ML18094A621
| ML18094A621 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 04/30/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18094A618 | List: |
| References | |
| 50-354-88-99, NUDOCS 8908180151 | |
| Download: ML18094A621 (32) | |
See also: IR 05000354/1988099
Text
..
INITIAL 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 2
ASSESSMENT PERIOD:
JANUARY 16, 1988 - APRIL 30, 1989
... -***'* .
- .**
,<"" - **.
., :. *,;* .... **-** .. ,.***:*** ...
.** ._: .... : .. :_ *-~ *.--: . . -*
- ... . -~'.:_ ..
- ,** *.
- :;.-:.',). _,,*:*-,--_.-.> -
I.
INTRODUCTION
II.
BACKGROUND .
TABLE OF CONTENTS
II.A Licensee Activities ......... .
II.B Direct Inspection and Review Activities
III. SUMMARY OF RESULTS ............ .
III.A Overview
. . . . . . . .
. . . . . . .
III.B Facility Performance Analysis Summary.
III.C Reactor Trips and Unplanned Shutdowns.
IV.
PERFORMANCE ANALYSIS ...
IV.A Operations .. * ....
IV.B Radiological Controls ..
IV.C Maintenance/Surveillance ......... .
IV.D Emergency Preparedness* (Common with. Salem).
IV.E.Security (Common with Salem) ...... .
IV. F Engi neeri ng/Techni ca 1 Support . . . . .. .
IV.G- Safety Assessment/Quality Verification ..
SUPPORTING DATA AND SUMMARIES
A.
Enforcement Activity ... * ..... .
8.
Inspection Hour Summary . . .
. .. .
C.
Licensee Event Report Casual Analysis
Attachment 1: * SALP Criteria
Page
2
3
3
3
4
4
5
6
8
8
10
13
17
19
21
23
27
27
28
-* - ..
~ - . - -- -
--
- '
, **
- ~-
~
- _*,*_r__::.*;_!,-_._!--~--~*-.:_._-:_:_.'._____:*~-**~* ***-t:."- *--*--:-***.*.**** ".;*.-::,,;<**.******"' .*..
- '*:
- - - -- ---
'.
,.
2
I. - INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) is an integrated
NRC staff effort to collect available observations and data on a periodic
basis and to evaluate licensee performance on the basis of this
information.
The SALP program is supplemental to normal regulatory
processes used to ensure compliance with NRC rules and regulations. It
is intended to be sufficiently diagnostic to provide a rational basis for
allocating NRC resources and to provide meaningful feedback to the
licensee's management regarding the NRC's assessment of their facility's
performance in each functional area.
This report is the NRC 1s assessment of Public Service Electric & Gas
(PSE&G) Co.'s safety performance at the Hope Creek Generating Station for
the period January 16, 1988 through April 30, 1989.
The PSE&G programs
and personnel in the functional areas of security and emergency
preparedness overlap between the Hope Creek and Salem stations.
Accordingly, the SALP Board assessed these two functional areas at Hope_
Creek and Salem over similar assessment periods and provided a combined
assessment for each functional area.
These combined assessments are
duplic.a-Ced in both the Hope Creek and Salem SALP Reports.
An NRC SALP Board, composed of the staff members listed below, met on
July 12~ 1989, to review the observations and data on performance and to
asses*s PSE&G 's performance in accordance with the guidance in NRC Manual
Chapter 0516, "Systematic Assessment of Licensee Performance".
The
guid_ance and evaluation criteria are summarized in Attachment 1 to this
report~ The Board's findings and recommendations were forwarded to the
NRC Regional Administrator for approval and issuance.
Board Chairman
Samuel Collins, Deputy Director, Division of Reactor Projects (DRP)
Board Members
B. Boger, (Acting) Director, Division of-Reactor Safety (DRS)
M. Knapp, Director, Division of Radiological Safety & Safeguards
(DRSS)
J. Linville, Chief, Reactor Projects Branch No. 2, DRP
P. Swetland, Chief, Reactor Projects Section No. 28, DRP
G. Meyer, Senior Resident Inspector, Hope Creek
W. Butler, Director, Project Directorate (PD) I-2, Office.of
Nuclear Reactor Regulation (NRR)
C. Shiraki, Project Manager, PD I-2, NRR
- .' ....
.< .... *.* **.~* ': . .
- .:
-~~ .. *:**;.:.
< .*.. ;. ~: \\.:. *--~~ ... :. '. >.>. :: ... :~ .. * .
~*>'** *. : "*.
- .*:* .: :,*
____ ___:_
.. :,__ __ _
- ... *:.
~ . . '
Other Attendees:
. David Allsopp, Resident Inspector, Hope Creek
Ronald Bellamy, Chief,. Facilities Radiological Safety & Safeguards
Branch, DRSS
Robert Bores, Chief, Effluents Radiological Protection Section, DRSS
Richard Conte, Chief, Boiling Water Reactor Section, DRS
Jason Jang, Senior Radiation Specialist, DRSS
Paul Kauffman, Project Engineer, Projects Branch No. 2, DRP
Ronald Nimitz, Senior Radiation Specialist, DRSS
Jack Strosnider, Chief, Materials & Processes Section, DRS
Robert Winters, Reactor Engineer, DRS
II.
BACKGROUND
II.A Licensee Activities
This assessment period began on January 16, 1988, with the reactor at full
power.
On February 13, 1988, Hope Creek began the first refueling outage,
which was completed in 63 days .. On April 15 the unit was returned to service.
~ive reactor scrams occurred in the following seven months, which resulte~ in
forced outages of short duration.
On Februq.ry 18, 1989, Hope Creek began a
two week mid-cycle outage.
Following return to service on March 7, the
reactor continued power operations through April 30, 1989, the end of the
period.
The reactor trips and unplanned shutdowns which occurred during the
period are described in Section III.C.
Early in* the assessment period, Steven Miltenberger was promoted to Vice
President and Chief Nuclear Officer.* On August 29, 1988, Stanley LaBruna was
promoted from General Manager - Hope Creek Operations to Vice President -
Nuclear Operations, and Joseph Hagan was promoted from Maintenance Manager to
General Manager ~ Hope Creek Operations.
On March 7, 1989,. and Apri 1 22, 1989, PSE&G management met with Re*gi on I
personnel.to describe Hope Creek accomplishments, organizational efforts to
improve performance, and planned initiatives.
II.B Direct Inspection and Review Activities
Two NRC resident inspectors were assigned to the site throughout the
assessment period with the currently assigned Senior Resident Inspector
assuming his duties on March 13, 1988.
Regional
inspecto~s performed routine
inspections throughout the period~ with added inspection emphasis during the
scheduled outages.
