Text

Errata to SALP Rept 50-213/85-98 for Mar 1985 - Feb 1986, Revising Section on Emergency Preparedness
	ML20206M916
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Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	08/14/1986
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
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ML20206M911	List: IR 05000213/1985098; ML20206M905;
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	50-213-85-98, NUDOCS 8608260024
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U.S. NUCLEAR REGULATORY COM11SSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-213/85-98 CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK NUCLEAR POWER PLANT ASSESSMENT PERIOD:

MARCH 1, 1985 - FEBRUARY 28, 1986 BOARD MEETING DATE:

APRIL 24, 1986

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SUMMARY OF RESULTS Facility Performance CATEGORY LAST CATEGORY THIS PERIOD (9/1/83-PERIOD (3/1/85-RECENT

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F CTIO LA A 2/28/85)

2/28/86)

TREND l

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Plan ations

1 Consistent 2.

Radiolo a

ontrols

2 Consistent 3.

Maintenanc Mod tions#

2 Consistent

4.

Surveillance

2 Consistent 5.

Emergency Prepare

2 Consistent 6.

Security & Safeguar

1 Consistent 7.

Refueling /0utage Manage

2 No Basis 8.

Assurance of Quality

2 Consistent 9.

Training and Qualification

Consistent Effectiveness 10.

Licensing Activities

Declining

Modifications were previously ad esse der Assurance of Quality.

Not previously addressed as a sep ar

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B.

Overall Facility Evaluation l

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In general, the licensee aggressively and tho o resolves matters

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with immediate operational or safety signific.

The Security area

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was particularly noteworthy in that, despite a 1 istory of excellent performance, there was a continuing aggressive ef t to improve perform-ance.

In other areas, however, there have been rec rent problems with procedure adherence, personnel errors, attention to tail, and admini-stration of routine activities.

Examples include nume us modification control errors, significant ALARA flaws, and untimely s mittals of

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modification packages to the Plant Operations Review Comm tee.

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result has been satisfactory out generally lower SALP rati s.

To im-prove overall performance, more effective management control at all levels are needed to assure that repetitive problems are ident'fied and corrected and that there is proper preplanning of work activiti The

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management attention to these activities that is evidenced in the ecur-l ity area is typical of that needed in other areas to avoid a furth

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decline in performanc t'

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6a III. SUMMARY OF RESULTS A.

Facility Performance CATEGORY LAST CATEGORY THIS PERIOD (9/1/83-PERIOD (3/1/85-RECENT FUNCTIONAL AREA 2/28/85)

2/28/86)

TREND 1.

Plant Operations

1 Consistent 2.

Radiological Controls

2 Consistent 3.

Maintenance & Modifications #

2 Consistent 4.

Surveillance

2 Consistent 5.

Emergency Preparedness

2 Improving 6.

Security & Safeguards

1 Consistent 7.

Refueling / Outage Management

2 No Basis 8.

Assurance of Quality

2 Consistent 9.

Training and Qualification

Consistent Effectiveness 10.

Licensing Activities

2 Declining

Modifications were previously addressed under Assurance of Quality.

Not previously addressed as a separate area.

B.

Overall Facility Evaluation In general, the licensee aggressively and thoroughly resolves matters with immediate operational or safety significance.

The Security area was particularly noteworthy in that, despite a long history of excellent performance, there was a continuing aggressive effort to improve perform-ance.

In other areas, however, there have been recurrent problems with procedure adherence, personnel errors, attention to detail, and admini-stration of routine activities.

Examples include numerous modification control errors, significant ALARA flaws, and untimely submittals of modification packages to the Plant Operations Review Committee.

The result has been satisfactory but generally lower SALP ratings.

To im-prove overall performance, more effective management controls at all levels are needed to assure that repetitive problems are identified and corrected and that there is proper preplanning of work activities.

The management attention to these activities that is evidenced in the Secur-ity area is typical of that needed in other areas to avoid a further decline in performance.

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IV.

PERFORMANCE ANALYSIS A.

Plant Operations (425 hours0.00492 days 0.118 hours 7.027116e-4 weeks 1.617125e-4 months , 24%)

1.

Analysis This functional area encompasses operational activities, plant housekeeping and fire protection, operator and staff performance, review committee activities, event reporting, and corrective actions.

The previous SALP rated plant operations as Category 1.

In the last SALP, strengths were noted in the quality of operator performance, plant coordination of day-to-day evolutions, review committee ef-fectiveness, and problem identification programs.

Weaknesses were noted in the operator requalification program, procedure adequacy and compliance, and the scope and timeliness of corrective actions for certain self-identified problems.

During the current SALP period, there were two region-based inspec-tions of this area.

Plant operations were observed by the resident inspectors throughout the period.

Operators carefully observed plant systems and conditions, and promptly identified developing problems to management.

Through use of the computer enhanced maintenance reporting and tagging system, operators efficiently tracked maintenance actions and implemented system tagging.

Corrective actions were generally well planned and ready for prompt implementation.

This team effort contributed to there being no error related plant shutdowns during the period.

The overall result was continuing effectiveness of the onsite team of management, operators and support staff.

Control room operators were evaluated as having a professional ap-proach to plant operations.

Although the age and small size of the control room were noted as potential negative influences, plant operators were observed to limit access to control panel areas, maintain adequate control over extraneous noise, and perform their duties effectively using readily available procedures, drawings, and administrative aides.

Also, the licensee instituted a dress code for plant operators.

Noteworthy housekeeping improvements were observed in the auxiliary feedwater room and in the recovery of several contaminated areas of the auxiliary building.

However, limited permanent and temporary storage space onsite forces the licensee staff to accept occasional clutter, and wet or soiled conditions.

Such was the case for the auxiliary water treatment facility in the turbine hall and contami-nated material storage in the spent fuel building lower level.

Upon licensee identification of these degrading conditions, corrective action was implemented.

A general upgrade of site facilities is in progress.

Improved facilities fcr outage personnel have been

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provided.

Construction of new facilities is underway, primarily for radioactive material processing and storage.

Such efforts, along with a continued licensee initiative to recover and upgrade remote areas such as the waste treatment building, RHR pit, and pipe enclosures should result in further improvement of plant housekeeping.

The timeliness and thoroughness of corrective actions for some problems identified in Plant Information Reports (PIRs) were iden-tified in the previous SALP period as weaknesses.

The licensee changed the PIR program to improve causal analysis and corrective actions.

Staffing increases were approved, in part to help reduce the PIR backlog.

Improvements were observed in the quality of PIR reviews, and the PIR backlog was reduced.

Many PIRs are, however, returned for further corrective action and some (particularly those related to fire barriers) involve recurrent problems.

Other recur-rent problems include late procedure reviews and self-identified radiological procedure violations.

Licensee efforts to decrease personnel errors and procedure-related problems have been partially effective.

The frequency of error-related operational events de-clined, but the frequency of fire protection door control problems rose (see LER trends cited in Section V).

Such recurrent problems indicate lack of effective management involvement and follow through.

An evaluation of LER quality, using a sample of 10 LERs issued dur-ing this assessment period, was made.

In general, the licensee's LERs were found to be satisfactory.

The principal concerns iden-tified were inconsistencies in subsection content between the selected LERs, incomplete corrective action plans in son;e LERs, and not addressing the possible consequences of events under different initial conditions.

For instance, LER 85-29 reported a potential failure dealing with loss of the semi-vital motor control center (MCC-5).

The LER safety assessment concentrated on the plant indi-cations and operator actions to mitigate the event but did not ad-dress the more severe potential consequences.

Overall, however, the quality of LERs has improved.

Licensee onsite and offsite review committees have been effective during this period.

The Plant Operations Review Committee has a large workload including response to operational events, plant pro-cedures, modifications, license changes and corrective actions for Plant Information Reports.

The PORC accomplishes detailed and ef-fective reviews.

PORC members are frank and inquisitive, and man-agement is supportive of the open and detailed review conducted by this committee.

Although the quality of PORC meeting minutes has improved, they do not always reflect the details of PORC discussions and often leave questions unanswered in the reader's mind.

A large number of multiple PORC reviews on individual topics and the length of PORC deliberations on certain reactive review efforts suggest weaknesses in the staff work performed prior to PORC submittal.

This unnecessarily involves PORC in details and can adversely affect

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the PORC's focus on the overall safety impact of the issue under consideration.

(A weakness related to the drain on plant supervi-sory activities created by lengthy PORC deliberations is described in the Refueling and Outage Management Section of this report.)

