IR 05000213/1987099

SALP Rept 50-213/87-99 for Apr 1987 - Jul 1988

ML20155E479
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	10/04/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20155E472	List: IR 05000213/1987099 ML20155E467
References
50-213-87-99, NUDOCS 8810120302
Download: ML20155E479 (41)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 87-99 CONNECTICUT YANKEE ATOMIC PCWER COMPANY HADDAM NECK NUCLEAR POWER PLANT S0-213 ASSESSMENT PERIOD: April 1,1987 - July 31,1933 BOARD MEETING DATE: September 19, 1928 0810120302 001004 PDR ADOCK 05000213 0 PNU J

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SUMMARY OF RESULTS II.A Overview This 16-month SALP period consisted of about nine months of refueling outage (due to extension for core barrel thermal shield repair) and about seven months of plant operation. Outage activities dominated the SAL The SALP results reflect a significant improvement in performance in all areas, with senior station management playing a prime role in that achievement. Daily staff meetings were observed to be highly functional ones which produced timely management guidance on issue resolution. There was increased, daily accountability of individual supervisors and managers onsite. Substantially improved coordination between the site and corporate organizations was observe A major improvement occurred in the radiological controls area. Inputs from the health and physics organization were given careful review and were effectively ,

integrated into activities. ALARA efforts became notably effective in reducing exposures during routine and high dose risk activities. This was a major challenge which was very well-handled, with core barrel thermal shield repair being a good example of related, highly competent performanc Plant operations was rated Category 2 during the last SAL It now has a Category I ratin This is more typical of the performance historically achieved in this area at Haddam Neck. Operator professionalism and knowledge of conditions were goo There were no plant trips due to operator arror. Respense' to off-ncrmal conditions were excellent. Safety com.mittee reviews were very good. An excellent management interface was observe Of the seven SALP areas, six were rated Category 1. The combined Maintenance and Surveillance area was rated Category 2. While there were many examples of good performance in this area, there were also several problems. A significant one was two plant trips in seven months of operation being due to maintenance inadequacies.

. There also was improper cutting of a containment penetration, breaching of fire

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barriers, improper motor-operated valve motor greasing, severing of a diesel fuel line, and breaching of vital area barrier ;

Overall, the performance reflected by this appraisal shows good potential for re-maining highly rated, especially if the rositive initiatives observed continu There were, however, performance deficiencie For example, there were two elec-trical noise-induced trips of the plar.t from zero power in addition to the two maintenance-related trips from power. Also, management emphasis and the procedure j upgrade program have improved procedure adherence and quality, but that effort requires much more work. Such factors emphasize the need to continue to pursue

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performance improvements vigorously, i

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II.B Facility Performance Tabulation This SALP report incorporates the recent NRC redefinition of the assessment func-tional areas. Changes include combining the previously separate Maintenance and Serve 111ance areas and addition of the Safety Assessment / Quality Verification are The Safety Assessment / Quality Verification section is largely a synopsis of obser-vations in other functional areas. Additionally, the Fire Protection, Licensing, Refueling / Outage, Training, and Assurance of Quality areas have been incorporated into the remaining functional areas as appropriat Rating Rating Last This Functional Area Period * Period ** Trend Plant Operations 2 1 -- Radiological Controls 2 1 -- Maintenance / Surveillance"* 2/2 2 -- Emergency Preparedness 2 1 -- Security 1 1 -- Engineering / Technical Support 2 1

-- Safety Assessment / Quality Verification # 1 -- Fire Protection 3 # -- Licensing Activities 2 # -- Refueling /0utages 2 # -- Training & Qualification Effectiveness 2 # -- Assurance of Quality 2 # --

• March 1, 1936 to March 31, 1937

" April 1,1937 to July 31, 1933

"' Previously addressed as separate area # Not addressed as a separate are . - - _ _ _ - - - _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ .

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II.C Unplanned Trips and Forced Shutdowns

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Power Root Functional j Date _ Lev el Description Cause Area

, 4/6/87 100*4 Automatic trip due to high steam Control oil Maintenance /

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flow in the Nos. 3 and 4 steam contamination Surveillance lines when the No. 4 turbine con-trol valve failed open (LER 87-05).

1 3/19/88 0*4 Automatic trip due to a spurious Equipment age: Engineering /

high startup rate on Intermediate Electrical Technical i Range Channel No. 21 during start- noise caused Support

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up physics testing (LER 88-08). by an annunci-ator relay.

3/22/88 0*4 Automatic trip similar to the Equipment age: Engineering /

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3/19/83 trip (LER SS-09). Specific in- Technical i

itiation not Support identified.

4/30/88 60?4 Automatic trip while returning an False trip sig- Maintenance /

, idled reactor coolant system loop nal indicated Surveillance j to servic The plant remained that both tur-

shut down until 5/30/88 to repair bine stop valves 1 the No. 3 Reactor Coolant Pump had closed, seal (LER BS-12). False signal was

due to impro-1 perly installed stop valve cam switche _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _

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III. CRITERIA Licensee performance was assessed in selected functional areas significant to j nuclear safety and/or the environment. The following were evaluated, as applicable, r to assess each are L

' Assurance of quality, including management involvement and contro . Approach to the resolution of technical issues from a safety standpoin . Responsiveness to NRC initiative . Enforcement his tor . Operational events (including response to, analyses of, reporting of, and corrective ar.tions for). Staffing (including management). Effectiveness of training and qualificatio Each functional area was rated as being one cf the followin . Category _1. Licensee management attention and involvement are readily evident

and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory

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requirenents. Licensee resources are ample and effectively used so that a

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high level of plant and personnel performance is being achieved. Reduced NRC g attention may be appropriate.

l Cate2ory_2. Licensee management attention to and involvement in the perform-l ance el nuclear safety or safeguards activities is good. The licenseo has attained a level of performance above that needed to neet regulatory require-j ments. Licensee resources are adequate and reasonably allocated so that good i plant and personnel performance is being achieved. NRC attention may be  ;

maintained at normal level (

L Category _3. Licensee management attention to and involvement in the perform- [

ance of nuclear safety or safeguards activities are not sufficien The lic- >

ensee's performance does not significantly exceed minimum regulatory require- L

unts. Licensee resources appear to be strained or not effectively use !

NRC attention should be increased above normal levels.

i The SALP Board also considered assigned performance trends for the last . .rter of the SALP period. A trend is assigned if definitely discernible, if the SALP '

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l Board concludes that its continuation might change the performance level, and if t considered necessary to either focus attention on declining performance or acknowl-edge improving performance. The SALP trend definitions are:

> l Improving: Licensee performance was determined to be improving near the close of i

the assessment perio ,

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Declining

Licensee performance was determined to be declining near the close of t

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the assessment period and the licensee had not taken meaningful steps to address  !

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l l For this SALP, no trends were assigne l

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IV. PERFORMANCE ANALYSIS I

IV. A Plant Operations (1080 hours0.0125 days <br />0.3 hours <br />0.00179 weeks <br />4.1094e-4 months <br />, 26'4)

i IV. Analysis i

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The previous SALP rated this area as Category 2 with a need to further improve root l

cause analyses, corrective actions for error-related events, and submittals to the Plant Operations Review Comnittee (PORC). Improvements were noted in operator requalification, PORC performance, and control room utilization. Action to eli- I minate operator contributions to unnecessary reactor trips was recommended.

a j This area now includes Refueling and Outage Management (previously Category 2) and  ;

Fire Protection (previously Category 3) aspects which were previously rated in

other functional areas. Effective efforts to overcome outage preplanning and fire i protection weaknesses are noted later in this section,

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'i This SALP is based on resident inspections and three team inspections covering f Emergency Operating Procedures, operational safety based on the Probabilistic  :

Safety Study, and readiness for Cycle XV startup. Due to the refueling outage

] (July 1987 - April 1983) being extended for core barrel thermal shield repair, the  ;

9 station operated at power for only about seven months of this 16-month SALP period.

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Four plant trips occurred. None of these involved operator error. One significant operator error was identified: a +.agging error blacked out the secondary plant control room annunciators after reactor shutdown 4 refuelin Response to off- !

normal conditions was very good. When an undergrc ,d fuel oil transfer line was i i cut (during excavation of the Service Building floor during construction of the '

i new Switchgear Building), personnel responded quickly and effectively. Chemistry (

and Health Physics Technicians acted promptly to contain the oil. Operations per- ,

sonnel quickly isolated the line and established the Fire Brigade. Response was l

also prompt and thorough for the reactor trip from turbine control valve failure I l and for the partial blackout of control room anaunciator Overall operator ef- [

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fectiveness was therefore considered excellen !

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I Besides producing good results, operating activities were conducted professionall I d The operators continually exhibited detailed and thorough knowledge of plant equip-  !

i ment, its status, and associated requirements. Operator distractions were minimal l and only one annunciator has been continuously lighted; a setpoint change is being l j processed to eliminate this. Shift supervisors censistently maintained authority l 3 over activitie They were frequently seen in the plant reviewing status and ac- f i tivities. Operator professionalism and effectiveness were a significant opera- [

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tional strength during this SALP perio r l

! Management attention to operations ws.s evident in frequent tours by the station  !

