ML20117C430
| ML20117C430 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Salem |
| Issue date: | 11/02/1983 |
| From: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Du Pont P DELAWARE, STATE OF |
| Shared Package | |
| ML20114F930 | List:
|
| References | |
| FOIA-84-616 NUDOCS 8505090423 | |
| Download: ML20117C430 (15) | |
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S neoloN I S3I PARK AVENUE Kiwo or Prussia.pawnsvi.vania se4es NOV 2 1983 The Honorable Pierre S. du Pont Governor of Delaware Dover, Delaware 19901
Dear Governor du Pont:
This letter answers the questions you asked about the Salem Nuclear Generating Station during our conversationt
'.n your office on September 13, 1983. At that i
meeting you asked for an analysis of the performance of the Salem plants in comparison with other nuclear power plants in this region.
One indicator of nuclear plant performance is the number of events at the plant that are reported to the NRC. Most of these reports are required to be made under thq, terms of each plant's operating license. Our review shows that both Salem, Unit I and Unit 2 had a higher-than-average number of event reports in 1981 and 1982, when compared with six other plants of similar design and age.
Part of the reason for this higher number of reports is that the utility, Public Service Electric and Gas of New Jersey (PSE&G), has established its own additional criteria for deciding when to report events to the NRC. Thus, some of the events reported by Salem (and often reported in the news media) are events that do not have to be reported to the NRC by other plants whose re-porting policy is essentially limited to meeting the NRC requirements written into their operating licenses.
' Another indicator of plant performance is how often the plant is automatically shut down (tripped). Here, again, we find that both Salem Unit I and Unit 2 had a higher-than-average number of trips, in 1981 and 1982, than did other plants of similar design and age. The relative frequency of occurrence of these plant trips is not a measure of risk to the public. Rather, it is an indicator that an important safety system, the Reactor Protection System, was called upon to shut down the plant for some reason. It was the failure of this system to work as expected, because of circuit breaker problems, in February 1983, that gave us such concern over that particular incident. This led the company to institute reforms in site operations that are discussed in greater detail in Enclosure 2 to this letter. The NRC levied an $850,000 fine that the company a few days ago announced it would pay.
Another useful indicator of plant performance is the annual Systematic Assess-ment of Licensee Performance (SALP) that we carry out for every nuclear power plant licensee. This assessment helps us to evaluate the licensee's performance in several areas, including plant operations and emergency preparedness. I have looked at the record of SALP reports for Salem Unit I and Unit 2 for 1982 and find their performance to have been average compared with all other Westinghouse-designed plants in our region. Nonetheless, the reactor trip breaker failure last February clearly showed that improvements were needed in management control at the site and in the carrying out of better quality control proce-dures. In response to our recommendations, PSE&G has developed an action plan for the improvement of Salem operations, and we are continually reviewing the implementation of this plan.
8505090423 841002 PDR FOIA BARFIEL84-616 PDR 7
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The Honorable Pierre S. duPont 2
Enclosure I to this letter provides a more detailed answer to your questions about how Salem compares with other plants. Enclosure 2, which I extracted from the two-inch thick report on the safety evaluation performed by the NRC staff before permitting the restart of Salem Unit I after the circuit breaker failures, goes into greater detail about the important safety considerations involved in our decision to allow the resumption.of operation, which you also had asked about.
i Regarding your expressed concern about the adequacy of Emergency Preparedness at the Salem site, after discussions with members of your staff and with the licensee, and after observing the drill of October 26, here is how I see it.
Compared with last year's drill, communications between the licensee's Emer-gency Operations Facility (EOF) and the Emergency Operations Center (EOC) of the State of Delaware have improved. Backup radio systems were tested in this recent Salem exercise. Your staffs in the Department of Public Safety and the Division of Emergency Planning and Operations, have told us that they now believe the other issues also have been resolved. Your consultants in emergency i
planning gave good and valuable support to your staff during this exercise. My staff found in the October 26 exercise that communications between the Salem EOF and the Delaware EOC were excellent.
I appreciated the opportunity to meet you and to hear personally your concerns i
with the Salem plant. My staff and I will continue to work closely with your
, staff in the Department of Public Safety and the Division of Emergency Planning and Operations so that we may continue to improve our mutual preparedness to deal with any emergencies that may occur at the Salem site.
