ML20052B319
| ML20052B319 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 04/01/1982 |
| From: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Conway W VERMONT YANKEE NUCLEAR POWER CORP. |
| References | |
| NUDOCS 8204300284 | |
| Download: ML20052B319 (47) | |
Text
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APR 011982 Docket No. 50-271 s
Vennont Yankee Nuclear Power Corporation RECEjVED ATTH: Mr. W. F. Conway, President t
Nmumg7902' 2 Apgg and Chief Operating Officer J
411 Western Avenue q,'
8emanad, @ '
Drawer 2 iSC West Brattleboro, Vennont 05301 3
Gentlemen:
Subject:
Systematic Assessment of Licensee Perfonnance (SALP)
This refers to the SALP perfonned by this office on September 14, 1981 regarding the Vermont Yankee Nuclear Power Station and to the discussions of our findings held with your staff on Septer4er 29,1981. That SALP covers the period of July 1,1980 through June 30, 1981.
The attached SALP report for your facility is being issued and distributed in accordance with recently established flRC policy. Although this report was prepared under previous criteria, the results have been reclassified under present guidance.
No reply to this letter is required. Your cooperation is appreciated, i
Sincerely.
Original atrned 2 n.
Ronald C. Ilaynes j
Regional Administrator
Enclosure:
SALP - Evaluation Report l
l cc w/ encl:
fir. Warren P. Murphy, Plant Manager Mr. R. L. Smith, Licensing Engineer Hr. E. W. Jackson, Manager of Operations i
Mr. L. H. Heider, Vice President l
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Infonnation Center (flSIC)
NRC Resident Inspector State of New ifampshire State of Vennont V. Rooney, HRR, LPH 20430cp_gy-c
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APR 011982 Corporation bec w/ encl:
Region I Docket Room (with concurrences)
Chief, Operational Support Section (w/o encis)
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SALP Cycle 2 SYSTEMATIC ASSESSMENT'0F LICENSEE PERFORMANCE VERMONT YANKEE NUCLEAR POWER CORPORATION VERMONT YANKEE NUCLEAR POWER STATION Region I PERFORMANCE EVALUATION Evaluation Period: 7/1/80 - 6/30/81 Board Date:
September 14, 1981 e
1 -1 I
r 9
FOREWARD The Region I SALP Board performed this assessment prior to the decision of the Nuclear Regulatory Commission to revise the NRC's program of Systematic Assessment of Licensee Performance. An important change in this revision was to' retitle and redefine the performance categories. This change affords better characterization of the staff's evaluations of licensee performance.
These revised performance cateSories were used for this report. The SALP Board formally evaluated the licensee's performance before the revised guidance was available. These initial rankings were subsequently equated with and converted to the new performance categories without fornally reconvening the Board.
The performance categories are to be printed in the Federal Register within a few weeks.
Each functional area evaluated is characterized as being in one of the following categories:
a.
Category 1:
Reduced NRC attention may be appropriate.
Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of per-formance with respect to operational safety or construction is being achieved.
b.
Category 2: NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are rea:cnably effective such that satisfactory performance with respect to operational i
,1 safety or construction is being achieved.
c.
Category 3:
Both NRC and licensee attention should be
. increased.
Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or construc-tion is being achieved.
In characterizing the licensee's performance in a functional area as being in one of the Categories, performance is evaluated against the following criteria:
a.
Management involvement in assuring quality, b.
Approach to resolution of technical issues from safety standpoint, c.
Responsiveness to NRC initiatives, d.
Enforcement history, e.
Report 1g and analysis of reportable events, f.
Staffing (including management), and g.
Training effectiveness and qualification.
ii
- VYNPC (Varmont Yankee'NPS)
SALP Cycle 2-l VERMONT YANKEE NUCLEAR POWER STATION PERFORMANCE EVALUATION AND ACTION PLAN September 14, 1981 REGION I LICENSEE PERFORMANCE EVALUATION (OPERATIONS)
Facility:
Vermont Yankee Nuclear Power Station Licensee: Vermont Yankee Nuclear Power Corporation Facility Information:
Docket No.
License No./Date of Issuance Unit No.
