IR 05000309/1987099
| ML20245E836 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 01/05/1989 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Frizzle C Maine Yankee |
| References | |
| NUDOCS 8901180036 | |
| Download: ML20245E836 (4) | |
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lJAN 051989
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Docket No. 50-309 Maine Yankee Atomic Power Company p
ATTN: Mr. Charles D. Frizzle President 83 Edison Drive Augusta, Maine 04336 Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP) Report
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No. 50-309/87-99 This refers to the evaluation of the nuclear facility operated by Maine Yankee
- Atomic Power' Company conducted by the NRC on September 20, 1988, and forwarded _
to you on October 6,1988.
A public meeting to discuss this evaluation _ was conducted at the plant site on November 10, 1988.
Our overall assessment of your facility's operation is that there is effective management attention oriented toward nuclear safety in all functional areas evaluated.
It is noteworthy that Category I assessment has been maintained or
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achieved in Operations, Maintenance, Surveillance and Emergency Preparedness.
Our concerns regarding Radiological Controls have been addressed in the subject report and other correspondence or meetings.
Your written comments of November 1,1988, relative to the report were received and reviewed prior to the November 10, 1988 meeting.
That letter provid'ed -
extensive comments in amplification of Radiological Control program initia-tives. While many of these were not addressed specifically in the SALP report, they were. considered during the deliberations of the NRC SALP Board proceed-ings.
As you noted, the report focused on the refueling outage when the Radiological Controls program is most significantly challenged; however, the initiatives resulting from lessons learned during that challenging period were also recognized in the assessment of an improving trend. Having reviewed your remarks, the Board concludes that no change in assessment is warranted.
No reply to this letter is required. Your actions in response to the NRC SALP will be reviewed during future inspections of your facility.
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OFFICIAL RECORD COPY LIMROTH 422 I?d28/88 - 0001.0.0
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JAN.051989
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L, Maine Yankee Atomic Power Company
Your cooperation with us'is appreciated.
Sincerely, Original Signed Br.-
UILLI27: T. E3SS2LL William T. Russell l'
l Regional Administrator -
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Enclosures:
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-1.
SALP Management Meeting Attendees 2.
St._P Report No.- 50-309/87-99 3.
IC Letter, W. T. Russell to J. B. Randazza, dated October 6,1988 4.
Maine Yankee Letter, J. B. Randazza to W. T. Russell, dated
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November 1,.1988-
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REGION I==
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT NUMBER 50-309/87-99 MAINE YANKEE ATOMIC POWER COMPANY
' MAINE YANKEE - DOCKET NO. 50-309
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ASSESSMENT PERIOD:
February 1,1987. through July. 31, 1988 BOARD MEETING DATE: September 20, 1988
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TABLE OF CONTENTS o
Page I.
INTRODUCTION.....................................................
A.
Licensee Activities.........................................
B.
Direct Inspection and Review Activities.....................
II.
S UMMARY OF RESU LT S...............................................
A.
0verview....................................................
B.
Facility Performance Analysis Summary........................
C.
Unplanned Shutdowns, Plant Trips and Forced Outages,........
III. CRITERIA...........
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'IV.
PERFORMANCE ANALYSIS..............................................
A.
Plant Operations............................................
B.
Radiological Controls.......................................
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Maintenance and Surve111ance................................
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Emergency Preparedness......................................
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Security....................................................
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Engineering and Technical Support...........................
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Safety Assessment / Quality Verification......................
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V.
SUPPORTING DATA AND SUMMARIES....................................
A.
En fo rc eme nt Acti v i ty........................................
B.
Inspection Hour Summary.....................................
.C.
Licensee Event Report Causal Analysis..............
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INTRODUCTION
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The Systematic Assessment of Licensee Performance (SALP) program is ' an integrated NRC stcff effort to_. collect available observations and data on a periodic basis and to evaluate licensee performance on the basis of this information.
The program Lis supplemental to normal regulatory processes used to ensure compliance with NRC rules. and regulations. It is intended to be sufficient 1y' diagnostic to p: ovide a rational basis for ' allocating NRC resources and to provide meaningful feedback to'the licensee's. manage-ment.regarding the NRC's assessment of their ' facility's performance in each functional area.
A NRC SALP Board, composed of.the staff members listed below, met on September 20, 1988, to review 'the observations-and data on performance, and to assess' licensee' performance in accordance with the guidance in NRC Manual Chapter 0516. " Systematic Assessment of Licensee Performance." 'The
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guidance and evaluation. criteria are summarized in Section III of this report.
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This report is' the NRC's astessment of the licensee's safety performance,
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at the Maine Yankee Atomic Power Station for the period of February 1, 1987 through July 31, 1988.
The SALP Board.was composed of:
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.W. Kane,' Director, Division of Reactor Projects (DRP) and SALP Board Chairman W. Johnston, Deputy Director, Division of Reactor Safety (DRS) (Part-Time Member)
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R. Wessman, Director, Project Directorate I-3, Office of Nuclear Reactor
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Reguiltion (NRR)
J. Wiggins, Chief, Projects Branch No. 3, DRP l-L. Tripp, Chief, Reactor Projects Section 3A, DRP
C. Holden, Senior Resident Inspector P. Sears, Licensing Project Manager, NRR R. Gallo, Chief, Operations Branch, DRS (Part-Time Member)
J. Durr, Chief Engineering Branch, DRS (Part-Time Member)
Other Attendees (Non-Voting)
R. Freudenberger, Resident Inspector L
P. Wilson, Reactor Engineer, DRP
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A.
Licensee Activities At the beginning of the period, the plant was operating at 94 percent power in coastdown.
The plant continued in coastdown operations until March 28 when the Cycle 10 outage began.
Major outage work consisted of chemical cleaning of the steam generators,. replacement of the rotating assembly and the motor for a reactor coolant pump,-
replacement of two of the four service water. heat exchangers, re-placement of the sixth point heaters and low pressure turbine work.
The reactor was taken critical on ' June 9,1987, and low power physics
- testing was conducted. The plant was then shut down awaiting comple-tion of turbine maintenance. During the course of the outage, crack-ing was identified in the disks of two ' stages of blading in the low pressure turbine. These. two rows of blades were cut from the rotor.
During the plant startup on June 18, 1987, and in subsequent opera-tions, vibration problems were experienced with the turbine.
On'
June 27, 1987, with a main feedwater regulating valve - (MFRV) in manual control, repair of the control. circuit for the MFRV was at-tempted.
Because plant prints were not specific enough, power was ~ '
inadvertently interrupted to the MFRV manual controller and level' in the steam generator increased until the operators inserted a manual trip in anticipation of an automatic steam generator high level trip.
The plant was returned to power operations for turbine vibration testing and was manually tripped on July 1,1987, due to excessive vibrations.
The plant was placed in cold shutdown on July 9 for disassembly of the low pressure turbine.
Following completion of low pressure turbine work, a plant startup
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was conducted on August 22 and the plant was near full power by the end of August.
With the exception of routine surveillance (such as turbine valve testing and mussel control evolutions) which require operations at approximately 75 percent, the. plant remained at full power for the remainder of the year except for a short period on December 15 when grid conditions required a reduction to 70 percent power for several hours. Two control rod drop events were experienced on October 14 and December 4, 1987, respectively.
On January 5,1988, the plant tripped due to a chain of events which started with a -failure of the heater drain tank level indicator. The plant returned to full power on January 6.
A leak in the electro
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hydraulic control system for the turbine forced a rapid power reduc-L tion to 49 percent on February 4.
The plant returned to full power on February 6.
Control rod drop events were experienced on January 19, February 29 and April 12, 1988. Power was reduced to 76 percent on April 29, 1988, due to a malfunction on the transmission lines but was returned to 100 percent later that same day. With the exception of surveillance testing, power remained at full power for i
i the remainder of the cycle.
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B.
Direct Irispection and Review Activities During this assessment. period there. were two NRC resident inspectors assigqed to the site.
There was a Regulatory Effectiveness Review.
condu:ted by a team of NRC Headquarters personnel on July 20-24,=1987.
' This - review centered around site security measures.. There was a.
Regic.nr.l. Team inspection of the status of' environmental qualification-of equyment on November 2-6,-1987.
A Vendor Interface and. Procure-ment :(eam inspection was conducted during ~ May 31 - June 10.and LJuly 18-22, 1988. There was a total of 5127 inspection. hours during the period or. 3418-on an annualized basis.
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II.
SUMMARY OF RESULTS A.
Overview The SALP Board assessment confirmed a continued commitment to safe plant operations. The Morning Managers' Meeting provided a thorough
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review of daily operations through the use of a multidisciplined management team.