-I will be glad to answer any further questions you may have. Please feel free to have members of your staff contact the Director of my Division of Project and Resident Programs, Richard W. Starostecki, for technical discussions of the enclosed reports.
Sincerely, l
Thomas E. Murley Regional Administrator
Enclosures:
1.
Evaluation of Management and Operations of the Salem Nuclear Generating Station 2.
Summary of NRC Ealuation of PSE&G Management Problems Involved in February 1983 Circuit Breaker Failures
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- ENCLOSURE 1 Evaluation of Management and Operations of The Salem Nuclear Generating S.tation The basic NRC program for evaluating overall licensee performance is the annual Systematic Assessment of Licensee Performance (SALP) conducted for each nuclear power plant. This process involves NRC Regional Management review of overall licensee performance in different functional areas of the company's responsi-bilities at the site. during the report year. In each area, consensus is reached among NRC staff participants in assigning a " grade" of Category I, II, or III.
Category I indicates a high level of performance where reduced NRC attention may be appropriate. Category II indicates NRC attention is appropriate to the level of performance by the company. Category III indicates a level of per-formance needing increased licensee and NRC attention. The premise is that overall performance, whatever the grade, is at least acceptable. If it were not, the NRC would already be taking action to either order a shutting down of the plant, or other enforcement action to achieve an immediate restoration of acceptably safe operation.
A comparison of Salem's last SALp, completed in the fall of 1982, with contem-porary evaluations of the remaining plants in the country, supports a con-clusion that the Salem plants are neither exceptionally good nor exceptionally
, bad. Table l'provides a comparison of SALP results for Salem against the results of other Region I plants for calendar year 1982. The comparison addresses only Region I plants because NRC Region I management is involved in the SALP process for Region 1 plants. The SALP process leans heavily on professional judgements arrived at through factual on-site experience and periodic NRC Licensee management-to-management contacts over operational issues.
The frequency of events which automatically shut down (trip) the plant provides a basis for one sort of performance comparison among plants. The Westinghouse design incorporates more automatic trip signal initiating systems, and there-fore more likelihood of a trip, than do other PWR designs. Comparing Salem against non-Westinghouse PWRs would not provide any meaningful information.
Also,;the frequency of reactor trips is not indicative of the level of risk that the plant poses to the public. Reactor trips are more closely related to the reliability or availability of the plant for operation. A proper evaluation of plant risk requires a comprehensive and integrated study of the sequences of events which can lead to accidents that are accompanied by radiation released that would endanger the public. Such a study, called probabilistic risk analysis, has not been performed for Salem. The NRC staff has considered the possibility of requiring all plants in the country to perform such an analysis, to be submitted for NRC review, but no decision has been made on this internal proposal.
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The following table compares the frequency of reactor trips at Salem with other 4
relatively new, Westinghouse PWRs, beginning in 1981. Although the data indi-cate that the Salem units have experienced more reactor trips than the average
- of similar Westinghouse PWRs,,the results for 1983 are biased in that both Salem units were restarted after extended outages. It is expected that right after.long outages, reactors will experience more trips than they will after many months of running. Nonetheless, the data from 1981 and 1982 do indicate that the occurrence of trips at Salem is high.
