ML18100A583
| ML18100A583 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 09/01/1993 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Miltenberger S Public Service Enterprise Group |
| Shared Package | |
| ML18100A584 | List: |
| References | |
| NUDOCS 9309080031 | |
| Download: ML18100A583 (55) | |
See also: IR 05000272/1991099
Text
Docket Nos. 50-272
50-311
50-354
Public Service Electric and Gas Company
ATIN: Mr. Steven E. Miltenberger
I 1993
Vice President and Chief Nuclear Officer
Post Office Box 236
Hancocks Bridge, New Jersey 08038
Gentlemen:
SUBJECT:
INITIAL SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
(SALP) REPORT NOS. 50-272/91-99, 50-311/91-99, AND 50-354/91-99
On July 29, 1993, an NRC SALP Board conducted a review to evaluate the performance of
activities associated with the Salem and Hope Creek Generating Stations for the period
between December 29, 1991 and June 19, 1993. The results of these respective assessments
are documented in the enclosed Initial SALP reports. As previously agreed, we will hold a
. management meeting to discuss these SALP findings on September 17, 1993, at the
Salem/Hope Creek Processing Center. You should be prepared to discuss these assessments
and your plans to improve performance. In accordance with NRC policy, this meeting will
be open for public observation.
During this issessment period, we concluded that activities at the Salem and Hope Creek
Stations have been performed in a safe manner. We noted that the functional areas common
to both stations, i.e., Emergency Preparedness and Security, continued to exhibit excellent
performance. However, we observed a declining trend in Emergency Preparedness,
primarily as a result of your failure to maintain the staffs ability to develop correct
Protective Action Recommendations, as demonstrated during training, drills and exercises.
With respect to the fire protection program, which is also common to both stations, a
weakness was noted in the management oversight of the firewatch program activities,
particularly contractor performance.
Relative to Hope Creek, the overall performance continues to be excellent with strong
management oversight in the functional areas of Operations, Maintenance/Surveillance,
Radiological Controls, and Safety Assessment/Quality Verification. We observed improved
performance of Engineering and Technical Support compared to the last period. The
performance at Hope Creek continues to exhibit strengths in overall operator safety
consciousness, management oversight and control, safety assessment and quality review.
/
\\
Public Service Electric and
Gas Company
2
Relative to the Salem facility, we concluded that your performance during this period was,
good, which was consistent with our previous assessment. We noted that you improved the
performance of Radiological Controls such that the functional area is considered excellent.
However, during this period, the Salem facility had a substantial number of operational
challenges. For example, nine reactor trips occurred, of which six were attributable to a
variety of component failures. Further, during this period, Salem Unit 2 experienced
significant events involving the Overhead Annunciator System and the Rod Control System,
which followed a significant event at the end of the last SALP period involving a turbine-
generator failure.
Additional management attention is warranted to reduce the frequency of operational
challenges at the Salem facility. In a recent meeting, we discussed your plans to further
evaluate the root causes for these events and to ascertain if there were any common
underlying performance issues. We expect that a status of your assessment will be discussed
at our meeting.
Finally, we are concerned with the adequacy and timeliness of PSE&G's management
response to significant events. Our concern is not with your ability to critically evaluate and
assess identified problems, but rather the consistency of your management evaluation and
decision-making process for initiating such actions. We note that once your attention was
focused on evaluating and assessing the issues, your organization performed very
comprehensive and thorough assessments, accomplished excellent root cause analyses, and
determined effective corrective actions. Although we acknowledge your staff initiated and
conducted extremely thorough and comprehensive assessments and root cause evaluations
concerning the performance of contracted firewatches and the morale of security personnel,
examples of such responsiveness are limited.
Upon completion of our discussion of these SALP findings on September 17, 1993, we
request that you provide written comments, including any correction of factual information,
within 20 days of the date of that meeting. The enclosed reports and your responses will be
placed in the NRC Public Document Room.
Your cooperation with us is appreciated.
Sincerely,
Original Sil!n&:f By:-
Ti1omas T. Martin
Thomas T. Martin
Regional Administrator
Public Service Electric and
Gas Company
Enclosures:
3
I.
Salem Generating Station, Initial SALP Report Nos. 50-272/91-99 and 50-311/91-99
2.
Hope Creek Generating Station, Initial SALP Report No. 50-354/91-99
cc w/encls:
J. J. Hagan, Vice President, Nuclear Operations
C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co.
C. Vondra, General Manager - Salem Operations
R. Hovey, General Manager - Hope Creek Operations
F. Thomson, Manager, Licensing and Regulation
R. Swanson, General Manager - QA and Nuclear Safety Review
J. Robb, Director, Joint Owner Affairs
A. Tapert, Program Administrator
R. Fryling, Jr., Esquire
M. Wetterhahn, Esquire
P .J. Curham, Manager, Joint Generation Department,
Atlantic Electric Company
Consumer Advocate, Office of Consumer Advocate
William Conklin, Public Safety Consultant, Lower Alloways Creek Township
K. Abraham, PAO (27)
The Chairman
Commissioner Rogers
Commissioner Remick
Commissioner de Planque
Institute for Nuclear Power Operations (INPO)
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of New Jersey
Public Service Electric and
Gas Company
bee w/encls:
4
Region I Docket Room (with concurrences)
bee via E-Mail:
J. Taylor, EDO
A. Ramey-Smith, DEDO
J. Lieberman, OE
S. Bajwa, NRR/DRIL/RPEB
M. Boyle, NRR
S. Dembek, NRR
J. Stone, NRR
Region I Staff (Refer to SALP Drive)
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OFFICIAL RECORD COPY
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bee w/encls:
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J. Taylor, EDO
D. Wheeler, OEDO
J. Lieberman, OE
S. Bajwa, NRR/DRIL/RPEB
M. Boyle, NRR
S. Dembek, NRR
J. Stone, NRR
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bee via E-Mail:
J. Taylor, EDO
D. Wheeler, OEDO
J. Lieberman, OE
S. Bajwa, NRR/DRIL/RPEB
M. Boyle, NRR
S. Dembek, NRR
J. Stone, NRR
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817193
ENCLOSURE 1
INITIAL DRAFf SALP REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
REPORT NOS 50-272/91-99
50-311/91-99
PUBLIC SERVICE ELECTRIC AND GAS COMPANY
SALEM GENERATING STATION UNITS 1 AND 2
ASSESSMENT PERIOD:
DECEMBER 29, 1991 - JUNE 19, 1993
9309080033 930901
ADOCK 05000272
O
PD~
BOARD MEETING DATE:
JUL y 29' 1993
TABLE OF CONTENTS
I.
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
II.
SUMMARY OF RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
II.A
Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Il.B
Facility Performance Analysis Summary . . . . . . . . . . . . . . . . .
4
Il.C
Unplanned Unit Trips . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
ill.
PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
ill.A
Plant Operations
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
ill.B
Radiological Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
ill.C
Maintenance/Survei11ance . . . . . . . . . . . . . . . . . . . . . . . . .
11
ill.D
Emergency Preparedness . . . . . . . . . . . . . . . . . . . . . . . . .
15
ill.E
Security and Safeguards . . . . . . . . . . . . . . . . . . . . . . . . . .
15
ill.F
Engineering and Technical Support . . . . . . . . . . . . . . . . . . .
15
ill.G
Safety Assessment/Quality Verification . . . . . . . . . . . . . . . . .
18
IV.
SITE ACTIVTI1ES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
22
IV .A
Licensee Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
22
IV .B
NRC Inspection Activities . . . . . . . . . . . . . . . . . . . . . . . . .
23
Attachment: SALP Evaluation Criteria, Performance Categories and Trends
i
I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC
staff effort to collect availab1e observations and data periodical1y, and to eva1uate 1icensee
performance on the basis of this information. The program is supplemental to normal
regulatory processes used to ensure compliance with NRC rules and regulations. It is
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 facilities' performance in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on July 29, 1993,
to review the observations and data on performance, and to assess licensee performance in
accordance with the guidelines in NRC Management Directive 8.6 "Systematic Assessment of
Licensee Performance," dated September 28, 1990. The SALP Evaluation Criteria utilized
by the Board are attached.
This report is a combined assessment for Sa1em Units 1 and 2 for the 18 month period of
December 29, 1991, through June 19, 1993. The Sa1em SALP Board members were:
CHAIRMAN:
W. D. Lanning, Deputy Director, Division of Reactor Projects (DRP), Region I (RI)
MEMBERS:
M. L. Boyle, Acting Director, Project Directorate 1-2,
Office of Nuclear Reactor Regulation (NRR)
C. W. Hehl, Director, Division of Radiation Safety and Safeguards (DRSS)
T. P. Johnson, Senior Resident Inspector, Salem/Hope Creek, RI
J. C. Stone, Project Manager (Salem), NRR
C. L. Miller, Acting Deputy Director, Division of Reactor Safety (DRS)
E. C. Wenzinger, Chief, Projects Branch No. 2, DRP, RI
2
OTHERS IN ATTENDANCE:
J. R. White, Chief, Reactor Projects Section 2A, DRP, RI
T. H. Fish, Resident Inspector, Salem/Hope Creek, RI
S. T. Barr, Resident Inspector, Salem/Hope Creek, RI
J. G. Schoppy, Resident Inspector, Salem/Hope Creek, RI
S. M. Pindale, Resident Inspector, Oyster Creek, RI
H. K. Lathrop, Resident Inspector, Calvert Cliffs, RI
B. J. McDermott, Reactor Engineer, DRP, RI
R. L. Nimitz, Senior Radiation Specialist, FRPS, DRSS, RI
C. Z. Gordon, Senior Emergency Preparedness (EP) Specialist, EP Section, DRSS, RI
S. Dembek, Project Manager (Hope Creek), NRR
R. R. Keimig, Chief, Safeguards Section, DRSS, RI
J. H. Lusher, EP Specialist, DRSS, RI
L. H. Bettenhausen, Chief, Operations Branch, DRS, RI
J. P. Durr, Chief, Engineering Branch, DRS, RI
S. A. Morris, Reactor Engineer, DRP, RI
J. I. Zimmerman, Project Engineer, NRR
M. J. Davis, Performance Evaluator, NRR
R. J. Summers, Project Engineer, DRP, RI
L. S. Cheung, Senior Reactor Engineer, DRS, RI
3
II.
SUMMARY OF RESULTS
Il.A
Overview
On July 29, 1993, the SALP board met to discuss PSE&G's performance at Salem during the
period from December 29, 1991 to June 19, 1993. The board conc1uded that the licensee
had operated the Salem units safely and that operator response to operational events was
excellent. The overall performance in the Operations area was good. However, weaknesses
were noted in the decisions to restart Unit 2 following the rod control system problems, in
the failure to follow procedures resulting in the loss of Unit 2 annunciators, and in the
inadequate oversight of the fire protection program.
PSE&G continued to implement effective radiological controis and ALARA programs during
this period. The SALP board noted improvements in this functional area inc1uding strong
management support and oversight. Quality Assurance audits in this area were of very good
quality.
The board conc1uded that the Salem maintenance and surveillance programs contributed to
the safe operation of the two units during the assessment period. In general, a declining
number of personnel errors in both maintenance and surveillance indicated improving
performance. However, the number of transients induced by component failures and the
significant problems with the rod control system raise questions regarding the overall
effectiveness of the maintenance and engineering support functions.
The SALP board determined that PSE&G maintained a genera11y strong and effective
emergency preparedness (EP) program. However, the board was concerned with an apparent
decline in the ability of the licensee to make correct initial Protective Action
Recommendations during training, drills and annual exercises. This concern resulted in the
board's assessment of a declining trend for this area. The board also conc1uded that PSE&G
continued to maintain an effective and performance-oriented security program during this
period. Overall, licensee performance in both EP and security remained exce11ent.