1 N rintendents, department heads, and corporate officer NRC inspectors noted j j supervisors' observations reflected detailed and conscientious review [

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Plant Operations Review Committee (PORC) performance was very good. Meeting pack- i

, ages were well prepared and were distributed in advance. For complex issues, de- '

i cisions were appropriately deferred to allow evaluation of details. This was the case fcr ground subsidence around the Emergency Diesel Generator fuel oil stcrage tanks and for the identification of single failure vulnerabilities in the charging ,

and residual heat removal systems. The approach to problem resolution has been

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technically sound, very thorough and routinely conservative. Root cause analysis ,

and associated corrective actions were highly stressed and appropriately reflected

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in Licensee Event Reports. Examples included reports made on the improper greasing i

} of valve motor-operators and improper wiring of dropped rod circuitr I 3 Several techniques were used to expedite the communication of operational issues.

, These included the assignment of Duty Officers and the use of Plant Irformation

] Reports to allow for more immediate management attention to occurrences. These !

were addressed in detail at morning station management meetings. The NRC observed ;

that these discussions provided early assessment of safety impr,ct and timely man- l

! agement guidance on resolution. This practice also provided for early management ;

! evaluation of corrective actions and of reportability to the NR '

l P.efueling outage activities included the 20 yea Inservice Inspection, Replacement

of the Low Pressure Turbine Rotors, and Emerger cy Core Cooling System (ECCS) and containment penetration modification The ou. age was extended for repair of the !

Core Support Barrel Thermal Shield. Operations personnel maintained good control '

of outage activities, with thorough morning planning reetings repeatedly eviden Also, a Senior Reactor Operator was dedicated to control of work orders. These i

controls proved effective in maintaining containtent integrity when a contractor l l erred during containment penetration modification '

! Outage preplanning and preparations were greatly improve Prior to the refueling :

outage, several status and planning meetings were held on site with active parti- >

cipation by corporate personnel. There was a major improvement in the timeliness ,

of availability of modification packages to the site. Excellent pre-job planning !

and execution were demonstrated for a maintenance outage fr.r a Reactor Coolant Pump i seal replacement in May 1988 and for replacement of a charging pump shaft during r power operation at the close of the SALP perio A notable undertaking has been the labeling of all station equipment with large descriptive tags. A standard format for the tags was established and operations !

personnel have been effectively implementing the program. The addition of these j tags was a significant positive initiative, i

Procedure standards have been improved significantly, with emphasis on human fac- !

tor Station procedures are being rewritten using desk-top publishing equipment l with graphics capabilitie The rcw foreat is very clear, with a style that draws l attention to precautions and data and signature blocks. Also, the procedure vali- i dation process has been beneficial. For example, a fuel move walkthrough identi- (

fied errors and enabled rrocecures to be corrected prior to fuel aovemen Proce- i dure upgrades and station management emphasis resulted in a v.gnificant improvetent j in procedure adnerence, a long-standing proble A team i',spection at the end cf 1 i

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the refueling outage concluded, however, that minor problems still exist with administrative procedure adequacy and adherenc The licensee's prog?am to re-

! write all station procedures is about 25'. complete.

i A team inspection in April 1987 found that the Emergency Operating Procedures (EOPs) were technically adequate but had human factors deficiencies. Operators i adequately used the E0Ps at the simulator, but some commitments to conform to the i procedures generation package human factors provisions had not been met. For ex-

! ample, some instructional statements were ambiguous, and E0P menclature did not correspond to the control room panels. Also, the team was concerned with the

practice of filing change notices in the front of the E0Ps. The licensee accele-l rated their schedule for E0P upgrades, included additional huma;. factors reviews, j and issued revised E0Ps for implementation in June 1988. This was considered to

] be a prompt and appropri P e response.

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A full-time Fire Protection Engineer s;as assigned to the Engineering Department

{] (as noted in SALP Se.:cfon 7,V.F Engineering / Technical Support). A computer-based tracking system was dev.' loped for Fire Protaction commitments. That data base allowed convenient access to commitment and implementation information, and the fire protection engineer began verifying the implementation of commitments. This

, lead, in part, to the discovery of defects in the design of the cable vault fire

! suppression system (also noted in SALP Section IV.F). Also, physical changes

! positively affected fire protection performance. These included the removal of l oil-filled transformers from the electrical switchgear room and upgrading the Halon j fire suppression system in that room. Other examples of e vd performance included j the timely reaction of the fire brigade to a cut diesel fuel oil line (previvusly

) noted in this section) and a heightened personnel awarer:ess of fire protection needs such as protecting access to fire equipment. Tnese efforts produced a not-l ably better fire protection performance than that which resulted in a Category 3 j Fire Protection rating during the last SALP.

f In summary, command, control, and performance of station activities were strong.

{ Superintendents and department managers were aware of plant status and actively j involved in operations through PORC invo'vement and normal activities. Corporate j and Station goals and policies were detailed and well ccmmunicated. There was strong emphasis on personnel and reactor safety. Licensed operators were profes-sional, knowledgeable, and thorough. Operator errors were few. Thorough prepara-

, tion and preplanning were stressed prior to the refueling outag Refueling was

much improve Station management was sensitive to NRC concerns and responsive i to correcting problem areas.

IV. Performance Rating: Category IV. Recommendations l Licensee: Consider using Quality Services Department reviews / audits to aid in l maintaining E0P qualit :

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i IV.B Radiological Controls (627 hours0.00726 days <br />0.174 hours <br />0.00104 weeks <br />2.385735e-4 months <br />, 154)

IV. Analysis t

Radiological Controls (

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The last SALP rated this area as Category 2. Concerns included: procedural inade-quacies, including poorly written procedures and frequent instances of failure to follow procedures, as well as inadequate procedure reviews; problems in training ,

workers in the applicable procedural requirements; lack of acequate computer soft-ware to support ALARA efforts and some aspects of the quality control program; poor outage job planning and frequent job delays; difficulties in controlling nonessen-

tial worker access and stay times in the radiological controls areas; continued ,

high station cumulative exposure; and inadequate exposure goal setting method (

Corrective actions for the above weaknesses, when proposed, were poorly formulated "

and narrowly defined and implemente (

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Eight specialist inspections were conducted in this area during the current SALP  :

period. There was routine daily review by the resident inspector '

Performance in most areas of concern identified during the previous SALP has sub-stantially irrproved. A cnanged management attitude on-site emphasized compliance  !

j with all procedural requirements and made department management accountability an ,

j important and highly visible factor dail This led to a reduced number of proce-dure violations and played a positive leadership role in improved exposure contro ,

4 Site management at all levels substantially increased their involvement in planning t outage work and in monitoring and coordinating the preparations for the outagt with

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There was an increased plant staff awareness of and regard for health physics in- l

] puts. Participation and influence of health physics personnel in plant activities was evaluated as a strengt This was observed for routine operational and outage :

activities as well as for high ris.k evolu"ions such as the thermal shield repai l r

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Corporate health physics overview of the site program has been changing. Periodic i

? audits by corporate health physic.ists continued at a significantly irrproved leve ,

Audit emphasis shif ted from one of ;ompliance to a broader and more useful one of l

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assessment of program quality. Man-hours devoted to the audits were increased and .

l the technical expertise of the auditors also improve However, NRC inspect.icns

] have not yet assessed the effectiveness of these audit [

! The site health physics staff developed and ir.plemented a good hot particle program.

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This program was based on a good understanding of the problems associated with ,

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highly radioactive, minute particles and on firm program frplementation. Through  ;

d the use of stay times and high sensitivity personnel moritors, skin exposures were >

effectively controlled. Designation of special hot particle areas within the

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reactor containtent and the use of additional protective clothing effectively con-  ;

trolled the spread of contamination. The program resulted in successful decon-  ;

tamination of many areas of the plant and iroroved tirreliness of contamination  ;

j detection to avoid exceeding skin exposure 41mit ;

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j The quality of some site procedures was a weakness identified in several inspec-

tions late in the last SALP period and early in the current SALP period. A com-

mittee of site and corporate health physics staff was established to review the i procedures. The procedures were then rewritten to correct weaknesses and ensure l conformance to a standard format. The licensee introduced graphics to the proce-

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dures to help illustrate the methods and equipment. New procedures were field i tested by the health physics staff prior to final s.pproval. The licensee is also i developing a procedures manual with an index and a cross reference. Generic pro-l cedures developed by the corporate health physics daf f are being revised to im-I prove site flexibility to modify procedures as appropriate to the facilit These substantial improvements will also include more detail on the regulatory and tech-

nical bases for the recommended methods.

