IR 05000272/1991099

Initial Draft SALP Repts 50-272/91-99,50-311/91-99 & 50-354/91-99 for 911229-930619

ML20056G984
Person / Time
Site:	Salem, Hope Creek
Issue date:	07/29/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18100A584	List: IR 05000272/1991099
References
50-272-91-99, 50-311-91-99, 50-354-91-99, NUDOCS 9309080033
Download: ML20056G984 (48)

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ENCLOSURE 1 INITIAL DRAFI' SALP REPORT l

l U.S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT NOS 50-272/91-99 50-311/91-99 PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM GENERATING STATION UNITS 1 AND 2 ASSESSMENT PERIOD:

DECEMBER 29,1991 - JUNE 19,1993 BOARD MEETING DATE:

JULY 29,1993 kho .200 272 G PDR _

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SUMMARY OF RESULTS l

I Overview i

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On July 29,1993, the SALP board met to discuss PSE&G's performance at Salem during the l period from December 29,1991 to June 19, 1993. The board concluded that the licensee l had operated the Salem units safely and that operator response to operational events was

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excellent. The overall performance in the Operations area was good. However, weaknesses were noted in the decisions to restart Unit 2 following the rod control system problems, in l the failure to follow procedures resulting in the loss of Unit 2 annunciators, and in the inadequate oversight of the fire protection progra PSE&G continued to implement effective radiological controls and ALARA programs during this period. The SALP board noted improvements in this functional area including strong ,

management support and oversight. Quality Assurance audits in this area were of very good l qualit The board concluded that the Salem maintenance and surveillance programs contributed to the safe operation of the two units during the assessment period. In general, a declining l number of personnel errors in both maintenance and surveillance indicate <1 improving performance. However, the number of transients induced by component failures and the significant problems with the rod control system raise questions regarding the overall effectiveness of the maintenance and engineering support function The SALP board determined that PSE&G maintained a generally strong and effective emergency preparedness (EP) program. However, the board was concerned with an apparent decline in the ability of the licensee to make correct initial Protective Action Recommendations during training, drills and annual exercises. This concern resulted in the board's assessment of a declining trend for this area. The board also concluded that PSE&G continued to maintain an effective and performance-oriented security program during this period. Overall, licensee performance in both EP and security remained excellen Engineering and technical support organizations provided good support for refueling and maintenance outages, and strong performance in addressing day-to-day problems. The SALP board noted that training programs for engineering personnel were excellent but that weaknesses were observed in the licensee's non-conformance, erosion / corrosion, and fire protection programs. Although the root cause training program was viewed as a strength, the board noted that the threshold for initiating actual root cause investigation was not clear or consisten PSE&G management continued to provide generally effective management support.

l Significant Event Response Team (SERT) reviews of major events have been effectiv However, the board noted that in several instances, PSE&G failed to initiate adequate root cause evaluation or assessment of abnormal conditions. NRC interaction with PSE&G management was needed in a number of cases in order for full evaluation and corrective

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! l l action to be taken in a timely manner. Once initiated, comprehensive assessment, root cause ;

l analysis and effective corrective actions were implemented. Outage planning and training  !

programs in all areas were considered strength j

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l I Facility Performance Analysis Summary l i

l Rating, Trend Rating, Trend ,

! Eunctional Area 12st Period This Period - Plant Operations 2 2 I

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. Radiological Controls 2, Improving I i l Maintenance / Surveillance 2 2 i I Emergency Preparedness 1 1, Declining l

Security 1 1

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! Engineering / Technical Support 2 2- t

! Safety Assessment / Quality 2 2  ;

i Verification

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Previous Assessment Period: August 1,1990 through December 28,1991

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Present Assessment Period: December 29,1991 through June 19,1993 l

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I Unplanned Unit Trips j t

Power Dalg IEvel Root Cause Functional Area :

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4 /8/93 100 % Grass content at circulating SA/QV  !

water suction Unit I automatically tripped following massive intrusion of sea grass into the circulating water suction area. Four of five operating circulating pumps tripped  !

during cleaning of their trash racks, causing loss of vacuum, turbine trip, and i e

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l subsequent reactor trip. Root cause was determined to be less than adequate i management sensitivity to the possible consequences of rack cleaning and incomplete !

implementation of corrective actions from a previous similar even l

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I /28/93 Suberitical Component failure Maintenance /

Surveillance

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Unit 2 was manually tripped by the operators per abnormal operating procedures l when control bank C", group 1 rods (four rods) fell into the core during dilution to !

criticality for post refueling startup. A rod control system integrated circuit card failure was attributed to a degraded solder trac j

l /16/93 100 % Random Component failure ~ N/A ;

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! Unit 2 amomatically tripped from 100% power due to a low-low level condition on ,

! No. 24 steam generator. A failed pressure control switch in the condensate polishing 1 system led to a low suction condition for. No. 22 steam genemtor feed pump and I subsequent feed pump tri l

1 /16/93 100 % Component failure N/A- )

Unit 1 automatically tripped from 100% power due to an over-temperature delta - l temperature signal caused by a faulty gain selector switch. This signal was received ]

with another channel already in the tripped position for ongoing channel calibratio )

i /28/93 100 % Component failure during Maintenance / !

troubleshooting Surveillance Unit 2 operators manually tripped the reactor from 100% power in response to the inadvertent loss of both operating steam generator feedwater pumps. A technician was manipulating recorder test leads in the feedwater control cabinet when both feed pumps automatically tripped. A loose module test jack was the caus . 1/16/93 13 % Random Component failure N/A ,

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Unit 1 operators manually tripped the reactor from 13% power in response to an inadvertent opening of all turbine bypass (steam dump) valves. The transient was initiated after a component in the control system faile !

l /3/92 100 % - Personnel error - equipment Maintenance /

operator operated wrong Surveillance i component

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Unit 2 tripped from 100% power due to the opening of the "A" reactor trip breake A non-licent03 equipment operator was to assist in surveillance testing of the trip breakers. He mistakenly opened the cabinet of the "A" trip breaker instead of the

"A" trip bypass breaker, f

8. 5/14/92 15 % Lack of training / incorrect Operations assessment of feedwater control system Unit 2 tripped from 15% power due to a low-low level condition in the No. 23 steam generator while personnel were troubleshooting feedwater level control problem While returning feedwater valves to their normal position, a transient occurred which caused level to drop below the reactor trip setpoint. Operator's incorrect assessment and lack of training associated with feedwater level control caused the even . 4/26/92 4% Random Component failure N/A Unit 2 tripped from 4% power due to a low-low level condition in the No. 24 steam generator. The low-low condition occurred while operators were transferring feed from auxiliary feedwater to the main feedwater pump. A fr ed component in the auto / manual feedwater control station caused sluggish valve response to both automatic and manual control demand signal .

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II PERFORMANCE ANALYSIS i

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II Plant Operations ]i III. Analysis The previous SALP rated the Salem Plant Operations functional area as Category 2; mixed l l

operator performance characterized that SALP period. The assessment noted a continued i

! effective effort in maintaining a low number of reactor trips attributed to operations i personnel. Daily supervision and management oversight of plant operations were goo Weaknesses were evident in the reactor operator training programs, and corrective actions ;

for identified weaknesses were at times incomplet ,

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! During this assessment period, PSE&G operated the Salem units safely. On several l occasions, station and operations management made conservative decisions to shut down the

! Salem units to accommodate various repair and/or testing activities. Examples included a Unit 2 shutdown to investigate erosion / corrosion concerns, a mini-outage at Unit I for l

secondary plant maintenance, and a Unit 2 shutdown to repair a main generator stator water

leak. In addition, the licensee periodically reduced power to accomplish various activities, I l such as condenser circulator cleaning and a Unit 1 primanf system temperature detector ;

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l replacement that required a containment entry. In one case, involving discrepar t l performance of the Salem Unit 2 rod control system during multiple successive restart l attempts, initial canagement response was not sufficient to understand and determine the >

l cause of the rod control system failures an.? the associated safety significance of the even Operators effectively responded to reactor trips and other operational transients. In some l l instances, prompt and effective operator actions averted the necessity for reactor trips. One j example included a Unit 2 steam generator feedwater pump trip while operating at full power, where prompt operator response prevented a unit trip. The personnel error rate ;

decreased during this SALP period, which was the result of aggressive management '

attention.

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l The licensed and non-licensed operator training programs were well developed, implemented l and strongly supported by management. Operations and training department personnel worked well together in assuring that a well trained, qualified, and competent operating staff l existed. Candidates for initial and requalification license examinations were well prepared j and knowledgeable. All candidates passed NRC exams given during the period. Weaknesses were noted in the area of simulator modeling and the quality of job performance measure The licensee initiated actions to address these weaknesses. Overall, the licensed operator requalification and initial qualification programs were strong and well manage Nine unplanned reactor trips occurred for both units during the period. Although these trips challenged the operations staff, most of the trips were the result of component failure or environmental conditions. This compares to five and six reactor trips in the last two -

assessment periods, respectively. A personnel error by a non-licensed operator (as discussed i

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in the surveillance section) who entered the Unit 2 reactor trip breaker cubicles on September 3,1992, to re-familiarize himself with breaker operation in preparation for a Unit I test caused one reactor trip. The root cause for the May 14,1992 Unit 2 reactor trip was an incorrect understanding and a lack of training by operations personnel of the design capability of the feedwater regulating bypass valve. In all cases, safety systems functioned as designed. Component aging, particularly in feedwater control systems, appears as a principal contributo The operations department effectively transitioned to 12-hour shift rotations. The five operating shifts were staffed adequately, utilizing an extra senior licensed operator to supervise the work control group. One extra licensed operator was added to the shift complement, and reduced the administrative burden in the control room during the Unit 2 outag Opereiuns supervision and management oversight and attention to daily unit operations continued to be good during the assessment period. Daily operational and outage meetings provided an effective forum for the exchange of relevant operational information among the various station groups and management levels. Those meetings maintained direct and effective communications between operations and station managemen Licensed operators demonstrated a generally good safety perspective and awareness of plant conditions. The operators generally displayed good adherence to procedures and sufficient attention m detail during activities. The completion of the operations procedure upgrade project has resulted in an improved quality of station procedures, and this contributed to a positive procedure adherence trend. However, an ap; arant isolated instance of incomplete procedures and failure to use procedures contributed to a Umt 1 loss of the overhead l annunciator (OHA) nstem. PSE&G initiated corrective action to previously identified l emergency and abnormal operating procedure deficiencies. The responsiveness of PSE&G personnel was thorough, as indicated through administrative enhancements, including verification and validation process strengthening.

