IR 05000354/1988099

Final SALP Rept 50-354/88-99 for 880116-890430

ML18094A715
Person / Time
Site:	Salem, Hope Creek
Issue date:	09/25/1989
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18094A713	List: IR 05000272/1988099 IR 05000354/1988099 ML18094A712
References
50-354-88-99-01, 50-354-88-99-1, NUDOCS 8910020203
Download: ML18094A715 (34)

Text

FINAL SALP REPORT U. S.,, NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT NO. 50-354/88-99 PUBLIC SERVICE ELECTRIC AND GAS COMPANY HOPE CREEK GENERATING STATION Enclosure 3 ASSESSMENT PERIOD:

JANUARY 16, 1988 - APRIL 30, 1989

SUMMARY OF RESULTS II I. A Overview Hope Creek programs continued to mature and exhibit a steady improvement in performanc PSE&G demonstrated a conservative, safety conscious approach in all functional areas, and the sound management philosophies, good administrative programs and skillful personnel achieved good result Performance in the operations and radiological control functional areas improved sufficiently t merit Category 1 ratings.. Excellent performance continued in the security are The plant's operating record was goo The operators did not initiate any plant tr~ps and responded correctly and promptly to operational events. The previously identified weaknesses regarding l{censed ~perator staffing and

. housekeeping were effectively ad.dresse The radiological controls program demonstrated good ALARA performance, effective control of work activities, and stron£ radioactive ~ffluent and transportation control PSE&G initiatives to reduce radiation exposure of workers were commendabl Good management support of the radiological controls and chemistry programs was eviden Performance in the emergency preparedness area, an area evaluated for Hope Creek and Salem in a combined manner, decreased to a Category 2 rating based primarilY on the weaknesses identified during the Salem-based full participation exercise and on the inability of the Sa 1 em Techni :al Suµport Cer.iter* to meet habitability requirement Improving trends were noted in the functional areas of maintenance/surveillance, engineering/technical support, and safety assessment/quality verificatio In these areas, the general programmatic approach was determined to be acceptable, meaningful PSE&G initiatives were underway, and inconsistent performance and personnel errors were being addresse The challenge for Hope Creek is to continue to apply r1s1ng standards to the

~stablished programs, to complete the initiatives underway, and to address the isolated personnel errors and equipment failures which have occurred during this assessment perio.

II Facility Performance Analysis Summary Functional Area Plant Operations Radiological Controls Maintenance/Surveillance Emergency Preparedness Security Engin~ering/Technical Support Safety Assessment/

Quality Verification Last Period (12/1/86-1/15/88)

2

. 1/2*

1

2**

Rated as separate functional area This Period Trend (1/16/88-4/30/89)

1

Improving

1

Improving

, 2 Improving

A similar area (Assurance of Quality) was assessed la~t perio Also~

the functional area of Licensing Activities, which ~as assessed as Category 2 during the last period, is currently included in this functional are II Reactor Trips and Unplanned Shutdowns Event Description Power Date Level Root Cause Functional Area While shutdown a reactor trip occurred due to an Intermediate Range Monitor (IRM) spik The spike resulted from electrical interference due to welding near the IRM electrical cabinets.* No control rods move /21/88 0%

Personnel error Maintenance

. While shutdown a reactor trip occurred due to an IRM spike concurrent with a half scram from unrelated surveillance testin The IRM.spike was suspected to have occurred due to.jarring of the support for the IR *electrical cabinet One control rod move /30/88

. 0%

Personnel error Maintenance A manual reactor trip *was initiated because of the loss of all circulating water pumps to the main condenser due to an electronic failure in the multiplexed pump control si~nal /30/88 80%

Component failure NA The reactor tripped automaticall~ o~ low reactor_ vessel level, because one of the two operating reactor feed pumps tripped. A Secondary Condensate Pump (SCP) had tripped when a preventive maintenance tagout removed power from its auxiliary oil pump and inadvertently removed power from the SCP control~.

5/5/88 100%

Personnel error/Design Maintenance The reactor tripped automatically following a turbine trip during functional testing of the turbine thrust bearing wear detecto A mechanical failure in the wear dete~tor linkage caused the turbine tri /26/88 100%

Component failure-NA The reactor tripped automatically on low reactor vessel level when the three reactor feed pumps tripped simultjneously on a false signal of high discharge pressur A failed electronic component had caused the false pressure signa /15/88 100%

Component failure NA

J*

Event Description Power Date Level Root Cause

Functional Area The reactor tripped automatically following a turbine trip caused by arcing in the collector of the main generator excite /1/88 100%

Component failure While shutdown the reactor tripped on an alternate rod insertion signa During instrumentation modifications, the procedure did not specify that a trip signal be reset in a Redundant Reactivity Control System (RRCS)

channel prior to work on another RRCS channe No control rods move /22/89 0%

Procedure inadequacy Maintenance

i I PERFORMANCE ANALYSIS I IV. Operations Analysis

{1486 hours, 37%)

The previous SALP rated Operations as Category That assessment concluded that Hope Creek displayed a conservative and safety conscious attitude toward plant operatio Licensed operator performance was very good with the exception of isolated attention to detail errors related to operational control of equipmen Non-licensed operator performance while generally adequate had more frequently shown the need for improvement i~ the areas of overall plant knowledge and attention to detail related to control of equipment in the f~el *

During this assessment period, PSE&G operated the reactor in a conservative,

• safety conscious manner, and the results were goo There were no reactor trips initiated by operators or to which operators contribute The responses of operators to reactor trips and transients we~~ timely, thorough, w~ll coordinated, and technically correc Prompt actions by operators prevented reattor trips in some instances, e.g., loss of vessel leve~ control in April 198 PSE&G had committed and continued to commit *resources to upgrade plant operations.. Spe~ifically, manpower resources were provided such that each operating shift had thr~e Senior Reactor Operator (SRO) licensed individuals

{bne above technical specification requirements), the Operations manpower budget was increased to enable a pipeline into licensed operator status, an SRO-licensed individual was added to supervise the work control group during regular maintenance hours, and additional Operations support staff was provide Further, the work control area was relocated outside the control room to m1nimize distractions to the control room, and the Operations Department offices were ielocated adjacent to the control room~

