ML18102B349

Readiness for Restart,Overview of Key Initiatives.

ML18102B349
Person / Time
Site:	Salem
Issue date:	05/28/1997
From:	Public Service Enterprise Group
To:
Shared Package
ML18102B348	List: ML18102B347 ML18102B349
References
NUDOCS 9706030302
Download: ML18102B349 (124)

Text

I READINESS FOR ESTART An Overview of Key Initiatives I

I I

I I

I The Power of Commitment PS~G i- * *~.~97~0~60;--3.;:-:o=-=-30=2-9-70-52-a - - --

May 28, 1997 PDR ADOCf.<. 05000311 1 P. PDR

I

- Table of Contents 1

Docketing Letter dated May 28, 1997 I

Introduction I

I 1. Process for Achieving Restart I 2. System Readiness Review Process II 3. Start-up & Power Ascension Testing Program

• I 4. Culture Change

5. Independent Oversight I

6. Operations I

7. Planning & Maintenance I

8. Engineering I

• 1 9. Training

10. Design I Licensing Bases Review I

I Public Service Electric and Gas Company eon R. Ellason Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1100 Chief Nuclear Officer & President Nuclear Business Unit MAY 2 8 1997 LR-N970286 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 CLOSURE OF CONFIRMATORY ACTION LETTER ITEM 4 SALEM GENERATING STATION UNIT NO. 2 DOCKET NO. 50-311 Ladies/Gentlemen:

By letter dated April 11, 1997 (LR-N970250), Public Service Electric and Gas Company stated that the performance of an operational readiness review, per Item 4 of the NRC Confirmatory Action Letter (CAL), dated June 9, 1995, has been fulfilled for Salem Unit No. 2. The following activities constitute the operational readiness review.

I 1. Routine self assessment, including third-party assessments and the Salem Integrated Readiness Assessment (SIRA), have been conducted as part of the activities described in 'the Salem Restart Plan. Department self assessments I continue to be performed as a normal business practice.

2. The Restart Action Plans described in the Salem Restart Plan have been I implemented. Effectiveness review and approval by the Management Review Committee (MRC) have been completed, with the exception of the Human Performance Restart Action Plan. Final approval of the Human Performance I Restart Action Plan will be completed prior to startup.

3. Departmental Readiness Affirmations have been reviewed and approved by the I MRC. PSE&G will re-affirm departmental readiness as a part of final preparation for restart.

I 4. System Readiness Reviews for restart have been reviewed and approved by the MRC. Final system affirmations to support system turnover to Operations are being completed to support the restart schedule.