l Operations support of refueling outage activities was very good. Reactor core alteration activities were conservatively conducted. The licensee demonstrated a good safety perspective during outage periods by ensuring safety equipment availability and by

! conducting independent reviews of the outage sequence. Operators performed unit startup I activities in a safe and deliberate fashion. Operators' performance and control during reduced reactor coolant system inventory operations were strong. Licensed operators were generally well trained on modifications prior to unit startup from outages. One exception was that the control room OHA system modification training did not adequately train the operators to routinely verify proper system operatio The fire protection program was good and staffed with dedica'ed fire protection personnel from the Site Protection group, who responded to fire and first aid emergencies. Plant and site management strongly supported the fire protection program. However, some distinctions affecting Salem included weaknesses involving procedure problems, fire water

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system knowledge shortcomings by plant personnel, and improper storage of combustible ;

f materials. Further, due to equipment and maintenance difficulties, both Salem fire pumps '

l were inoperable for an extended period. However, the licensee implemented timely compensatory measures in accordance with regulatory requirements. The licensee's investigation of a self-identified instance of misconduct by a firewatch revealed a more extensive weakness in oversight and control of contract personnel performing roving

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firewatch duties. More than one-half of the firewatch personnel annotated their logs to l

indicate they had inspected areas when, in fact, they had not. The licensee's corrective actions were prompt and comprehensive in assessing and resolving this deficiency.

l Summary PSE&G operated the Salem units safely. Operator response to reactor trips and other operational transients was excellent. Operations supervision and management oversight of day-to-day unit operations activities were good. Operations personnel generally demonstrated a good safety perspective. However, the licensee decided to restart Unit 2 before the rod control system problems were fully understood; and failure to follow procedures combined with a design problem resulted in a loss of Unit 2 annunciators. Operations support for i

refueling outages was very good. The PSE&G fire protection program exhibited programmatic and performance weaknesse III. Performance Rating: Category 2

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III. Board Comments: None

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II Radiological Controls III. Analysis ,

i The previous SALP rated the functional area of radiological controls at Units 1 and 2 as Category 2; improving. The radiological controls program was considered good. Staffing and training were good, as were radwaste processing, storage and transportation activitie ,

ALARA efforts and performance were commendable. Confirmatory measurements, effluent !

controls, and the Radiological Environmental Monitoring Program (REMP) were effectively implemente ,

The radiological controls and chemistry programs were challenged during the current l

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assessment period. Refueling outages were performed at both units; personnel made periodic !

j entries into the Unit 1 containment, with the reactor at power; and minor fuel leaks, which l

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were detected at both units, required monitoring. The NRC's reviews of these activities determined that the radiological controls and chemistry programs were effectively implemented. There was strong management and supervisory oversight of on-going activities and proactive involvement in radidion protection and chemistry programs. These were evidenced by excellent steam generator (SG) chemistry controls, responses to SG chemistry

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excursions, and the responses to minor fuel leaks on both units. Challenging 1992 goals for radiation dose, personnel contamination events, and solid radwaste volume were met. Goals for 1993 continue to be challenging and are being met. Planning and procedure development -

for implementation of the revised 10 CFR Part 20 were very goo The radiological controls organization and staffing levels were stable. There was very good use of station radiological controls personnel to oversee contractor activities, a good level of expertise within the organization, and minimal use of overtime. The outage radiological controls organizations were well defined Overall, radiation proiection and chemistry personnel were generally well trained and very i knowledgeable of their respective duties. However, early in the period the NRC identified that personnel transferred from the Hope Creek site to support outage activities at Salem were not provided training on Salem specific radiation protection procedures. Appropriate  ;

personnel were subsequently trained on Salem specific procedures in a timely manne '

Radiation workers received appropriate and timely training. For example, a new course titled " Integrated Training" was implemented at both Salem and Hope Creek Stations. The course involved radiation workers and radiological controls personnel planning and performing work activities together under realistic conditions on a mock-up. The majority of radiation protection and maintenance personnel attended the course. The course was considered a very good initiative. There were excellent pre-job briefings and explicit guidance specified on radiation work permits.

l l The overall internal and external exposure controls programs were strong, and control of j radiological work activities was commendable. An effective access control system using state-of-the-art computer supported equipment continued to be maintained. There were no

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internal or external exposures in excess of NRC limits and overall administrative controls of personnel exposure were effective. For example, the internal exposure controls for steam l

generator work were such that the majority of work was conducted without the need for l respiratory protection. The weaknesses associated with quality control of dosimetry,

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identified during the previous period, were corrected. Weaknesses in exposure records controls, identified by NRC early in the period, were also corrected. All dosimetry issues j were closed. The radiological occurrence report system was well supported by management l and effective in identifying root causes and corrective actions for radiological problems.

The ALARA program continued to be strong throughout the period. NRC independent review of work activitie s indicated commendable planning and preparation, use of l

appropriate exposure goals, and very good oversight of on-going activities from an ALARA

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standpoint. Aggregate personnel radiation exposure continues to be among the lowest in the industry. Emergent work received appropriate reviews and ALARA control Overall, the radioactive material and contamination control programs were strong. Isolated lapses in contamination controls were aggressively pursued and root causes were identified and corrected. Radiological Control Area and containment housekeeping improved during the period and contaminated floor areas were reduced significantly. In addition, the

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radioactive waste handling, storage and transportation programs were strong and well managed. Plans have been established for interim on-site storage of radioactive waste in the event of delays in finalization of compact efforts by the State of New Jerse The Radiological Effluent Control Program (RECP) and the REMP continued to be effective during this period. Personnel exhibited good knowledge of all RECP areas including ef6uent controls, radiation monitoring systems (RMS), and off-site dose calculations. Comparisons of projected off-site doses between the licensee and the NRC PCDOSE computer code were

in excellent agreement. Procedures were detailed, concise and well written and resulted in effective implementation of the RECP and REMP. The initiative to develop and issue RMS l manuals to assist in maintenance of the RMS, as well as the efforts to upgrade the RMS, l

were noteworthy. These actions indicated not only a clear understanding of technical issues, but also a proactive approach to maintaining the RMS. The meteorological monitoring program was effectiv Overall quality assurance (QA) oversight of program areas was very good. Special audits of dosimetry program matters were conducted to verify quality and independent assessors continued to be used to monitor outage activities. QA audits of effluent and environmental monitoring programs were thorough and of suf6cient technical depth to probe for programmatic weaknesses. Findings were promptly resolved. Early in the period, the NRC l

l identified a weakness in the area of audits of personnel quali6 cations. It was not clear that personnel quali6 cations of all appropriate groups were being systematically audited. Baseline audits were immediately initiated by the QA group and no unqualified personnel were identifie Summary PSE&G implemented effective radiological controls and ALARA programs. There was strong management support and strong supervisory and management oversight of program areas. External and internal exposure controls were effective, as were contamination controls, storage and handling of radioactive material, and radioactive waste transportation

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activities. The confirmatory measurements and effluent controls program, as well as the

! REMP continued to be effective. QA audits were of very good qualit III. Performance Rating: Category 1 III. Board Comments: None II Maintenance / Surveillance

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III. Analysis The previous SALP assessment rated the Maintenance / Surveillance area as Category ,

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i Personnel errors and inattention to detail resulted in problems in both maintenance and surveillance. A number ofimprovements in such areas as plant material condition and fewer missed surveillances had been noted in the previous assessment. Weaknesses were noted in the area of material control and procuremen I'

Maintenance The Salem maintenance program contributed to the continued safe operation of both Salem units during the assessment period. Maintenance department management was directly and effectively involved in the oversight of routine maintenance activities during power operations and during forced and refueling outages. PSE&G employed a fixed shift work ,

schedule, providing balanced work activity impact and contributing to maintenance planning j efficiency. Pre-outage system walkdowns were initiated to improve outage efficiency. Plant management screened work to be done during planned maintenance outages of safety-related equipment to achieve a net safety gain. Safety system availability was maintained high, also i demonstrating management's safety conscious control of the maintenance program. A new l work standards monitoring program provided for proper management review of maintenance i l

activitie l Maintenance Department staff adequately supported plant operations. Non-supervisory l personnel were technically knowledgeable of routine preventive and corrective activities; !

their training and experience remained a strength. Maintenance first-line supervisors l provided generally good oversight. Personnel errors resulted in one engineered safety j feature actuation early in the period, a partial loss of off-site power later in the period, and a l small number of non-cited violations throughout the period. However, the number of reportable events (including surveillance-related events) due to personnel error decreased from 24 in the previous SALP period to 12 in this perio Two reactor trips resulted from maintenance activities. In one case, control rods dropped because of a degraded solder trace from maintenance on a rod control printed circuit car Another trip resulted from installation of test equipment in a feedwater control cabinet which

had a loose module test jack. These maintenance-related trips and the continuing problems

due to personnel error reduced the effectiveness of the maintenance progra The conduct of routine maintenance activities was good. Coordination between maintenance and operations to schedule and accomplish work activities was effective and improving.

l Indicators of good maintenance performance included declining trends in the corrective and i preventive maintenance backlogs, in the number of industrial safety events, in the number of plant leaks and in the number of required radiation monitoring system work orders.

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Continued improvement in both units' material condition was also noted. The Salem Revitalization Project has positively impacted the plant material condition. Aggressive management attention in this area was evident. The Procedure Upgrade Program, nearing !

completion for I&C and Maintenance procedures by the end of the period, was a positive effor Salem has established and maintained a very good preventative maintenance (PM) progra Improvements in the PM program are continuing, and as a result, deferred PMs have been reduced significantly. Much of this program's success is attributable to a close working

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M mship between engineering, operations and maintenanc Salem performed three refueling outages; one at Unit I and two at Unit 2. Outage planning activities and outage conduct were strong. Outage meetings and good inter-departmental cooperation resulted in better daily work coordination and more efficient accomplishment of outage work. The delegation of some inservice inspection and balance-of-plant outage work to PSE&G Site Services reduced the dependency on contractors for those efforts and addressed a weakness from a prior SALP report. Good performance was noted during the outages in the restoration of the Unit 2 turbine generator, the service water piping

, replacement at both units, the erosion / corrosion work at Unit 1, and the 10-year overhaul of l all three emergency diesel generators at Unit Deficiencies were observed in PSE&G's troubleshooting effort involved with the Unit 2 rod control system following that unit's refueling outage at the end of the period. Mjntenance

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and troubleshooting activities were not well controlled. Since root cause determination

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policy and expectations were not well established, these activities initially did not identify design and physical circuit problems. Consequently, corrective actions were not effective.

