IR 05000354/1986099
| ML20148M102 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek, 05000000 |
| Issue date: | 03/04/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18093A779 | List: |
| References | |
| 50-354-86-99, NUDOCS 8804050334 | |
| Download: ML20148M102 (63) | |
Text
ENCLOSURE SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-354/86-99 PUBLIC SERVICE ELECTRIC AND GAS COMPANY HOPE CREEK GENERATING STATION ASSESSMENT PERIOD: DECEMBER 1, 1986 - JANUARY 15, 1988 MARCH 4, 1988
_
[BR*i888A Ps88lip ,
SUMMARY . ... .............. 49
'
TABLE 3 - ENFORCEMENT ACTIVITY. . . ... ... ........... 50 TABLE 4 - LICENSEE EVENT REPORTS. . . . . . . . . . . . . . . . . . . 53 TABLE 5 - SUMMARY OF LICENSING ACTIVITIES . . . . . . . . ..... 60
.
I. INTRODUCTION Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect observations and data on a periodic basis and to evaluate licensee performance. The SALP process is supplemental to the normal regulatory processes used to ensure compliance to NRC rules and regulations. It is intended to be sufficiently diagnostic to provide a rational basis for allocat-ing NRC resources and to provide meaningful guidance to licensee management in order to improve the quality and safety of plant operation An NRC SALP Board, composed of the staff members listed in Section B below, met on March 4, 1988 to review the collection of performance observations and data in order to assess the licensee's performance af, the Hope Creek Generating Station. This assessment was conducted in accordance with the guidance in NRC Manual Chapter 0516, "System-atic Assessment of Licensee Performance". A summary of the guidance and evaluation criteria is provided in Section II of this repor This report is the SALP Board's assessment of the licensee's safety performance at the Hope Creek Generating Station for the period December 1, 1986 through January 15, 198 The summary findings and totals reflect a thirteen month assessment perio SALP Board Members Chairman W. F. Kane, Director, Division of Reactor Projects Members E. C. Wenzinger, Sr., Chief, Reactor Projects Branch 2 (DRP) l R. R. Bellamy, Chief, Facilities Radiological Safety and Safeguards j Branch (DRSS) (part time) <
W. V. Johnston, Director, Division of Reactor Safety (part time) l S. J. Collins, Deputy Director, Division of Reactor Projects (DRP) ,
(part time) l J. P. Durr, Chief, Engineering Branch (DRS) (part time)
R. M. Gallo, Chief, Operations Branch (DRS)
P. D. Swetland, Chief, Reactor Projects Section 2B (DRP)
G. W. Rivenbark, Project Manager, PDI-2 (NRR)
R. W. Borchardt, Senior Resident Inspector, Hope Creek (DRP)
,
Other Attendees J. E. Richardson, Acting Deputy Director (DRS) (part time)
D. K. Allsopp, Resident Inspector, Hope Creek (DRP)
M. M. Shanbaky, Chief, Facilities Radiation Protection Section (DRSS) (part time)
W. J. Pasciak, Chief, Effluents Radiation Protection Section (DRSS)
(part time)
R. L. Nimitz, Senior Radiation Specialist (DRSS) (part time)
G. W. Meyer, Project Engineer, Branch 2 (DRP)
<
e
'l
,
I l
l l
l l
__
_
I CRITERIA Licensee performance was assessed in selected functional areas significant to nuclear safety at operating facilitie The following evaluation criteria were used to assess each functional area: Management involvement in assuring qualit . Approach to resolution of technical issues from a safety standpoin . Responsiveness to NRC initiative . Enforcement hi stor . Operational events (including response to, analysis of, and corrective actions for). Staffing (including management). Training effectiveness and qualificatio Based upon the SALP Board assessment, each functional area evaluated is classified inte one of three performance categorie The definitions of these performance categories are:
Category Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety is being achieve !
Category 2. NRC attention should be maintained at normal level Licensee management attention and involvement are evident and are con-cerned with nuclear safety; licensee resources are adequate and reasonably effective so that satisfactory performance with respect to operational safety is being achieve Category 3. Both NRC and licensee attention should be increase Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; iicensee resources appear to be strained or not effectively used so that minimally satisfactory per- l formance with respect to operational safety is being achieve Trend. The SALP Board may determine to include an appraisal of the l performance trend of a functional are Normally, this performance trend will only be used when both a definite trend of performance is discernible to the Board and the Board believes that continuation of the trend will result in a change of performance leve ,. - __-____
. .- -
Improving: Licensee performance was determined to be improving near the close of the assessment period.
Declining: Licensee performance was determined to be declining near the close of the assessment perio <
t y - -- , - . . , - .
- .- - - -- - . _ - - . - . - - . . - . .
l
.
! III. SUMMARY OF RESULTS
' Overall Summary Operation of the Hope Creek facility continues to'be characterized by a conservative and safety conscious attitud During previous years, a solid foundation of programs, procedures,-and qualified personnel had been established and although further improvements are needed in specific areas, the overall program has been effectively implemente !
, As the Hope Creek organization has matured, overall performance has improved.
l Considerable resources have been expended during this and the previous
,
period on plant features and enhancements that demonstrate a commit-ment to operational safety and the radiation protection principles i of As Low as Reasonably Achievable (ALARA). These enhancements include a semi-automatic control rod drive (CRD) removal system, CRD rebuil '
facility improvements, zinc passivation, robotics program, hydrogen addition and a plant painting program. A similar level of commitment is evident in the emergency preparedness, training, and security area ,
'
' Licensed operator performance remains a strength. While non-licensed operator performance is generally adequate, improvements are needed *
-
in the area of attention to detail to prevent additional control of plant equipment problems. Management attention is needed to assure
,
adequate shift manning in the future without the need for excessive ,
J overtim The radiation protection and chemistry program are effective and well coordinated. The coordination between radiation protection and all '
other departments has resulted in the incorporation of good ALARA principles on a daily basis. Excellent high radiation area and con-taminated area controls are in place. Areas in need of improvement i j include audits and the review of radiological incident '
)
'
The maintenance and surveillance programs utilize high quality procedures and are well controlled. Staffing levels are adequate and the continued .
,
reduction in the reliance upon contractors throughout the plant is a
,
'
positive trend. An increased attention to detail is necessary to prevent missed surveillance tests and component operability and procedure compliance problem Station management, quality assurance, supervision, and the onsite !
safety review group all contribute toward promoting quality on a daily .
basis. Each maintains a high level of visibility in the plan QA
'
<
and OSR have been aggressive in implementing new iritiatives.
A strong management team and a positive worker attitude have placed ,
Hope Creek on a generally positive performance trend. However, recurring problems with procedural compliance and attention to detail require
,
'
,
i prompt and effective corrective action. The first refueling outage, v
, senior management changes, and the Engineering Department reorganization !
will provide significant challenges during the next assessment perio '
)
,
- .___ - - - - - - _
__ _ _ _ ,__ , _ __
_ _ _ _ _ . _ , , ._, _. _ - _ , , _ _ , _ .
_
6 Background Licensee Activities The licensee entered the evaluation period with the plant in cold shutdown. On December 4, 1986, the reactor was taken critical for continuation of the power ascension test program, and on December 6 the load reject scram test was complete The reactor was taken critical on December 10, 1986, and the turbine generator synchronized to the grid on December 1 The Hope Creek facility officially entered commercial opera-tions on December 20, 1986. The unit remained at full power until February 11, 1987, when the licensee commenced a reactor shutdown and declared an unusual event due to a drywell unidentified leak rate in excess of the 5.0 gpm technical specification limit. A drywell inspection found that the leak was coming from a recirculation pump discharge valve. The crack was located in the heat affected zone of the drain line to valve body weld and had been vibration induce The licensee completed repairs and the reactor was taken critical and brought to full power on February 1 On February 24, 1987, the plant inadvertently scrammed from 100P. power during the conduct of an I&C surveillance test of the main turbine and feed pump turbine high water level trip circuitr An I&C technician personnel error caused a main turbine trip on a high water level signal which in turn caused the reactor scra The reactor was taken critical on February 28 and the generator
, synchronized to the grid on March 1. Two minutes after synch-ronization, an empty oil tanker transiting the Delaware River collided with and damaged a tower supporting the 500 KV Keeney transmission line to Hope Creek. The Keeney line snapped and two isolation breakers in the Hope Creek switchyard opened isolating the line. To maintain the grid stability, Hope Creek and both Salem units were required to be operated at a reduced electric output. The Hope Creek unit continued to operate at the maximum allowable power for these condition .
. . . _ .
On April 6, 1987, Steven Miltenberger was appointed to the position of Vice President - Nuclear Operations and Corbin McNeill promoted to Senior Vice President - Nuclear.
On April 29, 1987, the licensee shifted guard force contractors from YCH to Wackenhut.
On May 18, 1987, Stanley LaBruna relieved Roger Salvesen as the Hope Creek General Manager.
On July 30, 1987, the reactor automatically scrammed due to a reactor vessel low water level condition. The low water level condition was caused by a temporary loss of power to the feed-water control logic normally energized by a miscellaneous instrumentation power supply. The loss of power occurred wnen an equipment operator made an error while switching power supplies to the inverter in preparing for preventative maintenance on the inverter.
The reactor was taken critical on July 31, 1987.
On August 16, 1987, the licensee declared and terminated an unusual event for a reactor scram with HPCI injection. The trip occurred when operators were attempting to return a reactor feedpump turbine (RFPT) to service after corrective maintenance and inadvertently blew a RFPT rupture disc. After the disc blew out, condenser vacuum quickly dropped and tripped the two operating RFPTs. Reactor vessel level decreased until the scram occurred at level 3. The licensee took the reactor critical on August 17 and synchronized with the grid the same day.
The unit remained at essentially full power until August 29, when the reactor scrammed during performance of a weekly surveillance test on the main turbine combined intermediate valves (CIVs). While cycling the No. 5 CIV, a pressure transient in the electro-hydraulic control (EHC) system resulted in a turbine control valve fast closure and a main
- top valve closure which initiated the scram signal. The reactor was taken critical later the same day.
On September 18, 1987, the reactor was manually scrammed from approximately 20*; power and a 20 day surveillance test outage was commence In addition to surveillance tests, other outage work included recirculation system instrument line repairs and safety relief valve acoustic monitor accelerometer replacemen l j
l l
On October 10, 1987, the reactor was taken critical marking the end of the surveillance testing outage. The retest for replacement of the acoustic monitors included performing safety relief valve (SRV) lift tests at approximately 750 psig. Eight SRVs were cycled without incident, however the
"J" SRV stuck open during testing. After it was determined that the valve could not be shut, the reactor was -anually scram.med. The plant was placed in cold shutdown and the defective SRV was replaced. The reactor was taken critical on October 12, 198 On October 13, 1987, an explosion and fire occurred in a main transformer which resulted in a main turbine generator tri Because the reactor was operating at 20% power, no reactor scram occurred nor were any ESF systems actuated. The licensee's fire department responded and the automatic water deluge system initiated. No personnel injuries occurred as a result of the incident. The licensee shut down the reactor during the main transformer replacement and entered cold shut-down. Following the 13-day transformer replacement outage, the reactor was taken critical on October 26, 198 December 8, 1987, the rea: tor scrammed from 100% power. The scram was caused by a reactor protection system (RPS) channel ,
B 1/2 scram signal generated by surveillance testing combined with an RPS channel A 1/2 scram signal caused by a spurious spike of main steam line (MSL) radiation monitor. The reactor was taken critical on December 9, 1987 and the unit remained at full power until the end of this assessment period.
