of their
duties and responsibilities and security training was being performed in accordance with
the NRC-approved training and qualification plan. Protected area detection equipment
satisfied the NRC-approved Physical Security Plan (the Plan) commitments, security
equipment testing was being performed as required by the Plan, and maintenance of
security equipment was being performed in a timely manner as evidenced by minimal
compensatory posting associated with security equipment repairs. Based on observations
and discussions with security officers, the inspectors determined that they possessed the
requisite bowledge to carry out their assigned duties and that the training program was
effective. As an addition to the inspection, the UFSAR initiative, Section 4.2.2 of the Plan
titled, "Vehicle and Cargo Controls," was reviewed. The inspectors determined, based on
discussions with security supervision, procedural reviews, and observations, that vehicles
were being searched and controlled prior to entry into the protected area as described in
the Plan and applicable procedures.
/
iv
,.
TABLE OF CONTENTS
EXECUTIVE SUMMARY .............................................. ii
TABLE OF CONTENTS .............................................. * v
I. Operations .................... ; . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1
II. Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
14
Ill. Engineering .............................................. *. . . .
21
IV. Plant Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
25
V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
38
v
Report Details
Summary of Plant Status
Unit 1 remained defueled for the duration of the inspection period.
Operators maintained Unit 2 in Mode 5, Cold Shutdown, for the duration of the period.
I. Operations
01
Conduct of Operations
01.1
General Comments (71707)
Using Inspection Procedure 71707, the inspectors conducted frequent reviews of
ongoing plant operations. In general, the conduct of operations was professional
and safety-conscious; specific events and noteworthy observations -are detailed in
the sections below.
01.2 Mid-Loop Operations - Unit 2
a.
Inspection Scope
The inspectors reviewed the activities associated with the drain down, operation in
and restoration from a mid-loop condition at Unit 2. Th~ licensee established the
mid-loop conditions to repair several leaking steam generator manway covers. The
operators performed the drain down in accordance with operating procedure S2.0P-
SO.RC-0006, Draining The Reactor Coolant System < 101 FT With Fuel In The
Vessel, and restored the plant in accordance with operating procedure, S2.0P-
SO.RC-0002, Vacuum Refill Of The RCS.
b.
Observations and Findings
The inspectors noted several performance strengths during the drain down and
recovery evolutions including:
Strong plant management oversight as demonstrated by two special planning
meetings and by assignment of a test engineer to supervise the evolutions.
Good control room operator focus on key reactor plant parameters during the
drain down and refill.
.
- -
A thorough pre-drain down briefing that included discussion of the
compensatory actions for an unplanned loss of the residual heat removal
(RHR) system.
An instrument and controls technician appropriately identified and addressed
a problem involving maintenance procedure S2.IC-CC.RHR-0005, that
verified proper operation of the "Mid Loop" trouble alarm. Additionally, the
licensee initiated an action request to review the alarm logic and setpoints to
minimize the frequency of spurious alarm actuations.
..
2
Proper installation of the temporary equipment including the temporary level
indication tubing, and the establishment of reactor system pressure vent
paths through pressurizer system spray valve (PS25), and through pressure
relief valves (PR 1 and 2).
The inspector reviewed engineering evaluation, S-2-RC-MEE-1198, that evaluated use of
the PS-25 vent path. The evaluation contained conservative assumptions and provided
adequate justification for use of the PS-25 vent path.
Despite the generally good oversight and performance of this evolution the inspector noted
some minor performance weaknesses including:
The plant equipment operator did not consistently close the reactor vessel
water level indication tubing isolation valve, and the 52.0P-SO.RC-0006
procedure did not provide guidance for leaving the valve open. The
operations manager initiated an action request to enhance the procedural
controls for this valve.
The 52.0P-SO.RC-0002 procedure did not provide any limits or precautions
for monitoring the rate of temperature change during the vacuum refill of the
reactor plant. The inspector noted that the measured cooldown rate
remained within the allowable technical specification cooldown rate 100
° F/hour. An operations supervisor initiated an action request to review
whether additional temperature controls were required for this procedure.
The inspector considered the performance weaknesses minor and observed that the
licensee appropriately addressed each issue.
c.
Conclusions.
Operators performed well during the drain down to mid loop, control of the plant
while in mid-loop, and restoration from the mid-loop condition. The inspectors
noted some minor performance weaknesses that station and operations
management addressed promptly.
02
Operational Status of Facilities and Equipment
02.1
Vital Instrument Bus Operability
a.
Inspection Scope (71707)
The inspector reviewed control room narrative logs and equipment status to ensure
operation of the facility in accordance with technical specification (TS)
requirements.
b.
Observations arid Findings
At 11 :01 p.m. on April 7, 1997, with Unit 2 in mode 5 and with the nos. 2A and
28 electrical bus trains operable, operators transferred the no. 2C vital instrument
..
3
bus inverter to its alternate AC source in preparation for no. 2C 1 25 vdc bus
outage. At 12:36 a.m. on April 8, operators locked out the 2C emergency diesel
generator (EOG) as part of the bus outage. Technical Specification 3.8.2.2 for
Salem Unit 2 require.s that, in modes 5 and 6, two operable AC electrical bus trains
energized from sources of power other than a diesel generator but aligned to an
operable diesel generator. Each train consists of one 4KV vital bus, one 460V vital
bus and associated control centers, one 230V vital bus and associated control
centers, and one 115V instrument bus energized from its respective inverter
connected to its respective DC bus. At 1: 13 a.m. on April 8, operators declared the
2A EOG inoperable following a 2A safeguards equipment control trouble alarm. The
safeguards equipment control starts its respective EOG on under voltage or accident
conditions, and controls the sequence of the safeguards equipment onto the
associated vital bus. Th.e Technical Specification 3.8.2.2 action statement requires
that with less than two operable vital bus trains, establish containment integrity
within eight hours. Operators entered the TS 3.8.2.2 action statement and began
to restore the 2C EOG. At 4:42 a.m. on April 8, following a 2C EOG operability
run, operators declared 2C EOG operable and exited TS 3.8.2~2.
At approximately 1 :00 p.m. on April 8, the inspector noted that operators
considered the 2A EDG inoperable and the 2C electrical bus train operable. The
operators had not, however, realigned the 2C vital instrument bus to its inverter as
required by TS 3.8.2.2* .. The operating shift did not know the 2C vital instrument
bus inverter alignment status and did not recognize the importance of that status
relative to TS requirements. During discussions with the inspector, the control
room operator recognized the significance of the inverter alignment, and initiated
action to restore the 2C inverter to its correct alignment. At 4:00 p.m. on April 8,
operators completed the restoration and appropriately exited TS 3.8.2.2.
The operators initiated a significance level 1 root cause analysis of the event (CR
970408283). Operations management improved the TS tracking log and mandated
additional operator training on inverter lineup and operability requirements. In
addition, operations management noted that the action statement requirement to
establish containment integrity would require isolating the residual heat removal
flow path, since the initial accident alignment of RHR in the safety injection mode
takes suction from the refueling water storage tank. Plant management stated their
intent to request a change to the action statement requirement, perhaps similar to
the standard technical specification requirement to suspend operations involving
core alterations, positive reactivity changes, or movement of irradiated fuel and to
initiate corrective action to restore the minimum required vital bus equipment.
_The event had no actual safety consequence, since.a loss of off-site power did not
occur during the period of time (approximately 1 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) that the licensee did not
maintain containment integrity with less than 2 AC electrical bus trains operable.
The problem had minor safety significance as a result of Unit 2 plant status
(shutdown for 22 months) and the operator's ability to maintain the facility in the
shutdown condition for an extended time period. The inspector concluded that
failure to establish containment integrity within eight hours with *only one operable
4
AC electrical bus train while in mode 5 (Cold Shutdown) is a violation of TS 3.8.2.2. (50-311 /97-07-01)
Subsequent to the event, the inspector identified that S2.0P-S0.115-0013,
Revision 5, 2C 115V Vital Instrument Bus UPS System Operation, Section 5.9.4 did
not contain adequate guidance to ensure TS 3.8.2.2 compliance when operating the
inverter on DC only. Operators initiated action to revise S2.0P-S0-115-0013. In
addition, the Operations Technical Support Superintendent identified that S2.0P-
ST.4KV-0002, Revision 7, Electrical Power Systems AC Distribution, did not check
Vital instrument bus inverter alignment to its AC supply in mode 5 or 6. Thus,
procedure S2.0P-ST.4KV-0002 did not satisfy the surveillance requirements of TS 4.8.2.2. The operations staff revised the procedure and satisfactorily performed the
surveillance within the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed by TS Section 4.0.3. The operations staff
initiated CR 970410123 to evaluate -the apparent cause for the inadequate
surveillance and to determine why the Technical Specification Surveillance
Improvement Project (TSSIP) phase one did not identify and correct_ the deficiency.
This licensee-identified and corrected violation of failing to properly test the vital
instrument bus inverter as required by TS 4.8.2.2 is being treated as a non-cited
violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy.
c.
Conclusions
- Less than adequate technical specification tracking, knowledge deficiencies
concerning vital instrument bus inverter operation, and poor operator turnover
resulted in an NRC-identified violation of technical specifications concerning
electrical bus train operability. The operators and plant management they took
prompt and appropriate action to restore the. correct electrical configuration, identify
the cause, and prevent recurrence.
02.2 Operator Workarounds and Control Room Deficiencies
a.
Inspection Scope (92901 l
The inspector' assessed the effectiveness of continued implementation of SC.OP-
AP .ZZ-0030, Operator Workaround Program.
b.
Observations and Findings
Salem procedure SC.OP-AP.ZZ-0030 established the Operations Manager's
expectations concerning the identification, tracking, and management of operator
workarounds and burdens. The inspector identified that the operations staff failed
to meet these expectations in the following areas:
The operations work control superintendent did not maintain an updated
workaround listing available to the operating shifts. (A 10-week old listing
was available in front of narrative log.)
5
The operations shift support superintendent did not ensure that operating
shifts were knowledgeable of operator workarounds and burdens.
The operations work control superintendent did not perform a quarterly
assessment to determine the aggregate impact of workarounds on the plant
and operator capabilities.
The operations work control superintendent did not coordinate effectively
with the maintenance department to remove operator workarounds and
operator burdens.
The operations work control superintendent promptly initiated actions to improve
operator awareness (including an updated listing in the control room) and to assess,
manage, and coordinate the removal of operator workarounds and burdens. The
inspector noted that the recent turnover of work control superintendents and
licensed operators directly responsible for the program contributed to the observed
weakness in this area.
c.
Conclusions
Operations management did not ensure proper implementation of the operator
workaround program. The existing operator workarounds did not adversely impact
plant safety, however, continued inattention to underlying deficient conditions could
prevent the normal operation of structures, systems and components. The
operations work control superintendent initiated corrective actions to improve
performance in this area.
03
Operations Procedures and Documentation
03.1
Operator Questioning Attitude (71707)
07
07.1
a.