REACTOR TRIPS i
(Average trips per Reactor, Per Year) 1981 1982 1st Half-1983
- 4-lo'op West. Plants 9.2 5.8 2.8 Salem 1 21 8
5 Salem 10**
13 5
- Represents Averages of Six 4-loop Westinghouse Plants other than Salem
- Began commercial operation - 10/81 We have examined the causes of the Salem trips. Thirty-nine percent of the trips at Salem occurred at less than 20% power, indicating that a relatively large percentage of trips occur during startup or shutdown operations while the plant is not producing a significant amount of power. About 71% of the trips result from disturbances in the feedwater system (which is not part of the reactor primary system). Usually, this causes rapid changes of water level in l
part of the steam-making machinery called the steam generator. The steam generators are the principal means of removing the heat generated by the reactor. Severe imbalances between the rate of steam generation and of the c
makeup water jeopardize the ability to cool the reactor core. Therefore, when i
the water level sensors measure a low level of water a signal is sent to automatically initiate a reactor trip. This reactor trip can be viewed as anticipatory. The machine's logic assumes the cause of the fluctuating water level could be either a large leak from a broken steam pipe, a loss of the makeup water (feedwater) pumps, or a broken feedwater pipe. The resulting signal then shuts the plant down to reduce heat in the reactor and to conserve water for the other three steam generators after the leaking pipe has been isolated. Perturbations in the feedwater systems can happen at both high and low power, with loss of feedwater pumps being the principal cause of steam generator water level trips at. high power. At low power, operator error is the most common cause of fluctuating feedwater trips. Usually, an operator has failed to match feedwater supply to steam demand. As a result of problems with Salem's steam generator feedwater system, the staff expressed concern to PSE&G.
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3 Early in 1982, both at the staff's urging and on his own initiative, the licensee began taking steps to. stabilize the performance of the feedwater systems at both Salem units. The licensee recently improved the feedwater bypass. control system, installed additional steam generator feedwater flow instrumentation in the control room and, by license amendment, modified the steam generator level reactor trip setpoints to allow more margin for the operator to control steam generator level. Similarly, the licensee has also taken action to increase feedwater pump suction pressure which should help to reduce instances of loss of feedwater pumps and associated reactor trips. In addition, the Salem simulator, which is almost ready, will provide the opera-tors an opportunity to develop their low power operating skills. Control of feedwater during low power operation is a manual process and requires consi-derable operator skill gained only by experience. While the results of these initiatives remain to be seen, we expect that when all this has been done, fewer feedwater problems and, therefore plant trips, should occur.
Another quantitative method of comparing reactor facilities involves counting the number'of events reported to the NRC. These required reports are princi-
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pally of three types: reports to be made within one-hour, on the telephone to the NRC Headquarters Duty Officer; prompt reports (within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) usually to the Regional Office and Headquarters, usually a letter-form sent by telecopier;
-and 30-day written reports to the Regional Administrator. The latter two. types of reports, called Licensee Event Reports (LERs), are required for specific kinds of events and the requirements are written into are the facility Techni-cal Specifica~tions, which are part of the operating license. The 30-day LERs constitute the majority of the reports submitted. Typically, 30-day reports describe a degradation in emergency system availability for a limited period of time that is stipulated by the Technical Specifications. For example, if one train of two redundant otherwise fully operable emergency systems becomes 4
inoperable because of equipment failure, the situation would require a 30-day report. From a risk standpoint, however, should an accident occur when one train is inoperable, the remaining system is fully capable of achieving safe shutdown or adequately cooling of the core. Situations in which total system function (both trains) are or may have been lost would require a prompt report.
The technical specifications also may impose a time limit, after which one out of two or one out of three redundant systems is no longer enough to justify continued safe operation and the plant is manually shut down. That shutdown may require a prompt report before the 30-day limit on reporting the original problem expires.
Analysis of LERs, in general, reveal that the number of reportable situations is a function of specific facility Technical Specifications and plant design.
Accordingly, newer and larger PWRs such as Salem, with more safety systems, tend to report more often than the older plants having less comprehensive requirements. We have attached Table 2 which shows the frequenfy of LERs for PWRs that were licensed at approximately the same time as Salem. The data indicate that Salem, especially Salem 2, reported more occurrences than most other PWRs subject to similar requirements. It appears that Salem is subjected to more than an. average number of occurrences. However, having reviewed many individual LERs provided by Salem and by other plants, the NRC staff has concluded that the Salem management is more conservative than most plants in 4
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4 determining what will to be reported and what will not be reported. We find that many '.ERs were written for repeated problems involving certain equipment that eventually was modified by design change to correct the problems. This happened in the case of the frequent leaks and oth.er problems in the contain-ment cooling system fan coil units at Salem. Forty-seven LERs were written in 1982 on Unit 2's problems with these cooling coils. During the refueling outage, all these coils on Unit I and 2 were replaced with coils made of more corrosion resistant materials. That appears to have corrected the problem of leaking cooling, coils and to have sharply reduced the number of LERs. We already know that'the number of events reported by Salem this year are fewer than during the same time period last year.
