ML20140J387
| ML20140J387 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 06/12/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20140J379 | List: |
| References | |
| 50-354-97-03, 50-354-97-3, NUDOCS 9706190407 | |
| Download: ML20140J387 (34) | |
See also: IR 05000354/1997003
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION i
Docket No: 50-354
l License Nos: NPF-57
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Report No. 50-354/97-03
i Licensee: Public Service Electric and Gas Company
Facility: Hope Creek Nuclear Generating Station ,
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Location: P.O. Box 236
l Hancocks Bridge, New Jersey 08038
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l Dates: April 29,1997 - May 31,1997
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Inspectors: S. A. Morris, Senior Resident inspector
l J. E. Carrasco, Reactor Engineer '
J. Jang, Senior Radiation Specialist i
L. A. Peluso, Radiation Physicist
f D. Moy, Reactor Engineer
J. D. Orr, Reactor Engineer
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Approved by: James C. Linville, Chief, Projects Branch 3
Division of Reactor Projects
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9706190407 970612
PDR ADOCK 05000354
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EXECUTIVE SUMMARY
Hope Creek Generating Station
NRC Inspection Report 50-354/97-03
This integrated inspection included aspects of licensee operations, engineering,
maintenance, and plant support. The report covers a 5-week period of resident inspection;
in addition, it includes the results of announced inspections by a regional inspectors in the
areas of plant operations, engineering, and radiological effluents and environmental
monitoring. Additionally, a regional inspector was on site conducting oversight inspection
of the self-initiated Service Water Operational Performance inspection. The results of this
- effort will be documented in a future NRC report.
Operations
Operators responded well to the transient events, and acted safely, promptly and
effectively to stabilize plant conditions. Accurate event reports were completed well within ,
established criteria. (Section 01.1)
Operators demonstrated a generally good questioning attitude prior to authorizing ,
scheduled work in the station. Log keeping, peer checking, and procedural adherence was I
generally performed well. However, several examples of inappropriate equipment
manipulations and inattention to detail during control room operations caused the i
inspectors to question the effectiveness of recently instituted human performance '
improvement initiatives. (Section 04.1)
Maintenance
Observed maintenance activities were generally conducted well, with appropriate
procedures in use at the job sites. Frequent supervisory and engineering presence was
evident during risk significant on-line system outages. Work week management critiques
were thorough and highly self-critical. Recent management emphasis on corrective
maintenance backlog reduction has been effective. (Section M1.1)
Material condition of the station service water system improved as a result of the work
completed during recent on-line maintenance outages, but several unanticipated degraded
equipment conditions were identified during or following the work which led to a significant
increase in overall SSW system unavailability. (Section M2.1)
On two notable occasions, maintenance technicians failed to adhere to established
procedures for work on safety-related equipment; one of these instances resulted in the
unintentional (and unrecognized) inoperability of the high pressure coolant injection system
for 11 days. Though recently initiated corrective actions appeared to be good, prior
corrective actions stemming from similar previously identified occurrences were not
! adequate to preclude recurrence. (Section M4.1)
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Enaineerina
PSE&G's seismic evaluation of a condition involving missing or poorly secured Motor
Control Center and Substation Transformer cover bolts was considered to be good.
Corrective and preventive actions to address this specific concern were based on a
thorough root cause analysis and were deemed to be adequate. (Section E1.1).
Inadequate engineering design specifications provided to a strainer element manufacturer
led to additional station service water outage delays and design change implementation
deferrals. (Section M2.1)
Management of engineering work backlog improved during the period. Good engineering
involvement in the work week management process was observed. A Quality Assurance
department audit of engineering performance was judged to be excellent. However,
significant reductions in system engineering department staffing was a cause for concern
in light of the large engineering work load. (Section E7.1)
PSE&G's efforts to resolve a self-identified concern involving pre-mature f ailures of
Struthers-Dunn '219NE relays in safety-related panels was timely and comprehensive.
(Section E8.1)
Plant Support
The licensee implemented and maintained very good radioactive liquid and gaseous effluent
control programs which were in conformance with regulatory requirements. The chemistry
and radiation protection department staff demonstrated good knowledge of the effluent
control program. The radiation monitoring and plant air balance systems managers
(engineering department) also effectively demonstrated their knowledge of the programs.
The responsible department staff responded to QA Audit findings in a timely manner.and
with sound resolution. The inspector identified that sampling methodologies for air
particulates and charcoal filters could be improved to avoid the interruption of the effluent
Radiation Monitoring System (RMS) operation (Section R1 through R6).
The licensee continued to implement an effective radiological environmental monitoring
program (REMP) and meteorological monitoring program (MMP). The Offsite Dose
Calculation Manual (ODCM), Technical Specifications (TS), and the Updated Final Safety
Analysis Report were properly implemented. The 1995 and 1996 audit reports effectively
assessed the strengths and weaknesses of the REMP and MMP. The licensee's
performance of the REMP and MMP was good. Notwithstanding, the completion of a
design change package relative to updating and correcting thirty one meteorological
monitoring facility drawings was not timely. resulting in an unresolved item requiring
further review (R1 through R7).
The inspectors concluded that PSE&G operations and security personnel demonstrated
excellent response to the loss of vital area keys event; short and long term corrective
actions were both prompt and thorough. Security personnel appropriately logged this
event in department records. (Section S7.1)
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l TABLE OF CONTENTS
EX EC UTIV E S U M M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii
TA B LE O F C O NT E NTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv
l . O p e r a t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . 1 -
11. M a i n t e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
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lll. Engineering ................................................... 8
I V. Pl a nt S u p p o rt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
V. M anagem e nt Meeting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 ,
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Reoort Detajjs
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Summarv of Plant Status
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Hope Creek began the inspection report period at 100 percent power. Full power operation
was maintained throughout the period spanning April 29,1997 through May 31,1997,
except for a power reduction to 80 percent on May 27,1997 following an unplanned loss
of the "C" feedwater heater train and a further power reduction to 70 percent on May 31,
1997 to support control rod manipulations. At the end of the period the reactor had been
, operated continuously for 205 days and was 101 days from the beginning of the seventh
refueling outage.
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1. Operations i
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O1 Conduct of Operations j
j 01.1 General Comments (71707)
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Using NRC Inspection Procedure 71707, the inspectors conducted frequent reviews I
l of ongoing plant operations, in general, the conduct of operations was professional
! and safety-conscious; specific events and noteworthy observations are detailed in
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the sections below.
01.2 Opfrator Resoonse to Events and Transient Conditions I
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The inspectors continued to observe good overall operator response to transient
events and unplanned operational occurrences. During this report period, operators
were required to report three non-emergency events to the NRC. The first event
involved an unexpected automatic start (i.e. engineered safety feature actuation) of
the "C" station service water (SSW) pump on May 20,1997 while preparing to
remove the associated subsystem from service for a scheduled on-line maintenance
outage. This event was ultimately attributed to excessive silt buildup in the
redundant "A" SSW subsystem flow transmitter instrument lines which reduced the
indicated flow in that loop below the setpoint for opposite train automatic operation,
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l The second reportable event occurred on May 27,1997, and involved a brief,
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unplanned thermal power excursion 5 percent above the 3293 MW licensed power
level. This transient resulted from a failure of the power supply for the "C" feed
water heater train, which caused a reduction in feed water heating and a
subsequent reactor power increase. Additionally, operators effectively responded to
this transient condition and promptly placed the plant in a stable condition; alarms
were properly acknowledged, abnormal operating procedures were implemented,
and reactor power was quickly reduced to 80 percent using recirculation flow and
control rod insertion. Operators appropriately reported this event within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of
occurrence in accordance with Hope Creek license condition 2.F.
The final reportable event resulted from a May 28,1797 inservice test failure of the
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high pressure coolant injection system. Operators properly reported this condition
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j in accordance with 10 CFR 50.72(b)(2)(iii) as an event which alone could have
prevented the fulfillment of a safety function needed to mitigate the consequences
of an accident. Specific details associated with this event ara documented in <
Sections 04.1 and M4.1). l
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The inspectors concluded that operators responded well to the noted events, and
- acted safely, promptly and effectively to stabilize plant conditions. Accurate event
l reports were completed well within established timeliness criteria.