2. Inspection Activities Two NRC resident inspectors were assigned to the site throughout the assessment period. During this thirteen month assessment period, 3357 hours0.0389 days <br />0.933 hours <br />0.00555 weeks <br />0.00128 months <br /> of direct inspection were performed, which '
equate to 2955 hours0.0342 days <br />0.821 hours <br />0.00489 weeks <br />0.00112 months <br /> on an annual basi Tabulations of inspection activities and associated enforcement actions are contained in Tables 1, 2 and 3, .The percentage of total inspection time devoted to a functional area, tabulated in Table 2, is included at the heading of each area analyzed in Section I This assessment report also discusses "Training and Qualifi- '
cation Effectiveness" and "Assurance of Quality" as separate functional areas. Although these topics are assessed in the other functional areas, through their use as evaluation criteria, a synopsis of these two areas is provided. Quality assurance
__
effectiveness has been assessed on a day-to-day basis by resident inspectors and as an integral aspect of specialist inspections. Although quality work is the responsibility of every employee, one of the management tools to measure this effectiveress is reliance on quality assurance inspections and audits. Other major factors that influence quality, such as involvement of first-line supervision, safety committees, and worker attitudes, are discussed in each are Due to limited inspection activities in the fi e protection area, it is not included as a separate functional area in this report.
Inspection activity that was performed in the area of fire protection and housekeeping is included in the Plant Operations functional are ,
10 Facility Performance Analysis Summary Functional Category Category _Recent Area Last Period This Period Trend (11/1/85-11/30/86) (12/1/86-1/15/88) Plant Operations 2 2 Radiological Controls and Chemistry 2 2 Improving Maintenance and Outage Management 1 1 Surveillance 2 2
, Emergency Preparedness 1 1 Security and Safeguards 1 1 Engineering Support No Rating 2 Licensing A:tivitie: 1 2 Assurance of Quality 2 2 Improving Training and Qualification Effectiveness 2 1
. - -- .-
_ _ _ _ _ _ _
11 Unplanned Shutdowns, Scrams, and Forced Outages Date & Power Level Description Cause Functional Area 11/87 - 100% Controlled shut- Component Engineering down/ forced failure / (Construction)
outage; crack design on 3/4 inch inadequacy recirculation system pipe due to vibration induced fatigue failure 2/24/87 - 100% Automatic scram Personnel Surve ance caused by a error / attention (16C)
spurious high water to detail level main turbine trip signal generated during surveillance testing 7/30/87 - 100% Automatic scram; Personnel Operations incorrect operation error, non of an inverter l' censed operator /
at ention to detail 8/16/87 - 85% Automatic scram; Component Operations Reactor feedpump failure /
turbine diaphragm personnel rupture resulted error; operator in loss of feed, lack of procedure compliance contri-buted to diaphragm failure 8/29/87 - 85% Automatic scram; Component ------
Turbine control transient valve fast (exact cause closure during unknown); no surveillance recurrence testing 10/10/87 - 10% Manual scram; Component ------
Safety relief failure /
valve stuck open random during startup test 10/13/87 - 20% Controlled shut- Component ------
down; Main trans- failure /
former fire cause unknown
- -
12 Unplanned Shutdowns, Scrams, and Forced Outages (Cont.)
Date & Powa- Level Description Cause Functional Area 12/8/87 - 100% Automatic scram; Component ------
Spurious main failure /
steani line random radiation trip combined with a 1/2 scram due to surveillance testing Note: The root cause in this Table is the opinion of the SALP Board based on the inspector (s) description of the event; and may, in certain ,
instances, differ from the LE ,
I
!
l
!
1
_ _ -
__
I Performance Analysis Plant Operations (39%,1325 hours0.0153 days <br />0.368 hours <br />0.00219 weeks <br />5.041625e-4 months <br />) Analysis Plant operations was rated as category 2 during the previous assessment perio It was concluded that the proper perspective en safety had been established throughout the plant staff and procedure Control room operator performance was recognized as a noteworthy strength. Areas of weakness identified included an excessive number of control room overhead annunciators in alarm, inconsistency in the maintenance of control room logs, occasional breakdowns in communications between departments, and a need to improve administrative efficienc The licensee has taken steps to address eech of these weaknesses and as discussed in the following assessment, significant improvements have resulte Plant operations have continued to be conducted in a conserva-tive and safety conscious manner. A high level of management attention is evident on a daily basis and the performance of control room operators, in particular, remain a noteworthy strengt All aspect: c' plant crerations are well centrolled and coordinate The station's general manager and all department heads receive a briefing of plant conditions and problems each morning from the nuclear senior shif t supervisnr (NSSS). This is followed by a meeting of all work group supervisors and the NSSS to discuss planned work activities and possible conflict Finally, a daily management meeting establishes priorities and a 7 day general schedule. All work activities are scheduled by the planning department based upon the priorities established
- by management and input from the work group supervisor This system has proven to be effective in ensuring good inter- *
department communication and an effective approach to resolving problems. The NSSS exercises final authorization for all plant activities in order to ensure required system operability is not adversely affected. To obtain a more direct operation's perspective in the recent surveillance test outage, the opera-tions engineer functioned as the outage manager and the NSSS was utilized as the outage shift manage Strong management attention to resolving deficiencies identi-fied during the startup testing program was observed during the assessment period. This is evidenced by the very few (10)
results deficiencies remaining open at the conclusion of the startup progra This is in sharp contrast with the large number of outstanding items at the conclusion of the preopera-tional phase. The overall closeout process was well documented
.
._ _
-. -
I l
l
,
l and plans and responsibilities for resolving the few remaining outstanding items were well formulated and technically soun Licensed operator plant awareness, attention to detail and a professional control room atmosphere have all resulted in there being no control room operator induced reactor scrams or significant transient In fact, these same attributes contributed toward the operators' ability to minimize the severity of equipment induced transients such as a failure of feed system minimum flow valve control and severe feed pump turbine oscillation It is possible that both of these transients would have resulted in reactor scrams had the operator responses not been timely and correct. One instance of a failure to fully complete an abnormal proce-dure was noted during this assessment perio There have been several incidents which indicate lapses in attention to detail by licensed operators. These inclade an inadvertent lifting of a safety relief valve by an operator and two ccasions (once extending through shift turnover) when unauthorized running equipment was not detected in a timely manner. The operators failed to recognize an alarm on a new radiation monitoring system for 43 hours4.976852e-4 days <br />0.0119 hours <br />7.109788e-5 weeks <br />1.63615e-5 months <br /> which resulted in a violation of technical specifications. The safety significance of these examples were minor but point out a need to emphasize attention to detai The parformance of non-licensed equipment operators, while generally very good, has resulted in one reactor scram and a number of equipment availability problems. An equipment operator's personnel error in the transferring of power supplies to an instrument inverter resulted in the loss of feedwater control and a reactor scram. In addition to this isolated event are the personnel errors which resulted in mispositioned valves and equipment switches. Systems adversely affected by these errors included an emergency diesel generator air start compressor, High Pressure Cooling Injection System (HPCI) room coolers, and portions of the Automatic Depressuri-z: tion System logic. Operations' improper system restoration af ter maintenance on the reactor water cleanup (RWCU) pumps, resulted in a RWCU isolation and a subsequent failure of the pump mechanical seal. A number of spills occurred this period which indicate the need for operations personnel to exhibit additional vigilance in reviewing valve line-ups to preclude radiological incident For example, drain lines were left open on a reactor water clean-up pump resulting in blowdown of airborne radioactivity in the reactor building and limited intakes of radioactive material by personnel. Also, the wrong reactor water clean-up heat exchanger was drained resulting in l
.- _ _
the introduction of water into the work are An enforcement conference was held on October 19, 1987 to discuss the licensee's corrective actions relating to their control of plant equipment alignment problems. Corrective actions initiated included completion of the inst ument intermediate valve numbering and locking progrr- ; ditica4a:
of station aids on critical plant equipment, and e eaticn of an inc'ient and trip reduction task tea Sige. . cant effort was also made to improve individuals' alertness and need for attention to detail. Based upon recent performance, these corrective actions have been effectiv The operations department currently has an ample number of both licensed and non licensed operators to meet staffing requirements and man a 5 shift rotation with a moderate use of overtime. However, based upon projected normal attrition rates and the limited number of people in the license training program, the area of operator staffing will require strong management attention in the near future. The control room is consistently maintained in a professional manner with very good access and noise control. Noise contral is especially aided by the plant page system design which prevents routine pages from
'
being heard in the control room and by the addition of carpeting which has reduced background noise levels. The control room environment is also aided by the use of a work control group that processes all work orders, surveillance tests, and blocking permits outside of the control room with the exception of final dpprOVals. A number of licensed operators have been permanently transferred to other departments such as technical and planning while 2 others were on temporary assignment to training and emergency preparednes These assignments have been effective in providing an ope'ational awareness throughout the plant organizatio :
The station operations review commiitee (50RC) and the onsite safety review (OSR) group has done a noteworthy job in the review of plant significant events, safety evaluations, and system inspection Their recommendations are generally well thought out and technically correc During this assessment period, OSR conducted a Safety System Functional Review which ,
! was similar to an NRC Safety System Functional Inspection '
(SSFI). Future reviews of this type are planr.ed by the 4 license The licensee has made a number of administrative improvements, including implementation of an equipment malfunction identifi-cation system (EMIS) that eliminates duplicate work orders and provides an accurate tracking systea. These enhancements combined with a more moderate activity level have reduced the t
-- -
-
.
_
-
c --
administrative back logs noted in the previous SALP. The quality and consistency of control room logs has also improve Little or no progress was made during the first half of the assessment period toward reducing the number of control room overhead annunciators in alarm. However since June 1987, the number of alarms was reduced from approximately 45 to 20 (out of a total population of 454). Continuation of this effort is nece s sa ry .