50-271 DPR-28/ March 21, 1972 1
Reactor Information:
Unit 1 NSSS General Electric MWt 1593 Appraisal' Period: July 1, 1980 to June 30, 1981 Appraisal Date:
September 14, 1981 Review Board:
R. W. Starostecki, Director, DR&PI, RI V. L. Rooney, Licensing Project Manager, NRR T. T. Martin, Director, DE&TI, RI G. H. Smith, Director, DEP&OS, RI W. J. Raymond, Serior Resident Inspector, Vermont Yankee R. R. Kefmig, Chief, PB#2, DR&PI, RI Attendees:
R. M. Gallo, Chief, RPS 1A, DR&PI, RI S. J. Collins, Resident Inspector, Vermont Yankee 4
r 1-2
I l
VYNPC (Vermont Yank:e NPS) l SALP Cycle 2 PERFORMANCE DATA A.
Number and Nature of Noncompliance Items 1.
Noncompliance Category:
Number Violations 0
Infractions 5
Deficiencies 3
Severity Level V 10 Severity Level VI 4
Deviations 1
Total 24 2.
Areas of Noncompliance:
(Tabulated in Appendix 1 -A) 8.
Number and Nature of Licensee Event Reports 1.
Tabular Listing:
Type of Event:
Total A.
Personnel Error 4
B.
Design, Man./Const./ Install.
2 C.
External Cause 1
D.
Defective Procedure 3
E.
Component Failure 30 X.
Other 1
Licensee Event Reports Reviewed (Report Nos.):
Report No. 80-20/3L through 80-43/3L, and 81-01/3L through 81-15/3L I-3 l
i
SALP Cycle 2 2.
Causal Analysis (Review Period July 1,1979 through June 30,1981)
Four sets of common mode events were identified.
i a.
LERs 80-32, 80-33, 80-37, 80-41 and 81-11 concern piping / component degradation caused by service and/or environmental condition induced sensitivities. The dominant failure mode is cracking due to intergranular stress corrosion.
LER 81-16 constitutes 4
another event in the same series, but falls outside the analysis period (7/22/81).
Confirmation of IGSCC as the failure mode for LERs 81-16 and 81-11 is pending completion of metallurgical analyses.
LER 80-41 represents a failure caused by chloride induced stress corrosion cracking.
i The licensee has taken immediate corrective actions for each I
failure by replacing / repairing the affected components.
Surveil-lance programs for the affected systems have been implemented.
Actions taken for each area have been inspected.
Long term
. corrective actions for reactor water cleanup system Class 3 piping is under evaluation by the licensee and is subject to NRC staff followup review in Inspection Report 81-12.
b.
LERs 80-03, 80-21, 80-28, 80-40, 81-05, 81-09 and 81-13 concern a loss of air sample data at the Environmental Sample Stations.
Fourteen separate failures have occurred due to several causes, not all of which are considered causally linked.
Initial failures resulted from the apparent blowing of power supply fuses during electrical storms as reported by the licensee.
Installation of surge suppressors at the sample stations appears to have solved the problem.
Recent failures have been caused by bearing and/or winding degradation in the sample pumps.
Failures have continued in spite of corrective actions taken to obtain generic resolution of the problem. Additional actions are planned to improve sample pump reliability and are the subject of NRC staff followup in Inspection Report 81-15 and 81-02.
l l
c.
LERs 79-16, 80-17 and 80-20 concern failures of valves to I
operate due to an accumulation of dirt in or on critical compo-nents.
LERs 81-17 and 81-21 constitute other failures in the series, but they fall outside the analysis period. The events are considered to be loosely linked in a common-cause failure mode, since although the failure mechanism (dirt accumulation) is the same, the source of contaminant is different as well as the valve types involved. Of the five failures, two concern i
drywell air sample valves, where drywell air is the source of the contaminant and dirt buildup on the valve plunger caused the failure.
Licensee corrective actions taken/ planned include:
1-4
- VYNPC (Vermont Yankse NPS) i SALP Cycle 2 (1) replacement of valves with a type.not susceptible to the identified failure mechanism; and (ii) incorporation of the remaining, susceptible valves in the annual PM work list. NRC staff followup of these items is being tracked by Inspection Report 81-02.
