IR 05000271/1985099
| ML20210E084 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/21/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20210E079 | List: |
| References | |
| 50-271-85-99-01, 50-271-85-99-1, GL-83-28, NUDOCS 8603270197 | |
| Download: ML20210E084 (52) | |
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ENCLOSURE 2 i
f U. S. NUCLEAR REGULATOR'Y COMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
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INSPECTION REPORT 30-271/85-99 VERMONT YANKEE NUCLEAR POWER CORPORATION VERMONT YANKEE NUCLEAR POWER STATION ASSESSMENT PERIOD: NOVEMBER 1,-1984 - OCTOBER 18, 1985 BOARD MEETING DATE: DECEMBER 2, 1985 l
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SUMMARY OF LICENSING ACTIVITIES.............................. T6-1 TABLE 7 - PLANT SHUT 00WNS.............................................. T7-1
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I INTRODUCTION A. Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect the available observations and data on a periodic basis and to evaluate license performance based on this infor-mation. SALP is supplemental-to normal regulatory processes used to ensure compliance with NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to.tne licenree's man-agement to promote quality and safe plant construction and operation.
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A NRC SALP Board, composed of the staff members listed below,. met on December 2,1985 to review the collection of performance observations and data to assess the licensee's performance in <cordance with the guidance in NRC Hanual Chapter 0516, " Systematic ;ssessment of Licensee Performance". A summary of the guidance and perfo mance criteria is provided in Section II of this report.
This report is the SALI- Board's assessment of the salty findings at the Vermont Yankee Nuclear Power Station for the period o' November 1, 1984 i
through October 18, 1985. The summary of findings an0 totals reflect a twelve month assessment period, instead of the 18 mo th period recom-mended by the previous SALP Board. The abridged assessment period was selected by Region I management due to the extended pip replacement out-age that began in September,1985, and the need to bett + utilize inspec- -
tion resources during the plant restart scheduled in the Spring of 1986.
l B. SALP Board Members R. W. Starostecki, Director, Division of Reactor Projects (DRP), Chairman S. D. Ebneter, Director, Division of Reactor Safety (DRS) l W. Kane, Deputy Director, DRP R. R. Bellamy, Chief, Emergency Preparedness & Radiological Protection Branch, Division of Radiation Safety and Safeguards (DRSS)
, E. C. Wenzinger, Chief, Projects Branch No. 3, DRP L. E. Tripp, Chief, Projects Section No. 3A, DRP L. H. Bettenhausen, Chief, Operations Branch, DRS J. H. Joyner, Chief, Nuclear Materials Safety and Safeguards Branch, DRSS V. L. Rooney, Senior Project Manager, Project Directorate No. 2, Office of Nuclear Reactor Regulation (NRR) i B. Sheron, Deputy Director, Division.of Safety Review and Oversight l (DSRO), NRR W.-J. Raymond, Senior Resident Inspector Other Attendees W. J. Pasciak, Chief, BWR Radiological Protection Section, DRSS G. W. Meyer,. Project Engineer, PS 3A, DRP
'M. Shanbaky, Chief, PWR Radiological Protection Section, DRSS P. K.~ Eapen, Chief, Quality Assurance Section, DRS
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C. Background 1. Licensee Activities The plant was operating at 100% power at the start of the assessment period at the beginning of core Cycle XI.
Two forced power reductions occurred during November 1984 due to the loss of a single recirculation pump. The first occurred on November 11, 1984 due to a failed tachometer on the "B" recircula-tion pump motor generator. Full power operation resumed the same day following replacement of the tachomoter. Five days later, a second power reduction occurred due to the loss of the "A" recircu-lation pump when an auxiliary operator inadvertently tripped the motor control center 6A feeder breaker, causing a loss of the lube oil pump. The lube oil pump was restarted and full power operation resumed.
The plant remained at full power until February 6, 1985, when a turbine trip and reactor scram occurred during the performance of an I&C logic test on the core spray system. The plant remained shutdown for 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> until the cause of the event, a faulty test switch in the cere spray system logic, was identified and replaced.
The plant returned to full power operations.
The annual emergency full scale exercise was conducted during the assessment period. Participatiol in this event, in addition to the NRC, included the states of Vermant, New Hampshire and Massachusetts, FEMA and local emergency response organizations. The exercise is discussed further in the report.
The plant began an end of-cycle power coastdown in July,1985. On September 10, 1985, a third power reduction occurred due to the loss of a recirculation pump, which tripped as a result of a false close
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signal originating in the pump suction valve isolation circuitry.
The necessary repairs were made and the reactor coastdown continued until September 20, 1985 when the plant was shutdown for the 1985-86 recirculation pipe replacement and refueling outage.
At the close of this assessment period, the core was completely un-loaded into the spent fuel pool, and the plant was preparing to de-contaminate the recirculation system piping.
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2. Inspection Activities One NRC resident inspector.was assigned to the site during the en-tire assessment period. A second resident inspector was assigned to the site at the end of the assessment period as part of the NRC staffing plan to place two residents at each operating site. The
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total NRC inspection hours for this twelve month period was 2653 hours0.0307 days <br />0.737 hours <br />0.00439 weeks <br />0.00101 months <br /> (resident and region based) with a distribution in the ap-praisal functional areas as shown in Table 4.
NRC Emergency Preparedness teams observed and participated in the the emergency exercise on April 17, 1985.
A special team inspection of the licensee. actions in response to Generic Letter 83-28, Salem ATWS followup, was conducted on June 6-12, 1985.
A special team inspection of the licensee's corrective actions for deficiencies identified in the receipt inspection program was con-ducted on September 2-6, 1985.
Tabulations of Violations and Inspection Activities are attached as Table 3 and 5, respectively.
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II. CRITERIA Licensee performance is assessed in selected functional areas, depending on whether the facility is in a construction, preoperational, or operating phase.
Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas. Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used to assess each functional area.
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Management involvement and control in assuring quality 2.
Approach to resolution of technical . issues from a safety standpoint E 3. Responsiveness to NRC initiatives 4. Enforcement history 5. Reporting and analysis of reportable events 6. Staffing (including management)
7. Training effectiveness and qualification However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is clas-sified into one of three performance categories. The definitions of these performance categories are:
Category 1. Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of per-formance with respect to operational safety or construction is being achieved.
Category 2.
NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and are concerned with nuc-lear safety; licensee resources are adequate and reasonably effective so that satisfactory performance with respect to operational safety o' construction is being achieved.
Category 3.
Both NRC and licensee attention should be increased. Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not ef fectively used so that minimally satisfactory performance with respect to operational safety or construction is being achieved.
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The SALP Board also assessed each functional area to compare the licensee's performance during the last quarter of the assessment period to that during the entire period in order to determine the recent trend for each functional area. The trend categories used by the SALP Board are as follows:
. Improving: Licensee performance has generally improved over the last quarter
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of the current SALP assessment period.
Consistent: Licensee performance has remained essentially constant over the last quarter of the current SALP assessment period.
Declining: Licensee performance has generally declined over the last quarter of the current SALP assessment period.
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III SUMMARY OF RESULTS A. Facility Performance CATEGORY CATEGORY r
LAST THIS Recent FUNCTIONAL AREA PERIOD * PERIOD ** TREND ***
Plant Operations 1 1 Consistent-Radiological Controls 2 2 Consistent Maintenance and Modifications 2 1 Consistent Surveillance 1 1 Consistent
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Fire Protection and.
Housekeeping 2 N/A N/A Emergency Preparedness ~ 1 2 Improving
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Security and Safeguards 1 2- Declining *
Refueling and Outage 1 1 Consistent Management Quality Assurance 2 2 N/A'
Licensing Activities 1 1 Consistent
- May:1, 1983 to October 31, 1984 (18 months)
- November 1, 1984 to October 18, 1985 (12 months) .
- Trend during~last quarter of the current assessment period B. Overall Facility Evaluation During the previous assessment period, increased management attention was necessary in the functional areas of Plant' Operations, Radiation Protection, Maintenance, followup of Appendix R modifications and site
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Quality Assurance. More aggressive involvement was needed in Radiation Protection to formalize the ALARA program, promptly resolve anomalies, and improve the frisking policy. Actions to meet Appendix R requirements needed to be aggressively completed in accordance with NRC positions.
The Maintenance area required strengthening of supervisory oversight and QA/QC controls. The philosophy.regarding plant operations in an anomalous state needed to be more conservative.
l Improvements were noted in the Operations, Maintenance and Fire Protec- l tion areas during the current assessment period. Improvements wore also l noted in the Radiation Protection area in the frisking program and in l the resolution of' technical issues.
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While improvements were realized as indicated above, other programmatic problems were noted by the NRC which were not identified by the licensee.
These included programmatic deficiencies identified as the result of NRC followup of events such as the following: unplanned exposure (Radiological Control), false receipt inspection records (Quality Assurance), and im-proper plant access (Security). In the SALP Board's opinion, there is a licensee mindset stemming from his expertise,_ vast experience and generally good past performance, which results in a reluctance to ac-knowledge weaknesses and hinders recognition of areas where improvements can be achieved. There'is an NRC perception that there is less than full support and/or use by licensee management of the QA/QC function to pro-vide a viable feedback to measure and review station performance. It was noted that once the NRC communicates concerns to the licensee, man-agement actions are generally responsive and thorough to address the is-sues. The SALP Board has concluded that VY management needs to be more aggressive in self-evaluation, 'and more open and receptive to opportuni-ties for improvement.
The strength of the licensee's management controls is most notable in the conservative approach taken to assure safety in plant operations, the planning and control of outage activities and design changei, the effective housekeeping program, the completion of licensing actions, and in the preventive maintenance and operational surveillance programs.
This assessment noted reductions in the numbers of personnel errors dur-ing the performance of routine duties in the Surveillance, Radiological Controls, Operations and Refueling functional areas. Licensee management was effective in assuring an adverse trend did not develop to lower performance.
Although the licensee met commitments to improve procedures and personnel performance in the Maintenance area, previous corrective actions were insufficient to correct deficiencies in the onsite QC " peer" inspection process for maintenance and other plant activities. Management attention is required to assure corrective actions are sufficiently detailed in scope to not only correct the apparent problems when identified, but also to promptly identify and correct other deficiencies that may lessen ef-fective program implementation. Additional actions are also required to improve vendor interface controls.