Housekeeping, while generally adequate, has at times left room for improvement. Occasionally, improperly erected or stored scaffolding, evidence of eating and smoking in the radiological controlled area, and unsecured gas bottles can be found in the plant. At times, there appears to be a lack of aggressive monitoring of fire door operability anc fire extinguisher operability checks. Once identified, these discrepancie" are quickly correcte In conclusion, Hope Creek continues to display a conservative and safety conscious attitude toward all aspects of operation Licensed operator performance continues to be very good with the exception of limited number of isolated error:. Non-licensed operator performance while generally adequate has more frequently shown the need for improvement in the area of attention to detail and overall plant knowledg RC and the safety review groups continue to be effectiv . Conclusion Rating: 2 Trend: None 3. Board Recommendations Licensee Evaluate future licensed operator manning requirements to ensure adequate staffing levels are maintaine NRC None l l
i I
i
.-. . r Chemistry and Radiological Controls (20*4, 598 Hours)
' . Analysis Performance in the area of Radiological Controls and Chemistry was evaluated as Category 2 the previous assessment perio Weaknesses were identified in the areas of supervisory over-sight of program implementation, training and qualification of personnel, post accident sampling and water chemistry control. The licensee took timely action to correct these weaknesse Radiation Protection The licensee is maintaining and implementing an effective, well coordinated Radiation Protection Program. The licensee filled previously vacant positions with qualified personne The organization and staffing level is adequate to support routine and outage operations. Well qualified contractor personnel were obtained to augment the staff during the surveillance outage. Communications and working relationships with other station departn.ents (e.g. operations) is good. The licensee actively seeks out and implements appropriate lessons learned from the industr The Radiation Protection Program program is described by well defined well written procedures. Procedure quality is very goo A particularly strong area is the program for access to temporary '
.
and unusually Sigh radiation areas. Access to each area is
controlled by special procedures. An effort is currently underway to standardize the procedure program such that Salcm i
and Hope Cruk will have common procedures. This will allow for i a large pool of qualified staff with the capability of working ,
at both site l l
The radiation protection personnel training program is well described and implemented. Some technician training records were fragmented ann not easily retrievable resulting in super-visor difficulties in assuring that personnel were qualified for i
a given tas The licensee took immediats corrective action for this matter. Properly trained and qualified personnel were overseeing ongoing wor The general employee training program ;
is INPO certified. The licensee making good progress towards ;
INPO accrediting the Radiation Protection Personnel Training '
Progra ,
$
,
The external exposure control program i> well defined and with some mincr exceptions effectively implemented. These minor exceptions involved several instances of personnel not reading and signing revised RWPs and personnel not posting RWPs at work locations. These were quickly corrected by the licensee. Posting, barricading and locking of radiological controlled areas was effective. Radiation surveys to support pre planning and on-going work were comprehensive. With the exception of the minor weaknesses discussed above, the overall external control program is stron The licensee maintains and implements a generally effective internal exposure control program. Engineering controls a e effectively used to maintain airborne radioactivity levels well below those requiring respiratory protectio The licensee has established and is implementing a defined ALARA Program. Overall performance in maintaining occupational exposure to as low as reasonably achievable is good. New initiatives (e.g. Zinc passivation, and .:or. trol rod drive removal equipment enhancements) to reduce occupational exposure over the life of the plant are being implemente Plant and corporate management maintains an active interest in ensuring radiolcgical work activities are conducted in a manner to minimize occupational exposure. However, some areas for a"=mamant ara the ALARA on=le nr~ ram and the program for ,
performing ALARA re. views of work in progress, to ensure it is '
conducted in accordance with initial ALARA plans. Some goals were not challenging and the criteria for reviewing work in progress was not well define The licensee has initiated corrective acticqs to improve performance in these areas. In spite of these weakresses, the overall program is effectiv The station exposure total for 1987 is 129 person-rem (as of December 15, 1987). This exposure compare: favorably with other similar vintage plants when one consicers the work load and self-initiated work to reduce exposure over the life of the plan Observations last assessment period identified some weaknesses in the Radiation Protection QA Audit Program, the QC Surve'.llance Program and the Corporate Radiological Controls Assessment Program The audits, surveillances, and assessments were principally paper, not performance oriented and of marginal quality. The licensee took aggressive corrective action to improve the quality of ,
audits, surveillances, and assessments. One area for additional '
enhancement was 1dentified involving the Radiological Occurence i
Report System. The System did not provide for effective oversight and trending of radiological occurrences. The licensee is currently :
modifying the System to provide for real-time computer tracking and trending of occurrences. The licensee has been very responsive to NRC identified weaknesses in this area. All weaknesses iden-tified are being correcte .
The licensee corrective actions on previously identified NUREG 0737 post accident sampling and analysis weaknesses were found to be technically sound and timely. Licensee verification of i post accident effluent monitor calibration was commendabl Effluent Monitoring and Control The licensee has implemented a sound program for effluent monitoring and control, although several continuing problems similar to those identified during the previous period were note The most significant of these problems involved inoperable effluent con +rol equip 3ent, procedural problems relating to liquid scins411ation counting, and inadequate followup of RETS/00CM change Good response to identified concerns occurred once licensee attention was focused in this are The licensee improved administrative controls of oper-ability, provided status boards to assure alternate sampling and provided additional training for responsible individual These corrective actions reduced the nm ser of event reports caused by inoperable effluent monitors as the assessment period progresse Radioactive Waste Shipping The preparation, packaging and shipping program for solid waste was generally effectiv Early in the assessment period problems were noted caused by ineffective interface between the solid radwaste groups at Salem and Hope Cree Although NRC reviews during the previous assessment period had clearly directed licensee attention to the need for effective interface and communication, delineation of roles and responsibilities, and establishment of technical data transfers, these remained vaguely defined between the two stations resulting in failure to meet radwaste generator and shipping documentation requirements. Although the licensee established an interface document to clearly define the roles, responsibilities and technical data communication between the stations, this action followed NRC enforcement i action raising a concern for effective preventive actions in response to earlier NRC identified problem '
. Radiological and Non-radiological Chemistry A special review of the chemistry department (radiological and ,
non-radiological areas) was conducted early in the assessment i period in response to an allegation of the use of unqualified
! personnel in chemistry operations. The inspection found the
,
staff to meet or exceed required qualifications. Technician l training and qualification programs were acceptable, complete
- and met requirements. One violation involving failure to follow an administrative procedure was identified but corrected prior to the inspector leaving the site.
,
/
!
l
, - _ . - . _ .
_
Late in the assessment period a routine inspection was done of the licensee's radiological chemistry program. The inspection found that the licensee was implementing an effective radio-activity measurements progra Licensee and NRC measurearnts of split radioactivity samples were in agreemen Procedures and staffing were adequate. The licensee was piacing less reliance on ccat-actors as the staff became more experience Substantial improvements were made in this area from the last assessment perio Routine review of the non-radiological chemical measurements program early in the period found the program to be unreliable due to failure to implement a measurement control program, use of uncalibrated pipets, use of one point instrLment calibrations and single stock solutions for both calibration 3nd contro Although disagreements with NRC non-radiological itandards were low, many of the agreements were due to larger than customary uncertainties in the licensee's measurements. The l!censee stated during the inspection that they would respond to the problems identifie ,
In summary, the licensee is implementing an effective radiation protection program. ALARA planning to reduce exposure was particularly strong as evidenced by numerous ALARA initrative Radiation protection personnel working relationships with other statien departments is of high quality a-d enteworthy. How-ever, additional improvement in the quality of audits appears warranted. The licensee provided adequate control of plant chemistry, liquid and gaseous effluents and solid radwaste during the assessment period. Lapses in management control of
,
technical change, intra-site communications and process and laboratory measurements were noted indicating the need for programmatic improvements that had not been completed during the preoperational and startup periods of plant eneration Improvements were noted in these problem ; .s toward the end of the SALP perio . Cojelusion Rat ng: 2 -
Trene: Improving A Board Recommendations Licensee None NRC None
.
-~
C. Maintenance and Outage Management (9%, 262 Hours) Analysis The maintenance area was evaluated as category 1 in the previous SALP. Although based upon a limited amount of review, the previous SALP concluded that a good foundation of procedures and programs had been established, and effective corrective actions were taken for earlier procedure compliance and oper-ability determination problem Due to the limited scope of outage activities conducted during this period, an assessment of outage management is included in this functional area. Outages will be discussed in a separate functional area in future SALP report Although not fully challenged during this assessment period, the maintenance department appears to be adequately staffed with experienced personnel. The reliance upon contractors in the instrument and controls (I&C) area has been reduced significantly. A job classificaticn change has resulted in combining the electrical maintenance and I&C groups to form a controls group. It is anticipated that this reorganization will improve maintenance department accountability and responsiveness. There are approximately 46 personnel in the niechanical maintenance groups, all of whom are pSE&G employee Fif ty-five of the 70 control group perscnnel are permanent PSE&G employee The maintenance departa. ant has been very responsive to plant problems and in respond 1n; to the needs of the operating staff. The number of outstanding safety related high priority work orders has been kept low (normally less than 10).
The scheduling and status of all corrective and preventative main-tenance, and surveillance test; is coordinated by the managed maintenance information systc-m (MMIS). Although some difficulty was experienced in making the transition to MMIS, this system appears to be an ef fective planning and scheduling tool. MMIS is an on-line computer based program that integrates the master i equipment list, equipment history, recurring task scheduling, !
real time job status and parts :nventor l During this assessment period a 20 day planned outage was conducte Although the major focus of this wtage was ;
J surveillance testing, a num b r of corrective maintenance activities were also completed. The implementation of an .
outage management team proved to be effective in controlling and tracking the progress of outage activities. This team consisted of an outage manager (operations engineer) who had overall responsibility for outage activities, a shift manager
. -
'
i 22 ,
(senior shift supervisor) who provided outage management on a shift basis, department coordinators, area coordinators,-and shift schedulers. To improve the outage process, the station utilized the operations en.f ineer and shif t supervisor to obtain a more direct operations perspective. One significant mainte-nance activity was the repair and modification to a number of
. recirculation system small line pipe cracks. Excelle-t coordination between the maintenance, radiation protection, and system engineering organizations enabled this job to be completed in a timely and effective manner. This repair was accomplished utilizing a special procedure which incorporated the use of freeze plugs and specially made mechanical plug This innovative repair method resulted in a significant reduction in man-rem exposur Especially noteworthy was the planning and preparation which included the use of a full scale mock-up and video taped trial repair to validate and enhance the repair procedure. The actual repair effort was also video taped for ALARA considerations and future trainin Throughout the assessment period a number of maintenance activities were observed, including minor vsive repairs, MOVATS testing, service water pipe replacement, reactor water cleanup pump seal replacement and numerous preventative maintenance activitie These activities were Gund to be generally well 1 controlled and utilized well writte e procedure One example of bypassing supervisor hold points <as identifird, however this is considered an isolated case.
, The licensee has implemented an aggre tsive preventative maintenance program which includes both safety related and balance of plant equipment. ~he prog-am utiU zes predictive 3 :echniques such as vibration ind oil enalysis as well as '
standard maintenance metnods. A plar ed system outage '
schedule is used for accomplishing pr sventative and correc-tive maintenance activit %t as well as surveillance test During this SALP period there were 5 .aintenance related LERs in which 3 involved personnel errors. No plant trips were i caused by maintenance activities. A r n'ew of maintenance LERs did not reveal any programmatic r e t raining deficiencie The planning organization has done an 4': ective job in planning and coordinating daily and outage activities based upon manage-ment priorities. A forced outage schedule is established and
,
l
,
continuously maintained, enabling all departments to know the
, majority of their work load as soon as the outage begins. With
- the exception of the main transformer outage, which took 12 days, the unit averaged less than 2 days per forced outage, i
-, ._ .
!
In summary, the maintenance program is adequately staf fed [
with well trained and experienced personnel. Maintenance ,
activities were well controlled and received an appropriate level of supervisory attentio The maintenance, planning [
and outage organizations were effective durin0 planned and
~
unplanned outage . Conclusion
,
Rating: 1 Trend: None 3. Board Recommendations !