1 The Radiological Control Area (RCA) was divided into :enes to facilitate effective j health physics coverage and provide clear worker interface. Health Physics per-l sonnel were continually present within the RCA. Technicians and supervisors exer-cised their responsibilities in a conscientious manner. Specific attention was

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i paid to improving area housekeepin Department managers maintained close involve-ment with evolutions in the RCA.

l I:nprovements in control of high exposure jobs were instituted after an overexposure

incident occurred during the previous SALP neriod. The procedures for access to j high radiation areas were revised. Access to such areas was placed under more

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direct supervisory contro Check lists were developed to ensure all preparations

! for entry were completed. A new f acility to control steam generator work was used dm ing the refueling outage. The facility provided continuous remote monitoring of all generator work, as well as control of access to the steam generators.

i i Tc reduce external radiation fields and airborne radioactivity, the licensee made

! extensive use of underwater work for repairs of the reactor vessel core support l barrel and thermal shield supports, The licensee implemented a comprehensive pro-

{ gram of surveys, training, w.rk briefings, and personnel monitoring to assure diver j safet Good control was maintained over diving operatt.ns, and an incident in-i volving a highly radioactive particle encountered during one of the dives illu-l strated the excellent radiological controls inposed. Divers were equipped with telemetry dostmetry monitored by health physics personnel. When a diver encount-

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ered a highly radioacthe particle, the danger was immediately recogni:ed by the health physics technician, who ordered the diver out of the wate In this case, a potential serious overexposure was averted due to good worA planning, strong radiological controls, and effective and timely action by well qualified and trained personne ALARA performance improved during this perio The site health physics staff was closely involved in all aspects of outage planning, including job scope discussions, briefings on outage jobs by Corporate Engineering, on-site inspections of proposed work area and equipment, and job package tracking. Planning was significantly in-proved, and the job packages were more complete and wete generally received on-site within the planned time fram Increased presence of job supervisors at the job locations was eviden Exposure estimates were more carefully calculated compared to previous practice, and they were realistically tied to jcb scop Site manage-

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ment emphasized the importance of adherence to exposure estimates, and account-ability of section supervisors and department managers was efophasized and highly

, visible. Current exposuras were tracked routinely, and unexpected exposures re-l quired justification by the cognizant department manager to upper site management.

J ALARA goals were taken seriously by station supervision, and much effort was taken i

to meet those goals. Established goals were not chan;ed even when significant ad-

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ditional work was identified after the goals were established. For example, the

deterioration of the reactor vessel core support barrel the.rmal shield attachments was not known until disassembly during the refueling outage. Despite extensive

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i rspairs and modifications to this highly radioactive component, established station

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goals were not relaxed. Strong emphasis was placed on exposure reduction. This

! led to the extersive use of divers, fabrication of special remote operated milling equipment, and completion of the work without exceeding the earlier estimates.

, A second example involved the replacement of a reactor coolant pump seal assembly j after the extended refueling / maintenance outage. Again, special efforts were ef-fectively applied to job planning and placement of temporary shielding. A third i example was modification of the Steam Generator support skirts to allow technicians

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involved with eddy current inspection to remain in low exposure areas. The steam j generator health physics control point was located outside of the reactor contain-

ment; the eddy current equipment and the associated robotic arms were operated from

! a van, also located outside of the containment. Robotic arms eliminated the need

) for mst entries into the steam generator primary channel heads. Mock-up training i was und effectivel Extensive use was made of closed circuit television (CCTV)

l equipment to provide monitoring of high radiation area Television monitors were

! personally available to the Health Physics department supervisor for additional

] review. Videotapes were available for review as a means of further reducing ex-i

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posures. Outage steam generator inspection and plugging efforts covered 100*. of the tubes as in previous years, but with a 400 Rem exposure reduc .

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As a result of the ALARA efforts, the refueling outage was completed within the

) dosage estimate established beforehand. Although the cumulative exposure for the

{ outage was significantly higher than the industry average for pressurized water j reactors, the ALARA process and emphasis produced relatively low exposures in re-j lation to the work accomplished.

i j A problem identified in the last SALP was inadequate corporate support in develop-

! ing computer software to improve the data retrieval and analysis capabilities of

! the site ALARA group. Progress in developing this software has been slow and the affort should be considered for stronger management suppor The formal training program for the health physics staff was upgrade This came as a result of a cooperative effort between the site health physics staff and the training staff. The ur aded program increased the scope of the subject matter as well as the depth o coverag In addition to the formal training, the licensee attempted to improve worker anareness of radiological concerns by publishing a newsletter containing descriptions of events, procedural changes, and similar item A manual entitled "Radiation Protection Awareness" was also distributed to worker This manual supplemented radiation worker training and proviced discussions if basic radiological items such as the Radiation Work Fermit process, postings,

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i dosimetry requirements, high radiation area access requirements, use of respirators, plant layout and control zone boundaries, and similar items. The ALARA group also published a "Pre-Outhge ALARA Overview" which described planned outage jobs, work .

scope, a description of the work area, and the ALARA measures to be implemented !

for each job. The group also published a report on the previous outage detailing [

the jobs completed, the job statistics, problems encountered, and suggestions for improvemen Reports to cepartment heads and to upper site management were also i written to describe events of radiological significance and the status of exposure ;

Daily meetings of the radiological controls supervisors were held to discuss cur- [

rent site problems as well as relevant developments or incidents in the industr j

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Poor problems with radiological equipment and instruments past included inadequate !

technical oversight of the quality control program for measuring instruments. The ,

site health physicist was assigned the responsibility of reevaluating and oversee- !

ing that quality control program. Ne,< equipment was installed to facilitate and !

automate some of these quality control functions (calibrations, background counts, j etc.), in addition to upgrading the quality and reliability of the counting labora- 1 tor These changes were completed after the SALP period, and the NRC concern wat l basically eliminate j l

E'/ fl ue n t s j Gaseous and liquid radioactiva effluent control were inspected twice during the l SALP period. The chemistry department was primarily responsible for program im- !

plementation. Management controls were evident in the procedures for controlling !

discharges and scheduling surveillances. Radioactive effluent conteol instrumen- ;

tation was maintained and calibrated in accordance with requirements. The licensee l was responsive to NRC suggestions for improvements in ef fluent radiation nonitor ,

calibration. Effluent release records were complete and well maintained. Corpor- ,

ate audits were assessed as comprehensive and technically sound; NRC inspections -

noted timely findings and excellent follow-u Solid Radioactive Waste .

The licensee improved the handling of solid radioactive waste by adding new shred- l der-compactor equipment for volume reduction. Appropriate use was also made of !

contractors who offer material decontamination services. That permitted more com- (

plete decontamination of equipment and its uncontrolled releas l t

The licensee constructed a clean material release point at the RCA boundar Special monitoring equipment at that release point was used to check that radio-active material had not contaminated clean material at its exit poin Transportation One inspection of the licensee's transcortation program was conducted early in the assessment period. Several violations during the previous assessment perioc re-suited in an enforce ent conference; the licensee revisec a d improved job-related procedures and QA audit procedures. The procecures were effectively irolemented, and that resulted in a positive overall trend in this are The frequency and

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quality of QA audits activities also improved. Staffing was adequate with re-sponsibilities clearly defined in the licensee's procedures. All staff, including QA personnel, received required trainin Summary Licensee radiological controls performance reflected substantial general improve-ment and improvement in transportation in particular. Previous weaknesses were corrected except for computer software to support ALARA. ALARA control improve-ments in planning, in facilities, and in ef fectiveness of daily oversight in re-ducing dosaces were particularly noteworth IV.6,2 Performance Rating Category IV. Recommendations Non . _ _ _ _ _ _ _ _ _ _ _ _ _ _

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IV.C Maintenance / Surveillance (958 hours0.0111 days <br />0.266 hours <br />0.00158 weeks <br />3.64519e-4 months <br />, 23*.)

IV. Analysis '

l Maintenance and Modifications and Surveillance have been combined into one are [

Maintenance and Modifications was rated a Category 2 in the previous SALP. Areas ,

needing improvement included equipment and .taintenance personnel performance; par- l ticularly procedural compliance, work control, and documentation. Strengths were '

noted in preve9tive maintenance and technical training which extensively used equipment mock-ups. Surveillance was also rated a Category 2 in the last SAL Weaknesses were identified in attention to detail, nianagement involvement in Con- .

tainment Integrated Leak Rate Testing, and as-found containment leakage. The pro- l cedure upgrade effort and improvements in Steam Generator tube inspection were ;

noted strength !

This assessment is based on routine resident inspections, several Inservice In- !

spection and Testing inspections, and two tesm inspections (operational safety (

based on the Probabilistic Safety Study, and readiness for Cycle XV startup).

Surveillance activities caused no reactor trip Two reactor trips during the seven months of operation during this SALP period wete related to maintenanc The first of these was due to inadequate maintenance of the turbine lubricating oil system. The second was due to incorrect assembly of turbine stop valve posi- i tion snitche During the refueling outage, the turbine lubricating oil system was extensively flushed and cleaned. The turbine stop valve position switch link- l ages were aligned and associated procedures were improved. These actions were appropriate, but the two trips in seven months represent a weakness in maintena g e ,

effectiveness. It is also notable that both of these trips were due to ba?'9ce- ;

of plant (BOP) ecuipment problem '

Weaknesses were identified in contractor work control. Examples during the re- !

fueling outage were cutting of the incorrect containment penetration line while supporting modifications, unanticipated breaching of fire barriers in the switch- ,

gear room, and incorrect greasing of motor-operated valves. Recent incidents in- l cluded severance of an underground fuel oil line to the emergency diesel generator '

storage tanks and breaching a vital area barrier. Although these occurrences were (

licensee identified and vigorously addressed, their occurrence indicated inade- l quacies in managment and control of contractor work, i i

This appraisal period marked the end of the second ten year inservice inspection ,

interval, Inspections made during the outage included the reactor pressure vessel. L This inspection was greatly expanded beyond its original scope when NRC inspection identified that a full inspection had never been perforned of vessel belt-line welds because of changing code requirements. The licensee then performed ultra- l sonic testing (UT) to establish a UT baseline for almost all the welds. This i demonstrated good responsiveness to NRC inspection finding l

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Ouring core barrel removal, damage was identified on the core barrel thermal shield support devices. Extensive repairs and modifications to the thermal shield were made. Good work control, coordination, and communications between the departments involved were evident throughout the repair. This work on highly radioactive com-

ponents was well planned and was implemented through detailed procedures,

Good preplanning, mock-up training, procedural controls, and management involvement

! were evident during reactor coolant pump motor inspection, removal and replacement;

] reactor oolant pump seal replacement, and the recent charging pump repairs. It l was apparent that increased management attention was placed on suct evolution This was also evident in the decrease, relative to previous assessments, in the personnel errors resulting in licensee event reports (LERs).

j The previous SALP identified widespread weaknesses in procedures and procedure ad-i herence. The licensee embarked on a site procedure upgrade program based on the l pilot program completed on the Instrumentation and Controls department procedures.