Plant operations were well supported by the Training Departmen All five SRO license candidates and three of four Reactor Operator (RO) candidates passed*

the license examinations, a gorid ~erformance. In addition, prior to reactor startups the on duty ROs were given simulator refresher training on reactor startups immediately before taking the shift, if they had not recently restarted the reacto Licensed operators' plant awareness, safety perspective, and professional control room demeanor were consistently eviden Plant operations were well supported by detailed plant procedure Shift turnovers were formal and in-cluded thorough briefings of the relief cre Control room access was strictly controlled, and activities were limited to those directly related to plant operation Continued management support resulted in further reductions in the number of norm~lly energized control room overhead annunciator An operator's thoroughness during testing resulted in the early detection of a control room ventilation system problem resulting from a modificatio The use of overtime

~as properly controlle The performance of ~on-licensed equipment operators in general was good and continued to improve over the previous assessment perio However, during an NRC operator license examination walkthrough, the e~aminer noted minor ~xamples of plant condition discrepancies, which had apparently been overlooked* by non-licensed operator An NRC emergency operating procedure (EOP) inspection determined that the EOPs were technically correct and could be accomplished effectively by using existing equipment, controls, and instrumentation:. The operators were well trained on the EOPs and used the EOPs properly in all ap~licable instance Overall, the EOPs were found to be fully capable of performing their intended purpos'e. *

A high level of management attention to operations was evident on a daily basi An operational *perspective ~f plant problems and work prioritiz~tion was well understood by the station general manager and department managers*,

and was enhanced by the daily morning briefing conducted by the Senior Nuclear Shift Supervisor (the Senior).

This approach proved effective in ensuring good interdepartmental tommunication and in resolving rroblem *

Isolated instances of personnel errors in Operations continu*..-d.. Th~ errors were generally of minimal significance, occurred in different areas, a~d were committed by different peopl Acceptable, approprjate corrective actions were taken for each error, but the incidence of errors remained an area for improvemen Specifically, operational errors included disabling an incorrect valve, overlooking a v~lve 1 s return to service, losing track of inst~lled electrical jumpers, a cleanup system isolation due io deviating from a procedure, failing to fully close a valve that resulted in an 8,000 gallon spill ont_o the torus room floor, and erroneously placing two battery chargers irito service on one batter The frequency of personnel errors has continued to decrease compared to earlier assessment period PSE&G has developed an approach to these issues and continued to evaluate the previbus corrective actions and potential additional corrective action Housekeeping improved, and efforts were underway to c~mpl~te painting of the remainder of the plan Further, the storage and availability of ladders was

~pgraded, and platforms for better access to equipment were noticeably improve The fire protection program was well staffed, well equipped, and well organize Fire protection personnel were knowledgeable, which demonstrated an effective training progra The fire brigade was staffed by fire protection personnel, which minimized the reliance on operators to respond to emergencie Appropriate operator involvement in emergencies was provide The preventive maintenance and survei~lances of fire protection equipment were effective, although more aggressive monitoring of fire door operability was neede Once identified, all discrepancies were promptly correcte Overall, management properly iupported the fire protection are In summary,

~he Hope Creek operating staff continued to dis~lay a conservative and safety conscious approach to plant operation and had an e-xcellent o~e~ating record with no operationally caused reactor trip The operators were ~killful and knowledge~ble and properly responded to transient PSE&G improved support of operations with increased staffing in both onshift and support role The need for reduction in personnel errors represented the primary area for improvemen *

IV. IV. I IV. '

Performance Rating Category 1 Recommendations None Radiological Controls ( 452 hours0.00523 days <br />0.126 hours <br />7.473545e-4 weeks <br />1.71986e-4 months <br />, 11%)

Analysis The previous SALP

~ated Radiological Controls.as Category 2 (improving).

The radiological progr_ams were effective and well coordinate Areas for improvement were audits, review o-f radiologiCal *incidents, ALARA goals and review of 6n-goi ng work from an ALARA perspective..

During this assessment period, an effective radiulogical contro~s program was implemented and maintaine The program was controlled by well developed and dissemina~ted policies and procedure The responsibilities and authorities of the routine non-outage radiological controls organization were adequately define Weaknesses in the definition of responsibilities for the outage radiological controls organization, identified early in this assessment

_period, were correcte PSE&G recently reorganized the in plant radiological controls group to provide for enhanced oversight of the program in addition to improving ALARA planning and goal settin Required records (e.g. radiation survey and pe~sonnel training records ) for the various areas of the

_radiological controls program were well maintaine Staffing levels to support outage and non-outage radiological controls activities were goo PSE&G used personnel from the corporate radiological controls group and the Salem Station ta augment the staff during outage This minimized reliance on contractor suppor Communications between radiological con~rols personnel and other plant personnel were goo PSE&G 1 ~ program used for routine training and qualification of radiological controls personnel a~d radiation workers ~as well defined and implemente The special program used to train and qualify contractor radiological controls personnel for outages was of good quality and appropriately implemente A program to provide continuing training for the radiological controls staff was well d~fined and implemente Previous weaknesses in maintaining personnel qualifi~ation records and in implementing the continuing radiological controls

personnel training program, whiGh were identified last period, were correcie The radiation protection and chemi$try training programs were INPO accredited during this SALP perio The quality of audits, surveillances and assessments of this area have improve Observations found these to be performance oriented and continuing to improve throughout th_e assessment per*io PSE&G used outside technical *

specialists, where appropriate, to audit selected technical area NRC observations indicated radiological controls supervisory personnel and managers monitored on-going work performanc Overall PSE&G response to NRC identified concerns was good as demonstrated by timely resolution of the issues, such as improvement in ALARA goa 1 s, improvement in the review of on-going work and improvement in audit quality.*

The weaknesses in the tracking, trending and closure of radiological occurrences; a problem identified last period, were correcte Statibn management actively reviewed radiological occurrence NRC review of PSE&G action on self~identified problems indicated PSE&G took aggressive corrective*

actions to address these mati~rs. *The few isolated radiological events that have occurred in this area were promptly reported, analyzed and cotrecte *The external and internal exposure control programs were Well defined and, with ~ome exceptions) effectively ~mplemented. The radiological controls.*