I ~C'({O~C\ JW

~~~____:.__~~~~~~~~~~~~~~~~~~~~~~~~~~~-

I Document Control Desk 2 MAY 2 8 1997 LR-N970286

5. NRC Technical and Programmatic restart issues, described in the letter from NRC to Leon Eliason, "NRC Restart Action Plan - Revision 2," dated December 26, 1996, have been reviewed and approved by the MRC.

During the course of the Restart Assessment Team Inspection (RATI), we will discuss the outcome and conclusions of these readiness assessment reviews with your I representatives, per CAL Item 5.

To assist in the understanding of the scope of our restart efforts, including operational I readiness, we have prepared a series of ten Restart Briefing Papers. They are contained in the enclosed document entitled, "Readiness for Restart --An Overview of Key Initiatives." The papers provide an overview of the nature and extent of important I improvement initiatives, their results, and certain measurement criteria and performance indicators by which we monitor progress. While the papers summarize I the highlights of restart and improvement initiatives at Salem, details regarding the various efforts are documented and remain available on site for NRC review, as appropriate.

I Should you have any questions concerning this matter, please contact me at (609) 339-5700.

Sincerely, I

I Enclosure I

I I

I I

I INTRODUCTION I In June of 1995, Public Service Electric and Gas Company (PSE&G) management decided to shut down the Salem Generating Station (SGS) units for an extended period to make extensive improvements in people, processes, and plant. PSE&G committed I not to seek to restart the units until long-term reliable operation could be assured.

Salem Unit 2 is now ready to take the final steps to be returned to service.

I Over the last two years, PSE&G has taken many actions to improve our performance and ensure the safe and reliable operation of the plant. From a broad perspective, we have:

I

• installed a new management team which has raised human performance standards, I provided requisite training, instilled a questioning attitude and accountability in the workforce, and developed the basis for a safety conscious culture; I

• developed and implemented processes to assure that operations at Salem are conducted in a conservative and predictable manner, and that the consequences of transients are effectively controlled; and

• made extensive improvements to the physical plant which, among other things, will reduce operator challenges and improve equipment reliability.

I As we prepare to take the final steps to restart Salem Unit 2, it is important to inform the Nuclear Regulatory Commission and our other stakeholders about our progress and I future plans. With this in mind, we have prepared ten Restart Briefing Papers that ;*

summarize the key activities that form the backbone of our restart effort. The papers are similarly formatted to provide the reader with an overview of the central focus of the I activity, the principal initiatives involved, their results, and some of the measurement criteria that we use to monitor our progress.

I Summarized in the charts below are some of the major accomplishments in the areas of people, processes, and plant. The efforts have produced a significant amount of I information and data, and it would be impracticable to consolidate them into one document. The Restart Briefing Papers that follow are intended to familiarize the reader with the highlights of our extensive efforts. The details regarding the various I efforts are documented and remain available at the SGS site for review by the NRC and other stakeholders, as appropriate.

1 I

I PEOPLE

- ::::1at!1n1::::::::::::::::::::::::::1:::1:::::::::::::::1::::::::::::::::r::::::::::::::::::::tl:::::::::::::::rt:t::':::::::::':::::::::=:::l:t]* ]l.BY.1~:::::::::::r:r:r:::::::::::::::::::::t'r:::::::::::::::l:::::::1:1::::::::::::::::1::::::::lr::::::::':::::::::::::::::1::::::::=::::::,,::::::::::

Installed new Senior Leadership professionals with performing plants Obtained nuclear experience in turning around plant performance and infused new ideas into the Salem culture I Reorganized and re-directed Quality Assessment orQanization Better poised to evaluate plant performance Retrained Operations Department Instilled Operations personnel with I (Intervention)

Promulgated Operations Standards required knowledQe, skills, and attitudes Effectively communicated Operations Document management expectations I Retrained Maintenance Department (Intervention)

Comprehensively evaluated and remediated Maintenance workforce I Raised training standards Lowered threshold for reporting Improved personnel qualifications Raised self-identified Action Requests corrective actions from monthly average of 50 to 600 I Conducted Performance Rating &

Ranking twice Approximately 225 low performers are no longer with company Identified and trained leaders throughout Approximately 400 personnel completed I the organization About 400 personnel completed Dale Breakthrough Leadership TraininQ Improved personal communication ability Carnegie training on their own time Consolidated Nuclear Business Unit Improved maintenance effectiveness (NBU) maintenance team under one across the NBU Director I Instituted Pay for Performance Heightened incentive for quality work and accountability I Essentially all supervisors completed Management Action Response Checklist Management expectations communicated throughout the organization (MARC) training I Conducted 10 CFR 50.59 training for engineers Heightened quality of 50.59 reviews to better ensure consistency with design and licensing bases I Conducted Managing for Nuclear Safety Training, Root Cause Training, and Improved corrective actions and heightened self-identification of issues Human Error Reduction Training I

I 2

I

I PROCESS

1P:t'-ln1J,:]:,:::,,::]::::::::::::::::J:::=]::::=::,]:::::::::::::::::::::::::]:::: \ \ i 1~ ~j~ ~ j\~ ~ ~ ~ il~ ~ ~l~1~ ~ 1~ 1i\ )j~ ;i ~tl~f~!il~ l~ i\ ~f~1~; ,:,::1i§~dt$.::::::::,:::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::]:::::::]1:::::::::::::::::::1::::::::::::::]:::::::::t::::::::::::1::::::::::::::::::::

Revamped Corrective Action Program Experienced a significant rise in the initiation of Condition Reports, indicating heighten level of issue self-identification I Created Corrective Action Review Board Heightened standards for root causes and corrective actions Established System Readiness Review Created a disciplined approach to system I Process Developed System Index Database assessment, ownership, and accountability Created tool for system managers to System implement the SRRP I Implemented Design Engineering Review Heightened standards for system manager Board knowledge and understanding of system I Centralized Planning and Maintenance operations and design basis Promoted maintenance productivity in support of safe and reliable operations I Implemented Work Week Management Process Improved the availability of resources and hardware to resolve equipment issues Revised the Operability Determination Improved the quality of Operability I Process Provided training on Safety Evaluation Determinations Improved quality of 10 CFR 50.59 reviews Process and heighten personnel design and licensing bases knowledge Implemented Design I Licensing Bases Reviewed design and licensing bases Review Project documents, operational limitations within I the UFSAR, design output documents, implementing documents, and the as-built plant I Implemented System Team Concept (System ownership)

Created a disciplined approach to system assessment, ownership, and accountability I Established a streamlined Safety Tagging Program I Procedure Reduced the number of tagging errors Implemented an Employee Concerns Further facilitated the timely identification I Program of issues and concerns by station personnel Improved Performance Evaluation Ensured employees better understand I Process management expectations, and compared individual performance with defined performance dimensions I Implemented Self Assessment Program Increased self-identification of issues

. 3 I

I Developed and implemented a Heightened personnel access to and computerized Performance Indicator awareness of performance indicator data, System and improved management's ability to track improvement progress Received Engineering Support Kept training program in step with Personnel Training Accreditation industry's continually improving training standards and innovations Upgraded Salem Unit 2 EOPs following a Enhanced operator response to detailed comparison to the emergency situations Westinghouse Owners Group Emergency Response Guidelines.

Following the upgrade, each EOP was verified and validated by Westinghouse and Public Service Reviewed and validated Abnormal Enhanced operator response to abnormal I Operating Procedures and Integrated Operating Procedures operation conditions I Reviewing Alarm Response Procedures for adequacy Improved guidance to assist Operator's in response to plant conditions Reviewing, revising, and upgrading In- Increased efficiency in performance of I Service Testing Procedures component testing and greater reliability of systems Reviewed and improved the Technical Enhanced compliance with regulatory Specifications Surveillance requirements, heighten worker Requirements Matrix for Unit 2, and understanding of Technical Specification conducted a review to ensure that surveillance requirements I procedures implement the requirements.

Reviewed surveillance procedures at Unit 2 to ensure that acceptance criteria I exist for the associated requirements Reformatting and reviewing operating Promoted common expectations for logs for adequacy operating log documentation I Reviewing for adequacy and revising, as Enhanced guidance for quality related necessary, "Q" designated Operations administrative procedures I Department administrative instructions I

I 4

I _.

I PLANT

- Unified control room Advanced Digital Feedwater Control Digital Feed Enhances operations command & control Simplifies feedwater control for Operations I Containment Fan Coil Units System modifications resolve waterhammer issue (GL 96-06)

Turbine Rotor Replacement Improves performance and efficiency I Station Air Upgrades Enhances performance and reliability Circulating Water Upgrades Improves reliability and operations I Control Area Ventilation Supports new control room and design bases requirements Service Water Pump Replacement Improves net positive suction head I Service Water Pipe Replacement (NPSH) and overall pump performance Installed new corrosion resistant piping Service Water Strainer Modifications Eliminates waterhammer and improves I Emergency Diesel Generator strainer performance Eliminates vibration concerns and Modifications improves air start and lube oil performance I Reactor Protection System Completes refurbishment and/or replacement of all control modules Accomplished over 50,000 work activities Significantly improved the material condition of the plant Completed over 650 major and minor Corrected long standing system I design modifications performance issues and reduced operation workarounds I As a result of these and other efforts more fully described in the Restart Briefing Papers that follow, we have confidence in our enhanced people, processes, and plant at SGS.

I The Briefing Papers summarize the bases supporting our confidence and describe, among other things, achievements in the following areas:

I

• Higher Standards (e.g., pass rate for Operations);

Effective Training;

• Operational Leadership; I

• Equipment Ownership; Rigorous Integrated Testing; I

• System Quality and Reliability; Critical Self Assessments;

• Ingrained Corrective Action; and

• Effective Oversight.

. 5 I

I In summary, PSE&G is committed to safe, sustained, reliable operation of our nuclear plants. From the beginning, we stated that we would proceed with startup of the SGS units only when we are certain they are ready for safe, reliable operation. The roadmap for restart was established in 1995 and since then we have steadily followed it and continue to do so today. The new management team that was assembled to lead our restart efforts has brought focused leadership, instilled accountability and higher 1 standards in the workforce, and provided clear direction to SGS personnel. Our workforce is retrained, experienced, and skilled, and our employees perform their jobs in a "safety conscious" environment. Processes and procedures are improved and I effective. Plant equipment has been improved through extensive major and minor design modifications. We are now ready to take the final steps toward restarting Salem Unit 2.

I I

I I

I I

I I

I

. 6 I

I The Power of Commitment I SALEM GENERATING STATION I

I I

I I PROCESS FOR I ACHIEVING RESTART I

I I

I I

David F. Garchow I General Manager - Salem Operations May 28, 1997 I

11

I Key Issue Following development of the Salem Restart Plan (SRP), by what process will the Nuclear Business Unit (NBU) gain NRC agreement to restart the Salem Generating Station?

Executive The Salem Restart Process consists of five primary stages:

Summary Issue Discovery; Corrective Actions; Assessments and Affirmations; Recommendation; and Concurrence. Each of these stages, in turn, consists of several discrete processes or actions. As explained below, the inputs from the first three stages are reviewed and confirmed by the Management Review Committee (MRC) and/or Independent Oversight.

Recommendations from both are then provided to the Chief I Nuclear Officer (CNO), in stage four, who sends a letter to the

. Nuclear Regulatory Commission (NRC) stating the NBU's I readiness to restart Salem Unit 2 in stage five.

Process A schematic overview of the Salem Restart Process is set forth I Overview in the Appendix to this Restart Briefing Paper. It consists of five stages: Issue Discovery; Corrective Actions; Assessments and Affirmations; Recommendation; and Concurrence. The I processes and actions which collectively constitute each stage are summarized below.

I Issue Discovery To ensure the NBU discovered and had a comprehensive understanding of the issues to be resolved at Salem Generating Station prior to restart, the following actions were taken:

I Developed Restart Action Plans: The SRP, issued on November 8, 1995, identifies Restart Action Plaris which, I together, form a systematic process for correcting the causes that led to the decline in performance at the Salem Generating*

Station and within the NBU. The Restart Action Plans, which I consist of 57 specific problem statements, address deficiencies in the following nine areas:

I

• Conduct of Operations

• Human Performance Management I

• Engineering Performance Reliable Maintenance

• Work Control Process Improvement I

• Organizational Self-Assessment Corrective Action

• Salem System Engineering Function and Equipment I

• Reliability Accredited Training I 2 I

I The table below entitled "Restart Action Plans - Unit 2,"

provides a status report on the nine restart action plans, including completion of their respective Problem Statements and Action Elements.

Restart Action Plans - Unit 2 I 5/28/1997 Problem Statements Action Elements I Action Plan Human Performance Total 6

Comeleted 6

Total 39 Comeleted 39 Status NRC Closed NRC Closed I

Operations 6 6 144 144 Engineering 6 6 67 67 NRC Verbal Maintenance 8 8 58 58 NRC Closed I Work Control 8 8 108 108 NRC Closed Self Assessment 2 2 27 27 NRC Closed I Corrective Action 8 8 92 92 NRC Closed System Engineering 4 4 54 54 MRC Complete I Training 9 9 155 155 NRC Closed Total 57 57 744 744 I Note: MRC = PSE&G's Management Review Committee I Performed System Readiness Reviews: In response to equipment reliability and system engineering issues, PSE&G implemented the System Readiness Review Program (SRRP).

I This program, which is the subject of a separate Restart Briefing Paper, is a comprehensive and systematic process which ensures that plant systems are thoroughly evaluated, modified, I and maintained to support restart.

Identified and Evaluated Emergent Issues: As an ongoing I part of Phase II of the SRRP (i.e., Restart Activities Monitoring),

PSE&G evaluates emergent work items. Since March 1996, for example, approximately 29,000 activities have been added to I the Unit 2 work-scope. The process of adding items to the outage scope is defined by procedure.

I Identified NRC Restart Issues: In February 1996, the NRC Staff issued its restart plan for Salem Generating Station. It contains 43 Technical Restart Issues and 22 Programmatic I Restart Issues. Since then, 9 Programmatic and 2 Technical Issues have been added. Corrective actions addressing these I issues have been reviewed and approved by the MRC. The 3

I

I table below entitled, "NRC Restart Issues - Unit 2," indicates the status of the NRC's Programmatic and Technical Issues, including NRC approval and NRC closure as of May 27, 1997.

NRC Restart Issues - Unit 2 MRC NRC Approved I Programmatic 31 31 22 Technical 45 45 34 I

Total 76 76 56 I

Established Management Review Committee: The MRC was I established as an oversight committee to review the Restart Action Plans, System Readiness Reviews, the work scope of the outage, and other issues having the potential to impact restart ..

I Its purpose is to exercise management oversight and approval of the physical and programmatic work activities necessary to ensure a safe, uneventful restart and continued reliable I operation of the plant. The MRC, which is chaired by the General Manager - Salem Operations, is comprised of management personnel (of various disciplines, as appropriate)

I who are fully knowledgeable about and familiar with the content of the Salem Restart Plan. MRC functions are described in a Charter. These functions include for example, (1) establishing I expectations for the organization to evaluate issues and proposed actions according to established restart screening criteria, and (2) ensuring that the screening criteria are I consistently applied by station organizations.

Corrective Actions Having identified the scope of issues relevant to plant restart, I the NBU implemented corrective actions and enhancements to address deficiencies involving plant, people, and processes.

I Self-assessment results were incorporated into these corrective actions to ensure that the actions were both comprehensive and effective. The elements of this second phase of the restart I process are summarized below.

People and Process Enhancements: PSE&G has I implemented revisions, upgrades, interventions (i.e., the Maintenance and Operations Interventions which are discussed in two separate Restart Briefing Papers), and enhancements I related to human performance and various programs. These 4

I

I actions include those specified in the Restart Action Plans, the close-out of NRC Programmatic Issues, and Appendix E of the

- Salem Restart Plan ("Other Restart Considerations").

Equipment Repairs and Upgrades: Approximately 56,000 Unit 2 work activities, including post-maintenance tests and re-tests, to repair and modify plant equipment at Salem Unit 2 were I or will be performed by PSE&G. Included in this scope of work is the close-out of NRC Technical Issues.

I Self-Assessments: An integrated self-assessment process was developed and implemented based, in part, on a successful I program used at a high performing nuclear facility. The process includes formal planned self-assessments supplemented by management and peer assessments of activities in progress.

I Identified deficiencies are incorporated into and addressed through the Corrective Action Program.

I Assessments and The Salem Restart Plan requires the NBU to conduct a series of Affirmations self-assessments to test and affirm the readiness of plant, people, and processes to support restart. These assessments I are being or have been conducted in the following areas:

Routine Self-Assessments: Routine self-assessments are I performed for Salem and NBU support departments to establish an integrated line-management assessment and affirmation of system, departmental, and operational readiness for restart.

I System Readiness: Prior to restart, each of the 89 systems for Unit operation is affirmed by its applicable system team. This I team is led by the System Manager and includes Design Engineering support, as well as a dedicated system Senior Reactor Operator (SRO). (The System Readiness Assessments I are the subject of a separate Restart Briefing Paper and are discussed in greater detail therein.)

I Department Readiness: Operating departments, Licensing, and Security affirm their restart readiness in accordance with the I Operational Readiness Self-Assessment Program. As part of this process, each department confirms that its assigned restart actions are complete, programs/processes are sufficient to I support safe plant operation, and post-restart work and improvement efforts are adequately defined, prioritized, scheduled, and controlled. Initial Department Readiness Affirmations are completed prior to the NRC Restart Assessment Team Inspection (see below). Final department readiness affirmations address developments subsequent to the initial I affirmations. All affirmations are reviewed by the MRC.

5 I

I Operational Readiness: Each Senior Nuclear Shift Supervisor and operating crew assesses and affirms that the Operating Shift is satisfied with the plant material condition and they are ready to operate the unit in a safe and reliable manner. These affirmations, which are reviewed and approved by the Operating Engineer and the Director -- Salem Operations, also include a verification of operator training, establishment of an acceptable control room working environment, and verification that Operations performance expectations have been established and effectively communicated.

I Integrated Readiness: An integrated assessment using industry experts was conducted and utilized as input to adjust I the Restart Action Plans to address areas in which desired performance results were not being achieved. This assessment evaluated the performance of processes and people which are I essential to Salem restart. Corrective actions and enhancements were added to the appropriate Restart Action I Plans based on the results of the assessment.

MRC Review of Restart Affirmations: The MRC reviews and I evaluates several overlapping and interfacing readiness assessment results including the system, operational, and departmental readiness affirmations, the disposition or close-out I of restart items specified in each of the nine Restart Action Plans, the review of organizational and personnel readiness, other input from personnel and management, and NRC restart I issues. In particular, systems required for specific mode entry must present readiness affirmations for MRC approval prior to mode change.

I NRC Restart Assessment Team Inspection (RA Tl): The NRC Staff conducts an independent RATI to measure the readiness I of the Salem Generating Station for restart.

Quality Assurance (QA) Assessments: QA is performing a I series of assessments to measure restart readiness. (Details regarding the QA Assessments are included in a Restart Briefing Paper titled "Independent Oversight.")

I Nuclear Review Board Assessment: The Nuclear Review I Board provides an assessment of the overall status and results of Salem restart activities. This assessment is factored into the Independent Oversight assessment.

I I 6 I

I Recommendations Following completion of the above-described restart readiness assessments and affirmations, restart recommendations are made by the General Manager - Salem Operations (General Manager), the Senior Vice President -- Nuclear Operations, and Independent Oversight.

General Manager - Salem Operations: As MRC completes its I review of the inputs resulting from the restart readiness assessments and affirmations, the Salem Projects Group generates a letter to the General Manager documenting the I results of the MRC review. Based on his readiness assessment, the General Manager also provides a recommendation to the Senior Vice President -- Nuclear Operations regarding the I restart readiness of the Salem Generating Station.

Senior Vice President -- Nuclear Operations: The Senior I Vice President -- Nuclear Operations makes a written restart recommendation to the CNO on the basis of his personal I observations, input from the Senior Vice President -- Nuclear Engineering, and final consideration of the General Manager recommendation.

I Independent Oversight: The Director -- Quality Assurance/

Nuclear Safety Review (QA/NSR) makes an independent, I written restart recommendation to the CNO based on the results of the QA Assessments and Nuclear Review Board Assessment.

I Concurrence When the CNO believes, based on the recommendations of the Senior Vice President -- Nuclear Operations and the Director --

QA/NSR that Salem Generating Station is ready for restart, he I documents PSE&G's decision to request restart of Salem Generating Station in a letter to the NRC Region I Administrator.

I Conclusion PSE&G has a thorough and comprehensive process by which the NBU affirms readiness to restart the Salem Generating Station to the CNO and requests NRC agreement to restart.

I I

I I

I 7 I

I APPENDIX SALEM RESTART PROCESS 2

I Restart Action System Readiness Plans Revie\NS I I I Issue 4 I Discovery Emergent 3

,___~,~.i Management Review NRC Restart 5

""' Committee Issue Issues I .... *******************

(MRC)

Approved

• ~--------_J__--------.~

Resolution I Corrective People &

6 Self 7

Equipment 8

Process Repair &

Action Assessments I Enhancements Upgrades

................................................ 1..... .

I Restart Readiness 9

Departmental _. Restart 10

._ NRC Readiness 11 Quality 13 14 Nuclear Review Affirmations Assessment Assurance Assessments & Operational I & Affirmations Assessments MRC Approved Team Inspection Closure Assessments Board Assessment I 12 15 Management Review Committee I Recommendations General Manager - Salem Operations Sr. Vice President- Nuclear Engineering Independent oversight Restart Recommendation Sr. Vice President - Nuclear Operations I Restart Recommendations

,r ************************ t I 16 17 I Concurrence Chief Nuclear Officer Concurrence for Restart

... Letter Requesting NRC Agreement to Restart I

I 8 I

I The Power of Commitment

'*~!(~ PS~G

- ~.:

~j~~

~ &

1 I SALEM GENERATING STATION I

I I

I I SYSTEM READINESS REVIEW I PROCESS I

I I

I I ~'M.'y\_~

Eugene Nagy for I Michael W. Rencheck Director - Salem System Engineering I May 28, 1997 I

I Key Issue How does PSE&G have reasonable assurance that equipment operability and reliability problems at Salem Generating Station

- have been identified in a disciplined, systematic, and ,

comprehensive manner, and that effective corrective actions have been taken to assure safe and dependable start-up and operation of the plant?

1 Executive Summary The System Readiness Review Program (SRRP) provides PSE&G with reasonable assurance that equipment operability and reliability issues have been identified at Salem Generating I Station and that effective corrective actions have been taken to address them. As explained below, the SRRP is a I comprehensive and systematic process, separate and distinct from the work control process. The SRRP ensures that plant systems are thoroughly evaluated, modified, maintained, and I tested to support restart. In addition, the SRRP establishes a disciplined approach to system assessment, ownership, and accountability which will promote the sustained safe and reliable I operation of plant systems.

Initiatives Several issues associated with system and equipment reliability I had been identified at Salem prior to shutdown, including ineffective system engineering processes, lack of system "ownership," and recurring equipment problems. In response to I these issues, PSE&G implemented the SRRP.

System Readiness Under the SRRP, System Managers are systematically I Review Program assessing 46 select critical systems and affirming the readiness of other supporting systems. (As of May 15, 1997, 41 select systems have been completely or partially affirmed at Salem as I a part of Phase IV.) The 46 critical systems were selected on the basis of a combination of attributes such as safe shutdown risk, risk significance, historical power production impacts, and high I historical corrective maintenance. A System Engineering Department Directive provides guidance to System Managers in I researching, assessing, and documenting the readiness of critical plant systems. An additional 66 supporting systems are being reviewed using a thorough, but slightly less rigorous, I process. (As of May 15, 1997, review of 57 of these additional supporting systems is complete at Salem as a part of Phase IV.)

The remaining system reviews are being tracked in the I corrective action process.

The system readiness reviews involve:

I

• identification of problems and corrective actions; I 2 I

I

• monitoring of corrective action implementation; verification of corrective action completion; and continued monitoring of system performance.

I To accomplish these steps, the SRRP team developed a single database -- the Systems Indexed Database (SIDs) -- which I includes the open items for each of the two groups of systems, as well as pending procedure changes, records, technical justifications, and internal process findings. The database has I served as an effective tool for the System Managers' implementation of the SRRP. After restart it will be adapted to assist in the work control processes at Salem on an ongoing I basis.

Phase I The SRRP consists of four phases. The first phase, the Initial I Initial System System Readiness Reviews (ISSR), was completed in October Readiness Reviews 1995. It enabled system team members to get an initial (ISSR) understanding of the post-shutdown system condition. The I ISSR was the first opportunity to review and prioritize open*

items, with the assistance of SIDs. It included the following actions:

I

• a general review of system design basis documentation (e.g.,

Updated Final Safety Analysis Report (UFSAR), Technical I Specifications, Configuration Baseline Documents (CBD),

NRC Commitment Documentation);

I

• evaluation of open action items to the Restart Screening Criteria (i.e., issues are "restart required" if they resolve (1)

I an operability issue; (2) licensing/design basis issue; or (3) component or system reliability issue that would result in a plant transient, power derate, or plant shutdown);

I

• performance of multi-disciplined and/or System Manager system walkdown; I

• determination of Restart Workscope, Power Ascension Workscope, and Post-Restart Workscope; and I