Engineering and technical support organizations provided good support for refueling and
maintenance outages, and strong performance in addressing day-to-day problems. The SALP
board noted that training programs for engineering personnel were exce11ent but that
weaknesses were observed in the licensee's non-conformance, erosion/corrosion, and fire
protection programs. Although the root cause training program was viewed as a strength,
the board noted that the threshold for initiating actual root cause investigation was not dear
or consistent.
PSE&G management continued to provide generally effective management support.
Significant Event Response Team (SERT) reviews of major events have been effective.
However, the board noted that in several instances, PSE&G failed to initiate adequate root
cause evaluation or assessment of abnormal conditions. NRC interaction with PSE&G
management was needed in a number of cases in order for full evaluation and corrective
4
action to be taken in a timely manner. Once initiated, comprehensive assessment, root cause
analysis and effective corrective actions were implemented. Outage planning and training
programs in all areas were considered strengths.
Il.B
Facility Performance Analysis Summary
Rating, Trend
Rating, Trend
Functiona] Area
Last Period
This Period
1.
Plant Operations
2
2
2.
Radiological Controls
2, Improving
1
3.
Maintenance/Surveillance
2
2
4.
1
1, Declining
5.
Security
1
1
6.
Engineering/Technical Support
2
2
7.
Safety Assessment/Quality
2
2
Verification
Previous Assessment Period: August 1, 1990 through December 28, 1991
Present Assessment Period: December 29, 1991 through June 19, 1993
Il.C
Unplanned Unit Trips
1.
6/8/93
Power
Level
100%
Root Cause
Grass content at circulating
water suction
Functional Area
SA/QV
Unit 1 automatically tripped following massive intrusion of sea grass into the
circulating water suction area. Four of five operating circulating pumps tripped
during cleaning of their trash racks, causing loss of vacuum, turbine trip, and
2.
3.
4.
5.
6.
7.
5
subsequent reactor trip. Root cause was determined to be less than adequate
management sensitivity to the possible consequences of rack Cleaning and incomplete
implementation of corrective actions from a previous similar event.
5/28/93
Subcritical
Component failure
Maintenance/
Surveillance
Unit 2 was manually tripped by the operators per abnormal operating procedures
when control bank "C", group 1 rods (four rods) fell into the core during dilution to
criticality for post refueling startup. A rod control system integrated circuit card
failure was attributed to a degraded solder trace.
3/16/93
100%
Random Component failure
Unit 2 automatically tripped from 100% power due to a low-low level condition on
No. 24 steam generator. A failed pressure control switch in the condensate polishing
system led to a low suction condition for No. 22 steam generator feed pump and
subsequent feed pump trip.
2/16/93
100%
Component failure
Unit 1 automatically tripped from 100% power due to an over-temperature delta
temperature signal caused by a faulty gain selector switch. This signal was received
with another channel already in the tripped position for ongoing channel calibration.
1/28/93
100%
Component failure during
troubleshooting
Maintenance/
Surveillance
Unit 2 operators manually tripped the reactor from 100% power in response to the
inadvertent loss of both operating steam generator feedwater pumps. A technician
was manipulating recorder test leads in the feedwater control cabinet when both feed
pumps automatically tripped. A loose module test jack was the cause.
1/16/93
13%
Random Component failure
Unit 1 operators manually tripped the reactor from 13% power in response to an
inadvertent opening of all turbine bypass (steam dump) valves. The transient was
initiated after a component in the control system failed.
9/3/92
100%
Personnel error - equipment
operator operated wrong
component
Maintenance/
Surveillance
8.
9.
6
Unit 2 tripped from 100% power due to the opening of the "A" reactor trip breaker.
A non-licensed equipment operator was to assist in surveillance testing of the trip
breakers. He mistakenly opened the cabinet of the "A" trip breaker instead of the
"A" trip bypass breaker.
5114192
15%
Lack of training/incorrect
assessment of feedwater control
system
Operations
Unit 2 tripped from 15% power due to a low-low level condition in the No. 23 steam
generator while personnel were troubleshooting feedwater level control problems.
While returning feedwater valves to their normal position, a transient occurred which
caused level to drop below the reactor trip setpoint. Operator's incorrect assessment
and lack of training associated with feedwater level control caused the event.
4/26/92
4%
Random Component failure
Unit 2 tripped from 4% power due to a low-low level condition in the No. 24 steam
generator. The low-low condition occurred while operators were transferring feed
from auxiliary feedwater to the main feedwater pump. A failed component in the
auto/manual feedwater control station caused sluggish valve response to both
automatic and manual control demand signals.
7
ID.
PERFORMANCE ANALYSIS
ID.A
Plant Operations
ID.A.1
Analysis
The previous SALP rated the Salem Plant Operations functional area as Category 2; mixed
operator performance characterized that SALP period. The assessment noted a continued
effective effort in maintaining a low number of reactor trips attributed to operations
personnel. Daily supervision and management oversight of plant operations were good.
Weaknesses were evident in the reactor operator training programs, and corrective actions*
for identified weaknesses were at times incomplete.
During this assessment period, PSE&G operated the Salem units safely. On several
occasions, station and operations management made conservative decisions to shut down the
Salem units to accommodate various repair and/or testing activities. Examples included a
Unit 2 shutdown to investigate erosion/corrosion concerns, a mini-outage at Unit 1 for
secondary plant maintenance, and a Unit 2 shutdown to repair a main generator stator water
leak. In addition, the licensee periodically reduced power to accomplish various activities,
such as condenser circulator cleaning and a Unit 1 primary system temperature detector
replacement that required a containment entry. In one case, involving discrepant
performance of the Salem Unit 2 rod control system during multiple successive restart
attempts, initial management response was not sufficient to understand and determine the
cause of the rod control system failures and the associated safety significance of the event.
Operators effectively responded to reactor trips and other operational transients. In some
instances, prompt and effective operator actions averted the necessity for reactor trips. One
example included a Unit 2 steam generator feedwater pump trip while operating at full
power, where prompt operator response prevented a unit trip. The personnel error rate
decreased during this SALP period, which was the result of aggressive management
attention.
The licensed and non-licensed operator. training programs were well developed, implemented
and strongly supported by management. Operations and training department personnel
worked well together in assuring that a well trained, qualified, and competent operating staff
existed. Candidates for initial and requalification license examinations were well prepared
and knowledgeable. All candidates passed NRC exams given during the period. Weaknesses
were noted in the area of simulator modeling and the quality of job performance measures.
The licensee initiated actions to address these weaknesses. Overall, the licensed operator
requalification and initial qualification programs were strong and well managed.
Nine unplanned reactor trips occurred for both units during the period. Although these trips
challenged the operations staff, most of the trips were the result of component failure or
environmental conditions. This compares to five and six reactor trips in the last two
assessment periods, respectively. A personnel error by a non-licensed operator (as discussed
8
in the surveil1ance section) who entered the Unit 2 reactor trip breaker cubicles on September
3, 1992, to re-familiarize himself with breaker operation in preparation for a Unit 1 test
caused one reactor trip. The root cause for the May 14, 1992 Unit 2 reactor trip was an
incorrect understanding and a lack of training by operations personnel of the design
capability of the feedwater regulating bypass valve. In all cases, safety systems functioned as
designed. Component aging, particularly in feedwater control systems, appears as a principal
contributor.
The operations department effectively transitioned to 12-hour shift rotations. The five
operating shifts were staffed adequately, utilizing an extra senior licensed operator to
supervise the work control group. One extra licensed operator was added to the shift
complement, and reduced the administrative burden in the control room during the Unit 2
outage.
Operations supervision and management oversight and attention to daily unit operations
continued to be good during the assessment period. Daily operational and outage meetings
provided an effective forum for the exchange of relevant operational information among the
various station groups and management levels. Those meetings maintained direct and
effective communications between operations and station management.
Licensed operators demonstrated a genera11y good safety perspective and awareness of plant
conditions. The operators generally displayed good adherence to procedures and sufficient
attention to detail during activities. The completion of the operations procedure upgrade
project has resulted in an improved quality of station procedures, and this contributed to a
positive procedure adherence trend. However, an apparent isolated instance of incomplete
procedures and failure to use procedures contributed to a Unit 1 loss of the overhead
annunciator (ORA) system. PSE&G initiated corrective action to previously identified
emergency and abnormal operating procedure deficiencies. The responsiveness of PSE&G
personnel was thorough, as indicated through administrative enhancements, including
verification and validation process strengthening.
Operations support of refueling outage activities was very good. Reactor core alteration
activities were conservatively conducted. The licensee demonstrated a good safety
perspective during outage periods by ensuring safety equipment availability and by
conducting independent reviews of the outage sequence. Operators performed unit startup
activities in a safe and deliberate fashion. Operators' performance and control during
reduced reactor coolant system inventory operations were strong. Licensed operators were
generally well trained on modifications prior to unit startup from outages. One exception
was that the control room ORA system modification training did not adequately train the
operators to routinely verify proper system operation.
The fire protection program was good and staffed with dedicated fire protection personnel
from the Site Protection group, who responded to fire and first aid emergencies. Plant and
site management strongly supported the fire protection program.
However, some
distinctions affecting Salem included weaknesses involving procedure problems, fire water
9
system knowledge shortcomings by plant personnel, and improper storage of combustible
materials. Further, due to equipment and maintenance difficulties, both Salem fire pumps
were inoperable for an extended period. However, the licensee implemented timely
compensatory measures in accordance with regulatory requirements. The licensee's
investigation of a self-identified instance of misconduct by a firewatch revealed a more
extensive weakness in oversight and control of contract personnel performing roving
firewatch duties. More than one-half of the firewatch personnel annotated their logs to
indicate they had inspected areas when, in fact, they had not. The licensee's corrective
actions were prompt and comprehensive in assessing and resolving this deficiency.
Summary
PSE&G operated the Salem units safely. Operator response to reactor trips and other
operational transients was excellent. Operations supervision and management .oversight of
day-to-day unit operations activities were good. Operations personnel generally demonstrated
a good safety perspective. However, the licensee decided to restart Unit 2 before the rod
control system problems were fully understood; and failure to follow procedures combined
with a design problem resulted in a loss of Unit 2 annunciators. Operations support for
refueling outages was very good. The PSE&G fire protection program exhibited
programmatic and performance weaknesses.
ill.A.2
Performance Rating: Category 2
ill.A.3
Board Comments:
None
ill.B
Radiological Controls
ill.B.1
Analysis
The previous SALP rated the functional area of radiological controls at Units 1 and 2 as
Category 2; improving. The radiological controls program was considered good. Staffing
and training were good, as wer~ radwaste processing, storage and transportation activities.
ALARA efforts and performance were commendable. Confirmatory measurements, effluent
controls, and the Radiological Environmental Monitoring Program (REMP) were effectively
implemented.
The radiological controls and chemistry programs were challenged during the current
assessment period. Refueling outages were performed at both units; personnel made periodic
entries into the Unit 1 containment, with the reactor at power; and minor fuel leaks, which
were detected at both units, required monitoring. The NRC's reviews of these activities
determined that the radiological controls and chemistry programs were effectively
implemented. There was strong management and supervisory oversight of on-going activities
and proactive involvement in radiation protection and chemistry programs. These were
evidenced by excellent steam generator (SG) chemistry controls, responses to SG chemistry
10
excursions, and the responses to minor fuel leaks on both units. Challenging 1992 goals for
radiation dose, personnel contamination events, and solid radwaste volume were met. Goals
for 1993 continue to be challenging and are being met. Planning and procedure development
for implementation of the revised 10 CFR Part 20 were very good.
The radiological controls organization and staffing levels were stable. There was very good
use of station radiological controls personnel to oversee contractor activities, a good level of
expertise within the organization, and minimal use of overtime. The outage radiological
controls organizations were well defined.
