ML20035A620

Initial SALP Rept 50-213/91-99 for 910714-930109

ML20035A620
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	02/22/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20035A614	List: ML20035A613 ML20035A620
References
50-213-91-99, NUDOCS 9303290086
Download: ML20035A620 (27)

See also: IR 05000213/1991099

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ENCI.OSURE 1

INITIAL SALP REPORT

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

REPORT NO. 50-213/91-99

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CONNECTICUT YANKEE ATOMIC POWER COMPANT

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HADDAM NECK PLANT

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ASSESSMENT PERIOD: JULY 14,1991 - JANUARY 9,1993

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BOARD MEETING DATE: FEBRUARY 22,1993

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9303290086 930322'

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PDR

ADOCK 05000213

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TABLE OF CONTENTS

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INTRODUCTION

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II.

SUMM ARY OF RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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II.A

Oveniew

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II.B

Facility Performance Analysis Summary . . . . . . . . . . . . . . . . . . . . .

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III.

PERFORM ANCE AN ALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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III.A Plant Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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III.B Radiological Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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III.C Maintenance / Sun eillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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III.D Emergency Preparedness . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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III.E Secu ri ty . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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Iil.F Engineering / Technical Support

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III.G Safety Assessment / Quality Verification . . . . . . . . . . . . . . . . . . . . .

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IV.

SITE ACTIVITIES AND EVALUATION CRITERIA . . . . . . . . . . . . . . . .

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IV.A Licensee Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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IV.B NRC Inspection and Review Acdvities . . . . . . . . . . . . . . . . . . . . .

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ATTACHMENT - SALP EVALUATION CRITERIA

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I.

INTRODUCTION

The Systematic Assessment of Licensee Performance (SALP) program is an integrated

Nuclear Regulatory Commission (NRC) staff effort to collect available observations and data

on a periodic basis and to evaluate licensee performance on the basis of this information.

The program is supplemental to normal regulatory processes used to ensure compliance with

NRC rules and regulations. It is intended to be sufficiently diagnostic to provide a rational

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basis for allocating NRC resources and to provide meaningful feedback to the licensee's

management regarding the NRC's assessment of their facility's performance in each

functional area.

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An NRC SALP Board, composed of the staff members listed below, met on

February 22,1993, to review the observations and data on performance, and to assess

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licensee performance in accordance with the guidelines in NRC Manual Chapter 0516,

" Systematic Assessment of Licensee Performance," dated September 28,1990. The SALP

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Evaluation Criteria utilized by the Board are attached.

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This report is the NRC's assessment of the licensee's safety performance at the Connecticut

Yankee Atomic Power Station for the period of July 14, 1991, through January 9,1993.

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The SALP Board for the Connecticut Yankee Atomic Power Station was composed of:

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Chairman:

J. Wiggins, Deputy Director, Division of Reactor Projects (DRP)

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Members:

W. Lanning, Deputy Director, Division of Reactor Safety (DRS)

W. Raymond, Senior Resident Inspector, Haddam Ne i

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J. Stolz, Director, Project Directorate (PD) 1-4, Office of Nuclear Reactor Regulation (NR.R)

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A. Wang, Haddam Neck Project Manager, PD I-4, NRR

S. Shankman, Deputy Director, Division of Radiation Safety and Safeguards (DRSS)

L. Doerflein, Chief, Projects Section No. 4A, DRP

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Others in Attendance:

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E. Greenman, Director, DRP, Region III

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A. R. Blough, Chief, Projects Branch No. 4, DRP

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J. Linville, Chief, Projects Branch No. 3, DRP

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P. Habighorst, Resident Inspector, Haddam Neck

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R. De 12 Espriella, Reactor Engineer, Section No. 4A, DRP

J. Furia, Senior Radiation Specialist, DRSS

J. Lusher, Emergency Preparedness Specialist, DRSS

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G. Smith, Senior Physical Security Inspector, DRSS

J. Kottan, laboratory Specialist, DRSS

P. Patnaik, Reactor Engineer, DRS

Visitors:

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Victor F. Khromov, Deputy Chief Inspector of Ukrainian State Committee for Nuclear and

Radiation Safety General State Inspectorate

Andrei Y. Glinianov, Interpreter, International Relations Department, ULTainian State

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Committee for Nuclear and Radiation Safety

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II.

SUMMARY OF RESULTS

II.A

Overview

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The licensee continued to operate the plant safely. Adverse performance trends from the

previous SALP period in operations and safety assessment / quality verification were reversed.

However, performance in the emergency preparedness area declined. The licensee responded

well to a number of challenges during the refueling outage, and initiatives to reduce shutdown

risk were good. Sustained strong performance was observed in radiological controls,

security, and engineering / technical support. Engineering management continued to promote a

questioning attitude, resulting in the identification of existing design errors.

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Plant operations was rated a SALP Category 1. Operator performance was excellent with

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strong performance shown in response to transients. An adverse trend in licensed operator

performance was reversed. Operations management consistently took a conservative approach

to off-normal conditions, demonstrating an excellent safety ethic. A strong operator training

program contributed to operations' superior performance. Safety assessment / quality

verification was rated as a SALP Category 1. Management actions were successful in

reversing previous adverse trends in operator performance and in providing more timely

response to deficient plant conditions.

Maintenance and surveillance performance remained a SALP Category 2. The conduct of

maintenance supported safe and reliable operations. Improvements in maintenance's

performance reduced the number and significance of work documentation errors. The

performance of in-service testing and operational surveillance programs was good.

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Management actions were successful in decreasing the number of missed surveillances

significantly. While the improvement of previous maintenance and surveillance weaknesses

was noteworthy, overall change in performance was not substantial enough to change the

SALP category rating.