Interfaces between departments and tracking and resolution of plant anomalies were considered strengths. The lack of personnel errors indicated a strong commitment to training and good-coordination of maintenance and surveillance activities.
Root cause analyses. and resultant modifications to the feedwater systems have proved effective in reducing plant trips.
Performance in the Radiation Protection area has declined based upon observations of activities during the 1987 outage when significant radiological work was in progress.
' Improvements since that outage indicated an improving trend.
The lower rating in the security functional area this assessment period was primarily due to the ambiguous nature of the security plan and a compliance oriented response to NRC concerns which indicated a weak understanding of security objectives and requirements.
Engineering and technical support for the plant was good with aggres-siveness, conservatism and initiative shown in the licensee approach to issues such as motor operator valve settings, equipment qualifica-tion discrepancies and reestablishing plant design bases.
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more attention to electrical issues such as interrupting capacity for breakers and establishment of two reliable offsite power ' sources as well as procurement of replacement parts for safety related equipment is needed.
Excellent licensee management involvement in assuring quality and safety at Maine Yankee was evident in resolution of most problems.
Licensing activities showed improvement and were generally responsive
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to NRC needs and initiatives. A strong commitment to emergency pre-
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paredness which resulted in a readiness to implement the emergency plan continued to be demonstrated.
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Facility Performance Analysis Summary Functional Area last period This Period-Trend Operations.
1 Radiological 1LControls
3 Improving Maintenance /
Surveillance 2/1
1 Security
2 Engineering /
Technical Support N/A*
Safety Assessment /
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Quality Verification This area was not previously evaluated.
- This area was not previously evaluated, however, the Assurance of
Quality was rated Category ~ 2, improving; Licensing Activities was rated Category 2, -improving; and 1 raining and Qualification. Effec-tiveness was rated Category 1.
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C.
Unplanned Shutdowns, plant Trips and Forced Outages Power Date Level Root Cause-Functional Area 6/27/87'
Inadequate Drawings Engineering / Technical-Support Description:
During a repair to a Main Foedwater Regulating Valve (MFRV)
control circuit, power was interrupted to the manual con-trol section of the controller.. Drawings did not indicate that 'the lifting of a power lead would cause loss of power to the controller. The MFRV failed open and the plant was manually tripped in anticipation of an automatic trip (LER 87-006).
F 7/1/87
Component Failure
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Description:
While attempting to balance the main generator, vibration levels exceeded the administrative setpoint and the plant was manually tripped (LER 87-007).
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1/5/88 100 Component Failure Maintenance Description:
The level float for the heater drain tr.nk level controller failed causing an indicated low level, tripping both heater drain tank pumps. The main feedwater pump tripped on low suction pressure resulting in a turbine trip / reactor trip (LER 88-001).
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III. 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 environment. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observations.
Specia~1 areas may be added to highlight significant observations.
The following evaluation criteria were used, as applicable, to assess each functional area:
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Assurance of quality, including management involvement and control; 2.
Approach to resolution of technical issues from a safety standpoint; 3.
Responsiveness to NRC initiatives; 4.
Enforcement history;
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Operational and construction events ( including response to, analyses of, reporting of, and corrective actions for);
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Staffing (including management); and 7.
Effectiveness of training and qualification program.
On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categories.
The definitions of
.these performance categories are as follows:
Catecory 1.
Licensee management attention and involvem.ent are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirements.
Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieved. Reduced NRC attention may be appropriate.
Catecory 2.
Licensee management attention to.and involvement in the performance 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 are being achieved.
NRC sttention may be maintained at normal levels.
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Category 3.
Licensee management attention to and involvement in the performance 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 strained or not effectively used.
NRC attention should be increased above normal levels.
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The SALP Board may assess a functional area to compare the licensee's performance during the last quarter of the assessment period to that during the entire period in order to determine the recent trend.
The SALP trend categories are as follows:
Improving:
Licensee performance was determined to be improving near the close of the assessment p'
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Declining:
Licensee per. rmance was determined to be declining near the close of the assessment period and the licensee had not taken meaningful steps to address this pattern.
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A trend is assigned only when, in the opinion of the SALP Board, the trend is significant enough to be considered indicative of a likely change in the performance category in the near future.
For example, a classifica-tion of " Category 2,
Improving" indicates the clear potential for
" Category 1" performance in the next SALP period.
It should be noted that Category 3 performance, the lowest category, represents acceptable, although minimally adequate, safety performance.
If at any time the NRC concluded that a licensee was not achieving an ade-quate level of safety performance, it would then be incumbent upon NRC to take prompt appropriate action in the interest of public health ancf safety. Such matters would be dealt with independently from, and on a more urgent schedule than, the SALP process.
It should also be noted that the industry continues to' be subject to rising performance expectations. NRC expects licensees to use industry-wide and plant-specific operating experience actively in order to effect performance improvement. Thus, a. licensee's safety performance would be expected to show improvement over the years in order to maintain consistent SALP ratings.
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IV.
PERFORMANCE ANALYSES A.
Plant Operations (1427 hours0.0165 days <br />0.396 hours <br />0.00236 weeks <br />5.429735e-4 months <br />, 28%)
1.
Analysis
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This area w:s rated Category 1 in the previous SALP assessment, primarily as the result of strong management overview of daily activities, good tracking and trending of unexpected conditions
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and closecut of operational issues.
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The licensee continued aggressive overview of daily activities through the use of Morning Managers' Meetings.
These meetings utilized all key Department Heads as the participants and dis-cussions often included details of plant systems or sequences of planned actions.
Presentations were made on difficult issues and items were thoroughly discussed. Tracking and trending of a variety of issues 'were accomplished, such as, performance and coordination improvement opportunities among departments, unex-plained systems performance and recognition of individual good performance.
The end result was a multidisciplined team of senior managers that coordinated and resolved the daily business of the plant.
As evidenced by the plant performance during this assessment period, operator errors have been minimized. Of the three plant
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trips which ' occurred during this assessment period, none were
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attributed to operator error. Two were the result of conserva-tive manual actions by operators in response to plant parameters which were approaching an automatic trip setpoint or which exceeded administrative limits. There were no ESF actuations or other reportable events due to operator actions during this period. The reason for this good record can be attributed to good coordination between maintenance and operations, thorough research and coordination of specific activities and training.
The Operations Department implemented several initiatives which have contributed to good operator performance. The Performance Assessment Program (PAP) was initially developed by the Opera-tions Department. Otiier departments have adopted the concept.
In the program, licensed operators conducted surveillance of Operations Department activitier, such as, log keeping, watch-standing and tagging. Items identified as a result of the PAP surveillance requiring corrective action were tracked and closed. Over three hundred PAP surveillance were conducted in 1987. This program resulted in an improvement in a number of activities that directly impact on Plant Operations including more accurate logs and routine procedures.
In addition, oper-ators continued to be aggressive in identifying evolving issues, such as, elevated bearing temperatures or degraded system par-ameters, prior to these indications becoming equipment problems.
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Other initiatives included staff prewatch briefings and Crew Competition.
A member of the Operations' Staff conducted - the prewatch briefings for. operations crews that were away from.
daily operations for more than a few days as a result of the six crew rotation schedule.
These briefings helped to assure con-tinuity' of equipment knowledge.
The Crew Competition was a compilation of activities normally performed by crew members for
- which the crew was awarded points based-on their level of per-formance.
Some of the' activities included were ALARA: goals, casualty drills, response to events, and electrical generation.
Unannounced preplanned casualty drills were conducted on back-shifts to practice operator actions in response to emergency situations, such. as, Appendix R shutdown or station blackout.
These drills were graded and. the results contributed to crew competition.
Crew Competition created a heal. thy performance based achievement system among the crews. The combination of these initiatives resulted in motivated operating crews which were professional and which searched for. ways.to 'mprove plant performance.
The. Operations Dep,artment utilized six crew rotation. An addi-tional licensee position was added to the Operations Department to assist in support functions for the shifts.
The licensee hired only degreed individuals ; for the Operations Department replacement personnel pipeline. Licensed operator resources and the training pipeline were sufficient to assure no adverse impact due to the attrition.
The Training Department did an excellent job of auxiliary operator training which has resulted in observant, professional auxiliary operators who were able to spot and correct deficiencies as part of their everyday. routine.
Four individuals were administered _ senior reactor operator exam-inations. Three of the candidates passed this exam.- One candi-date passed the retest of the written section. All four candi-dates showed strengths with respect to the administrative re-quirements of the exam.
Although a few minor weaknesses were identified, the candidates' overall performance was indicative of sound senior management attention to operator training. Good responsiveness was exhibited in resolving previous NRC concerns identified prior to this assessment period involving simulator evaluations and a potential weakness in written requalification
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examinations concerning instrumentation and control system drawings.