Overall, radiation protection and chemistry personnel were generally well trained and very
knowledgeable of their respective duties. However, early in the period the NRC identified
that personnel transferred from the Hope Creek site to support outage activities at Salem *
were not provided training on Salem specific radiation protection procedures. Appropriate
personnel were subsequently trained on Salem specific procedures in a timely manner.
Radiation workers received appropriate and timely training. For example, a new course
titled "Integrated Training" was implemented at both Salem and Hope Creek Stations. The
course involved radiation workers and radiological controls personnel planning and
performing work activities together under realistic conditions on a mock-up. The majority of
radiation protection and maintenance personnel attended the course .. The course was
considered a very good initiative. There were excellent pre-job briefings and explicit
guidance specified on radiation work permits.
The overall internal and external exposure controls programs were strong, and control of
radiological work activities was commendable. An effective access control system using
state-of-the-art computer supported equipment continued to be maintained. There were no
internal or external exposures in excess of NRC limits and overall administrative controls of
personnel exposure were effective. For example, the internal exposure controls for steam
generator work were such that the majority of work was conducted without the need for
respiratory protection. The weaknesses associated with quality control of dosimetry,
identified during the previous period, were corrected. Weaknesses in exposure records
controls, identified by NRC early in the period, were also corrected. All dosimetry issues
were closed. The radiological occurrence report system was wen supported by management
and effective in identifying root causes and corrective actions for radiological problems.
The ALARA program continued to be strong throughout the period. NRC independent
review of work activities indicated commendable planning and preparation, use of
appropriate exposure goals, and very good oversight of on-going activities from an ALARA
standpoint. Aggregate personnel radiation exposure continues to be among the lowest in the
industry. Emergent work received appropriate *reviews and ALARA controls.
Overall, the radioactive material and contamination control programs were strong. Isolated
lapses in contamination controls were aggressively pursued and root causes were identified
and corrected. Radiological Control Area and containment housekeeping improved during
the period and contaminated floor areas were reduced significantly. In addition, the
11
radioactive waste handling, storage and transportation programs were strong and well
managed. Plans have been established for interim on-site storage of radioactive waste in the
event of delays in finalization of compact efforts by the State of New Jersey.
The Radiological Effluent Control Program (RECP) and the REMP continued to be effective
during this period. Personnel exhibited good knowledge of all RECP areas including effluent
controls, radiation monitoring systems (RMS), and off-site dose calculations. Comparisons
of projected off-site doses between the licensee and the NRC PCDOSE computer code were
in excellent agreement. Procedures were detailed, concise and well written and resulted in
effective implementation of the RECP and REMP. The initiative to develop and issue RMS
manuals to assist in maintenance of the RMS, as well as the efforts to upgrade the RMS,
were noteworthy. These actions indicated not only a clear understanding of technical issues,
but also a proactive approach to maintaining the RMS. The meteorological monitoring
program was effective.
Overall quality assurance (QA) oversight of program areas was very good. Special audits of
dosimetry program matters were conducted to verify quality and independent assessors
continued to be used to monitor outage activities. QA audits of effluent and environmental
monitoring programs were thorough and of sufficient technical depth to probe for
programmatic weaknesses. Findings were promptly resolved. Early in the period, the NRC
identified a weakness in the area of audits of personnel qualifications. It was not clear that
personnel qualifications of all appropriate groups were being systematically audited. Baseline
audits were immediately initiated by the QA group and no unqQalified personnel were
identified.
Summary
PSE&G implemented effective radiological controls and ALARA programs. There was
strong management support and strong supervisory and management oversight of program
areas. External and internal exposure controls were effective, as were contamination
controls, storage and handling of radioactive material, and radioactive waste transportation
activities. The confirmatory measurements and effluent controls program, as well as the
REMP continued to be effective. QA audits were of very good quality.
ID.B.2
Performance Rating: Category 1
ID.B.3
Board Comments:
None
m.c
Maintenance/Surveillance
ID.C.1
Analysis
The previous SALP assessment rated the Maintenance/Surveillance area as Category 2.
12
Personnel errors and inattention to detail resulted in problems in both maintenance and
surveillance. A number of improvements in such areas as plant material condition and fewer
missed surveillances had been noted in the previous assessment. Weaknesses were noted in
the area of material control and procurement.
Maintenance
The Salem maintenance program contributed to the continued safe operation of both Salem
units during the assessment period. Maintenance department management was directly and
effectively involved in the oversight of routine maintenance activities during power
operations and during forced and refueling outages. PSE&G employed a fixed shift work
schedule, providing balanced work activity impact and contributing to maintenance planning
efficiency. Pre-outage system walkdowns were initiated to improve outage efficiency. Plant
management screened work to be done during planned maintenance outages of safety-related
equipment to achieve a net safety gain. Safety system availability was maintained high, also
demonstrating management's safety conscious control of the maintenance program. A new
work standards monitoring program provided for proper management review of maintenance
activities.
Maintenance Department staff adequately supported plant operations. Non-supervisory
personnel were technicaJly knowledgeable of routine preventive and corrective activities;
their training and experience remained a strength. Maintenance first-line supervisors
provided generally good oversight. Personnel errors resulted in one engineered safety
feature actuation early in the period, a partial loss of off-site power later in the period, and a
small number of non-cited violations throughout the period. However, the number of
reportable events (including surveillance-related events) due to personnel error decreased
from 24 in the previous SALP period to 12 in this period.
Two reactor trips resulted from maintenance activities. In one case, control rods dropped
because of a degraded solder trace from maintenance on a rod control printed circuit card.
Another trip resulted from installation of test equipment in a feedwater control cabinet which
had a loose module test jack. These maintenance-related trips and the continuing problems
due to personnel error reduced the effectiveness of the maintenance program.
The conduct of routine maintenance activities was good. Coordination between maintenance
and operations to schedule and accomplish work activities was effective and improving.
Indicators of good maintenance performance included dec1ining trends in the corrective and
preventive maintenance backlogs, in the number of industrial safety events, in the number of
plant leaks and in the number of required radiation monitoring system work orders.
13
Continued improvement in both units' materiaJ condition was also noted. The Salem
RevitaJization Project has positively impacted the plant material condition. Aggressive
management attention in this area was evident. The Procedure Upgrade Program, nearing
completion for I&C and Maintenance procedures by the end of the period, was a positive
effort.
Salem has established and maintained a very good preventative maintenance (PM) program.
Improvements in the PM program are continuing, and as a result, deferred PMs have been
reduced significantly. Much of this program's success is attributable to a close working
relationship between engineering, operations and maintenance.
Salem performed three refueling outages; one at Unit 1 and two at Unit 2. Outage planning
activities and outage conduct were strong. Outage meetings and good inter-departmental
cooperation resulted in better daily work coordination and more efficient accomplishment of
outage work. The delegation of some inservice inspection and balance-of-plant outage work
to PSE&G Site Services reduced the dependency on contractors for those efforts and
addressed a weakness from a prior SALP report. Good performance was noted during the
outages in the restoration of the Unit 2 turbine generator, the service water piping
replacement at both units, the erosion/corrosion work at Unit 1, and the 10-year overhaul of
a11 three emergency diesel generators at Unit 2.
Deficiencies were observed in PSE&G's troubleshooting effort involved with the Unit 2 rod
control system following that unit's refueling outage at the end of the period. Maintenance
and troubleshooting activities were not wen controlled. Since root cause determination
policy and expectations were not well established, these activities initially did not identify
design and physical circuit problems. Consequently, corrective actions were not effective.
Further, PSE&G staff members responsible for maintenance of the rod control system did
not recognize that some exhibited system defects were outside of the system design basis
(e.g., the observation that one of the control rods withdrew from, instead of inserting into,
the core on an "insert demand signal"). Several rod control system failures and anomalies
were experienced without reaJizing that the defects were related. This led to an attempt to
restart the plant without understanding the cause or nature of the failures or the significance
of the anomalous performance. After NRC directed attention to this area, including the
formation of an Augmented Inspection Team, the licensee initiated a thorough and
comprehensive investigation of the rod control system deficiencies, and resolved the issues.
The licensee continued improvement in the area of spare parts procurement and availability.
The procurement program also included commercial grade component dedication. The new
integrated and automated warehouse was placed into operation during the period. A
computerized data base was widely used by the staff and was effectively integrated into the
procurement program. This system enabled the procurement activities to be processed
efficiently, and the procurement backlogs to be substantially reduced.
14
Surveillance
During this period the Salem surveillance program was safely and properly implemented and
confirmed the operability of safety-related equipment. The maintenance information system
was effectively used to schedule and track the completion of a large number of required
surveillance activities at both units. Technical Specification surveillances were completed
within the required periodicity, with four isolated exceptions. The missed surveillances were
not indicative of any program weakness and were properly addressed by PSE&G upon their
discovery. The four missed surveillances decreased from nine during the previous SALP
period. Technicians demonstrated a good level of knowledge during the performance of the
surveillance and inservice test activities.
Communications and coordination between technicians and control room operators were
good. Despite the association of one reactor trip with the performance of a reactor trip
breaker surveillance procedure and two engineered safety feature actuations, management
attention has reduced the number of personnel errors committed during surveillance test
performance. A design change involving the 4kV vital bus test points significantly reduced
potential for these kind of errors. The Procedure Upgrade Program continued to improve the
quality of surveillance procedures. However, an operations surveillance test was inadequate
to assure that the overhead annunciator system display was verified to be functioning on a
regular basis and contributed to a loss of annunciator event in December, 1992.
The inservice inspection and testing efforts were again well performed; a noted strength was
the performance of steam generator tube inspections during refueling outages. Unit 2's
second 10-year ISi interval program has been enhanced as a result of PSE&G's assuming its
preparation and control instead of delegating this responsibility to an ISi vendor, as was done
during the first 10-year interval. PSE&G responded well to the increased surveillance test
requirements following the restoration of the Unit 2 turbine generator and the placing of that
equipment into service.
Summary
The Salem maintenance and surveillance programs contributed to safe operation of the two
Salem units during the assessment period. Continued reduction of personnel errors in both
maintenance and surveillance activities was noted. A number of other trends indicated
continuing improvement. Three refueling outages were performed with strong planning and
implementation. However, a significant event still resulted from personnel error and
maintenance activities that were not well controlled. Improvements were noted in
procurement and material control.
m.C.2
Performance Rating: Category 2
ill.C.3
Board Comments: None
15
ID.D
Emergency Preparedn~
m.D.1
Analysis
This area is common for the Artificial Island site, refer to Hope Creek SALP report 50-
354/91-99, Section ill.D.1 for details.
ID.D.2
Perf onnance Rating: Category 1, Declining
ID.D.3
Board Comments: None
ID.E
Security and Safeguards.
ID.E.1
Analysis
This .area is common for the Artificial Island site, refer to Hope Creek SALP report 50-
354/91-99, Section ill.E.1 for details.
ID.E.2
Perfo~nce Rating: Category 1
m.E.3
Board Comments: None
ID.F
Engineering and 'J'echnical Support
ID.F.1
Analysis
The previous SALP rated Engineering and Technica1 Support as Category 2. The previous
assessment indicated that the control and limitations of temporary modifications improved.
Also improved was the quality of work performed by the onsite system engineers and in the
Salem Qualified Reviewers Program. Progress was observed in, the Salem RevitaJization
Project and the Configuration Baseline Project, two of the engineering enhancement projects.
Weaknesses were noted in the responses to NRC generic communications.
Engineering and Technical Support for Salem is provided by the corporate engineering,
known as Engineering and Plant Betterment (E&PB), and the onsite system engineering
organization. These groups effectively provided technical support for refueling and
maintenance outage activities. E&PB handles major engineering efforts such as plant
modifications and design bases reconstitution. The onsite engineering group supports
operations, maintenance, testing and minor design change activities. These groups are well
staffed with experienced personnel in various engineering disciplines. Both engineering
organizations communicated and interfaced well with the station and outage groups on a daily
basis. Reactor engineering generally provided strong support to the Salem station during
refueling, reactor startup and power ascension testing activities.