Reactor operators demonstrated good questioning attitudes and a willingness to
improve technical specification surveillance procedures. Operators identified and
documented questions conc;:erning potential diesel generator preconditioning (AR
97040908), potential operation of pressurizer overpressure protection system
(POPS) outside the design basis (AR 97042114 7), and diesel generator hot restart
testing enhancements (AR 970424061 ). The inspector concluded that operators
demonstrated a safety-conscious questioning attitude to ensure appropriate
management review of potentially safety significant technical issues.
Quality Assurance in Operations
Self Assessment Capability, NRC Restart Item 111.21 (Closed) and Salem Restart
Assessment Plan (Closed)
Inspection Scope
The inspectors reviewed the licensee's self assessment program consisting of work
packages and associated procedures prepared by the licensee to satisfy the Salem
6
Self Assessment Restart Action Plan as defined in the licensee's letter of March 26,
1996, to determine whether the actions within the plan that are needed for restart
have been completed. The inspection also reviewed the implementation and
effectiveness of the program to meet the expected results cited in the plan through
audits of self assessment reports in the areas of maintenance, operations and
planning, and areas that needed significant improvement at the time of plant
shutdown. Interviews were conducted with the Supervisor, Salem Station Projects;
the Salem Self Assessment Coordinator;. and several members of the Quality
Assurance organization. The inspection was conducted followir.g the guidance for
self assessment inspections that was included in Inspection Procedure 40500.
b.
Observations and Findings
From July 9 through July 11, 1996, and from January 6 through January 9, 1997,
NRR inspectors performed an inspection of the Salem Self Assessment Restart
Action Plan. The inspectors reviewed the actions that the licensee had taken to
satisfy the items in the plan, Revision 8, dated July 16, 1996. The objective of the
plan was to develop the capability and acceptance of the Salem organization such
that self assessment is used effectively and routinely to improve performance
continually. The plan consists of two Problem Statements needing resolution to
achieve an acceptable self assessment program. Problem Statement . No. 1 stated
that the existing *self assessment program was limited in scope and that the results
did not accurately identify the root causes of performance weaknesses. Problem
Statement No. 2. stated that the Salem work force, in general, rarely performed self
assessments, and when they were performed, they were done so inconsistently:
The licensee expected to establish a new culture that encouraged self assessment is
an automatic and explicit step' of every action by each employee; established
procedures to improve the use and effectiveness of self assessment; conducted
comprehensive organization self assessments that document its major performance
weaknesses and the completed actions that address these weaknesses; and
demonstrated an inc.reased trend in the percenta~e of self identified issues.
Revision 8 to the plan indicated that all restart actions needed to address each of
the Problem Statements have been completed. The inspectors audited (or reviewed)*
all of the backup files for the Problem Statement actions to review the bases for
licensee's findings.
Following are some of the items reviewed by the inspectors: ( 1) the Self
_ Assessment procedure for routine operations, SC.SA-AP.ZZ-0034(0), Revision 1,
- (2) the Self Assessment procedure for restart following outages,-SC.SA-SD.ZZ-
0035(0), Revision 0, (3) the qualifications of the Salem Self Assessment
Coordinator, (4) Self Assessments of Maintenance (for the periods of October 5-20,
1995, February 20 -23, * 1996, and December 3 - 13, 1996), Radiation Protection
(for the period of June 1 through June 29, 1996), Operations (December, 1996),
and Planning (December 18, 1996), and (5) Self Assessment of the Self
Assessment Program (for the perioc.i of May 22 - June 15, 1996) .
7
In addition, the inspectors reviewed the closure documents for Problem Statement
No. 1, dated February 15, 1996, and Problem Statement No. 2, dated July 8,
1996. The inspectors verified completion of all the actions in the plan required prior
to restart.
Problem Statement No. 1 stated that the existing self assessment program was
limited in scope and the results did not accurately identify the root causes of Salem
performance weaknesses. To assess the actions taken to address Problem
Statsment No. 1, the inspectors reviewed 3everal of the Self Assessment
procedures, interviewed the Station Self Assessment Coordinator, and reviewed his
qualifications. The inspectors considered the self assessment program broad in
scope and effectively managed, and able to effectively identify performance
weaknesses. These weaknesses are then handled by the Corrective Action
Program, discussed in NRC Inspection Report 50-272/311, 96-18. This Inspection
Report notes improvement in root cause analysis skills and concludes that the
-
actions taken to improve the Corrective Action Program supported restart. Thus,
the inspectors concluded that the objectives of Problem Statement No. 1 of the
Self Assessment Restart Action Plan had been met.
Problem Statement No. 2 stated that, in general, the Salem work force rarely
performed self assessments, and when they were performed, they were done
inconsistently .
_With regard to the frequency of performing self assessments, the inspectors noted
that the Self Assessment procedure for routine operations stated that the frequency
should be based on the inputs from the preceding self assessments, but that at
least four per year should be performed. It also stated that at least one assessment
per year should address the department's performance in the area of Corrective
Actions. The Self Assessment Coordinator stated that the four self assessments
per year do not have to be assessments of the entire department, but rather of a*
particular departmental function.
The Self Assessment procedure for restart following outages required a full
department Self Assessment prior to restart from a refueling outage or extended
outage of approximately four weeks. The Self Assessment Coordinator informed
the inspectors that this procedure will be changed to require that a self assessment
be performed prior to restart from any outage, reactor trip or inadvertent safety
injection actuation and that the scope of that self assessment will be determined
based on the cause of the outage.
_The inspectors concluded that the frequency of self assessments required by these _
two procedures has been met and satisfies the part of Problem Statement No. 2
that states that the Salem work force rarely performed self assessments.
In order to assess the progress the licensee has made in meeting the inconsistency
statement of Problem Statement No. 2, the inspectors reviewed self assessment
reports in the areas of maintenance, operations, planning, and radiation protection .
The inspectors found that the comprehensive Self Assessments effectively identified
8
areas that needed improvement. For example, the Self Assessment of the
Maintenance Department for the period of October 5-20, 1995, concluded that
there were weaknesses that needed to be resolved before the Maintenance
Department would be ready to safely and reliably support restart of Salem and
continued safe full power operation. The Self Assessment was a contributing factor
in management's decision to impose the Maintenance Intervention and provide
training for department personnel. The Self Assessment for the period of December
- 3 - 13, 1996, noted improvements in the maintenance area, but stated that
sustained performance in this area will be required to determine the effectiveness of
the Maintenance Intervention. The Self Assessment stated that several of the
people that were interviewed thought that they had learned a lot from the
Maintenance Intervention and that it will help them perform their job in a more
professional manner. Furthermore, the NRC Resident Inspector staff noted
improvement in the performance *of the Maintenance Department as noted in
Inspection Report 50-272/311, 97-03, dated April 3, 1997.
The recent self assessments of operations and planning concluded that both areas
were ready for restart, but noted areas that needed additional attention. These
areas, which will. be handled by the Corrective Action Program, include procedure
use and adherence, management presence in the field, and tagging.
The percentage of self-identified problems improved from about 60 per cent in
November, 1995, to about 90 per cent in June, 1996. This percentage remained
between 80 and 90 per cent, with several short-duration drops due to increased
outside inspections. This is an indication of the effectiveness of the Self
Assessment program.
The implementation of the management and peer observer program has shown
improvement. A new process instituted pre-printed index cards used to provide
field observation comments. This has increased the number of management
observations being reported. Peer observations are being done by supervisors,
rather than peers, because of objections by the union. The inspectors concluded
that this is an acceptable alternative and has been effective in identifying concerns.
Based on their review of several key self assessments, and noting the increase in
the percentage of problems that are self-identified and the improvements in
performance in the areas of operations and maintenance, the inspectors. concluded
that the inconsistency part of Problem Statement No. 2 has been adequately
corrected.
c.
Conclusions
Effective implementation of the Salem Assessment Restart Action Plan re_sulted in
establishment of a new self assessment, development of procedures to improve the
use and effectiveness of self assessment, conduct of comprehensive self
assessments that documented weaknesses, and an increased percentage of self-
identified issues. The inspectors concluded that the area of self assessment is
ready for restart.
9
07.2 Salem Human Performance Restart Plan (Closed)
a.
Inspection Scope
The inspectors reviewed the Salem Human Performance Restart Action Plan,
Revision 6, dated December 3, 1996, to determine whether actions within the plan
needed for restart had been completed. - The inspection also reviewed the
implementation and effectiveness of the program, as documented in audits of
human performance, in meeting the expected results cited in the plan. Inspectors
interviewed the Supervisor, Salem Station Projects; Planning and Development
Manager, Human Resources; the Project Manag'er, Restart Plan Coordinator; the
Manager, Corrective Actions and Quality Services; the Supervisor, Corrective
Actions; several members of the Quality Assurance organization; and a random
selection of plant personnel.
b.
Observations and Findings
From July 9 through July 11, 1996, arid from January- 6 through January 9, 1997,
NRR inspectors performed an inspection of the Human Performance Restart Plan.
The plan consists of six Problem Statements needing resolution to achieve an
acceptable Human Performance Program. The Expected Results in the plan are that
the management and supervisory positions are filled with the right people; that high
standards are established, communicated, understood and demonstrated by the
employees; that leaders are working together; t_hat there is ari increased number of
people on Performance Improvement Plans; and that the 11umber of incident reports
due to human error show a consistent decreasing trend.
Revision 6 of the plan, dated December 3, 1996, indicates that all of the restart
actions needed to address each of the Problem* Statemen_ts have been completed.
The inspectors audited the backup files for selected actions to review the bases for
the licensee's findings regarding supervisory performance improvement (Actions 1 e,
1 g, and 1 h); expectations, work processes, performance indicators (2b, 2c, 2g, 2j,
21); leadership training and self assessment skills (3c, 3e); communications (4c, 4e,
4g); teamwork and management presence in the field (5.1, 5.3); human
performance trending and causes (6.1, 6.2).
In addition, the inspection also reviewed the closure inputs for: Problem Statement
No. 1, dated October 3, 1996; Problem Statement No. 2, dated October 2, 1996;
Problem Statement No. 3, dated October 3, 1996; Problem Statement No. 4, dated
June 19, 1996; Problem Statement No. 5, dated November 13, 1996; and Problem
Statement. No. 6,.dated November 15, 1996.
As part of Problem Statement No. 1, the performance of the managers and
supervisors was evaluated. As a result, many personnel changes were made. The
inspectors, based on- interviews with the licensee's staff and discussions with the
NRC Resident Inspectors, concluded that the changes have resulted in a stronger
management team at the station. The inspectors concluded that the objectives of
Problem Statement No. 1 have been met.
,.
10
As part of Problem Statement No. 2, the licensee has instituted a program known
as Breakthrough FOCUS in which selected personnel are sent offsite for five days of
training intended to change the culture at the station and lead to improvements in
work practices. Approximately 400 people have received this training.
