IR 05000029/1986099
| ML20196L164 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 06/23/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20196L155 | List: |
| References | |
| 50-029-86-99, 50-29-86-99, NUDOCS 8807070265 | |
| Download: ML20196L164 (59) | |
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Enclosure 1 SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION
REGION I
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-29/86-99 YANKEE ATOMIC ELECTRIC COMPANY YANKEE NUCLEAR POWER STATION ASSESSMENT PERIOD; OCTOBER 7, 1986 - MARCH 31, 1988 g!R7 En Si%h9 l
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SUMMARY OF REST!LTS A '.
Overais Summary The Yankee Nuclear Power Station continues to be operated in a manner that reflects a strong orientation towards plant safety. Active involvement by plant management on a day-to-day basis has resulted in a sustained excellent level of plant performance.
The performance of plant operators was maintained at a high level, and reflects positive attitudes and a keen interest in operations excellence. An occasional lack of aggressiveness in resolving opera-tional problems and maintaining a proper questioning attitude sug-gests that improvements can occur in this area.
Licensed operator training and retraining programs have undergone significant program i
enhancements. Although the licensed operator training programs
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have not been evaluated fully, an improving trend in personnel per-formance and operator attitudes is evident.
The strong management
team that now has oversight of the training ares has effected a
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noticeable improvement in the level of training and qualification effectiveness in almost all area;,
In addition to the plant operations area, strong performance was-noted in the areas of surveillance, refueling and outage management, engineering support, licensing activities, and assurance of quality.
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Numerous quality program enhancements have been implemented that result in effective management tools for improving performance.
In general, these areas shared the common strengths of management
involvement, the ability to resolve technical issues, a strong
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enforcement history, and responsiveness to NRC initiatives.
The assessment of the radiological controls area concluded that over-all program performance was satisfactory. Although many licensee initiatives occurred, further effort to focus on industry progress
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in the radiation protection area is warranted to achieve continued program improvements.
In the area of maintenance, the licensee demonstrated the ability to maintain the plant in a safety-conscious manner that reflected a high level of personnel pride.
The occasional inability to maintain a high level of quality maintenance performance was representative
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of instances of insufficient supervision, inadequate work control procedures, and ineffective training. Aggressive management involve-ment and the initiation of effective corrective actions have resulted l
in a noticeable improving trend in maintenance program quality and
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performance near the close of the assessment period. Additionally, the areas of emergency preparedness and security and safeguards have both experienced improving performance trends as a result of ' cused
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actions supported by the positive influence of a strong management team and positive worker attitudes.
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Background 1.
Licensee Activities The facility operated at. full power -from the start of the assessment. period on October 7, 1986 until October 31, 1986 when
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. a manual shutdown to hot standby was initiated in response to a failed pressurizer wide range level channel. A reactor startup commenced - on November 1,1986 following repairs to the instru-ment channel and the plant was at full power on November 4, 1986.
On December 14, 1986 a load reduction to 50% power was initiated
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to allow turbine throttle valve and main steam non-return valve
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testing In addition, condenser tube cleaning and leak checks
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were conducted.
The plant was returned to full power on December 15, 1986.
On February 18, 1987 an automatic reactor trip occurred on high
main coolant system pressure.
This condition resulted from the'
plant operators decreasing turbine load too rapidly in response to a control rod that dropped from its full out to full in
4 position. Later that day with the plant in Mode 3, an inadver-i tent safety injection occurred as a direct result of maintenance l
i being performed on a main coolant pressure channel instrumen--
tation.
Following a reactor startup on February 19, 1987, the plant at-tained full power on February 22. The plant entered Cycle XVIII end-of-cycle coast-down operations on March 5, 1987.
On March.18 an emergency load reduction from 92% to 73% power was
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i implemented - by the plant operators in response to overheated packing on the inboard side of a boiler feedwater pump.
The plant returned to normal coastdown operations from Cycle XVIII
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on March 20.
From approximately 72% power, on May 2,1987, a plant shutdown was initiated for the Cycle XVIII-XIX refueling outage.
Cold shutdown (Mode 5) was achieved on May 4, and the plant was in the refueling mode (Mode 6) on May 12,1987. The licensee's
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planned six-week refuelir.g outage was extended two and one-half weeks principally due to:
an initially optimistic schedule;
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discovery of a damaged fuel assembly that required fuel recon-stitution, modification to core components and implementation of additional radiation protection measures in response to hot particle concerns; the expansion of steam generator eddy-current inspection and tube plugging activity in response to a re-evalu-ation of 1984 inspection data; and repair activities for a body-to-bonnet leak on a main coolant cold leg stop valve, which also resulted in valve disc replacement due to identified disc cracking.
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On July 1,1987 the licensee initiated Core XIX physics testing.
Initial criticality was achieved with testing satisfactorily completed on July 2,1987.
The turbine was phased to the grid on July 3,1987. While performing main turbine overspeed test-ing on July 6 with the plant in the startup mode (Mode 2), a reactor scram on main coolant high pressure occurred due to per-sonnel error. Successful completion of the turbine testing and phasing to the grid occurred on July 7.
Power escalation was halted and a plant load reduction to 50%
power occurred on July 9,1987 to allow the conduct of condenser tube leak checks.
The plant was at full power on July 11.
On July 31, 1987, a planned load reduction to the startup mode was initiated to repair a small steam leak on the high pressure turbine impulse chamber drain line. The plant was at full power on August 4.
Load reduction to the startup mode was conducted August 6 to enable repair activity as a result of a body-to-bonnet steam leak on a steam generator blowdown line check valve. The plant was returned to full power on August 10, 1987.
On September 18 an emergency load reduction to 73% power was initiated in response to a packing failure on a feedwater heater drain pump.
The plant was returned to full power on September 20, 1987.
Full power opes ation continued until September 28 when load was reduced to 73% power to repair a packing leak on a feedwater heater drain pump.
The plant returned to full power the same day.
The plant remained at full power operation until October 14, 1987 when the plant reduced power to the startup mode in order to repair a body-to-bonnet steam leak on a steam generator blowdown line check valve. Approximately six hours into the load reduc-tion, an emergency load reduction was implemented due to a blown gasket on the main condenser steam dump valve.
Although the generator was phased to the grid on October 15, the plant was removed from the grid and power again reduced to the startup mode cn October 16 to facilitate repair of a packing leak on a main steam line non-return valve.
The plant resumed full power operation on October 19.
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On November 21, 1987, an unplanned shutdown to the startup mode was initiated due to a loy nitrogen pressure alarm on a main steam non return valve.
The cause of the alarm was a low accumulator pressure condition. As a result of commencing plant shutdown to Mode 2, the plant declared an Unusual Event.
The plant resumed full power operation and remained at full power until December 3,1987, when a load reduction was initi-ated due to the failure to place.an inoperable main steam line pressure switch in the tripped condition within the technical specification-required one-hour time frame.
At 98% power, the channel was placed in the tripped condition, and the plant was returned to full power operation.
The plant remained at full power until January 15, 1988 when plant load was reduced to approximately 65% power in order to re pack a feedwater heater drain pump.
The plant returned to full power on January 17.
On January 19, a plant load reduction to 75% power was initiated to perform maintenance on a boiler feed pump outboard motor bearing due to an oil leak.
Full power operation was achieved on January 23, 1988 where the plant remained until February 20, when plant load was reduced to 50% power in order to perform main condenser tube cleaning and other maintenance.
The plant was returned to full power opera-tion on February 23 and remainea stable until February 27, 1988 when plant load was reduced to 75% power due to water contamina-tion of a botier feed pump oil supply.
The plant was at full power on February 28, 1988 and was main-tained at this power level until March 3, when plant load was reduced to 75% power due to a packing leak on a heater drain pump.
The plant was returned to full power the next day.
On March 12, 1988, a load reduction was initiated to 48% power to plug leaking condenser water box tubes and perform other maintenance.
The plant resumed full power operation on March 13 where it remained until March 16, when an errergency load reduc-tion was initiated to approximately 73% power.
This emergency load reduction was initiated due to the trip of a heater drain pump.
As the plant was returning to power, on March 17, 1988 with the plant at 87% power, load was reduced to 70% power to perform maintenance on a feedwater heater drain pump. On March 18 the plant resumed full power operatio _ _ - _ _ _ - _.
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On March 22, 1988, an automatic reactor trip occurred due to loss of power to nuclear instrumentation (NI) cabinet A.
The loss of power to the NI cabinet occurred as a result of a failed capacitor in a regulating transformer.
Following a reactor startup on March 24, 1988, power operation was delayed due to a problem with the 5<wer supply in the feed-water control system.
The generator w,M phased to the grid on March 24, and the plant had attained approximately 86% power when an automatic reactor trip occurred on March 26 on low steam generator water level. The low steam generator water levels in two steam generators were caused by the improper operation of a power supply in the feedwater control system.
This caused erratic operation of the feedwater control valves for those two steam generators.
Following a reactor start:o the same day, the plant was at full power operation March 29, 1988 and remained at 100% power through the end of the assessment period.
2.
Inspection Activities One NRC senior resident inspector was assigned full time during the assessment period.
A resident inspector was assigned and i
l reported in November, 1987. The total NRC inspection effort for the period was 3248 hours0.0376 days <br />0.902 hours <br />0.00537 weeks <br />0.00124 months <br /> (2165 hours0.0251 days <br />0.601 hours <br />0.00358 weeks <br />8.237825e-4 months <br /> annualized) with a dis-
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l tribution in the appraisal functional areas as shown in Table 1 (Inspection Hour Summary).
During this period, NRC team inspections were conducted in the following areas:
a.
Actions taken to implement a program for establishing and maintaining the qualification of electrical equipment within the scope of 10 CFR 50.49 (Inspection Report 50-29/
86-18).
b.
Licensee response to NRC/IE Bulletin 80-11, Masonry Wall Design (Inspection Report 50-29/87-01).
c.
Emergency Preparedness Exercise (Inspection Report 50-29/
87-03).
d.
Special Emergency Response Facility Appraisal (Inspection Report 50-29/87-05).
e.
Special Safeguards Inspection (Inspection Report 50-29/
87-08).
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Safety Assessment Team Inspection (Inspection Report 50-29/
88-02).