One PORC-related violation was identified: PORC concurred in the removal of Technical Specification required smoke detectors incident to a design change.

This error was recognized by the licensee prior i

to implementation of the change.

The offsite review committee (NRB) contributes effectively to safe plant operation.

Of particular note were the high quality and timely NRB reviews of plant modifications and the assessment tech-niques used by NRB to evaluate staff performance annually.

In ad-dition to routine audits, the NRB collects, trends and assesses performance indicators such as audit and inspection report findings, event reports, and nonconformance reports to measure staff perform-ance. A weakness identified by NRC concerned NRB involvement in assuring the quality of audits conducted by the quality assurance department.

NRB evaluation of audit scope, content, and findings was noted as an area for improvement.

No new operator license examinations were given during this period; no NRC assessment of that aspect was made.

During this period, the licensee made progress on the upgrade program for licensed operator requalification.

The upgrade and independent evaluation of certain licensed operators continued throughout the period.

In January 1986, the licensee began a revised requalification program which integrates training into the operator shift rotation schedule.

NRC review of the preparations for implementation of this program identified no problems.

The program has improved the timeliness of operator feedback on procedural and hardware changes, and significantly in-creases the training time to allow more discussion of the subjects covered.

Three violations were identified in the Plant Operations area.

None of these was a major violation.

However, one of the three was for failure to adhere to procedures, which is a continuing problem noted in the previcus SALP.

In summary, although the licensee has improved each area of weakness cited in the previous analysis, management attention is needed to further improve procedural compliance, LER quality, PORC efficiency, and corrective action effectiveness.

Overall, the rating in plant operations is weighted toward the operating staff's quality perform-ance in several operationally significant aspects of the analysis.

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Conclusion

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Rating:

Category 1.

Trend:

Consistent.

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3.

Board Recommendation:

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Licensee: None.

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None, t

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B.

Radiological Controls (393 hours0.00455 days 0.109 hours 6.498016e-4 weeks 1.495365e-4 months , 22%)

1.

Analysis

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The previous SALP rated this area as Category 2.. Radiation control

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policy, procedures, and staffing were found to be program strengths,

while weaknesses were noted in management control and effectiveness in monitoring program compliance, in ALARA controls at the job supervisor level, and in quality assurance (QA) for the radioactive material transportation program.

During the previous assessment

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period, several violations were cited relating to a potential per-sonnel overexposure during maintenance, and to QA problems in the radwaste area.

A recent appraisal of the Health Physics program at the site found

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that the overall program is a good one.

Weaknesses continued in the ALARA program and in radwaste QA.

Program procedures are com-

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prehensive and generally well written.

The Health Physics supervi-

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sory staff is adequately experienced and dedicated, and shows in-

itiative in proposing and instituting measures to improve perform-

ance.

However, the recurrence of many minor, self-identified radio-

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logical control procedure violations is indicative of ineffective l!

corrective actions in this area.

These incidents do not appear to indicate any fundamental programmatic weakness, yet more extensive

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training and accountability of workers and technicians is warranted.

The licensee has shown improvement in some aspects of radiological controls.

This improvement was noted in the methods used in con-

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tamination control and radiological surveillance during the 1986 outage.

These methods included innovative and effective techniques such as subdivision of the radiation controls areas into autonomous

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zones, and the use of closed-circuit television to monitor critical areas.

These methods were also effective in controlling the flow of work and in keeping work areas generally clean and orderly.

Other improvements include selection and qualification of HP person-t i

nel and attention to the experience and capabilities of the person-l nel placed in charge of the work zones.

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f The Radiological Incident Reporting system instituted by the licen-i see is working.

Although management response to incidents identi-

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fied by the system was initially inadequate, recently instituted i

procedural changes appear to have led to improvement in this area.

These improvements include increased management attention to iden-

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tify root causes and measures designed to minimize the chance of l

recurrence of similar incidents.

One example of lack of such re-sponse is an incident involving compacting of a highly radioactive

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l drum in a manner that violated plant procedures and resulted in internal and external exposure of workers, and extensive contamina-

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tion of the work area.

This event displays a weakness in job pre-

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planning and adherence to good health physics practices.

Management I

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response in that case was insufficient.

Another incident identified by the licensee is more recent and involved the installation of hoses to a high integrity resin container for de-watering.

In that incident, the couplings on the container and hook-up hoses did not match.

Careful planning could have prevented this problem.

Fur-thermore, the worker decided to remain in the high radiation area while investigating the problem, rather than exiting to seek assist-ance or to decide on the appropriate course of action.

As a result, the worker exceeded his assigned exposure by a factor of about two.

Management response to this incident was more prompt and more com-prehensive than in the case of the first example described.

Inci-dents such as those cited above are limited but recurrent instances of poor judgement, mainly on the part of the Health Physics techni-cians and the workers involved.

Weakness in the ALARA program was noted in previous SALPs and con-tinues to be a problem.

Emphasis at the supervisory and technician levels appears to focus mainly on keeping exposures within estab-lished limits rather than minimizing them. The same emphasis ap-pears to exist at management levels up through senior site and cor-porate management.

Indications of this tendency are provided by incidents such as those described above.

A common factor in most of these incidents appears to be the desire to "get the job done" without sufficient regard for the radiological consequences.

An-other indication of insufficient ALARA emphasis is the man-rem ex-posure record of the station.

This record shows that the man-rem exposures have been consistently much higher than those of the in-dustry since at least 1979.

These exposures have also been consis-tently higher than the licensee's own projections, particularly for outage-related work.

Part of the reason for this relatively poor exposure performance is ascribed to conditions peculiar to the sta-tion. The reactor system design is old and does not provide as much component shielding as is found in more modern stations, thus lead-ing to relatively high radiation fields in the work areas.

However, a recent NRC appraisal of the ALARA program indicated that this provides only a partial explanation for the poor ALARA performance.

The appraisal revealed serious weaknesses in the ALARA program at all levels of management.

There are extensive and well written ALARA procedures and policy statements, both at the station level and the corporate level.

However, the ALARA program is essentially a paper program, with poor implementation and oversight, particularly by corporate management.

Pre-job planning is frequently incomplete and flawed, leading to unforeseen radiation exposures in attempts to take remedial actions.

Pre-job planning is also frequently ill-timed, leading to inadequate lead time for review of these estimates by station personnel.

Short lead times also allow insufficient time to consider all the ALARA measures that may be taken to reduce ex-posures.

Furthermore, most high exposure outage jobs are performed by non-station personnel, such as contractors, and control of the number of people these contractors use and the man-hours expended

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-in radiological areas appears to be poor.

There is extensive effort expended in documenting job performance, analyzing the reasons for exceeding goals, and proposing measures to improve performance.

However, such efforts appear to receive inadequate management sup-port.

Furthermore, most of the analyses do not clearly isolate and identify.the root causes of the problem.

Finally, the most dis-turbing aspect of this problem is that management action'to take effective corrective measures was not apparent.

With regard to Effluent Control and Environmental monitoring, in-spections indicated that, while procedures are generally adequate and are followed, several minor examples of deficient procedures and instances of non-adherence to procedures were identified.

Specifically, an Environmental. Review Board failed to audit required reports, calibration procedures for meteorological sensors were not followed, and quality control samples were not sent to the vendor laboratory. Additionally, some records were found to be incomplete, and documentation was sometimes insufficient to determine that dis-crepant data had been reviewed. All of these findings had minor consequences but indicate weaknesses in the staff's implementation of QA program requirements.

In areas directly affecting effluent releases, such as radioactive releases, procedures and documentation were complete and adequate for controlling and monitoring effluents, and the QA program was sufficient to assure that all requirements and specifications were met.

The implementation of the Radioactive Waste Handling Program (RWHP)

is generally adequate with regard to staffing and training of the station staff responsible for the mechanics of the program.

In these areas, positions are well defined and identified relative to responsibilities and authorities; and the training and qualification program makes a positive contribution to performance of work with few personnel errors.

Some procedures were found to have weaknesses, but these were promptly addressed by the licensee.

The RWHP is also vulnerable relative to the assurance of quality.

In this area, quality assurance audits were found to lack sufficient thoroughness; quality assurance personnel were not sufficiently knowledgeable of shipping and radioactive waste disposal require--

ments; and the specifications of 10 CFR 61 were not fully imple-mented by the quality assurance program.