Licensee None E Maintain Normal Inspection Activity
8
,
,
l
'
I
!
j l l l
_ _
D. Surveillance (10% 288 Hours) Analysis The surveillance functional area was evaluated as a category 2 during the previous assessment period. Procedures and administrative controls were found to be adequate, however improvements were needed to reduce the number of missed non-routine surveillance tests and surveillance related reportable event Surveillance tests performed by the licensee are the responsibility of several departments, depending on the sur- i veillance. The operations, maintencnce, chemistry, and site protection departments each participate in surveillance testing with additional involvement from the planning department. This r section addresses surveillance tests performed without reference ,
to the particular department involve Su veillance activities '
were routinely witnessed by NRC inspectors. The surveillance ,
program is a well defined, computer based system that utilizes '
technically adequate procedures. The use cf a computerized system for scheduling all periodic surveillance tests allows for efficient and generally effective management oversight of the approximately 5000 surveillance tests performed on an annual basi Of the 57 reportable events during this assessment period, 17 are associated with the performance of surveillance test Eight of these events were due to personnel errors, one of
! which resulted in a reactor scram. The personnel errors consisted mostly of equipment accessibility and test lead
'
placement errors. One incomplete and one missed surveillance test were identified during the conduct of approximately 2100 operations department surveillance test '
- During this asseasment period a transition was made from '
, the inspection order (IO) system to a managed maintenance :
information system (KMIS) for the scheduling and tracking '
of surveillance tests. This transition contributed to 2
!
surveillance tests not being properly scheduled and
, subsequently not perforrred in the required time interval.
i The licensee promptly identified these oversights and the RMIS appears to be an effective management tool, i Although improved over the previous year's performance, I i further improvement app 1ars to be needed in recognizing the need for, and accomplishing situational type tests and sample
. analyse This is especially true in the radiation protection
- and chemistry arets where five failures to have required systems i i operable, compensatory samples analy
- ed, or surveillance tests
]
completed were identified.
'
!
a
_ _ _ _ . - _ -
_ _ _ _
_ _ _ . _ _
._
On occasion, breakdowns in the level of attention to detail and strict procedural compliance have been identified. On two separate occasions, unauthorized temporary modifications were installed in the plant due to inattention to the approved jumper control program. Also a filtration recirculation and-
'
ventilation system fan was made inoperable due to improper
- erte-:t i-- 3ad drefeyote 4 dnra-de-+ 14 y>p "e-4'ie:**en following surveillance testin Throughout this assessment period the station technicians have recommended refinements to surveillance procedures. When these refinements are incorporated the procedure quality has been improved. However, at times the staff's lack of timeliness in incorporating the technician's recommended changes has led to complacency toward strict procedural compliance. For instance, a situation was identified where technicians ignored a logic tester indication that they reasonably believed was giving a faulty indication, and instead used a portable meter to verify contact status. While their actions where technically correct, no effort was made to correct or annotate the procedure. The number of recommended changes tnd tFe lack of a prioritization system for addressing them contributed to the lack of timelines Once identified, the licensee promptly resolved the technical .
! concerns relating to the logic tester and also addressed the procedural issue.
The personnel performing surveillance tests are technically knowledgeable and deliberate in their actions. Based on inspector discussions with technicians and observation of activities; the training program, including on the job training, has been effectiv Supervisory and site management involvement is evident on a day to day basis, as is excellent coordination between the control room operators and the technicians. The
,
practice of limiting work to a specific logic channel on any -
given day has aided in more eft'ective scheduling of surveillance tests and in preventing inadvertent actuations or transient ,
In summary, the licensee has implemented an effective ,
surveillance program that utilizes procedures of high qualit l j
'
Personnel are well qualified and conscientious, however the importance of attention to detail needs to receive continued emphasis to reduce the number of personnel and missed surveil-lance errcrs.
l l
)
_ _ . . _ ___
,
1 Conclusion Rating: 2 Trend: None Board Recommendations ,
,
Licensee None i
_NRC None b
I h
a
!
j
,
i
Y
,
,
a'I
!
I
'
i a
p l
-. -- ,_ _ _ , _ - . _ . _ _ , _ . _ _ _ _ . _ . -- . - , _ _
4 E. Emergency Preparedness (13%, 377 Hours) Analysis There is a consolidatsd Emergency Plan for the Artificial Island complex, including the Salem and Hope Creek facilitie Consequently, the assessment of emergency preparedness is a comprehensive evaluation of both facilities' emergency response capabilitie During the previous assessment period, the licensee was rated i
,
Category 1 in the area of Emergency Preparedness at Hope Creek and Salem. This assessment was based on strong management commitment to the hardware and programmatic requirements of this functional area, and the performance of the licensee's staff during exercises at both Salem and Hope Cree During this assessment period there were three announced inspections of Emergency Preparedness at Artificial Islan One inspection was the observation of a Hope Creek full participation exercise. There was no exercise at Sale In addition, four actual unusual events were declared at Hope Creek and one at Sale Implementing procedures were correctly followed for all but one of the unusual event On July 30, 1987, Hope Creek made a one hour notification i to the NRC per 50.72(b) instead of declaring an unusual j even The licensee detected the error within sixteen minutes and then declared the unusual event. The Hope Creek Event Classification Guide has been modified to avoid a recurrence of this misclassificatio Observations made during the routine safety inspections at Hope Creek and dalem indicate regulatory requirements were fully satisfied. A drill is conducted at both Salem and Hope Creek on a weekly basi The high degree of training and experience is reflected in the excellent performance noted during their annual exercise. Emergency response
,
r training is current: 1,450 personnel are qualified for one or more emergency response positions - 600 for each site and 250 for both sites. Operators received eight hours of emergency preparedness training including response to one fast breaking scenario "run" on the Hope Creek simulator.
- Health Physicists demonstrated the ability to correctly use the four available dose projection systems. A dosimetry comparison was made involving three of the licensee's systems, systems for both states and the NRC. The results were within acceptable limit '
,
i I
l l
l
_ _
A resiew of communications and call-in test data also showed satisfactory result Independent audits are curren Executives and senior managers interface with State government officials. Safety parameter display systems (SPOS) are in place and functional at Hope Creek and Salem, a Post Inplementation Appraisal for Salem has been conducted. No significant deficiencies have been identified to dat PSE&G has put considerable effort into working with off-site authorities to complete final review and approval of off-site plans. Results of the annual public Alert and Notification system (sirens, etc.) test specified by FEMA were submitted during December 103 FEMA has not completed the review. The Delaware Emergenc Plan was given contingent, favorable reviews and comments per 44 CFR 350.12, pending acceptance by FEMA of the siren test dat New Jersey has submitted its plan for similar review. The licensee has developed a computerized data base for special needs residents (hearing and mobility impaired)
living within the ten mile Emergency Planning Zon Additional licensee strengths in this area are noted as '
follows: (1) Contracts are in place to provide for plume aerial surveillance; (2) ten diverse, redundant communications systems are in place; and (3) a full-time, 37 person site fire department is available for emergency support, with half of
"~ qualifiad at E ~ caa-" vedical Technician Tha staff is divided into shif ts and work around-the-cloc In summary, a strong management commitment to emergency preparedness is evident by the hardware and comprehensive training program achievetents in this area, and by licensee cooperation with outside agencies toward approval of State Emergency Plans. Licensee effectiveness is demonstrated by the consistent high quality performance of the staff during emergency exercise . Conclusion Rating: 1 Trend: None 3. Board Recommendations Licensee: None NRC: None
__
F. Security and Safeguards (5*;,158 Hours) Analysis There is a consolidated Security Plan for the Artificial Island complex, including the Salem and Hope Creek facilitie !
>
Consequently, the assessment of security and safeguarcs is a combined evaluation of both facilities' protection capabilitie During the previous assessment periods, both the Salem and Hope Creek security programs were assessed as Category 1. These ratings were influenced by a well planned transition for the integration of the two security programs; a major upgrade of security systems to include the installation of an integrated security computer system and associated hardware, computerized access control devices, state-of-the-art assessment aids and new search equipment; and a strong security management staf Management's attention to, and involvement in, assuring the implementation of an effective and quality security program remained evident during this assessment period. The licensee was very effective in maintaining good support for the security program frcm other functional groups at both stations. Frequent organizational interfaces and good working relationships were
apparent from the professional attitude of all employees toward the security program, as well as the attention given by the maintenance groups to prevention and correction of problems with security systems and equipmen ,
As further evidence of management's interest in an effective i
and quality program, it was noted that all security shift supervisors, who provide around-the-clock oversight of the contract security force, attended a special 30-day training course on regulatory and security program requirements and objectives. In addition, security management continued to participate in nuclear industry groups engaged in security related matter The licensee also continued to implement a self-initiated appraisal program carried out by security managerent and supervisory personnel. Adverse findings were promptly resolved and factored into the training and qualification program in an effort to prevent their recurrence. ,The appraisal program is in addition to the NRC's required annual program audit that is ccoducted by experienced quality assurance personnel. Tha last annual audit was i comprehensive in both scope and depth. Audit findings were distributed to appropriate management personnel for review, and corrective actions for deficiencies were prompt and effective. This also demonstrates the licensee's desire
-
to implement an effective and quality security progra l l
- - _ ___
a During this assessment period, the licensee engaged a new '
contractor to provide the administration, supervision, and training of the security forc The new contractor was able to retain most of the incumbent members of the force. The change in contractors went smoothly as a result of good
,
planning on the part of the license Staf fing of the security organization appears adequate, as evidenced by a controlled use of overtim The installation and maintenance of state-of-the-art systems and equipment has significantly reduced the use of compensatory posts for systems and equipment failures and, thus, reduced the need for extensive overtime. Both the licensee's proprietary supervisors and the contractor's supervisors are well trained and experienced, and exhibit a conservative and positive attitude toward securit Security force personnel are also well-trained and exhibit high morale and professionalism in carrying out their dutie The licensee's efforts to establish and maintain such a professional image for the security force is another indicator of the licen-see's desire to implement an effective and quality security progra It is also reflected by the generally excellent state i of cleanliness in all security facilitie The training and requalification program is well developed and carried out by a training administrator and two full-time
instructors. In addition to initial and requalification training, on-the-job performance evaluations are conducted which test the proficiency of individuals on general and specific security program requirements. The on-the-job performance evaluations have provided management the ability
, to review and enhance the performance and job knowledge of security personnel and to correct deficiencies as they are
- detected, This is another initiative that is indicative of ,
I the licensee's desire to implement an effective progra During the assessment period, there were two events involving security guards who were discovered being unattentive to dutie One (at Hope Creek) was discovered by the NRC Resident Inspector c and the licensee was cited for the violation. The other (at !
Salem) security guard was discovered by the on duty security shift superviso ,
i
'
In each case, the licensee took prnmpt and effective corrective action. The associated security event reports submitted by the licensee pursuant to 10 CFR 73.71c were complete and well
'
written, and required no further information from the license These events appear to be isolated cases of poor performance and do not indicate a programmatic problem. They occurred
'
during the latter part of the assessment period and until that time, the licensee's overall good enforcement record during
!
this period is attributed to management's involvement in the
1
- - - - - . - . .-,
7 - , , - - - - - - - - - -
. . .-
'
security program, the continuing self-appraisal program, com-prehensive annual audits and the security ttaining progra During this assessment period, the licensee submitted three
"temporary Changes" to the Plans. These changes included compensatory measures to be implemented during construction of a building addition inside the r-:'c:*.4 '-c? >d 90-ia:
the special supervisory training program. The changes were clear and fully described the issue Prior to submittal of these changes, the licensee discussed them with Region I safeguards personnel at a licensee-requested meeting on site ;
and at the Region I office. The licensee also provided its response to the August 4, 1986 Miscellaneous Amendments to 10 CFR 73.55 codified by the NRC, and submitted the consoli-dations of the Salem and Hope Creek Security Plans, Safeguards Contingency Plans, and Training and Qualification Plans into the Artificial Island Security Plan, Safeguards Contingency Plan, and Training and Qualification Plan. The Artificial Island Plans were generally of high quality; however, several discrepancies were identified during the NRC review. A management meeting was held with the licensee during which the licensee was able to fully explain each discrepancy and provide acceptable resolutions. The licensee subsequently submitted amendments to the plans that resolved the discrepancie Considering the magnitude of the effort involved in
_ consolidating the Salem and Hope Creek plans into one, the discrepancies were considered by the NRC to be minor oversights that did not materially effect the quality of the Artificial Island Plans. The safeguards licensing group is adequately staffed with experienced personnel who are knowledgeable of NRC security program cbjectives and committed to maintaining an effective and high quality security program. Management involvement, advance planning, and the expenditure of necessary capital and personnel resources was noteworthy and indicative of high level management suppor In summary, the licensee continued to implement a highly effective and quality security program for Artificial Islan Management interest in the program remained evident through its continued support and attention to program needs.