deficiencies identified in this area, e.g., poor contamination control, were attributable to isolated instc.nces of poor performance by radiological controls technician NRC observations during the ~id-cycle outage laie in the period indicated improved.)erforn1anc The program to minimize airborne radioactivity and to issue and control respiratory protection equipment was particularly noteworth The program used state-of-the-art techniques with an effective computerized syste PSE&G evaluation of radiological conditions during the first movement of spent fuel was commendabl This was evidenced by excellent radiological evaluations to verify shielding integrity duriflg spent fuel movemen PSE&G's control of and minimization of contaminated areas were goo J ndustri a 1 safety concerns including heat stress, use of safety lines and improper use of scaffolding were identified at Salem Statio In.response, PSE&G took action to preclude these problems at Hope Cree Some isolated NRC observations, e.g., use of untagged scaffolding, were noted during the mid-cycle outag These examples indicated ihe need for continued attention to industrial safety at Hope Cree The ALARA program was effectiv Station aggregate exposure since initial startup was commensurate with plant radiological operations and compared favorably with industry average Aggressive oversight and controi of major exposure tasks were note Previously identified w~akne~ses in goals development and exposure tracking were.correcte ALARA goals were considered challengin Lessons learned were effectively used for ALARA planning purpose PSE&G continued to aggressively pursue dose reduction actions and initiatives that could reduce aggregate exposure over the life of the facilit For example, a semiautomatic control rod drive removal system was installed and operationally tested for exposure reduc~ion during routine system maintenance, and robots were purchased and used where needed to minimize personnel exposur Water chemistry was closely monitored, and the imminent implementation of hydrogen water chemistry is a positive initiative to address pipe cracking and associated operational and radiological problem Fuel performance has been goo These initiatives will aid in maintaining exposures ALARA in the futur *

Also, PSE&G used zinc injection to minimize cobalt-60 buildup on primary pipin However, some higher than expected radiation fields caused _by zinc-65 were encountere PSE&G continues to evaluate the reason for the unexpected field A formalized cobalt* reduction program was under development ~t the end of the assessment period to provide further reduction of the station 1 s radiation source ter Staffing in the,~LARA area was goo PSE&G placed radiological controls personnel in the planning and scheduling department to evaluate work oackag~s and interface between work groups and the radiological controls grou This improved ALARA planr1in Improvement was observed in the areas of calibration of the liquid and gaseous monitors, effluent control equipment, and effluent control procedures which were identified as significant weaknesses in the previous assessmen An effective program for co11trolling radioactive effluent releases from the site was in plac Effluent sampl~ng, analyses, and reporting were goo Air cleaning systems were well maintained and teste The review of the radiological environmental monitoring program (REMP) indicated an adequate program was in plac Timely, thorough corrective actions were taken regarding violations for failure to audit an REMP area and for an inadequate downscale trip function on a liquid effluent monito The QA audits covered the stated objectives and were thorough, and corrective actions were prompt and effectiv PSE&G has an effective solid radioactive waste processing, preparation, packaging and shipping progra Overall, PSE&G management controls, waste processing procedures, QA audits and training in the area of radwaste were adequat During this assessment period PSE&G completed a major accomplishment in this area: the testing of a new asphalt solidification/dewatering system to ensure that a suitable waste form for disposal was provided and key process parameters were identifie Hope Creek continued its aggressive water chemistry control program, which received good plant management suppor Chemistry related parameters such as conductivity, chlorine, and condenser in-leakage were continually kept lo In summary, PSE&G maintained and implemented an effective radiological controls and chemistry progra ALARA performance relative to comparable facili'ties was goo PSE&G initiatives to reduce radiation exposure of workers were commendabl Overall radiological controls for work activities were effectiv Performance in the areas of radioactive effluent controls and transportation was generally stron Management oversight of the program was goo Effective corrective actions were taken for self-identified and NRC identified problem PSE&G's overall performance in these areas indicated good management commitment to and support of the-radiological controls progra V. IV. I IV. Performance Rating Category 1 Recommendations None Ma;ntenance/Surveillance (1143 hours0.0132 days <br />0.318 hours <br />0.00189 weeks <br />4.349115e-4 months <br />, 29%)

Analysis The previous SALP rated Maintenance as Category 1 arid Sutveillance as Category The SALP concluded that the maintenance organization was effrctively implementing corrective and preventive maintenanc The surveillance program was assessed as utilizing procedures of high quality, but the assessment encouraged improvement in the attention to detail area to reduce the number of personnel *errors and missed surveillance Maintenance:

The Maintenance Department continued to effectively manage maintenance activitie Management involvement was commendable, especially the first line supervisors, who were frequently evident at the work 16cations, were-informed regarding the problems, and resolved problems effectivel The managers exercised a conservative approach to problem resolution, and status meetings between managers were well controlled and focused on problem resolutio Work activities were well planned and coordinated which minimized equipment out-of-service tim The availability of safety equipment was very good, with a minimum number of corrective maintenance problems on major safety equipmen Equipment outages were largely pr~ventive maintenanc The utilization of a forced outage schedule allowed effective planning and maximum repair effort when the unit was unexpectedly shutdow Maintenance activities continued to be well controlled and received an appropriate level of

supervisory attentio The Maintenance Department was adequately staffed with skillful, well trained personnel and provided an appropriate level of detailed procedures for their us There were four reactor trips which resulted from.component failure The four failures involved multiplexed circulating water pump controls, turbine bearing wear detector, feedwater pump controls, and the collector of the main generator excite None of the failures indicated problems within the preventive maintenance program, and PSE&G took effective corrective actions to prevent continued reactor trips from similar component failure Four maintenance related reactor trip system actuations occurred, three of which had minimal safety significance as the reactor was already shutdow All four trips were related to the control of maintenance work; one trip resulted from improperly removing an auxiliary oil pump from service to perform preventive maintenance, one trip resulted from a procedure inadequacy regarding resetting of logic system trip signals during transmitter modifications, and two trips occurred due to welding and lifting adjacent to electronic cabinet Clearly, the operators who authorized the auxiliary oil pump tagout and work in proximity of operati:-.q elect.ronics cabinets sh~red responsibility for these trip Nonetheless, better.planning and control of maintenance work would reduce challenges to the operators and to safety system The maintenance planning and outage organizations were effective and an integral part of the performance of the work, both during outages and routine uperatio The planning group was properly supported by management, in that the staffing was adequate, and the assigned personnel had experience in operations, maintenance, and radiological protectio The managed maintenance information system (MMIS).continued to be an effective scheduling and tracking system for.all corrective and preventive maintenanc MMIS is an on-line computer based program that integrates the master equipment list, equipment history, recurring task scheduling, real time job status, and parts inventor Early in the assessment period Hope Creek completed its first refueling outage in 62 day The station personnel generally worked well together and

~ccomplished many tasks effectivel Some problems ~ccurred in modification work, and twice control of electrical jumpers was lost, although the impact on safety was minima Hope Creek completed a successful scheduled mid-cycle maintenance outage in April 1989, which lasted 17 day Effective interdepartmental coordination and planning was evident as the station implemented approximately 60 design changes and responded effectively to emerging problem The station completed all procedure revisions associated with the design changes prior to returning the unit to operatio Outage management control was enhanced by use of an outage management team, which consisted of an overall *outage manager and shift manager The smooth functioning outage and. the significant work accomplished in a short period of time demonstrated a highly effective tea The training center maintained extensive electrical and mechanical trainfng facilities, both INPO accredite Both electrical and mechanical technicians in the field have demonstrated technical knowledge and skill in accomplishing assigned task At the. end of the period the electrical and maintenance organ1zations were fully staffed and did not utilize any contractor personne Surveillance:

The surveillance program encompassed approximately 5000 surveillance tests performed annually within the Operations, Maintenance, Chemistry, *Radiation Protection and Site Protection Department The computerized system (MMIS)

described above scheduled all periodic surveillance tests and enabled the generally effective control of the surveillance progra There were five instances where surveillance tests were missed primar1ly due to personnel erro The missed tests had minimal safety significance, were identified by PSE&G, and typically involved poor retogniti6n of the effect of changing plant conditions on required surveillance test Effective corrective actions were implemented for ~he missed surveillanc~ ln general, surveillance test procedures were well written, accurate and complec Inadequate surveillahce testing procedures were responsible for a Nuclear Steam Supply Shutoff System (NSSSS) channel A isolation and a loss of shutdown cooling for twelve minute Also, early i'n the period, there was one surveillance test which did not adequately demonstrate operability of the liquid radwaste radiation monito This appeared to be an isolated.case, as no other test was found to inadequately test a syste Technicians freely provided feedback and r~commended procedure revisions to improve procedures based on field experienc These improvements have contributed to a significant backlog of procedure revisions (approximately 600) which have been implemented at a rate of 15-20 a wee This was a positive initiative which warranted continued PSE&G emphasis to provide for timely disposition of procedure revision There were two incidents which could have been prevented with improved attention to detail or better trainin The incidents involved the misapplication of test equipment, which resulted in a cleanup system isolation, and an incorrect alignment on an ECCS logic tester, which caused a C channel ECCS isolatio Other personnel errors involved a procedure deviation, which caused a HPCI isolation; an NSSSS isolation, which was gene~ated when a test equipment meter lead became grounded in a steam leak detection cabinet; and an inadequate return to service of a ventilation instrument.* Effective corrective actions were taken for each of the ~rrors, including personnel disciplinary actions, remedial training, and procedure improvement The rate of personnel errors continued to decline compared to previous assessment periods, but represented an area for improvemen The Inservice Test (IST) program was generally good with several strengths and weaknesses note The strengths included a comprehensive IST program submittal

..

to NRC staff with relatively few issues that required resolution, a comprehensive review team that e~tablished a documented program basis, and generally well prepa~d test procedure Good engineering practice and conservatism were evident in the pump reference values, which were traceable to the FSAR, the valve stroke time limits derived from actual stroke times, and the actions taken to resolve the safety relief valve (SRV) setpoint drift and pilot valve stickin The weaknesses included the delay in establishing an !ST coordinator and a few instances of failure to disseminate !ST applicable NRC Bulletins and Information Notices to all affected partie I~ addition, following a modification to a check valve~ the !ST procedure lacked adequate detail and acceptance criteria and the equipment operators were not trained in the modified desig Overall the !ST program was properly implemente The Inservice Inspection (IS!) program was properly defined and implemente Local Leak Rate (LLRT) activities were properly administered and implemented by the IS! grou PSE&G's program for monitoring erosion-corrosion in susceptible piping systems and components was goo PSE&G reviewed 100% of the !SI data as part of the progra PSE&G's response to Generic Letter 88-01 on Intergranular S~ress Corrosion Crack1ng was timely and addressed all required areas with no relief request~d. Overall the !SI program was effectiv Measuring and test equipment (M&TE) was routinely controlled; however, one finding indicated an instance where the lack of M&TE control prompted the need for additional effort to ensure all M&TE is properly calibrated prior to us In summary, the maintenance organization continued to effectively manage preventive and corrective maintenanc The maintenance, planning and outage organizations were well trained and productively coordinated to minimize degraded equipment.* Better control of maintenance work was demonstrated during the mid-cycle outage, with no reactor trips versus the three reactor trips during the refueling outag The surveillance area was well staffed with technically knowledgeable and experienced personne Surveillance test procedures were detailed and continued to be refined from in-plant implementation feedbac The reduction of the number of personnel errors and missed surveillances continued to represent areas for improvement. -

IV. Performance Rating Category 2; Improving IV. Recomm~ndations None

I IV. Emergency Preparedness Analysis

(136 hours0.00157 days <br />0.0378 hours <br />2.248677e-4 weeks <br />5.1748e-5 months <br />, 3%)

There is a consolidated Emergency Plan for the Artificial Island compl

,

including the Salem and Hope Creek facilitie Consequently, -the as ssment of emergency preparedness is a combined evaluation of both faciliti s'

emergency response capabilitie *

The previous SALP rated Emergency Preparedness as Category had demonstrated strong emergency response capability during e Hope Creek based exercis~.

No exercise weaknesses 6r areas for improv ent were identifie There was no Salem-based exercis The licen ee had maintained a strong. management awareness of and commitment to emergen preparednes O~e weakne~s was identified regarding the adequacy of th em staff response to

~ager call-in tests:

During this assessment period, a Salem based ful ~'<'ar icipation exercise took place which involved Delaware and New Jerse i luded an ingestion pathway respons~ in New Jgrse Theri was no f l scale exercise for Hope Creek. * Two routine eme~~ency preparedness *

were conducted and the

. Resider: Inspector ob.served several traini ~

During the full-participatiori -exercise * W aknesses were identified by the NR One weakness involved the fact e Control Room and Technic~l Support Center staffs did not recogn* e stulated containment failure for an hour and forty minute The other p ss involved a communication problem; the Emergency Response Manager di ~

nform the Emergency Operations Facility staff that recovery co

~* s had been attaine In addition, several other areas of lesser cance were identifie Remedial drills demonstrated effective corre ction for all identified exercise weaknesses with one excepti cognition of containment failure, which will be evaluated in a future er In other areas, correc ~ tions have been completed regarding pager call-in respons Management so responded to NRC concerns and took steps to improve the quality of dose tion calculations and field monitoring technique Sixteen Unusual Eve ts (UEs) were declared during this ~ssessment perio Licensee response o the events was generally in accordance with procedures; however, some ar as for improvement were identifie Two similar events at Salem w~re cla ified differently (one as a UE and one not classified),

indicating in onsistent interpretation _and use of EAL classification procedures the operator The procedures have been revised to provi~e clarificat"o On two other occasions, *inaccurate or incomplete information was prov* ed to the NRC Headquarters Operations Office A Hope Creek UE was declare 45 minutes after the event had begu Management recognized the need for c rective action in these cases and reemphasized to the Senior_Reactor Oper ors the importance of prompt, accurate declaration I IV. Emergericy Preparedness Analysis 17A ( 136 hours0.00157 days <br />0.0378 hours <br />2.248677e-4 weeks <br />5.1748e-5 months <br />, 3%)