Table 2 provides a synopsis of enforcement data for the assess-ment period.
This report also discusses "Training and Qualification Effec-tiveness" and "Assurance of Quality" as separate functional areas.
Although these topics, in themselves, are assessed in the other functional areas through their use as criteria, the two areas provide a synopsis, For example, quality assurance effectiveness has been assessed on a day-to-day basis by resi-dent inspectors and as an integral aspect of specialist inspec-tion.
Although quality work is the responsibility of every employee, one of the management tools to measure this effective-ness is reliance on quality assurance inspections and audits.
Other major factors that influence quality, such as involvement of first-line supervision, safety committees and work attitudes, are discussed in each area, f
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C.
Facility Performance Analysis Summary Category Category last Period This Period Functional Area 02/01/85 - 10/06/87 10/07/86 - 03/31/88 Trend A.
Plant Operations
1 B.
Radiological Controls
2 C.
Maintenance 1#
Improving 0.
Surveillance
1 E.
2 Improving F.
Security and Safeguards
2 Improving G.
Refueling and Outage Management
1 H.
Engineering Support
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Licensing Activities
1 J.
Assurance of Quality
1 K.
Training and Qualification Effectiveness
2 Improving Fire Protection and Housekeeping
- Previously assessed as Maintenance and Modification
- Not previously addressed as a separate area
- This area was not evaluated as a separate functional area during this assessment period.
Pertinent observations are covered in other appropriate functional area.
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D.
Unplanned Shutdowns, Plant Trip and Forced Outages Root Functional Date & Power Level Description Cause Area ___
10/31/86-100%
Manual shutdown to hot Random
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standby in response to a component failed p'essurizer wide failure range level channel; required by T.S. 3.3.1
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11/1/86-Restart 2/18/87-100%
Automatic reactor trip due Procedural
. Engineering to high main coolant system inadequacy pressure, caused by over-due to compensation in. generator inadequate load reduction in response engineering to a dropped control rod review Inadvertent safety injection Inadequate Maintenance due to maintenance performed temporary on the No. 1 main coolant procedure pressure channel review by instrumentation operators and
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I&C Supervisor 2/19/87-Restart 7/6/87-10%
Automatic reactor trip on Personnel Operations main coolant system high error due pressure, caused by to poor excessive throttle valve coordination operation and inadequate communications 7/7/87-Restart
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7/31/87-100%
Load reduction to the Random
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l-startup mode and turbine component
generator removed from failure grid to repair a small
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steam le6k on the high pressure turbine impulse
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chamber drain line
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Root Functional Date & Power Level Description Cause Area 8/6/87-100%
Load reduction to the Inadequate Maintenance startup mode and plant procedure removed from the grid to due to lack enable repair activity as of vendor a result of steam leak on technical No. 1 SG bl edown line information check valve 10/14/87-100%
Load reduction to the Inadequate Maintenance startup mode and plant procedure due removed from the grid to to lack of enable repair activity as vendor a result of steam leak on technical No. 4 SG blowdown line information check valve Emergency load reduction Random
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implemented approximately component six hours into above load failure
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reduction due to blown gasket on main condenser steam dump valve 10/16/87 Load reduction to the Random
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startup mode and plant component removed from grid to failure facilitate repair of packing leak on No. 1 main steam line NRV 11/21/87-1004 Load reduction to the Inadequate Maintenance startup mode and plant pressurization removed from grid due procedure due to a low nitrogen pressure to test alarm on No. 2 NRV instrumentation inaccuracies 3/22/88-100%
Automatic reactor trip due Random r
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to failure of regulated component power supply for nuclear failure instrumentation cabinet A 3/24/88-Restart
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Root Functional Date & Power Level Description Cause Area 3/26/88-86%
Automatic reactor trip on Random
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low steam generator water component level due to feedwater failure control sys+,em power supply failure Note:
The root causes identified in this table are the opinion of the SALP Board based on its analysis of the event; and mu/,
in certain instances, differ from the licensee's cescription of cause, as provided in LER's or monthly operating reports.
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.IV.
PERFORMANCE ANALYSIS LA.
Plant Operations- (790 hours0.00914 days <br />0.219 hours <br />0.00131 weeks <br />3.00595e-4 months <br />, 24%)
1.
Analysis The previous SALP rated plant operations as Category 1, with notable accomplishments that were indicative of the operating and. support. staff's overall quality performance.
Areas identi-fied where improvements 'could be realized included the ability of the operator licensing pr7 gram to effectively prepare large classes of candidates to operate the facility, timely issuance of plant information reports, and actions to improve procedural quality and availability.
During.the current SALP period, there was one safety assessment team inspection in this area.
Plant operations were observed throughout the period.
The performance level by the operations staff is high, as indi-cated by the low number of personnel errors and good plant per-formance record. The plant availability factor was 88 percent.
The manner in which the plant operators and licensee management responded to plant events and conditions involving 1) plant
. operations with degrarSd fuel cladding, 2) a dropped rod event, and 3) developing equipment performance requirements to compen-sate for less than an optimal 125V dc station battery system
'have demonstrated a posit've approach in resolving issues from a safety standpt nt.
The performance level of plant operators during routine and transient plant operations reflects a con-scientious attitude and concern for plant safety.
Operators exhibit positive attitudes and. a keen interest in operations excellence.
Control room operators and shif t turn-overs are done well. As a result of industry initiatives, the licensee ha; been responsive to the need to enhance both oper-ator professionalism and the control room environment.
Profess-ional appearance guidelines have been issued.
Human factor enhancements for the main control room panel have occurred.
In general, plant operators are aware of and monitor off normal
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equipment performance.
Documentation of equipment malfunctions and the initiation of corrective maintenance are performed rou-tinely and reflects the operators' conservative approach to safety.
NRC inspectors have observed that there appears to be an occasional lack of aggressivaness in resolving problems observed during plant operations and at times a lack of a proper questioning attitude. Examples included 1) inadequate operation of a control rod primary position indication channel during a
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plant startup, 2) incorrect recorder paper used in two control room strip chart recorders for nine days, 3) inconsistencies between control' room instrumentation for pumps.in the feedwater
. system, and 4) anomalous indications on feedwater flow instru-mentation as a result of a frozen steam generator pressure sen-sing line.
This indicates a need for improved control room status reviews by the operators.
During the eighteen month assessment period, four plant trips occurred during plant operation.
Two trips were caused by com-
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ponent failures, one was caused by an inadequate procedure, and one was caused by a combination of inadequate procedure and operator performance during turbine overspeed testing.
This resulted in a low reactor scram (trip) rate of 0.26 scrams per 1000 critical hours while at power which is significantly below the national average of about two per 1000 critical hours.
There were four examples of failure to recognize the applicabil-ity of technical specifications actions statements. In these cases there was minimal safety significance, and licensee cor-rective actions were appropriate.
These conditions occurred because of inconsistencies and ambiquitics in the limiting con-ditions for operation and attendant action statements of the respective Technical Specifications.
A coordinated licensee effort to resolve these conditions in a timely manner does not presently exist.
On a case-by-case basis, the licensee has been cooperative in attempting to resolve NRC concerns on this issue.
The licensee's performance in the area of submitting licensee events reports (LER's), as required by 10 CFR 50.73, continues to be effective as a result of established well-stated adminis-trative controls, the increased involvement of the Technical Services Department, and additional oversight of the Plant Operations Review Committee (PORC). As a result, LER's are, in general, properly identified, analyzed, and reported in a timely manner.
The in place corrective action systems, which utilize plant information reports (PIR's), to promptly identify the non-reportable concerns were utilized effectively by the licensee to provide appropriate corrective action to prevent recurrence.
The PIR's were issued in a timely manner.
In the area of event reporting required by 10 CFR 50.72, there was a minor programmatic breakdown that resulted in enforcement action due to the repetitive failures to make proper reporta-bility determinations and timely notifications to the NRC. The licensee has demonstrated responsiveness to the NRC concerns by taking prompt and effective short term corrective actions, with a technically sound and thorough proposal for long term correc-tive action.
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-Routinely, the PORC was observed.to engage.in active and probing discussions on items of. concern and plant events. Although the PORC meeting minutes have improved in the level of detail, they still do not at all times adequately reflect the attitudes and s
concern -for plant safety. exhibited during ; the discussions.
Licensee enhancements occurred to further improve the safety review effectiveness of the PORC. The Nuclear-Safety ' Audit _ and '
Review Committee was determined to be -properly staffed and functioning.
Reviews-of required activities were timely and thorough.
Operations and supporting departments are adequately staffed.
Retirements and promotions have affected key positions, with the positions-being filled on a priority basis.
The licensee has been aggressive in staffing new -support positions in. the opera-tions and technical departments to cope with increased work'
levels. A five-shif t rotation schedule is used. A sixth shift supervisor (SS) position and a sixth senior control room opera-tor (SCRO) position is on the roster to facilitate operational flexibility. The spare SS position was maintained, however, the spare SCR0 was staffed.only eight months of the assessment period. The licensee relies on a modest use of overtime to meet watchstanding needs.
The current class of R0 and SR0 licenses is comprised of four and three candidates, respectively. Manage-ment initiative. to develop an ample number of operators, is evident.
The current requalification training program for licensed opera-tion is making a positive contribution to safe operation of the plant, as evidenced by the operators' performance record that includes a good level of knowledge, adherence to licensed condi-tions, and adherence to procedures with few personnel errors.
The operators reflect positive attitudes pertaining to training effectiveness and quality of the program.
The licensee has ' been responsive to NRC initiatives by taking aggressive actions to improve procedural quality and availabil-ity. The licensee was responsive to the issue of over-reliance on special orders used in lieu of approved procedures, as evi-i denced by aggressive managennt attention to the issue.
Prob-i lems in this area generally have not recurred.
Procedures are being developed for all plar.ned operations, and human factor reviews on operational procedures have made a positive contribu-tion to the quality of procedures and provided increased empha-sis on attention to detail during procedure reviews. The opera-
tional procedures are of high quality and provide the depth of
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detail in an orderly form to permit verbatim compliance.