Further, PSE&G staff members responsible for maintenance of the rod control system did not recognize that some exhibited system defects were outside of the system design basis l (e.g., the observation that one of the control rods withdrew from, instead of inserting into, l the core on an " insert demand signal"). Several rod control system failures and anomalies ,

! were experienced without realizing that the defects were related. This led to an attempt to I restart the plant without understanding the cause or nature of the failures or the significance {

of the anomalous performance. After NRC directed attention to this area, including the formation of an Augmented Inspection Team, the licensee initiated a thorough and

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comprehensive investigation of the rod control system deficiencies, and resolved the issues.

j The licensee continued improvement in the area of spare parts procurement and availabilit The procurement program also included commercial grade component dedication. The new j integrated and automated warehouse was placed into operation during the period. A computerized data base was widely used by the staff and was effectively integrated into the procurement program. This system enabled the procurement activities to be processed efficiently, and the procurement backlogs to be substantially reduced.

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Surveillance During this period the Salem surveillance program was safely and properly implemented and l confirmed the operability of safety-related equipment. The maintenance information system was effectively used to schedule and track the completion of a large number of required i surveillance activities at both units. Technical Specification surveillances were completed j

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within the required periodicity, with four isolated exceptions. The missed surveillances were not indicative of any program weakness and were properly addressed by PSE&G upon their !

discovery. The four missed surveillances decreased from nine during the previous SALP l period. Technicians demonstrated a good level of knowledge during the performance of the surveillance and inservice test activitie ;

Communications and coordination between technicians and control room operators were good. Despite the association of one reactor trip with the performance of a reactor trip breaker surveillance procedure and two engineered safety feature actuations, management attention has reduced the number of personnel errors committed during surveillance test performance. A design change involving the 4kV vital bus test points significantly reduced ]

potential for these kind of errors. The Procedure Upgrade Progmm continued to improve the I quality of surveillance procedures. However, an operations surveillance test was inadequate ;

l to assure that the overhead annunciator system display was verified to be functioning on a l l regular basis and contributed to a loss of annunciator event in December,199 !

The inservice inspection and testing efforts were again well performed; a noted strength was l

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l the performance of steam generator tube inspections during refueling outages. Unit 2's l l second 10-year ISI interval program has been enhanced as a result of PSE&G's assuming its preparation and control instead of delegating this responsibility to an ISI vendor, as was done l

during the first 10-year interval. PSE&G responded well to the increased surveillance test requirements following the restoration of the Unit 2 turbine generator and the placing of that equipment into servic Summary i l l The Salem maintenance and surveillance programs contributed to safe operation of the two Salem units during the assessment period. Continued reduction of personnel errors in both j maintenance and surveillance activities was noted. A number of other trends indicated I

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continuing improvement. Three refueling outages were performed with strong planning and l implementation. However, a significant event still resulted from personnel error and l

maintenance activities that were not well controlled. Improvements were noted in

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procurement and material contro III. Performance Rating: Category 2 III. Board Comments: None l

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II Emergency Preparedness III. Analysis This area is common for the Artificial Island site, refer to Hope Creek SALP report 50-354/91 99,Section III.D.1 for detail III. Performance Rating: Category 1, Declining III. Board Comments: None

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l This area is common for the Artificial Island site, refer to Hope Creek SALP report 50-l 354/91-99,Section III.E.1 for details.

l III. Performance Rating: Category 1 III. Board Comments: None

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II Engineering and Technical Support

III. Analysis The previous SALP rated Engineering and Technical Support as Category 2. The previous assessment indicated that the control and limitations of temporary modifications improve Also improved was the quality of work performed by the onsite system engineers and in the Salem Qualified Reviewers Program. Progress was observed in, the Salem Revitalization Project and the Configuration Baseline Project, two of the engineering enhancement project Weaknesses were noted in the responses to NRC generic communication Engineering and Technical Support for Salem is provided by the corporate engineering, known as Engineering and Plant Betterment (E&PB), and the onsite system engineering organization. These groups effectively provided technical support for refueling and maintenance outage activities. E&PB handles major engineering efforts such as plant modifications and design bases reconstitution. The onsite engineering group supports operations, maintenance, testing and minor design change activities. These groups are well staffed with experienced personnel in various engineering disciplines. Both engineering organizations communicated and interfaced well with the station and outage groups on a daily basis. Reactor engineering generally provided strong support to the Salem station during refueling, reactor startup and power ascension testing activitie ~~

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The licensee has an excellent program for controlling design changes and plant modification l The " workbook" used in the design change process provides easy-to-follow guidance to the ;

preparer of plant modification packages. The modification packages reviewed were of good !

quality. They were thorough and contained adequate safety reviews. However, the licensee

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made minor changes to the facility as described in the UFSAR without determining if there was an unreviewed safety question involved as required by procedures. There were no other j identified cases of the licensee failure to follow the 10 CFR 50.59 implementation procedur While these failures to follow procedures did not result in safety problems, the finding indicates a potential weakness in the licensee's 10 CFR 50.59 progra The loss of the overhead annunciator (OHA) system on Unit 2 and failure to recognize that loss for 90 minutes had several root causes, some that were engineering in nature. The l multi-microprocessor OHA system that was recently installed failed to provide the necessary human-machine interface. The system also gave higher priority to other actions besides providing alarm indications to the operators and did not provide indication of failure. The engineering staff performed little software review of the OHA modification. In addition, the staff's knowledge of the OHA system and the associated new technology was less than adequate. Only after NRC directed attention to this area, including the formation of an Augmented Inspection Team, did the licensee initiate a thorough and comprehensive investigation to determine the cause and effect resolution.

I As a result of concerns identified during an NRC inspection, PSE&G further identified significant programmatic weaknesses in the site Erosion / Corrosion (E/C) Program. The licensee used incorrect criteria in determining minimum wall thickness. Subsequently, ;

numerous piping erosion conditions involving roa-safety related feedwater piping were dispositioned incorrectly for both Salem units ':&PB subsequently implemented substantial

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programmatic improvements to correct the E/C Program to an acceptable condition.

l l Concerns were also identified by the NRC with regard to the licensee's Appendix R L l program. It was determined that the fire barrier systems were not installed in accordance l with the tested configuration. In response to the inoperable status of these fire barrier

systems, due to the lack of proper qualification test data to substantiate the design of the in-plant configuratien, the licensee had to institute hourly fire watch patrols in the plant areas containing the questionable fire barrier system The licensee has an excellent training program for E&PB staff and onsite system engineering l personnel. A typical system engineer receives substantial theory-based training, including thermodynamics, heat transfer, and fluid mechanics. Recent enhancements to the E&PB training program have advanced towards a more performance / application oriented approac In addition, the licensee has an excellent Root Cause Analysis and Decision Making course ]

designed for members involved in problem solving and incident investigations. However, the threshold for initiating root cause investigations was not clear or consisten l

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Several longer standing design and hardware concerns represent challenges to the reliable operation of the facilities. For example, control room operators entered Technical Specification 3.0.3 on several occasions due to design problems associated with the analog rod position indication system. Automatic main steam line isolations continued to occur during plant heatup due to design deficiencies. In addition, some reactor trips were caused by random failures of plant hardware. On the positive side, the engineering organizations implemented several system design modifications and other actions to address long-standing concerns. Examples included the safeguards equipment cabinets (load sequencers),

pressurizer power operated relief valves, service water and radiation monitoring systems (in progress), and vital /non-vital switchgear transformer The engineering organizations proactively identified and addressed a number of technical

, problems in a timely manner. These included auxiliary feedwater system excessive flow, a l longer than expected overall response time for the containment spray system, a potential

! overload condition associated with the emergency diesel generators, and a condition outside l the design basis for the control air containment isolation valve System engineers generally exhibited strong performance in addressing day-to-day problems.

i The system engineers effectively evaluated safety-related pump failures, and switchgear l transformer failures. System engineer performance, however, demonstrated some control j and coordination weaknesses while troubleshooting problems with an emergency diesel l generator, which resulted in an engine overspeed tri The licensee's response to recent failures in the rod control system indicated the following weaknesses: (1) the lack of a site wide root cause determination policy; (2) the lack of supervision and control over vendor activities; (3) PSE&G's inadequate understanding of the depth and capabilities of the vendor's circuit card testing program; (4) the less than adequate control over the vendor' . non-like-for-like replacement of the rod control system digital group counters; (5) the lack of control of the vendor's troubleshooting; and (6) the lack of appropriate troubleshooting rigor. However, the licensee allocation of resources for each individual event was adequate. Furthermore, after the initiation of the NRC's AIT, the l upper management oversight and the investigation of the event by the Significant Event l Response Team (SERT) were considered strength Engineering and Plant Betterment has initiated an aggressive program to substantially reduce the engineering work request (EWR) backlogs for both Salem and Hope Creek. They were I successful in reducing the backlog during this perio ]

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The licensee has separate programs for controlling nonconformance reports (NCR) in each division. The NRC identified weaknesses in this area due to lack of interface between ,

individual programs. For example, a fire damper, which provides ventilation to the station battery to prevent hydrogen accumulation reaching the ignition limit, failed to the closed position (due to damaged fusible link) and remained closed for more than 18 months. The E&PB NCR, which identified the deficiency, was closed without assuring either: 1) that the safety impact of the deficiency was properly addressed and the deficiency corrected, or 2)

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that the nonconformance was addressed by site engineerin The quality of the technical content of licensee submittals has appeared to level off with some room for improvement still remaining. Of the ten amendments approved during the SALP period, four required signi6 cant information to be submitted before approval. The responses to various generic letters required signincant revision before satisfactory resolution of these issues were achieved. Other requests from the licensee, such as relief requests from ASME Code requirements have been generally acceptabl The erosion / corrosion monitoring program for high energy piping has shown improvement from an administrative control standpoint. Both units have their own respective administrative procedures. Predictive analyses are more appropriate and conservative than past evaluation Summary Engineering and Plant Betterment and the onsite system engineering provided good technical support for refueling and maintenance outages. System engineering exhibited strong ,

performance in addressing day-to-day problems. The modi 6 cation packages reviewed were )

i of good quality, with a few exceptions. The training program provided for E&PB staff and system engineering personnel was determined to be excellent. Several operational problems ,

were caused by long standing design and hardware concerns. The engineering organization

implemented several system design modi 6 cations to address some long-standing concern ;

l However, coordination weaknesses were observed in troubleshooting emergency diesel l l generator problems and the root cause determination and troubleshooting associated with the f rod control system failures. Both E&PB and system engineering have initiated aggressive ;

programs to reduce substantially the engineering backlogs. Weaknesses were observed in the l licensee's non-conformance, erosion / corrosion, and fire protection (Appendix R) program III. Performance Rating: Category 2 III. Board Comments: None l II Safety Assessment / Quality Verification ,