Based on the results of the Culture Index Survey, improvement is taking place in all
of the five key characteristics known to be present in high performing organizations:
missions and goals, knowledge and skills, lateral integration, simple work processes,
and self improvement culture. The inspectors concluded that the objectives of
Problem Statement No.2 have been met. *
As part of Problem Statement No. 3, the licensee offers, on a voluntary basis, a
Dale Carnegie personal development course which been taken by approximately 350-
people. All supervisors have taken MARC training which involves the appropriate
use of direction and discipline in the workplace. The inspectors conciude that the
leadership training and self assessment objectives of Problem Statement No. 3 have
been met.
As part of Problem Statement No. 4, to improve communications the licensee
started conducting meetings on a regular basis to keep staff informed of key issues
and hear feedback from their management. Use was made of a publication called
"Nuclear Today" to communicate key items of progress and key issues regarding
Salem Restart Plans. The Communications Exchange Process was started in late
1995 to communicate key messages from the Salem management team and the
departments through face-to-face weekly meetings. Feedback was requested and
communicated to the Salem management team. Face-to-face meetings were
initiated to increase department manager/supervisor field presence. The licensee
also conducted audits through questioning of Salem employees regarding the
effectiveness of the Communications Exchange Process. Although the licensee
concludes that improvement in the quality of communications has occurred, the
face-to-face mode is lagging with respect to other modes of communication.
The inspectors observed the Management Meeting that was held on July 10, 1996,
where management goals, schedules, performance indicators and key plant and
licensing issues were discussed. The Chief Nuclear Officer/President of the Nuclear
Business Unit to first level supervision attended the meeting. It began with a
statement from someone who had recently completed the Breakthrough training.
He appeared to be satisfied with the training. The inspectors found that the
meeting was effective in improving communications at the site.
The inspectors agree that_communications has inJp(oved as evidenc~d by pul;>li_sh_ed
information placed on bulletin boards throughout the plant and a sampling of staff
meetings. The inspectors conclude that the. objectives of Problem Statement No. 4
have been met.
One of the actions in Problem Statement No. 5 is to increase manager/supervisor
presence in the field. The licensee stated that is not able to verify the time spent in
the field by managers and supervisors, but believes it is improving. The inspectors,
11
based on random discussions with plant personnel and discussions with the
Resident Inspectors, agree that manager/supervisor presence in the field has
improved, but improvement in this area is still needed.
Another objective of Problem Statement No. 5 was to improve teamwork in the
Salem management group. The regularly scheduled Management Meetings
previously discussed under Problem Statement No. 4 have been effective in
improving teamwork at the site. Thus, the inspectors conclude that the objectives
of Problem Statement No. 5 have been met.
As a result of comments from an independent assessment team, the licensee added
Problem Statement No. 6 dealing with trending of human performance. The
trending of human performance, using methodology developed by FPI International,
entails the classification of human error events as either breakthrough events, near
misses, or precursors. The number of occurrences is then calculated per 10,000
person-hours and plotted month-to-month. The inspectors reviewed the results for
the period of August through November of 1996 and noted a slight decrease in the
number of human error events. The inspectors concluded that the process is a
good method for trending human error events, but it has not been in place long
enough to determine the actual human error trend at the station. *
c.
Conclusions
Implementation of the Salem Human Performance Management Restart Action Plan
resulted in significant improvement in the quality of oversight, teamwork; and
assessment of worker performance. The inspectors concluded that it is too early to
judge the effectiveness of the trending results of the human performance errors.
The inspectors noted increased supervisory presence in the field, however, station
management does not have an effective tool for monitoring these observations.
However, on balance, the inspectors concluded that the improvements in human
performance management were adequate to support restart.
08
Miscellaneous Operations Issue
08.1
(Closed) Inspector Follow-up Item 50-272&311 /96-16-02: improperly coded
corrective action documents. Salem staff corrected the significance coding on
several corrective action documents that an NRC inspector identified as incorrect.
Salem staff also determined that the mis-coding was not a generic issue. This item
is closed.
08. 2
(Closed) Violation 50-27 2&311/94-24-01 : failure to ensure containment integrity.
Technical Specification 3.9.4 requires containment integrity during core alterations.
The loss of integrity that occurred in October 1994, resulted from open service
water vent valves inside containment thus providing a release path to open service
water drain valves outside containment. Corrective actions to this violation were
inadequate as indicated by a similar event the inspectors documented as a violation
in NRC Report 50-272&311/96-18 (VIO 96-18-02). In this more recent event,
operators lost containment integrity when mechanics removed a service water valve
~-----------------------
12
in piping outside containment at a time when service water*vents for the piping
were open inside containment. For administrative purposes, item 94-24-01 is
I
closed and corrective action adequacy will be tracked under iter:n number 96-18-02.
08.3
(Closed) Violation 50-272&311 /96-07-02: violation of Technical Specification 6.8.1
requirements. An equipment operator failed to perform a procedure step to close
the control power breaker after racking up a 13kV breaker and subsequent failure of
the responsible senior reactor operator to initiate appropriate action. The inspector
concluded PSE&G staff's response 'to the violation was adequate. Also, the NRC
staff determined the Corrective Action Restart Plan appropriately addressed generic
corrective action issues. This violation is closed.
08.4
(Closed) Violation 50-272&311/96-15-01: corrective action for op~rator
performance problems. This violation identified that Operations staff inadequately
investigated an instance where operators inadvertently operated an emergency
control air compressor without service water cooling being supplied to the
compressor. Operations management developed procedure SC.OP-AP.ZZ-0114(Z),
Event Identification and Investigation. The procedure provides guidance to
operators for initial shift investigations of events. The inspector determined the
procedure was adequate and confirmed Operations staff trained the operators on
the new procedure. Also, NRC staff concluded Salem staff adequately addressed
the generic issue of corrective action through the Corrective Action Restart Plan.
This violation is closed.
08.5 (Closed) Violations 50-272&311/EA94-239-01012. 50-272&311/EA96-177-01012,
and 50-272&311/EA96-177-01022: discrimination against employees engaged in
protected activities as defined in 10 CFR 50. 7 (a)( 1). A brief summary of each
event follows:
Violation EA94-239-01012
In December 1992, two Safety Review Group (SRG) engineers attempted to
document a safety concern on a corrective action document, however, the then-
General Manager - Salem Operations tried to dissuade them from issuing the
document. When they suggested that they may need to file a safety concern he
told them to get out of his office.
Violation EA96-177-01012
In 1993 and 1994, an Onsite Safety Review (OSR) engineer received negative
performance reviews from the matrager-Nuclear Safety Review because the OSR
engineer supported the two engineers, mentioned above, regarding their roles in
the December 1992 event.
Violation EA96-177-01022
In August 1994, PSE&G management transferred an SRG engineer, against his will,
from the Salem organization to the Hope Creek organization because of his role in
the December 1992 event.
13
The inspector reviewed the responses to these violations and examined a number of
supporting documentation such as corporate memos, training material, station
procedures, and interviewed members of the Employee Concerns Program. The
corrective actions for these violations was comprehensive. They include:
Since 1994, senior PSE&G management made significant personnel changes
throughout the Salem and Hope Creek organizations. The managers involved
in the above events are no longer at Salem or Hope Creek.
PSE&G management communicated, and continues to emphasize, company
policy regarding safety concerns. The policy is that expressing a concern
about safety is not only acceptable, it is a professional responsibility.
Management training and General Employee Training emphasii;es handling of
safety concerns.
-
A formal Employee Concerns Program is in place with dedicated staff.
Employees have access to this program via an office visit, mail, drop box,
phone, or exit interview.
Additionally, based on observations made over the past eight months during plant
inspection activities, the inspector has noted significant improvement in company
environment regarding openness toward safety concerns. Management has also
improved the corrective action programs that address those concerns. The
inspector concluded senior PSE&G management took comprehensive and effective
corrective actions in response to the discrimination events. These violations are
closed.
08.6 (Closed) LER 50-272/96-041 - missed surveillance for radiation monitors
source check. This LER was a minor issue and was closed.
08. 7
(Closed) LER 50-311 /96-011 - missed surveillance for sampling boron concentration
of refueling canal. The inspectors discussed the subject of this LER in NRC Report
No. 50-272&311 /96-12. The LER did not reveal any new issues. This LER is
closed.
08.8 (Closed) LER 50-311 /96-013 - missed surveillance for performing *tritium grab
samples when the refueling canal was flooded. This event occurred due to a
misinterpretation of the technical specification requirement to sample within twenty-
four _hours of flooding the refueling canal. Operators thought the twenty-four hour
interval began at the- completion -of the flooding. Salem staff later concluded the
interval started at the initiation of flooding and revised the appropriate procedure
accordingly. The inspector verified Salem staff revised the procedure. This LER is
closed.
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14
II. Maintenance
M 1
Conduct of Maintenance
M 1 . 1 General Comments
a.
Inspection Scope* (62707)
The inspectors observed all or portions of the following work activities:
- * * *
970224263:
970117323:
961227217:
970209046:
steam generator primary manway leak repair
28 EOG exhaust manifold leak repair
CFCU SW piping modification
no. 21 RHR pump casing flange gasket leak repair
The inspectors observed that the plant staff performed the maintenance effectively
within the requirements of the station maintenance program.
b.
Inspection Scope (61726)
The inspectors observed all or portions* of the following surveillances:
- * * * * * *
S2.0P-ST.DG-0002:
S2.RE-ST.ZZ-0002:
S2.0P-ST.DG-0001:
S2.0P-ST.DG-0019:
S2.0P-ST.CAN-0007:
S2.0P-ST .4KV-0002:
S2.0P-ST .PZR-0002:
28 diesel generator surveillance test
shutdown margin calculation
2A diesel generator surveillance test
2A diesel generator hot restart test
refueling operations - containment closure
electrical power systems AC distribution
inservice testing PORV and PORV block valves
modes 1-6
The inspectors observed that plant staff did the surveillance safely, effectively
proving operability of the associated system.
M1 .2 Adequacy of the Foreign Material Exclusion (FMEl Program, NRC Restart Inspection
Item 111.5 (Closed)
a.
Inspection Scope
Inspection Rep9rt 50-272,311 /96-08 documented an inspection performed in
August 1996 for this restart item. The inspector concluded at that time that
although much had been done to improve the FME program, problems still existed
with implementation of the program. Since then, the inspector made several field
tours for' the purpose of rr0nitoring FME compliance and reviewed the corrective
action for problems identified in the previous inspection report.
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15
b.
Observations and Findings
The inspector found that since the August inspection, implementation of the FME
program has improved. When violations of the program have been found, Salem
staff has documented these in the corrective action program and in their trending
program. Also, Salem management has responded to these violations with pre-job
briefings with emphasis on FME practices, with follow up observations, and with
additional FME training for Salem maintenance personnel. During plant tours, the
inspector found that when required, FME areas have been posted and adequate
precautions have been taken to prevent introduction of foreign material into systems
and components. Numerous examples of good FME practices have been witnessed
during these plant tours.
c.
Conclusions
The inspector concluded that PSE&G has made significant improvement since the
shutdown of the Salem units in mid 1995. In addition, management continues to
respond to problems and continues to make progress in improving overall FME
compliance. This issue is adequate to support the restart of Salem Units 1 and 2.
M1 .3 Tagging. NRC Restart Item 111.3 (Closed)
a.