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In _ summary, ~ the-licensee's consistent high level of-performance
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in this area is indicated by. the low number of reactor trips -
and minimal.' number of personnel errors, a; strong orientation towards nuclear safety and responsiveness to issues _. raised
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' internally and by the NRC, Plant operations continue to reflect the positive influence _ of active management involvement on a day-to-day basis, and the positive attitudes displayed by oper-ating and support personne1'at the plant.
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2.
Conclusion Rating:
Category 1
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Trend:
'None 3.
Board Recommendation Licensee:
Address apparent inconsistencies and ambiguities-in existing Tech-nical Specifications.
NRC: None
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Radiologica'l Controls (286 hours0.00331 days <br />0.0794 hours <br />4.728836e-4 weeks <br />1.08823e-4 months <br />, 9*4)
Analysis y
During the previous assessment period, no significanc issues were identified and the radiological controls area was rated Category 1.
During this assessment period, one special inspection and three routine inspections were conducted along with ongoing reviews throughout the period.
Areas reviewed were organization and
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staffing, audits, training and qualifications, facilities and
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equipment, internal and external exposure controls, and the ALARA program. Two violations related to hot particle exposure controls were identified.
In addition, three violations were identified by the licensee for which prompt corrective actions were taken.
Radiation Protection The licensee's supervisory staffing and management involvement for the radiation protection program provided an adequate level of program oversight and implementation.
Through newly insti-tuted programs, the supervisors are touring the facility to-identify and correct radiological infractions.
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The licensee continued to be responsive to NRC-identified con-cerns during this assessment period.
Programmatic weaknesses
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identified in NRC inspection reports early in -the assessment period were generally resolved by the end of the assessment period.
One notable exception to this was the timely develop-ment of a fully effective "hot particle" control program. Iris industry issue had beer previously discussed in twc NRC Informa-tion Notices and site inspection reports.
Several radiological control problems associated with "hot particles" were noted dur-ing this period, which resulted in two violations. These viola-tions involved a failure to adequately evaluate a skin contam-ination, and an overexposure of the skin in excess of regulatory limits.
Licensee actions in response to these issues are con-tinuing; near the end of the assessment period, an NRC review had determined that r.he program and implementing procedures had not been completed.
Licensee quality assurance audits of the radiation protection program were found to be technically sound and thorough.
The NRC identified one deficiency in the licensee's audit program regarding radiation protection staff qualifications, which was promptly corrected.
Audit findings were resolved in a timely manner.
The 'icensee's program to upgrade the radiation protec-l tion procedu -s was completed during this assessment period. A l
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review of the. procedures indicated that the final product was of high quality,.providing clear _ and concise directions and re-quirements.
A few procedures, such: as "hot particle" idose assessment procedures, were found to require additional tech-nical review and revision.
The licensee upgraded the health physics control point during this assessment period.
The control point was expanded to
~ facilitate access into and out of the radiologically controlled area. -The new dose tracking and computerized access controls
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provided significant improvements. - State-of-the-art whole body personnel friskers were acquired and used.
Repetitive problems existed in the licensee's external exposure controls program regarding posting, labeling and controlling high radiation areas, radiation areas, and radioactive mate-rials. NRC inspections identified problems with the delineation of' radiation areas and high radiaticn areas, and with inconsis-tent and improper labeling of radioactive materials.
Such problems included lack of area boundary definition, lack of high radiation area access posting, and inadequate material labeling.
The licensee identified a failure to maintain positive control over a high radiation area (LER 87-013, dated August 8,1987),
in which the access door to a high radiation exclusion area was-found open and unattended. At the end of the assessment period, the licensee identified that a "swinging gate" radiation area barrier, with required area posting, was removed from its post.
The health' physics technician on shift was inforvied of this l
condition, but failed to re-establish the barrier and to repost
the area or. notify plant management.
This unposted condition L
existed for seven hours before it was corrected. Although each l
of these incidents were minor in nature, when _ viewed collec-l-
tively, they indicate a need to assess the effectiveness of root l
cause analysis and corrective action 'in the external exposure
control program.
I Weaknesses were noted in the licensee's ALARA program during this assessment period.
Early in the assessment period, NRC inspections noted that personnel assigned responsibility for the l
ALARA program were not trained in ALARA practices or techniques
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and appeared unable to support ALARA reviews. Implementation of the ALARA procedure was poor, in that ALARA reviews were not done for all jobs requiring such reviews. Exposure tracking of l
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- tasks, - other than. steam generator work, was; not done.
Also,
' unrealistic steam generator. mock-up training was provided. in support of outage activities.
Toward the_ end of the assessment period, the licensee had -corrected some -of. these weaknesses.
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. Also, ALARA benefits were achieved through aggressive shielding and - decontamination pragrams, resulting in -fewer contaminated and locked high radiation areas, to reduce collective personnel exposure.
The radiation protection training and qualif.ication program was found to be adequate during this. assessment period.
However,
'there were indications of a need for improvement in some areas.
Repetitive NRC-identified deficiencies were noted in radiation area posting and radioactive material labeling resulting from training inadequacies.
The licensee had identified that the training program required -improvement, and had initiated major program revisions for the training of plant workers, HP tech-nicians and HP supervisors.
Summary The licensee's radiation protection program performance was ade-quate this assessment period.. Licensee strengths were. noted in their responsiveness to NRC-identified concerns and their qual-
ity assurance audit findings. Supervisory staf fing was adequate
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to ensure program oversight and effective implementation. How-ever, control of high radiation areas, radiation areas and radioactive materials appears to need licensee attention to identify and correct the root cause of repatitive incidents.
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The licensee.has implemented initiatives to enhance its program.
However, further attention needs to be focused on industry progress in radiological developments for continued piogram
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improvements.
2.
Conclusion Rating:
Category 2
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Trend:
None l
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Board Recommendation Licensee:
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Strengthen the controls for high radiation area and radiation
area barricade posting and labeling deficiencies
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Finalize the "hot particle" control program to assure NRC and
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i industry concerns are addressed and incorporated.
l NRC: None
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Maintenance (473 Hours, 15%)
1.
Analysis During the previous ' assessment' period, the maintenance area was rated Category 1.
Positive findings were made in the areas of
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management involvement, plant reliability, preventive mainten-dnce programs, and licensee responsiveness to NRC initiatives.
Weaknesses were identified that. involved the Maintenance Support Department (MS0), control.of vendor information, and involvement-of QC in routine maintenance activities.
In. this assessment period, ongoing maintenance activities were routinely reviewed by the resident inspectors.
Maintenance activities were also reviewed la various regional inspections.
The. general condition of the plant, equipment performance and consistently high level of plant reliability, are~ reflective or a caring and conscientious attitude of qualified craft and supervisory personnel.
Maintenance personnel continue to exhibit a pride in performance and maintain good housekeeping conditions. Positive attitudes reflecting a management philoso-phy of "d3 the job right the first time" is considered to be the craftsman's responsibility in assuring-quality.
Rework is usually not required, and when it does occur it is not due to deficiencies in personnel performance.
Strong programs asse-ciated with valve maintenance and rotating electrical n.achinery were evident. Maintenance backlogs were routinely maintained at iow levels.
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The licensee continues to demonstrate an appropriate level of concern for plant aging - and the need for equipment upgrading.
The licensee's preventive maintenance program has been viewed as a licensee strength. Enhancements of the progran have occurred, such as including check valves subject to severe operating con-ditions.
An example during this usessment period that was representative of a conservative, technically sound and thorough approach involved the licensee's corrective actions in response to a body-to-bonnet flange leak on a main coolant system stop valve. The loss of decay heat removal during low reactor cool-ant level operation, was factored into planning efforts.
Quality assurance and quality control (QA/QC) oversight of main-tenance activities was evident.
In general, the QA/QC is func-tioning at the appropriate level to support site maintenance activities. Licensee responsiveness to resolve prior SALP con-cerns was demonstrated by the improvements noted in more effec-tive integration and involvement of QC in routine maintenance activities.
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In this SALP period, there were six maintenance-related LER's.
One' of the LER's ' involved a safety injection system actuation while. the plant 'was in Mode 3, howe *,er, no injection occurred, because the main coolant system was being maintained at full system pressure. Although this event was principally related to
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personnel error, there were elements of program deficiencies involving inadequate review practices to identify.the impact on operating systems of the implementation of a temporary change request (in this case a lifted lead activity).
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Two significant examples of maintenance-related problems occurred in this assessment period that demonstrated that.the programs for control of site activities involving modification and maintenance were not fully effective.
The first example involved the failure to install concentric 0-rings in a contain-ment penetration blank flange (LER 87-11). Although the instal-J lation was completed during a-refueling outage in a previous assessment period, the n'ultiple failures that allowed this con-dition to occur were representative of program and personnel weaknesses that existed during this assessment period.
The second incident involved the installation of a non-environ-mentally qualified solenoid valve in the fuel oil system for one of the emergency. diesel generators. Although later engineering analysis confirmed that the valve would have functioned as
?? quired, the incident was a significant breakdown in implemen-ting the mair.tenance system.
Factors that were attributed to the occurrence of this event included:
1) an unclear under-standir.g by personnel. as to which equipment required mainten-ance; 2) pcor ver' al communications between personnel; 3) as-o signment of the repair activity to the wrong department; and, 4) a number of failures involving the MR process itself.
The corrective actions as a result of this event included:
1) up-grading of facilities for the maintenance.and maintenance sup-port groups to improve communications between maintenance per-sonr.el; 2) identifying. manpower deficiencies within the mainten-ance support department and first line maintenance supervisory positions; 3) upgrading maintenance procedures to aid in train-ing replacement personnel and ensuring the performance of quality work; and, 4) improving the training of personnel involved in maintenance activities.
The licensee's corporate and site management responded to these events in a thorough and aggressive manner.
During the prior assessment period, a weakness which resulted in enforcement action was noted involving the failure to document or perform maintenance activities as required by the maintenance request (MR) procedure. In this assessment period, similar con-cerns were identified.
This longstanding regulatory issue was
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attributable to the licensee's failure to understand the under-lying reasons for their staff's inability to carry out important elements of the programs in a consistent manner. As a result, the formulated corrective actions were ineffective.