The overall performance in the support areas of Radiation Protection, Security, and Emergency Planning was not as good as that in functional areas that have a direct bearing on plant operating safety. Additional management attention is warranted in these areas to assure: better over-sight of the security contractor and effective program implementation; the emergency response organization communication and control functions are strengthened; and,' detail and structure is added to the.ALARA program.
The licensee should also review, in particular, the radiation protection program procedures to assure they.are sufficiently detailed to preclude additional problems from occurring.
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The need for open and candid communication with the NRC staff was iden-tified as an area requiring greater management attention during this as-sessment period. While improvements have been noted, additional attention to this item is required to assure licensee identified deficiencies are promptly communicated to the NRC.
Although training was considered in the overall rating of each functional area of this report, a summary is provided below from an overview stand-point. Quality assurance activities affect the assessment in several functional areas, but QA nas also been included as a separate functional
. area in recognition of observed problems, past history, and NRC inspec-tion resources devoted to this area. A summary of activities in the Fire Protection area is provided below to highlight the progress of actions taken in response to problems noted the previous assessment. Assessment of performance in the Housekeeping and Fire Protection / Appendix R Areas are included in.the Plant Operations and Licensing functional areas, respectively.
Training The licensee maintained a strong commitment to training in the licensed and non-licensed programs as demonstrated by the plant specific simulator and training labs now nearing completion and scheduled for initial oper-ation during the next assessment period. Actions are in progress to achieve INPO accreditation for the licensed operator training program.
The generally low rate of personnel performance errors is indicative of training program effectiveness in each functional area. Another indica-tion of effectiveness is the generally high level of knowledge exhibited by personnel in all disciplines.
Fire Protection This area received a Category 2 rating during the last assessment due to the licensee's incorrect implementation of Appendix R requirements and their slowness in responding to the NRC once the deficient areas were noted. Based on subsequent licensee responses to issues and actions 1 to complete a reanalysis of the Reactor building in November 1984, the !
licensee demonstrated an increased sensitivity and responsiveness to Ap-pendix R issues. The routine fire protection programs and plant house-keeping remained an element of strength during this assessment period.
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IV. PERFORMANCE ANALYSIS A. Plant Operations (822 nours; 31%)
1. Analysis The area was rated as Category 1 during the previous period with problems noted in response to NRC initiatives on procedure improve-ments, the need to encourage attention to detail in the performance of routine duties to reduce personnel errors, and, the need to take a more conservative approacn in response to apparent operational anomalies.
Plant operations were monitored by the resident and regional in-spectors during the assessment period. Improvements were noted in all areas. A strong commitment to safety in plant operations was evident in the licensee's response to apparent and potential equip-ment prcblems. Although there were no instances during the period involving operation under anomalous conditions, licensee responsive-ness indicated that improvements can be expected in this area.
Plant and corporate management invohement in plant operational ac-tivities have been evident by plant visits, routine reviews of logs, and tours of the facility. Management, actions were completed to stabilize supervision of the Operations Department, and.the restruc-turing of the operations support staff should be beneficial in de- ,
veloping resources from within the department. The transition be-tween Operations Supervisors occurred smoothly, and actions were taken to define the incumbent's duties within the restraints of Technical Specification 6.0 pending completion of a senior operator's certification.
Plant operators have consistently shown a good overall understanding-of plant systems and status, and are sensitive to equipment problems that may involve technical specification LCOs. Operators make con-sistently conservative calls regarding equipment operability, and questions regarding. technical specification LCOs are discussed with the NRC staff before they become compliance issues. Plant logs and records are well maintained. Operations personnel and the Opera -
tions Supervisor in particular have displayed positive and conser-
-vative approaches toward safety and regulatory compliance. The lic-ensee demonstrated an aggressive and conservative response to equip-ment problems and operability issues during the assessment period.
No generic or overall programmatic weaknesses were noted as a result of the two sets of-license examinations given during the assessment period in January 1985 and in March 1985. Three of the four candi-dates for upgrade to SR0 or Instructor Certification in January failed due to weakness in theory and procedures. The five candi-
-dates examined in' March passed the written exam and demonstrated
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an appropriate depth of knowledge during the oral examinations.
Vermont Yankee has had training department organization changes within 'the lest six months and is continuing to upgrade their training program. The simulator installation has'been delayed until early 1986. The overall training program effectiveness for both requalification and initial license training is expected to improve greatly with the use of the simulator.
One area where management oversight of operator training was lacking concerned the effort to implement the new symptom oriented emergency operating procedures (EOPs) without full support ~from the operator ranks. Operator questions regarding the new E0Ps were not fully answered and, even though the proposed procedures and plans were adequate, that information was not adequately communicated to the operators. The operators did not receive sufficient training on the new procedures to be familiar enough with them for implementa-tion. There was inadequate management evaluation, sensitivity and/
or communication with licensed operators to identify their lack of readiness to implement the new E0Ps. NRC action was required to solicit further feedback from the operators regarding their readi-ness to implement the E0Ps. When NRC identified the problem in this area, the licensee provided the additional simulator training needed to increase operator familiarity and confidence with the procedures prior to their implementation. Continued management attention is warranted in this area to assure operations supervision remains open and responsive to operator feedback.
There were no violations identified in this area, and the one plant trip during the period (LER 85-04) was caused by equipment failure.
There has been an observed improvement in the area of adherence to procedures. No LC0 violations were identified by either the licen-see or the NRC during the assessment period. There were 6 in-stances of personnel error noted during the period, but only 2 of the 6 had operational significance. The number of personnel errors is considered minimal and improvements in this area were noted.
This is indicative of an effective training program.
NRC staff observations of PORC activity during the assessment period indicate the committee is serving its intended function. Good technical discussions occur on issues requiring resolution and the committee displayed the proper regard for nuclear safety issues.
PORC followup of outstanding items is appropriate and effective.
NRC inspectors noted in January 1985 that sixty-five plant procedures remained unreviewed for a period of up to 17 months past their re-quired biennial review date. The licensee acknowledged that this problem was a continuing concern and noted that the backlog of 1 overdue procedure reviews which numbered 110 in November 1984 had been reduced to 30 in November 1985. This problem was first noted I as a concern during an NRC audit in 1980 and the recurrence of the 1 overdue procedure reviews is addressed further as a QA concern in
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Section'H below. Licensee management attention is required to as-sure PORC reviews of plant procedures are completed in a timely manner.
NRC staff assessment of. control room protocol during the assessrant
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period found that the control room environment is maintained in a manner conducive to safe and efficient operation. The facility was
, consistently maintained in a good condition of cleanliness. Good plant. housekeeping practices during routine and shutdown operations
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were evident throughout the assessment period. The routine fire
. protection program was maintained and well: implemented during the i period. Fire detection and protection equipment were well main-tained and controlled.
A detailed evaluation of LER quality using a sample of 8 LERs issued during L.te assessment period was made by AE0D using a refinement of the basic methodology presented in NUREG/CR-4178. In general, they found these LERs to be of barely acceptable quality based on the requirements contained in 10 CFR 50.73. There were two LERs submitted for this functional area and both were-caused by equipment failures. There were no adverse trends noted. A generally conser-
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vative approach is taken in the reports made under 10 CFR 50.73.
In summary, the strength of the licensee's. management controls in this area is best demonstrated by the~ conservative approach taken to assure safety in plant operations whenever equipment problems or operability issues arise. The long period of operation with only one reactor trip (due to equipment problem) and the minimal. number and significance of personnel errors were especially noteworthy.
2. Conclusion Rating: Category 1. l Trend: Consistent.
3. Board Recommendations Licensee:
Ccntinue..to improve communic'ations within the Operations Department.
Consider the use of PORC subcommittees.for the review of plant pro-cedures to assure biennial review dates are met.
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B. Radiological Controls (351 hours0.00406 days <br />0.0975 hours <br />5.803571e-4 weeks <br />1.335555e-4 months <br />, 13%)
1. Analysis The licensee's Radiological Controls Program was rated as Category 2 during the previous assessment period due to weaknesses in the ALARA and contamination survey programs and problems in the trans-portation program.
During the current assessment period, a major problem in the radi-ation protection program area involving unplanned exposure during Traversing In-Core Probe (TIP) room entry and several other weak-nesses were identified. Six specialist inspections were performed of the Radiological Controls Program plus periodic coverage by the resident inspector. A civil penalty was proposed and a Confirmatory Action Letter was issued regarding the TIP room unplanned exposures.
1.1 Radiation Protection The unplanned radiation exposure of a technician in the TIP room indicated procedures for control of exposures in locked high radiation areas were informal and poorly defined. The technician had not been adequately instructed in precautionary actions or procedures to minimize radiation exposure if high exposure rates were encountered. TIP room entry procedures had not been provided despite suggestions from the NRC that they were needed. Foilowing the unplanned exposure, permanent administrative control procedures regarding TIP room entries and entries into other similar high radiation areas were pre-pared by the licensee in response to-NRC initiatives, including Confirmatory Action Letter 85-15.
Additional weaknetises were noted in licensee procedures con-cerning radiation work permits and personnel dosimetry. Tech-nically sound and thorough revisions were made by the licensee in response to these NRC concerns.
The need for a formalized "As low As Reasonably Achievable" (ALARA) program has been brought to the licensee's attention on several occasions since.the issue was identified during the Health Physics Appraisal,in 1980. Although the licensee's piping replacement contractor had developed and was' implement-ing a formalized ALARA program to support piping replacement, the licensee had not formalized a station wide ALARA program.
The f,LARA program lacked an adequately stated and understood management policy statement providing a commitment to ALARA.
The ALARA committee's charter did not define the term "high radiation exposure jobs" within that committee's purview. Fo r-mal procedures for ALARA instructions, preoperational briefings,
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se of engineering controls, practice in low radiation exposure
, a eas and scheduling tasks to reduce radiation exposures were no in place. Outage activities (outside piping replacement)
wer governed by "VY ALARA Guidelines". Those guidelines were not viewed, approved and implemented as controlled plant ad-minist ative procedures.' Radiation workers were not aware of the mea to input ideas for dose reduction and improved health
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physics actices provided in.the guidelines. This long-stand-ing regula ory issue needs licensee management attention to formalize a improve the station ALARA program. Requiring a more struc red and disciplined approach, in the SALP. Board's opinion, coulc have avoided the unplanned exposure in the~TIP Room. Such a s uctured approach could have been achieved with a more formalize program.