16
The licensee has an exce11ent program for controlling design changes and plant modifications.
The "workbook" used in the design change process provides easy-to-follow guidance to the
preparer of plant modification packages. The modification packages reviewed were of good
quality. They were thorough and contained adequate safety reviews. However, the licensee
made minor changes to the facility as described in the UFSAR without determining if there
was an unreviewed safety question involved as required by procedures. There were no other
identified cases of the licensee failure to fo1low the 10 CFR 50.59 implementation procedure.
While these failures to follow procedures did not result in safety problems, the finding
indicates a potential weakness in the licensee's 10 CFR 50.59 program.
The loss of the overhead annunciator (OHA) system on Unit 2 and failure to recognize that
loss for 90 minutes had several root causes, some that were engineering in nature. The
multi-microprocessor OHA system that was recently installed failed to provide the necessary
human-machine interface. The system also gave higher priority to other actions besides
providing alarm indications to the operators and did not provide indication of failure. The
engineering staff performed little software review of the OHA modification. In addition, the
staff's knowledge of the OHA system and the associated new technology was less than
adequate. Only after NRC directed attention to this area, including the formation of an
Augmented Inspection Team, did the licensee initiate a thorough and comprehensive
investigation to determine the cause and effect resolution.
As a result of concerns identified during an NRC inspection, PSE&G further identified
significant programmatic weaknesses in the site Erosion/Corrosion (E/C) Program. The
licensee used incorrect criteria in determining minimum wall thickness. Subsequently,
numerous piping erosion conditions involving non-safety related feedwater piping were
dispositioned incorrectly for both Salem units. E&PB subsequently implemented substantial
programmatic improvements to correct the E/C Program to an acceptable condition.
Concerns were also identified by the NRC with regard to the licensee's Appendix R
program.
It was determined that the fire barrier systems were not installed in accordance
with the tested configuration. In response to the inoperable status of these fire barrier
systems, due to the lack of proper qualification test data to substantiate the design of the in-
plant configuration, the licensee had to institute hourly fire watch patrols in the plant areas
containing the questionable fire barrier systems.
The licensee has an excellent training program for E&PB staff and onsite system engineering
personnel. A typical system engineer receives substantial theory-based training, including
thermodynamics, heat transfer, and fluid mechanics. Recent enhancements to the E&PB
training program have advanced towards a more performance/application oriented approach.
In addition, the licensee has an excellent Root Cause Analysis and Decision Making course
designed for members involved in problem solving and incident investigations. However, the
threshold for initiating root cause investigations was not clear or consistent.
--~
17
Several longer standing design and hardware concerns represent challenges to the reliable
operation of the facilities. For example, control room operators entered Technical
Specification 3.0.3 on several occasions due to design problems associated with the analog
rod position indication system. Automatic main steam line isolations continued to occur
during plant heatup due to design deficiencies. In addition, some reactor trips were caused
by random failures of plant hardware. On the positive side, the engineering organi:zations
implemented several system design modifications and other actions to address long-standing
concerns. Examples included the safeguards equipment cabinets (load sequencers),
pressurizer power operated relief valves, service water and radiation monitoring systems (in
progress), and vital/non-vital switchgear transformers.
The engineering organi:zations proactively identified and addressed a number of technical
problems in a timely manner. These included auxiliary feedwater system excessive flow, a
longer than expected overall response time for the containment spray system, a potential
overload condition associated with the emergency diesel generators, and a condition outside
the design basis for the control air containment isolation valves.
System engineers generally exhibited strong performance in addressing day-to-day problems.
The system engineers effectively evaluated safety-related pump failures, and switchgear
transformer failures. System engineer performance, however, demonstrated some control
and coordination weaknesses while troubleshooting problems with an emergency diesel
generator, which resulted in an engine overspeed trip.
The licensee's response to recent failures in the rod control system indicated the following
weaknesses: (1) the lack of a site wide root cause determination policy; (2) the lack of
supervision and control over vendor activities; (3) PSE&G's inadequate understanding of the
depth and capabilities of the vendor's circuit card testing program; (4) the less than adequate
control over the vendor's non-like-for-like replacement of the rod control system digital
group counters; (5) the lack of control of the vendor's troubleshooting; and (6) the lack of
appropriate troubleshooting rigor. However, the licensee allocation of resources for each
individual event was adequate. Furthermore, after the initiation of the NRC's AIT, the
upper management oversight and the investigation of the event by the Significant Event
Response Team (SERT) were considered strengths.
Engineering and Plant Betterment has initiated an aggressive program to substantially reduce
the engineering work request (EWR) backlogs for both Salem and Hope Creek. They were
successful in reducing the backlog during this period.
The licensee has separate programs for controlling nonconformance reports (NCR) in each
division. The NRC identified weaknesses in this area due to lack of interface between
individual programs. For example, a fire damper, which provides ventilation to the station
battery to prevent hydrogen accumulation reaching the ignition limit, failed to the closed
position (due to damaged fusible link) and remained closed for more than 18 months. The
E&PB NCR, which identified the deficiency, was closed without assuring either: 1) that the
safety impact of the deficiency was properly addressed and the deficiency corrected, or 2)
18
that the nonconformance was addressed by site engineering.
The quality of the technical content of licensee submittals has appeared to level off with some
room for improvement still remaining. Of the ten amendments approved during the SALP
period, four required significant information to be submitted before approval. The responses
to various generic letters required significant revision before satisfactory resolution of these
issues were achieved. Other requests from the licensee, such as relief requests from ASME
Code requirements have been generally acceptable.
The erosion/corrosion monitoring program for high energy piping has shown improvement
from an administrative control standpoint. Both units have their own respective
administrative procedures. Predictive analyses are more appropriate and conservative than
past evaluations.
Summary
Engineering and Plant Betterment and the onsite system engineering provided good technical
support for refueling and maintenance outages. System engineering exhibited strong
performance in addressing day-to-day problems. The modification packages reviewed were
of good quality, with a few exceptions. The training program provided for E&PB staff and
system engineering personnel was determined to be excellent. Several operational problems
were caused by long-standing design and hardware concerns. The engineering organization
implemented several system design modifications to address some long-standing concerns.
However, coordination weaknesses were observed in troubleshooting emergency diesel
generator problems and the root cause determination and troubleshooting associated with the
rod control system failures. Both E&PB and system engineering have initiated aggressive
programs to reduce substantially the engineering backlogs. Weaknesses were observed in the
licensee's non-conformance, erosion/corrosion, and fire protection (Appendix R) programs.
ID.F.2
Performance Rating: Category 2
ID.F.3
Board Comments:
None
ID.G
Safety A~ent/Quality Verification
m.G.1
Analysis
The previous SALP rated this area as Category 2. That assessment noted that management
continued to be involved in problem resolution and the assurance of nuclear safety. Groups
that provide independent reviews were effective and provided safety conscious reviews of
licensee activities. A continuing concern with personnel errors, procedure compliance, and
licensee submittals was noted.
During this period, performance at both Salem units was good. Cooperation, communication
and coordination between the different departments at Salem continued to improve. There
19
were, however, indications that personnel error and lack of procedure adherence continue to
exist.
The Station Operations Review Committee (SORC) properly performed their Technical
Specification required duties and provided conservative and effective review of design
changes, post-trip reviews and significant events. However, in the case of the rod control
system problems at Unit 2, late in the SALP period, SORC did not perform well in that
multiple startup attempts were permitted without requiring the root cause of the problems to
be determined. Some weaknesses were identified in the IO CFR 50.59 process as discussed
in the Engineering and Technical Support section.
The licensee properly implemented the Significant Event Response Team (SERT) process in
order to provide an independent assessment of all reactor trips and other major events. The
NRC found the SERT reviews to be effective, and SERT recommendations were
appropriately received and considered by plant management.
The PSE&G on-site Safety Review Group (SRG) and Station Quality Assurance (SQA)
performed effectively in reviewing Salem station activities. SRG provided consistently good
shutdown risk assessments for three refueling outages and maintained good independence
from the station staff. SQA provided good coverage of routine and non-routine activities at
Salem, and produced effective monthly reports and appropriately performed all audits
required by Salem Technical Specifications.
Outage planning and preparation developed into a strength during this assessment period.
Outage work was well controlled, inter-department coordination was very good, and
emergent issues were properly addressed in the three refueling outages which occurred
during the period and during the forced outages of the period. Management involvement and
control of the outage work were evident.
Salem station management, including the General Manager and individual department heads,
generally provided effective and conservative oversight of station activities. This
management involvement was provided in daily meetings with senior nuclear shift
supervision and through management accountability meetings. The Salem General Manager
conducted informative State-of-the-Station meetings to convey expectations to plant
personnel. Corporate management also provided a highly visible presence at the station.
However, when the station was challenged by significant events, management response was
not as effective. In some cases, management was not promptly informed of the event (loss
of overhead annunciators) or did not appreciate the significance of the event (rod control
system anomalies). As a result, management response was initially inadequate. However,
once these conditions were understood and recognized, management took conservative,
thorough, and comprehensive actions, and brought the issue to a timely resolution.
20
PSE&G has an excellent root cause analysis and decision making training program designed
for personnel involved in problem solving and incident investigation; however, management
has not effectively developed the criteria or expectations for when the root cause of an event
must be determined prior to the resumption of normal plant operations. This contrast in the
quality and ability of the program versus its implementation was demonstrated most notably
in the licensee's failure to identify root cause in their handling of the Unit 2 rod control
system problems.
The licensee's corrective action program generally functioned well, but there were signs of
reduced effectiveness. The weaknesses were noted in troubleshooting activities associated
with the emergency diesel generator, rod control system and overhead annunciators. In
addition, inadequate oversight of contractors and vendors led to less than full knowledge of
the overhead annunciator system and rod control system maintenance activities. This
contributed to a delay in the root cause determination of these events. The erosion/corrosion
program as implemented at Salem had significant programmatic weaknesses. Jn all of these
cases, once the deficiency was identified by NRC, PSE&G management took immediate and
appropriate actions.
Training programs implemented by PSE&G in all areas were well developed and effective.
Of particular note were the training of licensed and non-licensed operators, radiation
protection personnel, safeguards and security personnel and on-site and off-site engineering
personnel. This training and the strong results of the licensee's procedure upgrade program
have resulted in improvements in the areas of reduced personnel errors and procedure
adherence.
The quality of the technical content of licensee submittals (e.g., amendment requests,
responses to NRC generic communications, and other licensee initiated requests) is
occasionally deficient. Of the ten amendments that were approved, four required significant
additional information to be submitted before approval. Responses to three generic letters
required significant revision before satisfactory resolution of the issues was achieved.
Sum mazy
PSE&G management continues to be involved in station activities and have genera1ly
provided effective management support. In several significant instances (e.g., the overhead
annunciator event, the rod control system problem, and the issue involving erosion/corrosion
of system piping), the licensee failed to initiate adequate root cause evaluation or assessment
of the abnormal condition. However, once management attention was directed to these
issues, the licensee initiated very thorough and comprehensive efforts to understand and
resolve the issues. SERT reviews of major events have been effective and recommendations
have been accepted by licensee management. Outage planning has developed into a licensee
strength. Training programs in all areas have been found to be effective with only minor
weaknesses noted. Prior weaknesses in personnel errors and procedure adherence were
effectively addressed. The quality of routine license submittals is occasionally deficient.
m.G.2
m.G.3
21
Performance Rating: Category 2
Board Comments:
The NRC is concerned with the adequacy and timeliness
of PSE&G's management response to significant events and to the cha11enges
presented by numerous component failures and several unreso1ved design
issues at Salem.