Subse-quently, various task forces were established to resolve the issues and define corrective action to ensure that adequate con-trols for work activities are in place and functioning. At the end of the assessment period, a new MR procedure was in the final development stage. The licensee made substantial progress in dealing with NRC concerns by defining the need for, and developing, a new post maintenance testing procedure.
The training department which has active representation in task force activities, is developing the required lesson plans to ensure all appropriate personnel are fully qualified when the new MR and post maintenance testing procedures are implemented in August, 1988.
The prior SALP assessment found maintenance department staf fing to be adequate, with the exception of weaknesses in the resource level of the MSD.
The MSD has evolved from a group of mainten-ance engineers within the I&C and maintenance groups, and has become more involved in the design process and less involved in day-to-day maintenance activities.
As a result of MSD being heavily involved in design related activities, this group of plant engineers has not been readily available to suuport plant personnel for routine activities.
Areas such as engineering review and evaluation of maintenance tasks, development of pre-dictive maintenance activities ano equipment performance trend analysis have not been developed to the extent expected from a site engineering organin tion.
The staffing of a technical assistant in the MSD was provided to enhance utilization of existing engineering rescurces.
In January 1988, authorization was granted to expand the roster of eight MSD engineers to ten.
In addition, initiatives are underway to refocus the efforts of the M50 away from modification activities and toward involvement in day-to-day maintenance activities and resolution of identi-fied deficiencies.
The Yankee Nuclear Services Division (YNSD)
engineering support organizations are prepared to expand their involvement in on-site modification activities.
The slow development of a program for control of technical manuals, as specified by Generic Letter 83-28, was a prior SALP concern.
No substantial progress has been made as exemplified by the licensee's identification that outdated lubrication prac-tices involving certain safety-related air circuit breakers had occurred since 1979.
The configuration control program initia-tives of the YSND Yankee Projects Group is currently addressing this issue, and includes plans to expand the program to Balance-of-Plant equipment in 198. _ -_ _
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gg A weakness was noted in the area of dedication of commercial grade ' components. used in safety related systems.
One example involved the use of unqualified fuses' in a containment pressure instrument channel. In addition, the drawings for these compon-ents failed to. identify the equipment design bases.
Both con-cerns resulted in a violation.
Interim corrective actions are
.in effect until a program is developed to deal with,the program-matic issues involved.
In the area of training and qualification effectiveness,. main-tenance personnel appear to be well versed in the details of equipment maintenance.
Recurrent weaknesses -in implementing programmatic controls' indicates that the licensee's training and qualification efforts were not fully effective. Training issues from the prior SALP involving MSO engineers have been addressed.
In summary, -the licensee was inconsistent in maintaining a high level of ~ quality maintenance implementation _throughout the assessment period.
In general, the plant was being well main-tained in a manner that reflects personnel pride.and a safety conscious attitude.
Where poor work practices existed, they were generally not reflective of personnel attitudes, but were more properly-representative of insufficient supervision, inade -
quate work control procedures, or ineffective training.
The licensee has taken positive steps,to upgrade the maintenance-program, including training, to improve effectiveness and improvement in QA/QC ef fectiveness in this area was noted.
Inis was evident through the conduct.cf aggressive investigations and
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analysis that resulted from two significant maintenance related
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events.
The new maintenance manager is aggressively pursuing issues and coordinating actions to improve the programs.
2.'
Conclusion Rating:
Category 2 Trend:
Improving 3.
Board Recommendation Licensee: None NP_C :
None
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D.
Surveillance (322 hours0.00373 days <br />0.0894 hours <br />5.324074e-4 weeks <br />1.22521e-4 months <br />, 10%)
1.
Analysis Surveillance was assessed as a Category 1 during the previous
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-SALP period.
A. weakness was identified in the area of ensuring appropriate surveillance requirements were addressed and pro-perly incorporated-into procedures.
NRC inspectors examined surveillance activities as part of the routine inspection program. Inspectors also examined activities associated with steam generator in-service inspection.
The surveillance program was determined to be ef fective, well-defined and well-controlled, previous procedural weaknesses generally have been corrected.
Surveillance procedures accur-ately reflected technical specification' requirements, were tech-nically accurate, included. adequate detail to assure correct performance and included appropriate acceptance criteria with the exception of the eighteen-month emergency diesel generator load test procedure, as noted below.
Records :were well main-tained, accessible and complete.
Staffing is adequate and the pride in workmanship displayed by personnel performing surveillance activities is noteworthy.
Supervisors were observed to be knowledgeable and their involve-ment is evident on a day-to-day basis.
Personnel performing surveillance tests are knowledgeable of the facility, equipment i
under test and plant procedures. Excellent coordination between the control room operators and technicians is evident. Surveil-lance testing was conducted in a careful, safety-conscious
. manner with consistent management oversight. Rased on inspector
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discussions with technicians and observation of activities, the trairing program, including on-the-job training has been effective, No trips were caused by surveillance tests. One LER was issued which involved a missed surveillance due to personnel error.
This was an isolated occurrence when compared to the large num-bers of surveillance scheduled and performed during this period and licensee corrective action was ef fective. A second LER was issued as a result of a refueling outage surveillance procedure failure to accurately reflect technical specification surveil-lance testing acceptance criteria. As a result of improvements l
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in the licensee's biennial review of plant. procedures, a dis-crepancy between procedural and technical specification require-ments was noted.
However, the licensee was slow in assessing-preliminary information which indicated that they were not demonstrating the design basis of the emergency diesel genera-tors.
The licensee's ~ corrective actions were conservative. A third LER concerned main steam line pressure switch problems that' were detected during surveillance testing, which is-dis-cussed in the functional area of Engineering Support.
LER 87-11 concerned the failure of the May, 1987 Type B and C containment surveillance leakage testing.
Also, the licensee declared the containment integrated leak rate test (CILRT) a failure.
The CILRT failure resulted principally from the fail-ure to install flange 0-rings in the fuel chute dewatering sys-tem isolation blank flange during the previous refueling outage in December 1985.
Licensee investigation of the failure was expeditious and aggressive; prompt and appropriate corrective actions were taken. Although the CILRT was declared a failure, the test was well controlled and executed. Analysis of the as-found condition of the containment penetration determined that even with the flange 0-rings not installed, containment integ-rity was maintained.
Corporate engineering involvement-in site activities was evi-dent, illustrated by the ev6luition conducted on the adequacy of station batteries and licensee iritiatives to assess pipe wall thinning in response to the Surry feedwater line' rupture.
One violation in this area invclved failure by the licensee dur-ing a previous refueling outage to plug all steam generator tubes exceeding the Technical Specification plugging limit.
Quality verification was not adequate during analysis _of steam generator eddy current testing (ECT) data in that there was a
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lack of secondary or independent review of the ECT data gener-
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ated during the 1984 examinations.
The licensee took effective corrective actions.
This item was an isolated incident and it does not detract from an otherwise excellent performance record.
Procedures and planning for steam generator surveillance were good. The ECT procedures were sufficiently detailed and empha-sized precautions necessary for satisfactory performance of the measurement.
A YNSD ECT expert was at the site and provided good oversight of the steam generator wor.
In summary, the licensee continues to exhibit strong overall performance in this area.
The surveillance program is well-defined and well-controlled and positive personnel attitudes continue to be a strength in this area.
Management attention and involvement was aggressive toward assuring a high level of safe performance of surveillance activities. Licensee resources are ample and effectively used.
2.
Conclusion Rating:
Category 1 Trend:
None 3.
Board Recommendation Licensee: None NRC:
None
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E.
Emergency Preparedness (659 hours0.00763 days <br />0.183 hours <br />0.00109 weeks <br />2.507495e-4 months <br />, 20%)
1.
Analysis During the previous assessment period licensee performance in this area was rated Category 2 based upon one partial partici-pation and one full participation exercise, and a routine safety inspection.
Programmatic weaknesses and exercise deficiencies were identified during the June 11, 1986, full participation exercise.
During the current assessment period, one partial participation exercise was observed, an Emergency Response Facility (ERF)
Appraisal was performed, and two routine inspections were con-ducted.
Emergency response capability was also routinely examined during the period.
During the partial participation exercise conducted on March 31, 1987, the licensee demonstrated acceptable performance with no significant deficiencies.
Command and control were effective at each emergency response facility.
State notifica-tions and personnel augmentation notifications were prompt.
Protective action recommendations were appropriate and conserva-tive.
The ERF Appraisal was conducted during the period March 30 through April 3,1987. Generally, this appraisal ver-ified that the licensee's facilities meet the requirements of 10 CFR 50 and the orders issuea to implement Supplement 1 of NUREG-0737, with one exception. A Notice of Deviation was issued due to six required plant variables not being available to emergency response personre? in the fechnical SLpport Center and the Emergency Operations Facility.
The appraisal also io01tified other minor improvement areas.
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Ouring the assessment period, the position of Emergency Pre-paredness Coordinator (EPC) became vacant, ana within three months a replacement was hired.
Because the EPC does not have previous experience with commerical r;uclear power, he is under-going an aggressive training program to strengthen his knowledge about the industry, reactor fundamentals, and site specific requirements.
The licensee has completed a rewrite of the emergency plan and associated implementing procedures.
The corresponding lesson plans have also been rewritten.
As part of this rewrite, the licensee has also completed a review of their Emergency Actions Levels (EAL) for consistency with federal guidance, quantifica-tion of symptoms where appropriate, and consideration of human factors.
This has resulted in a restructuring of the EAL's.
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This review of the EAL's was undertaken due to a' basic weakness in understanding of the EAL's and repeated licensee idantified weaknesses in.their use.
Short term cnrrective measures for these weaknesses have been aggressive and timely, and with ade-quate results.
Long t rm corrective measures are in place to eventually integrate: the EAL's with the Emergency Operating
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It should be noted that when EAL's have been used, the licensee takes a conservative and timely ~ approach from a technical perspective.
Weaknesses had been -identified by the licensee and the NRC dur-ing the period in the area _of EP training.
As a result,. the licensee has reorganized the training organization to provide additional expertise.
To facilitate training of all emergency organization' and response personnel, three instructors were assigned from the' corporate office.
The new organization trained personnel in preparation for the full participation exercise of April 1988.
Facilities and equipment generally have fulfilled their intended purpose with the exception of the Nuclear Alert System (N\\S), a system dedicated to communications with the State of Vermont and Commonwealth of Massachusetts.