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III. Analysis

i The previous SALP rated this area as Category 2. That assessment noted that management ;

continued to be involved in problem resolution and the assurance of nuclear safety. Groups that provide independent reviews were effective and provided safety conscious reviews of licensee activities. A continuing concern with personnel errors, procedure compliance, and licensee submittals was note During this period, performance at both Salem units was good. Cooperation, communication and coordination between the different departments at Salem continued to improve. There i

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were, however, indications that personnel error and lack of procedure adherence continue to !

exis i j The Station Operations Review Committee (SORC) properly performed their Technical

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Specification required duties and provided conservative and effective review of design ,

changes, post-trip reviews and significant events. However, in the case of the rod control ,

system problems at Unit 2, late in the SALP period, SORC did not perform well in that l multiple startup attempts were permitted without requiring the root cause of the problems to be determined. Some weaknesses were identified in the 10 CFR 50.59 process as discussed ;

in the Engineering and Technical Support sectio ;

The licensee properly implemented the Significant Event Response Team (SERT) process in !+

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order to provide an independent assessment of all reactor trips and other major events. The l NRC found the SERT reviews to be effective, and SERT recommendations were t appropriately received and considered by plant managemen ,

The PSE&G on-site Safety Review Group (SRG) and Station Quality Assurance (SQA)

performed effectively in reviewing Salem station activities. SRG provided consistently good

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shutdown risk assessments for three refueling outages and maintained good independence i from the station staff. SQA provided good coverage of routine and non-routine activities at Salem, and produced effective monthly reports and appropriately performed all audits ;

required by Salem Technical Specification l Outage planning and preparation developed into a strength during this assessment perio .

Outage work was well controlled, inter-department coordination was very good, and emergent issues were properly addressed in the three refueling outages which occurred during the period and during the forced outages of the period. Management involvement and l control of the outage work were eviden I I

l Salem station management, including the General Manager and individual department heads, i generally provided effective and conservative oversight of station activities. This management involvement was provided in daily meetings with senior nuclear shift supervision and through management accountability meetings. The Salem General Manager conducted informative State-of-the-Station meetings to convey expectations to plant personnel. Corporate management also provided a highly visible presence at the statio However, when the station was challenged by significant events, management response.was

not as effective. In some cases, management was not promptly informed of the event (loss l of overhead annunciators) or did not appreciate the significance of the event (rod control i l system anomalies). As a result, management response was initially inadequate. However, once these conditions were understood and recognized, management took conservative, thorough, and comprehensive actions, and brought the issue to a timely resolution.

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PSE&G has an excellent root cause analysis and decision making training program designed for personnel involved in problem solving and incident investigation; however, management

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has not effectively developed the criteria or expectations for when the root cause of an event must be determined prior to the resumption of normal plant operations. This contrast in the quality and ability of the program versus its implementation was demonstrated most notably in the licensee's failure to identify root cause in their handling of the Unit 2 rod control system problem The licensee's corrective action program generally functioned well, but there were signs of reduced effectiveness. The weaknesses were noted in troubleshooting activities associated with the emergency diesel generator, rod control system and overhead annunciators. In addition, inadequate oversight of contractors and vendors led to less than full knowledge of the overhead annunciator system and rod control system maintenance activities. This contributed to a delay in the root cause determination of these events. The erosion / corrosion program as implemented at Salem had significant programmatic weaknesses. In all of these cases, once the deficiency was identified by NRC, PSE&G management took immediate and appropriate actions.

l Training programs implemented by PSE&G in all areas were well developed and effectiv Of particular note were the training oflicensed and non-licensed operators, radiation protection personnel, safeguards and security personnel and on-site and off-site engineering personnel. This training and the strong results of the licensee's procedure upgrade program have resulted in improvements in the areas of reduced personnel errors and procedure adherenc The quality of the technical content of licensee submittals (e.g., amendment requests, l responses to NRC generic communications, and other licensee initiated requests) is

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occasionally deficient. Of the ten amendments that were approved, four required significant additional information to be submitted before approval. Responses to three generic letters required significant revision before satisfactory resolution of the issues was achieve Summarv

! PSE&G management continues to be involved in station activities and have generally I provided effective management support. In several significant instances (e.g., the overhead l annunciator event, the rod control system problem, and the issue involving erosion / corrosion of system piping), the licensee failed to initiate adequate root cause evaluation or assessment i of the abnormal condition. However, once management attention was directed to these

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issues, the licensee initiated very thorough and comprehensive efforts to understand and resolve the issues. SERT reviews of major events have been effective and recommendations have been accepted by licensee management. Outage planning has developed into a licensee strength. Training programs in all areas have been found to be effective with only minor weaknesses noted. Prior weaknesses in personnel errors and procedure adherence were effectively addressed. The quality of routine license submittals is occasionally deficient.

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III.G.2 Performance Rating: Category 2  ;

l III.G.3 Board Comments: The NRC is concerned with the adequacy and timelmess of PSE&G's management response to significant events and to the challenges presented by numerous component failures and several unresolved design  !

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issues at Sale l

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I SITE ACTIVITIES I Licensee Activities  ;

Unit 1

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The unit began the period at full power. On January 21,1992, the unit was shut down when three circulators were lost due to a control power cable failure. The unit was restarted on January 27,199 Unit 1 operated until it was shut down for its tenth refueling outage on April 4,1992. The unit remained in an outage to repair linear indications identified on three of the four steam generator feedwater nozzles and to replace portions of turbine building feedwater piping due to minimum pipe wall concerns. The unit was returned to service on August 16, 199 ;

Unit I remained at power until December 24,1992, when the unit was removed from service l

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l due to a loss of circulating water pumps as a result of excessive debris and increased sodium

! levels in the steam generators as a result of failed condenser tubes. Power operation !

j resumed on December 29,1992, and continued until January 16,1993, when control room )

l operators initiated a manual reactor trip from 13% power following the failure of the steam l dump system. The unit was being shut down at the time for control rod position indication !

system maintenance. Following completion of the related repair activities, the unit was restarted on January 21,199 An automatic reactor trip occurred from 100% power during nuclear instrumentation testing on February 16, 1993. A spike occurred on another channel (loop 11 Tave) resulting in a two of four coincident Over Temperature Delta-Temperature reactor trip. The unit restarted ;

on February 22,199 J l

The unit operated at power until it automatically tripped from 100% power on June 8,1993, l when four of five circulators tripped due to large sea grass intrusion. The unit remained shut l l down at the end of the SALP perio Unit 2 The unit began the period in its sixth refueling outage following the November 9,1991, ;

turbine generator failure. Unit 2 was restarted on April 19, 199 '

A reactor trip from 4% power occurred on April 26,1992. The unit was restarted on May 3,1992, and on May 14, 1992, a trip from 15% power occurred. Both of these trips occurred on low-low steam generator level due to problems with the feedwater level control system. The unit was restarted on May 18, 199 On June 18, 1992, the licensee shut down Unit 2 due to feedwater pipe wall thinning caused by erosion / corrosion. The unit was restarted on July 15,1992, and continued to operate

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until September 3,1992, when an automatic reactor / turbine trip occurred from full power.

l The cause of the trip was determined to be a non-licensed operator error. The unit was restarted on September 6,199 Unit 2 operated at power until January 28,1993, when control room operators manually tripped the unit from 100% power, immediately following the loss of both operating steam generator feed pumps caused by a loose test connector. The unit was restarted on January 31, 199 .

The unit operated at power until March 16,1993, when the unit automatically tripped from l 100% power on low steam generator level caused by a failed pressure control switch in the

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condensate polishing system. The licensee then began the unit's seventh refueling outag Several aborted post refueling startups occurred during the period May 24 - June 4,199 This included a manually initiated reactor trip on May 28,1993, when one control rod bank dropped into the core. The unit remained shut down at the end of the period while rod control system problems were investigate I NRC Inspection Activities Four NRC resident inspectors were assigned to Artificial Island during the assessment period. NRC team inspections were conducted in the following areas:

• Salem 2 restart readiness after a six month outage to repair / replace the turbine generator from March 22 - May 2,199 * Motor Operated Valve Insyction on May 4-8, 199 * Emergency Preparedness Inspection conducted on October 27-29,1992, to observe the Artificial Island annual exercise.

l e Augmented Inspection Team to review a loss of annunciators event at Unit 2 from December 14-23, 199 e Fire Protection Appendix R Inspection on May 17-21, 1993.

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l e Augmented Inspection Team to review Unit 2 rod control abnormalities from June 5-28,1993.

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ATTACHMENT 1

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SALP EVALUATION CRITERIA. PERFORMANCE CATEGORIES AND TRENDS

The following evaluation criterion were used, as applicable, to c.ssess each functional area: Assurance of quality, including management involvement and contro . Approach to the identification and resolution of technical issues from a safety standpoin . Enforcement histor . Operational and construction events (including response to, analyses of, reporting of, and corrective actions for). Staffing (including management). I Effectiveness of training and qualifications progra !

l The performance categories used when rating licensee performance are defined as follows: l

Category 1. Licensee management attention to and involvement in nuclear safety or l safeguards activities resulted in a superior level of performance. NRC will consider reduced j levels of inspection effor I i

Category 2. Licensee management attention to and involvement in nuclear safety or safeguards activities resulted in a good level of performance. NRC will consider maintaining i normal levels of inspection effor )

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Category 3. Licensee management attention to or involvement in nuclear safety or l safeguards activities resulted in an acceptable level of performance; however, because of the NRC's concern that a decrease in performance may approach or reach an unacceptable level, NRC will consider increased levels of inspection effort Category N. Insufficient information exists to support an assessment oflicensee performance. These cases would include instances in which a rati'ig could not be developed because of insufficient licensee activity or insufficient NRC inspectio The SALP Board may assess a performance trend, if appropriate. The trends are:

Imoroving: Licensee performance was determined to be improving during the assessment perio Declining: Licensee perfonnance was determined to be declining during the assessment period and the licensee had not taken meaningful steps to address this patter Trends are normally assigned when one is definitely discemable and a continuation of the trend is expected to result in a change in performance during the next assessment perio I L , . , -

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ENCLOSURE 2 l

l INITIAL DRAFT SALP REPORT ,

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l U.S. NUCLEAR REGULATORY COMMISSION !

l REGION I  !