As a result, errors on the part of the radwaste handling department were not likely to be caught. by QA review of shipment activities.

For example,-Iron-55 has been identified in the facility waste streams, but it was fre-quently omitted from consideration in waste manifests and shipping

papers.

The repetitive omissions resulted in significant under-l estimation of activities in radwaste shipments, and were also in-

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dicative of a breakdown in the responsibilities for assurance of

quality in radwaste shipments.

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In summary, the licensee has improved some health physics practices, including better control and assignment of HP technicians, zone coverage within the radiologically controlled areas, and followup on self-identified radiation protection discrepancies.

However, continuing problems in the radwaste transportation and ALARA pro-grams were noted as significant weaknesses in this area.

Continued increases in workload, contractor personnel onsite and personnel exposures during outages have emphasized the continuing poor ALARA practices.

Although improvements in some aspects of this functional area were noted, the overall assessment was that radiological con-trols performance had declined since the previous SALP.

2.

Conclusion:

Rating:

Category 2.

Trend:

Consistent.

3.

_ Board Recommendation:

Licensee: Conduct a comprehensive management review of the ALARA program and implement the changes necessary to achieve an effective program.

NRC:

Continue normal inspection efforts with special emphasis on the implementation of the ALARA progra Y

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C.

Maintenance and Modifications (314 hours0.00363 days 0.0872 hours 5.191799e-4 weeks 1.19477e-4 months , 18%)

1.

Analysis The previous SALP rated maintenance as Category 1.

In a separate analysis area, modification activities were rated as Category 2.

Documentation and trending of main _tenance activities and the backlog of plant maintenance work were previously noted as areas needing improvement, and significant programmatic deficiencies in the design change control area had resulted in escalated enforcement action.

During the current assessment period, one region-based inspection reviewed the progress of NRC ordered design change control improve-ments.

Two special inspections reviewed modification related prob-lems in the auxiliary feedwater and fire detection systems, and the resident inspectors reviewed maintenance activities throughout the period.

The licensee has a strong preventive and corrective maintenance program.

Automated tracking and scheduling of maintenance assists in controlling the large number of preventive maintenance (PM) tasks performed.

Comprehensive and frequent program review and update reflects management commitment to the PM program and has resulted in a high degree of equipment reliability.

One notable exception during this period was the performance of the main feedwater system.

Several plant trips and shutdowns were directly related to main feedwater system problems and the inability to isolate portions of the system due to isolation valve leakage.

Had the feedwater system isolation valves been repaired during the first system outage on August 18, 1985, subsequent plant shutdowns for feedwater system repairs would have been avoided.

The licensee recognized the im-portance of feedwater system reliability as evidenced by the major overhaul during the 1986 refueling outage.

The instrumentation and control (I&C) and maintenance departments are manned by competent and motivated personnel.

Although a backlog of maintenance activities remains, it is managed effectively by prioritization and overtime, and the licensee has implemented or approved new positions to improve the effectiveness of this organi-zation.

The licensee is upgrading staff technical training, including general system and technical speciality training.

Improved I&C technician training in the Technical Specification operability as-pects of maintenance and testing activities was implemented as a result of an event in which a variable low pressure scram channel of the reactor protection system was rendered inoperable during maintenance.

Based on generally high quality performance on other maintenance activities, this maintenance error was judged to be an isolated cas.f-

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During refueling outages, the plant staff is augmented by contractor and utility workers in order to accomplish the large number of maintenance activities. The licensee addresses the increased staff size by upgrading certain technicians to supervisory positions.

Repair activities during the 1986 outage were observed to be pro-perly conducted with the exception that a high pressure safety injec-tion pump failed during post maintenance testing.

The pump was not reassembled properly because of personnel error and inadequate pro-cedural update after pump modifications.

Significant pump rework was required as a result.

Also, several contractor performed valve

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repairs were repeated several times in order to achieve satisfactory results.

These events appeared to be isolated cases in an otherwise effective program.

Documentation of maintenance activities continued to be a weakness during this p iod.

Poor documentation of repairs prevented accurate determination of the cause of failure and contributed to the late or incomplete submittal of several Licensee Event Reports (LERs 85-02, 05, 10).

Also, a violation involving several instances of procedural noncompliance indicated inattention to detail in repair activity control and recording. No equipment operability problems were identified in these instances.

Three violations were identified in this area.

None of these was major. While multiple instances of modification control problems were noted in one violation, these instances were not related.

As a result of previously identified weaknesses and NRC enforcement action, the licensee implemented major changes to the modification control program.

NRC review of modifications made during this SALP period have identified significant improvement in the documentation and control of design changes.

Nevertheless, continuing modifica-tion control errors unnecessarily challenge the defense in depth concept incorporated in the modification process.

NRC identified discrepancies with testing, procedure updates, material issue, technical specification changes, and documentation of field changes for recent modifications point out the need for further improvement in the implementation of plant modifications.

In one example, ap-proved retests specified after emergency diesel generator air system modifications would not have verified all aspects of system opera-tion.

In summary, maintenance programs are effective overall and improve-ment has been noted in the modification control program.

However, maintenance errors involving procedural compliance were identified.

The backlog in and inadequate documentation of maintenance activi-ties continued to be weaknesses.

Also, problems with the implemen-tation of modifications were noted.

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2.

Conclusion Rating:

Category 2.

Trend:

Consistent.

3.

Recommendations:

Licensee: Provide effective management attention to the new modifi-cation control process to assure that it is understood and properly implemented at all levels.

NRC:

None.

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D.

Surveillance (230 hours0.00266 days 0.0639 hours 3.80291e-4 weeks 8.7515e-5 months , 13%)

1.

Analysis Surveillance was rated Category 2 during the last SALP.

Inadequate procedures and technician performance resulted in three events, one of which received a mitigated escalated enforcement action.

In ad-dition, weaknesses in the scheduling of serveillances and resolution of containment leakrate testing (CLRT) deficiencies were noted.

Surveillance was observed by resident inspectors throughout this SALP period.

The licensee continued the long term surveillance up-grade program initiated during the previous period.

Procedural up-grades and technician training were successful as evidenced by no surveillance error-related events or violations being identified.

Several nuclear instrument problems were identified early in this period.

Accelerated testing, troubleshooting and repairs were suc-cessful in eliminating them.

Inspector discussions with licensee technicians found them to be competent, knowledgeable of procedures, and conscientious in the implementation and evaluation of surveillance results.

The licensee's long term review of surveillance procedure adequacy is ongoing and scheduled for completion in mid-1986.

Inadequacies are still being identified as exemplified by the licensee's failure to properly test 27 of 80 containment electrical penetrations be-cause the test procedure listed an incorrect valve lineup.

In ad-dition, several reported missed surveillances (see LER chain in Section V of this report) occurred because procedures did not com-prehensively cover all Technical Specification requirements.

Fur-ther, there was minimal involvement of Quality Assurance in the technical adequacy of surveillance procedures.

In addition, as

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noted in Section V, 3 LERs addressed missed fire protection sur-

veillance tests due to personnel error.

One other problem involved the licensee's failure to implement all aspects of a post-accident systems integrity inspection commitment (LER 85-30).

Upon NRC s

identification of this problem, the licensee fully implemented the

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commitment.

During this period, an auxiliary feedwater initiation test failure pointed out the need for more frequent exercise / testing of sticking solenoid actuation valves as an action to prevent recurrence.

Be-cause of licensee concerns about the acceptability of on-line test-ing of this system, it took over ten months to develop and implement the appropriate test procedure.

Then, when the test was run, a similar initiation failure occurred. Weekly testing thereafter identified no further component failures.

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NRC inspection of previous CLRT activities identified weaknesses including the quality of Type A test techniques and the responsive-ness to previous NRC inspection findings.

The licensee made efforts to formalize CLRT activities among its units and centralize the CLRT program under a governing corporate level procedure.

NRC observa-tion of CLRT activities shortly after the end of this assessment period identified improved test performance. With regard to open inspection findings, the licensee's approach was not fully respon-sive.

The licensee response to the previous SALP indicated that the open inspection items would be addressed in the last quarter of 1985.

The licensee position submitted on December 23, 1985, restated previous positions which did not resolve the existing dis-crepancies with 10 CFR 50 Appendix J.

The licensee has a basically sound surveillance program which pro-perly performs a large number of tests in a timely manner without challenging safety systems.

There are, however, continuing problems with surveillance procedures, QA of surveillance activities, imple-mentation of commitments, and timeliness of corrective actions.