22
IV.
SITE ACTIVITIES
IV .A
Licensee Activities
Unit 1
The unit began the period at full power. On January 21, 1992, the unit was shut down when
three circulators were lost due to a control power cable failure. The unit was restarted on
January 27, 1992.
Unit 1 operated until it was shut down for its tenth refueling outage on April 4, 1992. The
unit remained in an outage to repair linear indications identified on three of the four steam
generator feedwater nozzles and to replace portions of turbine building feedwater piping due
to minimum pipe wall concerns. The unit was returned to service on August 16, 1992.
Unit 1 remained at power until December 24, 1992, when the unit was removed from service
due to a loss of circulating water pumps as a result of excessive debris and increased sodium
levels in the steam generators as a result of failed condenser tubes. Power operation
resumed on December 29, 1992, and continued until January 16, 1993, when control room
operators initiated a manual reactor trip from 13% power following the failure of the steam
dump system. The unit was being shut down at the time for control rod position indication
system maintenance. Following completion of the related repair activities, the unit was
restarted on January 21, 1993.
An automatic reactor trip occurred from 100% power during nuc1ear instrumentation testing
on February 16, 1993. A spike occurred on another channel (loop 11 Tave) resulting in a
two of four coincident Over Temperature Delta-Temperature reactor trip. The unit restarted
on February 22, 1993.
The unit operated at power until it automatically tripped from 100% power on June 8, 1993,
when four of five circulators tripped due to large sea grass intrusion. The unit remained shut
down at the end of the SALP period.
Unit 2
The unit began the period in its sixth refueling outage fo1lowing the November 9, 1991,
turbine generator failure. Unit 2 was restarted on April 19, 1992.
A reactor trip from 4 % power occurred on April 26, 1992. The unit was restarted on May
3, 1992, and on May 14, 1992, a trip from 15% power occurred. Both of these trips
occurred on low-low steam generator level due to problems with the feedwater level control
system. The unit was restarted on May 18, 1992.
On June 18, 1992, the licensee shut down Unit 2 due to feedwater pipe wall thinning caused
by erosion/corrosion. The unit was restarted on July 15, 1992, and continued to operate
23
unti1 September 3, 1992, when an automatic reactor/turbine trip occurred from fu11 power.
The cause of the trip was determined to be a non-licensed operator error. The unit was
restarted on September 6, 1992.
Unit 2 operated at power until January 28, 1993, when control room operators manua11y
tripped the unit from 100% power, immediately following the loss of both operating steam
generator feed pumps caused by a loose test connector. The unit was restarted on January
31, 1993.
The unit operated at power until March 16, 1993, when the unit automatica11y tripped from
100% power on low steam generator level caused by a failed pressure control switch in the
condensate polishing system. The licensee then began the unit's seventh refueling outage.
Several aborted post refueling startups occurred during the period May 24 - June 4, 1993.
This included a manually initiated reactor trip on May 28, 1993, when one control rod bank
dropped into the core. The unit remained shut down at the end of the period while rod
control system problems were investigated.
IV .B
NRC Inspection Activities
Four NRC resident inspectors were assigned to Artificial Island during the assessment
period. NRC team inspections were conducted in the following areas:
Salem 2 restart readiness after a six month outage to repair/replace the turbine
generator from March 22 - May 2, 1992.
Motor Operated Valve Inspection on May 4-8, 1992.
Emergency Preparedness Inspection conducted on October 27-29, 1992, to observe
the Artificial Island annual exercise.
Augmented Inspection Team to review a loss of annunciators event at Unit 2 from
December 14-23, 1992.
Fire Protection Appendix R Inspection on May 17-21, 1993.
Augmented Inspection Team to review Unit 2 rod control abnormalities from June 5-
28, 1993.
ATTACHMENT 1
SALP EVALUATION CRITERIA. PERFORMANCE CATEGORIES AND TRENDS
The following evaluation criterion 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.
Enforcement history.
4.
Operational and construction events (including response to, analyses of, reporting of,
and corrective actions for).
5.
Staffing (including management).
6.
Effectiveness of training and qualifications program.
The performance categories used when rating licensee performance are defined as follows:
Category 1. Licensee management attention to and involvement in nuclear safety or
safeguards activities resulted in a superior level of performance. NRC wiII consider reduced
levels of inspection effort.
Cate~ory 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 or 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 efforts.
Category N. Insufficient information exists to support an assessment of licensee
performance. These cases would include instances in which a rating could not be developed
because of insufficient licensee activity or insufficient NRC inspection.
The SALP Board may assess a performance trend, if appropriate. The trends are:
Improving: Licensee performance was determined to be improving during the assessment
period.
Declinin~: Licensee performance was determined to be declining during the assessment
period and the licensee had not taken meaningful steps to address this pattern.
Trends are normally assigned when one is definitely discemable and a continuation of the
trend is expected to result in a change in performance during the next assessment period.
- - - --------
--
ENCLOSURE 2
INITIAL DRAFT SALP REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
REPORT NO 50-354/91-99
PUBLIC SERVICE ELECTRIC AND GAS COMPANY
HOPE CREEK GENERATING STATION
ASSESSMENT PERIOD:
DECEMBER 29, 1991 - JUNE 19, 1993
BOARD MEETING DATE:
JUL y 29' 1993
TABLE OF CONTENTS
I.
IN'TRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
II.
SUMMARY OF RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
II.A
Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
II.B
Facility Performance Analysis Summary . . . . . . . . . . . . . . . . .
4
III.
PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
III.A
Plant Operations
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
III.B
Radiological Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
III.C
Maintenance/Surveillance . . . . . . . . . . . . . . . . . . . . . . . . .
10
III.D
Emergency Preparedness . . . . . . . . . . . . . . . . . . . . . . . . .
12
III. E
Security and Safeguards . . . . . . . . . . . . . . . . . . . . . . . . . .
14
III.F
Engineering and Technical Support . . . . . . . . . . . . . . . . . . .
16
III.G
Safety Assessment/Quality Verification . . . . . . . . . . . . . . . . .
18
IV.
SITE ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
21
IV.A
Licensee Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
21
IV.B
NRC Inspection Activities . . . . . . . . . . . . . . . . . . . . . . . . .
21
Attachment: SALP Evaluation Criteria, Performance Categories and Trends
I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC
staff effort to collect available observations and data periodically, and to evaluate licensee
performance on the basis of this information. The program is supplemental to normal
regulatory processes used to ensure compliance with NRC rules and regulations. It is
intended to be sufficiently diagnostic to provide a rational basis for a11ocating NRC resources
and to provide meaningful feedback to the licensee's management regarding the NRC's
assessment of their facilities' performance in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on July 29, 1993,
to review the observations and data on performance, and to assess licensee performance in
accordance with the guidelines in NRC Management Directive 8.6, "Systematic Assessment
of Licensee Performance," dated September 28, 1990. The SALP Evaluation Criteria
utilized by the board are attached.
This report is an assessment for the Hope Creek Generating Station for the 18 month period
from December 29, 1991, to June 19, 1993. The Hope Creek SALP Board members were:
CHAIRMAN:
W. D. Lanning, Deputy Director, Division of Reactor Projects (DRP), Region I (RI)
MEMBERS:
M. L. Boyle, Acting Director, Project Directorate I-2,
Office of Nuclear Reactor Regulation (NRR)
S. Dembek, Project Manager (Hope Creek), NRR
C. W. Hehl, Director, Division of Radiation Safety and Safeguards (DRSS)
T. P. Johnson, Senior Resident Inspector, Salem/Hope Creek, RI
C. L. Miller, Acting Deputy Director, Division of Reactor Safety (DRS)
E. C. Wenzinger, Chief, Projects Branch No. 2, DRP, RI
2
OTHERS IN A ITENDANCE:
I. R. White, Chief, Reactor Projects Section 2A, DRP, RI
T. H. Fish, Resident Inspector, Salem/Hope Creek, RI
S. T. Barr, Resident Inspector, Salem/Hope Creek, RI
I. G. Schoppy, Resident Inspector, Salem/Hope Creek, RI
S. M. Pindale, Resident Inspector, Oyster Creek, RI
H. K. Lathrop, Resident Inspector, Calvert Cliffs, RI
B. I. McDermott, Reactor Engineer, DRP, RI
R. L. Nimitz, Senior Radiation Specialist, FRPS, DRSS, RI
C. Z. Gordon, Senior Emergency Preparedness (EP) Specialist, EP Section, DRSS, RI
J. C. Stone, Project Manager (Salem), NRR
R. R. Keimig, Chief, Safeguards Section, DRSS, RI
I. H. Lusher, EP Specialist, DRSS, RI
R. J. Summers, Project Engineer, RI
L. H. Bettenhausen, Chief, Operations Branch, DRS, RI
I. P. Durr, Chief, Engineering Branch, DRS, RI
S. A. Morris, Reactor Engineer, DRP, RI
I. I. Zimmerman, Project Engineer, NRR
M. I. Davis, Performance Evaluator, NRR
L. S. Cheung, Senior Reactor Engineer, DRS, RI
3
II.
SUMMARY OF RESULTS
II.A
Overview
On July 29, 1993 the SALP board met to discuss PSE&G's performance at Hope Creek
during the period from December 29, 1991 to June 19, 1993. The board concluded that the
licensee had operated Hope Creek in a safe and conservative manner. Operator training was
a strength and the operator error rate remained low, contributing to a decreased reactor
scram rate. PSE&G provided effective management oversight and attention to a11 operational
activities. A weakness was noted in management's oversight of firewatch program activities,
a common function affecting Salem and Hope Creek.
The licensee continued effective implementation of their state-of-the-art radiological controls
program. The SALP board noted that management support and control, staffing levels,
quality assurance oversight, and ALARA were program strengths.
PSE&G demonstrated superior results in maintenance program implementation at Hope
Creek, and very good results in surveillance testing. Continued management involvement in
improving program performance and correcting identified problems was evident. The SALP
board also noted specific improvements in procurement and material control during this
period.
The SALP board determined that PSE&G maintained a generally strong and effective
emergency preparedness (EP) program. However, the board was concerned with an apparent
decline in the ability of the licensee to make correct initial Protective Action
Recommendations during training, drills, and annual exercises. This concern resulted in the
board's assessment of a declining trend for this area. The board also concluded that PSE&G
continued to maintain an effective and performance-oriented security program during this
period. Overall, licensee performance in both EP and security remained excellent.
Engineering and technical support for the Hope Creek station improved during this SALP
period. The board noted improvements in the licensee's program for contro11ing design
changes and plant modifications, MOV program implementation, training of the engineering
staff, and reduction of engineering backlogs. Although the root cause training program was
viewed as a strength, the board noted that the threshold for initiating actual root cause
investigation was not clear or consistent.
The licensee continued to perform well in the area of Safety Assessment and Quality
Verification during this period. First line supervision and management oversight were very
good, as was the independent review provided by the On-site and Off-site Safety Review
Groups and by Station Quality Assurance. Performance by individuals was strong, as
evidenced by a reduction in the personnel error rate.
4
Il.B
Facility Performance Analysis Summary
Rating, Trend
Rating, Trend
Functional Area
Last Period
This Period
1.
Plant Operations
1
1
2.
Radiological Controls
1
1
3.
Maintenance/Surveillance
2, Improving
1
4.
1
1, Declining
5.
Security
1
1
6.
Engineering/Technical Support
2
2, Improving
7.
Safety Assessment/Quality
1
1
Verification
Previous Assessment Period: August 1, 1990 through December 28, 1991
Present Assessment Period: December 29, 1991 through June 19, 1993
5
III.
