BVY-93-126, Responds to Violation Noted in Insp Rept 50-271/93-08 Re Operational Safety Team Insp at Plant on 930607 & 0702. Corrective Actions:Leadership Training Utilizing Case Studies to Improve Mgt Effectiveness for Section of Staff

Responds to Violation Noted in Insp Rept 50-271/93-08 Re Operational Safety Team Insp at Plant on 930607 & 0702. Corrective Actions:Leadership Training Utilizing Case Studies to Improve Mgt Effectiveness for Section of Staff

ML20059L287
Person / Time
Site:	Vermont Yankee
Issue date:	11/12/1993
From:	Reid D VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BVY-93-126, NUDOCS 9311160424
Download: ML20059L287 (4)

Text

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VERMONT YANKEE NUCLEAR POWER CORPORATION

. c. Ferry Road. Brattleboro, VT 05301-7002 ,y,

) ENGINEERING OFFICE s_/ 5,80 MA!N STREET BOL10N MA 01740 (50B) 779 6711 November 12,1992 BVY 93-126 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

References:

(a) License No. DPR-28 (Docket No.00-271)

(b) USNRC to VYNPC, Region i Operational Safety Team inspection (OSTI),

Report No. 50-271/93-80, dated 9/8/93

Subject:

Vermont Yankee Response to OSTI inspection, Report No. 50-271/93-80 Vermont Yankee appreciates the insights of your inspection team in conducting an Operational Safety Team inspection (OSTI) at our Vernon, Vermont generating station between June 7 and July 2,1993.

We believe your report presents a fair and accurate appraisal of our performance in the identified areas.

This response provides a summary of our improvement initiatives to address the areas of management controls over processes and programs and reviews of industry experience. Our improvement initiatives are divided into the four categories of Operations, Maintenance and Surveillance, Engineering ard Technical Support, and Management Processes and Corrective Actions.

Operations:

Vermont Yankee has recently instituted two additional daily meetings of key personnel. Daily Plant Manager Meetings are held every morning to facilitate effective inter-departmental communication, l

review emerging issues and prioritize work efforts. These provide an ideal forum for management 10 provide direction and clarity expectations on a wide variety of issues, including current industry events. '

Also, a Daily Shift Briefing Meeting is conducted with shift personnel at the beginning of each shift.

Items discussed in this meeting include planned evolutions for the shift, pertinent night orders or special instructions and any unusual conditions.

Vermont Yankee has, and will continue to reinforce our expected high standards at Operations Shift Supervisor Meetings, including the importance of detailed log keeping, appropriately maintaining control room deficiency stickers and correctable deficient conditions. Deficiency stickers are the subject of a quarterly Operations Department self-assessment and were individually reviewed as part of our startup readiness assessment, completed prior to returning the plant to operation from our 1993 Refueling Outage.

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I U.S. Nuclear Regulatcry Commission VERMONT YANKEE NUCLEAR POWER CORPORATION November 12,1993 Page 2 In June of 1993, Vermont Yankee completed a self-assessment of the Temporary Modification (TM) process and identified a number of administrative improvements to strengthen our program. These changes include requiring an independent engineering review of all TM's, improved information in the control room for impact on operating procedures / drawings and improved field Irbelling. Additionally, based on our own audit program results and discussions with your OSTI teafn, controls concerning Plant Operations Review Committee (PORC) review of outstanding TM's have been strengthened.

Additional TM process revisions are scheduled to be implemented by the end of 1993. A continuing effort to convert older TM's to permanent installations is being carried out by the design change process. Currently, nine of these TM's are identified on our project work list for closure during 1994.

Maintenance and Surveillance:

Several enhancements have been recently implemented in our Inservice Testing (IST) implemern 'g procedures to require independent review of data and engineering rewew of baseline changes.

Additionally, we recently completed a OA Audit of this area. Your inspection and our own OA Audit both highlighted the need for improvements in the assignment of responsibilities and ownership for this program. We are currently evaluating this area for improvements and expect to have a corrective action plan finalized by the end of 1993.

The procedure controlling our work order process (AP-0021) has been enhanced to include administrative requirements for canceling work orders.

The newly instituted Daily Plant Manager mee ngs review emerging issues and provide an opportunity for defining management expectations and specifying appropriate oversight. Additionally, we have initiated a review of our planning and scheduling activities as a part of our Commitment to Excellence Program (CEP). This CEP review includes a critical self-assessment of the way we plan and schedule all work at Vermont Yankee.

General Electric Service Information Letter (SIL) 477 was identified by your team as an unresolved item in the report. This SIL has been re-reviewed as a result of your concerns. The only item requiring followup with reDard to this issue is that some minor descriptions in our FSAR require clarification.