The NAS has demonstrated repeated equipment failures.
The licensee initiative to increase testing of the system verified repeated failures, how-ever, corrective measures to permanently fix the problem have been slow in fruition.
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The licensee's' relationship with offsite agencies is generally
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good.
Personnel from Yankee Nuclear Services Division (YNSD)
are primarily ' responsible for training and coordination efforts.
YNSD is currently werking with.the local towns to upgrade their plans and facilities, and aid in local training activities. The licensee is also working with the Commonwealth of Massachusetts to upgrade.its capabilities regarding Yankee, including the revision of the state's emergency plan.
In summary, the licensee has demonstrated effective oversight and control, has been responsive to most NRC initiatives, and has improved in their ability for self examination. The licen-see has demonstrated a commitment, and expended a great deal of
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effort in upgrading the program.
Although cutside the period, the April 1988 full participation exercise demonstrated that improvements have been made in exercise performance as a result l
of the extensive emergency plan revisions and subsequent re-
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training effort.
However, several key program areas have not yet been completed and evaluated including:
the completion of
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EPC training; the final integration of the EAL's and E0P's; and s final review of the off-site plans and procedures.
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examples of lack of fully effective oversight in this area are
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several weaknesses noted in the 1988 exercise scenario and a
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high failure rate of the NAS.
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_C_oncl u si on Rating:
Category 2 Trend:
Improving 3.
Board Recommendations Licensee:
Continue efforts to resolve concerns involving EAL's.
NRC:
None I
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F.
Security and Safeguards.(196 hours0.00227 days <br />0.0544 hours <br />3.240741e-4 weeks <br />7.4578e-5 months <br />, 6%)
1.
Analysis During the previous SALP, the licensee's performance in this area was Category 2.
Management attention to the overall security program and its effectiveness was required, as evi-denced by the weaknesses identified by -the Regulatory Effective-ness Review (RER) team and routine NRC inspections.
During this assessment period, one routine unannounced physical security. inspection and one special physical security inspection were. performed.
Routine inspections continued throughout the period.
Four violations were identified and the imposition of a civil penalty resulted from three of the four violations.
In the early portion of this assessment period, the effects of management inattention continued and four violations were iden-tified during a special inspection conducted between February 18 and May 22, 1987.
These issues resulted in the imposition of the civil penalty, and since that time there has been continu-ing, increased evidence of plant and corporate management atten-tien to and interest in the security program.
Priority atten-tion has been placed on upgrading the security program to achieve and maintain an effective and high quality security program.
About mid-way through this assessment period, the licensee for-mal'ly committcd to the NRC to improve management of the security program, principally by assigning program responsibilities to the Manager of Administrative Services, hiring an experienced Security Msn:ger, and providing more oversight of and interface with the security contractor. With the reassignment of the pro-gram responsibilities to the Manager of Administrative Services, it was immediately apparent that the program was receiving dedicated attention by a strong and responsible individual who was very rapidly able to recognize and understand the weaknesses in the program and who had the full support of corporate and plant management to ef fect needed improvements.
This manager's interest in and attention to the program remained highly visible throughout the assessment period. Several meetings, in addition to telephone conversations, with the NRC were requested to add.'ess program improvements and their status, to obtain clear understandings of NRC security obj ectives,
and to discuss enhancements to program plans and procedures.
During one such
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- recent meeting, the licensee introduced its new Security Manager, who is experienced and well qualified to direct program and advised NRC of planned security program organ-activities, izational philosophy changes, which include the establishment of shift supervisors and proprietary supervisors for proprietary key program elements, such as training and qualificatian, badg-ing and screening. Previously, these supervisory functions were performed by contractor personnel. The impact of these changes upon the program, as wel'i as the other changes that the licensee has made and is making, will be evaluated by NRC during the next assessment period.
the last assessment period, there was evidence of increased In for security program equipment.
This in-maintenance support creased support was also evident during this period by a reduc-and in in the use of compensatory measures and overtime, tion reduced downtime for equipment.
In addition, the licensee recently advised NRC that planning is in progress to establish a comprehensive preventive maintenance program and to implement These licensee improved maintenance and design work controls.
further examples of increased licensee support initiatives are involvement.
for the security program and significant management The impact of these initiatives will be evaluated during the next assessment period.
The tcain tenance of security records ard reports, and their accessibility to security management for routine pregram over-sight, was also a concern expressed by NRC in the last assess-ment period. Action has been taken by the licenrae to alleviate that concern by establishina a centralized records center and resources to maintain it.
Record retrieva-providing adequate ollity during this assessment period was found vastly improved.
Significant interest and involvement by the licensee in the and in interfacing with the security force security program and security force during the latter portion of the contractor assessment period has resulted in improvements in security force performance, training, staffing and morale.
Some specific licensee initiatives that prompted these improvements are:
pro-viding skill training for supervisors; emphasizing security and force professionalism; monitoring of the training program; creating improved personal and working relationships between The NRC con-plant personnel and the contract security force.
siders that these initiatives and strong licensee management interest are significant contributors to program improvements that are already evident.
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Another. indicator of the licensee's. interest 'in the program is -
the effective resolution of. a majority of the - findings that.
resulted from the Safeguards Regulatory Ef fectiveness Review, conducted by the NRC in n.id-1986, and the pursuit of effective resolutions.for the few' remaining findings.
The resolutions.
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ef fected,. and those.being pursued, are evidence of a much
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clearer. understanding of NRC security objectives on the part of
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the licensee.
The recent annual audit of the security program, performed by the licensee's quality assurance group, was comprehensive in scope and depth.
Corrective. actions on deficiencies identified during this audit were prompt and effective with adequate follow-up to ensure their propar implementation.
This is fur-ther evidence of management attention to and support for the program.
One of the three violations that provided the basis for the civil penalty, involved the licensee's failure to notify the NRC of a security event because of management's lack of understand-ing of NRC reporting requirements in this area.
Review of the licensee's recent security event reports and reporting proced-
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ures found them to be consistent with NRC's regulations (10 CFR 73.71). The three other security event reports that were sub-mitted during the assessment period involved a. vital area door that was not procerly secured by a member of the guard force, a vital area key taken off-site by a member of the guard force, and inadequate control of expired ID/ key cards.
Adequate cor-rective measures were taken in each case.
Two minor security program revisions were submitted during the assessment period. They were clear and concise, and adequately described in a summary transmitt'ed with each revision.
Plan pages were clearly marked so facilitate review.
In summary, weaknesses observed in the prior assessment period continued into the early part of this period. These weaknesses concerned a lack of sufficient management oversight of the security program, including contractor activities.
The licen-sce's failure to take corrective measures to address the weak-nesses allowed events to occur that reflected a breakdown in the security program. This breakdown resulted in the imposition of a civil penalty.
Subsequently, a corrective action plan was developed by the licensee. As a result, major improvements in the security program were evident during the latter portion of the assessment period, otners have been initiated and still others are planned.
These improvements result from a signifi-cant increase in the direct involvement of licensee management in the program, which heretofore, was at best, minimal.
The licensee's commitment to a high quality and effective program that meets regulatory objectives is apparent.
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Conclusion Rating:
Category 2 Trend:
Improving 3.
Board Recommendations Licensee:
Maintain management involvement at the same high level as was evident during the latter portion of this assessment period.
NRC:
None l
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i G.
Refueling and Outage' Management (132, hours,4%)
l A'alysis 1.
n The previous' SALP rated this area as Category 1. ' The licensee's
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performance in this. area during the. last assessment period,was
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considered to be a noteworthy strength.
Active. involvement of corporate and site managers with quality performance of person-nel involved in outage activities resulted in timely completion of outage activities.
During this assessment period, major outage activities. included human factors improvements made in the control room, steam generator inservice inspection, replacement of the high and low pressure safety injection relief valves, installation of six fixed incore detector assemblies and an incore monitoring system and installation of eighteen core baffle plugs.
The strong' outage management team noted in the previous SALP continued.
A high level of attention by. both senior corporate and site management was provided in the scheduling, planning and control of activities.
Excellent prior planning, scheduling, follow-up of status and ensuring compiiance with licensed condi-tions was a noted strength provided by the dayshift refueling outaga coordinator. A daily outage briefing was held to coordi-nate and review planning activities.
Corporate managers per-forming site visits during the outage were noted to be active participants.
During unscheduled outages, strong management oversight and planning was evident.
Numerous work items were schedu?ed and performed to utilize the outage in an effective manner by per-ferming maintenance and surveillance tasks that can only be done with the plant not in an operating status.
The planned six-week outage was extended to an eight and one-half week refueling outage principally due to the discovery of a severely damaged fuel assembly that required fuel reconstitution and other unanticipated equipment repairs.
The licensee's initially optimistic outage schedule contributed to problems resulting from hurried activities in two cases that were except-ions to the excellent prior planning and assignment of prior-ities. The first involved recurrent problems with a non-return valve, where the valve was removed and disassembled prior to I&C troubleshooting being performed on the valve; this could have negatively impacted on a root cause investigation.
The second item involved a spill of component cooling water in the vapor container during a valve line-up due to poor coordination of procedural implementation.
The NRC and the plant management were mutually concerned about these events, with timely and effective corrective measures instituted by the licensee that precluded further recurrenc _
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Staffing during the outage was ' adequate. Contrtetor personnel were effectively used to assist licensee perscnnel.
General training in plant policies and practices, as well as specialized training for selected craft personnel was providtd to contractor personnel prior to the outage.
Effective training and strong management oversight of licensee and contractor ' personnel was evident by the lack of personnel errors and a high level of per-formance associated with refueling outage -tasks.
The licensee has established well-stated administrative procedures to assure that excessive overtime hours have not been assigned to plLnt staff who perform safety related functions. These procedures and policies were adhered to with respect. to the use of overtime during the outage.
YNSD project engineering provided on-site engineering assistance to the. Maintenance Support Department prior to and during the outage by ' assigning cognizant engineers to follow major. engineering design change requests while YNSD engineers were assigned to maintenance-support for assistance as required.
The licensee's use of a "lessons learned" procedure developed from recent design change installations is noted to be an excel-lent illustration of management involvement and control and reflects the licensee initiatives to improve quality.