PERFORMANCE ANALYSIS
ID.A
Plant Operations
ID.A.1
Analysis
The previous SALP rated Hope Creek operations as Category 1. That assessment concluded
that PSE&G operated the Hope Creek reactor conservatively with nuclear safety as the top
priority. Operator errors remained low, however, the frequency of automatic reactor scrams
was a concern. Strong management and supervisory oversight of, and involvement in,
operations were evident. The licensee conducted its third refueling outage effectively. An
effective training program was noted; though, the failure rate for initial Reactor Operator
license examinations near the end of the period indicated weak preparation.
During this assessment period, PSE&G operated the reactor in a professional and safety
conscious manner. Well-trained operators ski11fully performed their duties during unit
startups, shutdowns, and transients. For the two reactor scrams that occurred during the
period, operator performance was not a causal factor. During a loss-of-offsite power and a
failure of reactor feedwater pump automatic control, prompt and effective operator actions to
restore equipment and to deal with power reductions mitigated these plant transients and thus
averted plant scrams. The licensee completed an event-free 300 day run in the middle of
1992 when the unit was shut down for a scheduled mid-cycle outage.
The licensee exceeded the minimum Technical Specification shift staffing requirements for
Senior Reactor Operators (SRO) and Reactor Operators. Additionally, SRO licensed
individuals supervised the work control group continuously. SRO licensed personnel
provided field support for day shift operational activities.
Plant management maintained effective and thorough oversight and attention to an operational
activities on a daily basis. Daily status meetings were used to provide an operational
perspective of plant problems and work prioritization with the focus on nuclear safety, as
was evidenced by the timely and thorough followup to a boron dilution problem in the
standby liquid control system, the initiation of a timely shutdown for failure of three torus-to-
drywell vacuum breakers, and a very proactive approach to shutdown risk management.
The licensed and non-licensed operator training programs were well developed, effectively
implemented, and received strong management support. Candidates for initial and
requalification license examinations were well-prepared and knowledgeable. There were no
license examination failures during this period, indicating that corrective measures taken as a
result of weak performance on license examinations in the previous period had been
effective. Training facilities and materials were excellent, and the licensee's use of the
simulator for training, event analysis, drills, and observations of performance was a strength.
The requalification program identified weaknesses related to evaluation standards in the
operating portion of the examination and administrative procedures and controls for use of
the scenario examination bank during training. These weaknesses involved administrative
procedures and controls, and linkage between simulator scenarios and conditions.
6
The professional control room demeanor, nuclear safety perspective and knowledge of plant
activities of the licensed operators continued to be a strength. Operating procedures were
detailed and accurate. Operations managers implemented a number of procedure
enhancements to promote continued improvement. For example, SRO licensed personnel
author, review, and perform safety screening responsibilities for operations department
procedures, which has resulted in a decrease in the procedure revision request backlog.
Overtime usage was properly controlled. The personnel error rate was very low.
The licensee's implementation of the Emergency Operating Procedure (EOP) program was
very good overall. Several long-standing issues involving procedure implementation levels
were acceptably resolved. The licensee continued to improve the administrative procedures.
ROs and non-licensed operators demonstrated thorough knowledge and attention to detail in
the operation and testing of equipment and systems. Equipment operator effectiveness was
enhanced during the period by the implementation of a computerized equipment surveillance
log system, which simplified data collection and also provided improved data review and
trend analysis capabilities.
Concerned with a higher-than-expected number of scrams over the previous periods, the
licensee conducted a thorough investigation into the root causes of the scrams and
implemented a number of corrective actions during this period. During the current period
one scram occurred due to equipment problems and one due to contractor personnel error.
Licensee actions have effectively reduced the scram rate from that observed during the
previous period.
The fire protection program was good and staffed with dedicated fire protection personnel
from the Site Protection group, who responded to fire and first aid emergencies. Plant and
site management supported the fire protection program. The licensee's investigation of a
self-identified instance of misconduct by a firewatch revealed a more extensive weakness in
oversight and control of contract personnel performing roving firewatch duties. More than
half of the firewatch personnel annotated their logs to indicate they had inspected areas when
in fact they had not. The licensee's corrective actions were prompt and comprehensive in
assessing and resolving this deficiency once it was identified.
Overall, plant housekeeping was very good. Improvements continued during the period,
including facility painting, resealing of floor surfaces, using sticky pads to prevent dirt and
hot particle spread, and implementing a clean bootie program for selected work groups.
These activities positively reflected the level of support provided by management and
contributed significantly to plant cleanliness and housekeeping conditions.
The licensee effectively prepared for Hope Creek's fourth refueling outage, including a very
thorough shutdown risk assessment. Work performance during the outage was very good,
with minimal rework required. However, personnel errors contributed to two potentially
safety-significant events: an inadvertent loss of reactor cavity inventory and a short-term loss
of shutdown cooling. However, the licensee took prompt corrective actions to preclude
recurrence. The unit was returned to service in a safe and efficient manner.
7
Summary
PSE&G operated the Hope Creek unit in a professional and safety conscious manner, and the
frequency of abnormal events remained low. Strong management oversight and attention to
all operational activities were noted. The fourth refueling outage was effectively planned and
executed. Operator training was strong, as evidenced by the examination results and field
observations. Weaknesses were noted in management's oversight of firewatch program
activities.
ID.A.2
Performance Rating: Category 1
ID.A.3
Board Comments:
None
ID.B
Radiological Controls
ID.B.l
Analysis
The previous SALP rated the functional area of radiological controls as Category 1. NRC
reviews during the previous period determined that radiological controls staffing levels were
excellent, effective measures were taken to minimize personnel exposure, and radiological
work activities were effectively managed. The environmental monitoring and effluent
controls programs were effectively implemented as were the radwaste processing, handling
and shipping programs.
NRC reviews during the current period identified that there was a high degree of
management and supervisory oversight of radiation protection and chemistry activities. For
example, NRC reviews of outage activities identified very good work planning and control, a
high degree of radiation protection involvement in on-going activities, and excellent efforts at
minimization of ambient radiation dose rates and aggregate personnel radiation exposure
through successful implementation of the hydrogen water chemistry, iron reduction, and
depleted zinc injection programs. Although the 1992 goals for radiation dose and personnel
contaminations were slightly exceeded, the licensee performed very well in keeping exposure
As Low As Reasonably Achievable (ALARA). An aggressive refueling outage dose goal
was met despite emergent work. Planning and procedure development for implementation of
the revised 10 CFR Part 20 was very good.
The radiological controls organization was well defined, well staffed, and augmented, as
appropriate, to support outage work activities. There was minimal use of overtime and a
very good level of technical expertise within the organization. Late in the period the
radiological controls group was re-organized and the position of radiation
protection/chemistry manager was eliminated and replaced with direct reporting managers for
each organization. The re-organization was performed in a controlled manner and no
negative effects were identified by the close of the period. Appropriately qualified personnel
continued in responsible positions.
8
The training and qualification program continued to be a strength. Radiation workers
received appropriate and timely training. A new course titled, "Integrated Training," was
implemented at both Hope Creek and Salem Stations. This course involved radiation
workers and radiological controls personnel planning and performing work activities together
under realistic conditions on a mock-up. The majority of radiation protection and
maintenance personnel attended the course. The NRC considered the course a very good
initiative. Radiation protection and chemistry personnel were well trained and very
knowledgeable. A well defined initial qualification program for both permanent radiation
protection personnel and contractor radiological controls personnel was maintained.
However, an NRC review determined that the radiation protection technician staff were not
always reviewing required reading material (e.g., procedure changes). Enhanced supervisory
oversight of required reading activities was immediately initiated including supervisor
verification of completion.
The internal and external exposure control programs were effective and overall control of
radiological work activities was commendable. There were no internal or external personnel
exposures in excess of NRC limits and overall administrative controls of personnel exposure
were effective. An effective access control system using state-of-the art computer supported
equipment continued to be maintained. The weaknesses associated with quality control of
dosimetry, identified during the previous period, were corrected. Also, NRC identified
weaknesses in exposure records controls, identified early in the period, were also corrected.
Radiation protection personnel demonstrated excellent containment entry controls and
appropriately responded to the inadvertent reactor cavity inventory loss and standby liquid
control system boron loss.
The radiological occurrence report program, well supported by
management, was effective in identifying root cause and corrective actions for radiological
problems.
A strong radioactive material and contamination control program was implemented. The
licensee continues to maintain very good programs for monitoring and control of Zinc-65, a
difficult to detect radionuclide. Late last period, aggressive monitoring detected minor
migration of this contamination outside the radiological controlled area boundary into the on
site sewage system. The contaminated sewage was isolated and properly disposed of, and
appropriate corrective actions were implemented to preclude recurrence. Station
housekeeping continued to be noteworthy. Total contaminated area square footage was
rigorously controlled.
The radioactive waste processing, handling, storage and transportation programs continued to
be effective and well coordinated. Plans have been established for interim on-site storage of
radioactive waste in the event of delays in finalization of state compact efforts.
9
The ALARA program continued to be effective in maintaining personnel radiation exposure
low. Exposure goals were found to be challenging, planning and preparation was effective,
and very good oversight of on-going activities from an ALARA standpoint was performed.
The licensee continued to aggressively implement long term exposure reduction initiatives
(e.g., snubber reduction, iron reduction, hydrogen water chemistry, and robotics). A
working group, with BWR vendor representatives, was established to plan and implement
innovative shut-down techniques to maximize clean-up of radioactivity in the reactor coolant
during shutdown. Emergent work received appropriate reviews and ALARA controls.
The Radiological Effluent Control Program (RECP) and Radiological Environmental
Monitoring Program (REMP) continued to be effectively implemented during this assessment
period.
Licensee personnel exhibited good knowledge of all RECP areas including effluent
controls, radiation monitoring systems (RMS) and off-site dose calculations. Comparisons of
projected off-site doses between the licensee and the NRC PCDOSE computer code were in
excellent agreement. Procedures were detailed, concise and well written and resulted in
effective implementation of the RECP and REMP. Effluent RMS calibrations were excellent
and exceeded industry practices. The meteorological monitoring was effectively
implemented. Reactor coolant chemistry was excellent with a very low fission product
activity level.
Overall quality assurance (QA) oversight of program areas was very good. Special audits of
dosimetry program matters were conducted and independent assessors continued to be used to
effectively monitor outage activities. QA audits of effluent and environmental monitoring
programs were thorough and of sufficient technical depth to probe for programmatic
weaknesses. Findings were promptly resolved. Early in the period, the NRC identified a
weakness in the area of audits of personnel qualifications. It was not clear that personnel
qualifications of all appropriate groups were being systematically audited. The QA group
immediately initiated baseline audits and no unqualified personnel were identified.
Sum mazy
The licensee continued to maintain and implement an effective state-of-the art radiological
controls program. There was excellent support and control by management and effective
QA oversight. Staffing levels continued to be very good, and the ALARA program was
effective in reducing personnel exposure. The internal and external exposure control
programs were well maintained and effectively implemented as were the environmental and
effluent controls programs. Radwaste processing, handling, and shipping programs also
continued to be well maintained and effectively implemented.
ID.B.3.2
Performance Rating: Category 1
ID.B.3.3
Board Comments:
None
10
m.c
Maintenance/Surveillance
m.C.1
Analysis
The previous SALP rated the maintenance/surveillance functional area as Category 2,
Improving. Program strengths included effective management involvement, a stable, well-
trained staff, and well-written procedures. Weaknesses involved material procurement,
occasional lapses in attention to detail, and continued personnel error initiated plant events.
Maintenance
During this period, the Hope Creek maintenance program demonstrated superior
performance. The program was staffed with skillful, well-trained personnel. Procedure
quality and adherence were strong, and effective management oversight of activities was
present. Results from the maintenance program were excellent. Previous weaknesses
regarding procurement, attention to detail, and personnel errors were effectively addressed
and corrected.