During the last outage, housekeeping activities were given low priority and as a result, the material condition of the plant
deteriorated. During routine operations, plant cleanliness did l
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J not vary from Maine Yankee's typically high standards.
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Even with this good performance there'were areas identified for
= further ~ licensee action.
Two Licensee Event-Reports (LERs)
identified problems with locked valves and the NRC identified several discrepancies associated with the administrative control of safety system valve positions.
In each case,. the _ valves.
identified with ' insufficient administrative controls were found in their proper position. Further action with regard to admin-istrative control of safety system valves appears warranted.
Overall, the lack of operational errors or events, strong senior management involvement, good daily overview and coordination by.
the Morning Managers' Meeting and new initiatives within the Operations Department have contributed to sustained good performance.
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performance Rating Category: 1 3.
Recommendations Licensee:
None NRC:
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None
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Radiological Controls (487 hours0.00564 days <br />0.135 hours <br />8.052249e-4 weeks <br />1.853035e-4 months <br />,10%)
1.
Analysis The Radiological Controls functional area is an assessment of.
licensee performance. in the areas ~ of occupational. radiation safety, radiological environmental monitoring and radwaste man-
agement and transportation..During the previous assessment period, licensee performance in this functional area was char-acterized as-inconsistent and rated Category 2.
Several pro-grammatic weaknesses identified last assessment period in,the areas of occupational radiation safety. continued to be factors
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in.this assessment.
Radiation protection Early in the assessment period during the outage, significant a number of-radiation programmatic problems and weaknesses in protection program' elements were evident. The problems. included inadequate radiation protection coverage. of ongoing radiologi-cally significant work, ~ inadequate high radiation area posting and control and inadequate personnel and area contamination
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control. The NRC took escalated. enforcement action for the identified. problems.
The problems identified during the outage clearly demonstrated inadequate middle and upper site management review and. oversight.
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of on going activities and a failure to identify and take appro-priate, comprehensive corrective actions to address degrading
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radiological controis for outage activities. Once' problems were identified by the NRC, the licensee took aggressive, timely, and technically sound corrective actions.
Licensee corrective action to address NRC concerns included reorganization and reassignment of personnel to improve in-field oversight of activities, improved prioritization of work and redirection of audits to areas of concern.
The licensee also suspended all significant radiological work activities until all
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personnel had been briefed as to the radiological conditions associated with their work activity and the expected level of performance by personnel. However, housekeeping, including con-tamination control was still poor at the end of the outage requiring extensive cleanup for several weeks following resump-tion of operations.
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The experience level of the staff was low and contributed t'o-the problems identified during the outage.
For example, some tech-nicians possessed limited outage radiological controls experi-
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Combined with the large workload,- the result'.was limited oversight by station personnel,. degradation in.tbe quality of radiological. controls and lapses in program implementation.'.The licensee increased off-site training, including completion.of an assignment of the Radiation Protection Manager at INPO for more.
than a year. Additional' training was being integrated into the licensee's organization.
Poor licensee external and internal l exposure controls an'd con-p tamination controls during the outage were also. partially at-
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L tributable to inadequate procedures for high radiation arec access. control, inadequate -radiological surveys,- inadequate
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procedures for airborne ' radioactivity sampling (particularly alpha airborne radioactivity sampling), poor guidance for review of off-scale-dosimetry, and inadequate procedures for whole body-counting.
Although ' the licensee took -action to resolve these -
. ide-concerns including extensive procedure revisions, the w
spread. problems with procedures reflected a need for 'a compre-hensive. and thoro' ugh review of radiation protection procedures by-technically knowledgeable personnel.
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A problem discussed in the previous assessment, poor. control of airborne radioactivity sample analysis results, continued this period. Also this period, a problem with lack of timely analysis of air samples was also identified by the NRC. The problems in this-area were attributed to weak supervisory oversight of these program areas.
By the end of the assessment period, a significantly higher level of licensee planning and preparation for the upcoming out-age was evident at all organizational levels. This included developwnt of an action plan to close out previous concerns, advance review and generation of radiation. work permits for planned work, advance development of organizations and staffing levels to support planned work and development of an Outage Plan to document and describe planned activities.
During routine operations, the Radiological Control's Section planned its work in coordination with the Planning Section.
Coverage of radiological ' jobs by Health Physics (H.P. ) tech-nicians was good and ALARA principles were routinely followed.
Maintenance work involving high exposure levels were reviewed by the ALARA committee.
A-job observation program including a first line supervisor and an H.P. technician was utilized to
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identify deficiencies and sensitize H.P.
technicians to good work practises.
Approximately 200 observations were completed during this assessment period.
Periodic reports were made to Jentur Plant Management which tracked budgeted versus actual exposures, contaminated areas, contamination events and other Radiological Controls Section Activities.
Routine surveys scheduled were adjusted based on the need to access areas.
H.P.
technicians were assigned to specific plant areas for routine surveys and activity planning in an effort to provide ownership of the radiological controls program for that area of the plant.
The combination of these programs was effective in controlling work activities and minimizing personnel exposure.
In light of the problems identified by the NRC, the licensee initiated action to improve the radiation protection audits.
Recent audits were noted to focus on performance based observa-tions of on going work and examined implementation of the cor-rective action plan for previous identified deficiencies.
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radiation protection job observation program discussed above ad the radiation incident report program were beneficial in reduc-ing the overall frequency and severity of concerns identified.
Recurrence of some concerns (e.g., radiation work permit ade-
quacy and implementation, lack of surveys and high radiation access control) demonstrated a need to improve the corrective action process to enhance personnel accountability for deficient conditions or actions.
The licensee did not have an adequate program to address con-tractor worker concerns necessitating NRC involvement. The NRC reviewed and substantiated a number of worker radiological con-cerns that could have effectively been resolved by the licensee.
The licensee's results of measurements of the NRC's whole body counting phantom were generally good.
One problem relating to the positioning of the detectors prior to counting of personnel was identified which indicated a Jack of understanding of the detector's capabilities and its limitations.
If the detectors were not properly psitioned, the counter would not properly quantify radionuclides. This problem was corrected.
Licensee performance in the ALARA area, relative to average industry exposure values was good.
Total exposure the past two years was above average due to significant in vessel and steam
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generator work. Overall exposure reflected a high level of pre-ventive maintenance to improve reliability and safety. Licensee planning and preparation of major exposure tasks was good; exposures for individual. jobs compared favorably to exposures at other sites for similar work.
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However, there were areas for significant. improvement.
For example, about 200 person-rem of the 700 person-rem received in 1987 was. due to " routine" work which received little if any ALARA review. Also, there was poor worker sensitivity to ALARA as evidenced by. NRC observation' of workers in containment during the outage performing. general support tasks in radiation fields ranging from 10 - 50 mrem /hr.
The licensee has initiated aggressive action to improve perform-ante in the ALARA area. This includes review and upgrading of procedures and review of routine work activities that were not previously receiving ALARA reviews. One area needing attention was source term control.
The station exhibited a significant number of hot spots on piping which tended to increase general area dose rates.
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Radiological Effluent Monitoring and Control The overall liquid and gaseous effluent program this assessment period was adequate.
Semiannual effluent release reports were issued in a timely manner.
Procedures were adequate to imple-ment the effluent monitoring and control program. Effluent con-trol instruments and ventilation systems were maintained, cali-brated and tested in accordance with the regulatory requirements.
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Two spills occurred on site during this period.
Both were promptly identified and terminated. Licensee response to inci-dent reports for one of the spills was considered poor.
Al-though soil contamination up to 35 mrem /hr. was identified, the licensee only initiated action to clean-up the contaminated soil
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when prompted by the NRC.
Due to poor contamination control practices and unplanned leaks, sections of the backyard area were contaminated.
The licensee has cleaned up the areas.
Radioactive Waste Management and Transportation Although some weaknesses were identified in this area, proced-ures for the program were generally acceptable.
The overall '
evaluation of this area was that the licensee was implementing a generally adequate. program.
The Hazardous Waste Coordinator, one of the key positions in the radwaste program, was open for a good portion of the assessment period.
The individuals performing that function were reas-signed within radiation protection as an attempt to strengthen supervision. in that area. The position was filled, late in the assessment period by an individual with limited radwaste ship-ping experience.
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The. licensee failed to verify -the half life ' and radioactive concentration of a' dewatered filter and thus exceeded a condi-tion of their radioactive waste license with the State of South Carolina. A ci il penalty was assessed by the State. The vio-lation appears to be the result of the formatting of a procedure such that Agreement State license requirements were not: readily apparent.
This appeared to be an isolated incident and not indicative of programmatic problems.