• presentation of System Readiness Reviews to the System Readiness Review Board (SRRB) and the Management I

Review Committee (MRC).

3 I

I Phase II Phase II of the SRRP consisted of Restart Activities Monitoring Restart Activities (RAM). It was completed in October 1996, and entailed team Monitoring (RAM) follow-up on identified restart activities, scoping new open actions, and performing root cause analyses. Specifically, as part of HAM, PSE&G:

• formed system teams for all 46 critical systems, which included representatives from various station departments;

• reviewed open corrective action items; I

• reviewed emergent action items for restart; I

• scheduled restart work within the appropriate System Work Window;

• I

• performed an intrusive examination of field work; I

• developed Startup System Test Plans;

• completed regularly scheduled walkdowns by the System I Manager;

• established system priorities and performance indicators; I

• updated the SIDs database; and I

• reviewed Phase II results (by the Outage Scope Management Team, the System Readiness Review Board, I and the Management Review Committee).

As part of the Phase II reviews, a team performed a general I review of design basis documents to ensure their conformance with design basis requirements found in the UFSAR, Technical Specifications, and NRC Safety Evaluation Reports (SERs).

I (This aspect of the Phase II SRRP is discussed in the "Design/Licensing Bases" Restart Briefing Paper.)

I Phase Ill Phase 111 of the SRRP is complete for the 46 select systems and Final System essentially complete as of May 15, 1997 ( i.e., 63 of 66 systems)

Readiness Review for support systems. During this phase, PSE&G performed I system walkdowns and assessed the impact of post-restart open actions. A Final System Readiness Review Report was produced detailing results and identifying the remaining open I

items that must be completed prior to system affirmation. As of 4

I

I May 15, 1997, approximately 877 items remained out of approximately 35,000.

- The specific actions undertaken as part of Phase Ill include the following:

• completion of System Readiness Walkdowns by the System I Manager and a representative of the Operations department;

• presentation of the Final System Readiness Review Report, I prior to restart, to the System Readiness Review Board and the Management Review Committee; I

• review of work not completed prior to restart, including an assessment of impact on the individual components involved I and the aggregate impact of deferred work on the system involved; I

• final review of System Startup Test Plans; and

• presentation of the "Macro Review of appropriate sections I of the Updated Final Safety Analysis Report.

- Phase IV Upon final system affirmation, the SRRP hands the systems, I Startup and Power whose work windows are complete, back to Operations for the Ascension initiation of startup and power ascension testing. (The Startup and Power Ascension Testing Program is the subject of a I separate Restart Briefing Paper.) Final system affirmation includes the review of Technical Specification action logs with ii Operations, elimination of as many temporary modifications on a system as possible and identification of the remainder, completion of system walkdowns including a comprehensive I system team walkdown, and elimination of most workarounds.

As part of Phase IV, PSE&G is:

I I

• reviewing designated test results identified by the Test Review Board; I

I I

• completing regularly scheduled system walkdowns;

I

• completing the final review of System Startup Test Plans;

• completing System Readiness Affirmations; and I 5 I

I

• conducting oversight of Phase IV results by the SRRB and the MRC.

In addition, as part of Phase IV activities, System Managers are developing performance monitoring baselines for system performance tracking and trending. They also are monitoring any new corrective maintenance activities or Condition Reports, I and are continuously monitoring system readiness.

Results and Phases I through IV of the SRRP are substantially complete, I Performance with the result that restart workscope was identified and that the restart impact of open work items has been determined. Upon Indicators completion of Phase IV of the SRRP, the final system I affirmations will be made and all systems will be returned to Operations for startup and power ascension testing, and I ultimately full power operation.

Major There have been numerous major modifications made to Salem I Modifications systems resulting from the SRRP. A small sample includes the following:

I

• Advanced Digital Feedwater Control -- simplified feedwater control for Operations; I

• Turbine Rotor Replacement -- improve performance and efficiency; I

• Station Air -- modifications to station air compressor control system which results in enhanced performance and reliability; I

• Circulating Water Upgrades -- modifications on screens and I controls resulting in reliability and operation improvements;

• Control Area Ventilation -- modification to supply both control

,I rooms and meet design bases requirements;

• Service Water Pump Replacement -- improved net positive I suction head (NPSH) and overall pump performance characteristics; I

• Service Water Piping Replacement -- upgrade service water piping to new corrosion resistant piping; I 6 I

I

• Service Water Strainer Modifications -- eliminated back-wash waterhammer conditions and improved strainer performance;

• Emergency Diesel Generator Modifications -- eliminated vibration concerns, improved performance of the air start and lube oil systems; and

• Reactor Protection System -- complete refurbishment and/or replacement of all control modules.

I Restart Item The chart below entitled, "Salem 2 & Common Restart Work Closure Completion Progress," depicts the closure of open restart items at Salem between December 1996 and May 5, 1997.

I System Readiness Review Status I 35000 Salem 2 & Common Restart Work Completion Progress IJ)

E 30000 I ~

t:

ra (ii Ql 25000 20000 0::

I 0 Ql

..c z

E

J 15000 10000 5000 i I * ..... .. " ... ..., - -"'

I 1996/1997 0

§"' "'~ § I

0 I

~

II!

g 0

~ ~

0

~

"'('l iii iii ~ !!?"' ;;i ...;;i ~ ~

0 ..,

n

~

I

;

.., ~ ill ~

o

~

o 111111111!1!1 Open Restart Items lllllll!llil!IClosed Restart Items -+-Revised Sched. Workoff I

I This performance indicator represents the magnitude of the I restart effort (approximately 35,000 restart-required items) and our progress to date. The effort is nearing completion and all systems have been returned to Operations for mode transition I through Mode 5.

Conclusion The SRRP provides PSE&G with reasonable assurance that I equipment operability and reliability problems at Salem Generating Station have been identified in a disciplined, systematic, and comprehensive manner, and that effective I corrective actions have been taken to assure safe and dependable start-up and operation of the plant.

I I 7 I

I The Power of Commitment

~&:~?>

/,~.:::'

r.::i-.

w.--:**

~* *.~~""'

• ~

• .fj~

• . PS~G &

~'~~r-*

I I SALEM GENERATING STATION I

I I

I STARTUP AND POWER ASCENSION TESTING I

PROGRAM I

I I

I I ~N::;o)t6if Michael W. Rencheck Director - Salem System Engineering May 28, 1997 I

I

I Key Issue How does PSE&G have reasonable assurance that plant equipment at Salem Generating Station will perform its intended function in a safe and reliable manner following the extended shutdown?

Executive The Startup and Power Ascension Program is an important Summary element of the Salem System Readiness Review. It involves an integrated and systematic testing approach to establish the readiness of equipment in areas where corrective maintenance and modifications have been made during the shutdown. The test program is based on the best attributes of other successful startup and restart programs used in the nuclear industry. It has been developed and implemented by an experienced and multi-disciplined team.

I Startup System Test Plans are developed through a careful, deliberative process to assure the overall adequacy of testing.

I Special Test Procedures are prepared and implemented as required by the test plans. The Test Review Board reviews the adequacy of Startup System Test Plans and Special Test I Procedures. This process ensures a comprehensive test program which will be safely conducted.

Initiatives One key element of establishing the readiness of plant equipment is the Startup and Power Ascension Test Program.

This testing is being conducted as part of the overall System I Readiness Review Program (which is the subject of a separate Restart Briefing Paper).

I A team was organized to develop the Startup and Power Ascension Program. The team includes members with multi-I disciplined backgrounds and experience ranging from 15 to 25 years. Team members' experience includes initial plant startups (e.g., Calaway, Braidwood, Byron, Palo Verde, South Texas I Project, Watts Bar, Hope Creek, Wolf Creek, Comanche Peak) as well as plant restarts following extended shutdown periods (e.g., Turkey Point, Browns Ferry).

I The startup and power ascension testing, to be completed as part of restart, consists of four phases:

I

• Phase I Component Level Testing

• Phase II System Level Testing I

• Phase Phase Ill IV --

Integrated Functional Testing Power Ascension Testing I 2 I

I Tests are presently scheduled in the following stages:

• Pre-Core Load Tests

• Pre-Mode 4 Tests

• Mode 4 through Mode 3 Tests

• Zero Power (Mode 2) Tests

• Power Ascension (Mode 1) Tests There are 46 "Select Systems" identified in the System Readiness Review Program, which required a formal system readiness review. These systems are the basis for the test program. The Startup and Power Ascension Test Program includes additional testing to the extent necessary to validate changes to the design basis for these systems (e.g., plant structures, systems, and components which have been I modified). This testing supplements post-modification testing as a means to establish the readiness of the plant to resume operation. (The select systems and remaining non-selected I support systems and components remain subject to the surveillance testing program, in-service tests, and preventive maintenance to establish and ensure reliability and operability I on an ongoing basis.) The philosophy of the test program is to demonstrate that the Salem work control, design change, special testing, and procedural development processes have functioned properly to support and validate individual design changes.

I The startup test team developed a comprehensive procedure for the program and a test matrix similar to one successfully used at Comanche Peak. The matrix, set up in a Startup System Test I Plan (SSTP), specifies the tests to be performed during mode and power ascension. An SSTP is developed for each of the

• 1 select systems. Additionally, SSTPs were developed for Integrated Functional Testing (Phase Ill) and Power Ascension Testing (Phase IV). The SSTPs are reviewed by the Test I Review Board (TRB), Station Operations Review Committee (SORC), and approved by the General Manager - Salem Operations (General Manager).

I Based on the SSTPs, Special Test Procedures are developed.

The development, planning, and implementation of these I Special Test Procedures are governed by a careful and controlled process to assure that testing is appropriate in scope and safely conducted. The overall process is illustrated in a flow I chart, Appendix A. As required, the Special Test Procedures are subject to a documented safety evaluation pursuant to 10 CFR 50.59. (Initially this involves a 10 CFR 50.59 I 3 I

I applicability review; which may determine the need for a safety evaluation.)

- Once the Special Test Procedure is developed, there is thorough pre-test planning. A test team designated for each test identifies the test equipment and performs test walkdowns and/or rehearsals. There are contingency plans and pre-test 1 shift briefings. Industry operating experience related to the conduct of testing is reviewed and incorporated into the test procedures.

I In addition, there is a Startup and Power Ascension Sequencing Procedure. The safety evaluation for this procedure assesses I the aggregate impact of all planned startup and power ascension testing. Hold points in this sequencing procedure are planned to allow systematic review and assessment of plant and I personnel performance, and to assure that both the plant equipment and the organization are ready to proceed with the I startup plan. These criteria incorporate important attributes and parameters, including plant material condition, completion of necessary corrective actions, personnel performance, and I responsiveness of the support activities. The program procedure also calls for Post-Test Reports to be generated and reviewed by the TRB to validate that the test results are acceptable and that any lessons learned are incorporated into future startups.

I Results and Performance The Startup and Power Ascension Test Program achieves the following results. This test program will be completed as part of the restart process.

Indicators I

• The Startup and Power Ascension Program procedure was developed, approved by the Management Review I Committee, and is being implemented. This is the procedure that governs the development, planning, and implementation of the test program.

I

• Management established and filled the position of the I Startup Testing Manager.

• All SSTPs for Unit 2 were issued and reviewed by TRB and I SORC, and approved by the General Manager.

• A startup and power ascension test schedule was developed .

I

• Startup and power ascension test procedures were developed.

4 I

I

• Steps have been taken to increase the System Managers' awareness of and involvement in the special tests on their systems. In some cases, the System Managers are the Test Engineer for the startup and power ascension tests on their systems. The fact that the SSTPs have been developed by the System Managers and processed through TRB and SORG also indicates ownership by the System Manager in the testing process.

• System team meetings have been held to solve problems.

I These have resulted in the development of additional procedures which will be utilized during startup and power I ascension (e.g., Secondary Plant Performance Monitoring Procedure, and Moisture Separator Reheater Logic Test).

Also, several design changes were initiated to correct long-I standing problems.

• Startup testing has commenced.

I Performance indicators are used to track the remaining activities. As shown below, the scope of total work and retest I remaining activities remaining is tracking downward:

SALEM 2 - TOTAL WORK & RETEST ACTIVITIES REMAINING (SCHEDULED) 1800 1600 I 1400 1200 ,_

10001 I 800 600 400 I 200 I -Added (wkly) =completed (wkly) -rarget --Actual Remaini'lg * *

• Current Schedule Conclusion The Startup and Power Ascension Test Program is an important I element of the Salem System Readiness Reviews. The test program and procedures are carefully developed and implemented to assure that the tests are thorough and safely I conducted. When the test program is completed, including implementation of any necessary corrective actions, there will be reasonable assurance that plant equipment will perform its I intended function in a safe and reliable manner.

I 5 I

APPENDIX A SPECIAL TEST PREPARATION AND PLANNING FLOW CHART DEVELOPMENT PHASE System Manager TRB SORC Develop Test Manager Develop System Review of Review of Startup Form Test Test Plan Test Plan Test Plan Schedule Team I I Follow Normal Testing ~. N0 N0

. Processr * ._,1_ _ _ _ _ _ _ __ 1 I

PLANNING PHASE Develop Operations Establish Pre Plan TRB Review of Identify Test ._---'_ Contingency and Test - - - Criteria For Test Implementation Equipment Plan Team Training Acceptance Briefing Strategy IMPLEMENTATION PHASE Prepare TRB Perform Shift Perform Test Results Post-Test Review END Briefing Test Report Test NO NO Initiate AR/CR and Initiate AR/CR and Retest Accordingly

! - - - - - - - - - - - - - - - - Retest Accordingly 6

I The Power of Commitment 1

I SALEM GENERATING STATION

,I I

I CULTURE CHANGE I Management Initiatives Human Performance 19 Corrective Action Program I Self-Assessment Employee Concerns Program I

I I

I I

Q,MP:~J I.

11 I

David F. GarchW General Manager - Salem Operations May 28, 1997 I

I Key Issue How does PSE&G have reasonable assurance that Nuclear Business Unit (NBU) personnel have internalized a questioning

- attitude, are free to raise concerns, and hold themselves accountable for prompt identification and resolution of problems so that Salem Generating Station will be operated in a safe and reliable manner?

1 Executive Summary Cultural change has occurred at Salem and within the NBU as a result of various management initiatives, as well as programmatic improvements in the following areas: (1) human I performance; (2) the Corrective Action Program (CAP); (3) self-assessment; and (4) the Employee Concerns Program.

I In terms of management initiatives, managers at the station have defined expectations, clearly communicated them to Salem personnel, and increased personnel accountability.

I These management actions have been the driving force behind human performance improvements at the station. Managers I are measuring personnel performance against human performance indicators to ensure that this aspect of cultural change does not backslide. Likewise, through various I feedback opportunities (e.g., the CAP and employee surveys),

employees have been given an opportunity to assist in the recovery effort. In addition, programmatic improvements in the areas of corrective action, self-assessment, and employee concerns have contributed to the cultural transformation at Salem.

I The effectiveness of these cultural improvements is evident in the significant rise in the initiation of Condition Reports (CRs)

I regarding equipment and programmatic issues at the station, indicating a heightened self-identification of problems.

Employee survey results and other documents have confirmed I that station personnel are knowledgeable about the Employee Concerns Program and believe it to be credible. Thus, PSE&G has reasonable assurance that NBU personnel have I internalized a questioning attitude, are free to raise concerns, and hold themselves accountable for prompt identification and I resolution of problems so that the Salem units are operated in a safe and reliable manner.

I Initiatives New Management The first step to effecting lasting cultural improvement at Salem Team was the formation and introduction of a new management team manned by proven industry performers. This team promptly established a vision/mission statement that places safety on an I 2 I

I equal footing with reliable and efficient plant operation.

Underpinning the vision/mission statements, the management team identified eight core values, or behaviors, that all NBU employees needed to internalize to assure accomplishment of the overarching goals: (1) Safety; (2) People; (3) Reliability; (4) Financial Discipline; (5) Environment; (6) Culture; (7) 1 Community; and (8) Integrity.

One of these key core values is "Culture." From a "cultural" I perspective, safe and reliable plant operation at Salem is assured through initiatives in three principal areas: human performance, corrective actions, and self- assessment.

I I

Yon are the difference! thenewNBU I 1'Jdl5"?"5Cw I

I ASSESSMENT SELF I

I These three principal areas form the foundation for change I within the PSE&G workforce. Management expectations and personnel accountability have been established. Personnel understand the expectations and their roles and responsibilities I in the process of change. Employees are participating in the change and management is receptive to their input and striving I each day to further improve its responsiveness. The following sections describe how PSE&G has improved in each of these key areas .

I 3 I

I Human Managers have defined expectations, clearly communicated Performance them to Salem personnel, are holding personnel accountable to meet established standards, and are measuring personnel performance against human performance indicators (e.g.,

human errors) to ensure that this aspect of cultural change is enhanced and sustained. As a result, cultural improvements in human performance at Salem are mainly driven by people, and tracked through various programs. Specifically, the new management team developed and communicated the expectation to employees that significant improvement was necessary in four key areas:

• effective leadership; I

• productive teamwork; I ** corrective action; and I

• effective training.

Collectively, these four areas constitute the key management I expectations that define a healthy culture, and serve as the standard for accountability among all personnel. The fundamental expectation communicated by Senior Management is that all personnel -- management, supervision, and craft --

must do their jobs right the first time, every time.

I These messages have been repeatedly communicated to Salem personnel in various contexts. For example, they are set forth in the NBU Business Plan, Nuclear Today, and in I weekly Key Messages. Furthermore, they have been personally communicated by management in Senior Reactor Operator Meetings, Supervisor Meetings, Employee Survey I Feedback Meetings, and All-Hands Meetings. In summary, management's expectations have been communicated in a I repetitious manner and along parallel paths through all organizations at Salem and the NBU as a whole.

I In addition to communication efforts, several initiatives have been completed which better enable personnel to meet senior management expectations in the human performance arena.

I Key among these initiatives are Management Action Response Checklist (MARC) Training, Dale Carnegie instruction, and Breakthrough Leadership training. The MARC Management I Protocol Group maintains consistency as a follow-up to training.

I 4 I

I

• MARC Training -- Provides methods by which supervisors can effectively establish a clear understanding of performance expectations and develop a structure by which to achieve goals. The emphasis is on fair, open, honest, consistent and considerate treatment of employees.

Essentially all supervisors have taken this course.

1

• Dale Carnegie -- This training consists of a series of personal development workshops in which attendees learn and practice skills which better enable them to: adapt to I change, reduce stress, improve communications, set goals, solve problems, and improve teamwork. Classes contain a mix of management, support staff, and union personnel.

I

• Breakthrough Leadership -- This training teaches people how to make change in an organization at an accelerated I rate through personal commitment, teamwork, and accountability. Focused on the NBU Vision, Mission, and Core Values, it trains personnel in the skills that, when

• I carried back to their work groups, will support the NBU Mission. Approximately 400 people completed this 5-day I course.

Having communicated the message to Salem personnel and trained them to meet expectations, PSE&G management continuously monitors and holds personnel accountable for the effectiveness of human performance improvement efforts at I Salem. On an individual level, a performance-based Ranking and Rating System ensures that employees understand expectations, and compares individual performance with I defined performance dimensions. Regular feedback is provided through periodic performance reviews. On a plant-wide basis, the NBU has developed performance indicators I (e.g., that measure human error rates, procedure adherence, unavailability, and maintenance re-work), performed self-assessments, reviewed Quality Assessment (QA) audit results, I and undergone independent assessments by industry experts.

For example, the NBU conducted a Culture Survey utilizing I techniques developed by Failure Prevention International. The survey was designed to measure several key human I performance areas, including organizational mission and goals, level of knowledge and skills, teamwork, simple work processes and procedures, and self-improving culture and programs. By measuring these five factors, the survey helped PSE&G determine how well the NBU is living up to Senior Management's vision, mission, and values.

I 5 I

I The first survey results were obtained in September 1995. In general, the September Culture Survey indicated that the area of "knowledge and skills" is a strength at Salem, while "work processes and procedures" and "self-improving culture" remained as areas in need of continued focus. Three additional surveys ha\/e been completed; one in March 1996, another in November 1996, and a third in April 1997. Although I the final survey's results are currently under management review, the overall survey results show continuing progress, as depicted in the chart below entitled, "Culture Survey Index I Trend for the NBU." Restart will provide an important opportunity to observe personnel on a real-time basis and, thus, to validate this progress.

I I

I I

19 Corrective Action In 1995, PSE&G initiated a comprehensive evaluation of the Program corrective action process. Among the issues addressed were I root cause analyses, an understanding of Conditions Adverse to Quality, effective corrective measures, and trending capability. A key factor contributing to these issues was that I various mechanisms were being used to identify and resolve issues, and these mechanisms were not well coordinated. As a result of the evaluation, PSE&G improved the Corrective Action I Program as described below.

Like the human performance area discussed above, Corrective I Action Program initiatives begin with management expectations. At Salem, Senior Management has communicated the expectation that problems be identified by I personnel, regardless of significance level. To achieve this expectation, PSE&G has developed a simplified, comprehensive procedure that centralizes the reporting, I analysis, and resolution of identified problems. As part of this initiative, PSE&G has:

I

• developed a centralized Corrective Action Group; 6

I

I

• identified a single point of electronic or manual entry for corrective action issues;

• established a lower threshold for entry of issues into the Corrective Action Program, including the establishment of significance levels for identified problems (i.e., Levels 1 through 3);

• provided a vehicle to enter enhancements into the system;

• improved trending capability (e.g., development of quarterly Collective Analysis Trending Analysis Reports);

I

• required documented effectiveness reviews for all significant issues; I

• created a process interface for operating experience feedback; I

• required management approval for extension of corrective action due dates; and I

• developed a comprehensive set of performance indicators as a management tool.

Taken together, these initiatives are designed to ensure the effective identification, ownership, evaluation, and correction of I issues from identification to verification. In addition, they are designed to ensure that identification and resolution of such issues are not only timely, but also effective.

I PSE&G recognizes that an effective Corrective Action Program involves all employees and does not rest solely with the QA I organization. Thus, substantial emphasis has been placed on involving line management and employees in the corrective action process. Key activities performed by line organizations I include the:

I

• establishment of departmental corrective action coordinators (by function, not title);

I

• review of all Salem Level 1 and 2 issues by a composite line management team to establish direction and assure prompt action assignment; I

• formation of a Corrective Action Review Board (GARB),

made up of key line managers and supervisors, to review 7

I

I and approve the root cause analyses and appropriateness of corrective actions for all Level 1 and selected Level 2 issues;

• effectiveness reviews (CRVRs) are required for all Level 1 CRs;

• establishment of Corrective Action Review Committee (CARC) for Level 2 CRs;

• assignment of and training for individuals within each department to act as Root Cause Specialists in their areas of expertise (e.g., over 90 personnel have been trained in root cause fundamentals, human error reduction techniques, and organizational/programmatic error analysis).

I Several additional areas have been enhanced at Salem to improve the quality of the Corrective Action Program.

I

• Appropriate training has been provided in the following I areas: the revised Corrective Action Program procedure; root cause analysis and investigation techniques; trending concepts; and computerized entry of identified issues into the corrective action system .

.* Communications have been improved through a variety of I efforts, including the preparation of a root cause manual, use of the Operating Experience Feedback newsletter, and development of "quick reference" pamphlets for the I Corrective Action Program and trend codes.

• Oversight of corrective action processes to ensure their I effectiveness has been improved through the establishment of formal review organizations, including the CARS and the CARC.

I

• PSE&G has developed enhanced corrective action I performance indicators and made them more readily accessible to employees.

I Looking ahead to the post-restart period of operation, PSE&G has planned additional enhancements to the Corrective Action Program, including:

I

• making the Corrective Action Program computer interface more "user friendly";

I 8 I

I

• further streamlining Corrective Action Program procedures and policies;

• developing a more refined trending capability in the area of human performance; and I

• continuing to consolidate programs and procedures to assure a fully integrated Corrective Action Program.

I Self-Assessment One of the areas in need of improvement at Salem Generating Station was self-assessment. In the past, Salem did not adopt self-assessment as part of its everyday business practice and I culture. When self-assessments were performed, they were not consistently effective in identifying problems, processes, or programs in need of improvement.

I In order to improve the station's self-assessment culture, PSE&G has undertaken a number of initiatives. First, it I implemented a Self Assessment Program at Salem. Second, for purposes of restart, PSE&G has conducted departmental I self-assessments. Finally, procedures governing assessments to be performed prior to restart following refueling outages have been developed and implemented by the NBU. Each of