The remaining three events concern failures due to dirt in the Instrument Air Supply to the valves.
Licensee evaluation of cause and appropriate corrective action is in. progress and will be the subject of NRC staff followup as documented in Inspection Report 81-15.
d.
LERs 79-27, 79-36, 80-01, 80-14, 80-25, 80-35, 80-36 and 81-07 concern degradation of instruments / equipment due to setpoint i
drift. Vario"s systems are involved with all eight events and no excessive tailures of any one system or component has been observed. The total number of failure events is considered small in comparison with the total number of instruments in the facility. Actions have been taken to upgrade certain safety related instruments to improve reliability and setpoint stability.
Based on the events observed, no correlation that would identify a common cause for setpoint drift is apparent.
l i
4 1-5
f i VYNPC (Vermont Yankee NPS)
SALP Cycle 2 C.
Escalated Enforcement Actions Civil Penalties: None Orders:
The following orders concern requirements that were imposed generically to either all licensees or all reactors in the same class as Vermont Yankee.
Order for Modification of License Concerning Environmental Qualification of-Safety-Related Electrical Equipment, dated October 24, 1980 Order for Modification of License Concerning BWR Scram Discharge Systems, dated January 9, 1981 Order for Modification of License and Grant of Extension of Exemption, dated January 13, 1981. This Order requires that the reassessment of the containment design for suppression pool hydrodynamic loading conditions be promptly instituted and resulting modifications be installed by November 30, 1981.
Immediate Action Letters IAL 80-34 dated October 3, 1980 -
Subject:
Emergency Preparedness Capabilities at Vermont Yankee NPS IAL 80-51 dated December 2, 1980 -
Subject:
Cracking in "(:;vice Sensitivie" Stainless Steel Piping IAL 81-17 dated April 1, 1981
Subject:
Establishment, Maintenance and Execution of a Quality Assurance Program for Packaging and Delivery of Radioactive Material to a Carrier D.
Management Conferences Held:
At the request of USNRC HQ, Vermont Yankee participated in a meeting at Region I on August 4, 1981, for the purpose of gathering information from BWR licensees in regard to IE Bulletin 80-17, 80-17 Supplement I, and 80-17 Supplement II, Failure of Control Rods to Insert During a Scram at-a BWR.
A management meeting was held at the Vermont Yankee Nuclear Power Station on June 27, 1980, to discuss the SALP board conclusions-from the Cycle.1 analysis. The results of the meeting are documented in Vermont Yankee Inspection Report 50-271/80-09.
l-6
SALP Cycle 2 E.
Licensee Activities Gap Period-(May 1, 1980 - June 30, 1980): At the beginning of the period the plant was operating at rated full power. On May 15, 1980 a power reduction to approximately 60*4 was initiated to take corrective action for an apparent Hydrogen recombination upstream of the A0G recombiners (LER 80-19/IT, Revision 1), the plant returned to full power on May 19, 1980.
At 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> on June 11, 1980, a power reduction was initiated to investi-gate leakage into containment; the plant was shutdown to repair a leak in a feedwater check valve. As a result of licensee followup an inadequacy in the design of the drywell leakage detection system was identified (LER 80-18). The plant returned to power on June 13, 1980.
On June 17, 1980, the reactor scrammed dte to a turbine trip caused by a high level in the moisture separator dra!n tank, the plant returned to power the same day. At the end of the period, the plant was operating at rated full power.
Cycle 2 Period (July 1, 1980 - June 30, 1981): At the beginning of the period the plant was operating at rated full power.
On July 11, 1930, the plant was shutdown to effect repairs to the 4 inch diameter B recirculation pump discharge bypass valve, V2-548, packing, and perform testing in accordance with IE Bulletin 80-17 requirements.
The plant returned to power on July 13, 1980.
The plant shutdown at 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> on September 26, 1980, in preparation for the annual refueling outage.