Summary.
Significant problems in the occupational radiation safety pro-gram occurred during the 1987 outage. The problems identified during the initial part of the outage indicated that the licen-see's radiation protection program was not providing an adequate level of performance to appropriately oversee worker health and.
safety. Weaknesses in staffing and management support were con-tributors the problems in this area.
The licensee initiated
aggressive, timely, technically sound corrective action to ad-dress NRC identified concerns.
Performance ~during routine operations was generally good.
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The radwaste shipping and effluent monitoring and control pro-grams including implementation were generally sati sf actory.
Significant licensee improvements were observed in the licen-see's approach for the upcoming outage including increased staffing, supervision and preplanning.
2.
Conclusion Category: 3, Improving
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3.
Board Recommendations Licensee:
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Perform a self-assessment of radiological controls during the outage and review results with the NRC.
NRC:
Increase inspection monitoring in the area of radiation protec-tion during the upcoming refueling outage.
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C.
Maintenance and Surveillance (1237 hours0.0143 days <br />0.344 hours <br />0.00205 weeks <br />4.706785e-4 months <br />, 24%)
1.
Analysis The previous SALP rated Mainte' nance Category 2 and Surveillance l-Category 1.
This is the first assessment of these two areas combined.
Maine. Yankee's good operational. record during this assessment period is due in part to good maintenance practices.
Mainten-ance' planning. starts with the identification of a deficiency and the assignment of a priority by the on duty Plant Shift Super-
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visor (PSS).
The PSS attended the Morning Managers Meeting to L
discuss operational concerns. The end result-was a Maintenance
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Department which was responsive to plant needs by aggressiveness in identifying the root causes of equipment failures. Engineer-ing and design changes were used where appropriate to alleviate i
recurring equipment malfunctions.
Several initiatives this period have contributed to improved maintenance performance.
The Maintenance Planning section published a two week work list which integrated required' support from other departments such as tagging and radiation surveys.
This schedule formed 9: basis for maintenance work.
Daily changes or high priori'; items were discussed during the Morning Managers Meeting.
Coordination Improvement Opportunities were tracked by the Morning Managers Meeting to resolve the cases when departments did not interface as required to accomplish the scheduled task.
Outstanding Deficiency Reports (DR) were tracked in several categories and outside contractors were utilized to reduce the backlog of DR's when necessary. Addi-tional supervisory positions were established in the maintenance area which impreved the oversight of maintenance activities.
Based on NRC observations, maintenance supervisors spent more time in the plant which helped idsntify potential problem areas.
Post modification testing was tracked through a manual file system. Oversight of this system was provided by an additional SRO licensed individual assigned to provide tagging support to the onshift crew during the refueling outage.
Although the system was cumbersome, it worked adequately because of the over-
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sight provided by the tagging SRO and the emphasis placed on testing by senior plant management.
The licensee developed a computer aided tracking system for post modification testing that is coordinated 'with the Planning Section.
The licensee
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plans to utilize this system along with the tagging SRO for the next refueling outage.
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One plant trip was the result of _ a float type level, switch failure on the heater drain tank which led to an indicated loss of. heater drain tank level.
Both heater drain tank pumps used this level instrument for a trip on low heater drain tank. level.
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The loss of both heater drain tank pumps resulted in a loss of suction pressure to the main feed pump causing a plant trip. The
. licensee took extensive corrective action.. including the.estab-lishment of a preventive maintenance program for all similar float type level switches. However, the licensee's root cause analysis indicated that this trip was preventable.
Substantial management involvement in I&C activities was evi-dent.
I&C. 'and maintenance shops had good management control programs for surveillance and calibrations.
Personnel were well trained and procedures were well written with set points and tolerances within the ~ limits.
The I&C group developed an excellent automated system for identifying, controlling and tracking calibration of safety related instruments.
The program for periodic surveillance continued to be a licen-see strength with planned surveillance scheduled through..the Planning Section and interfaces listed on the two week schedule.
Redundant installed equipment was utilized to allow refueling interval Preventive Maintenance (PM's) to be performed prior to the refueling outage. This alleviated some of the outage work-load and permitted more resources to attend to critical path jobs.
Surveillance tests conducted during the refueling outage were well prepared.
When an emergency diesel generator failed to start in the required time during the loss of offsite power-test, corrective action was extensive.
A coordinated effort from a variety of departments collected and tracked information via a matrix closeout plan. The plan was successful in correc-ting the diesel start problems.
Similarly, the licensee de-veloped an experienced group of technicians who conducted main-
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tenance and surveillance on motor operated valves, reactor trip breakers and station service batteries.
Procedures were thorough and well understood by those technicians. The licensee conservatively used safety related battery surveillance proced-ures on all battery systems.
There was one missed surveillance this assessment period. In an attempt to coordinate two surveillance procedures and reduce down time for one of the containment hydrogen analyzers, a scheduling error was made. The licensee identified the problem
and took adequate corrective action.
This was considered an
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isolated instance.
Personnel errors during surveillance activities were minimized with no ESF actuations during opera-tions or other unnecessary plant challenges.
Overall, the licensee's surveillance program has been implemented by know-ledgeable technicians using thorough procedures.
Good senior management involvement in steam generator surveil-lance activities was also noted.
Surveillance activities on steam generator secondary water chemistry and tube eddy current sampling expertise assisted in assuring steam generator tube integrity.
The licensee's surveillance were well defined, thorough and were identifying problem areas.
All Local Lech Rate Testing (LLRT) personnel were adequately trained, qualified in their positions and displayed technical competence. Administrative control of LLRT was inadequate. For example, flowmeters used for LLRT were not calibrated every three weeks per procedure.
Also, no " Running Total" records were maintained for LLRT Test results. QA/QC coverage of LLRT was minimal and did not address overall program effectiveness.
Licensee management committed to exercise measures to correct the above administrative deficiencies.
The area of chamical measurements ' improved significantly during this assessme" period as determined by evaluation of chemical
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measurement cap bility against technical specification and other regulatory requirements. Performance on NRC supplied chemistry standards was good with only three out of thirty-seven results in disagreement.
The disagreement were due to sampling error and were not considered to be significant.
The licensee was responsive to NRC suggestions for program improvements.
Ef-forts to improve the laboratory facilities and upgrade the instruments were noted. The licensee participated in an inter-laboratory cross check program with the Yankee Environmental Laboratory as an additional QA measure.
Audits of this area were thorough and of excellent technical depth. The chemistry department organiza, tion was adequate to administer the radio chemistry program.
Although the staff was knowledgeable and dedicated, vacancies in two staff positions res.ulted in excess-ive work load for the Senior and Systems Chemists.
In summary, with the added emphasis on the coordinated effort between Operations and Maintenance, both maintenance and sur-veillances had little adverse impact on plant operation. Good coordination existed through the Morning Managers' Meeting and increased maintenance field supervision.
One plant trip was attributed to the lack of preventive maintenance.
The correc-tive action was thorough.
Surveillance testing was character-ized by good preparation, coordination and conduct with good management involvement and control.
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2.
Conclusion Category: 1 3.
Board Recommendation Licensee:
None
_NRC:
None
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D.
Emergency preparedness (125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br />, 2%)
1.
Analysis During. the previous assessment period, licensee performance in this area was rated Category 1. During the current assessment
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period, one. full participation emergency exercise was observed, a routine safety inspection was conducted, and changes to the
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emergency plan and implementing procedures were reviewed.
During the full participation exercise held en June 8,1987, the licensee's execution and participation in the exercise. demon-strated thorough planning and a strong commitment to emergency preparedness. Emergency response personnel were observed to be knowledgeable in their duties and properly used the emergency plan and implementing procedures.
Analysis and classification-of events were timely and command'and control exhibited by man-agers of-each emergency response facility were effective.
No significant deficiencies were identified.
However, several
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minor weaknesses were' brought to the licensee's attention. The licensee concurred in the findings and initiated appropriate corrective action.
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All major areas of the licensee's emergency preparedness program including program changes, emergency facilities, equipment, or-ganization and management control, training, program audits and follow-up of open items were reviewed by NRC during this assess-ment period. No significant deficiencies were found in regard to programmatic changes or walkthroughs (training) of key emerg-
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ency personnel.
Concerns were identified with the licensee's ongoing drill program in that health physics and medical drills were not conducted at the frequency specified in Emergency Plan implementing procedures. Those drills that were conducted were not formally reviewed or approved by management as also required by the Emergency Plan implementing procedures. Corrective _ac-
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tions taken by the licensee were prompt and included planning meetings between corporate and ple-t staff and reassignment i
and/or coordination of onsite emert.