2.

Conclusion Rating:

Category 2.

Trend:

Consistent.

3.

Board Recommendation Licensee: Complete the ongoing surveillance upgrade program.

NRC None.

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Emergency Preparedness (166 hours0.00192 days 0.0461 hours 2.744709e-4 weeks 6.3163e-5 months , 9%)

1.

Analysis The previous SALP rated this area as Category 2.

There were three sign cant deficiencies which were identified during the full-scale er nc exercise in May 1984.

These deficiencies, involving in-at n w between the Control Room and Technical Support Centers (T

, delayed declaration of Emergency Action Levels and demonstra-tio o echnical support functions at the TSC, were addressed by a Con tory Action letter (CAL 84-10) on June 5,1984.

During t riod, one NRC inspection was conducted to review changes ma e to the Emergency Preparedness Program and to observe the March 3 1985 annual full-scale emergency exercise.

It was found that th

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rec ' e actions described in CAL 84-10 had been satisfactorily omplet During the 1985 exercise, the licensee demonstrated the w SC which had been established within the Emergency Operati @ nter (E0F).

Technical support activities were adequately imp ap6qted except that the development of approved emergency procedures a9 not demonstrated.

There were no major de-ciencieswereidentifie%5 exercise;however,twentyminordefi-ficiencies noted in th several of these problems were recur-rent items from the previ ercise.

The licensee's onsite emerge paredness staff consists of one full time Emergency Planning o inator who is provided with emer-gency preparedness activities s rt by corporate and contractor personnel.

NRC observation of e c

xercise activities con-cluded that personnel were appropr y trained and qualified to perform their emergency functions.

he licensee's performance demonstrated that they could implemen th

~mergency Plan and its implementing procedures adequately.

I

!

The licensee's multiple locations for com and control and tech-

!

nical support functions provide independent s sment of emergency activities and backup technical support.

Ho redundant acti-l vities in these distant centers are often conf by delayed or l

incorrect data, resulting in improper recommenda 'ons or unnecessary requests for clarification.

This vulnerability o

,n w gency acti-vities to good real-time data communication emphasi' es the need for a hard-wired plant data transmission system.

In the 'nterim, the

,

licensee has a dedicated data coordinator who responds to the emer-gency response team paging system and manually inputs p nt data

,

l to the transmission network (NESS) available at the emerg icy oper-ating centers.

Telecopiers are available to back up the N. S system.

Also, the State and utility emergency plans incorporate auto tic protective action recommendations (PARS) with the declaration f each Emergency Action Level (EAL).

This makes event classifica ion and EAL declaration particularly important, and different becaus

.

-

.- -

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.

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.

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E.

Emergency Preparedness (166 hours0.00192 days 0.0461 hours 2.744709e-4 weeks 6.3163e-5 months , 9%)

,

1-

!

' 1.

Analysis

!-

The previous SALP rated this area as Category 2.

There were three significant deficiencies which were identified during the full-scale

emergency exercise in May 1984..These deficiencies,. involving in-formation flow between the Control Room and Technical Support Centers (TSC), delayed declaration of Emergency Action Levels and demonstra-

'

tion of technical support functions at the TSC, were addressed by a Confirmatory Action letter (CAL 84-10) on June 5,1984.

l.

During this period, one NRC inspection was conducted to. review l

changes made to the Emergency Preparedness Program and to observe

the March 30, 1985 annual full-scale emergency exercise.

It was j

found that the corrective actions described in CAL 84-10 had been

'

satisfactorily completed.

During the 1985 exercise, the licensee-demonstrated the new TSC which had been established within the

-

Emergency Operations Center (EOF). Technical support activities were adequately implemented except that the development of approved j

emergency procedures was not demonstrated.

There were no major de-ficiencies noted in the 1985 exercise; however, twenty minor defi-ciencies were identified, and three of these problems were identi-

.

fied in the previous exercise.

i The licensee's onsite emergency preparedness staff originally con-l sisted of one full time Emergency Planning Coordinator who was pro-l vided with emergency preparedness activities support by corporate

and contractor personnel.

During the assessment period, a second I

full time Emergency Planner was assigned to the site. A third full

time Emergency Planning individual is assigned to Haddam Neck at

the corporate office.

NRC observation of emergency exercise acti-

'

vities concluded that personnel were appropriately trained and qualified.to perform their emergency functions.

The licensee's

>

performance demonstrated that they could implement their Emergency Plan and its implementing procedures adequately.

t

The licensee's multiple locations for command and control and

!

technical support functions provide independent assessment of j

emergency activities and backup technical support.

Although those facilities are mutually supportive and have backup cap-i l

abilities with checks and balances, redundant activities in l

these distant centers are often confused by delayed or incorrect t'

data, resulting in improper recommendations or unnecessary re-quests for clarification.

This vulnerability of emergency acti-

,

vities emphasizes the need for a hard-wired plant data transmission system.

In the interim, the licensee has a dedicated data coor-

dinator who responds to the emergency response team paging system and manually inputs plant data to the transmission network (NESS)

available at the emergency operating centers.

Telecopiers are

!

.

. - -

_ _ _

D.

.

t e classification may carry with it inappropriate sheltering or ev cuat'

recommendations.

Resolution of these discrepancies re-qui c

ination at all emergency centers, which could either dela ve t lassification or result in overly conservative PARS.

No actu vents during this assessment period required the imple-mentatio he Emergency Program.

Inspector observation of oper-ational o ences such as plant trips and a February 1986 dropped fuel eleme eve identified appropriate operator response, prompt management s rt, d safe and conservatively planned recovery activities.

r ration for Hurricane Gloria in September 1985, the licensee c s to fully man the emergency facilities, with pro-visions for exte implementation of the emergency organization.

hW6 gh the area without any significant damage The storm passed

to plant systems.

o eficiencies in emergency plan activities were noted by onsite NRC s rvers.

In summary, the licens trected some of the previously noted de-ficiencies and satisfac il plemented the site emergency plan

during the annual exerci o emergency planning weaknesses were identified during operati ccurrences.

2.

Conclusion Rating:

Category 2.

Trend:

Consistent.

3.

Board Recommendation Licensee: Complete the installation of the hard-wired data transmis-sion system, and review the e'

ectiveness of automatic protective action recommendatio s.

NRC:

None.

I

i

. l-

.

21a available to back up the NESS system.

Also, the State and utility emergency plans incorporate an Emergency Action Level (EAL) and state posture code correlation table which results in automatic pro-tective action recommendations (PARS) for fast breaking events.

This makes~ event classification and EAL declaration particularly important, and different because the classification may carry with it inappropriate sheltering or evacuation recommendations.

Resolu-tion of thest discrepancies requires coordination at all emergency centers, which could either delay event classification or result in overly conservative PARS.

No actual events during this assessment period required th+. imple-mentation of the Emergency Program.

Inspector observatfor of oper-ational occurrences such as plant trips and a February 1986 dropped fuel element event identified appropriate operator response, prompt management support, and safe and conservatively planned recovery activities.

In preparation for Hurricane Gloria in' September 1985, the licensee chose to fully man the emergency facilities, with pro-visions for extended implementation of the emergency organization.

The storm passed through the area without any significant damage to plant systems.

No deficiencies in emergency plan activities were noted by onsite NRC observers.

In summary, the licensee corrected some of the previously noted de-ficiencies and satisfactorily implemented the site emergency plan during the annual exercise.

No emergency planning weaknesses were identified during operational occurrences.

2.

Conclusion Rating:

Category 2.

Trend:

Improving.

3.

Board Recommendation

Licensee: Complete the~ installation of the real time data transmis-

>

sion system, and review the effectiveness of automatic

,

protective action recommendations.

!

NRC:

None.

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F.

Security and Safeguards (79 hours9.143519e-4 days 0.0219 hours 1.306217e-4 weeks 3.00595e-5 months , 5%)

1.

Analysis Previous SALP evaluations have identified consistently high perform-ance in this area.

During this rating period, one routine physical security inspection and one routine material control and accounting inspection were performed by region-based inspectors.

Routine resident inspections continued throughout the assessment period.

No violations were identified.

Management is involved in the physical security program and continues to be supportive.

Resource planning continues to consider needs for improving quality by self-inspection techniques and ensuring comprehensive corporate audits.

These efforts, combined with a positive management approach and clear, concise procedural controls, contributed to error-free performance by the security organization.

