ML18096A596
| ML18096A596 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 02/27/1992 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18096A593 | List: |
| References | |
| 50-354-90-99, NUDOCS 9203310110 | |
| Download: ML18096A596 (25) | |
See also: IR 05000354/1990099
Text
-.
ENCLOSURE 2
INITIAL. SALP REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
REPORT NO. 50-354/90-99
PUBLIC SERVICE ELECTRIC AND GAS COMPANY
HOPE CREEK GENERATING STATION
ASSESSMENT PERIOD: AUGUST 1, 1990 - DECEMBER 28, 1991
BOARD MEETING DATE: FEBRUARY 27, 1992
TABLE OF CONTENTS
I.
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
II.
SUMMARY OF RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
II.A
Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
II.B
Facility Performance Analysis Summary . . . . . . . . . . . . . . . . . . . . . 4
II.C
Unplanned Shutdowns, Unit Trips and Forced Outages . . . . . . . . . . . .
5
ill
PERFORMANCE ANALYSIS ............ * .... : . . . . . . . . . . . . . . . 7
ill.A Plant Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
ill.B Radiological Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
ill.C Maintenance/Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
11
ill.D Emergency Preparedness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
14
ill.E Security . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
15
ill.F Engineering/Technical Support . . . . . . . . . . . . . . . . . . . . . . . . . .
15
ill.G Safety Assessment/Quality Verification . . . . . . . . . . . . . . . . . . . . .
17
IV.
SITE ACTIVITIES AND EVALUATION CRITERIA . . . . . . . . . . . . . . . .
21
N .A Licensee Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
21
N.B NRC Inspection and Review Activities . . . . . . . . . . . . . . . . . . . . .
21
N. C SALP Evaluation Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
22
I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) is an integrated Nuclear
Regulatory Commission (NRC) staff effort to collect observations and data and to
periodically evaluate licensee performance on the basis of this information. The SALP
process is supplemental to normal regulatory processes used to ensure compliance with NRC
rules and regulations. SALP is to be sufficiently diagnostic to provide a rational basis for
allocating NRC resources and to provide meaningful feedback to the licensee's management
to improve the quality and safety of plant operations.
An NRC SALP Board, composed of the staff members listed below, met on February 27,
1992, to review the collection of performance observations and data and to assess the
licensee's performance at the Hope Creek Generating Station. This assessment was
conducted in accordance with the guidance in NRC Manual Chapter 0516, "Systematic
Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is
provided in Section N. C of this report.
This report is the NRC's assessment of the licensee's safety performance at the Hope Creek
Generating Station for the period August 1, 1990 to December 28, 1991.
The SALP Board was composed of:
Chairman:
C. W. Hehl, Director, Division of Reactor Projects (DRP), Region I (RI)
Members:
T. P. Johnson, Senior Resident Inspector, Salem/Hope Creek, RI
S. Dembek, Project Manager (Hope Creek), Office of Nuclear Reactor Regulation (NRR)
C. L. Miller, Director, Project Directorate I-2, NRR
A. R. Blough, Chief, Projects Branch No. 2, DRP, RI
M. W. Hodges, Director, Division of Reactor Safety (DRS), RI
R. W. Cooper, Deputy Director, Division of Radiation Safety and Safeguards (DRSS), RI
Others in Attendance:
J. R. White, Chief, Reactor Projects Section 2A, DRP, RI
H. K. Lathrop, Resident Inspector, Salem/Hope Creek, RI
S. M. Pindale, Resident Inspector, Salem/Hope Creek, RI
B. C. Westreich, Reactor Engineer, DRP, RI
I. B. Moghissi, Reactor Engineer Intern (Salem), NRR
J. C. Stone, Project Manager (Salem), NRR
M. J. Davis, Performance Evaluator, Performance & Quality Evaluation Branch, NRR
L. S. Cheung, Senior Reactor Engineer, Electrical Section, DRS, RI
2
Others in Attendance (continued)
R. J. Paolino, Lead Reactor Engineer, Electrical Section, DRS, RI
D. L. Caphton, Senior Technical Reviewer, DRS, RI
W. J. Pasciak, Chief, Facilities Radiation Protection Section, (FRPS), DRSS, RI
R. L. Nimitz, Senior Radiation Specialist, FRPS, DRSS, RI
J. C. Jang, Senior Radiation Specialist, Effluents Radiation Protection Section, DRSS, RI
C. Z. Gordon, Senior Emergency Preparedness (EP) Specialist, EP Section, DRSS, RI
D. F. Limroth, Senior Reactor Engineer, Safeguards Section, DRSS, RI
3
II.
SUMMARY OF RESULTS
II.A
Overview
PSE&G operated the Hope Creek reactor in a manner that demonstrated a high level of
nuclear safety, and exhibited a safety conscious attitude. Strong licensee management
involvement and oversight were evident, and conservatism was displayed in most functional
areas. Strong performance was also noted during Hope Creek's third refueling outage. Self-
assessment, corrective action and root cause analysis programs were maintained at a strong
and effective level. As a result, plant operations, radiolOgical controls, emergency
preparedness, security, and safety assessment/quality verification (SA/QV) maintained a
superior level of performance. However, relative to SA/QV, the SALP Board did express
some reservation due to instances of management inattention and poor communications that
affected the quality of licensee response to certain generic issues (motor operated valves and
station blackout rule). Personnel errors continued to persist in nearly all functional areas,
but appeared to be on the decline.