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE l l >

j REPORT NO 50-354/91-99

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PUBLIC SERVICE ELECTRIC AND GAS COMPANY IIOPE CREEK GENERATING STATION

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ASSESSMENT PERIOD:

l DECEMBER 29,1991 - JUNE 19,1993 BOARD MEETING DATE:

JULY 29,1993 l

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TABLE OF CONTENTS I NTR OD U CTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 I SUMMARY OF RESULTS ................................. 3 I Overvi ew . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 I Facility Performance Analysis Summary . . . . . . . . . . . . . . . . . 4 i

II PERFORM ANCE ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 II Plant Operations ............................... 5 !

II Radiological Controls ............................ 7 II Maintenance / Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . 10 II Emergency Preparedness ......................... 12 II Security and Safeguards . . . . . . . . . . . . . . . . . . . . . . . . . . 14 i II Engineering and Technical Support . . . . . . . . . . . . . . . . . . . 16 II Safety Assessment / Quality Verification . . . . . . . . . . . . . . . . . 18 ;

I SITE A CTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 I Licensee Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 l I NRC Inspection Activities . . . . . . . . . . . . . . . . . . . . . . . . . 21 :

Attachment: SALP Evaluation Criteria, Performance Categories and Trends  ;

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' INTRODUCTION l l 1 t

l The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC l i

staff effort to collect available observations and data periodically, and to evaluate licensee performance on the basis of this information. The program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations. It is i intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources !

I and to provide meaningful feedback to the licensee's management regarding the NRC's j l assessment of their facilities' performance in each functional are )

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An NRC SALP Board, composed of the staff members listed below, met on July 29,1993, to review the obse: cations and data on performance, and to assess licensee performance in accordance with the guidelines in NRC Management Dirudve 8.6, " Systematic Assessment of Licensee Performance," dated September 28,1990. The SALP Evaluation Criteria utilized by the board are attached.

l This report is an assessment for the Hope Creek Generating Station for the 18 month period j from December 29,1991, to June 19, 1993. The Hope Creek SALP Board members were:

CHAIRMAN:

W. D.12nning, Deputy Director, Division of Reactor Projects (DRP), Region I (RI)

l l MEMBERS:

! M. L. Boyle, Acting Director, Project Directorate I-2, l Office of Nuclear Reactor Regulation (NRR)

S. Densbek, Project Manager (Hope Creek), NRR C. W. Hehl, Director, Division of Radiation Safety and Safeguards (DRSS)

T. P. Johnson, Senior Resident Inspector, Salem / Hope Creek, RI  :

j C. L. Miller, Acting Deputy Director, Division of Reactor Safety (DRS)

l E. C. Wenzinger, Chief, Projects Branch No. 2, DRP, RI

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I l' 2 l OTHERS IN ATTENDANCE:

J. R. White, Chief, Reactor Projects Section 2A, DRP, RI T. H. Fish, Resident Inspector, Salem / Hope Creek, RI S. T. Barr, Resident Inspector, Salem / Hope Creek, RI J. G. Schoppy, Resident Inspector, Salem / Hope Creek, RI S. M. Pindale, Resident Inspector, Oyster Creek, RI H. K.12throp, Resident Inspector, Calvert Cliffs, RI B. J. McDermott, Reactor Engineer, DRP, RI R. L. Nimitz, Senior Radiation Specialist, FRPS, DRSS, RI C. Z. Gordon, Senior Emergency Preparedness (EP) Specialist, EP Section, DRSS, RI J. C. Stone, Project Manager (Salem), NRR R. R. Keimig, Chief, Safeguards Section, DRSS, RI  !

J. H. Lusher, EP Specialist, DRSS, RI  ;

R. J. Summers, Project Engineer, RI

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L. H. Bettenhausen, Chief, Operations Branch, DRS, RI J. P. Durr, Chief, Engineering Branch, DRS, RI S. A. Morris, Reactor Engineer, DRP, RI ,

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J. I. Zimmerman, Project Engineer, NRR M. J. Davis, Performance Evaluator, NRR L. S. Cheung, Senior Reactor Engineer, DRS, RI

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l' 3 I SUMMARY OF RESULTS

, Overview i

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On July 29,1993 the SALP board met to discuss PSE&G's performance at Hope Creek during the period from December 29,1991 to June 19, 1993. The board concluded that the licensee had operated Hope Creek in a safe and conservative manner. Operator training was a strength and the operator error rate remained low, contributing to a decreased reactor scram rate. PSE&G provided effective management oversight and attention to all operational activities. A oveakness was noted in management's oversight of firewatch program activities, a common function affecting Salem and Hope Cree ,

The licensee continued effective implementation of their state-of-the-art radiological controls program. The SALP board noted that management support and control, staffing levels, quality assurance oversight, and ALARA were program strengths.

i PSE&G demonstrated superior results in maintenance program implementation at Hope Creek, and very good results in surveillance testing. Continued management involvement in improving program performance and correcting identified problems was evident. The SALP board also noted specific improvements in procurement and material control during this period.

l The SALP board determined that PSE&G maintained a generally strong and effective emergency preparedness (EP) program. However, the board was concerned with an apparent decline in the ability of the licensee to make correct initial Protective Action Recommendations during training, drills, and annual exercises. This concern resulted in the board's assessment of a declining trend for this area. The board also concluded that PSE&G continued to maintain an effective and performance-oriented security program during this period. Overall, licensee performance in both EP and security remained excellen Engineering and technical support for the Hope Creek station improved during this SALP period. The board noted improvements in the licensee's program for controlling design changes and plant modifications, MOV program implementation, training of the engineering staff, and reduction of engineering backlogs. Although the root cause training program was viewed as a strength, the board noted that the threshold for initiating actual root cause investigation was not clear or consisten The licensee continued to perform well in the area of Safety Assessment and Quality Verification during this period. First line supervision and management oversight were very

good, as was the independent review provided by the On-site and Off-site Safety Review

! Groups and by Station Quality Assurance. Performance by individuals was strong, as evidenced by a reduction in the personnel error rat l

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l l I Facility Performance Analysis Summary  ;

Rating, Trend Rating, Trend Functional Area Last Period This Period -

i Plant Operations 1 1 l Radiological Controls 1 1 Maintenance / Surveillance 2, Improving 1 l Emergency Preparedness 1 1 Declining Security 1 1 l Engineering / Technical Support 2 2, Improving l Safety Assessment / Quality 1 1 l Verification

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Previous Assessment Period: August 1,1990 through December 28,1991 l l l Present Assessment Period: December 29,1991 through June 19, 1993 l

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II PERFORMANCE ANALYSIS f

II Plant Operations III. Analysis i

The previous SALP rated Hope Creek operations as Category 1. That assessment concluded that PSE&G operated the Hope Creek reactor conservatively with nuclear safety as the top i

priority. Operator errors remained low, however, the frequency of automatic reactor scrams was a concern. Strong management and supervisory oversight of, and involvement in, operations were evident. The licensee conducted its third refueling outage effectively. An effective training program was noted; though, the failure rate for initial Reactor Operator license examinations near the end of the period indicated weak preparatio During this assessment period, PSE&G operated the reactor in a professional and safety conscious manner. Well-trained operators skillfully performed their duties during unit startups, shutdowns, and transients. For the two reactor scrams that occurred during the period, operator performance was not a causal factor. During a loss-of-offsite power and a failure of reactor feedwater pump automatic control, prompt and effective operator actions to restore equipment and to deal with power reductions mitigated these plant transients and thus avetted plant scrams. The licensee completed an event-free 300 day run in the middle of 1992 when the unit was shut down for a scheduled mid-cycle or~ v The licensee exceeded the minimum Technical Specification shift stafnng requirements for Senior Reactor Operators (SRO) and Reactor Operators. Additionally, SRO licensed individuals supervised the work control group continuously. SRO licensed personnel l

provided field support for day shift operational activitie Plant management maintained effective and thorough oversight and attention to all operational activities on a daily basis. Daily status meetings were used to provide an operational l perspective of plant problems and work prioritization with the focus on nuclear safety, as was evidenced by the timely and thorough followup to a boron dilution problem in the standby liquid control system, the initiation of a timely shutdown for failure of three torus-to-

drywell vacuum breakers, and a very proactive approach to shutdown risk managemen The licensed and non-licensed operator training programs were well developed, effectively l implemented, and received strong management support. Candidates for initial and I

requalification license examinations were well-prepared and knowledgeable. There were no license examination failures during this period, indicating that corrective measures taken as a result of weak performance on license examinations in the previous period had been effective. Training facilities and materials were excellent, and the licensee's use of the l

simulator for training, event analysis, drills, and observations of performance was a strengt ,

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The requalification program identified weaknesses related to evaluation standards in the operating portion of the examination and administrative procedures and controls for use of

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the scenario examination bank during training. These weaknesses involved administrative procedures and controls, and linkage between simulator scenarios and conditions.

