ML20042G851
| ML20042G851 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 04/11/1990 |
| From: | Nichols S Maine Yankee |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20042G837 | List: |
| References | |
| MN-90-39, NUDOCS 9005160176 | |
| Download: ML20042G851 (6) | |
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l ENCLOSURE'34 Ma;,meYankee; m
FtELIABLE ELECTRICITY FOR MAINE EINCE 1912 i -
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. EDISON ORIVE AUGUSTA [ MAINE ;04330. (207) 6224068 April ill,1990 '
- MN-90-39 '
SEN-90-104_
y, Region I a.'
UNITED STATES NUCLEAR-REGULATORY. COMMISSION:
475 Allendale Road '
~ King of Prussi.a, PA. 19406-
- Attention: - Mr. : Thomas TL Martin,. Regional. Administrator-
Reference:
(a) LicenseNo.fDPR-363(DodetNo.-50-309)
(b): USNRC-Letter to MYAPCo. dated: February 20, 1990; Systematic ~
Assessment'ofLicensee(Performance-(SALP). Report No. 50-409/88 "
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Subject:
1990:SALP ReportL t
Gentlemen:
i Thank you' for the. opportunity to exchange 1our respective thoughts' on Maine-Yankee's: performance-during our March'1' meeting. We are-pleased:that the NRC's?
fl SALP report, Reference (b),< acknowledged our good' performance in all arease :We:
are.particularly pleased that:you continue to rate ;us'. Category-1 in: plant -
0 operations a'nd maintenance / surveillance.-
This SALP. period was one in which Maine:Yarikee's resources were; pressed to respond-to NRC' initiatives imposed-through1 team) inspection to an extent. greater than any we recall-- previously. We.are pleased that we were' able:toigain the',
respect of the teams in our ability'and willingness' to support:the' team. inspector process and its follow-up workload. Many of the inspection teams commended us for what they'found.
Attached are Maine Yankee comments on each of:the~ rated, areas, -and our plans -
for resolution of the licensee recommendations.
Wei plan-to continue our efforts.
t for improvement, focusing on those areas which you have rated as: Category-2.
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Very truly yours~,-
$dd)lrb' s
S. E. Nichols -
Licensing Section.Headi
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Attachment c:
Dr. Malcolm R. Knapp Mr. Eric J.. Leeds Mr. :Cornelius' F. Holden 9005160176 900507
.SEN90'104f.LTR PDR ADOCK 05000309 PDC g
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-Operations (Cateaory 1) i Maine Yankee continues to be rated Category 1 in the Operations area. We i
plan to continue using Norning Management' Meetings to focus on. ongoing _ and emerging issues. We expect continued management involvement in plant a:tivities, and we believe the excellent training and experience-of our personnel will ensure continued success in this area, i
Radioloaical Controls' (Cateaory 2)
The NRC noted several improvements in-this area.
Maine Yankee instituted a Radiation Protection Improvament Plan during the rating period. Maine Yankee has also recently contracted Westinghouse Corporation to conduct an internal evaluation of all, aspects of. our Radiation Protection Program. This evaluation was completed in March of this year, and we plan to present the results to members of your staff in early April.
There were no formal recommendations for ' licensee action listed at the end of the Radiation Protection portion of the SALP Report. The text of the report, L
however, suggested the following:
Improve procedure and RWP adherence Increase technician understanding of-job coverage requirements Improve management attention to and follow up on 'self-identified items Improve high radiation area access control--
Increase management oversite of radwaste transportation.
The above items came from inspections conducted during the SALP period, and they are being addressed as part of the Radiological Controls Improvement Plan.
In addition, the assessment conducted by Westinghouse further evaluated each of these areas in detail. The results of the Westinghouse evaluation will serve to focus our improvement efforts in the coming SALP period.
Maintenance / Surveillance (Cateaory 1)
We continue to be rated Category 1 in this area.
Maine Yankee has carefully reviewed the SALP report and identified several items for performance improvement.
The identified items have been added to a SALP Initiative Matrix prepared by our Maintenance Department with plans, assignments and schedules for resolution.