Reviews of routine erations, planning and preparation for the piping replaceme outage and early outage activities in-dicated a generally e ective radiation protection program was being maintained. The diation protection organization and staffing level were gene 11y adequate to support normal opera-tions and the piping repla ement outage. The licensee promptly filled the Health Physicist acancy (i.e., radiation protection manager) when it occurred. 'th the exception of the Outage ALARA coordinator (filled as a collateral duty by the Emergency Response Coordinator), key radi tion protection' staff positions were adequately staffed.
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Selection, training and qualificati programs for replacement
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contributed to generally acceptable p sonnel performance and adherence to procedures.
Documentation of radiation protection act1 ities was generally complete, adequately maintained and availab e. Dosimetry records were well-organized and available.
The total personnel exposure reported for the cility for 1984 was 603 manrems which is about average for BWRs comparable age and operational status.
I n 1.2 Radioactive Waste Management / Effluent Controls
The licensee maintained an effective radioactive waste anage-ment and effluent controls program. Planned releases of iquid radwaste were minimized as a result of prior planning by e licensee to control liquid processing activities. There we e
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no unplanned releases during the assessment period.
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13A use of engineering controls, practice in low radiation exposure areas and scheduling tasks to reduce radiation exposures were not in place. Outage activities (outside piping replacement)
were governed by "VY ALARA Guidelines". Those guidelines were not reviewed, approved and implemented as controlled plant ad-ministrative procedures. Radiation workers were not aware of the means to input ideas for dose reduction and improved health physics practices provided in the guidelines. This long-stand-l ing regulatory issue needs licensee management attention to formalize and improve the station ALARA program. Requiring a more structured and disciplined approach, in the SALP Board's opinion, could have avoided the unplanned exposure in the TIP Room. Such a structured approach could have been achieved with a more formalized program.
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Reviews of routine operations, planning and preparation for the piping replacement outage and early outage activities in-dicated a generally effective radiation protection program was being maintained. The radiation protection organization and staffing level were generally adequate to support normal opera-tions and the piping replacement outage. The licensee promptly filled the Health Physicist vacancy (i.e., radiation protection manager) when it occurred. With the exception of the Outage ALARA coordinator (filled as a collateral duty by the Emergency Response Coordinator), key radiation protection staff positions were adequately staffed.
Selection, training and qualification programs for replacement personnel in radiation protection were generally adequate and contributed to generally acceptable personnel performance and adherence to procedures.
Documentation of radiation protection activities was generally l complete, adequately maintained and available. Dosimetry '
records were well-organized and available.
The total personnel exposure reported for the facility for 1984 was 603 manrems which is about average for BWRs of comparable age and ope ational status.
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1. 2 Radioactive Waste Management / Effluent Controls The licensee maintained an effective radioactive waste manage-ment and effluent controls program. There were no releases of liquid radwaste as a result of prior planning by the licensee l to control liquid processing activities. There were no un-planned releases during the assessment period.
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Staffing and functional positions were adequately identified, authorities and responsibilities were defined, and a generally adequate staff was available. Contra tors performed specialized radwaste treatment operations under defined authorities and responsibilities. A generally effective annual retraining program was maintained in applicable procedures, technical specifications, and related administrative controls, which contributed to a generally acceptable level of personnel per-formance with few personnel errors.
Radioactive waste management and effluent control procedures were generally complete, adequately maintained and available.
Minor technical inadequacies noted during review of procedures were adequately addressed and corrected by the licensee. The licensee made technically adequate changes in procedures fol-lowing an inadvertent Group 3 primary containment isolation and start of the Standby Gas Treatment system during functional calibration (Licensee Event Report 85-05).
1.3 Environmental Monitoring On April 1, 1985, Amendment No. 83 to the licensee's Technical Specifications became effective requiring changes to the lic-ensee's Radiological Environmental Monitoring Program (REMP).
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Management control of the transition from the previous Techni-cal Specification requirements to the requirements of Amendment No. 83 for the REMP showed evidence of planning and assignment of priorities. A systematic review of the changes to the REMP was completed and a management action plan to implement changes to procedures and practices was developed. The transition to the requirements of Amendment No. 83 was completed in a gener-ally timely manner.
REMP procedures were rarely violated. The loss of data from an environmental monitoring station in January,1985 due to a failed sample pump appears as a continuation of previous problems at the sample stations, but no adverse trends in pump performance or the licensee's efforts to resolve the problem were evident for this period. The licensee promptly reported the events.
Review of the training and retraining program effectiveness for the licensee's staff and contractors showed those programs contributing to an adequate understanding of the work and ad-herence to procedures with few personnel errors. An adequate training program was provided in March, 1985 to ensure that operations personnel were aware of the requirements in Amend-ment No. 83. Contractor laboratory personnel received adequate training in their duties.
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1.4 Transportation An effective transportation program was maintained during this assessment period. Program improvements in the areas of qual-ity assurance and training were noted. Quality assurance per-sonnel assigned to shipping activities received effective training in Departnent of Transportation and NRC requirements, waste burial site requirements and other technical areas asso-ciated with radioactive materials shipments. The licensee provided acceptance criteria, specific attributes and regulatory
limits on checklists used in quality control inspections of transportation activities. General indoctrinations and speci-fic training were provided to personnel assigned to radioactive a
materials shipping activities. The training contributed to understanding of shipping requirements, adherence to shipping procedures and few personnel errors.
.
Quality assurance audits of'the above areas were timely, thorough and performed by technically qualified personnel. Actions taken in response to audit findings were timely, technically. adequate and indicative of an effective program for identification and correction of deficiencies in these areas.
2. Conclusion Rating: Category 2.
Trend: Consistent.
3. Board Recommendation Licensee The ALARA program has not been' effective in minimizing radiological
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doses to the VY staff, as evidenced by the exposure of a worker in the TIP room in August of 1985. It is the staff's opinion that the lack of a structured ALARA program contributed to this program in-effectiveness. The Board finds that the recirculation piping re-
,
placement ALARA program is a good example of a structured ALARA
! program, and recommends that this or a similar program form the basis for a structured plant ALARA program.
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i 16 C. Maintenance and Modifications (366 hours0.00424 days <br />0.102 hours <br />6.051587e-4 weeks <br />1.39263e-4 months <br />, 14%)
1. Analysis This area received a category 2 rating during the last assessment period due to maintenance personnel performance errors and the need to strengthen management oversight and QA controls in the maintenance area. No significant problems were identified in the area of modi-fications and the design change control program.
This area was under periodic review by the resident inspector, and three inspections were performed in this area by region-based per-sonnel during the current assessment period.
The design change control program remained a significant licensee strength. Station, corporate and engineering procedures for design changes assure a consistently high level of review and management involvement in the modification process. The program was well im-plemented by qualified personnel who had good familiarity with the administrative process and the facility. No programmatic deficien-cies were noted. One violation identified during the period (IR 85-08) concerned the failure to control changes to surveillance and operating procedures following a design change on the fire protec-tion system, which resulted in the release of the modified system for operations without the revised procedures. The finding appeared to be an isolated incident.
The decision to replace piping in the recirculation /RHR systems was made in 1983 aftet the initial detection of IGSCC. In the interim, the licensee complied with NRC requirements regarding the repair and reinspection of cracked welds. The licensee provided to the NRC good supporting justification for'the interim period of-opera-tion. The justification was based upon the latest available tech-niques for the detection and sizing of IGSCC. These decisions were examples of continued management involvement in the cracking issue.
The planning evident regarding the pipe replacement indicated that licensee management was heavily involved in the decisions which were ;
j made. Staffing for the replacement project appears to be ample in '
that there is a good representation of QA/QC, sufficient craft and supervisory personnel to cope with contingencies, and adequate
- supervisory oversight. l Modifications were previously compieted to meet the Environmental
)
Qualification rule for a majority of the plant equipment required ,
for safe shutdown, and a schedule for qualifying additional equip-
, ment by November 1985 was established with the NRC staff in a timely i manner. Licensee evaluation to justify continued operations for the interim period were adequate. Further licensee reviews during this assessment period identified additional qualification defi-l
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4 ciencies that will require further action to assure EQ requirements are met. None of the equipment deficiencies had safety significance and licensee evaluations to disposition.the items for the interim
) period were adequate. Licensee management should assure that all EQ issues have now been identified and corrected per the established schedules.
The effectiveness of the licensee's actions in response to Generic Letter 83-28 (GL 83-28) entitled " Generic Implications of Salem ATWS Event", and specifically, the areas of Equipment Classification,
Vendor Interfaces and Post Maintenance Testing were reviewed.
Overall, the licensee was thorough in his actions, with one excep-
! tion as noted below. Licensee management recognized the need to make improvements in the equipment classification program and com-
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mitted to a December 1986 completion date for implementation of the necessary changes.
- In the area of vendor interface control, it was noted that the lic-
! ensee's system did not always assure vendor information was current l and_ complete. This fact may impact preventive maintenance, equip-
ment upgrading and replacement, and licensee notification of fail-ures incurred by other users. Further licensee action is warranted in this area to resolve the issue.
The routine preventive and corrective maintenance programs continued to be well implemented by a qualified staff. An improvement has been noted in this area regarding the correct performance of main-tenance activities in accordance with the established procedures.
, The licensee was responsive to NRC concerns by reviewing and im -
proving refueling maintenance procedures as necessary to assure the
'l correct performance of routine activities. The preventive mainten-ance program continues to be well documented in both the I&C and l Mair.tenance areas. Staffing for the area is adequate and the Main- ;
tenance Superintendent position was permanently filled during the assessment period. Supervisor invo.1vement in daily work' activities !
remained consistent with previous observations and an element of j strength.
'
Maintenance of plant safety related equipment was consistently given the right priority. Station personnel were effective in properly.
' diagnosing problems and performing the appropriate repairs to assure problems do not recur. Licensee evaluations regarding inoperable or degraded components were consistently proper. Safety equipment was properly controlled prior to and after removal from service.
Post maintenance testing was well implemented and procedures for maintenance-test activities were technically adequate. The proce-
dures provided criteria and responsibilities for review and approval of post maintenance testing and record keeping requirements. The
.
licensee's post maintenance testing activities remained adequate j j and effective in demonstrating operability of affected systems.