1 Overall, station procedures have been technically sound. The station's standards l for procedure content were improved significantly, with emphasis on human factors i effects. Within each station department the procedures are being rewritten (see l Section IV. A, Plant Operations). Specific to Maintenance and Surveillance Proce-j dures is the inclusion of Technical Mar.ual drawings to provide additional clarity

! and detail. In addition, the inspectors noted use of pre-implementation walk-l throughs for procedures as a means of validation. These initiatives were consi-dered significant positive contributors to performance.

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During the refueling outage, a full pressure Containment Integrated Leak Rate Test

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(CILRT) was conducted for the first time since preoperational testing. The proce-1 dures and methodology for local leak rate tests (LLRTs) and the CILRT were improved j ones. Management was closely involved with test progress and provided support as

necessar Test personnel were knowledgeable and competen However, as f t.und

) leakage exceeded limits for the third consecutive CILRT and for the fourth con-

! secutive set of LLRTs. Both failures were due to excessive penetration leakag During the refueling outage, fifteen penetrations were rsdified, including most

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of the historically leaky one This was a noteworthy initiative.

l Most leakage testing was completed several months before the end of the refueling i outage. To verify a leak tight containment before startup, the licensee reper-formed the LLRis for seven recurrent leaky penetrations, One failure was identi-

fied (the Reactor Coolant Systen vent header isolation valves) due to routine fill

and vent evolutions. Station startup procedures were then revised to require f fitshing and a successful as-left LLRT after system filling ard venting is complete.

A similar situation was icentified in the fire suppression line to the containment

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spray during valve stroke testing; procedure changes were incorporated to require l 4 flushing and LLRT after stroke testin Overall, the licensee nas made signifi-i cant improve ents in CILRT and LLRT performance including rnintenan:e, surveillance, modifications, and post-activity testin However, excessive as-fourc containcent l

l leakage has been a Icngstanding problem which has rot yet been shoan to be corrected.

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As noted in the Radiological Controls section, effective exposure reduction initi- ;

i atives were implemented during eddy current testing of the steam generators. A !

problem with manual steam generator inspection data transfer was solved by using j a computer to transfer data from the site to corporate offices. Also, an addi- !

tional data review was incorporated for a third verification of necessary plugging, j i Prior to restart the licensee extensively studied steam generator eddy current data t to determine the susceptibility to a tube rupture event like that at North Anna l Unit The licensee had been advised that their generators could experience anti- l L vibration bar wear which could result in a rapid tube failur Initial evaluation .

J identified four tubes as susceptible to this type of failur Pending further i i analysis, the licensee is relying on leak detection abilities inherent to stainless i

] steel clad fuel, using tritium as a tracer. This study involved considerable ef- i fort by site and corporate engineering prior to issuance of NRC Bulletin 88-02 on .

' the North Anna event. The licensee maintair 4 close contact with the NRC during ,

this evaluation and took prompt and thorough actions to resolve this significant (

technical issue before station startu l

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A significant new initiative to improve the refueling outage modification process was the development and ieplementation of a preoperational test program for modi- }

fication testing peior to turnover for operatio This program essentially em- t bodies the characteristics of a near-term operating plant preoperational and I startup test program to assure component and system operability. Such test re- i

) quirements were applied to outage modifications such as tnose invo'ving the High !

Pressure Safety Injection, Reactor Protecti,3, Switchgear Room Fire Suppression, !

and Containment Instrument Air Systems. The program is being used as a model to i

! formulate a corporate policy for modification testin l

} f l Surveillance testing continued to be well scheduled and tracked with the Production [

l Maintenance Management System. During the assessment period, two required sur- t j veillances were missed due to personnel erro The first was a delayed verifica-l tion of reactor power during physics testing and the second was .t failure to notify

{ chemistry personnel when compensatory sampling was required for an inoperable '

radiation monitor. These errors were considered minor and not an indication of program implementation inadequacie Based on the safety-significant naintenance observed to be outstanding during rog-

) tine inspecticn tours, the number cf open work orders has been reduced to a ore !

l manageable level. Progress has been made in rectifying previous weaknesses in work l order documentation and backlog, A program providing guidance for proper documen-tation in work order packages has been initiate These were considered to be f necessary positive init.iatives, j Chemistry reasurement capability was evaluated midany through the SALP period.

I Licensee perforrance on NRC supplied chemistry standards was good, with only two of 36 results in disagreement, primary and secondary plant chemistry status re-

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ceived canagerent attention during each station morning meeting. Reactor Coolant !

System activity, stea'n generator primary-to-secondary tube leakage, and secondary i plant che'nistry were routinely discussed and trendec. Licensee initiatives in- f l cluded upgrading of enemistry laboratory equipment, installation of additional on- i line monitors for water chemistry control, and use of television m nitors to reduce (

the nu-ber of irdividuals in high radiation area [

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) In summary, much management attention was devoted to this area and improvements [

were evident. The procedure upgrade program has been a positive and much needed ,

initiative which needs ongoing attention. Management emphasis has seen effectively i J

placed on critical path, highly visible projects. The licensee has become very -

sensitive to containment leanage problems. How6ver, contractor work control prob- !

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lems indicated a need for more supervisory and Quality Assurance attention, and i balance of plant maintenance effectiveness needs to be improved to eliminate i

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avoidable scrams.

IV. P_erformance Rating: Category 2.

j IV. Recomendations

{ Licensee: (1) Improve balance of plant maintenance in order to decrease avoidable [

j reactor trips, t l (2) Improve overview of contractors.

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NRC: Non I l s l

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IV.0 Emergency Preparedness (149 hours0.00172 days <br />0.0414 hours <br />2.463624e-4 weeks <br />5.66945e-5 months <br />, 4*;)

IV. Analysis i

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During the previous assessment period, licensee performance in this area was rated i Category That rating was based upon satisfactory response capability in the

! full participation exercise and results of a routine safety inspection.

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l During the current assessment period, a partial participation exercise was observed

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and changes to the Emergency Plan and Implementing Procedures were reviewed.

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The partial participation exercise was conducted on May 26, 1957. The licensee's

] Emergency Response Organization (ERO) staff recognized syrptoms, selected the cor-rset Emergency Onerating Procedures, classified accidents correctly, developed

Protective Action Recommendations (PARS), calculated projected doses and dose ccm-1 mitments, activated and staffed Emergency Response facilities (ERFs) in a timely I

manner, effected command '.nd control as well as information ficw within and among

ERFs, uncertook inplant and offsite surveys, controlled ERO team doses, completed site staf f assembly and accountability, risintained site access and security, pro-

Vided technical support to repair and corrective action teams, fought simulated fires, and began recovery planning. No significant deficiencies were identified,

] however, one minor weakness was identified in that notification of the declaration q

of a General Emergency to of fsite authorities was hisyed by several minutes (but

not untirrely). Also, multiple mock control room inadequacies were noted

+ne room .

j lacked reference documents and status boards, and noise and temperature levels were i high during the exercis The plant process computer was replaced and the emergency facilities equiprnent up-

! graded to install both the Safety Parameter Otsplay System and telemetry data link l to the corporate main frame computers. With these inprovements, plant parameters I were available to the users sf the time Share computer terminal Selected vari-l ables were displayed to tupport the evaluation of plant condition Prior to hav-l ing this system, plant data were gathered tranually and transuitted telephonically.

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{ An emergency planning exercise was conducted for training on June 28, 1958. Adct-l tionally, the licensee held several off-hours exercises for the on-cali personnel, i including one requiring response to the site. One of the all-in exercises also 1 tecluded corporate personnel. These exercises were successful: hearly all respond-l er,ts answered and backup personnel were also available, i

j Northeast U'.ilities established a system-wide Emergency Preparedness Program (EFP)

d renaged and operated ty Northeast Utilit.ies Service Company (NUSCO). EPP at each

. site is headed by a site Emergency Preparedness Ccordinator (EPC) who reports to i the Supervisor, Energency Preparedness, NUSCO while eaintaining close liaison with

, the site Sta*. ion Services Superintendent and Station 5sperintenden A Corporate

! ERO has also been establi,hed. Meteorology and Ocs, Assessment activities in sup-j port of the Had am Neck Plant are undertaken by the Corporate ERO. A 5'ste support i group has been establisned which interf aces with Senior State of ficials.