One-hour reports to the NRC Headquarters Duty Officer are required for those types of events which may require an immediate NRC response. These include all reactor grips and any implementing of the facility Emergency Plan. Even the lowes) level of Emergency classification, called an " Unusual Event," is defined as an event for which there is a potential degradation of the level of safety at a plant, and declaring an " Unusual Event" requires an immediate phone call to the NRC Headquarters Duty Officer. The call usually is made on the Emergency Notification System telephone, a dedicated " hot line" linking each nuclear power plant control room in the country directly to our Headquarters Operations Center.
PSE&G has established a comparatively low threshold for declaring occurrences
,at Salem to be Unusual Events. That declaration requires calling local and state officials and others, and often. includes or leads to calls to the news media. Other not-so-serious events receive widespread media attention even though they are not serious enough to require a formal report to the NRC.
Resident NRC inspectors are informally told a great deal and would tell the licensee of a reporting requirement if it had not been met. Just telling the Resident Inspector usually does not fulfill the reporting requirements. As a result of frequent wide publicity, Salem may be perceived as more trouble prone than other facilities experiencing the same types and numbers of events but generating fewer reports.
For example, the Salem Emergency Plan specifies that any unit trip, (planned or unplanned) from greater than 20% power, has to be declared an Unusual Event.
This is a more conservative requirement than that of the NRC. Most other l
facilities adhere strictly to the NRC guidance, which does not require declaration of an unusual event just because of a reactor trip, even at full pcwer. It is i
the nature of the cause of the trip that may trigger an emergency declaration.
1 Last April 16, a number of workers inside the Salem Unit 2 containment were subjected to unexpected, but low levels of airborne contamination. The highest exposure was 5 percent of NRC limits. The event did not meet any criterion of the site Emergency Plan, nor was it significant enough to require a report
5 under NRC Regulations. However, PSE&G filed a written report with Region I within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (not required) and notified both states, although no unusual event was declared. News media became aware of the event about 8 to 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> after it occurred, and it was widely reported by the media.
Another event, on May 13, involved a spill of about 100 gallons of low level contaminated water onsite. The water was contained and did not leave the site and, correctly, the Emergency Plan was not invoked. Since the occurrence identified a lap.s.e in administrative controls which could have resulted in an offsite release, the licensee made the required reports to NRC. These two events are examples of occurrences which are expected to happen now and then at operating facilities. These kind of events by themselves do not present a threat to public health and safety. Both the company and the NRC analyzed the events to search for weaknesses in plant operations so that corrective action could be,taken to see that these possible weaknesses did not lead to more seriops events. It is the repetition of similar events and underlying common causes of trouble that are of greater interest to us.
The NRC expects the licensee to analyse any trends of problems, to examine the patterns of failure, so that corrective actions will be taken in time to prevent recurrence. The NRC performs its own' analysis of the causes of events reported in LERs, and the results become an integral part of the SALP process. The qualitative judgements arrived at by the SALP, the results of NRC inspections, and the NRC's daily interaction with plant management by the resident inspectors provide what I believe to be a sound basis for concluding that Salem management and staff are
, competent to operate the facility without undue risk to the public health and safety.
PSE&G has acted in the past two years to further improve the technical support available at the Salem site. The utility has transferred engineering and Quality Assurance staff from the corporate offices in Newark, to the site. We consider such initiatives to be positive steps, but the pace of these steps has been relatively slow. We continue to review and closely monitor the licen-see's actions to assure that proper staffing and good technical integration of all support functions with the operating organization continue in order to achieve a better level of overall operation of these nuclear plants.
Attachments: (1) Table 1 - Region I CY82 SALP Results (2) Table 2 - No. of LERs (1981,1982) comparison e
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TABLE 1.- REGION I CY 82 SALP RESULTS A.
ALL REGION I OPERATING PLANTS Areas Evaluated Number of Plants in each Category Category 1 Category 2 Category 3 Plant Operationi" 7
10 3
Radiological Controls 10 6
3 Maintenance 8
10 2
Surveillance 10 7
2 Fire Protection 9
8 2
11 0
Security / Safeguards 10 8
2 Refueling 8
7 Licensing 9
10 1
B.