Emergency preparedness was rated a SALP Category 1, but NRC staff identified several

weaknesses which indicated a declining trend in performance. Weaknesses noted during the

conduct of the annual EP exercise included untimely development of dose projections to make

protective action recommendations, and delayed deployment of repair teams from the

Operations Support Center. Concerns were also noted with the completion of required EP

training, the maintenance of the emergency plan, and in the scope of audits.

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II.B

Facility Perfonnance Analysis Summary

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Functional

Rating, Trend

Rating, Trend

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Last Period

This Period

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Plant Operations

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Radiological Contmis

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Maintenance /

Surveillance

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Emergency

Preparedness

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1, Declining

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Security

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Engineering /

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Technical Support

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Safety Assessment and

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Quality Verification

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Previous Assessment Period: February 16,1990, through July 13, 1991

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Present Assessment Period: July 14,1991, through January 9,1993

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III.

PERFORMANCE ANALYSIS

III.A Plant Operations

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III. A.1

Analysis

Plant operations was rated a SALP Category I with a declining trend in the previous

assessment period. Operator professionalism, response to off-normal plant conditions, and

antrol room conduct were strong. The implementation of the revised technical specifications

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and the new emergency operating procedures were strengths. Operator performance was

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mixed, and the frequency of significant operator errors increased, suggesting a problem with

personnel performance.

During the current SALP period, the licensee completed an assessment of operator

performance issues to identify root causes of performance problems. The assessment found

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that better management of change (personnel, programs, procedures) would improve

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performance. NRC staff found that the internal review conducted to identify the root causes

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of the operator performance concerns and the corrective actions taken were thorough and

comprehensive.

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Although, one operator error involving the premature removal of a reactor protection system

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trip signal occurred early in the assessment period, there was a significant reduction in the

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number and significance of operator ermrs. Also, while minor performance problems

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persisted, principally in the area of log keeping and fire watch tours, operations management

continued to stress attention to detail in the performance of routine duties. Overall, station

management has been very effective in achieving significant improvements, and remained

active in addressing concerns in this area.

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The operators' professionalism, their conduct of control room operations, and their response

to off-normal plant conditions and transients were superior. Operators averted unnecessary

reactor trips on several instances by promptly and effectively acting to mitigate the effects of

equipment failures, and responded aggressively to a failure of a reactor coolant loop isolation

valve during plant cooldown. Strengths included maintaining proper plant operational

configuration, good communications, and thorough shift turnover activities. An excellent

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approach to safety was displayed by the shift supervisors in their response ~to plant equipment

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problems, and in the application of technical specification requirements. Operator adherence

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to procedures was very good during startup, shutdown and routine power operations. NRC

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staff noted good performance by auxiliary operators in the conduct of routine duties, and the

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auxiliary operator training program contributed to their strong performance. Overall, station

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housekeeping continued to be very good, although some areas required attention.

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Operation's management demonstrated a safety conscious approach toward plant operations by

acting promptly and conservatively to resolve safety issues affecting operator performance.

For example, management quickly acted to provide a bistable trip procedure following the

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identification of problems in this area. The licensee's fire protection program was well

implemented, and fire brigade training was good. Staffing was ample to support routine shift

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operations and training needs.

The operators displayed a high degree of proficiency during one initial operator licensing

examination and one operator requalification examination. All six operators who took the

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initial licensing exam passed the examination and received licenses. Three of four licensed

operators passed the requalification examination. All operators displayed highly developed

team skills and communications practices. A high degree of proficiency was also displayed

by the operators during a simulator drill for a station blackout as part of an NRC review of

the manual actions in the emergency operating procedures. During the emergency planning

exercise, NRC staff identified the control room operators' ability to diagnose problems and

formulate mitigating strategies as a strength.

Connecticut Yankee showed a superior level of performance in the area of licensed operator

evaluations. The operations training staff contributed to the operators' proficiency and to the

improvement of plant procedures and policy. The training staff demonstrated high standards

by challenging the operators with complex scenarios in the dynamic simulator environment.

'Ile training department worked closely with operations management bringing procedural and

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operator performance issues to the attention of operations management. The training

department also promulgated operations management policies and technical licensing issues to

the operators.

Operations procedure quality was very good and contributed to the safe operation of the

plant. Although the lack of clear guidance in a startup procedure contributed to a reactor trip

during a plant startup, overall, the number of plant events attributable to procedural problems

was low and improved from the last SALP period. An emergency operating procedure

problem that was identified by NRC staff during a requalification examination also received

prompt management attention.

CYAPCo successfully completed a number of challenging activities during the refueling

outage, taking a significant number of precautions to reduce shutdown risk. The shutdown

risk reduction achievements were noteworthy and contributed to mitigating the significance of

a partial loss of off-site power event during the outage. Operators identified one breach of

containment integrity during core alterations. The event was caused by poor procedure

guidance and control of secondary work activities. Licensee corrective actions were

thorough.

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In summary, operations management continued to be effective by providing prompt,

conservative assessments of plant events and operational issues. Operator performance was

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excellent, with strong performance shown in response to off-normal conditions and transients.

An adverse trend in licensed operator performance noted in the previous SALP was reversed.

The operators displayed a high degree of proficiency, and a strong operator training program

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contributed to their superior performance. Procedure weaknesses contributed to two events;

however, the quality of normal and emergency operating procedures continues to be very

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good.

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Performance Rating: 1

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Trend: None

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Recommendation: None

III.B Radiological Controls

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Analysis

The previous assessment identified continued high levels of performance throughout the

radiological controls functional area, with continued reductions in personnel exposure and

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source term onsite. High quality programs in the areas of effluents, environmental

monitoring, and radwaste were also identified.

Radiological Protection

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The licensee conducted a reorganization of its Radiation Protection Department during the

assessment period, to streamline its operation and better define programmatic responsibilities

within the Department. In addition, the licensee made a permanent appointment to the Health

Physics Manager's position. Initial indications are that these changes will enhance

performance within the Radiation Protection Department.