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The NUSCO Training Department located at the Millstone site provided training for each site. A trainer was assigned site responsibilit Training developed lesson plans which were revia,ed by the site EPCs and the NUSCO Emergency Preparedness Manage Training set the schedule, administered examinations, and maintained training records. Overtil, ERO training was stron ERO staffing was ampl There were 210 Haddam Neck plant personnel qualified for sponse Organization (ERO) positions. At least six persons were qualified for each ERO position. Technical Support Center (TSC) engineers are trained in accident classification, severe accident analysis and Core Damage assessment. Operators received emergency preparedness training including Emergency Action Level (EAL)

classification and PAR There was a good relationship with State and local official The licensee has met with the State and discussed and reviewed EALs and PARS. These topics were covered with the towns during their training. The State used hardware and software for dose projection identical to that used by NUSCO, and participated in monthly dose assessment drills. About 250 officials from 18 towns have been traine Medical, ambulance, and fire department training was also current. The annual siren test will be conducted during the forthcoming annual exercis Overall, the licensee has responded to NRC initiative The mock control room is being upgraded. The licensee cooperated in rescheduling the annual exercise based upon an NRC request. Plans and procedures were current. Training was extended to operators, TSC engineers, support n,edical facilities, and offsite authoritie The Itcensee maintained good relations with State and Town official IV. Performance Rating Category IV. Recommendations Licensee: Continue efforts to improve control room simulatio NRC: None.

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IV.E Security (145 hours0.00168 days <br />0.0403 hours <br />2.397487e-4 weeks <br />5.51725e-5 months <br />, 4'f)

IV. Analysis During the previous SALP, the licensee's security performance was Category That rating was largely due to licensee responsiveness to the NRC, initiatives to review the ef fectiveness of the security program, continued support for the program from corporate and site management, and no violations during four consecutive rating periods (1980 to March 31, 1987).

During this assessment period, one region-based security inspection was performe Routine inspections by the resident inspector continued throughout the perio One special inspection of the degradation of two vital area barriers was conducted by the resident inspector Corporate security management continued to be actively involved in all site secur-ity program matters, including visits to the site by the corporate staff to conduct audits and provide assistance in the budgeting and planning processes for program modifications, upgrades and program plan changes. Security management personnel were also actively involved in the Region I Nuclear Security Association and other industry groups engaged in nuclear plant security matters. This demonstrated pro-gram support and attention from upper level corporate managemen As in past periods, thq licensee used a self-appraisal program which is independent of the NRC's required .nnual security program review. This permitted early iden-tification and correct on of potential problems and weaknesses, and also increased the effectiveness of the program through continued monitoring of its implementatio Such self-appraisal, combined with the licensee's annual program review, is be-lieved by the NRC to be a factor in the success of the program and to reflect the licensee's commitment to a high quality and effective program. The annual review by the licensee's quality assurance group was comprehensive in scope and depth, and focused on the details of the licensee's commitments in the NRC-approved Security, Contingency, and Training and Qualifications Plans. Corrective actions on deficiencies identified during the self-appraisals and the annual review were prompt and ef fective, with adequate follow-up to ensure their proper implementatio The licensee continued to make program enhancement Noteworthy among these were establishing a more effective search procedure for packages hand-carried into the protected area and installing an electronic means to prevent personal access con-trol devices from being removed from the protected area. This was indicative of the licensee's continuing effort to increase the effectiveness of the progra Five security events required reporting under 10 CFR 73.3 Two events in the latter part of the period involved the detection of a vital area barrier degrada-tion, two involved the detection of a personal firearm unintentionally in the possession of security force members when reporting for work, and one reported a strike by security force personne Review of the reports indicated that, with one exception, they were consistent with the NRC's recorting requirements (10 CFR

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73.71). The exception involved a misunderstanding of the NRC's reporting require-ment for one of the degraded barriers. This was an isolated exception to the lic-ensee's overall good understanding of reporting requirement As during previous periods, effective supervision and training of the security force was evident in a low personnel error rate, high morale, and a professional attitude toward job performance. During contract negotiations, there was a brief, incident-free strike lasting about one day. Staffing of the contract security force was appropriate, as indicated by the limited use of overtime. The security force training and requalification program was well developed and effectively ad-ministered. This was apparent from the excellent job knowledge demonstrated by security personnel during interviews by NRC personnel. The licensee also used experienced proprietary supervisors to provide oversight of the contractor on a shift basis. This licensee initiative is also thought by the NRC to contribute to the success of the program and to further demo.istrate the licensee's interest in and commitment to the program. These supervisors were also well trained and prepared to assume all guard force functions during the brief strik The licensee conducted numerous contingency plan drills to exercise members of the security force in emergency procedures. It was noted by the NRC that there was very little participation from the operations organization in these drills. When this was brought to the licensee's attention, plans were promptly developed to conduct these drills with significantly more operations participatio Af ter an enforcement conference, a Severity Level IV violation was cited late in the period for two vital area barrier degradations that were discovered by licensee

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supervisory personnel. One of these resulted from an oversight by a proprietary l supervisor while conducting a task that was poorly prescribed by procedures. The second resulted from inappropriate implementation of guidance to a crew doing work involving vital area barrier In each case, the licensee's corrective action was prompt, well-developed and comprehensiv Neither of the degradations posed a serious safety or security threa Detection of the degradations substantiated the alertness of the security personnel and +.he effectiveness of the pregra Six revisions to the licensee's security program plans were submitted to the NRC under 10 CFR 50.54(p) during this SALP period. These changes were clear and con-cise, and detailed explanations for the changes were provided. This was indicative of knowledgeable personnel and adequate management oversight of submittal The nature of the changes also reflected the licensee's efforts to improve program implementation and keep the plan meaningful and curren In summary, the licensee continued to ig lement a security program that was highly effective and exceeded regulatory requirements and security plan commitment Licensee initiatives, responsi ess to NRC concerns, support for the program, and excellent program implementat en were readily apparent and provided a high quality program, i IV. Performance _ Rating: Category 1.

, IV. Recommendations: None.

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IV.F Engineering / Technical Support (871 hours0.0101 days <br />0.242 hours <br />0.00144 weeks <br />3.314155e-4 months <br />, 21%)

IV. Analysis The prior assessment period was the first time Engineering / Technical Support was evaluated as a discrete functional area. Strengths were identified in the corpor-ate technical support capability and in the Probabilistic Risk Assessment (PRA)

program. Weaknesses were noted in site engineering staffing and in corporate en-gineering support of plant modifications, of refueling, of environmental qualifi-cation of electrical equipment, and of the fire protection program. The assessment identif'ved problems in poor coordination and communications and a non-cohesiveness between corporate and site staffs. The Board rated engineering support activity as Category 2 and rerommended the licensee improve communication and coordination between the site and corporate staff The current evaluation is based on assessments of engineering support effectiveness from all the routine and special inspections performed during this assessment period. Several inspections were conducted specifically to review and make as-sessments of the licensee's engineering performance, while others assessed engi-neering support effectiveness during routine inspections of other functiona' area During this SALP period, the site engineering staff was stable and, as supplemented by contractor assistance, adequat Positive attitudes were noted at the site and corporate office. Effective communications were eviden Monthly tite-corporate meetings were held to work out details of pro.iect assignments. Nr.w methods of testing design changes were implemented. A partnership type apsroach of having a site plant engineer work closely with a corporate project engineer has been in-stitute The assignment of a site engineering supervisor with a corporate engi-neering background and known technical capability fostered the site to corporate relationshi m porate engineering support was provided by the offsite NUSCO (Northeast Utili-ties Service Company) Nuclear Engineering and Operations organization. This group was further subdivided into Generation Engineering and Construction, responsible for design modification activities, and Nuclear and Environmental Engineering, responsible for reliability-type activities. Approximately 1000 engineering em-ployees of all technical disciplines provided technical support for the four nuc-lear plant From review of major project assignments and personnel commitments, an equitatGe share of corporate engineering support was allotted to Haddam Nec Inasmuch as engineering commitments were generally met on time, support for Haddam Neck was adequat Several major design projects completed during the 1937 outage were indicative of effective corporate engineering planning, design and implementation. The low pressure turbine rotor and inner casing replacement of both turbines, a large task, was carefully planned and executed. This resulted in relatively few problems and in timely completio The thermal shield repair was a major work effort initiated as a result of the licensee's second 10 year ISI inspection finding That task required considerable corporate engineering planning and coordination of contractor and site engineering on an urgent basis. This work was the critical path item and

