IR 05000271/1988099

SALP Rept 50-271/88-99 for Jul 1988 to Sept 1989.Category 1 Assigned in Areas of Maint/Surveillance,Emergency Preparedness,Engineering/Technical Support & Safety Assessment/Quality Verification

ML19354E094
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	01/08/1990
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19354E081	List: IR 05000271/1988099 ML19354E080
References
50-271-88-99, NUDOCS 9001250363
Download: ML19354E094 (37)

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ENCLOSURE INITIAL SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE SALP BOARD REPORT 50-271/88-99

VERMONT YANKEE NUCLEAR POWER CORPORATION-

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VERMONT YANKEE NUCLEAR POWER STATION

ASSESSMENT PERIOD: JULY 1, 1988 - SEPTEMBER 30, 1989 BOARD MEETING:

NOVEMBER 21, 1989 AND DECEMBER 13, 1989

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9001250363 900108

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SUMMARY OF RESULTS II.A.

Overview The SALP Board assessment noted a continued licensee commitment to the safe operation of the Vermont Yankee Nuclear Power Station.

During the assessment period, few challenges to personnel and safety systems occurred, and the plant experienced a low transient rate. Overall performance was indicative of a man-agement involvement in plant operations that was comprehensive and strongly oriented toward nuclear safety.

Technical competence and management strengths were most notable in the functional areas of plant operations, maintenance and surveillance, engineering and technical support, and emergency preparedness.

Several licensee strengths were evident during this SALP period.

Plant operat-ing history,.which included a successful refueling outage and a low plant transient rate attest to good overall management involvement, good operational oversight, a good training program, and a strong orientation at all levels

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towards nuclear safety.

Licensee outage management remains a notable strength.

Continuing management attention resulted in improved maintenance and surveil--

lance programs.

Strong performance in these areas occurred and demonstrated a strong commitment to maintenance of plant systems.

Improvements to the emer-gency preparedness program, which were noted in the last assessment period, were clearly demonstrated by the licensee and resulted in a strong performance in this area. Another notable strength was the overall engineering support.

Both on-site and off-site staffs provided a high level of quality support to l

all levels of plant departments.

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While overall performance in several functional areas remained strong and im-provements were noted in others, the SALP Board assessment noted weaknesses where correction is needed to either prevent possible reduced levels of per-formance or reverse already diminished performance. One weakness related to program documentation and included needed improvements in the procedure review process and formal definition of the maintenance program. Another weakness was the effectiveness of the licensee corrective action process.

This weakness impacted several functional areas and resulted in instances of repetitive prob-

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l lems. Correction of this weakness appears to require a programmatic approach l

by management.

Several weaknesses in the security program resulted in a re-l duced level of performance. Deficiencies included hardware inadequacies, main-tenance and surveillance problems, and lack of adherence to security = proce-dures. Management assessment and correction of these deficiencies is necessary

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to return performance in this area to the previous level.

II.B.

Facility Performance Analysis Summary This SALP report incorporates the recent NRC redefinition of the assessment functional areas. As indicated in the tabulations below, changes include com-bining the previously separate Maintenance and Surveillance areas and adding

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the Safety Assessment / Quality Verification area.

The Saft'. Assessment / Quality Verification section.is largely a synopsis of observations in other functional areas. Additionally, Fire Protection, Licensing, Refueling / Outage, Training, Chemistry Control, and Assuranca of Quality have been incorporated into the remaining functional areas as appropriate.

Rating Rating Functional Area Last Period *

This Period **

Trend ***

Plant Operations

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Radiological Controls

2 Maintenance / Surveillance ****

2(+)/1

Emergency Preparedness 2(+)

Security

2 Engineering / Tech. Support

1 Safety Assessment / Quality Verification

Licensing Activities

Assurance of Quality 2(+)

Training and Qualification Effectiveness

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l January 1,1987 to June 30, 1988

July 1, 1988 to September 30, 1989

Trends are improving (+) or declining (-)

• • • • Previously evaluated as separate areas

Not addressed as a separate area

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III. PERFORMANCE ANALYSIS l

III.A.

Plant Operations (1184 hours0.0137 days <br />0.329 hours <br />0.00196 weeks <br />4.50512e-4 months <br />, 38'4)

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l III.A.I. Analysis The previous S/ LP report rated performance in the 0perations' area as Category 1, with an overall conclusion that the licensee continued to demonstrate a strong commitment to safe plant operations.

Notable strengths included good management involvement and oversight, a strong orientation toward nuclear.

t safety, responsiveness to issues, clear management support for training, and successful Appendix R and E0P programs from an operations standpoint.

Plant operations reflected the positive attitudes displayed by operating and support personnel, however, some overall decline in performance was observed. Areas i

requiring improvement included attention to detail and a better lessons learned function.

Plant activities during routine power operation and shutdown periods were re-viewed during this assessment period. The licensee continued to demonstrate strong and effective management controls that assurea safe facility operations, as evidenced by a good plant performance record, adherence to license condi-

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tions and safe operating practices, and a demonstrated commitment to safety by operators and supervisory personnel. Overall strong plant' reliability was

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demonstrated by an extremely low plant transient rate, few challenges to _ safety.

systems, high plant availability, and a successful refueling outage.

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plant housekeeping-conditions were excellent during power operations as well as

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the outage.

Operators consistently demonstrated a good overall understanding of plant sys-L tems and status, and responded conservatively to equipment' problems that in--

volved technical specification limiting conditiens for operations. Attention to operations and active involvement in oversight were evident in. frequent man-agement tours of the control room and plant.

Routine NRC inspection also con-sistently noted strong management involvement in-response _to non-routine evolu-tions and problems.

There was consistently good communication between opera-tions, upper management, and other plant groups. The licensee demonstrated a strong safety orientation in problem resolution and a conservative approach to

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l p'. ant operations.

Professionalism was evident at all levels. Corporate man-l agement was active in site evolutions during the refueling outage and in re-I sponse to operating problems, as evidenced by frequent site visits, facility.

tours, and meeting attendance.

l Operator alertness was routinely observed by inspectors during day and back I

shifts. Overall, operating shift functioning was evaluated as smooth and pro-I fessional.

Control room distractions were neither allowed nor observed. Acti-l vities were conducted carefully and with sufficient formality.

Shift turnovers I

were consistently thorough and effective.

Operator attitudes were excellent i

during operations and outages. Briefings for tests and infrequent evolutions,

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especially during the outage period, were detailed and involved frequent inter-action among team members.

Frequent observance of evolutions showed that writ-ten procedures were routinely followed.

Control room protocol was maintained conducive to safe operation through the control of access, limiting business to plant operating activities, and through plant management controls that restrict unrelated reading material or other potentially disruptive activities. There is good morale among the operators, and a good sense of cooperation with all plant departments.

In general, opera-tor performance during plant transients and routine operations was noteworthy and reflects the success of the operator training program.

However, during' the

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outage, performance of some activities indicated occasional diminished control.

During that period, two Unusual Events and several engineered safety feature (ESF) actuations were either due to or displayed ineffective communications or a lack'of attention to detail. Generally, unusual or infrequent operations

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received excellent licensee attention and execution, while a less questioning approach was exhibited during some routine or minor activities.

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Five Unusual Events were declared during this assessment period.

Plant staff, management, and operators performed well during event identification, classifi-cation, emergency plan implementation, and shutdown activities.

A conservative approach to event resolution was evident in all cases.

Due to rapid equipment repairs and testing, and problem resolution, events were terminated expedi-tiously.

During this assessment period, one operator licensing examination was adminis-

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tered. Although the small sample size prevented detailed assessment of the l

licensee licensed operator training program, the licensee was effective at pre-I paring the candidate for successful completion of the NRC licensing examina-tion. The licensee Auxiliary Operator (AO) training program produced operators l

that were well trained on plant systems-and had considerable on-the-job experi-The current requalification training program for licensed operators made ence.

a positive contribution to safe operation of the plant, as evidenced by opera-tor performance records that included'a good level of knowledge, adherence to

licensed conditions, and adherence to procedures. The operators reflected-positive attitudes pertaining to training effectiveness and quality of the pro-gram.

Good communications within the operations department were due to effective man-

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agement and coordination by operations department supervision. The operations support staff was used effectively to address technical and procedural issues, to provide an interface with other groups and activities, and to address per-sonnel and administrative matters. Operations and support groups were ade-quately staffed. The licensee maintains a fully staffed six shift control room-rotational schedule, in which overtime is well-controlled and minimized.

The outage organization performed well. The Operations Superintendent was de-signated as Outage Manager, however, other superintendents substituted in his absence to maintain full-time coverage of the position.