In addition, a special inspection of Emergency Operating
Procedures was performed in September 1988, and a Regulatory Effectiveness
Review was performed in April 1989.
NRC performed a total of 4007 hours0.0464 days <br />1.113 hours <br />0.00663 weeks <br />0.00152 months <br /> of
inspection during the period, which equates to 3120 hours0.0361 days <br />0.867 hours <br />0.00516 weeks <br />0.00119 months <br /> on an annualized
basis.
- .-.*.* * .. *.:.
. _,*,
. * ... * .. * .
t
ia
III. SUMMARY OF RESULTS -
III.A Overview
Hope Creek programs continued to mature and exhibit a steady improvement in
performance.
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 results.
Performance in the
operations and radiological control functional areas improved sufficiently to
merit Category 1 ratings.
Excellent performance continued in the security
area.
The plant's operating record was good.
The operators did not initiate any
plant trips and responded correctly and promptly to operational events. The
previously identified weaknesses regarding licensed operator staffing and
housekeeping were effectively addressed.
The radiological -controls. program demonstrated good ALARA performance,
effective control of work activities, and strong radioactive effluent and
transportation controls.
PSE&G initiatives to reduce radiation exposure of
workers were commendable.
Good management support of the radiulogical -controls
and chemistry- programs was evident.
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 Sal em Techn i ca 1 Support Center to meet
habi tabi f; ty requirements.
Improving trends were noted in the functional areas of maintenance/surveillance,
engineering/technical support, and safety assessment/quality verification.
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 addressed~
The challenge for Hope Creek i~to continue to apply r1s1ng standards to the
established programs, to complete the initiatives underway, and to address the
isolated personnel errors and equipment failures which have occurred during
thi*s assessment period.
- . *:~--:~:.--.~~---:~? * ... *.:* .. _~:.!
.. * * *.*.* .. ,' , ..... "'=~: . .
------
III.8
Facility Performance Analysis Summary
Functional Area
-Last Period
This Period
Trend
(12/1/86-1/15/88)
(1/16/88-4/30/89)
Plant Operations
2
1
Radiological Controls
2
1
Maintenance/Surveillance
1/2*
2
Improving
1
2
Security
1
1
Engi neeri ng/T_echni ca 1
2
2
Improving
Support
Safety Assessment/
2**
2
Improving
Quality Verification
Rated as separate functional areas.
A simi*lar area {Assurance of Quality) was assessed last period.
Also,
the functional .area of Licensing Activities, which was assessed as
Category 2 during the last period, is currently included in this
functional area.
. *.** .. ***
.... '.
- ..
. .....
...
III.C
6
Reactor Trips and Unplanned Shutdowns
Event Description
Power
Date
Level
Root Cause
Functional Area
1.
While shutdown~ reactor trip occurred due to an Intermediate Range
Monitor (IRM) spike.
The spike resulted from electrical interference due
to welding near the IRM electrical cabinets.
No control rods moved.
3/21/88
0%
Personnel error
Maintenance
2.
While shutdown a reactor trip occurred due to an IRM spike concurrent
with a half scram from unrelated surveillance testing.
The IRM spike was
suspected to have occurred due to jarring of the support for the IRM
electrical cabinets.
One control rod~oved .
.. 3/30/88'
- Q%;
Personnel error
Maintenance
3.
A manual reactor trip was initiated because of the loss of all
circulating water pumps to the main condenser due to an e~ectronic
failure. in the multiplexed pump control signals.
4/30/88
. 80%
Component failure
NA
4.
The reactor tripped automatically on low reactor vessel level, because
one -0f 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 controls.
5/5/88*
100%
Personnel error/Design
Maintenance
5.
The reactor tripped automatically fo 11 owing a turbine trip during
functional testing of the turbine thrust bearing wear detector. A
mechanical failure in the wear detector linkage caused the turbine trip.
8/26/88
100%
Component failure*
NA
6.
The reactor tripped automatically on low reactor vessel' level when the
three reactor feed pumps tripped simultaneously on a false signal of high
discharge pressure. A failed electronic component had caused the false
pressure signal.
10/15/88
100~
Component failure
NA
. :.*.**-.
..
- Event Description
Power
Date
Level
--
7
Root Cause
Functjonal Area
7.
The reactor tripped automatically following a turbine trip caused by
arcing in the collector of the main generator exciter.
11/1/88
100%
Component failure
NA
8.
While shutdown the reactor tripped on an alternate rod insertion signal~
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 channel.
No control rods moved.
2/22/89
0%
Procedure inadequacy
Maintenance
'*
~* ':'
..
IV.
PERFORMANCE ANALYSIS
IV.A
IV .A.1
Operations
Analysis
- 8
(1486 hours0.0172 days <br />0.413 hours <br />0.00246 weeks <br />5.65423e-4 months <br />, 37%)
The previous SALP rated Operations as Category 2.
That assessment concluded
that Hope Creek displayed a conservative and safety conscious attitude toward
plant operation.
Licensed operator performance was very good with the
exception of isolated attention to detail errors related to operational
control of equipment.
Non-licensed operator performance while generally
adequate had more frequently shown the need for improvement in the areas of
overall plant knowledge and attention to detail related to control of
equipment in the field.
During this assessment period,-PSE&G operated the reactor in a conservative,
safety conscious manner, and the results were good.
There were no reactor
trips initiated by opera-tors or to-which operators contributed. The responses
of operators to reactor trips and transients were timely, thorough, well
coordinated, and technically correct.
Prompt actions by operators prevented
reactor trips in some instances, e.g., loss of vessel level control in April
1988.
PSE&G had committed and continued to commit resources to upgrade plant
operations*.
Specifically, manpower resources were provided such that each
operating shift had three Senio~ Reactor Operator (SRO) licensed individuals
(one above technical specification requirements), the Operations manpower
budget wa-s increased to enable a pipeline into licensed operator :;tatus, an
- SRO-licensed individual was added to supervise- the work control group
during regular maintenance hours, and additional Operations support staff was
provided.
Further, the work control area was relocated outside the control
room to minimize. distractions to the control room,- and. the Operations
Department offices were relocated adjacent to the control room.
Plant operations were well supported by the Training Department.
All five SRO
license candidates=and-three of four Reactor Operator (RO) candidates passed
the license examinations, a good performance.
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 reactor.
Licensed operators' plant awareness, safety perspective, and professional
control room demeanor were consistently evident.
Plant operations were well
supported by detailed plant procedures.
Shift. turnovers were formal and in-
cluded thorough briefings of the relief crew.
~untrol room access was strictly
controlled, and activities were limited to those directly related to plant
operations.
Continued management support resulted in further reductions in the
number of normally energized control room overhead annunciators.