04 Operator Knowledge and Performance
04.1 Control of Routine Activities
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a. Inspection Scoce (71707) j
Throughout the report period the inspectors witnessed numerous activities in the l
> control room, including tasks which were administrative in nature as well as those
involving control of safety-related and balanca of plant equipment. Additionally, the
inspectors conducted frequent interviews and reviewed varying significance level
action requests generated in accordance with PSE&G's corrective action program,
both to assess the effectiveness of the program as well as to include self-identified
and self-revealing operational issues as part of the overall evaluation.
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b. Observations and Findinac
, The inspectors noted that operators typically demonstrated good, careful use of
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procedures both in the control room and in the field. . Additionally, when plant
l conditions warranted entry into abnormal operating procedures, that fact was
j generally noted in the reactor operator's narrative logs. Several reactivity
j manipulations were made during the report period which were completed without
j incident, in spite of difficulties experienced with several control rods " sticking" and
l " double-notching." Operators were appropriately sensitive to the impact of
scheduled work activities on plant operation, and frequently rejected ' work orders
which had the potential to adversely impact overall risk. The inspectors observed
frequent use of the newly instituted management expectation for " peer checking,"
which appeared to help increase individual awareness of planned equipment
manipulations during routine operation and testing.
In spite of the observations noted above, the inspectors were concerned about the
implications of two specific equipment mis-manipulations that were caused by
operations department trainees. Specifically, on May 25,1997, a trainee
l unintentionally operated a safety-system motor-actuated valve from the control
room while " walking down" a control panel. Another event which occurred just
after the inspection period ended involved a trainee who improperly operated
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emergency diesel generator controls from the control room while attempting to
synchronize the machine to its associated vital AC bus. The inspectors were
- concerned that station operators did not maintain an appropriate amount of
sensitivity and supervision over the actions of licensed-operator trainees.
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Additionally, the inspectors reviewed a licensee-identified issue involving multiple
errors associated with a routine quarterly inservice test (IST) of the high pressure 1
coolant injection (HPCI) system. Specifically, on May 29,1997, the Hope Creek
IST engineer determined that operators failed to establish the required HPCI system !
flow during the conduct of the test procedure, HC.OP-IS.BJ-0001(O). Further, the i
shift supervisor had reviewed and approwd the data recorded by the reactor j
operator during the May 28,1997 test and failed to identify that the acceptance ;
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criteria had not been satisfied. Subsequent root cause analysis performed by '
operations department personnel concluded that individual inattention to detail
during the conduct of assigned duties was the primary factor. The inspectors noted
that operators judged the May 28,1997 test to be invalid and the test was
successfully re-performed on May 30,1997.
The inspectors reiterated their concerns to station management regarding operations
department human performance during the conduct of routine evolutions; ;
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particularly since the inspectors had raised similar concerns following other events
in the recent past which were similar in nature. Hope Creek management stated
that human performance improvement was a top priority of the station, and that
severalinitiatives had been recently instituted to better understand the magnitude of
the problem (e.g. developed specific performance indicators) and to cause
immediate and lasting improvements in this area.
l c. Conclusions
l Operators demonstrated a generally good questioning attitude prior to authorizing
scheduled work in the station. Log keeping, peer checking, and procedural
adherence was generally performed well. However, several examples of
l inappropriate equipment manipulations and inattention to detail during control room
l operations caused the inspectors to question the effectiveness of recently instituted
human performance improvement initiatives.
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l 08 Miscellaneous Operations issue j
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08.1 (Closed) Violation 50-354/95-087-01013: failure to perform an adequate written
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safety evaluation prior to startup and operation of the Decontamination Solution ,
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Evaporator (DSE). The inspector verified the corrective actions described in the ;
licensee's response letters, dated August 17,1995 and September 15,1995, to be )
reasonable and complete. ;
08.2 (Closed) Violation 50-354/95-087-01023: failure to establish adequate procedures
for ensuring proper operation of the DSE, as well as for limiting any releases to the
environment. The insperior verified the corrective actions described in the
- licensee's response letters, dated August 17,1995 and September 15,1995, to be
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reasonable and complete. No similar problems have been identified.
l 08.3 (Closed) Violation 50-354/95-160-01014: failure to ensure a Senior Reactor
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Operator (SRO) remains in the Control Room. The inspector verified the corrective ;
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actions described in the licensee's response letter dated December 1,1995, to be
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l reasonable and complete. The inspector also verified the responsible Senior Nuclear
l Shift Supervisor's response letter dated October 10,1995, to be reasonable and
accurate.
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08.4 (Closed) Violation 50-354/95-160-02014: failure to submit a Licensee Event Report
after discovering that no Senior Reactor Operator was present in the Control Room.
The inspector verified the corrective actions described in the licensee's response
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letter dated December 1,1995, to be reasonable and complete. The inspector also
verified the responsible Senior Nuclear Shift Supervisor's response letter dated
October 10,1995, to be reasonable and accurate.
08.5 (Closed) URI 50-354/94-19-02: On September 16,1994, PSE&G reported that a
licensed Senior Reactor Operator assumed licensed duties as a Nuclear Shift
Supervkor without having completed the required proficiency watches. The
licensee implemented detailed instructions to alllicensed operators and Shift
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Technical Advisors (revised in Personnel Qualification and Trainina, HC.OP-AP.ZZ-
0014 on December 20,1994). Based on the isolated nature of the incident and the
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subsequent licensee administrative controls, the inspector concluded that PSE&G
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has properly addressed and resolved the issue. This licensee-identified and
entrected violation is being treated as a Non-Cited Violation, consistent with Section
Vh.B.1 of the NRC Enforcement Poliev.
08.6 (Closed) URI 50-354/95-016-01: On September 8,1995, an automatic ESF
actuation occurred when the HPCI pump suction path swapped over from the CST
to the suppression chamber on high torus level. This unresolved item was open
pending submittal of a Licensee Event Report. LER 95-020 was submitted on
October 9,1995. This LER was considered closed in NRC Inspection Report 50-
354/95-17. A supplement to LER 95-020 was submitted on November 30,1995.
The supplemental LER described the root cause and additional licensee corrective
actions. The inspector concluded that the licensee's analysis and corrective actions
in the supplemental LER were appropriate. The unresolved item is administratively
closed.
08.7 (Closed) Violation 50-354/95-019-01: failure to perform technical specification
requirements during a reactor shutdown and during refueling operations. The
licensee's responses to these violations were provided in Licensee Event Reports,
50-354/95-034-00 and 50-354/95-035-00. The LERs were ci sed in NRC
l Inspection Report 50-354/95-19. The inspector verified the corrective actions
l described in the LERs to be reasonable and complete.
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l 08.8 (Closed) Violations 50-354/95-216-01013&O1023&O1033&O1043: f ailure of
l Reactor Operators to correctly implement procedures during the shutdown cooling
l bypass event on July 7-9, 1995. The inspector verified the corrective actions
i described in the licensee's response letter, dated January 11,1996, to be
reasonable and complete. No similar problems were identified.
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11. Maintenance
M1 Conduct of Maintenance
M 1.1 General Comments
a. Insoection Scope (62707)
The inspectors observed all or portions of the following work activities:
- Hiller-actuated SACS valve replacements
- AK403 Safety-related panel room chiller unit outage
- "A", "C", "D" Service water system outages
- "B" Reactor protection system motor generator replacement
- Struthers-Dunn safety-related panel relay replacements l
- "E" Filtration, Recirculation, and Ventilation system outage
Details of specific work activities are documented in later sections of this report.
Additionally, the inspectors reviewed maintenance and planning department l
performance indicators, work week management critique reports, and quality ;
assurance audit materials while conducting their assessment.
b. Observations and Findinas
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Throughout the report period, the inspectors witnessed generally good overall
control and implementation of safety-related work activities at the station. In all
observed cases, appropriately authorized work orders and associated maintenance
procedures were present at the job sites. First-line maintenance supervisors and
planning department work week managers were frequently observed monitoring the
status of in-progress work activities. Temporary scaffolding, where needed to
support work, was properly constructed and evaluated per established guidance, )
and removed in a timely manner following completion of the work activities they
were there to support. Post-maintenance testing was adequate to demonstrate
equipment operability following outage completion.
The inspectors noted that corrective maintenance backlog at the station has been
reduced significantly over the past several months, from a total of nearly 1200 work
activities in December 1996 to approximately 600 at the end of the report period.