There is a consolidated Emergency Plan for the Artificial Island complex, including the Salem and Hope Creek facilitie Consequently, the assessment of emergency preparedness is a combined evaluation of both facilities'

emergency response capabilitie The previous SALP rated Emergency Preparedness as Category The 1 i censee had demonstrated stro,ng emergency response capabi 1 ity during the Hope Creek based exercis No exercise weaknesses or areas for improvement were identifi~d. There was no Salem-based exercise.* The licensee had maintained a strong management awareness of and commitment to emergency preparednes One weakness was identified regarding the adequ~cy of the Salem staff response to pager call-in test D~ring this assessment period, a Salem. based full-p~rticipation exercise took place which involved Delaware ~nd New Jerse It included an ingestion pathway respon~e in New Jerse There was no full~scale exercise for Hope Cree Two routine emergenLy preparedness inspections were conducted and the Resident Inspector observed several training drill During the foll-participation exercise two weaknesses were identified by the NR One weakness inv0lved the fact that the Technical Support Center staff did not recognize postulated containment failure for an hour and forty minute The other weakness involved a communication problem; the Emergency Response Manager did not inform the Emergency Operations Facility staff that recovery conditions had been attaine In addition, several other areas of lesser significance were identifie Remedial drills demonstrated effective

corrective action for all identified exercise weaknesses with one exception, recognition of containment failure, which will be evaluated in a future exercis In other areas, corrective actions have been completed regarding pager call-in respons Management also responded to NRC concerns and took steps to improve the quality of dose projection calculations and field monitoring technique /

Sixteen Unusual Events (UEs) were decl~red during this assessment perio Licensee response to the events was generally in accordance with procedures; however, some areas for improvement were identifie Two similar events at Salem were classified differently (one as a UE and one not classified),

indicating inconsistent interpretation and use of EAL classification procedures by the operator The procedures have been revised to provide clarificatio On two other occasions, inaccurate or incomplete iriformation was provided to the NRC Headquarters Operations Officer. A Hope Creek UE was declared 45 minutes after the event had begu Management recognized the need for corrective action in these cases and reemphasized to the Senior Reactor Operators the importance of prompt, accurate declaration A reorganization placed the Emergency Preparedness Department in the Nuclear Services Department, which is intended to enhance corporate involvement in this area as the Nuclear Services Department General Manager (GM) has an operations and emergency response background and has maintained close contact with the emergency preparedness program '(EPP).-

Corporate management i nvo 1 vement and interest in this area was evident by the considerable amount of effort by the onsite Vice Presidents devoted to emergency preparedness issues, including off-site interface Support of and cooperation with the states remained at a high leve One new staff position; requiring a ~adiation protection background, wa-s added to emergency preparednes Two senior reactor operators are to be assigned full time to the EPP staf Emergency Preparedness Training (EPT) was a collaborative effort between EPP and the Training Department (TD).

The TD was changing its approach to EPT:

additional trainers are being qualified; a modular methodology based on Job Task Analysis will be used to ensure trainers hav~ an adequate understanding of emergency response organization staff needs; and the frequency of weekly training drills has been revised to one for each site every two weeks (on a trial basis).

At least thre~ persons were qualified for each position in the Emergency Response Organizatio The licensee recently affirw.ed that the Salem Technical Support Center (TSC),

an interim TSC per the Salem Unit 2 License, has not met NRC design require-ments regarding ventilatio This is a condition which has existed for eight year The licensee committed to resolve the deficiencies by October 198 Under the current situation, in the event TSC evacuation is required due to uninhabitability, the Salem TSC staff will relocate to the Hope Creek TS In most areas the licensee demonstrated a high level of interest and involvement in maintaining emergency response capability:

the licensee had an excellent Rumor Control organization, which could be manned by about 300 people on two shifts; an upgraded route alerting mechanism was developed; and a VHS tape was developed to train offsite workers in radiological self-protectio Siren availability was 98.5%.

Ten independent, redundant and diverse offsite communication systems were in place. *The Emergency News Center (ENC) was located about 7.5 miles from the sit Although it was not required, an a~ternate Emergency News Center has been identified and logistics arranged to support activation, if necessar In summary, the licensee maintained a good Emergency Preparedness Progra Management remained involved, was reasonably responsive to NRC concerns, and maintained an adequate staff for the Emergency Response Organizatio An effective training program ~as been maintaine Salem staff performance during the annual exercise was not at the same high level as that noted in the previous Hope Creek exercise; however, it was acceptabl There were isolated event classification problem The licensee's corrective actions with regard to resolving TSC operability concerns are scheduled to be completed by October 198 IV. Performance Rating Category 2 IV. Recommendations None I Security (222 hours0.00257 days <br />0.0617 hours <br />3.670635e-4 weeks <br />8.4471e-5 months <br />, 5%)

IV. Analysis

.One security program covers Salem and Hope.Creek, and the protected areas and security staffs overla Acc~rdingly, this 1assessment of security applies to both site The previous SALP rated the Salem and Hope Creek security program as Category This rating was largely influenced by management's attention to and invclvement in the program, an effective self-appraisal program, a clear understanding of NRC security objectives and a good enforcement histor Management's attention to, and involvement in, assuring the implementation of an effective security program remained eviden The licensee was very effective in maintaining good support for the security program from other functional groups at both station Frequent organization interactions and good working relationships were apparent from the profess{onal attitude of employees toward the security program, as well as the attention given by the maintenance group to the prevention and correction of problems with security systems and equipmen As further evidence of management 1 s interest in an effective and quality program, it was noted that all security shift supervisors, who provide around-the-clock oversight of the contract security force, attended a yearly training course given by the licensee on regulatory and security program requirements and objective In addition, security management continued to participate in the Region I Nuclear Security Organization and in other nuclear industry groups engaged in nuclear security related matter The licensee also continued to implement a self-initiated appraisal program carried out by security management and supervisory personne Adverse findings were promptly resolved and provided*to training personnel to factor into the training program to prevent their recurrenc The appraisal program is in adtjition to the NRC 1s required annual program audit that is conducted by quality assurance personne The last annual audit was very comprehensive in both scope and dept Audit findings were distributed to appropriate management personnel for review, and corrective actions for deficiencies were prompt and effectiv This also demonstrated the licensee's desire to implement an effective and quality security progra. I l

I l'

- - - - - - - - - -

During this assessment period, the licensee appointed a new site security manager.. The new security manager was promoted from within*the existing organization, and the transition went s~oothly which was indicative of good planning and effective managemen The security force contractor had effective management as was evidenced by continuous onsite contractor management, steps taken to improve the security program (e.g., employee benefits, training aids, and better equipment), and the low turnover of personnel (about 7%).