An -Operator's
thoroughness during testing resulted in the early detection of a control room
ventilation system problem resulting from a modification.
The use of overtime
..... -..
,* ..
Ii .. *-.
9
was properly controlled.* The performance of non-licensed equipment operators
in general was good and continued to improve over the previous assessment
period.
However, during an NRC operator license examination walkthrough, the
examiner noted minor examples of plant condition discrepancies, which had
apparently been overlooked by non-licensed operators.
An NRC emergency operating procedure (EDP) 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 applicable instances.
Overall, the EOPs were found to be fully capable of performing their intended
purpose.
A high 1eve1 of management attention to ope rat ions was evident on a daily
basis.
An operational perspective of plant problems and work prioritization
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 interd.epartmental communication and in resolving problems.
Isolated instances of personnel errors in Operations continued.
The errors were
generally of minimal significance, occurred in different areas, and were
committed by different people. Acceptable, appropriate corrective actions
were taken for each error, but the incidence of errors remained an area for
improvement.
Specifically, operational errors included disabling an incorrect
valve, overlooking a valve's return to service, losing track of installed
electrical jumpers, a cleanup system isolation due to deviating from a procedure,
failing to fully- close a valve that resulted in an 8,000 gallon spill onto the
torus-room floor, and _erroneously placing two battery chargers into service on
one battery.
The frequency of personnel errors has continued to decrease
compared to earlier assessment periods.
PSE&G has developed an approach to
these issues and continued to evaluata the previous corrective actions and
potential additional corrective actions.
Housekeeping improved, and efforts were underway to complete painting of the
remainder of the plant. *Further, the storage and availability of ladders was
upgraded, and platforms for better access to equipment were noticeably
improved.
The fire protection program was well staffed, well equipped, and well
organized.
Fire protection personnel were knowledgeable, which demonstrated
an effective training program.
The fire brigade was staffed by fire
protection personnel, which minimized the reliance on operators to respond to
emergenci~s. Appropriate operator involvement in emergencies was provided.
The preventive maintenance and surveillances of fire protecti0H equipment were
effective, although more aggressive monitoring of fire door operability was
needed.
Once identified, all discrepancies were promptly corrected.
Overall,
management properly supported the fire protection area.
. __ ______:_*~-- .:__
.. ** . * .. -* .*
'
I
- '
10
In summary, the Hope Creek operating staff continued to display a conservative
and safety conscious approach* to plant operation and had an excellent
operating record with no operationally caused reactor trips.
The operators
were skillful and knowledgeable and properly responded to transients.
PSE&G
improved support of operations with increased staffing in both onshift and
support roles.
The need for reduction in personnel errors represented the
primary area for improvement.
IV.A.2
Performance Rating
Category 1
IV.A.3
Recommendations
None
IV.B
Radiological Controls . (452 hours0.00523 days <br />0.126 hours <br />7.473545e-4 weeks <br />1.71986e-4 months <br />, 11%)
IV.B.1
Analysis
The previous SALP rated Radiological Controls as Category 2 (improving).
The
radiological programs were effective and well coordinated. Areas for
improvement were audits, review of radiological incidents, ALARA goals and
review of on-going work from an ALARA perspective.
During thjs.assessment period, an effective radiological controls program was
imp 1 emented and maintained.
The program was cont ro 11 ed by we 11 deve 1 oped and
disseminated policies and proceduresA
The responsibilities and authorities of
the routine non-outage radiological controls organization were adequately
defined.
Weaknesses in the definition of responsibilities for the outage
radiological controls organization, identified early .in this assessment
period, were corrected.
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 setting.
Required records (e.g. radiation
survey and personnel training records ) for the various areas of the
radiological control*s program were well maintained.
Staffing levels to support outage and non-outage radiological controls
activities were good.
PSE&G used personnel from the corporate radiological
controls group and the Salem Station to augment the staff during outages.
This minimized reliance on contractor support.
Communications between
radiological controls personnel and other plant personnel were *good.
PSE&G's program used for routine training and qualification of radiological
controls personnel and radiation workers was well defined and implemented.
The special program used to train and qualify contractor radiological controls
personnel for outages was of good quality and appropriately implemented.
A
program to provide continuing training for the radiological controls staff was
well defined and implemented.
Previous weaknesses in maintaining personnel
qualification records and in implementing the continuing radiological controls
-*.,- *._.:.*
. -.**.
. - .-:.* .. -
11
personnel training program, wh1ch were identified last period, were corrected.
The radiation protection and chemistry training programs were INPO accredited
during this SALP period.
The quality of audits, surveillances and assessments of this area have
improved.
Observations found these to be performance oriented and continuing
to improve throughout the assessment period.
PSE&G* used outside technical
specialists, where appropriate, to audit selected technical areas.
NRC
observations indicated radiological controls supervisory personnel and
managers monitored* on-going work performance.
Overall PSE&G response to NRC
identified concerns was good as demonstrated by timely resolution of the
issues, such as improvement in ALARA goals, 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 corrected. Station
management actively reviewed radiological occurrences.
NRC review of PSE&G
action on self-identified problems indicated PSE&G took aggressive corrective
actions to address these matters.
The few isolated radiological events that
have occurred in this area were promptly reported, analyzed and corrected.
The external and internal exposure control programs were well defined and,
with some exceptions, effectively implemented.
The radiological controls
deficiencies identified in this area, e.g., poor contamination control, were
attributable to isolated instances of poor performance by radiological
controls technicians.
NRC observations during the mid-cycle outage late in
the peri o_d indicated imp roved performance.
The program to minimize airborne radioactivity and to issue and control
respiratory protection equipment was particularly noteworthy.
The program
used state-of-the-art techniques with an effective computerized system.
PSE&G
evaluation of. radiological conditions during the first movement of spent fuel
was commendable.
This was evidenced by excellent radiological evaluations to
verify shielding. integrity during spent fuel movement.
PSE&G 1 s control of and
minimization of contamihated* areas were good.
Industrial safety concerns including heat stress, use of safety lines and
improper use of scaffolding were identified at Salem Station.
In response,
PSE&G took action to preclude these problems at Hope Creek.
Some isolated NRC
observations, e.g., use of untagged scaffolding, were noted during the mid-
cycle outage.
These examples indicated the need for continued attention *
to industrial safety at Hope Creek.
The ALARA- program was effective. Station aggregate exposure since initial
startup was commensurate with plant radiological operations and ~ompared
favorably with industry averages.
Aggressive oversight and control of major
exposure tasks were noted.
Previously identified weaknesses in goals
development and exposure tracking were corrected.
AL.ARA goals were considered
challenging.
Lessons learned were effectively used for AL.ARA planning
purposes.
12
PSE&G continued to aggressively pursue dose reduction actions and initiatives
that could reduce aggregate exposure over the life of the facility.