This fact indicated that recent management emphasis on corrective maintenance
backlog reduction has been effective. Overall work backlog, however, including
preventative maintenance items and work scheduled for completion during the
upcoming refueling outage, had not declined as dramatically.
Each week, station personnel involved with work week planning, scheduling and
implementation gathered to critically assess their performance with respect to the
work week management process. The inspectors noted that these assessments
were thorough and highly self-critical, and provided an open and honest evaluation
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of station performance. The inspectors observed that a common theme in recent >
work week critiques was that system outage scope growth and emergent work
resulting from unanticipated equipment failures had the largest impact on schedule
adherence, currently averaging about 85 percent. Additionally, inadequate planning
and procurement practices often caused scheduled work to be withdrawn just prior
to work commencement. The inspectors were aware that numerous initiatives were
either planned or being implemented to address the documented problems,
c. Conclusions
Observed maintenance activities were generally conducted well, with appropriate
procedures in use at the job sites. Frequent supervisory and engineering presence
was evident during risk significant on-line system outages. Work week
management critiques were thorough and highly self-critical. Recent management ;
emphasis on corrective maintenance backlog reduction has been effective. ;
M2 Maintenance and Material Condition of Facilities and Equipment
M2.1 Service Water System Outaaes
Three separate station service water (SSW) on-line maintenance outages were
conducted during the report period, all of which were designed to improve the
overall reliability of the system. The inspectors noted that PSE&G categorized SSW
as an "a(1)" system in accordance with 10 CFR 50.65 (" maintenance rule"), and
that appropriate justification had been established prior to increasing SSW
unavailability for additional on-line maintenance. Planning and engineering
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personnel developed adequate on-line maintenance plans in an effort to maximize
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the efficiency of the outages and to minimize their impact of plant risk. -The primary
objectives of the outages were to perform SSW pump replacements, implement a
discharge strainer element design change, and perform routine preventive 1
maintenance.
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In many instances, the objectives of the SSW outages did not meet expectations. i
Specifically, average outage lengths were double the scheduled durations, largely i
due to unanticipated work needed to resolve degraded conditions (excessive strainer ;
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vessel corrosion, a check valve replacement, a motor replacement, traveling screen '
misalignments, etc.) identified either during the outages or during post-maintenance
testing. Additionally, the planned strainer element modification could not be
implemented because the new elements would not fit properly in the strainer
assembly, a condition later attributed to a failure to provide the manufacturer with
appropriate critical dimensions prior to fabrication. Some procedural adherence
issues were also evidenced during the associated work, examples of which are
detailed in Section M4.1 below. The inspectors noted that, for each of the issues
that surfaced during the work, PSE&G personnel initiated action requests to !
document and determine appropnate resolution. j
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The inspectors concluded that, though the overall material condition of SSW system
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maintenance outages, several unanticipated degraded equipment conditions were
identified during or following the work which led to a significant increase in SSW
system unavailability. Additionally, inadequate engineering design specifications
provided to a SSW discharge strainer element vendor led to additional outage delays
and design change implementation deferrals.
i M4 Maintenance Staff Knowledge and Performance
M4.1 Maintenance Procedure Quality and Adherence
During the report period, the inspectors either observed or were informed of several l
instances of failures by maintenance technicians to adhere to established procedure !
requirements during safety-rela +ed work activities. Additionally, the inspectors
reviewed several action requests generated during the period which identified
problems with maintenance procedure quality.
Specifically, on May 22,1997, during an on-line maintenance outage of the "C" 1
SSW system, the inspectors reviewed a completed work package associated with a l
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pump discharge check valve inspection. The inspectors observed that a technician
had completed the inspection and had made narrative remarks on the work order
l regarding the "as found" condition of the valve and the fact that the inspection was
completed satisfactorily. Since some degradation of the valve internals was noted,
the inspectors questioned the basis for a satisfactory inspection and reviewed the
attached governing inspection procedure, HC.MD-GP.ZZ-0046(O). However, upon
review of the procedure at the job site, it was evident that the procedure had not
been used during the actual valve inspection since the applicable steps had not been
signed off and the included inspection checklist had not been annotated.
The inspectors questioned the cognizant mechanical maintenance supmvisor who
believed the check valve inspection to be within the " skill of the craft." However,
based on a review of PSE&G management expectations with regard to procedural
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compliance and an interview with the responsible work planner, the inspectors
concluded that the procedure should have been used. Additionally, the inspectors
judged the quality of the noted procedure to be weak in that no explicit inspection
acceptance criteria was available to make an informed decision about the
permissible amount of valve internal degradation. An action request was promptly
initiated to document the latter concern regarding procedure quality, but
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maintenance management intervention was required to document the former
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concern; an action request describing this issue was not generated until June 6,
1997.
On May 28,1997, station operators reported that the high pressure coolant
injection (HPCI) system was declared inoperable due a failed inservice test.
' Specifically, the pump minimum flow valve failed to close as required following
HPCI initiation. Prompt PSE&G investigation into the cause of this condition
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determined that the differential pressure transmitter which provides a signal for the
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minimum flow valve to close was " valved out" of service. Subsequent validation of
this presumed cause resulted in the discovery that this transmitter had been ;
calibrated by naintenance technicians on May 17,1997, but not properly restored ;
to service in rccordance with the governing maintenance procedure. Additionally, !
PSE&G learned that the independent verification of valve positions following the !
calibration activity was not performed according to procedural requirements,
resulting in a missed opportunity to identify the problem early on.
In response to this event, PSE&G management initiated a significance level 1 action
request to investigate fully the cause(s) of this event. Immediate actions, which
included a detailed review of all other work the responsible technician had ;
performed that day, were deemed to be comprehensive. The impact on the I
functional capabilities of the HPCI system (i.e. amount of system flow diverted I
away from the reactor vessel through the minimum flow valve), had not been fully i
evaluated by the end of the report period. Further, long term corrective actions and
preventive measures had not yet been developed, but the licensee stated that a
previously-initiated maintenance department " intervention," which involved two
weeks of intensive off-site maintenance training in an effort to improve the " culture"
of the department, was intended to result in improvements in this area. Finally, an
operations and maintenance department " stand down" was held by station
management on May 30,1997, to communicate the implications of this event and
to reiterate PSE&G management's expectations with regard to procedural
compliance,
in light of the above described events, combined with recently issued licensee event
reports (LER 97-04 and 97-06) which describe reportable events attributed to poor
maintenance practices, the inspectors judged that the corrective actions instituted
as a result of similar NRC findings made in early 1996 as part of the Restart
Assessment Team inspection and follow up reviews, were ineffective. As a rasult,
the inspectors judged these recent examples of maintenance technicians failing to
adhere to applicable procedures for safety-related work to be two examples of a
violation of 10 CFR 50 Appendix B Criterion XVl; specifically, ineffective corrective
action for a previously-identified significant condition adverse to quality. (VIO 50-
354/97-03-01)
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E1 Conduct of Engineering
E1.1 NRC Follow-uo on Loose or Missina Fasteners Associated with Electrical Covers of
l the Motor Control Center (MCC) and Substation Transformer (ST) Cabinets
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a. Insoection Scoce (92903)
On May 14-16,1997, an inspection of Hope Creek Generating Station was
performed to determine the status of the licensee's assessment and corrective
actions for loose or missing fasteners for the electrical covers of the Motor Control
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Center (MCC) and Substation Transformer (ST) cabinets. The scope of this
inspection included: a) a review of the root cause analysis addressing the loose or
missing fasteners; b) a review of the seismic evaluation to verify that the as-found
condition of the MCC and ST are capable of withstanding a postulated seismic
event by keeping the back covers in place; and c) an assessment of the licensee's
corrective and preventive actions.
b. Observations and Findingn
> Root Cause Analysis
The inspector reviewed the licensee's root cause analysis which concluded that the
design of the MCC cover attachment was poor because periodic removal of the
panels to perform routine maintenance activities is required. Action Requests (AR)
were initiated on all deficient MCCs to address the generic implications. All existing
deficiencies have been evaluated and no deficiencies which would affect seismic
operability were found.
PSE&G engineering personnel also determined that the ST cabinet cover problems
were the result of damaged threads or mechanical misalignment; and, in addition,
these deficiencies had not been entered into the station Corrective Action Program.
The inspectors noted that this has been corrected and that all deficiencies have
been entered. Once again, there were no seismic operability implications regarding
the STs as a result of cover fastener problems.