Inspection Scope
In response to numerous tagging errors, Salem management established an
improved Safety Tagging Program. The inspectors assessed the adequacy of the
revised program.
b.
Observations and Findings
Salem staff analyzed a data base of approximately 100 tagging issues, covering .the
period November 1994 through January 1996. Their analysis showed tagging
errors had root causes in inadequate program design, inadequate training,
inadequate supervisory methods, and inadequate work practice. In response, the
Operations staff: sharply reduced the number of people authorized to perform
tagging evolutions; performed a job task analysis and issued qualification cards for
. tagging; re-qualified personnel according to their tagging responsibilities; filled
positions in the work control center only with individuals qualified to new tagging
standards; and issued a significant revision to the tagging procedure, NC.NA-AP.ZZ-
0015(0), Safety Tagging on January 15, 1997.
The inspector reviewed performance indicators for the month following
implementation of the revised tagging procedure to determine whether the new
program was effective. The inspector noted three relatively minor errors. Also, the
rate of tagging errors was the lowest in over a year, even though during this recent
interval plant personnel performed many more evolutions (445) than during a similar
interval in 1996 (341 ). The inspector also assessed the significance of the errors
and noted that no event was a breakthrough event (defined as an event where
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16
process barriers failed, with potential or actual personnel injury or equipment
damage). Historically, there was at least one breakthrough event a month from
August 1 996 to January 1 997. The inspector attributed the favorable performance
in tagging to operators adequately implementing the improved procedure.
The inspector also noted that management added a self-assessment element to the
tagging program. Senior reactor operators evaluate one out of every five tagging
evolutions and each maintenance supervisor conducts three job evaluations per
week. Salem staff initiated condition r~solution reports to address deficiencies
identified as a result of these assessments.
c.
Conclusions
The inspector concluded that PSE&G has made significant improvement since the
shutdown of the Salem units in mid 1995.. In addition, management continues to
respond to problems and continues to make progress in improving overall FME
compliance. This issue. is adequate to support the restart of Salem Units 1 and 2.
M7
Quality Assurance in Maintenance Activities
M7. 1 Work Control
a.
Observations and Findings
During the inspection period plant managers noted continued difficulty in completing
daily work as planned and scheduled .. In particular~ the managers noted that plant
staff continued to distract control room operators with requests for authorization of
work not previously. planned for that day. The requests caused operators and shift
technical advisors to spend time reviewing the potential impact of the requested *
activities on plant conditions and already ongoing activities. The review provided
the potential to distract control room staff from their normal duties.
As a result of their concern about scheduling effectiveness, the plant managers
decided to direct operators to refuse to authorize work not previously scheduled,
unless the operators concluded that failure to perform the work would have an
adverse impact on safety. In addition, the managers implemented the twelve-week
work schedule for Salem Unit 2, starting with the activities for week five of the
twelve week schedule. The managers expect that the twelve week schedule will
improve the ability of plant staff to plan and control the daily work.
b.
Conclusions
The ability to plan and schedule work, then accomplish the work according to the
schedule and plan has been a long-standing weakness at Salem. The Salem
management and f:taff made significant improvement in the effectiveness of
planning and scheduling during the current shut down. During the current
inspection period, plant management implemented the twelve week work
' '
MS
MS.1
17
schedule to further improve the effectiveness of planning and scheduling, and to
reduce distractions and potential challenges to control room staff.
Miscellaneous Maintenance Issues
(Closed) Unresolved Item 50-272 & 311/94-01-01: control of maintenance
troubleshooting. In February 1994, maintenance technicians inadvertently caused
the opening of the main steam dump valves to the condenser. This item was
opened pending the investigation of the event. Salem staff determined that the root
cause was inadequate pre-job planning.
Since that time, maintenance personnel
have been through a significant training program to strengthen technical skills and
to emphasize attention to detail. The inspector found this training appropriate to
address this event. This item is closed.
MS.2 (Closed) Preventive Maintenance Change Request Backlog
a.
Inspection Scope
The inspector reviewed the Salem maintenance program relative to the outstanding
backlog of requests for changes. Specifically, the inspector held discussions with
Preventive Maintenance Group staff members, reviewed the list of outstanding
Preventive Maintenance Change Requests (PMCRs), reviewed a sample of PMCRs,
and reviewed procedures in place to control the processing of PMCRs.
b.
Observations and Findings
From discussions with the Preventive Maintenance Group staff, the inspector
learned that there were 249 outstanding PMCRs for Salem Unit 2 .. They expect that
this backlog will be reduced by a factor of eight to about thirty by the end of 1997.
Although the group is short of staff, recruiting is in progress to obtain additional
personnel. The inspector obtained a list of all 249 outstanding PMCRs and
reviewed it to select a sample of those that by the description appeared to have a
potential for safety impact (i.e., due to a safety function of the component and the
age of the PMCR). The inspector selected fifteen and then reviewed the details of
the PMCR documentation for those sampled. None were found which the inspector
believed would present a safety impact even if delayed until years' end.
From the review of the administrative procedures, the inspector found that the
procedures provide guidance for processing of PMCRs from initiation until closure.
From a discussion and demonstration regarding the computerized database, the
inspector *found that it contained pertinent data related to the PMCRs such as
description, reason for initiation, and due date. The data was also easily retrieved.
The inspector also learned that PSE&G actively monitors the size of the backlog via
a PMCR "Burn-Off" curve. Also, PSE&G staff screen PMCRs and assign due dates
to ensure that they make changes in sufficient time to support the next performance
of the task.
18
c.
Conclusions
From the inspection observations, the inspector found it reasonable to concluoe
that the backlog of PMCRs, although sizable, does not represent an impact to the
safe operation of Salem Unit 2. The administrative control of the PMCRs is
appropriate and effective. PSE&G staff is aware of the size of the backlog and is
working to reduce it.
M8.3 (Closed) Violation 50-272&31 'I /95-12-01: inadequate corrective action for ITE
circuit breaker problems. During the period from December 4, 1989, to March 29,
1995, Salem staff documented thirteen failures of safety related ITE breakers.
During this time, management failed to perform a timely root cause analysis and
failed to implement corrective action to prevent repetitive failures; inspectors
identified two significant concerns with this issue: the technical issue of correcting
the hardware problem, and the programmatic problem of lack of rigor and timeliness
in PSE&G staff determining the root cause.
Regarding the first concern, PSE&G staff, with the aid of the breaker manufacturer,
determined the route cause to be less than adequate preventive maintenance.
PSE&G engineers enhanced the preventive maintenance procedure and performed
the procedure on suspect ITE breakers (i.e., those with sluggish closing times). The
engineers later decided to perform an extensive overhaul on all ITE breakers. The
inspector confirmed that Salem staff completed this overhaul for Unit 2 and that
plant staff is tracking overhaul tasks for Unit 1 breakers. The inspector's review of
the recent performance history revealed no examples of breaker failure following
overhaul. Also, during an interview with the system engineer, the inspector learned
that a newly approved preventive maintenance procedure provides for in place in-
place breaker timing tests every 18 months. These tests detect degradation in
breaker performance.
Regarding the programmatic issue, PSE&G management implemented extensive
changes to improve the corrective action program. Management documented those
changes in their response to NRC Restart Issue 111.a.10, Corrective Action Program.
NRC staff reviewed the program, concluded the improvements *have been effective,
and documented closure of that restart issue in NRG Report 50-272&311 /97-03.
Based on that review and on the information in the previous paragraph, this
violation is closed.
M8.4 (Closed) LER 50-311196-014 - emergency diesel generator automatic start - ESF
actuation. The EDG automatically started during a manual transfer of one off-site
power supply to another. Salem staff determined the cause to be a defective relav
in a vital supply breaker. The corr.active actions included replacing the breaker,
notifying the manufacturer, and revising the breaker inspection procedure to include
details for inspecting the relay. Additionally, Salem staff identified other relays
susceptible to the defect and found that the relays operated satisfactorily. The
inspector considers this LER closed.
'
'
19
MS. 5 (Closed) LER 50-311/96-01 2 - engineered safety feature actuation, 2A 4kv vital bus
undervoltage. While performing an electrical test of the service water pump motor,
two potential transformer fuses opened causing one *of three undervoltage relays to
trip. When operators tried to measure phase to phase voltages using a local panel
voltmeter, a second undervoltage relay tripped causing initiation of the Safeguards
Equipment Controller. This started the 2A EOG. There was little safety significance
since the EOG started and loaded the bus as designed and the plant was already
shutdown and defueled.
Salem engineers performed a formal root cause analysis of the event. They
attributed the cause of the first incident, the blown fuses, to lack of attention to
detail during testing. The cause of the second undervoltage relay tripping was a
design deficiency which is only present when one of the two potential transformers
has open fuses.
The inspector reviewed the corrective actions and determined
they were adequate.
MS.6 (Closed) LER 50-311 /96-015 - breach of containment closure during core reload.
Inspectors documented this issue in NRC Inspection Report 50-272&311 /96-1 S. As
a result of this event, the NRC staff issued violation 50-311 /96-1 S-02.
MS. 7 {Closed) LER 50-311/96-016 - missed surveillance for determining response time of
high containment gaseous radioactivity ESF actuation. Technical specifications
require a verification of this ESF actuation response time every eighteen months.
The maintenance dep,artment tracks this surveill.ance requirement using a
proceduralized computer search of required recurring tasks. The database
incorrectly indicated'that the surveillance was applicable in modes 1 through 5. The
technical specification requirement is applicable in modes 1 through 6.
The inspector reviewed the cofrective action as detailed in Salem's root cause
analysis of the event and concluded that it was satisfactory. In addition, Salem
staff addressed the generic issue of technical specification problems with the
Technical Specification Surveillance Improvement Program (TSSIP).
MS.S (Closed) LER 50-272/96-021 - potential common mode failure for 2SV DC battery
chargers due to molded case circuit breaker damage. During a review of
maintenance inspections, Salem staff determined that circuit breakers within the
2SV DC battery chargers experienced common mode failure of the terminals
involving cracked terminal blocks. In response to this finding, Salem staff revised
maintenance inspection procedures to require inspection specifically for the cracking
which precedes this failure mode. In addition, PSE&G staff investigated whether
similar breakers were in use in other applications at Salem and Hope Creek.
Although PSE&G staff did locate other applications, none was configured in the
manner which induced the cracking. The inspector concluded that the corrective
action for this event was .:;;atisfactory.
MS.9 {Closed) LER 50-272/96-025 - inadequate calibration of overpower delta
temperature protection channels. While performing the calibration of a turbine first
stage impulse pressure channel, the technicicm noticed that the output of the Hagan
'
'
20
lead/lag module was higher than expected. Subsequent testing revealed that the
method used to calibrate the modules was inadequate. The method yielded a non-
conservative output. The inspector learned that this was reportable because these
modules provide output which is used to shutdown the reactor to protect against
excessive power.
The inspector reviewed the corrective action for this problem and learned Salem
staff corrected calibration procedures and then properly calibrated the units. Also,
the investigation determined that other modules in the plant were also being
improperly calibrated so PSE&G staff applied corrective actions to these as well.