• I these initiatives is summarized below.

The Self Assessment Program The NBU has developed and implemented procedures for the Self Assessment Program. A dedicated position of Station Self I Assessment Coordinator was established and filled with an external hire who is an expert in nuclear self-assessment.

11 I

Modeled after industry best practices, the Self Assessment Program has four primary elements: Planned Assessments; Peer Observations; Management Observations; and Individual Assessments.

I

• Planned Assessments are performance-based assessments concentrating on evaluation of the most I important aspects of personnel performance, plant and equipment conditions and performance, and the I performance of procedures and programs. Station departments are required to perform four planned assessments per year. The focus of these assessments ranges from a complete functional-area assessment to support an affirmation of restart readiness, to the effectiveness/results of a process specific to the Department I 9 I

I (e.g., work control [work order handling], tagging [protection of plant personnel and equipment], system cleanliness,

!e I

• foreign material exclusion [FME]) and the resultant effect on safety, reliability, and economic performance.

Peer Observations are scheduled by departments and are conducted by technically qualified personnel to evaluate I processes or activities.

• Management Observations are being conducted by I station managers and superintendents in focus areas that are reviewed and changed, based on existing conditions and plant events. These Management Observations I specifically include off-hours tours of the station.

• Individual Assessments entail individual utilization of the I principles of "Stop, Think, Act, Review" (STAR) and "BASIC Keys of Success" in assessing their own activities and reporting enhancements to processes. The principles I remind individuals to stop and think before acting and to report, as well as to maintain attention to detail, self-check, I exercise an inquiring attitude, and be conservative in operations.

Departmental Self-Assessments The initial planned departmental self-assessments conducted I under the new program were completed in December 1995.

The purpose of these initial assessments was three-fold: (1) to determine departmental restart readiness; (2) to identify the I actions necessary to ensure restart readiness if it was determined that a given department would not to be ready; and (3) to gauge the self-assessment abilities of departments at I Salem. The results of these assessments were presented to the Management Review Committee (MRC).

I Since the inception of the new Self Assessment Program, station departments have each completed at least four other planned assessments. Each time, the quality of the I departmental self-assessment has improved. Lessons learned have been incorporated into the station's self-assessment procedure. Other improvements to assist departments in future I self-assessments include: development and installation of a computerized assessment diagnostic, based on industry-wide I standards and evaluation criteria; and implementation of an improved observation training program, which includes self-assessment.

I 10 I

I Salem Integrated Readiness Assessment (SIRA)

I*~ An integrated self-assessment was conducted by a team of industry experts led by a Salem Manager. This assessment I reviewed Management Programs and Independent Oversight, Operations, Maintenance and Surveillance, and Engineering and Technical Support. The results of this assessment led to I revisions in Restart Action Plans and other corrective and improvement actions.

I Restart Readiness Self-Assessments As previously mentioned, self-assessments were conducted by I each department to identify existing conditions and the readiness for restart and continued safe and reliable operation of the plant. Another series of functional area assessments I were conducted by station departments to support an affirmation of readiness to restart during November and December 1996, with affirmation conducted in December 1996, I and January 1997. Final readiness affirmations are being scheduled for June 1997, and departments will conduct assessments as necessary to support those affirmations.

I End-of-Outage Self-Assessments PSE&G has developed and implemented procedures governing self-assessments that are performed prior to completion of an I outage. These procedures will be invoked for future outages to require affirmations by cognizant managers of restart readiness. This process was followed in the recent restart I readiness assessments and affirmations, which are now part of the culture at Salem.

I Employee Concerns Program In February 1995, PSE&G implemented a formal Employee Concerns Program (ECP) to further facilitate and ensure the timely identification of issues and concerns by station I personnel, and the corresponding resolution of any and all such concerns. This initiative also serves to improve the culture at Salem Generating Station. The ECP is staffed by I three full-time employees whose collective experience encompasses Engineering, Chemistry, Licensing, and Operations. PSE&G incorporated benchmarks and lessons I learned at other utilities in developing the ECP at Salem .

The existence and nature of the ECP has been aggressively communicated throughout the site. It has been incorporated into General Employee Training for all personnel granted I 11 I

I access to the site and it has been integrated into the exit process for all people leaving the NBU, including contractors.

The ECP department developed training titled "Managing for Nuclear Safety," which is mandatory for all supervisors and managers. The training focus is on two-way communications, development of a welcoming environment, intenU behavior/

impact of supervisors actions, and addressing potential allegations. To date, over 500 employees and contractors have received the training.

Since its inception, the ECP has initiated numerous formal investigations of concerns. These investigations have been conducted in accordance with an investigation protocol that I provides a structured approach to the conduct, documentation, and closure of formal investigations. The results of a number of these investigations have been communicated across the I site through issue resolution letters, not only to inform NBU personnel about the substantive resolution of the underlying concern but also to further emphasize management's openness I to the identification of employee concerns through both the Corrective Action Program and the ECP.

I A self-assessment of the ECP conducted in the fall of 1996 compared process performance with procedure requirements

• I and performance expectations. The assessment concluded that the program has been effectively implemented and that conclusions reached regarding concerns are supported by a substantial review backed with appropriate documentation.

Results and I Performance Indicators I The Right Team Is In Place at Salem As part of the human performance improvement initiatives and monitoring activities, there have been several management For Restart and "interventions" at Salem and approximately 225 employees who I Plant Operation could not or chose not to meet management expectations have left the NBU. The management "interventions" have occurred I in the areas of training, personnel performance, operations, and maintenance. The Operations and Maintenance interventions are discussed in separate Restart Briefing I Papers. "Interventions" in other areas have taken place on a case-by-case basis, for example, when supervisors have halted performance of a task to re-instruct the employee(s). As a result of these efforts, PSE&G has in place the team of personnel who can and will safely restart and operate the Salem plant.

12 I

I Human Culture survey results indicate that the NBU has made positive Performance improvements. People are noticing positive accomplishments, and several volunteers articulated their observations in the I "Rally for Restart" video.

Significant Rise in As a result of lowering the threshold for the identification and I the Initiation of Condition Reports entry of issues into the Corrective Action Program, there has been a significant increase in the number of CRs initiated at (CRs) Salem since June 1995. Following this increase, the number of I CRs initiated has leveled off. Over time, we expect this level to further decline after restart and the plant achieves reliable operation. This trend is depicted in the graph that follows, II entitled, "Salem Condition Reports Written."

I 1400 Salem Condition Reports Written

-==========

1200 I 1000 800 I

lt'l (l) a>

O?c: C: O?c:

I In summary, conditions which may have previously been tolerated are now documented and addressed. This trend I demonstrates that cultural and process improvements have enabled Salem personnel to more effectively identify issues to line management.

I Corrective Action The improved corrective action process has fostered ownership I Program Results of the problems identified within the NBU. Despite the high volume of issues identified (as shown above), the quality of I evaluations and cause determinations has improved, according to CARB reviews. Moreover, as explained above, PSE&G has developed a comprehensive set of performance indicators to I effectively manage corrective actions at Salem. These indicators demonstrate not only the effectiveness of and improvements in corrective action processes, but also the readiness of the Corrective Action Program to support plant restart and operation. Attachment 1 provides an overview of overall process effectiveness.

13 I

I In addition, the graph and chart that follow further demonstrate improvements in Salem's corrective action processes.

Specifically, the data show a steady percentage of self-identified problems. The significant level of identified items is indicative that the organization has become more self-critical.

SALEM UNIT 2 SELF-IDENTIFIED CRs I 1000 100%

800 80%

I Ci:"'

u Q

Cl) 600 60%

=:2 u

~

.....0 400 40% .....0 I "" 200 0

20%

0%

rfl.

Oct-96 Nov-96 Dec-96 Jan-97 Feb-97 Mar-97 Apr-97 I 111111111111111# of Self-Identified --+-% ofTotal CRs I Problem Self Identification I

I I

I I

I 14 l1

I Improvements in PSE&G closely monitors industry and NRC data concerning the Identification allegations. The NRC's most recent data indicates that, for and Evaluation of Salem, the total number of allegations received by the NRC is Employee higher than the average for other multi-unit utilities. Several Concerns factors have contributed over time to this situation: (1) management changes in the NBU; (2) high expectations and accountability established by management; and (3) reorganization of departments and reductions in staffing.

I PSE&G acknowledges that the allegations numbers are higher than desired and indicate a need for continued management attention to the employee concerns area. However, PSE&G I believes that there are a number of positive indicators that recommend continuing the course of actions currently in place and being implemented as the appropriate response. They are I discussed below.

One such indicator is the Employee Concerns Program I Performance Index. As depicted in the following graph, this indicator demonstrates program performance and reflects NBU personnel confidence in the program's ability to adequately review issues. It combines figures measuring the timely closure of concerns and employee confidence in the ECP. As reflected below, the ECP is meeting its objective of resolving I issues in a timely manner while simultaneously maintaining NBU personnel belief that issues are being adequately I reviewed.

I EMPLOYEE CONCERNS PROGRAM PERFORMANCE INDEX I

I I JAN FEB MAR APR Timely resolution of concerns is a key program objective. As reflected in the chart below entitled, "Average Days to Concern 15 I

I Closure," the program is currently meeting its goal of resolving routine concerns in less than 30 days. Concerns that require more than routine participation, i.e., those involving formal investigations, may exceed this time frame; however, the assigned investigator maintains frequent communication with the concerned individual to keep him appraised of the investigation progress.

I r*~~~~~~~~l:~

I - ~---_-------

I I

---

~!I Another indicator reflects the results from the Employee Concerns Program Benchmark Survey conducted in March 1997. This survey indicated a slight decline over last year's results. Nevertheless, the tenor of the survey may best be summed up by the response to the following question -- "If you I had a nuclear safety concern, would you raise it with your supervisor?" In short, 95% of the 863 respondents answered "yes."

I I Ensuring Continued Having effected the above-described cultural improvements at Salem, PSE&G recognizes the importance of ensuring that improvements in the areas of leadership, teamwork, corrective Effectiveness of I Cultural action, and self-assessment continue into the future. The key behavioral modification resulting from "cultural" initiatives at the Improvements station (i.e., accountability) must be maintained on a long-term I basis. The following actions will yield long-term results:

• recognizing that performance expectations are dynamic in I nature and must be continually refined by management to reflect current circumstances and incorporate feedback from NBU personnel;

• continuing to communicate performance expectations on an ongoing basis through one-on-one communications from 16 I

I management to plant personnel, meetings at various organizational levels (e.g., supervisors meetings), and training sessions for both management and line personnel (e.g., Breakthrough Leadership and Dale Carnegie) on both an initial and periodic "refresher" basis;

• continuing to refine performance indicators applicable to people, plant, and processes which accurately define and, to the extent possible, quantify performance expectations within the NBU and at Salem on a long-term basis; I

• providing Human Error Reduction Training to Salem personnel; I

• assessing whether personnel behavior at the station meets I performance expectations, on a continuing basis, as defined by performance indicators, through both self-assessments, QA audits, and/or third-party assessments (e.g., the NBU is planning to continue conducting Culture Surveys to confirm improvement on a longer-term basis and then to follow with periodic QA samples and an annual survey);

• providing additional cultural training, as necessary, to ensure that performance meets expectations (e.g., MARC and Dale Carnegie) as well as continued emphasis on the cultural aspects of technical, accredited training programs; I

• extending Managing For Nuclear Safety Training to first-line personnel and contractors; and I

• implementing corrective actions to address deviations in performance from established expectations (e.g.,

I Performance Rating and Ranking, Performance Reviews) and to hold station personnel accountable for continued cultural improvement on a long-term basis.

I In order to "maintain the course" and ensure that cultural improvements become permanent at Salem, the NBU will I continue to implement the above-described actions for both new and existing personnel at the station. Cultural expectations and realities will be ingrained in new employees I from their first day in the NBU. Thereafter, existing personnel will receive ongoing attention through "refresher" actions (e.g.,

perhaps refresher MARC training in 1997) to ensure that the Salem culture becomes part of everyday business. Eventually, NBU management believes that evidence of sustained cultural improvement will be found in performance benchmarks 17 I

I demonstrating reductions in unavailability and human error rates.

An important link to sustained, future cultural improvement has been built at Salem through the succession planning process.

The Organization and Staffing Review (OSR) identifies succession candidates for critical positions and potential employees for accelerated development. The OSR plan will ensure that a talent pool is developed which has the competencies to execute NBU business strategies. The plan I will also align individual skills of high-performing employees with NBU needs.

I NBU management knows, through experience, that the desired culture must be consistently nurtured to meet the demands of a dynamic environment. With this in mind, management will I continue to assess the effectiveness of the actions described above to ensure their continued effectiveness over time and I modify them, as necessary.

Conclusion PSE&G has implemented effective actions which have I improved the culture within the NBU and at the Salem Generating Station to accommodate high standards in the areas of Human Performance, Self Assessment, and Corrective Action. It has supported these cultural improvements with added programmatic improvements, primarily through the development and implementation of the Corrective Action I Program, Self-Assessment Program, and ECP. The initiatives described above, in combination with the results achieved at Salem to date, provide reasonable assurance that NBU I personnel have a questioning attitude, are free to raise concerns, and hold themselves accountable for prompt identification and resolution of problems. The process for I* creating accountability has been established. As a result, PSE&G concludes that the Salem plants will be restarted and operated in a safe and reliable manner.

I I

I I 18 I

I I ATTACHMENT I I Salem Unit No. 2 I' Corrective Action Process Status I

I I

I I

I I

I I 19 I

- -.- - - - - - - - - - - - - -,,. - SALEM ENGINEERING UNIT NO. 2 JAN I FEB IMAR CORRECTIVE ACTION PROCESS APRIL APRIL 291 339 241 IDue I Overdue I 2,1551 140 I 2,329/

184 I 2,357/

286 Open CR Activities NewCRs 273 2,244/228 (Information Only)

Timelln~ss:

Schedule Adherence:

221 I 228 I 240 Corrective Actions Scheduled (%

.... R Average Age of Open CRs (Days) 259 Scheduled in Next 6 Months) 48% R Average Time To Accept y

I y I y Completion of Scheduled Corrective y

C\. ~ .

Evaluations (Days) © y Actions for Month (% Complete) ~

Quality:

I Level 1 f Level 2 I y

• Average Time To Complete Quality of Evaluations Evaluations (Days) (Level 1=% Approved; Level 2=Score)

I I

• I y y y y *y y Average Time to Complete Corrective Actions (Days) © y Overall y GREEN= EXCELLENCE YELLOW = MEETS STANDA RD RED = NEEDS IMPROVEMENT NOTE: The actual data point appears In the lower left corner of the box for the current month.

Responsible Manager: J. Carey ext. 1035 Report Date: 05/0&'97 S:INUCQAI' *'i-Pl'CA-PROC.XLS

- - - - - - - - - - - - - -~ -

JAN I FEB IMAR SALEM UNIT NO. 2 CORRECTIVE ACTION PROCESS APRIL APRIL 249 337 332 IDue I Overdue I 910/1391 110131 1956173 115 Open CR Activities NewCRs 367 (Information Only) 1,212/65 Timeliness:

160 I 157 J 149 Schedule Adherence:

Corrective Actions Scheduled (%

v I v I v Average Age of Open CRs (Days) 154 Scheduled in Next 6 Months) @> y Average Time To Accept v I v I v Completion of Scheduled Corrective C;\

y y y Actions for Month (%Complete) ~ y Evaluations (Days)

Quality:

Average Time To Complete v I v I v I Level 1 I Level 2 I Quality of Evaluations Evaluations (Days) y (Level 1=% Approved; Level 2=Score)

Average Time to Complete y I y I y y y YI Corrective Actions (Days) ~ Y _o_v_e_ra_ll~~~~~~~~~~--~~~~Y~~~~~

GREEN = EXCELLENCE YELLOW = MEETS STANDARD RED = NEEDS IMPROVEMENT NOTE: Engineering figures are not included in this performance indicator. The actual data point appears in the lower left corner of the box for the current month. Responsible Manager: J. Carey ext. 1035 Report Date: 05/08/97 S \NUCC 'H-Pl\CA*PROC XLS

I The Power of Commitment SALEM GENERATING STATION I I INDEPENDENT OVERSIGHT I

I I*

I I

I I £d;};;c~

Manager - Quality Assessment - NBU I May 28, 1997 11

I Key Issue How does PSE&G have reasonable assurance that independent oversight activities are sufficiently intrusive, effective, and timely

- Executive to identify conditions adverse to quality and to ensure that plant restart and continued operation are in conformance with Nuclear Business Unit (NBU) standards and expectations?

Since the shutdown of Salem Unit 2, many enhancements have 1 Summary been made to the independent oversight capabilities within the NBU at Salem. The driving management initiative in this area has been to reorganize and heighten the experience level of I personnel in the Quality AssessmenUNuclear Safety Review (QA/NSR) organization. Personnel in the QA/NSR organization have been assigned to plant functional areas, such as I Operations, Engineering, and Maintenance, to better enable them to evaluate plant performance. In addition, new personnel from both within and outside of PSE&G have been added.

I Another improvement is the formation of a Nuclear Review Board (NRB) composed primarily of individuals with external senior management experience. This Board provides an I additional level of executive oversight to the QA/NSR function.

Over the last two years, the QA/NSR organization has made the I transition to performance-based auditing, with an emphasis on utilizing industry technical specialists as part of the audit teams.

It also has developed and implemented an overall strategy to I assess restart readiness of the Salem units.

As a result of these initiatives, QA/NSR is now an integral part of I the management team, recognized for its role in the effective oversight of station operations. It provides important, timely feedback to line organizations at Salem Generating Station. For I these reasons, PSE&G has reasonable assurance that independent oversight activities are sufficiently intrusive, effective, and timely at Salem to identify conditions adverse to I quality and to support station operations in conformance with NBU standards and expectations.

I Initiatives In order to provide effective independent oversight at Salem, PSE&G has undertaken several initiatives as part of the CNO's reorganization of the QA/NSR function. As explained in greater I detail below, these efforts include: the infusion of new, experienced personnel, drawn from both within and outside of I PSE&G, into the QA/NSR organization; transition within the QA organization to a functional area alignment using performance-based assessment techniques; and the formation of the NRB .

QA/NSR also plays an integral role in the process leading to I

Salem restart.

2 I

I Heightened The Chief Nuclear Officer's (CNO's) first step in the QA/NSR Experience of reorganization was to bring in a new Director with extensive QAINSR management and QA experience. As of May 1997, this individual is serving as Director, Salem Unit 1 Recovery. The current Director QA/NSR completed planned improvements to the QA/NSR organization, including the formation of the Nuclear Review Board. Future improvements will focus on instilling a I heightened quality mind-set in the line organizations.

The leadership of the QA/NSR organization was further I bolstered through the addition of experienced personnel from both inside and outside of PSE&G. Outside QA/NSR hires have included:

I

• The Director - QA/NSR noted above.

I

• Two QA Assessment Supervisors. One has licensed Senior Reactor Operator (SRO) experience, and the other has NRG I inspection experience.

• Six QA Engineers. Three were experienced Audit Team I Leaders with at least six years experience as licensed operators, a fourth has experience both as a senior reactor operator and NRG resident inspector, a fifth was a Senior Mechanical Engineer with a nuclear engineering consulting company who participated in several Safety System Functional Inspections, and a sixth had extensive nuclear security oversight experience.

Internal QA/NSR hires have included:

• The current (May 1997 organizational change) Director of QA/NSR, who came to PSE&G in 1995, and has over 20 years of experience in the nuclear industry, with particular focus in the areas of training and operations.

• The new QA Manager, has over 20 years of line experience at all levels and also has an SRO certification at Hope Creek.

• Two additional Assessment Supervisors. One is a registered Professional Engineer with extensive design engineering and management experience, and the other is an experienced system engineer with outage management experience.

• Seven additional QA Engineers. One was a Senior Supervisor in the Radiation Protection organization and 3

I holds a Masters Degree in Environmental Engineering.

Another holds a degree in Electrical Engineering, has over 20 years of experience in nuclear operations including Maintenance and System Engineering Management, is SRO certified, and is a registered Professional Engineer. Two are experienced equipment operators who have been recognized by PSE&G as high performers and "breakthrough leaders."

1 Three additional line supervisors were hired into QA; two Maintenance Supervisors and one Chemistry Supervisor.

I As a result of these initiatives, the QA/NSR organization at Salem is now manned by an experienced team of personnel.

Eight of them have held Senior Reactor Operator and/or Reactor I Operator licenses, three hold SRO certifications, 19 have engineering or technical degrees, three hold graduate engineering degrees, and three have Professional Engineering I licenses.

Functional Personnel in the QA/NSR organization also have been assigned I Organization to functional areas of plant operation to better enable them to evaluate and assess plant performance in their areas of I expertise. These functional area assignments, in combination with their experience level and qualifications, ensure the ability of QA personnel to effectively and intrusively focus on plant performance and operation.

Transition to Over the last two years, the QA/NSR organization has made the I Performance- transition from compliance-based to performance-based Based Audits auditing, which involves a broader focus on safety. This has been accomplished by having more direct QA management I involvement in the planning and implementation of audits, the use of recent industry experience to determine areas of focus, and the use of industry technical specialists as part of the audit I teams.

Restart Oversight QA/NSR has developed and implemented a six-pronged I strategy to assess restart readiness of the Salem units. This includes:

I

• Evaluation of the nine Restart Action Plans, including evaluation of the adequacy of the plans, verification of selected completed actions, and evaluation of the I effectiveness of the actions.

• Continued day-to-day, performance-based assessment in all

1. assigned functional areas.

I 4 I

I

• Evaluation of selected Engineering Technical Programs and Technical Issues.

Continuation of the enhanced Audit Program.

Evaluation of selected Startup System Test Programs.

1

• Performance of other selected assessments to support Salem restart, including an evaluation of Station Operations Review Committee (SORG) and Management Review I Committee (MRC) effectiveness by an industry consultant and Restart Action Plan culture surveys.

I Formation of the An additional aspect of the QA/NSR reorganization was the Nuclear Review formation of the Nuclear Review Board (NRB). This board is Board made up of current and former executive-level professionals I from both the NRC and other nuclear utilities. One of the members of the NRB is a designated liaison with the Nuclear Committee of the Board, a committee of Public Service I Enterprise Group's Board of Directors. The NRB meets at least quarterly to review the performance of both the Salem and Hope I Creek Stations. Based on its oversight activities, the NRB provides advice and counsel directly to the Chief Nuclear Officer (CNO). The NRB has general oversight of the QA/NSR function as well as other aspects of nuclear safety. The Board provides an additional level of executive oversight.

I Results Improvements in independent oversight can be observed in several areas, including the "cultural" transformation at the station, the feedback from the quality function to the line I organization, and the oversight of the restart process.

Cultural Changes in the QA/NSR organization have resulted in a I Transformation "cultural" transformation at Salem. QA/NSR is now an integral part of the management team, recognized for its role in the effective oversight of station operations. For instance, it:

I

• Responds to requests from the line organizations by providing targeted assessments in areas of concern.

I

• Provides a monthly report to senior management and I PSE&G stakeholders identifying issues requiring their attention .

• Provided direct feedback that resulted in immediate corrective action during the Maintenance Intervention (the I 5 I

I subject of a separate Restart Briefing Paper) after observing that the evaluators were not being sufficiently critical.

-

• Is actively involved in the Salem General Manager's Quality Meetings, as well as in the SORC, the MRC, the Corrective Action Review Board (CARS), the Corrective Action Review Committee (CARC), the Testing Review Committee (TRG),

1 and the System Readiness Review Board (SRRB).

Improved As a result of the transformation to performance-based audits, I Feedback to Line QA/NSR has provided important, timely feedback to line Organizations organizations at Salem. A contributor to the success of these QA/NSR audits was the use of external technical specialists.

I Significant audit issues identified by QA/NSR to line organizations include:

I

• Controls Maintenance Audit (6/95): Identified weaknesses in the Preventive Maintenance program, corrective actions, and setpoint control. As a result, the NBU implemented projects I to upgrade these programs.

• Operations Audit (7/95): Identified weaknesses in the I implementation of Generic Letter 91-18 and weaknesses in resolving operator workarounds.

• In-Service Testing Audit (8/95): Identified weaknesses in program implementation that resulted in a QA stop work I order and a major effort by Engineering to upgrade the program.

I

• Corrective Actions Audit (12/95): Identified weaknesses in "departmental ownership" and "implementation of the process," as well as in the Operating Experience Feedback I Program.

• Training Audit (2/96): Identified weaknesses in the I Maintenance Training Program that, had they gone unidentified, could have resulted in losing accreditation.

I

