B12592, Responds to & Comments on Findings of SALP Board W/Emphasis on Board Recommendations for Individual Evaluation Categories.Response to Each of Board Recommendations for Plant Encl.Util Goal to Return to Category 1 in All Areas

Responds to & Comments on Findings of SALP Board W/Emphasis on Board Recommendations for Individual Evaluation Categories.Response to Each of Board Recommendations for Plant Encl.Util Goal to Return to Category 1 in All Areas

ML20235X142
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	07/17/1987
From:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
B12592, NUDOCS 8707240061
Download: ML20235X142 (15)

Text

1 .

CONNECTICUT YANKEE ATO MIC POWER COMPANY B E R L I N. CONNECTICUT P.O. box 270 e HART FORD. CONNECTICUT 06141 4 270 TELEPHONE 203-665-$000 July 17,1987 Docket No. 50-213 B12592 Re: SALP U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Haddam Neck Plant Systematic Assessment of Licensee Performance The Staff recently forwarded the SALP Board Report (l) for the 13-month period ending March 31,1987 for the Haddam Neck Plant. Subsequent to receipt of the SALP Board Report, a meeting was held on June 18, 1987 between members of the Staff and members of Connecticut Yankee Atomic Power Company (C Y APCO).

The purpose of this letter is to respond to and comment on the findings of the SALP Board with particular emphasis on the Board recommendations for the individual evaluation categories. Attachment A to this letter contains the CYAPCO response to each of the Board's recommendations for the Haddam Neck Plant.

In reviewing the SALP report, CYAPCO finds it disappointing that the NRC considers that overall facility performance has declined since the last SALP evrluation period. We believe that significant initiatives have taken place to further improve plant performance. CYAPCO finds much in the text of the report to support this conclusion. However, if CYAPCO is not headed in the right direction in the judgement of the NRC Staff, this must be identified so that

• a mutual understanding and appropriate corrective actions can be taken promptly.

(1) W. T. Russell letter to E. 3. Mroczka, "SALP Report No. 50-213/86-99,"

dated June 10,1987.

Q7240063 ADDCK 05000g33 070737 Y O y PDR '! \

k

U.S. Nuclear Regulatory Commission B12592/Page 2 July 17,1987 Accordingly, CYAPCO wishes to maintain an open dialog with the NRC concerning its current performance trend. CYAPCO's goal is to return to Category 1 performance in all functional areas. CYAPCO believes that this goal is attainable.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY 4H 4c)

E. F.ka (/

Senio 'ce President cc: W. T. Russell, Region 1 Administrator F. M. Akstulewicz, NRC Project Manager, Haddam Neck Plant

3. T. Shediosky, Senior Resideat Inspector, Haddam Neck Plant i

l 1

M

Docket No. 50-213 B12392 i

)

l Attachment A ,

Connecticut Yankee . Atomic Power Company l Haddam Neck Plant Response to SALP Report

~I i

I i

l l

)

i l

July,1987 )

-_ _ _ _ _ _ - - - - - - w

Functional Area: PLANT OPERATIONS Board Recommendation: Correct the causes of operator contribution to unnecessary trips.

1

Response

l Two causes were identified f ar operator contribution to unnecessary trips. One l was operator error during startup, and the other was inadequate coordination 1 between the operators and technicians performing the work.

The circumstances surrounding the operator error during startup indicated that I

this was an isolated occurrence. A turbine test engineer, concerned over getting the turbine through its critical speed, rushed the operator during turbine startup. I l Steam demand increased too quickly, causing a plant trip. While the test engineer's concern over excessive turbine vibration is appropriate, the overzealous manner in which he expressed this concern was not. The Operations  ;

Supervisor reviewed this event with all Operations Department personnel, '

stressing the responsibility of the operators to operate plant equipment properly regardless of the circumstances.

The two trips that were due to inadequate coordination between the operators and working technicians indicated that there was a need to formalize the interface between these groups. Accordingly, a new station procedure was developed to provide a formal review of work conducted on the back shif ts. Key to this review is a checklist which is completed by the technician and the Shif t Supervisor prior to initiation of work. This checklist is intended to help the Shif t Supervisor and technician identify potential problems with the proposed work before it is actually performed, thus minimizing the chances for an unnecessary trip.

l In order to continue to improve the operator training program, a Licensed Operator Continuing Training Program Implementing Procedure (TPIP) was issued in September,1986. This procedure, in concert with the Nuclear Training Manual, provided detailed programmatic and administrative requirements related to training content, examinations, removal from shift for unsatisfactory performance, scheduling, departmental duties, instructors qualifications, training effectiveness, and records. Copies of this procedure were informally provided to both the Haddam Neck Plant Resident Inspector and Region I PWR-Westinghouse )

Lead Operatorwas the procedure Licensing Examiner transmitted to the in the for NRC October,1986 time {Ir me. In addition, formal review. j Additionally, A  ;

NUSCO QA Surveillance was performed in December,1986 indicating that the administrative controls were in place at that time. Such measures should help to decrease the number of operator errors that occur.