Seismic Evaluation
The inspector reviewed the licensee's seismic evaluation of the as-found
configuration of the MCC and the ST back cover fasteners and determined that the
evaluation was performed properly and that the conclusions regarding operability
were reasonable.
The Equivalent Static Method was used to perform the Seismic II/I evaluation on the
MCC back covers with missing screws. The acceleration used in the evaluation
was very conservative. The results showed that the stress on the screws is within
the allowable tolerance. Seismic evaluation for the ST cover with missing bolts was
also performed using Site Specific acceleration data, and Equivalent Static Method.
The resulting calculated stresses were less than the allowable and in both
cases (MCC and ST) the calculated results support the conclusion that the as found
configurations were capable of holding the covers in place. Therefore, there was no
potential Seismic 11/1 interaction.
Corrective Actions
Although in this case the operability of the as-found configuration of the missing
and loose back cover fasteners of the MCC and the ST cabinets was demonstrated,
the licensee took corrective and preventive actions to reduce the likelihood
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l of loose or missing cover fasteners. The inspector reviewed the licensee's actions
and determined them to be acceptable. ;
Alternate methods of securing the MCC covers were considered. Based on this
evaluation, a tool has been procured and satisfactorily tested to install a threaded
insert in the hole left by stripped threads. With the threaded insert installed, a
machine screw is used to secure the MCC cover. Since an MCC outage is required
to install the threaded inserts, the noted problems will be addressed during normally
scheduled MCC outages. The MCC Preventive Maintenance (PM) Procedure
(HC.MD-PM.ZZ-OOO6 (Q)) will also be revised to provide instructions for installing
threaded inserts in the stripped thread locations. This action will begin during the
upcoming Hope Creek refueling outage (RF07), when the MCCs scheduled for PMs
will be taken out of service.
Regarding the transformer covers, licensee management stressed that maintenance {
personnel must ensure that ARs are initiated for all conditions adverse to quality as
described in NC.NA-AP.ZZ-OOOO (Q), " Action Request Process." When equipment
is reassembled after corrective or preventive maintenance, it is the expectation that
all bolts and fasteners will be properly secured before the equipment is released for
service, or an AR will be initiated to docurnent any deficiencies.
c. Conclusion
Thorough root cause and seismic analyses demonstrated that the licensee
appropriately addressed the issue of loose or missing fasteners associated with
electrical covers of the Motor Control Center (MCC) and Substation Transformers
(ST) cabinets. Operability of the as-found condition was demonstrated, and the
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-corrective and preventive actions to ensure proper fastening of these back covers
appear to be adequate.
!
E7 Quality Assurance in Engineering Activities ,
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E7.1 General Observations
a. Insoection Scope (37551)
Throughout the report period, the inspectors focused on the quality oversight of
engineering department work. The inspectors reviewed quality assurance (QA)
department audit reports, action requests generated pertaining to engineering work
practices, and conducted interviews with various levels of the design and system
engineering staffs,
b. Observations and Findinas
in general, the inspectors observed good coordination of scheduled work week
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activities with engineering staff. System engineers were frequently observed in the
plant monitoring the status of work activities 'Jeing conducted on their respective
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' systems. Engineering backshift coverage was also evident for significant on-line
system outages. l
l The inspectors noted that management of the engineering work backlog, which
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included evaluations to support action request (corrective action program) follow up,
safety evaluations for planned design changes, and resolution assessments of
degraded plant equipment, improved over the past several months. Specifically,
engineering supervision instituted changes in the manner in which work backlog
was tracked and pricritized to better understand and manage the efforts needed to
reduce significant overdue items. Additionally, engineering department
performance indicators were established and utilized to assist station managers in
their evaluation of needed focus areas.
Several exarrDies of engineering department work at the individual level was also
judged to be good. For example, on May 9,1 An7, a system engineer initiated an
action request to document a self-identified concern involving a potential single l
failure issue in the rod control system. This potential failure mechanism, which had 1
been previously unrecognized in the nuclear industry, was promptly reported to the )
equipment vendor for 10 CFR 21 reportability evaluation. Additionally, this concern !
was communicated to operations personnel with recommended compensatory
actions to mitigate the resultant effects should such a failure occur. Another
example of quality engineering work involved follow up to a self-revealing event in
which contaminated water was discovered the station's service air system. Prompt
and effective re ponse to this issue was evident; engineers initiated a good plan to
identify the source of the contamination and developed a safety evaluation (later -
appaved by the Station Operations Review Committee) which justified continued
use of the service air system until the problem was ultimately corrected.
The inspectors reviewed the results of a recently completed QA department audit of
engineering practices. Seventeen different individuals participated in this month-
long review, several of which were non-PSE&G employees specifically utilized to
gain insights from industry operating experience. The auditors concluded that while
engineering work practices, including design change development, safety evaluation
performance, and communications were improving, several problems were still
evident regarding compliance with established engineering programs and l
management expectations. Specific concerns wee raised with respect to the !
quality and quantity of departmental self-assessments, inconsistencies in
engineering documentation, and attention to detail in configuration management.
Several concerns involving engineering " cultural" issues were also highlighted,
which seemed to indicate that future good performance of entineers would be
affected if the issues raised were not promptly addressed by sution management.
Overall, the inspectors judged the quality of this OA effort to be excellent.
Lastly, the inspectors noted a declining trend in system engineering department
staffing over the past several months. Specifically, nearly 10 engineers of a
normally 30 to 35 member department had either left the comoany or the
engineering organization. In recognition of some of the cultural issues raised in the
I. recent QA audit, combined with the large engi ering work backlog and the
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l necessary preparations for the upcoming refueling outage, the inspectors were
l concerned that the quality of engineering work, especially the routine plant system
monitoring to support continued safe and reliable operation of the facility, would
degrade. Tho inspectors expressed this issue to station management and learned
that the concerns were shared by them and that they were taking comprehensive
steps to mitigate the potential impact of the reductions in staff. These steps
included hiring temporary contractor personnel, recruiting new engineering
employees, and diverting some routine work to other Hope Creek departments.
c. Conclusions
Management of the engineering work backlog improved during the period. Good
engineering involvement in the work week management process was observed. A
Quality Assurance department audit of engineering performance was judged to be
excellent. However, significant reductions in system engineering department
staffing was a cause for concern in light of the large engineering work load.
E8 Miscellaneous Engineering issues
E8.1 LClosed) LER 50-354/97-007: Struthers-Dunn 219NE Series Relay Failures Due to
Thermal Degradation of Magnetic Vinyl Plastic Bearing Pad Material. This issue was
described in NRC Inspection Report 50-354/97-02, Section M8.2 (see also URI 50-
354/97-01-02). Based on a review of the information documented in this Licensee
Event Report, and an independent verification of a sample of the corrective actions
planned and/or implemented to date, the inspectors concluded that PSE&G's efforts
to resolve this matter were timely and thorough. Additionally, the inspectors
concluded that PSE&G's documentation of this concern accurately described the
circumstances involved.
E8.2 (Closed) URI 50-354/97-01-02: Struthers-Dunn 219NE Series Relay Failures Due to
Thermal Degradation of Magnetic Vinyl Plastic Bearing Pad Material. This issue was
left unresolved pending inspector review of an associated licensee event report,
primarily to determine the adequacy of planned corrective actions. This LER review
is described in section E8.1 above. Based on che results of this review, the
inspectors considered this item closed.
IV. Plant Support
R1 Radiological Protection and Chemistry (RP&C) Controls
R 1.1 Imolementation of the Radioloaical Environmental Monitorina Proaram
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- a. Inspection Scoce (84750)
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The Radiological Environmental Monitoring Program (REMP) was inspected against
Sections 3/4.12.1 and 3/4.12.2 of the Technical Specifications (TS) and Regulatory
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L Guide 4.1, " Programs for Monitoring Radioactivity in the Environs of Nuclear Power
! I'lants." The following activities were conducted to assess the licensee's capability
la implement the program,
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- Review of the land use census results;
- Review of sample results to confirm sample frequency and impact of the
p! ant on the environment;
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- Assessment of the method for evaluating the results of the samples;
- Observation of personnel collecting samples from selected sampling
locations;
- Examination of air sampling equipment relative to function, operability, and
calibration; and,
- Review of results of prevailing wind determination for the last ten years to
assess any significant changes since pre-operation to the present.
b. Observations and Findinas
Previously, oversight of the REMP was the responsibility of the senior staff )
engineer, Chemistry Services, Technical Services, in April 1997, the REMP was
moved to Radiological Protection Services, Technical Services. (Section R6.1
pertains.) The contractor laboratory, PSE&G Maplewood Testir.g Services (MTS),
- was responsible for the collection and analysis of environmental samples,
performing the land use census, reviewing and assessing the' analytical data, and
generating the annual Radiological Environmental Operating Reports (REOR).