• Corrective Actions Audit (5/96): Noted improvement in some areas but also noted weaknesses in Evaluation Manager ownership of issues and implementation and follow-through I of corrective actions.

• Procurement and Material Control Audit (7/96): Identified I inadequate implementation of Commercial Grade Dedication Testing.

I 6 I

I

• Emergency Preparedness Audit (11/96): Concluded that the program was being effectively implemented but that management attention was warranted to ensure strict compliance with regulations due to the number of identified issues.

• Training Audit (1/97): Found that the analysis, design, and development of the Operator Training Program was weak and that management attention was needed to ensure adequate implementation of industry standards in this area.

I

• Maintenance Audit (2/97): Identified many weaknesses in the implementation and control of the Measuring and Test I Equipment program. The audit concluded that the Maintenance Intervention at Salem was successful in improving cultural awareness and the quality of maintenance.

I

• Document Control & Records Management Audit (3/97):

Identified inadequacies in the implementation of both the I Document Control System and the Records Management System, resulting in a root cause evaluation and an extensive upgrade plan for both systems.

I

• Engineering Audit (5/97): Concluded that established programs and processes ensured compliance with ANSI N45.2.11. However, identified weaknesses regarding the effectiveness of implementation of these programs and I processes were noted.

Audit findings, including self-identified weaknesses, from the I above audit reports have been entered into the correction action program for resolution, as warranted.

I Effective Restart Functional area oversight and restart assessments have also Oversight provided critical feedback to the NBU. Specific areas of focus include the System Readiness Review Process, Operations I Restart Training, Operator Performance, the Work Week Management Process and Maintenance performance. (For instance, the QAfNSR assessment of Maintenance performance I was a major contributor to the decision to implement the Maintenance Intervention to upgrade performance, which is addressed in a separate Restart Briefing Paper.)

I During the first quarter of 1997, to assess Salem's readiness to proceed to Mode 4, the QA organization performed over 1 ,700 I hours of direct observation of operator performance and made over 160 field observations of Maintenance activities. These assessments, coupled with evaluations of Engineering's ability I 7 I

I to support an operating plant, concluded that Salem is ready to continue with the transition to Mode 4. Quality Assessment will continue to evaluate station performance in all areas through the mode changes and plant heat-up to help ensure restart readiness before recommending restart and proceeding to Mode 2.

I Conclusion The reorganization of QA/NSR and the infusion of new personnel with valuable qualifications in their assigned functional areas have afforded the QA/NSR organization the I ability and credibility to provide effective, intrusive oversight.

QA/NSR issues are openly accepted without defensiveness by line organizations and are responded to promptly. QA/NSR-I identified issues are being corrected. The General Manager -

Salem Operations and each department manager challenge QA/NSR assessors to be as critical as possible. Additionally, I QA/NSR is given a daily forum to identify issues at the morning management meetings. As a result, PSE&G has reasonable I assurance that the QA/NSR organization is effective and has the requisite abilities to support restart and subsequent plant operation.

I I

I I

I I

I I

I 8 I

I The Power of Commitment I SALEM GENERATING STATION I

I I

I OPERATIONS I

I I

I I

I I

I ~-

A. Christopher Bakken, Ill Director - Salem Operations I May 28, 1997 I

I Key Issue How does PSE&G have reasonable assurance that the Operations Department provides adequate oversight of plant activities and that its personnel are focused on safety, have a questioning attitude, and are demonstrating sufficient leadership, knowledge, and skills to assure the plant is operated in a safe, reliable manner?

I Executive Summary Both the Operations and Training Departments at Salem Generating Station contributed to the decline in plant and Nuclear Business Unit (NBU) performance in this functional area.

I During shutdown of the Salem units, PSE&G implemented several initiatives to address identified deficiencies in both departments. These included improving leadership and I personnel qualifications through staffing changes and training, as well as establishing higher standards of performance and evaluating personnel in accordance with these new standards.

I Most importantly, PSE&G undertook an aggressive Operations Intervention effort to instill in the Operations department and I operating personnel the required knowledge, skills, and attitudes to assure that the plant is operated safely and reliably following restart. This intervention consisted of a series of evaluations of I the knowledge, skills, and attitudes of the licensed operators.

As a result of these evaluations, PSE&G established a comprehensive Startup Training Program.

• Operating crews on shift for restart have completed this I program, involving approximately three (3) months of intensive review in systems, theory, and procedures, as well as simulator training and in-plant walkthroughs.

I

• Support for the Operations department training has been extensive in order to emphasize heightened management I expectations for crew performance.

• In parallel, a comprehensive effort is currently underway to I upgrade all Salem Operations training materials and the Salem full-scope simulator.

I PSE&G is confident that this training and requalification will greatly facilitate safe and event-free startup and operation.

I Additional improvements have been made in Operations Department policies, processes, and procedures. Among them are improvements to Operations procedures and personnel I procedure adherence, as well as more aggressive Operations ownership of plant equipment and leadership in problem resolution.

I 2 I

I Initiatives Prior to the development and implementation of the Operations Restart Plan and Operations Intervention, Salem Operation's performance was hampered by the following deficiencies:

• low standards for personnel and equipment performance;

• weak supervision and leadership;

• lack of ownership (i.e., not an Operations-led organization);

I

• deficient policies and procedures; I

• ineffective self-assessment and corrective actions; and I

• lack of fully integrated processes.

In order to address and resolve these weaknesses, Salem set a I course of action by which to accomplish several initiatives in the area of Operations. These efforts are described below.

I Improve Leadership and Historically, both the Operations and Training departments at Salem Generating Station were staffed with personnel from Qualifications within the company who were promoted on the basis of service Through Staffing time. They had little exposure to other nuclear plants that would Changes lead to the identification and adoption of good industry practices.

Therefore, an important element of improvement initiatives in the I area of Operations was a search for new, experienced talent to come to the Station and help change the operating culture.

PSE&G recognized that proven performers from other nuclear I facilities would bring valuable experience, perspectives, and standards to Salem.

I As a result of this search, in late 1995 PSE&G replaced most of Operations and Training management. New managers and I instructors have raised the standards for operating crew performance, as well as those applicable to the Operations and Training departments as a whole. Personnel exchanges I between the Operations and Training departments have further enhanced cultural and performance improvement initiatives.

I PSE&G also brought in additional personnel with the intention of substantially increasing the number of licensed operators.

I

• Five individuals with substantial industry experience in plant operations were licensed as Senior Reactor Operators (SROs) at Salem. They were put through an accelerated I 3 I

I SRO program for Salem in early 1996 and four are now on shift crews.

• PSE&G also qualified five additional experienced Shift Technical Advisors (STAs) from other Westinghouse facilities. These individuals were put through an accelerated STA program to become qualified at Salem and are now on shift.

Higher Standards Throughout the shutdown period, the new Operations I and Expectations management team identified the need for higher standards and expectations for Operations personnel. Their first step toward establishing and implementing new departmental standards was I the issuance of a document (SC.OP-DD.ZZ-0004(Z),

"Operations Standards") which defines PSE&G's expectations for operator performance. A companion document (SC.OP-I AP.ZZ-0002(Q), "Organization & Responsibilities") stipulates the specific duties and responsibilities assigned to each position I within the organization of the Salem Operations Department.

Following their development, these new standards were put into I effect and introduced to departmental personnel through Operations Restart Training, an intensive training period during which the new standards were continuously reinforced with each crew. Specifically, an Assistant Operations Manager established expectations for crew behaviors in classroom and simulator training. Peers from other facilities have been brought in to I assist with evaluation and training. In addition, the Operations Manager has participated in simulator training as a means by which to communicate experience and expectations.

I Performance in this area is tracked and measured on an ongoing basis, for example, by supervision of crews in the simulator.

I Additionally, all operating crews were sent (as a crew) to INPO-identified high performing plants to observe plant operations, identify good practices that can be used as part of Salem's I restart, and further reinforce our heightened performance standards and expectations.

I The Operations Intervention --

Numerous improvements in plant material condition, design, and procedures will assist greatly in assuring safe and reliable I Exploration and Training operation after restart. However, this alone is insufficient.

PSE&G recognizes that operating personnel must be equipped with the knowledge, skills, and attitudes that are required for I excellence in nuclear operations. At the station, there was a need to overcome an historic culture in the Operations and Training departments that accepted minimum requirement I 4 I

I performance levels. Accordingly, PSE&G directed an aggressive Operations Intervention training initiative to achieve improved operating crew performance prior to restart.

Specifically, PSE&G developed and implemented a comprehensive, two-phase Startup Training Program to support safe startup and reliable operation. This is referred to as the Operations Intervention. Phase One of the Intervention, the Exploration Phase, was a thorough evaluation of operator knowledge, skills, and attitudes. Based on this evaluation, the I second phase was a training phase that specifically targeted weaknesses identified in Phase One.

I Phase One:

Exploration During the Intervention's Exploration Phase, a series of comprehensive evaluations were administered to the licensed and non-licensed operators. These included knowledge-based I written and oral evaluations and performance-based simulator evaluations. These were "as-found" (i.e., no preparation)

I evaluations in order to permit a realistic assessment of existing performance levels and program weaknesses. Of the total population of operators, approximately 94 percent of the licensed I operators and 100 percent of the non-licensed operators participated in the evaluation. Personnel who did not participate were either on leave, in initial training, identified as not to return to on-shift licensed duty, or were exam prepares/validators.

Important attributes of these evaluations include the following:

I

• The licensed operator written evaluation was designed to test knowledge of reactor theory, heat transfer and fluid flow, I transient and accident analysis, abnormal and emergency operating procedures, and other administrative topics. The written evaluation exceeded a NUREG-1021 examination in I scope, length, and difficulty. The non-licensed operator written evaluation was designed to test knowledge of system design and operation.

I

• The licensed and non-licensed oral evaluation was designed I to test knowledge of in-plant systems, procedures, and protocols. It was administered one-on-one, with the candidate responding to questions in the areas of plant I operation, administrative procedures, technical specifications, radiation protection, and conduct of operations.

I

• Performance evaluations were administered on the Salem plant-specific simulator. A minimum of two evaluations per crew were performed. The evaluations were approximately I 5 I

~

ii two-hours each, and included normal operations, instrument failures, component failures, abnormal plant operations, and emergency plant operations. Both competencies and critical tasks were evaluated.

Phase One The Phase One evaluations revealed improvement needs based Results on performance indicators for knowledge, skills, and attitudes.

Because the results of these evaluations for individuals did not correlate to a history of performance, PSE&G concluded that the issues identified were programmatic, related to standards and I training, and not a personnel issue. However, based upon performance history and evaluations, prior to restart the licenses for approximately 9 percent of the operators will have been I retracted.

I Restart Training Status I

License Inactive I

11%

License Retracked

• 9%

Completed Restart Training I 80%

I The comprehensive evaluation results were used to shape the I Training Phase of the Startup Training Program described below.

The results of the evaluations were reviewed with all of the participants as part of the remedial training in order to capitalize I on lessons learned.

I

• A detailed evaluation and analysis of evaluation results was performed with each crew's Senior Nuclear Shift Supervisor and Operations Department management.

I

• A comprehensive written evaluation review was conducted with each crew, identifying "high-miss" questions.

I Individuals at the low end of the scoring also reviewed their written evaluation with an instructor one-on-one.

I 6 I

I

• The oral evaluation (in-plant evaluation) was reviewed with individuals identified as below-standard in a one-on-one setting to address weak areas.

• The results of the simulator evaluations were reviewed on an individual basis with each crew member by the Senior Nuclear Shift Supervisor and the Lead Simulator Instructor.

Operations The results of Phase One were analyzed to determine the best I Intervention Phase possible method to improve operator knowledge, skills, and Two: Training attitudes. The weaknesses identified in the evaluations were used to build the framework for Phase Two -- Vertically I Integrated Crew Training. This training, which is designed to address the performance weaknesses identified during Phase One of the Intervention, I

• involves all operating crew personnel, from non-licensed to I senior personnel;

• encompasses the spectrum of training environments --

I classroom, in-plant, and simulator; and

• focuses on knowledge and skills, as well as the culture and 19 attitudes, that are so important to successful operations.

In total, each crew receives over 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> of intense review and I simulator training. Success is measured by achieving an 80 percent Grade Point Average (GPA), an increase from the previous passing GPA of 70 percent, and passing the annual I requalification examination.

The major topical areas covered in this training are INPO Control I Room Team Dynamics, reactor theory, heat transfer and fluid flow, electrical theory, transient analysis, mitigating core damage, I and integrated plant operations. In addition, several Salem and industry operating events were specifically incorporated into the training. The Nuclear Equipment Operators (NEOs) are I integrated into the training in the simulator and through mentoring exercises with reactor operators.

I This training is being conducted in groups. The first group --

which has completed its training -- was composed of the higher performers during the evaluation phase and was based on the assumption of staffing the four present shifts. The second group

-- which also has completed the training -- has now augmented the four shift rotation. The third group -- for which training is I 7 I

I ongoing -- will allow Operations to reconstitute a fifth shift in June 1997.

In total, the Vertically Integrated Crew Training is an ambitious and comprehensive effort to provide the operating crews with the skills and attitudes necessary to assure the long-term success of I both the individuals and the plant. The crews that will support restart of Salem will have completed this program prior to standing watch.

I Training The Operations Intervention also recognizes the close link Improvements between operator performance and training. Training must I continue to fulfill its function in an exemplary manner in order to support long-term safe and reliable operation. PSE&G identified past weaknesses in this area and has taken actions to bolster I that performance. The training improvements described immediately below are pertinent to Operations. Other Training initiatives and improvements are discussed in a separate Restart I Briefing Paper devoted to the subject in general.

I During the evaluation process, PSE&G identified an historic "train to examine" culture in the Operations Department.

Management expectations were directed at those skills necessary to pass annual requalification examinations. The focus was on short- term remediation for operators with identified weaknesses. The procedures (especially the Emergency I Operating Procedures) became cluttered with information intended to assist the operators in passing examinations, but with the unintended effect that procedures became cumbersome I and slowed operator performance during their use.

New management in the Operations and Training departments is I changing these conditions. Some of the measures taken include:

• The Salem Operations Training group is undergoing a re-I engineering to address resource issues and to better align with the Operations department. A resource study has been completed as part of this effort and contractors have been I brought in to meet present needs while permanent personnel are identified and trained.

I

• More form?lly licensed personnel are being used as instructors and more instructors are being licensed to I increase their qualifications. Eventually, most instructional personnel will enter an SRO training program to acquire an SRO license. This effort is estimated to be complete by I 8 I

December 1999. Instructors will attend continuing training and be required to take and pass continuing training examinations.

• A comprehensive effort is underway to upgrade all Salem Operations Training materials. This includes classroom lesson plans and simulator scenario guides. The improved materials have been incorporated into the Startup Training Program, as completed.

• The results of the licensed and non-licensed operator evaluations will be input into a two-year plan for continuing training. This training will focus on identified weak areas and on material from prior segments of continuing training to assure the training is effective.

• The Salem simulator is undergoing a model upgrade to engineering-quality Reactor Coolant and Reactor Core models.

The operational focus of the Training organization is now established. Training is accountable to Operations, and has clear Operations management support.

Several efforts have been completed to improve Operations procedures and personnel procedure adherence within the department, including:

• the establishment of a streamlined Safety Tagging Program involving short-term efforts to reduce the number of tagging errors and longer-term process and qualification improvements which were completed in January 1997;

• the establishment of the Operations Department Self Assessment Program;

• the establishment of the Operations Department Corrective Action Group;

• reduction of the Operations procedure backlog, primarily through screening and Mode coding efforts undertaken as part of the System Readiness Review Process;

• revision and/or deletion of Operations Department Directives, as appropriate, and review/revision of all Operations Department Administrative Procedures (including Conduct of Operations and Procedure Usage); and 9

I

• verification of procedure readiness to support a safe and controlled startup, including review and revision of the Emergency Operation Procedures (EOPs), Abnormal Operating Procedures, Alarm Response Procedures, Integrated Operating Procedures, and the Department Logs.

In order to improve Operation's ownership of plant equipment and leadership in problem resolution, PSE&G:

I

• established Operations Department System Managers who, through an interface with cross-disciplinary system teams including a System Engineering System Manager and I counterparts in Design Engineering, Planning, and Maintenance, were given formal signature approval and responsibility for system acceptance prior to system I affirmation; I

• improved the quality of Operability Determinations (ODs) by revising the Operability Determination Process, which now includes SORC review of ODs and crew training on Generic I Letter 91-18; and

• improved plant configuration control, primarily through the control and elimination of operator workarounds, which are controlled and evaluated procedurally and managed through a departmental performance indicator.

I Results Having closed out the Operations Restart Plan and effected the Achieved and overall Operations Intervention, PSE&G has achieved the I Performance desired improvements requisite for restart and operation of Salem Unit 2.

Indicators I Improved In summary, PSE&G has improved the quality of leadership in Leadership and the Operations Department and heightened personnel I Staff Qualifications qualifications as demonstrated by the following:

,I

• New management is in place in both the Operations and Training departments.

I

• The Operations Department has retained additional personnel with outside experience in the nuclear industry.

This includes several licensed Senior Reactor Operators and I Shift Technical Advisors, all of whom have gone through accelerated training and are now serving on shift.

I 10 I

I

• Phase One of the Startup Training Program was completed, allowing a comprehensive assessment of the state of the operating crews' knowledge, skills, and attitudes.

• Phase Two of the Startup Training Program is underway.

Crews presently on-shift have completed the intensive program involving over 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> of review, including theory, systems, simulator time, in-plant evaluations, and procedures.

Crews that support restart and operation following restart will I have completed this program.

• Numerous training materials have been upgraded and I incorporated into the Startup Training Program as available.

A Lesson Upgrade Project upgraded classroom materials.

I Adherence to Various assessment efforts, including those conducted by QA, Elevated the Station Integrated Readiness Assessment (SIRA) team, and I Performance Standards and our own departmental self-assessments, indicate that crew personnel who have been through the Operations Restart Expectations Training Program are exhibiting practices consistent with new I standards and expectations. The graph that follows illustrates this conclusion.

I I

I I

I I

I I 11 I

I Effectiveness of One important measure of the results achieved by the Startup

- Training Training Program is provided by the requalification examination results for the operators who have completed the training. They are set forth in the following graph.

I I

I CJ Assessrrent 13/aluation Ill Restart Final Average I

I SRO NCO NED I

The first two groups of plant operators have completed Startup Training. Overall group performance is indicated below:

I Licensed Operator Annual Examination Performance I

I I

I I

I 12 I

I Non-Licensed Operator Annual Examination Performance I

I I There were two licensed operator crew failures, both occurring in Group One. These failures were analyzed by Operations and I Training management and the apparent cause of failure was determined to be a failure in team skills. These crews, because I they have had limited time together (they were assembled in February 1996), were susceptible to this type of failure, which is normally more prevalent with initial license candidates.

All four Group One crews were immediately enrolled in a two-week course specifically aimed at improving team skills.

Exercises included a simulator scenario on the Hope Creek simulator and an exercise where the SRO was located outside the simulator in a blind classroom communicating to the reactor operators by full-multiplexed headsets. The two crews that failed were re-examined by the administration of two new simulator scenarios per crew. Both crews successfully passed their re-I examinations. The lessons learned from the Group One crews were factored into the Group Two training. There were no crew failures in Group Two.

I The individual failures have been remediated and the personnel re-evaluated. All have passed subsequent evaluations.

I I

I I 13 I

I Conformance to the Work Standards Handbook communication model also was monitored in conjunction with measuring program effectiveness. The following figure illustrates the improvement in crew communications for the program. Communications were measured as part of the simulator training phase and covered normal, abnormal, and emergency events.

Three Point Comnunications I

I -~..,

c c

Cll IJ Pre-Restart I (.J Cll D.

llllFinal I A 8 c D E F G Restart Training Crew I

Improved Operability Determinations (ODs) are tracked and controlled Operability within the Corrective Action Program. They are means by which I Determinations potentially degraded or nonconforming conditions are evaluated for impact on the operability of plant structures, systems, and components. The OD process also ensures that corrective I actions are developed and tracked to completion.

Implementation of an OD process consistent with the NRC guidelines in Generic Letter 91-18 has improved the overall I quality of the evaluations. As evidenced by the following performance indicator, a significant reduction in outstanding ODs has been achieved at Salem.

I I

I I

I 14 I

I Outstanding Operability Determinations 11 I Jan-96 Mar-96 May-96 Ju~96 Sep-96 Nov-96 Jan-97 Mar-97 I I f.*......i Unit 1 - Unit 2 c::lleommon -Totals -Red --G-Green I I An assessment of the OD process was conducted by the Nuclear Safety Review Department in May 1996. This assessment identified the need for design and licensing basis training for I Operations and Engineering personnel. NRC Inspection Report 97-03, dated April 3, 1997, concluded that effective training for Operations and System Engineering department personnel I contributed to an effective OD process.

While the new OD process and current level of training support safe plant restart and operation, continued improvement in this area, on a long-term basis, will be realized through the further enhancement of operator understanding of the plant design and I licensing bases. The latter is addressed in a separate Restart Briefing Paper on Design and Licensing Bases Reviews.

I I

I I

I I

I* 15 I

I Control and As demonstrated by the performance indicator data below, Elimination of Salem operators now have a low tolerance for anything Operator perceived as a workaround. Additionally, management is Workarounds committed to eliminating workarounds once they are identified by Operations. For instance, there has been a steady decline in Control Room deficiencies, as depicted in the figure below I entitled, "Salem Unit 2 Control Room Deficiencies."

I I

I I

I There also has been a reduction in operator workarounds, as shown by the following figures. First, the number of temporary modifications at Unit 2 is low.

I I

I

• I I

I I 16 I

I Similarly, there has been a reduction in the number of workarounds at Unit 2.

I I

I I

I Improved

• The Emergency Operating Procedures (EOPs) have been I Procedure Quality and Adherence revised to industry standard content, including upgrade to revision 1B of the Westinghouse Emergency Response Guidelines. In addition, through use of an integrated training/validation plan the Group One startup crews have provided feedback allowing a streamlining of the EOPs to facilitate meeting time-critical evolutions identified in the I Updated Final Safety Analysis Report.

• Procedure writers were assigned to the Training Center to I work with the operating crews during the startup training.

This has facilitated timely correction of procedure problems prior to startup.

I I

I I

I 17 I

I

• As for the procedure backlog, the chart below contains data applicable to both restart and non-restart procedures.

Unit 2, 3, & Common Procedure Backlog I 500 450

- ~ ~

~

400 ..... - - -

I 350 300 250 I 200 150 100 I ~0 I I i ' i 12/8/96 12/29/96 1/12/97 I I 212197 i I 2116/97 I I 1 3/2197 I i 3/16/97 i

3/'30/97 i :

4113/97 t i 4127/97 I

I Ill Mode 5 *Mode3, 4 c;iMode 1, 2 C Non-Restart I Conclusion Management changes have been made and new, experienced personnel have joined the Operations Department. PSE&G has conducted an aggressive Operations Intervention to improve the performance of the Operations and Training organizations. In addition, PSE&G has conducted a comprehensive evaluation of the licensed operators and a thorough Startup Training Program I to address the knowledge, skills, and attitudes of the licensed operators. As a result, Operations Department leadership is in I place and operating personnel are focused on safety, have a questioning attitude, and have demonstrated the ability to restart and operate the Salem Generating Station in a safe and reliable I manner.

I I

I I

I 18 I

I The Power of Commitment

£%f?a:<

&.~1_-~*i*t?.~

~--

v#""...

-~

• • ~

PS~G p~

\:)