As a result, during three consecutive rating periods, no violations of NRC requirements have been identified.

The decision making pro-cess for the security program, by management and supervisory per-sonnel, is effective.

Records are well maintained and available.

Security improvements noted during this rating parfod included the purchase of a new vehicle to enhance site perimeter patrols, in-stallation of new protected area fencing, paving a perimeter access road, purchase of additional security force shelters, completion of renovation of the interior of the security building, development of a slide presentation of security program features for use as a training /information aid, and the expansion of the drill program in support of the Safeguards Contingency Plan.

A total of 180 drills were carried out by the security organization during CY 1985.

These improvements demonstrate the licensee's continuing support of the program.

As a new initiative, the licensee is utilizing the NRC's Regulatory Effectiveness Review Program generic findings from other licensed sites to improve the effectiveness of its security program.

Im-provements to barriers, detection aids, and duress procedures have been implemented as a result.

The licensee maintains dedicated technicians for support of security systems and equipment.

The effectiveness of this is evidenced by the fact that only one security event during this period involved a hardware problem (four hardware-related problems were reported during the previous period).

The problem caused the computer to be off-line for only 21 minutes, during which time repairs were effected.

Compensatory measures were effectively implemented and the licensee's event report to the NRC was timely and comprehensive.

i l

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_ _ _ _ _ _

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P j

!

Staffing of both proprietary and contract security positions was effective.

Sufficient, well-trained and qualified supervisors and security officers were assigned during the period. Morale and pro-fessional competence were observed to be high.

Also noteworthy was the ability of security force members at all levels of the organi-zation to describe their duties and responsibilities, in detail and without hesitation.

This was done with enthusiasm and pride.

The licensee's commitment to continuously improve professional skills via the use of drills and job knowledge critiques strengthens the perforrtance capability of the organization.

Additionally, the lic-ensee provides funds for management / supervisory attendance at pro-fessional seminars and training courses.

There were two Security Plan changes submitted in accordance with 10 CFR 50.54(p) during this rating period.

The revisions were re-viewed and considered acceptable.

The changes were adequately sum-marized and appropriately marked on revised pages for clarity.

With regard to material control and accounting practices, the lic-ensee was in compliance with NRC requirements.

Procedures and prac-tices were adequate for the control of special nuclear material.

Records and reports were complete, well-maintained and available.

In summary, security and safeguards inspections by resident inspec-tors and region-based specialists have identified exemplary programs.

Security continues to be a noteworthy licensee strength, because

'

of management support for program improvements, aggressive self evaluation, and prompt and effective preventive / corrective actions.

2.

Conclusion Rating:

Category 1.

Trend:

Consistent.

3.

Board Recommendation Licensee: None.

NRC:

None.

l l

I

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.

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F-

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Refueling and Outage Management (151 hours0.00175 days 0.0419 hours 2.496693e-4 weeks 5.74555e-5 months , 9%)

1.

balysis Pre licensee performance in refueling and outage activities een Category 1.

During this period, a planned 8-week refueling began on January 4, 1986.

By the end of the assessment pe

, delays in installacion of a new permanent reactor cavity sea lems with decontamination of steam generator primary chann ds, and recovery of a fuel assembly dropped during re-fueling perations had extended the outage by approximately 25 days.

Refueling out tivities were reviewed by the resident in-spectors and re ion-based project inspector, including outage preparations a rdination, refueling operations, and recovery after the Febru

, 1986 dropped fuel element event.

The licensee mainta 24-hour per day management level coordina-tors to follow outage

'vities and bring problems to management attention.

Also, outa tu meetings were held twice a day with all departments and crit.

obs represented.

The licensee's com-puter-based outage plannin gram was effective in tracking the details of job status.

Str

.

'censee commitment to the mainten-ance and updating of this pro s evident throughout the outage.

Consequently, it was readily re gnized which critical path activi-ties were experiencing problems ch t additional attention could be focused in that area.

Under th os r scrutiny, the allotted time for some jobs was found to be i o

t.

In particular, under-estimation of work package preparatio tablishment of plant con-ditions, and coordination and documenta o f system turnover re-quirements reflected inadequate pre pla f outage activities.

As a result of deadlines and commitments, se al plant modifica-tions were required to be implemented during t is outage.

These modifications included reactor vessel level indi ation, various Appendix R improvements, seismic support upgrades, and equipment environmental qualification replacements.

Although he licensee has guidelines which require early submittal of plant design change packages, only 8 of 32 modifications were ready for im ementation at the start of the outage.

In addition, the need for t nty other modifications was identified during the outage.

Consequen ly, a major effort involving considerable engineering and supervi ry effort was necessary, especially during the first month of th out-age, to assure the appropriateness of pre-approval release of m i-fication work packages and in the review and approval of the modi fications as they became ready.

i

t'

24 a G.

Refueling and Outage Management (151 hours0.00175 days 0.0419 hours 2.496693e-4 weeks 5.74555e-5 months , 9%)

1.

Analysis Previous licensee performance in refueling and outage activities has been Category 1.

During this period, a planned 14-week refuel-ing outage began on January 4, 1986.

By the end of the SALP period, there had been problems with installation of a new permanent reactor cavity seal, decontamination of steam generator primary channel heads, and a dropped fuel assembly.

The outage lasted about 20 weeks, well beyond the end of the SALP period.

Refueling and outage activities were reviewed by the resident in-spectors and a region-based project inspector, including outage preparations and coordination, refueling operations, and recovery after the February 26, 1986 dropped fuel element event.

The licensee maintained 24-hour per day management level coordina-tors to follow outage activities and bring problems to management attention.

Also, outage status meetings were held twice a day with all departments and critical jobs represented.

The licensee's com-puter-based outage planning program was effective in tracking the datails of job status.

Strong licensee commitment to the mainten-ance and updating of this program was evident throughout the outage.

Consequently, it was readily recognized which critical path activi-ties were experiencing problems such that additional attention could be focused in that area.

Under this closer scrutiny, the allotted time for some jobs was found to be incorrect.

In particular, under-estimation of work package preparation, establishment of plant con-ditions, and coordination and documentation of system turnover re-quirements reflected inadequate pre planning of outage activities.

As a result of deadlines and commitments, several plant modifica-tions were required to be implemented during this outage. These modifications included reactor vessel level indication, various Appendix R improvements, seismic support upgrades, and equipment environmental qualification replacements.

Although the licensee has guidelines which require early submittal of plant design change packages, only 8 of 32 modifications were ready for implementation at the start of the outage.

In addition, the need for twenty other modifications was identified during the outage.

Consequently, a major effort involving considerable engineering and supervisory effort was necessary, especially during the first month of the out-age, to assure the appropriateness of pre-approval release of modi-fication work packages and in the review and approval of the modi-fications as they became ready.

._

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Although no safety-significant discrepancies in design change imple-mentation were noted as of the end of the assessment period, the high volume of modifications implemented prior to completion of the final design approval taxed those responsible fcr quality implemen-tation of field installations.

Another negative aspect of the large expenditure of engineering and supervisory talents in design change package preparation and review, noted in Section C, was the diversion of these talents from their normal line organizational functions during the outage.

Better pre-job planning, supervision, and coordination may have reduced or al-leviated such problems as were experienced with the steam generator (SG) TV camera setup, SG decontamination, and high pressure safety injection pump repair jobs.

In addition, more direct management /

supervisory effort to reduce job-related radiation exposure might have reduced or eliminated the margin by which many outage jobs exceeded the man-rem exposure goals as detailed in Section B.

The dropped fuel element on February 26, 1986 created a significant perturbation of outage activities.

Recovery actions including dropped element inspection and recovery, core component damage evaluation and repairs, and re-analysis of the core reload pattern excluding the damaged elements were promptly integrated into the outage schedule.

The licensee's cautious and deliberate approach to recovery action reflected a strong commitment to plant safety at the expense of the outage schedule.

However, the coordination of preparations for recovery actions such as production and testing of lift rigs could have been improved.

In two instances, the re-covery efforts were delayed because lift rigs had not been prepared in parallel with procedure preparation.

Overall, however, through-out the recovery process, management priorities were properly di-rected toward assuring the safety and quality of the recovery pro-cedures and training, and the alertness of the recovery team.

In summary, although outage activities were carefully scheduled and tracked, notable inadequacies in job pre planning and coordination were identified.

Extraordinary supervisory efforts were required to assure proper implementation of safety-related system modifica-tions.