The licensee's program for the assurance of quality in the radiation protection area continued

to be a notable strength throughout the assessment period. Licensee responsiveness to

identified pmblem areas has been prompt and thorough. The licensee implemented an

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aggressive internal assessment program in the radiation protection area, conducting in-depth

reviews of a variety of program areas, resulting in pmgrammatic improvements.

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In addition to their self-assessment program, the licensee took prompt and thorough corrective

actions for several challenges to the radiation protection program that occurred during the

assessment period. Early in the assessment period, the licensee identified several instances of

improper high radiation area entries which the licensee responded to by making significant

improvements to its program in this area. As a result, the number of subsequent incidents

was reduced significantly. A further major challenge to the program has been in reducing

personnel exposure which occurs due to high radiation levels throughout the Containment,

which are the result of past fuel failures. In this area, the licensee has instituted high

boration shutdowns, and reduced the porosity size of the primary letdown filters. In addition,

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the licensee's decision to replace its present fuel with zircalloy clad fuel will also reduce the

source term. These initiatives reduced the source term late in the period.

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Radiological support of maintenance and surveillance activities throughout the period was

good, including that associated with steam generator manway and diaphragm removal, steam

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generator nozzle cover installation, fuel movement within the spent fuel pool, and reactor

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coolant loop isolation valve repairs. Minor control practice deficiencies, such as tools and

equipment being passed over radiologically controlled boundaries without proper survey, were

noted by NRC staff early in the assessment period; however, the licensee took prompt and

effective corrective actions, such that these problems did not recur in the last half of the

SALP period.

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The licensee made significant improvements in the training programs for both permanent staff

and outage contractor technicians, such that this area is now a licensee strength. In addition

to an in-depth initial and annual retraining program established for both radiation protection

and radwaste technicians, the licensee has led the industry in the development of contractor

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technician training. The initial training and qualification examinations developed by the

licensee have been adopted by numerous other utilities throughout the country, such that the

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licensee now maintains a registry of contractor technicians who have successfully completed

this training program. General employee training was consistent with regulations and guides,

but was somewhat unique in that it encouraged student participation. Staffing levels remained

appropriate throughout the assessment period. During this period the program continued to

be implemented in a highly successful manner.

The radwaste and transportation program continues to be a licensee strength. During this

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assessment period, the licensee made a sigriificant improvement in this~ program area by the

addition of a spent resin tank and processing area. This has resulted in greater flexibility in

waste processing, and made significant reductions in the doses expended in this program area.

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Radiological Effluent and Enviromnental Monitoring Programs

Excellent performance in the effluents and environmental monitoring program continued

during this assessment period. The licensee effectively implemented both the Radiological

Effluent Contre! Program (RECP) and the Radiological Environmental Monitoring Program

(REMP). Licensee personnel exhibited excellent knowledge of all RECP areas, including

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process and effluent radiation monitor calibrations and offsite dose calculations. Procedures

were well written and resulted in effective implementation of the RECP and REMP. QA

audits were thorough and of sufficient technical depth to probe for programmatic weaknesses.

The licensee had in place a thorough and eifective program for the mview of REMP samples

and QC data.

In summary, the licensee continued to implement a highly effective radiological controls,

radwaste effluents and radiological environmental monitoring programs. The areas of self-

assessment, work control and training of radiation protection technicians were regarded as

strengths.

Ill.B.2

Performance Ratine: 1

Trend: None

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Fecommendations: None

III.C Maintenance / Surveillance

III.C. I.

Analysis

The maintenance and surveillance area was rated category 2 during the previous assessment

period. Maintenance activities were well managed and coordinated and had no negative

impact on plant operations. The licensee successfully converted to revised technical

specifications; however, a significant decline occurred in the surveillance test program

performance. Also, management had not corrected quality services audit findings, and did

not critically assess maintenance program performance.

During this assessment period, the licensee's quality services department (QSD) continued to

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identify maintenance work order and administrative control deficiencies. Maintenance

department line management did not respond quickly to some of the QSD's audit findings in

the areas of work order documentation and the control of lubricants. The licensee attributed

these errors, in part, to the lack of a dedicated planning organization. Station management

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subsequently took corrective actions to address the problems by increasing the work planning

staff, and increasing management oversight of the work control process. At the end of the

assessment period, considerable reductions occurred in the number and significance of work

order documentation errors.

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Site management ensured maintenance activities contributed to the continued safe operation of

the plant. Significant maintenance challenges occurring during the refueling outage were

addressed effectively, and coordinated with other departments. These included fuel

reconstitution, repairs to the refueling water storage tank, repairs and inspections of the

reactor coolant loop isolation valves, main steam safety valve inspections, and emergency

diesel generator rotor repairs. Additionally, corrective actions to address the root cause of

the equipment problems were appropriate. NRC staff determined that maintenance first-line

supervisory oversight and involvement were good. Maintenance management's oversight of

routine maintenance activities during power operations was good, and maintenance

department input into root cause assessments of plant equipment malfunctions was thorough.

The Plant Operations Review Comraittee (PORC) provided valuable insight to prioritize

emergent maintenance work activities.

Maintenance department staffing is sufficient to support plant operations. Non-supervisory

personnel were technically knowledgeable of routine preventive maintenance and surveillance

activities. Site management also increased staffing for work planning and procedural

upgrades based on previous weaknesses in the work control process and timeliness of biennial

procedure reviews. As a result, improvements occurred in the depth and coordination of

planning, and in the timeliness of procedure reviews.

The conduct of routine maintenance and surveillance was good, with appropriate emphasis on

procedural adherence and personnel safety. ' Die licensee's conduct of the inservice test,

cperational surveillance and the steam generator eddy current test programs remained

significant strengths. No engineered safety feature or reactor protection system actuations

occurred due to improper maintenance. This was an improvement over the last assessment

period. However, poor communications between instrument specialists and the operations

department contributed to a significant feedwater transient, and improper outage modification

work resulted in a partial loss of off-site power.