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Prior to end subsequent to outages, the licensee conducted-plan ~
ning meetings to address resource allocation and planning items.
These planning meetings are effectively used by the licensee to ensure quality performance in this - area.
These meetings are held at the plant site and are frequently attended by corporate management.
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Defined procedures for control of activities were available and utilized.
Plant management demonstrated thorough, conservative and technically sound approaches and decisions concerning issues that had safety sicnificance.
Appropriate management overview of plant work was evident and plant management routinely re-viewed safety related events to ensure that proper analysis and corrective actions were performed.
Examples of effective man-agement oversight and involvement included the licensee's cor-l rective actions concerning failed fuel, main coolant cold leg stop valve disc cracking, pressurizer and main steam code safety valve setpoint drift and operational assessment feedback related to main coolant stop valve stem failure.
One LER was issued for this area that involved personnel error that resulted in the automatic start of two emergency diesel generators.
This low incidence of personnel error and the
strong adherence to procedural requirements reflects positively on training and qualification activities that prepare licensee personnel for refueling outages.
Events that were non-report-able in nature were the subject of plant information reports that contained root cause determinations and corrective actions j
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In summary, the refueling was well managed.
Planned mainten-ance, modifications and major outage tasks were effectively scheduled, coordinated and implemented in a quality manner.
Strong active involvement by corporate and site managers was noteworthy with a conservative approach to safety and attention to detail consistently observed. The low incidence of personnel error along with excellent prior planning contributed to the safe refueling of the plant.
2.
Conclusig Rating:
Category 1 Trend:
None 3.
Board Recommendation Licensee: None NRC:
None
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H.
Engineering Support (390 hours0.00451 days <br />0.108 hours <br />6.448413e-4 weeks <br />1.48395e-4 months <br /> 12*,')
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1.
-Analysis The previous SALP did not address engineering as a separate-functional area.
During this assessment period the engineering capabilities of both the Maintenance Support Department (MSD) and the Yankee Nuclear. Services Department (YNSD) were evaluated.
Both of these organizations have key roles in modification design pack-age development, safety review process, equipment failure root
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cause analysis and configuration control.
The onsite engineer-ing organization is the MSD.
Engineering involvement in assuring the quality of modifications was evident. The procedures used to control the design process are thorough and strictly adhered to, YNSD and MSD staff per-sonnel are very well qualified as determined by personnel inter-views, training and qualification records, and the existence of high quality design documents. The design change packages which were reviewed were found to be complete and detailed, and as a result very little rework was required. Calculations performed as a part of design change packages were found to be technically correct and in keeping with good engineering practices.
Closure
.of completed design change packages was performed in a timely fashion.
YNSD is considered the licensee's primary design agent for all modifications and has review.and approval authority for both plant and engineering design change requests.
The interface between the MSD and YNSD appears to be strong.
This is evi-denced by frequent plant visits by YNSD project personnel, plan-ning meetings between YNSD and MSD, and temporary assignment of YNSD personnel to the plant staff during outages.
l Post modification testing requirements are clearly specified in the engineering design change request packages and the plant
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design change request packages.
The types of tests specified included surveillance tests, pre-operational tests and special tests prepared for the modification package.
In all cases the
,
l tests specified were found to demonstrate the static and dynamic sys' em characteristics.
l
.
.-
40-On its-own initiative, the licensee has instituted a configura-tion control program.
This program consists of several ele-ments, namely; engineering manual procedural _ guidance, a con-trolled document system, a design basis index, updated technical manuals, a setpoint study, plant life ' extension program, M0 VATS and seismic classification documentation.
This configuration control program is -an aggressive effort which is designed to result in documentation of the original design bases of the plant, and a method to systematically maintain the bases.
NRC review of the licensee's 10 CFR 50.59 safety reviews per-formed by plant personnel found that the conclusions reached in the reviews were valid, but were not always in sufficient detail to clearly demonstrate acceptability with respect to the cri-teria of 10 CFR 50.59. The licensee has revised the plant pro-cedures which govern the conduct of 10 CFR 50.59 safety reviews, and the revised procedures appeared to provide improved guidance such that safety reviews are now conducted in a more consistent and thorough manner. Additionally, YNSO is involved in industry efforts to develop guidelines to ensure the proper conduct of-10 CFR 50.59 required safety reviews.
Initial response to operational problems requiring engineering analysis appears to be timely and to have a good safety perspec-tive. The licensee's YNSD project group provided analysis for problems associated with disk cracking on main coolant isolation valves, pressurizer and main steam safety valves, a dropped rod event, and out-of-specification fuel pellets.
Exceptions to this normally good support include an area of concern identified during this SALP period involving an apparent lack of timeliness in resolving problems observed during plant operations regarding the continuously degrading condition of the main steam line pressure switches over a three year period. Although temporary fixes have been accomplished and root cause analysis is in process, no final resciution had been reached. A second example of lack of aggressive follow-up by YNSD projects group involves the untimely performance of a metallurgical analysis on the main coolant stop valve disks as recommended in a July 1987 engineer-ing evaluation.
The plant trip that resulted from a dropped rod was originally classified as an operator error.
Subsequent analysis of the event by YNSD engineering determined that the event response procedure contained inappropriate instructions to the operators in response to the event. The current upgrade ef fort for Emerg-ency Operating Procedures includes an engineering evaluation to assure the expected operator actions and plant response reflect plant desig.
41-A team ' inspection involving an evaluation of engineering sup-port in the development and implementation 'of programs address-ing environniental qualification (EQ) per 10 CFR 50.49 was con-ducted during this SALP period.
Programmatic and performance initiatives were found to comply with the requirements of 10 CFR 50.49, with one unresolved item involving wiring. of Limitorque valve operators outside containment being identified.
A com-prehensive-EQ-related training program was determined to exist at both YNSD offices-and the plant.
The high level of observed performance of the licensee's engi-neering personnel, as evidenced by the quality design work. that rarely results in rework or design inadequacies, and the iden -
tification-of no personnel errors reflect positively on the training and qualification programs that exist. Almost without exception,. design efforts are completed prior to initiating installation -' activities, reflecting a proper prioritization of work and the timely completion ~ of activities.. This is the result of a proper level of interface between site and engineer-ing organizations and an adequate level of engineering resources applied to design and support activities.
In summary, engineering activities related to the design change process are well managed, procedurally controlled and staffed by a-stable and-knowledgeable group.
The licensee has taken on an aggressive configuration control initiative to better document and control the plant design bases.
The licensee has a proper safety perspective which -is reflected in the quality of the design change packages, and ' the low amount of rework.
Minor weaknesses exist in the documentation ' of the basis for 10 CFR 50.59 safety reviews and the occasional lack of timeliness in prnblem resolution.
2.
Conclusion Rating:
Category 1 Trend:
None 3.
Board Recommendation Licensee:
NRC:
._______ -- _ -
I
,
n
-.,.
t
.
q I.
Licensing-Activities 1.
Analysis
'
-The previous-SALP rated this area as Category 1.
During the SALP evaluation period, the licensee continued to show excellent management overview in the area of -licensing activities. As indicated in the prior assessment, the licensee does not have a formal integrated implementation schedule plan.
However, the licensee has a system for. establishing priorities on issues such that both licensee and NRC resources are focused-on the most significant issues. Also, the licensee has a system-for coordinating manpower requirements, equipment procurement and engineering changes for outage planning.
The licensee has-been open in discussing their priorities for both completion of licensing issues and for their implementation with NRC and has been receptive to' NRC comments.
On a once-a-month schedule, meetings are held between the licensee and the NRC to discuss and prioritize licensing issues.
The NRC has noted evidence of prior planning, in particular, timely submission of license amendments related to the forthcoming November 1988 reload out-age. The licensee amendment requests submitted by the licensee contain high quality evaluations for both significant hazards considerations and safety analysis.
The submittals are 'gener-ally complete which results in very few formal requests for additional information from the NRC staff.
Licensee management has taken an aggressna role in an effort to achieve resolution of long-standing is<ues such as the Systematic Evaluation Program (SEP) rniews. With the issuance of the final three NRC SEP Safety Evaluations in July 1987 and the issuance of supplement No. I to NUREG-0825 "Integrated Plant Safety Assessment-Systematic Evaluation Program," dated October 1987, the ten year old SEP was closed out for '.he Yankee Nuclear Power Station. In order to implement as much of this program as possible during the forthcoming refueling outage, the licensee is employing extensive resources to perform seismic reanalysis of safety related piping systems and supports inside of containment.
During this SALP period the licensee committtd to using the Westinghouse Owner's Group type of Emergency Operating Proced-ures (E0P's) and in line with this effort has resubmitted an updated Procedures Generation Package.
In anticipation of NRC review, the licensee has started rewriting the 50P's.
When these new E0P's are fully implemented there should be a signifi-cant improvement in post-accident recovery ano public and site safety. Upper management involvement in establishing priorities and in reaching technical resolution of the SEP and E0P's has been eviden _ _ - _ - _ _ _ _ _ _ _ _
..
.
,
The Yankee plant is unique in many aspects and the -licensee
.often relies. on.the long operating experience and simplicity of
~
design to justify alternative approaches to resolution.
Because of the -age and size of-the plant m%y generic resolutions of issues are not appropriate and thus more work is required by both the NRC and licensee to complete the reviews. In general, the licensee has been able to satisfy the intent of NRC require-ments in plant-specific applications. -For example, the licensee has met all the guidelines of Regulatory Guide 1.97, "Instrumen-tation for Light-Water-Cooled Nuclear Power Plants to Assess
Plant and Environs Conditions During and Following an Accident,"
except in regard to nuclear instrumentation.
The installed nuclear instrumentation does not meet minimum RG 1.97 guide-lines.
The licensee submitted a 't isk-based analysis to put this deficiency in perspective.
The licensee stated the potential for core damage is so low that no plant modifications are justi-fied. While staff review is not yet complete, this PRA approach is a_ novel way to resolve this problem.
The licensee has submitted, during tSe SALP period, completely
<
new small break and large break LOCA analyses.
In addition, many of the physics and thermal-hydraulic codes supporting these analyses are also being upgraded.
The licensee's technical
,
staff developed these analyses in house.