~~~11 I

I SALEM GENERATING STATION I

I I

I I PLANNING AND MAINTENANCE I

I I

I I

I 11

'.I I

I Key Issue How does PSE&G have reasonable assurance that deficiencies in the Salem Maintenance organization and the control of work have been resolved, that equipment reliability and station material condition have improved, and that Salem Maintenance personnel have the knowledge, skills, and "culture" to ensure that the quality of workmanship meets expectations in support of restart and plant operations?

Executive In the area of maintenance, broad improvement initiatives I Summary (discussed below) were implemented under the Salem Reliable Maintenance Restart Action Plan. The overall objective of the Restart Action Plan was to identify, assess, correct, and re-I assess the deficiencies in maintenance to improve equipment reliability and material condition at Salem. In addition, the Plan I included measures to improve processes, personnel skills, and "culture." Initiatives undertaken as part of the Plan included training enhancements and the Maintenance Intervention, work I management and control improvements, process improvements, and preventive and corrective maintenance action items.

Moreover, when recurring concerns were identified with the I quality of Maintenance Department work, the Restart Action Plan was amended to address them.

I With respect to maintenance training, Salem management, in conjunction with the IBEW (local union), designed and directed a major, three-month evaluation and remediation initiative known I as the Maintenance Intervention Program (MIP). Through baseline testing of maintenance personnel and supervisors for skills and knowledge levels, followed by training and I remediation in areas of demonstrated weakness, Salem achieved improvements in maintenance performance.

I Through this and other efforts in the maintenance area, the conduct of maintenance at Salem has improved. Restart Plan expectations have been met in this functional area.

I

• In addition to training enhancements, work processes have I improved.

• Standards and expectations for equipment and personnel I performance have been communicated.

• Accountability has been established for changes in the I maintenance process through the use of performance indicators, the encouragement of a questioning attitude among personnel, and the use of self-assessment.

I 2 I

I

• The dedicated Corrective Action group in Maintenance Programs has provided a qualified staff to perform cause analyses and coordinate actions to resolve corrective action items assigned to Maintenance.

• Self-identification of problems by Maintenance personnel I through the Action Request (AR) process has increased and corrective actions have improved.

I

• Maintenance organization oversight of non-station personnel performing maintenance on plant equipment has been enhanced.

I

• The Preventive and Corrective Maintenance programs (PM and CM) have been revised to clearly define roles and I responsibilities and to establish program ownership within the Maintenance organization.

I Improvements in work management and control also have been realized at Salem which ensure safe plant restart and continued I operation.

• Reorganization of the Maintenance organization has clarified I lines of authority and accountability.

• Management has defined the role of all participants (i.e.,

I Maintenance, Operations, Engineering, Work Control) in the work management system, enhanced performance standards, and has clarified the need for communication and I coordination.

• A new work management program and associated training I have been implemented which improve the availability of resources and hardware to resolve equipment deficiencies.

I

• Schedule adherence has improved, although Maintenance work quality is emphasized more than schedule deadlines.

I

• Improvements in work quality have resulted in less rework; the significance of rework items has decreased.

I The material condition of equipment following maintenance activity has improved markedly, and now meets the standards I needed to support long periods of sustained operation.

I 3 I

I Initiatives

- Maintenance In 1995-1996, PSE&G hired a number of new Maintenance and Organization Training management personnel with significant nuclear industry Changes experience. These management changes initiated the culture shift towards technical excellence and accountability, which was subsequently reinforced by the MIP evaluations and training.

1 The Maintenance Department also has been reorganized to I allow supervisors to concentrate on specific systems and personnel. The Maintenance Training group is undergoing re-engineering to improve its alignment with the Maintenance I Department. For example, instructional personnel assigned to the Maintenance Training staff may be temporarily assigned to provide outage support for the station, which is designed to I ensure that the instructional staff stays current with station policies and procedures. Instructors also are required to complete the Supervisor Qualification Program to supplement I the station staff on an as-needed basis or for rotational assignments.

I Because of the success of the Work It Now (WIN)

Team, other composite, multi-discipline teams are to be added to the Maintenance organization.

I Heightened Maintenance management also was deemed deficient in Standards and establishing and enforcing standards and expectations for the I Expectations conduct of maintenance, and in developing and adhering to maintenance programs. To address this issue and improve work quality, Maintenance management developed and I communicated standards, for example, through the Common Sense Guide to Quality Maintenance. Organizational changes, I including the establishment of the Maintenance Programs Group to centralize programmatic and administrative issues, facilitated greater focus solely on maintenance-related tasks and was I designed to reduce worker errors.

Because Maintenance corrective actions and management I follow-through were determined to be insufficient, Department management reiterated expectations regarding the actions and behavior of maintenance personnel. These expectations I included:

• improvement in personal accountability; I

• verbatim procedural compliance; I 4 I

I

• self-identification of problems when possible; and

-

• improvement in work quality to minimize repeat maintenance.

Management expectations are reinforced via use of the Maintenance Assessment Program (MAP) card. The MAP card is a departmental performance monitoring tool used for I Maintenance department supervision of field work. The MAP cards serve as a means of documenting the degree to which field work meets management expectations. Maintenance I supervisors use MAP cards to rate performance in areas including safety (industrial and radiological), procedure I compliance, and the ability to self-identify conditions adverse to quality. MAP card data is evaluated to identify potential areas of concern and communicate specific guidance and performance I expectations to department personnel.

To ensure that expectations are and will continue to be satisfied I at Salem, management:

• established a dedicated Corrective Action Group; I

• convenes ad-hoc review groups as needed: the Human 1e

• Performance Review Committee and the Corrective Action Review Committee; and developed performance indicators to monitor trends and I verify progress.

I Maintenance management continually communicates expectations and means of improving performance. For example, the MAINTENANCE FLASH! is an electronic I communication tool for timely dissemination of information considered important to the site Maintenance organization (i.e.,

including Salem, Hope Creek, and Maintenance Service I Departments).

Training Deficiencies in the Maintenance Training Program, which were I Enhancements -

The Maintenance attributable in part to a lack of management ownership of and commitment to that program, were identified through a Intervention comprehensive self-evaluation (CSE) in 1995. Senior I Program Management determined that maintenance skills and culture at Salem were not consistent with management expectations and were not at a level sufficient to assure sustained good I performance in the future. In response, training expectations were developed and communicated to maintenance personnel.

I 5 I

I Task lists were validated and updated, and observations and assessments of training were made.

The most significant training effort, undertaken in September 1996, was the two-phase Maintenance Intervention Program (MIP). Phase One of the MIP involved an in-depth evaluation of the pre-existing fundamental knowledge, skills, and attitudes of I maintenance personnel. Phase Two involved training and re-evaluation specifically targeting the weaknesses identified in Phase One.

I Designed to restore the knowledge, skills, and culture of the Maintenance work force, the MIP was a comprehensive I evaluation and remediation program designed to facilitate safe, event-free startup and sustained operation in the future. In I summary, it involved taking the majority of the Maintenance work force off duty for an 8- to 10-week period to accomplish, in essence, a "re-baselining" of the maintenance function.

I The MIP was intended, in large part, to change a culture that supported minimum performance levels and failed to ensure I consistent incorporation of industry improvements and good practices into the maintenance area at Salem. With regard to both its objective and approach, the effort was similar to the Operations Intervention (including the Startup Training Program) discussed in a separate Restart Briefing Paper.

I MIP Phase One --

Assessment As part of MIP Phase One, comprehensive evaluations were administered to Mechanical Maintenance Technicians, of Instrumentation and Controls (l&C) Technicians, and I Personnel Electricians. The evaluations included both knowledge-based written examinations and performance-based maintenance proficiency examinations. To provide a baseline for measuring I improvement, the evaluations were as-found; that is, there was no preparatory training prior to the evaluations.

I The written examinations were:

I

• based on a representative sample of fundamental knowledge and administrative requirements necessary for the technicians to perform routine plant maintenance; I

• developed based on examination questions used by other utilities, and knowledge-based questions from EPRI and I PSE&G's internal examination bank; and I 6 I

I

• administered based on the incumbents' qualifications, with an average of five examinations administered per technician.

The performance evaluations:

• were based upon the individual's task qualifications and basic skill levels; I

• addressed both technical performance issues and the cultural behaviors observed through the Salem Self-I Assessment Program and the Corrective Action Program; and I

• were performed by peer evaluators from other utilities and the bargaining unit, as well as Nuclear Training Center instructors, performed the evaluations. Independent I oversight was provided during the evaluations by line management and QA.

I The Maintenance management team identified and communicated higher standards and expectations for both I Maintenance and Training personnel. During the performance evaluations, personnel demonstrated increased awareness of the standards and expectations for the Conduct of Maintenance 19 and Procedure Use.

A review of evaluation results was performed with the I technicians and the Salem Maintenance management team. An instructor reviewed the written evaluation results with the technicians to identify areas of weakness. Similarly, the I performance evaluations were reviewed with any individual identified as below-standard by an evaluator in a one-on-one session.

I MIP Phase Two-- The second phase of the MIP entailed the remediation and re-Remediation evaluation of the identified weaknesses. Remediation consisted I Training and Re-Evaluation of both classroom and laboratory training. Recognizing the importance of a behavioral shift, sessions dealing with I teamwork, positive attitude, accountability, and ownership were provided during the second phase.

I

• Each individual received five different modules, resulting in approximately 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of instruction and development of skills in these areas.

I I 7 I

I

• One of the modules, Management Expectations Workshop, was delivered by Maintenance management, with the assistance of a trained facilitator.

• Cultural issues identified during the MPE's in Phase One were reviewed during this session, and management's expectations for those areas were re-emphasized.

I Upon completion of their remediation, the incumbents had sufficient time to practice the tasks. They were then re-I evaluated using the same process that was administered during the evaluation phase. A second remediation was performed for I those candidates who required additional help mastering the tasks.

I Follow-up written evaluations were administered in the mechanical area since the knowledge tested during the performance evaluations represented a small percentage of the I issues contained in each training module (and associated written exam). Conversely, knowledge required to complete the Electrical and l&C performance evaluations overlapped I substantially with the written evaluations.

Employees who demonstrated technical and/or cultural 19 weaknesses during the performance evaluation were re-evaluated following remediation. They were not assigned work in the plant in tasks showing deficiency until they satisfied the I technical and cultural behavior expectations established by line management in the performance evaluations.

I The behavior shift resulting from Phase Two of the MIP was measured in the re-performance of the MP Es during re-evaluation, and was reflected in the significant increase in I average scores. Weaknesses identified during the MIP will be used as a tool to assist in development of Maintenance I Department continuing training.

Planning Because the relationship between the Maintenance and I Department Planning Departments is important for the effective performance Intervention of maintenance activities, the Salem Planning Department instituted a Planning Intervention Program (PIP). The PIP was I modeled after the Maintenance and Operations Departments' Interventions.

I Phase one consisted of testing and evaluations, similar to those performed by the Maintenance Department during the MIP, I

consisting of:

8

I

• maintenance fundamental knowledge examinations;

• knowledge examinations related to administrative requirements needed to perform planning functions;

• proficiency evaluations consisting of the planning of two I actual plant work orders, which were subsequently graded by Planning Department management; and I

• graded oral interviews to measure behavioral and cultural skills.

I Phase two involved the remediation and re-evaluation of identified weaknesses. With the help of the Maintenance I Department and the Training Center, the remediation was developed using the identified weaknesses from phase one.

This included training in Nuclear Administrative Procedures I (NAPs), the Work Management Manual and associated Desk Guides, planning of work packages, and selected maintenance topics.

ll The PIP, like the MIP, has achieved positive results. The re-evaluation was successful, with planners improving their test scores; i.e., the overall average of the 20 planners improved to 90 percent. As with the MIP, the success of the PIP, as reflected in Planning Department improvement, will be evaluated on an ongoing basis by the Self Assessment and Corrective Action Programs, as well as QA.

New Work The maintenance work management system and associated Management work control processes were found to be inadequate to Program and Work effectively identify, prioritize, schedule, plan and execute Control maintenance work, return equipment to service, and close out equipment deficiencies. To address these issues, a task team

• 1 was assembled to review work management methods, identify problem areas, propose solutions to deficiencies, and develop new program documents.

I The most important result was the development and implementation of a new work management program which is a I comprehensive approach to managing the identification, validation, scheduling, planning, and implementation of all work activities on plant systems, structures, and components. The program establishes and maintains an integrated work management process which supports safe and reliable 9

I

I operations, promotes productivity, and meets or exceeds management's goals and expectations.

The basis for the program's success is the development of a baseline schedule. The latter starts with a 12-week rolling schedule, which has been developed based on the scheduling of PM activities and surveillances required on plant systems and components, and factors in the probability risk assessment required to maintain the plant in an acceptable risk condition.

CM, design change packages, planned maintenance and operating experience feedback items will be integrated into the 12-week rolling schedule. This will serve as the foundation for both short- and long-range planning.

I Other work management program improvements include:

I

• procedure revisions authorizing the new work management process; I

• development of a Work Management Manual describing work programs and processes (e.g., Department personnel

I were trained on the Program and Desktop Guide for Maintenance); and I

• creation of a partnership between Maintenance Department groups, Operations, Planning & Scheduling, and Engineering.

I Preventive and The PM and CM programs were not completely effective prior to i.I Corrective shutdown. Accordingly, these programs have received Maintenance heightened attention. Ownership of both programs has been undertaken by the new Maintenance Programs group. Additional resources, including individuals with relevant background and I expertise, were assigned to these programs. Program weaknesses documented through internal and external I assessments were itemized and addressed until follow-up assessments indicated that the PM and CM programs were improving.

I Results and Performance I Indicators Improved The MIP and PIP, as well as related management actions, have I Personnel fostered fundamental changes and improvements in the Qualifications Maintenance and Planning organizations at the Salem Generating Station. Based on these efforts and the results I 10 I

I achieved, the current organizations possess the knowledge, skills, and cultural attitudes to meet management expectations regarding the quality of workmanship at the plant. The performance improvement will support safe unit restart and reliable operation in the future.

In particular, the MIP has achieved positive results which have substantially bolstered the qualifications of Maintenance personnel.

• The re-evaluation following completion of the remediation I process revealed significant improvement in written examination results.

/

I

• Post-remediation results indicated that 98 percent of the evaluations met the established technical standards and cultural standards on the first post-remediation re-evaluation.

I

• Any technicians who achieved unsatisfactory results on the initial attempt were remediated again and the evaluations I were re-administered.

• Average scores, for the technical and cultural components of I the post-remediation evaluations, were in the low 90's.

I The success of the MIP will be evaluated on an ongoing basis.

This will be accomplished by in-plant observations and Corrective Action Program trending.

Management Maintenance supervision uses MAP cards as a means of Assessment consistently evaluating and coaching performance of field work Program (MAP) and documenting the extent of conformance to management Card Results expectations. Results are compiled and evaluated to facilitate communication of specific guidance aimed at improving

• performance. Results tabulated below for the month of April show that performance generally met or exceeded expectations.

• 11

I

- APRIL MECHANICAL MAP CARD RESULTS Rad Safetv Exceeds Exoectations 12 Below Meets Exoectations Exoectations 0 37 I Taaaina Indus Safetv 6

11 2

2 73 144 Procedures 15 1 283 I FME NAP-6 5

3 0

0 51 17 Comm 8 0 183 I STAR Tool Use M&TE 2

5 2

0 0

0 33 91 35 I Housekeeoina Chem. Cont.

Work Closeout 9

8 5

3 0

0 90 36 106 PMT 0 0 1 I Facilitv 103 14 353 I APRIL l&C MAP CARD RESULTS I Exceeds Below Meets Exoectations Exoectations Exoectations Rad Safetv 2 0 46 I Taaaina Indus Safetv 0

2 0

4 27 143 Procedures 1 0 221 I FME NAP-6 0

0 0

0 54 16 Comm 0 5 184 I STAR Tool Use 1

1 0

0 68 117 M&TE 1 0 107 I Housekeeoina Chem Cont Work Closeout 2

0 0

3 0

2 69 8

80 I PMT Facilitv 0

0 0

9 19 228 I

I I

12

I APRIL ELECTRICAL MAP CARD RESULTS Exceeds Below Meets Exoectations Exoectations Exoectations Rad Safetv 0 0 6 Tannina 0 0 16 Indus Safetv 0 0 36 Procedures 0 0 103 FME 0 0 20 I NAP-6 Comm 0

0 0

0 4

49 STAR 0 0 11 I Tool Use M&TE 0

0 0

0 20 18 Housekeeoina 0 0 19 I Chem Cont Work Closeout 3

0 0

0 0

27 PMT 0 0 5 I Facilitv 4 2 107 I Procedure Revision Salem has reduced and continues to monitor backlogs of Backlog Reduction maintenance procedure revision requests, which are classified as "restart" and "non-restart" as shown in the following performance indicator.

I Unit 2, 3, & Common I Maintenance Procedures Requiring Revision I

I I Feb-23 Mar-9 Mar-23 I ::iil9R~ijt~if:t:::

Apr-6 Apr-20

x =l@Af&fiia¢$.ilitl:!J!.*.j May-4 I

I I 13 I

I Effective Corrective Improvements in the Corrective Action Program, as described Actions Leading To elsewhere in the Restart Briefing Paper on "Culture," have Improved facilitated improvements in maintenance processes. For Maintenance example:

Processes

• The Corrective Action Program backlog was reduced and remains at a manageable level.

• QA Corrective Action Review Committee scores for maintenance have been good.

• Culture changes as a result of the MIP appear to have improved employees' willingness to write ARs, based on the increase in self-identified problems.

I

• A self-assessment on the Maintenance Department's Corrective Action Program is scheduled for the third quarter I of 1997 to ensure continued effectiveness.

I Effective Work Although full implementation of the new Work Management Control Program is not possible until Unit 2 comes on line, those I aspects of the program that could be accomplished before restart have been successfully carried out. Use of this new program has resulted in noticeable improvement in schedule I compliance, as demonstrated in the graphs below.

I I

I I Imm% Adherence - 1 3 Week Rolling Average I I

I I 14 I

I Electrical Maintenance Schedule Compliance 100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

10-Feb 24-Feb 10-Mar 24-Mar 7-Apr 21-Apr 5-May I ~%Complete - 1 3 Week Rolling Average I 100%

l&C Maintenance Schedule Compliance 90%

I 80% ~

70%

~rn-60%

50%

~

I 40% >--- t---

30% ~ - - -

20% - -~ -

10% -

~

0% - 4- 4- --t- '-I I 10-Feb 24-Feb 10-Mar 24-Mar 7-Apr 21-Apr 5-May IIm.ml!% Adherence - 1 3 Week Rolling Average I I

Rework and To more accurately gauge progress in work performance, rework I Repeat and repeat maintenance activities have been classified using Maintenance INPO criteria, and performance indicators have been developed to trend these repetitive work activities. For example, there has I been an overall decline in the level of department rework compared to performance before the MIP. This trend continues to be monitored. In addition, rework reports are also reviewed I for enhancements to training.

I As a matter of routine practice, monthly data are validated through review by the Corrective Action group in Maintenance Programs. In addition, as part of its routine oversight of I maintenance activities, the QA Department reviews ARs to validate the repeaUrework performance indicator. QA identifies ARs which potentially should be added to the repeaUrework I total. The Maintenance Department evaluates the QA data to disposition the findings and reconcile the performance indicator as appropriate .

I 15 I

I Advances in PM As a result of the increased attention and resources allocated to and CM it, the PM program now has a firm foundation, with qualified personnel overseeing its implementation. New PM program procedures were developed, organization interfaces between departments were established, and the groundwork was laid for a PM Optimization program.

I As shown in the performance indicator below, due and overdue PMs are monitored, and significant progress has been made in reducing PM backlogs.

I 52 SALEM PREVENTIVE MAINTENANCE INVENTORY 1~

2000 - . - - - - - - - - - - - - - - - - - - - - - - - - - - - ,

1800 1600 1400 I 1200 ITJ1000 L!J 800 600 I 400 200 I *Overdue & Applicable El Overdue - Not Applicable :::: Initiated-no due date Ill Due -<iot overdue I Approximately 6,500 CM action requests/work orders (AR/WOs) were reviewed to determine if they were valid, resulting in a I reduction of approximately 31 percent of the backlog due to duplicate or otherwise invalid CMs. The remainder of the CM backlog has been reviewed by both Maintenance and I Engineering for impacts on restart readiness, and will be worked in accordance with the 12-week schedule. Performance indicators were developed to provide consistent definition and I tracking of backlogs.

A cross-functional team has been established to address issues I involving work order holds (i.e., work activities on hold for parts or engineering potentially resulting in excessive delays and process inefficiencies). Performance indicators measuring I backlogs and activity holds are used to monitor the effectiveness of the Work Control Process improvements. Backlogs of CMs, categorized by age, are also tracked, as shown by the following performance indicator.