The NRC noted improvement in the surveillance test program performance. A significant

decline occurred in the number of missed surveillances due to increased management attention

to surveillance tracking. The missed surveillances in this period were not indicative of a

program weakness. Additional actions to improve surveillance tracking were in progress at

the end of the period.

Maintenance and surveillance procedures were of good quality with only a few isolated

deficiencies such as improper verification of the load shed function during the loss of normal

power surveillance. Procedure quality continued to improve, as the licensee continued with

its self-assessment program to highlight procedure deficiencies.

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A motor operated valve (MOV) team inspection noted good MOV maintenance procedures

with generally well specified and controlled post-maintenance test requirements. The licensee

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adopted acceptable measures to incorporate vendor information and industry experience for

motor operated valves. However, a maintenance program weakness was noted, in that,

vendor information was not included in maintenance procedures to prevent potential spnng

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pack hydraulic lock and relaxation problems. NRC staff also noted that the licensee's

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training facilities for motor-operated valve overhauls and diagnostic testing were good.

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Equipment problem reporting continues to be a licensee strength. Examples of good

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identifications of equipment deficiencies were the potential to overload the emergency diesel

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generator as a result of troubleshooting the 'B' station air compressor, water / oil emulsion in

the senice water pump, and overlap circuit testing. Notwithstanding a strong identification

process, se.eral long-standing minor maintenance reliability issues were found associated with

the boric acid system.

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Several maintenance program enhancements impmved the quality of maintenance. These

included a preventive maintenance program to non-destructively test main steam safety

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valves, an upgrade of the surveillance pmgram for auxiliary feedwater relief valves,

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expansion of the lubricating oil program, modifications to valve packing program, and

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implementation of a pilot program for reliability centered maintenance.

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In summary, management consistently implemented a good maintenance and surveillance

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program to support safe plant operations. Management's actions in response to QSD

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identified deficiencies of work order documentation and control of lubricants improved;

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however, deficiencies continued to occur. Improvement in the surveillance test program was

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due to management attention in this area. The conduct of maintenance and sun'eillance

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activities was good, with appropriate emphasis on procedural adherence and personnel safety.

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Equipment problem reporting continues to be a licensee strength.

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III.C.2

Performance Ratinc: 2

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Trend: None

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Recommendations: None

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III.D Emergency Preparedness

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III.D.1

Analysis

During the last SALP, EP was rated Category I based on program quality, good Emergency

Response Organization (ERO) performance, and positive command and control of Emergency

Response Facilities during two NRC-observed exercises. Emergency response training,

technical issue resolution, and response facility upkeep were performed well. EP audit

independence and comprehensiveness were a concern.

During this SALP period, the licensee made three emergency declarations; all were Unusual

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Events. One was an instmment malfunction causing incorrect control rod position indication.

Two were gaseous radioactive releases; one of these was withdrawn, but the initial

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declaration was appropriate. There also was panial manning of the Emergency Operations

Center for Hurricane Bob; no associated emergency declaration was required or made.

Overall, emergency declarations were prompt and appropriate.

Operators performed extremely well during NRC-conducted EP walk-through drills. In the

full-participation emergency exercise, there were strengths in event diagnosis, formulation of

mitigating strategies, and command and control in the Emergency Operations Facility and the

Corporate Emergency Operations Center (CEOC). Protective Action Recommendations

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(PARS) were timely and accurate, despite a weakness involving failure by the CEOC dose

assessment u iff to provide timely and correct dose projections. Another weakness was the

notably slow formation, briefing and deployment of damage control teams by the Operations

support Center (OSC). Neither of these weaknesses were identified by the licensee's critique.

Overall performance in events, walk-through drills, and the emergency exercise was very

good, but with significant room for improvement in CEOC dose projection development and

in OSC performance.

Participation of all ERO personnel in at least one licensee drill per year was a goal; about

95% of those personnel did so. That high level of drill panicipation showed a strong

commitment to EP training. The licensee held other EP training throughout the year in

accordance with the Emergency Plan and Nuclear Training Department directives. Off-site

support groups were trained by the corporate staff. Required classroom training and the five

drills conducted were appropriate for maintaining ERO qualifications. However, the NRC

identified that Technical Support Center Managers had not received the licensee-prescribed

annual training in Emergency Action Levels (EALs). Overall, EP training was very good,

with strong drill participation, but there was room for improvement in assuring completion of

training.

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The licensee began staffing a 24-hour, On-Site Director of Site Emergency Operations

(ODSEO) position during this period. This relieved the shift supervisor of DSEO

responsibilities earlier in an event. NRC observations during emergency drills, simulator

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drills, and event responses concluded that the licensee's emergency response capability had

been enhanced by this change. Also, an effective call-out procedure with strong management

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oversight of call-out drills was a notable strength. Both the ODSEO staffing commitment and

the call-out program demonstrated strong management support for EP.

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EP specialist staffing was sufficient to conduct drills and exercises, maintain emergency

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response facilities, and maintain a well-qualified Emergency Response Organization (ERO).

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The EP staff was reorganized and increased significantly in size, both to better support the

Haddam Neck and Millstone sites and to improve EP support for the State and for local

municipalities. As reorganized, the EP Department was headed by a Corporate (NUSCO) EP

Director and included the EP Technical Programs staff, the Off-Site Program staff, and the

On-Site EP staffs at Haddam Neck and Millstone. This reorganization showed strong

management involvement in and support of EP; its effectiveness will require additional time

and review to assess.