For
example, a semiautomatic control rod drive removal system was installed and
operationally tested for exposure* reduction during routine system maintenance,
and robots were purchased and used where needed to minimize personnel
exposure.
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 problems.
Fuel
performance has been good.
These initiatives will aid in maintaining
exposures ALARA in the future.
Also, PSE&G used zinc injection to minimize cobalt-60 buildup on primary
piping.
However, some higher than expected radiation fields caused by zinc-65
were encountered.
PSE&G continues to evaluate the reason for the unexpected
fields.
A formalized cobalt reduction program was under development at the
end of the assessment period to provide further reduction of the station's
radiation source term.
Staffing in the ALARA area was good.
PSE&G placed radiological controls
personnel in the planning and scheduling department to evaluate work packages
and interface between work :~roups and the radio l ogi ca 1 contra 1 s group.
This*
improved ALARA planning.
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 assessment.
An
effectivs program for controlling radioactive effluent releases from the site
was in place.
Effluent ~ampling, analyses, and reporting were good.
Air
cleaning systems were w~ll maintained and tested.
The review of the
radiological environmental monitoring program (REMP) indicated an adequate
program was in place.
Timely, thorough corrective actions were taken regarding
violations for failure to audit an REMP area and for an inadequate downscale
trip fcnction on a liquid effluent monitor.
The QA audits covered the stated
objectives and were thorough~ and-corrective actions were prompt and effective.
PSE&G has an effective solid radioactive waste processing, preparation,
packaging and shipping program.
Overall, PSE&G management controls, waste
processing procedures, QA audits and training in the area of radwaste were
adequate.
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 identified.
Hope Creek continued its aggressive water chemistry control program, which
received good plant management support.
Chemistry related parameters such as
conductivity, chlorine, and condenser in-leakage were continually kept low.
I
I
I_.
13
- In summary, PSE&G maintained and implemented an effective radiological
controls and chemistry program.
ALARA performance relative to comparable
facilities was good.
PSE&G initiatives to reduce radiation exposure of
workers were commendable.
Overall radiological controls for work activities
were effective.
Performance in the areas of radioactive effluent controls and
transportation was generally strong.
Management oversight of the program was
good.
Effective corrective actions were taken for self-identified and NRC
identified problems.
PSE&G's overall performance in these areas indicated
good management commitment to and support of the radiological controls
program.
IV.B.2
Performance Rating
Category 1
IV.B.3
Recommendations
- None
IV.C
Maintenance/Surveillance (1143 hours0.0132 days <br />0.318 hours <br />0.00189 weeks <br />4.349115e-4 months <br />, 29%)
IV.C.1
Analysis
The previous SALP rated Maintenance as Category 1 and Survei *,lance as
Category 2.
The SALP concluded that the maintenance organization was
effectiv~y implementing corrective and preventive maintenance.
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 surveillances.
Maintenance:
The Maintenance Department continued to effectively manage maintenance
activities. Management involvement was commendable, especially the first
line supervisors, who were frequently evident at the work locations, were
informed regarding the problems, and resolved problems effectively. The
managers exercised a conservative approach to problem resolution, and status
meetings between managers were well controlled and focused on problem
resolution.
Work activities were well planned and coordinated which minimized
equipment out-of-service time.
The availability of safety equipment was very
good, with a minimum number of corrective maintenance problems on major safety
equipment.
Equipment outages were largely preventive maintenance.
The
utilization of a forced outage schedule allowed effective planning and maximum
repU:i"':!°"effort when the unit was unexpectedly shutdown.
Maintenance activities*
continued to be well controlled and received an appropriate level of
. . ~--* .
. * ....
- .
~
~: ***-.--*
.
14
supervisory attention.
The Maintenance Department was adequately staffed with
skillful. well trained personnel and provided an appropriate level of detailed
procedures for their use~
There were four reactor trips which resulted from component failures.
The
four failures involved multiplexed circulating water pump controls, turbine
bearing wear detector, feedwater pump controls, and the collector of the main
generator exciter.
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 failures.
Four maintenance related reactor trip system actuations occurred, three of
which had minimal safety significance as the reactor was already shutdown.
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 we*lding and lifting adjacent to
electronic cabinets~ Cl early, the operators who authorized the auxiliary oil
pump tagout and work in proximity of operating electronics cabinets
sharr,d responsibility for these trips. Nonetheless, Detter planning
and control of maintenance work would reduce cha 11 enges to the operators and
to safety systems.
The maintenance planning and outage organizations were effective and an
integral part of the performance of the work, both during outages and routine
operation_.
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 protection.
The managed maintenance
information system (MMIS) continued to be an effective scheduling and tracking
system. for all corrective and preventive maintenance.
MMIS is an on-line
computer based program that. integrates th~ master equipment list, equipment
history, recurring task scheduling, real time job status, and ~arts inventory.
Early in the assessment period Hope Creek completed its first refueling outage
in 62 days. *The station personnel generally worked well together and
accomplished many task~ effecttvely .. Some problems occurred in modification
work, and twi"ce control of electrical jumpers was lost, although the impact on
safety was minimal.
Hope Creek completed a successful scheduled mid-cycle maintenance outage in
April 1989, which lasted 17 days.
Effective interdepartmental coordination
and planning was evident as the station implemented approximately 60 design
changes and responded effectively to emerging problems.
The station completed
all procedure revisi-O"ns associated with the design changes prior to returning
the unit to operation.
Outage management control was enhanced by use of an
outage management team, which consisted of an overall outage manager and shift
managers.
The smooth functioning outage and the significant work accomplished
in a short period of time demonstrated a highly effective team.
--.-
.. -* .*
!
. : . : .... -. .. . . . .
~.
- -~,,.
- . -
. . . .
'
. ' ... -*~;: : -*- .:-
.* .. < .. '* : .
' '
15
- The training center maintained extensive electrical and mechanical training
facilities, both INPO accredited. Both electrical and mechanical technicians
in the field have demonstrated technical knowledge and skill in accomplishing
assigned tasks.
At the end of the period the electrical and maintenance
organizations were fully staffed and did not utilize any contractor personnel.
Surveillance:
The surveillance program encompa~sed approximately 5000 surveillance tests
performed annually within the Operations, Maintenance, Chemistry, Radiation
Protection and Site Protection Departments.
The computerized system (MMIS)
described above scheduled all periodic surveillance tests and enabled the
generally effective control of the surveillance program.
There were five
instances where surveillance tests were missed primarily due to personnel
error. The missed tests had minimal safety significance, were identified by
PSE&G, and typically involved poor recognition of the effect of .changing plant
conditions on required surveillance tests.
Effective corrective actions were
implemented for the*mtssed surveillances.