This licensee-identified and corrected violation is being treated as a Non-Cited
Violation, consistent with Sec.tion Vll.B.1 of the NRC Enforcement Manual.
M8.10 (Closed) LER 50-272/96-027 - diesel watt meter inaccuracies not accounted for in
surveillance testing. There are three technical specification requirements to perform
EOG testing with the diesels loaded to 2500 - 2600 kw. In October 1996, Salem
staff determined tt)at the diesel watt meter inaccuracy was actually +/- 65 kw. This
meant that even if the testing were performed with a meter indication of exactly
2550 kw, the actual foad could be 15 kw above or below the prescribed load band.
The inspector considered the safety significance of this event to be minimal since
the EDGs were still capable of performing their intended function. Salem staff
revised the surveillance procedures to utilize more accurate test equipment and *
retested the Salem Unit 2 EDGs. There is also a corrective action tracking
document to assure Salem staff applies the corrective action for Salem Unit 1 EDGs
as well.
MS.11 (Closed) LER 50-272/96~029 - surveillance test did not meet technical specification
surveillance requirement. During a recent 18 month surveillance test on a hydrogen
recombiner, *a measurement of the heater and neutral to ground resistance indicated
values below the acceptance criteria. The technicians questioned the test results
because the recombiner had performed well during an operability test. An
investigation revealed two things: 1) Technicians were not taking readings properly
because of procedure inadequacies and, 2) Technicians took previous readings with
a digital volt/ohm meter (DVOM) instead of with a meggar. The surveillance
procedure does not direct using the DVOM, which if used may provide incorrect
data.
The corrective action included a revision to the surveillance procedure to provide
details for attaching test equipment, and general counseling of personnel to strictly
follow procedures. The hydrogen recombiners were retested using the re.vised
method and met the surveillance requirement.
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21
Ill. Engineering
E2
Engineering Support of Facilities and Equipment
E2.1
Generic Letter 96-06 (GL 96-06) Modifications
a.
Inspection Scope (37551)
Design engineering began installation of design change package (DCP) 2EC-3590 to
address saf.ety issues identified in GL 96-06 as they impacted the Salem Unit 2
containment fan cooler units (CFCUs) and attached service water system piping.
The inspector evaluated the engineering organization's involvement in the
b.
Observations and Findings
Design engineering did not allow sufficient time in the schedule for installation and
testing of the CFCU modification. Despite schedule pressure, contract maintenance
supervisors provided continuous and focused oversight of ongoing SW piping
modifications to ensure personal safety and minimal impact of SW system
operation. Salem maintenance supervisors, by contrast, provided little oversight of
field installation .
Contract maintenance supervisors identified that technicians attached a portion of
the new SW piping to the no. 21 SW header prior to proper hanger installation.
Plant management promptly declared the associated SW header inoperable and
disconnected the new section of piping .. Maintenance supervision initiated a
significance level 2 condition resolution report (970404205) to evaluate the cause
and potential adverse affects of this problem .
. The inspector observed that design engineers provided frequent engineering
oversight at the job site, and quality assurance inspectors and operations senior
nuclear shift supervisors conducted regulator field observations of the SW piping
modifications.
c.
Conclusions
Design engineering did not allow sufficient time for installation arid testing of the*
CFCU modifications without adversely affecting the outage plan. Design engineers,
quality assurance inspectors and senior nuclear shift supervisors provided frequent
oversight of the installation.
E7
Quality Assurance in Engineering Activities
E7 .1
Technical Specification Surveillance Improvement Program (TSSIP)
In NRC Inspection 50-272&311 /96-15, the NRC requested that PSE&G provide
justification for not completing TSSIP, Phase 2, prior to restart of Salem Unit 2. In
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'
22
a letter to the NRC dated April 10, 1997, PSE&G provided a discussion of the TSSIP
process, the accomplishments of Phase 1, and the results of FSAR, LER, and
additional technical reviews. In the letter, PSE&G concluded that the multiple
reviews and the corrective actions stemming from the reviews provided reasonable
assurance the Salem Technical Specification Surveillances and implementing
procedures are adequate to support restart. The inspectors concluded that PSE&G
provided reasonable assurance the Technical Specifications and implementing
procedures are adequate to support restart of Salem Unit 2.
Miscellaneous Engineering Issues
E8. l
(Closed) Violation *50-272&311 /96-117-03013 and -04013: inappropriate corrective
action. The technical issue involved the dete.rmination and resolution of
noncpnservative setpoint methodology with regard to the POPS. The programmatic
issue involved the general failure of Salem staff's corrective action program.
Together, these violations represented examples where management failed to
implement timely corrective action, failed to promptly issue a Licensee Event Report
for an operating condition outside the licensing basis, took credit in a calculation for
an operating configuration outside the design basis, and took credit for an American
Society of Mechanical Engineers (ASME) Code Case that the NRC had not yet
approved for use. These violations were significant and resulted in civil penalties.
E8.2
The NRC staff documented the review of the technical issue regarding* acceptable
POPS design basis in NRC Report 50-272&311 /96-07, .Section E8.4. Following
NRR review and approval of proposed new limits, NRC staff closed the issue in NRC
Report 50-272&311 /97-02! Section EB.6.
Salem management addressed the programmatic issues regarding the corrective
action program in the response to NRC R'estart Issue 111.a.10, Corrective Action
Program. NRC staff documented the review and acceptance of the Corrective
Action Program in NRC Report 50-272&311 /97~03. Based on acceptable closure of
the technical and programmatic issues related to these violations, the two violations
are closed.
(Closed) Violation 50-272&311 /96-117-06013: valve not properly positioned
following a plant modification. In May 1993, plant personnel added drain lines and
a drain valve to Pressurizer Overpressure Protection system piping. The installation
process, however, did not ensure that operators properly positioned the drain valve
following the modification. As a result, the valve remained closed (instead of open)
from May 1993 until October 1994.
The inspector determined that operators have correctly positioned the valve and
that Salem staff reviewed the valve alignment database to assure themselves no
other similar examples e"'.isted. The inspector also verified that Salem staff revised
SC.OP-AP.ZZ-0103(0), TRIS Configuration Control, to address proper system
alignment following design changes. The inspector reviewed this procedure and
considered the process adequate. This violation is closed .
' .
23
E8.3
(Closed) LER 50-272/96-019 - misclassification of blowdown sample valves. In July
1996, while performing a review of 10 CFR 50 Appendix J valves, Salem staff
identified four valves in the steam generator blow down sample system which were
not included in the leak rate test program. A 1985 Licensing Change Request
deleted the valves from the technical specifications and from the leak rate test
program. Salem staff requested the change because they believed the valves were
part of a closed system within containment and were therefore not required to be in
the test program. However, during the July 1996 review, Salem staff determined
that because the system was seismic Category II rather that Category I, the system
is not a closed system.
The inspector reviewed the corrective action plan and found it adequate to address
the issue. Also, this corrective action is documented in the Salem corrective action
tracking system to assure completion. This licensee identified violation is being
treated as a Non-Cited Violation consistent with Section Vll.B.I of the NRC
E8.4
(Closed) Violation 50-311 /96-13-02: failure to follow procedures. During a recent
inspection, an inspector found two examples where Salem staff failed to adhere to
approved procedures. One example involved a field discrepancy that an operator
identified and corrected, but did not result in anybody initiating a corrective action
document. Another example involved a change made to a safety evaluation after
Salem staff had approved the evaluation. The inspector reviewed the corrective
action for the violation and found it to be satisfactory. In addition,* the inspector
noted that the generic issue of procedure compliance was addressed in the
licensee's response to NRC Restart Item 111.3, Procedure Use and Adequacy.
Inspection Report 50-272&311 /97-03 documented closure of that issue. This
violation is closed.
E8.5. (Closed) Violation 50-272&311/E94-112-01013: failure to promptly identify and
correct the cause of spurious high steam flow signals. The spurious signals
occurred during reactor/turbine trips on June 10, 1989, July 11, 1993, February
10, 1994 and on April 7, 1994.
There were two issues of concern regarding this violation. One was the technical
issue of understanding the cause and implementing corrective action to resolve the
spurious signal problem. Salem staff specifically addressed that issue in PSE&G's
response to NRC Restart Issue 11.38, Spurious High Steam Flow Signals Causing SI.
The NRC staff is reviewing that information for acceptability. The second concern
was the broader programmatic issue of timely and adequate corrective action and
the general application of that program by PSE&G staff. Salem staff addressed that
issue in PSE&G's response to NRC Restart Issue 111.10, Corrective Action Program.
NRC Inspection Report 50-272&311 /97-03 documented the NRC review and
closure of that issue and documented that the corrective action plans are adequate
to support Salem restart. Since the NRC tracked the technical concern as a restart
issu*e and has closed and documented the programmatic issue, this violation is
closed.
- '
'
24
E8.6
(Closed) Violation 50-272&311 /96-08-04: failure of Salem staff to initiate a
corrective action document in a timely manner. A team that reviewed temporary
and permanent modifications installed at Salem identified conditions potentially
adverse to quality. Salem staff, however, did not write a condition report to
address the conditions until a month after the audit team exited. PSE&G staff
addressed the broad issue of the corrective action program, including the prompt
initiation of corrective action documents, in the response to NRC Restart Issue
111.10, Corrective Action Program. NRC Inspection Report 50-272&311 /97-03
documented NRC review and closure of that issue. Based on that closure, this
violation is closed.
E8.7
(Closed) Violation 50-272&311/E95-117-02013: inadequate corrective action for
No. 12 switchgear fan failure. In December 1994, No. 12 switchgear penetration
area ventilation (SPAV) fan failed. In May 1995, No. 13 SPAV fan failed, resulting
in the SPAV system being unable to perform its design function of cooling safety
related switchgear. In the response to the violation, Salem management identified
several contributing factors, including operator and engineering staff lack of
knowledge of the SPAV system design basis.
E8.8
For corrective actions, Salem staff repaired the fans; created additional preventive
maintenance tasks for the fans; revised the Operability Determination procedure and
the nuclear safety equipment and surveillance tracking procedure, and revised the
.
.
.
corrective action program. The inspector reviewed the revised documents,
including those that track surveillances for non Technical Specification equipment
important to safety. This element of corrective action was satisfactory. Other
elements of the violation response are satisfactory based on prior NRC closure of
restart items that addressed the Corrective Action Program, Operability
Determinations, and Operator Performance. This violation is closed.
(Closed) Violation 50-272 & 311/E95-117-05013: Salem staff did not promptly
identify and correct miscellaneous conditions adverse to quality. The violation
identified nine examples where PSE&G failed to take appropriate corrective action
for conditions adverse to quality. The conditions occurred during the period from
1990 until 1995.
The inspector reviewed PSE&G' s response to this violation and found that for each
example, PSE&G had implemented corrective action to resolve each condition.