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extended the outage five months, but the work was performed carefully and deliber-ately. Also, in addition to the significant upgrade of the thermal shield attach-ments, two new systems to monitor for loose parts and internals vibration were installe The design and construction of the new switchgear building has been a major effor The building is near completi^n and most major equipment and some conduits are in place. There has been coord.aated overview of work, as it progressed, by cceporate engineering and site engineering. Corporate maintained an engineer on site throughout the construction. As was evident from work stoppages by site management due to concerns over construction controls, management has been quality minded al-though, as noted in SALP Section IV.C, Maintenance / Surveillance, contractor control was a proble During plant operation, site engir.eering focused pr.imarily on daily problem Items which received priority attention and appropriate engineering resolutions included service water flow to a containment air recirculation fan and moisture removal problems in the turbine building air dryers. Concurrent with the support of operational issues, site engineering was involved with engineering procedure upgrading and developed new procedures to better control and provide guidance in procurement, dedication, and ungrading of commercial grade equipment. Site engi-neering also provided root cause analysis and technical support to the Maintenance and Instrumentation and Controls staff Two reactor trips during this assessment period were due to recurring electrical noise in the aging nuclear instrumentation (NI) system. This system has high pri-ority status for replacement during the next refueling outage. The fact that these trips occurred shows, however, that the replacement timing has been late. The first phase of the replacement effort included the replacement of equipment for Pressurizer Pressure, Pressurizer Level, Reactor Coolant System Temperature, High Pressure Steam Dump and Charging Flo The final phase of this project includes the replacement of the nuclear instruments and the RPS trip system An automatic turbine load runback was caused by electrical noise in nuclear in-struments. After analysis, the runback on negative rate was eliminated. NRC assessment concluded this was an appropriate step, but one which should have been accomplished before this SALP perio The ECCS analysis upgrade was a strong corporate engineering effort. Upgrade of the small break LOCA and Non LOCA transient analyses was completed and the licensee demonstrated an excellent working knowledge of Codes and their application. Cycle XV represented the first in-house licensee reload package; the licensee performed a complicated review and prnvided an excellent submittal. During the ECCS analysis upgrade, the licensee identified a Westinghouse calculatioral error in the LPSI flow delivery rate for the worst case single failure. The reduced flowrate re-quired a justification for continued operation (JCO) and an emergency Technical Specification change. The initial JC0 submittal lacked some technical detail, but

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the licensee responded immediately with a clarification of their JC0 and proposed Technical Specification. A revised JC0 and Technical Specification were subse-quently submitted and approved by the staf Good licensee performance in follow-up of the failure of a motor-operated valve electrical controller during surveillance led to the discovery of a long-standing single failure problem in the charging pump suction supply line. The ECCS analysis did not identify this failure mechanism, but it had been identified in the licen-see's Probabilistic Safety Study (PSS) and prioritized under the Integrated Safety Assessment Program (ISAP). After the surveillance highlighted the charging system vulnerability, the licensee instituted a program of system review for other single failure problem As a result, a single failure vulnerability associated with Residual Heat Removal Pump cooling was discovered and correcte Significant effort was made to track fire protection commitments and their imple-mentation. A computer data base was developed to enable efficient handling of several thousand Appendix R correspondence item Additionally, initiatives by the full-time on site 'icensee fire protection engineer led to the discovery of deficiencies in the performance of the cable vault fire suppression system and the containment fire detector system. A cable vault fire suppressiun system test (the first in the life of the plant) led to the discovery of system def:ciencies. The switchgear area fire suppression system also was tested and upgrade Equipment qualification (EQ) inspection noted that E0 staffing appeared limite This was evident in six examples where the qualification of a safety-related elec-trical component was not appropriately established (this resulted in a violation).

In these instances the licensee's record files did not contain all the necessary details due in part to inadequate review of equipment qualification document While the documentation files were not complete, the necessary information was available at other locations, reducing the severity of the findings. Overall, the licensee's understanding of EQ issues was good, with generally sound approaches taken to resolving them. Also, tailored EQ training was given to various levels of EQ personnel. Dispositions of most EQ issues were technically acceptable, but were not always timely. The licensee initiated action to improve EQ staffing and documentatio The licensee continues to be a leader in the use of Probabilistic Risk Assessment (PRA) techniques. PRA is used as a dynamic working tool to provide an analytical basis for prioritizing work from a safety and economic viewpoint. The PRA model is continually updated to reflect plant and procedural modifications. A recent change placed the PRA group in the design change approval chain. This will enable earlier conceptual assessment of the ef fect design changes have on calculated ris The close ties between Engineering and the PRA groups and provided assurance that i modifications will f avorably impact safet The plant probabilistic safety study also was entered into a personal computer data base and has been used frequently to evaluated the impact of equipment out-of-service, possible compensatory measures, and the impact of plant modification , .

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The results of the NRC PRA inspectior, indicated that the plant staff and the emer-gency core cooling systems were capable of reliable response to the dominant icci-dent sequences of small and medium LOCAs, Loss of Offsite Power, and a LOCA outside containment. This inspection identified a violation relating to the insufficient depth of a safety evaluation for a residual heat removal (RHR) system special flow tes The licensee's evaluation did not consider the degree of throttling of the component cooling water flow (CCW) required to control the RCS cooldown rate, nor did the special test procedure quantify the CCW finw. As a result, the RHR pump heated up and its lubricating oil degraded. Engineering did not sufficiently focus on the one-time test in this instance and, as a result, the procedural inadequacy was overlooked. This was considered to be a non-representative flaw in Engineering performanc The Quality Services (QS) organization and work performance related to engineering overview was reviewed during the SALP period. This. organization was staffed with several senior engineers, enabling several audits of engineering to be performe These audits reviewed design input, calculations, in process field installations, and tt.e testing of the equipment. There has been acceptance of this type of audit by Engineering and the audit feedback was beneficia The licensee's engineering contribution to NRC Bulletin responses and Information Notice evaluations has been timely and technically sound. The staff also reviewed several licensee 10 CFR 50.59 reports in detail. One case, the Reactor Protection System upgrade, required more than normal NRC interaction with the licensee, but the reviews contained conservative assumptions and were technically sound. The Plant Design Change Request Packages were thoroughly prepared and judged to be excellen The licensee addressed the past SALP period recommendation to improve engineering communications and cooperation. There were many positive licensee initiatives, with PRA use and outage support being especially noteworthy. Exchanges of person-nel between site and corporate engineering, and new site managements' philosophy of a team concept has been beneficial. Major modifications and daily operational problems had appropriate technical support. The licensee continued to improve use of PRA as a working tool. The licensee's Quality Service Organization performed i hardware oriented inspections and in depth reviews of Engineering. Negativr. EQ findings were not of major significance. The instance of the RHR pump overheating due to a safety evaluation not performed in depth was significant, but the licensee compensated with far-reaching corrective actions that yielded additional benefit The trips due to noise in the aging NI system were also significant, but NI re-placement had already been planned. Overall, the problem findings were relatively minor in relation to the many positive engineering factors.

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IV. Performance Rating: Category 1.

i IV. Recommendations: None.

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IV.G Safety Assessment / Quality Verification (319 hours0.00369 days <br />0.0886 hours <br />5.274471e-4 weeks <br />1.213795e-4 months <br />, 8%)

IV. AnQysis This area e.orporates the Assurance of Quality functional area in past SALPs, and is expandeu to encompass activities previously evaluated in the Licensing func-tional area, including safety evaluations, and considers other aspects of safety assessment. The area is a synopsis of the observations in the other functional areas, with the specific NRC inspection hour contribution to QA aspects being a relatively minor inpu The SALP Board considered contributors to assuring safety such as implementation of management goals, planning of routine activities, worker attitude, management involveme;.t, and trainin In the last SALP, Assurance of Quality and Licensing both received Category 2 rat-ings. Strengths ide.1tified were strong management commitment to plant safety, eff:rts to upgrade safety, and initiatives to improve outage planning and initi-ation of action items. Weaknesses identified were lack of comprehensive planning and timeliness in submittals, an ineffective ALARA program, a high number of vio-lations of NRC requirements, and a high number of personnel errors resulting in plant transients and event During the SALP period, there was strong evidence of worker and management consi-deration of the safety implications of relatively minor observation For example, incorrect motor-operated valve greasing was discovered through observed misplace-ment of drain plugs. Also, observed ground subsidence during switchgear building construction led to increased Quality Assurance presence on the job-site. Water inleakage into the containment electrical penetration area was evaluated, resulting in installation of flood alarms and a heightened station sensitivity to flooding potentia During surveillance testing, potential containment penetration leakage and ECCS single failure problems were identified for evaluatio Plant housekeeping improved during this SALP period. Facilities for radioactive waste handling and storage were expanded. During the outage, significant effort was expended in decontamination of historically neglected areas such as the RHR pi Tighter controls over materials entering the radiologically controlled area were also established. Consideration of post-accident conditions led to the re-moval of tools and equipment stored inside containmen Turbine rotor missiles were considered during design of the new rotor, reducing the probability of failure and reducing the potential for an adverse impact on the Containmen Licensee management actively tracked indicators of plant performance, regulatory compliance, and maintenance program performanc Their observations and self-assessments were used to carry forward safety initiatives such as the procedure upgrade program and component labelin Plant management also emphasized their requirement for the highest degree of procedural compliance to station personnel, i

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The quality of Licensee Event Report (LERs) has improve LERs w m thorough and included detailed, well-written descriptions and root cause analyses. Effective attention was paid to the analyses: there were no repeat events due to inadequate corrective actions of root cause. As described in Section V.C, many LERs detailed the discovery of inadequacies in analysis, design, and testing which occurred in the previous assessment perio Generally, the number of events requiring LERs has significantly dropped (from about 40 to about 30).

