IR 05000272/1985099
| ML20141B810 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 02/14/1986 |
| From: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Corbin McNeil Public Service Enterprise Group |
| References | |
| NUDOCS 8602240412 | |
| Download: ML20141B810 (3) | |
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u Docket Nos 50-272 24 586 50-311 Public Service Electric and Gas Company Attn: Mr. Corbin A. McNeill, J Vice President - Nuclear P.O. Box 236 Hancock's Bridge, New Jersey 08038 Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP)
Nos. 50-272/85-99; 50-311/85-99 Thfs refers to the evaluation we have conducted on November 19, 1985, of the nuclear facility operated by Public Service Electric and Gas Company.. This report was discussed in a meeting held on January 15,-1986, at the Salem Generating Station, Hancock's Bridge, New Jerse The list of attendees is attached as Enclosure.l. The NRC Region I SALP Report is provided as Enclosure 2. Our letter of December 30, 1985, (Enclosure 3) forwarded the SALP Board Report and solicited comments within 30 days of receipt of that letter. As you indicated during the January 15 meeting, no comments have been receive Our overall assessment of your facility operation concludes that your initiatives have improved performance and that there is effective management attention and involvement oriented toward nuclear safety in the functional ar as evaluated. Specifically, active management actions have resulted in two Category I assessments and improving trencfs in three others. We encourage continued management attention to provide for feedback and ongoing evaluation of your program initiative We consider that our meeting and interchange of information was beneficial and improved mutual understanding of your activities and our regulatory progra No reply to tnis letter is required. Your actions in response to the NRC Systematic Assessment of Licensee Performance will be reviewed during future inspection of your licensed facilit Your cooperation is appreciate
Sincerely, 8602240412 960214 "'I #8d h7 PDR ADOCK 05000272 2cmas E. Xurley G PDR Thomas E. Murley Regional Administrator 0FFICIAL RECORD COPY 1 LIMROTH 2/3/86 - 0001. /06/86
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Public, Service Electric 2 and Gas Company FEB 141986
Enclosures:
1. SALP Management Meeting Attendees 2. NRC, Region I SALP, Salem Nuclear Generating Station, November 19, 1985 3. NRC, Region I letter, T. Murley to C. McNeill, December 30, 1985
REGION I==
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-272/85-99 AND 50-311/85-99 PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM NUCLEAR GENERATING STATION ASSESSMENT PERIOD: SEPTEMBER 1, 1984 - SEPTEMBER 30, 1985
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BOARD MEETING: NOVEMBER 19, 1985
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O SUMMARY OF RESULTS Overall Facility Evaluation During this assessment period the licensee has accomplished a number of noteworthy milestones including:
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The successful replacement of a Westinghouse generator with a General Electric generator on Unit 2. This project required extensive prior planning and considerable rework of structural and electrical component Continued excellence in the area of primary and secondary water chemi st r A continuous run of 273 days on Unit 1 surpassing the previous Salem record of 88 day A significant reduction in man-Rem exposure and an equally sig-nificant reduction in solid radiological wast INPO accreditation of all training areas. (This was achieved following completion of the assessment period.)
These accomplishments reflect an improving trend in managemen A number of other areas observed during this assessment have not re-ceived adequate attention and increased efforts in these areas is warranted. These areas are:
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The undesirable number of reactor trip The apparent lack of timely and effective engineering support to plant operation Trips and events caused by the lack of procedure adherenc The misuse of on-the-spot changes. This has been a repetitive problem, however it is recognized that the licensee has ad-dressed this item and issued a new administrative procedure in this are The licensee's management and philosophy of operation has undergone considerable change during the latter portion of this assessment pe- l riod. While it is not possible to draw a final conclusion on the effectiveness of these changes it appears that they have the poten-tial for significantly improving the licensee's performance. An im-proved performance has been observed since their implementation. It is noted that this new philosophy, organization and management has ; yet to be tested by such events as a refueling outage, a full scale i
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. 9 emergency exercise, the reduction of contractor forces with a commit-i ment to perform the maintenance activities by station personnel, the'
i reduction of the security force and its ability.to manage security i tasks utilizing the newly functional security system. These areas L will be observed throughout the coming assessment period to appraise ' , performance of the new organization and effectiveness of newly imple-l mented operational philosophy.
l , Training The licensee has maintained a strong commitment to training and has continued to conduct training in all the areas required to operate the facility. Since the end of the assessment period the training program has been accredited by INPO in all areas. .This accomplish-ment, accompanied by the well equipped training facility complete with a Salem specific simulator, indicates management's commitment to training suppor Quality Assurance Within the functional areas reviewed, the Quality Assurance Depart- , ment has maintained effective involvemen The licensee has completed Action Plan Item 2.5.1 pertaining to Qual-ity Assurance as required by the NRC-Order issued as a consequence of the ATWS event. A goal of the Action Plan was to improve the QA De-partment's capability to manage the Salem QA program and included ' consolidation of QA personnel on site, adequate staffing for the QA Department and " team building" sessions for QA Department personne The QA Department was reorganized to establish a group dedicated to the operational phase activities at the Hope Creek facility. The Quality Assurance Control Section was eliminated and its functions assigned to the Audit Grou Management support in Quality Assurance Department matters is evi- i denced by adequate department staffing with qualified personnel, en-dorsing and implementing QA Department recommendations to increase field inspections, demonstrated support of the QA auditing program through the Vice President's approval of the master audit schedule and the requirement for 100 percent QC coverage for reactor trip breaker surveillanc While the licensee's actions thus far have been consistent with the action plan, the effectiveness of the reorganization and evaluation of management's commitment to the QA program needs to be assessed during future NRC inspection . -
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, Facility Performance Functional Category Category Recent Area last Period This Period Trend i (October 1,1983 - (September 1,1984 - I August 31,1984). September 30,1985)
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A. Plant Operations 3 2 Improving B. Radiological 2 1 Improving Controls C. Maintenance 2 2 No Basis D. Surveillance 2 2 . Consistent ' E. Fire Protection / 3 2 Improving Housekeeping F. Emergency 2 2 Improving ! preparedness * G. Security and 1 1 Consistent Safeguards
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H. Outage Management 2 2 No Basis and Modification Activities ! I. Licensing 2 2 Consistent t B I
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IV. PERFORMANCE ANALYSIS ! Plant Operations (45%, 1850 hours) Analysis The analysis discussed in this section includes plant management, l support activities of the Nuclear Department and plant operations.
l This area was under routine review by the resident and regional based ! inspectors. One team inspection was conducted to assess the licensee's preparation for Unit 2 startup following an extended out-ag Three management meetings were held to discuss the licensee's , progress and proposed closecut of the Action Plan which was a result l of the Order issued subsequent to the ATWS event on May 6, 1983.
{ l During this assessment period the licensee has shown an improvement ' in pre planning as evidenced by the reduction in man rem and genera-tion of solid radioactive waste produced during the outage (more de-tail in section B of this performance analysis). This trend has continued during the remainder of the period as well. Corporate man-agement presence is evident at the site, especially during the latter part of this assessment period. Site visits by upper corporate man-agement personnel and dialogue between site and corporate management have been observed by the inspectors. Site engineering support, how-ever, is still not totally supportiv At morning and outage meetings, observed by the inspectors, the engi-l neering support group frequently does not have answers to problems at hand; they do not have the design change or repair parts on site or do not know where the parts are; and some key personnel are not badged for access to the site. All indications point to a willing-ness to support plant operations, but only when asked. The initia-tive to lead in the support activities has not been displayed by this t ' grou The engineering support group seem to have a different set of priorities than the operations group at the station.
l The Onsite Safety Review Committee (50RC) and the Onsite Safety Re-view Group (SRG) have been meeting on an acceptable basis. The SORC conducts required post-trip reviews of all plant trips and concurs in the identified cause and corrective actions to prevent recurrence, l prior to the unit startup. The results of the 50RC reviews have led to disciplinary actions, retraining of operators and supervisors, and j plant improvement The SRG have been active in conducting in-depth analyses of identified concerns resulting from plant trips and other ' identified discrepancies. These analyses hate been presented to en-gineering and the Vice President Nuclear for resolution. The resi-dent inspectors have not identified any corrective actions as a result of these analyses to dat Management has provided adequate guidance on policies and has made j sound decisions concerning these policies. More attention on the
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part of shift supervisors and plant foremen is requ' ired in the area of procedure adherence. There have been a number of occurrences , where operating personnel have failed to follow procedures. Records l are generally complete with the necessary documentation to evaluate the proce:,ses that were accomplished by the procedure The licensee's operation of the two units has not been consistent.
l ' Unit I reactor trips are recorded as having been the lowest for one year since the unit began operation. Unit 2 has been hampered by a i greater than desirable number of trips. The total number of trips is fifteen of which five were attributable to operator error, failure to ! follow procedures, and lack of Shift Supervisor overview. The re-maining trips have been attributed to equipment failure. (A summary of the trips and their causes appear in Table 6).