During the Vermont Yankee 1980 refueling outage, the following major modifications and activities occurred:
+ Inservice Inspection i
+ Fuel Shuffle
+ ATWS - ANALOG /RECIRC pump trip system installation
+ Mark I torus (LTP modifications) including:
. installation of vent header deflectors l
. reroute RHR discharge lines
. torus saddle plate installation
. downcomer tie installation l
. SRV reroute and T quencher installation 1-7
[
SALP Cycle 2
+ NUREG 0578, Category 8 items:
. DW High Range monitor installation
. torus level and D/W pressure instrumentation
. noble gas high range effluent monitor installation
+ PCLRT Type B and C testing
+ CRD replacement
+ Two control rod drop events
+ Dropped LPRM event
+ Identification of crack in No. 8 jet pump beam (IEB 80-07 inspection) and its replacement (LER 80-33)
+ Identification of core spray sparger crack (IEB 80-13 inspection) and installation of junction "C" end cap clamp (LER 80-32)
+ Identification of cracking and leakage from 4 inch diameter RWCU-line CUW-18 inside the drywell discovered during ISI inspection.
The licensee subsequently replaced the 4 inch piping system inside the drywell (LER 80-37).
At 1950 hours0.0226 days <br />0.542 hours <br />0.00322 weeks <br />7.41975e-4 months <br /> on December 23, 1980, the reactor was critical following completion of the 1980 refueling and maintenance outage. The outage period lasted approximately 12 weeks.
On December 24, 1980, the reactor scrammed'due to a combination of a feedwater instrument failure and malfunction of a TG mechanical pressere regulator; the shutdown was continued to repair excessive packing led. age from valve RHR V-81 located inside the drywell. The reactor was critical and the generator phased with the grid at 1948 hours0.0225 days <br />0.541 hours <br />0.00322 weeks <br />7.41214e-4 months <br />, December 28, 1980.
On December 29, 1980, the licensee identified two through wall leaks in a 5-foot section of 4 inch diameter RWCU piping between the regenerative 4
and nonregenerative heat exchanger.
Power operation was held at 25% FP during the period of December 29 thru January 1, 1981, while the RWCU system was isolated and the 5-foot section of the CUW-3 piping containing the defects was cut out and replaced (LER 80-41).
Repairs of CUW-3 were complete and power increase was initiated on January 1,1981.
1 -8
SALP Cycle 2
/
On January 2, 1981, at 1051 hours0.0122 days <br />0.292 hours <br />0.00174 weeks <br />3.999055e-4 months <br />, a power reduction was initiated and the generator was removed from the grid for the repair of MSIV's 86A and 80B (LER 81-01); on January 3,1981, power increase was initiated.
On January 17, 1981, power reduction was initiated and the generator was removed from the grid for repair of TG #9 bearing; at 0106 hours0.00123 days <br />0.0294 hours <br />1.752645e-4 weeks <br />4.0333e-5 months <br /> on January 18th, the generator was phased on to the grid, full power was obtained on January 21, 1981.
During the period of March 14-March 19, 1981, the licensee conducted stability testing and torus response testing to obtain data for licensing support and model qualification, and to determine the response of the torus and its supports to SRV actuation under cold pipe and hot pipe conditions.
On May 6, 1981, a leak was observed in the RWCU piping drain line CUW-424 coupling on heat exchanger E-15-1A.
The RWCU system was isolated and the fitting replaced (LER 81-11). On May 11, 1981, the reactor scrammed due to a blown fuse in the RPS; reactor startup commenced May 12, 1981.
On June 21, 1981, the licensee idantified leakage at a one inch to three-quarter inch reducer fitting-on RWCU vent line CUW-426; the RWCU system was isolated and the fitting replaced (LER 81-16).
F.
Inspection Activities a.
SALP Cycle 2 Gap (May 1, 1980 - June 30, 1980)
Two NRC residents onsite for entire period.
Meeting between USNRC Regional personnel, resident inspectors and community and state officials was conducted on June 27, 1980, b.
SALP Cycle 2 Period (July 1,1980 - June 30,1981)
Two NRC residents onsite for entire period.
On July 29, 1980, Messrs. T. T. Martin, VY Section Chief, and W. J.
Raymond met with the Vermont State Nuclear Advisory Panel in Montpelier, Vermont.
Health Physics appraisal conducted September 22 - October 2, 1980, IR 50-271/80-14.