1 1

l i

1 0

I l

(1) E. 3. Mroczka letter to C. I. Grimes, " Revised Licensed Operator Requalification Training Program Procedures and Program Descriptions,"

dated December 8,1986. )

1 1

1

-_-_ __-_____ - - - -~-

Functional Area: RADIOLOGICAL CONTROLS Board Recommendation: Assure effective site and corporate coordination and pre-planning of radiological controls activities.

Response

Northeast Utilities, as has been previously stated, is actively pursuing improvement of the corporate / site interface. This effort includes the Radiological Controls Area, and has already resulted in a joint committee being formed to review and upgrade the station Health Physics procedures.

Improved cooperation has also been evident in the'ALARA planning for the 1987 Refueling Outage. A joint NUSCO/CYAPCO committee has reviewed virtually all of the scheduled major construction projects for ways to reduce radiation exposure. This planning has yielded significant reductions in the exposure estimates and hence lowered the radiation exposure goal for the outage.

Initiatives to improve the site / corporate interface will cor.tinue, including an increase in the effectiveness of the corporate audit / appraisal process.

l 1

Functional Area: MAINTENANCE AND MODIFICATIONS Board Recommendation: Consider measures to improve equipment and maintenance personnel performance in order to prevent unnecessary trips.

Response: i j

A new station procedure to improve coordination for work on back shifts that could result in a plant trip has previously been described in the response under Plant Operations. In addition to this, any new measures that can reduce plant trips will be given priority consideration. The obvious benefits of reducing the number of unnecessary trips makes this policy a prudent one.

The final paragraph of this Functional Area cited personnel errors, instances of ineffective maintenance, procedural and documentation inadequacies, and the maintenance backlog as factors which prevented the attainment of overall i maintenance excellence. With the exception of the backlog, CYAPCO feels that i these problem:; are all related to deficiencies in procedural quality and adherence. This has been a common theme of recent plant evaluations both internal and external. CYAPCO is addressing this problem on several fronts, including procedure upgrades, improved training, increased supervisory involvement, and increased station management emphasis on procedural compliance. Efforts are currently underway in each of these areas. In addition, CYAPCO has become involved in human performance evaluation systems and root cause analysis techniques to better evaluate plant occurrences. CYAPCO expects these efforts to yield tangible results during the present SALP period.

With regard to the maintenance backlog, it is CYAPCO's policy to diligently pursue reduction of the backlog on an ongoing basis. As stated in the SALP Report, the backlog has been reduced 17% during the recently completed SALP evaluation period. This is an indication that the policy is effective. 1

Functional Area: SURVEILLANCE Board Recommendation: Assure that acceptable containment leakage is maintained throughout operating cycles.

Response

As noted in the SALP text, containment leakage in excess of allowables is currently being addressed. Additional containment isolation valves are being added to those penetrations which historically have experienced excessive leakage. New hardware which will allow the use of improved test methods is also being installed on some penetrations. In addition, new isolation valves are being installed in the service water system which will prevent river water contamination of the componetit cooling water system during surveillance testing. Contamination of the component cooling water system has been identified as a cause of many leaky isolation valves. Finally, a full pressure Integrated Leak Rate Test will be performed at 40 psig during the 1987 refueling outage. CYAPCO is committed to assuring containment integrity, and believes that its actions demonstrate this commitment.

I L-_.__------_--_-----______ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - - - - - - _ _ _ _ - - .---- _. - - _ _ -------_a

Functional Area: EMERGENCY PREPAREDNESS Board Recommendation: None.

Response

CYAPCO does not agree with the SALP evaluation in this functional area. While the details given in the text are accurate, we conclude that they do not support the Category 2 rating.

The exercise deficiencies noted, while accurate, are in our estimation of very low significance. They are the types of human errors that one would expect from individuals involved in a task which they perform infrequently. As noted in the SALP report, there were several strengths exhibited _by these same individuals.

The NRC concern over a lack of procedural definition of the DSEO/NRC DSO interface is being addressed as noted in the SALP report. This concern is, however, an artificiality in our opinion since the DSEO and NRC DSO would be located in very close physical proximity during an actual event (in adjacent rooms in the EOF). Certainly,- the NRC DSO would be kept abreast of the situation along with the rest of the Emergency Operation Center staff.

The NRC concern over augmentation was shared by current plant management; hence the unannounced drill on March 24,1987. The unacceptable results of this licensee initiated test were, as noted in the text, dealt with immediately and decisively by plant management.

Given the significant, licensee initiated improvements in the Emergency Preparedness area, coupled with two well executed exercises in 1986 and 1987, CYAPCO's reaction to the present evaluation is one of disappointment.

CYAPCO will continue to investigate future improvements to further' upgrade the program.

I i

i l

Functional Area: SECURITY AND SAFEGUARDS Board Recommendation: None.