The inspector reviewed the REMP procedures and observed the contractor
personnel collect certain samples using the procedures. The sampling and analysis
procedures were controlled and updated by the laboratory and Technical Services
maintained a copy of the procedures. The REMP procedures contained appropriate
information and methods comparable to industry standards and good practices. The
inspector observed the centractor personnel exchange air particulate filters and
charcoal canisters from selected air samplers, and discussed certain sample
techniques not observed such as collection of milk, water, and sediment samples.
The inspector visited a milk farm and several selected thermoluminescent dosimetry
(TLD) locations for direct radiation measurements. Sampling procedures and
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practices were designed to minimize the chances of cross contamination. Samples ,
were collected from the locations and at the frequencies required by the TS and
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ODCM. The analytical results demonstrated that the types and frequencies of
analyses were performed as required. The inspector noted that radiological dose to
j the public was in conformance with technical specifications.
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The licensee continued to collect and analyze supplemental samples in addition to
the routine samples required by the requirements in Technical Specifications to
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enhance the data source of the environmental monitoring program. The type,
i frequency, and results of the routine and extra samples were documented in the ,
Annual Radiological Environmental Operating Reports (REOR) for 1995 and 1996. !
In 1996, the licensee removed analyses not specifically required by the Salem and
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Hope Creek Technical Specifications from the REMP. The' analyses removed.were_
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l the strontium analysis in air particulates, well and potable waters; gross alpha ,
analysis in air particulate and surface waters; monthly TLDs; gamma spectroscopy ;
in beef; potassium-40.by atomic adsorption; and tritium analysis of fish and crab l
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flesh. The changes were documented in the 1996 annual REOR. The inspector
reviewed the licensee's justification and noted that the licensee determined that the
program changes would not impact the intent of the REMP. The licensee continued
to collect more samples than required by the TS and implemented the REMP ,
effectively.
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[ The 1996 land use census was performed by October 25,1996, according to the
l procedure and Section 3/4.12.2 of the TS. Performance of the land use census
l was thorough and complete. No program changes (e.g., changes in sample
! locations) were required as a result of the census. 1
i in 1995, the licensee moved an air sampler (location 2F2) 1.4 miles closer to the
l sits. The air sampler was moved because electricity at the original location had
I been terminated. The new location was indicated as 2F6 (same sector) in the
ODCM. = The licensee submitted a safety analysis review according to 10 CFR
50.59. The inspector reviewed the analysis and determined it to be complete. !
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Based on the wind direction analysis, the licensee's decision for the new location
appeared to be satisfactory
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The inspector reviewed the wind direction assessments (wind roses) from the past
10 years and compared them to the pre-operational. wind roses to detect changes, if
any, in the prevailing wind directions. No significant changes were determined.
The environmental monitoring control stations are still valid.
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The inspector noted the licensee intends to move the location of the control air
sampler. Currently, the sampler is 110 miles north from the site, located on the i
roof of the Maplewood building. Although this location is clearly beyond impact j
from plant operations, the licensee decided to place a new sampler closer to the i
sight and in the least prevalent wind direction. The original control air samplers will I
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remain until the new ones becomes effective. The licensee reviewed meteorological
data from June 1969 to May 1971, January to December 1995, and January to i
June 1996 to determine the most appropriate location for the new air sampler. The !
licensee chose a location in the west northwest direction (Sector 14) approximately
15 kilometers from the site. The inspector reviewed the data and determined that
the licensee's choice for this new sampler satisfies both the Salem and Hope Creek
Technical Specifications. The licensee plans to submit a safety analysis review
! according to 10 CFR 50.59 and document the change in the ODCM.
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The inspector noted that Technical Services does not have a program / process to ,
periodically review and assecs results of the environmental samples analyzed by the
contractor laboratory. The contract laborator y collects and analyzes environmental i
i samples, reviews the analytical results, and generates the annual REOR. The senior
! staff engineer, Technical Services reviewed the annual report approximately 2 to 3 .
l weeks prior to submittal to the NRC, as required by procedure NC.CS-RR.ZZ-0003 '
j -(Q), " Implementation of the REMP." Technical Services relied on the laboratory +
itself and the quality assurance audit program to review the analytical results. The 1
inspector discussed this issue with the Tecnnical Services supervisor who j
i subsequently initiated actions to incorporate periodic review of analytical results as
part of the REMP oversight. l
! The air samplers were in operation and good physical condition. The MTS
! personnel maintained a program to minimize the amount of sample loss due to
mechanical failure. Each unit was inspected for general function every week during
exchange of filters and cartridges. They were replaced every 12 months for
overhaul and the gas meters were calibrated every 2 years. The results of the
calibrations were within the established acceptance criteria. The inspector noted
that the procedure did not specify calibration frequency for the gas meters. The
i licensee stated that a calibration frequency will be added to the procedure and
justification for the selected frequency will be documented by the end of 1997,
c. Conclusions
Based on the above review, observation, and discussions, the inspector determined
the licensce's performance in implementing the REMP continued to be good.
R1.2 Meteorolooical Monitorina Proaram (MMPl
a. Insoection Scope (84750)
The Meteorological Monitoring Program (MMP) was inspected against -1
l Sections 2.3.3.2 and 7.7.1.13 of Salem UFSAR and Sections 2.3.3 and 7.7.1.11 of !
Hope Creek UFSAR. The following activities were conducted to assess the
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licensee's ability to implement the program.
- Review of calibration procedures, calibration results, and channel check logs;
- Review of calibration results of individual sensors;
- Discussion of data acquisition and availability of data; l
- . Observation of the material condition of meteorological equipment; and
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- Reviewed status of the meteorological monitoring facility drawings. j
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b. Observations and Findinas
The inspector observed the contractor, J. Healy Co., perform the quarterly
calibration of the meteorological monitoring instrumentation. The inspector noted
that the licensee performed the calibrations according to the implementing
procedures. The licensee does not submit the wind speed sensors to a wind tunnel
test. The licensee relies on the contractor's knowledge and experience to ensure
the sensors are performing properly. Every quarter, the contractor performs a visual
check for cup damage and shaft alignment, tests are performed at the logic board
from the sensor, zero and span checks are performed, and known signals generated
by a calibrated Fluke digital voltmeter are traced through the loop and the bearings
are replaced semi-annually to assure the low starting speed threshold is met. The
results of this calibration were within the acceptance criteria. The inspector
reviewed calibration data from 1995 to 1997. The calibrations were performed
quarterly, checks were performed monthly, and the results were within the
acceptance criteria as required by the procedure ND.RS-SC. MET-1201 (Q) Rev. 3, ,
" Artificial Island Meteorological Monitoring Program Calibration and Maintenance l
Procedure."
The inspector reviewed the UFSAR for Salem and Hope Creek and 'W i
meteorological administrative procedure. Hope Creek received approval from the l
NRC to transfer the meteorological program requirements from the TS to the Hope !
Creek UFSAR on September 25,1996. The administrative procedure ND.RS-
AP. MET-1201(O), "ArtU:cial Island Meteorological Monitoring Program
Administrative Procedure" dated July 1995 had not been changed to reflect the
transfer. In response, the licensee initiated actions to update the administrative
procedure.
The incoector reviewed the status of thirty one (31) meteorological monitoring
facility drawings and noted that the drawings were in the process of revision. The
31 drawings consisted of electrical, mechanical, piping, and instrument drawings.
The inspector noted that the licensee had not taken action to complete a design l
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change package (DCP 1 AE-1075) relative to making corrections (red-line) to the
drawings since the DCP had been initiated. The DCP had been initiated in 1994 in
response to an action request opened during the 1993 quality assurance audit. The
1993 audit identified deficiencies in 31 meteorological monitoring facility drawings.