On the evening of November 11, 1980, the resident inspectors met with representatives of the Vermont Yankee Decommissioning Alliance to discuss the status of the 1980 Vermont Yankee Refueling Outage,
-9 j
' VYNPC (Vermon?. Yankee NPS)
SALP Cycle 2 A five member team from IAEA was onsite during September 18-19, 1980, to test a locally made fuel pool activity verification instrument.
Two representatives from the Los Alamos Laboratories were onsite during the period of March 2-March 6,1981, under contract with the NRC, as part of a program to review physical security at nuclear facilities.
During the SALP Cycle 2 period, the resident inspectors have had frequent contact with Vermont State Environmental Board members, and have obtained Regional permission for accompaniment during resident inspections.
Performance Appraisal Branch (PAB) inspection conducted April 7 -
May 1, 1981, IR 50-271/81-3(PAS).
G.
Investigations a.
Cycle 2 Gap Period (May 1, 1980 - June 30, 1980)
None b.
Cycle 2 Period (July 1, 1980 - June 30, 1981)
There were no formal investigations during this review period.
During the fall 1980 refueling outage, the resident inspectors responded to a contractor inquiry concerning a CBI company policy of holding workers in a control point area prior to entering the job site (torus).
The individual questioned whether the workers were being exposed to needless radiation.
The inspectors conducted a followup inspection in this area which did not substantiate the specific concerns and reported the findings to the individual and the contractor supervisor. The resident inspectors followup as a result of the initial inquiry is documented in VY inspection report 50-271/80-15.
f During the fall 1980 refueling outage, an anonymous telephone call
- l was made to the NRC Resident office by an individual who expressed concern over personnel monitoring provided for a specific work party
.n the drywell. The individual stated that self reading pocket dosimeters for two members of the work crew read offscale upon leaving the drywell and he questioned whether sufficient health physics controls had been applied.
Resident Inspector followup identified no instances where licensee administrative or regulatory exposure limits were exceeded.
Followup as a result of the inspectors actions is documented in VY inspection report 50-271/80-15.
-10 j
8
SALP Cycle 2 As a result of a contractor allegaticn concerning qualification of N.D.E. personnel a region-based inspector conducted an examination of the N.D.E. contractor's documentation of personnel qualifications during the fall 1980 refueling outage. The allegations were not substantiated. The inspectors actions as a result of the initial concern is documented in VY inspection report 50-271/30-16.
Allegations concerning the adequacy of the fire barrier penetration seals installed at VY were received by the Region I staff in November 1980. A region-based inspector conducted an inspection in this area (IR 50-271/80-18) and resident inspector followup has been ongoing.
H.
Cycle 1 and Cycle 2 SALP Gap (May 1, 1980 - June 30, 1980)
Three inspections were conducted during the Gap period. One resident inspection (IR 50-271/80-05) identified one item of noncompliance in the radiation protection area, regarding maintenance personnel working inside a High Radiation Area without RWP controls in effect.
LERs (Gap)
Number A - Personnel Error 0
B - Design / Fab Error 1
C - External 0
D - Procedures 0
E - Component Failure 1
S - Other 1
Total 3
LERs included: 80-17/3L through 80-19/1T LER 80-18/1T concerned the potential for fluid system leakage inside the drywell to flow into the torus (via the vent lines) without being collected in the drywell sumps and thereby bypassing the drywell leakage collection systems. Modifications were subsequently completed to remove the potential flow path.
LER 80-19/1T concerned taking both A0G radiation monitors out-of-service under controlled conditions while investigating an operational problem - hydrogen burn upstream of the A0G Recombiners.
I 1-11
SALP. Cycle 2 1
I.
NONCOMPLIANCE AREAS
-Facility Name Vermont Yankee 1
Noncompliances and Deviations Investigation
& Inspection Severity Level.
Classification Functional Area Manhours I
II III IV V-VI Vio. Inf. Def. Dev.
1.
Plant Operations 448 0
0' 0
0 2
1 0
0 0
0 2.
Refueling Operations 95 0
0 0
0 0
0 0
0 0
0 3.
Maintenance 47 0
0 0
0 0
1 0
0 1
0 4.
Surveillance &
Inservice Testing 230 0
0 0
0 1
0 0
0 0
0 5.
Personnel, training
& plant procedures 75 0
0 0
0 2
0 0
0 0
1 6.