Licensee attention to the maintenance/surveillance area has resulted in some improvement.
However, a Category 2 with an improving trend was once again assigned. The SALP Board
determined that performance deficiencies in the maintenance/ surveillance area and
shortcomings associated with spare parts/material procurement prevented this functional area
from fully achieving anticipated improvements.
The level of performance in the engineering/technical support area declined during this
assessment period. Significant weaknesses were noted relative to engineering's development
and response to the motor operated valve program. This was indicative of a lack of
management involvement and oversight, and miscommunication and poor attention to detail
on the part of engineering personnel. Additional weaknesses were noted relative to other ..
engineering support activities. While these deficiencies existed, some improvements have
been made in spare parts availability and material procurement. Plant operations and
maintenance were well supported by the onsite and corporate engineering staffs. Corrective
actions for engineering-related deficiencies were generally timely and effective.
Overall, individual performance and supervisory involvement in the field was very good,
though some personnel errors were apparent in most functional areas. Personnel errors also
contributed to reactor trips, but effective management attention appears to be producing an
improving trend as evidenced by performance at the end of this SALP period.
...
4
11.B
Facility Performance Analysis Summary
1.
2.
3.
4.
5.
6.
7.
Functional
Area
Plant Operations
Radiological Controls
Maintenance/
Surveillance
Emergency
Preparedness
Security
Engineering/
Technical Support
Safety Assessment/
Quality Verification
Previous Assessment Period:
Rating, Trend
Last Period
1
1
2, Improving
1
1
1
1
Rating, Trend
This Period
1
1
2, Improving
1
1
2
1
May 1, 1989 through July 31, '1990
Present Assessment Period: August 1, 1990 through December 28, 1991
~' .
5
11.C
Unplanned Shutdowns, Unit Trips and Forced Outages
1.
11/4/90
Power Level Root Cause
100%
Personnel error/
Design
Functional Area
- Maintenance/
Surveillance
The reactor scrammed from high power due to the closure of one main steam isolation valve
(MSIV) when the MSIV' s instrument gas line sheared at the instrument block. The gas line
had been improperly connected after valve maintenance. This combined with a poor design
resulted in vibration induced fatigue cracking of the line and MSIV closure.
2.
11/17/90
100%
Component failure/
Safety Assessment/
incomplete root
Quality Verification
cause
The reactor scrammed following a main turbine trip due to high moisture separator level
during surveillance testing of the combined intermediate valves. Licensee root cause analysis
for a similar trip occurring on January 6, 1990, was incomplete. A failed check valve on the
normal drain line allowed backflow to the moisture separator during testing.
3.
2/19/91
24%
Component failure
NI A
The reactor scrammed on lbw water level during startup when the feedwater level control
valve failed closed. A relay in the control circuitry failed, closing the startup level control
valve. Level decreased to the scram setpoint before operators could respond to the
condition.
4.
2/23/91
24%
Component failure/
NI A
incomplete vendor
information
An unplanned shutdown occurred due to hydrogen leakage from the main generator. Vendor
modifications to the No. 9 hydrogen seal were not communicated to the licensee. Once
installed, the seal failed.
\\
5.
5/7/91
100%
6
Personnel error/
Design
Maintenance/
Surveillance
The reactor scrammed on low water level during surveillance testing of the f eedwater level
control (FWLC) system by a maintenance I&C technician. A personnel error due to lack of
attention to detail caused the FWLC to sense a false high level resulting in reactor feedwater
pump response to lower actual level. A contributing cause was design of cabinet such that
leads had to be lifted inside. The licensee had previously identified this issue and had
initiated a design change; however, it had not been completed prior to the scram.
l.
7
ill
PERFORMANCE ANALYSIS
ill.A Plant Operations
III.A. I
Analysis
The previous SALP rated Hope-Creek operations as Category 1. That assessment concluded
that the Hope Creek reactor was operated skillfully and in a safety conscious manner.
Reactor operator error contributed to one of four reactor scrams. Strong management and
supervisory oversight and involvement occurred at all levels from the senior reactor operator
through the station general manager. An aggressive approach by management was effective
in reducing the number of personnel errors: Senior reactor operator failure rate during
licensing and requalification exams was higher than normal.
During this assessment period, the reactor was operated in a manner that demonstrated a
nuclear safety conscious attitude. Operators competently performed their duties during unit
startups, shutdowns and transients. There were four reactor scrams during the period, but
none were the result of operator error. Operator response to reactor scrams and plant
transients was commendable. In several instances, prompt actions by operators minimized
plant transients and averted the necessity for reactor scrams due to a lightning strike event, a
runback of the recirculation pumps event, and reactor feedwater and condensate pump trips.
The five operating shifts are effectively staffed as each has three Senior Reactor Operator
(SRO) and three Reactor Operator (RO) licensed individuals (one above Technical
Specification requirements). Two separate SRO licensed individuals supervise the work
control group during regular hours. There are a total of 41 licensed operators, including 31
on shift, and 10 in staff and training positions.