These examples represented failures of the Salem corrective action program, failures
of operations operability determinations, and one failure to install a safety classified
part. Since mid 1995, PSE&G has made significant improvements in plant programs
as part of resolving NRC Restart Issues. Specifically, PSE&G has responded to NRC
Restart Issue 111.a.10, Corrective Action Program, Restart Issue 111.6, Operability
Determinations, and Restart Issue 111.18, Parts Availability and Accuracy of Bill of
Material. The NRC has reviewed PSE&G's response to these issues and has found
the corrective actions adequate. The NRC has documented this in Inspection
Reports 50- 272 & 311 /96-08, /97-03, and /97-02, respectively. The inspector
has reviewed the scope of those restart issues and found that they envelop the
generic corrective action requirements for the nine examples of this violation.
' .
25
Based on the review of the violation response, and the three closed restart issues,
this violation is closed.
IV. Plant Support
R1
Radiological Protection and Chemistry (RP&C) Controls
R 1. 1
External Exposure Controls
a.
Scope (83750)
The inspector reviewed facility postings and high radiation area controls, reviewed
RP instrument and respiratory protection controls, and reviewed dosimetry vendor*
changes during this inspection period. Tours of the facility, review of documents
and interviews with licensee personnel were conducted.
b.
Observations and Findings
The inspector verified that selected locked high radiation areas were locked as
required and verified that the high radiation area key controls were in place and all
keys were accountable. RP oversight of the primary RCA access control point was
excellent. RP instrument and respiratory protection issue was provided through RP
technicians utilizing computer review of qualifications for equipment issuance and
accountability for the equipment issued. All RP equipment available for issuance
was appropriately calibrated and source-checke*d as reqL::~ed.
Both Units _1 and 2 containments were well posted and radiologically controlled.
The auxiliary buildings were, in general, appropriately posted and controlled. The
inspector observed some discrepancies in the solid radwaste "hot" machine shop
area, in that some lexan tent areas were posted in excess of actual radiological
conditions. Tent number 1 had a shielded component on the floor with a radiation
area posting on the door, but no other indication of the radiological hazard in the
tent from the shielded component. Tents 2 and 3 were both posted as radiation
areas, while a current survey indicated dose rates of less than 1 mR/hr. Further
review indicated that the shielded component in Tent number 1 was an SJ valve
that was last worked in June 1996. The licensee determined that the valve was
waste material and was disposed of during the inspection. All three lexan tent
areas were deposted in accordance with survey results.
Radiation Work Permits (RWPs) were written with an emphasis on restricting
individual doses per entry with very low dose alarm set points used on electronic
dosimetry. Typical values* of 3-15 mr'em alarm setpoints were used. Higher
expected doses per entry involve ALARA prejob discussions prior to er.1:ry,. resulting
in customized setpoints based on specific work requirements.
Beginning April 1, 1997, the licensee b~gan utilizing Pennsylvania Power and Light
(PP&L) as a TLD processing vendor. The inspector verified that PSE&G had
26
conducted a QA audit prior to accepting the new vendor and that PP&L was a
NVLAP-accredited laboratory in categories I-VIII. PSE&G continues to conduct a
blind spike program by exposing 15 TLDs to a known exposure and submitting them
to PP&L with each batch of personnel badges for quality assurance purposes.
PSE&G continues to maintain responsibility and cognizance for personnel dosimetry
processing and record dose determination processes.
c.
Conclusions
The licensee provided excellent oversight of the RCA access control point and
provides very effective exposure controls, limiting individual exposures to only
necessary and expected values. Continued diligence is necessary to ensure
accurate postings reflect survey results and for the timely removai of unnecessary
radiological hazards. TLD vendor processing was properly reviewed by the licensee
with appropriate quality control procedures implemented.
R1 .2
Internal Exposure Controls
a.
Scope (83750)
The inspector reviewed the bioassay measurement facility, reviewed applicable
calibration and source check records, reviewed current internal exposure
assessment results, licensee procedures, and interviewed licensee personnel.
Over the past 3 years, the licensee has maintained one whole body counter that
utilizes sodium-iodide detectors for conducting bioassay measurements. Previous
inspection reports have documented the complex of radionuclides present at both
Salem and Hope Creek stations and questioned the capability of the sodium-iodide
counter to accurately discriminate between these radionuclides. There have not
been any recorded internal exposures during that time period, however, the
capability for providing accurate measurements has been in question.
b.
Observations and Findings
During this inspection, the inspector verified that the licensee's germanium detector
whole body counter had been calibrated on March 13, 1997, sufficient to provide
the radionuclide discrimination capability. The inspector observed that since vendor
calibration in March 1997, daily source check counts of the germanium whole body
counter had not been successfully obtained and, therefore, the instrument had not
yet been put into service. The inspector determined that the whole body counter
operator did not have the skills required to effect a successful fine gain adjustment
on the germanium whole body counter.
The inspect:Jr reviewed whole body count records since the previous RP inspection
in December 1996. Four positive whole body counts were documented, of which,
only one reached an 'a,ction level requiring repeat measurements and exposure
assessment. Rapid radionuclide clearance from the body was appropriately
assessed by the licensee as a gastro-intestinal deposition resulting in less than 1 0
'
'
27
mrem CEDE (procedures require recording at 50 mrem or greater). The inspector
noted that the subject investigational whole body count was not recorded in the
licensee's PREMS database system as required by procedure ND.RS-Tl.ZZ-0403(0),
Rev. 3. When this discrepancy was identified, the licensee initiated an action report
to evaluate and correct this issue. The inspector determined that since there was
no exposure significance to this omission that this met the criteria for a non-cited
violation.
The inspector reviewed the above mentioned procedure, "Evaluation of Bioassay
Data," and observed that very limited guidance was provided for conducting an
internal exposure assessment and no requirement for a peer review to verify
calculations was provided.
c.
Conclusions
The inspector determined that the licensee at both Salem and Hope Creek stations
continues to conduct RP programs resulting in no recorded internal exposures. A 3-
year issue regarding calibration of the licensee's investigational whole body counter
has been .recently resolved. Although recently calibrated, the investigational whole
body counter has not been in service due to limitations in training of the operator.
The Radiation Protection services supervisor stated that additional whole body
counter trainina on the investigational whole body counter would be provided during
1997. The inspector also noted t~at the internal exposure assessment procedure
lacked sufficient guidance relative to the conduct of internal exposure assessments.
The Radiation Protection services staff indicated that procedure development was
underway. The internal exposure assessment program is improving but some
weaknesses in staff training and procedure adequacy remain.
R1 .3
As Low As Is Reasonably Achievable. (ALARA)
The inspector discussed with the licensee collective occupational exposure results
for 1996 at Salem Station. A Salem Station exposure goal of 208 person-rem was
established in late 1995 based on both units being returned to operation in February
and June of 1996, as originally scheduled and without anticipating the replacement
of steam generators in Unit 1. The licensee reported 209 person-re*m for 1996
withoL1t including the Unit 1 steam generator replacement exposures. Inclusion of
the 1996 Unit 1 steam generator replacement exposure (130.8 person-rem) resulted
in a total of 340.3 person-rem for Salem station 1996 exposures. The steam
generator replacement project was originally estimated to cost 166.5 person-rem,
however, the estimate was revised upward to 232.9 person-rem in early 1997 due
to additional steam generator support modifications, steam generator removal
equipment modifications and outage schedule delays. Salem Station exposure
estimates for 1997 are projected to be 30 person-rem plus 102.1 person-rem for
completion of the Unit 1 steam generator replacement project. Current (as of April
21, 1 997) 1997 exposure results are tracking within the goal at 17.7 person-rem
and 85.6, respectively. In light of the short duration of planning the steam
generator replacement project, exposures were well managed and controlled. The
. ' '
R6
R6.1
a.
28
Salem Station ALARA program for 1 996 through this inspection period was found
to be effective.
RP&C Organization and Administration
RP Organization Changes
Scope (83750)
The inspector reviewed the current RP staffing level of Salem Station commensurate.
with both units in extended outage conditions.
- b.
Observations and Findings
Individual reactor unit RP oversight was provided by specifically assigned RP
supervisors. The 35 permanent RP technician workforce was expanded by 30
additional contractor RP technicians that were appropriately trained and qualified to
provide the necessary radiological safety coverage. Inspector outage observations
indicated adequate personnel resources were provided.
c.
Conclusions
Salem Station RP staffing resources were appropriate during extended outage
conditions of both Units ..
R7
Quality Assurance in RP&C Activities
R7. 1
RP Program. Oversight
a.
Scope (83750)
The licensee's QA organization was beginning a biennial RP program audit during
this inspection arid was, therefore, not reviewed. During this inspection, additional
review of the RP corrective action process for identified problems was conducted,
the program oversight provided by RP services (Section R8.1, UFSAR review) was
reviewed, and the RP self-assessment program was reviewed. This review
consisted of examination of selected licensee documents and interviews with
applicable licensee personnel.
b.
Observations and Findings
During a previous inspection\\ significant weakness was reported with respect to
providing effective corrective actions for licensee-identified radiological problems.
PSE&G correspondence to the NRC, dated February 6, 1997, addressed these
concerns. The licensee indicated that a root cause manual was enhanced and that
. 1 Inspection Report Nos. 50-272/96-17 and 50-311/96-17
c.
29
the program now requires identification o"f a corrective action for each root cause or
causal factor, or a justification when a corrective action is not specified for each
root cause or causal factor. The licensee indicated that the improved corrective
action process was implemented January 1, 1997, and indicated that an RP
corrective action desk guide would be developed by March 31 , 1 997.
The inspector reviewed the following station corrective action program procedures:
"Action Request Process," NC.NA-AP.ZZ-OOOO(Q), Rev. 1
"Corrective Action Program," NC.NA-AP.ZZ-0006(0), Rev. 14
"Radiological Occurrence Investigations," NC.RP-Tl.ZZ-1001 (Q), Rev. 0
"Salem Radiation Protection Department Self Assessment/Corrective Action
Program Desk Guide," Rev. 0
The licensee indicated that the improved corrective action program in the RP
department was fully implemented by mid-February 1997, with some changes
added in March 1997 to improve the thoroughness of handling radiological
incidents. The inspector noted that while the program was implemented,
insufficient information was available to assess effectiveness.
The* action request process procedure designated level 1 events as:. severe or
unusual plant transients, safety system malfunction or improper operations,
radiation in excess of limits( or severe injury. The corrective action program
procedure provides root cause analyses for only Level 1 events with corrective
actions associated with each cause to prevent recurrence of the event. Level 2
events were defined as conditions that do not have a significant impact on plant or
personnel safety. The Level 2 events are assigned apparent causes and corrective
action is assigned to resolve the conditions. For Level 2 events, assigning actions
to prevent recurrence or to verify effectiveness was optional. In practice, Sale.m
RORs are all designated as level 2 or 3 events, not requiring the identification of
root causes and with no requirement for assigning corrective actions to each
identified cause. In practice, however, the RP department has shown in recent
results, that level 2 events are carefully considered with all causes identified and
corrective actions assigned to each. Additional program guidance was contained in
an RP department desk guide, which required a peer review and RPM review for
each level 1 and level 2 event and specified that a corrective action be identified for
each identified cause. The desk guide provided the additional program guidance
necessary to effectively resolve radiological incidents.