Emeraency Preparedness (Cateaorv 2. Imorovinal This is the only rated area that was rated at a lower category than the previous SALP. We are concerned with this rating, and are committed to restoring consistent Category 1 marks.
During this rating period Maine Yankee added an Emergency Preparedness Training Instructor, an Onsite Emergency Preparedness Coordinator and an Emergency Preparedness Supervisor to the Emergency Preparedness area.
The Onsite EP Coordinator has extensive reactor operations experience.
The Emergency Preparedness Training Instructor and the EP Supervisor have both held emergency preparedness positions in the past. Together, these individuals have more than ten years experience in radiological emergency preparedness.
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Two' items mentioned in the SALP report were identified during Maine Yank'ee's 1988 annual exercise.- The NRC noted that our Recovery Manager was not required to be part of event classification decisions, and they noted we had experienced 1
Ldifficulty using radios ~ to communicate between the Operations Support Center and the-inplant response teams.
Following that exercise we modified EP procedures to require the Emergency Coordinator confer with the Recovery Manager when deciding whether to escalate or de-escalate event classification, and the radio base stations were rewired to-separate frequencies for the.0SC and Security.
The SALP report also mentions that EP training "was noted to.be ' informal in many cases.". Maine Yankee has' committed to developing an EP training program based on-job analysis, INP0 guidance and industry standards. This. training, which is_ part of our improvement program, will -include new lesson plans on the use of-our recently installed dose. assessment program, METPAC. Under the new training 3rogram, and with assistance of the new training instructor, formal training will ae provided to the key emergency response organizat-ion individuals'and their:
alternates.
We have worked closely with the State of Maine to greatly enhance our.
emergency notification system.
To date, twenty-six. additional sirens have been installed, powered and tested. We committed to installing these sirens by the end of 1990.
Currently we are well ahead of schedule and, barring unforseen circumstances, we expect'to complete the installation by June of 1990. When completed, populated areas within a five-mile-radius of-the plant will be 3rovided with sixty decibel siren coverage. Tone alert radios will-be offered to: tie remaining residents. Outside the five mile radius populated areas'are covered with either sixty decibel siren coverage, tone alert radios-or notifier routes.
Most importantly, the enhanced alerting system, when complete, will result in a substantial reduction in the number of notifier routes.
We have developed-an EP Improvement Plan.
This plan assembles and tracks'NRC-and internal audit comments, drill-and exercise deficiencies, and self initiatives. We would like to present this plan and provide regular status reports to members of your staff as we feel it represents our program for I
regaining a SALP Category 1.
We will contact Mr. Lazarus of your staff separately to arrange such a meeting.
I Security (Cateaory 2) i l
The NRC noted several of our improvements in the area = of security.
Specifically noted was our management involvement, upgraded training and. hardware, and increased security force staffing.
Also noted was the improvement in event reporting and responsiveness.
j During this SALP period, Maine Yankee undertook a major effort to upgrade the Security Plan. Our goal was to develop an effective performance-based Security Program. We will continue to work with members of your staff to establish a Security Plan which is both effective and manageable.
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up Along with our facility upgrades in= security we have worked to improve 4
relations with our contracted security force and to reduce overtime..During' this SALP period we instituted weekly meetings with the contractor,' a Contractor i
Suggestion Award Program, and frequent contractor meetings that include licensee management-briefings. Our use of overtime has been reduced by increased staffing and by improved: scheduling of work assignments' for Security personnel.. Also, we plan to supplement our management team by adding.an individual who has nuclear J
power security systems knowledge.
We also plan to improve our Security Officer's depth.of understanding of the l
NRC's security requirements through improved realistic contingency drills. We have developed contractor hip pocket and checklist exercises which promote self-identification of-security items requiring attention. And, in an effort to improve security awareness by all individuals in our organization we have involved i
plant Maintenance and Operations Department personnel in local law j
enforcement / security drills.
Also,, Security' takes part-in the-Morning Management 1
meetings, and Operations requalification training' includes regular sessions on.-
q security: requirements.