Response

None.

i 1

I

)

i

l Functional Area: REFUELING AND OUTAGE MANAGEMENT l

I Board Recommendation: None. )

i

Response

CYAPCO agrees that the initiatives taken to date, while significant, must be proven through use during the 1987 Refueling Outage. Performance during this outage will demonstrate tnat the changes have been effective.

l 4

l l

Functional Area: ASSURANCE OF QUALITY Board Recommendation: None.

Response

CYAPCO management intends to continue and expand the positive Initiatives cited in the SALP text. ' Procedures and personnel adherence to these procedures are being closely scrutinized. CYAPCO beliesos- that its overall trend is positive and plans to build on this foundation.

4 i

l

4 Functional Area: TRAINING AND QUALIFICATION EFFECTIVENESS l

Board Recommendation: None.

Response

Our response concerning the Plant Operations. functional area addresses the implementation of operator requalification program administrative controls.

i l

)

i I

J i

'l I

l l

l l

l

i l

l Functional Area: LICENSING ACTIVITIES Board Recommendation: Develop overall approach for planning submittals to  ;

assure they are fully supported and submitted in a i timely fashion.

l Response:

We believe that communications are being improved between the NRC and i l

CYAPCO on outstanding information requests and othet _ licensing actions,  ;

thereby allowing timely decisions to be made to resolve outstanding issues. One l recent example of this effort is the establishment of periodic meetings with the NRC Project Manager to prioritize and schedule current licensing issues in a manner that is supportive of both the NRC Staff's schedule and our available resources. This overall approach for planning submittals on current licensing issues provides greater assurance that information requests are fully supportive and submitted in a timely fashion. Long-standing NRC concerns with respect to t Technical Specification upgrades for NUREG-0737 issues and degraded grid voltage have recently been placed in the high-priority category.

We have continually strived to provide comprehensive, thorough, and technically sound submittals. In cases where the NRC Staff has required additional information, we have been quick to respond to' the request with follow-up  ;

conference calls, meetings, or additional written submittals.  !

l l As discussed briefly during the June 18, 1987, SALP meeting, we note that l l voluntary initiatives such as the Probabilistic Safety Study and ISAP analyses l

may identify areas of plant vulnerability which were not previously analyzed.

I Therefore, this may result in the need for prompt expenditures of both CYAPCO and NRC resources, including a temporary waiver or an emergency license amendment. While we certainly wish to keep such evolutions to a minimum, safety considerations occasionally dictate otherwise. We request the NRC to take this into account in evaluating our performance in this functional area.

In summary, we believe that the licensing activities associated with the Haddam Neck Plant demonstrate that an overall approach for planning submittals is in place. CYAPCO management is firmly committed to providing the proper resources and direction necessary to provide assurance that all licensing issues are fully supported and submitted in a timely fashion, and the resultant commitments are fully implemented.

l l

l l-

c4 - R b>

I l

1 l

Functional Area: ENGINEERING SUPPORT l

Board Recommendation: Improve communication and coordination between the j site and corporate staffs.

Response

l During the SALP period, major improvements in communication and coordination '

between the site and corporate staff have occurred in the area of outage i modifications. The ties that have been established during this effort are being ,

extended to other areas, most notably Fire Protection. This evolutionary process  !

is highly endorsed by management and will continue. i The text of the SALP also stated that training for site engineering personnel is  !

deficient but that a training program was under development. This program is now developed and is awaiting INPO accreditation in the interim, the training is being administered using the new!y developed program.  !

l Pre-operational testing has been an area of concern for some time at the Haddam Neck Plant. In response to this, a new procedure is being finalized that will provide specific, detailed guidance in this important area.

I i

i I

i 1

l u______._______ _ _ _ _ _ _ _ _ _ _ - __. _ _ _ _ _ _ _ _ _ - _ - _ - _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . - , . - _-___ - - _ _.__-_a

a i

i i

Functional Area: FIRE PROTECTION Board Recommendation: Take appropriate action to improve management involvement in the fire protection area and enhance the interface between the site and corporate staffs.

Response

CYAPCO is committed to improving the Fire Protection Program. This ,

commitment is evidenced by such significant items as: I 1

i o Construction of a new switchgear room as part of the Appendix R compliance effort; 4

1 o Contracting a consulting firm to perform a licensing commitment review; j i

o Conducting ongoing fire protection system code compliance reviews; Perhaps most significant for the long term improvement in the fire protection )

area is the addition of a full time fire protection engineer to the plant {

engineering staff. This individual was previously located in the corporate Fire i Protection Group, and has already improved markedly the site / corporate {

interface in fire protection. Most importantly, this individual will provide the i continuity that was lacking in the previous approach' to this issue. CYAPCO believes that the actions it is taking will result ultimately in a strong fire protection program.

l 1

1 1

l l

l l

i i

_ _ _ _ _ _ _ _ . _ _ _ _ _ . J