The 1995 quality assurance audit identified, during follow up of corrective actions
relative to the 1993 action request, that the DCP 1EA-1075 had not been
completed and that no action had been taken by the responsible department.
Another action request was opened and the auditor received a completion
commitment date of November 15,1995. The inspector noted, as of May 16,
1997, that DCP 1EA-1075 had remained open, the revised drawings were not
validated, and were not considered controlled drawings. The inspector discussed
this issue with the auditor and Technical Services and noted that no action had
been taken to complete the DCP. The licensee representatives stated that they
planned to review the drawings and the current configuration applicable to the
drawings to ensure the current revisions are correct, make further revisions if
l necessary, and complete the DCP after the restart of the Salem Unit 2.
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The inspector noted that these drawings may not be related to the safety of the
plants, but have been used on at least two occasions to make repairs to the tower
(i.e., a power transmitter relay and an inverter). Notwithstanding, without
controlled drawings in place, potential exists for improper or inadequate repair,
modification, or design change to components and systems that affect the
meteorological monitoring program.
Based on the above findings, the inspector determined that completion of the DCP
was nct timely and that this matter represented a weakness in the licensee's ability
to effect timely corrective action for self-identified deficiencies. This matter is
considered an unresolved item pending review of the licensee's process and
procedures for maintaining control of configuration and design relative to this
matter. (URI 50-272/97-12-01; 50-311/97-12-01; AND 50-354/97-03-02)
c. Conclusion
Based on the direct observations, discussions with personnel, and examination of
procedures and records for calibration of equipment, the inspector determined that,
overall, the licensee's performance of maintaining and calibrating the meteorological
monitoring instrumentation was very good. The data were available as required and
were easily accessed from several locations, including the control room and the EOF
as specified in the UFSAR. The licensee's actions to complete the DCP were not
timely, and require further review.
R1.3 Implementation of the Radioactive Liauid and Gaseous Effluent Control Proarams
1
a. Inspection Scope (84750-01) j
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The inspection consisted of: (1) tour of radioactive liquid and gaseous effluent
pathways and its process facilities including effluent radiation monitorF, radWaste j
control room, and the main control room; (2) review of radioactive liquid and i
gaseous effluent release permits; (3) review of unplanned or unmonitored release l
pathways; (4) review of the quantification technique for the airborne tritium release, i
and (5) observation of air particulates and charcoal sampling techniques. !
b. Observations and Findinas
The inspector toured the radwaste and main control rooms and selected radioactive l
liquid and gas processing facilities and equipment, including the effluent radiation l
monitors and air cleaning systems. This equipment was operable at the time of the
tour. Effluent / process / area radiation monitors were also operable. )
Effluent / process / area radiation monitoring terminals in the main control room and at
the HP checkpoint were also operable.
During the review of selected radioactive liquid and gaseous effluent discharge
permits, the inspector determined that discharge permits were complete and met
the Technical Specification /Offsite Dose Calculation Manual (TS/ODCM)
requirements for sampling and analyses at the frequencies and lower limits of
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detection established in the TS/ODCM. The inspector also noted that there were no
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unplanned /unmonitored radioactive liquid and gas releases since the previous
inspection conducted in February 1996. The inspector noted that the licensee had
reviewed the effluent control programs relative to IE Bulletin No. 80-10,
" Contamination of Nonradioactive System and Resulting Potential for Unmonitored,
Uncontrolled Release of Radioactivity to Environment."
- The inspector requested the licensee to demonstrate its capability for monitoring
l and quantifying airborne tritium. The licensee used the water loss values described
in the UFSAR (2 gpm for normal operation and 5 gpm for refueling operation) from
the spent fuel pool (SFP), since actual makeup to the spent fuel pool (SFP) is not
normally tracked. The licensee assumed that water loss was due to evaporation
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from the SFP released to the environment via the plant vents. The licensee
I calculated the airborne tritium released using SFP tritium measurement results.
Calculated airborne tritium released through the plant vent during 1996 was 14.04
l curies and through the main condenser evacuation was 3.7 curies. The licensee
! reported, in the 1996 Annual Effluent Report, that 18.96 curies of airborne tritium
was released. Accordingly, the inspector determined that the licensee's
assumptions and calculation methodologies were effective in monitoring and
quantifying airborne tritium releases. The inspector noted that if the licensee
tracked actual makeup to the SFPs more accurate airborne tritium release could be ;
calculated.
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The inspector observed sampling methodologies for particulate filters and charcoal ^
cartridges at the north piant vent (NPV) sampling skid. The inspector noted that the l
sampling skid had separate sampling chambers for the particulate filter (moving
filter) and the charcoal cartridge. The licensee took about two hours to complete
the weekly sampling. The inspector stated that the sampling time could be
reduced, perhaps from hours to minutes, if the configuration of the sampling skid
was changed to follow industry standard practice. The current industrial practice l
! for the air particulate filter uses the same diameter filter as the charcoal filter and
ascembled in the same sampling chamber. The inspector noted that the RMS
system manager had evaluated modifying the sampling skid for all plant vents prior
to this inspection. This improved sampling skid is expected to be installed upon the
completion of the evaluation and approval by management.
c. Conclusions
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Based on the above reviews, that inspector determined that the licensee maintained
and implemented very good radioactive liquid and gaseous effluent control programs
that were effective in monitoring and controlling radiological effluents.
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R2 Status of RP&C Facilities and Equipment
R2.1 Calibration of Effluent / Process / Area Radiation Monitorina Systems (RMS)
a. Insoection Scoce (84750-01)
The inspector reviewed the most recent calibration results for the following selected
effluent / process RMS and its system flow rates. The inspector also reviewed the !
licensee's RMS self-assessment and RMS availability.
l
e South Plant Vent Stack (low, mid, and high ranges) Monitors,
o South Plant Vent S;ack Flow Rate Measurement Device
- North Plant Vent Stack (low, mid, and high ranges) Monitors, j
e North Plant Vent Stack Flow Rate Measurement Device !
e FRVS Noble Gas Monitor,
e Offgas Radiation Monitor,
e Liquid Radwaste Discharge Monitor,
e Cooling Tower Blowdown Monitor,
e Cooling Tower Blowdown Flow Rate Measure. ment Device j
e Safety Auxiliary Cooling Radiation Monitor,
o Control Room Vent Radiation Monitor,
o Main Steam Line Monitors,
e Spent Fuel Pool Area Radiation Monitor, and
e Auxiliary Building Area Radiation Monitor. l
b. Observations and Findinas
The l&C department had the responsibility to perform electronic and radiological
calibrations for the above radiation monitors. The system manager had the
responsibility to trend and track the above RMS. All reviewed calibration results
were within the licensee's acceptance criteria. Calibration results of the offgas
monitor will be reviewed during a subsequent inspection, as they were unavailable
to the inspector due to being microfilmed.
During the review of tSe above RMS calibration documentation, the inspector
independently calculated and compared several calibration results, including linearity
tests and conversion factors. The inspector determined that the licensee's results
were comparable to the independent calculations.
The licensee applied very good calibration methodologies for the above area
radiation monitoring systems, including radiological and electronic calibrations.
Alert and alarm setpoints calculation methodologies were good. Calibration
procedures were very detailed and easy to follow.
The inspector also reviewed RMS assessment and quarterly trending reports that
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were prepared by the RMS system manager. The RMS system manager assessed
the RMS availability using a tracking system (e.g.,99.0% availability of the TS
radiation monitor during the first quarter of 1997). The inspector determincd that
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the RMS system manager provided focus and attention in the areas of: (1) RMS
system improvement project; (2) trending analyses for conversion factors and
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linearities; and (3) follow-up on the progress of modifications.
j c. Conclusions
! Based on the above reviews, the inspector determined that the licensee maintained
and implemented good calibration and assessment / trending programs for
effluent / process / area radiation monitoring systems.
R2.2 Air Cleanina Systems and Plant Air Balance
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a. Insoection Scope (84750-01)
The inspection consisted of the licensee's most recent surveillance test results -
(visual inspection, in-place HEPA and charcoal leak tests, air capacity tests,
pressure drop tests, and laboratory tests for the iodine collection efficiencies) for
the following systems:
e Filtration, Recirculation, and Ventilation System, ,
e Control Room Emergency Filtration System,
e Offgas Exhaust System, and
e Reactor Building Exhaust System.