Those efforts challenged the level of quality assurance normally provided by supervisory oversight.

2.

Conclusion Rating:

Category 2.

Trend:

No Basis.

3.

Board Recommendations Licensee: Commit additional attention to the pre planning of outage activities, especially design changes.

!

NRC:

None.

i l

I

f

.

H.

Assurance of Quality 1.

Analysis During this assessment period, management involvement and control in assuring quality is being considered as a separate functional area in addition to being one of the evaluation criteria for the other functional areas.

Consequently, this discussion is a synopsis of the assessments relating to quality work conducted in other areas.

Licensee management emphasizes proper performance on the first try and that quality is each individual's job.

Therefore, the QA or-ganization is not looked upon as the central control for quality; line management is. _However, for those individual errors which are not picked up by supervisory oversight, management has other tools to assure quality such as onsite (PORC) and offsite (NRB) review committees, quality control (QC) inspections, and QA audits.

The success of this program is evident in the high quality performance of individuals noted in selected aspects of the operations, main-tenance, and security areas.

On the other hand, individual errors which were not identified or corrected by quality assurance activi-ties were also noted in the radiological controls, surveillance, and modification areas.

PORC and NRB were noted to be effective in their assigned functions; however, these functions were notably reactive, and were not effec-tive in preventing the recurrence of certain procedural and modifi-cation-related problems.

QA/QC coverage of backfit and Betterment Engineering projects was evident in the number of QA/QC findings required to be dispositioned during the 1986 outage.

QC coverage of maintenance was not as extensive.

Licensee improvement in QA/QC involvement in operational activities in progress and in the rad-waste transportation area was observed.

However, NRC identification of ongoing problems with personnel errors, procedural adequacy, surveillance scheduling, and radwaste processing and shipment indi-cate a need for more effective self evaluation.

It was also noted in several areas that the corrective actions for NRC and self-iden-tified problems were not always effective in preventing recurrence.

Control of fire barriers, missed surveillances, and inadequate ALARA controls were examples.

QA audited activities in accordance with department schedules.

NRC review of audit reports found them to be generally effective. With the exception of one environmental audit program which omitted re-quired document review'in the audit scope, no audit program defi-ciencies were identified.

Nonetheless, the NRC noted that improve-ment in management involvement in audit scope, findings, and cor-rective action promptness was needed to improve the quality and effectiveness of the self-evaluation process.

i

. _ _ _ -.

.

f-

.

In summary, the licensee performs many activities very well, pri-marily as a result of good individual and supervisory efforts.

The review committees were effective from a reactive perspective and, to the, extent employed, QA audits and inspections were satisfactory.

However, many minor problems were identified and several of these continued throughout the assessment period without effective cor-rective action. Management involvement in preventing problems, and assuring quality in all activities was noted as an area for improve-ment.

2.

Conclusion Rating:

Category 2.

Trend:

Consistent 3.

Board Recommendations

Licensee: Reevaluate the effectiveness of systems for self-

identification and resolution of problems.

NRC:

None.

l

-

,

- - - -

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,

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..

.

I.

Training and Qualification Effectiveness 1.

Analysis During this assessment period, Training and Qualification Effective-ness is being considered as a separate functional area for the first time. Training and qualification effectiveness continues to be an evaluation criterion for each functional area.

The various aspects of this functional area have been considered and discussed as an integral part of other functional areas and the respective inspection hours have been included in each one.

Conse-quently, this discussion is a synopsis of the assessments related to training conducted in other areas.

Training effectiveness has been measured primarily by the observed performance of licensee personnel and, to a lesser degree, as a review of program adequacy.

The discussion below addresses three principal areas: licensed operator training, non-licensed staff training, and the status of INP0 training accreditation.

The licensee's commitment to comprehensive and effective training programs at all organizational levels was evident in the ambitious program of training development and accreditation ongoing throughout this assessment period.

At the end of the period, though no train-ing programs had been accredited by INPO, the licensee had reas-sessed the program goals and milestones to establish a " ready for accreditation" status in all operator, staff, and technician pro-grams before the end of 1986.

No new operator license examinations were given during this period.

The licensee continued to in.plement the upgraded licensed operator i

requalification program committed to as a result of significant t

weaknesses identified as a result of NRC audits during the previous period.

In January 1986, a new requalification program was initi-ated, including requalification as an integral part of the normal operator shift rotational schedule.

NRC review of the licensed operator upgrade program rid '.he preparations for the new requali-fication program ident%1 s :tisfactory completion of the licen-see's commitments.

t-e-r

cific simulator has been installed and should be operat3..a1

,iid-1986.

The licensee relies heavily on departmental on-the-job training to establish and maintain personnel technical qualification.

General employee training (GET) provides safety, security, and health

physics training.

The security department was particularly noted

'

as having an effective training program.

Overall, the quality of operations, maintenance, and surveillance activities reflects training strengths in these areas.

Weaknesses were identified in some functional areas such as: I&C technician understanding of Technical Specifications (maintenance); engineer understanding of

,

u o

'

1 design change control procedures (modifications); inattentiveness of the licensee's staff to minimizing radiation exposures, and quality control inspector knowledge of radwaste transportation; (radiological controls); and general knowledge of the control of fire barriers (plant operations).

These weaknesses indicate the need for improved training in these areas.

Another problem identified during this period related to weaknesses in licensee control over the examination process for GET.

The fail-ure to establish formal examination controls during GET testing al-lowed the occurrence of an incident involving talking between ex-aminees during a GET exam.

The licensee responded adequately to this event by implementing more comprehensive examination controls for all training programs.

In suminary, the minimal number of personnel-error-related operational events reflects positively on the effectiveness of operating staff training.

Likewise, strong licensee performance in security and maintenance are due in part to the effectiveness of training in these areas.

It was also noted, however, that recurrent weaknesses in the ALARA, modification control and fire protection programs result from personnel errors and misunderstanding of program requirements.

These reflect negatively on the quality of training in these areas.

2.

Conclusion Rating:

Category 2.

Trend:

Consistent.

3.

Board Recommendations.

Licensee: Reorient technical training programs to address weaknesses identified in the functional areas.

NRC:

None.

,

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.

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J.

Licensing Activities 1.

Analysis The basis of this appraisal was the licensee's performance in sup-port of licensing actions that were either completed or active dur-ing the current rating period.

These activities consisted of amendment requests, exemption requests, responses to generic letters, TMI items, SEP and ISAP topics, and related actions.

Licensing activity during the SALP period has been at a very high level.

Although several licensing actions have been deferred for resolution under the Integrated Safety Assessment Program (ISAP),

twice the number of licensing actions have been completed during this 12-month rating period than were compieted during the previous 18 month SALP period.

In addition to the routine actions, major activities completed or ongoing include fuel reload (Cycle 14), steam generator tube sleeving, the voluntary ISAP initiative, environmental qualification modifications, exemptions for fire protection require-ments, and the rervirenents for an updated Facility Description and Safety Analysis (FDSA). At the start of the SALP rating period, there were 75 active licensing actions.

During the rating period, 50 actions were completed and 29 new actions were added. Thus, at the end of the rating period, 54 active actions remain. The specific licensing activities reviewed are listed in Section V.E of this re-

,

port.

In resolving technical issues, the licensee has exhibited a good understanding of licensing issues and has generally employed a con-servative safety approach.

The licensee's applications or submittals were generally timely and acceptable resolutions were generally pro-posed.

For example, the licensee's application for relief from some requirements for inservice inspection of reactor coolant pumps was well prepared and exhibited a conscientious effort to comply with the regulations. However, there have been some instances where the licensee's resolution of technical issues and responsiveness have been poor.

Examples are: submittal of information concerning the reliability of the Auxiliary Feedwater System, and in support of Technical Specifications for degraded grid protection, facility overtime, RETS and STS conversion.

While the licensee's management has been notably involved in major licensing issues, there have been occasions when incomplete or un-timely submittals have caused the staff to request improved manage-ment oversight.

Notable examples include the Cycle 14 reload and steam generator tube sleeving license amendment applications.

The Cycle 14 reload application, dated December 11, 1985, lacked the necessary technical information which was subsequently provided on January 16, 1986.

Similarly, the steam generator sleeving applica-tion was received December 6, 1985, but the technical justification (sleeving report) was not provided until January 7, 1986.

The un-

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1 timeliness of the supporting technical material for the above ap-plications created a significant burden on the staff to complete the required licensing reviews to support the scheduled startup date of March 4, 1986.