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The professional control room demeanor, nuclear safety perspective and knowledge of plant activities of the licensed operators continued to be a strength. Operating procedures were detailed and accurate. Operations managers implemented a number of procedure enhancements to promote continued improvement. For example, SRO licensed personnel author, review, and perform safety screening responsibilities for operations depanment procedures, which has resulted in a decrease in the procedure revision request backlog.

l Overtime usage was properly controlled. The personnel error rate was very lo The licensee's implementation of the Emergency Operating Procedure (EOP) program was very good overall. Several long-standing issues involving procedure implementation levels were acceptably resolved. The licensee continued to improve the administrative procedure ROs and non-licensed operators demonstrated thorough knowledge and attention to detail in l the operation and testing of equipment and systems. Equipment operator effectiveness was enhanced during the period by the implementation of a computerized equipment surveillance log system, which simplified data collection and also provided improved data review and ,

trend analysis capabilitie ;

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Concerned with a higher-than-expected number of scrams over the previous periods, the licensee conducted a thorough investigation into the root causes of the scrams and i implemented a number of corrective actions during this period. During the current period 1 l one scram occurred due to equipment problems and one due to contractor personnel erro Licensee actions have effectively reduced the scram rate from that observed during the ;

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The fire protection program was good and staffed with dedicated fire protection personnel l from the Site Protection group, who responded to fire and first aid emergencies. Plant and site management supported the fire protection program. The licensee's investigation of a self-identified instance of misconduct by a firewatch revealed a more extensive weakness in oversight and control of contract personnel performing roving firewatch duties. More than half of the firewatch personnel annotated their logs to indicate they had inspected areas when in fact they had not. The licensee's corrective actions were prompt and comprehensise in assessing and resolving this deficiency once it was identifie i

! Overall, plant housekeeping was very good. Improvements continued during the period, '

including facility painting, rescaling of floor surfaces, using sticky pads to prevent dirt and I

hot particle spread, and implementing a clean bootie program for selected work group ,

These activities positively reflected the level of support provided by management and l l contributed significantly to plant cleanliness and housekeeping condition The licensee effectively prepared for Hope Creek's fourth refueling outage, including a very thorough shutdown risk assessment. Work performance during the outage was very good,

with minimal rework required. However, personnel errors contributed to two potentially safety-significant events

an inadvertent loss of reactor cavity inventory and a short-term loss

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of shutdown cooling. However, the licensee took prompt corrective actions to preclude

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recurrence. The unit was returned to service in a safe and efficient manne i I

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Summary PSE&G operated the Hope Creek unit in a professional and safety conscious manner, and the frequency of abnormal events remained low. Strong management oversight and attention to all operational activities were noted. The fourth refueling outage was effectively p'anned and executed. Operator training was strong, as evidenced by the examination results and field

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observations. Weaknesses were noted in management's oversight of firewatch program activitie III. Performance Rating: Category 1

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l III. Board Comments: None i

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II Radiological Controls l I

III. Analysis  !

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The previous SALP rated the functional area of radiological controls as Category 1. NRC

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reviews during the previous period determined that radiological controls staffing levels we l excellent, effective measures were taken to minimize personnel exposure, and radiological l l work activities were effectively managed. The environmental monitoring and effluent  !

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! controls programs were effectively implemented as were the radwaste processing, handling and shipping program NRC reviews during the current period identified that there was a high degree of l management and supervisory oversight of radiation protection and chemistry activities. For example, NRC reviews of outage activities identified very good work planning and control, a high degree of radiation protection involvement in on-going activities, and excellent efforts at i minimization of ambient radiation dose rates and aggregate personnel radiation exposure i through successful implementation of the hydrogen water chemistry, iron reduction, and depleted zine injection programs. Although the 1992 goals for radiation dose and personnel contaminations were slightly exceeded, the licensee performed very well in keeping exposure i As 14w As Reasonably Achievable (ALARA). An aggressive refueling outage dose goal was met despite emergent work. Planning and procedure development for implementation of )

the revised 10 CFR Part 20 was very goo l l The radiological controls organization wic, well defined, well staffed, and augmented, as l appropriate, to support outage work activities. There was minimal use of overtime and a very good level of technical expertise within the organization. 12te in the period the radiological controls group was re-organized and the position of radiation i protection / chemistry manager was eliminated and replaced with direct reporting managers for l

each organization. The re-organization was performed in a controlled manner and no negative effects were identified by the close of the period. Appropriately qualified personnel l continued in responsible position l

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The training and qualification program continued to be a strength. Radiation workers received appropriate and timely training. A new course titled, " Integrated Training," was implemented at both Hope Creek and Salem Stations. This course involved radiation workers and radiological controls personnel planning and performing work activities together under realistic conditions on a mock-up. The majority of radiation protection and maintenance personnel attended the course. The NRC considered the course a very good initiative. Radiation protection and chemistry personnel were well trained and very knowledgeable. A well defined initial qualification program for both permanent radiation protection personnel and contractor radiological controls personnel was maintaine However, an NRC review determined that the radiation protection technician staff were not always reviewing required reading material (e.g., procedure changes). Enhanced supervisory oversight of required reading activities was immediately initiated including supervisor verification of completion.

I The internal and external exposure control programs were effective and overall control of l

radiological work activities was commendable. There were no internal or external personnel !

i exposures in excess of NRC limits and overall administrative controls of personnel exposure l were effective. An effective access control system using state-of-the art computer supported equipment continued to be maintained. The weaknesses associated with quality control of dosimetry, identified during the previous period, were corrected. Also, NRC identified

! weaknesses in exposure records controls, identified early in the period, were also correcte Radiation protectior. personnel demonstrated excellent containment entry controls and appropriately responded to the inadvertent reactor cavity inventory loss and standby liquid

control system boron loss. The radiological occurrence report program, well supported by l management, was effective in identifying root cause and corrective actions for radiological problem A strong radioactive material and contamination control program was implemented. The licensee continues to maintain very good programs for monitoring and control of Zine-65, a difficult to detect radionuclide. Late last period, aggressive monitoring detected minor migration of this contamination outside the radiological controlled area boundary into the on site sewage system. The contaminated sewage was isolated and properly disposed of, and

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appropriate corrective actions were implemented to preclude recurrence. Station

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housekeeping continued to be noteworthy. Total contaminated area square footage was rigorously controlle The radioactive waste processing, handling, storage and transportation programs continued to i be effective and well coordinated. Plans have been established for interim on-site storage of l radioactive waste in the event of delays in finalization of state compact efforts.

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The ALARA program continued to be effective in maintaining personnei radiation exposure low. Exposure goals were found to be challenging, planning and preparation was effective, and very good oversight of on-going activities from an ALARA standpoint was performe The licensee continued to aggressively implement long term exposure reduction initiatives (e.g., snubber reduction, iron reduction, hydrogen water chemistry, and robotics). A working group, with BWR vendor representatives, was established to plan and implement innovative shut-down techniques to maximize clean-up of radioactivity in the reactor coolant during shutdown. Emergent work received appropriate reviews and ALARA control '

The Radiological Effluent Control Program (RECP) and Radiological Environmental Monitoring Program (REMP) continued to be effectively implemented during this assessment period. Licensee personnel exhibited good knowledge of all RECP areas including effluent controls, radiation monitoring systems (RMS) and off-site dose calculations. Comparisons of projected off-site doses between the licensee and the NRC PCDOSE computer code were in excellent agreement. Procedures were detailed, ccacise and well written and resulted in ;

effective implementation of the RECP and REMP. Effluent RMS calibrations were excellent and exceeded industry practices. The meteorological monitoring was effectively implemented. Reactor coolant chemistry was excellent with a very low fission product activity leve Overall quality assurance (QA) oversight of program areas was very good. Special audits of dosimetry program matters were conducted and independent assessors cantinued to be used to effectively monitor outage activities. QA audits of effluent and environmental monitoring programs were thorough and of sufficient technical depth to probe for programmatic weaknesses. Findings were promptly resolved. Early in the period, the NRC identified a weakness in the area of audits of personnel qualifications. It was not clear that personnel qualifications of all appropriate groups were being systematically audited. The QA group immediately initiated baseline audits and no unqualified personnel were identifie i Spmmarv l

The licensee continued to maintain and implement an effective state-of-the art radiological j controls program. There was excellent support and control by management and effective j QA oversight. Staffing levels continued to be very good, and the ALARA program was !

effective in reducing personnel exposure. The internal and external exposure control !

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programs were well maintained and effectively implemented as were the environmental and i

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effluent controls programs. Radwaste processing, handling, and shipping programs also !

continued to be well maintained and effectively implemente III.B. Performance Rating: Category 1 III.B. Board Comments: None l

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II Maintenance / Surveillance l III. Analysis

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The previous SALP rated the maintenance / surveillance fmetional area as Category 2,

Improving. Program strengths included effective management involvement, a stable, well-l trained staff, and well-written procedures. Weaknesses involved material procurement, j occasional lapses in attention to detail, and continued personnel error initiated plant events.

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During this period, the Hope Creek maintenance program demonstrated superior performance. The program was staffed with skillful, well-trained personnel. Procedure

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quality and adherence were strong, and effective management oversight of activities was l present. Results from the maintenance program were excellent. Previous weaknesses I regarding procurement, attention to detail, and personnel errors were effectively addressed and correcte Management supported specialized training, including the use of PSE&G's extensive electrical and mechanical training facilities. Excellent procedure adherence and strong direction from line management and supervision contributed to the high quality of work and ,

low error rates. Management at all levels, from first line supervision through department and plant management, was observed in the field providing the appropriate oversigh Maintenance program implementation provided excellent results. The quality of corrective j maintenance work was excellent, including a very low rework rate. There were no i maintenance initiated reactor scrams, and reportable events attributable to maintenance were minor.

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Effective maintenance planning and implementation resulted in a low maintenance backlo Equipment forced outages were rare and of short duration, an indication of an effective preventive maintenance program. Based on NRC observation, safety-related equipment availability was excellen PSE&G addressed previous weaknesses in procurement and personnel errors, and impioved the maintenance program in other areas. As previously noted, personnel errors were low and significantly reduced from the previous period. Results improved in procurement as j demonstrated by adequate spare parts which properly supported work efforts. Management j strengthened their approach on planned equipment outages to ensure that a net safety gain l

would be achieved during any planned and executed equipment / system outage. Based on NRC inspection and observation, these initiatives were effective and demonstrated a safety-conscious attitude.

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The licensee continued improvement in the area of spare parts procurement and availabilit The new integrated and automated warehouse was placed into operation during the period and provided effective suppon in effons to reduce the corrective maintenance backlog and to support refueling outage activities. For example, during the unit's fourth refueling outage, the licensee ensured spare parts availability in order to complete scheduled tasks on tim Additionally, pans were available for emergent work such that no negative impacts to scheduled activities or outage duration occurred.

I Hope Creek completed a scheduled mid-cycle outage, a refueling outage, and several forced outages during this SALP period. Strong maintenance planning and outage organizations conducted these outages safely and effectively. A strong safety-conscious attitude was demonstrated during shutdown risk and equipment outage reviews. Emergency diesel generator overhauls and control rod drive replacements were effectively and safely conducted.

A wiring error caused by maintenance personnel was not corrected during motor-operated l

valve work, and resulted in an unplanned reactor cavity inventory loss. This personnel error was caused by inadequate wiring diagrams and tabulations, weak communications, and poor working practices. PSE&G appropriately responded to this event and initiated effective corrective actions.

i l Surveillance l The Hope Creek surveillance program was effectively implemented and demonstrated very l good results. Strong oversight by management and good cooperation among departments contributed to a successful surveillance program. Surveillance tests were effectively  ;

scheduled and tracked by the central planning organization using the maintenance information system. Two surveillances were missed: one due to a personnel error and one due to a j procedure inadequacy. The frequency of these errors has continued to decrease over the last i few assessment period !