The licensee has been proactive in taking actions on industry events such as loss of decay heat remova Additional operator training conducted before the outage included a review of other utility experiences and prevention and identification of such events. Resources were also dedicated to early reaction to steam generator tube / anti-vibration bar wear and inspection for incore thimble tube thinnin During this assessment period, PORC reviews of special test and der 'gn change safety evaluations were observed to be thorough, with strong emphasis on system interaction However, one violation was identified relating to a special flow test of the Residual Heat Removal (RHR) Syste (The test was conducted during the last SALP period.) This resulted in overheating of an RHR pump bearing. The ,

NRC Probabilistic Risk Assessment inspection identified that the test safety an- '

alysis did not identify the need for limitations on controlled parameters or pro-vide appropriate quantitative control guides. During this SALP period, the licen-see strengthened administrative controls and emphasized the need for thorough technical reviews of items prior to presentation to PORC. Examples of these strengthened reviews included the single failure reviews of charging system and service water cooling to the RHR pumps, and the charging pump shaft failur Licensing activity during the current SALP pericd remained very high, Fi f ty-five licensing actions were completed during this 16-month rating period compared to 45 licensing actions completed during the previous 13-nonth rating period. In addition to routine actions, mtjor activities completed were an extension of the license term to 40 years from ssuance of the operating license, the Cycle XV re-load package, completion of the small break LOCA analysis (TMI Items II.K.3.30 and II.K.3.31), completion of non-LOCA transient analysis, and the partial completion of hardware modifications to the ECCS to resolve discovered deficiencies in long term decay heat removal. The staff found that excellent licensee understanding of the licensing issues usually was reflected in technically sound submittal The previous SALP noted several submittals that were untimely and/or inadequate for review. In addition, several long-standing NRC concerns such as the NUREG-0737 TMI Technical Specification (TSI upgrade and the degraded grid voltagt TS were unresolved. The TMI TS upgrade was submitted as of July 1988 and, af ter a February 25, 1988 meeting with the licensee, a detailed submittal on degraded grid voltage was received on August 29, 1938 (after the SALP period). Implementation of the licensee's integrated implementation schedule should significantly improve the ability to submit comprehensive submittals on tim The integrated schedule will allow the licensee to prioritize all work for the plant based on safety and cost, and to provide a long term schedule. The basis for the prioritization is the In-tegrated Safety Assessment Program (ISAP), to which the licensee remains committe Effectiveness of the integrated schedule was demonstrated during the refueling

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outage when the licensee met all mdor milestones. Our experience to date with integrated implementation schedules is that the licensee has demonstrated that they can optimize both NRC and licensee resources while maintaining or improving plant safety, reliability and availabilit During the SALP period, the NRC staff evaluated the licensee's 10 CFR 50.59 reviews of the thermal shield repair, the reactor protection system (RPS) upgrade, and the charging pump ESF logic. These reviews included meetings, conference calls, and written requests for additional informatio The licensee made conservative as-sumptions to determine the existence of unreviewed safety questions. The RPS uo-grade review required more than normal interaction but, overall, the plant design ,

change packages were found to be appropriately detailed and technically complet The licensee used in-house capability to perform and maintain a probabilistic safety study (PSS), and was a leader in the use of probabilistic risk assessment (PRA). Effective use of PRA has increased licensee understanding of the plant and its vulnerabilities, and facilitated making effective modifications to reduce the core melt frequency and support various licensing actions. After a recently iden-tified charging pump single failure vulnerability, the licensee was able to perform an expedited single failure analysis using cut sets from the DSS. This review re-suited in the identification of a residual heat removal (RHR) pump cooling single f'.ilure vulnerability which the licensee quickly correcte Site use of the PSS increased. Increased surveillance and preventive maintenance was used to improve availability of various equipments. For example, in response to the recent charging pump shaf t failure, the PSS was used to justify operation beyond an administrative control limit more stringent than NRC requirements. PSS data identified increased surveillance on other safety equipment that would improve its availability and thereby offset the increased risk caused by the loss of the pump for its repair perio Although the plant has not yet converted to Standard-format Technical Specifica-tions (STSs), the station procedures endorse the STSs. All procedures are being upgraded to STS requirements where those are more limiting. For example, a 72-hour STS action statement limiting ECCS component unavailability is incorporated in station procedures even though the present TSs do not have that restrictio Licensee management actively tracked performance indicators relating to plant per-formance, regulatory compliance, and maintenance program performance. Their ob-servations and self-assessments were used to formulate safety initiatives such as the procedure upgrade program and component labelin Plant management has em-phasized their requirement for the highest degree of procedural compliance.

! The ineffectise ALARA program identified in the previous SALP was addressed as a concern during NRC review of the extension of the license term to 40 years from

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the date of issuance of the operating license. As noted in the Radiological Con-trols section of this SALP, ALARA planning and overview substantially improved during this SALP period. The staff concluded that the licensee's significantly upgraded ALARA program was acceptable for the issuance of the license extensio '

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The QA organization, known as Quality Services (QS), had several high level senior engineers as sub-tier supervisors. That provided credibility and an increased cap-ability to perform quality audits in new areas. Comprehensive engineering audits were performed and were meaningful. The current QS capability and recent licensee audits had already been involved with the PBV-type hardware oriented review During this assessment period, there were two trips from power operations due to inadequate maintenance and two trips from criticality at zero power due to elec-trical noise in the nuclear instrumentation. These trips represent inadequate maintenance effectiveness and lateness in nuclear instrument upgrade In summary, corporate and plant managemeni and staff demonstrated dedicated and competent involvement in safety at tne Haddam Neck Plant. The licensee has initi-ated several positive programs such as maintaining a "living" PSS, radiation pro-tection improvements, the procedure upgrade program, and the integrated implemen-tation schedule. In addition, the licensee has upgraded their small break LOCA and non-LOCA transient analysis while achieving this capability in-hous IV. Performance Rating: Category IV. Recommendations: None.

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31 SUPPORTING DATA V.A Allegations There was one allegation concerning the qualification of electrical connectors used with the reactor vessel water level indication system (RI-87-A-51). It was re-ferred to the NRC vendor inspection branch for generic consideratio V.8 Management Conferences On June 18, 1987, a meeting was held at the Haddam Neck site to discuss the pre-vious SALP report finding On July 6, 1988, an enforcement conference was held in the Region I office to dis-cuss the degradation of vital area barrier V.C Licensee Event Reports V. , Report Quality LERs adequately described events, including contributing component or system fail-ures and significant corrective action The reports were thorough, detailed, well-written, and easy to understan Narrative sections typically included de-tails such as valve identification numbers, model numbers, operable redundant systems, dates of completion of repairs, et Root causes were identifie Many LERs presented information in an organized pattern with separate headings and specific information that led to a clear understanding of the even Previous similar occurrences were properly reference V. Causal Analyses Twenty-nine Licensee Event Reports (LERs) and five Safeguards Ever ,s were submitte The LERs were classed as either personnel errors or equipment failure Twenty-four (24) events were classified as personnel errors. Within this group, nine (87-04, -07; 88-01, -04, -05, -06, -10, -13, and -15) were for errors in de-sign made prior to the period. These LERs showed that the licensee was critically examining plant conditions and components against the design bases. Four of the personnel errors were also tied to inadequate procedures (87-18; 88-03, -12, and-503). Two LERs were for missed surveillances (83-11 and 88-14).

Seven LERs addressed nine events related to fire protection systems and and proce-dures (87-04, -13, -14 [three events]; 87-17, 88-02, -03, and -05). These LERs resulted from a positive effort to upgrada fire protectio Ten LERs addressed component or equipment failures which were not tied to personnel or procedure errors. Of those, five (5) concerned mechanical components such as valves or piping (87-09, -10. -11, -12, and -16), three concerned proble's with the nuclear instrument system (87-06, 88-08, and 88-09), and one concerned balance of plant equipment (87-05).

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TABLE 1: ENFORCEMENT / SEVERITY LEVEL AREA 1 2 3 4 5 DEV Total Plant Operations 1 1 2 Radiological Controls haintenance/ Surveillance 1 1 2

. Emergency Preparedness Security 1 1 Engineering / Technical support 2 2 Safety Assessment / Quality Verification Totals: 4 2 1 7 Report /Date Requirement Level Area Violation 213/C7-10 CYAPC0 LTRs D Plant Emergency Operating Proce-4/13/87- 4/15/83 & Operations dures did not adhere to the 4/17/87 9/1/83 Writers Guid /87-21 10 CFR 50.72 5 ' Plant Failure to report inoper-7/15/87- Operations ability of spent fuel pool 8/25/87 cooling syste /87-22 TS 6. Engineering / Special flow test of Resi-8/24/87- Technical dual Heat Removal did not 9/4/87 Support prevent pump overheatin /87-28 10 CFR 50 4 Maintenance / Improper greasing of Lini-11/16/87- app B Surveillance torque Motor-Operated Valve /20/87 213/87-28 10 CFR 50.49 4 Engineering / Six failures to show quali-11/16/87- lechnical fication of safety-related 11/20/37 Support electrical equipmen /88-01 TS Maintenance / Failure to record valve 1/11/88- Surveillance opening time during sur-1/21/88 veillance testin /88-12 10 CFR 72.55 4 Security Failure to maintain vital 5/17/83- area barrier in two case /1/88 T-1-1