./ preparedness activities
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l to the Emergency Preparedness Coordinator (EPC).
Onsite and offsite emergency preparedness activities were admin-istered by the EPC 'from* the corporate office. The EPC had no additional staff to assist in routine program activities but coordinated support from the site, contracted with Yankee Atomic Electric Corporation for scenario development and the training department for instruction of most emergency response personnel.
Overall manning in this area was appropriate.
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Dedicated emergency response facilities were well maintained throughout the period.
These included the Emergency Operations Facility, Alternate Emergency Operations Facility, Technical Support Center, and Operations Support Center.
Equipment and supplies were also dedicated within each facility and were found to be in good working order.
The licensee coordinated closely with the State of Maine and local towns concerning offsite emergency preparedness.
They assisted the State in the development of' procedures for the newly instituted secondary emergency planning zone (EPZ). This change also resulted in a rezoning of. towns in the primary EPZ along geographical boundaries. The licensee regularly met with State and local officials to coordinate activities.
Addition-ally, the licensee. assisted in emergency preparedness training of State and local personnel.
In summary, the licensee demonstrated a commitment to emergency preparedness. Management involvement was of the quality neces-sary to ensure their emergency preparedness program could be efficiently implemented.
Training of all levels of emergency response personnel was effective as evidenced by exercise per-formance. Designated facilities and equipment were continually maintained. Although documentation, review, and approval of the drill and exercise process were found to be informal, respon-siveness to NRC initiatives was timely, and overall management involvement in emergency preparedness activities was effective:
2.
Conclusion Category: 1 3.
Board Recommendation
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Licensee:
None NRC:
None
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E.
Security (621 hours0.00719 days <br />0.173 hours <br />0.00103 weeks <br />2.362905e-4 months <br />, 12%)
1.
Analysis During the previous assessment period, the licensee's perform-ance in this area was rated Category I based on the licensee's consistent adherence to the security plan implementing proced-ures and a good-enforcement history.
During this' assessment period, in addition to the routine inspection of program implementation, an NRC Regulatory Effec.
tiveness Review (RER) was conducted.
An RER is designed to assess the effectiveness of a licensee's security program to protect against the NRC's design-basis threat, rather than to assess the licensee's compliance with the security program plans.
With this broader assessment, the licensee's overall performance was viewed.as less consistent with the NRC's secur-ity program objectives when compared to previous NRC assessments that primarily focused on the licensee's compliance with program plans. The ambiguous and vague nature of security plan commit-ments leaves some of the commitments open to broad interpreta-tion.
This does not provide for consistent and readily under-stood bases from which to implement these commitments. This is also likely to have affected the NRC's previous assessments of the licensee's performance, particularly for the element of enforcement history, as relatively few violations had been cited because of these ambiguous and vague commitments.
Early in the assessment period, an NRC inspection identified four violations.
Three of those resulted from ambiguities in the security plan. While individually the violations were not of high Mcurity significance and the licensee took prompt action to correct the specific deficiencies, it was done pri-marily by revising the security plan implementing procedures.
The licensee did not take the initiative to correct the base document, the security plan, from which the implementing proced-ures were derived, even though that action was discussed at
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length with the licensee. A further example of this occurred with the licensee's security plan revisions in response to the NRC's new miscellaneous amendments to 10 CFR 73.55. While the licensee's revised commitments were found acceptable in meeting the intent of the various amendments, no effort was made to strengthen the program in these areas beyond just meeting the mandate. This indicated a reluctance on the part of the 11cen-see to assure a strong and unambiguous docurent on which to base its implementing procedures and is indicative of a licensee which is content with implementing only a compliance oriented
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program. The NRC is also concerned with the compliance-oriented nature of the licensee's responses to the violations.
For
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example, in response to a violation concerning a vital' area
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enclosure, the licensee did not recognize tne need to secure the
roof o' the enclosure because that aspect was not specifically I
addossed in the plan. Additionally, in response to a violation concerning non-security personnel providing access control, I
which was not addressed in the plan but was addressed incom-pletely by an implementing procedure, the licensee contended it l
was not a violation even though the NRC's regulation, 10 CFR j
l 73.55(f)(1) specifically addresses the point in contention.
Another example of the licensee's compliance-oriented nature was reflected in the licensee's responses to the RER findings.
The RER team identified fourteen items which warranted atten-tion.
The licensee committed to fully correct eight of the items and most aspects of one additional item. Those items were related to licensee commitments in the security plan.
For the remaining five findings, which were not related to commitments in the plan, the licensee either only noted the item or provided a. superficial response that did not address the substance of the finding.
Subsequent to a Regional follow-up inspection, the licensee submitted an additional response which expanded slightly on the original submittal but did not commit to any program enhancements. Licensee management should be alert for a complacent or degenerating attitude toward the security program.
Security force adherence to security plan implementing proced-ures was consistent during this assessment period.
Both licen-see and contractor supervisory and administrative staffing were appropriate as evidenced by relatively problem-free, day-to-day operations and the absence of a backlog of work. The authority and responsibilities of the security organization were generally well-defined and disseminated and interface with other plant groups appeared to be well established.
This indicated that program implementation was stable and consistently applied.
The licensee's security training program was carried out by two individuals who were experienced and assigned on a full-time basis.
Training facilities had adequate classroom space and instructional aids were utilized.
Lesson plans were generally thorough and kept current from various feedback channels, such as routine program implementation, licensee audit results, and NRC inspection findings.
Security force manning was consistent with the licensee's com-mitments in the security plan. Morale was good and members of the force exhibited professional demeanor in carrying out their duties. They were al.so knowledgeable of the requirements of the security plan implementing procedures which was indicative of
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effective training for routine duties. The turnover rate in the
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force was high during much of the assessment period due to a strong economy in the area.
In order to reduce the turnover rate, the licensee augmented the wage and benefits package when the security force contract was renewed.
The initiative has significantly reduced the turnover rate and is evidence of management involvement in and oversight of the program.
The licensee submitted one security event report pursuant to 10 CFR 73.71 during the assessment period. The event resulted from a security force supervisor who. failed to take action for a security alarm in a timely manner and belatedly recorded the event in a manner intended to mask his oversight. The licensee took prompt and appropriate corrective action.
The licensee program for the control and accounting of special nuclear material -(SNM) was generally effective and carried out in accordance with appropriate procedures. However, just prior to the start of this assessment period, the licensee was unable to locate an incore neutron detector, containing a minute quan-tity of SNM, during an inventory. The licensee finally assumed that the detector was inadvertently compacted and sent to burial with other radioactive waste, about two years earlier. Respon-sibility for the control and a'ccounting of SNM was strengthened to prevent a future similar occurrence. The licensee's correc-tive action was considered appropriate but the delay in detect-ing the missing detector indicates the need for more emphasis by the licensee on strict physical accounting of SNM during inventories.
In summary, the ambiguous and vague nature of the security plan and compliance-oriented responses to the NRC, leads to the con-clusion that the licensec's security program is primarily focused on assuring compliance rather than displaying initiative in achieving a well-defined, performance-based program with maximum effectiveness.
2.
Conclusion Category: 2 3.
Board Recommendation Licensee:
Review the security program and determine how it can be improved through clarification and additional detail including correla-tion with NRC security objectives.
NRC:
Conduct management meeting with licensee to review findings of the licensee's review.
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F.
Engineering and Technical Support 1.
Analysis The area of engineering and technical support was not treated as -
a separate functional area during previous assessment' periods.
During this period, this functional area addresses en51neering and technical support for plant activities, reverification of
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-design bases, plant modifications and outage support.
Plant on-site engineering involvement in day-to-day technical activities was good.
The Plant Engineering Department (PED)
actively participated in Morning Managers' Meetings held to co-ordinate activities. During these meetings, PED was frequently assigned -the responsibility for review and analysis of selected operational events and development of proposals for performance improvement where appropriate.
The assignment of engineering resources to these tasks was based ' on the recognition of the complexity of the assigned operational problems, the need for in-depth review and, on occasion, the development of additional data.
Senior engineering management was also routinely involved in plant issues through attendance at on-site meetings. The end result of these involvements was an integrated team resolving issues before they became problem areas.
The licensee's engineering approach to technical issues was
, generally sound, conservative, thorough, and clearly focused on operational safety. The timely replacement of class IE batter-ies and recent development of degraded voltage studies support this conclusion.
In particular, the licensee's approach was exhibited in their aggressive program to address NRC require-ments contained in Bulletin 85-03.
One well-trained off-site engineer was designated to oversee the entire p,rogram. During the last outage, an outside contractor was utilized to provide signatures and recommended settings for torque and limit switches for motor operated valves to address this Bulletin.