16 I

I Salem 2 Non-Outage CM Backlog Age - Safety Related 1500 - . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ,

1400

>- 1300

~ 1200 IB I-1100

~ 1000

~ 900

>- 800

"' 700

"'ffi I

600

il 500

~ 400

"' 300

~

I I

27-I 4 1S Eh 1 Year 1- S- 15 ll':ilg -12 Months 29 12 26 11116 - 9 Months 1(). 17 31-03 - 6 Months 7-

-~~~~--

14 2S 12-D< 3 Months I Conclusion As a result of the above-described improvement initiatives, I PSE&G has reasonable assurance that past deficiencies in the Salem Maintenance Department and work control function have been effectively resolved_ Equipment reliability and plant I material condition have improved, and Maintenance and Planning personnel have the knowledge, skills, and "culture" to ensure that the quality of work meets management expectations I in support of plant restart and operation_

ie I

I I

I I

I I

I 17 I

I The Power of Commitment v

~~~ PS~G ~

SALEM GENERATING STATION I

I I

I I ENGINEERING I

I I

I I

I E. C. Simpson Senior Vice President - Nuclear Engineering May 28, 1997 I

I Key Issue How does PSE&G have reasonable assurance that Engineering personnel are properly focused on safety, are imbued with a I sufficient questioning attitude, and demonstrate sufficient leadership, knowledge, and skills to assure that engineering controls and equipment are maintained within prescribed design I and licensing bases and that the plant operates in a reliable manner?

I Executive Summary Engineering has aggressively sought to address its prior performance problems. Through systematic evaluations, assessments, and analyses, we have identified the underlying I root causes of the deficiencies in Engineering Department at Salem. These evaluations clearly demonstrated that a key focus of the corrective actions must be on improving Engineering I personnel's knowledge, skills, safety ethic, and sense of ownership. Other assessment activities demonstrated that there I was a need to enhance practices and processes, as well as to reduce the backlog and improve equipment reliability. The corrective actions implemented in the Engineering area support I safe plant restart and continued operation.

Initiatives

• I Training and The level of Engineering performance is directly proportional to Qualification the knowledge and skills possessed by personnel, as well as the quality of the supporting training program. In this regard, PSE&G

• conducted a number of benchmarking efforts to assess personnel competence.

I

• Approximately 350 PSE&G engineers were surveyed.

I

• Two areas were considered: (1) engineering judgment; and (2) problem solving knowledge.

I

• The findings indicated that engineering judgment was adequate but problem solving skills required enhancement.

I Consequently, PSE&G initiated comprehensive remedial training for Engineering personnel. The training focus areas included:

• Root Cause Analysis Techniques and Methodology

• Root Cause Analysis Application

• Error-Free Design and Installation 2

I

I

• Safety Concern Focus

• Human Error Reduction Techniques I A follow-up assessment indicated that these training initiatives were successful because there was improvement in three indices. Specifically, the training was effective in improving I engineering problem solving ability and root cause investigation techniques, as well as fostering a questioning attitude. In addition to the above-described training pertinent to various I engineering skills, additional training was provided at Salem to improve the consistency of engineering management in the following areas:

I

• Management Action Response Checklist (MARC) Training I

• Business Leadership Development (BLD) Training I In August 1996, PSE&G was awarded INPO accreditation for the Engineering Training program. This was the result of a robust Engineering Support Personnel (ESP) training program which I satisfies the requirements of INPO's Training Standard ACAD 91-017.

Building on the above, PSE&G recognized that the effectiveness of this training and the maintenance of basic knowledge and skills for engineering personnel could be better assured through I the use of a review board. Specifically, a design engineering review board was established. The board is manned by senior-level, experienced managers who orally test each engineer on I fundamentals of design engineering and the design/licensing bases.

I The focus of the testing is on the codes, standards, and other source documents applicable to the systems to which they are

'I assigned. The acceptance level for engineer competency has been established well above that for minimal performance.

Engineers who fail to meet this standard or exhibit marginal I competence are placed in remedial programs, as appropriate.

Enhancing Based on an initial screening, 54 key engineering practices and Programs and processes were selected for assessment. Included were not only Processes engineering-specific programs/practices, but certain other key interfacing processes (e.g., work control). Among other things, the assessment evaluated the practices/processes with regard to their: (1) interface; (2) consistency of implementation; and 3

I

I (3) adequacy when compared to purpose. The assessment effort used:

• personnel involved in the implementation of the I practices/processes;

• input from the departments that depend on these I practices/processes; and

• outside process experts.

I The first step was to develop self assessment measurement criteria. These criteria were derived from various industry "best I practices" sources (e.g., INPO, EPRI and "top performing" utilities). With these criteria, the second step of the assessment was to baseline each practice/process to determine how it I functions, what works well, what is not working satisfactorily, and why. This was accomplished by various means, including self-I assessments, procedure reviews, process flowcharting, and team focus groups. Once the function and effectiveness was understood, each practice/process was benchmarked against I industry "best practices."

Based on the assessment results, 9 programs required follow-up reviews. These programs included:

• In-Service Testing; I

• Check Valve; I

• Appendix R;

• Component Bill of Materials; I

• Fuse I Breaker Coordinators - Fuse Control; I

• Internal Hazards; I

• Electrical Loads;

• Fire Protection; I

• Vendor Manual.

Issues identified for corrective action during these follow-up reviews were included in Action Requests (ARs). "Restart-required" ARs are complete and Engineering Departments 4

I

I affirmed that they were ready for restart and could support Operations through the operating cycle.

The design change process (DCP) was specifically targeted as I an area for improvement, given a number of self-identified concerns. For example, the number of revisions and corrections to DCP packages was unacceptable, and was an indication that I the jobs were not being done right the first time. In addition, corrective action items, quality assurance and Institute of Nuclear Power Operation (INPO) findings also were identifying I weaknesses within the DCP.

In response to these findings, PSE&G took a number of remedial I actions. Chief among these actions were several third-party evaluations:

I

• in November 1995, completed DCPs were reviewed to determine whether modifications completely and accurately addressed the initiating concern; I

• between February and June 1996, a contractor assisted in the I review and enhancement of the DCP. Among the activities were: (1) training for engineers on 10 CFR 50.59, (2) review of DCPs to assure that important impacts were properly considered (e.g., operator training and environmental), and (3) review of process effectiveness (e.g., interfaces among organizations); and I

• in May and June 1996, a contractor (i.e., "DCP Improvement Team") evaluated the DCP from the standpoints of efficiency I and economics -- this review resulted, for example, in the expanded use of the minor modification process.

I Proactive Engineering PSE&G management recognized early-on that safe operation of the Salem station was firmly grounded in the perceptions, Organization With attitudes, and motivations of the workforce. To gain a more clear I Strong Safety Culture understanding of these attributes, PSE&G conducted a number of employee surveys to determine their views on the quality of Engineering's services and products. The surveys focused on I the following areas:

I

• quality of technical deliverables;

• responsiveness;

• communications; 5

I

I

• safety focus and safety culture; and

• support to station operations.

I The employee surveys were augmented by self-assessments performed for each Engineering department. In certain instances, third-party reviews also were performed.

I Management analyzed the collective findings from the review efforts. Based on this analysis, training was shown to be a key I improvement area necessary to anchor a safety culture within Engineering. As ~uch, significant emphasis was directed at training engineers in error-free design concepts, root cause I analysis and the corrective action process. In addition to the training improvements, the following key actions were initiated:

I

• the Maintenance Engineering Organization was established to shift the reactive engineering work load from the system I managers;

• Engineering personnel, including supervisors, were required I to meet minimum qualification standards commensurate with their assigned responsibilities;

• performance expectations, roles, and responsibilities were clearly defined; and I

• Engineering goals have been established and communicated to personnel.

I PSE&G conducted, to date, four Culture Surveys using techniques developed by Failure Prevention International. The surveys measure a number of key human performance areas.

I Although the fourth survey results are currently under management review, the overall results of the first three surveys for Engineering show continuing improvement.

I Licensing and Understanding the Salem design and licensing is the foundation I Design Basis for engineering success, the two major tasks completed in this Assurance area included: (1) completion of the UFSAR project which provided assurance that Salem could operate within its licensing I and design basis; and (2) implementation of training recommendations identified in the Salem Integrated Restart Assessment (SIRA) report.

The UFSAR project verified that Chapter 15 Safety Analysis assumptions and input parameters were used consistently in the 6

I

I implementing surveillance tests, calculations, specifications, or other supporting documentation. The safety evaluation reports associated with Technical Specification amendments for Salem Unit 2 were reviewed to assure their requirements were correctly I incorporated. In addition, 47 systems identified under the Maintenance Rule were compared against Technical Specification, configuration drawing or documents, and selected I UFSAR chapters, including Chapter 15. Further, in-depth vertical slice inspections, that included reviews of DCPs and 50.59 Safety Evaluations, were performed on the following seven I systems:

• Spent Fuel Pool Cooling; I

• Fuel Handling Building Ventilation; I

• Auxiliary Building Ventilation; I

• Reactor Protection System;

• Containment Building Ventilation; I

• Safety Injection; and

• Miscellaneous Ventilation Systems.

Actions identified in the above reviews were captured in the I corrective action process. As an additional measure, the review efforts were validated by an independent third party experienced in design and licensing bases reviews. The result of the UFSAR I review provided reasonable assurance that Salem will be able to return to service and operate within its licensing basis. As mentioned in the SIRA report and previous audits, design basis I training is necessary. As a result, design basis training has been incorporated into ESP training, as well as remediation for Design I Engineering Review Board (DERB) examinations. The DERB measures the level of licensing and design bases knowledge within Engineering. Over a two year time frame, engineers will I be examined in this effort to validate engineering knowledge levels.

I Reduction of The Engineering backlog is comprised of items from numerous Engineering sources (i.e., Action Tracking System, Deficiency Evaluation Backlogs Forms, Engineering Work Requests, Performance IR, and Action Requests). In the past, this diversity contributed to the less than

- adequate management oversight and employee accountability in completion of backlog items. To address this situation, the 7

I

I various tracking mechanisms were screened for outstanding engineering open items and against restart criteria. This resulted in creating two components of the Engineering backlog -- "restart required" and "post-restart" items.

I For the restart-required items, over 20,000 work activities were completed for the Salem Unit 2 Readiness Review process, I including the engineering backlog reduction effort. Items identified as restart-required were incorporated into a defined resolution plan and a responsible supervisor or manager was I assigned to monitor success. Some activities, by necessity, will be performed during power ascension and restart; however, to date, most activities have been closed, as indicated in the I performance indicator data set forth in the graph below entitled, "NOE Salem 2 & Common Restart Work Documents."*

I For the post-restart items, PSE&G performed a "smart" sample review based on safety significance considerations, to assess whether there were any aggregate impacts that needed to be I addressed as part of restart. This review did not identify any such concerns. The post-restart backlog has been reviewed and I characterized a number of times. The post-restart determination has been made per procedural criteria and documented in a database for each item. Those items also have been categorized by work activity (e.g., drawing update, procedural revision) such that Engineering management knows what is in the engineering backlog.

I Improved Root As noted above, comprehensive root causes and effective Cause Analysis and corrective actions were identified as a weakness. Several I Effective Corrective Actions principal actions were taken to address these weaknesses: (1) establishing a Root Cause Analysis (RCA) Group that is experienced and trained in RCA techniques; (2) establishing and I implementing a process for the identification and resolution of technical issues; (3) RCA training for engineers; and (4) establishing a requirement to perform in-depth root cause I analysis for significant events.

• Regarding the first action, the RCA Group was established to I provide a focal point for equipment failure root cause analyses. Group members lead or participate in significant equipment failure root cause investigations, and assisUcoach I others to effectively raise the overall level of root cause analysis throughout the NBU.

• As to the second action, Engineering initiated a daily management meeting to identify and review emerging 8

I

I engineering issues, and to work more effectively with customer organizations. Upon identification of such issues, the Group assigns responsibility for corrective action and continues to monitor progress to ensure prompt and effective I resolution. The effectiveness of the Group is demonstrated by the increased number of identified issues that are effectively resolved (e.g., Waste Gas Analysis Failure issue I and Emergency Diesel Generator Lube Oil Flow Control Check Valve issue).

I

• For the third action, engineers have been trained in RCA techniques (except for new hires who are to be trained).

I

• Finally, for the fourth action, the corrective action procedure (NAP-6) was revised to require a "formal" RCA for Level I ARs.

I Results and I Performance Indicators I Organizational Improvements and The Engineering organization has been restructured to provide more effective and proactive support to Salem operations and Training/ maintenance. In addition, the engineering interface with station Qualifications organizations has been improved. For example, Engineering has been integrated into day-to-day Operations and Maintenance I issues.

Effective training initiatives have improved the knowledge and I skill of Engineering personnel. This level of improvement is reflected in the results of the Failure Prevention International (FPI) Quality Index Reviews. Specifically, FPI measured the I Engineering Judgment Index (EJI) and Problem Solving and Knowledge Index (PSKI). An Engineering Quality Index (EQI) is the average of the EJI and PSKI. An index of 50 to 70 has been I correlated by FPI to an Engineering organization at a SALP 2 rating. The following table reflects the improvement in these indices after training in specific problem solving techniques had I been provided:

Date of Survey EJI EQI PSKI I Nov. 1995 April 1996 69.89 71.73 55.41 62.48 40.95 53.87

- 9 I

I Improved Work The work processes have been enhanced at Salem. Specifically, Processes the SORC rejection rate, as depicted below, has, with one I exception, exceeded the applicable performance expectation standard. This confirms the high nuclear safety quality of design changes prepared by Engineering.

I Salem Plant Engineering & Projects I 60 55 SORC Performance 100%

90%

iS 50 80% ...,

0 45 ~

I :ii 40 70% f:!

~ 35 60% Q.Q.

a.. 30 50% ~

() 25 40% .

c 0

'O 20 30% ~ ..

I 15

'It 10 20% a..

5 10%

0 0%

ca ..,::>c:  ; a

~

I -SORC Approved

-Percent Approved

• *

• Excellence 1996/97

~ SORC Rejected

--Needs Improvement I The Salem DCP error rate is also tracked. Within the past 12 months, the DCP error rate has consistently been at "Meets" or "Exceeds" standards. Engineering continues to monitor the error rate closely for adverse trends.

I Backlog Reduction The restart-required Engineering backlog has been significantly reduced, and will be eliminated, prior to restart. The current status of this backlog is illustrated in the following graph.

I NOE Salem 2 & Common Restart Work Documents 1000-.---~~~~~~~~~~~~~~~~~~~~~~~

I 900 800 700 I 600 Better 500 400 300 I 200 100 I

10 I

I Quality Engineering The quality and timeliness of Engineering products and services Products and Root to support station operations has improved. The Engineering Cause Analysis organizations are integrating root cause analysis as part of the normal Engineering review process. The graph that follows I illustrates the conclusion that Nuclear Engineering has sustained the high quality of its root cause analyses.

I Nuclear Engineering Root Cause CARB Approved/Rejected I "'0 30 25 -.........- - - - -. - . * .. -. -

~

~ * * * *

• 100%

90%

80%

c 20 ...... 70%

"O Q) e>

~ 1l!t 60%

c., 15 50% ~

0.

I 0

~

0..

it 10 5

40%

30%

20%

c Q)

I:

Q) 0..

10%

I MAY JUN JUL AUG SEP OCT NOV DEC

'96 JAN

'97 FEB MAR APR 0%

-CARB Approved

~ CARB Rejected -Percent Approved 1996/97 I --Needs Improvement Excellence

• I Conclusion PSE&G has conducted an aggressive engineering plan to improve performance. Personnel and process changes have been made, and performance has improved. The standards have been raised across the organization in training, with heighten focus on problem identification, solving, and corrective action.

Culture surveys indicate an improvement in knowledge, skills, and attitudes of the engineering staff. Prior backlogs have been I reduced, which will result in greater equipment reliability and more prompt response time to emergent issues. As a result of I these actions, Engineering department leadership and personnel are focused on safety, have a questioning attitude and have demonstrated the ability to effectively resolve engineering issues.

I Further, processes have been established to ensure sustained improvement in the Engineering Department. Each Department within Engineering has performed an exhaustive internal self-I assessment and has affirmed its ability to support the Salem units' safe and reliable return to service.

I Related As an example of the new culture in the Engineering Department,

Subject:

the In-service Inspection group's inspection of the Salem Unit 1 steam generators (SG) in early 1996 revealed serious tube Steam degradation. After evaluating repair and replacement G~nerators alternatives, PSE&G decided to purchase and install in Unit 1 11 I

I unused SGs of an improved design from another utility.

Subsequent investigations into the circumstances surrounding the development and identification of the tube degradation have resulted in identification and mitigation actions. In addition to the I replacement of the Unit 1 SGs, PSE&G has established an SG Group to provide focus and leadership for SG-related activities, including inspections, and has hired a new eddy current testing I (ECT) contractor.

The performance improvements summarized below ensure that I the existing Unit 2 SGs and the Unit 1 replacement SGs are safe and reliable for operation:

I

• On a programmatic level, PSE&G has upgraded and expanded the scope of the inspection program. These programmatic improvements were in place during the re-I inspection of Unit 1 and the January 1996 ECT inspection of Unit 2. They also were in effect during the pre-service inspection conducted on the Unit 1 Replacement SGs I (RSGs).

I

• PSE&G has made significant efforts to determine the root cause of the tube degradation. These efforts include destructive examination of the pulled tubes, water chemistry historical reviews and analyses, and consultation with industry experts.

I

• PSE&G has continued to improve the water chemistry program (emphasizing shutdown layup conditions and operating chemistry), and has implemented physical plant I modifications to provide a more corrosion-resistant operating environment given the materials of original fabrication.

I

• PSE&G has performed evaluations to ensure the structural integrity and leak tightness of the SGs in both units.

I Together, these actions ensure the safe and reliable operation of the Salem Unit 1 and 2 SGs in the upcoming cycles of operation.

I 12 I

I The Power of Commitment u~>>

1:.~'fff?JA PS~G &

I I SALEM GENERATING STATION I

I I

I TRAINING I

I I

I I

I I

I How does PSE&G have reasonable assurance that personnel Key Issue are trained and qualified to perform the tasks they are assigned during plant restart and operation?

Executive Operations, Maintenance, Engineering, and Training Summary Departments at the site contributed to the decline in training program performance, and thus plant performance as well, at I the Nuclear Business Unit (NBU). As a result, training was the subject of one of nine Salem Restart Action Plans.

I To ensure future training program success, management needs to reassure that the main reasons for training program failures were corrected. The line organization must involve itself in the I direction and support of plant training and the ongoing self-evaluation process. These and other improvements to NBU training programs, implemented as part of the Restart Action I Plan and as described below, include upgrades to procedures and training materials, consistent reinforcement of management expectations by line and training management, and renewed line I ownership through training review groups.

I During our recovery period, we received substantial support, guidance, and assistance from the Institute of Nuclear Power Operations (INPO). Both INPO and industry peers interacted with the NBU staff during this time. Recent feedback from INPO and industry peers indicates that the programmatic fixes were successful. Additional actions, such as peer review trips and I regional industry memberships, were taken to keep the training staff in step with the industry's continually improving training standards and innovations.

I Two of the major changes in Salem's training programs, negotiated with the bargaining unit, included: (1) having On-the-I Job Training I On-the-Job Evaluation (OJT/OJE) performed by represented line personnel; and (2) increasing minimum passing grades for all programs from 70 to 80 percent.

I Evaluations have been performed by training program owners and are discussed in other Restart Briefing Papers, particularly I those on Operations, Maintenance, and Engineering. Each of those Papers describe additional evaluation and training that was conducted in those specific functional areas. The lessons learned from each evaluation have, in turn, been internalized and passed along to all disciplines undergoing similar assessments of their programs and personnel.

2 I

I The Salem Operations Training Programs Accreditation was renewed by the National Academy for Nuclear Training in 1996.

- The combined Salem and Hope Creek Technical Training Programs, an industry first in bringing two reactor technologies together, had their accreditation renewed in May 1997. The future direction of site training efforts will continue to be led by the Senior Vice Presidents through the Nuclear Training I Oversight Committee, as well as individual line managers who oversee their specific programs' Training Review Group.

I Initiatives Initially, new training management personnel, with significant industry experience, were successfully recruited by the NBU.

They brought with them a new mindset of professionalism and I personal accountability, as well as new ways of performing training.

I During this early period, training procedures were streamlined and simplified to strengthen the Systematic Approach to I Training (SAT) process and to increase process and staff efficiency. Because of its impact, OJT/OJE was one of the first processes to be addressed at Salem. The process has been I revised and the framework is now in place for the line organization to effectively implement OJT and OJE.

To strengthen line management ownership, the Training Review Board Program was upgraded such that a Senior Vice President now chairs the Nuclear Training Oversight Committee (NTOC).

I Additionally, managers now function as chairmen of the individual programs' review groups. The higher standards and fresh ideas of the newly hired staff influenced the operation of I the review boards. Management expectations were clearly defined and constantly reinforced. The quality and the quantity of management's observations of training, in all settings, has I improved at Salem.

The self-evaluation process, although in place in the training I organization, had not been using the strengths of industry peers to critically review the programs against rising industry I standards. Additionally, line managers were not responsible for conducting such comprehensive self-evaluations of their training programs. Reviews have been conducted over the past I eighteen months which have been noted by INPO to be greatly enhanced since the operator program was placed on probation.

This critical objective of the Systematic Approach to Training Process (SAT) was reviewed and accepted through two

- successful National Academy Board reviews. During this time, the site Corrective Action Program was upgraded and the 3

1

I Nuclear Training Department's self-evaluation process was aligned with this program.

- The Nuclear Training staff also was changed to reflect the new management's higher standards. The instructor and support staffs developed new, higher performance standards based on industry best practices. The structure of the organization was I changed to more closely align with the line organizations.

Training staff members were required to reapply for their positions, based on the new standards. This process resulted in I approximately a 30 percent change in the staff.

I To keep staff performance consistence with line standards, a rotational program with the line has been instituted by the NBU.

This continuously infuses new blood into the organization in I conjunction with a robust instructor training program. The ease of acquiring talented trainers (subject matter experts) from the line organization speaks to the ownership of the training I programs at the grass roots level.

Results INPO accreditation reviews have concluded that notable I improvements have been made in our site's management oversight of training, the self-evaluation process, and OJT/OJE.

These reviews culminated with the Salem Operations Training Programs accreditation being renewed in 1996 and the combined Salem and Hope Creek Technical Training Programs accreditation renewal in May 1997.

I Performance indicators and improved trends demonstrating the effectiveness of training programs at Salem are provided in the I "Effectiveness of Training" section in the Operations Restart Briefing Paper, the "Improved Personnel Qualifications" section I of the Maintenance and Planning Restart Briefing Paper, and in the "Organizational Improvements and Training/Qualifications" section of the Engineering Restart Briefing Paper.

I Conclusion The reorganization of Nuclear Training and the infusion of new personnel with valuable qualifications in their assigned I functional areas have provided the Training organization with both the ability and credibility to provide technical, cultural, organizational, and training support to line disciplines.

Critical self-evaluation is now an integral part of the NBU's culture, both in the line and at the Training Center. Line ownership of training is evident throughout the organization (from technician level through Senior Management) and it is this 4

I

I culture that will keep the training programs healthy and growing in the months and years ahead.

The NBU conducted aggressive training "interventions" that improved the performance of both discipline and training organizations. Plant and training personnel have the knowledge, skills, and "culture" to ensure that their quality of I work meets site management's expectations in support of plant restart and operation.

I I

I I

I I

I I

I I

5 I

I The Power of Commitment

~*

A.~~fft~:~

tf:_*

• '*-:s#

PS~G P..!i

\:}