The contractor also implemented

, changes to its supervisory structure, which eliminated duplicat~ supervisory positions between the licensee and the contracto Staffing of the security organization appeared adequate, as evidenced by a limited use of overtime and a low backlog of wor The installation and maintenance of some state-of-the-art systems and equipment during this period significantly reduced the use of compensa.tory posts for systems and equipment failure and, thus, reduced the need for extensive overtim Both the*

licensee 1 s proprietary supervisors and the contractor 1 s supervisors were well trained and experienced, and exhibited a conservative and positive ~ttitude tOWf. rd securit Security force personne 1 were a 1 so we 11-tra i ned and exhio~tEd high ~orale and professionalism in carrying out their dutie The licensee 1 s efforts to establish and maihtain such a professional image for the security force was another indicator of the licensee 1 s desire to implement a quality security progra It was also reflected by the generally excellent 3tate of cleanliness in all security facilitie The training and requalification program was well developed and carr1ed out by a Training Administrator and two full-time instructor In addition to initial and requalification training, on-the-job performance evaluations were conducted which test the proficfency of individuals on general and specific security program requirement The on-the-job performance evaluations provided management the ability to review and enhance the performance and job

• knowledge of security personnel and to correct deficiencies as they were detecte This was another initiative that was indicative of the licensee 1s desire to implement an effective progra Several minor deficiencies were identified that were promptly and effectively correcte The licensee 1s good enforcement record during this period is attributed to management 1s involvement in the security program,. the continuing self-appraisal program, comprehensive annual audits, and the security training progra The licensee submitted three security event reports pursuant to 10 CFR 73.71(c) during the assessment perio One report involved an inadvertent tailgating incident and the other two reports involved security guards who were inattentive to dut The licensee's actions were prompt and effective in each cas During this period, the licensee also developed a program to minimize the recurrence of inattentive guards; the program includes limiting overtime and conducting organized discussions on topics such as proper nutrition and physical fitnes *

An NRC Safeguards Regulatory Effectiveness Review (RER) of the Island reviewed the protected area boundary and identified several potential weaknesses associated with the Salem-facility due to older equipment that the licensee had planned to replac The licensee was responsive to the RER findings and implemented short-term corrective measures where necessar However, several of the potential weaknesses were readily apparent to members of the RER team and should have been identified and corrected by the security organizatio The licensee submitted one change to the contingency plan under 10 CFR 50.54(p).

This change was made to provide clarification to certain areas in the pla This was indicative of the licensee desire to provide its security force with unambiguous instructio The change was clear and fully described the issue Prior to the submittal of this change, the licensee discussed the change with Region I safeguards personnel at a licensee requested meeting~

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 need IV. IV. I IV. Performance Rating Category 1 Reco~mendations None Engineering/Technical Support (382 hours0.00442 days <br />0.106 hours <br />6.316138e-4 weeks <br />1.45351e-4 months <br />, 10%)

Analysis The previous SALP rated Engineering and Technical Support as Category Significant inconsistency was noted in the quality of engineering work from the corporate Engineering and Plant Betterment (E&PB) Departmen A reorganization had been implemented in December 1987, at the end of the last SALP period, with the potential for improved corporate engineering support of plant activitie This late implementation of the reorganization did not allow time for a meaningful evaluation of its effect during the previous assessment perio The station systems engineers were observed to perform a valuable and effective functio However, the role of systems engineers needed to be more clearly define During this assessment period, significant changes were made to the corporate engineering department (E&PB) and its interaction with the station. These included:

implementation of an Engineering Work Request System; use of a Project Management System; establishment of a Project Matrix Organization; revision of the Design Change Process; more direct station input in prioritizing engineering work; and, improved responsiveness of EP&B to site need With the establishment of the new matrix organization, senior engineers are designated as project manager They coordinate and are responsible for design changes and other major projects from inception to completion~ This has resulted-in enhanced personnel accountability yielding an improv£ment in control over design change and project development and implementatior Plant involvement has been accomplished by including the system and QA engineers on project team The E&PB's new project organization has provided better tracking of engineering work within E&PB and enabled better coordination of techrufcal concerns, priorities and resources between Hope Creek and E&P During the two week mid-cycle outage late in the assessment period, a substantial amount of work was accomplished in an effective and efficient manne The f&PB project organization contributed to this accomplishment as the design changes were well organized and project personnel were present to resolve any problem A preestablished workbook approach to design change package developmemt has been instituted during this SALP perio This represented an improvement over the previous, less formalized proces The new design change procedures and checklists enabled better configuration management contro ImproveG supporting information in the design change package~ is intended to aid field installatio Overall, the modification work was acceptable under both the old and new system However, inconsistencies in the quality of engineering work from E&PB were note Engineering associated with feedwater flow measu~ement calculations and analyses supporting the Emergency Operating Procedures (EOPs)

were flawe Design changes regarding ventilation changes adjacent to the control room, instrumentation relay replacements,_ and instrumentation tubing supports had errors which needed corrective actions following turnover to the statio The full implementation of the upgraded design change process has the potential to prevent such errors, but design changes under this µriocess have only begun to be installe The E&PB Nuclear Engineering Group effectively supported plant operation,

