ML20138H104
| ML20138H104 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 08/09/1990 |
| From: | Keimig R, Lancaster W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20138G636 | List:
|
| References | |
| FOIA-96-351 NUDOCS 9701030129 | |
| Download: ML20138H104 (12) | |
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l SALP PHYSICAL PROTECTION Licensee:
Public Service Electric t cas comoany Hancocks Bridae, New Jersey Assessment Period:
May 1.
1989 - July 31, 1990 Report Draft Due Date (SG): Auoust 7, 1990 Report Draft Duo Date (DRP):
huoust 15. 1990 Prepared b
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8!9 W. K. Laidast'er, Physical Security Date Inspector d!k TO Reviewed by:
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R. R. Kedlig, Chief, safeguards Section Date
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Approved by:
R. R. Bellamy, Chief, Facilities Date Radiological Safety and Safeguards Branch, Division of Reactor Safety and Safeguards 9701030129 161226 PDR FOIA O'NEILL96-351 PDR
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SALP Hoom Creek and Salem l
C==_rison' of Performance to Criteria Attributes i
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EVALUATION CRITERIA AND ATTRIBUTES FOR ASSESSMENT OF LICENSEE PERFORMAN I
TA8LE 1 r* m Assurance of Quality. Including Management Involvement and Control l
1.
Category 1 Category 2 Category 3 Qg l
EQ There is little evidence of Q>
There is evidence of prior a.
of prior planning and planning and assignment of prior planning and assignment
., d.
There is consistent evidence a.
assignment of priorities; priorities; procedures for of priorities; procedures for mO l
procedures for control of control of activities are control of activities are poorly O
activities are well stated, stated and defined.
stated or not well understood.
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controlled, and explicit.
b.
Policies are adequately stated b.
Policies are poorly stated,
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Policies are well stated, oe j
disseminated, and under-and understood.
poorly understood or nonexistent.
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l standable.
c.
Decisionmaking is usually at a c.
Decisionmaking is seldom at a O
i h Decisionmaking is consist-level that ensures adequate level that ensures adequate 3
ently at a level that ensures I
adequate management review.
management review.
management review.
d.
Corporate management is usually d.
Corporate management is seldom involved in site activities in or ineffectively involved in l
h Corporate management is fre-quently and effectively site activities.
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g, involved in site activities, an effective manner.
Engineering evaluations are Engineering evaluations are e.
h Engineering evaluations are generally adequate and records frequently inadequate and e.
consistently technically records and plant performance t
adequate and records and and plant performance data are data are not complete, well generally complete, well plant performance data are maintained, and available.
maintained, or available.
i complete, well maintained, l
and available.
f.
Corrective action is usually f.
Corrective action is not timely 0l g
! h Corrective action is taken but may not be effective or effective and generally ad-X 3,
effective as indicated by dresses symptoms rather than o
lack of repetition of in correcting the root cause j
of the problem, as indicated by root causes, as indicated by occasional repetition of events.
repetition of events.
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- events, e
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Root cause analyses and self-g.
Corporate management does not E
(ISEG, onsite, offsite, assessments are occasionally appear to rely on self-assessment h, e
g.
Safety review committees g.
etc.) and fecesck from evident and sometimes result to ensure quality in activities.
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QA/QC activities are used in improvements.
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to provide critical self-l assessments to the corporate i
management and to improve l
work activities.
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TABLE 1 (Continued) l l
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Approach to the Resolution af Technient Issues from a Saf ty Standpoir.t z
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g Category 1 Category 2 Category 3 v
a.
Understanding of issues is a.
Understanding of issues is f
h Clear understanding of issues is demonstrated.
generally apparent.
frequently lacking.
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h Conservatism is routinely b.
Conservatism is generally b.
Minimum requirements are met.
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E exhibited when potential for exhibited.
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safety significance exists.
f c.
Approaches are viable and c.
Approaches are often viable, but h Approaches are technically sound and thorough in almost generally sound and thorough.
lacking in thoroughness or depth.
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g all cases.
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- @ISEG and safety review
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d.
Problems often recur before d.