This development will provide the licensee with a greater understanding of core be-havior and.of the more vulnerable pipe sizes in terms of LOCA
-
analysis. These understandings should contribute to safer plant operations as well as self sufficiency in core design and acci-dent analysis. Staffing levels seem satisfactory for the level of work required.
A long standing problem has been in the issue of bus under-voltage protection. This involved both first and second level undervoltage protection. The licensee has submitted acceptable
.
technical specification change requests to resolve these issues.
The problem of minimum starting voltages in the electrical
,
distribution system has also been resolved, i
i On balance, the licensee continues to respond promptly to NPO staff initiatives. However, during the summer and fall of 1987 the licensee did not submit any new license amendment requests l
due to the licensee's engineering staff being totally involved in the SEP process.
The positive safety impact of the comple-
'
tion of the SEP outweighs the time lag in submittal of new license amerdments.
The NRC staff was aware of the pending submittals and none of them were of imminent safety significance.
During this performance period the licensee has made all neces-sary submittals needed to close out the remaining NUREG-0737, NUREG-0737 Supplement I and Generic Letter 83-28 (Salem ATWS)
issue. _ - _
.
'
In summary, the licensee's organization has performed at a high level in the licensing area during the report period as evi-denced by the large number of completed actions. The licensing backlog has been reduced from 34 to 17 open items during the SALP period. The majer licensing reviews which continue through the end of this SALP period are:
an extension to the operating license expiration date, crane travel over the spent fuel pit and LOCA re-analysis. All of these large reviews are underway and should be completed in mid-1988, Major programs completed during this period included the SEP, as previously noted, the Safety Parameter Display System, RG 1.97 review, Pressurized Thermal Shock (10 CFR 50.61) review, the Regulatory Effective-ness Review, and a final Apoendix R exemption. These actions are indicative of strong management involvement.
2.
Conclusion Rating:
Category 1 Trend:
None 3.
B_oard Recommendation Licensee: None MC:
None
i l
l l
l l
l l
l L
._3
-
Y
,
.
~
<
J.
A~ssuranceuof Quality (104 hours0.0012 days <br />0.0289 hours <br />1.719577e-4 weeks <br />3.9572e-5 months <br />, 3%)
1.
Analysis During the previous assessment period, this functional area was rated Category 1.
The assessment noted that there were weak-nesses including QC inspection functions at the site,-which were an exception to an otherwise exemplary performance in this functional area.
During this assessment period, Assurance of_ Quality is again being considered as a separate functional area.
Management involvement and control in _ assuring quality continues to be one of the evaluation criteria for each functional area.
The
'
various aspects of programs to assure quality have been con-sidered and discussed as a.n integral part of some functional areas and the respective inspection hours are included in those areas, with the exception of hours that reflect specific inspec-tions ' of the QA program.
Ccnsequently, this section is a synopsis of the assessments relating to management involvement and control in assuring the quality of work conducted in all areas.
During this assessment period, significant improvement ~ in the performance of the onsita QC group was observed. To address the
"
NRC concerns, the licensee's Quality Assurance Department (QAD),
which has responsibility for all plant related QA/QC activities, was re-organized in Mar:h 1987. A Quality Services Group (QSG)
was formed to provide expertise in specific areas of the Opera-tional Quality Assurance Program, including inspection and sur-veillance of plant activities, and trendine - alysis.
The QA
'
Surveillance and QC Inspection Programs were extensively revised to improve the effectiveness of the activities.
Appropriate goals were established with actions predicated on a philosophy of prevention versus detection of deficient conditions.
The QC function continues to evolve as a result of improvements neces-
[
sary to be responsive to identified plant needs and evaluations
)
that resulted from the internal auditing program and by the l
Combined Utility Assessment Program.
The improvements in effectiveness observed over the course of this assessment period are exemplified by the QSG's accomplish-i ing the necessary integration of the QC inspection with the
'
plant maintenance functions; the demonstrated ability to iden-tify relevant deficient conditions; and the recognition by the
,
'
operating organization that the QSG provides useful feedback to department and plant management. A few examples of significant
,
.i
^
deficient conditions identified by the QSG personnel were the release of a component for a safety related air circuit breaker from ' the plant storeroom without the use of programmatic con-
- trols; and installation of replacement parts for an emergency diesel generator by a vendor without licensee personnel first conducting the required receipt inspection on the components and materials.
.There was routine involvement by QAD and QSG managers, as well as QA specialists assigned to conduct program effectiveness evaluations, at 'the site for the purpose of pro-viding the proper level of oversight and management involvement.
to correct concerns.
The QAD audit program is conducted in accordance with the licen-see's procedure and published schedule. 'The conducted audits-are effective in identifying quality concerns as evidenced by in-depth and comprehensive reports issued. Licensee initiatives to improve effectiveness have included:
1).the use of a ver-tical slice audit approach as a safety system interface aspect of the audit, the ECCS system was selected because of its importance to plant safety; 2) expansion of the use of technical specialists, including personnel from other operating plants, to provide increased technical capability on the audit team; 3)
redirecting the audit program from compliance based tcward per-formance based, with an increased emphasis on viewing activities from a perspective of technical adequacy; and 4) improving. a classification system for deficiencies and observations that reflects levels of importance to quality that conserves manage-ment resources and allows senio. managers to focus on ths more significant issues.
This last item is an example of a recom-mendation developed by the involvement of the QAD in a Quality Improvement Task Force.
The plant operating organization views the conduct of audits as important and considers them to be an effective quality activity.
Regarding QA0 vendor activities, their involvement was noted in the conduct of a task force established to study the vendor Quality Assurance Program.
The study has been issued, with
'
recommendations for program enhancements being incorporated into an implementation plan.
The Plant Operations Review Committee (PORC) and the Nuclear Safety Audit and Review Committee (NSARC) are involved in the review of operational performance, design changes, and the review of deficiencies involving the need for corrective n tions.
The NSARC provides an oversight function of the In-Plant Audit Program.
The members of both safety assessment committees consistently demonstrate a clear understanding of the i
. - -
-
.
- _-----------. -- _ __ _ ____ _
\\
' -
technical and safety aspects of issues presented for their
- review, and appear to be generally effective in overseeing station operations. Both _ committees have -been actively involved ~
in licensee efforts to develop guidelines and conduct training of licensee _ personnel that will ensure the proper conduct = of safety evaluations required by 10 CFR-50.59.
The licensee utilizes operating experience assessment (OEA) and
- corrective action' programs as methods for ensuring a high level of quality in plant and personnel performance. The OEA program appears to be generally effective, however, the need for addi-tional management oversight of the initial screening process was determined to be warranted by the NRC. At the end.of the SALP period, licensee actions were in progress to address the issue.
Many of the OEA documents, such. as LER's and PIR's share the same Project Commitment Tracking Responsibility (PROCTR) System, as does the various ~ program elements of the Corrective Action Program.
NRC concerns were raised this assessment period as a result of corrective action items not receiving timely manage-ment attention.
Examples involved untimely completion of the licensee's commitments made in response to an NRC violation and untimely disposition of deficiencies identified by Nonconform-ance Reports. These examples reflect weaknesses in the PROCTR System' that is being used as a commitment tracking control.
Senior licensee managers are aware of the concerns and were aggressively pursuing remedial actions near the end of the SALP period.
There were many activities and initiatives implemented during this assessment period that indicates that management involve-ment in assuring quality is effectively integrated into all aspects of plant operations and support activities.
A few examples are: 1) initiatives in the area of configuration con-trol; 2) a strong and effective program dealing with fitness for duty; 3) establishing programs to deal with stress in the work-place; 4) senior corporate officials, line managers and licen-sing personnel interface meetings with the NRC to discuss issues of current interest; 5) the utilization of resources or exper-tise available through INPO, including management development programs, peer inspection programs, observer training, and development of training programs; 6) the development of a plant life extension group that will deal with relicensing issues and enhance the licensee's understanding of the affects of aging on plant components and equipment; 7) the YNSD Project Groups use of lessons learned to improve the quality of design change activities and engineering support for the plant; 8) plant management initiatives involving worker and plant observation programs, 9) management efforts to ensure a high level of professional conduct is maintained and control room decorum is improved; and 10) training department observation program for both licensed a d unlicensed plant personne.
'
With the exception noted in the maintenance area, active in-volvement of first-line supervision was observed.
Licensee corrective actions have been identified to cddress the weakness in the maintenance area.
The work attitudes of the licensee's staff is positive, and reflects a safety-conscious approach.
In summary, manage:nent involvement and control in assuring quality continues to provide the proper level of oversight.
Good progress was made in this assessment period for resolving the longstanding regulatory :oncern involving QC inspection activities at the plant reflected proper level of managemenc involvement in an area affecting quality.
Quality program enhancements are numerous, are effectively integrated into operational and support activities, and generally receive acceptance because they are found to be genuine improvements that increase quality program effectiveness.
2.
Conclusion Rating:
Category 1 Trend:
None 3.
Board Recommendation Licensee: None
@C:
None
_ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
K.
Training and Qualification Effectiveness 1.
Analysis The previous SALP recognized that the review of the licensed operator training program detected significant weaknesses that had negatively impacted on the ability of the licensee to successfully prepare candidates for NRC examinations. Continued and additional management attentien was warranted to provide corrective measures to: 1) improve training ef fectiveness upon identification of candidate weaknesses and 2) provide aggressive training department oversight of training programs.
Training material was identified as a training weakness with no signifi-cant improvement noted during the assessment period.
Non-licensed training was assessed to be effective. A category 2 rating was assigned.
Although attributes of this topic are discussed in other SALP functional areas, the topic is segregated here because of its importance and to provide a synopsis of the training and qualif-ication programs. Training effectiveness was assessed primarily by observations of performance of licensee personnel.
This assessment includes a review of the licensed operator requalifi-cation program, the examination of four reactor operator (RO)
candidates and two senior reactor operator (SRO) candidates.
At the beginning of the assessment period, the effectiveness of the training department in implementing the requirements of the licensed operator tralMng program was marginal.
The licensee had maintained a relatively small training staff and relied on contractor support to perform a large portion of initial opera-tor instruction, simulator training and most of the candidate evaluations conducted prior to NRC examinations.