The licensed reactor operator training programs for Hope Creek were well developed,
implemented, and strongly supported by management. Licensed operator initial and
requalification examinations have shown that candidates were well prepared. Increased
management attention was effective in reducing exam failures. As a result, the candidates
performed well during examinations. Facilities used for training were excellent. During
examinations, the operators exhibited good administrative knowledge, good knowledge of and
familiarity with plant systems and components, good understanding and interpretation of
annunciators and alarm signals, and the ability to quickly and accurately diagnose the events
or conditions based on signals or other instrument readings. However, results of an initial
examination near the end of the period indicated a higher than expected number of candidate
failures. Non-licensed operator training was found to be performed well.
Strong plant management oversight and attention to operations were evident on a daily basis.
An operational perspective of plant problems and work prioritization was well understood
- .
8
and was enhanced by daily meetings. Examples included scram followup, actions associated
with a fuel pin leak, and the identification and diagnosis of increasing drywell unidentified
leak rate.
Licensed operators' plant awareness, safety perspective, and professional control room
demeanor were consistently evident. Plant operations were well supported by detailed
procedures.
Procedural adherence was very good. Shift turnovers were formal and
included thorough briefings of the relief crew. Control room access was controlled, and
activities were limited to those directly related to plant operations. Aggressive management
attention has resulted in significant reductions in the number of lit annunciators. The use of
overtime was properly controlled. Good performance of non-licensed equipment operators
was noted during observations made on plant tours, and during equipment testing and
operation. The licensee was successful in keeping operations department personnel errors
low. This was particularly evident during the refueling outage.
Overall, the licensee's implementation of the Emergency Operating Procedure (BOP)
program has functioned well. EOPs have been improved with technical adequacy issues
being satisfactorily resolved. Implementation of the current EOPs has been performed in a
thorough manner. Continued BOP administrative improvements are in process.
A higher than expected number of automatic scrams has continued for several years. The
licensee was very concerned about these scrams and embarked on an independent,
comprehensive scram review in order to identify common causal factors and establish
corrective actions. This review was thorough. Short term results appeared to be successful
as the unit operated continually for seven and one-half months at the end of the period. Two
scrams occurred in 1991.
Plant housekeeping has continued to improve during the period. Plant area painting, the ..
assignment of housekeeping area responsibilities, and management focus and attention have
been effective in achieving this level of housekeeping.
The overall fire protection program was effective. Dedicated fire protection personnel
performed well and were knowledgeable, which demonstrated an effective training program.
The fire brigade was staffed by the Site Protection group personnel, which minimized the
reliance on operators to respond to fire and first aid emergencies. Appropriate operator
involvement and interface in fire emergencies were provided. Overall, plant and site
management aggressively supported the fire protection program.
Hope Creek conducted its third refueling outage during the period. Outage preparations
were excellent. The licensee employed many lessons learned from the previous post
refueling outage critique, resulting in an effectively conducted outage, despite significant
emergent work. Refueling activities, including reactor core offload, the subsequent reload,
..
9
and fuel sipping, were effectively controlled. The unit was returned to service from its third
refueling outage in a safe and effective manner. Pre-startup activities, unit startup and power
ascension were well planned and executed.
Summary
The Hope Creek reactor was operated conservatively with nuclear safety as the top priority.
Operator errors remained low; however, unplanned automatic reactor scrams continued to be
a concern. Strong management and supervisory oversight of and involvement in operations
were evident. The licensee conducted its third refueling outage effectively. An effective
training program was noted as evidenced by exam results and operator performance during
routine and transient events. However, pobr performance was noted during an initial exam
given at the end of the period.
ill.A.2
Performance Rating: Category 1
ID.B Radiological Controls
ill.B.1
Analysis
The previous SALP report rated radiological controls as Category 1. , Program strengths
included: good management involvement, effective internal review processes such as quality
assurance audits and surveillances, good resolution of technical issues, and good staffing
levels. No weaknesses were noted.
During the current assessment period, the level of management involvement was excellent.
Managers actively observed ongoing work activities, identified problems were effectively"
corrected using the formal Radiological Occurrence Reporting system, and internal self-
assessments, audits and surveillances continued to be used effectively to assure quality in the
Hope Creek radiological control programs.
The level and quality of staffing in the area of radiation protection (RP) remained high
throughout this period. A new, appropriately qualified Radiation Protection Manager (RPM)
was .appointed during this assessment period, and the level and quality of staffing of RP
technicians continued to be excellent. Although RP technicians met appropriate qualification
requirements, there was a need to clearly define types of work experience acceptable for RP
technician qualification purposes.
The RP training program continued to be excellent. For example, RP supervisors received
annual continuing training which included systems training; nuclear codes, standards, and
regulatory concerns; and root cause analysis. The RP technician continuing training also
10
remained excellent, and included plant systems training. An area for improvement was the
system training programs, which contained little on expected radiological conditions expected
during various system operating modes.