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The good personnel performance in the maintenance and modification areas indicated that training for these areas was effective in as-suring thorough implementation of the programs.
One violation during this period (IR 85-22) concerned the failure to maintain material procurement control of two replacement parts in systems designated as safety related. The parts involved had no safety significance. The licensee promptly responded to this problem by revising its procedures and by upgrading the training provided to stores personnel. The licensee further responded to the issue by initiating a review to determine whether procurement controls were maintained for other work. NRC review of this effort was in progress at the end of the assessment period.
The licensee responded to IEB 79-02 and 79-14, and performed the required actions in an acceptable manner. However, for IEB 79-02, the licensee performed the tests and' analysis only on seismic sup-ports and not on dead weight supports. Because the contribution of dead weight supports was not considered in the design analyses for the seismic supports, the intent of the bulletin was not met when these dead weight supports were excluded from the review. The licensee's engineering evaluations were found adequate to assure that a safety factor of at least 2 existed for all supports of con-cern. Modifications are scheduled to be completed during the shut-down as part of the voluntary seismic reanalysis program that will assure a safety factor of four is restored. A confirmatory action lettor (CAL) was issued to assure that the deadweight supports would be adequately considered. These actions were necessitated by a lack of licensee thoroughness in understanding and implementing actions in response to the bulletin intent. Licensee management attention is warranted on this item to assure the remaining pipe support is-sues are resolved in a timely manner.
The licensee was responsive to NRC initiatives to review and improve the control and QC inspection of routine plant maintenance activi-tiec. However, a QA audit performed early in 1985 identified de-ficiencies in the onsite QC " peer" inspection process and licensee management' took actions to institute temporary interim controls to assure proper documentation inspection practices. Actions to com-plete long term program improvements were in progress at the con-l clusion of the assessment period. The recurrence of program defi-ciencies in the peer inspection of maintenance activities is dis-cussed further in Section I, below as a QA program issue.
In summary, activities in the Maintenance and Modification area were completed by experienced personnel in accordance with well estab-lished programs and procedures, with good regard for safety. Im-provements can be realized by assuring thoroughness in design change reviews, correcting program weaknesses in peer inspection process, and strengthening vendor interface controls. An overall performance improvement was noted in this functional area.
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19-2. Conclusion Rating: Category 1.
Trend: Consistent.
i 3. Board Recommendations Licensee:
Complete actions on modifications indicated above to assure timely resolution of issues (Bulletins 79-02 and 79-14). Complete actions to improve vendor interface controls.
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D. Surveillance (69 hours7.986111e-4 days <br />0.0192 hours <br />1.140873e-4 weeks <br />2.62545e-5 months <br />, 3%)
1. Analysis There were no significant concerns identified in this area during the previous assessment period. The occurrence of personnel errors during routine duties was identified as requiring management atten-
- tion to assure no adverse trends developed.
i i
The operational surveillance program was under periodic review by resident and regional inspectors during the assessment period. One inspection was conducted by a regional inspector in the preservice and routine inservice inspection program areas, and of the program for nondestructive examination of recirculation system welds. The implementation of an operational surveillance program by an experi-enced staff remains a significant strength.
Surveillance activities were completed in accordance with estab-lished controls. Procedural adherence was good. Planning and staffing were adequate, and the surveillance test program was well implemented and maintained. Personnel were well experienced with test activities and the associated testing procedures, and were knowledgeable of the facility, its operation and the equipment under test. There was generally good regard for administrative policies and practices.
Supervisory review of test results was done well and was effective
~
in identifying problems for followup calibration or additional maintenance. One violation in the area concerned the failure to identify and correct discrepant I&C test results for stack gas quarterly calibrations (IR 85-25). The item was an isolated inci-dent and it does not detract from an otherwise excellent performance record. The second violation identified in the area concerned the failure to cycle-a normally open isolation valve in the fire pro-tection loop for the reactor building due to a typog*aphical error in the test procedure. The error should have been identified by Engineering Support review of the procedure revisions and test re-sults.
Surveillance procedures were generally well written, technically adequate and provided the right amount of detail to assure corrdct performance. The actions in progress to upgrade the format of I&C procedures to better assure correct performance is notable. Sur-veillance records were well organized, filed and easily retrievable for independent review and followup of events or performance his-
>
tories. Test results were trended to detect the development of equipment problems.
NRC reviews of the Inservice Inspection area found the program con-
- tinues to be well established and implemented. No problems were noted during the review of the licensee's program for baseline
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ultrasonic examination of the welds in the new recirculation system piping. The ISI and PSI program was well staffed and implemented by qualified personnel. The licensee maintained adequate control over ISI examinations by direct surveillance.
l The Operational Inservice Test program was'also adequately estab-lished and implemented by experienced personnel. The recent change
! in program administration to use the Shift Engineers for results
! review and evaluation is an improvement in the program that will aid in the timely identification of potential equipment problems.
Actions taken to resolve difficulties with portable vibration test equipment enhanced program implementation.
l Two events during the period (LERs 84-24-and 85-02) concerned missed l
surveillances due to scheduling errors, which were relatively in-significant when compared to the large numbers of surveillances
scheduled and performed during the period. .Two additional instances of personnel error were noted in LERs 84-23 and 85-05. Both events
- concerned the generation of a PCIS Group III isolation signal while l calibrating the refueling zone radiation monitors. The events were not operationally significant. Both events resulted from inatten-tion to details and not from deficiencies in training. An improve-ment has been noted overall in performance of routine duties and the reduction of errors.
The total number of reported events in the area was low and no adverse trends or common causes were noted from the reported events.
2. Conclusion Rating: Category 1. '
Trend: Consistent.
3. Board Recommendations None
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22
. Emergency Preparedness (327 hours0.00378 days <br />0.0908 hours <br />5.406746e-4 weeks <br />1.244235e-4 months <br />, 12%)
1. Analysis
!
This area was rated as Category 1 during the previous assessment
- period and no significant problems were identified.
D ing this assessment period, one routine inspection was conducted an ne full scale exercise, which included NRC Region I participa-i tion, was observed.
In revie ing emergency preparedness program changes, NRC identified a need fo improved definition of duties, responsibilities, and lines of au ority for onsite emergency response personnel. Several areas of conc n were also identified in the EP training program.
Several key eme ency response personnel demonstrated difficulty j. in performing do assessment calculations and emergency classifi-
cations, and were familiar with use of Emergency Plan Implementing Procedures (EPIP). ese programmatic weaknesses indicated that this area had not rec 'ved sufficient r.anagement attention or self-evaluation. A review o the licensee's audit program and actions ~
on previous NRC inspectio findings indicated that corrective ac-tions were generally effec 've and timely.
I Consistent with the above fin 'ngs, the licensee's performance dur-ing the full scale exercise in til 1985 indicated deficiencies in the'overall emergency organiza on. Specifically, weaknesses were identified in the areas of co and and control of the emergency response facilities, dissemination o information, and communica-tions/ flow of information. The licer 's performance was assessed
.,
as marginally acceptable. The licensee as agreed to ta.ke actions to: 1) clearly define resptnsibilities a authorities of emergency response personnel in the Emergency Plan; 7. perform training of emergency response personnel; 3) reassess the effectiveness of their overall communications system for disseminatio of information dur-ing emergencies; and 4) to schedule a drill to onstrate use of the new E0F.
i The licensee has been responsive to NRC concerns as d onstrated by completion of a major revision-to the emergency resp se or- )
'
ganization. Effective in September 1985, the Vermont Ya 'ee Emer-gency Mana'gement Organization was established and identifi in the Emergency Plan to more clearly define overall direction and ntrol during emergencies. A drill was also held in September 1985 demonstrate the new E0F and associated changes to the Emergency lan.
No significant problems were identified during that drill. The n EOF facility was declared operational on September 16, 1985, ahead of schedule.
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22A E. Emergency Preparedness (327 hours0.00378 days <br />0.0908 hours <br />5.406746e-4 weeks <br />1.244235e-4 months <br />, 12%)
1. Analysis This area was rated as Category 1 during the previous assessment period and no significant problems were identified.
During this assessment period, one routine inspection was conducted and one full scale exercise, which included NRC Region I participa-tion, was observed.
In reviewing emergency preparedness program changes, NRC identified a need for improved definition of duties, responsibilities, and lines of authority for onsite emergency response personnel. Several areas of concern were also identified in the EP training program.
Several key emergency response personnel demonstrated difficulty in performing dose assessment calculations and emergency classifi-cations, and were unfamiliar with use of Emergency Plan Implementing Procedures (EPIP). These programmatic weaknesses indicated that ,
this area had not received sufficient management attention or self- '
evaluation. A review of the licensee's audit program and actions on previous NRC inspection findings indicated that corrective ac-tions were generally effective and timely.
Consistent with the above findings, the licensee's performance dur- I ing the full scale exercise in April 1985 indicated deficiencies in the overall emergency organization. Specifically, weaknesses were. identified in the areas of command and control of the emergency i response facilities, dissemination of information, and communica- ;
tions/ flow of information. The licensee's performance was assessed j 1s marginally acceptable. The licensee has agreed to take actions I to: 1) clearly define responsibilities and authorities of emergency '
response personnel in the Emergency Plan; 2) perform training of emergency response personnel; 3) reassess the effectiveness of their overall communications system for dissemination of information dur-
,
ing emergencies; and 4) to schedule a drill to demonstrate use of j the new EOF.
The licensee has been responsive to NRC concerns as demonstrated by completion of a major revision to the emergency response or-ganization. In September 1985, Vermont Yankee committed to evaluate the authority and functional responsibility of key managers in the Emergency Plan prior to the next annual Emergency Plan Drill to more clearly define overall direction and control during emergencies.
A drill was also held in September 1985 to demonstrate the new EOF and a. ;ociated changes to the Emergency Plan. No significant prob-lems were identified during that drill. A revision was made to the Emergency Plan to reflect the new EOF facility and it was declared operational on September 16, 1985, ahead of schedule.
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2. Conclusion Rating: Category 2.
Trend: Improving.