.
I
$
- .- - .. . . . - - . . . - ... - . -. -. - --- - -. .-.. - - - . - . - . . . . . . . - . - -
.
.
I
,
1 Conclusion 1 Rating: 1
)
- 1 i
Trend: None i I
3 .
i l Board Recommendations
.
J j
,
Licensee: None
i NRC: None !
! I i ,
I
!
l i
.i a
i
! !
I f
{ !
.
)
l
.
i i
I
! !
.
I b
, .
J
$
l, j
,
i i
t i
i s
i i i
,
(__ . . . . . _ _ _ . - . _ , _ - - . . . . . _ . _ , . _ _ _ _ _ _ ..-
~. . - .
.
G. Engineering Support (4i;,106 Hours) Analysis The functional area of outages was evaluated during the previous SALP period, however due to a lack of normal outage ,
'
activities no rating was issue The board recommended that the licensee meet with NRC to present the results of the engineering department task force and plans for addressing the findings. This meeting was conducted on April 24, 198 The major weakness noted during the previous SALP period involved a need for improvement in the engineering departmen The licensee established a task force to review performance measurement systems, and evaluate methods to simplify management processes. The task force, including an outside management consultant, concluded that although the above areas needed to be addressed, a ce prehensive department reorganization was also needed. A major portion vi this assessment period was consumed by defining job descriptions, conducting interviews and making personnel selections in order to establish a project matrix organization. Since the new organization was implemented during December 1987, there has not been sufficient basis on which to i
'
make a performance evaluation. Significant changes to the engineering department and its interaction with the station ,
include:
-
Implementation of an Engineering Work Request System, *
-
Use of a Project Management System,
-
Revision of the Design Change Process, !
-
Establishment of a Project Matrix Organization; and, !
-
More direct station input in prioritizing engineering wor The engineering department's performance remained inconsistent throughout this assessment period. Long delay tirnes in updating instrument calibration data (ICD) cards hampered the station's ability to complete some surveillance tests and instrument calibrations. Failure to meet design change package issuance dates had an adverse affect on outage scheduling. On two occasions DCP work was commenced prior to obtaining SORC approval. Engineering's failure to update composite drawings directly contributed to a turbine auxiliary cooling system ,
isolation during corrective maintenance. Engineering was slow to respond to QA concerns relating to updating of the master equipment list and lacked aggressiveness in resolving numerous cooling tower blowdown sample pump failures. Offsite engineering ard the system engineers responded promptly and .
effectively to make repairs to recirculation system strail line '
pipe crack ;
-
J
.. _ __ _ _ - - . .-
i The station system engineers have continued to perform a >
valuable and effective function. They have frequently involved themselves with plant problems early enough to ensure a well
- thought out and technically correct approach is taken. During l this assessment period all system engineers completed a 5 month
, SRO level training pregram. This comprehensive training program x. , p. e <<e:t he 4 n~..,4- e,"
] ca p eer has an understanding
of the integrated plant and recognizes operational rest 4ctions,
^
i In additio.1 to individual system responsibilities, the system engineers and the technical department staff play a prominent i role in the incident report program, LER development, station commitment tracking program, annunciator reduction efforts, .
.
temporary modification tracking, and act as station qualified '
i reviewer A clearer definition of the system engineers' role is neede An occasional sense of frustration and confusion has been created among the system engineers due to the frequently ;
changing priorities and inconsistent expectations of other ,
'
departments. The absence of a clear job description and steady priorities may have contributed to 2 problems with main steam line (MSL) radiation monitors discovered this assessment perio ;
On one occasion, the trip setpoints were found to be set non- ~
i conservatively high beyond the technical specification limit '
- At another time a delay in changing a MSL radiation monitor t trip setp W t may hve
- re-tr S ted t^ n faadvertent scram.
3 Operations had identified the need to change the setpoint
- weeks before the scram but delays were experienced in writing
! and approving the DCP.
] In summary, station engineering support has been adequate,
however the role of system engineers needs to be more clearly
) defined. The performance of the new engineering department
,
organization could not be evaluated during this assessment -
period and will be closely monitored during the next assessmant perio !
2. Conclusig P
i Rating: 2 Trend: None
! ,
'
! 3. Board Recommendations
'
Licensee Clarify the system engineers' function and responsibilities.
] (
[iRC None l
.
!
!
!
- - . -- - . - . - .-
__ _ . _ . . . _ _ _ _
i
'
H. Licensing Activities
- Analysis
,
During the previous SALP period, the licensee was rated as Category The previous SALP input noted that the licensee's corporate maniaa-ea+ H exhibitec ++ m ia"eive eat =ad l control in Hope Creek licensing activities and that most of the licensee's submittals have exhibited careful forethought, thorough cor. sideration of the proposed action and technically
,
sound response l I At the beginning of the current SALP period, the licensing backlog for Hope Creek was eleven (11) active licensing action !
items representing a mixture of licensee and staff initiative Twenty one (21) actions, almost all of which were licensee '
initiatives, were added and nineteen actions (19) were closed during the period, leaving a backlog of thirteen (13) actions at the end of SALP perio Management involvement in assurance of quality in licensing activities as reflected by the timeliness of submittals, adequacy of technical approach and completeness of informa-tion in submittals requesting NRC licensing action have varied t throughout the SALP period. The licensee demonstrated good involvement by management in the issue of the license condition i requiring that four additional SPDS parameters be completed
'
prior to restart following the first refueling outag The licensee evaluated the SPDS and determined that it would be better to replace the complete SPDS with a new one that includes the four additional parameters and provides additional flexibility than to add the four parameters to the existing system. The licensee requested a timely nieeting to discuss the issue, then made a timely request for a schedular extension in the license condition to allow it to properly install and test the new SPD NRC approved the request. While most requests for licensing action have been timely, the licensee's untimely requests for an ;
j exemption from the requirements of Appendix J, i.e., testing
requirements, and code relief and Technical Specification changes j for testing requirements on certain valves, for a Technical Specification change related to the source range monitor count rate requirements, and for approval of a revised inservice
,
j inspection program and its associated code relief requests l i indicate that more attention should have been given to schedular planning for these submittals.
) With regard to the resolution of technical issues, a number of 1 the licensee's requests for licensing action e.g., the initial
,
request for an emergency technical specification change related a
l
,
!
i
__
- _ - . . . . . - _
- '
,
to the safety relief valve acoustic monitors, its initial proposal with respect to use of the standby liquid control system in meeting ATWS rule requirements, its initial request to revise suppression chamber water level technical specification, its request for exemption from the local leak rate testing requirements of Appendix J, and its request to revise the high '
reer!e-a -^elant injectiaa rystem's tee" icd treti'ie'tica response time requirements, were deficient in either the proposed technical resolution or in the information supporting L
'
and justifying the proposal.
! With regard to NRC initiatives, the licensee's responses to the staff's requests for additional information have generally been timely with respect to the need for completing the review i
of the related activity and have been technically responsive ;
and adequat During the current SALP period, the NRC initiated its Safety Issues Management System (SIMS) to improve its tracking of implementation schedules associated with safety issues. The [
'
licensee was responsive to the SIMS initiative and provided a couple of SIMS updates, most recently on November 3, 198 !
! As evidenced by their generally prompt and technically accurate i
responses to the oral and written questions discussed with the .
NRC, we conclude that the licensee maintains a qualified and
t well trained staf l
,
In summary, the licensee continues to maintain a knowledgeable f licensing staff and has been responsive to the NRC's initiative '
However, the quality of the licensee's submittals requesting licensing actions has varied throughout the SALP period, The
'
, licensee showed evidence of inadequate prior planning for its
- submittals for several requests in that insufficient time was
- allowed for the NRC to complete its reviews. It als; did not l conduct an adequate review of several submittels in that these i
submittals did not provide an adequate technical approach or did I
not provide sufficient information to support the technical approach.
i Conclusten !
i
- Rating
- 2 1
Trend: None ,
l !
i l J
,
J
. _ . .._ . _ _ _ . .. . - ._ . .. . , ,. . .
i
!
37 c i !
< l
'
3. Board Recommendations ,
'
! Licensee Provide additional effort to assure the quality of all j submittals; and submit requests requiring NRC action earlier with respect to the required action date, i t
NDC Naae i
,
.; I
>
!
j
.
4 i
., !
4 ;
I r >
i
,
I
-
L a
i a
?
I 4 {
I u
f
!
I
!
i j
i 3 l i
i i
l l
.
l
i
!
I. Training and Qualification Effectiveness ' Analysis t A high license examination pass rate and the good performance of .
both licensed and non-licensed personnel throughout the plant !
y m 4 + g m.<gn m < . errnti.fe training program during the previous SALP perio The licensee was noted to have dedicated ,
significant resources toward training facilities. A category 2 rating was assigned to this are '
The various aspects of this functional area have been considered and discussed as an integral part of other functional areas and the respective inspection hours have been included in each on Consequently, this discussion is a synopsis of the assessments related to training conducted in other areas. Training effec-tiveness has been measured primarily by the observed performance of licensee personnel and, to a lesser degree, as a review of program adequacy. No license exams were administered during this assessment perio The licensee operates and maintains well equipped training facilities which provide training for all of the nuclear departments, including operations, I&C technicians, electri-cians, mechanics, chemists, health physics technicians, nhinists, and welder The u na Cred training program is modeled after the Salem program which has been INPO ar. credited in all ten training area The licensee's corporate and station management involvement in training is good. Training review .
groups evaluate training on a regular basis and provide feedback [
to the training program. The training departtrent is staffed with experienced personnel. In the non-licensed training area a '
permanent staff of approximately 50 instructors and supervisors administer the training program to over 700 non-licensed operators, craft, technical, and supervisory personnel. Laboratory facilities are excellent and provide hands on training on such things as rebuilding circuit breakers, limitorque valve operators, and motors. During this assessment period, improve-ments to the nuclear department laboratories included additions :
of a Cyoerex inverter, fire alarm systems, and cable tray systems ,
for training purposes. The temporary assignment of licensed !
operators to the training department is a positive feedback '
mechanis A comprehensive six month training program for all station system engineers was conducted during this SALP perio The course of study included basic engineering principles, in-depth system reviews, integrated plant operations, technical specifi-cations, and simulator experience. This broad bac Wround has i increased the operational awareness of the system engineer I l
- _ _ - - ._- .