-including post-refueling startup testing, thorough evaluations of secondary plant efficiency, and resolution of power oscillation concern NRC review of the Mark I containment design found that resolutions of previously identified issues were acceptabl The supporting analyses were of good quality and thoroug Engineering personnel involved with this activity were knowledgeable regarding the issues and their resolutio Communications between organizations and at all levels from the engineers to senior management were observed to be good regarding management control of projects and tasks in E&P Senior management is informed of the pla~t status and site activities through formal monthly meetings with the department head The General Manager of E&PB meets weekly with the functional managers for discussions of department activitie The functional managers met weekly with their staff The EP&B staffing was noted to be generally adequat The staff was found to be competent and knowledgeable in their areas of responsibilit PSE&G strongly supports participation in industry, owner groups and professional societie Progress was made toward better management of the various roles of the systems engineers, a problem noted during the previous assessment perio The systems engineers have continued to provide responsive, effective engineering support on day-to-day equipment problem This group remained a strength in the organizatio The systems engineers played significant roles in resolving numerous plant problems, including loss of power to instrumentation optical isolator panels, feedwater flow measurement errors, circulating water pump control problems, and Rosemount transmitter problem The system engineerihg groups were staffed with experienced knowledgeable engineers, who received six months of system and engineering trainin Further, PSE&G management staffed some unassigned positions to facilitate the training and development of replacement systems engineer Nevertheless, the overall experience level of the system engineers has decreased-due to the more experienced engineers pursuing other opportunities, and more supervision of the system engineers will be needed to maintain a consistent level of performanc In summary, PSE&G continues to make progress in addressing the engineering and technical support deficiencies identified during the previous assessment perio The full potential of PSE&G initiatives was not yet achieved, and inconsistencies in the quality of engineering work from E&PB remai The system engineers continue to be an organizationa-strength, but reduced experience levels within the system engineering group cou1d present a challenge to their performanc IV. IV. I IV. Performance Rating Category 2; Improving Recommendations None Safety Assessment/Quality Verification (186 hours0.00215 days <br />0.0517 hours <br />3.075397e-4 weeks <br />7.0773e-5 months <br />, 5%) *

Analysis This new functional area combines the previous functional areas of Licensing Activities and Assurance of Quality and assesses the effectiveness of PSE&G 1 s programs in assuring the safety and quality of plant operations and activitie The previous SALP rated the Assurance of Quality functional -area as Category 2 with an improving tren The report noted that PSE&G had established the programs, procedures, and working environment to promote high quality, and encouraged continued management attention to weak areas such as the engineering departm~nt. The previous SALP rated Licensing Activities, a separate functional area, as Category 2 and noted the inconsistent quality of licensing submittals regarding technical content and timelines During this assessment period, PSE&G did a good j6b of addres~ing technical issues in a straightforward ma~ner.. PSE&G went beyond technical specification requirements to ensure proper system operation; for example, all fourteen safety relief valves (SRVs) were lift tested at power following replacement, not just the required five SRVs, and the acceptance criteria for High Pressure Coolant Injection (HPCI) System response time testing were reduced for low pressure condition After an acceptable HPCI overspeed test, the test was repeated to confirm acceptabilit When a test engineer raised concerns regarding the orientation of isolation valves in primary containment ventilation lines, the concern was expeditiously raised to the plant management level and corrective actiG~s were initiate These efforts demonstrated a conservative, safety conscious approach to these issue PSE&G 1s adherence to the concept of personal accountability was most noticeable when observing the Senior Nuclear Shift Supervisors (the 11Seniors 11 ), the SRO licensed ope:--ators held accountable for plant operations on each operating shif The Seniors ensured that they concurred with decisions, such as technical specification interpretations, the acceptability of equipment being returned to service. and courses of actio Each morning, the department managers attended a meeting run by the Senior to discuss plant status and plans, which reinforced the Senior 1 s responsibility and provided the opportunity for him to have department managers address his concern The meeting provided ready accessibility from the operating crews to upper and middle level management, as well as being a vehicle that quickly involved engineering talent in operational problem However, as detailed in the individual functional areas, the PSE&G programs have generally been well designed and properly supported with adequate staffs of trained personnel, but the day-to-day implementation has resulted in numerous personnel error These errors have had minor safety significance and have been properly correcte The errors were variously caused by technician error, inadequate procedure review, poor work practices, or a loss of control of equipmen Further, the errors affected a broad cross section of the plant activities, including post-maintenance testing, workmanship, and management oversigh Frequently, the errors involved personnel errors indicative of a lack of attention to detail, e.g., a technician checked off a test step but did not place the switch in bypass as specified, an instrument was returned to service and verified despite a closed valve, et PSE&G has initiated the Human Performance Evaluation System (HPES), a detailed analysis method for determining root causes in incidents involving personnel error This analysis technique is intended to provide a thorough, innovative analysis of personnel error During the evaluation of the feedwater flow measurement errors that resulted in the facility being operated slightly above its maximum licensed power level, the engineering_ staff displayed a willingness and ability to analyze data and events independent of the vendor representative In this instance, an engineer did not accept General Electric (GE) Company assurances that their (GE's) calculations were correct and GE subsequently corrected the information by issuing a Service Information Lette.

.

Good problem identification occurred both from within and from outside each organizational elemen Numerous examples occurred in which personnel not directly responsible for activities raised issues which were promptly elevated to proper levels for resolution, including the orientation of containment isolation valves on the torus and control room pressure differentia Incident Reports continued to bG used to identify and resolve plant problems and off-normal events and for tracking corrective actions to completio Hope Creek had 170 Incident Reports in 1928, 36 of which were reportable to the NR PSE&G continued to an~lyze and tren~ the Incident Reports; their analyses demonstrated a steadily decreasing Incident Report frequenc The Station Operations Review Committee (SORC) was composed of department managers and provided consistent, effective review of significant plant issues, including design cha1ges, µost-trip reviews, reportable events, and station-wide procedure During the optical isolator failure, the SORC met during the night to review the course of action before its implementation, a good indication of the SORC 1 s rol *

The Quality Assurance Department, the Onsite Safety Review Group, and the Offsite Safety Review Group pro~ided effective, independent review of plant activitie The station quality assurance (QA) organization provided day-to-day review in the quality control and in-process review areas and was integrated into the station's resolution of problem As noted in the individual functional areas, the quality of auditing improved and provided an effective, independent review of plant programs and activitie Procurement and receipt inspection were iffectiv Station QA involvement in ISi and startup testing was apparen In the ISi area QA performed surveillance of in-progress ISI contractor activities, in-house reviews of contractor ISI procedures and audits at the contractor f~cilitie QA performed many surveillance activities du~ing the post-refueling startup testing progra Sixteen licensing actions (amendments, relief requests, exemptions, etc) were processe The quality of the technical evaluations was generally good,

indicating that PSE&G has a general understanding of the technical issues, is aware of and participates in industry groups, *and uses acceptable approaches to problem solution Submittals generally reflected good planning and effective assignment of prioritie PSE&G's responses to requests for additional information or necessary corrections were usually prompt and well handle The one exception dealt with a license change request concerning the Filtration, Recirculation, and Ventilation Syste There was one instance of an incomplete license change request dealing with an amendment to the Technical Specification surveillance test intervals and allowable outage times for the reactor protection syste These are viewed as exceptions to an otherwise effective progra The supplemental information was submitted promptly and correctl PSE&G's response to regulatory initiatives (i.e. Generic Letters, Bulleti~s and a TMI Action Plan update request) has been timely and complet Frequent communications indicate that they commence work on their responses sufficiently in advance that they are able to meet commitment dates without requesting