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Routine management involvement in EP was excellent. Senior technical staff and

management maintained ERO qualifications. Tne On-Site Lead Senior Nuclear Emergency

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Preparedness Coordinator was actively involved with plant management daily. A close and

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cffective working relationship between the on-site EP staff, plant managers, the corporate

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office EP staff, and corporate managers was indicated by the high quality of the many

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changes and upgrades to the emergency plan implementing procedures. The EP staff also

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met with State and local officials to discuss the NUSCO ERO and other areas affecting off-

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site response. NUSCO also supported State and local emergency plan updates to meet new

Federal Emergency Management Agency (FILMA) directives. Further, a 10-meter, back-up

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meteorological mast was installed to provide additional wind speed and direction to

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compensate for Doppler Acoustic Sounder inaccuracy during high winds or heavy

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precipitation.

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The licensee conducted two annual EP audits during this assessment period. The first was

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performed by personnel who did not have direct responsibility for the EP program, but who

reported to the Radiological Assessment Branch Manager, who had that responsibility. The

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second audit was conducted by the NUSCO Quality Services Department, providing auditor

independence. EP audits were generally sufficient in scope and depth, but the required 12-

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month audit of off-site interfaces was not included in the second audit. Overall, EP auditing

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was assessed as adequate. NRC's auditor independence conce.rn was resolved; the audit

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scope concern remains.

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A weakness in Emergency Plan maintenance was evident in: (1) a valid Emergency Plan

Implementing Procedure (EPIP) change in the Emergency Action Ixvels (EALs) of the

Containment critical safety function status tree was not incorporated in the plan, which was

two revisions behind the EPIP revisions; and (2) minor discrepancies between the inventory

lists in the Emergency Plan and those in use in the facilities. No associated response

inadequacy or facility degradation was evident. These were instances of inattention to detail

in keeping the Emergency Plan current. Inasmuch as the Emergency Plan was otherwise well

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maintained, plan maintenance was assessed as satisfactory.

All equipment in the Emergency Response Facilities was operable and properly maintained,

and response facility maintenance was assessed as excellent.

In summary, the licensee's EP program is sound. A high level of Emergency Response

Organization qualification was shown by pmficient event responses and by very good

emergency exercise performance and drill panicipation. Maintenance of Emergency

Response Facilities was excellent. Strong management support of and participation in EP

was evident in the assignment of 24-hour duty On-Site Directors of Site Emergency

Operations, in a major change to upgrade the EP organization, and in routine EP involvement

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by management. There was good coordination with State and local officials. The

Emergency Plan and procedure changes made were of high quality. However, weaknesses

were noted in the scope of audits , Emergency Plan maintenance, Operations Support Center

performance, development of dose projections by the CEOC, and assurance of completion of

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required EP training, indicating a noteworthy negative trend.

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III.D.2

Performance Rating: Category 1

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Tren<i: Declining

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III.D.3

Recommendations: None

III.E Security

III.E.1.

Analysis

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During the previous assessment period, the licensee's performance was rated as Category 1

based upon a very effective, performance-based security program with cicar evidence of

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management support. The self-assessment and audit programs were effective in identifying

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potential weaknesses and ensuring prompt corrective actions. Security management exhibited

a high degree of expertise and maintained an excellent knowledge of nuclear security

objectives.

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During this assessment period, the security program continued to be effective and

performance-based. Corporate and plant security management attention to and involvement

in the program were evident through the continuation of improvements and enhancements to

plant security. These included a major protected area lighting upgrade, the procurement of a

new security vehicle, and the installation of a new computerized badging system.

Additionally, the licensee completed an upgrade to a vital area, which included the installing

of additional fencing, a new type intrusion detection system and additional assessment

equipment. Appropriate compensatory measures were established by the licensee during

security upgrades. These improvements and enhancements reflect the licensee's awareness of

program needs and indicate the licensee's commitments to an effective, performance-oriented,

and high quality program.

Excellent rapport and effective communications among security and other plant groups were

maintained throughout the assessment period. These were strengthened by security

management's active participation in the daily plant staff meetings, especially during the

refueling outage. This interaction provided a vehicle for identifying and resolving potential

problems prior to the start of the planned work. Corporate and plant security personnel also

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remained active in industry groups involved with nuclear plant security matters.

Additionally, the licensee maintained a close and effective liaison with state and local law

enforcement agencies through interface meetings and drill participation.

Late in the assessment period, the Security Manager was promoted to a corporate security

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position. He was succeeded by the Security Coordinator who administered the program for

the remainder of the period without a reduction in performance or effectiveness. The

licensee's security staff, under the Security Manager, was composed of well trained and

qualified security professionals, who provided effective oversight and guidance to the contract

security force. During this assessment period, the turnover rate in the security force was

low. Staffing remained consistent with program needs and members of the security force

continued to demonstrate a professional demeanor, high morale and, in general, an excellent

knowledge and understanding of their duties.

The security force training program, administered by the security contractor, was well

developed and staffed by experienced and knowledgeable instructors. Training facilities and

training aids were appropriate and well maintained. The program is continually upgraded

through feedback provided by trainers assigned to each shift. ' During this assessment period,

there were several loggable badge issuance events attributable to errors by new security

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personnel. To rectify the problem, the training staff developed and incorporated changes in

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the requalification training program to reinforce the instructions in this area. The corrective

action appeared to be effective based on a significant reduction in the occurrences of similar

events. Additionally, the licensee continued its initiative of conducting self-assessments and

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appraisals to provide additional oversight of program implementation and personnel

performance.

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The licensee submitted one, one-hour event report during the assessment period. The event

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involved a security guard stationed as a compensatory measure who left his post momentarily

to conduct a non-security related activity. The licensee took pmmpt and appropriate

corrective actions. The licensee's event reporting procedures wem clear and consistent with

NRC requirements, and were well understood by the security supervisors. The licensee's

security event logs properly categorized all events, which were appropriately analyzed and

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tracked, with timely corrective actions, as necessary.

NRC staff found the licensee's Fitness-for-Duty pmgram and its implementation to be

responsive to both the spirit and intent of the NRC's rule, as well as aggressive,

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comprehensive and directed toward assuring public health and safety.