~~~

I I SALEM GENERATING STATION I

I I

I DESIGN I LICENSING BASES REVIEW I

I I

I I

David R. Powell Manager - Nuclear Licensing and Regulation May 28, 1997 I

I Key Issue How does PSE&G have reasonable assurance that design/

licensing documents sufficiently reflect the as-configured and as-operated plant hardware and systems to support safe and reliable operation?

Executive The Final Safety Analysis Report (FSAR) Project consisted of Summary several initiatives to assess the design and licensing basis documentation, including the Updated Final Safety Analysis Report (UFSAR) safety analyses and system descriptions. This includes efforts to verify the plant configuration and its operation.

I Ongoing programs and projects, such as configuration walkdowns, the Technical Specification Surveillance Improvement Program, and the Emergency Operating Procedure I Upgrade Program also provide assurance that the design and licensing bases are consistent with plant operation. Issues identified as part of on-going efforts will be captured, as I appropriate, in the corrective action program.

Also, several evaluations and upgrades to the Salem I configuration control processes, such as the 10 CFR 50.59 and corrective action process, help assure that the licensing and I design bases will be appropriately considered in the future.

Enhanced programs now are in place such that plant and procedure changes are fully evaluated and that documentation will be appropriately updated and maintained. Training on these processes is an important component and assures that the organization has the skills to appropriately maintain design and I licensing basis information in the future.

As an ongoing effort, the Design/Licensing Bases Review I Project (DLBRP) will review design and licensing basis documents, operational limitations within the UFSAR, design output documents, implementing documents, and the as-built I plant. The intent of the reviews is to identify deficiencies, missing information, or ambiguities in the design basis documentation, operating procedures, and engineering design I output documents. Assessment and review depth will, in part, be adjusted as appropriate upon identification of deficiencies that may exist in a system's baseline design bases or design I documentation. An inspection plan will provide guidance to team members for the review of plant design documentation during the validation of design basis parameters.

The reviews will maximize the use of PSE&G resources to ensure clear ownership and improve the understanding of design bases by PSE&G personnel. Multi-discipline teams will be formed to perform a comprehensive review of design bases 2

I

I information on a system basis. The product of the DLBRP will be documented design/licensing bases for the reviewed systems, which have been validated through plant procedures, and will be easily accessible for use in the day-to-day performance of work.

Initiatives Based on company assessments and NRC inspection findings, PSE&G concluded that there was a need to*obtain further I assurance that the Salem Generating Station design and licensing basis documents are current and that the station would be maintained and operated within its design and licensing I bases. As a result, in July 1996, PSE&G initiated the FSAR Project.

I The FSAR Project involved several new initiatives to evaluate design and licensing basis information. These included reviews of the licensing basis requirements and commitments embodied I within the UFSAR (particularly the safety analyses found in Chapter 15), the Technical Specifications, and plant engineering and design documents (including drawings, calculations, test I procedures and specifications). These efforts supplemented several other parallel assessments of current system configuration and operation to assure consistency with the I documentation.

The new initiatives included:

• A UFSAR Chapter 15 Safety Analysis Review I

• A Macro Review of 46 UFSAR System Descriptions I

• Vertical Slice Inspections of Select Systems

• A Review of NRC Safety Evaluation Reports (SERs)

I Associated with Technical Specifications

• Screening and review of selected Deficiency Evaluation I Reports (DEFs)

• A Review of Engineering Evaluations (EEs) and Justifications I for Continued Operation (JCOs)

The relevant parallel programs, some of which are ongoing, include:

• Configuration Walkdowns 3

I

I

• The Technical Specification Surveillance Improvement Program (TSSIP)

• Emergency Operating Procedure (EOP) Upgrade Program

• Configuration Baseline Document (CBD) Validation I

• Maintenance Rule Implementation The new initiatives and parallel programs listed above are I explained in more detail below.

New Initiatives UFSAR (Chapter 15) Safety Analysis Review I This review encompassed the relevant system and component I inputs and assumptions (or parameters) that underlie the accident analyses found in Chapter 15 of the UFSAR. The parameters were validated against the appropriate calculation, I surveillance test, or other supporting documents. Where the parameters could be validated, they were documented in a matrix with their associated reference. Where they could not be I validated, an Action Request was initiated.

UFSAR Macro Review of 46 Systems UFSAR macro reviews were incorporated into system readiness reviews. This effort encompassed the 46 systems identified for I maintenance rule implementation. For each system, the UFSAR description was reviewed for primary system parameters (pressure, temperature, flow, etc.) and attributes (single failure I considerations, seismic classification, etc.). The parameters and attributes were compared to the Chapter 15 analyses, Technical Specifications, other UFSAR chapters, and configuration I drawings or documents. Deficiencies or discrepancies were addressed by Action Request. {This review is part of the System Readiness Review process discussed in a separate Restart I Briefing Paper.)

Vertical Slice Inspections on 7 Systems I As part of the UFSAR Project, vertical slice reviews were conducted for seven safety-significant systems. (Vertical slices were originally conducted for four additional systems as a pilot project. These pilot reviews were more limited in scope and depth and are not credited, but do provide some added assurance.) The seven systems for vertical slice review can be separated into two basic categories:

4 I

I Non-Ventilation Svstems

~

• Spent Fuel Pool Cooling

• Safety Injection

• Reactor Protection System Ventilation Svstems I

• Auxiliary Building Ventilation

• Fuel Handling Building Ventilation I

• Containment Building Ventilation Miscellaneous Ventilation Systems (Intake I Structures, Emergency Diesel Generators, Switchgear & Penetration)

I The vertical slice approach utilizes a multi-disciplinary team that systematically starts with a review of licensing basis information (e.g., UFSAR, licensing correspondence) and then evaluates the I fidelity of that information to associated design documents (e.g.,

calculations, drawings, design packages) and the implementation or operating bases (e.g., operating and emergency procedures, .

I testing, safety evaluations) documents. Where potential problems are identified, the team goes further into review of support systems or other interfacing areas (e.g., Motor Operated Valves (MOVs), fire protection). This technique has been used successfully by the NRC in major team inspections such as Safety System Functional Inspections.

I Deficiency Evaluation Form (DEF) Closure Reviews I A technical review of previously closed DEFs addressed whether licensing and design bases issues were appropriately handled in DEF closure. This encompassed DEFs related to 16 safety I analysis systems. Approximately 1, 700 DEFs were screened and, as a result, approximately 500 reviewed.

I Engineering Evaluations (EE) -Justification for Continued Operation (JCO) Reviews I The FSAR Project encompassed screening of EEs used to support past JCOs to assure that EEs were appropriately dispositioned and did not impact system readiness.

5 I

I Safety Evaluation Report (SER) Reviews NRC SERs associated with NRC license amendments issued through May 1996 were reviewed to assure that they have been correctly incorporated into the UFSAR.

Parallel Several initiatives, parallel to those described above, contribute Programs to the reasonable assurance that design and licensing basis information is either already correct or will be corrected in a timely manner. While it is likely that some discrepancies will I remain to be identified as these programs continue, the scope of completed efforts and the results achieved provide the assurance that safe operation will not be impacted.

I Configuration Walkdowns I Configuration walkdowns are conducted by System Managers as part of System Readiness Reviews. (These are mentioned in the separate Restart Briefing Paper on the System Readiness I Review Process.)

I In addition, the Nuclear Engineering Design organization recognized the need to address configuration control-related (CCR) Incident Reports. As a result, that organization initiated configuration control walkdowns of systems considered important to safety and to reliable operation. From the outset, the configuration control walkdown project was aligned with the I System Readiness Program. At the end of each system walkdown, a conformance meeting was held in which the walkdown team reviewed their results with the System Manager I and his Design Engineering counterpart. These conformance meetings assured alignment on CCR issue resolution.

I Although the primary focus of the walkdown effort was to verify the as-built piping, instrumentation, and electrical configuration against plant Piping and Instrument Drawings (P&IDs) and I Electrical Schematics and/or One-Line diagrams, supplemental efforts addressed specific configuration issues previously noted in Incident Reports (e.g., sampling pipe flange and bolting I material). Final closure and acceptance of CCR issues will be made prior to the restart of the Salem units.

I Technical Specification Surveillance Improvement Program (TSSIP)

PSE&G initiated the Salem Technical Specification Surveillance

. Improvement Program (TSSIP) to evaluate the quality of the 6

I

I Technical Specification surveillance program. Specifically, TSSIP is designed to review the surveillance testing program to enhance administrative controls, assure proper scheduling and tracking of surveillances, and validate the implementing procedures, with certain exceptions, for Technical Specification surveillance testing requirements.

I TSSIP is being performed in two phases. Phase 1 will be completed at each unit prior to unit restart. To carry out Phase I 1, the Technical Specification surveillance requirements (including conditional requirements and the associated trigger mechanisms, but excluding Section 6.0 Administrative Controls)

I were identified and placed into the Technical Specification Cross Reference Matrix. Use of the matrix format indicates the appropriate implementing procedure/surveillance requirement I relationship. Approximately 1,000 Technical Specification surveillance requirements were identified and reviewed during the Unit 2 Phase 1 process to ensure the matrix was complete, I that recurring tasks were in place for each Technical Specification surveillance testing line item, and that the correct mode was referenced for each line item.

I A general review was performed of the associated implementing procedures. This review involved a comparison of the Technical Specification surveillance requirements against the procedure and its purpose statement and acceptance criteria. This review was designed to validate that the implementing procedure I accurately reflects and references the surveillance requirement, and that the stated acceptance criteria are consistent with the associated Technical Specification.

I As of May 1997, the TSSIP reviews resulted in approximately 80 Requests for potential conditions adverse to quality, and I approximately 790 revision requests for procedure enhancements. TSSIP also reviewed surveillance procedure revisions and Technical Specification amendments for potential I impacts on surveillance requirement implementation. For conditional surveillance requirements, the TSSIP review focused on ensuring that the appropriate initiation (trigger) mechanism is I in place such that each conditional (or event-driven) surveillance requirement is recognized and implemented.

I Phase 1 also included a scheduling review. This involved a comparison of each surveillance-related Managed Maintenance Information System (MMIS) Recurring Task against the Technical Specification requirements and a detailed evaluation of mode transition controls and verifications. This provided 7

1

I assurance that surveillance requirements are scheduled at the appropriate frequency and performed in the correct modes or conditions.

Phase 2 of TSSIP will involve longer-term initiatives including a detailed review of the technical adequacy of the specified surveillance procedures and development of a basis for I compliance with each surveillance requirement. This phase encompasses reviews committed to in our response to Generic Letter 96-01. Further Phase 2 actions may include evaluation of I testing requirements identified in the Updated Final Safety Analysis Report (UFSAR) as well as evaluation of a methodology to ensure continued technical accuracy of Technical I Specification implementing procedures following TSSIP. Phase 2 is scheduled to be complete by the end of 1997.

I Emergency Operating Procedure (EQP) Upgrade Program I A project was specifically organized in January 1996 to direct and manage a review and upgrade of the EOPs. The review specifically incorporated lessons learned from NRC EOP I inspections (e.g., NUREG-1358) and industry experience (e.g.,

INP0-83-004, INP0-83-006). The EOP verification and validation has been completed, and EOPs have been upgraded and successfully utilized during simulator scenarios with crews during restart training.

I Configuration Baseline Document (CBD) Validation Design Basis information in the CBD's will be validated as part of I our Design Basis Review Project described in our letter to the NRC dated May 14, 1997.

I Maintenance Rule Implementation Another initiative involving reviews of design and licensing basis I information at Salem Generating Station has been the implementation of the maintenance rule. The scope of the maintenance rule, 10 CFR 50.65, is based upon system I function(s) with regard to safe shutdown and 10 CFR Part 100 considerations. The FSAR was used as a "first cut" at system function verification/validation at Salem. Risk significance was I then determined on the basis of applicable Core Damage Frequency. The system functions, and associated risk significance, were verified by the respective System Managers,

- 8 1

I as well as reviewed and approved by an Expert Panel comprised

~

of qualified Operations, Engineering, Maintenance, and Nuclear Safety Review members.

Process Several existing processes are important for maintaining Improvements configuration and design/licensing basis documentation in the future. In this regard, several process evaluations have been I conducted at Salem, including the following:

• 10 CFR 50.59 Safety Evaluations I

• 10 CFR 50.90 License Change Requests

I

• Design Calculations and Analyses I

• Configuration Baseline Documents

• Engineering Programs I

• Procedure Change Process I

• DCPs/Drawings/ Temporary Modifications (TMODS) o Self-Assessments

• Corrective Action Program I

• UFSAR Revisions and Maintenance

• Commitment Tracking I Evaluations of these processes have in many cases resulted in enhancements and upgrades that reflect NRC guidance and I industry best practices. There also has been training on the new or enhanced processes. These efforts provide added assurance I that design and licensing basis information will be properly maintained in the future.

I Results Based on the various activities described above, as well as the system readiness reviews described separately, PSE&G believes with reasonable assurance, that the units will operate within their I respective design and licensing bases.

- 9 I

I FSAR Project The initiatives of the FSAR Project have validated the licensing Improvements basis commitments against the UFSAR, Technical Specifications,

- Chapter 15 safety analyses, and plant engineering and design documents. The actual plant configuration is also substantiated on an ongoing basis by walkdowns, EOP upgrades, maintenance rule implementation, and the TSSIP program.

1 The NRC has been briefed on the efforts of the FSAR Project and performed its own assessment. As noted in an Inspection Report of December 31, 1996, the NRC observed portions of the I FSAR Project in progress and reviewed a sample of its outputs.

The NRC found the project to be a substantial effort that was well-managed, with "well-focused elements of independent I confirmation." To provide its own assessment of PSE&G's efforts related to design and licensing basis information, the NRC also initiated an SSFI. Findings from this assessment will be I addressed.

TSSIP Results The Phase 1 TSSIP review for Salem identified about 1,000 Unit I 2 Technical Specification surveillance requirements. This resulted in a Phase 1 review of over 900 Unit 2 and common I Technical Specification implementing procedures. TSSIP also reviewed approximately 1,300 Unit 2 MMIS Recurring Tasks, as well as all departmental mode transition procedures and Technical Specification conditional surveillance trigger mechanisms (approximately 250 of the line item Technical Specification surveillance requirements are conditional). As of I May 1997, the TSSIP team has written and submitted:

• approximately 790 revision requests to clarify or modify I surveillance procedures;

• approximately 1,300 requests to update or revise Technical I Specification information in MMIS; and

• approximately 80 Action Requests to document conditions I adverse to quality.

The issues identified to date have not had plant safety I consequences, but those deficiencies identified that could have safety implications have been or will be thoroughly evaluated prior to restart.

I

- 10 1

I Vertical Slice As discussed above, PSE&G performed vertical slice inspections Review Results on seven systems.

• For the non-ventilation systems, only two Level 2 Action Requests (ARs) were initiated related to spent fuel pool issues.

I

• For the ventilation systems, a number of ARs were generated.

Of particular concern was the Auxiliary Building Ventilation system. As a result, safety significant ventilation systems, I except Control Area Ventilation (currently undergoing major renovations), were evaluated. Further review of these systems will continue after completion of the FSAR Project.

I Correction of the restart-required ventilation system ARs will provide reasonable assurance of operation within the licensing and design bases.

I Chapter 15 Safety The Chapter 15 safety analysis review demonstrated a high

.I Analysis Results degree of consistency and accuracy in the input and assumptions associated with systems and components. During the Chapter 15 Safety Analysis Review alone, I

• slightly more than 400 inputs and assumptions (or parameters) were reviewed, and approximately 87 percent were determined to be without deficiencies, except for several minor clarifications identified for future resolution.

I the remaining parameters, i.e., approximately 13 percent, were not acceptable because either: (1) the associated calculations had not been finalized (this was limited to the Control Area I Emergency Air Conditioning System) or (2) the source documents were unavailable.

I UFSAR Macro The UFSAR Macro reviews of 46 important-to-safety systems Review Results revealed a number of minor deficiencies but no major issues.

Approximately 97 percent of some 2,000 system attributes were I reviewed and validated with no problems. These results, when coupled with the vertical slice results, provide reasonable assurance that the plant can and will be operated consistent with I the licensing and design bases.

Section 50. 54(f) On October 9, 1996, the NRC's Executive Director for Operations I Response sent a letter to all licensees pursuant to 10 CFR 50.54 (f),

requesting information. The NRC's request encompassed a description of:

• Processes for engineering and design control; 11 I

I

• Processes that assure that design basis requirements are translated into operating, maintenance, and test procedures;

• Rationale for concluding that the plant configuration is consistent with design and licensing basis requirements; and I

• Processes for the identification and correction of non-conformances.

I PSE&G's response to this Section 50.54 request overlaps, in many ways, the information provided above.

I Conclusion PSE&G has conducted a number of specific new initiatives directed at assuring the accuracy of design and licensing basis I documents. These initiatives are supplemented by several ongoing programs that involve review and validation of design and licensing basis information. Together, these activities I provide reasonable assurance that the station will be operated within appropriate design basis limitations and that documentation is substantially up-to-date. Ongoing programs I provide a mechanism whereby remaining issues will be identified and addressed. As a result of evaluations and upgrades, improved processes are now in place to maintain the licensing and design basis in the future.

I I

I I

I I

- 12 I