After a review of the recommendations, the licensee decided to apply some additional conservatism to the settings.
Later the contractor upgraded the recommended settings based on more information.
Because the licensee was initially conservative,
~the impact of this change was minimal. The licensee's aggress-ive approach to correct this problem was well planned and thorough.
Personnel involved with the motor operated valve project were knowledgeable, experienced and professional.
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A special team inspection noted good off-site engineering sup-port in the equipment environmental qualification-program. The
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licensee's environmental qualification (EQ) program was found to be thorough and effective.
The EQ files were.well organized, complete, and maintained in an easily, retrievable format.
The licensee's QA' department conducted an extensive audit of the EQ program and the deficiencies -identified were resolved in a timely manner.
The licensee utilized an EQ Coordinator from Yankee Atomic Electric Company.
Good -initiative was shown - in conducting an independent programmatic and technical evaluation of the EQ program.
Several environmental qualification' (EQ) problems were identi-fied by -the licensee during this assessment period. They ir,-
volved unqualified cable to a temperature detector, heat shrink tubing installations not in accordance with current installation instructions and additional valves that required modifications to satisfy EQ requirement. While the staff expressed a concern that these issues could have been identified earlier, it was concluded that these findings were the result of extensive licensee reviews in this area during this period and demon-strated a good understanding of EQ requirements.
Staffing of the EQ program was adequate and, training and qualification of the licensee's ' EQ personnel were good.
The foregoing demon-strated good corporate and site management involvement and effective control of their EQ program.
In several areas, the licensee demonstrated a responsiveness to NRC initiatives. These included the licensee's prompt correc-
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tive actions to address a lack of breakers, and a commitment to prepare a formal control process to track electrical load growth to replace the current informal process. Two areas were noted where improvements in dealing with long-standing problems are warranted.
These areas include marginal interrupting capacity for site 6.9 kv and 4.16 kv tireakers, and establishment of two reliable offsite power sources.
Senior management attention is required to assure prompt resolution of these issues.
Respon-siveness to NRC's initiatives was good as evidenced by: (1) the licensee's prompt action after receiving IN 86-03 concerning potential deficiencies in EQ of Limitorque valve operator wiring and IN 86-53 concerning improper installation of Raychem heat shrinkable tubing; and, (2) the licensee's EQ program met the required deadline without extensions. Based on NRC reviews, all of the identified problem areas were promptly reported, ' analyzed and proper corrective actions taken.
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Good engineering practice was noted during a special team inspection conducted during this period to ascertain '_that the i.
present configuration of the plant electric power systems will I
support safe operation of the plant..The. licensee has made several modifications to the electric power systems since the plant was. licensed in 1971. Engineering (on-site and off-site),
and plant ~ management involvement in assuring the quality of these modifications was generally evident. Corporate management
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including engineering support personnel were. generally involved in the implementation of all modifications..The licensee's safety evaluations of the modifications were found to be tech-nically sound.
e A licensee ' initiative is: their action to address concerns over.
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the maintenance of the design bases for the plant. A functional inspection of the Auxiliary / Emergency Feedwater system was initiated which reviewed the system from 'as designed'
to
' currently installed' including-the modifications since original installation.
This-review has been completed and the High pressure and Low Pressure Safety Injection Systems are currently i
!.
under review. These reviews. are a. good engineering initiative l
resulting in compilation of all design information in one docu-l'
ment and in promoting a better understanding of the plant sys-tems during modifications.
Finally, the overall management of the last outage and technical support for the last outage were effective and involved a coor-dinated effort from a variety of departments at Maine Yankee.
o I
Maintenance Planning provided all the scheduling for system availabilities and support functions.
Outage controllers, including two licensed Shift Supervisors, coordinated the outage functions relieving the control room of additional distractions during this-heavy work load period.
All scheduling and interface work was coordinated through the Planning Section. Daily planning meetings were held to keep the outage on schedule with more frequent meetings as required for specific areas of interest. Two licensed senior operators were utilized to assist in the tagging function. This relieved the onshift crew from the administrative burden of writing tagouts during the outage. A manual functional test tracking system was used which worked because of the constant overview from the tagging coordinators. Engineering provided a cognizant engineer for each design change. These individuals-followed the design change package from initial inception through the review commit-
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tee, installation and package closeout. This process provided for additional oversight of modification installation in the field by the project engineer.
The overall effect was a well coordinated, multidisciplined team which removed the coordina-tion of the outage from the control room and allowed the Operations Department to concentrate on maintaining plant
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The plant ~ experienced one plant trip which was attributed to Engineering - ard Technical Support this SALP period.
This was the result of replacement of a component in the feedwater' con-trol system. The repair effort was researched and well planned; however,' available drawings were inadequate to support the work.
With feedwater control in manual, power was removed from the component by lifting the incoming power lead.
This action resulted in the loss of power to the manual controller.
The plant was manually tripped in' anticipation of a high steam generator water level. Additionally, there were five rod drop
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events this assessment period. Although the causes of the rod drops were individually corrected, an action plan developed, and routine outage upgrades have improved the performance of the control element drive system, the number of these events and their potential impact indicated a need for further corrective action.
Because of the number of plant trips cau:,ed by the feedwater system last SALP cycle, the licensee conducted a thorough review and modified portions of the feedwater and related control sys-tems. As a result of these modifications, there has been a not-able improvement in the performance of the feedwater system.
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The combination of these modifications and aggressive followup and root cause determination of secondary plant systems problems resulted in a dramatic reduction in plant trips (last SALP cycle had 8 plant trips and 3 unplanned shutdowns.)
Several deficiencies were identified in procurement activities,
which were collectively indicative of a programmatic weakness.
These deficient areas included the failure to invoke Part 21 requirements on many safety related purchases, the failure to audit all vendors used for safety related materials and com-pont:nts, and inadequate evaluations to support the upgrading of comnercial quality items to safety class applications. The root cat 'es for these deficiencies included misinterpretation of the requirements of part 21, lack of detail in procedures and a lack of understanding of 10 CFR Appendix B requirements for replace-ment parts for safety related systems.
The actual impact on equipment caused by these deficiencies was difficult to measure; it was still being evaluated at the end of the period.
The licensee committed to perform an in-depth review of the procure-ment system and make changes to the program as appropriate.
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In! summary, day-to-day - engineering' technkcal support, off-site engineering support and technical support were good.
Initiative was noted in the design bases reverification program and, ag-gressive and conservative - actions. were noted' in the equipment environmental qualification program and the program to review torque and limit switch settings for motor operpted. valves.
These activities exhibited good licensee management attention.
' Senior management attention is needed to address several electrical concerns.
Continued' senior management attention to the problems identified in the procurement. program is also warranted.
2.
Conclusion Category: 2
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3.
Board Recommendations Licensee:
Meet with the NRC staff and resolve electrictl. issues.
NRC:
None I
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Safety Assessment /Ouality verification (410 hours0.00475 days <br />0.114 hours <br />6.779101e-4 weeks <br />1.56005e-4 months <br />, 8%).
'1.
Analysis
' Management involvement in assuring quality has been considered-as a ' separate functional area' in. past SALP's in addition. to
.
being one of. the evaluation criteria in each functional area.
This area has been expanded to encompass activities previously
- evaluated in Licensing, including safety evaluations. This dis-cussion is a synopsis of quality 'and safety' evaluation _ philoso-phies reflected in - other functional areas.
In' assessing this-area, the 'SALP Board has considered attributes which are key contributors in ' assuring safety and verifying quality..Imple-mentation of management goals, planning of routine activities, worker attitude, management. involvement, and training are
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examples.
This is the first assessment for this functional area.
In tne l
last SALP Assurance of Quality was rated Category 2, Improving.
,
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. and Licensing Activities were rated Category 2.
Safe plant operations were listed as one of: the licensee's-Cor-
.porate Goals.
Through primary and supplemental ' goals, this L
element.was passed to each level in the organization.
Super-visors spent portions of their day in the field observing work lj
. practices, especially in the maintenance area which staffed
extra positions this past year to accomplish more field super-
'
vision.
Routine inspections by senior plant managers - accom-panied by plant workers were scheduled and the results were.
tracked until' closecut of each item.
Plant Management was involved'in correcting anomalous indications through the Morning
.
Managers Meeting prior to serious problems developing.
Multi-disciplined teams were utilized to study evolving issues and resolve them. Through all levels of the organization emphasis.
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was placed on quality.
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Root cause determinations were assigned to the Nuclear Safety.
Engineers (NSE's). Most of the NSE's have Senior Reactor Oper--
ator licenses and were trained in causal factor analysis and Human Performance Evaluation System (HPES) analysis. Addition-ally, a variety of personne1' in other departments were trained in causal factor analysis.