3. Board Recommendations
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F. Security and Safeguards (92 hours0.00106 days <br />0.0256 hours <br />1.521164e-4 weeks <br />3.5006e-5 months <br />, 3%)
1. Analysis During this assessment period, one routine and one special physical protection inspection were conducted by region based inspectors.
Routine resident inspections continued throughout the period.
'
Three violations were identified during a routine security inspec-tion. The licensee responded to these violations adequately with I
both short and long term corrective actions. These actions included:
(1)' replacement of various system components whose performance had deteriorated; (2) review of the preventive maintenance program in an effort to upgrade its effectiveness and implementation; (3) re-I view of the functional features and testing of the alarm and access control systems to ensure compliance with industry standards; and, (4) review of supervisory staffing and technical support for the
) program. The comprehensiveness of these actions is a positive in-
, dication of the licensee's responsiveness to NRC identified concerns.
1 Licensee management should ensure that these actions are carried
-
out in a timely and effective manner. ,
Two apparent violations resulting from an access control incident on September 20, 1985 were the subject of an enforcement conference on October 21. The nature of the problems brought into question the adequacy of licensee management oversight of the security pro-gram, and security personnel awareness of the objectives of the program and its implementation.
After identification of the above problems and prior ~ to the en-forcement conference, the licensee formed a special task force to evaluate the total security program and its implementation. While
,
this action and those listed above are noteworthy, it raises ques-tions concerning the effectiveness of the licensee's audit program (further discussed below) and the adequacy of day-to-day supervisory and management oversight, which could have identified the trend, particularly with respect to systems hardware, much earlier. The failure by licensee management to detect this trend may be due in part to the lack of fresh perspective regarding program.implementa-tion. Increased attention by corporate management to the overall program and its effectiveness in meeting physical protection ob-jectives is necessary.
i The licensee's security audit program meets the commitments of the NRC approved Security Plan, but recent NRC inspections identified long standing program deficiencies which indicate that the audits 1 may not have been sufficiently comprehensive or detailed, or that j they focused only on the regulatory aspects of the program without <
consideration of program objectives.
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Seven licensee security. event reports, required by 10 CFR 73.71, were submitted during the assessment period and were considered adequate in terms of timeliness, completeness and compensatory actions.
Staffing of the security organization is consistent with the re-quirements of the security plan. However, the recently established task force should carefully assess supervisory staffing to determine if it is adequate to maintain appropriate oversight of day-to-day program implementation, and whether this responsibility is adequately identified and defined. The security force training and qualifica-tion program is well defined and effective as evidenced by .only one identified event involving personnel-error. That event is attributed to inattentiveness rather than a training deficiency.
However, while security force personnel performed their assigned duties well, their overall awareness and appreciation of physical protection program objectives should be increased so that they are
- able to more readily recognize weaknesses and bring them to man-
- agement's attention. Some examples of problems that could have been identified and corrected by the guard, force included the large number of nuisance alarms; the improper location of a trailer within the protected area; and, the failure of SAS functions to be fully redundant with CAS functions. Additionally, the sensitivity of all plant personnel ~to existing' security procedures should be increased, particularly with respect to the use of access control hardware, in order to reduce unnecessary alarms and associated response.
2. Conclusion Rating: Category 2.
Trend: Declining.
3. Board Recommendations Licensee:
Improve self evaluation and audit program to identify weaknesses before they become program deficiencies. Increase corporate man-agement attention to site activities to add fresh perspective and
'
oversight-of program implementation. Increase the sensitivity of plant personnel to security needs.
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l G. Refueling and Outage Management (147 hours0.0017 days <br />0.0408 hours <br />2.430556e-4 weeks <br />5.59335e-5 months <br />, 6%)
'
1. Analysis Jk) significant concerns were identified in this area during the last assessment period and it was rated as Category 1.
The plant was in the beginning of a planned 32 week refueling and maintenance outage for the last 4 weeks of this assessment period.
All phases of shutdown operational activities completed in prepar-ation for the replacement of the recirculation piping were reviewed.
Plant activities completed and reviewed during this assessment period included: receipt and inspection of new fuel; preparation of refueling procedures; complete defueling of the reactor; inspec-tion of vessel internal components; and, setup of the vessel for decontamination and pipe replacement. Recirculation system decon-tamination activities were in progress at the end of the assessment period. A meeting was also held with licensee staff on July 17, 1985 to review the plans and procedures to control the replacement of the recirculation system.
For the licensee's Cycle XI startup testing, including administra-tive controls for the test procedures, test programs and QA surveil-lance during the startup testing, there was clear evidence of prior planning in the test program. The startup physics tests were con-ducted according to the approved written procedures by adequately trained and qualified personnel. The test program outlined the steps in the testing sequence, set initial conditions and prere-quisites, specified calibration and surveillance procedures at ap-propriate locations and referenced detailed test procedures and data collection. Records were well prepared, complete, and readily re-trievable. There were good QC coverage and audits of startup testing activities.
Routine outage activities were well planned and controlled by the proper level of supervision of station personnel. Plant staff was effectively used to coordinate contractor activities. Daily staff outage meetings are effective in maintaining good communication and coordination between outage groups.and planned activities. Planning for the recirculation pipe replacement work was very thorough and well done, particularly in the areas of the design change package, its safety evaluation, and the ALARA program for the control of work activities.
i Receipt inspections of new fuel were completed by experienced per-sonnel, who were knowledgeable of the procedures, fuel assembly de-sign and specifications, and the inspection equipment. Refueling, in-vessel examination and inspection procedures were technically adequate. Personnel displayed-a good regard for nuclear safety.
Refueling, spent fuel pool activities, and other in-vessel mainten-
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ance and surveillances were conducted by qualified personnel in-ac-cordance with.the procedures and administrative policies. There was good management and QA/QC oversight and management control of contractors. Improved training effectiveness was demonstrated dur-ing refueling activities, and training effectiveness was also evi-dent in the new fuel inspections.
Problems with refueling equipment were minimal and the problems that.
did occur were appropriately dispositioned. Discrepancies noted during in-vessel examinations were followed through with the appro-priate level of detail to assure proper dispositioning of potentially significant problems. Licensee actions to evaluate and disposition questions regarding the previous use of a certain decontamination solution for the recirculation system were appropriate.
The supervision and control of refueling and maintenance outages remains a significant management strength.
2. Conclusion Rating: Category 1.
Trend: Consistent.
3. Board Recommendations NRC The above assessment was based on preparation for and the initial phases of the outage. In view of the nature and length of the outage, a readiness assessment team inspection should be performed prior to plant restart.
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H. Quality Assurance (449 hours0.0052 days <br />0.125 hours <br />7.423942e-4 weeks <br />1.708445e-4 months <br />, 17%) {
i 1. Analysis .
The area was rated as Category 2 during the previous assessment ,
period due to problems identified in the QA program, staffing, '
training, and a QA program that was too narrow in scope and coverage.
Three inspections were performed in this area by region-based per-sonnel during the current assessment period, and the area was under periodic review by resident and regional inspection personnel. The specific problems identified in the previous SALP report were either corrected or in process during this assessment period. Additional QA problems were identified during the current assessment period, and as a result, through discussions with the licensee onsite and at an enforcement conference, the licensee formally committed to make major changes to improve performance. Subsequent NRC inspec-tions indicated that the licensee's program and management involve-ment, when fully implemented, should correct the program areas.
The record storage program and procedures identifying records re-quired to be maintained were satisfactory. An inspection identified problems (violation IR 85-11) involving instances of inadequate re-ceipt inspection and possible false receipt inspection records.
The inadequacies in the receipt inspection and storage program in-cluded: inadequate receipt inspections of safety-related material which were conducted because of inadequate procedures; receipt in-spectors who were not provided adequate training, tools, or guidance to perform their duties; a QA program evaluation of the area which was of questionable effectiveness since it failed to detect the weaknesses identified by the NRC; a preventive maintenance program for stored electrical items which was inadequate; and instances of receipt inspection reports which failed to accurately document the characteristics inspected. None of these inadequacies resulted in actual hardware failures or unsafe plant conditions. An investiga-tion of this area by the NRC's Office of Investigations determined that the false records were not knowingly falsified with the intent to deceive, and there was no attempt by either workers or management to cover up deficient materials. The NRC investigation did confirm that, while licensee management had identified programmatic problems in the receipt inspection area, that information was not quickly identified to upper management levels for action, and corrective actions were not initiated in a timely manner. These actions indi-cated a lack of sensitivity to QA and potential compliance issues by mid-level management and their supervision. Additionally, ac-tions taken during the March 1985 NRC inspection indicated that the Station Staff was less than fully open by waiting until the receipt inspection problems were identified by the NRC inspector before discussing internal findings.
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These problems led to~several discussions with the licensee and an enforcement conference. The licensee was responsive and committed to broad QA corrective measures and management actions. A number of corrective actions were implemented immediately after identifi-cation of these problems during the NRC inspection. These actions were considered appropriate by the NRC. A Task Force reported to the Plant Manager on a number of recommendations for improvement of the. receipt inspection process. These recommendations included
{ extensive procedure revisions, inspection guidelines and staff training placed in effect by August 1, 1985. These activities
'
showed thoroughness and initiative by the licensee in correcting identified problems in the receipt inspection and storage program, i By the end of the assessment period, the revised procurement, re-l ceipt, storage and handling program was greatly improved. Manage-
{ ment provided the needed guidance for performing receipt inspections and was more involved in the program. Considerable improvement was noted in licensee candidness and cooperation with the NRC staff, but additional improvements can be realized.
The NRC identified in 1980 that plant procedures were overdue in their biennial reviews. Corrective actions were initiated at that time to correct the problem. An NRC inspection.in January 1985 noted that the problem had not been corrected. -The licensee ~ac-knowledged that the problem was a continuing concern and a 1984 review of overdue procedures during a QA audit had also identified the need for further corrective actions. This is indicative of a lack of effectiveness in the licensee's internal corrective action program. This lack of effectiveness in corrective actions was'also highlighted by a second problem in this area (IR 85-25), which con-cerned the inability to adequately correct deficiencies in the on-site QC " peer" inspection program. Licensee initiatives to identify problems in the program via a QA audit early in 1985 were notable.