As noted in Figures 1 and 2, the trips occun ed during short time durations within the thirteen month SAlp rating period displaying the 1 inconsistency of operation. Operations management attention is war-ranted to correct the cause of and to complete an already started , investigation into the cause of and correction of the trips to reduce ' the total numbe During the latter portion of the assessment period the resident in-spectors have been closing out. violations and inspector follow items opened by previous inspections ahd have presented the licensee with a list of items to be closed. The licensee has a clear understanding of the items presented by the inspection and has provided response These responses nave been generally reasonable and acceptable to the , resident inspector ' There has not been any identified water chemistry problem in the pri-mary or secondary plants during this assessment period. This was due to supervisory attention in the Chemistry Department and an aggres-sive water chemistry progra The licensee has had no major violations in plant operations. A trend l or pattern could not be identified. The number of violations has I decreased corpared to past SALP periods with one violation directly l ' attributable to management, two to the Shift Supervisor, two to oper-ators and two to the use of "on-the-spot changes" (OTSC). The l I licensee has had considerable attention drawn to their practices of OTSC which has led.to violations and LERs. The licensee has recently taken steps to address the condition by issuing a completely new pol-icy for incorporating changes into procedures and design change The effectiveness of initiative will be addressed in future inspection Licensee Event Report (LER) submittals are accurate and timely, how-ever, the licensee occasionally relies on followup reports which are not always as timely as the originals. The licensee has recently embarked on a reduction of modification program and has cancelled i
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.' 13 l plant betterment modifications that are no longer considered neces-l sa ry. Some of these modifications were commitments to fixes identi-
! fied in supplemental LERs. The licensee is currently addressing the l issue by a review of past submittals and the cancelled modification The quality of LERs is outstanding presenting a clear understanding of the event, its cause, and corrective action taken or committed to be taken.
l The licensee has all key positions filled with qualified personnel a ! who have the authority to exercise their positions and understand I their responsibility. Staffing appears to be adequate and licensed shift operator excessive overtime is not eviden The Itcensee has an aggressive approach to licensed and nuclear plant operator training and retraining. They are not hesitant to utilize the Training Department to rectify self-identified weak areas. In response to esents, management has expeditiously provided training and retraining programs in order.to enhance operational skill . Conclusion Rating: Category 2 Trend: Improving 3. Board Recommendations ( Licensee l Complete assessment of trip history and make presentation to the NR With regard to changes instituted as a result of the Order and Action l Plan it is recommended that the Order be lifted or rescinded.
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. , 14 Radiolocical Controls (11*;, 477 hours) Analysis In this assessment period, four minor violations were identifie There were no escalated enforcement actions, civil penalties or con-firmatory action letters. There were three routine and three reac-tive inspections of the radiation protection program. The radioactive waste management, transportation, effluent control, and monitoring programs were each inspected in addition to the continual reviews conducted by the resident inspector Total personnel exposure has been reduced by a factor of four and the volume of radwaste by a factor of three. Although additional gains of this magnitude are unlikely, corporate management has tar-geted further reductions of 15*. in each area for 198 This perfor-mance is indicative of aggressive management support of the ALARA and radwaste programs. Management's next emphasis is to reduce the l square footage of contaminated area and reduce valve packing leakage to Zer A Health physics reorganization created the position of Radiation Protection and Chemistry Manager and several senior supervisor posi-tions including an ALARA Coordinator and Administrative Assistant,
, yet unfilled, in the Radiation Protection Department. In addition I coordination and cooperation between the in plant and the corporate HP organizations has improved. As a result these changes have pro- , vided the opportunity for increased management ove'rsight and provided a larger pool of technically qualified personnel to implement the ' progra There is a persistent weakness with regard to the adequacy of review and control of changes to chemistry and HP procedures. To correct , ' the inconsistency with the levels of procedure review the licensee has instituted a new approach to procedures involving two tiers of
- procedures. The implementation of this solution will be evaluated for effectiveness in the futur !
Radiation Protection Management involvement and control in the radiation protection pro-grams was significantly increased during this period. The Vice Pres-ident established specific goals for man-rem exposures, cubic feet of radwaste, square footage of contaminated area and number of leaking valves. A computer program initially used to store, analyze and graphically display personnel exposures during outages has been ex-panded to track performance relative to HP Department goals. HP su-pervisors have been directed to increase direct observation of work ! and to interview workers to determine adequacy of briefings and ' awareness of radiological conditions. The hours of direct supervi-sory monitoring of work is logged by the computer.
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Midway through this period, a reorganization created the position of Manager, Radiation Protection and Chemistry. The position was filled by an experienced and competent individual. Several additional se-nior and junior supervisory positions were also created. Although not all positions are filled, this reorganization significantly in-creased the potential for supervisory oversight of activitie During the assessment period procedures and policies were occasional-ly misunderstood. As examples: a violation resulted from failure to monitor upper arm radiation exposure; trainees were allowed to con-duct routine radiation surveys; a crew performed work in an area posted as a high radiation area without proper authorization; and, workers had a misunderstanding of the " Lapse of Radiological Con-trols" procedure used to identify radiological control nonconformanc-es, and were reluctant to report problems. All of these issues were l satisfactorily resolved by the licensee.
' Records are generally complete and well maintained. Records of radiation surveys including maps were readily available for surveys conducted back to 1983. Personnel dosimetry records were up-to-dat Good practices have been routinely exhibited in the radiation safety program. Corporate policy has been reoriented to clearly require active support of the radiation safety program by all operating de-partments. A training course in ALARA principles was conducted for design engineers. Excellent control of exposures was achieved during ! outages by assigning an ALARA coordinator to all major work, using lessons learned from previous performance of similar work (See Sec-tion H) and monitoring job progress versus exposure with a computer, , Good ALARA practices were exhibited during the recovery of a metal 1 l t chip reading in excess of 1000 R/HR on contact in the reactor cavit The personnel dosimetry facility is designed to be operational during , any emergency. Industry accreditation (NVLAP) of the dosimetry pro- , gram was obtained. Analysis of fluctuating environmental sample data l was technically sound and indicated a thorough review of routine da-t The procedures and facilities to calibrate and maintain survey l instruments were found to be good. The controls of potentially con-l ' taminated tools were increased by a policy requiring additional sur-veys prior to removal from the sit A well defined training program has been implemented with dedicated resources. The respiratory protection training program was signifi-cantly improved and expanded as were the other general employee training classes, and the licensee achieved industry (INPO) certifi-cation. Classroom instructors were observed in plant reviewing qual-ification progress of HP technicans-in-training. These observations are the licensee's followup to training with regard to the trainees i completing their qualification cards which are prerequisite to quali-l fication as radiation control technicians. The inspector observed l that as prospective technicians receive the signatures they are ! deemed qualified to perform the evolution.
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.- . 16 Radioactive Waste Manacement and Transportation Although the level of management assigned to provide oversight to the radwaste program has been low, performance has been excellent. By carefully recording and analyzing the waste output, the licensee was able to control and eliminate large volumes of dry active wast Current generation of approximately 11,000 cubic feet per year is well below the industry average. Pilot studies with a new pressurized resin bed have produced similar reductions in volume of resin expende The licensee is providing additional training for auditors which has-enhanced the Quality control oversight of radwaste shipment This is provided in each step of the process rather than only prior to shipment. The segregation, packing and shipment of dry active waste l consistently exceeds regulatory requirements. The annual audits of l these activities has not reached the same level of performance.
l l Records of waste disposal are complete, well maintained and contain l extra detailed information that the licensee effectively utilizes. A l computer program is used for dose rate to curie conversions and files ! are frequently updated with waste stream analysis dat A training program has been implemented for the radwaste operation supervisors and worker This program has been particularly effec-tive for QC inspector Ef fluent Control and Monitoring i In the water treatment program area within the radiological effluents ) technical specifications, during the startup phase of the new sys- ! tems, responsibility for the effluent control and monitoring program was shared by the Operational Test Group (OTG) and the Chemistry De- , partment Both departments were cited with minor violations for ! apparent inattention to procedures. The OTG had revised testing pro-cedures without obtaining the required post-change reviews. The Chemistry Department had failed to requalify the Chemistry Technical l ' Assistant as required by training procedures. Since the violations occurred this new equipment has been adequately tested and is now under the control of the Chemistry Department. The OTG is no longer a part of the organization at Sale Inadequate control of procedure changes was also demonstrated when a new waste gas decay tank sample point was actually providing samples of clean air. Supporting records confirmed that no discharge limits were exceeded during this perio Records are generally complete; however, the results of tests of the , Fuel Handling Area air cleaning systems could not be locate Records of laboratory tests of charcoal for methyl iodine removal did not provide the date of the tes . . __ . ._
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l Inspection reviews indicate that controls and oversight are adequate , to ensure that effluent releases are within Technical Specifications, i Performance in these areas was weaker than other ' areas within the . t i i combined HP/ Chemistry department. Since the Chemistry Department.has ! assumed complete control of effluent systems this area has improve Additional inspections will be necessary to assess the changes within j the Health physics and Cl.amistry Department in light of proposed pro-l gram change and new department alignment, which has occurred during l the latter portion of this assessment periody l 2. Conclusion Rating: Category 1 Trend: Improving I 3. Board Recommendation Licensee Complete staffing initiatives. Monitor and evaluate procedure change mechanis NRC During subsequent inspections conduct QA/QC overview inspection,
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- ' . 18 C. Maintenance (4*.,141 hours) Analysis During this assessment period, routine reviews of corrective mainte-nance and one specialist inspection were conducted by Region I. The specialist inspection was to assess the licensee's training in the areas of Maintenance, I&C, Electrical, and Mechanical. The mainte-nance area was also inspected during the closecut of items that had been opened during previous inspections. A programmatic review of preventative maintenance has not been conducted during this assess-ment perio Management involvement has improved and the department has benefited from the increased attention. Prior planning and assignment of pri-orities and responsibilities through procedures and new programs have l decreased the number of outstanding work orders since the last SALP period. Contractor personnel who, in the past were usually involved
' in the repair and installation of equipment, were removed from the ! site during this assessment period and station personnel are perform-ing their own maintenance. Other indications of maintenance improve-ments are the institution of a consolidated Master Equipment List, a j work order tracking system and further development of the Nuclear Plant Reliability Data System (NpRDS).
The records reviewed by the inspectors are well controlled and well documente The records which document the performance of mainte-nance and training are not stored in a manner which makes them easily retrievable. Sometimes records are not readily available for review by the inspectors. This could hamper engineering in the review of work performed by the Maintenance Department in order to make correct assessment of the maintenance work performed.
l The licensee has further committed to upgrade the maintenance program at the site and has proposed a managed maintenance program to facili-tate the planning, scheduling and analysis of maintenance work activ-ities. The manager of the new Planning Department has been named and ' the department will be directly responsible to the Station Manage This department will be responsible for planning and scheduling of all maintenance and outage work. This initiative is still in its early stages of development and its effectiveress has not been assesse The licensee's approach to regulatory issues is technically sound and the responses to regulatory concerns are timely and, generally, ac-ceptable to the inspector No items of non-compliance were identified in the maintenance are The licensee has been addressing items that were identified in previ-ous rating periods and the corrective actions appear to be effective i as experienced by the reduction in identified concerns by the
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' , 19 inspector The department has an effective means of reporting prob-lems and ongoing events through the morning meetings. No reportable issues were identified during this rating perio The licensee appears to have adequate management staffing to adminis-ter the maintenance program. The management positions are clearly '
identified with authorities and responsibilities defined. At this time it is difficult to assess whether the staff is capable of sup-porting the repair and disposition of the maintenance work requests that are generated by the other departments. The backlog of mainte-nance work requests was beginning to increase at the end of the as-sessment period apparently due to increased management attention to plant betterment which has generated more maintenance work requests l (MWRs) than normal, and the decrease in contractor personne The Maintenance Department has an aggressive training and retraining program that is administered by the Training Department. The program is well defined and implemented with adequate resources. The train-ing facility is one of the best in Region I with equipment that is a duplicate of that in the, plant. The training and qualification pro-gram combined with gccd procedures and adequate staffing, has led to an improved effective maintenance progra The assessment of this functional area is based almost exclusively on day-to-day observations by the resident-inspectors. A program-matic inspection in this area is planned for the coming SALP assess-ment period; however, none was performed during this period. Limited inspection in this functional area complicated by reassignment of l resident inspectors provides no basis for assessing a tren . Conclusion l Rating: 2 Trend: No Basis 3. Board Recommendations , ! Licensee , l ' Continue to develop preventative and corrective maintenance program i as committed to in the Salem Action Plan.
! l NRC Conduct review of licensee maintenance program and its implementation.
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D. Surveillance (8*4, 341 hours) l Analysis This area was under routine. review and during this assessment period three specialist inspections were conducted in the following areas: Surveillance testing, Reactor Coolant System (RCS) leakage measure-ment program, and In-service Inspection (ISI).
The surveillance tests are well documented and utilize detailed pro - , cedures, instructions, test forms, and acceptance criteria. Manage-I ment involvement is evident by the immediate and-long term actions that are taken in response to identified issue For example, sur-veillance identified equipment malfunctions are usually promptly cor-rected, and Reactor Trip Breaker measurements continue to receive a high level of management attention. During this' assessment period i one surveillance was missed. Overall, the staff, including techni-l cians, plant engineers and QA personnel are knowledgeable, responsi-i
ble and well traine Several areas of concern were identified during this assessment peri-od. During surveillance testing, technicians' lack of strict adher-ence to procedures was the direct cause of one violation and three reactor trip Two violations were issued in the area of Reactor Coolar.t System (RCS) leak rate detection resulting from the licensee's incorrect interpretation of RCS leakage classificatio Both of these areas have been addressed by management and the actions taken have corrected the concerns. However, adequate time has not-elapsed for the inspectors to properly assess the long-term results of management's actions to enhance procedure compliance.
! l The review of the in-service inspection program of Salem Unit 2 indi-cated that management's involvement and control to assure quality was adequate, especially in the area of steam generator tube examinations and associated actions. This was demonstrated by the licensee's ac-tions to plug certain steam generator tubes that were not defective by the Code but had the potential to degrade primary system integri-t There is a need for more effective staff training for' review of ISI vendor supplied data. Several instances were identified where ultrasonic examination data was incorrectly plotted and evaluations were not based on all of the available informatio The licensee's staffing is adequate and utilizes qualified personne l The I&C Group usually performs the bulk of the surveillance testing in conjunction with the Operations Department. During the latter portion of this assessment period the I&C Group has been placed in l the Maintenance Departmen This change was implemented by the i licensee in order to align all maintenance (!&C, Electrical and Me-chanical) under the same manager. The impact of this change will be addressed in the next SALP rating period.
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2. Conclusion Rating: Category 2 Trend: Consistent 3. Board Recommendations None l l l , . l l ! i
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! E. Fire Protection / Housekeeping (4*4. 177 hours) l , Analysis l The areas of fire protection and housekeeping were under routine re-view during this assessment period. Two fire protection / prevention specialist inspections were conducte A significant improvement in both management attention and perfor-mance has been seen in these areas during the second half of this assessment period. Although improvements are still needed, a working program appears to be in place. The formation of a Site Protection Department has resulted in a more aggressive approach toward resolv-ing a number of long-term problems. In addition, the incorporation of full time trained firemen has relieved the Operations Department of fire brigade team responsibilities. This also resulted in more meaningful fire brigade team training.
l l Both units have been in the Technical Specification action statement I ' for degraded fire barrier penetrations for almost four years; howev-er, the fire barriers were found to have deteriorated further since the last assessment perio The further degradation of fire barri-ers, including damage to a fire damper and ventilation duct fire pro-tective wrap, was cited as a violation. Although unsealed penetrations in the auxiliary building stairwells were identified t the licensee as a problem in January 1984, no corrective actions had been implemented as of December 198 Repairs and replacement of the fire proofing of steel columns was negated by the fact that the fire proofing was redamaged almost immediately by. work crews transporting equipmen As the assessment period continued, increased management attention became evident in the area of fire barrier integrity. A consultant was hired and an aggressive program to repair or replace all degraded fire doors was initiated. Although the licensee was still in the fire barrier action statement at the end of the assessment period, the items remaining to correct were relatively mino The licensee has not exhibited the samo initiative in response to concerns and unresolved items identified by the NRC during the safe shutdown inspection.. Items such as the deficiencies in the fire pro-tection featuras, sprinkler system and detection, have not been resolve The licensee's commitment toward improving the level of general plant cleanliness and the results achieved to date is noteworthy. The ef-fort expended to make these improvements was significant and has re-sulted in improved performance in this area. The removal of a large number of contractor personnel has increased the PSE&G employee's sense of pride and ownership in the facility which has resulted in more attention to good housekeeping practices.
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% . ' .' 23 The licensee has undertaken a number of housekeeping improvement pro-grams including reducing the number and size of contaminated areas and coating floor surfaces with unit specific colors. In addition to improving the unit's appearance, the painting of equipment and sur-faces with a unit specific color is intended to reduce wrong unit error . Conclusion Rating: Category 2 Trend: Improving l
! 3. Board Recommendations Licensee ! Meet with NRC to assess implementation of resolutions to longstanding ! fire protection issue E None i i l ! l . k
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, i F. Emergency Preparedness (20*;, 845 hours) l [ Analysis This assessment is primarily based on NRC team inspections of the annual emergency exercise conducted on October 23, 1984, and two spe-cial inspections on November 5-9, 1984, and July 8-11, 1985, relating specifically to the followup of major deficiencies identified during and subsequent to the exercise.
! During the October 23, 1984, emergency exercise, the NRC inspection team identified a number of deficiencies which were indicative of a , significant breakdown in Emergency Preparedness program effective-l ness. As a result, a meeting was held on October 31, 1984, at NRC/RI j with PSE&G and NRC managemen PSE&G was given the opportunity at f this meeting to present additional information that'would assist the l NRC in evaluating the exercise. PSE&G was informed that a followup i inspection would be performed to evaluate the additional information and to determine the underlying causes of the major deficiencies identified during the annual exercise.
During the November 5-9, 1984 team inspection, additional violations of NRC requirements were identified. These violations involved defi-ciencies in the training of PSE&G personnel and failure by PSE&G man-agement to correct deficiencies in the Emergency Preparedness program. These deficiencies had been previously identified during quality assurance audits and emergency drills by the licensee prior to the October 23, 1984 drill but were not acted upon until NRC in-spection activities identified the same deficiencies.
' The licensee presented a program of proposed corrective actions to the NRC during an enforcement conference on January 24, 1985. Al-though the NRC recognized that these corrective actions, if aggres-sively implemented, should preclude recurrence of the violations, it I was felt that the failure to promptly correct licensee-identified deficiencies in the first instance represented a lack of management involvement to the emergency preparedness program. As a result, a civil penalty was issued to PSE&G in the amount of $50,000 for the violations identifie Since January 1985, the Itcensee has made significant progress in resolving the deficiencies identified in October 1984 and in upgrad-ing the overall emergency preparedness program. Management involve-ment has been strong, demonstrating a renewed commitment toward maintaining a high level of emergency response capability. Evidence of these efforts was verified during a team inspection on July 8-11, 1985. As a result of this inspection, all of the deficiencies which resulted in the civil penalty were closed by the inspection tea The training program has been substantially improved and tracking systems have been set up to keep track of deficiencies noted (by both
_ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ .
- .
.. '. , gg
'
,.
( QA and within the EP program) and actions taken to correct the These tracking systems are presented to high levels of managemen Also contributing to the dramatic improvement in the Emergency Pre-paredness program have been recent organizational changes which have provided strong management for both the Emergency Preparedness De-partment specifically and for the plant as a whole. Performance.im-provements in key EP positions now represent a commitment by PSE&G to
'
i maintain the EP program at a high level of effectivenes . Conclusion Rating: Category 2
,
Trend: Improving Board Recommendations None i f I t
! ,
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26 Security and Safecuards (4*4,158 hours) Analysis These areas were under continual review during this assessment peri-od. There were one special and two routine unannounced physical pro-tection inspections conducte Escalated enforcement action (Severity Level III - no civil penalty) was taken as a result of a firearm being introduced into the plant protected area when a member of the security force was negligent in following procedures. The lessons learned from the event were promptly communicated to the security force and incorporated into the l security force training program. The licensee's corrective actions i were very responsive and promp Allegation followup resulted in a violation identified by the licensee as a result of its followup of the allegation which could not be proven or disproved. However, the licensee treated the alle-gation as true and took appropriate actions to rectify the alleged matter and to prevent further occurrence.
l The licensee submitted one event report pursuant to 10 CFR 73.71(c) I during the assessment period. The description of the event was clear l and the corrective actions taken were adequate and prompt.
l Corporate involvement in the program was evidenced by the expenditure of a significant amount of capital and human resources to upgrade and improve the existing security program for Salem and to provide for the incorporation of.the Hope Creek site into the program. Improve-l ments included construction of a new Access Control Facility, instal-lation of a new integrated security computer system and associated hardware, computerized access control devices, state-of-the-art closed circuit television systems and new personnel search equipment.
, ! These improvements and the elimination of non-security related duties for the security force enabled the licensee to reduce the security i force by 50*;, thus removing the previous extensive reliance on human ! element . l The licensee's onsite security staff was reorganized during this as-sessment period to provide better oversight of the contract security force and also to provide for the incorporation of Hope Creek. Of l significance was the addition of licensee security professionals to l each shift to monitor contractor performance. Several instances of ! inattention to duty on the part of members of the contractor security - i force were identified during NRC inspections. In the middle of this l assessment period, the licensee had detected some decline in its mon-l itoring of, and the contractor's supervision of the security force.
This recent initiative is expected to detect performance lapses as they occur such that they do not become a problem. The licensee's staff remains composed of well qualified and experienced professional i _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ . _ _ _ . _ _ _
F1 ' S 9 s xy\
*- . _27 pers'onnel who appear to discharge their assigned responsibilities effectively as evidenced by the overall quality of the program imple- .
mentation found during inspection During this assessment period, the onsite contractor management and members of the security. force were confronted with security program changes and improvements that created extreme pressures and extraor-dinary working. conditions. The security force responded in an excel-lent and professional manner to these adversities indicating a dedication to the job by all members of the security force.
n , The training and requalification program remained well defined and
*
was administered in a_ professional' manner.by highly qualified in-structor No adverse inspection findings could be attributed to the training progra . Conclusion Rating: Category 1 Trend: < Consistent Board Recommendations None
:
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s
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,
Outage Management and Modification Activities (4%,-139 hours)
' . Analysis This assessment period began with Unit 1 in a refueling outage..Seven days later the unit began a startup and encountered difficulties,dur-ing rod drop; testing (See below). Later in the period Unit 2 began-
, an outage to refuel the-reactor and to replace;the main generator , which had failed during operation. This area was under continual review and a special team inspection was conducted prior to the startup of Unit '
; Management attention and prior planning were poorly conducted during_
the reassembly of the reactor-following the split pin modification that was conducted during the outage on Unit 1. During the startup- .
'
of the unit several rods became stuck and had to be driven back into . ! the core. The subsequent disassembly of the reactor found that two guide tube extensions in the top hat assembly area were rotated 90 degrees from the correct position. During reassembly of the reactor
.
a core exit thermocouple guide tube was bent for a second time during ' this outag . Management attention and prior planning were improved during the out-age on Unit 2; however, the same design changes and refueling work packages were not performed as in Unit 1. The result was an outage of shorter duration with~less man-rem expended during the performanc of the work packages. Most compared tasks were completed with less ' than the projected man-rem exposure and the overall total for man-rem expended was less than projected for the entire outage.
, ;
, The station experienced less outage. time on the units during_this 4~
assessment period than any other period during the life of the sta-tion. The outages, illustrated in table 6 of this report,'were rela - tively short in duration and prior planning on the part of management was evident. The work performed during these outages was controlled
~
and well documente Three violations were attributable to outage management and modifica-tion activities. The violations were improper use of use of scaf-Yolding in the vicinity of_ Class I_ seismic structures, procedures which did not detail malfunction and shelf life of expansion joints, and failure to adequately torque seismic anchors in the installation of a Class I system. These violations have been corrected by the licensee. As a result of one of the licensee resolutions, the sta-tion has established a structured program for the use and placement-of scaffolding so that its presence does not impact on safety related' equipment'in the event of a seismic occurrenc l During the assessment period the licensee completed modifications.and adjustments to the condensate and feedwater system of Unit 2 which -l has corrected previously identified feedwater instabilities, noted j i ,
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e e - p-- - , y
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'
,
during previous assessment periods, caused by low suction' pressure , which led to plant trips. The correction was to install higher head condensate pumps which eliminated the feedwater problem Subsequent ' testing and Unit 2 operation has demonstrated that no other repairs are necessary and the feedwater low suction pressure problems have been correcte The licensee has recently changed the staffing in the area of plan-ning. The Planning Department now reports directly to station manage-ment. This is seen as a strong move on the part of management to have more control over planning and outage related activities. This department will be evaluated in more depth as the department assumes more responsibilities and especially during the next outag Overall, the outages and outage related activities have improved dur-ing this assessment period with more emphasis by station management being placed on pre planning and quality work. Licensee initiatives have resulted in prior planning meetings and work packages have been issued for the Unit 160-day outage planned for February 198 . Conclusion Rating: Category 2 . ' Trend: No Basis. Recent indications of trend, as indicated by out-age on Unit 2 indicate improvements in this functional are . Board Recommendations None
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y - e y ._
* ,- .,'* _ , . _ _ _ ,. .[ $ .
, .
+ [' 30 I. Licensino Activities (% NA) Analysis
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During this rating period the licensee's management demonstrated ac-tive participation in licensing activities and kept abreast of cur-rent and anticipated licensing actions. The management's. involvement in licensing activities generally assured a timely response to re-quirements of the Commission. The licensee's management generally exercised good control over its internal activities and its contrac-tors and maintained effective communication with the NRC staff. In anticipation of long review times for several amendment change re-quests dealing with their next refueling shutdown,_the licensee held advance meetings with the NRC staff to try to identify and smooth out review problem areas that might arise. Although the licensee usually met licensing schedules, response times where the -licensee was re-quested to supply additional information in order to process "Sholly" notices sometimes took too long. In several instances, these delays caused amendments to be processed out of order, resulting in further delays to correct the situation to assure that the correct Technical Specification pages were put in place. PSE&G management has been made aware of these instances and efforts are being made to cure the situatio Further, there has been no need for emergency or expedit-ed issuance of amendments, indicative of good planning and management of licc-nsing activitie The interaction of the licensee with the NRC staff resulted in good understanding of safety issues. In the usual case, satisfactory technical approaches were taken by the licensee's technical staff toward their resolution. Adequate conservatism was exhibited in re-lation to significant safety issues on a routine bases. The licensee's aggressive approach to the technical issues has been dem-onstrated by the number and complexity of the licensing actions com-pleted during this perio There were several issues where the licensee initiatives resulted in different technical approach than NRC guidance had provided. Resolu-tion of the issues was obtained through compromise by a series of follow-up discussions and additional information requests. In these cases, the staff reviewers felt that the technical disagreement could have been avoided by timely communications with the staf The licensee's commitments to meeting schedules were usually on. tim For those that were late, the licensee provided adequate advance no-tice to the Project Manage The licensee was aggressive in pursuing closecut of open licensing
-
issues. Licensee personnel are in constant open dialog with the NRC ! Project Manager; verbal commitments were always adhered to and fol- ) lowed up in writin j l
.
l
.I
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. ..
. 31 There are no long standing regulatory issues attributable to 'the
~
license The licensee has a licensing. staff.which appears to.be sufficient to provide adequate and' timely responses. There appears to be an ade-quate understanding of the regulatory requirements, technical . issues and adherence to procedure However, there were~ instances wher delays in processing time of actions did occur. The licensee is cur-rently trying to correct these situations. The-licensee further sup-- plements his licensing capability by active participation in nuclear industry groups.and committee . Conclusion
Rating: Category 2
,
Trend: Consistent 3. Board Recommendations None r ! , i l
r-r - , ,. y.-
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32 SUPPORTING DATA AND SUMMARIES Licensee' Event Recorts Tabular Listing Type of Events: Unit 1 Unit 2 Total Personnel Error 7 7 14 Design / Man./Const Instal External Cause Defective Procedures 1 2 3 Component Failure 1 9 10 Other _6 5 11 Total 24 29 53-Licensee Event Reports Reviewe Unit 1: Reports 84-17 'brough 84-29, 85-01 through 85-11 Unit 2: Reports 84-18 through 84-25, 85-01 through 85-20 Causal Analysis of LERs Four incidences of failure to follow procedures; two by operators, and two.by instrument technicians contributed to four of the LERs Three failures of service water components such as. vent and drain leaks contributed to three events that required re-porting to the NRC. The licensee currently has established a study group to assess why these failures continue to occu Investigative Activities None - Miscellaneous allegations were examined during routine inspection Escalated Enforcement The following violations resulted in escalated enforcement actions; Two Level III violations in emergency preparedness resulted in a
$50,000 civil penalt . One Level III violation in security resulted in no civil penalt . - . ~' . * . * 33
. Management Conferences Management Meetings on November 16, 1984, April 19, 1985, and September 25, 1985, to discuss the development and close out of the PSE&G Action Plan for improvement of. Nuclear Department Operation . Enforcement Conference on. January 24,.1Pa5, to discuss viola-tions and identified. deficiencies which represented a signifi-cant programmatic weakness in the emergency preparedness progra t
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y -- ep --: j
. . l " . T1-1 TABLE 1 TABUI AR LISTING OF LERs BY FUNCTIONAL AREA SALEM '.UCLEAR GENERATING STATION - UNITS 1 AND 2
_ Area Cause Code A B C D E X Total Plant Operations 9 5 2 1 3 20 Radiological Controls 1 1 ! , Maintenance 0 Surveillance 4 2 1 7' , Fire Protection / i Housekeeping 0 Emergency Preparedness 0 Security and Safeguards 0 Outage Management and Modification Activities 2 1 -3 ] Licensing Activities 0 l Other 6 8 8 22 l Totals 14 15 3 10 11 53 Cause Codes Personnel Error Design, Manufacturing, Construction, or Installation Error External Cause Defective Procedures Component Failure Other F , i -
, -, - . . . . - _ . _ . - _ - . .
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, -T2-1 .
!
" i TABLE 2
.
.
t INSPECTION HOURS SUMMARY (9/1/84 - 9/30/85)
4 SALEM NUCLEAR GENERATING STATION
i '
. Hours % Of Time i Plant Operations............................... 1850 45 Radiological Controls.......................... 477 ~11.
I Maintenance.................................... 141 4 I Surveillance............ ...................... 341 8
>
d Fire Protection / Housekeeping................... 177 4.
. l Emergency Preparedness........... ............. 845 20
4 d Security and Safeguards........................ 158 4 I i Outage Management and Modification Activities 139 4
'
i Licensing Activities......... ................. N/A N/A Total 4148 100 ] i t
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l < f i e
4 I
_
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, , T3-1 TABLE 3 ENFORCEMENT SUMMARY (9/1/84 - 9/30/85) SALEM NUCLEAR GENERATING STATION UNITS 1 & 2 Number and Severity Level of Violations' Severity Level No Severity Level I O Severity Level II 0 Severity Level III 3 Severity Level IV
~
Severity Level V _4 Total 23 Violations vs. Functional Area Severity Levels , FUNCTIONAL AREAS I II III IV V DEV TOTALS Plant Operations 8 8 r i Radiological Controls 1 3 4 J Maintenance 0- l l Surveillance 1 1
- Fire Protection & Housekeeping 1 1
' Emergency Preparedness 2 2 Security and Safeguards 1 2 1 4 , Outage Management and Modification Activities 3 3- Licensing Activities 0 Violation and Deviation Totals: l3 16 4 23 ! i _ , - . . _, -__ _ .
_ _ ._ -
-
e
-*
l . ,
. T3-2 i
TABLE 3 (CONT'D)
' , . Summary - Enforcement Data Inspection Inspection Severity Functional Report N Date Re Level Area Violation l
l Combined 8/14/84- TS 6. IV Surveil- Failure to follow
Inspection 9/24/84 lance procedures while
! 84-32/84-32 performing surveillance on'
'
- Main Turbine.
, i TS 6.11 V Rad. Con. Failure to comply 1 with radiological postin Combined 9/17-21/84 TS 6.5. IV OP Failure to perform Inspection a 50RC review in a
: 84-34/84-34 timely manner.
TS V Rad. Con. Failure to provide required requalification
- training for
- Chemistry 3 Technician in a j timely manne j 50-272/ 9/18-24-84 10CFR20.202 IV Rad. Con. Failure to supply
,
84-35 proper i radiological
;
monitoring equipmen ! Combined 10/22-26/84 10CFR50.47 III Emer Certain personnel Inspections 10/31/84 (b)(15) Pla did not receive 84-39/84-38 11/5-9/84 adequate training i " 84-43/84-41 11/30/84 for Emergency Planning, j 10CFR50.47 III Emer Prompt corrective { (b)(14) Pla actions were not " i taken on ! identified l ' deficiencies l l a i . l
, - , - , , .-. , - - -- , , , , - , , .
- - - - . . . - --.-
~ . . T3-3 TABLE 3 (CONT'D)
Inspection Inspection Severity Functional Report N Date- Re Level Area Violation Combined 10/27/84 - 10CFR50.59 IV Outage . Improper use of Inspection 12/14/84 (b) Man. Mods, scaffolding in the 84-42/84-42 close proximity of Class I seismic structure CFR50 AP IV Outage Procedures did not B Criterion V Man. Mods, provide adequate , details to install expansion joints in service wate Combined 12/17-21/84 TS 3.7.11 IV Fire Fire barriers and Inspection Prot, fire doors were 84-46/84-46 found non-functiona Combined 12/15/84 - TS 6.11 V Ra No record of Inspection 1/22/85 Co survey result /84-47 TS 6. IV OP Began maintenance on one boric acid transfer pump heat tracing while the other train was inoperable rendering both inoperabl Combined 1/21/85 TS IV OP Improperly imple-Inspection 2/4-7/85 mented primary 85-01/85-04 leak rate
.
calculations in a accordance with NRC rules and guideline Combined 1/8/85 Security III Security Vehicle entered Inspection Plan protected area 85-02/85-01 with unauthorized i item in a suitcase
- (No Civil Penalty because of mitiga-
ting conditions)
- _ _ _ _ -_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ . - . _ _ _ _ _ _ _ _ - - _ _ _ - _ _ _ . . . _ - _ _ _ _ _ - - - _ _ _ - _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _
a
. . .' T3-4 TABLE 3 (CONT'D)
Inspection Inspection Severity Functional Report N Date Re Level Area Violation Combined 1/23/85 - TS 3.3. IV OP Purging and pres-Inspection 3/1/85 TS 3. sure relieving 85-03/85-03 containment without proper radiological instrumentation and isolation protectio Combined 3/2/85 - TS IV OP Improper change to Inspection 4/5/85 a procedure making ' 85-07/85-07 it inconsistent with Technical , Specification /85-08 3/21-22/84 10CFR50 IV Man. Mods. Failure to ' 3/25-29/85 APP B adequately torque Criterion II seismic anchors in installation of a Class I syste Combined 4/8-11/85 Security IV Security Not enough illumi-Inspection Plan nation at required 85-10/85-10 areas of the sit Security IV Security Security officer Plan was observed not properly manning his pos Combined 5/7-31/85 Security V Security Licensee Inspection Plan identified failure 85-12/85-13 to meet require-ments of Training and Qualification Pla Combined 7/1-31/85 TS 6. IV Op Improper sampling Inspection of waste gas decay 85-15/85-17 tanks due to improperly implemented l on-the-spot I chang ! l
- C.,
* - , T3-5 TABLE 3 (CONT'D)
Inspection ~ Inspection Severity Functional Report N Date ~ Re Level Area- Violation TS 6. IV Op Unit trip'due to operator failure to follow procedur Combined 9/1-30/85 TS IV Op Improperly imple-Inspection mented primary 85-20/85-22 leak rate calcula-tions in accordance with NRC rules and guideline ,
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. . ., . T4-1 TABLE 4 INSPECTION REPORT ACTIVITIES-(9/1/84 - 9/30/85)
SALEM NUCLEAR GENERATING STATION Report / Dates Inspector Hours Areas Inspected Unit 1 Unit 2 84-32 84-32 Resident 215 Routine, daily inspec-9/1-24/84 tions and unscheduled backshift inspection Cancelled 1 84-34 84-34 Specialist 36 Routine, unannounced ' 9/17-21/84 inspection of the-licensee's radioactive waste management program, t 84-35 --- Specialist 48 Special, announced 9/18-24/84 safety inspection to review control of work in the reactor head area and to investigate an allegation regarding improper exposure i monitoring and recor keepin Resident 191 Routine, daily inspec-9/25-10/26/84 tions and unscheduled backshift inspection SALP 10/1/83-8/31/84 84-38 84-37 Specialist 69 Unannounced inspection 10/15-19/84 by two region-based inspectors to determine effectiveness of licensee's non-licensed training progra .
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P
.' T4-2-TABLE 4 (CONTD)
i Report / Dates Inspector Hours -Areas Inspected 84-39 84-38 Specialist 655 Routine observation of 84-43 84-41 annual emergency exer-10/22-26/84 cise and followup 11/5-9/84 inspection of emergency ' preparedness program.
! 84-40 84-39 Specialist 98 Routine, unannounced 10/22-26/84 safety-inspection of radiation safety progra Specialist Special Team Inspection 10/29 - 11/2/84 84-42 84-42 Resident 264 Routine, daily inspec-10/27 - 11/30/84 tions and unscheduled backshift inspection This Report Combined With 272/84-39; 311/84-38 84-44 84-43 Resident Management Meeting to 11/16/84 discuss status and details of PSE&G Action Plan for improvement of Nuclear Department operations.
l 84-45 84-44 Specialist 208 Special announced l 11/26-30/84 inspection of the implementation of the licensee's commitments relative to , post-sccident sampling l , and mo11torin Specialist 44 Routine, unannounced l 12/10-21/84 inspeccion of ISI l acti'ities.
l ' 84-46 84-46 Specialist 70 Routine, unannounced 12/17-21/84 inspection of the Fire
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Protection / Prevention i Progra .. -
.. , ' . * T4-3
TABLE 4 (CONTO) Report / Dates Inspector Hours Areas Inspected 84-47 84-47 Resident 198 Routine, daily inspec-12/15/84 - 1/22/85 tions and unscheduled backshift inspection Routine, unannounced
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Specialist 162 1/21-25/84 inspection of the a 2/4-7/85 Reactor Coolant System '
;
leakage measurement i progra , 85-02 85-01 Specialist 4 Special, unannounced
; 1/8/85 physical protection inspection.
< 85-03 85-03 Resioent 194 Routine, daily , 1/23 - 2/22/85 inspections and unscheduled backshift inspections.
' 85-04 85-04 Cancelled , 85-05 85-05 Specialist 9 Special, unannounced 2/25/85 inspection to review concerns expressed by workers.
85-06 85-06 Cancelled- ! 85-07 85-07 Resident 156 Routine, daily 3/2 - 4/5/85 inspections and unscheduled backshift inspection ' 1 ---- 85-08 Resident 116 Special Team Inspection 3/21-29/85 of selected design change request , 85-08 85-09 Specialist 41 Routine, announced 4/1-4/85 inspection to follow up unresolved items relating to Fire l Protection / Prevention > Progra l
.' ' ,' T4-4 TABLE 4.(CONTD)
Report / Dates Inspector Hours Areas Inspected I-l 85-09 85-11 Resident 82 Routine, daily- ! 4/6 - 5/6/85 _ inspections and unscheduled backshift inspections.
l 85-10 85-10 Specialist 37 Routine, unannounced i 4/8-11/85 physical security inspectio Specialist 10 Management meeting to 4/19/85 discuss action plan.for improvement of Nuclear , department.
l !
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85-12 Specialist 80 Routine, unannounced 4/15-19/85 inspection of the radiation safety progra Resident 130 Routine, daily 5/7-31/85 inspections and j unscheduled backshift inspection Resident 147 Routine, daily 6/1-30/85 inspections and unscheduled backshift inspections.
l 85-14 85-16 Specialist 92 Routine, unannounced 6/24-28/85 inspection of Quality i Assurance program, i 85-15 85-17 Resident 182 Routine, daily 7/1-31/85 inspections and unscheduled backshift , inspection Specialist 140 Special, announced inspection of the i ' Emergency Preparedness Program.
l l l
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g i a . -T4-5 j TABLE 4 (CONTD)- - Report / Dates- Inspector Hours Areas Inspected
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85-17 85-19 Specialist 12 Special reactive . 7/3/85- inspection to review licensee ~ reported problems with waste gas tank' sampling and control of contaminated tools.
85-18 85-20 Resident 177 Routine, daily 8/1-31/85 inspections and unscheduled backshift inspection Specialist 37 Routine, unannounced l 8/19-23/85 inspection of physical
~ ; protection inspectio <
85-20 85-22 Resident 190 Routine, daily
: 9/1-30/85 inspections and- '
unscheduled backshift.
t inspection Specialist 44 Routine, unannounced , 9/9-13/85 inspection of the radiation safety , progra Resident 10 Management meeting to 9/25/85 discuss status and-closeout of PRE &G i Action Pla , _ . . . , , .- . . .-
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- TS-1 l TABLE 5
,
LER SYN 0pSIS (9/1/84 - 9/30/85) ' SALEM GENERATING STATION j . UNIT 1 i
- LER Number Event Date Cause Code Description
! -! 84-17 7/16/84 X ~ Foreign Material in Charging Pump - Suction Line l 84-18 7/13/84 A' Inadvertent Safety Injection . ~ Signal
! 84-19 8/29/84 X Impingement of Sea Turtle in the ! Circulating Water Intake i
84-20 8/22/84 8 Containment Air Locks - Design ) Deficiency ! 84-21 10/14/84 8 Containment Isolation Valve < i ICC131 Inoperable. (Unit j Shutdown) i Inadvertent closure caused by ll pressure transient when service water pump vas started.
j 84-22 10/19/84
A Containment Isolation Valves ICV 68 and ICV 69 Inoperable.
{ ' Operator judgement in error by using a valve that was thought to j have been tested properl : I; 84-23 10/22/84 8 Reactor Trip From 8% While j Performing Turbine Overspecd Test 't 84-24 10/20/84 X Engineered Safety Feature
Actuation System Feedwater
; Isolation Malfunction
- 84-25 11/6/84 E Reactor Trips From 91% and 93% !
I Due to Low-Low Level No. 13 Steam l Generator , {- 84-26 11/7/84 B Containment Isolation Valve 11MS18 Inoperable. Valve leaking
,
by.
.
. ~ ^ . . -.= ' . TS-2-TABLE 5 (CONTD)
LER Number Event Date Cause Code - Description 84-27 11/18/84 B' Service Water Leaks Inside Containment 84-28 12/23/84- A Reactor Trip From 77% While . Reducing High Flux Trip Setpoints 84-29 12/31/84 B Reactor Trip From 93% Due to Partial Closure of 11BF19 ' 85-01 2/5/85 B AFW Pump Circuitry Does Not Meet
>
Single Failure Criteria 85-02- 2/13/85 A Containment Pressure Relief Operations Not IAW Technical Specification Requirements
' 85-03 2/14/85 B 12MS28 Closed Signal to SSPS Train "B" Inoperable , 85-04 2/26/85 X Foreign Matter Contamination of
- New Terrestic T-68 Lube Oil 85-05 7/1/85 0 Waste Gas Decay Tanks Not Sampled Prior to Releasing Contents-85-06 3/20/85 X Service Water Leak Inside of ,-
i Containment 85-07 7/8/85 X No. 14 Waste Gas Decay Tank - i Inadvertent Release of Contents 85-08 7/29/85 B Service Water Leak Inside of Containment 85-09 9/13/85 A Exceeded Time Limit on Diesel Surveillance Testing 85-10 9/19/85 A Waste Gas Dacay Tank 0xygen Not Continuously Monitored
'
85-11 9/22/85 A Action Statement for Reactor Coolant System Leak Rate Not
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Entered.
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TABLE 5 (CONTO) t LER SYNOPSIS (9/1/84 - 9/30/85) 1~
!
l SALEM GENERATING STATION ! 1 UNIT 2
LER Number Event Date Cause Code Description i 84-18 7/25/84 E Reactor Trip From 66% With l Resultant Safety Injection : ! 84-19 7/26/84 A Both Containment Spray Systems Inoperable in Mode 4 84-20 8/13/84 A Component Cooling System - Missed Surveillance - 84-21 8/26/84 E Reactor Trip From 100% Due to. Low j Low Level #24 Steam Generator 84-22 9/5/84 E Reactor Trip From 54% - SF/FF i Mismatch and Low Level #24 Steam t Generator , i 84-23 9/6/84 X,A Plant Vent Sample Pump Inoperable - 84-24 10/4/84 X Reactor Trip From 100% Due to Turbine Generator-Failure J
- 84-25 11/26/84 A Weekly' Plant Vent Particulate
' Sample Not Analyzed Within Time : . Required by Technical ;
; Specifications i
,
! 84-26 12/21/84 B Radioactive-L.iquid Release Not j Continuously Recorded > l' 85-01 1/28/85 A 2A Ofesel Generator - Test
Failure. Service water valve ! installed incorrectly caused high j_ cooling water temperature.
] 85-02 3/8/85 X 2A Diesel Generator - Test
'
Failure. Excessive friction 1 i preventing proper fuel rack ' i i motio ' I
:
i i ! a e
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T5-4 TABLE 5 (CONTD) LER Number Event Date Cause Code Description 85-03 3/29/85 X Pressurizer Overpressure Protection System Channel II Initiations 85-04 4/13/85 X Reactor Trip From 25% During Startup Operations 85-05 4/17/85 E Reactor Trip From 17.5% Power During Startup Operations 85-06 4/23/85 D Reactor Trip From 54% - Turbine Trip and P-7 85-07 4/7/85 X Number 22 Steam Generator Safety Valves Inoperable 85-08 5/2/85 0 Reactor Trip From 69*4 - Main Generator " Loss of Field" Pelay Actuation 85-09 5/10/85 8 Reactor Trip From 100% - Dropped Control Rod 85-10 7/7/85 B Failure to Comply with Technical Specification Action Requirements 85-11 7/7/85 A Reactor Trip From 33% - High-High Level No. 21 Steam Generator / Turbine Trip 85-12 7/8/85 B Reactor Trip From 10% Due to Low-Low Water Level in #23 Steam Generator 85-13 7/6/85 X 28 Diesel Generator Test Failur Malfunction of Field Ground Relay due to mechanical latch alignmen /11/85 X 28 Diesel Generator Test Failure Due to Fuel Oil Leak , 85-15 7/20/85 X Reactor Coolant System Unidentified Leakage Greater Than T/S Limit L
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. T5-5 TABLE 5 (CONTO) l LER Number Event Date Cause Code Description 85-16 7/23/85 X Boric Acid Tanks and Boron Injection Tank Boron-Concentration Below Specifications 85-17 8/8/85 X,8 Reactor Trip From 100% During Solid State Protection System-Testing 85-18 8/27/85 X,8 Component Cooling Water Heat Exchanger Service Water Flo. Rate Below Required Value 85-19 9/11/85 B -Service Water Leak in Containment 85-20 9/21/85 X Manual Reactor Trip
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TABLE 6
- REACTOR TRIPS AND PLANT SHUTDOWNS - UNIT 1 Power Date Level Description Cause 9/1/84 The fifth refueling outage 10/12/84 commenced on February 24, 1984 10/13-16/84 Low power physics testing r following refueling outage 10/14/84 Shutdown due to inoperable Limitorque
! containment isolation valve operator failed - i 10/21/84 Shutdown due to feedwater valve Unknown i problem (3 of 4 BF13 Valves) closing without cause 10/21/84 Startup I 10/22/84 8% While performing overspeed trip An induced vibra- ] test on the main turbine, after tion during the
; refueling, with power greater turbine overspeed
than P-7 interlock. Operator resulted in a I
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error. Trip could have been false pressure avoided with power less than signal P-7 interlock l 10/23/84 Startup
11/4/84 Shutdown due to periodic Low Stator water pumps j Flow alarms on Stator Water were cavitating Systen during system i purges due to i improper method i 11/4/84 Startup 11/6/84 91% Trip due to Low Steam Generator EHC System i
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level in #13 Steam Generator, malfunction EHC System on Main Turbine causing a load ] caused trip rejection < i 11/9/84 Startup
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l . T6-2 l L TABLE 6 (CONTD) REACTOR TRIPS AND PLANT SHUTDOWNS - UNIT 1 l Power Date Level Description Cause 11/11/84 93% Trip due to Low Steam Generator EHC System level on #13 Steam Generator malfunction ! EHC System on Main Turbine caused trip 11/20/84 Startup 12/3/84 77% Technician error while. adjusting over temperature delta T circuits setpoints with channel 44 Nuclear Instrumentation bypassed (allowed by Technical Specifications).
The technician mistakenly placed channel 44 back in service causing the trip 12/3/84 Startup 12/23/84 Trip due to Over temperature Technician error Delta T 12/28/84 Startup 12/31/84 95*. Trip due to Steam Generator steam Malfunctioning flow / feed flow mismatch and steam feedwater control generator low level caused by valve malfunction of air operated feed regulation valve - 1/1/85 Startup .
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. T6-3 TABLE 6-(CONTD) REACTOR TRIPS AND PLANT SHUTDOWNS - UNIT 2 Powe Date Level Description Cause 9/5/84 54% While operating on one feed- Steam Generator water pump the other feedwater Pump tripped due pump tripped causing a low to air intrusion Low water level in No. 24 in the pump Steam Generator suction line 9/7/84 Startup 10/4/84 100% Trip due to generator Generator Failure differential relay protec-tion actuation 10/4/84 - Refueling and Generator Replacement Outage 4/10/85 4/10/85 Startup and Low Power Physics Testing 4/13/85 25% While performing maintenance / Steam Generator Feed surveillance on steam flow Pump. Failure instruments a low steam generator level with steam flow / feed flow mismatch tripped the unit. Transmitter voltage checks were being performed with one channel in tes Plant isolations caused another channel to trip causing the reactor to trip. This trip was attributed to poor judgment on the part of the supervisor to ' allow testing while the plant was in a low power isolating condition 4/13/85 Startup 4/17/85 17% Trip was caused by Low Low Feedwater Transient-in No. 24 Steam Generator when No. 21 Steam Generator feed pump lost speed due to condensate collecting in the steam supply. Caused by crud and corrosion products in the steam traps which could not remove the condensat .
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16-4 TABLE 6 (CONTD) REACTOR TRIPS AND PLANT SHUTDOWNS - UNIT 2 Power Date Level Description Cause 4/18/85 Startup-4/23/85 54% Turbine trip and P-7 interloc Turbine Lube Oil Cooler A spike in turbine control improperly operated oil pressure induced by air trapped in the lube oil cooler. When the coolers were shifted the air entered the control oil syste /23/85 Startup 5/2/85 69% Turbine trip / generator trip due Improper wiring of the to loss of field relay actua- Loss of Excitation tio Improperly wired relay, during installation of new main generator. Wired improperly due to incorrect wiring schematic 5/4/85 - Startup 5/10/85 100% Trip due to high negative Dropped rod due to a flux rate when Rod (2C4) poor electrical dropped inot the cor /15/85 Startup 6/28/85 Shutdown to repair a Flange Leakage on leaking Pressurizer Safety Pressurizer Safety Valve Valve 2PR-4 7/7/85 Startup 7/7/85 53% Main turbine tripped due to Operator Error High High water level in No. 21 Steam Generator. Operator erro Failure to follow procedure while tranferring modes of operation for feedwater system 7/8/85 Startup '
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- , REACTOR TRIPS AND PLANT SHUTDOWNS'- UNIT 2 i
, Power Date Level Description Cause i ,.
7/8/85 10% ThN, rip was caused by Low Operator Error
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Low water level in No.~23 Steam Generator. Operation-was being conducted at a power-
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level above the capacity ~for the auxiliary feedwater pumps to deliver the necessary water flow to sustain water level in the proper band. Management inattentien to plant startup was caus /8/85 Startup 7/20/85 Shutdown to Repair RCS RCS Leakage Valve Leakage 7/22/85 Startup 7/23/85 Shutdown to correct Boro Boron Concentration out
, Injection Tank and Boric of specification Low Acid Storage Tank Boro Concentrations 7/23/85 Startup ,
8/8/85 100% P-7 turbine trip due to loose Loose Lead'in Reactor t wire in reactor trip breaker Trip. breaker cabinet found during normal breaker surveillance testin /10/85 Startup 8/27/85 Shutdown to Repair ~ Component Vibration Induced Cooling Service Water Flow Fatigue Failure of Problems 'J 225W356 8/29/85 Startup' s s r n
.g 9/21/85 Manual Trip dbe to inability Leakage past '
to maintain RCS pressure pressurizer spray
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isolation valve 9/23/85' s4 Startup
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TABLE 7 RECORD OF MEETINGS AND OFFICIAL DOCUMENTS ISSUED 1. NRR/ Licensee Meetings at NRC Semi-auto Switchover 11/29/84 11/30/84 Refueling Outage Technical Specifications: 07/25/85 Briefing New Division of Licensing Director 02/14/85
2. Site Visits / Meetings by the Project Manager and Other NRR Personnel ' SALP Management Meeting 11/15/84 Management Meeting - Discuss Action Plan
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11/16/84 Management Meeting - Discuss Action Pla /19/85 - Management Meeting - Discuss Action Plan 09/25/84 DCRDR Pre-Implementation Audit 11/26/84 AEOD Meeting - Wrong Train / Unit 07/23/85 E0P Upgrade Audit 09/25/85 3. License Amendments Issued Amend N Subject Date Unit 1 Unit 2 57 26 Main Steam Isolation Valve 10/15/84 58 27 RCS Inventory Balance 10/17/84 59 28 (1) RETS 12/05/84 (2) Nuclear Dept. Changes , (3) RTB Testing & Sur Removes License Condition 02/07/85 30 Revise K(z) Normalized FQ(z) -02/22/85 60 31 (1) Modifies Tech Spec Table 11/13/84 (2) Corrects Typo Error (3)-Revises delta T Trip 61 61 32 Extend Impl Time for RETS 04/09/85 62 33 Nuclear Dept Reorg 05/13/85
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34 Revises Power Dependent 05/17/85 Insertion Limits 63 35 RETS Corrections 05/28/85 _
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T7-2 TABLE 7 (CONTD) License Amendments Issued (Cont'd) Amend N Subject Date Unit 1 Unit 2 64 36 RETS Changes 05/30/85 37 Control Room Leak Test Pressure 05/30/85 38 Sodium Hydroxide Test Flow Value 06/13/851
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65 39 Purge and Vent Tech Specs 06/25/85 i 7 40 Corrects Typo Error 09/16/85 66 41 Add Surv Regt for Safety 09/16/85 Injection Pumps
67 42 Add Tech Spec for Post 09/16/85~ i Accident Sampling System Exemptions (Technical and Schedular)' - None Granted Reliefs - None Granted Orders Issued - None Letters with Safety Evaluation - Total of 21 Total Licensing Actions Plant-specific Multi plant TMI Unit 1 Unit 2 !! nit 1 Unit 2 Unit 1 Unit 2 On 10/1/84, active- 9 11 17 17 16 16 action Completed during 10 16 9 9 5 5 SALP period New Actiuns 19 17 9 On 9/30/84, active 18 12 17 17 11 11 actions
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unirta sTAras NUCLEAR RESULATORY COMMISSION Enclosure 3' g
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xiNG OF PRUSSI A.PaMNSYL.VANIA 1940s t - u.e s c ms Docket Nos. 50-272 50-311 Public Service Electric and Gas Company ATTN: Mr. Corbin A. McNeill, Jr'. Vice President - Nuclear P.O. Box 236 - ., Hancocks Bridge, New Jersey 08038 Gentlemen:
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Subject: Systematic Assessment of Licensee Performance (SALP) - Report Nos. 50-272/85-99; 50-311/85-99 The Region I SALP Board has reviewed and evaluated the performance of activities"at the Salem Generating Station Units 1 and 2 for the period September 1,1984, through September 30, 1985. The results are contained in the enclosed repor A meeting to discuss this assessment can be scheduled should you so desir ( Such a meeting would be intended as a forum in .which you should be prepared to discuss your plans to improve performance where weakness was note '~ Should you desire to submit comments to this assessment, such comments should be submitted within 30 days of receipt of this letter; however, no written response is require Your cooperation is appreciate
Sincerely, Thomas E. Murley Regional Administrator Enclosure: SALP Report Nos. 50-272/85-99; 50-311/85-99 l l Of p l O O b '3 _ p 'tL/ F 2 & " .
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