Fire protection
& housekeeping 35 0
0 0
0 0
0 0
0 0
0 7.
Design changes &
modifications 95 0
0 0
0 0
0 0
1 0
0 l
8.
Radiation protection, 0
0 0
0 0
0 0
1 0
0 radioactive waste manage-0 0
0 0
0 0
0 0
0 0
ment transportation 483 0
0 0
1 0
1 0-0 0
~0 9.
Environmental Protection 60 0
0 0
0 0
0 0
0 0
0 10.
0 0
0 0
0 0
0 0
0 11.
Security & Safeguards 102 0
0 0
0-4 0
0 3
2 0
.12.
Audits, reviews, &
committee activities 64 0
0 0
0 0
1-0 0
0 0
-13.
Administration, QA, records, procurement 45 0
0 0
0 1
0 0
0 0
0
- 14. Corrective actions-
& reporting 323 0
0 0
0 0
0-0 0
0 0
Totals 2159 0
0 0
1 10 4
0
.5 3
1-Total Noncompliances = 23 Total Deviations = 1 i
l e
1 A-1
8
SALP Cycle 2 VERMONT YANKEE ENFORCEMENT HISTORY MAY 1980 TO JUNE 1981 I
I 1-B-1
VYNPC (Verriont Ycnkee NPS)
SALP Cycle 2 VERMONT YANKEE ENFORCEMENT H f STORY MAY 1980 TO JUNE 1911 INSPECTION NUMBER DATE SEVERITY AREA SUBJECT
- 80-05 4/28-5/16/81 INFRACTION-5 8 RADIATION PROTECTION - TWO ELECTRICAL MAINTENANCE PERSONNEL WERE OBSERVED WORKING INSIDE A HIGH RADIATION AREA WITHOl' RWP CONTROLS ISSUED OR IN EFFECT 80-11 7/28-8/1/80 DEFICIENCY-6 11 SECURtTY - SECURITY PROCEDURE NOT CONSISTENT WITH SovuRITY PLAN (RECORD RETENTION)
INFRACTION-5 11 SECURITY - BARRIERS:
ISOLATION ZONE NOT MAINTAINED AS REQUIRED (OBSTRUCTIONS PRESENT)
INFRACTION-5 11 SECURITY - TESTING AND MAINTENANCE: REACTOR BUILDING ACCESS DOOR ALARM NOT TESTED AT REQUIRED FREQUENCY DEFICIENCY-5 11 SECURITY - RESPONSE: SECURITY ASSISTANCE ARRANGEMENT WITH FBI, MILITARY, NOT DOCUMENTED INFRACTION-5 11 SECURITY - LOCKS, KEYS AND COMBINATIONS: FAILURE TO IMPLEMENT KEY CONTROL PROCEDURE 80-12 8/12-8/15/80 INFRACTION-5 7 DESIGN CHANGES AND MODIFICATIONS - FAILURE TO UPDATE OPERATIONS VALVE LINEUP PROCEDURES TO INCLUDE NEWLY INSTALLED INSTRUMENT AIR VALVES DEFICIENCY-6 3 MAINTENANCE - FAILURE TO MAINTAIN DOCUMENTATION OF SAFETY RELATED MAINTENANCE AND INSPECTION ACTIVITIES 80-15 9/15-10/17/80 INFRACTION-5 8 RADIATION PROTECTION - FAILURE TO POST AND BARRICADE A HICH RADIAfl0N AREA 80-19 11/17-11/21/80 LEVEL V 1 OPERATIONS - FAILURE TO APPROVE VALVE LINEUPS AND CHANGES TO VALVE LINEUPS LEVEL V 5 PROCEDURES - FAILURE TO PROPERLY DOCUMENT VALVE LINEUP VALVE POSITION CHANCES: APPROVAL OF INCOMPLETE VALVE LINEUP; AND ISSUE OF PROCEDURES IN WRONG CATEGORIES AND WITH NO PORC REVIEW
- Inspection Report 80-05 Falls within the Gap interva l of May 1, 1980 to June 30, 1980.