Pre-outage planning meetings were attended by the appropriate levels of management and resulted in

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realistic critical path schedules. The-daily outage meetings were attended by all key outage supervisory personnel.

Potential and existing conflicts were resolved, critical path schedules were revised and near-term activities were discussed. Corporate and plant management frequently attended these meetings and made plant tours of outage work areas. Operations personnel remained cog-

nizant of plant conditions and maintained appropriate communications throughout

major evolutions. The licensee ability to minimize activity conflicts on a

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real-time basis was indicative of good organizational communications and proper

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supervision.

This trait was especially evident when resolving major emergent-work issues during the outage.

Several significant unplanned maintenance acti-vities tested the licensee ability to effectively respond to such challenges.

The licensee was highly effective in integrating and accomplishing these acti-vities. The formation of a management oversight group to ensure smooth transi-

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tion through outage milestones was a positive initiative.

Management involve-ment in the preparations for restart was extensive. _ A separate recovery sched-ule was developed.

The Plant Operations Review Committee (PORC) performed ex-tensive reviews of outage activities and temporary system alterations to ensure plant conditions would support restart.

This multi-day management review demonstrated a commitment to safe operations. Overall, outage coordination and control continued to be a notable licensee strength.

Overall, operating procedures supported safe and reliable plant operations.

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major procedure inadequacies were found.

Personnel routinely followed proce-i dures and properly identified and proposed appropriate changes.

However, there I

were some instances where revised procedures proved to be inadequate.

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case a procedural deficiency resulted in a partial ESF actuation during per-formance of the containment integrated leak rate test.

In another case, a par-tial ESF actuation occurred when an inadequate procedure was used to're power a logic cabinet, Additionally, incorrectly revised procedures resulted in a

missed valve leak test surveillance and an inadequate main storage battery sur-

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veillance.

These deficiencies indicate that greater attention to detail in the

implementation of the procedure development and revision process is appropriate

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to assure that the defense-in-depth provided by multiple reviews is achieved.

Licensee efforts to streamline the biennial procedure review process continued to be successful in reducing the backlog of overdue procedure reviews. The

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moving average of overdue procedures was roughly halved over the assessment period, and represents only a small fraction of the total procedure library.

The p0RC review process continued to assure that standing procedures awaiting

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review were acceptable for continued use beyond the biennial review date pend-ing issuance of new revisions.

The quality of Licensee Event Reports (LERs) remained good as determined by analysis of the LERs submitted during the assessment period.

The reports were deemed to be very well written and easily understood with good event descrip-tions. A minor problem with report timeliness was corrected by the end of the

assessment period.

The licensee generally fulfilled other reporting require-ments under 10 CFR 50.72.

Problems associated with effective implementation of 10 CFR 50.72 reporting criteria thresholds were corrected by the end of the assessment period.

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L The plant problem identification system was generally sound. The Potential Reportable Occurrence (PRO) forms were deliberately generated with a low thres-

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hold for identifying a wide range of problems and issues.

The system provided an effective method for trending events and ensured an appropriate level of review and corrective action.

Significant events were generally evaluated and I

reported when necessary and within regulatory requirements as noted above.

Licensee elevation of appropriate significant events to the status of a Plant Information Report (PIR) was a highly effective method of~ focusing resources to investigate and correct pervasive or persistent problems.

Early in the assessment period the licensee experienced several problems with the execution of fire protection measures.

Deficiencies were diverse and in-cluded failures to post technical specification required firewatches, inade-quate fire protection program training, and spurious actuations of fire sup-pression systems that impacted control room operations. Additional fire pro-tection deficiencies are discussed in Section III.F.

The licensee initially responded to these deficiencies as singular events but eventually addressed an assessment of the program as a whole. All identified deficiencies were cor-rected by the end of the assessment period.

Increased management attention to this area was effective in applying appropriate resources to program improve-ment efforts.

Significant improvements in program execution and oversight were

evident.

l In summaru, the licensee continued to demonstrate a strong performance in plant

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operations, with good management involvement and oversight, a strong orienta-tion toward nuclear safety, responsiveness to safety issues, and clear manage-I ment support for training.

Plant operations continued to reflect the positive-l attitudes displayed by operating and support-personnel.

Continuing management I

attention is necessary to ensure improvements are maintained in the fire pro-tection program and during procedure.eviews.

III.A.2.

Performance Rating: Category 1

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III.A.3.

Recommendations Licensee: None.

NRC:

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III.B.

Radiological Controls (248 hours0.00287 days <br />0.0689 hours <br />4.100529e-4 weeks <br />9.4364e-5 months <br />, 8%)

III.B.1. Analysis The Radiological Control Program at Vermont Yankee was rated as Category 2 dur-

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ing the previous assessment period.

Program weaknesses identified last period were the lack of timely responses to NRC concerns, and lapses in the program established to control radioactive material.

During this assessment period, inspectors performed four routine inspections I

and two reactive inspections. The inspectors reviewed the recently activated low level radwaste storage area, radwaste, transportation, radiological en-vironmental monitoring and effluents.

Inspectors also' reviewed radiological controls during a Maintenance Team Inspection. The resident inspectors re-viewed this area on an on going basis.

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Radiation Protection

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The licensee implemented administrative and organizational changes to the health physics department during this assessment period.

These actions were taken to resolve deficiencies, improve effectiveness, and strengthen the man-agement of the radiological control program.

The Ra'diation Protection organization and interfaces with other plant disci-plines were well defined.

Staffing levels were adequate to support routine operations and were appropriately augmented by contractor personnel during out-age activities.

The programs for control of internal -and external personnel exposure continued to function in a generally effective manner. The licensee continued to improve the ALARA program.

Licensee management appeared' committed to an effective pro-gram and supported the use of engineering techniques to minimize occupational radiation exposure.

Examples of techniques and. improvements implemented during the refueling outage included: movement of the moisture separator underwater;

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I use of portable shields; transferring work to low dose areas where possible; hydrolazing piping hot spots; emphasis on personnel using low dose waiting areas; improved use of staging; and, assignment of ALARA coordinators to each department.

Successful use of these techniques resulted in substantial man-rem savings. The pre-outage estimate of 180 man rem was the lowest in licensee history, while the actual expenditure of 155 man rem represented even greater i

improvement. Additionally, incorporation of ALARA principles into routine maintenance activities was noteworthy.

Examples included a RCIC valve repair in the steam tunnel, transfer of vacuum filters from the spent fuel pool, and l

RWCU pump-seal work.

In addition, the licensee enhanced the program for test-ing and reuse of respirator filter cartridges, a weakness noted during the pre-

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l vious SALP period,

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i In contrast, however, deficiencies were identified this period which included the use of inappropriate breathing zone air sampling equipment which incor-porated vortex separators that may not have provided representative sampling.

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A repetitive violation in radiological area posting was effectively addressed by the licensee.

Revisions to procedures and program modifications improved i

the posting process.

Responsiveness to NRC concerns has improved.

Licensee actions were timely fol-lowing an incident early in the SALP period where workers intentionally by-passed controls on high radiation area doors which were locked. However, de-spite the corrective actions, which included training workers in the signi-

ficance of these controls and the necessity of verifying that doors remain I

locked upon exiting, improvements were inadequate as evidenced by two addi-tioaal related incidents later in the period.

Radioactive Waste Management Two inspections of the licensee. solid radwaste program were conducted, one early and one late in the assessment period.

The. licensee consistently impla-mented an effective program for the processing, preparation, packaging, charac-

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terization, and classification of solid-radwaste. The Quality Assurance or-ganization at the Vermont Yankee Site (QAVY) performed periodic audits of the program. The QAVY provided excellent coverage in terms of-scope, depth, and frequency. Overall, the solid radwaste program was evaluated as excellent.

Late in the last assessment period the licensee learned that it had unknowingly disposed of sewer sludge contaminated with low levels of radioactivity to the

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Brattleboro Municipal Sewage Treatment Facility.

This was discovered by a state official who initiated a survey af ter reviewing a newly released NRC In-

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formation Notice on the subject.

The licensee had not reviewed the Information Notice for applicability to their site until it was brought to their attention

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by the state. Once alerted to the problem, the licensee immediately terminated

releases, investigated the issue, ano developed timely and appropriate correc-

tive actions. While the event may suggest that more attention is needed in taking appropriate actions to Information Notices, the licensee overall hand-ling of the event was excellent.

The licensee has constructed an on-site low-level waste (LLW) storage facility, designed to accommodate the LLW produced at the facility for about five years.

The licensee possesses all the equipment and expertise to safely operate the

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on-site storage facility.