In general, surveillance test procedures were well written, accurate and
compl~te. Inadequate surveillance testing procedures were responsible for a
Nuclear Steam Supply Shutoff System (NSSSS) channel A isolation and a loss of
shutdown cooling for twelve minutes.
Also, early in the period, there was one
surveillanc~ test which did not adequately demonstrate operability of the
liquid radwaste radiation monitor.
This appeared to be an isolated case, as*
no other test was found to inadequately test a system.
Technicians freely
provided feedback and recommended procedure revisions to improve procedures
based on field experience~ These improvements have contributed to a
.
significant backlog of procedure revisions (approximately 600) which have been
implemented at a rate of 15-20 a week.
This was a positive initiative which
warranted continued PSE&G emphasis to provide for timely disposition of
procedure revtsions ..
There were two incidents which could have been prevented with improved
attention to detail or better training.
The incidents involved the
misapplication of test* equipment, which resulted* in a cleanup system
isolation, and an,.incorrect a~i.gnment on an ECCS logic tester, which caused a
C channel ECCS isolation. Other personnel errors involved a procedure
deviation, which caused a HPCI isolation; an NSSSS isolation, which was
generated 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 errors,
including personnel disciplinary actions, remedial training, and procedure
improvements.
The rate of personnel errors continued to decline compared to
previous assessment periods, but represented an area for improvement.
The Inservice Test (IST) program was generally good with several strengths and
weaknesses noted.
The strengths includ~d a comprehensive IST program submittal
.
.
' .. : -:* .. **:. .*
. .
-* . : *~:* .
- ~.;.,- '. ' .
- ~...-:-_* -. ___ -- ..
- .. * *.* ,*,_ ::* ..
- -
~** _.* :__C:_:: .* -~.*-
16
to NRC staff with relatively few issues that required resolution 9 a comprehensive
review team that established a documented program basis~ and generally well
prepared test procedures.
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 9 and the actions
taken to resolve the safety relief valve (SRV) setpoint drift and pilot valve
sticking.
The weaknesses included the delay in establishing an IST
coordinator and a few instances of failure to disseminate IST applicable NRC
Bulletins and Information Notices to all affected parties.
In addition,
following a modification to a check valve, the IST procedure lacked adequate
detail and acceptance criteria and the equipment operators were not trained in
the modified design.
Overall the IST program was properly implemented.
The Inservice Inspection (ISI) program was properly defined and implemented.
Local Leak Rate (LLRT) activities were properly administered and implemented
by the ISI group.
PSE&G 1s program for monitoring erosion=corrosion in
susceptible piping systems and components was good.
PSE&G reviewed 100% of
the ISI data as part of the program.
PSE&G's response to Generic Letter 88-01
on lntergranular Stress Corrosion Cracking was timely and add~essed all
required areas with no relief requested.
Overall the IS! program was
effective.
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
use.
In summary, the* maintenance organization continued to effectively manage
preventive and corrective- maintenance.
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 outage.
The surveillance area was well staffed
with. technically knowledgeable and. experienced personnel.
Surveillance test
procedures were detailed and continued to be refined from in-plant
implementation feedback.
The reduction of the number of personnel errors and
missed surv~illances continued to represent. areas for improvement.
IV.C.2
IV.C.3
Performance Rating
Category 2; Improving
Recommendations
None
'
. ** ... :.* .. * ,.
.
':*~ ::-*. ,._.. . . ,
': ...
. ....... _
- .~*. :
- _~...
- .--~
IV.D
IV.D.1
Analysis
17
(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 facilities.
Consequently, the assessment
of emergency preparedness is a combined evaluation of both facilities*
emergency response capabilities.
The previous SALP rated Emergency Preparedness as Category 1.
The licensee
had demonstrated strong emergency response capability during the Hope Creek
based exercise.
No exercise weaknesses or areas for improvement were
identified. There was no Salem-based exercise.
The licensee had maintained a
strong management awareness of and commitment to emergency preparedness.
One
weakness was identified regarding the adequacy of the Salem staff response to
pager call-in tests. *
During this assessment.period, a Salem based full-participation exercise took*
place which involved Delaware and New Jersey. It included an ingestion
pathway response in New J~rsey. There was no full-scale exercise for Hope
Creek.
Two routine emergency preparedness inspections were conducted and the
Resident Inspector observed several training* drills.
During the* full-participation exercise two weaknesses were identified by the
NRC.
One weakness involved the. fact that the Control Room and Technical
Support Center staffs did not recognize postulated containment failure for an
hour and_forty minutes.
The other weakness involved a communication problem;
the Emergency Response Manager did not inform- the Emergency Operations
Facility staff that recovery conditions had been attained.
In addition,
several other areas of lesser significance were identified.
Remedial drills
demonstrated effective corrective action for all identified exercise
weaknesses with on~ exception,. recognition of containment failure, which will
be evaluated in a future exercise.
In other areas, corrective actions have been completed regarding pager call-in
response.
Management also responded to NRC concerns and took steps to improve
. the quality of dose projection. calculations and field monitoring techniques.
Sixteen Unusual Events (UEs) were declared during this assessment period.
Licensee response to the events was generally in accordance with procedures;
however, some areas for improvement were identified.
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 operators.
The procedures have been revised to provide
clarification.
On two other occ*asions, inaccurate or incomplete information
was provided to the NRC Headquarters Operations Officer. A Hope Creek UE was
declared 45 minutes after the event had begun.
Management recognized the need
for corrective action in these cases and reemphasized to the Senior Reac~or
Operators the importance of prompt, accurate declarations.
'
~: * . .'. - . !.,.::. :. .**** ; ..* ~-***. -:
.
- .. -**.
..
~ ~. . .. .. -. _..* .
- ** < '* *** '*.* * .-.
- *
'" .< .. :
"
... - * * * ... -
~ * .-....
.. * ...
18
A reorganization placed the Emergency Preparedness Department in the Nuclear
Services Department, which is iritended 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 involvement
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 interfaces.
Support of and cooperation with the states remained at a
high level.
One new staff position, requiring a radiation protection
background, was added to emergency preparedness.
Two senior reactor operators
are to be assigned full time to the EPP staff.
Emergency Preparedness Training (EPT) was a collaborative effort between EPP
and the Tr~ining 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 have an adequate understanding
of emergency response organization staff needs; and the frequency of weekly
- training dril 1 s has been revised to one for each site every two weeks (on a .
trial basis). At least three persons were qualified for each position in the
Emergency Response Organization.
The licensee: recently affirmed that the Salem Technical Support Center (TSC),
an interim TSC per the Salem Unit 2 License, has not met NRC design require-
ments regarding ventilation. This is a condition which has existed for eight
years.