I
Twenty four of the 57 reportable events during thi; assessment period were judged to be caused by personnel errors. Whereas this ratio could indicate a weakness in some aspects of the training program no significant common cause could be identified. Many of these personnel errors were caused by
,
lapses of attentiveness or attention to detail rather than a lack of specim krMe5 For example, 7 reportable events involved a missed or overdue surveillance test, or a break-down in communications resulting in a missed action statemen Five others involved manipulating an incorrect switch or componen This type of attention to detail needs to be
, stressed by supervision on a daily basis in addition to periodic reinforcement through formal training. A lack of knowledge may have contributed to four unrelated reportable events, however no programmatic training program deficiencies could be identifie Strengths noted throughout this SALP report including licensed operator performance, security, maintenance, and health physics are indicative of the effectiveness of the training progra Emergency preparedness and response training was specifically evaluated and found to be effective during this assessment period. This was based upon a routine program inspection and on the observation of a full participation emergency exercise conducted on September 9, 198 The training department has coordinated with the station in
, taking advantage of training opportunities within the plan An example was the repair work conducted on the small diameter instrument line off of the recirculation piping in the drywel Both the mock-up training and the actual job were video taped for real time and future training efforts,
In summary, the performance of licensed and non-licensed 4 personnel demonstrates that an effective training program ,
has been implemented. Personnel errors during this assessment [
period resulted from inattention to detail rather than specific i
- training deficiencie Enhancements continue to be made at !
i the training facility in an attemnt to increase direct simu-l lation of installed in-plant equipment. Formal and on the
, job training efforts need to continue placing a strong emphasis on individual attention to detail and procedural
- compliance.
!
2. Conclusion j
,
)
- Rating
- 1 l
'
J
>
Trend: None
,
'
l i
. _ __
_ __ _ . - _ - _ _ _ _ _ _ _ . . _ _ . _ ._ .
3. Board Recommendations Licensee: Resolve personnel error /'nattention to detail problem I N_RC : None
,
j l
.
- _ _ .. . . _ _ ._
.
b i
- - 41 l
.
i j J. Assurance of Quality i Analysis
'
This functional area was rated as category 2 during the previous !
SALP period. A generally effective program for ensuring quality -
had been established, plant procedures were of high quality, and f the role of the individual worker was properly emphasized. The board also concluded that increased management attention was warranted in the radiological controls area.
3 The primary purpose of this functional area is to assess the effectiveness of the licensee's program for identifying and correcting problem This functional area is not an assessment of the quality assurance department alone, but includes all management control, verification, and oversight activities which l
affect or assure the quality of plant activities, structu es, systems, and components. It also assesses the attitude and
"
'
performance of plant staff personne ;
Various aspects of this area were routinely examined as part of the resident inspector and region based specialist inspec- ;
- tion program The licensee has maintained a high enphasis on ,
'
i quality throughout all levels of the organization. Although l there are occasional breakdowns and areas to be strengthened, l good workar attitude and perfor~ance indicate that the basic i
program is sound. Specific inspections found the procurement I system, record storage, and corrective actions system to be I
adequate.
1 Plant procedures were originally written based upon the optrating experience evaluation program's review of over l
3000 industry documents from the NRC, INPO, and vendor Commitments and requirements are easily recognizable in the i body of a procedure by its specific closing document (CD)
number in the margin. This system ensures that the reference l document is reviewed prior to changing an applicable procedure l ste Technicians and operators frequently initiate procedure ,
,
changes to improve the quality and accuracy of these procedures, i
) however delays in incorporating some of these changes created '
- frustration and complacency in the instrument and controls area I i late in the assessment period. Increased familiarity with >
procedures may also be introducing loss of formality and lack of i attention to detail as evidenced by the bypassing of independent '
! verification requirements and improper return to service of a Filtration Recirculation and Ventilation System (FRVS) fan. The
'
licensee has implemented a Human Performance Evaluation system to investigate the causes for various personnel errors and
- recommend corrective actions, i j
j .
,
.
U
_.. . _ . _ _ __ _ _ _ .
-
.
l 42 ,
'
The incident report program remains an effective tool for identifying and resolving plant problems, however improvement i is needed in the timeliness of developing, implementing, and documenting corrective actions. Over 200 incident reports
,
were generated in 1987 and some with little safety significance ,
4 consumed much more staff time than was warranted and delayed the -
s processing of high priority report The cc--4-aa* tracking system (CTS) which tracks the status of NRC open items, LERs,
- commitments, and inner- company commitments has been highly
. effective.
'
Management involvement with all aspects of plant operations is
evident on a daily basi Department managers and first line supervisors frequently tour the plant to ascess work activities,
,
conditions, and housekeeping. The use of tailgate meetings in each department helps foster intra department communicatio The relocation of manager offices to the department work space will further encourage internal communications. Management status and planning meetings, shift briefings, and supervisor planning meetings each promote intra departmen; communication which reduce future scheduling conflict ,
i The site quality assurance (QA) organizatien and the station have open lines of communication and interact on a daily
'
basts. QA is frequently requested to perform inspections on
'
1 arat notice in order to provide an independent assessrent of f certain issues and QA personnel are occasionally requested to 1 accomplish specific tasks. For example, QA was assigned responsibility for coordinating and facilitating the comple-t tion of backlogged design change documentation packages. The :
QA organization should ensu e that these types of assignments
do not interfere with its independent assessment rol The assessments conducted by QA go far beyond programmatic reviews ,
j and have included observation of technical specification sur- t j veillance tests, equipment failure ana1lSe., fire suppression !
system revirw*, and instrument calibration data accuracy investigati- ..
The engineering department's reorganization process appears j to have had an adverse affect on performance. Engineering i response to plant requests was inconsistant and was slow '
, to resolve QA findings relating to master equipment list
'
and vendor manual update .
- l l
The nnsite safety review (05R) group has done a noteworthy job
- in the review of plant significant events, cafety avaluations,
, and system inspection Their recommendatins: are generally l well though ou' and technically correct.
.O i
i
-m __ - -, . . ,.- _
During this assessment period, OSR conducted a Safety System Functional Review which was similar to an NRC Safety System Functional Inspection (SSFI). This review was of high quality and future reviews of this type are planne A professional and conscientious attitude is displayed by all members of the plant staff. Free and open communication is encouraged with all outside groups, including the NRC. However, the shifting priorities and inconsistent interaction with other departments has left some system engineers frustrated with their role and function. The transfer of personnel between departments and the temporary assignment of licensed operators to training and emergency planning has aided in improving the overall quality of station performanc In summary, the licensee has implemented the procedures, pro-grams, and work environment to promote high quality. Continued management attention is warranted in the areas of engineering department performance, timeliness of incident report followup and defining the role of system engineers.
2. Conclusion Rating: 2 Trerd: Improving 3. Board Recommendations Licensee None NRC None
V. Supporting Data and Summaries Investigations, Petitions and Allegations Two allegations were received during the assessment period relating to the following areas:
-
Security computer access controls during the night shif t
-
Adequacy of plant security during regular security drills Both of the allegations were determined to be unsubstantiate Escalated Enforcement Actions None Management Conferences April 24, 1987 - Management meeting to discuss the results of the engineering department review of engineering performance. An overview of the new organization was provide July 29, 1987 - Meeting to discuss the site specific radiological control progra October 19, 1987 - Enforcement Conference to discuss the cause and corrective actions relating to control of plant equipment problem Liccasee Event Reports (LERs) Report Quality Utilizing the basic evaluation methodology presented in NUREG-1022, Supplement 2, the overall quality of licensee event reports (LERs) is very good. A strong point for Hope Creek's LERs continues to be the in-depth discussion of the mode, mechanism, and effect of failed components. There has been improvement in the identification of manufacturer and model number of failed components. There has also been 1 improvement in the safety assessment discussions, but this is an area which would benefit frcm added attention. While reviewing 57 LERs this assessment period, clarification was needed on three occasions by the staf l l
. _ _ - - - _ - _
45 Causal Analysis Four LERs (354/87-01, 87-11, 87-22, and 88-01) concerned radiation protection and chemistry personnel errors which resulted in four technical specification violation The first three LERs which occurred between January and May, related to the failure to complete scheduled surveillar,ce tests or required action statements. These oversights were caused by a lack of' attention to detai The fourth LER concerned a discrepancy between technical specification requirements and the design of inu ' led equipment. Four LERs (354/87-09, 87-23, 87-34, anc _/-40) described opera-l tions department personnel vrors which resulted in a I
technical specifica+.f on violation or an engineered safety f feature actuation. Three of-these four events were caused by non-licensed eauipment operators. Corrective actior, taken in this area after the October 19, 1987 Enforcement i
Conference may have largely resolved the problems as evidenced by no recurrence for a major portion of the.SALP perio Three LERs (354/87-03, 87-20, and 87-28) reported i
'
reactor water cleanup (RWCV) inadvertent isolations. RWCU logic and double valve isolation design changes and instal-lation of improved interior panel lighting are scheduled i
for the refueling cutage in February, 1988.
)
During this assesment period,15 licensee identified violations of technical specifications were noted with only 4 being cite Although the station's effort to identify violations has been-succcssful, additional management attention is needed to reduce the number of violations committed. Of the 24 LERs caused by personnel error, the major weakness was in the area of attention to detail (6) and procedural compliance. Formal and on the job training must ccasistently reinforce attention to detail and procedural compliance standard ,
l The number of LERs has declined from 89 last SALP period to 57 during this current assessment period. Although specific conclusions are complicated by the fact that the previou SALP period included. initial plant startup and the power ascension program, the nurber of LERs has been significantly reduce _ -_-
TABLE 1 HOPE CREEK INSPECTION REPOPT ACTIVITIES REPORT NUMBER INSPECTION DATES INSPECTOR HOURS AREAS INSPECTED 86-56 RESIDENT 151 ROUTINE RESIDENT INSPECTION 11/18/86 - 12/31/86 86-57 SPECIALIST 52 INSPECTION IN RESPONSE T0 fcEGION I 12/01/86 - 12/04/86 ALLEGATION RI-86-A-0130, CHEMISTRY 86-58 SPECIALIST 68 ROUTINE INSPECTION OF THE OVERALL POWER 12/01/86 - 12/12/86 ASCENSION PROGRAM.
86-59 SPECIALIST 20 INSPECTION OF EXTERNAL EXPOSURE CONTROLS 12/03/86 - 12/05/86 INCLUDING HIGH RADIATION AREA CONTROLS INTERNAL EXPOSURE CONTROLS ALARA & 00SIMETRY TESTING.
86-60 SPECIALIST 6 REVIEW OF THE LICENSEE'S PROGRAM FOR 12/30/86 - 12/30/86 CONDUCTING SECURITY DRILLS 87-01 RESIDENT 162 ROUTINE RESIDENT INSPECTION 01/01/87 - 02/09/87 87-02 SPECIALIST 83 ROUTINE INSPECTION OF LICENSEE'S SOLID 01/12/87 - 01/16/87 RADI0 ACTIVE WASTE PROGRAM 87-03 SPECIALIST 132 ROUTINE, ANN 0UNCED INSPECTION OF THE 02/09/87 - 02/13/87 LICENSEE'S EMERGENCY PREPAREDNESS PROGRAM i 87-04 SPECIALISI 48 ROUTINE INSPECTION OF THE NONRADI0 LOGICAL 01/27/87 - 01/30/87 CHEMISTr.( PROGRAM 87-05 RESIDENT 146 00? TINE RESIDENT INSPECTION 02/10/87 - 03/09/87 87-06 SPECIALIST 23 ROUTINE INSPECTION OF POWER ASCENSION I 02/24/87 - 02/26/87 TEST PROGRAM FOLLOWING COMPLETION OF TESTING ACTIVITIES.