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Radiological Effluent Control and Monitoring

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An inspection of the licensee radioactive effluent control program was con-

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ducted near the end of the assessment period, lhe licensee met the Technical Specification requirements with respect to gaseous effluent sampling, analyz-

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ing, and reporting. Air cleaning systems were maintained and. tested in accord-ance with the Technical Specification requirements. Calibration and surveil-lance tests of liquid and gaseous effluent monitors were performed more fre-quently than required by the Technical Specifications.

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C effluents have not been discharged since 1982. These actions provide evidence of outstanding management planning and commitment in the liquid effluent con-trol program.

With the service water effluent radiation monitor out of service from May to

October 1988, the licensee discovered that required daily grab samples had not-been taken from the service water effluent due to a lack of communication and I

understanding between operations and chemistry personnel. -Lack of comprehen-sive corrective action for a previous event (as described in LER 88-01) as well as poor management oversight of the effectiveness of previous corrective ac-tions, as committed to in LER 88-01, resulted in a repeat event.

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the above discovery on October 15, 1988, management conservatively decided that l

daily grab samples of service water effluent would be taken, regardless of the i

operability of the effluent monitor, until administrative controls were up-graded and adequate training was completed for operations and chemistry per-sonnel.

During periods when the effluent monitor was inoperable, no actual release of radioactivity occurred and there were no adverse impacts on the public health and safety.

Late in the assessment period the Radiological Environmental Monitoring Program (REMP) was reviewed.

The review included audits, QA/QC of the contractor laboratory, and calibration and functional tests of the meteorological monitor-ing equipment. Audit findings and recommendations, and QA/QC of the contractor l

laboratory were found to be excell'ent.

Calibration and functional tests of the

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meteorological instrumentation were excellent.

l Early in the assessment > period one confirmatory measurement inspection was per-

-i formed using the Region Mobile Laboratory.

Results of all samples split be-I tween the licensee and the NRC were in agreement.- A noted strength of the Chemistry Department was an experienced and stable staff.

Technical depth and thoroughness of the QA audit was noted.

Senior management attention and fol-

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low-up of the QA audit results were also noted. Overall, the licensee confirma-tory measurement program was excellent.

Transportation The licensee continued to implement an effective transportation program.

Training of responsible staff was thorough, as indicated by-the lack of.per-i sonnel errors; audits were conducted using independent technical specialists;

and QA/QC activities covered a range of activities including packaging, trans-portation, and delivery of packages to carriers.

The overall evaluation of the

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transportation program was excellent, i

a Summary

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In summary, the licensee radiological controls program generally improved and the transportation, chemistry and effluents program remained strong.

The lic-ensee made significant ALARA improvements in operations associated with reactor vessel head removal. Additional management oversight is necessary in improving the effectiveness of corrective actions and is further discussed in Section III.G.

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III.B.2.

Performance Rating: Category 2

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Recommendations

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Licensee: None.

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NRC

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III.C.

Maintenance / Surveillance (969 hours0.0112 days <br />0.269 hours <br />0.0016 weeks <br />3.687045e-4 months <br />, 31%)

III.C.I. Analysis i

The previous SALP report rated maintenance and surveillance performance as two

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distinct functional areas. Maintenance was rated as Category 2 with an improv-ing performance trend.

The Maintenance program was considered a licensee strength as evidenced by high quality of craftsmanship and by overall plant reliability. The Board recommended the licensee review and evaluate the root

causes of balance of plant equipment induced reactor scrams'and age-related

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equipment failures to identify possible underlying trends.. Surveillance was rated as Category 1.

The report concluded the in-service and operational sur-veillance programs remained an overall licensee strength. The Board recom--

mended the licensee expeditiously complete an independent surveillance program verification audit.

Maintenance activities during routine power operations, short notice and un-planned maintenance outages, as well.as, refueling outages were reviewed during this assessment period. Additionally, an NRC Maintenance Team Inspection was conducted during the 1989 refueling outage.

The routine preventive and cor-rective mLintenance programs continued to be effectively implemented, as evi-denced by high equipment availability, reliability and performance. Management maintained a low tolerance for degrLded equipment and typically pursued conser-vative' resolution of maintenance deficiencies.

The strength of the maintenance program is clearly derived from the individuals within the staff.

The main-

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tenance organization is a highly stable, skilled and dedicated staff with ex-tensive plant system knowledge.

Maintenance personnel. ensured work area clean-liness and restoration, thus perpetuating excellent plant housekeeping condi-tions.

Transient equipment is typically observed to be properly stowed and l

secured. Pride of ownership is obvious in the quality of workmanship in daily activities.

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Plant management awareness of maintenance activities was evident during plant l

walk-downs and active involvement in the weekly operations and' daily outage meetings. Similar corporate management involvement was noted periodically dur-ing routine operations and more frequently during outages and periods of sig-nificant activities.

Recently, the licensee conducted two major self-initi-atives in the form of a Safety System Functional Inspection and an extensive maintenance program self-assessment, These initiatives have provided insight into potential programmatic and hardware improvements.

Additionally, a com-puter based management data system is being devel' ped.

Present projections o

l estimate the system to be fully functional by the end of 1991. These initi-atives are indicative of a continuing licensee commitment to improved main-(

tenance program performance.

Engineering support to the maintenance process has been well integrated. The I&C and maintenance departments engineers typically effectively handled daily I

activities. Additional on-site technical expertise is routinely provided by

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Further, engineering resources, as neces-i sary, are provided by YNSD in Bolton, MA. The licensee failure-mode analysis

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and root cause determination of inoperable equipment were deliberate and tech-

nically sound. The recent staffing of additional maintenance engineers has fur-ther improved this function.. The immediate benefit of increased resources has been realized in the identification and resolution of various-HPCI and RCIC trip

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and throttle valve design deficiencies; investigation and analysis of the RHR service water valve stem failure; resolution of slow EDG starting times; as well as, a reduction in the backlog of root cause determinations.

These determina-tions are typically accurate as indicated by a low-incidence of repeat corrective

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maintenance activities. However, the licensee has been frustrated in attempts

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to increase the reliability and availability of the uninterruptible power supply l

system (UPS) and the toxic gas monitoring system (TGM). As a result of diverse random failures and poor design application, the UPS system is scheduled to be

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replaced during the next refueling outage.

The recommendations of an I&C task-force have been only partially successful in improving TGM performance. Addi-tionally, recurring reactor water cleanup (RCU) pump seal package failures have.

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resulted in unanticipated increased departmental man-rem exposures...-Extensive efforts toward improved TGM system and RCU pump performance, as well as the commitment to replace the UPS system, were typical of a conservative licensee

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philosophy toward resolution of equipment reliability issues.

l The staffing levels of the maintenance organization are sufficient to support activities during routine operations.

Contractor and vendor experts'are uti-lized for outages and special projects. Co'ntractor and vendor training and QA programs were required to be consistent with those of.VYNPC.

Departmental man-agement oversight of contractor and vendor activities was well-maintained.

Technical training programs have been properly implemented for maintenance and

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I&C personnel.

Individual near and long term training objectives are clearly defined.

Recently, a mechanical and electrical laboratory within the training center conducted its initial training sessions. A similar I&C laboratory is l

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expected to be functional shortly.

These hands-on facilities should enhance the quality of maintenance activities as well as provide potential reductions in man-rem exposures.

A previously identified deficiency was the lack of a program to ensure vendor manuals were maintained accurate and current. This deficiency had been high-lighted in previous SALP reports and in the maintenance team inspection report.

The licensee has since initiated an intensive program to establish vendor manual accuracy. The program ensures consistent control of the preparation, review, revision and approval of vendor provided technical information. At the

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conclusion of the assessment period, a dedicated contract engineering group had updated approximately two thirds of the vendor manuals. The program is now well-defined and addresses this concern.

Maintenance activities were appropriately prioritized, scheduled, and performed in accordance with safety significance and TS requirements.

Improved planning has greatly reduced the average preventive maint<. nance activity backlog.

Throughout the assessment period, the licensee demonstrated the ability to accomplish a number of significant and diverse maintenance activities during

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short notice outages and power reductions to perform corrective maintenance.

Additionally, the maintenance department performed well during the five Unusual

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Events declared during this assessment period.

In each instance, failed equip-

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c ment was expeditiously repaired and returned to service and the event was ter-T.inated prior to appreciable power reduction.

The maintenance organization continued to exhibit generally excellent perform-ance in outage activities.