Management supported specialized training, including the use of PSE&G's extensive
electrical and mechanical training facilities. Excellent procedure adherence and strong
direction from line management and supervision contributed to the high quality of work and
low error rates. Management at all levels, from first line supervision through department
and plant management, was observed in the field providing the appropriate oversight.
Maintenance program implementation provided excellent results. The quality of corrective
maintenance work was excellent, including a very low rework rate. There were no
maintenance initiated reactor scrams, and reportable events attributable to maintenance were
minor.
Effective maintenance planning and implementation resulted in a low maintenance backlog.
Equipment forced outages were rare and of short duration, an indication of an effective
preventive maintenance program. Based on NRC observation, safety-related equipment
availability was excellent.
PSE&G addressed previous weaknesses in procurement and personnel errors, and improved
the maintenance program in other areas. As previously noted, personnel errors were low and
significantly reduced from the previous period. Results improved in procurement as
demonstrated by adequate spare parts which properly supported work efforts. Management
strengthened their approach on planned equipment outages to ensure that a net safety gain
would be achieved during any planned and executed equipment/system outage. Based on
NRC inspection and observation, these initiatives were effective and demonstrated a safety-
conscious attitude.
11
The licensee continued improvement in the area of spare parts procurement and availability.
The new integrated and automated warehouse was placed into operation during the period
and provided effective support in efforts to reduce the corrective maintenance backlog and to
support refueling outage activities. For example, during the unit's fourth refueling outage,
the licensee ensured spare parts availability in order to complete scheduled tasks on time.
Additionally, parts were available for emergent work such that no negative impacts to
scheduled activities or outage duration occurred.
Hope Creek completed a scheduled mid-cycle outage, a refueling outage, and several forced
outages during this SALP period. Strong maintenance planning and outage organizations
conducted these outages safely and effectively. A strong safety-conscious attitude was
demonstrated during shutdown risk and equipment outage reviews. Emergency diesel
generator overhauls and control rod drive replacements were effectively and safely
conducted.
A wiring error caused by maintenance personnel was not corrected during motor-operated
valve work, and resulted in an unplanned reactor cavity inventory loss. This personnel error
was caused by inadequate wiring diagrams and tabulations, weak communications, and poor
working practices. PSE&G appropriately responded to this event and initiated effective
corrective actions.
Surveillance
The Hope Creek surveillance program was effectively implemented and demonstrated very
good results. Strong oversight by management and good cooperation among departments
contributed to a successful surveillance program. Surveillance tests were effectively
scheduled and tracked by the central planning organization using the maintenance information
system. Two surveillances were missed: one due to a personnel error and one due to a
procedure inadequacy. The frequency of these errors has continued to decrease over the last
few assessment periods.
The surveillance test program effectively demonstrated system operability. Surveillance
procedures were generally well written, appropriate and complete. Procedure weaknesses
were identified and immediately corrected. Implementation and review of surveillance
procedures were competently performed. A few instances of lack of rigor in post-test
reviews and comparisons with design data were noted. These were corrected upon
identification.
The number of surveillance caused events continued to decrease compared to previous
periods. There were no surveillance initiated reactor scrams as compared to two last period.
A total of 7 personnel errors occurred in the surveillance area (out of 9,000 surveillance
activities) which resulted in Licensee Event Reports; this total was fewer than last period.
Four engineered safety feature actuations were caused by personnel errors during surveillance
testing. Corrective actions for these events were thorough and timely. PSE&G completed a
design change to improve testability. This change provided better identification of test points
and relocated these test points to prevent inadvertent actuations.
12
The inservice inspection program continued to be well planned and implemented with
appropriate quality assurance department oversight. The feedwater nozzle ultrasonic
examinations and snubber examinations used state of the art technology and specially trained,
qualified technicians. The erosion/corrosion program was improved. PSE&G corrected the
prior identified weaknesses in the predictive analysis of erosion/corrosion rates by
establishing a programmatic standard for the erosion/corrosion monitoring program.
Sum mazy
Hope Creek demonstrated superior results in maintenance and very good results in
surveillance testing. Management involvement in improving program performance and
correcting identified problems was evident. Program strengths included effective, detailed
procedures, skillful staff, and excellent oversight by managers and supervisors. Although
some personnel errors occurred, they were at a decreased rate as compared to previous
periods. A maintenance caused wiring error resulted in an unplanned reactor cavity level
loss. Improvements were noted in procurement and material control.
m.c.2
Performance Rating: Category 1
m.C.3
Board Comments:
None
m.D
Emergency Preparedness (Hope Creek and Salem - Combined Assessment)
ill.D.1
Analysis
During the previous SALP, Emergency Preparedness (BP) was rated Category 1. That rating
was based on strong management involvement and commitment to BP, a highly qualified EP
staff, a thorough and innovative training program, and excellent support of off-site agencies.
PSE&G's Emergency Response Organization (ERO) was well qualified as evidenced by
effective exercise performance.
During this SALP period, the licensee responded to two events at Salem and two events at
Hope Creek. The Salem events were low river level and transportation of a contaminated
injured person to the local hospital; Hope Creek had an Emergency Core Cooling System
(ECCS) initiation with vessel injection and inoperability of primary containment. In each
case, PSE&G correctly classified these events as Unusual Events and properly implemented
the Emergency Plan. Notifications of on-site and off-site response organizations were
timely.
Salem Unit 2 also experienced a loss of Control Room overhead annunciators (OHAs) on
December 13, 1992. Operators restored the OHAs within two minutes of recognition of
their loss. However, this event involved the unidentified (for about 90 minutes) existence of
a condition defined as an emergency, and subsequent notification of cognizant
13
organizations was not accomplished until after repeated prompting by the resident inspector.
At the end of the SALP period, licensee classification and reporting of this event was still
under licensee and NRC review.
PSE&G's performance in the October 1992 full-participation exercise at Salem was very
good. Under a challenging scenario, strengths were identified in Emergency Response
Facility command and control, Technical Support Center engineering assessment, Operational
Support Center prioritization and management of repair tasks, and Emergency Operations
Facility (EOF) dose assessment. One exercise weakness was identified: the initial
(sheltering) protective action recommendation (PAR) was not consistent with this General
Emergency. That was corrected by an upgraded PAR (for evacuation). PSE&G conducted
numerous other drills during the period, including an assembly and accountability drill in the
protected area and an unannounced off-hours callout of the ERO. These were well
coordinated by the BP Department and showed excellent PSE&G initiative.
Management support of EP was evident. Senior managers met periodically with the
Manager, EP for program status reports. Senior staff were qualified in upper-level ERO
positions. EP staff regularly met with state and local officials to discuss EP issues. A very
good working relationship with off-site agencies was indicated. This was evident at a
PSE&G-sponsored forum for New Jersey State and local officials, FEMA, and the NRC to
discuss emergency response roles and relationships.
Independent licensee audits of the EP program were of good quality and resulted in minor
recommendations for program enhancement. The corrective action system was effective and
appropriately used by BP staff to track outstanding items to resolution.
BP training effectiveness was demonstrated during NRC-observed table-top walk-through
scenarios with shift crews from Salem and Hope Creek. Overall, crews worked together and
responded well. However, weaknesses were identified in making emergency classifications
and protective action recommendations (PARs), and in providing complete information to the
NRC. For example, the loss of containment was not recognized, this resulted in a different
classification than was specified in the Event Classification Guide and in non-conservative
PARs/PAR upgrades. Additionally, PSE&G Emergency Action Levels for fission product
boundary failures did not clearly address the loss of the containment boundary. PSE&G
committed to addressing these concerns through training and procedure revisions. The
effectiveness of the licensee's actions has not yet been inspected.
EP staffing was a strength. The program was administered by a stable staff of fourteen,
including a very good mix of well qualified and responsible senior reactor operator, health
physics, and maintenance personnel. The ERO was also fully staffed, with managerial
positions filled by experienced senior personnel.
PSE&G successfully implemented the Emergency Response Data System (EROS) in February
1993. Emergency Response Facilities were maintained in a very good state of readiness.
Appropriate equipment and supplies were available. Surveillances were completed at
prescribed frequencies and instrumentation was calibrated. Noteworthy improvements were
14
made to the prompt notification system (siren) hardware and software. All communications
equipment was found to be consistent with licensee procedures. However, portable
respirators were found stored inside the radiological controlled area instead of in designated
Control Room/Operational Support Center lockers.
Summary
PSE&G maintained a generally strong and effective EP program. Senior management
commitment to EP was evident through program involvement and qualification in key ERO
positions. EP was well staffed, with a good discipline mix. The Emergency Plan was
effectively implemented during four Unusual Events. Licensee response to the December
1992 loss of the Salem 2 control room OHAs resulted in non-classification and non-reporting
of a defined emergency which remains under NRC review. Training was generally good, but
table-top exercises, and emergency drills and exercise performance indicated a need to
improve procedural guidance and training in event classification and PAR formulation.
Facilities were maintained in good operational readiness.
ill.D.2
ill.D.3
ill.E
ill.E.1
Performance Rating: Category 1, Declining
Board Comments:
NRC was concerned with the licensee's ability to make
accurate and consistent PARs.
Security and Safeguards (Hope Creek and Salem - Combined A~ment)
Analysis
The previous SALP rated this area Category 1. That rating was based on the licensee's
maintaining an effective, performance-based security program which, in many areas,
exceeded regulatory requirements; and demonstrating sensitivity in effectively managing
events that challenged the performance of the security organization. In addition, audits and
self-assessments of the security organization, program upgrades and enhancements were
indicative of excellent support from both corporate and station management for the security
program.
During this SALP period, corporate and station management acted prudently and responsibly
in contracting for an independent review of station security and other support programs
following the off-duty suicide of a security-force member. The comprehensive, in-depth
review did not show any work-related culpability. Throughout the period, there were no
appreciable adverse results from the incident on the morale or performance of the security
organization.
Station security management demonstrated initiative in evaluating the effectiveness of the
security program and in enlisting the support of corporate and station management for
program improvements and enhancements. This initiative was evident by the licensee's
efforts to enhance tactical training by additional contractor support. The training involved
15
defensive strategy, full-scale contingency drills and tabletop analyses of numerous scenarios
of the design basis threat. Further initiative was shown in coordinating a security drill
among state and local law enforcement agencies, and the security force. The drill was well-
planned and executed. It also provided the law enforcement agencies with valuable insight of
security procedures and station layout. In addition, excellent management support,
throughout the period, was evident for the systematic upgrade of the aging assessment aids
and other program enhancements.
The licensee also maintained aggressive, effective audit and self-assessment programs
throughout the period. These programs were instrumental in identifying potential weaknesses
such as the improper control of safeguards information, and fitness-for-duty (FFD) problems
and assisting the licensee in implementing corrective measures before problems developed.
Excellent rapport with other plant groups also helped minimize the number and extent of
problems.
The FFD program was generally well implemented and comprehensive. However,
programmatic problems were identified relative to personnel with infrequent, unescorted
station access and training for newly appointed supervisors who were responsible for
implementing certain aspects of the FFD program. While the licensee identified these
problems, they were not effectively resolved before coming to NRC attention. Despite these
programmatic problems, the program proved effective in identifying personnel who did not
meet FFD requirements. For example, the licensee took effective corrective actions when a
supervisor on a tour identified a security officer who failed to meet FFD parameters.
Staffing for the security organi7.ation was appropriate. This was evident during the
unplanned outage following the turbine failure at Salem and three planned refueling outages,
two at Salem and one at Hope Creek. Each of the outages required only a small amount of
overtime for security personnel.