Critical self-assessment is d.
committees are routinely and they are effectively resolved.
lacking; therefore, problems I
i effectively used to identify are not identified until they 8
become evident.
underlying problems before they become issues.
Resolutions are timely in e.
Resolutions are generally e.
Resolutions are often delayed.
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e' almost all cases.
timely.
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h 10 CFR 50. N reviews are f.
10 CFR 50.59 reviews are done f.
10 CFR 50.59 reviews are not well well documented and demon-well, but frequently lacking in documented and reflect a minimal strate a technical documented detail or technical analysis.
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rationale.
technical basis.
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l TA8tE 1 (continued) i 3.
Responsiveness to NRC Initiatives O ca Category 1 Category 2 Category 3
@H ta Q a.
Responses generally are timely.
a.
Extensions of time are N>
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h Deadlines are met.
frequently required.
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h Resolution of issues is b.
Few longstanding regulatory b.
Longstanding regulatory issues O
timely.
issues are attributable to are attributable to licensee.
licensee.
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Responses are technically c.
Responses are viable and c.
Resposses are often viable, but
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sound and thorough in almost generally sound and thorough.
lacking in thoroughness or m2H all cases.
depth.
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Acceptable resolutions are d.
Acceptable resolutions are d.
Considerable NRC effort er
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I proposed initially in most generally proposed.
repeated submittals are needed to obtain acceptable resolutions.
cases.
4 Implementation of NRC e.
NRC initiatives and policies e.
Implementat.fon of MRC initiatives c',
initiatives and policies are implemented within an and policies is frequently is timely and effective acceptable timeframe, but delayed or not done in a thorough 1
and ifcensee consistently licensee usually relies on NRC manner.
l meets expectations with to establish an adequate scope, i
i regard to schedule or content, or timeframe.
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content.
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TA8LE 1 (continued)
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4.
Enforcement History W
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Category 1 Category 2 Category 3 f
e v
Multiple major violations or p
I a.
Major violations are rare a.
E. @ Major violations are rare and are not indicative of and may indicate minor program-programmatic breakdown is s
matic breakdown.
indicated.
y progransnatic breakdown.
Minor violations are not b.
Multiple minor violations b.
Minor violations are repetitive 8
f repetitive cnd not indicative or minor programmatic breakdown and indicative of programmatic 5
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of programmatic breakdown.
is indicated.
breakdown.
c.
Corrective action is timely c.
Corrective action is delayed or b
@ Corrective action is prompt E.
and effectL.ve.
and effective in most cases.
not effective.
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w Root cause analyses are d.
Root cause analyses are d.
Root cause analyses are super-effective as evidenced by frequently ineffective.
ficial, deal only with evident problem, and are not effective 3
lack of recurrence.
in preventing recurrence.
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7 TA8LE 1 (continued) r* m 5.
Operational -
Events
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Category 1 Category 2 Category 3 "N
a.
Occasional significant opera-a.
Frequent significant opera-
@ Few significant operational tional or construction events, tional or construction events, J
i tributable to causes under attributable to causes under the attributable to causes under the, tis O or construction events, at-the licensee's control, have ifcensee's control, have occurred licensee's control, have occurred O
occurred that are relevant that are relevant to this that are relevant to this functional area.
$g to this functional area.
functional area.
- > ra b.
Events are reported in a timely b.
Events are frequently reported yf}i h
Events are promptly and manner; some information is late or not ccepletely.
to :=
d completely reported.
occasionally lacking.
O Events are accurately identi-c.
Events are poorly identified or 3l
@ Events are properly identi-fled, but some analyses are analyses are marginal; events c.
fled and analyzed.
are associated with program-marginal.
matic weaknesses.
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Deficiencies in man-machine d.
Deficiencies in man-h Deficiencies in man-machine interface repeatedly result in machine interface (e.g., in interface result in personnel human engineering design and errors, but effective corrective personnel errors.
procedures) rarely result actions are implemented.
in personnel errors.
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TABLE 1 (continued) 6.
Staffing (Including Management) x
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Category 2 Category 3 g
Category 1 ts 4
a.