Information has been presented to the NRC Resident inspector for closeout of this unresolved inspection team item.

Our Industry experience review has been improved through revisions to our procedures by requiring an assessment of the broader implications when evaluating these documents. Departments assigned the review of industry information are now required by our program to review the generic / broader implications of the information and perform field walkdowns where appropriate. A written technical rationale is required when an item is considered to be not applicable. Selected GE SIL's and INPO SOER's have been evaluated for continued adequacy of previous reviews and recommendations. As a result of our initial review, several older SIL's and SOER's have been reassigned for further evaluation.

Engineerina and Technical Support:

Vermont Yankee is committed to continuing the development and enhancement of engineering methods and processes. Examples of initiatives which have been completed or initiated since the OSTI inspection include:

. U.S. Nuclear Regulatory Commission VERMONT VANKEE NUCLEAR POWER CORPORATION November 12,1993 Page 3 Completion, review and approval of a new LOCA analysis whose results provide additional margin to limits. The new analysis is now part of the Vermont Yankee FSAR.

Initiation of bi-weekly meetings of Vermont Yankee and Yankee Nuclear Services DMslon Engineering Management to review current work items, prioritize work and strategize future plans.

Development of a refresher 50.59 safety evaluation training program util! zing lessons learned from those who write safety evaluations and covering the new LOCA analysis.

Initiation of a second round of efforts to further improve the design change scoping and development process.

Stream!!ning our One-For-One and Equivalency Evaluation processes to improve consistency.

Manecement Processes and Corrective Actions:

In response to items identified by your hsp6'ction and our own OA audits in the area of corrective action, Vermont Yankee is currently benchmarking cur overall process against other utility programs that have a more " streamlined" approach. We recognize additional improvement is necessary, including establishing a clearer distinction between competing processes, lowering of the threshold for which items require a root cause evaluation, improving the consistency of determining what constitutes "significant" vs. "minnr" conditions and ensuring events are consistently evaluated and reviewed by appropriate levels of management. A recently completed independent assessment team consisting of senior OA managers from other utilities provided additional suggestions for improving our Corrective Action process. We plan to complete our evaluations and have an improved program in place by mid -

1994.

Some additional initiatives that you may not be aware of, that have, or will improve our management controls are:

Leadership Training utilizing case studies to improve management effectiveness for a broad cross section of our management staff.

Expanded focus of Nuclear Safety Audit and Review Committee (NSARC) to be more active in plant activities, including participation in OA audits, quarterly reviews of audit plans and reviews of the results of completed audits.

Enhancement of our Observation Program to incorporate additional housekeeping and trending requirements.

Revised QA Trend Reports to provide more useful results to facilitate followup by management.

Integrated OA audit and QA surveillance plans to improve coverage of activities.

Plant-wide emphasis on procedure adherence to ensure strict compliance with Technical Specification requirements and management expectations.

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. U.S. Nuclear Regulatory Commission VERMOf6T YANKEE NUCLEAR POWER CORPORAT'lON November 12,1993 Page 4 INPO assist visits in the areas of Training and Radiation Protection to provide us with suggested improvement initiatives from superior performing plants.

Formulation of a formal Outage Guideline to capture NUMARC and EPRI outage safety initiatives for conducting outages with a " defense-in-depth" philosophy.

Performance Review Group Meetings between department heads and senior plant management to allow for an open format to discuss issues of mutual concem such as identified weaknesses, self-assessment results, and specific department issues.

Benchmarking of our Security Program through a formal process of measuring, evaluating and emulating the security practices of our strongest industry peers.

A formal self-assessment of Technical Specification surveillance requirements to ensure correct procedural implementation and to identify potential areas for clarification and improvement.

Continued emphasis and development of Self-Assessment Program to further instill a questioning attitude in our organization. Recent evidence of this emphasis occurred during our most recent refueling outage when several precursors to potential problems were identified and corrected (For example: Low Pressure Turbine inspections, RHRSW motor cooling, Alternate Cooling Tower sitting, Core Spray suction strainer sizing and safety-related switchgear anchoring).

In summary, the management and staff at Vermont Yankee have already initiated significant improvements in many of the areas examined by your inspection team. We are committed to make continuous and effective improvements in all areas that affect the safe operation of the plant to ensure Vermont Yankee remains a safe and reliable producer of electric power.

, We look forward to additional discussions with your staff on these initiatives and will keep you apprised '

of their status.

Sincerely, Vermont Yankee Nuclear Power Corporation Donald A. Reid Vice President, Operations cc: USNRC Region i Administrator USNRC Resident inspector - VYNPS USNRC Project Manager - VYNPS