Similar examples of untimely submittals of exemption requests for issues being addressed under ISAP have occurred near the end of this rating period.

Notable examples include the schedular exemption requests for the fire protection modifications in the switchgear room (March 7,1986) and for Appendix J (March 12, 1986).

Both examples reflect cases where approval / denial of these exemption requests were outage related issues yet the submittal of the requests occurred well into the outage.

We believe that the above examples demonstrate that the performance and management oversight of licensing activities were declining during the end of the rating period and that it does not appear to be at the level of previous rating periods.

There also appears to be a tendency on the licensee's part to declare a position on issues without providing the follow-up needed to assure appropriate licensing actions are formulated to address the issue.

In particular, Appendix R, environmental qualification (feed and bleed), and other exemptions related to issues being considered under ISAP were filed close to the regulatory deadlines with significant technical issues yet to be resolved.

Although the licensee had pre-viously addressed these areas, they had not aggressively followed through to assure the acceptability of their positions.

In conclusion, management attention and involvement with matters of nuclear safety are evident, but there also is evidence that the quality of the licensing activities at the Haddam Neck Plant has decreased.

During this rating period there were instances when amendment applications were either incomplete or untimely, and when follow-up activities were delayed.

Requests for extension of sub-

,

mittal dates were common, reflecting an inadequate level of pre-i planning.

2.

Conclusion Rating:

Category 2.

Trend:

Declining.

3.

Board Recommendations Licensee: Take action to assure that licensing submittals are ade-quately pre planned, comprehensive and reflect considera-tion for regulatory deadlines.

Aggressively pursue each open item to closure.

NRC:

None.

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V.

SUPPORTING DATA AND SUMMARIES A.

Investigation and Allegation Review Two allegations were received during this assessment period.

One alleged that the licensee exceeded Technical Specification (TS) rod insertion limits.

No evidence was found to substantiate this allegation.

The second allegation concerned an incident involving two examinees discuss-ing test material during a General Employee Training (GET) exam. This allegation was substantiated.

Although this was shown to be an isolated case, a lack of clear instructions for exam conduct and an inadequate testing environment were found by the licensee to need corrective action.

The licensee upgraded their examination administrative controls to cor-rect the deficiency and close out the allegation.

The individuals in-volved passed a subsequent reexamination.

B.

Escalated Enforcement Actions 1.

Cf il Penalties There were no civil penalties issued during this assessment period.

2.

Orders A memorandum and order, issued on November 20, 1985, granted an ex-tension from the November 30, 1985, deadline for environmental qualification of electrical equipment.

The deadline was extended to January 4, 1986.

Modifications needed to fully qualify the ex-empted equipment were implemented during the January-April,1986 refueling outage.

3.

Confirmatory Action Letters There were no confirmatory action letters issued during this as-sessment period.

C.

Management Conferences 1.

On March 25, 1985, an enforcement conference was held at the NRC Region I office to discuss Reactor Protection System (RPS) Loss of Flow trip channel problems and associated surveillance and proce-dural reviews.

2.

On October 31, 1985, a management meeting was held at the NRC Region I office to discuss the causal factors and corrective actions for auxiliary feedwater system wiring deficiencies.

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D.

Licensee Event Reports 1.

Tabular Listing Type of Events:

A.

Personnel Errors

B.

Design / Man./Const./ Install

C.

External Cause

D.

Defective Procedure

E.

Component Failure

X.

Other

Total

LERs Reviewed LER No. 85-03 to 86-09 2.

Causal Analysis (Review Period 3/1/83 - 2/28/86)

Six sets of common mode events were identfied:

a.

LERs 85-14, 85-18, 85-22, 85-27 and 86-01 reported fire door control problems caused by personnel errors.

b.

LERs 85-12, 85-23 and 86-07 reported missed fire protection system surveillance tests due to personnel errors.

c.

LERs 85-04, 84-12 and 86-06 report failures of containment penetration local leak rate tests during three consecutive surveillance cycles.

d.

LERs 84-28 and 86-02 reported main steam safety valve setpoint drift problems, e.

LERs 85-5 and 85-24 reported auxiliary feedwater system actu-ation problems caused by sticking solenoid-operated actuation valves.

f.

LERs 84-10 and 86-04 reported problems with operability of the low pressure overpressure protection system.

,

'

There was a small increase in the percentage (38% to 43*e) of per-sonnel/ procedural error-related events since the previous assessment and a high level of component failure b

.

E.

Operating Reactor Licensing Actions 1.

Schedular Extensions Granted March 28, 1985; Extended the deadline for environmental qualifica-

'

tion of electrical equipment to November 30, 1985.

August 26, 1985; Extended the date of compliance with commission order (dated June 12, 1984) upgrading the Emergency Operating Procedures (EOP) at the Haddam Neck Plant to September 1, 1986.

2.

Reliefs Granted June 10, 1985; Relief granted from requirements of Section XI of ASME Boiler and Pressure Vessel Code for volumetric examination of reactor coolant pump casing welds.

3.

Exemptions Granted April 11, 1985; Granted a six (6) month exemption from 10 CFR 50.71(e) requirements updating the Facility Design and Safety Analysis (FDSA).

November 22, 1985; Conditionally extended the April 11, 1985 (FDSA upgrade) to June 30, 1987, provided specified milestone FDSA sub-mittals are met.

4.

License Amendments Issued Amendment No. 62 issued on April 24, 1985, revised Technical Speci-fications to change the Power Dependent Insertion Limits curve to allow greater flexibility in plant operations when reducing or in-creasing power.

Amendment No. 63 issued on July 1, 1985, changed the completion date for Item III.D.3.4, Control Room Habitability, as specified in the commission's March 14, 1983, Confirmatory Order.

Amendment No. 64, issued on August 12, 1985, deleted Technical Specification Environmental Qualification (EQ) requirements as cur-rent EQ and schedular requirements were incorporated into 10 CFR 50.49.

l Amendment No. 65 issued on September 3, 1985, revised Technical Specifications by deleting the logic requirement of the Pressurizer Low Water Level for the Safety Injection Trip.

Amendment No. 66 issued on September 3, 1985, modified Technical Specifications to add new Limiting Conditions for Operations and Surveillance requirements for Post-Accident Instrumentation.

.

_

. _ _ _.

..

E

.

Amendment No. 67 issued on September 3, 1985, modified Technical Specifications to change discharge pressure requirements for Emer-gency Core Cooling System (ECCS) pumps.

Amendment No. 68 issued on September 5, 1985, approved Radiological Effluent Technical Specifications (RETS) which incorporated the re-quirements of Appendix I to 10 CFR 50 and deleted Technical Speci-fication Appendix B, Environmental Technical Specifications.

Amendment No. 69 issued on October 16, 1985, modified Technical Specifications to restrict the volume of flammable liquids in the control room to no greater than one pint.

Amendment No. 70 issued on October 16, 1985, revised Technical Specifications to update the pressure and temperature limit curves for hydrostatic and leak rate testing and for heatup and cooldown rates.

Amendment No. 71 issued on December 10, 1985, revised Technical Specifications to include restrictions on the excessive use of facility staff overtime.

Amendment No. 72 issued on February 19, 1986, revised Technical Specifications to allow testing of normally closed, non-automatic isolation valves that are part of the Post Accident Sampling System (PASS).

.

..

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-, - -._,-

--.

-.-

, - -

,

. ~ - -

- -.. -

- - -. _ -, - -,,, -,,-

-

.

--

-

..

E

.

TABLE 1 TABULAR LISTING OF LERs BY FUNCTIONAL AREA HADDAM NECK PLANT AREA NUMBER /CAUSE CODE TOTAL A.

Plant Operations 7A 3B 6E 2X

B.

Radiological Controls none C.

Maintenance & Modifications 2A 2.

D.

Surveillance SA 2D 8E

E.

Emergency Preparedness none F.

Security and Safeguards none G.

Refueling and' Outage Management none H.

Quality Assurance none I.

Training none J.

Licensing Activities

2 Totals 14A SB

14E 2X

Cause Codes A - Personnel Error B - Design, Manufacturing, Construction, or Installation Error C - External Cause D. Defective Procedures E - Component Failure X - Other

'

,

!

i t

!

.

. _ - -,.

... _ _

, _.. _ _,. _ _

., _ _ -. -.. -. _ _. _ _ _ _ _.. _ _ _. -......