The* licensee committed to* resolve the deficiencies by October 1989.
Under the current situation, in the event TSC evacuation is required due to
uninhabitability, the Salem TSC staff will .relocate to the Hope Creek TSC.
- 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-protection. Siren* a-vailability was 98.5%.
Ten independent, redundant
and diverse offsite communication systems were in place.
The Emergency News
Center (ENC) was ldcated about 7.5 miles from the site. Although it was not
required, an alternate, Emergency News Center .has. been identified and logtstics
arranged to support activation, if necessary.
In summary, the licensee maintained a good Emergency Preparedness Program.
Management remained involved, was reasonably responsive to NRC concerns, and
maintained an adequate staff for the Emergency Response Organi~ation. An
effective training program has been maintained.
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 acceptable.
There were isolated
event classification problems.
The licensee 1 s corrective actions with regard
to resolving TSC operability concerns are scheduled to be completed by October
1989.
','.
- **.* '.
. *-*
-~-
~ .. "'.
'. ~ .. -~ ~* ' .
-*- .. - *- .
IV.D.2
IV.D.3
IV.E
IV.E.1
19
Performance Rating
Category 2
Recommenda.t ions
None
Security
(222 hours0.00257 days <br />0.0617 hours <br />3.670635e-4 weeks <br />8.4471e-5 months <br />, 5%)
Analysis
One security program covers Salem and Hope Creek, and the protected areas and
security staffs overlap.
Accordingly, this assessment of security applies to
both sites.
The previous SALP.rated the Salem and Hope Creek security program as
Category 1.
This rating was largely influenced by management's attention to
and involvement in the program, an effective self-appraisal program, a clear
understanding of NRC security objectives and a good enforcement history.
Management's attention to, and involvement in, assuring the implementation of
an effective security program remained evident.
The licensee was very
effec~ive in maintaining good support for the security program from other
functional groups at both stations.
Frequent organization interactions a~d
good working relationships were apparent from the professional 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 equipment.
As further evidence of management'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 objectives.
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 matters.
The licensee also continued to implement a self-initiated appraisal program
carried out by security management and supervisory personnel.
Adverse
findings were promptly resolved and provided to training personnel to factor
into the training program to prevent their recurrence.
The appraisal program
is in addition to the NRC 1 s required annual program audit that is conducted by
quality assurance personnel.
The last annual audit was very 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 demonstrated the licensee 1 s desire to
implement an effective and quality security program.
'
20
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 smoothly which was indicative of gaod
planning and effective management.
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 duplicate supervisory
positions between the licensee and the contractor.
Staffing of the security organization appeared adequate, as evidenced by a
limited use of overtime and a low backlog of work.
The installation and
maintenance of some state-of-the-art systems and equipment during this period
significantly reduced the use of compensatory posts for systems and equipment
failure and, thus, reduced the need for extensive overtime.
Both the
- licensee's proprietary supervisors and the contractor's supervisors were well
trained and experienced, and exhibited a conservative and positive attitude
toward security.
Security force personnel were also well-trained and
exhibited high morale and professionalism in carrying out their duties.
The
licensee's efforts to establish and maintain such a professional image for the
security force was another indicator of the licensee's desire to implement a
quality security program.
It was also reflected by the generally excellent
state of cleanliness .in all security facilities ..
The train_i*ng and requalification program was well developed and carried out by
a Training Administrator and two full-time instructors.
In addition to
initial and ~equal.ification training, on-the-job performance evaluations were
conducted which test the proficiency of individuals on general and specific
security program requirements.
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
detected.
This was another initiative that was indicative of the licensee's
desire to implement an effective program.
Several minor deficiencies.were.identified that were promptly and effectively
corrected.
The licensee's good enforcement record during this period is
attributed to management's involvement in the security program, the continuing
self-appraisal program, comprehensive annual audits, and the security training
program.
The licensee submitted three security event reports pursuant to 10 CFR
73.71(c) during the assessment period.
One report in~olved an inadvertent
tailgating incident and the other two reports involved security guards who
were inattentive to duty.
The licensee's actions were prompt and effective in
each case.
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 ~s proper
nutrition and physical fitness.
'* .. :: .. ls"**-,:;..
......
21
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 replace. The licensee was responsive to the RER findings and
implemented short-term corrective measures where necessary.
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 organization.
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 plan.
This was indicative of the licensee desire to provide its security
force with unambiguous instruction. The change was clear and fully described
the issues. 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 Island.
Management interest in the program
remained evident through its continued support and attention. to program needs.
IV.E.2
Performance Rating
Category 1
IV.E.3
Recommendations
None
IV. F
Engi neeri ng/Techn.i cal Support
(382 hours0.00442 days <br />0.106 hours <br />6.316138e-4 weeks <br />1.45351e-4 months <br />, 10%)
IV.F.1
Analysis
The previous SALP rated Engineering and Technical Support as Category 2.
Signtficant inconsistency. was noted in the quality of engineering work from
the corporate Engineering and Plant Betterment (E&PB) Department.
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 activities. This late implementation of the reorganization did not
allow time for a meaningful evaluation of its effect during the previous
assessment period.
The station systems engineers were observed to perform a
valuable and effective function.
However, the role of.systems engineers needed
to be more clearly defined.
During this assessment period, significant changes were made to the corporate
engineu~~ng 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
needs.
-:,~::___ ~~** * : . * ~*
22
With the establishment of the new matrix organization, senior engineers are
designated as project managers.
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 improvement in
control over design change and project development and implementation.
Plant
involvement has been accomplished by including the system and QA engineers on
project teams.
The E&PB's new project organization has provided better tracking of
engineering work within E&PB and enabled better coordination of technical
concerns, priorities and resources between Hope Creek and E&PB.
During the
two week mid-cycle outage late in the assessment period, a substantial amount_
of work was accomplished in an effective and efficient manner.
The E&PB
project organization contributed to this accomplishment as the design changes
were well organized and project personnel were present to ~esolve any
problems.
A preestablished workbook approachto design change package development has
been instituted during this SALP period.
This represented an improvement over
the previous, less formalized process.
The new design change procedures and
checklists enabled better configuration management control.
Improved
supporting information- in the design change packages is intended to aid field
i n s ta 11 at i on .
Overall, the modification work was acceptable under both the old and new
systems.
However, inconsistencies in the quality of engineering work from
E&PB were_ noted.
Engineering associated with feedwater flow measurement
calcul~tions and analyses supporting the Emergency Operating Procedures (EOPs)
were flawed. * Design *changes regarding venti-lation changes adjacent to the
control room, instrumentation relay replacements, and instrumentation tubing
supports had errors which needed corrective actions following turnover to the
station~ The full implementation of the upgraded design change process has
the potential to prevent such errors, but design changes unde~ this process
have only begun.to be installed.