The surveillance test program effectively demonstrated system operability. Surveillance procedures were generally well written, appropriate and complete. Procedure weaknesses were identified and immediately corrected. Implementation and review of surveillance procedures were competently performed. A few instances oflack of rigor in post-test i reviews and comparisons with design data were noted. These were corrected upon identificatio The number of surveillance caused events continued to decrease compared to previous periods. There were no surveillance initiated reactor scrams as compared to two last perio A total of 7 personnel errors occurred in the surveillance area (out of 9,000 surveillance actMties) which resulted in Licensee Event Repons; this total was fewer than last perio Four engineered safety feature actuations were caused by personnel errors during surveillance testing. Corrective actions for these events were thorough and timely. PSE&G completed a design change to improve testability. This change provided better identification of test points and relocated these test points to prevent inadvenent actuation i

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The inservice inspection program continued to be well planned and implemented with appropriate quality assurance department oversight. The feedwater nozzle ultrasonic examinations and snubber examinations used state of the art technology and specially trained, qualified technicians. The erosion / corrosion program was improved. PSE&G corrected the j prior identified weaknesses in the predictive analysis of erosion / corrosion rates by establishing a programmatic standard for the erosion / corrosion monitoring progra Summary Hope Creek demonstrated superior results in maintenance and very good results in surveillance testing. Management involvement in improving program performance and l correcting identined problems was evident. Program strengths included effective, detailed i procedures, skillful staff, and excellent oversight by managers and supervisors. Although some personnel errors occurred, they were at a decreased rate as compared to previous

periods. A maintenance caused wiring error resulted in an unplanned reactor cavity level loss. Improvements were noted in procurement and mateial contro IH. Performance Rating; Category 1 l

IH. Board Comments: None *

l l II Emergency Preparedness (Hope Creek and Salem - Combined Assessment)

III. Analysis  :

During the previous SALP, Emergency Preparedness (EP) was rated Category 1. That rating was based on strong management involvement and commitment to EP, a highly qualified EP j staff, a thorough and innovative training program, and excellent support of off-site agencies. l PSE&G's Emergency Response Organization (ERO) was well quali5ed as evidenced by effective exercise performanc During this SALP period, the licensee responded to two events at Salem and two events at l

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Hope Creek. The Salem events were low river level and transportation of a contaminated injured person to the local hospital; Hope Creek had an Emergency Core Cooling System l (ECCS) initiation with vessel injection and inoperability of primary containment. In each case, PSE&G correctly classified these events as Unusual Events and properly implemented the Emergency Plan. Notifications of on-site and off-site response organizations were timel Salem Unit 2 also experienced a loss of Control Room overhead annunciators (OHAs) on December 13, 1992. Operators restored the OHAs within two minutes of recognition of their loss. However, this event involved the unidentified (for about 90 minutes) existence of a condition defined as an emergency, and subsec,uent notification of cognizant

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organizations was not accomplished until afte. repeated prompting by the resident inspecto At the end of the SALP period, licensee classification and reporting of this event was still under licensee and NRC revie PSE&G's performance in the October 1992 full-participation exercise at Salem was very good. Under a challenging scenario, strengths were identified in Emergency Response Facility command and control, Technical Support Center engineering assessment, Operational Support Center prioritization and management of repair tasks, and Emergency Operations Facility (EOF) dose assessment. One exercise weakness was identified: the initial (sheltering) protective action recommendation (PAR) was not consistent with this General Emergency. That was corrected by an upgraded PAR (for evacuation). PSE&G conducted numerous other drills during the period, including an assembly and accountability drill in the protected area and an unannounced off-hours callout of the ERO. These were well coordinated by the EP Department and showed excellent PSE&G initiativ Management support of EP was evident. Senior managers met periodically with the Manager, EP for program status reports. Senior staff were qualified in upper-level ERO positions. EP staff regularly met with state and local officials to discuss EP issues. A very good working relationship with off-site agencies was indicated. This was evident at a PSE&G-sponsored forum for New Jersey State and local officials, FEMA, and the NRC to discuss emergency response roles and relationship Independent licensee audits of the EP program were of good quality and resulted in minor recommendations for program enhancement. The corrective action system was effective and ,

appropriately used by EP staff to track outstanding items to resolutio ;

EP training effectiveness was demonstrated during NRC-observed table-top walk-through scenarios with shift crews from Salem and Hope Creek. Overall, crews worked together and responded well. However, weaknesses were :dentified in making emergency classifications and protective action recommendations (PARS), and in providing complete information to the NRC. For example, the loss of containment was not recognized, this resulted in a different classification than was specified in the Event Classification Guide and in non-conservative PARS / PAR upgrades. Additionally, PSE&G Emergency Action Levels for fission product boundary failures did not clearly address the loss of the containment boundary. PSE&G committed to addressing these concerns through training and procedure revisions. The I effectiveness of the licensee's actions has not yet been inspecte EP staffing was a strength. The program was administered by a stable staff of fourteen, l

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including a very good mix of well qualified and responsible senior reactor operator, health physics, and maintenance personnel. The ERO was also fully staffed, with managerial !

positions filled by experienced senior personnel.

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PSE&G successfully implemented the Emergency Response Data System (ERDS) in February 1993. Emergency Response Facilities were maintained in a very good state of readiness.

l Appropriate equipment and supplies were available. Surveillances were completed at prescribed frequencies and instrumentation was calibre.ed. Notewonhy improvements were ,

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made to the prompt notification system (siren) hardware and software. All communications equipment was found to be consistent with licensee procedures. However, portable respirators were found stored inside the radiological controlled area instead of in designatcd Control Room / Operational Support Center locker Summary PSE&G maintained a generally strong and effective EP program. Senior management commitment to EP was evident through program involvement and qualification in key ERO positions. EP was well staffed, with a good discipline mix. The Emergency Plan was effectively implemented during four Unusual Events. Licensee response to the December 1992 loss of the Salem 2 control room OHAs resulted in non-classification and non-reporting of a defined emergency which remains under NRC review. Training was generally good, but table-top exercises, and emergency drills and exercise performance indicated a need to improve procedural guidance and training in event classification and PAR fonnulatio Facilities were maintained in good operational readiness.

I III. Performance Rating: Category 1, Declining III. Board Comments: NRC was concerned with the licensee's ability to make accurate and consistent PAR I II Security and Safeguards (IIope Creek and Salem - Combined Assessment)

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The previous SALP rated this area Category 1. That rating was based on the licensee's I maintaining an effective, performance-based security program which, in many areas, exceeded regulatory requirements; and demonstrating sensitivity in effectively managing events that challenged the performance of the security organization. In addition, audits and i self-assessments of the security organintion. program upgrades and enhancements were indicative of excellent support from both corporate and station management for the security program.

l During this SALP period, corporate and station management acted prudently and responsibly l

in contracting for an independent review of station security and other support programs following the off-duty suicide of a security-force member. The comprehensive, in-depth review did not show any work-related culpability. Throughout the period, there were no appreciable adverse results from the incident on the morale or performance of the security organizatio Station security management demonstrated initiative in evaluating the effectiveness of the security program and in enlisting the support of corporate and station management for program improvements and enhancements. This initiative was evident by the licensee's efforts to enhance tactical training by additional contractor support. The training involved

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defensive strategy, full-scale contingency drills and tabletop analyses of numerous scenarios of the design basis threat. Funhet initiative was shown in coordinating a security drill among state and local law enforcement agencies, and the security force. The drill was well-planned and executed. It also provided the law enforcement agencies with valuable insight of security procedures and station layout. In addition, excellent management support, throughout the period, was evident for the systematic upgrade of the aging assessment aids ;

j and other program enhancements.

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l The licensee also maintained aggresive, effective audit and self-assessment programs throughout the period. These programs were instrumental in identifying potential weaknesses such as the improper control of safeguards information, and fitness-for-duty (FFD) problems and assisting the licensee in implementing corrective measures before problems develope Excellent rapport with other plant groups also helped minimize the number and extent of problem ,

The FFD program was generally well implemented and comprehensive. However, f programmatic problems were identified relative to personnel with infrequent, unescorted station access and training for newly appointed supervisors who were responsible for implementing certain aspects of the FFD program. While the licensee identified these problems, they were not effectively resolved before coming to NRC attention. Despite these programmatic problems, the program proved effective in identifying personnel who did not

meet FFD requirements. For example, the licensee took effective corrective actions when a supervisor on a tour identified a security officer who failed to meet FFD parameter Staffing for the security organ:zation was appropriate. This was evident during the unplanned outage following the turbine failure at Salem and three planned refueling outages, ,

two at Salem and one at Hope Creek. Each of the outages required only a small amount of l overtime for security personne A minor supervisory oversight problem was identified by the NRC late in the period when security personnel were observed searching a vehicle contrary to the manner in which they were trained. Generally, however, supervisory oversight of the security force was good, and the security force continued to demonstrate attentiveness to security responsibilities and responsiveness to identified problems. This was evident in the relatively smooth day-to-day on-site operations and prompt and appropriaa handling of security threats, such as a 1 telephone threat and the identification by x-ray of contraband material. The security force also performed very capably on April 10,1992, when an apparent lightning strike resulted in a loss of the security computer and during a severe winter storm that occurred March 12-15,1993, that resulted in significant system degradation !

Training for the security force continued to be well-developed and generally well administered. This was evident, throughout the period, by the high level of performance indicated above and the small number of security personnel errors during the perio i l

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The licensee's event reporting procedures were found to be clear and consistent with NRC i reporting requirements. One event, which involved the x-ray search detection of contraband mentioned earlier, required prompt reporting to the NRC during this period. The licensee's report was clear, concise and indicated appropriate responses. The licensee's event log was found to be well maintained and utilized for tracking repetitive event During this period, the licensee submitted two revisions to the physical security plan and one revision to the training and qualification plan. The revisions were of high quality, technically sound and reflected well-developed policies and procedure Summary t In summary, the licensee continued to maintain a very effective and performance-oriented security program. Corporate and plant management attention to and support for the program remained evident throughout the period. Improvements to the program were made where necessary, to maintain its effectiveness. Excellent rapport was maintained with other plant j groups, to minimize problems. The audit and self-assessment programs remained effective, ;

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and enhanced program implementation. However, corrective actions were not always timely as evidenced by the delay in resolving FFD problems Staffing reflected program needs and the training program was strong. Program plans and procedures were well-written and understood by all concerned and reflected a thorough and comprehensive understanding of regulatory requirements.

l III. Performance Rating: Category 1 III. Board Comments: None II Engineering and Technical Support  !