The licensee implemented an aggressive ALARA program. Excellent exposure reduction
efforts were undertaken during the refueling outage. For example, an elaborate automated
system for removal, maintenance and re-installation of the control rod drive mechanisms was
used. In addition, audio/visual and remote reading dosimetry were effectively utilized to
control work under the vessel to reduce unnecessary personnel exposure. The licensee was
sensitive to any opportunity to reduce personnel exposure, as evidenced by removal of a
carbon steel reactor water clean-up line located in the overhead of a Reactor Building
corridor. The line exhibited contact dose rates of 800 mR/hr and required shielding to allow
personnel free access to the corridor. Licensee efforts to reduce personnel radiation
exposure during surveillance and in-service inspection (ISI) activities continued to be
effective as evidenced by excellent water chemistry control and the use of zinc injection.
Overall control of work in -radiologically controlled areas typically was excellent.
Late in the period, an evaluation of the on-site dosimetry processing laboratory by personnel
from the National Voluntary Laboratory Accreditation Program (NVLAP) identified a
number of significant weaknesses in the management of the PSE&G processing laboratory.
The licensee immediately suspended processing of dosimeters and implemented extensive
corrective actions to improve processing. NRC reviews at the end of the period indicated
corrective actions were on-going and dosimetry system performance met applicable
performance standards. The NRC's review of this matter found that the weaknesses
- stemmed from the loss of key supervisory and management personnel and a lack of
understanding, by replacement personnel, of regulatory aspects associated with maintaining
an accredited personnel dosimetry program. Although no decrease in the quality of
dosimetry processing information was identified, this matter indicated weak understanding of
program and personnel qualification requirements by management.
The solid radwaste/transportation program continued to be strong. The organization and
staffing exhibited stability and strength. The unique asphalt solidification system continued
to operate well, and the on-site storage of radwaste was minimal. The quality oversight of
radwaste processing was of good technical depth and scope, with an appropriate level of
surveillance of the various radioactive material shipments. For example, QC surveillances .
identified calculational errors, in some radioactive shipments, that were corrected
immediately. The licensee's training program continued to provide excellent radwaste and
transportation content.
The licensee continued to conduct an effective Radiological Environmental Monitoring
Program (REMP). The meteorological monitoring program was sufficient in ensuring that
meteorological instruments were operable, maintained, and calibrated. Furthermore, the
meteorological data were obtainable from various locations on and off site. An effective QC
program was in place to assure the quality of REMP sample analyses. The audits performed
...
11
by the Quality Assurance Department were thorough and of technical depth to assess the
REMP.
The licensee continued to conduct excellent radioactive liquid and gaseous effluent control
programs. Outstanding calibration techniques for effluent/process radiation monitoring
systems were employed. The Nuclear Training Department conducted an excellent training
program for Chemistry/Radiation Protection technicians who were actually performing
effluent processes.
The licensee summarized and reported historical radioactive liquid and gaseous release data
since the start of commercial operations for trending purposes in its semiannual report. Such
reporting was a noteworthy licensee initiative.
Late in the period, the licensee identified low level contamination in the on-site sewage
system. The licensee isolated the contaminated sewage and implemented appropriate
corrective actions to preclude recurrence, reflecting an excellent understanding of this
technical issue. Air cleaning systems were well maintained and tested.
Summary
PSE&G continued to maintain and implement an effective radiological controls program.
Managers effectively controlled radiological work. Staffing levels continued to be excellent.
The ALARA program continued to demonstrate management's commitmentto reducing
personnel exposure and maintaining a low source term within the plant. The licensee
implemented an effective environmental and effluent controls program as well as an effective
radwaste processing, handling and shipping program.
III.B.2
Performance Rating: Category 1
ill.C Maintenance/Surveillance
III.C.l
Analysis
The last SALP rated the Hope Creek maintenance/surveillance functional area as a Category.
2, improving. That assessment concluded that the station had successful maintenance and
surveillance programs which were adequately scheduled, planned and implemented. Program
strengths included effective management, a well-trained and experienced work force and
good procedures. Weaknesses were noted in the procurement process and post-maintenance
system restoration. Personnel errors continued to contribute to noted plant events and
..
12
Maintenance:
The Hope Creek maintenance program was well planned, staffed and organized, and
demonstrated strong performance in this area, including improved adherence to procedures
and appropriate oversight of maintenance activities. Management at all levels was noted to .. *.
be directly and intimately involved in the maintenance program. During the period, the
licensee implemented the use of fixed shift work coverage, leveling work activity impact and
improving scheduling efficiency and accuracy. Pre-outage system walkdowns were initiated
to improve outage efficiency. Planned maintenance outages of safety-related equipment were
screened by plant management to assure that a net safety benefit was provided. These
initiatives have been effective and were positive indicators of management's safety-conscious
and detailed control of plant maintenance. *Safety-related equipment availability was high, as
indicated by the licensee's trending data.
The most significant strength of the maintenance organization continued to be its stable and
well-trained staff. Maintenance training received strong management support, with the
training center providing extensive electrical and mechanical training facilities. Line
supervision provided good work direction. . Adherence to procedures and attention to detail
continued to improve, as evidenced by a reduced amount of rework and fewer personnel
errors. However, a small number of instances were noted where attention to detail was
poor. For example, a number of minor post maintenance material deficiencies existed on the
standby liquid control system, and required preventive maintenance was not performed on a
spare core spray pump motor after rewinding. Overall, the maintenance staff was very
knowledgeable in their respective areas of responsibility.