In this assessment period, there was strong evidence of increased emphasis and resources by licensee management on licensed and non-licensed training.
Training department management was changed, the training staff was increased from fourteen to twenty-two licensee staff and training facilities were added and upgraded.
Use of contractors was limited to simulator training.
During this period, one licensing examination was conducted for two SR0 and four R0 candidates. The four R0 candidates success-fully completed an INP0 accredited program and passed the NRC examinations. The SRO candidates completed an INPO accredited training program consisting of classroom, self-study and on-the-job training and failed the examination. The failures are con-sidered a result of a marginal iaitial licensing program which is in transition.
Subsequent to the two SRO failures, the NRC again identified that the licensee had not yet taken action to correct identified deficiencies, in that the licensee was still not teaching integrated plant response / failure analysis.
.
,
In cooperation with the State University of New York, the licen-see is in the process of developing an educational program which will lead to a Bachelor's degree and provide course credits for licensed operator training. A noteworthy initiative was hands-on training of start-ups and shutdowns by R0 candidates at the University of Loweli.
fraining of R0 candidates in the control room is performed in an aggressive and cooperative manner by the licensed staff.
By the end of the assessment period, the licensee had made significant improvements in the licensed operator requalifica-tion program. The operator retraining schedule was changed from i six-week, once-a-year training session, to a segmented pro-gram. The training department had redone the job task analysis, lesson plans, enabling objectives, system descriptions and examination bank questions. Formal procedures were put in place to conduct candidate walk-throughs.
Instructor teaching skills have been upgraded.
There is effec-tive use of written examinations as diagnostic, evaluative and learning tools. A third party examination used as a diagnostic tool to identify areas which required retraining was adminis-tered at the beginning of the first requalification training segment. Written examinations at the end of a training week are used to ensure that information is being retained ty the operators.
The rewritten training material is a significant improvement over previous material.
Integrated plant operations have bien specifically added to each lesson plan and a single individual has been assigned responsibility for maintaining the accuracy and currency of the system descriptions.
f :reased management oversight in the area of licensed operator training was evident.
The technical advisory committee is used to continuously evaluate licensed operators and candidates.
Senior licensee management observed the simulator training at the Zion simulator to evaluate the effectiveness of the train-ing, identify weaknesses and develop positive items for improve-ment.
Plant management regularly addresses the requalification classes to allow feedback from the operators and re-emphasize management philosophy and expectations.
The requalification program was evaluated as marginal ear'y in the assessment period.
Periodic evaluations of the changes being made to the requalification program indicated a signi fi-cent improvement in the quality of the training and an increased involvement by management.
l i
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., -
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'
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The effectiveness of the requalification training program-will'
be judged by an integrated objective NRC evaluation.
However, due_ to the temporary suspension of ' the NRC requalification pro-gram,. a date for the evaluation has not been established.
In
-
the interim, a limited inference of training effectiveness could be.made for licensed operators who have been ' performing st an.
~
excellent lev ~el.
During this assessment period, ' non-licensed training. proved - to be effective as evidenced by few personnel errors. The licensee is still pursuing training program accreditation with INP0- for mechanical, electrical, instrumentation: and control, chemistry, radiation protection and -technical. staff.
The INP0 accredita-tion board has been scheduled for June,1988.
Strengths noted throughout this assessment period included licensed operator performance and performance. of _ personnel dur-ing surveillances; these were indicative of the effectiveness of the training program.
The effectiveness of the training of-plant personnel was also evident due to the low number of LER's
. attributed to personnel error and the strong performance during the refueling outage. Plant personnel were observed to be know-ledgeable of the facility, systems, equipment under test and plant procedures.
Radiation protection training and qualifica-tion was-found-to be adequate, but improvements are needed in some areas as noted in Section B, Radiological Controls. Al-
-
though most training programs were effective, a weakness iden-tified in the maintenance area is discussed below and-in Section C, Maintenance.
Training department personnel regularly attend daily maintenance meetings to maintain current knowledge of plant status. A new formal training program under the training department for main-tenance, and I&C personnel has been developed. Training person-
,
nel staff has been increased for non-licenstd training.
Lesson plans have been written and are implemented for the_ new person-nel indoctrination to plant systems training.
Weaknesses in training have been identified in maintenance department imple-l mentation of the maintenance system for safety-related l
equipment.
In summary, significant improvements have been made, as evi-
,
denced by the low number of personnel errors, in the licensed
!
training programs over the last eleven months of the assessment period. Only one plant trip was attributed to personnel error.
Prior to that time, little or no improvement was seen in the training program or materials. A number of licensee initiatives during this assessment period indicate strong management in-volvement in all aspects of training.
Licensed operators were observed to have a good level of knowledge and reflect positive
,
-
. _ _
e
'
attitudes pertaining to the training effectiveness and quality of their training programs.
Non-licensed training was also effective, no plant trips occurred due to surveillance testing and no plant trips were attributable to training deficiencies.
On-the-job training is a noted licensee sti 'ngth and is very effective. While several deficiencies were notud in maintenance and radiation protection training, overall training effective-ness is good, reflecting program improvements and a high level of personnel performances.
The licensee is committed to de-velopment and effective implementation of high quality training programs to support plant operations.
2.
Conclusion Rating:
Category 2 Trend:
Improving 3.
Board Recommendation Licensee: None NRC:
None l
l
.
e
'
V.
SUPPORTING DATA AND SUMMARIES A.
Allegation Review s
There was one unsubstantiated 6, legation this SALP period.
B.
Escalated Enforcement Action One Civil Penalty was issued, $25,000, Inspection Report No. 50-29/
87-08, in the Physical Security Area.
C.
Management Conferences
--
On June 23, 1987, an enforcement conference was held at the NRC Region I Office to discuss station security violations.
--
On June 23, 1987, a management meeting was held at the NRC Region I c'fice to discuss operator licensing and requalifica-tion training program inadequacies and licensee corrective actions.
On March 18, 1988, a managemer,'. meeting was held at the NRC
--
Region ! Office to discuss licensee actions to improve the security program including plans for a security reorganization.
D.
Operating Reactors Licensing Actions 1.
Exemptions Granted An exemption to Appendix R was issued October 8, 1986 2.
License Amendments Issued Amendment 100 issued December 1, 1986.
Minimum number of oper-able incore thimbles.
Amendment 101 is,ued January 6,1987.
Increase time period that valve CS-MOV-532 is open.
Amendment 102 issued January 7, 1987.
Power removal from RCS vent system valves.
Amendment 103 issued February 17, 1987. Maximum enrichment of reload fue o
.
-
Amendment 104 issued May 7, 1987.
Reporting requirements and iodine spiking.
Amendment 105 issued May 13, 1987.
Surveillance testing of neutron flux channels.
Amendment 106 issued June 26, 1987. Operable neutron detector thimbles for Cycle 19 operation.
.
e
.
.
TABLE 1 YANKEE NUCLEAR POWER STATION INSPECTION HOUR SUMMARY
_
AREA HOURS PERCENT OF TIME PLANT OPERATION 790
RADIOLOGICAL CONTROLS 286
MAINTENANCE 473
SURVEILLANCE 322
EMERGENCY PREPARECNESS 659
SECURITY SAFEGUARDS 196
I REFUELING AND OUTAGE MANAGEMENT 232
ENGINEELING SUPPORT 390
LICENSING ACTIVITIES
ASSURANCE OF QUALITY
TRAINING AND QUALIFICATION EFFECTIVENESS
TOTALS:
3248 100 Inspection Reports Considered in this Review:
50-29/86-18 to 50-29/88-06.
Hours expended in facility license activities are not included
with direct inspection effort statistics
- The inspector hours for this composite assessment is incorporated in the functional areas.
T-1
.
.
.
_ _ _ _ _.
_ _ _
- _ _ _ _ _ _ _ _ _ - -
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ - _ _ - _ _ _
~ l tL
.;
.
TABLE 2
,
t YANKEE NUCLEAR POWER STATION ENFORCEMENT SUMMARY A.~
Violations versus Functional Area by Severity Level No of Violations in Each Severity Level AREA
2
4
DEV TOTAL
___
.
PLANT OPERATIONS
1 RADIOLOGICAL CONTROLS
-2 MAINTENANCE
1
.
SURVEILLANCE
1 SECURITY AND SAFEGUARDS 1*
REFUELING AND OUTAGE MANAGEMENT
ENGINEERING SUPPORT LICENSING ACTIVITIES ASSURANCE OF QUALITY TRAINING & QUALIFICATION EFFECTIVENESS TOTALS
5
1
.
- 3 VIOLATIONS TOTAL: AGGREGATE LEVEL 3
- POTENTIAL ENFORCEMENT / UNRESOLVED ITEM INVOLVING QUALIFICATION OF OUTSIDE CONTAINMENT LIMITORQUE OPERATOR INTERNAL CONTROL WI9ING IS PENDING
.
T-2
1
,., -, - -.. _. _,,
%
,
e..
$
[
TABLE 3 YANKEE NUCLEAR POWER STATION A.
LISTING OF LICENSEE EVENT REPORTS BY FUNCTIONAL AREA CAUSE CODES AREA A
B C
D E
X TOTAL PLANT OPERATIONS
1
5 RADIOLOGICAL CONTROLS
1 MAINTENANCE
2
6 SURVEILLANCE
1
4 EMERGENCY PREPARE 0 NESS SECURITY AND SAFEGUARDS REFUELING AND OUTAGE MANAGEMENT
1 ENGINEERING SUPPORT
1
LICENSING ACTIVITY ASSURANCE OF QUALITY TRAINING AND QUALIFICATION EFFECTIVENESS TOTALS:
3 D
5 D
CAUSE CODES:
A - PERSONNEL ERROR 8 - DESIGN, MANUFACTURING, CONSTRUCTION OR INSTALLATION C - EXTERNAL CAUSE D - DEFECTIVE PROCEDURES E - COMPONENT FAILURE X - OTHER B.
LICENSEE EVENT REPORTS REVIEWED Report Numbers86-014, 87-001 thru 87-015, and 88-001 thru 88-004.
NOTE:
The causes identified in this table are the opinion of the SALP Board based on its analysis of the event; and may, in certain instances, differ from the LER.
T-3