III. Analysis The previous SALP rated Engineering and Technical Support as Category 2. The previous j assessment indicated weaknesses in engineering's development of the safety-related motor l operated valves (MOV) program in response to Generic Letter (GL) 89-10. Other weaknesses were also observed in Hope Creek responses to the Station Blackout Rule, in the i initial root cause evaluation associated with the filtration, recirculation and ventilation system (FRVS) heater fuse failures and in responses to the NRC regarding GLs. Despite these weaknesses, Hope Creek was provided with strong technical support during the previous SALP perio Engineering and Technical Support for Hope Creek is provided by corporate engineering, known as Engineering and Plant Betterment (E&PB), and the onsite system eni,iaeering group. These groups effectively provided technical support for refueling and maintenance outage activities. E&PB handles major engineering efforts such as plant modifications and

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design bases reconstitution. The onsite system engineering group supports operations, maintenance, testing and minor design change activities. These groups are well staffed with experienced personnel in various engineering discipline The onsite system engineering group was well-staffed with experienced, knowledgeable and well-trained pmonnel. The licensee continued their eight-month system engineer training program. Most of the system engineers have successfully completed this program and almost all have received formal root cause analysis training. The system engineering group has provided good support for safe and efficient plant operation as demonstrated by the progress l made on the implementation of the GL 89-10 MOV program and by their analysis and l resolution of a number of emergency diesel generator design and operability issues.

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However, there was a recurring number of EDG jacket cooling water pump seal fdlures. A l contributing factor to these failures was inadequate system engineering review and root cause

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l E&PB worked well with the onsite system engineering group. Examples included the torus l to drywell vacuum breaker disc torquing analysis and the emergent snubber analysis work during the fourth refueling outage. Several improvements to the design change process were i made to reduce paperwork ar aetter focus on safety significant issues. For example, a simplified " workbook" or design and review package was introduced that significantly reduced design package preparation and review time. In response to previously identified l deficiencies in the GL 89-10 program, the licensee made noteworthy progress in implementing program requirements. For example, during the unit's fourth refueling outage, 134 of 258 MOVs were statically tested and 23 dynamically tested. However, a wiring error and inadequate followup by engineering and test personnel resulted in an unplanned reactor cavity level decreas I The modification packages reviewed were of good quality. They were thorough and j contained adequate safety reviews. However, the licensee made a change to the facility as described in the UFSAR without determining if there was an unreviewed safety question l involved. Furthermore, there were other isolated cases of the licensee failing to follow its 1 10 CFR 50.59 implementation procedure. Individually, these failures to follow procedure did not have safety significance; however, the finding indicates a continuing defect in the licensee's 10 CFR 50.59 progra The licensee had an excellent training pagram for E&PB staff and onsite system engineering personnel. A typical system engineer received substantial theory-based training, including thermodynamics, heat transfer, and fluid mechanics. Recent enhancements to the E&PB training program have advanced towards a more performance / application oriented approac The Design Change Process training was being expanded to include examples of completet packages; the Configuration Baseline Documentation (CBD) training has been revised to emphasize the application of the CBDs and the maintenance of the documents due to regulatory and operating experience reviews. In addition, the licensee has an excellent Root Cause Analysis and Decision Making course designed for members involved in problem solving and incident investigations such as licensee event reports (LER).

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The licensee has initiated an aggressive program to pursue resolution of the Hope Creek hydraulic control unit (HCU) accumulator lining pitting problem, although the safety evaluation indicated that the pitting would not inhibit the movement of the piston during a reactor scram. The licensee aggressively gathered information from other utilities and the accumulator vendors to resolve this problem, and instituted a program to detect this problem in the remaining HCUs during the refueling outag E&PB assumed responsibility for locating discontinued parts and effectively implemented a program to develop new sources for parts and to provide equivalent replacements. E&PB has also initiated an aggressive program to reduce substantially the engineering work request (EWR) backlogs for both Salem and Hope Creek. Similar progress was made by the onsite system engineering. For Hope Creek, the number of EWR backlogs was redu w.d by more than one thir As a result of concerns identified during an NRC inspection at Salem, PSE&G identified significant weaknesses in the site Erosion / Corrosion (E/C) Program. E&PB subsequently implemented substantial programmatic improvements. The current program meets the industry standards and appears effective to monitor long term E/C issue '

Summary Hope Creek was provided with improving engineering and technical support by a competent, experienced and stable corporate engineering organization, and a well staffed and knowledgeable onsite system engineering organization. Noteworthy progress was observed in implementing the MOV program. The modification packages reviewed were of good quality. The training program provided for E&PB staff and system engineering personnel was determined to be excellent. The licensee has implemented an effective procurement program, which utilized a user-friendly computer database system. Both E&PB and system engineering groups have initiated aggressive programs to reduce substantially the engineering backlogs. Weaknesses were identified in the erosion / corrosion program and the implementation of 10 CFR 50.59. Root cause programs were generally effective with some  ;

minor errors note III. Performance Rating: Category 2, Improving III. Board Comments: None l l

II Safety Assessment / Quality Verification III. Analysis ,

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l The previous SALP rated this area as Category 1 and indicated that Hope Creek was a well run, safety conscious facility. The licensee effectively identified problem areas, and ensured prompt and effective corrective actions. The licensee's management of the third refueling i

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outage was a noteworthy strength. The licensee's MOV program and its responses to generic issues we:e noted weaknesses. Personnel errors were noted in all functional areas. Safety review committees and QA groups provided effective and independent oversight of activitie Throughout this period, individual performance was very good. Direct supervision at the site by first and second line supervisors and comprehensive management oversight of station '

activities were strengths. The licensee has been successful in reducing the personnel error mte; however, errors were observed in some functional areas, including one by a contractor which resulted in a manual reactor scram. Another example involved a motor operated valve (MOV) wiring error was not corrected per procedures, and resulted in an unplanned reactor cavity level loss. Troubleshooting by contractor engineering and test personnel failed to properly identify, document and correct the wiring error, and resulted in a drain down of about 50,000 gallons. Licensee follow-up for this event included a thorough root cause investigation and establishment of effective corrective action The licensee's amendment and relief requests were generally of high quality, though occasional lapses in clarity and omission of detali were noted. This was evidenced in the licensee's request for a change to the licensing basis for the emergency diesel generator (EDG) fuel oil storage and day tank minimum level requirement Notwithstanding this specific deficiency, the Station Operations Review Committee (SORC)

l provided consistent and effective review of other significant plant issues, including design j changes, post-scram reviews and reportable events. The licensee's major event review process, the Significant Event Response Team (SERT), effectively performed comprehensive scram and event reviews. Recommendations generated from SERT reviews were promptly l acted upon by management and tracked in the licensee's Action Tracking System. As discussed in the engineering section, the licensee root cause corrective action and 10 CFR 50.59 programs were generally very good, with only minor problems note The On-site and Off-site Safety Review Groups (SRG) and Station Quality Assurance (SQA)

demonstrated effective independent reviews of Hope Creek issues. For example, SRG performed a detailed and effective review of the shutdown risk for the fourth refueling

outage. SQA performed a thorough review of a temporary air compressor tie-in and l identified concerns and recommended effective corrective actions. Both the SRG and SQA provided assistance to all SERT effort The licensee took aggressive action to review its reportable events. Licensee Event Reports were well written and accurat I Hope Creek conducted its fourth refueling outage during the period. Outage preparations !

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were excellent. A number of shutdown risk initiatives were successfully performed. SQA j l was effective during all phases of the outage, performing a large number of performance !

! based surveillance and hold point activities. Overail outage performance was good.

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Hope Creek station management, including the General Manager and department heads, provided effcctive and safety conscious oversight of station activities on a daily basis. This ,

was evidenced in daily meetings with the senior nuclear shift supervision and operating crew l and in management accountability meetings. In addition, the General Manager conducted informative State-of-the-Station meetings. Corporate management was highly visible relative to Hope Creek station activities. Operations personnel exhibited a professional and questioning attitude during the performance of their duties. A review of the Hope Creek turbine generator overspeed protection system was comprehensive and displayed a conservative approach to safet Summary The licensee continues to perform well in this functional area. The licensee's first line supervision management, SORC, and independent third part oversight was very goo Individuals performed well, as evidenced by a reduction in the personnel error rate.

I Excellent independent review and root cause determinations continued to be obsen>ed this period. The licensee's performance in the fourth refueling outage was judged to be excellen III. Performance Rating: Category 1 III. Board Comments: None

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I SITE ACTIVITIES )

I Licensee Activities f

The Hope Creek unit began the SALP period operating at full power. The unit completed a  !

300 day continuous run when PSE&G shut down the unit on March 6,1992, for planned i mid-cycle outag ,

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The unit was restarted on March 17, 1992, and operated at power until May 26,1992, when [

PSE&G initiated a shutdown due to failure of drywell-to-torus vacuum breakers. The unit  !

restarted on May 31,199 l i

The unit operated until September 12, 1992, when PSE&G initiated a shutdown to commence  !

the fourth refueling outage. The unit was restarted from the refueling outage on November j 6,1992. A reactor scram was manually inserted when both reactor recirculation pumps i tripped due to a loss of room ventilation on December 3,1992. The unit was restarted on i December 10, 199 l l

On May 16,1993, the unit automatically scrammed from 60% power en high reactor -;

pressure due to a failed electrohydraulic control relay. The unit was restarted on May 19, 199 l Small power reductions were performed throughout the period to perform maintenance and  ;

testing activities. At the end of the SALP period, the unit was operating at full powe !

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I NRC Inspection Activities Four NRC resident inspectors were assigned to Artificial Island during the assessment )

period. Two of there resident inspectors were rotated with new msidents assigned during the i period. NRC team inspections were conducted in the following areas ,

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• I Emergency Preparedness Inspection conducted on October 27-29,1992, to observe the Artificial Island annual exercis * Electrical Distribution Safety Functional Inspection conducted January 13 - February 14, 199 * Surveillance Test Program Inspection conducted during April 6-21,199 I

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