The inspector also reviewed surveillance test results (maintaining negative
pressures) for the following buildings:
e UFSAR 9.4.4.1 Turbine Building (Negative Pressure)
e UFSAR 9.4.3.1.2 Auxiliary Building Radwaste Area (Negative Pressure)
e UFSAR 9.4.2.1 Reactor Building (Negative Pressure)
b. Observations and Findinas
All reviewed surveillance test results were within the licensee's TS/UFSAR
acceptance criteria. The inspector determined that the licensee maintained and
implemented a good routine surveillance test program.
The licensee rnaintained negative pressures for the auxiliary building radwaste area
and turbine buildings. The inspector verified the negative pressure during a plant
tour. However, there were no pressure differences in the measurement devices for
these f acilities. The licensee (system manager and engineer) verified appropriate
negative pressures by periodic exhaust / supply air volume reviews. The licensee
stated a formal surveillance log book would be established to track and trend air
l balance results.
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The licensee installed differential pressure (delta-P) measurement devices for the
reactor building and read delta-P in the main control room. The licensee recorded
negative pressure values in the daily surveillance log book each shift (3 times / day).
The inspector noted that the licensee maintained about -0.35 inches of water for
the reactor building,
c. Conclusion
Based on the above reviews, the inspector determined that the licensee maintained
and implemented a good routine surveillance test program for the air cleaning ;
systems. The responsible individuals had very good knowledge in the area of the l
plant air balance.
R3 RP&C Procedures and Documentation I
a. Inspection Scope (84570-01)
The inspection consisted of: (1) review of selected chemistry procedures to verify
processes; (2) review of 1995 and 1996 Annual Radioactive Effluent Report to
verify the implementation of TS requirements; and (3) review of the contents of the j
ODCM for performing the effluent control programs, including projected dose !
calculations to the public.
b. Observations and Findinas
The inspector noted that reviewed effluent control procedures were detailed, easy
to follow, and ODCM requirements were incorporated into the appropriate
procedures. The licensee had good procedures to satisfy the TS/ODCM
requirements for the routine and emergency operations.
The inspector reviewed the 1995 and 1996 annual radioactive effluent release
reports. These reports provided data indicating total released radioactivity for liquid
and gaseous effluents. The annual reports also summarized the assessment of the
projected maximum individual and population doses resulting from routine
radioactive airborne and liquid effluents. Projected doses to the public were well
below the Technical Specification limits. The licensee summarized historical
radioactive liquid and gaseous release data and projected doses since the start of
commercial operations for trending purposes, and reported this trend data in annual
reports. The inspector determined that there were no anomalous measurements,
omissions or adverse trends in the reports.
The inspector reviewed the licensee's ODCM, Revision 15, effective
December 1996. The inspector noted that this ODCM was an improvement over
l previous versions. The ODCM provided better descriptions of the sampling and
'
analysis programs, which were established for quantifying radioactive liquid and
l gaseous effluent concentrations, and for calculating projected doses to the public.
All necessary parameters, such as effluent radiation monitor setpoint calculation
methodologies, site-specific dilution factors, and dose factors, were listed in the
. _ _ _ _ - _ _ _ . . _ . _ . - - _ _ - . _ - _ _ - . . _ . . _ - . _ . _ _ _ _ _ . .
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ODCM. The licensee adopted other necessary parameters from Regulatory Guide
1.109. :
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c. Conclusion
P
Based on the above reviews, the inspector determined that:' (1) effluent control
procedures were sufficiently detailed to facilitate performance of all necessary steps
for the routine and emergency operations; (2) the licensee effectively implemented
the TS/ODCM requirements for reporting effluent releases and projected doses to
the public; and (3) the licensee's ODCM had improved and contained sufficient
specification, information, and instruction to acceptably implement and maintain the
radioactive liquid and gaseous effluent control programs.
R6 RP&C Organization and Administration ;
l
R6.1 The inspector reviewed the organization and administration of the radioactive liquid
and gaseous effluent control programs and discussed with the licensee changes -j
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made since the last inspection, conducted in February 1996.
There were no major changes since the last inspection of the programs. The -
l
chemistry department had the major responsibility to conduct the effluent control )
programs. Other groups (i.e., radiation protection, operations, I&C, and system
engineers) had supporting responsibilities to the program. Staffing levels appeared
to be appropriate for the conduct of routine and emergency operations.
R6.2 Manaaement Controls
a. Insoection Scope (84570)
The inspector reviewed organization changes and the responsibilities relative to
oversight of the REMP and MMP, and the annual radiological environmental
operating report to verify the implementation of Salem TS Section 6.9.1.7 and the )
Hope Creek TS Section.
'
b. Observations and Findinas
The licensee made changes to the organization that have affected the REMP and
MMP since the previous inspection. Effective April 1997, oversight of the
environmental monitoring and meteorological monitoring programs was under
Radiation Protection Services (RPS), Technical Services. The supervisor of RPS
reports to the technical services manager, who reports to the director of Training
and Radiation Safety. The director of Training and Radiation Safety reports to the
vice president of Nuclear Operations. The responsibilities relative to oversight of
the REMP and MMP have essentially remained the same, however, there were two
l personnel changes directly related to the REMP responsibility. The supervisor of
RPS has been in the position for 2 months, and the senior staff engineer has been in
l the position for 1 week. The previous senior staff engineer remains available to
,
assist the current engineer and provide turnover. The supervisor stated that he will
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perform a self-assessment audit of the REMP and MMP to understand the status of
the programs and will make changes as needed.
l
l The annual radiological environmental monitoring reports for 1995 and 1996
l provided a comprehensive summary of the results of the REMP around Salem and
Hope Creek and met the TS reporting requirements. No omissions, mistakes, or
obvious anomalous results and trends were noted.
c. Conclusion
Based on the above review, the inspector determined that the organization changes
did not appear to have a negative impact on the oversight of the REMP or the MMP
and there were no concerns regarding the annual reports.
1
R7 Quality Assurance in RP&C Activities
{
R7.1 Radioloaical Effluent Audits
a. insoection Scooe (84750-01)
The inspection consisted of: (1) review of the 1996 audit and its responses, if any;
(2) QA policy of the measurement laboratory; (3) implementation of the
measurement laboratory QC program for radioactive liquid and gaseous effluent
samples; and (3) attending a SORC meeting.
b. Observations and Findinas
The inspector reviewed QA audit report No. 96-151/152, " Nuclear Business Unit."
The inspector noted that the audit team also included other technical personnel.
The 1996 audit team identified three C dings. These findings were not safety-
related, but rather recommended ar, whancement to the effluent control programs.
The response to these findings was completed in a timely manner. The inspector
noted that the scope and technical depth of the audit were sufficient to assess the
quality of the radioactive liquid and gaseous effluent control programs.
The licensee held the first meeting of the " Hope Creek / Salem Chemistry QA Policy".
The representatives, of the both Chemistry Departments discussed the tentative
contents of the QA Policy. The inspector attended the meeting and determined that
contents and outlines of the policy were good. The inspector reviewed the QC data
for intra /interlaboratory comparisons and QC control charts for the gamma
spectrometry. When discrepancies were found, effective resolutions were
determined and implemented,
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! The licensee identified that a small segment of the service air piping in the solid
radwaste build:ng was contaminated by spent resin in 1988. Service air piping is
- normally a clean system, therefore, the licensee evaluated the condition to satisfy
its procedure and IE Bulletin 8010 requirements pertaining to control and
monitoring of normally nor> radioactive systems that became contaminated. The
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safety evaluation (AR-970515178) evaluated the actual and potential safety
significance, including projected dose calculation to the public.
The inspector attended the. Hope Creek SORC Meeting (SORC Meeting No.97-039)
on May 19,1997. This special SORC meeting was held for about two hours to
review the safety evaluation for AR-970515178, which dealt with the potential for
the release of radioactive materials to the environment, and the controls and
practices to eliminate or reduce the significance of such potential through monitored
plant vents.
Based on the observation of discussions of the technicalissues, the inspector
determined that SORC meeting was very critical and that the SORC members
!