The E&PB Nuclear Engi~eering Group effectively supported* plant operation,
. including. post"."refueling startup testing, :thorough. evaluations of secondary
plant efficiency, and resolution* of power oscillation concerns.
NRC review of the Mark I containment design found that resolutions of
previously identified issues were acceptable.
The supporting analyses were of
good quality and thorough.
Engineering personnel involved with this activity
were knowledgeable regarding the issues and their resolution.
Communications between**iJf'9anizations and at all levels from the engineers to
senior management were observed to be good regarding management control of
projects and tasks in E&PB.
Senior management is informed of the plant status
and site activities through formal monthly meetings with the department heads.
The General Manager of E&PB meets weekly with the functional managers for
discussions of department activities.
The functional managers met weekly with
their staffs.
. . .
~-.
.' ...
23
The EP&B staffing was noted to be generally adequate.
The staff was found to
be competent and knowledgeable in their areas of responsibility.
PSE&G strongly
supports participation in industry, owner groups and professional societies.
Progress was made toward better management of the various roles of the systems
engineers, a problem noted during the previous assessment period.
The systems
engineers have continued to provide responsive, effective engineering support
on day-to-day equipment problems.
This group remained a strength in the
organization. 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 problems.
The system engineering groups were staffed with experienced knowledgeable
engineers, who received six months of system and engineering training.
Further, PSE&G management staffed some unassigned positions to facilitate the
training and development of replacement systems engineers.
Nevertheless, the
overall e-xperience 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
performance.
In summary, PSE&G continues to make progress in addressing the engineering and
technical support deficiencies identified during the previous assessment
period. The*full potential of PSE&G* initiatives-was not yet achieved, and
inconsistencies in the quality of engineering work from E&PB remain.
The
system engineers continue to be an organizational strength, but reduced
experience.levels within the system engineering group could present a
challenge to their performance.
IV.F.2
IV.F.3
IV .G .
IV.G.l
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's
programs in assuring the safety and quality of plant operations and
activities.
. . ,* ' "- :* .. * .... . .,, .*
--~ * ... ***-
' -.
'* Y ***.*.
.. ---, ... -.:** .
24
The previous SALP rated the Assurance of Quality functional area as Category 2
with an improving trend.
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 department.
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 timeliness.
During this assessment period, PSE&G did a good job of addressing technical
issues in a straightforward manner.
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 conditions.
After an acceptable HPCI overspeed test, the test was
repeated to confirm acceptability.
When a test engineer raised concerns
regarding the orientation of isolation valves in primary containment
ventilation* lines, the concern was expeditiously ra*ised to the plant
management level and corrective actions were initiated. These efforts
demonstrated a conservative, safety conscious approach to these issues.
PSE&G 1 s adherence to the concept of personal accountability was most
noticeable when observing the Senior Nuclear Shift Supervisors (the
Seniors"), the SRO licensed operators held accountable for plant operations
on each operating shift.
The Seniors ensured that they concurred with
decisions, such as technical specification interpretations, the acceptability
of equi pm_ent being returned to service, and courses of action.
Each morning,
the. department.managers attended a meeting ruil.by the Senior to discuss plant
status and plans~ which reinforced the Senior's responsibility and provided
the opportunity for him to have department managers address his concerns.
The
meeting provided ready accessibility from the operating crews to upper and
middle level management, as well as be-ing a* vehicle that quickly involved
engineering talent in operational problems.
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 errors. These errors have had minor safety significance
and have been properly corrected.
The errors were variously caused by
technician error, inadequate procedure review, poor work practices, or a loss
of control of equipment.
Further, the errors affected a broad cross section
of the plant activities, including post-maintenance testing, workmanship, and
management oversight.
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, etc.
- : .... 7.-~ :::..,.-**_._
.-:~ ... -** _.
.* _(.;.:-*-.** <~ -* *****
.-* .......
-.
-:-:'_:___~_-**-*~
., .. * ..
- -. *.**
25
PSE&G has initiated the Human Performance Evaluation System (HPES), a detailed
analysis method for determining root causes in incidents involving personnel
errors. This analysis technique is intended to provide a thorough, innovative
analysis of personnel errors.
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 representatives.
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 Letter.
Good problem identification occurred both from within and from outside each
organizational element.
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 differential.
Incident Reports continued to be used to identify and resolve plant problems
and off-normal events and for tracking corrective actions to completion.
Hope
Creek had 170 Incident Reports in 1988, 36 of which were reportable to the
NRC.
PSE&G continued to analyze and trend the Incident Reports; their
analyses demonstrated a steadily decreasing Incident Report frequency.
The Station Operations Review Committee (SORC) was composed of department
managers and provided consistent, effective review of significant plant
issues, i-ncluding design changes, post-trip reviews, reportable events, and
stat i*on-wide procedures.
During the opt i ca 1 i so 1 a tor failure, the SORC met
during the~night to review the course of action before its implementation, a
good indication of the SORC's role.
The Quality Assurance* Department, the Onsite Safety Review Group, and the
Offsite Safety Review Group provided effective, independent review of plant
activities.
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 problems.
As noted in the
individual functional.areas, the quality of auditing improved and provided an
effective, independent review of plant programs and activities.
Procurement
and receipt inspection were effective.
Station QA involvement in IS! and startup testing was apparent.
In the !SI
area QA performed surveillance of in-progress !SI contractor activities,
in-house reviews of contractor !SI procedures and audits at the contractor
facilities.
QA performed many surveillance activities during the post-
refueling startup testing program.
Sixteen licensing actions (amendments, relief requests, exemptions, etc) were
processed.
The qu_ality of the technical evaluations was _generally good, .
.i. *. ,-
.,
w
_,.,.
26
indicating that PSE&G has a general understanding of the technical issues, is
aware of and participates in industry groups 9 and uses acceptable approaches
to problem solutions. Submittals generally reflected good planning and
effective assignment of priorities.
PSE&G 1 s responses to requests for
additional information or necessary corrections were usually prompt and well
handled.
The one exception dealt with a license change request concerning the
Filtration, Recirculation, and Ventilation System.
There was one instance of
an incomplete license change request dealing with an amendment to the
Technical Specification surveillance test intervals and allowable outage ti~es
for the reactor protection system.
These are viewed as exceptions to an
otherwise effective program.
The supplemental information was submitted
promptly and correctly.
PSE&G's response to regulatory initiatives (i.e. Generic Letters, Bulletins
and a TMI Action Plan update request) has been timely and complete.
Frequent
communications indicate that they commence work on their responses sufficiently
in advance that they are able to meet commitment dates without requesting
extensions.