SALEM 1 & 2 (1982 SALP)
Category 1 Category 2 Category 3 Areas Evaluated Plant Operations X
Radiclogical Controls X
Maintenance X
Surveillance X
Fire Protection X
Security / Safeguards X
Refueling X
Licensing X
d e.
TABLE 2 - NUMBERS OF LERs COMPARISON 1981 1982 Salem 1 122 93 Salem 2 131*
157 Plant A 194*
94 Plant B 90 80 Plant C 70 67 Plant D 89 88 Plant'E 170*
i Plant F 75 118 Plants A-F are large PWRs licensed within the last several years Denotes prior to commercial operation e
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ENCLOSURE 2 A Summary of the NRC Evaluation of PSE&G Management Problems Involved in the February 1983 Circuit Breaker Failures at Salem Units 1 & 2 Following the Salem circuit breaker failures in February 1983, the licensee (PSE&G), at the staff's request, agreed to keep both Salem units shut down until plant startup was approved by the NRC. A detailed NRC staff review was undertaken of the events and their causes. As a part of this effort, the staff focused on those problem areas requiring prompt attention and remedial action by the company before restart could be allowed. Because acceptable corrective actions were taken, the startup of Salem Unit I was authorized, and the basis for permitting that return to operation was documented in the Restart Authort-zation Safety Evaluation published on April 29, 1983. This excerpt from that report summarizes the collective NRC staff perception of the licensee's manage-ment capability prior to the ATWS events. In addition to short term remedial actions, the staff also required a longer term program to more systematically review and upgrade the management structure, including control systems. While the management structure was, and is, considered safety-oriented, the licensee agreed to undertake a major corrective action program which includes subjecting the utility to a number of third party evaluations and other initiatives to further improve station management. This approach allows a more structured approach that should lead to longer-lasting improvement of organization, staffing and control systems.
The third party reviews, particularly the management diagnostic evaluation and quality assurance assessment by the Management Analysis Company, and a correc-tive action program assessment by the BETA corporation, have been completed and submitted to the NRC. These reviews recommended many improvements that warrant PSE&G attention and long term corrective action. The licensee recently sub-mitted to the NRC an action plan to address each deficiency or recommendation cited in these third party reviews. We are now reviewing this action plan. We have already found that these reviews have not identified any deficiencies of sufficient magnitude to require urgent attention.
Also addressed in the staff's Safety Evaluation were misclassification of procurement documents and maintenanc'e work orders that may have contributed to the reactor trip breaker failures. After exhaustive review of practically all such documents by the licensee, and independent verification by the staff, no misclassifications were found that would have caused problems with equipment important to plant safety. This provides some evidence that the reactor trip breaker incident was not indicative of a total management breakdown.
l Tre excerpt from the Salem Restart Safety Evaluation Report follows:
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b C.9 Ovira11 Manacement Capability and Performance The initial deficiencies identified during the review of circumstances sur-rounding these events raised questions about the responsiveness, practices and capability of licensee management at the corporate and station level.
As noted in the preceeding section (C.1 through C.8), a number of specific manage-ment issues directly related to the failure of the reactor trip breaker event were identified and have been evaluated.
Although each of the specific pro-blems is understood and has been resolved, it is necessary to consider the overall management capability and performance in a broader context.
The staff has re-examined the performance of PSE&G over the last few years from a regula-tory prespective.
Salem Restart SER 36
On the one hand, there are se.veral good aspects of the licensee's efforts that are beneficial and are indicative of a licensee that is striving to develop Some examples include:
a computerized thoroughly satisfactory practices.
J tagging program, independent verification program for system lineups, oiniaturized control room design, and a computer scheduling system for Our examination generally concludes-surveillance testing and maintenance.
that the licensee has devoted resources and developed noteworthy programs to support operation of the Salem facility.
)
Historically, however, PSE&G management has not displayed the expected aggressive effort to self evaluate and redirect efforts to correct internally identified problems.
However, the licensee has responded to the specific evaluations conducted by external organizations pur.h as INPO, NRC and consultants.