Management dedicated additional resources to address weaknesses noted in maintenance
support activities. The material and procurement groups were reorganized and placed under
the direction of a general manager. A new warehouse, into which central receiving and the
numerous on-site storage areas would be consolidated, was completed late in the period.
Maintenance facilities were generally well equipped, maintained and controlled. Material
control was enhanced by the implementation of the computerized warehouse automated
material management system (WAMMS). However, spare parts availability and
obsolescence continued to impact the timeliness of some maintenance activities. The number
of delayed routine maintenance requests due to parts problems decreased over the period.
During the assessment period, Hope Creek completed one refueling outage and conducted
several forced outages. Maintenance planning and outage organizations were noted strengths
during the third refueling outage from December 1990 to February 1991. Virtually all pre-
planned activities were completed with less than two percent rework, an indication that
management had effectively communicated their expectations regarding attention to detail and
work performance quality. Significant emergent work on the recirculation system piping
welds was completed with no adverse impact on the overall outage. Control rod drive
maintenance activities and forced outage repairs to a leaking hydrogen seal on the main
generator in late February 1991 were well-planned and executed. In general, station
".
13
housekeeping was very good. However, instances were noted where post-maintenance
system restoration and cleanup were poor. Management was aggressive in addressing these
issues and improvements in these areas were noted in the latter half of the period.
Maintenance contributed to one of four scrams during the period. In November 1990, the
reactor scrammed after a main steam isolation valve closed when its instrument gas line
sheared at the instrument block. This line had been incorrectly reinstalled following
maintenance during a previous assessment period. However, the design of the gas supply
lines and their susceptibility to vibration were also causal factors.
Notwithstanding the minor weaknesses identified in this area, the licensee has managed and
performed a large number of maintenance activities in an effective and safety conscious
manner.
Surveillance:
The Hope Creek surveillance program was effectively and conservatively managed and
implemented throughout the assessment period. Surveillance tests were effectively scheduled ..
and tracked through the managed maintenance information system (MMIS), which
coordinated the performance of the affected departments. The cooperative interaction of the
groups involved continued as a strength in the surveillance program.
Surveillance procedures were well written, accurate and complete. Procedural enhancements
were made in a timely manner, however, a weakness was identified in the procedure revision
process where needed changes were not always incorporated in all related procedures. The
licensee had implemented a policy whereby most surveillance activities which affected safety
system redundancy or initiation were performed on the night shift, but only between the
months of May and September when electrical load demands were high. During this
assessment period, that policy was extended to a year-round basis. As a complement to the
fixed shift work schedule, this policy contributed significantly to reducing stress levels in the
control room and to reduction in the number of late or missed surveillances.
The number of surveillance related incidents, while still high, continued to decrease from the
two previous assessment periods. Corrective actions taken to reduce personnel errors, the
predominant cause of such incidents, have been generally effective, particularly during the .
second half of this period: For example, the introduction of plastic spring clips to assist in
properly locating and identifying relay contacts, terminal strip points and cabling in mid 1991
aided in reducing the misidentification of components. No such events occurred during the
latter part of the period. Additionally, there were no missed maintenance or I&C
surveillances during 1991. While one scram occurring during this period was attributed to
personnel error during surveillance testing of the feedwater level control system, an
inadequate cabinet design contributed to the event. The licensee had addressed the issue of
cabinet scram sensitivity, but the appropriate design modification, to install external test
boxes, had not yet been implemented for this particular cabinet.
14.
The inservice inspection (ISi) program at Hope Creek continued to be well planned and
implemented. Licensee personnel involved in the program were noted to be knowledgeable
and thorough in the performance of their inspection activities including ultrasonic testing of
intragranular stress corrosion cracking (IGSCC) susceptible piping. In particular, the
licensee's investigation into indications discovered in recirculation piping welds during the -
third refueling outage, including the development of an enhanced testing technique, and the
resultant corrective actions, were commendable. The licensee had implemented an effective
program, based on industry standards, to assess erosion/corrosion in various plant
components and piping. No significant thinning was detected in over eighty areas inspected
during the third refueling outage.
Summary
The Hope Creek station has continued implementation of successful and effective
maintenance and surveillance programs. These programs have been well scheduled, planned
and managed. Program strengths included management involvement, a stable and well-
trained staff and well-written procedures.
Management efforts have been successful in
reducing the number of personnel error related events. Weaknesses included. occasional
lapses in attention to detail, material procurement, and continued, albeit reduced, personnel
error initiated plant events.
III.C.2
Performance Rating: Category 2
Trend: Improving
III.C.3
SALP Board Comment
While progress has been made on resolving a number of issues in this area, the Board noted
the continuing number of.personnel errors, especially in the surveillance area, and persistent
spare-parts related backlogs were issues requiring continued close management attention.