87-07 SPECIALIST 40 ROUTINE INSPECTION OF LICENSEE'S GASEOUS 03/0Q/87 - 03/13/87 AND LIQUID RADWASTE CONTROL PROGRAM.
87-08 RESIDENT 229 ROUTINE RESIDENT INSPECTION 03/10/87 - 04/13/87
- ~.
)
i l
!
)
i l
TABLE 1 (cont.) l l
INSPECTION REPORT ACTIVITIES 87-09 SPECIALIST 41 INSPECTION OF NON LICENSED STAFF 04/06/87 - 06/16/87 TRAINING 87-10 SPECIALIST 90 INSPECTION OF POST-ACCILENT MONITORING 03/16/87 - 03/20/87 SYSTEM TO ASSESS CONFORMAi'CE WITH REGULATORY GUIDE 1.97 87-11 RESIDENT 168 ROUTINE RESIDENT INSPECTION 04/14/87 - 05/11/87 87-12 SPECIALIST 7 EFFECTIVENESS OF QUALITY CONTROL AND 04/15/87 - 04/20/87 QUALITY ASSURANCE IN PROCUREMENT &
PREVENTATIVE HAINTENANCE FOR STORED ITEMS 87-13 SPECIALIST 24 INSPECTION OF LICENSING ACTIVITIES IN 05/04/87 - 05/06/87 AREAS OF SURVEILLANCE TE tTING, PROCEDURES AND RECORD RESIDENT 182 ROUTINE RESIDENT INSPECTION 05/1?/87 - 06/08/87 87-15 SPECIALIST 31 PHYSICAL SECURITY INSPECTION 05/18/87 - 05/21/87 87-16 RESIDENT 212 ROUTINE RESIDENT INSPECTION 6/09/87 - 7/13/87 87-17 RESIDENT 189 ROUTINE RESIDENT INSPECTION 07/14/87 - 08/17/87 87-18 SPECIALIST 2 MEETING BETWEEN PSE&G AND NRC REGION I TO 07/16/87 - 07/16/87 OISCUSS CONSOLIDATED EMERGENCY PLAD 87-19 SPECIALIST 49 RADIATION PROTECTION INSPECTION 07/24/87 - 08/14/87 87-20 SPECIALIST 189 INSPECTION AND OBSERVATION OF LICENSEE'S 09/08/87 - 09/10/87 FULL-PARTICIPATION, EMERGENCY EXERCISE ON SEPTEMBEd 9, 1987 87-21 SPECIALIST 38 INSPECTION OF LICENSEE PROGRAM FOR l 08/17/87 - 08/21/f7 RESOLVING QA ACTION REQUESTS i 87-22 RESIDENT 196 ROUTINE RESIDENT INSPECTION 08/18/87 - 09/28/87 l
TABLE 1 (Cont.)
INSPECTION REPORT ACTIVITIES 87-23 RESIDENT 250 ROUTINE RESIDENT INSPECTION 10/27/87 - 11/30/87 S7-24 RESI7ENT 166 ROUTINE RESIDENT INSPECTION 09/29/87 - 10/26/87 87-25 SPECIALIST 37 INSPECTION OF RADIOLOGICAL CONTROLS 09/21/87 - 09/25/87 DURING THE CUTAGE 87-26 SPECIALIST 40 PROGRAMMATIC REVIEW 0F MAINTENANCE 11/16/87 - 11/20/87 87-27 SPECIALIST 24 ROUTINE RADIOLOGICAL CONTROLS INSPECTION 11/16/87 - 11/20/87 87-28 SPECIALIST 82 INSPECTION OF THE LICENSEE'S 11/16/87 - 11/20/87 PADI0 CHEMICAL MEASUREMENTS PROGRAM 87-29 RESIDENT 180 ROUTINE RESIDENT INSPECTION 12/01/87 - 01/04/88
TABLE _2 HOPE CREEK INSPECTION HOUR SUMMARY AREA HOURS HOURS ANNUALIZE0 PERCENT OPERATIONS 1325 1166 39 RAD PROTECTION 680 598 20 MAINTENANCE /0UTAGES 298 262 9 SURVEILLANCE 327 287 10 EMERGENCY PRE SEC/ SAFEGUARDS 179 158 5 ENGINEERING SUPPORT 120 106 4 TRAINING 0 LICENSING 0 QUALITY ASSURANCE 0 TOTALS: 3357 2055 100
,
- .. - ,
.
TABLE 3 HOPE CREEK ENFORCEMENT SUMMARY Violations versus Functional Area by Severity Level No. of Violations in Each Severity Level AREA 1 2 3 4 5 DEV TOTAL
_ _ __ _ ___ _
OPERATIONS 0 0 0 3 0 1 4 RAD PROTECTION 3 2 5 MAINTENANCE /0UTAGES SURVEILLANCE 3 3 EMERGENCY PRE SEC/ SAFEGUARDS 1 1 ENGINEERING SUPPORT TRAINING .
LICENSING -
ASSURANCE OF QUALIFY TDTALS: 10 2 1 13
1
TABLE 3 Summary of Violations
!"(DCCT.*0N REPORTS REQUIREMENT SEVERITY FUNCTIONAL INSPECTION DATES VIOLATED __ LEVEL __ AREA DESCRIPTION 354/86-57 TECH SPEC 5 RAD-CHEM FAILURE TO FOLLOW 12/01/86 - 12/04/86 PROCEDURE FOR DEVIATION FROM ANSI /ANS 3.1-1981 FOR CHEMISTRY ENGINEER 354/86-59 TECH SPEC 5 RAD-CHEM LICENSEE DID NOT 12/03/86 - 12/05/86 6.11 ADHERE TO PROCEDURES 354/87-01 TECH SPEC 4 SURVEILLANCE FAILURE TO TAKE DLD 01/01/87 - 02/09/87 GRAB SAMPLES 354/87-02 10CFR20.311 4 RAD-CHEM FAILURE TO INCLUDE 01/12/87 - 01/16/87 (b) IRON-59 AND
?!RCONIUM-95 ON MANIFEST 354/87-02 10CFR20.311 4 RAD-CHEM 10CFR20.311(C)
01/12/87 - 01/16/87 (C) IMPROPER CERTIFICATION 354/87-08 TECH SPEC 4 ENGINEERING NON-CONSERVATIVE MSL 03/10/87 - 04/13/87 RAD MONITOR SETTINGS 354/87-14 FSAR, D OPERATIONS CONTROL ROOM COMMON 05/12/87 - 06/08/87 AMEND. 14 H202 HEAT TRACE ALARM 354/87-16 TECH SPEC 4 . OPERATIONS THERMAL OVERLOAD 06/09/87 - 07/13/87 BYPASS NOT INSTALLED 354/87-17 TECH SPEC 4 OPERATIONS RHR PRESSURE 07/14/87 - 08/17/87 TRANSMITTER ,
ISOLATED /HPCI ROOM i COOLER IN0PERABLE 354/87-17 TECH SPEC 4 OPERATIONS ADS AND HPCI ACTION 08/14/87 - 08/17/87 STATEMENTS NOT ENTERED l
- - ,
TABLE 3 (Cont.) ,
354/87-22 TECH SPEC 4 SECURITY / GUARD ATTENTIVENESS 08/18/87 - 09/28/87 SAFEGUARDS 354/87-23 TECH SPEC 4 SURVEILLANCE UNAUTHORIZED 10/27/87 - 11/30/87 TEMPORARY MODIFICATIONS 354/87-29 TECH SPEC 4 SURVEILLANCE INADEQUATE 12/01/87 - 01/04/88 RESTORATION OF FRVS FOLLOWING SURVEILLANCE
-
.
TABLE 4 HOPE CREEK LICENSEE EVENT REPORTS A. LER by Functional Area Nuniber by Cause Codes FUNCTIONAL AREA A B C D E X TOTAL
_ __ _ _ _ _
OPERATIONS 7 7 0 2 ,9 1 26 RAD PROTECTION 4 1 . 6 MAINTENANCE /0UTAGES 3 2 5 SURVEILLANCE 8 6 1 2 17 EMERGENCY PRE SEC/ SAFEGUARDS ENGINEERING SUPPORT 2 2 TRAINING 1 1 LICENSING QUALITY ASSURANCE TOTALS: 24 15 0 6 !! 1 57 LEGEND:
A - PERSONNEL ERROR B - DESIGN, MANUFACTURING, INSTALLATION i C - EXTERNAL l D - PROCEDURE l E - COMPONENT FAILURE X - OTHER i
.
I
1
. .
TABLE 4 (Cont.) LER Synopsis HOPE CREEK LER NUMBER EVENT DATE CAUSE CODE DESCRIPTION 86-091-00 12/05/S6 A INADVERTENT OPENING 0F "P" SAFETY RELIEF VALVE 86-092-00 12/06/86 X UNEXPECTED ACTUATION OF HPCI, RCIC AND CHANNEL D OF THE PRIMARY CONTAINMENT ISOLATION SYSTEM (PCIS)
86-093-00 12/09/85 D SHUTDOWN COOLING ISOLATION DURING INSTRUMENT BACKFILLING 86-094-00 12/10/86 B INADVERTENT ISOLATION OF REACTOR WATER CLEANUP SYSTEM 87-001-00 01/06/87 A INADVERTENT OMISSION OF CONTAINMENT ATMOSPHERE GRAB SAMPLE COLLECTION AND ANALYSIS 87-002-00 01/08/87 A INADVERTENT CONTROL ROOM VENTILATION SYSTEM ISOLATION RESULTING IN CREF ACTUATION 87-003-00 01/12/87 B REACTOR WATER CLEANUP SYSTEM ISOLATION CAUSED BY INADVERTENT GROUNDING OF TEST EQUIPMENT ,
87-004-00 01/13/87 E REACTOR WATER CLEANUP SYSTEM ISOLATION DUE TO SPURIOUS SIGNAL INDUCED BY TEMPERATURE MONITORING 87-005-00 01/23/87 E PRIMARY CONTAINMENT ISOLATION SYSTEM l
ACTUATION DUE TO MOMENTARY .0SS OF i POWER TO RADIATION MONITORING l EQUIPMENT l 87-006-00 01/23/87 A ENGINEERED SAFETY FEATURE ACTUATION CUE TO PERSONNEL ERROR DURING SURVEILLANCE
1
- . ,
TABLE 4 (Cont.)