During this assessment period, the licensee submitted three revisions to its Physical Security

Plan and one revision to its Contingency Plan under the provisions of 10 CFR 50.54(p). The

revisions were technically sound and reflected well-developed policies and procedures,

indicating appmpriate management oversight and attention to quality.

In summary, the licensee continued to maintain a very effective and performance-based

program. Notable program strengths included excellent management support for

improvements, very effective oversight, active participation in industry groups and liaison

with law enforcement agencies, very professional and knowledgeable staff, performance-

oriented training with effective feedback, and very good rapport with licensee and contractor

management. These attributes demonstrated the licensee's commitment to a high quality

security pmgram.

III.E.2

Performance Rating: 1

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Trend: None

III.E.3

Recommendations: None

III.F Engineering / Technical Support

Analysis

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This functional area was rated Category 1 in the last SALP period. The previous SALP

report identified a strong and effective corporate engineering as . evidenced by the planning,

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design and implementation of several major design projects. Plant engineering was strongly

involved in providing suppert to plant operations. Corporate engineering was restructured

near the end of the last SALP period to form the new Connecticut Yankee Project Services

Department (CYPSD).

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During this SALP period, the hcensee mamtained the strengths identified in the previous

SALP. The new CYPSD organization was staffed and operational during the summer of

1991 and assumed leadership on all cycle 16 refueling outage projects. The Department

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established a satellite office at the plant that was responsive to the needs of the plant staff.

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The licensee's engineering planning and design during this SALP period were excellent, and

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engineering safety evaluations were completed in a high quality manner. Examples of major

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engineering plant modification packages included the conversion to a new neutron flux

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mapping system, addition of mid-loop instrumentation to monitor coolant levels in the reactor

coolant loop, modifications to the auxiliary feedwater system to correct design deficiencies

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and installation of a new condensate storage tank.

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Engineering resolutions oflong-standing equipment problems were effective. Plant

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modifications developed by the engineering organization to resolve long-standing issues

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included an upgrade of the containment isolation system, and changing existing isolation

valves and vent valves to comply with 10 CFR 50 Appendix J requirements. Two condensate

pots on the pressurizer level instrumentation reference legs were replaced with an impulse

line from the pressurizer, to establish a constant reference leg. This addressed an issue

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concerning inaccurate pressurizer level indication during rapid plant depressurization, due to

hydrogen effervescence in the pressurizer condensate pots. Additionally, the containment air

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recirculation (CAR) fans' service v.ater filter bypass valves were modified to open

automatically upon a high containment pressure actuation signal, to ensure maximum flow

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through the CAR fan coolers. This eliminated the need to station operators at the bypass

valves if filter differential pressures would exceed their limits.

The engineering organization demonstrated a conservative approach to resolving engineering

issues, and a high regard for equipment and personnel safety. For example, during ultrasonic

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inspection of the cycle 16 core, corporate engineering used more restrictive guidelines than

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those recommended by the vendor. This conservatism better assured satisfactory fuel

performance during the fuel cycle. During erosion / corrosion monitoring of high energy

piping, engineering demonstrated a conservative approach by measuring the minimum wall

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thickness of 523 components, a sample size significantly above the 202 components predicted

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by computer modeling as candidates for pipe thickness measurements. This approach was

based on industry experience, plant specific experience, walkdowns, and known concerns

with piping in the Terry Turbine Building ('ITB)'. ' Throughout the'SALP period,

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engineering's Probabilistic Risk Analysis (PRA) group provided useful insights into proposed

plant modifications, surveillance test intervals, and changes to the emergency operating

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procedures.

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The licensce's identification of technical issues continued to be a strength. Probing questions

resulted in the identification and resolution of several safety issues, including those involving

setpoints for relief valves in the emergency diesel generator (EDG) air system, an operability

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determination for a containment isolation valve, the heat removal capability of the EDG heat

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exchangers, postulated environmental conditions in the 'ITB, operability of a letdown

containment isolation valve, and environmental qualification of auxiliary feedwater

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instrumentation. Engineering operability decisions for the problems identified during the

auxiliary feedwater post-modification testing, the bio-fouling of the service water system

components, the tube leakage and plugging of the containment air recirculation coolers, and

EDG room ventilation issues were acceptable.

The MOV team inspection noted that, although the licensee had developed an Engineering

Program Plan to address the recommended actions of Generic Letter 89-10, the detailed

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MOV program project instructions were inecmplete at the time of the inspection, and an

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assessment of the program could not be made. An internal licensee audit had previously

identified that development of the MOV progam details was not completed on schedule, and

the licensee had to revise the commitment date. Additional resources were provided to

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ensure the MOV program manual was issued by the revised commitment date. The MOV

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team also identified a concern regarding the need for the timely evaluations of test results for

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impact on MOV operability.

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The plant modification program was a licensee strength. However,- the licensee identified

isolated design deficiencies in the actuator for the steam admission valve for the auxiliary

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feed water pump turbine during post-modification testing, during validation of analog to

digital conversion of the auxiliary feedwater signals, in the evaluation of the acceptability of

containment isolation valve seat material, and in the acceptability of auxiliary feed water

check valves. The deficiencies were not indicative of programmatic pmblems. NRC staff

also noted other instances where engineering support could be improved, including untimely

revision to hydraulic resistance curves for the containment air recirculation fans, untimely

causal evaluation of auxiliary feedwater flow indications, and insufficient evaluation of the

effects of the seal water hoses during the recirculation mode of operation.

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The staffing level in Engineering increased during this SALP cycle. This, in part, resulted in

a consistent reduction in the engineering backlog through eacn quarter of 1992 by providing

increased emphasis on administrative closcout efforts. Training of engineering department

personnel was satisfactory. New engineers received formal indoctrination in engineering

instructions, station procedures, administrative procedures, a curriculum in nuclear training,

and on-the-job training. All engineering personnel were required to complete annual

refresher training, reviewing specific procedures and applicable sections of 10 CFR 50. In

Corporate Engineering, the new engineers were trained on applicable procedures, and

provided specialized training as required.