However, the deficiencies noted in this audit in documenting in-
} spections of maintenance activities were a recurrence of problems previously identified by the NRC in 1983. The failure to adequately
'
correct the deficiencies in the maintenance area, and on a plant-wide basis, was indicative of corrective actions in 1983 that were too narrow in scope and which lacked depth of perspective. NRC re-view of actions needed to correct this problem were still in pro-
'
gress at the end of the assessment period.
License actions to correct programnatic deficiencies in the onsite peer QC inspection process were in progress at the conclusion of
'
the period and interim measures to bring the program into compliance with established requirements for outage activities were effective.
Additional licensee management attention is warranted to this item to assure long term corrective actions are completed in a timely manner and are effective.
i
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The quality assurance program was effectively implemented in most functional areas, as reflected in other sections of this report, by the procedures and administrative requirements established and implemented by qualified personnel. The effectiveness of the qual-ity assurance program was most evident in the modification and de-sign change program. QA audits of program implementation were ef-fective in most functional areas, but improvement can be realized in the security and receipt inspection areas by assuring these programs are effective in meeting the stated objectives. The pro-curement and vendor programs were well implemented.
Working level personnel generally exhibit a good attitude towards QA, proper procedures and checklists are in use and the QA/QC func-tions are adequately staffed with personnel with appropriate tech-nical capabilities and training. The audit program, with some ex-ceptions such as the receipt inspection program, is effective with good followup corrective actions.
The problems-in the areas of followup corrective actions as well as receipt inspection, storage procedures and training for receipt inspectors and the low level of management attention prior to NRC identification are indicative of weaknesses in this functional area that require management attention to improve performance.
2. Conclusion Rating: Category 2.
Trend: The Board could not establish a trend based on the infre-quent inspection coverage. The Category 2 rating was the result of improved performance noted late in the assess-ment period.
3. Board Recommendations Licensee:
Complete program improvements in receipt inspection area. Continue efforts to assure candid and open communications with NRC inspection personnel.
Additional attention is needed to assure the onsite " peer" inspec-tion program long term improvements are implemented in a timely manner and are effective in correcting the~ identified deficiencies.
Worker, supervisor, and mid-level management sensitivity to the QA program should be emphasized to assure program problems are promptly identified and prioritized for correction. Actions should be promptly completed to review the overall QA program implementation to assure the requirements of Y0QAP-I-A and 10 CFR 50, Appendix B are met.
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NRC:
Provide additional review of long-term program improvements to assure they are effectively implemented.
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1 32
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i I. Licensing Activities (30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, 1%)
_
1. Analysis i
q Licensing.
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This area was rated as Category 1 during the previous assessment i
period. The licensee's performance during this assessment period i was evaluated based on the following attributes: management in-volvement and control in assuring quality; approach to resolution
of technical issues from a safety standpoint; and, responsiveness i
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to NRC initiatives. The inspection hours listed above represent the NRC staff onsite inspection time required to review the proposed license. amendment for degraded grid protection.
i Vermont Yankee Nuclear Power Corporation and Yankee Atomic Electric Company management have an awareness of the various licensing issues by virtue of extensive experience in the industry, technical exper-tise and active participation in industry and professional organi-zation activities. Management takes actions in a timely manner to
ensure safety issues are properly addressed. Examples of this at-tribute during this report period are the preliminary discussions
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and submittals related to activities in the present pipe replacement
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outage. To assure quality during the pipe replacement outage, a dedicated management team was assigned one and one-half years in advance of the outage. Additionally, the fact that no emergency technical specification changes have been requested during the period evidences consistent planning-by management to take into l account license requirements.
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Vermont Yankee senior management has' sought to identify for correc-tive action, areas the project manager perceived as deficient, in quality or timeliness of response, and has been effective in dealing with areas so identified. Candid discussions between the project manager and licensee management has facilitated resolution of cer-tain complex issues, such as recombiner capability (A-19).
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There was consistent evidence of prior planning and assignment of priorities and decision making was consistently at a level that ensures adequate management review.
Favorable evaluations from the technical reviewers are indicative of the licensee's technical understanding of most issues. The Ver-
mont Yankee engineering staff, in concert with support from the
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Yankee Atomic Electric Company, assures that most engineering work, either done inhouse or performed under its direction by contractors,
adequately addresses complex technical issues. An example of the licensee's initiative and technical capability is the staff's ap-proval, on September 27, 1985, of the use of a fuel performance code developed by the licensee. The review of this code for lic-J
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l ensing purposes required several years and extensive documentation, l and is the first case in which the staff has approved use of a fuel performance code not developed by a major fuel vendor. The licensee frequently forms technical judgements independently from the indus-try, and these judgements are well thought out and supported.
The licensee has shown technical initiative and responsibility in conducting a seismic upgrade program which has already resulted in l structural modifications to the hydraulic control unit assembly rack. Schedular requiremente for follow on improvements to the in-sert and withdraw lines are under consideration by the NRC staff.
The licensee demonstrated a clear understanding of issues, and technically sound and thorough approaches in almost all cases. The licensee completed a reanalysis of the Reactor Building in November 1984, in response to NRC concerns and submitted a report of his findings to the staff for review. The results of this reanalysis was the identification of areas where walls needed to be upgraded to fire walls. The licensee was installing penetration seals in these walls and provided NRC with a closeout schedule for the en-gineering modifications needed as a result of the reanalysis. The licensee implemented acceptable interim compensatory measures until l the modifications were completed. The licensee submitted a modified
! set of exemption requests on April 24, 1985 that are presently under i
! review by NRR. Licensee actions in this area were responsive to i NRC concerns.
Open and effective communication channels exist between the NRC and Vermont Yankee licensing staffs. Effective dialogue between the staffs most times promote prompt and technically sound responses to NRC initiatives. The licensee meets most established commitment dates or provides a written submittal explaining the circumstances l and establishing a new firm date. Despite the obvious problems of I communication and authority presented by the physical separation of the licensee's plant and corporate staff in Vermont from the licensing staf f in Framingham, Massachusetts, licensing activities are handled fairly well. This'is in large part due to dedicated, competent staffs at both locations. Conference calls with the staff are usually promptly established and include appropriate engineering and plant personnel. The Vermont Yankee licensing engincer and/or his management, in most cases, promptly and effectively resolve l issues. The licenree has shown willingness to reallocate resources in order to accomplish schedular improvements required by the NRC (for example, NUREG-0737, Supplement I activities). The improvement in the "no significant hazards consideration" determinations accom-panying proposals for license amendment changes shows responsiveness on the part of the licensee. In summary, the licensee's responses are generally timely, sound, thorough and viable.
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! 2. Conclusion Rating: Category 1.
Trend: Consistent.
3. Board Recommendations t-None.
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I j V. SUPPORTING DATA AND SUMMARIES
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A. Investigations, Petitions and Allegations
! 1. Office of Investigation Report 1-85-008 dated 10/1/85 concerning l the potential willful falsification of receipt inspection records.
l Receipt inspection record inaccuracies were found to be due to pro-
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gram deficiencies rather than record falsifications.
B. Escalated Enforcement Actions 1. Civil Penalties.
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$50,000 civil penalty was proposed on 10/22/85 relating to the un-
, planned TIP Room exposure described in NRC Inspection Report 50-j 271/85-21
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j 2. Actions Pending/ Resolved ,
i IR 83-26 violation for failure to provide protection per Appendix R, III.G.2 for equipment in the Reactor Building. :
j 3. Orders a. Confirmed Emergency Response Capability, 8/29/85 b. Confirmed E0P Implementation Date, 6/6/85
) 4. Confirmatory Action Letters (CAL).
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a. CAL 85-06, Confirmed Actions on IE Bulletin 79-02 Seismic j Pipe Supports, 6/5/85 i
i b. CAL 85-15, Confirmed Actions Following Unintended 8/9/85 '
TIP Room Exposure, 9/9/85 C. Management Conferences
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a. SALP Management Meeting, 1/9/85 b. Mr. Stello, NRC Deputy Executive Director for Regional Operations and Generic Requirements toured VY, met the staff and discussed ;
various topics of current interest, 3/4/85 j c. Enforcement Conference to discuss NRC Inspection Report 50-271/85-11
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results regarding receipt inspections, 4/17/85 d. Management Meeting with VY President to discuss recent issues, i
5/23/85
- e. Management Meeting to discuss analysis results for deadweight l
- - supports on seismic class piping, 5/23/85
- f. Management Meeting to discuss VY's response to the findings observed i during the annual emergency exercise, NRC Inspection Report 50-271/
, 85-27, 7/3/85
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g. Management Meeting to discuss plans and preparation for recircula-tion pipe replacement outage, 7/17/85 h. Management Meeting to discuss Receipt Inspection and Peer Inspection l Program Issues, 8/7/85 l i. Enforcement Conference to discuss NRC Inspection Report 50-271/85-21 results regarding TIP Room controls, 9/4/85 j. Management Meeting to discuss NRC Inspection Report 50-271/84-11 findings regarding placement of containment high range radiation l monitors, 9/4/85 l k. Management Meeting with VY President to discuss recent issues, l
9/24/85 l 1. Enforcement Conference to discuss NRC Inspection Report 50-271/85-31 i
results regarding the 9/20/85 unauthorized security access, 10/21/85 l
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Type of Events:
A. Personnel Error . . . . . . . . . . . . . . 4 i
B. Design / Mfg / Construction / Install Error . . . 0
- C. External Cause. . . . . . . . . . . . . . . 0
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O. Defective Procedure . . . . . . . . . . . . 1 i E. Component Failure . . . . . . . . . . . . . 3 i . <
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- TOTAL 8
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i Licensee Event Reports Reviewed:
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- Reports 84-23, 84-24 and 85-01 to 85-06 Causal Analysis
Three sets of causally linked events were identified.
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, a. LERs 84-23, 84-24, 85-02, 85-03,85-05 and 14 LERs received during
- the last SALP report period were due to personnel error. The
majority of these errors were in the area of Plant Operations, j Radiological Controls and Surveillance. An improvement has been :
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made in this area with the personnel errors occurring less fre- l quently this report period that last.
j b. LERs 84-08, 84-14 and 85-01 involved failures in collecting the
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weekly environmental air sample. One failure involved personnel
) error while the other two incidents involved unrelated equipment '
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T-1-1 TABLE 1 LISTING OF LERS BY FUNCTIONAL AREA VERMONT YANKEE NUCLEAR POWER STATION Area Number /Cause Code Total A. Plant Operations 2E 2 .