A minor supervisory oversight problem was identified by the NRC late in the period when
security personnel were observed searching a vehicle contrary to the manner in which they
were trained. Generally, however, supervisory oversight of the security force was good, and
the security force continued to demonstrate attentiveness to security responsibilities and
responsiveness to identified problems. This was evident in the relatively smooth day-to-day
on-site operations and prompt and appropriate handling of security threats, such as a
telephone threat and the identification by x-ray of contraband material. The security force
also performed very capably on April 10, 1992, when an apparent lightning strike resulted
in a loss of the security computer and during a severe winter storm that occurred
March 12-15, 1993, that resulted in significant system degradations.
Training for the security force continued to be well-developed and generally well
administered. This was evident, throughout the period, by the high level of performance
indicated above and the small number of security personnel errors during the period.
16
The licensee's event reporting procedures were found to be clear and consistent with NRC
reporting requirements. One event, which involved the x-ray search detection of contraband
mentioned earlier, required prompt reporting to the NRC during this period. The licensee's
report was clear, concise and indicated appropriate responses. The licensee's event log was
found to be well maintained and utilized for tracking repetitive events.
During this period, the licensee submitted two revisions to the physical security plan and one
revision to the training and qualification plan. The revisions were of high quality,
technically sound and reflected well-developed policies and procedures.
Summary
In summary, the licensee continued to maintain a very effective and performance-oriented
security program. Corporate and plant management attention to and support for the program
remained evident throughout the period. Improvements to the program were made where
necessary, to maintain its effectiveness. Excellent rapport was maintained with other plant
groups, to minimize problems. The audit and self-assessment programs remained effective,
and enhanced program implementation. However, corrective actions were not always timely
as evidenced by the delay in resolving FFD problems. Staffing reflected program needs and
the training program was strong. Program plans and procedures were well-written and
understood by all concerned and reflected a thorough and comprehensive understanding of
regulatory requirements.
ID.E.2
Performance Rating: Category 1
ID.E.3
Board Comments:
None
ID.F
Engineering and Technical Support
ID.F.1
Analysis
The previous SALP rated Engineering and Technical Support as Category 2. The previous
assessment indicated weaknesses in engineering's development of the safety-related motor
operated valves (MOV) program in response to Generic Letter (GL) 89-10. Other
weaknesses were also observed in Hope Creek responses to the Station Blackout Rule, in the
initial root cause evaluation associated with the filtration, recirculation and ventilation system
(FRVS) heater fuse failures and in responses to the NRC regarding GLs. Despite these
weaknesses, Hope Creek was provided with strong technical support during the previous
SALP period.
Engineering and Technical Support for Hope Creek is provided by corporate engineering,
known as Engineering and Plant Betterment (E&PB), and the onsite system engineering
group. These groups effectively provided technical support for refueling and maintenance
outage activities. E&PB handles major engineering efforts such as plant modifications and
,.
17
design bases reconstitution. The onsite system engineering group supports operations,
maintenance, testing and minor design change activities. These groups are well staffed with
experienced personnel in various engineering disciplines.
The onsite system engineering group was well-staffed with experienced, knowledgeable and
wen-trained personnel. The licensee continued their eight-month system engineer training
program. Most of the system engineers have successfully completed this program and almost
all have received formal root cause analysis training. The system engineering group has
provided good support for safe and efficient plant operation as demonstrated by the progress
made on the implementation of the GL 89-10 MOV program and by their analysis and
resolution of a number of emergency diesel generator design and operability issues.
However, there was a recurring number of EDG jacket cooling water pump seal failures. A
contributing factor to these failures was inadequate system engineering review and root cause
determination.
E&PB worked well with the onsite system engineering group. Examples included the torus
to drywell vacuum breaker disc torquing analysis and the emergent snubber analysis work
during the fourth refueling outage. Several improvements to the design change process were
made to reduce paperwork and better focus on safety significant issues. For example, a
simplified "workbook" or design and review package was introduced that significantly
reduced design package preparation and review time. In response to previously identified
deficiencies in the GL 89-10 program, the licensee made noteworthy progress in
implementing program requirements. For example, during the unit's fourth refueling outage,
134 of 258 MOVs were statically tested and 23 dynamically tested. However, a wiring error
and inadequate followup by engineering and test personnel resulted in an unplanned reactor
cavity level decrease.
The modification packages reviewed were of good quality. They were thorough and
contained adequate safety reviews. However, the licensee made a change to the facility as
described in the UFSAR without determining if there was an unreviewed safety question
involved. Furthermore, there were other isolated cases of the licensee failing to follow its
10 CFR 50.59 implementation procedure. Individually, these failures to follow procedure
did not have safety significance; however, the finding indicates a continuing defect in the
licensee's 10 CFR 50.59 program.
The licensee had an excellent training program for E&PB staff and onsite system engineering
personnel. A typical system engineer received substantial theory-based training, including
thermodynamics, heat transfer, and fluid mechanics. Recent enhancements to the E&PB
training program have advanced towards a more performance/application oriented approach.
The Design Change Process training was being expanded to include examples of completed
packages; the Configuration Baseline Documentation (CBD) training has been revised to
emphasize the application of the CBDs and the maintenance of the documents due to
regulatory and operating experience reviews. In addition, the licensee has an excellent Root
Cause Analysis and Decision Making course designed for members involved in problem
solving and incident investigations such as licensee event reports (LER).
18
The licensee has initiated an aggressive program to pursue resolution of the Hope Creek
hydraulic control unit (HCU) accumulator lining pitting problem, although the safety
evaluation indicated that the pitting would not inhibit the movement of the piston during a
reactor scram. The licensee aggressively gathered information from other utilities and the
accumulator vendors to resolve this problem, and instituted a program to detect this problem
in the remaining HCUs during the refueling outage.
E&PB assumed responsibility for locating discontinued parts and effectively implemented a
program to develop new sources for parts and to provide equivalent replacements. E&PB
has also initiated an aggressive program to reduce substantially the engineering work request
(EWR) backlogs for both Salem and Hope Creek. Similar progress was made by the onsite
system engineering. For Hope Creek, the number of EWR backlogs was reduced by more
than one third.
As a result of concerns identified during an NRC inspection at Salem, PSE&G identified
significant weaknesses in the site Erosion/Corrosion (EiC) Program. E&PB subsequently
implemented substantial programmatic improvements. The current program meets the
industry standards and appears effective to monitor long term EiC issues.
Sum mazy
Hope Creek was provided with improving engineering and technical support by a competent,
experienced and stable corporate engineering organi7.ation, and a wen staffed and
knowledgeable onsite system engineering organii.ation. Noteworthy progress was observed
in implementing the MOV program. The modification packages reviewed were of good
quality. The training program provided for E&PB staff and system engineering personnel
was determined to be excellent. The licensee has implemented an effective procurement
program, which utilized a user-friendly computer database system. Both E&PB and system
engineering groups have initiated aggressive programs to reduce substantially the engineering
backlogs. Weaknesses were identified in the erosion/corrosion program and the
implementation of 10 CPR 50.59. Root cause programs were generally effective with some
minor errors noted.
ID.F.2
Performance Rating: Category 2, Improving
ID.F.3
Board Comments:
None
ID.G
Safety As.ses.sment/Quality Verification
ID.G.1
Analysis
The previous SALP rated this area as Category 1 and indicated that Hope Creek was a well
run, safety conscious facility. The licensee effectively identified problem areas, and ensured
prompt and effective corrective actions. The licensee's management of the third refueling
19
outage was a noteworthy strength. The licensee's MOY program and its responses to generic
issues were noted weaknesses. Personnel errors were noted in all functional areas. Safety
review committees and QA groups provided effective and independent oversight of activities.
Throughout this period, individual performance was very good. Direct supervision at the site
by first and second line supervisors and comprehensive management oversight of station
activities were strengths. The licensee has been successful in reducing the personnel error
rate; however, errors were observed in some functional areas, including one by a contractor
which resulted in a manual reactor scram. Another example involved a motor operated valve
(MOY) wiring error was not corrected per procedures, and resulted in an unplanned reactor
cavity level loss. Troubleshooting by contractor engineering and test personnel failed to
properly identify, document and correct the wiring error, and resulted in a drain down of
about 50,000 gallons. Licensee follow-up for this event included a thorough root cause
investigation and establishment of effective corrective actions.
The licensee's amendment and relief requests were generally of high quality, though
occasional lapses in clarity and omission of detail were noted. This was evidenced in the
licensee's request for a change to the licensing basis for the emergency diesel generator
(EOG) fuel oil storage and day tank minimum level requirements.
Notwithstanding this specific deficiency, the Station Operations Review Committee (SORC)
provided consistent and effective review of other significant plant issues, including design
changes, post-scram reviews and reportable events. The licensee's major event review
process, the Significant Event Response Team (SERT), effectively performed comprehensive
scram and event reviews. Recommendations generated from SERT reviews were promptly
acted upon by management and tracked in the licensee's Action Tracking System. As
discussed in the engineering section, the licensee root cause corrective action and 10 CFR
50.59 programs were generally very good, with only minor problems noted.
The On-site and Off-site Safety Review Groups (SRG) and Station Quality Assurance (SQA)
demonstrated effective independent reviews of Hope Creek issues. For example, SRG
performed a detailed and effective review of the shutdown risk for the fourth refueling
outage. SQA performed a thorough review of a temporary air compressor tie-in and
identified concerns and recommended effective corrective actions. Both the SRG and SQA
provided assistance to all SERT efforts.
The licensee took aggressive action to review its reportable events. Licensee Event Reports
were well written and accurate.
Hope Creek conducted its fourth refueling outage during the period. Outage preparations
were excellent. A number of shutdown risk initiatives were successfully performed. SQA
was effective during all phases of the outage, performing a large number of performance
based surveillance and hold point activities. Overall outage performance was good.
_
,*
20
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
informative State-of-the-Station meetings. Corporate management was highly visible relative
to Hope Creek station activities. Operations personnel exhibited a professional and
questioning attitude during the performance of their duties. A review of the Hope Creek
turbine generator overspeed protection system was comprehensive and displayed a
conservative approach to safety.
Summary
The licensee continues to perform well in this functional area. The licensee's first line
supervision management, SORC, and independent third part oversight was very good.
Individuals performed well, as evidenced by a reduction in the personnel error rate.
Excellent independent review and root cause determinations continued to be observed this
period. The licensee's performance in the fourth refueling outage was judged to be
excellent.
m.G.2
Performance Rating: Category 1
m.G.3
Board Comments:
None
---~- __ J
21
IV.
SITE ACTIVITIES
IV .A
Licensee Activities
The Hope Creek unit began the SALP period operating at full power. The unit completed a
300 day continuous run when PSE&G shut down the unit on March 6, 1992, for planned
mid-cycle outage.
The unit was restarted on March 17, 1992, and operated at power until May 26, 1992, when
PSE&G initiated a shutdown due to failure of drywell-to-torus vacuum breakers. The unit
restarted on May 31, 1992.
The unit operated until September 12, 1992, when PSE&G initiated a shutdown to commence
the fourth refueling outage. The unit was restarted from the refueling outage on November
6, 1992. A reactor scram was manually inserted when both reactor recirculation pumps
tripped due to a loss of room ventilation on December 3, 1992. The unit was restarted on
December 10, 1992.
On May 16, 1993, the unit automatically scrammed from 60% power on high reactor
pressure due to a failed electrohydraulic control relay. The unit was restarted on May 19,
1993.
Small power reductions were performed throughout the period to perform maintenance and
testing activities. At the end of the SALP period, the unit was operating at fu11 power.
IV .B
NRC Inspection Activities
Four NRC resident inspectors were assigned to Artificial Island during the assessment
period. Two of these resident inspectors were rotated with new residents assigned during the
period. NRC team inspections were conducted in the following areas:
Emergency Preparedness Inspection conducted on October 27-29, 1992, to observe
the Artificial Island annual exercise.
Electrical Distribution Safety Functional Inspection conducted January 13 - February
14, 1992.
Surveillance Test Program Inspection conducted during April 6-21, 1992.