Positions are poorly identi-g Key positions are identified,
@ Positions are identified, a.
and authorities and responsi-and responsibilities are fied, or authorities and respon-bilities are well defined.
defined.
sibilities are ill defined.
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Vacant key positions are b.
Vacant key positions are usual-b.
Key positions are left vacant for 8 filled on a priority basis.
ly filled in a reasonable time.
extended periods of time.
E c.
Expertise is usually avaliable c.
Very little expertise is avail-h Expertise is available with-in the staff; outside consul-within the staff; consultants able within the staff; there is l
3 tants are rarely needed; are appropriately used; staffing excessive reliance on consultants; w
staffing is ample as indi-is adequate as indicated by staffing is weak or minimal as f) cated by control over backlog occasional difficulties with indicated by excessive backlog or and overtime, backlog or overtime.
overtime.
3 h
Experience levels for manage-d.
Experience levels for management d.
Experience levels for management Y
ment and operations personnel and operations personnel meet and operations personnel are be-exceed commitments made by commitments made by licensee at low commitments made by licensee licensee at time of licensing.
time of licensing.
at time of licensing.
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1P 1 TA8tE 1 (continued) 7.
Effectiveness of Training and Qualification Program O ne Category 3 y*4 l
Category 1 Category 2 mg Training and qualification E>
l Training and qualification pro-a.
$ Training and qualification gram contributes to an adequate program is found to be the major
., d a.
MO program makes a positive con-tribution, commensurate with understanding of work and fair contributing factor to poor understanding of work, as indi-
$>N procedures and staffing, to adherence to procedures, as O
the understanding of work and indicated by a modest number of cated by nurserous procedural violations or personnel errors.
$g adherence to procedures, as personnel errors.
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indicated by few personnel errors.
d Training program is well b.
A defined program is implement-b.
Program is either lacking, O
I defined and implemented with ed for a large portion of the poorly defined, or ineffective 1y applied for a significant segment 3
of the staff.
l dedicated resources and a staff.
means for feedback of expe-i rience program is applied to nearly all the staff.
Inadequate training could Inadequate training could occa-c.
4 Inadequate training could regularly be traced as a root c.
rarely be traced as a root sfonally be traced as a root cause of major or minor events cause of major or minor events cause of major or minor events or problems occurring during or problems occurring during or problems occurring during the rating period.
the rating period.
the rating period.
d.
Procedures and policies are d.
Procedures and policies are
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g h Procedures and policies occasionally violated.
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are followed.
rarely violated.
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J Analysis During the previous assessment period, the licensee's performance was rated as Category 1.
That rating was based on an excellent enforcement history, the continued' implement-tion of an effective and performance-based program, knowledgeable and e,;rienced security supervisory personnel and management's involvement in and support for the program.
During this assessment period there were two unannounced security inspections (one routine and one special) and one announced fitness for duty inspection by l
region-based inspectors, and routine inspections by the resident inspectors continued throughout the period. one minor violation in the area of training l
was ide..tified and promptly corrected. The licensee continued to implement a high quality and very effective program and management's attention to and involvement in the program remained evident.
The site security supervisor and his staff are well-trained and qualified professionals who have been vested with the necessary authority and discretion to ensure that the security program is carried out effectively and in l
compliance with NRC regulations. The site security manager and his staff l
continued to actively participate in the Region I Nuclear Security Association l
and other' groups engaged in nuclear plant security matters. They also j
maintained excellent rapport and effective communication channels with the I
plant staf f who exhibit respect and a good attitude toward the program.
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staffing of the contract security force was consistent with program needs.
The morale of the security force appeared good and did not appear to be i
l adversely impacted by 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts, which resulted from corporate budget cuts. Early in this assessment period, the security force attrition rate was l
24 percent. Licensee and contractor efforts through personal incentives were successful in reducing this rate to 9 percent by the end of this period.
The licensee also continued to demonstrate responsiveness to NRC concerns.
This was evident when several potential weaknesses were identified by the NRC.