In addition to completing scheduled activities in a quality manner, the maintenance organization demonstrated the ability to effec-tively dispose of major emergent work issues. The licensee appropriately re-vised critical path schedules and performed comprehensive engineering evalu-ations to support 4KV emergency bus insulation replacement, RHR heat exchanger division plate inspection and repairs, feedwater check valve stellite guide cracking analysis, and various RHR service water valve repairs.

Excellent external and interdepartmental communications were evident during complex acti-vities.

Notwithstanding excellent personnel and a good equipment'and system reliability record, the maintenance program lacks a formal,' comprehensive plan that clearly documents program policies, responsibilities, and objectives. Absence of a plan hampers the licensee ability to provide a consistent approach to mainten-ance activities and to establish a baseline for determining program effective-By the end of the asses'sment period, the licensee had developed and sub-ness.

stantially documented a formal program plan.

Surveillance activities inspected this assessment period included routine test-ing, calibration control programs, control of measuring and test equipment, and

containment integrated and local leak rate test programs.

The surveillance program continued to be well controlled and properly imple-mented.

Surveillance procedures were technically accurate and provided suffi-cient instruction to help assure proper performance.

The biennial procedure review program helped ensure adherence to TS requirements and the incorpora-tion of content and format upgrades. Quality records were properly maintained, accessible and complete.

Surveillance procedures were performed by highly experienced and knowledgeable personnel who demonstrated extensive understanding of component and instrument operations. A consistently high level of attention to detail and procedural compliance was demonstrated with a noteworthy lack of personnel errors.

Strong interdepartmental communications and coordination routinely ensured necessary plant conditions and prerequisites were established.

Supervisory assistance was observed to be readily available to field technicians throughout surveil-lance activities.

Responsibilities for the IST program were reorganized during the assessment period.

Responsibilities for data acquisition and evaluation were more clearly defined.

The reorganization, in conjune uion with improved test instrumenta-tion, has resulted in consistent data acquisition techniques with increased accuracy, as well as more meaningful data reduction and preventive maintenance l

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recommendations.

Additionally, the valve inspection program was further re-fined.

Particular improvements were obtained in the area of check valve in-spection.

The licensee aggressively pursued the previous SALP recommendation to complete a surveillance program review.

During the assessment period, a comprehensive 100% audit of technical specification surveillances was conducted by an inde-pendent organization.

The licensee expeditiously addressed and corrected the the deficiencies identified by the audit. These deficiencies were primarily surveillance program administrative weaknesses rather than technical inade-

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quacies.

In conclusion, the maintenance and surveillance programs remained licensee i

strengths.

The maintenance organization continues to be comprised of experi-

-

enced and highly dedicated personnel. Management routinely demonstrated a con-servative approach to maintenance issues.

Increased staffing of maintenance engineers has improved design reviews, causal and failure analyses, and reduced work effort backlogs.

Superior performance during short notice and refueling activities continued to be a licensee strength.. The surveillance program con-tinued to be well implemented.

The minimal incidence of personnel errors re-flected an extremely knowledgeable, dedicated, and alart staff.

Incorporation of the surveillance audit corrective actions have further enhanced the admini-stration of the surveillance program,

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III.C.2.

Performance Rating: Category 1 III.C.3.

Recommendations Licensee: None.

NRC:

None.

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III.D.

Emergency Preparedness (163 hours0.00189 days <br />0.0453 hours <br />2.695106e-4 weeks <br />6.20215e-5 months <br />, 5%)

111.0.1. Analysis During the previous assessment period, licensee performance in this area was rated Category 2 with an improving trend.

This assessment noted some excep-

,

tions to an otherwise strong program including a licensee failure to identify, during a QA audit, weaknesses relating to Emergency Action Levels (EAL) con-sistency with federal guidance and incomplete drill documentation, and a fail-ure to review off-site agency interfaces. The previous SALP report also noted licensee organizational changes that resulted in increased visibility and

,

effectiveness of the Emergency Response Organization (ERO).

f During the current assessment period, a full participation and a partial-participation exercise were observed, one routine inspection was conducted, and changes to the emergency plan and procedures were reviewed.

During both the partial participation exercise early in the assessment period-and the full participation exercise near the end of the period,- the licensee demonstrated very effective implementation of the emergency plan and implement-ing procedures.

Dose assessment activities were conservative and pro-active, i

I and licensee interactions with state and local drill participants were effec-l tive, contributing considerably to scenario realism. Use of the new Emergency News Center (ENC), located at corporate headquarters, during. both exercises,-

demonstrated significant improvement in the effectiveness of this Emergency Response Facility (ERF).

Licensee performance during both exercises indicated

.

that a high level of program effectiveness was being consistently maintained.

.

The licensee experienced five Unusual Events (UE) during this assessment period.

Plant staff, management, and operators performed well'during event identification, classification, and emergency plan implementation. A conser-vative approach to event resolution was evident in all cases.

Events'were cor-rectly identified and classified.

Partial mobilization of elements of the emergency response organization was conservative and professionally executed.

An UE involving the start-up transformers involved a partial manning of the Region I Emergency Response Center.

The licensee coordination with Region I and NRR was excellent during this event.

The licensee maintained a strong management commitment to the emergency pre-paredness (EP) program, as evidenced by the significantly improved ENC dis-cussed above and the allocation, during this assessment period, of an addi-tional staff position to the EP program to concentrate on off-site problems and concerns.

This staff augmentation is intended to allow the Emergency Planning Coordinator (EPC) to devote appropriate time to the. on-site portion' of the pro-

gram.

Further, the licensee commitment tracking program was revised to require that the EPC review procedure changes which may affect the EP program for appropriateness and conformance with 10 CFR 50.54(q). The effectiveness of the licensee program was also demonstrated by the fact that no violations or devi-ations were identified during the assessment perio.

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.

,

During the assessment period, the individual to whom the EPC reports was changed from the Assistant to the President to the new Director of External Affairs.

The new position is at an organizational level consistent with the

l previous reporting structure.

The individual appointed to the new position has-j approximately ten years of experience with the 1icensee and Yankee Atomic Elec-

!

tric Corporation in the security, administrative services, and licensing areas.

l l

The licensee made substantial progress in revising EAls to a symptom-based con-figuration in order to promote increased efficiency of use by the control room operators.

During this effort, the licensee was very responsive to NRC com-ments with regard to' consistency with the guidance of NUREG-0654, Appendix 1 and has altered the EALs accordingly.

The use of these revised EALs was effec-tively demonstrated during the full participation exercise.

The EP training program continued to improve.

Training modules are well organi-zed and appropriate for meeting stated objectives.

Training documentation re-flects that the required EP training is current and properly documented to en-sure a sufficient depth of personnel for all ERO positions.

In response to NRC

,

comments, the licensee now requires that the EPC review all EP training proce-l dures and course outlines to ensure conformance with station requirements and l

training objectives. Also, a training matrix has been developed to assure that ERO position training is completed in a timely manner.

The 1988 independent audit of the EP program was performed by the Yankee Nuc-lear Services Division Quality Assurance Group.- The audit was thorough, com-

,

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prehensive, and in conformance with NRC requirements.

The audit was signifi-cantly improved over the audit performed during the previous assessment. Areas of concern identified during the audit were addressed by the licensee and appropriate corrective actions taken. The audit appropriately assessed those areas identified by NRC as deficient in the previous SALP report,

,

In summary, the licensee continued to improve the quality of' emergency pre-paredness procedures, facilities and training.and was responsive to NRC find-ings.

Licensee actions during the two emergency exercises of this SALP assessment period were indicative of a consistent, high level of performance.

The continued active support of upper level management was evident.

III.D.2.

Performance Rating: Category 1 III.D.3.

Recommendations Licensee: None.

NRC:

Non,

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III.E.

Security (105 hours0.00122 days <br />0.0292 hours <br />1.736111e-4 weeks <br />3.99525e-5 months <br />, 3%)-

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III.E.1. Analysis-

,

During the previous two' assessment periods, the licensee's performar,ce was rated as Category 1.. These ratings were based in part on se.ral program im--

l provements, excellent enforcement history and increased liceosee management l

attention to and monitoring of the program implementation, l

i During this assessment period, there were~ two routine unannounced security in-l-

spections by region-based inspectors and routine inspection by the resident

,

inspector continued throughout the period.

>

Several noticeable-strengths:and weaknesses of the licensee's security program

~

were identified by the NRC during this assessment period.

Examples of strengths in the program are as follows: excellent protected area (PA): per-manent lighting; PA barriers that exceed regulatory requirements; well-maintained isolation zones (both exterior and interior); excellent training lesson plans; well qualified, full-time training' instructors; and good liaison with off-site. law enforcement agencies.