- i Maine Yankee is committed to an improved performance-based Security Program-I that is effective in providing protection to-the public.and employees, 1
Initiatives towards this goal will continue throughout 1990 and beyond, working i
toward a consistent SALP l rating. We appreciate the staff's willingness to.
continue quarterly management meetings, and we _will do.so through the new SALP
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period.
l Technical Sucoort (Cateaory 2F Maine Yankee acknowledges the opportunity.to institute further improvements in areas such as dedication of commercial grade items, contractor oversite, and
.l qualification of electrical equipment.
Several efforts-are planned or underway in these areas.
Maine Yankee is continuing its efforts at improving environmentally qualified equipment and programs. During the 1990 refueling outage, a major upgrade to the containment EQ electrical penetrations will. be implemented to1 provide improved 10 CFR 50.49 qualified electrical penetrations.-
In addition, several_ limit switches will also be upgrtded during the 1990 outage to provide improved seals, and i
program / procedure enhancements continue to improve the EQ Program processes.
Procurement enhancement activities continue especially in the' areas of improved identification and verification of critical performance characteristics in the dedication process. Maine Yankee has completed a data base for molded case circuit breakers (MCCB). The data base. includes pedigree and technical data on the MCCBs, including data for developing critical. performance characteristics in the dedication process. Test procedures have been developed and testing of the commercial grade breakers dedicated for safety related application both in stock and in service is ongoing and should be completed prior to plant start-up from the 1990 refueling outage.
In addition, specifications and test criteria are being developed-for active engineered complex items to be used during the dedication process.
This effort includes performance testing of commercial grade items procured for safety-related applications.
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- The Plant Engineering Department has initiated a " Department Improvement j
Program" which includes an element dedicated to improving contractor oversight. A a
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" Lessons Learned" manual has been developed to inform craft and engineering
. personnel of past deficiencies and successes.in project / task implementation.
Also,~- an improved contractor. training program was developed _ to improve foremen / supervisory contractor training in procedure adherence, lessons learned application, quality of performance, and project success criteria.
. Safety Assessment /Oualit'v' Verification (Cateaory 2) l Maine Yankee acknowledges the need to improve our ability-to identify and l-prevent repetitive deficiencies.' Some of the 1989 initiatives in this area.
' include changes to the corrective action system (Procedure 0-16-1) to require o
determination of recurrence of each deficiency for.which 'a Corrective Action Request (CAR).is written. Also, our trend data base was revised and expanded to
. provide a'more' detailed breakdown of casual factors, and to incorporate _ deficiency.-
-data generated by the radiological controls. job observation / incident report programs.
Prior occurrences are now identified in each Unusual Occurrence Report
-l initiated by the Nuclear Safety Engineering Section. Deficiencies generated.by
.these reports are added to the trend data base.
We have increased our use of technical specialists and/or specialty training
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in the areas of instrumentation and controls, and emergency preparedness.- -We believe this has improved our ability to provide performance based internal assessments. Also, we recognize the need to increase management oversight of the i
-solid radwaste and transportation activities and plan to make appropriate-changes -
to the audit and surveillance programs.
During the rated SALP period, Maine Yankee instituted measures to utilize our plant specific Probabilistic Risk Assessment (PRA) Phase 1 document during' normal plant operations. Our on-shift Nuclear Safety Engineers (NSEs) have received training on our PRA and they are responsible for implementation'of the plant-integrated uses of the PRA. This is accomplished by. providing the safety =
engineers with a PRA based Equipment Importance Ranking Table for prioritization of Maintenance activities. The on-shift NSEs use the: table:and their knowledge of the PRA to perform daily review of Discrepancy Reports (maintenance work orders) and failed surveillances. This review. examines.the impact of the component failure or degradation-by itself, as well as the impact-of the degradation or failure due to other degraded equipment.
The SALP report noted that licensee initiated submittals were. typically of -
exceptional quality; whereas, submittals.in response to NRC initiatives were not-of the same quality.
Maine Yankee is in the process of instituting procedural 4
guidelines which we believe will aid in assuring technically complete and responsive submittals.
These guidelines involve Management planning sessions to discuss resolution of recently issued Generic Letters, Bulletins, etc. Our aim is to involve the individuals assigned to responding to the NRC initiative soon after s
receipt of the correspondence to enable more timely and complete resolution of the matter.
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