The 1981 INPO evaluation identified opportunities for improvement in numerous areas including staffing, personnel safety practices, adherence to procedures, control of documents and design changes, availability of technical support, cperating gractices with respect to inoperable alarms and tagouts, shift turnover procedures, and goals and objectives.
Based on continuing observa-tion, the licensee responded positively to selected findings by various actions, although the effectiveness of these actions has been less than oxpected.
Four SALP assessments were conducted by the NRC during the period October The earlier assessments identified weaknesses in the areas t
1980-October 1982.
design change documentation, engineering support responsiveness, health of:
physics, physical security and overall management followup in numerous areas.
The later SALP assessments acknowledge licensee management attention to, and l
improvements in the areas of design change tracking and documentation and health physics.. Physical security, despite several initiatives on the part of I
the licensee to improve the area,* continued to be weak.
Very recently, the licensee has dedicated considerable resources to physical security which, if properly implemented, should facilitate a number of hardware improvements and add several managers to the organization to more effectively monitor security activities on a day-to-day basis.
The most visible li':nsee initiatives are organizational. During the licensing process fo. Salem Unit 2 in 1981, the licensee made a decision to place all activities, including engineering under a single vice president.
Commitments were made to relocate these activities from the corporate offices While the in Newark.. New Jersey to the site located in southern New Jersey.
licensee was hopeful that such relocation of the engineering staff, including QA personnel, to the site would prove more effective, the process has moved much more slowly than hoped and has resulted in the loss of certain personnel.
i In January 1983, the 0A department was placed in the Nuclear Department, and began moving to the site. The organizational and location changes have been in transition for almost 18 months.
The maintenance, operations and technical departments are led by experienced Operational management contrnis have been progressively middle managers.
strengthened over the past few years and have addressed problems as they are identified. Similarly, maintenance department controls have improved and new l
1 37 Salem Restart SER
s initiatives have been instituted for the conduct and planning of caintenance which recently has resulted in more comprehensive review of proposed maintenance In addition, the licensee has reduced the bargaining unit employee activities.
to supervisor ratio to 10 to 1 in order to improve direct supervision of work in progress.
However, the support groups, in particular maintenance and engineering, tend to be too isolated from one another and, therefore, their collective efforts are not well integrated in overall station operation.
In the staff's view this has resulted in a degree of parochialism.
Conse'quently, the staff's perception is that poor communications among the various departments has hindered the development of a sensitivity within the station staff to identify and resolve problems that are outside their direct sphere of influence.
Over the past two years durng which Public Service Electric and Gas Company (PSE&G) has operated two nuclear plants at the Salem Generating Station, it has developed improved programs and procedures that are consistent with industr,y standards.
This observation is based on an overall review of NRC inspection reports and taking cognizance of INPO evaluations.
Notwithstanding such progress, the staff has noted in its SALP reviews that the licensee needs A problem to devote more effort to take steps to make such programs work.
which had previously been addressed with the licensee during enforcement i
conferences and SALP results meetings and has been noted during this evalutaion, is one of high level station management and first line station l
supervision failing to adequately assess the performance of their subordinates, Historically, improper especially with respect to adherence to procedures.
performance or violation of station procedures did not result in any adverse actions to the involved individuals.
Generally, it has been observed that poor performance was mildly critized, then rationalized.
Also, first line supervisors appear to refrain from raising issues outside of their defined scope of responsibility and their effectiveness is seldom monitored.
As a result, department managers may not be cognizant of problems requiring their attention.
The licensee has now initiated a training program for first-line supervisors which will include supervisory skills, procedures, programs, quality assurance and systems training. The program will include a discussion of corrective discipline actions available. The trianing program will be completed for new supervisors prior to assignment and will be provided to all existing supervisors.
A similar training program The program is expected to start in September 1983.
for senior supervisors is to be developed by October 1983.
When balancing the various aspects with the issues identified herein, it is clear that some problems remain. One of the purposes of the staff examination was to ascertain whether there were major flaws in the licensee's approach.