These weaknesses primarily involved system and equipment aging. As a result, l
the licensee conducted a very comprehensive evaluation of all systems and l
equipment and developed appropriate plans and a timely schedule for upgrading and/or replacing the affected equipment. The licensee also took the initiative to reduce the station's protected area by relocating the protected area barrier near the station's transformer yard.
In addition, the licensee i
implemented a fitness-for-duty program in response to new NRC requirements during the period. The licensee's policy has been clearly stated and widely disseminated among both employees and contractors.
It was found to be aggressively implemented by knowledgeable personnel, and processing facilities and procedures were excellent. These efforts represented a proactive l
management approach that continually seeks to improve the ef fectiveness of the l
entire security program.
The security force training and requalification program is well-developed and administered by an experienced staff of two full-time and five part-time instructors, and a supervisor. Facilities are provided on-site for training and requalifications and were well-equipped and well-maintained. During this period, the licensee established additional oversight of the contractor's training and requalification program by providing a full-time licensee representative to administer the program.
l The licensee's event report procedures were found to be clear and consistent
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The security force training and requalification program is well-developed and administered by an experienced staff of two full-time and five part-time l
instructors, and a supervisor.
Facilities are provided on-site for training l
and requalifications and were well-equipped and well-maintained. During this j
period, the licensee established additional oversight of the contractor's l
training and requalification program by providing a full-time licensee representative to administer the program.
1 The licensee's event report procedures were found to be clear and consistent with the NRC's reporting requirements. One event report was submitted to the l
NRC during the assessment period. This report involved the loss of power to j
the security system and was properly compensated for by the security force.
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The licensee's report was clear and concise, and indicated an appropriate j
response to the event.
During the assessment period, the licensee submitted three revisions to the security program plans under the provisions of 10 CFR 50.54(p). These l
revisions were of high quality and technically sound, and reflected well-i l
developed policies and procedures. The licensee also updated all Physical security Plan implementing procedures.
Summary The licensee continued to maintain a very effective and performance-based security program that exceeds regulatory requirements. Significant enhancements were made to the program which demonstrated management's attention to and interest in the program. The licensee's ongoing program to identify and correct potential weaknesses in systems and equipment during this period are commendable and demonstrated the licensee's commitment to maintain an effective and high quality program.
Conclusion l
Category 1 Board Recommendations:
Licensee: None NRC: None l
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I Post Inspection SALP Data Input Form LICENSEE:
PSE&G DATES OF INSPECTION: 7/11-14/94 SITE:
Salem /HC AREA (S) INSPECTED:
Emergency Preparedness INSPECTION No.: 94-15/94-14 INSPECTORS:
Silk, Lusher i
Tvoe of Inspection: CO/RI Previous SALP Ratina 1
f Inspection Module:
82701 Inspection Findinast Strenoths All aspects of the EP program were well implemented.
The experienced EP staff has remained stable since the last inspection.
The ERO positions are qualified to a depth of three or four individuals.
Vacancies created in the ERO by recent licensee lay-offs were immediately addressed by EP management.
The licensee has an effective rapport with offsite agencies.
ERO and offsite training / retraining was good.
The licensee's corrective action program for EP was aggressive in identifying, tracking, and resolving issues to enhance the program.
Weaknesses / violations / Unresolved Items / Inspection Follow-up Items No tracked items were identified during the inspection.
Only minor issues were documented in the report.
The 50. 54 (q) evaluation process needs to be more thorough and formalized.
The EOF ventilation system's HEPA filter had not been tested since it was installed.
(The licensee did test the filter the week after the inspection.)
Since offsite officials did not remember seeing the 50. 54 (t) report assess the licensee's interface with offsite agencies, the licensee will be sending the report to the county offices J
directly to improve circulation of the report.
The 50. 54 (t) audit team composition needs to include EP expertise from other licensees.
The TSC rad monitor being out of service for over 18 months demonstrated a somewhat lackadaisical attitude toward ERF equipment status.
Sionificant Observations (Not Documented)
The licensee's EP staff members were very helpful during the inspection.
They readily accepted constructive criticism to improve their program.
The EP group's document filing system was excellent.
The inspectors could readily retrieve documents as they were needed during the inspection.
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