The RP department has been conducting self-assessments since October 1995.
The inspector reviewed RP self-assessment reports for the last 6 months. The
inspector noted variable quality and value of these self-assessments.
Conclusions
The licensee's corrective action response letter of February 2, 1997 described
actions taken for Level 1 events. RP incidents that do not result in exceeding
- i'
30
exposure limits (Level 2 and 3 events), do not require a root cause or corrective
action review. The RP department has developed a desk guide to accomplish an
improved review of level 2 events.
The RP department self-assessment program is beginning to provide some value,
although the assessments continue to be of variable quality.
RS
Miscellaneous RP&C Issues
RS.1
Review of Updated Final Safety Analysis Report (UFSARl Comr-:-:itments
a.
Scope (83750)
The inspector reviewed current Salem Station practices with respect to Section
12.4 of the UFSAR.
b.
Observations and Findings
While performing the inspections discussed in this report, the inspector reviewed
Section 12.4 of the UFSAR that related to the areas inspected. The following
inconsistency was noted between the wording of the UFSAR and the plant practices
and procedures observed by the inspector .
Within Section 12.4 entitled, "ALARA Program," the UFSAR lists the functions to
be provided by the Principal Health Physicist-Radiological Safety, which include:
ensuring periodic reviews of the ALARA program are conducted and providing
periodic assessments of the station RP program.
The inspector reviewed documented results of the RP services group efforts over
the last several years, and did not find significant evidence of periodic reviews of
the ALARA program scheduled by RP services that were conducted, nor any
evidence of periodic assessments of the Salem s'f:ation RP program provided by RP
services. *Documents reviewed indicated that in late 1995, RP and ALARA program
elements were scheduled for assessment by the RP services group over a 4-year
time period, however, none of the subject assessments were conducted.
c.
Conclusions
The UFSAR commitment discussed above is specified in licensee procedure NC.NA-
AP.ZZ-0024(0), Rev. 7, which states in Section 3.6 that, the Principal Health
Physicist-Radiological Safety is responsible for ensuring periodic reviews of the
ALARA program are conducted and is responsible for periodic, scheduled
assessments of the station RP program with a frequency such that all functional
activities are assessed at least every 4 years.
Contrary to the above, the Principal Health Physicist-Radiological Safety has not
scheduled or provided periodic ALARA program reviews, nor RP program
assessments for the past 4 years. The Principal Health Physicist-Radiological Safety
31
documented a business process action report on April 14, 1 997, indicating that
assessments of the RP program have not been systematically performed, however,
.no corrective actions had been taken at the time of this inspection. Considering the
time period of omission and lack of results reviewed, this is considered a violation
of RP procedures (50-272/97-07-02, 50-311/97-07-02).
S 1
Conduct of Security and Safeguards Activities
a.
Inspection Scope
Determine whether the security program, as implemented, met the licensee's
commitments in the NRC-approved security plan (the Plan) and NRC regulatory
requirements. The security program was inspected during the period of
March 17-21rand April 14-17, 1997. Areas ins.pected included: previously
identified items; protected area barriers and detection aids; alarm stations and
communications; testing, maintenance and compensatory measures; training *and
qualification; organization and administration; quality assurance; and security and
safeguards activities.
b.
Observations and Findings
Appropriate corrective actions have been implemented to address previously
identified weaknesses in the program. The alarm station operators were
knowledgeable of their duties and responsibilities, and security training was being
performed in accordance with the NRC-approved training and qualification plan ..
Protected area detection equipment satisfied the NRC-approved Physical Security
Plan (the Plan) commitments, security equipment testing was being performed as
required by the Plan, and maintenance of security equipment was being performed
in a timely manner. Based on observations and discussions with security officers,
the inspectors determined that they possessed the requisite knowledge to carry out
their assigned duties and that the training program was effective.
c.
Conclusions
The inspectors determined that the licensee was conducting its security and
safeguards activities in a manner that protected public health and safety:
S2
Status of Security Facilities and Equipment
S2.1
Protected Area Barrier (PABl and Detection Aids
a.
Inspection Scope
Conduct a physical inspection of the PAB and intrusion detection systems (IDSs) to
verify that the PAB satisfied the requirements of the Plan and the IDSs were
functional, effective, and met licensee commitments .
._:
'
32
b.
Observations and Findings
On March 19, 1997, the inspectors observed the testing of the IDSs. However, the
inspectors noted, during a walkdown of the PAB, that in several areas, the height of
the PAB was below the requirements noted in the Plan. The inspectors determined,
based on observations and discussions with security management, that the
discrepancy was caused by gravel within the PAB washing against the fence during
heavy rains. To correct the concern, the licensee committed to rake out all areas
along the PAB where a height discrepancy was identified and include surveillance of
the PAB as part of routine patrols.
c.
Conclusion
On April 16, 1997, the inspectors determined by observation, that the actions taken
by the licensee to correct the concern were adequate. The inspectors determined
that the height of the PAB satisfied the requirements of the Plan and that the IDSs
were functional and effective, and were installed and maintained as described in the
Plan.
S2.2
Alarm Stations and Communications
a.
Inspection Scope
Determine whether the Central Alarm Station (CAS) and Secondary Alarm Station
(SAS): (1) are equipped with appropriate alarm, surveillance and communication
capability; (2) are continuously manned by operators; and (3) include independent
and diverse systems so that no single act can remove the capability for detecting a
threat and calling for assistance, or otherwise responding to the threat, as required *
by NRC regulations.
b.
Observations and Findings
Observations of CAS and SAS operations verified that the alarm stations were
equipped with the appropriate alarm, surveillance, and communication capabilities.
Interviews with CAS and SAS operators found them generally knowledgeable of
their duties and responsibilities. However, on March 19, 1997, the inspectors
noted during interviews that there was some confusion on the part of several of the
CAS/SAS operators regarding when it was necessary to dispatch a responder to
assess an alarm; however, the inspectors did not observe any problems with actual
alarm responses. The concern was discussed with security management by the
inspectors. To address the concern, the licensee agreed to reiterate the expectation
concerning appropriate alarm assessment with all CAS/SAS operators during shift
briefings. Additionally, the inspectors also verified through observations and
interviews that the CAS and SAS operators were not required to engage in activities
that would interfere with the assessment and response functions, and that the
licensee had exercised communication methods with the local law enforcement
agencies as committed to in the Plan.
'
33
c.
Conclusion
The inspectors determined by discussions with the CAS/SAS operators on
April 16, 1 997, that the actions taken by the iicensee to reiterate expectations
concerning alarm assessment were effective. T~e determination was based on the
CAS/SAS operators' responses to the inspectors' questioning. The CAS/SAS
operators were knowledgeable of their alarm assessment responsibilities and the
alarm stations and communications met the licensee's Plan commitments and NRC
requirements.
52.3
Testing, Maintenance and Compensatory Measures
a.
Inspection Scope
Determine whether programs are implemented that will ensure the reliability of
security-related equipment, including proper installation, testing and maintenance to
replace defective or marginally effective equipment. Additionally, determine that
when security-related equipment fails, the compensatory measures put in place are
comparable to the effectiveness of the security system that existed prior to the
failure.
b.
Observations and Findings
The inspectors reviewed testing and maintenance records for security-related
equipment and found that documentation was on file to demonstrate that the
licensee was testing and maintaining systems <,lnd equipment as committed to in the
Plan. However, the inspectors noted that the testing re ... ords of the access control
search equipment did not indicate any equipment failures. On March 20, 1997, the
inspectors observed testing of the metal detectors and noted that three of eight
metal detectors failed the testing criteria. When questioning security management
about the failures and lack of failures annotated on the equipment test records, the
inspectors were informed that failures were not annotated on the test records for
the access control equipment because normal practice was to have the
instrumentation and calibration (l&Cl department make the necessary repairs
immediately upon notification of equipment failures. The inspectors stated that
even though such a practice ensures timely repairs of the equipment, the lack of
failures annotated on the test records eliminates the possibility of trending
equipment reliability. The licensee agreed with the inspectors' rationale and stated
that future equipment testing documentation would capture equipment failures. The
inspectors noted that a priority status was being assigned to each work request and
repairs were normally being completed th.e same day a work request necessitating
compensatory measures was generated. The inspectors also noted that the*
working relationship between security, maintenance and the l&C departments was
excellent as evidenced by the low number of open work requests related to security
equipment during the review of maintenance records .
c.
34
Conclusions
Documentation on file, reviewed April 16, 1997, confirmed that security equipment
was being tested and maintained as required; however, failures of search equipment
were not being documented in the test records. The licensee agreed to change its
practice to allow for tracking and trending of equipment failures found during
testing. Repair work was timely and the use of compensatory measures was found
to be appropriate and minimal.
S5
Security and Safeguar~s Staff Training and Qualification
a.
Inspection Scope
Determine whether members of the security organization are trained and qualified to
perform each assigned security-related job task or duty ln accordance with the NRC-
approved Training and Qualification (T&Q) Plan.
b.
Observations and Findings
On March 17, 1997, the inspectors met with *the security training staff and*
discussed training initiatives associated with enhanced contingency response drills
and tactical response training. The inspectors also observed classroom re-
qualification training addressing the use of force, and determined that the
instructor's presentation was good and that all course material was properly
covered.
The inspectors randomly selected and reviewed T&Q records for fifteen security
force members (SFMs) on April 15, 1997. Physical and firearms re-qualification
records were inspected for armed and unarmed SFMs and security supervisors. The
irispectors found that the training had been conducted in accordance with the T&Q
Plan and was properly documented. Additionally, the inspectors observed weapons
requalification training and determined that the training was conducted in
accordance with the T&Q Plan and that the range was.controlled in a safe manner.
Throughout the inspection,* the inspectors interviewed a number of SFMs to
determine if they possessed the requisite knowledge and ability to carry out their
assigned duties.
c.
Conclusions
The inspectors determined that training had been conducted in accordance with the
T&Q Plan. Based on the SFMs' responses to the inspectors' questions and the
inspectors' observations, the training provided by the security training staff was
considered effective.
"
I
..
35
S6
Security Organization and Administration
a.
Inspection Scope
Conduct a review of the level of management support for the licensee's physical
security program.
b.
Observations and Findings
The inspectors reviewed various program enhancements made since the last
program inspection, which was conducted in August 1996. These enhancements
included the procurement of new weapons to enhance tactical response capabilities,
new uniforms and web gear for the security officers, and the procurement of 17
new radios for communication enhancement. The inspectors reviewed the Manager
- Nuclear Security's position in the organizational struc;:ture and reporting chair.. The
Manager - Nuclear Security reports to the Director - Nuclear Operations Services,
who reports directly to the Senior Vice President - Nuclear Operations, who reports
directly to the Chief Nuclear Officer and President - Nuclear Business Unit.
c.
Conclusions
Management support for the physical security program was determined to be
adequate. No problems with the organizational structure that would be detrimental
to the effective implementation of the security and safeguards programs were
observed or reported.