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TABLE 2 INSPECTION HOURS SUMMARY Area Hours ?J of Time Plant Operations 1080 2 Radiviogical Controls 627 1 Maintenance / Surveillance 958 2 Emergency Preparedness 149 Security 145 Engineering / Technical Support 871 2 Safety Assessment / Quality Verification 319 Totals: 4149 10 T-2-1

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TABLE 3 LISTING OF LERs BY FUNCTIONAL AREA Area A B C D E X Totals Plant Operations 2 1 3 Radiological Controls Maintenance / Surveillance 6 3 9 18 Emergency Preparedness Security 4 1 5 Engineering / Technical Support 9 9 Safety Assessment / Quality Verification __ __ __ __ __ __

Totals: 12 9 1 3 10 35 Cause Codesa :

A - Personnel Error B - Design, Manufacturing, Construction or Installation Error C - External Cause 0 - Defective Procedure E - Component Failure X - Other

• Cause Codes in this table are based on inspector evaluation and may differ from those specified in the LE SUMMARY OF LERs LER Event Cause Func Number Date Code Area Description 87-04 4/E'87 B ENG/TS Fire Barrier Declared Inoperable Due to Inadequate Design 87-05 4/16/87 E MNT/SUR Water Centaminated Turbine Control Oil Causes Control Valve Malfunction and Rx Trip 87-06 4/21/87 E MNT/SUR Spurious Down Spike on Nuclear Instrumen-tation Causes Turbine Load Runback T-3-1

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Table 3

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I LER Event Cause Func Number Date Code Area Description 87-07 4/22/87 B ENG/TS Groundwater Inleakage into Containment Cable Vault Due to Inadequate Design 87-08 6/25/87 E 0.25 Blown Control Rod Fuse Causes Dropped Rod and Steam Generator Over Feed 87-09 7/18/87 E MNT/SUR Main Steam Safety Valves Fail Lift Pressure Test 87-10 7/30/87 E MNT/SUR Safety Injection Check Valve Has Excessive Leakage

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87-11 7/21/87 E MNT/SUR Containment Penetration Fails Local Leak Rate Test 87-12 8/1/87 E MNT/SUR Steam Cenerators Require 100*. ECT Based on Initial Inspection Results 87-13 8/5/87 A MNT/SUR Inoperable Fire Suppression System Due to Personnel Error 87-14 8/11/87 A MNT/SUR Inadequate Contractor Training / Awareness Results in Inoperable Fire Barriers 87-15 8/14/87 A MNT/SUR Personnel Error Causes Temporary Loss of Spent Fuel Pit Cooling Pumps' Power 87-16 10/9/87 E MNT/SUR RCS Safety Valve As Found Lif t Pressure High Oue to Setpoint Drift 87-17 10/23/87 A MNT/SUR Inoperable Fire Protection System Due to Personnel Error

87-18 11/20/87 0 MNT/SUR Personnel Error Results in Declaration of I EEQ MOVs as Inoperable 88-01 1/14/88 8 ENG/TS Design Error Found In Steam Generator Blowdown Isolation Circuit 88-02 1/10/88 A MNT/SUR Fire betection Subsystems Inoperable Due  :

to Damaged Heat Detectors 88-03 2/4/88 0 MNT/SUR Electric Fire Pump Declared Inoperable Due to High Starting Amperage 88-04 2/25/88 B ENG/TS Post Modification Testing Identified Dropped Rod Circuitry Improperly Wired r

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Table 3 l LER Event Cause Func Number Date Code Area Description 88-05 2/27/88 B ENr /TS Leak Path Renders Cable Vault CO2 System Inoperable 88-06 2/27/88 8 L'q/T S Leak Path Identified in Cable Vault Flood Barrier

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88-07 3/10/88 A OPS Residual Heat Removal System Not Operating in Mode 5 During Plant Heatup 88-08 3/19/88 E OPS Zero Power Reactor Trip Oue to Spurious High Startup Rate Caused by Electrical Noise 88-09 3/22/88 E MNT/SUR Zero Power Reactor Trip Due to Spurious *

High Startup Rate Caused by Electrical Noise 83-10 3/24/88 8 ENG/TS Error Found in Large Break LOCA Analysis 86-11 4/8/88 A MNT/SUR Technical Specification Surveillance Frequency Exceeded for Overpower Trip Tests SS-12 4/30/88 0 MNT/SUR Reactor Trip Due to Improper Installation of Turbine Step Valve Cam Switches 88-13 5/2/88 B ENG/TS Design Deficiency Identified in Motor Operator for Charging Pump Suction Valves 88-14 5/11/88 A OPS Failure to Take Technical Specification Required Samples With Service Water Effluent Monitor Out of Service 88-15 5/18/83 8 EN3/TS Design Deficiency Identified in Residual Heat Removal Pump Seal Coolers SAFEGUARDS EVENTS87-501 11/12/87 A SEC Detection of Weapon at Access Point 83-501 3/1/83 A SEC Detection of Armunition at Access Point 88-502 3/20/88 C SEC Strike of Bargaining Unit Se:urity Per-sonnel 88-503 5/17/88 A SEC Deficient Vital Area Barrier 88-504 5/26/S8 A SEC Deficient Vital Area Barrier T-3-3

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TABLE 4 INSPECTION REPORTS Report Number Dates Inspector Hours Areas Inspected 87-08 3/19/87- Swetland 240 Routine Resident 5/5/87 87-09 3/26/87- Temps 0 Requalification Program Evaluation 5/26/87 87-10 4/13/87- Prell 170 Inspection of E0Ps 4/16/87 87-11 4/20/87- Sherbini 42 Routine Health Physics Inspection 4/24/87 87-12 5/6/87- Swetland 136 Routine Resident Inspection 6/9/87 87-13 5/26/87- Thomas 112 Routine Safety Inspection of Annual 5/27/87 Emergency Preparedness Exercise 87-14 5/4/87- Bicehouse 41 Routine Safety Inspection of Solid Radwaste 5/8/87 Program 87-15 5/20/87- Martin 12 Routine Physical Security Inspection 5/21/87 87-16 5/21/87- Kottan 13 Routine Safety Inspection of Whole Body 5/22/87 Counting Facility 87-17 7/27/87- Pasciak 172 Special Team Inspection of Radiation 7/31/87 Protection Program and Outage Activities 87-18 6/10/87- Swetland 204 Routine Resident Inspection 7/14/87 87-19 7/6/87- Briggs 35 Routine Inspection of Refueling Outage 7/10/87 Preparations 87-20 7/20/87- Sherbini 46 Routine Radiation Safety Inspection of 7/24/87 Outage Preparation' .d Contamination Control 87-21 7/15/87- Shediosky 192 Routine Resident Inspec 'on 8/25/87 T-4-1

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Table 4 Report Number Dates Inspector Hours Areas Inspected 87-22 8/24/87- Murphy 313 PRA Based Inspection of Safety Significant 9/4/87 Activities and Equipment

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87-23 8/3/87- Bissett 42 Routine Inspection of Maintenance Organi-8/7/87 zation, Program and Activities 87-24 8/10/87- McBrearty 38 Routine Specialist Inspection of Licensee 8/14/87 and Vendor ISI Activities 87-25 8/26/87- Shediosky 395 Routine Resident inspection 10/8/87 87-26 8/18/87- Varella 43 Inspection of Foundation Design and Con-9/4/87 struction for the New Switchgear Building 87-27 10/9/87- Shediosky 215 Routine Resident inspection 12/7/87 87-28 11/16/87- Paolino 170 Environmental Qualification Program 11/20/87 87-29 11/30/87- Jang 56 Nonradiological Chemistry Program Inspec-12/4/87 tion 87-30 11/16/87 Sherbini 40 Routine Inspection of Radiological Controls 11/20/87 Program 87-31 12/08/87- Shediosky 72 Routine Resident Inspection 1/12/88 88-01 1/11/88- Kucharsky 89 Inspection of Inservice Test Program 1/21/88 88-02 1/13/88- Shediosky 191 Routine Resident Inspection 2/29/88 88-03 3/1/88- Shediosky 147 Routina Resident Inspection 4/4/88 88-04 1/25/88- Davidson 31 Inspection of Liquid and Gaseous Radio-1/28/88 active Effluents Program 88-05 2/2/88 Sherbini 36 Routine Radiation Program Inspection 2/5/88 88-06 3/7/88- Conte 183 Readiness for Startup Team Inspection 3/11/88 T-4-2

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. Table 4 Report Number Dates Inspector Hours Areas Inspected 88-07 3/14/88- Martin 35 Routine Safeguards Inspection 3/17/88 88-08 4/5/88- Shediosky 249 Routine Resident Inspection 5/16/88 88-09 5/16/88- Winters 35 Steam Generator ISI and Secondary Chemistry 5/20/83 Control 8S-10 5/23/83- Jang 38 Operational Radiological Environment 5/27/80 Monitoring Program 88-11 5/17/88- Shediosky 258 Routine Resident Inspection 7/31/88 88-12 5/17/88- Shediosky 23 Special Security Inspection 6/1/88 88-14 7/18/88- Chaudary 35 Switchgear Building Construction 7/22/88 T-4-3