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maintained a questioning attitude. Safety evaluation presenters and SORC
. members: (1) prepared to discuss technical issues of the cafety evaluation report;
(2) discussed strengths and weaknesses of the safety evaluation; (3) discussed
other possible alternate methods; and (4) developed conclusions. The SORC
- members concluded that the safety evaluation required more consideration and ;
( development of temporary modifications, procedure changes, and administrative
i
controls prior to being resubmitted to the SORC for approval.
c. Conclusion _s l
Based on the above reviews, the inspector determined that the licensee's QA audit
_
was sufficient to effectively assess the radioactive liquid and gaseous effluent
. control program. Hope Creek / Salem Chemistry QA Policy appeared to be adequate.
l The licensee implemented a good QC program to validate measurement results for ;
l effluent samples. The inspector also determined that the licensee's SORC was
thorough, and demonstrated a critical and questioning attitude. !
R7.2 Quality Assurance Audit Prooram !
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a. Insoection Scope (84750)
The Quality Assurance (QA) audit report (Radiological Effluent Audit 95-151) was
!
reviewed against Section 6.5.2.4.3.J of Salem TS and 6.5.2.4.3.j, k, & m of the
Hope Creek TS.
b. Observation and Findinas
l
The inspector noted that the licensee conducted Radiological Effluent Audit 95-151
during September 11 - October 2,1995, according to TS. The scope of the audit
included the environmental monitoring and meteorological monitoring program
requirements. All aspects of the scope were completed. The inspector noted that
the audit team leader utilized a technical specialist to assess the REMP and the
MMP. The technical specialist (auditor) reviewed and understood the TS, ODCM,
I
and the pertinent program procadures. The auditor was familiar with sampling and
- analytical practices and observed collection of certain samples and reviewed the
. results obtained by the analytical laboratory. The audit findings were appropriate
_ . _ __
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and were suggested to refine the REMP. The auditor appropriately followed up on
an action request documented in the 1993. The auditor kept the item open but
assigned the issue a new action request number. The inspector discussed this issue
with the auditor (see Section R1.2 of this report). The auditor stated that item
- remains open in the quality assurance tracking system and will be reviewed during
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the 1997 audit.
c. Conclusions
l Based on the review of the audits and discussions with the auditor, the inspector
! concluded that the audit was of sufficient technical depth to effectively identify and
assess program strengths and weaknesses. The audit evaluated the technical
l adequacy of implementing procedures, TS requirements, and practices and
!
performance of the licensee and laboratory personnel.
R7.3 Quality Assurance of Analvtical Measurements
I
a. Insoection Scoce (84750)
The inspector reviewed the Quality Assurance (QA) and Quality Control (OC)
programs against Section 3/4.12.3 of the TS and recommendations of Regulatory
Guide 4.15, " Quality Assurance for Radiological Monitoring Programs (Normal
Operations) - Effluent Streams and the Environment" to determine whether the
licensee had adequate control with respect to sampling, analyzing, and evaluating
data for the implementation of the REMP.
b. Observations and Findinos
The Maplewood Testing Services (MTS) implemented an interlaboratory comparison
program, required by the TS, through continued participation with Environmental
l Protection Agency (EPA). The inspector reviewed the analytical results of this
program and noted the results were within the established acceptance criteria. The
inspector reviewed selected quality control charts and calibration records. The
charts and calibrations were within the established acceptance criteria.
The inspector noted that the laboratory did not conduct self assessment to measure
,
its own performance against regulations or standards. The laboratory relies on the
l information presented to them from the quality assurance audits and makes
i improvements or changes based on the audit findings. The laboratory personnel
l stated that they intend to initiate a self assessment program by the end of the third
,
quarter (September) of 1997.
l
c. Conclusion
Based on the above observations, the inspector determined that the performance of
the contract laboratory was good and the interlaboratory program was effective.
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R8 Miscellaneous RP&C lesues
! A recent discovery of a licensee operating their facility in a manner. contrary to the
! UFSAR description highlighted the need for a'special focused review that compares
'
- plant practices, procedure and/or parameter to the UFSAR descriptions.
l
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While performing the inspections discussed in this report, the inspectors reviewed
the applicable portions of the UFSAR that related to the areas inspected. The
!
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inspector verified that the UFSAR wording was consistent with the observed plant
practices, procedures, and/or parameters.
S7 Quality Assurance in Security and Safeguards Activities
S7.1 Loss of Vital Area Kevs
,
On May 1,1997, a Hope Creek equipment operator discovered a set of vital arrea
keys lying unattended on the floor of a bathroom in the station. The operator
promptly reported his discovery to site security personnel and the senior nuclear
l shift supervisor. The inspectors noted that security personnel immediately retrieved
the keys after notification, and commenced a thorough investigation into the matter.
! Specifically, security management ensured that all Hope Creek vital area doors were
physically verified to be closed and locked, all gun cabinets were inventoried, a
complete inventory of all security keys was conducted, and security system alarm
.
! histories were reviewed for anomalous conditions. The keys were not under
j positive security guard control for approximately 8 minutes.
During the investigation, security management discovered that the keys were
inadvertently released from the key ring attached to an on-watch security officer's
belt when he leaned against a sink in the bathroom. Further reviews determined
that the key ring used was deficient in that the prong on the key ring "J" hook was
outside of the clasp; it was later learned that many such rings purchased by the
- security department were received from the vendor in this deficient condition. This
information was promptly disseminated among all security force members in order
to correct the problem.
The inspectors concluded that PSE&G operations and security personnel
demonstrated excellent response to the loss of vital area keys event; short and
long term corrective actions were both prompt and thorough. Security personnel
appropriately logged this event in department records,
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V. Manaaement Meetinas
X1 Exit Meeting Summary
l' The. inspectors presented the inspection results to members of licensee management at the
i conclusion of the inspection on June 10,1997. The licensee acknowledged the findings
! presented.
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The inspectors asked the licensee whether any materials examined during the inspection
should be considered proprietary. No proprietary information was identified.
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INSPECTION PROCEDURES USED
!P 61726: Surveillance Observations
IP 62707: Maintenance Observations
IP 71707: Plant Operations
IP 37551: Plant Engineering j
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iP 84750-01: Radioactive Waste Treatment, and Effluent and Environmental
Monitoring
IP 90712: Event Report Review
ITEMS OPENED, CLOSED, AND DISCUSSED l
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Opened
)
- 50-354/97-03-01 VIO ineffective corrective action for previously identified '
concerns with maintenance procedural adherence
50-354/97-03-02 URI potential weaknesses in the design change process. j
l
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Closed
50-354/94-19-02 URI licensed SRO assumed licensed duties as a Nuclear
- Shift Supervisor without having completed the required
l proficiency watches
- 50-354/95-16-01 URI engineered safety feature actuation occurred when the
.
the suppression chamber on high torus level
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50-354/95-19-01 VIO failure to perform technical specification requirements
during a reactor shutdown and during refueling
,
operations
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50-354/95-087-01013 VIO failure to perform an adequate written safety evaluation
prior to startup and operation of the DSE
50-354/95-08 01023 VIO failure to establish adequate procedures for ensuring
proper operation of the DSE, as well as for limiting any
releases to the environment
50-354/95-160-01014 VIO failure to ensure a SRO remains in the control room
50-354/95-160-02014 VIO failure to submit a licensee event report after
discovering that no SRO was present in the control
- room
,
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50-354/95 216-01013, VIO failure of operators to implement procedures ,
! 01023, 01033, & 01043
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50-354/97-007-00 LER Struthers Dunn 219NE series relay failures
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50-354/97-01-02 URI ' Struthers-Dunn 219NE series relay failures
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Discussed
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LIST OF ACRONYMS USED
l
AB Auxiliary Building l
ALARA As Low As is Reasonably Achievable
ARMS Area Radiation Monitoring System
DSE Decontamination Solution Evaporator ,
HEPA High Efficiency Particulate '
HP Health Physics
HPCI High Pressure Coolant Injection
MTS Maplewood Testing Services
NRC Nuclear Regalatory Commission
ODCM Offsite Dose Calcula: ion Manual
PDR Public Document Room
PSE&G Public Service Electric and Gas
OA Quality Assurance
QC Quality Control
REMP Radiological Environmental Monitoring Program
REOR Radiological Environmental Operating Reports
RMS Radiation' Monitoring System
RP&C Radiological Protection and Chemistry
SACS Safety Auxiliary Cooling System
SFP Spent Fuel Pool
SORC Station Operations Review Committee
SRO Senior Reactor Operator
SSW Station Service Water
TS Technical Specifications
UFSAR Updated Final Safety Analysis Report
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