. _.... _ _ _.,,....., _ _ _ _.... _ _.. _ _.., _, - -,

_ _..

~9

.

TABLE 2 LER SYNOPSIS HADDAM NECK PLANT LER No.

Summary Description 85-3 Nonconservative Loss of Flow Setpoint 85-4 NIS Overpower Setpuint Drift 85-5 Failure of Auto AFW Flow Valves to Open 85-6 Feed Pump Suction Pipe Rupture 85-7 Plant Trip due to Feedwater Recirculation Valve Failed to Open 85-8 Cable Vault Ventilation System Inoperable 85-9 Inoperable Fire Door 85-10 Service Water MOV Failure 85-11 Multiple Dropped Control Rods 85-12 Failure to Perform Fire Detection Surveillance

't 85-13 Misaligned Rod Analysis 85-14 Inoperable Fire Door 85-15 Spurious Load Runback 85-16 NIS Dropped Rod Setpoint Drift 85-17 Post LOCA Release Paths Outside Containment 85-18 Inoperable Fire Door 85-19 Spurious Load Runback

, 85-20 Potential Unauthorized Access to a High Radiation Area 85-21 Cable Spreading Area Fire Barrier Problems 85-22 Inoperable Fire Barrier 85-23 Missed Fire Protection Surveillance Test

-.

-

-.

-

-..

. - -.. -. -. -

-.

--

-

.

'?

.

T-2-2 LER No.

Summary Description 85-24 AFW Initiation 50V Failure 85-25 Unplanned Gaseous Release 85-26 Partial Loss of Variable Low Pressure Scram Protection 85-27-Fire Barrier Penetrations 85-28 High Steam Flow Reactor Trips 85-29 More Probable Loss of MCC 5 85-30 Systems Integrity Inspection Missed 86-01 Inoperable Fire Doors 86-02 Main Steam Safety Valve Failures 86-03 Category C-3 Steam Generator Tube Inspection 86-04 Low Pressure Over Pressure Protection System Malfunction 86-05 Inoperable Switchgear Halon System 86-06 Containment Local Leak Rate Failures 86-07 Missed Fire Protection Surveillance 86-08 Improperly Tested Containment Penetrations 86-09 Inadequate Service Water Flood Barriers

,

!

. -..

.

-

-..

-

.. -,. -. -..

-.

- - -

.. - -. - ~.. -,. -,,.... - -, -, -, -,. - _.

_

. _ -

I'

.

TABLE 3 INSPECTION HOURS SUMMARY HADDAM NECK PLANT HOURS

% GF TIME A.

Plant Operations............

425

B.

Radiological Controls 393

-

.........

C.

Maintenance & Modifications 314

......

D.

Surveillance..............

230

E.

Emergency Preparedness.........

166

F.

Security and Safeguards

5

........

G.

Refueling & Outage Management 151

.....

H.

Quality Assurance

-

...........

-

I.

Training................

-

J.

Licensing Activities..........

-

Total 1758 100 Note: Allocations of Inspection Hours vs. Functional Areas are approximations based on inspection report data.

The Quality Assurance and Training analyses are a synopsis of the. evaluations of Quality Assurance and Train-ing rating criteria in each functional area.

Consequently, inspection hours for Quality Assurance and Training are included in the other respective areas.

i

.

TABLE 4 ENFORCEMENT SUMMARY

'

HADDAM NECK PLANT Severity Levels FUNCTIONAL AREAS I II III IV V DEV Total A.

Plant Operatior.s

3 B.

Radiological Controls

1

C.

Maintenance & Modifications

2

D.

Surveillance E.

Emergency Preparedness

.

F.

Security Safeguards G.

Refueling & Outage Management H.

Quality Assurance I.

Training

'

J.

Licensing Activities

__ __

__

Totals by Severity Level

3

9

p>

.

0-TABLE 5 ENFORCEMENT DATA HADDAM NECK PLANT Inspection Inspection Severity Functional Report No.

Date Level Area Violation 85-08 3/15-29/85 V

Inadequate scope of environmental audit program.

85-09 4/8-12/85 IV B

Failure to perform receipt in-spection of Radwaste QA systems and failure of PORC to review a Radwaste processing procedure 85-15 6/14-26/85 IV C

Inadequate design change review such that a TS change was missed.

85-15 6/14-26/85 IV A

Onsite review committee failure to identify that a required TS change was missed.

85-21 10/16-12/02/85 IV A

Failure to follow procedures (multiple instances).

85-21 10/16-12/02/85 IV A

Inadequate corrective action for previous violations.

86-01 1/9-2/6/85 V

C Inadequate processing of modifi-cation field changes.

86-01 1/9-2/6/86 V

C Inadequate test plan for a plant modification.

86-02 2/10-14/86 IV

Failure to compact radwaste in accordance with an approved procedure.

i l

-

I

.

TABLE 6 INSPECTION REPORT ACTIVITIES HADDAM NECK PLANT Inspection Inspection Areas Report No.

Hours Inspected 85-04

Radiological Controls 85-05

Management Meeting (Surveillance)

85-06 166 Emergency Preparedness 85-07

Routine Resident 85-08

Radiological Controls 85-09 144 Radiological Controls 85-10

Management Meeting (Training)

85-11

Routine Resident 85-12

Security 85-13 137 Routine Resident 85-14 cancelled 85-15

Special Resident - (Design Change Control)

85-16

Fire Protection 85-17

Design Change Control 85-18

Requalification Program

,

85-19

Routine Resident 85-20

Special Resident (Auxiliary Feedwater)

85-21 152 Routine Resident 85-22

Management Meeting (Auxiliary Feedwater)

85-23

Security 85-24

Chemistry

?

-

..

T-6-2 Inspection Inspection Areas Report No.

Hours Inspected 85-25 113 Routine Resident 86-01 206 Routine Resident 86-02

Radiological Control 16-05

Quality Assurance

.

r

~

P,

.

TABLE 7 PLANT SHUTDOWNS

HADDAM NECK PLANT Shutdown Period Description Cause March 12, 1985 Scram from 50% power.

High pressurizer Random Equipment Fail-pressure trip due to rapid plant load ures reduction as a resut of a loss of feed-water flow to steam generators, which was caused by a broken control air line to a feedwater recirculation valve.

A main condensate pump motor short pre-viously caused a load reduction to 50%

power.

March 16, 1985 Manual scram due to a main feedwater Equipment Failure-pipe rupture.

The reheater drain pump (design-related)

flow control valve directed flow against the pipe wall causing signifi-cant erosion of the pipe.

May 16, 1985 Manual scram due to two dropped con-Equipment Failure trol rods.

(design-related)

August 18, 1985 Shutdown to replace a main feedwater Equipment Failure pump seal (pump isolation valve leakage forced a shutdown rather than a power reduction).

November 10, 1985 Scram due to spurious high main steam Both events were caused flow signals.

by a design deficiency /

abnormal operating November 21, 1985 Scram due to spurious high main steam conditions -- lower flow signals, margin to the trip setpoint during coast-down operation allowed existing inter-channel interference to actu-ate the reactor pro-tection system (de-sign related).

November 27, 1985 Shutdown to replace main feedwater Equipment Failure pump rotating assembly (pump isolation (maintenance planning-valve leakage forced a shutdown rather related)

than a power reduction).

_

.__ _ _.. _

. _.

._.

_.

_

_ - -.

.

o

r NUMBER OF DAYS SHUTOOWN ( ) PER MONTH

'

.-

.

1985

!

l MAR 2 SD~l (1)

!

l APR MAY M,(1)

.

'

JUIE j

JULY

\\

-

l AUG M' (1)

-

.n SEP

.

..

-

9,

!

OCT

,,

.,,

~

,

l NOV 3 5D 1,

(2)

.

,

l DEC 1986 l

] (27)

JAN 1 SD:

for Cycle 14 refueling outage I (20)

FEB NA: Cycle 14 refueling outage i

l

1 I

I I

I i

t

5

15

25

)

tlUMBER OF DAYS

l l

i l

l

....

v t e Inspection Report - Haddam Neck - 1985098
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \| 25 \|
1985 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 7(0) 8(0) 9(0) 10(0) 11(0) 12(0) 13(0) 16(0) 17(0) 18(0) 19(0) 20(0) 21(0) 22(0) 23(0) 24(0) 25(0) 98(0) 99(0) 99(0) 25(0) Security Operator Exams Emergency Planning Other

IR 05000213/1985098

Text

REGION I

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