III.D.1
Analysis
The Emergency Preparedness for Artificial Island covers both Hope Creek and Salem
Generating Stations, therefore the assessment of emergency preparedness is a combined
evaluation.
III.D.2
Performance Rating: Category 1
15
ID.E Security
III.E.1
Analysis
The Security Plan for Artificial Island covers both Hope Creek and Salem Generating .
Stations, therefore the assessment of security is a combined evaluation.
III.E.2
Performance Rating: Category 1
ID.F Engineering/Technical Support
III.F.l
Analysis
The previous SALP rated Engineering and Technical Support as Category 1. The previous
assessment indicated that improvements in the performance of corporate engineering were
observed. The overall experience levels within the onsite system engineering group were
also improved. No significant weaknesses were observed during the last SALP period.
Engineering and Technical Support for Hope Creek was provided by corporate engineering,
lmown as Engineering and Plant Betterment (E&PB), and the onsite system engineering
group. E&PB handled major engineering efforts such as plant modifications, and design
bases reconstitution. The onsite system engineering group supported operations,
maintenance, testing and minor design change activities. E&PB is well staffed with
experienced personnel in various engineering disciplines.
The onsite system engineering group was well staffed with experienced and knowledgeable
personnel. The licensee continued to implement their pipeline program to train new system
engineers. Most system engineers have received formal root cause training. Evidence of
good system engineer support for station activities and a good safety perspective include:
(1) identification and followup of an ultimate heat sink related design deficiency;
(2) maintenance trending; (3) disposition for degraded equipment; (4) procedure generation;
(5) identification of and corrective actions for control rod scram time calculation errors; and
(6) disposition of reactor recirculation instrument line leakage.
The licensee has been generally aggressive in identifying and following up on engineering
related deficiencies. The corrective actions taken as a result of a recirculation system pipe
weld crack is a good example. The corrective actions involved state-of-the-art equipment
and techniques and the use of recognized industry experts for analysis. These actions, along
with a metallurgical analysis of samples obtained from the cracked welds effectively resolved
the problems and surpassed ASME Section XI Code requirements. In contrast, the licensee
was slow to properly identify the root cause and implement appropriate corrective actions
after a filtration, recirculation and ventilation system (FRVS) heater fuse failure.*
16
Technical support for refueling and maintenance outage periods, and for post outage recovery
activities was noted to be effective. Both E&PB and onsite system engineering participated
in and interfaced with the outage organization on a daily basis. The system engineering
group provided strong support during reactor startup and power ascension testing.
On schedule progress was observed in the Hope Creek Configuration Baseline Documents
(CBD) project. The CBD project involves the design basis reconstitution of 146 systems and
structures for Hope Creek. Twenty four systems were completed during this SALP period.
The CBD project has delivered quality products. The licensee also implemented the
computerized Document Information Management System (DIMS) to complement the hard
copy CBD for the completed sy~tems.
E&PB worked well with onsite system engineering. The establishment of an E&PB small
design change project group, coupled with an effective plant modification design change
process, has been effective in reducing the system engineering group workload. This has
resulted in increased system engineering presence in the field. However, significant
weaknesses were found in engineering's development of the safety related motor operated
valve (MOY) program in response to Generic Letter 89-10. Several recommended actions of
the generic letter were not properly addressed. For example, due to a lack of management
attention and poor communications, the development of a program to address safety related
MOYs was slow and well behind the committed schedule; switch setpoint values for safety
related MOYs were not properly communicated to the maintenance department from the
engineering department, and the switches were set improperly; and known industry issues,
such as diagnostics inaccuracies, differential pressure testing, trending of failures, and
periodic verification of MOY capability were not adequately addressed in the program.
Improvements were noted in the engineering procurement activities. Until 1990, the licensee
had no formal procedure for controlling the commercial grade item dedication program. The
Hope Creek program was based on the EPRI guidelines, was fully implemented, and worked
very well. However, spare parts deficiencies, involving documentation and planning,
continued, including: (1) inadequate supply of replacement parts resulting in the seismic
monitoring system being out of service during a seismic event; and (2) environmental
qualification inadequacies for nuclear instrumentation system detector connectors.
Engineering's Self-Assessment Program emphasized the key performance elements to the
engineering and management personnel. By setting goals and tracking them and by having
upper management support, significant improvements have been achieved in the areas of
overdue item reduction, safety evaluation quality and design change progress timeliness.
- The submittals and supporting analyses for license amendment requests were generally well
written and technically sound with one exception; the incorrect classification of the
suppression pool water temperature instruments (Category 1 vs. Category 2). The need for
NRC additional information requests was infrequent. However, Hope Creek responses to
,,_
.J
17
generic issues were in some cases incomplete or inadequate. For example, the Hope Creek
responses to the Station Blackout Rule (SBR) were determined to be incomplete.
Conclusions that Hope Creek complies with the SBR could not be drawn from the licensee's
submittals. As discussed above, the response to GL 89-10 and its supplements was inferior.