1 -B-2
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.____m
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SALP Cycle 2 i
i INSPECTION NUMBER DAl[
SEVERITY AREA SUBJECT 80-21 11/30-12/15/80 LEVEL V 11 SECURITY - FAILURE OF A MEMBER OF THE SECURITY FORCE TO RECEIVE HIS ANNUAL PHYSICAL EXAMINATION LEVEL V 11 SECURITY - ALARMS: FAILURE TO PROVIDE ANNUNCIATOR TO INDICATE STATUS i
OF STANDBY POWER SOURCE 80-22 11/17-12/31/80 LEVEL V 4 SURVEILLANCE - FAILURE TO OBTAIN REVIEW AND CONCURRENCE OF CHANGES 4
]
TO APPENDIX B 0F OP 4029 (CILRT) ITY TWO SENIOR LICENSED INDIVIDUALS 81-04 1/26-1/29/81 LEVEL VI 8 TRANSPORTATION - FAILURE TO MARK 9 DRUMS " RADIOACTIVE - LSA"
}
81-06 3/16-3/20/81 LEVEL V 11 SECURITY - ESCORT: LICENSEE DESIGNATED VEHICLE LEFT UNATTENDED j
AND UNLOCKED, WITH KEYS IN THE IGNITION
~
81-07 3/24-3/27/81 LEVEL lV 8 TRANSPORTATION - FAILURE TO MEET REQUIREMENTS FOR A GENERAL LICENSE DUE TO INCOMPLETE IMPLEMENTATION OF QA PROCRAM FOR PACKAGING 31-08 4/1-5/15/81 LEVEL V 1 OPERATIONS - SHIFT SUPERVISOR AUTHORIZATION AND DOCUMENTATION CONTROLS 1
WERE NOT MET FOR JUMPER AND LIFTED LEAD REQUESTS LEVEL VI 1 OPERATIONS - RETEST / RESTORATION SECTION OF THE MWR FORM WAS NOT COMPLETED FOR THREE MWRs AS SOON AS OPERATIONAL TESTING WAS COMPLETED LEVEL Vl' 12 AUDITS - 00AD DID NOT PROVIDE A PROCEDURE WITH QUALITATIVE OR QUANTITATIVE ACCEPTANCE CRITERIA.FOR THE CONDUCT OF RANDOM INFORMAL SURVEILLANCE AUDITS OF PLANT ACTIVITIES LEVEL V 13 PROCUREMENT - PROCEDURAL CONTROLS ALLOW STORAGE OF QUALITY LEVEL B ITEMS IN LEVEL C STORAGE AREA; AND. QUALITY LEVEL B PARTS WERE 1
STORED IN QUALITY LEVEL C STORAGE AREA i
?
. LEVEL V 11 SECURITY - VISITORS WERE NOT ESCORTED AT ALL TIMES WITHIN THE PROTECTED AREA l
DEVIATION 5 TRAINING - NUREG 0737 PASS / FAILED CRITERIA WERE NOT APPLIED TO AN RO ANNUAL EVALUATION (SRO AUDIT) EXAMINATION: NOR WAS THE RO RETRAINED PRIOR TO RESUMPTION.0F' LICENSED DUTIES i
81-10 5/4-5/7/81 LEVEL V 5 PROCEDURES - FAILURE TO REVIEW AND APPROVE VENDOR (TELEDYNE) l PROCEDURE FOR SR ANALYSIS (OFFSITE) 81-12 5/18-6/30/81 LEVEL Vf 3 MAINTENANCE - CORRECTIVE MAINTENANCE WAS PERFORMED TO REPLACE RHRSW ACB P-8-1B WITHOUT AN APPROVED MAINTENANCE REQUEST BEING-ISSUED-1-B-3
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SALP Cycle 2 GRMONT YANKEE NUCLEAR POWER STATION PERFORMANCE ANALYSIS
SUMMARY
Category Category Category Functional Areas 1
2 3
l 1.
Plant Operations x
2.
Refueling Operations x
3.
Maintenance x
4.
Surveillance and Inservice Testing x
5.
Personnel, Training and Plant Procedures x
6.
Fire Protection and Housekeeping x
7.
Design Changes and Modifications x
8.
Radiation Protection, Radioactive Waste Management and Transportation x
9.
Environmental Protection and Confirmatory Measurements x
- 10. Emergency Preparedness x
- 11. