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ACCESSION NBR:9111250053 DOC.DATE: 91/11/19 NOTARIZED: NOFACIL:50-387 Susquehanna Steam Electric Station, Unit 1, Pennsylva

50-388 Susquehanna Steam Electric Station, Unit 2, Pennsylva'=AUTH.NAME AUTHOR AFFILIATION

KEISER,H.W. Pennsylvania Power & Light Co.RECIP.NAME RECIPIENT AFFILIATION

CURTISS,J.R. NRC — No Detailed AffiliationGiven

SUBJECT: Forwards set of viewgraphs describing principal activitiesof nuclear safety assessment group 6 paper presented atAmerican Nuclear Society Reactor Operations Div Topicalmeeting last Aug in Bellevue,WA.

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WOV la SM,

Pennsylvania Power 8 Light CompanyTwo North Ninth Street ~Allentown, PA 18101-1179 ~ 215/774-5151

Harold W. KeiserSenior Vice President-Nuclear215/774-4194

Commissioner James R. CurtissU.S. Nuclear Regulatory CommissionWashington, D.C. 20555

SUSQUEHANNA STEAM ELECTRIC STATIONPP&L NUCLEAR SAFETY ASSESSMENT GROUPPLA- 1 FILE R41-2

Docket Nos. 50-387and 50-388

Dear Commissioner Curtiss:

During your recent visit to the Susquehanna Station you expressed an interest in the activitiesof our Nuclear Safety Assessment Group (NSAG). Unfortunately, time did not permit adiscussion of NSAG work.

Enclosed is a set of viewgraphs which describes the principal activities of the PP&L NSAG.The viewgraphs provide an overview of what the group does and how their work has impactedthe station. We willbe glad to provide copies of individual reports or arrange a briefing shouldyou wish to pursue the matter further.

Also enclosed is a short paper on Safety Performance Evaluation, which was presented by theManager Nuclear Safety Assessment to the American Nuclear Society Reactor OperationsDivision Topical Meeting last August in Bellevue, Washington. Itcaptures in a few pages someof the innovative work being done by our NSAG.

tI

Very truly yours,

H. W. Keiser

Enclosure

cc: I:NRCZ)ocument„Control Desk (original)~NRC Region IMr. C. R. Miller, NRC Project Director - OWFNMr. J. White, Division of Reactor Projects - Region IMr. G. S. Barber, NRC Sr. Resident Inspector - SSESMr. J. J. Raleigh, NRC Project Manager - OWFN

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PENNSYLVANIA POWER AND LIGHT

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October 31, 1991

NUCLEAR SAFETYASSESSMENT GROUP

SDOS

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J

SR. VICE PRESIDENT-NUCLEAR

HAROLD W. KEISER

CA 431

MANAGER-NUCLEARSAFETY ASSESSMENT GROUP

JAMES R. MILTENBERGER

SENIO NUCLEARSAFETY EVALUATOR

SITE SAFETY ASSESSMENTGROUP SUPERVISOR

ANDRE DOMINGUEZ

NUCLEAR SAFETYEVALUATOR

WILLIAMR. LICHT

NUCLEAR SAFETYEVALUATOR

RICKEY E. DIXONRICHARD A. HENRY

October 31, 1991

C

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QUALIFICATIONS OF PEOPLE

NAME 'DUCATIONLICENSE OR

EQUIVALENTNUCLEAR EXPERIENCEMILITARY COMMERCIAL

MILTENBERGER BS CEMS MGT

SRO (NAVY)PE

16 10

DOMINGUEZ BS ME PE 16

HENRY BS NUCE SRO 16

LICHT BS CHEM E

MS CHEMMS NUCE

DIXSON BS NUCE SRO

VACANT

October 3'1, 1991

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ACTIVITIES

1. PREPARE DAILY REPORT

2. INVESTIGATE INCIDENTS

3. SAFETY ENGINEERING TO PREEMPT PROBLEMS

4. ASSESSMENT OF PERFORMANCE

5. POINT OF CONTACT FOR EMPLOYEES'AFETYCONCERNS

6. PARTICIPATE IN EMERGENCY ORGANIZATION

7. PERFORM SPECIAL ASSIGNMENTS

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DAILY REPORT

OBJECTIVES:

1. ACCURATE, TIMELY INFORMATION TOMANAGER-NSAG, SR. MGT.

RCE NSAG PERSONNEL TO GET OUT INANT AND LOOK AT CONDITIONS, REVIEWGS, ETC., EVERY DAY.

3. ENSURE THAT NSAG PEOPLE ARE KNOWN BYTHE OPERATORS.

DISTRIBUTION:

CEO PPRLEXECUTIVE VPSRVP

VP-NUCLE-NUCLEAR 0

-0ARPE

PERATIONS

RATIONSSPSUSERE

ECIAL ASST. TO PRESIDENTPERINTENDENT-SSESNIOR MANAGERS-NUCLEAR DEPARTMENTSIDENT INSPECTOR

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4

INITIATION

INVESTIGATE INCIDENTS

o SENIOR V.P. OR V.P. -NUCLEAR OPERATIONS

o PLANT SUPERINTENDENT

o INDIVIDUAL'CONCERNS

o NSAG INITIATIVE

CRITERIA

o MAJOR INCIDENT INVOLVING OPERATOR ERROROR A VIOLATION

o MINOR INCIDENT WHICH APPEARS TO HAVE ALESSON

o ATTENTIF THEUSUALL

ION DY AREY DQE

EVOTED BY LION TQP QF P

S NQT PURSUE

NE ORGANIZATION.ROBLEM, NSAG

OBSERVATION

o REDCAUGRO

UCED FREQUENCY AS PLANT STAFF ROOTSE INVESTIGATION CAPABILITY HASWN.

RECENT INCIDENT INVESTIGATIONS

4-88 FUEL POOL RESIN DISCHARGE EVENT OF3/23/88

5-88 STEAM SEPARATOR INCIDENT OF 4/23/88

2-89 SCRAM OF 1/04/89

4-89 HPCI STOP VALVE INCIDENTS

7-89 RAILROAD BAY DAMPER MISPOSITIONINGEVENT OF 7/21/89

8-89 UNANTICIPATED EXPOSURE EVENT OF8/31/89

2-90 LOSS OF SHUTDOWN COOLING EVENT OF2/03/90 (ALERT)

3-91 IMPLICATIONS OF USING RWCU INBLOWDOWN MODE

5-91 SCRAM OF 7/31/91

SAFETY ENGINEERING TO PREEMPT PROBLEMS

RECOGNIZE A SITUATION AND MAKE AN IN DEPTHANALYSIS

PRINCIPAL AREA HAS BEEN OUTAGE SAFETY

o HEAT REMOVAL

o DRAINAGE EVENTS

o OUTAGE SAFETY REVIEWS

PLANNING

EXECUTION

SIGNIFICANT IMPACT QN THE STATION - GQQDBANG FOR THE BUCK

o BIG EFFORT

o NO VISIBLE PRNORMALLY A PRREADINESS MEE

DUCT - RESULT ISSENTATIQN AT QUTAGEING

o NSAG INPUTS ARE NORMALLY VERBAL TOOUTAGE PLANNING STAFF.

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SSES IS LEADER IN INDUSTRY IN OUTAGESAFETY

o POST VOGTLE BUZZ WORD IS OUTAGEPLANNING TQ MINIMIZE RISK

o SSES HAS BEEN DOING OUTAGE RISKPLANNING FOR YEARS

o NSAG HAS INFLUENCED THE RISK PLANNINGEFFORT

o OUTAGE REVIEM METHODOLOGY PRESENTED TONRC, TO INPO AND TO INDUSTRY MEETINGS

o OUTAGE TUTORIAL PRESENTED BY NSAG ATPERRY

o DEVELOPED OBJECTIVE CRITERIA FOR OUTAGESAFETY PERFORMANCE MEASUREMENT

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ty

CHALLENGES:

1. C

R0

NSOLIDATE KNOWLEDGE GAINED IN ANTAGE PLANNING MANUAL - DECAY HEATMOVAL CHAPTER DONE. (REPORT 4-90)

2. INFLUENCE INDUSTRY - RULE MAKING ISINEVITABLE. MUST BE DONE CORRECTLY.

o SR VP-NUCLEAR HEADED NUMARC OUTAGERISK MANAGEMENT EFFORT

o NSAG DID LEG WORK.

SAFETY ENGINEERING TO PREEMPT PROBLEMS

NSAG ACTIVITIES AND REPORTS

5-83 ASSESSMENT OF SURVEILLANCE TESTINGPROGRAM.

13-84 IMPLICATIONS OF LOSS OF WATER FROMTHE SPENT FUEL POOL.

OPERATIONS WITH POTENTIAL FORDRAINING THE REACTOR VESSEL.

PLI-44871

DECAY HEAT REMOVAL UNIT 2FIRST REFUELING OUTAGE.

ASSESSMENT OF POTENTIAL FORDROPPING HEAVY LOADS ON SPENT FUEL.

4

9-88 WORK PRACTICONTAINMENTCONTAINMENT

CES RELINTEGRHATCHE

ATED TO PRIMARYITY (ASSEMBLY OFS).

5-89 SURVEILLANCE TESTING METHODOLOGY.

OUTAGE PLANNING INFORMATION.

ANALYSIS OF ALTERNATE SHUTDOWNCOOLING.

OUTAGE REVIEWS - ALL OUTAGES TODATE

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ASSESSMENTS OF PERFORMANCE

CATEGORIES:

1. SURVEILLANCES QF OPERATIONS ANDMAINTENANCE

o SEVEN OPERATIONS

o FOUR MAINTENANCE

I

2. ASSESSMENTS OF PROGRAMS

o OQA

o RELAY CALIBRATION

o SECURITY AND RADIATION PROGRAMSEFFECT UPON EMERGENCY ACCESS

o STATES LINKS PROGRAMS

3. ASSESSMENTS OF DEPARTMENT PERFORMANCE

o MONTHLY SAFETY OVERVIEW

o ANNUAL SUMMARY ASSESSMENT REPORT

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MONTHLY SAFETY OVERVIEW AND ANNUAL SUMMARYASSESSMENT BOTH GO TO THE CORPORATEMANAGEMENT COMMITTEE AND BOARD OFDIRECTORS.

FOR YEAR1990 PHIASSESSME

S BOLADENT R

THLPEP

WERE UNIQUE TO PPRL. INHIA ELECTRIC DID A SUMMARYORT. OTHERS MAY BE DOING

THEM ALSO.

OPERATIONS SURVEILLANCE AND MAINTENANCESURVEILLANCE ARE NO LONGER UNIQUE TO PP&L.TO BEST OF OUR KNOWLEDGE, THEY WERE DONEHERE FIRST.

J lI''

OBSERVATIONS CONCERNING PERFORMANCEASSESSMENTS

OPERATIONS SURVEILLANCE HAS HADSIGNIFICANT IMPACT OVER THE YEARS

o CONTROL ROOM QUIETING

o USE OF PROCEDURES

o COMMUNICATIONS

o ROUNDS SHEETS

o PANEL WALKDOWNS

October 31, 1991

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OBSERVATlQNS CQNCERNING PERFORMANCEASSESSMENTS CONTINUED

MAINTENANCE - FIRST THREE SURVEILLANCESDONE. ZERQ VISIBLE IMPACT

o SOURCE OF GREAT NSAG FRUSTRATION

o FINDINGS HAVE BEEN CONSISTENT WITHTHOSE OF INPO AND'RC

ATTEMPTING TO IMPROVE VIA BETTERCOMMUNICATION AND LIAISON WITH MAINTENANCESECTION

o DEVELOPED 1991 SURVEILAND CHECK LIST IN COOPMAINTENANCE MANAGEMENT

LANCE PLANERATION WITH

EILLANCES.

o FINDINGS AGAIN CONSISTENT WITHTHOSE QF NRC AND OF INPO.

o 1991 RESULTS MUCH BETTER RECEIVEDBY MAINTENANCE. MAINTENANCE USINGCHECK LISTS TO CONDUCT THEIR OWNSURV

PROGRAM ASSESSMENTS HAVE BEEN EFFECTIVE

o RELAY CALIBRATION - MAJOR PROGRAMOVERHAUL

o STATES LINK - RIGOROUS LATE OUTAGECHECK ESTABLISHED

o SECURITY EFFECT ON EMERGENCY ACCESS- ELIMINATE KEY NUMBERS

October 31, 1991

SUMMARY ASSESSMENT REPORT

MAJOR NSAG EFFORT

ATTEMPTING TO MAKE A RATIONAL, OBJECTIVEASSESSMENT OF NUCLEAR SAFETY PERFORMANCE.

METHOD IS TO DEFINE A SET OF SAFECONDITIONS AND THEN MEASURE DEPARTURESFROM THOSE CONDITIONS.

COMPARE PERFORMANCE MITH:

o INDUSTRY WHEN POSSIBLE

o PAST PERFORMANCE AT SUSQUEHANNA

OPINION IS THAT PERFORMANCE ASSESSMENT ININDUSTRY IS POOR.

OMPANY HINGES TO SOMEIS SUBJECTIVE.THIS PROCESS.

FINANCIAL HEALTH OF CDEGREE ON SALP. SALPINDUSTRY MUST UPGRADE

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GOAL IS TO:

1. DEVELOP AN OBJECTIVE PROCESS BY WHICHTO MEASURE PERFORMANCE AT SSES.

2. ATTEMPT TO NUDGE THE INDUSTRY TOWARDMORE OBJECTIVE PERFORMANCE INDICATORS.

o NSAG PRESENTED PPERFORMANCE EVALMEETINGS IN 1991

APERS QN SAFETYUATION AT TWO ANS

o CONTRIBUTE TO NUMARC ANDOWNERS'ROUP

EFFORTS

METHODOLOGY IS TO:

1. DEVELOP THE NECESSARY DATA BASE FOROBJECTIVE INTERNAL ASSESSMENTS.

2. PREACH THE GOSPEL WHEN THE OPPORTUNITYARISES.

l I

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RECENT PERFORMANCE ASSESSMENTS

1-89 SUMMARY ASSESSMENT - JANUARY 1989

3-89 SURVEILLANCE OF PLANT OPERATIONS-APRIL 1989

9-89 MAINTENANCE SURVEILLANCE - NOVEMBER1989

1-90 SUMMARY ASSESSMENT - JANUARY 1990

3-90 SURVEILLANCE OF PLANT OPERATIONS-MAY 1990

1-91 SUMMARY ASSESSMENT - JANUARY 1991

2-91 SURVEILLANCE OF PLANT MAINTENANCE,MARCH 1991

4-91 SURVEILLANCE OF PLANT OPERATIONS,JUNE 1991

October 31, 1991

EMERGENCY ORGANIZATION ACTIVITIES

1. SERVE IN QN-CALL POSITIQNS

RECOVERY MANAGERMOC STAFFMOC TECHNICAL BRIEFERS

- WRL- RAH

AJDRED

2. REFEREE FOR DRILLS

3. ASSIST IN SCENARIO PREPARATION

4. ASSIST IN TRAINING

5. QNLY LINE FUNCTIQN DONE BY NSAG.VALUES ARE:

A. DEMQNSTRATE COMPETENCE

e. INTERACT IN NON-ADVERSIAL ROLE

c. SHARE EMERGENCY PLAN BURDEN

l

POINT OF CONTACT FOR EMPLOYEE SAFETYCONCERNS

MANAGER NSAG MAINTAINS A FILE OF ALLALLEGATIONS KNOWN TO COMPANY

NSAG MEMBERS RECEIVE AND INVESTIGATECONCERNS RAISED BY INDIVIDUALS WHO ELECTTO GO OUTSIDE OF THE LINE ORGANIZATION.

1989 6

1990 3

1991 2

REPORTS GENERATED FROM EMPLOYEE SAFETYCONCERNS

6-87 INVESTIGATION OF OPERATOR CONCERNS

8/7/87)INATTENTION TO DUTY PROBLEM OF

8-87 ANONYMOUS ALLEGATION REGARDINGQUALITY CONTROL PROGRAM

-88 ALLEGATION FALSIFIED DATA SHEPHERDCALIBRATION, MODEL 89

8-88 ALLEGATION CONCERNING QUALITYCONTROL INSPECTOR QUALIFICATIONS

6-89 HANDLING OF EMPLOYEE SAFETYCONCERNS

t

oy

'

4

SPECIAL ASSIGNMENTS TO MANAGER NSAG

CHAIR SUSQUEHANNA REVIEW COMMITTEE(SINCE DECEMBER 1983)

SIT ON NUCLEAR REVIEW BOARDS AT PEACHBOTTOM AND LIMERICK

LEAD RECOVERY MANAGER IN EMERGENCYORGANIZATION

REPRESENT COMPANY AT GE TECHNICALCONFERENCE (2/85)

RUSSIA TRIP OF APRIL 1989

MRITE "WHITE PAPER" FOR CONGRESSIONALQUERY INTO ALERT OF 2/03/90

~ ~ ~

,1

*

MEASURES OF EFFECTIYENESS

1. RECOMMENDATIONS HAYE BEEN (ARE BEING)IMPLEMENTED.

o OYERHAUL OF SURYEILLANCE PROGRAM

o OUTAGE SAFETY

o UPGRADE OF RELAY CALIBRATIONPROGRAM

o OPERATIONS WITH POTENTIAL FORDRAINING REACTOR VESSEL

o PROCEDURE USE AND IMPROYEMENT

2. PLANT MANAGEMENT ROUTINELY REQUESTSNSAG TO INVESTIGATE PROBLEMS

o SUPPRESSION POOL HATCH INCIDENT

o RESIN DISCHARGE EVENT

o STEAM SEPARATOR INCIDENT

o OYEREXPOSURE EYENT

~ ~ ~

~ o LOSS OF SHUTDOWN COOLING (ALERT)

o DETAILED REVIEW OF ESW/RHRSW SAFETYFOR UNIT 1 5RIO

3. NSAG KEEPS RECEIVING SPECIALASSIGNMENTS

4. RECOGNITION BY OUTSIDE AGENCIES

o SPECIFICALLY ClTED FOR EFFECTIVEWORK EVERY SALP FROM 1985

o OTHER UBY INPOFUNCTIO

TILITIES REFETO PPRL AS E

N SHOULD BE P

RREDXAMPERFO

BY NRC ANDLE OF HOWRMED

o REPORTS HAVE BEEN USED BY INPOINDUSTRY WIDE

CAVITY SEAL (13-84) FIRSTPREEMPTIVE SER. (SER 72-84SUPPLEMENT 1)

RELAY CALIBRATION (9-85) USED BYINPO TO GENERATE SER 8-86

o PP&L INVITED TO ADDRESS INDUSTRYGROUPS INCLUDING THE ACRS

I p

PPLL NSAG

1. KEY CHARACTERISTICS

o SIX WELL-QUALIFIED PEOPLE

oo TWO IN GENERAL OFFICE

oo FOUR AT PLANT

o REPORT DIRECTLY TO SR.-Y.P. NUCLEAR

o NO LINE DUTIES (EXCEPT E. PLAN)

o OPERATIONS ORIENTATED

o HIGH QUALITY PRODUCT (LOW OUTPUT),

oo SOLID FACTS

oo RELENTLESS INTERNAL CRITIQUE

oo REALISTIC RECOMMENDATIONS

o UNOBTRUSIVE

oo NEVER SANDBAG THE LINEORGANIZATION. PASS ONINFORMATION AS IT IS LEARNED

MAYS PRRORS OFMAIN OU

oo ALERRE

OVIDE CHANCE TO CORRECTFACT. CONCLUSIONS

R RESPONSIBILITY

oo LINE MANAGER ALWAYS GETS CREDIT

o VISIBLE TO AND COMFORTABLE WITHPLANT STAFF PERSONNEL

oo DAILY REPORT FORCES VISIT TOCONTROL ROON

oo CHECK FACTS ON THE SCENE

oo CONSULTING SERVICE

2. PL ENVIRONMENT MAKES SUCCESS POSSIBLE

o SUPPORTED BY SENIOR MANAGEMENT

o ORGANIZATION IS RECEPTIVE TQCONSTRUCTIVE CRITICISM

oo NRC

oo INPO

oo INTERNAL - NSAG

0

3. ABLE TO MAKE A DIFFERENCE

o SURVEILLANCE PROGRAM UPGRADE

o OPDRV PROGRAM

o OUTAGE SAFETY

o RELAY TEST PROGRAM UPGRADE

o CONDUCT OF OPERATIONS

oo CONTROL ROOM NOISE

oo USE OF PROCEDURES

oo OPERATIONAL COMMUNICATIONS

SAFETY PERFORMANCE EVALUATION

J. R. MiltenbergerManager Nuclear Safety Assessment

Pennsylvania Power and Light CompanyTwo North Ninth Street (A6-I)

Allentown, Pennsylvania 18101-1179215-774-7535

ABSTRACT

Pennsylvania Power and Light has defined the nuclear safety objectives of: a)minimizing transients, b) adherence to the safe operating envelope and c)controlling radioactivity and its effects. We have tabulated and analyzeddepartures from the defined conditions. Comparison of current data with pastperformance provides a reasonably objective method of assessing performancetrends. Senior Management has found this approach to be useful in evaluating ouroperation and in allocating resources to enhance performance. We believe thata similar approach could be used to compare performance with other stations andto remove some of the subjectivity from performance evaluations.

INTRODUCTION

The thesis of this paper is that the nuclear industry must develop an objectivemethod of performance appraisal. PP&L has done some work in this area whichcould be of interest to others.

Performance ratings are a fact of life. The investment community must considerreactor safety when assessing investment risk. Public utility commissions canbe expected to apply sanctions toward a plant whose performance makes itvulnerable to a regulatory shutdown. The Nuclear Regulatory Commission (NRC)must make comparative evaluations of safety performance in order to be crediblewith the Congress and with the public. If plausible performance ratings are notassigned by the industry or by the Government, they will be generated by analystson Wall Street and in the various state capitols because these people need themto'do their jobs.

Both the NRC and INPO have developed a set of performance indicators, which arepublished regularly. Both the NRC and INPO have stated that the performanceindicators will not be used as the basis for judgment of relative performance.The premise is that if performance indicators are emphasized utility managementwill manage to the indicators rather than do the right thing and safety willsuffer.

There is no question that people will manage to performance indicators. Thechallenge is to choose the indicators such'that the desired behavior is achieved.No one opposes managing intelligently to maximize generation. The indicatorsmust be chosen such that they enhance nuclear safety. An example is scramfrequency. INPO figures show that unplanned scrams dropped from 7.4 per unit in

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I

1980 to 1.8 in 1989. The industry has managed to'his indicator and there is noquestion that safety has improved as a result. The writer has seen no evidencethat utilities are circumventing safety to avoid scrams. Indeed, exactly theopposite has occurred as utilities and owners'roups have found ways to make thescram circuitry more reliable and the criteria for manual trips more useful tothe operators. The net effect of managing to reduce scram frequency has been toenhance nuclear safety. The industry must take the lead in developing objectiveperformance indicators whose achievement will maximize safety.

PPKL APPROACH

PP3.L has struggled with the problem of objective safety performance measurement.The approach has been to establish a set of criteria and then to examine theevents of the year against these criteria. Data from past years are comparedwith current performance and a judgment is made as to whether performance isimproving declining or stagnant. When possible Susquehanna data are comparedwith those of the industry to establish relative performance. Each year a formalassessment of nuclear safety performance is prepared by the Nuclear SafetyAssessment Group. This report is presented to Senior Corporate Management andto the Board of Directors as part of the due diligence process.

The mission of the PPLL Nuclear Department is, "To operate, maintain and supportSusquehanna such that the station reliably and efficiently generates the maximumamount of electricity without compromising public and employee safety."

It follows that two major criteria exist for measuring operational performance:

o Power generation

o Nuclear safety

Power generation is easily measured. Comparative figures are readily available.We will note in passing that 1990 was an excellent generation year at Susquehannaand will move on to nuclear safety.

Safety performance is a stickier wicket. Neither we nor the industry has devisedany absolute measure of how safely the station is being operated. However, wehave observed that we can record and analyze'vents. This leads to theconclusion that, while we can not measure safety in absolute terms, WE CAN

MEASURE DEPARTURES FROM A SAFE CONDITION. It. appears reasonable to assume thatthe conditions specified in the operating license are safe.

A nuclear power plant can operate at 100 percent power for an indefinite periodas long as the key parameters are maintained inside of the safe operatingenvelope. The cognizant authorities — government and industry — have agreed upona set of conditions inside of which the safety analyses are valid. Theseconditions are defined in the Technical Specifications, which are part of theoperating license. The Technical Specifications allow equipments to be out ofservice for limited periods in order to accomplish necessary maintenance andrepairs. Obviously, the reactor is in its safest configuration when all safety-related equipments are fully operational; and equally obviously, it is safestunder steady state conditions.

With the above in mind one can define a set of safe conditions. The basiccriteria are as follows:

1. Maintain steady state conditions. (Preferably at 100 percent power.) Putanother way, AVOID TRANSIENTS.

"2. Stay inside 'the safe operating envelope.

3. Keep all safety-related equipment operable as much as possible.

4. Control radioactivity and its effects.

o Avoid spills and health physics events.

o Meet ALARA goals.

The above criteria apply under all situations. Experience has shown that underoutage conditions meeting the Technical Specifications is necessary but notsufficient. Therefore, we have defined the outage criteria as:

1. Satisfy the requirements of the Technical Specifications.

2. Perform the following critical functions:

o Remove decay heat.

Keep the core covered.

Control reactivity.

Maintain secondary containment as needed.

With some definitions of safe conditions in place it becomespossible to measure departures from these conditions. We can tabulate andanalyze:

o Transient events

o Challenges to the safe operating envelope

Violations of the rules.

oo Technical Specification Violations

oo NRC Violations

oo Reactivity control errors

Critical equipments (systems) out of service.

oo ECCS and ESF

oo Containment

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oo Diesel generators

o Events involving control of radioactive materials andpersonnel exposure..

Radioactive spills and Health Physics events

Cumulative exposure

o Outage events which jeopardize:

Decay heat removal

Keeping the core covered

Reactivity control

Availability of secondary containment when needed.

Analysis requires a standard of performance, which causes a problem. Except fora few items, such as scrams and cumulative radiation exposure, industry data havenot been readily available for comparison. Consequently, PP&L has used pastperformance at Susquehanna as the reference. We have established a data base ofthe operational events, which have occurred since 1985 when Unit 2 wentcommercial, and we compare the events of the current year against these data.This methodology does not measure performance on an absolute scale or relativeto the industry. However, it does provide an objective measure of performancetrends.

As far as possible PP&L has attempted to use categories of events that are notsubject to interpretation, or that have already been established by officialreports. Scrams, shutdowns and power reductions are a matter of record. ESFactuations and Technical Specification violations are reported to the NRC usingthe Licensee Event Report (LER) system. Events such as fires, waterhammers, lossof reactor water level and loss of shutdown cooling are fairly unambiguous.Others, such as containment degradations, health physics events and reactivityerrors are less well defined. PP&L has developed a classification guide whichensures reasonable consistency while screening events.

We have tried to avoid double counting. For example, scrams are, by definition,ESF actuations. They have been counted once. On the other hand, some - but notall — high voltage events cause ESF actuations. They show up in both categories.In our opinion, there is not enough duplication to distort the conclusions. Theevents included in these data are ALL UNPLANNED. Scheduled scrams, shutdowns,power reductions for rod pattern adjustments, ESF maintenance outages, etc. havenot been included.

SUMMARY OF DATA

Table 1 lists the events in each major category for the years 1986 through 1990.

TABLE 1

SUMMARY OF EVENTS BY YEAR

TRANSIENTSScramsShutdownsPower ReductionsESF Actuations(Duplicates) *Inadvertent StartsNet Transients

CHALLENGES TO SAFEOPERATING ENVELOPE

VIOLATIONS OF RULESTech SpecNRC ViolationsReactivity ControlErrorsTotal Departures

E(UIPMENTS OOS

ECCS and ESFContainmentDiesel GeneratorTotal OOS

Total Challenges toSafe OperatingEnvelope

EQUIPMENT DAMAGE

EVENTS WITH POTENTIALFOR DAMAGE

High VoltageWaterhammerFiresFloodingLoss of LevelChemical SpillsTotal

EMERGENCY PLAN

RADIOLOGICAL EVENTSRadioactive SpillsHealth PhysicsTotal Radiological

1986

1

11331(1)1

46

8122

22

2091645

67

. 51

4

224

24327

1987

251024(2)544

16

219939

55

80320215

151227

1988

25

1223(2)

42

1487

29

1471536

65

17

501

1

2312

122133

1989

51430(4)1

50

10116

27

16141747

16

52205

18

92534

1990

261611

(2)1

34

1393

25

18122252

75

81

21

35

20

162036

* Scrams, by definition, are ESF actuations.

Table 2 shows the causes by category on an annual basis.

TABLE 2

SUMMARY OF CAUSES BY YEAR(Percentage)

1986 1987 1988 1989 1990

Operator ErrorError Non-OperatorDesignMalfunction

15 1133 2511 2541 39

10 13 730 39 3520 11 1040 37 48

The 1990 data are consistent with the pattern observed in past years. Theprincipal change is a sharp reduction in ESF actuations, which reduces the numberof transient events to less than 80 percent of that observed in the next bestyear. The number of diesel generator events has increased. This is partiallythe result of the increased number of starts made necessary by the extensiveoverhaul and test program executed over the year.

CONCLUSIONS

Comparison of the events of 1990 with the criteria of avoiding transients,adherence to the safe operating envelope and controlling radioactivity and itseffects leads to the conclusions that:

Operational nuclear safety performance was excellent in 1990.

o Transients were controlled.

The severity of transients was about the same as thatexperienced in past years.

The number was sharply reduced due to significantly betterperformance in avoiding ESF actuations.

The average of one scram per unit places the Station in thefirst quartile among U.S. reactor plants according to INPOfigures.

o The safe operating envelope remained intact.

The rules were obeyed in all essential respects. There wereno infractions of the Technical Specifications, NRC violationsor reactivity control errors that adversely impacted the

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safety of the public or of the reactor plants.

Equipment outages were minimized. All remained within thelimits of the applicable LCOs.

Some degradation in safety margin existed because of problemswith the diesel generators. The station operated for ll-l/2days with only three operable diesel engines. An LCOextension was granted by the NRC.

There were no significant fires, floodings, waterhammers, lossof level or chemical spill events.

o Radioactivity and its effects were controlled.

The number of radioactive spills and health physics events wascomparable with that of past years. All were minor.

The total of 440 Man Rem for the station was in the INPO firstquartile for BWRs.

The station is experiencing random events within a well defined band setby the physical installation and existing management practices.Management theory applied to our data suggests that in order to makesubstantial improvement the system must be changed.

o The total number of events in the various categories has remainedessentially constant over the past five years. The exception is1990 ESF actuations, which were half those of previous years.

The greatest potential for improvement lies in reducing the number oferrors by, non-operators and by improving the reliability of components.

o Operator error caused, only eleven percent of the incidents averagedover the past five years.

How safe are we? We do not know. Evaluations by the NRC and by INPO over theyears have indicated that safety performance at Susquehanna compares favorablywith that observed in the industry. We do know that the scram and exposurenumbers for 1990 are in the first quartile according to the latest published INPOdata. And we know that our departures from the defined safe conditions have beenremarkably consistent over the years. Accurate knowledge of our deviations hasprovided the basis for intelligent application of resources to effectimprovement. It has also provided a strong position from which to interact withthe regulators.

We believe that safety goals such as avoiding transients, maintaining the safeoperating envelope and controlling radioactivity and its effects are viable.Management to achieve these goals will promote safety. Furthermore, performancecan be measured in a reasonably objective manner by recording and analyzingevents, which are departures from these goals.

SUMMARY

In summary, PP8L has defined the nuclear safety objectives of: a) minimizingtransients, b) adherence to the safe operating envelope and c) controllingradioactivity and its effects. We have tabulated and analyzed shortfalls fromthe defined objectives. Comparison of current data with past performanceprovides a reasonably objective method of assessing performance trends. SeniorManagement has found this approach to be useful in evaluating our operation andin allocating resources to enhance performance. Except for a few data pointswe do not know how our performance compares to that of the industry. We believethat if a suitable data bank were established, a similar approach could be usedto compare performance with other stations and to remove some of the subjectivityfrom performance evaluations.