During the fact-finding team review during the first week of March 1983 and concurrent analysis of the breaker failure events,' licensee treatment of the reactor trip breakers and the circumstances surrounding their failure on February 22 and 25, provided the NRC staff with several indicators suggesting a major breakdown in management and quality assurance program implementation at the Salem Nuclear Generating Station.
Subsequent detailed reviews and evalua-tions by the licensee and the NRC staff have confirmed that the programs in place are basically sound.
Two aspects of these programs surfaced as the t.1.m Restart SER 38 j--
6 principal causes of the events discussed in this safety evalu'aticn.
The first of these was a perceived lack of resolve on the part of managers and supervisors in enforcing adherence to procedures by station personnel.
The second aspect relates to the safety perspective displayed by corporate management in pro-viding ' policy direction and priorities to the operating staff and the three existing review committees.
It is clear that the numerous initiatives undertaken by PSE&G during the last few years have not yet been fully implemented.
In order to assist PSE&G in making the transition successful and to further analyze their difficulties, an independent consultant firm, Management Analysis Company (MAC) has been retained to perform a diagnostic evaluation of both the Quality Assurance Program and the licensee's overall nuclear management program.
The MAC approach relies on interviews and team evaluations to identify causes of management problems.
Its process has been observed at other facilities and has been found to be useful.
Rather than presume an understanding of the nature of a problem, the MAC diagnostic examines the many aspects of a utility, includiqg the following:
organization, management controls, staffing levels and capabilities, training and retraining, intra and inter-departmental communi-cation, commitment controls, station generation, engineering configuration management Q-list, nuclear operations support and organizational freedom in Based on such reviews, the MAC evalua-problem identification and resolution.
tion focuses on underlying problem areas and recommendations are provided for resolving them.
PSE&G has committed to develop an action plan which addresses these recommendations.
NRC staff will monitor the MAC and PSE&G effort.
Meetings will be held with MAC and PSE&G to review the results of the evalua-tion, the development of an action plan and subsequent meetings with PSE&G will be held on a periodic basis to, monitor implementation of the action plan.
The MAC assessment is expected to be completed by May 2,1983.
In the interim, PSE&G has also retained the services of experienced and quali-fied individuals from the BETA Company to examine the steps taken to date in preparation for restart of Salem Unit 1.
This independent evaluation should provide an additional level of assurance to PSE&G as to the adequacy and completeness of the steps taken to resolve the problems associated with the two The staff will review the results of this overview, along with ATWS events.
resolution of any other identified issues, prior to allowing restart.
The licensee has also committed to establish on a one year trial basis an independent Nuclear Oversight Committee comprised of 3 to 5 members, including nuclear utility operations executives, college professors and This committee will meet at least quarterly and will former regulators.
provide reports to the Vice President Nuclear evaluating overall management attention to nuclear safety and reporting on progress in resolving open issues i
relating to NRC commitments and independent evaluations.
Consequently, the initiatives taken by the licensee will be monitored by an independent group to assure the safety-related problems are identified to the corporate managers.
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The NRC will also review the quarterly reports of the Nuclear Oversignt Committee.
==
Conclusion:==
The management initiatives and improvements described should
' considerably strengthen exisiting programs, should add a number of additional 39 Salem Restart SER
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reviews of corporate and station canagement effectiveness, and will provide for independent assessments of management.
No evidence. suggests that the organizational. structure or programs currently defined contributed to the problems identified in this evaluation.
The soure.e of the problems appears to be a lack of aggressive implementation of those programs.
The collective steps described above are expected to result in an increased awareness on the part of managers and supervisors as to the status of implementation of the many programs and allow more timely involvement to either provide redirection, priority or resources to resolve problems.
Accordingly, management programs in place, as modified by the steps described above, are acceptable to support ccntinued operation of both Salem units.
III. Overall Conclusions
$2ction A of this Safety Evaluation Report discussed and evaluated the NRC staff concerns in the areas of maintenance procedures, verification testing, and surveillance testing programs.
The licensee has acceptably revised his maintenance procedures, revised and expanded his surveillance testing prcgrams, pr6vided an adequate verification testing program, and will submit proposed Technical Specification changes for incorporating NRC notification requirements for maintenance testing results that exceed acceptance criteria and for measured trip forces that exceed recommended upper limit.