LER NUMBER EVF.NT DATE CAUSE CODE DESCRIPTION 87-007-00 01/23/87 8 UNANTICIPATED ACTUATION OF HPCI OUTBOARD STEAM SUPPLY VALVE CAUSED BY HIGH TEMPERATURE DIFFERENTIAL - DESIGN ERROR 87-008-00 01/26/87 A INADVERTENT START OF CORE SPRAY PUMP
"B" DUE TO IMPROPER PERFORMANCE OF SURVEILLANCE PROCEDURE 87-009-00 01/27/87 A UNDETECTED INOPERABILITY OF COOLING TOWER BLOWDOWN RMS SAMPLE PUMP RESULTING IN VIOLATION OF T.S. -
PERSONNEL ERROR 87-010-00 01/30/87 B NUCLEAR STEAM SUPPLY SHUT 0FF SYSTEM CHANNEL "A" ISOLATION CAUSED BY GROUNDING TEST EQUIPMENT IN STEAM LEAK DETECTION CABINETS 87-011-00 08/21/86 A DELAYED TESTING OF 4 LICENSED RADIOACTIVE SOUDCES - T.S. VIOLATION DUE TO PERSONNEL ERROR 87-012-00 02/03/87 E REACTOR WATER CLFANUP SYSTEM ISOLATION DUE TO SPURIOUS SIGNAL INDUCED BY TEMPERATURE MONITORING MODULES 87-013-00 02/05/67 E LOSS OF REACICR PROTECTION SYSTEM BUS
"B" DUE TO DE-ENERGIZATION OF MOTOR CONTROL CENTER 87-014-00 02/11/87 E FORCED REACTOR SHUTDOWN DUE TO UNIDENTIFIED LEAKAGE GREATER THAN 5 GPM & SUBSEQUENT MANUAL SCRAM DUE TO RSCS ROD BLOCK WHEN SHUTTING DOWN 87-015-00 02/13/87 8 AUTO-ISOLATION OF THE CONTROL ROOM VENTILATION SYSTEM CAUSED BY SPURIOUS SIGNAL FROM RADIATION MONITORING SYSTEM l
87-016-00 02/18/87 E AUTOMATIC START OF FILTRATION, l RECIRCULATION, AND VENTILATION SYSTEM <
I DUE TO UNKNOWN CAUSES l
!
.- . .
l
56 l
TABLE 4 (Cent.)
LER NUMBER EVENT DATE CAUSE CODE DESCRIPTION 87-017-00 02/24/87 A REACTOR SCRAM DURING PERFORMANCE OF A SURVEILLANCE PROCEDURE ON REACTOR WATER LEVEL INSTRUMENTATION 87-018-00 02/24/87 8 UNANTICIPATED FAILURE OF MSIV TO CLOSE ON SIGNAL - BLOCKED PORT OF SOLEN 0ID VALVE OPERATOR 87-019-00 04/13/87 A T.S. VIOLATION - MAIN STEAM LINE RADIATION MONITORS SET ABOVE ALLOWABLE LIMITS DUE TO ADMINISTRATIVE ERRORS 87-020-00 04/21/87 B ISOLATION OF RWCU WHILE PLACING FILTER /DEMINERALIZER IN "HOLD" MODE-PROBABLE DESIGN DEFICIENCY 87-021-00 05/08/87 B REACTOR PROTECTION SYSTEM (RPS) BUS
"A" INADVERTENTLY DE-ENERGIZED DURING PREPARATION FOR SURVEILLANCE RESULTING IN ESF ACTUATION 87-022-00 05/09/87 A T.S. VIOLATION-COOLING TOWER BLOWDOWN RADIATION MONITORING SYSTEM SAMPLE PUMP OUT OF SERVICE 5 12 HOURS &
REQUIRED GRAB SAMPLES NOT TAKEN 87-023-00 6/05/87 A T.S. VIOLATION - EMERGENCY DIESEL GENERATOR B & C STARTING AIR PRESSURE LOW DUE TO TS INCONSISTENCY 87-024-00 6/08/87 A UNANTICIPATED PRIMARY CONTAINMENT ISOLATION SYSTEM TRIP - ESF ACTUATION
- PERSONNEL ERROR 87-025-00 6/11/87 0 NON-CONSERVATIVE LIQUID EFFLUENT SAMPLING FREQUENCY DUE TO INCONSISTENCY BETWEEN T.S. REQUIREMENTS & PROCEDURAL REOUIREMENTS 87-026-00 6/15/87 A T.S. VIOLATION - MOV THERMAL OVERLOADS INSTALLED WITHOUT BYPASS CAPABILITY DUE TO INADEQUATE TS & DESIGN REVIEWS 87-027-00 6/26/87 E SPURIOUS ISOLATION OF HIGH PRESSURE CO0LANT INJECTION INBOARD STEAM ISCLATION VALVE DUE TO FAILED TEMPERATURE MODULE l
TABLE 4 (Cont.)
LER NUMBER EVENT DATE CAUSE CODE DESCRIPTION 87-028-00 6/29/87 B ISOLATIONS OF RWCU SYSTEM ON HIGH DIFFERENTIAL FLOW DUE TO DESIGN DEFICIENCIES 87-029-00 07/18/87 A T.S. VIOLATION - RHR PUMP DISCHARGE PRESSURE TRANSMITTER INSTRUMENT ROOT VALVE FOUND CLOSED 87-030-00 07/I4/87 B ESF ACTUATION - HIGH PRESSURE COOLANT INJECTION SYSTEM INITIATION WHEN VALVING IN REACTOR VESSEL LEVEL TRANSMITTER 87-031-00 07/14/87 0 UNANTICIPAYED INITIATION OF FRVS DURING INSTRUMENTATION MAINTENANCE / TROUBLESHOOTING -
PROCEDURAL DEFICIENCY 87-032-00 07/29/87 A "B" FILTRATION, RECIRCULATION, AND VENTILATION SYSTEM RECIRCULATION FAN FLOW LESS THAN INDICATED FLOW DUE TO INCORRECT CALIBRATION DATA 87-033-00 07/30/87 E UNANTICIPATED INITIATION OF "E" FRVS RECIRCULATION FAN - MALFUNCTIONING SWITCHES 87-034-00 07/30/87 A REACTOR SCRAM DUE TO INADVERTENT DE-ENERGIZING OF 120 VAC INVERTER 87-035-00 08/04/87 B UNANTICIPATED START OF "B" SLCS PUMP 87-036-00 08/04/87 A LOSS OF CONTROL POWER TO HPCI, RHR &
CORE SPRAY LOGIC CIRCUITS 87-037-00 08/16/87 D REACTOR SCRAM & HIGH PRESSURE COOLANT INJECTION (HPCI) INJECTION 87-038-00 08/18/87 A FAILURE TO PERFORM A REACTOR LEVEL INSTRUMENTATION SURVEILLANCE WITHIN THE REQUIRED PERIOD 87-039-00 08/29/87 B REACTOR SCRAM WHILE PERFORMING TURBINE OVERSPEED OPERABILITY TEST DUE TO PRESSURE TRANSIENT IN TURBINE ELECTR0 HYDRAULIC CONTROL SYSTEM
TABLE 4 (Cont.)
LER NUMBER EVENT DATE CAUSE CODE DESCRIPTION 87-040-00 09/10/87 A RWCU SYSTEM ISOLATIONS (2) FOLLOWING RWCU PUMP MAINTENANCE DUE TO NOT ADHERING TO PROCEDURES 87-041-00 09/10/87 A OVERDUE CHANNEL FUNCTIONAL TEST DUE TO PERSONNEL BEING UNFAMILIAR WITH NEW COMPUTERIZED SCHEDULING SYSTEM 87-042-00 09/20/87 E INVALID LOSS OF COOLANT ACCIDENT SIGNAL ISOLATION WHEN PERFORMING TEST DUE TO LEAKING INSTRUMENT VALVE 87-043-00 09/22/87 B RESIDUAL HEAT REMOVAL SYSTEM ISOLATION WHILE PERFORMING SURVEILLANCE TEST DUE TO INSUFFICIENT WORK SPACE - DESIGN DEFICIENCY 87-044-00 09/25/87 A RESIDUAL HEAT REMOVAL SYSTEM ISOLATION WHILE PERFORMING SURVEILLANCE TEST -
CAUSE UNKNOWN 87-045-00 10/07/87 A PRIMARY CONTAINMENT ISOLATION SYSTEM INITIATION WHEN RESTORING POWER TO LOGIC CABINET DUE TO SPURIOUS LOGIC MODULE INPUTS 87-046-00 10/16/87 0 PRIMARY CONTAINMENT ISOLATION SYSTEM INITIATION WHEN SWAPPING REACTOR PROTECTION SYSTEM BUS POWER DUE TO LACK OF INDICATION - DESIGN DEFICIENCY 87-047-00 10/10/87 E SAFETY / RELIEF VALVE FAILURE TO CLOSE -
SAND BLASTING GRIT IN SOLEN 0ID 87-048-00 11/25/87 0 TRIP 0F "B" AND "D" SAFETY AUXILIARIES COOLING SYSTEM PUMPS AND AUTO START OF
"A" SACS PUMP DUE TO PROCEDURAL &
DESIGN DEFICIENCIES 87-049-00 04/09/87 E PRIMARY CONTAINMENT LEAK RATE DETERMINE 0 IN EXCESS OF ALLOWABLE (LA)
!
DURING LOCAL LEAK RATE TEST DUE TO COMPONENT MALFUNCTION l
l l
l
.
l l
l
59 i TABLE _4_ (Cont.)
LER NUMBER EVENT DATE CAUSE CODE DESCRIPTION 87-050-00 12/04/87 A MISSED SURVEILLANCE OF A MSIV OUiBOARD STEAM SEALING GAS TEST LINE ISOLATION V/LVE 87-051-00 12/08/87 B REACTOR SCRAM CAUSED BY A SPURIOUS SPIKE IN A MAIN STEAM LINE RADIATION MONITOR 87-052-00 12/10/87 8 REACTOR WATER CLEANUP SYSTEM ISOLATION WHEN PRESSURIZING THE "B" FILTER /
DEMINERALIZER DUE TO F/0 INLET DESIGN GEFICIENCY 88-001-00 01/06/88 A MISSED SURVEILLANCE ON LIQUID RA0 WASTE l
,
l l
TABLE 5 SUMMARY OF LICENSING ACTIVITIES A. NRR LICENSEE MEETINGS 5/21/87 Safety Parameter Display System Schedular Extension B. NRR SITE VISITS 5/18-20/87 PM attended Unescorted Access Training Course - and made brief site visi /29/87 PM attended meeting with licensee and Region I personnel to discuss Licensee Radiological Protection Plan. PM also toured plan /9-10/87 PM observed full scale emergency Hope Cieek exercise.
C. COMMISSION BRIEFINGS None D. SCHEDULAR EXTENSIONS GRANTED 11/24/87 License condition regarding SPDS completion schedule amended to extend schedule.
E. RELIEFS GRANTED 6/9/87 Relief from Section XI of ASME code to delay Leak Tests on 27 valves until first refuelin /7/87 Relief from Section XI of ASME code with respect to certain valve and pump testing requirements on an interim basis until review of the revised IST program !
is completed.
F. EXEMPTIONS GRANTED 6/9/87 Exemption from Appendix J requirement to leak test l certain valves - mtil first refueling outag I I
l
.
. . . ..
TABLE 5 (Cont.)
SUMMARY OF LICENSING ACTIVITIES G. LICENSEE AMENDMENTS ISSUED Date Amendment N Title 12/9/86 1 MCPR (Emergency TS)
2/6/87 2 Radioactive Effluent Monitoring Instrumentation 4/7/87 3 Single Loop Operation 6/9/87 4 Local Leak Rate Test 6/17/87 5 SRV Acoustical Monitor (Evergency TS)
7/7/87 6 Secondary Containment Damper Closure Time 7/7/8/ 7 Emergency Bus Undervoltage Trip 8/17/87 8 Steamline High Radiation Setpoint 8/25/87 '
MCPR 9/1/87 10 Revision of TS Section Numbers 11/9/87 11 ATWS TS Changes 11/24/87 12 Emergency Diesel Generator Air Start Receiver 11/24/87 13 SPDS License Condition H. EMERGENCY CHANGES TO TECHNICAL SPECIFICATIONS l
12/9/86 MCPR Revision l l
6/17/87 SRV Acoustical Monitor (Temporary Change)
I. ORDERS ISSUED None 1