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In summary, the licensee's performance in this area remained high. Management support and

attention to this program were evident. The engineering organization's performance was

excellent, providing support to the plant site in design, engineering, coordination, outage

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planning, and resolution of technical issues. The licensee's identification of technical issues

continues to be a strength. The plant modification program was considered a strength.

Increased engineering department staffing levels were noted to have a positive impact on the

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engineering backlog.

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III.F.2

Performance Rating: 1

Trend: None

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III.F.3

Recommendations: None

Ill.G Safety Assessment / Quality Verification

III.G. I .

Analysis

In the last SALP, the licensee received a Category I rating in this functional area. Strengths

identified included continued corporate and station management commitment to plant safety,

management emphasis on critical self assessment activities, and use of the "living"

probabilistic risk assessment. Untimely transmittal oflicensing submittals to NRC remained a

weakness.

During this assessment, the Plant Operations Review Committee- (PORC) and the Nuclear

Review Board (NRB) continued to perform critical and thorough reviews of technical issues.

Noteworthy examples included problems with the reactor fuel vendor's quality assurance

program, auxiliary feedwater modifications, and acceptability of containment isolation valves.

The committees adequately monitored and evaluated routine plant performance issues.

Examples of routine plant performance issues included the restart from the reactor trips, and

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cleaning of the spent fuel pool heat exchangers during the refueling outage. In addition, the

NRB routinely reviewed quality services department (QSD) reports and the Combined Utility

Assessment Report, The assessment reports resulted in required correcdve actions that

contributed to the prevention of problems; Critical self-assessment activities occurred

concerning controls for vendor information, and actions regarding containment isolation valve

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seat material performance. Isolated deficiencies in performance of assessment activities

occurred. The deficiencies included failure to perform a process control program review, and

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emergency planning audit of off-site activities.

The licensee continues to implement a strong problem identification program. The plant

information report process was a program strength. The NRC noted appropriate causal

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analysis and corrective actions to events. The licensee consistently reported events

conservatively and the Licensee Event Reports were of good quality.

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Root cause evaluations documented acceptable actions to prevent recurrence. However,

issues that continued to Ircur prior to and during the assessment periou included fire

protection barrier compensatory measures, adequacy of technical specification surveillance

and tracking, reliability of the boric acid filter, use of incorrect material for high piessure

safety injection pump seal water supply hoses, and suitability of seat material for containment

isolation valves. The NRC noted improvement of corrective action scope near the end of the

assessment period.

There was a decline in reportable events that was directly attributable to the improved

performance by the plant staff, as evidenced by the decrease in the number of personnel

errors. Cuerall, the number of reports issued during the SALP cycle was largely driven by a

conservative approach to reporting and the licensee's identification of design deficiencies,

which reflects on the licensee's strong safety ethic and the effectiveness of the programs to

identify, evaluate and report potential safety problems.

The operating experience feedback (OEF) program was comprehensive and generally effec:ive

to address industry events. Good actions were observed by NRC staff in response to a high

energy line break vulnerability identified as result of a similar configuration at Millstone

Unit 1. However, NRC staff determined that some actions in response to industry events

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were not effective, or actions taken were delayed. Examples include emergency diesel

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generator surveillance deficiencies, reactor coolant loop isolation valve controls, and

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preservation of non-safety grade service water heat exchangers. Licensee responses to

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10 CFR Part 21 reports were appropriate.

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Licensing activity during the SALP period remained high. The licensee completed work on

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several long-standing licensing issues including station blackout,10 CFR 50 Appendix R and

the new switchgear building, Zircaloy clad fuel conversion, and high energy line breaks in

the Terry Turbine Building. These issues entailed significant reviews in terms of resources

and safety significance. The submittals were complete, with good technical analysis. The

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resolution of these items improved the safety of the plant and provided a clearer design basis.

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The engineering and technical support to close these issues was significant. The licensee

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demonstrated excellent knowledge and understanding of the plant design and the regulatory

requirements associated with these issues. Licensee management attention and involvement

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were evident in their continued effort to reduce the licensing backlog except for several

Systematic Evaluation Program (SEP) topics. While many licensing 'ssues were effectively

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addressed, the licensee was untimely on several submittals most notably dealing with SEP

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topics. Although this has not created any safety problems or concerns, this is a recurring

issue apparently caused by overly optimistic proposed schedules. In particular, the licensee

had slipped the submittal schedules by 6 months on containment isolation, high energy line

breaks inside containment, and wind and tomado loads.

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The licensee's responses to generic letters (GL) and bulletins during the SALP period were-

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generally complete and timely. However, the licensee missed a major milestone in their GL 89-10 submittal. The MOV program was to have been developed by April 1991, but based

- on an internal licensee audit, the licensee determined that the program details would not be

completed until December 31,1992.

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The licensee has maintained the plant specific PRA and continued its use in the Integrated

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Safety Assessment Program (ISAP). A sampling verification of completed ISAP topics and;

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Three Mile Island (TMI) Action Items concluded that the licensee continued to maintain the.

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controls and processes committed to in response to the topics. The examples verified wem

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ISAP topics such as Loss of Direct Current Study, Bayesian Updates, and Steam Binding of

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the Auxiliary Feedwater System. The TMI action item concerning reactor coolant pump seal

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cooling modifications was completed. The licensee has used the PRA to gain insights for

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their Risk Reduction Task Force, positioning of service water control valves, and extending

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surveillance intervals in TSs.