Summary
Hope Creek has been aggressive in identifying and following up on engineering related
deficiencies. The corrective actions taken as a result of the recirculation system pipe weld
crack is a good example. Significant weaknesses in the development of the safety related
MOY program were observed. Weaknesses were also observed in Hope Creek responses to
the Station Blackout Rule, in the initial root cause evaluation associated with the FRVS
heater fuse failures, and in responses to the NRC regarding Generic Letters. Despite these
weaknesses, E&PB and onsite system engineering worked well in providing technical support
to the plant. Improvement in the engineering procurement program was observed however,
some minor problems were noted relative to documentation and planning.
III.F.2
Performance Rating: Category 2
III.F.3
SALP Board Comment
There was a distinct difference in quality between the licensee's responses to generic issues
and its other submittals. The licensee should pay particular attention to improving the
overall quality of its responses to generic issues.
ill.G Safety Assessment/Quality Verification
III.G.l
Analysis
The previous SALP rated Safety Assessment/Quality Verification (SA/QV) as Category 1.
The Hope Creek licensee was commended for having a well run, safety conscious
organization. Management was noted as being involved with the plant on a daily basis, and
for making its safety conscious attitude known throughout the plant. The licensee effectively
identified problem areas and ensured prompt and effective corrective actions. However,
isolated personnel errors continued to be an area meriting additional management attention.
Throughout this period, individual performance was very good. Direct supervision at the site
by first and second line supervisors and comprehensive management oversight of station
activities were strengths. However, personnel errors continued in all functional areas.
Additionally, four automatic scrams from power occurred during this SALP period, including
one attributed to the SA/QV area. The scram attributed to SA/QV was a repeat reactor
scram due to a moisture separator high level induced turbine trip. The licensee review of an
identical scram, in January 1990, did not completely identify all of the causal factors of the
,*
.....
18
event. Otherwise, licensee actions to determine root causes of personnel errors and scram
rates were thorough and aggressive. An independent root cause analysis of the twelve*
- scrams occurring since August 1988 was performed. Management endorsed the report's
findings and implemented a wide range of corrective measures based on the report's
recommendations. No scrams occurred during the second half of the assessment period.
Another exception to this good personnel performance was when chemistry, training and
emergency preparedness personnel failed to adequately follow procedures associated with
post accident sampling system (PASS) operations. Consequently, deficient conditions
involving the operability of the PASS were not documented or corrected promptly.
As mentioned in the Engineering/Technical Support section of this report, the licensee's
amendment and relief requests were generally of high quality, technically sound and
complete. The staff rarely required additional information to evaluate the licensee's
proposal. Although the licensee's amendment requests were generally technically well
written, there have been numerous administrative errors in their submittals during this SALP
period. Two NRC Regional Waivers of Compliance were processed during this SALP
period. One licensee submittal was well written and demonstrated good engineering
practices. However, weaknesses were identified in a second submittal concerning the
replacement of a safety auxiliaries cooling system pump casing relative to the completeness
of the technical information and the safety basis determination. This occurred early in the
period. Additionally, as previously noted in the Engineering/Technical Support section, the
licensee's responses to NRC GL 89-10 Supplement 3 and the Station Blackout Rule were not
technically adequate.
As discussed in the engineering/technical support section, Engineering and Plant Betterment
(E&PB) generally performed well. However, one major exception was a lack of
management attention and oversight regarding the motor operated valve (MOV) program.
Poor communications among plant maintenance, licensing and E&PB personnel were
contributing factors in this poor performance.
The Station Operations Review Committee (SORC) provided consistent and effective review
of significant plant issues, including design changes, post-scram reviews and reportable
events. Following repeated multiple failures of the filtration, recirculation and ventilation
system (FRVS) heater fuses in May and July, 1991, the SORC met on several occasions to
perform an in-depth review of the root causes, safety implications and proposed corrective
actions. While the licensee was not aggressive in its response to the May 1991 fuse problem,
actions taken following the July 1991 event were thorough.and effective.
The licensee's major event review process, the Significant Event Response Team (SERT),
was effective during this period. In addition to the comprehensive scram review, a review of
the November 1990 high moisture separator level scram led to significant enhancements in
19
turbine control valve surveillance testing. Recommendations generated from SERT reviews
were promptly acted upon by management and tracked in the licensee's Action Tracking
System.
The Safety Review Group (SRG) and Station Quality Assurance (SQA) have demonstrated
effective independent reviews of Hope Creek issues. For example, SRG performed a
detailed and effective review of the safety evaluation process. SQA performed a thorough
review of personnel errors and recommended effective corrective actions. Both the SRG and
SQA provided assistance to all SERT efforts, and SRG led and managed the detailed scram
review effort.
The licensee generally took aggressive action to review its reportable events. Licensee Event '
Reports (LERs) were well written and accurate. A large number of the LERs submitted
during this SALP period listed a previous occurrence of a similar reported event (e.g., FRVS
fan automatic starts).
Hope Creek conducted its third refueling outage during the period. Outage preparations
were excellent. The licensee employed many lessons learned from the previous post
refueling outage critique, which resulted in outage completion essentially as scheduled despite
significant emergent work. SQA was effective during all phases of the outage, performing a
large number of performance based surveillance and hold point activities. The continuous
24-hour day coverage provided by SQA was a noted strength, as was management
involvement during all phases of the outage. PSE&G instituted an incentive plan involving
both Hope Creek and Salem personnel in order to increase the focus on plant safety, job
quality and attention to detail. Overall outage performance was very good and no safety
significant concerns were identified.