Examp.les of the weaknesses in the program are as follows: problems with PA assessment and detection aids; in-I stances of weaknesses in security force member (SFM) knowledge of and adherence

,

l to proc'edures; SFMs-failing to identify and initiate work requests for ineffec-tive and/or malfunctioning equipment; complacency among SFMs; and lack of thorough Quality Assurance (QA) audits of the security program. Although the program generally provides good overall performance, the weaknesses have im-pacted program performance and therefore require site and corporate management attention.

There was a lack of aggressive management support with regard to some. aspects

!

of the security program, as evidenced by deterioration in the assessment aids and perimeter intrusion detection systems and by problems with the testing pro-gram for both systems. Not only were the testing programs ineffective, but-l

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several of the security force members responsible for the testing were.un-familiar with the proper testing procedures.

These problems were compounded by

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I the failure of the annual security audit to identify the weaknesses found by the NRC.

It appears that the audit team focused its attention on compliance, rather than assessing the effectiveness of the security program.

i l

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l Staffing of the contract security force appeared to be consistent with the workload as evidenced by the limited use of overtime.

However,. during the second and third shifts, staffing was only marginally adequate because of the decreased level of staffing on these shifts and the assignment of security

force members to collateral duties.

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Security maintenance records revealed that security equipment was occasionally unavailable or degraded for 30-90 days before maintenance was performed to cor-l rect inoperable or degraded conditions.

This lack of attention resulted in the perception among SFMs that management did not support the security program and appeared to contribute to failures to report similar degraded conditions.

The lack of timely identification and correction of equipment problems, combined f

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with the ineffective testing program for both the perimeter assessment and in-

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trusion detection systems, suggest that the security program has become compli-l ance based, rather than performance based.

During the assessment period, the licensee submitted one change to the security i

l plan under the provisions of 10 CFR 50.54(p). _This submittal was, for the most

!

part, complete and clear. However, another plan change was made incorrectly, in that the change was not followed up by a corresponding submittal to the NRC as require by 10 CFR 50.54(p). This indicates an incomplete understanding of the regulations and the proper procedures regarding plan changes.

As noted previously, the licensee program includes several notable strengths that either continued from, or resulted from action during, prior assessment periods.

For example, the fixed lighting system and the perimeter barrier were well-inaintained and both exceeded minimum regulatory standards.

The lighting helped provide clear assessment capability for alarm response officers in all exterior portions of the protected area (PA). The licensee ensured that isola-tion zones were well maintained and kept clear at all' times, thereby providing an excellent field of view for assessment aids. The licensee security train-ing program continued to receive excellent support from a well-experienced'

j staff and to produce excellent trainir.g lesson plans that clearly incorporated j

the NRC-approved security plan and implementing procedures.

Further, security j

computer upgrades implemented in the previous SALP period have resulted in j

generally reliable and effective computer operations to support the security

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program.

The use of an alarm station simulator to train SFMs was a good licen-j see initiative which was implemented during the last assessment period 'and con-

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tinued during this period.

!

The licensee action in response to and reporting to NRC security events was i

prompt and appropriate.

Two one-hour reports were submitted during the assess-t ment period, one involving the loss of the security computer system, and the

other related to the site access screening program.

However, the licensee re-

vised the security event reporting procedure near the end of the assessment

!

period in a manner that was inconsistent with NRC requirements contained in 10

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CFR 73.71.

This deficiency was indicative of a misunderstanding of regulatory requirements.

In summary, the licensee security program has decreased in effectiveness dur--

l ing this assessment period. Management involvement in certain program aspects was weak. While the perimeter barrier and protected area exterior lighting i

were of excellent quality, the perimeter intrusion detection system and assess-ment aids suffered by failure of some security force members to report problems they identified and by delays in implementing repairs.

The security training group was well-supported and developed excellent programs. 'However, implemen-tation of the program was not fully successful as evidenced by a lack of con-sistent familiarization with security surveillance procedure requirements by security personnel.

The failure of the licensee security program audit group to identify the problems further suggests that the program is not maintaining its previous level of effectiveness.

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III.E.2.

Performance Rating: Category 2

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III.E.3.

Recommendations Licensee:

Assess effectiveness of older security. systems and components.

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l Conduct self-assessment of the program to include:

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Audit focus and thoroughness, as well as expertise of personnel con-ducting annual audits,

,

. Management involvement and oversight of the guard-force.

• NRC:

Conduct inspection and evaluation near the middle of the SALP cycle to assess licensee performance trend.

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a III.F.

Engineering / Technical Support (284 hours0.00329 days <br />0.0789 hours <br />4.695767e-4 weeks <br />1.08062e-4 months <br />, 9%)

!

III.F.1. Analysis The previous SALP report rated performance in. this area as Category 1, with an overall conclusion that the licensee continued to demonstrate a high quality

'

engineering program.

No significant deficiencies were identified in this area.

In general, the quality of engineering support provided by the on-site and off-

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site groups continued to be excellent during this assessment period.

Notable examples of good engineering support and technical expertise included the evaluations and recommended technical resolutions for flaws identified in the feedwater check valves, residual heat removal (RHR) heat exchanger division plate degradation, and emergency electrical bus insulation problems. Aggres-sive licensee review of the applicability of generic issues led to=the identi-fication of several design deficiencies.

In response to NRC questions related to Generic Letter 88-14, " Instrument Air System Problems," the licensee identi-fied two areas for which immediate engineering support was provided to deter-mine if design bases assumptions were violated.

Later in the assessment

,

period, licensee review of a safety system functional -inspection (SSFI) con-ducted at another facility identified a design discrepancy in the power supply for a reactor building closed cooling water (RBCCW) system motor operated valve.

l Licensee engineering reviews identified several design and operational ~def t-ciencies in the RHR service water (SW) system.

The "B" train RHR heat ex-changer SW outlet valve control instrumentation was found to be powered by the

"A" emergency diesel generator thereby rendering redundant portions of the RHRSW system susceptible to single-mode failures. A failure analysis of the same valve in the "A" train identified several deficiencies including improper

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l valve stem heat treatment and a mismatched valve stem and disc nut which re-

'

suited in the issuance of a Part 21 Report.

The licensee also-found the valve body to be installed backwards.

Inservice testing (IST) of two RHRSW check valves failed to determine the inability of the valves to prevent reverse flow.

In addition, the "B" RHR heat exchanger end bell division plate weld was found degraded to such an extent that the plate fractured at the weld.

Engineering evaluation and resolution for each of these issues was sound and effective.

However, the diversity of-the identified deficiencies may indicate the need for a thorough review of the RHRSW system.

The engineering support department (ESD) provides quality planning for plant modifications as exhibited by plant design change requests (PDCRs) and engi-neering scoping memos related-to various plant modifications. Modification packages were organized and included input from plant and corporate organiza-tions which contributed to the successful installation of the related modifi-cations. This is indicative of the excellent communication that is maintained between ESD, other plant organizations, and YNSD corporate engineering groups.

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i In general, licensing submittals to the NRC were found to be timely and well organized. The licensee submittals were complete and well developed. The safety considerations and significant hazards considerations were especially comprehensive, technically sound, and of high quality.

No formal requests for additional information were required for these reviews.

In particular, the licensee Technical Specification change request regarding the alternate testing of ECCS instrumentation was of very high quality.

It was technically sound, supported by a comprehensive risk analysis, and provided good justification for the licensee position.

The analysis was thorough and the presentation of the methodology and data was exceptional.

In addition, a review of the licensee submittal on the environmental and safety aspects of a request to extend the operating license to recapture the construction period was completed. The staff found that the submittal showed a good understanding of NRC concerns and was in full compliance with applicable regulations.

Evidence of an adequate, competent, and well-trained staff was demonstrated by the planning of design changes and modifications which were generally completed on schedule and the timely completion of the projects with a minimum of field changes and rework, k

Plant Licensee Event Reports (LERs) were well written with clear descriptions of the subject events.

Root cause analysis was good, and recommended correc-

,

tive actions were technically correct. When in-depth analysis and evaluation-were required, the problem was referred to YNSD, which was further evidence of the excellent interaction between the plant and corporate organizations.

The engineering support provided to inservice inspection (ISI) was excellent regarding the disposition of nonconforming examination results.

The engineer-ing dispositions were based on technically correct evaluations and showed a good understanding of ASME Code and regulatory requirements.

Close contact between the engineering support department staff and the ISI coordinator en-i t

i hances the capability to assure that open items are tracked and dispositioned l

on a timely basis.

l Despite these areas of strong performance some areas were identified where im-provement was necessary.

Those areas are discussed below.

l The development of justifications for continued operation-(JCO) for some issues

!

was initially weak due to lack of a formal method for the development, review, l

and approval of JCOs.