Root cause determinations were thorough and corrective actions were extensive. Plant manage-
!
ment requested HPES analyses of a variety of issues that would not ordinarily qualify for a root cause determination. As Maine Yank.ee's operational record attests, root cause analysis and subsequent modifications of the feedwater system contributed to reducing the number of plant trips from 8 last SALP to 3 this SALP period.
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Maine Yankee took several initiatives during this assessment
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period designed to identify potential problem precursors and self improvement areas.
Maine Yankee conducted a Design Basis Review of the Auxiliary Feedwater System similar to an NRC Safety System Functional Inspection.
Similar Design Basis Reviews were initiated for the High Pressure Safety Injection and Low Pressure Safety Injection Systems. During the routine senior management plant tours discussed above, operators and technicians accompanied the managers and each wrote a separate list of deficiencies. This method was instructional in addition to its intended safety / housekeeping monitoring program.
The Performance Appraisal Program where operators conducted surveil-lanc s of Operations Department programs was anot'er initiative that not only identified and corrected problems but initiated routine critical review. The Morning Managers' Meeting tracked and reviewed a number of potential problem identification sys-tems including Performance Improvement Opportunities, Coordina-tion Improvement Opportunities, Close Calls and Anomalous Indi-cations.
The combination of these programs contributed to the resolution of issues prior to the development of significant problems.
The Quality Assurance / Quality Control function was a diverse group with a variety of backgrounds.
Yankee Atomic Electric Company supplemented the onsite Quality organization by per. form-ing audits for the Offsite Committee.
Followup corrective actions were tracked and.in most cases were timely.
The NRC identified two areas during this assessment where more thorough audits could have identified the problems earlier. Those areas were radiation protection and procurement activities for upgrad-ing commercial grade items to safety class.
In the radiation protection area, NRC field observations of in progress work dur-ing the outage identified concerns. The NRC identified problems with procurement activities for upgrading commercial grade items to safety class as a rcsult of the failure to properly under-stand and implement NRC requirements; this experience also
,
l reflected a lack of knowledge of similar industry problems, but on a smaller scale, previously identified by the NRC.
The licensee may need to review their audit activities to assure comprehensive program evaluations include these elements.
The refueling outage had mixed results. Some good initiatives in outage planning were identified and personnel radiation l
exposures for potentially high exposure jobs showed application I
of good ALARA principles.
However, the large workload and limited staff contributed to deficiencies identified in the
,
I Radiological Controls area.
Relaxation of housekeeping stand-ards compounded contamination control problems. The approach to security issues was too focused on compliance instead of focus-
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l ing on effectiveness to enhance safety.
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During this SALP period, a large percentage of older licensing issues were resolved. Two examples are Technical Specifications for Limiting Overtime and Technical Specification Revising the
,
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Testing Requirements for Hydraulic Snubbers.
Similarly, the
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Inadequate Core Cooling Instrumentation issue has been resolved and that instrumentation is scheduled to be' i.nstalled during cycle 11 refueling outage.
An example of a Maine Yankee initiative is the Increase of -
Maximum' Nominal Enrichment - of Fuel from 3.5% to 3.7%.
This allows a fuel cycle extension from 15 months to 18 months, thus generating less spent fuel over the remaining life of the plant.
The primary review area was the capability of the fuel storage areas to meet NRC reactivity criteria when containing fuel of this enrichment.
In general, licensing submittals improved during this SALP period.
One exception to this was a submittal concerning the Adequacy of Offsite Power.
The existing offsite power system satisfies the requirements set forth in General Design Criterion 17 when the 115 kV Mason line is one of the lines in service.
When the Surowiec line is the only 115 kV in service, there ar*e possible situations in which the line has not been demonstrated to be adequate. This issue is not new, having been initiated in 1982. At the staff's request, the licensee proposed a Technical Specification change prohibiting reliance on the Surowiec line until that line is -upgraded by installation of a new capacitor bank. This Technical Specification change was authorized after the SALP. period. Maine Yankee's responsiveness to NRC requests
_
was consistently good.
Implementation of upgrades recommended by the Seismic Design Margins Program was aggressive.
Senior Management demonstrated active participation in licensing activities to ensure high quality in the resolution of issues.
The Plant Onsite Review Commit. tee (PORC) meetings were charac-terized by frank, open discussion.
Membership was well pre-pared.
Subcommittee meetings for procedure reviews were thorough allowing regular meetings to concentrate on routine business.
Unscheduled PORC meetings were called to review emerging problems and review special projects.
As a result, PORC maintained a good overview of plant activities. Management meetings were held at a variety of levels throughout the year to
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l discuss plant goals and develop programs to attain those goals.
The licensee's Quality Improvement Program has been reinstated as a tracking system for initiatives for the plant.
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In summary, excellent licensee management involvement in asst.r-ing quality and safety at Maine: Yankee was evident. Plant man-agement actively resolved actual and potential operational prob-lems before they became significant concerns through aggressive daily coordination and tracking activities.
Licensee initia-tives in self assessment and root.cause analyses in several areas. were especially noteworthy.
However, problems in the radiation protection program during the outage were. only ' par-tially. identified by the licensee and deficient procurement practices were not identified by internal audits indicating that more objective independent assessments 'of such areas may' be
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warranted.
Licensing activities showed improvement and were generally responsive to NRC needs and initiatives.
2.
' Conclusion
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Category: 2 3.
Board Recommendations Licensee:
Review audit activities to assure comprehensive program evalua-tions are adequate.
NRC:
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None'
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o V.
SUPPORTING DATA AND SUMMARIES A ',
Enforcement-Activity Number of Violations by Severity Level-Functional Area V
II III. II I
Total ~
Plant Operations
. Radiological Controls
2
5 Maintenance / Surveillance.
-1
1
.
Security
4
.
Engineering / Technical Support
2 Safety Assessment / Quality
- Verification Total
10
14 One enforcement conference was held with the licensee on June 8,1987.
The. topic was radiological controls program implementation during the refueling outage. No civil penalties resulted from the associated viola-tions.
.
9
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4 B.
Inspection Hour-Summary Annualized
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Actual Hours _.
Percent-Plant-Operations 1427 951
Radiological Controls 487 325
Maintenance / Surveillance'
1237-825 24-Emergency Preparedness 125
2-Security 621 414
Engineering / Technical Support 820 547
Safety Assessment / Quality Verification.
410 273
!+
5127 3418 100 Al. locations of Inspection-Hours vs.
Functional Areas are
approximations based on inspection report data.
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Licensee Event Report Causal Analysis
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C D
E X
Total l.
~A
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Functional Area'
,
Plant Operations
2
4'
1
Maintenance
_
1
Engineering / Technical Support Total.
6
2
12 Cause Codes *
Tctal i
'
A Personnel Error
8
Design, Manufacturing, Construction.
or Installation Error
50 C
External Cause
-0 D
Defective Procedures
17 E
Component Failure
'17 X
Other
8
Root causes assessed by. the SALP Board may differ fecm those listed
in the LER.
' The following common mode events were identified:
Half-of the reportable events were categorized as attributable to Design, Manufacturing, Construction or Installation errors. Of these six events, the majority were issues identified as the result of licensee initiatives to review design bases or "as installed" configurations of. safety.related systems.
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Inadequate procedures accounted for two reportable events, both of which were related to the administrative control of safety system valves.
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The two component failures resulted in two of the three plant trips this-period.
One of the twelve events was attributed to personnel error.
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UNITED STATES ENCLOSURE-3
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.t NUCLEAR RESULATORY COMMISSION
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O
.y REGION 1 -
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. 475 ALLENDALE ROAD
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KING OF PRUSSIA. PENNSYLVANIA 19400 00T 061988
~*
Docket No. 50-309 Maine Yankee Atomic Power Company ATTN: Mr. J. B. Randazza President 83 Edison Drive Augusta, Maine 04336 Gentlemen:
. Subject:
Systematic Assessment of Licensee Performance (SALP) Report No. 50-309/87-99 The NRC SALP Board has assessed the performance of activitics at.the Maine.
-Yankee Nuclear Power Station for the period February 1,1987 to July 31, 1988.
The results are documented in the enclosed SALP Board Report.
A meeting at Maine Yankee to discuss this assessment will be scheduled by separate corres-pondence.
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At the SALP meeting you should be prepared to - discuss our assessment, in particular, the areas of radiation protection and security. Your discussion should specifically address your assessment of the root causes for the problems noted in these areas and your plans to effect permanent corrective action.
Your cooperation is appreciated.