S7
Quality Assurance in Security and Safeguards Activities
S7. 1
Effectiveness of Management Controls
a.
Inspection Scope
Determine if the licensee has controls for identifying, resolving and preventing
programmatic problems.
b.
Observations and Findings
The inspectors reviewed the licensee controls for identifying, resolving and
preventing security program problems. These controls included departmental self-
assessments and the performance of the NRC-required annual quality assurance
(QA) audits. The licensee also utilizes industry data, such as violations of
regulatory requirements identified by the NRC at other facilities, as criteria for self-
assessment. The inspectors reviewed documentation applicable to the performance
of the self-assessment program and noted that the self-assessment program was
limited in scope. Specifically, 13 of 14 tasks developed to implement the program
have been performe~ repeatedly for the past four years. Additionally, the results of
the performed tasks have not been trended since October 1995. Even though self-
assessment tasks are assigned and performed by security supervision on a weekly
..
c
\\ ....
- c.
36
basis, the inspectors questioned the effectiveness of the program with security
management. The inspectors were informed by security management that a new
self-assessment program was being developed and would be implemented in the
near future.
Conclusions
The inspectors concluded that the self-assessment program in place to identify,
prevent and resolve potential problems was weak and an improved self-assessment
program would enhance program effectiveness.
S7.2
Audits
a.
Inspection Scope
Review the licensee's QA report of the NRC-required security program audit to
determine if the licensee's commitments as contained in the Plan were being
satisfied.
Observations and Findings
The inspectors reviewed the 1996 QA audit of the security program, conducted
May 6-17, 1996, (Audit No.96-031 ). The audit was found to have been
conducted in accordance with the Plan. To enhance the effectiveness of the audit,
the audit team included two independent technical specialists .. The audit report
identified four weaknesses. The weaknesses were in the areas of vital area
documentation, preventive maintenance for security equipment, closed circuit
television improvements, and the identification of contraband by the security force
member, during an audit drill. The weaknesses were not indicative of programmatic
weaknesses but, if corrected, would enhance program effectiveness. The audit
results had been disseminated to the appropriate levels of management. The
inspectors determined, based on discussions with security management and a
review of the responses to the weaknesses, that the corrective actions were
effective.
c.
Conclusions
The review concluded that the audit was comprehensive in scope and depth, that
the findings were appropriately distributed and addressed and that the audit
program was being properly administered.
S7 .3
Adequacy of Security, NRC Restart Inspection Item 111.24 (Closed)
All open items identified in previous inspection reports were reviewed and corrective
actions were verified to be reasonable, complete and properly implemented.* Security
program implementation has been determined to be adequate to support restart.
37
Miscellaneous Security and Safeguards Issues
S8.1
Review of Updated Final Safety Analysis Report (UFSAR)
. A recent discovery of a licensee operating its facility in a manner contrary to the
UFSAR description highlighted the need for a special focused review that compares
plant practices, procedures, and parameters to the UFSAR description. Since the
UFSAR does not specifically include security program requirements, the inspectors
compared licensee activities to the NRC-approved physical security plan, which is
the applicable document. While performing the inspection discussed in this report,
the inspectors reviewed Section 4.2.2 of the Plan, titled "Vehicle and Cargo
Control," the inspectors determined, based on discussions with security supervision
and reviews of applicable procedures and records, that vehicles were being
searched and controlled prior to entry into the protected area as described in the
Plan a_nd applicable procedures. *
S8.2
(Closed) Inspection Followup Item 50-272, 50-311, 50-354/93-28-01 - Review the
effectiveness of assessment aids after upgrade is complete. The program to
upgrade the assessment aids has been completed and the assessment aids were
. determined to be adequate to perform their intended function.
S8.3
(Closed) Violation 50-272, 50-311/96-18-01, 50-354/96-10-03- Failure to control
badge/keycards and failure to display photo badges in the protected area. The
inspectors verified the corrective actions described in the licensee's response letter,
dated February 26, 1997, to be reasonable and complete and they were found to be
properly implemented. No similar problems were identified.
S8.4
(Closed) Violation 50-272, 50-311, 50-354/EA96-344-01013 - Failure to exercise
positive access control over photo badge keycards thereby creating the opportunity
for unauthorized access to the vital areas. The inspectors verified that corrective
actions described in the licensee's response to letter, dated January 10, 1997, to
be reasonable and complete and they were found to be properly implemented. No
similar problems were identified ..
S8.5
(Closed) Violation 50-272, 50-311, 50-/EA96-344-02013 - Failure to conduct a
physical pat-down search of a contractor that had caused two portal metal
detecto.rs to alarm on three different attempts to pass through them, although these
alarms provided reasonable cause to suspect that the contractor was attempting to
introduce firearms, explosives, incendiary devices, or other unauthorized material
into the protected area, before issuing him a photo badge keycard, and allowing him
to enter the protected area. The inspectors verified the corrective actions described
in the licensee's response letter dated January 10, 1997, to be reasonable.
and complete and properly implemented. No similar problems were identified.
S8.6
(Closed) Violation 50-272, 50-311, 50-354/EA 96-344-02023 - Failure to notify the
senior nuclear shift supervisor (SNSS) of a security threat when a contractor that
should have received a pat-down search entered the protected* area without a pat-
down search. The failure to notify the SNSS resulted in the event not being
58.7
58.8
38
classified per Event Classification Guide 16. The inspectors verified the corrective
actions described in the licensee's response letter, dated January 10, 1997, to be
reasonable and complete and properly implemented. No similar problems were
identified.
(Closed) Violation 50-272, 50-311, 50-354/EA96-344-03014 - Failure to inactivate
the security photo badges and personnel access clearance for 1 2 employees
terminated in June and July 1996 within two working days of termination of
employment. The inspectors verified the corrective actions described in the
licensee's-response letter, dated January 10, 1997, to be rea~rrnable and complete
and properly implemented.
(Closedl°Violation 50-272, 50-311, 50-354/EA96-344-04014 - Failure of two
security supervisors to qualify in all required crit.ical security tasks prior to being
assigned field operations supervisor duties. The inspectors verified the corrective
actions described in the licensee's response letter, dated January 10, 1997, to be
reasonable and complete and properly implemented. No similar problems were
identified.
58.9
(Closed) Violation 50-272, 50-311, 50-354/EA96-344-05014 - Failure to complete
all required tests of an alarm zone prior to releasing the security force member
posted at the alarm zone. The inspectors verified the corrective actions described
int he licensee's response letter, dated January 10, 1997, to be reasonable and
complete and properly implemented. No similar problems were identified.
V. Management Meetings
X1
Exit Meeting Summary
Security inspectors met with licensee representatives at the conclusion of the inspection
on April 17, 1997. At that time, the inspectors reviewed the purpose and scope of the
inspection and presented the preliminary findings. The licensee acknowledged the
preliminary inspection findings.
The inspectors presented the inspection results to members of licensee management at the
conclusion of the inspection on May 7, 1 997. The licensee acknowledged the findings
presented.
The inspectors asked the licensee whether any materials examined during the inspection
should be considered proprietary. No proprietary information was identified .
'
v'.,
- , -
..
INSPECTION PROCEDURES USED
IP37751:
IP 61726:
IP 62707:
IP 71707:
Onsite Engineering
Surveillance Observations
Maintenance Observations
Plant Operations
IP 71750:
Plant Support
IP 81700:
IP 83750:
Physical Security Program
Occupational Radiation Exposure
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-311/97-07-01
50-272,311 /97-07-02
Closed
50-272&311/EA94-239-01012,
EA96-177-01012 & 50-272&
failure to establish containment integrity within
eight hours with only one operable AC electrical
bus train while in mode 5 (Cold Shutdown)
Failure of RP Services to provide periodic RP
program and ALARA program assessments.
311/EA96-177-01022
discrimination against employees engaged in *
protected activities as designed in 10 CFR 50.7
(a)(1)
50-272&311/EA94-112-01013
.VIO
50-272&311/94-01-01
50-27 2&311/94-24-01
50-272&311 /95-12-01
50-272&311 /EA95-117-02013
50-272&311 /EA95-117-05013
50-27 2&311/EA96-117-03013&
04013
50-272&311 /EA96-117-06013
50-272&311 /96-07-02
50-272&311 /96-08-04
50-311 /96-13-02
50-272&311/96-15-01
failure to promptly identify and correct the cause
of spurious high steam flow signals
control of maintenance troubleshooting
failure to ensure containment integrity *
inadequate corrective action for ITE circuit
breaker problems
inadequate corrective action for #12 switchgear
fan failure
Salem staff did not promptly identify and correct
miscellaneous conditions adverse to quality
- inappropriate corrective action
valve not properly positioned following a plant
modification
violation of TS 6.8.1 requirements
failure of Salem staff to initiate a corrective
action document in a timely manner
failure to follow procedures
corrective action for operator performance
problems
...
' . .
50-272&311/96-16-02
50-272/96-019 '
50-272/96-021
50-272/96-025
50-272/9.6-027
50-272/96-029
50-272/96-041
50-311 /96-011
50-311/96-01 2
50-311/96-013
50-311 /96-014
50-311/96-015
50-311/96-016
Discussed
2
IFI
improperly coded corrective action documents
LER
misclassification of blowdown sample valves
LER
potential. common mode failure for 28V DC
battery chargers due to molded case circuit
breaker damage
LER
inadequate calibration of overpower delta .
temperature protection channels
LER
diesel watt meter inaccuracies not accounted for
in surveillance testing
LER
surveillance test did not meet TS surveillance
requirement
LER
missed surveillance for radiation monitors source
check
LER
missed surveillance for sampling boron
concentration of refueling canal
LER
ESF actuation, 2A 4kv vital bus undervoltage
LER
missed surveillance for performing tritium grab
samples when the refueling canal was flooded
LER
emergency diesel generator automatic start
LER
breach of containment closure during core reload
LER
missed surveillance for determining response
time of high containment gaseous radioactivity
ESF actuation
, /
....
I
<
A LARA
CRO
DVOM
NRC
OHA
OSR
POPS
PRE MS
PSE&G
SEC
SFM
SPAV
SRG
T&Q
the Plan
- TS
TSSIP
LIST OF ACRONYMS USED
As low as is reasonably achievable
American Society of Mechanical Engineers
Central Alarm System
Closed Circuit Television
Control Room Operator
Design Change Package
Digital Volt/Ohm Meter
lntrusiqn Detection Systems
Nuclear Regulatory Commission
Overhead Annunciator
Onsite Safety Review
Protected Area
Public Document Room
Plant Equipment Operator
Preventive Maintenance Change Requests
Pressurizer Overpressure Protection System
Personnel Radiation Exposure Management System
Public Service Electric and Gas
Radiological controlled area
Radiation Protection
Quality Assurance
Secondary Alarm System
Safeguards Equipment Cabinet
Security Force Members
Switchgear Penetration Area Ventilation
Safety Review Group
Training and Qualification
NRC-approved Physical Security Plan
Thermoluminescent dosimeter
Technical Specification
Technical Specifica~ion Surveillance Improvement Program