The licensee will also submit proposed Technical Specifications that incorporate the additional surveillance requirements identified by the staff, for the reactor trip and bypass breakers.
Section B addressed staff concerns in the areas of plant operations, operator precedures, training, and operator response, the licensee has acceptably identified reliable control room indicators that provide positive indication Gf automatic reactor trip demand, without operator analysis or verification, and has revised procedures to direct the operators to insert a manual trip whenever positive indication of an automatic reactor trip demand is present, without delay to evaluate the plant status.
The licensee has also acceptably completed training actions and commitments in the areas of training on proce-dures, training utilizing the Reactor Protection System, and the administration of this training.
As such, the licensee's ATWS training program for licensed cperators and for auxiliary operators is now acceptable.
5;ction C addressed staff concerns in various management areas.
These manage-ment areas were Master Equipme.nt List, procurement procedures, work order pro-ceduras post trip reviev, timeliness of event notification, updating vendor i
supplied information, involvement of QA personnel with other station depart-ments, post maintenance operability testing, and overall management capability t
and perfomance.
The licensee has acceptably revised his procedures and con-r ducted acceptable training to ensure that work orders and procurement documents will be properly classified in the future.
The licensee has conducted an cceeptable review of psst prccurement documents and work orders to verify that the misclassification problem associated with the reactcr trip breakers was an isolated incident.
Additionally, the licensee has developed an acceptable post trip review procedure to ensure a systematic and comprehensive review of reactor trips is conducted prior to returning to operation.
Finally, the licensee has instituted an acceptable program involving both outside consultants and addi-l l
tional corporate safety committees to further evaluate and upgrade the effective-l tess and safety of the licensee's nuclear activities.
Salem Restart SER 40 t
k l
U.S. NUCLEAR REGULATORY COMMISSION Dec. 20, 1983 No. 84-02 REGION I NOTICE OF SIGNIFICANT LICENSEE MEETING Name of Licensee:
Public Service Electric and Gas Company Name of Facility:
Salem Nuclear Generating Station, Units 1 and 2 Docket Numbers:
50-272 and 50-311 Time.and Date:
9:30.a.m., January 5,1984 Location of Meeting:
NRC Region 1 Office, King of Prussia, Pa.
Purpose of Meeting:
Periodic Meeting on Salem ATWS Event Corrective Action Program NRC Attendees:
R. Starostecki, Director, Division of Project and Resident Programs (DPRP)
H. Kister, Chief, Reactor Projects Branch No. 2, DPRP L. Norrholm, Chief, Reactor Projects Section 28, DPRP S. Varga, Chief, Operating Reactors Branch No.1, Division of Licensing, NRR R. Jacobs, Project Engineer, DPRP J. Linville, Senior Resident Inspector D. Fischer, Licensing Project Manager, NRR Licensee Attendees:
R. Uderitz, Vice-President - Nuclear J. Zupko, General Manager, Salem Nuclear Station J. Driscoll, Assistant General Manager, Salem Nuclear Station J. Boettger, General Manager, Nuclear Support NOTE: Attendance by NRC personnel at this meeting should be made known by 4:00 p.m., January 3,1984, via telephone call to L. Norrholm, Region I, at FTS 8-488-1114.
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P epared by Re/J.lprrholm, Chief L.
N g'qq gs acto" Projects gi Section 2B, DPRP Distribution:
William J. Dircks, Executive Director for Operations Richard C. DeYoung, Director, Office of Inspection and Enforcement D. Eisenhut, Director, Division of Licensing, NRR S. Varga, Chief, Operating Reactor Branch No.1, DOL, NRR l
C. Heltemes, Director, Office of Analysis and Evaluation of Operational Data J. Axelrad, Director, Enforcement Staff, IE i
Public Document Room (PDR) fo Local Public Document Room (LPDR)
S S. G. Kuhrtz, Director, Division of Environmental Quality, State of New Jersey
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l bec:
Regional Administrator Deputy Regional Administrator Division Directors Branch Chiefs Faith Brenneman Public Affairs Officer Region I Receptionist DRMA Files DPRP Files 4
l RI RP Norrholm/jm/dmg 12/20/83 0FFICIAL RECORD COPY
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