-
Hope Creek station management, including the General Manager and department heads,
provided effective and safety conscious oversight of station activities on a daily basis. This
was evidenced in daily meetings with the senior nuclear shift supervision and operating crew
and in management accountability meetings. In addition, the General Manager conducted
effective State-of-the-Station meetings twice a year. Corporate management was highly
visible relative to Hope Creek station activities. Operations personnel exhibited a
professional and questioning attitude during the performance of the their duties. A good
safety perspective was noted involving the discovery, evaluation and actions taken when
drywell unidentified leakage significantly increased in September 1990.
Summary
Hope Creek continued to be a well run, safety conscious facility. The licensee's
management of the third refueling outage was a noteworthy strength. The licensee
effectively identified problem areas, and ensured prompt and effective corrective actions.
Individual performance was very good; however, isolated personnel errors continued to be an
-area meriting additional attention. Lack of management attention and poor interdepartmental
20
communications resulted in an inadequate response to the motor operated valve program.
Safety review committees and quality assurance groups provided effective and independent
oversight of activities.
III.G.2
Performance Rating: Category 1
III.G.3
SALP Board Comment
While the Board considered that the licensee, overall, continued to achieve excellent
performance in this area, isolated instances of management inattention and poor
communication contributed to the insufficient quality of PSE&G's responses to generic
communications pertaining to motor operated valves and the station black-out rule. As
expressed in ill.F.3, prompt management attention to this area should prevent performance
decline.
21
IV.
SITE ACTIVITIES AND EVALUATION CRITERIA
IV .A Licensee Activities
The Hope Creek unit began the SALP period operating at full power. The unit automatically
scrammed on November 4, 1990, when one main steam isolation valve inadvertently closed
at full power due to a rupture of the primary containment instrument gas line. The unit then
proceeded to cold shutdown to perform maintenance and followup activities for the reactor
The unit was restarted on November 14, 1990, and the turbine generator was synchronized
on November 15, 1990. On November 17~ 1990, the unit automatically scrammed from
100% power due to a main turbine trip during valve testing. The unit was restarted on
November 18, 1990.
The unit was shutdown on December 26, 1990, to commence the third refueling outage. The
unit restarted from the refueling outage on February 16, 1991. A reactor scram on reactor
water low level from 24% power occurred on February 19, 1991. The unit restarted on
February 21, 1991; however, a shutdown due to excessive generator hydrogen leakage was
performed on February 23, 1991. Restart from this forced outage occurred on March 2,
1991.
On May 7, 1991, the unit automatically scrammed from 100% power due to low water level
caused by a feedwater control malfunction. The unit restarted on May 11, 1991.
Small power reductions were performed throughout the period to perform maintenance and
testing activities. At the end of the SALP period, the unit had operated continuously for 231
days.
IV .B NRC Inspection and Review Activities
Four NRC resident inspectors were assigned to Artificial Island during the assessment
period. NRC team inspections were conducted in the following areas:
Emergency Preparedness Inspection conducted on October 29 through November 2,
1990, to observe the Artificial Island annual exercise.
Training programs team inspection at the Nuclear Training Center on April 1 through
5, 1991.
Motor Operated Valve Inspection conducted at Hope Creek on July 15 through July
19, 1991, to assess licensee response to Generic Letter 89-10.
- ~;
22
IV .C SALP Evaluation 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 in that area.
Special areas may be added to highlight significant observations.
The following evaluation criteria were used, as applicable, to assess each functional area:
1.
Assurance of quality, including management involvement and control;
2.
Approach to the identification and resolution of technical issues from a safety
standpoint;
3.
1Enforcement history;
4.
Operational events (including response to, analysis of, reporting of, and corrective
actions for);
5.
Staffing (including management);
6.
Training and qualification effectiveness;
Based upon the SALP Board assessment, each functional area evaluated is classified into one
- of three performance categories. The definitions of these performance categories are:
Category 1: Licensee management attention to and involvement in nuclear safety or
safeguards activities resulted in a superior level of performance. NRC will consider reduced
levels of inspection effort.
Category 2: Licensee management attention to and involvement in nuclear safety or
safeguards activities resulted in a good level of performance.
NRC will consider
maintaining normal levels of inspection effort.
Category 3: Licensee management attention to and involvement in nuclear safety or
safeguards activities resulted in an acceptable level of performance; however, because of the
NRC's concern that a decrease in performance may approach or reach an unacceptable level,
NRC will consider increased levels of inspection effort.
t
,
I
23
The SALP report may include an appraisal of the performance trend in a functional area for
use as a predictive indicator. Licensee performance during the assessment period is
examined to determine whether a trend exists. Normally, this performance trend would only
be used if both a definite trend is discernable and continuation of the trend would result in a
change in performance rating.
The trend, is used, is defined as:
Improving: Licensee performance was determined to be improving during the assessment
period.
Declining: Licensee performance was determined to be declining during the assessment
period and the licensee had not taken meaningful steps to address this pattern.