In summary, the safety conscious approach.instilled by p~ant management and
exercised by Hrpe Creek personnel was commendable.
The personnel errors which
occurred in all functional* areas need continued management attention.
Problem
identification was excellent, and problems were promptly addressed and
corrected.
PSE&G licensing activities were generally complP.te and timely.
IV.G.2
IV.G.3
Performance Rating
Category 2; . I_mprov.i ng .
Recommendations
None
-- --
.
"';*~: -*. --*
.. *.* ..
-
.'._*-~-* . . *.
,*
27
SUPPORTING DATA AND SUMMARY
A.
Enforcement Activitl
Number of Violations bl Severitl Level
Functional Area
v
IV
III II
I
Dev.
Total
-
-
Plant Operations
2
2
Radiological Controls
Maintenance/Surveillance
2
1
3
0
Security
0
Engineering/Technical
1
2
3
Support
Safety Assessment/Quality
1
1
Verification
Other
l*
l*
Totals
1
7
1
0
0
1
10
A Severity Leve 1 III violation without a civil penalty was issued for
discrimination in 1985 by Bogan (PSE&G cont~actor) against an employee
for raising* safety concerns.
B.
Inspection Hour Summary*
Annualized
Actual
Hours_
Percent
Plant Operations
1486
1157
37% -
Radiological Control~
452
352
11%
Maintenance/Surveillance*
1143
890
29%
136
106
3%
Security
222
173
5%
Engineering/Technical Support 382
297
10%
Safety Assessment/Quality
186
145
5%
Verification
Totals
4007
3120
100%
- .* -.*-:;-****
~-*_.:
- i:.__.*:*;*~
~*-*~*~~*~-**~*,* ***-~-
...
J,.)
_,
.. *.**
28
c.
Licensee Event Re~ort Causal Anal~sis
Functional Area
A
B c
D
E x
Total
Operations
7
7
Radiological Controls
2
2
Maintenance/Surveillance
15
1
13
29
Security
2
2
Engineering/Technical Support
4
4
8
Safety Assessment/Quality
Verification
Totals
30
4
1
13
48
This analysis includes LERs 88-02 through 89-11 and two safeguards LERs.
Cause Codes*
TyQe of Events
A.
Personne 1 Error. . . . . . . . . .
~O
Poor judgement
-
8
Lack of knowledge/training -
6
_Attention to detail
- 16
B.
Des.; gn/Man/Constr ./Install
4
C.
External Cause ...
D.
Defective Procedure.
1
E.
Component Fa i 1 ure.
13
X.
. Other.
. ...
-
Total.
48
- Root causes assessed by the.SALP Board may differ from those listed in the
LER.
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 50.6
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
vintage.
Clearly, the above causal analysis shows that personnel errors remained the
major contributor to reportable events.
PSE&G'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 er~or. These
errors caused at least half of the events in each functional area and involved
< *.* .:**> .*
- ~
,.
-
.. *. *
- .,_ **';;
r
- "-
- , <.¥" '.
~ -. '
- **
. . ' . . . .
- .: ..... , .-
29
six violations of Technical Specifications (all PSE&G identified and only one
cited).
p*sE&G analyses, including the Human Performance Evaluation System
(HPES), have not identified any common root causes for the personnel errors.
Personne-1 at. various working lev.els were involved, from technicians to procedure
writers to engineers to supervisory licensed operators.
The next significant causal factor was component failure.
Review of these
failures did not determine any shortcomings in the preventive maintenance
program,
.
I
'
-
. ~ .. :
.. *
' ' :
- .
~ ** ..
.*.: .. -*
-*.
- .
- .... _ ........
- -
""
"J1. "*'
Attachment 1
SALP CRITERIA
Licensee performance is assessed in selected functional areas, depending on
whether the facility is in a construction, or operational phase.
Functional
areas normally represent areas significant to nuclear safety and the
environment.
Some functional areas may not be assessed because of little or
no licensee activities or lack of meaningful observations.
Special areas may
be added to highlight significant observations.
The following eval~ation criteria were used, as applicable, to assess each
functional area:
1.
Assurance of quality, including management involvement and control;
2.
- Approach to. resolution of technical issues from a safety standpoint;
3.
Responsiveness to NRC initiatives;
4.
Enforcement history;
5.
Operational and construction events (including response to, analyses of,
reporting of, and corrective actions for);
6.
Staffing (including management); and
. .
. . .
.
7.
Effecti¥eness of trai~ing and qualification: program.
On the basis of the NRC assessment, each functional area evaluated is rated
according to three performance categories.
The definitions of these
performance categories are:
Category* l:
Licensee management attention and involvement are evident and
pl ace emphasis on superior* performance of nuclear safety or safeguards
activities, with the resulting performance substantially exceeding regulatory
requirements.
Licensee resources are ample and effectively used so that a
high level of plant and personnel performance is being achieved.
Reduced NRC
attention may be appropriate.
Category 2:
Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities is good.
The licensee
has attained a level of performance above that needed to meet regulatory
requirements..
Licensee re::;ources are adequate and reasonably a 11 ocated so
that good plant and personnel performance are being achieved.
NRC attention
should be maintained at normal levels.
- _:**:. ; ':.
- ...
. ...... ' .....
Attachment 1
-2-
Category 3:
Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are not sufficient.
The licensee's performance does not significantly exceed that needed to meet
minimal regulatory requirements.
Licensee.resources appear to be strained or
not effectively used.
NRC attention should be increased above normal levels.
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
trend.
Generally, performance in the latter part of a SALP period is compared
to the performance of the entire period.
Other trends in performance from one
period to the next may also be noted.
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 period.
Declining:
Licensee performance was determined to be declining near the close
of the assessment period and the licensee had not successfully addressed this
pattern.
A trend is assigned only when, in the op1n1on of the SALP Board, the trend is
significant enough to be considered indicative of a likely change in the
performance category in the near future.
For example, a classification of
"Category "2~ Improvi-ng
11 indicates the clear potential for "Category 1
11
performance in the next SALP period.
It should be noted that Category 3 performance, the lowest category,
represents acceptable, although minimally. adequate, safety performance.
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 safety.
Such matters
would be dealt with independently from, and on a more urgent schedule than,
the SALP process.
It should be also noted that the industry continues to be subject to rising
performance expectations.
NRC expect£ each licensee to actively use
- industry-wide and plant-specific operating experience in order to effect
performance improvement.
Thus, a licensee's safety performance would be
expec~ed to show improvem~nt over the years in order to maintain consistent
SALP ratings.
.. -'*~*~
.____,_____:___~_*._
- .. _--:
.__!:_____' *
- *
- .;* ,: * * *
- *'
- ... ~ * ' * .. , ...... ..
...
. .