8. Radiological Controls IA 1E 2 .
C. Maintenance and Modifications None .
D. Surveillance 3A 1D 4 .
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E. Emergency Preparedness None .
F. Security and Safeguards None .
G. Refueling and Outage Management None .
H. Quality Assurance None .
I. Licensing Activities None .
TOTAL 8 Cause Codes: A. Personnel Error B. Design, Manufacturing, Construction or Installation ~ Error C. External Cause D. Defective Procedure E. Component Failure X. Other
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T-2-1 TABLE 2 LER SYNOPSIS (11/1/84 - 10/18/85)
VERMONT YANKEE NUCLEAR POWER STATION i LER Number Summary Description 84-23 An inadvertent group 3 isolation occurred during normal operation while testing the Reactor Building Ventilation and Refueling Radi-ation Monitors when I&C technicians removed the monitor bypass while a trip signal was still simulated on the monitor.
84-24 Monthly functional testing of the HPCI Torus Water Level system was not performed due to an administrative oversight in scheduling.
85-01 During the weeks of December 31, 1984 and January 7,1985, while environmental air sampling at Station AT2.1, it was discovered that a continuous air sample was not taken as required by TS 3.9.D.2.
j The failed environmental air sampling pump was replaced with a re-i paired spare pump.
85-02 During normal operations on January 28, 1985, upon reviewing of the master surveillance list, it was found that a quarterly calibration of LPCI low reactor pressure #3 channel was not performed during j the week of October 25, 1984 as required by TS Table 4.2.1.
85-03 Monthly river water samples scheduled to be collected during the week of January 13, 1985 were collected 1 week late. This was a result of personal error and contrary to the sampling period allowed by TS 4.9.D.
85-04 Reactor Scram from 100% power on February 6, 1985 due to a failure of the core spray test switch in the Core Spray Logic Blocking Relay
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85-05 On April 2, 1985, during a refuel floor alarm functional calibration, a group 3 primary containment isolation and standby gas treatment initiation occurred due to personnel error.
85-06 On June 6, 1985, a break in the tubing in the system II Drywell Hydrogen /0xygen Analyser resulted in a loss of Primary Containment Integrity for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> through the 1/4" diameter sample line.
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T-3-1 TABLE 3 VIOLATIONS (11/1/84 - 10/18/85)
VERMONT YANKEE NUCLEAR POWER STATION A. Number and Security Level of Violation Severity Level I O
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Severity Level II 0 Severity Level III 1 Severity Level IV 7 Severity Level V 3 Deviation 0 Under Review 2 Total 13 8. Violation Vs. Functional Area Severity Levels
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FUNCTIONAL AREAS I II III IV V DEV A. Plant Operations B. Radiological Controls 1 C. Maintenance and Modifications 1 1 0. Surveillance 2 E. Emergency Preparedness F. Security and Safeguards *2 - TBD 3 G. Refueling and Outage Management H. Quality Assurance 3 I. Licensing Activities TOTALS 1 7 3
- 2 violations -Severity Levels To Be Determined
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C. Summary - Enforcement Data Inspection Inspection Severity Functional Report No. Date Level Area 85-06 1/28-2/1/85 IV QA Failure to take the neces-sary corrective action to improve the timeliness of ;
plant procedure reviews 85-08 2/5-3/4/85 IV M/M Failure to revise operating and surveillance procedures upon completion of fire system modifications V SURV Failure to test a testable valve in the flow path of the vital fire water system 85-11 3/11-15/85 IV QA Inadequate receipt inspec-tion and storage program for safety related systems 85-19 5/20-24/85 IV S/S Failure to complete alarm recording requirements IV S/S Failure to control CAS security IV S/S Duplication of CAS function in SAS 85-21 8/9/85 III HP Failure to adequately train (CP) HP technician for entry into TIP room 85-22 6/3-12/85 V M/M Failure to properly control the installation of safety related replacement parts 85-25 8/5-9/20/85 V SURV Failure to identify dis-crepant results during sur-veillance testing IV QA Failure to implement cor-rective actions to preclude recurrance of deficiencies in the peer. inspection program
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T-3-3 Inspection Inspection Severity Functional Report No. Date Level Area 85-31 9/24-26/85 TBD S/S Failure to control access
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to protected area TBD S/S Failure to control detection aids i
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T-4-1 TABLE 4 INSPECTION HOURS SUMMARY (11/1/84 - 10/18/85)
VERMONT YANKEE NUCLEAR POWER STATION HOURS % OF TIME A. Plant Operations . . . . . . . . . . . . . . . 822 31 B. Radiological Controls. . . . . . . . . . . . . 351 13 C. Maintenance and Modifications. . . . . . . . . 366 14 D. Surveillance . . . . . . . .......... 69 3 E. Emergency Preparedness . . . . . . . . . . . . 327 12 F. Security and Safeguards. . . . . . . . . . . . 92 3 G. Refueling and Outage Management. . . . .... 147 6 H. Quality Assurance. . . . . . . . . . . . . . . 449 17 I. Licensing Activities . . . . . . . . . . . . . 30 1*
TOTAL 2653 100
- Most hours expended in facility licensing activities and operator license activi-ties are not included with direct inspection hour statistics. The 30 hrs reported above resulted from an onsite inspection in support of a TAC on Degraded Grid Protection.
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T-5-1 TABLE 5 INSPECTION REPORT ACTIVITIES (11/1/84 - 10/18/85)
VERMONT YANKEE NUCLEAR POWER STATION Inspection Inspection Report No. Hours Areas Inspected 84-22 88 Routine, Resident 84-24 72 Radiological Controls 84-25 --
SALP 84-26 41 Routine, Resident 85-01 --
License Exams 85-02 108 Routine, Resident 85-03 24 Radiological Controls 85-04 111 Special Safety IE8 79-02 & 79-07 85-05 32 Radiological Controls 85-06 78 Plant Procedures 85-07 56 Startup Testing 85-08 135 Routine, Resident 85-09 125 Emergency Preparedness 85-10 94 Routine, Resident 85-11 75 QA Records Storage Program, Procurement, Receipt Inspection Program 85-12 --
License Examinations 85-13 158 Emergency Drill 85-14 125 Routine, Resident 85-15 24 Enforcement Conference 85-16 --
Number Cancelled
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! Inspectio'n Inspection Report No. Hours Areas Inspected 85-17 72 Radiological Controls
85-18 113 Routine, Resident
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85-19 28 Safeguards 85-20 177 Routine, Resident
! 85-21 5 Radiological Controls 85-22 165 Special Inspection IEB 83-28-Salem ATWS 85-23 122 Routine, Resident 85-24 34 Radiological Controls 85-25 170 Routine, Resident
85-26 146 Quality Assurance Program 85-27 14 Management Meeting 7/3/85 EP Drill Concerns 85-28 37 Radiological Controls 85-29 36 Degraded Grid TAC l
85-30 139 Routine, Resident Outage Activities 85-31 14 Security Event Followup 85-32 35 Surveillance / Modification i
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e T-6-1 TABLE 6 SUMMARY OF LICENSING ACTIVITIES
- 1. NRR/ Licensee Meetings
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February 13, 1985, Project Status Briefing
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February 14, 1985, LOCA Analysis Methods
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July 16, 1985, Fire Prevention, Appendix R,Section III.G Exemption
- Requests 2. NRR Site Visits
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April 1-4, 1985, Detailed Control Room Design Review,In-Progress Audit 1 --
October 15-17, 1985, Pipe Replacement Outage I
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3. Commission Briefing i
None 4. Schedular Extension Granted None 5. Reliefs Granted None 6. Exemptions Granted None 7. License Amendments Granted
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December 4, 1984, Amendment No. 84, Main Steam Line Low Pressure Setpoint
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January 23, 1985, Amendment No. 85, HPCI Automatic Suction Transfer 3
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February 21, 1985, Amendment No. 86, Main Steam Line High Flow Setpoint i
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April 1, 1985, Amendment No. 87, Alternative Staffing Requirements '
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June 6, 1985, Amendment No. 88, Suppression Pool Temperature Limit
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July 9, 1985, Amendment No. 89, Snubbers
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October 9, 1985, Amendment No. 90, Shift Staffing, Organization Chart and l Condensate Tank Level Limit
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[ 8. Emergency Technical Specifications Issued None
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T-6-2 9. Orders Issued
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August 29, 1985, Order Confirming Licensee Commitaients on Emergency Response Capability 10. NRC/ Licensee Management Conferences None
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T-7-1
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TABLE 7 PLANT SHUTOOWNS Date Description Cause November 1, 1984 Beginning of assessment period plant at 100% power February 6, 1985 Automatic Scram Main turbine trip and reac-tor scram due to an inad-vertent trip signal caused by a faulty test switch in the Core Spray Logic.
February 7, 1985 Startup - Continue to full power operation September 20, 1985 Scheduled shutdown. Shutdown for 1985/86 re-circulation pipe replacement and refueling outage.
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no see UNITED STATES
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g NUCLEAR REGULATORY COMMISSION .
? e neaoMe
O E 431 PA'XK AVENUE
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! K No or enussiA. PsNNSYLVANIA 19400
%,...../ DEC 311985 Docket No. 50-271 ENCLOSURE 3 Vermont Yankee Nuclear Power Corporation '
ATTN: Mr. Warren P. Murphy Vice President and Manager of Operations RD 5, Box 169 Ferry Road Brattleboro, Vermont 05301 Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP) Report No.
50-271/85-99
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The NRC Region I SALP Board conducted a review on December 2, 1985 and ei luated the performance of activities associated with the Vermont Yankee Nuclear wer Station. The results of this assessment are documented in the enclosed SALP Board report. A meeting nas been scheduled for January 10, 1986 near the site to dis-cuss this assessment. This meeting is intended to provide a forum for candid dis-cussions relating to this performance.
At the meeting, you should be prepared to discuss our assessment and'your plans to improve performance. Any comments you may have regarding our report may be j discussed at the meeting. Additionally, you may provide written comments within 30 days af ter the meeting. ,
Following our meeting and receipt of your response, the enclosed report, your, re-sponse, and a summary of our findings and ' planned actions will be placed 'in'the.
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NRC Public Document Room. '
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Your cooperation is appreciated.
Sincerely,
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Thomas E. Murley Regional Administrator Enclosure: NRC Region I SALP Report 50-271/85-99
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V2rmont Ycnk:2 Nucisar Power 2
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R. W. Capstick, Licensing Engineer W. F. Conway, President and Chief Executive Officer J. P. Pelletier, Plant Manager Donald Hunter, Vice President Cort Richardson, Vermont Public Interest Research Group, Inc.
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New Hampshire State of Vermont
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TABLE OF CONTENTS
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INTRODUCTION . . . . . . . . . . . . '. . . . . . . . . . . . 1 A. Purpose and Overview. .................. 1 B. SALP Board Members. . . . . . . . . . . . . . . . . . . .
C. Background. . . . . . .
................. 2 II.
CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . 4 III. SUMMARY OF RESULTS .................... 6 A. Fa c i l i ty Pe r fo rma nce. . . . . . . . . . . . . . . . . . . 6 B. Overall Facility Evaluation . . . . . . . . . . . . . .. 6 IV. PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . . . . 9 A. Plant Operations. . . . . . . . . . . . . . . . . . . : . 9 B. Radiological Controls . . . . . . ............
C. Maintenance and Modifications . ............. 16
- ' D. Surveillance. . . . . . . . . . ...... ....... 20
... E. Emergency Preparedness. . . . . . . . . . . . . . . . . . 22 F. Security and Safeguards . . . . . . . . . . . . . . . . . 24 G.-Refueling and Outage Management . ............ 26 H. Quality Assurance . . . . . . . . . . . . . ....... 28 1. Licensing Activities. . . . . . ............
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. SUPPORTING DATA AND SUMMARIES. . . . . . . . *. . . . . . . . 35 A.' Investigation, P.etitions and A) legations. . . . . ... . .
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B. Escalated' Enforcement Actions . . . . . . . . . . . . . . 35 C. Management Conferences. . . . . . . . . . . . 35 D. Licensee Event Reports. . . . . . . . . . . ...... ....... 37 TABLES TABLE 1 - LISTING OF LERS BY FUNCTIONAL AREA .......... T1-1
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TABLE 2 - LER SYNOPSIS ..................... '
T2-1 TABLE 3 - ENFORCEMENT SL'MMARY . . . . . . . . . . . . . . . . . . T3-1 TABLE 4 - INSPECTION HOUR SUMMARY . . . . . . . . . . . . . . . . T4-1 TABLE 5 - INSPECTION REPORT ACTIVITIES ............. TS-1 TABLE 6 - SUMMARY OF LICENSING ACTIVITIES . . . . . . . . . . . . T6-1 TABLE 7 - PLANT SHUTDOWNS . . . . . . . . . . . . . . . . . . . . T7-1
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ENCLOSURE 4 ERMONT YANKEE )
NUCLEAR POWER CORPORATION
. FVY 86-11
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RD 5. Box 169, Ferry Rcad. Brattleboro, VT 05301 ,,
ENGINEERING OFFICE 1671 WORCESTER ROAD
, FRAMINGHAM, MASSACHUSETTS 01701
. TELEPHONE 617-6F2-4100 February 12, 1986 U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attn: Dr. Thomas E. Murley Regional Administrator References: a) License No. OPR-28 (Docket No. 50-271)
b) Letter, USNRC to VYNPC, NVY 85-274, dated 12/31/85 :*
c) Letter, VYNPC to USNRC, FVY 85-82, dated 9/12/85 d) Letter, VYNPC to USNRC, FVY 85-86, dated 9/12/85 Dear Sir Subject: Systematic Assessment of Licensee Performance (SALP Report No. 50-271/85-99) Licensee Comments The purpose of this letter is to provide you with comments regarding your Systematic Assessment of Licensee Performance (SALP) Report No. 50-271/85-99.
We appreciated the opportunity to discuss this report with you on January 10, 1986 during the public meeting held at Vernon, Vermont. In general, we believe
, that tne report is a fair appraisal of our activities during the November 1, 1984 through October 18, 1985 time period; however, as discussed during our meeting, we believe there are certain areas within the report which warrant clarification.
Accordingly, we submit the following comments for your consideration:
(1)Section IV.A.1, Operations The SALP Report states that based upon a sample of eight (8) LER's eval-cated by AE00, our LER's were of " barely acceptable quality."
We have reviewed the AEOD comments regarding our Licensee Event Report (LER's) with our Resident Inspector._ While we cannot disagree that there were some shortcomings in some of our LER's, we certainly do not agree that they were "of barely acceptable quality." We feel that, in some cases, the commenter's observations were subjective and not necessary based on the requirements of 10CFR50.73. It is also noted that several of the comments are purely editorial in nature. It is not clear from the report how heavily these were considered in the final determin& tion of " adequacy".
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VERMONT YANKEE NUCLEAR POWER CORPORATION
U.S. Nuclear Regulatory Commission February 12, 1986 Page 2 Pending clarification by the Resident Inspector of some of the comments and our questions, we will take whatever additional steps are necessary to address all valid deficiencies.
(2)Section IV.B.I.2, Radioactive Waste Management and Effluent Controls The SALP Report states that " Planned releases of liquid radwaste were minimized...." As discussed at our meeting, Vermont Yankee has had no liquid releases during the report period. We would appreciate modification of the SALP Report to reflect this fact, so as to not have the potential for misunderstanding on the record.
(3)Section IV.E.1, Emeroency Preparedness
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The SALP Report states that "Ef fective in September 1985, the Vermont Yankee Emergency Management Organization was established and identified in the Emergency Plan to more clearly define overall direction and control during emergencies. Two points require clarification, as discussed during our meeting.
First, the implication that the Vermont Yankee Emergency Management Organization was established in September 1985 leaves the impression that no such organization existed prior to that time, which is obviously incorrect. We would appreciate your rewording to clarify this point.
Secondly, with respect to more clearly defining overall direction and control during emergencies effective September 1985, as noted in our
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Reference d) letter, Vermont Yankee committed to evaluate the authority and functional responsiblity of kev managers in the Emergency Plan prior to the next annual Emergency Plan Drill. Reference c) noted that Vermont Yankee's new EOF was operational, and that a revision to the Emergency Plan had been issued to reflect the new facility. Your correction of this point, in the interest of clarity, is appreciated.
In general, Vermont Yankee was very disappointed with your rating of our performance in this area. As stated during our meeting, achieving excellence in Emergency Planning is one of Vermont Yankee's highest priorities, and we believe our efforts over the evaluation period were indicative of our commitment. Overall, Vermont Yankee received no items of noncompliance in Emergency Preparedness, nor were there any reportable events in that area. During this same period, we implemented our new EOF, considerably improving upon the old facility. We believe, therefore, that your assessment was based primarily upon our annual drill.
Our experfence, based upon the actual Emergency Plan activation for the withdrawn TIP probe in 1984, is that Vermont Yankee's performance in actual events is substantially better than in drills. We attribute this to a number of factors, as follows:
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U.S. Nuclear Regulatory Commission February 12, 1986 Page 3 o EOF Facilities - The drill was performed, with the NRC, States and Vermont Yankee knowing the marginal acceptability of the EOF facili-ties'to accommodate the large number of responders. This problem was recognized within Vermont Yankee, and factored into the new EOF design, which is now operational.
o Drill as a training tool - Vermont Yankee uses annual drills to augment formal training, resulting in " trainees" in many positions.
This results in, at times, less than smooth drills, but does ensure experienced individuals in key roles, and through having people " play" more than their Plan-assigned position, promotes familiarity with the overall emergency response activities, o Scenario defects - Based on the need to exercise all three states f.
within the Emergency Planning Zone, realistic scenarios are not possible. This results in cerceived difficulties with Vermont Yankee's off-site consequence analysis which are scenario induced, rather than real. Coupled with minor scenario problems (i.e.,
instructions, timing, prompting, time-induced limitations in free-play, etc.), we believe this results in an erroneous impression of Vermont Yankee capability.
o Excessive Personnel - The combination of controllers, observers and players severely taxes the pnysical facilities of the various emergency facilities, raises background noise levels interferring with required communication and impedes movement of personnel and infor-
, mation between various organizations housed at the emergency facili-ties. We believe that the lack of controllers and observers is one reason our actual Emergency Plan Activation ran significantly better than have our drills.
While we do understand that, particularly in emergency planning, there is a substantial subjective component inherent in your evaluation, we believe that providing you with our assessment, and reiterating our commitment to excellence in this area is approoriate.
One other point also noted during our meeting, was that this was the first time the NRC had participated at'a Vermont Yankee exercise. We were -
impressed with the professionalism of the NRC players and particularly with the lack of problems experienced in interfacing with counterparts in our organization. Unfortunately, the NRC players departed immediately upon concluding the exercise. We believe that'a formal critique, involving both NRC and Vermont Yankee's players would have been beneficial and educa-tional, drawing upon the NRC's knowledge of activities at other facilities.
We would recommend such an activity for your consideration when your per-sonnel- are actively participating in an Emergency Planning Exercise.
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- VERMONT YANKEE NUCLEAR POWER CORPORATION
U.S. Nuclear Regulatory Commission February 12, 1986 Page 4 (4) General During our meeting, there was substantial comment regarding free and open
' discussion on the part of Vermont Yankee personnel with the NRC. We would like to take this opportunity to reiterate that it is Vermont Yankee's position that all Vermont Yankee personnel be free and open in their discussions with NRC representatives. If any problems are perceived, we reiterate our request that you bring this problem to the highest level of Vermont Yankee management necessary to remedy the problem.
An opinion was stated that VY is reluctant to acknowledge weaknesses and recognize areas where improvements can be made. Although our experience i and good operational history may lead to this perception, it should also b'e'
recognized that our resources are limited. We must distinguish between good ideas and enhancements, and necessary, regulatory required fixes 'and changes. As such, when the necessity of an enhancement is not obvious, it has to be very clear to us that the enhancement is both valid and necessary. When our performance is perceived by us to be satisfactory in an area, especially one which has been judged satisfactory by the NRC during their audits, it makes these judgements all the more difficult to make.
Again, we appreciated the opportunity to meet with you and discuss the SALP Report. We trust you will consider our feedback in your ongoing evaluation /
assessment process.
t Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION W
Warren P.f. MurphyVYgl Vice President and Manager of Operations
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