Initially, JCOs were not required to be. approved by PORC l

and were deficient in some areas including discussion of appropriate interim I

repairs, such as the JC0 for the reactor building railroad access doors.

How-I ever, the quality of JCOs and PORC involvement in their development and imple-

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mentation has improved greatly throughout the assessment period.

In mid-1988, the NRC identified a general programmatic deficiency in licensee l

control of temporary modifications. The deficiency was multi-faceted and in-i volved the lack of a cohesive program including; lack of required PORC review of safety related temporary modifications; lack of approved procedures for the installation and removal of temporary modifications;'and, inadequate control of l

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i temporary scaffolding and radiological shie'. ding.

In response, the licensee revised the temporary modification program an, 'rocedures.

The revisions were comprehensive and addressed the concerns raisei c/ the NRC. However, the lic-

'

ensee was slow in developing and implementing the new program.

Weaknesses were identified by both the NRC and licensee with the fire protec-tion program including design deficiencies in fire protection panels;-fire pro-tection system repair material certification problems; cable vault suppression system testing deficiency; and, inadequate fire barrier and penetration sur-veillances. Adaitionally, as discussed Section III.A., fire detection systems were made inoperable without proper compensation as a result of inadequate fire protection training. The NRC requested that the licensee respond to these

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weaknesses, The licensee initiated actions to improve performance in this area -

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including enhanced training, and accelerated procedure review and revision.

These actions appeared to be effective.

The fire protection program was

,

staffed with two part-time individuals with occasional site visits by the cor-porate fire protection engineers.

The NRC findings in this area resulted in

'

increased licensee management attention during the assessment period.

Licensee management was receptive to findings of weaknesses'and deficiencies in the areas discussed above. Actions taken to improve performance in the areas of fire protection, development and implementation of JCOs, and temporary modi-fications were indicative of manag,ement desire for an efficient and safely-operated plant.

In summary, the quality of engineering support provided by the on-site and off-site engineering groups was generally excellent.

Engineering reviews identi-fied several design and operational deficiencies, root cause analysis of plant

)

LERs was good, and corrective actions were technically correct.

Plant modi-l fication planning and implementation were indicative of a well trained and com-petent staff with open lines of communication among various plant'and corporate organizations. Weaknesses in the development of JCOs, the program for tem-

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porary modifications, and the fire protection program were identified during this assessment period.

Efforts to improve these areas were made by the lic-ensee and were effective.

III.F.2.

Performance Rating: Category 1

,

III.F.3.

Recommendations l

Licensee: None.

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NRC:

None.

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III.G.

Safety Assessment /Ouality Verification (189 hours0.00219 days <br />0.0525 hours <br />3.125e-4 weeks <br />7.19145e-5 months <br />, 6%)

III.G.I. Analysis In previous SALP reports, Assurance of Quality and Licensing Activities were evaluated in separate sections of the report. This new section (Safety Assess-ment / Quality Verification) has been created to consolidate those two sections and also encompass activities such as safety reviews, responses to NRC gene-rated st.fety initiatives, and to provide a broad assessment of the liter.see ability to identify and correct problems related to nuclear safety. This in-cludes the effectiveness of the licensee quality verification function in identifying and correcting substandard or anomalous performance and in moni-toring the overall performance of the plant.

This constitutes the first assessment of this functional area.

For the previous SALP report Licensing Activities was rated Category 1 and Assurance of Quality was rated Category 2, improving.

The current assessment is based in part on interactions with the licensee in the course of normal processing of safety-related licensing actions, such as issuance of license amendments and implementation of NRC Safety Bulletins and Generic Letters. Additional input includes normal inspections of QA act4vi-ties, plant operations, observations of committee activities, and interactio.i with licensee management (see Section III.A. for Plant Operations).

In licensing matters, the primary contact between the licensee ard the staff is the Vermont Yankee Licensing Engineer in the Yankee Atomic Electaic (YAEC) or-ganization.

The distance from the plant and organizational sepatation makes close communication between YAEC and the licensee necessary for this arrange-ment to be workable.

Despite a recent change in the staffing r.f the Licensing Engineer position, this close communication was retained thrsoghout this report period.

This conclusion is based on prompt availability of cognizant personnel for detailed technical discussions and by apparent licensee understanding of NRC staff perspectives.

The fact that no emergency technical specification changes were requested dur-ing the report period demonstrated consistent planning by management to take into account license requirements. The staff processed two routine fire pro-tection program exemptions during the period.

There was also a relief request processed to enable plant restart, after the reload, in early 1989. This re-quest involved flaws in the seats of feedwater check valves.

These flaws, after analysis, did not represent a threat to valve integrity.

Technical qual-ity of these submittals was excellent.

A significant amount of activity during this period continued in the area of the proposed spent fuel pool expansion which was before a hearing board. The final appeal board decision on the fuel pool expansion on July 26, 1989 ruled in favor of the staff, and closed further NRC hearing activity on this matter, exclusive of involvement by the Commission itself.

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Licensing t'oards also completed proceedings on two other interventions during the report priod. On August 9, 1988 a proceeding related to a change in trip system logic testing was terminated after a negotiated agreement by all parties to the proceeding. A second proceeding related to a surveillance testing fre-quency change when engineered safeguards are out-of-service ended on May 23, 1989, following a negotiated settlement.

In all of these hearings, the licen-see competently supported the proposed licensing action, and exhibited reason-able fitribility enabling the proposed action to go forward.

License amend-ments have already been issued in the latter two cases. Staff approval of the spent fuel pool expansion awaits licensee submittal of design details for the enhanced spent fuel pool cooling system. An additional license amendment which is before a hearing board is the proposal for construction period recapture.

The State of Vermont is the sole intervenor in this action, i

The licensee has shown initiative in pursuing improvements to mitigate the con-sequences of postulated severe accidents and to improve the reliability of its Mark I containment. Durino the 1989 refueling outage, the licensee completed installation of an enhanced containment spray capability and improved pressure vessel depressurization reliability by adding a non-safety grade diesel gene-rator to provide power beyond design battery life.

In September 1989 the lic-ensee committed, ir, advance of most other utilities, to install a hardened wet-

,

well vent path by the end of the 1992 refueling outage and to double the auto-matic depressurization nitrogen accumulator capacity.

These voluntary activi-ties followed from the 1986 Vermont Yankee Containment Safety Study, Vermont Yankee management has been cooperative in directing resources to elimi-nate as many of the long standing open licensing actions and outstanding in-spection report items as possible.

Submittals were complete, of high technical quality, and well organized.

Efficient and cooperative interaction by the licensee in supporting licensing actions during the report period led to the (

issuance of twelve license amendments and closeout of eleven other licensing l

actions. Three NUREG-0737 items remain uncompleted and these are rapidly being I

closed out.

Licensee activities in this area have been outstanding.

Vermont Yankee has demonstrated a responsible safety attitude in meeting lic-ensing requirements in a manner which integrates operational and safety con-siderations. One example of this is the VY Safety Parameter Display System (SPDS), which not only met staff design requirements, but also was developed in a fashion which considers other NUREG-0737 Supplement I activities such as ex-panded computer capacity, and operator design involvement.

It is currently in use at the simulator as an operator training aid.

The original plant instal-

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lation schedule slipped somewnat due to contractor problems, which have now been resolved.

The installed plant SPOS is nearly operational.

The Licensee Annual Operating Report for 1988 provided the latest 10 CFR 50.59 reports of this SALP period. Many of the changes were minor or of a temporary nature. One change, that related to new fuel rack installation, was a major design change.

The NRC review of this safety analysis found it to be complete and very thorough. While the issue of fuel pool expansion was in litigation for most of this SALP interval, the adequacy of the licensee analysis for rack

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installation was not questioned by either the NRC nor any of the four inter-venors. Subsequent to the 1988 report, the NRC has had no questions concerning 10 CFR 50.59 analyses performed by the licensee.

The number of licensee initiatives had a continuing positive impact on the quality of plant operations. A few examples included: (1) continued use of an independent management consulting firm to perform periodic reviews of corporate and station policies, procedures and operations; (2) use of an outside engi-neering firm to perform an independent audit of the surveillance program; (3) administrative organization changes to improve oversight, control and per-formance in the procurement and health physics areas; (4) senior corporate officials, line managers, and licensing personnel interface meetings with the NRC; and, (5) emphasis on performance based quality assurance reviews.

The assurance of quality was the stated responsibility of each licensee em-ployee. All personnel were encouraged to perform their work activities in a quality fashion and effectiveness was evidenced by the relathely low number of personnel error related events.

Pride in a job well done is reflected by per-connel throughout the plant.

Employees were also encouraged to report any in-dication of differences between expected plant parameters and observed operat-ing conditions that suggested a potential problem.

Plant resources were directed at understanding these differences.

First-line supervisors frequently reviewed in progress work. The overall effect was quality job performance at all levels within the licensee organization.

i Detailed audits of plant activities were performed by the Quality Assurance Department (OAD) Audit Group. The audits were effective, with the exception of the security audit noted in Section III.E., in identifying quality initiatives l

to improve program effectiveness and included: (1) expansion of the use of l

technical specialists, including personnel from other operating plants, to pro-l vide increased technical capability on the audit team; (2) continuing reliance on performance based reviews, with an increased emphasis on viewing activities

'

from a perspective of technical adequacy; and, (3) use of a classification system for deficiencies and observations that reflected levels of importance to quality that conserves management resources and allows senior managers to focus on the more significant issues.

Audit deficiencies were actively tracked and processed with status reviews by upper level management. The plant operating organization viewed the conduct of audits as important and considered them to be an effective quality activity.

'

The QA surveillance procedures were improved during this period and QA surveil-lance checklists provided auditors with assessment flexibility. As a conse-quence, surveillances continued to be focused and provided performance based i

assessments.

The results of surveillances were discussed in exit meetings with

'

department heads and a monthly status report tracked deficiency resolutions.

l Good communication between the Quality Services Group (QSG) and plant personnel was evident. The QSG supervisor regularly met with group superintendents to discuss activities and program status.

Surveillance categories and schedules were disseminated to solicit plant feedback.

The QSG continues to elicit plant cooperation, feedback, and requests for unscheduled independent surveillance,

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The licensee implemented several additional self-assessment initiatives includ-ing: international information exchange of maintenance and outage practices; use l

of other utilities to provide independent QA assessment of the licensee Quality

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Assurance Program; use of additional QA audits to examine areas of interest or

'

suspected weakness; and performance of an SSFI.

The licensee self-assessment program is comprehensive and effective.

It demonstrates a corporate desire to i

provide the highest standards of quality assurance.

The Plant Operations Review Committee (PORC) performance improved during the assessment period and resulted in effective addressing of nuclear safety issues.

Open and constructive discussions occurred and the committee typically displayed a conservative safety perspective. A notable PORC strength was a comprehensive review of plant conditions prior to startup from the refueling outage.

Deft-ciencies in PORC performance relating to involvement in the temporary modifica-tion process, involvement in tha justification for continued operation (JCO)

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process, and routine reviews of plant operations were corrected during the assessment period. The quality of PORC involvement in these areas improved and resulted in strong performanco by the end of the period.

The licensee experienced difficulty in maintaining an effective corrective action process.

Several NRC and lic nsee identified deficiencies were inadequately cor-rected resulting in repetition of the problem.

Specific corrective action in-adequacies included: compensatory actions for an inoperable service water radi-ation monitor; adherence to radiation area posting requirements; emergency diesel i

generator fuel oil analysis; implementation of a cold weather procedure; fire protection program issues; and, at least initially, event reporting requirements.

Although the process exhibited several deficiencies, it also produced some notable

'

successes including a constantly improving root cause analysis program, surveil-lance program audit, temporary modification program implementation, a safety re-lated valve stem failure analysis, and a diesel generator starting time problem resolution. Management emphasis on corrective action program improvements showed l

some success towards the end of the assessment period.

However, the process is

'

neither well-defined nor fully coordinated. Although the process contains several attributes of an effective program, lack of formal definition, including re-sponsibilities, hampers effective feedback and management assessment. Continued management attention to promoting an effective corrective action program is appropriate.

In summary, the licensee performed well in licensing and technical areas during the assessment period.

Submittals were timely, responsive to NRC initiatives, and of a high technical quality. Quality verification programs have improved consi-derably since the previous SALP period, especially in the areas of self-assessment, QA audits and QA surveillance procedures.

Strong management involvement was noted.

III.G.2.

Performance Rating: Category 1 III.G 3.

Recommendations Licensee: None.

N_RC :

None.

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REFERENCE INFORMATION

A.

CRITERIA Licensee performance is assessed in selected functional areas, depending on whether the facility is in a construction or operational phase, Functional areas normally represent areas significant to nuclear safety and the environ-ment.

Some functional areas may not be assessed because of little or no lic-ensee activities or lack of meaningful observations.

Special areas may be added to highlight significant observations.

The following evaluation criteria were used, as applicable, to assess each functional area:

1.

Assurance of quality, including management involvement and control.

2.

Approach to the resolution of technical issues from a safety standpoint.

3.

Responsiveness to NRC initiatives.

4.

Enforcement history.

5.

Operational events (including response to, analyses of, reporting of, and corrective actions for).

6.

Staffing (including management).

7.

Effectiveness of training and qualification program.

However, the NRC is not limited to these criteria and others may have been used l

where appropriate.

l On the basis of the NRC assessment, each functional area evaluated is rated l

according to three performance categories.

The definitions of these perform-ance categories are as follows:

1.

Category 1.

Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially ex-ceeding regulatory requirements.

Licensee resources are ample and effec-tively used so that a high level of plant and personnel performance is being achieved.

Reduced NRC attention may be appropriate.

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2.

Category 2.

Licensee management attention to and involvement in the per-

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formance of nuclear safety or safeguards activities is good. The licensee has attained a level of performance above that needed to meet regulatory requirements.

Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved. NRC atten-tion may be maintained at normal levels.

3.

Category 3.

Licensee management attention to and involvement in the per-formance of nuclear safety or safeguards activities are not sufficient.

The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirements.

Licensee resources appear to be

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strained or not effectively used.

NRC attention should be increased above normal levels.

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The SALP Board also considered assigning performance trends for the SALP l

period. A trend is assigned if it is definitely discernible, if the SALP Board

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concludes that its continuation will probably change the licensee performance rating, and if it is considered necessary to either focus attention on de-clining performance or acknowledge improving performance.

The SALP trend de-

finitions are:

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Improving:

Licensee performance was determined to be improving over the assessment period.

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Declining:

Licensee performance was determined to be declining over the assessment period and the licensee had not taken meaningful steps to address this pattern.

It should be noted that Category 3 performance, the lowest Category, represents i

acceptable, although minimally adequate, safety performance.

If at any time

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the NRC concluded that a licensee was not achieving an adequate level of safety performance, it would then be incumbent upon NRC to promptly take appropriate action in the interest of public health and safety.

Such matters would be dealt with independently from, and on a more urgent schedule than the SALP pro-Cess.

It should be noted that the industry continues to be subject to rising perform-ante expectations.

For example, NRC expects licensees to actively use in-dustry wide and plant-specific operating experience to effect performance im-provements. Thus, a licensee's safety performance would be expected to show improvement over the years in order to maintain consistent SALP ratings.

B.

Licensee Activities At the beginning of the assessment period the licensee was completing a one week maintenance outage.

Reactor startup and power ascension was commenced on July 2, 1988, On July 3, 1988 a reactor shutdown was initiated from 58% full power to repair a feedwater heater steam leak.

During the shutdown, a reactor scram occurred from approximately 1% due to a malfunction of the turbine mechanical hydraulic control system. Heater repairs were completed and the reactor was taken critical on July 7,1988.

The plant had returned to full power by July-15, 1988 when power was reduced to 37% to facilitate isolation of a leaking feedwater heater sightglass. The plant returned to full power on July 16, 1988.

r The plant continued full power operations until August 24, 1988 when a plant shutdown was completed to determine and correct the cause of increasing leakage into the drywell.

After identifying and correcting the cause of leakage, the plant was started up on August 28 and returned to full power on August 30, 1988.

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The plant remained at full power until October 29, 1988 when a planned power reduction to facilitate maintenance was commenced.

During single loop opera-tions (necessary to rebrush recirculation pump M-G sets) at approximately 44%

power, power oscillations of fifteen to eighteen percent were observed and sub-sequently corrected by operator action.

The plant returned to full power operations by October 31, 1988, The plant remained at full power until November 27, 1988 when pre-outage power coastdown operations commenced. A technical specification (TS) required shut-down was commenced and an unusual event (UE) was declared on November 30, 1988 when diverse low pressure emergency core cooling system (ECCS) components were found to be inoperable.

Prompt repair of faulty components resulted in only a minor power reduction, termination of the UE, and return to full power opera-tions on December 1, 1988.

Coastdown operations continued until February 10, 1989 when the plant was shut-down to commence the refueling outage.

During the coastdown, a UE was declared and a TS-required shutdown was commenced on January 4,1989 for a condition similar to that noted above.

Prompt repair again resulted in only a minor power reduction prior to termination of the UE.

Another UE was declared and subsequently terminated on February 2, 1989 due to an unplanned loss of the startup transformers.

This event required no power reduction.

The refueling outage was completed on April 7, 1989 and the plant returned to full power operations by April 13, 1989.

During the outage two UEs were de-clared due to an unanticipated decrease in reactor water level on March 9 and an unanticipated torus water level increase on April 9.

The plant continued normal full power operations through the conclusion of the assessment period. On June 5 1989 power was reduced to 90% in response to

elevated off gas radiation levels. After assessment of the condition, power was returned to 100% by June 15, 1989.

The licensee determined that the most probable cause of the increase was a degradation of cladding on one or more fuel pins.

Several licensee management changes occurred during the assessment period in-ciuding: Mr. J. Herron's seiection as Operations Department Supervisor; Mr.

E. Lindamood's selection as Radiation Protection Supervisor; and, Mr.

J. Sinclair's selection as corporate Director of External Affairs.

C.

Direct Inspection and Review Activities One NRC senior resident and one resident inspector were assigned to the site full-time for the assessment period. The resident inspector was assigned tem-porary duty at another facility from March to August 1989.

The total NRC direct inspection effort for the period was 3142 hours0.0364 days <br />0.873 hours <br />0.0052 weeks <br />0.0012 months <br /> (2513 hours0.0291 days <br />0.698 hours <br />0.00416 weeks <br />9.561965e-4 months <br /> on an annualized basis).

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Tabulations of inspection activities and associated enforcement actions are contained in Tables 1, 2, and 3.

The percentage of total inspection time de-voted to each functional area is included at the heading of each area in Sec-tion III.

During this period, two NRC weam inspections were conducted to assess the effectiveness of the annual emergency preparedness exercises for 1988 and 1989, and another team reviewed the facility maintenance program. A reactive in-spection was conducted in response _to circumstances surrounding evidence of defeating locks on radiological control area barriers.

D.

Unplanned Trips and Shutdowns Power Date Level Description Root Cause Functional Area 7/2/88 58%

During power ascension Random equipment Not Assigned following a short out-failure, age, a plant shutdown from 58% was commenced to repair a feedwater heater steam leak. A reactor trip occurred at 1% power due to a malfunction of the tur-bine and bypass valve control system.

8/24/88 100%

Controlled shutdown to Random equipment Not Assigned facilitate drywell failure, entry to identify and correct cause of in-creasing leakage into the drywell.

Note:

For an unplanned trip or shutdown which was not assigned to a functional area, no performance deficiency was identified.

E.

Allegations One allegation (RI-89-A-0039) was reviewed by the NRC during this assessment period.

The allegation dealt with timeliness of the issuance of the FEMA re-port subsequent to the 1987 emergency preparedness exercise. The FEMA report l

was issued in June 1989. All but one of the deficiencies identified in the

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report had been corrected and inspected. The remaining deficiency was cleared during the August 1989 exercise. The NRC review of this allegation found no l

safety significance.

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Management Conferences On October 26, 1988, a meeting was held in the Vernon Town Office, Vernon, VT to discuss the previous SALP report findings.

On January 26, 1989, the NRC and licensee held a meeting in the NRC Region I office to discuss plant status, project progress, and initiatives.

On May 10, 1989, the NRC and licensee held a meeting to discuss the licensee operator examination process..

On June 15, 1989, the licensee conducted a meeting in the NRC Region I office to discuss mid-SAlp cycle progress in various functional areas.

On September 6,1989, the licensee met with the NRC in the Region I offices to discuss the security program.

G.

Licensee Event Reports G.1 Quality Table 3 reflects a summary of Licensee Event Reports (LERs) submitted during the SALP period. The LERs adequately described the major aspects of each event, including comg9ent or system failures that contributed to the event and the significant corrective actions taken or planned to prevent recurrence.

The reports were thorough, detailed, well written and easy to understand. The nar-rative sections typically included specific details of the event such as valve identification numbers, model numbers, number of operable redundant systems, j

the date of completion of repairs, etc., to provide a good understanding of the event.

The root causes of the events were generally identified.

Drevious similar occurrences were properly referenced in the LERs as applicable.

A minor problem with report timeliness was corrected by the end of the assess-ment period. Although minor errors were occasionally noted, the licensee con-tinued to improve upon the already high quality of LERs.

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G.2 Causal Analysis l

Thirty-one LERs spanning the range of causal factors were submitted or occurred

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during the assessment period.

NRC review and evaluation noted some recurring problems.

The majority of these problems were effectively addressed by the licensee.

Twelve LERs were classified as caused by personnel errors.

Most of these errors were singular events.

However, two instances of repetitive failures

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l were noted involving service water grab sampling (LER 88-13) and posting of

firewatches (LERs 88-10 and 11).

These deficiencies were partly attributable L

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o to corrective action program problems as detailed in section III.A of this SALP report. The balance of personnel errors were generally attributed to a lack of attention to detail as discussed in section III.A.

Six LERs were wholly or partially classified as caused by procedure deficien-cies. Two resulted in missed surveillances (LERs 89-20 and 24) and two re-suited in partial ESF actuations (LERs 89-15 and 16). ~ Licensee attention is directed to this issue in section III.A.

Five LERs involved design errors. Generally these errors were identified by the licensee as the result of proactive programs and self-assessment initi-atives, i

Four LERs involved the fire protection program. Although these events affected different aspects of the program, a common cause appeared to be lack of ade-quate program support.

This issue is discussed in section III.A.

H.

SALP Tables TABLE 1:

LICENSEE EVENT REPORTS

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Licensee Event Report Causal Analysis Functional Area A

B C

D E

X Total Plant Operations

1

4

16

Radiological Controls

4

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Maintenance / Surveillance

1

5 Emergency Preparedness

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Security

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Engineering / Technical Support

2

l Safety Assessment / Quality Verification Totals I2

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If Includes LER 88-09 through 88-15 and 89-01 through 89-24 l

Cause Codes *

A.

Personnel Error B.

Design

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C.

External Cause D.

Defective Procedure E.

Component Failure X.

Other

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• Causes identified in this table are based upon SALP Board evaluation of the events and, in certain instances, may differ from those specified in the LER.

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0 TABLE 2: ENFORCEMENT SUMMARY Number of Violations by Severity Level Functional Area V

IV III II I

Total Plant Operations

2 Radiological Controls

1

Maintenance / Surveillance

1 Emergency Preparedness Security

5 Engineering / Technical Support

2 Safety Assessment / Quality Verification Other Totals

10 Il TABLE 3:

INSPECTION HOURS SUMMARY Area Hours

% of Time Plant Operations 1184

Radiological Controls 248

Maintenance / Surveillance 969

Emergency Preparedness 163

Security 105

Engineering / Technical Support 284

Safety Assessment / Quality Verification 189

TOTALS:

3142 100

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I.

SALP Board Membership and Attendance An NRC SALP Board, composed of the staff members listed below, met on November 21, 1989 and December 13, 1989 to review the observations and data on perform-ance and to assess licensee performance in accordance with Chapter NRC-0516,

" Systematic Assessment of Licensee Performance." The guidance and evaluation criteria are summarized in the Reference Information Section of this report.

The Board findings and recommendations were forwarded to the NRC Regional Ad-ministrator for approval and issuance.

The SALP Board for Vermont Yankee Nuclear Power Station was composed of:

Chairman:

W. Kane, Director, Division of Reactor Projects (DRP)

Members:

J. Johnson, Chief, Projects Branch No. 3, DRP R. Blough, Chief, Reactor Projects Section 3A, DRP G. Grant, Senior Resident Inspector, Vermont Yankee W. Johnston, Deputy Director, Division of Reactor Safety (DRS)

J. Joyner, Division Project Manager, Division of Radiation Safety and Safeguards (DRSS)

R. Wessman, Director, Project Directorate I-3, Office of Nuclear Reactor Regulation (NRR)

M. Fairtile, Project Manager, NRR Other Attendees:

H. Eichenholz, Senior Resident Inspector, Yankee Rowe T. Hiltz, Reactor Engineer, DRP

• R. Keimig, Chief, Safeguards Section, DRSS

• W. Lancaster Physical Security Specialist, DRSS

• E. Sylvester,g Physical Security Specialist, DRSS

• J. Kottan, Laboratory Specialist, DRSS

• W. Lazarus, Chief, Emergency Preparedness -Section, DRSS

• D Vito, Emergency Preparedness Specialist, DRSS

• R. McBrearty, Reactor Engineer, DRS RI-8