,
Sincerely, j'
L:<L W111'iam T. Russell Regional Administrator l
Enclosure:
l SALP Report No. 50-309/87-99
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i Maine Yankee Atomic Power Company
00T 061988
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C. D. Frizzle, Vice President / Manager of Operations J. H. Garrity, Vice President Quality Programs and Engineering E. T.'Boulette, Plant Manager G. D. Whittier, Licensing Section Head
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J. A.. Ritsher, Attorney (Ropes and Gray)
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P. Ahrens, Esquire Public Document Room (PDR)
local Public Document Room (LPDR)
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Nuclear Safety Information Center (NSIC)
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NRC Resident Inspector State of Maine Chairman Zech Commissioner Roberts Commissioner Carr Commissioner Rogers K. Abraham,.PA0 - RI (17 copies)
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E!! CLOSURE 4 MaineYankee REUASLE ELECTRICITY f OR MAINE SINCE 1972
'
EDtSoN DRIVE. AUGUSTA. MAINE 04330.(207) 623 3521
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November 1, 1988 MN-88-105 GDW-88-293 Region I UNITED STATES NUCLEAR REGULATORY COMMISSION 475 Allendale Road King of Prussia PA 19406 Attention:
Mr. William T. Russell., Regional Administrator References:
(a) License No. DPR-36 (Docket No. 50-309)
(b) Systematic Assessment of Licensee Performance (SALP)
Report No. 50-309/87-99 Gentlemen:
Subject: Response to 1987 SALP Report This letter provides Maine Yankee's response to Reference (b).
Each area evaluated in the report is addressed separately below.
Plant Operations (1)
He are pleased that our excellent rating in this area has been sustained
during the last SALP period. We will continue to strive to maintain our rating and to improve our performance in this area.
Radiation Controls (3)
We do not believe that our performance in this area is accurately reflected in the rating and request reconsideration based on the following:
Maine Yankee's radiation control program over its sixteen years of operation has been above average.
He have never had a single case of personnel exposure above the
regulatory limit, nor has any individual exceeded 5 Rem in any year since 1974, far better than the industry average.
Only Approximately 0.51,of our employees and contractors with recorded
exposures have ever exceeded 3 Rem in a year.
Our average personnel exposure over the sixteen years has been below
the industry average.
0613L-GDW W
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UNITED STATES NUCLEAR REGULATORY COMMISSION MN-88-105
Attention: Mr. William T. Russell Page Two We have never had a radiation release in excess of regulatory limits,
nor have we had an incident of off site contamination.
The dose commitment (person-rem) to the public has been less than one
hundred thousandth (10) of background.
Since 1980, the Maine Yankee Radiation Protection program has been rated as a 2.
The SALP report for the period ending January 31, 1987 noted some weaknesses but also noted the following:
"The licensee has initiated a number of program, policy and procedure
upgrades during this assessment period to improve the Radiological Controls Program".
"The Radiological Controls Improvement Program has been introduced to
identify, track, analyze and resolve radiological incidents."
_
"There is evidence of corporate and site management involvement (in
radiological controls) including frequent meetings, use of feedback and
,
tracking mechanisms, assessment of activities, etc. with very tight control at all levels."
"The licensee has been conducting an effective program for liquid and
gaseous effluent control."
"There was significant progress in radwaste volume reduction activities
in 1986 including a 47% volume decrease...."
,
"The licensee's ALARA program is well documented and effective at all
levels of the organization. Actual exposure of 92 man-rem (for 1986)
reflects good controls in this area."
"In summary, although there were many areas of strength and no major
programmatic deficiencies observed in this f0nctional area, there were j
i several areas where improvements could be realized." (SALP Report l
85-98, p. 15).
Prior to that SALP report, we had embarked on a program to improve our performance in this area. Among the initiatives taken were the following:
The onsite and offsite training provided to Maine Yankee radiological
controls personnel increased. The Radiological Controls Section Head was assigned to the INPO staff for fifteen months. This permits us an excellent opportunity to effect continued performance improvements in the radiological controls area by having witnessed first-hand good practices at other facilities.
0613L-GDW
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l UNITED STATES NUCLEAR REGULATORY-COMMISSION MN-88-105 Attention: Mr. William T. Russell-Page Three;
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Maine. Yankee'has implemented a ' policy of hiring only college graduates
/
as Radiation Controls Technicians. 'Although this program may have j
.
resulted in a reduction of.the level of experience of our technicians in the-short run, we believe.that. 1n the longer term, the improved
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professionalism and level of competence of our technicians will' enhance-
.'the overall quality of our radiation controls program. We also believe l
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L that this' policy leads <the industry and-is consistent with the Commission's. desire to hire college graduates wherever possible.
- Extensive capital improvements.were made to the Radiological Controls Access. control area and facilities to enhance overall. access. control; and to improve.the working area for the radiological controls staff.
- The Radiological Controls Improvement Program has continued to be effective in identifying, analyzing, trading, and resolving radiological incidents.
This, coupled with the Radiological Controls Performance Assessment Program (PAP), continues to identify areas where performance can be and has been improved.
The current SALP-report indicates that the radiation control program exhibited some weaknesses during the last outage but was good during normal operations. We. agree with this assessment but we do not agree that a category 3 appropriately reflects performance for the entire SALP period.'
~
The 1987 refueling outage occurred during the beginning of the SALP period and. lasted for.approximately two months, or about ten percent of the-eighteen-month SALP period. During the outage, in an effori;, to' improve plant safety and reliability, we undertook more radiatten work than may have been appropriate from a strict radiation controls standpoint. From a performance, standpoint, we continued to achieve excellent results from our radiation controls program. The man-rem for these jobs were comparable to similar jobs at other facilities.
As recognized in the SALP report, Maine Yankee aggressively responded to NRC concerns with sound corrective actions. During the outage, when the NRC ir.spector pointed out several areas where our program controls could be improved, we instituted prompt and effective corrective actions including suspension of significant radiological work until all workers were briefed on radiological conditions. Other longer term improvements to our radiation controls program, as mentioned in your report, were implemented soon after the last outage. These included significant enhancements in our radiation controls outage planning.
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0613L-GDW
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' UNITED STATES NUCLEAR REGULATORY COMMISSION MN-88-105 Attention: Mr. William T. Russell Page Four As noted in the report, one individual reported concerns to the NRC instead of reporting them first to his employer or to Maine Yankee.
These concerns were investigated by the NRC.
No violations of regulatory requirements were identified.
The performance of the radiological controls program was rated as
" generally good" (P. 16) for the majority of the SALP evaluation period during routine operations. Also, performance in this area was determined to be improving near the close of the assessment period.
This is consistent with NRC's assessment, as documented in SALP, of Maine Yankee's performance in radiological controls for the past eight years, except for the observations of performance during the 1987 refueling outage. He believe that the performance of our radiological controls program during the two-month 1987 refueling outage is being given disproportionate weight compared to our historic performance and that during the remainder of the
.
period.
He believe that our record in Radiation Protection is one of constantly striving for improvement and learning from our past experiences, rather than a record of declining performance.
For the reasons stated above, we request that the rating in this area be reconsidered.
.He plan to assess the effectiveness of our Radiation Controls Program during this refueling outage and discuss our findings with you as recommended by the report. The assessment will be in addition to the normal Performance Assessment Program (PAP).
Maintenance and Survelliance (1)
Maine Yankee is pleased with the improvements noted in this area and plan to continue to work for further improvements.
<
Maine Yankee is pleased with the continued excellence noted in this area. He plan to continue to strive for improvement in this area.
Security (2)
i Maine Yankee was not aware,* prior to the receipt of the SALP report, that the NRC approved security plan was no longer considered adequate by the Staff. He plan to work with the Staff to identify specific areas of concern and to
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propose appropriate improvements to the Security Plan.
0613L-GON L
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UNITED STATES NUCLEAR REGULATORY COMMISSION MN-88-105 Attention: Mr. William T. Russell Page Five Maine Yankee. has made and is planning further enhancements to the security program in response to the NRC's RER inspection and will work with the Staff to resolve any residual concerns they may have in this area.
Engineering and Technical Support (2)
. Maine Yankee has met with the Staff to discuss our ongoing initiatives with regard to off-site power. We understand that this meeting' resolved the Staff's concerns in this area, pending further technical review of the capacitor bank installation.
Nonetheless, we'are investigating further reliaD111ty sahancements in this area.
Safety Assessment / Quality Verification (2)
Maine Yankee plans to review audit activities to assure comprehensive program evaluations are adequate as recommended by the Staff.
Please feel free to contact me if you should have any questions 'or need any additional information.
Very truly yours, MAINE YANKEE W"A ge John 8. Randazza President SDE:MLJ c: Mr. Richard H. Wessman Mr. Patrick M.
Sears Mr. Cornelius F. Holder,
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