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In summary, corporate and plant management attention and involvement in this area has

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impmved as demonstrated by the plant's performance during this SALP period. Licensee self .

assessment programs reversed the declining trends in Plant Operations and Safety

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Assessment / Quality Verification. Program strengths identified during the previous SALP

period were maintained. PORC and NRB reviews have been critical and thorough. The -

licensee continues to implement a strong problem identification program. The operating

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experience feedback program was generally comprehensive and effective in addressing

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industry events. The licensee continued to effectively use their living PRA for various

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licensing actions. The licensee continues to make significant progress in reduction of the

licensing backlog.

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III.G.2

Performance Rating: 1

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Trend: None

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III.G.3

Recommendations: None

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IV.

SITE ACTIVITIES AND EVALUATION CRITERIA

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IV.A Licensee Activities

This assessment period began on July 14, 1991 with the plant operating at full power. Full

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power operations continued until August 18, when plant load was reduced to 40% in response

to the threat of Hurricane Bob. Full power operation resumed on August 20 and continued

until the end-of-cycle power coastdown began on October 10, 1991.

On October 17, a capacitor failed in the 'A' condensate pump power supply. Plant load was

reduced to 40% for repairs. However, high generator exciter vibration caused the licensee to

start the refueling outage two days early. The plant was cooled down to Mode 5 on

October 21.

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Iieactor disassembly and core off-load was complete on November 16. Major outage

activities included: repair of the #3 reactor coolant pump isolation valve; repair of the A

emergency diesel generator pole piece; fuel recenstitution (there were 100 failed pins and no

core debris was found); steam generator inspections and tube plugging; inspection of

sceandary plant piping for crosion/ corrosion; repair of the refueling water storage tank; and,

modifications to the auxiliary feedwater (AFW) system.

The reactor remained de-fueled until December 23. Reactor reassembly was completed and

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Mode 5 was reached on January 26. The plant remained in Mode 5 as erosion / corrosion

inspections protracted the scheduled restart date, and due to the need to address CAR tube

leakage. Plant heat-up to Mode 4 occurred on February 13 and Mode 3 was reached on

February 17. Further startup activities were delayed pending the correction of a diesel

generator load shed deficiency, and the completion of modifications to the AFW steam

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admission valves.

The reactor was taken critical on March 11,1992. Two reactor trips occurred for unrelated

reasons on March 12, due to a procedure inadequacy and equipment failure, respectively.

The reactor was restarted on March 15 and rated power was attained on March 27,1992.

Connecticut Yankee operated at full power for the rest of the SALP period, except for power

reductions ~due to routine te' ting and in response to equipment failures. Power was reduced

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for brief periods on May 5, May 8 and May 14,1992 to support repairs to the feedwater

regulating valve pneumatic positioners. Power was reduced to 65% on July 20-21,1992 to

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perform quarterly valve test and to isolate a ground on the low pressure steam dump system.

The SALP period ended on January 9,1993 with the plant at full power and having been on-

line for 297 days.

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IV.B NRC Inspectioe < -d Review Activities

Two NRC reht inspectors were assigned to the site during the assessment period. NRC

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team insperdons were conducted in the followmg areas

A Safety Team Inspection was conducted December 9 through Decernber 13,1991, to

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evaluate the effectiveness of the identification, evaluation, and determination of

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operability for safety-related equipment.

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An Emergency Pmwsiness Inspection was conducted on April 25,1992, to observe

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the full participation annual exercise.

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A Systems Based Instrument and Controls Inspection was conducted February 24

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through March 13,192 to evaluate design and configuration requirements of selected

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instrumentation.

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A Fire Safe Shutdown Inspection was conducted June 22 through 26,1992, to

evaluate Fire Protection / Prevention Program and the facilities for 10 CFR 50,

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Appendix R Safe Shutdown.

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A Motor-operated Valve Inspection was conducted October 5 through 9,1992 to -

evaluate the program in comparison to NRC expectations in Generic I.etter 89-10.

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ATTACIIMENT

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SALP EVALUATION CRITERIA

Licensee performance is assessed in selected functional areas, depending on whether the

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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. Special 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

Approach to the resolution of technical issues from a safety standpoint

Enforcement history

Operational and construction events, including response to, analysis of, reponing of,

and corrective action for

Staffing, including management

Effectiveness of training and qualification program

On the basis of the SALP Board assessment, each functional area evaluated is rated according

to three performance categories. The definitions of these performance categories are given

below.

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Category 1:

Licensee management attention to and involvement in nuclear safety or

safeguards activities resulted in a superior level of performance. NRC will

consider reduced levels of inspection effort.

Category 2:

Licensee management attention to and involvement in nuclear safety or

safeguards activities resulted in a good level of performance. NRC will

consider maintaining normal levels of inspection effort.

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Catecorv 3:

Licensee management attention to and involvement in nuclear safety or

safeguards activities resulted in an acceptable level of performance. NRC will

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consider increased levels of inspection effort.

Category N: Insufficient information exists to support an assessment oflicensee

performance. These cases would include instances in which a rating could not

be developed because of insufficient licensee activity or insufficient NRC

inspection.

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The SALP Board may assess a functional area and compare the licensee's performance during

a portion of the assessment period to that during an entire period, in order to determine a

performance trend. Generally, performance in the latter part of a SALP period is compared

to the performance of the entire period. Trends in performance from one period to the next

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may also be noted. The trend categories used by the SALP Board are as follows:

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Attachment

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Improving:

Licensee performance was determinecl io be improving during the assessment

period.

Declining:

Licensee performance was determined to be declining during the assessment

period and the licensee had not taken meaningful steps to address this pattern.

A trend is assigned only when, in the opinion of the SALP Board, it is significant enough to

be considered indicative of a likely change in the performance category in the near future.

For example, a classification 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

safety performance. If at any time the NRC concluded that a licensee was not achieving an

adequate level of safety performance, it would then be incumbent upon the NRC to take

prompt appropriate action in the interest of public health and safety. Such matters would be

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dealt with independently from, and on a more urgent schedule than, the SALP process.

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