-

extension In summary, the safety conscious approach instilled by plant management and exercised by Hope Creek personnel was commendabl The persc.1nel errors which occurred in all functional areas need continued management attertio~. Problem identification was excellent, and problems were promptly addressed and correcte PSE&G licensing activities were ge~erally complete and timely.-

IV. Performance Rating Category 2; Improving IV. Recommendations None

SUPPORTING DATA AND SUMMARY Enforcement Activity Number of Violations by Severity Level Functional Area v

IV III II I

De Total

-

-

Plant Operations

2 Radiological Controls Maintenance/Surveillance

1

Emergency Preparedness

Security

Engineering/Technical

2

Support Safety Assessment/Quality

1 Verification Other l*

l*

Totals

7

0

1

• A Severity Level III violation without a civil penalty was issued for disc~imination in 1985 by Bogan (PSE&G contractor) against an employee for raising _safety concern~. Ins~ection Hour Summary Annualized Actual Hours_

Perce Plant Operations 1486 1157 37%

Radiological Controls 452 352 11%

Maintenance/Surveillance 1143 890 29%

Emergency Preparedness 136 106 3%

Security 222 173 5%

Engineering/Technical Support 382 297 10%

Safety Assessment/Quality 186 145 5%

Verification Totals 4007 3120 100%

_, 28 Licensee Event Reeort Causal Analysis Functional Area A

B c D

E Operations

Radiological Controls

Maintenance/Surveillance

1

Emergency Preparedness Security

Engineering/Technical Support

4 Safety Assessment/Quality Verification Totals

4

13 This analysis includes LERs 88-02 through 89-11 and two Cause Codes*

Tyee B. E. of Events Personnel Error..........

Poor judgement

Lack of knowledge/training -

At~ention to detail

Design/Man/Constr./Install External Cause...

Defective Procedur Component Failur Other.......

Tota x Total

2

2

48 safeguards LER *Root causes assessed by the SALP Board may differ from those listed in the-LE Overall, the number of LERS declined from 57 last SALP period (411 days) to 48 during this assessment period (471 days); this represents annual rates of 5 for last period and 37.2 for this period, a reduction of over 26%.

Also, this number of LERs compared favorably with other units of similar construction and vintag Clearly, the above causal analysis shows that personnel errors remained the major contributor to reportable event PSE&G 1 s analysis also showed personnel errors to be the major contributor, but to a lesser extent; over the assessment period, PSE&G attributed 21 events to personnel erro These errors caused at least half of the events in each functional area and involved

..

l

six violations of Technical Specifications (all PSE&G identified and only one cited).

PSE&G analyses, including the Human Performance Evaluation System (HPES), *have not identified _any common root causes for the personnel error Personnel at various workin*g levels were involved, from technicians to procedure writers to engineers to supervisory licensed operator The next significant causal factor was component failur Review of these failures did not determine any shortcomings in the ~reventive maintenance progra Attachment 1 SALP CRITERIA Licensee performance is assessed in selected functional areas, depending on whether the facility is in a construction, or operational phas Functional areas normally represent areas significant to nuclear safety and the environmen Some functional areas may not be as~essed because of little or no licensee activities or lack of meaningful observation Special areas may be added to highlight significant observation The following evaluation criteria were used, as applicable, to assess each functional area: Assurance of quality, including management involvement and control; Approach to resolution of technical issues from a safety standpoint; Responsiveness to NRC initiatives; Enforcement his~ory; Operational and construction events (including response to, analyses of, reporting of, and corrective actions for); Staffing (inc~~ding management); and Effectiveness of training and qualification progra On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categorie The definitions of these performance categories are:

Category 1:

Licensee management attention and involvement are evident and place emphasis on superior performance of nuclear safety or safeguards

~ctivities, with the resulting performance substantially exceeding regulatory requirement Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieve Reduced NRC attention may be appropriat Category 2:

Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities is goo The licensee has attained a level of performance above that needed to meet regulatory requirement Licensee resources are adequate and reasonably allocated so that good plant and personnel performance are being achieve NRC attention should be maintained at normal level ~

(

Attachment 1-2-Category 3:

Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not sufficien The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirement Licensee resources appear to be strained or not effectively use NRC -attention should be increased above normal level The SALP Board may assess a functional area and compare the licensee's performance during a portion of the assessment period (generally the latter part) to that during an entire period in order to determine a performance tren Generally, performance in the latter part of a SALP period is compared to the performance of the entire perio Other trends in performance from one period to the next may also be note The trend categories used by the SALP Board are as follows:

Improving:

Licensee performance was determined to be improving near the close of the assessment perio Declining:

Licensee performance was determined to be declining near the close of the a~sessment period and the licensee had not successfully addressed this patter A trend is assigned only when, in the op1n1on of the SALP Board, the trend is significant enough t~ be considered indicative of a likely change in the performance category in the near futur For example, a classification of

"Category 2, Improving" indicates the clear potential for "Category 1

performance in the next SALP perio *

It should be ncted that Category 3 performance, the l owe*s't category, represents acceptable, although minimally adequate, safety performanc If at any time the NRC concluded that a licensee was not achieving an adequate level of safety performance, it would then be incumbent upon NRC to take prompt appropriate action in the interest of public health and safet Such matters would be dealt with independently from, and on a more urgent schedule than, the SALP proces It should be also noted that the industry continues to be subject to rising

~erformance expectation NRC expects each licensee to actively use industry-wide and plant-specific operating experience in order to effect performance improvemen Thus, a lice~see's safety performance would be expected to show improvement over the years in order to maintain consistent SALP rating Enclosure 6 ERRATA SHEET SALP BOARD REPORT ERRATTA SHEET PAGE LINE NOW READS SHOULD READ Salem

7 3..... 3 1..... 1

11 30..... 73 28..... 71

13 security events 88-01 one sa i>1guards LER

8

through 88-03

17

28

23

71 Basis:

These changes reflect the correction of an administra ;ive erro Hope Creek & Salem SM 18 SM 18 HC 17 HC 17 Basis:

,2

18

the Control Room and Technical Staffs the Control Room and Technical Staffs the Technical Staff the Technical Staff These changes indicate that the Technical Support Center Staff, and not necessarily the Control Room Staff, were noted in the emergency exercise inspection report as not recognizing the postulated containment failure in a timely manner.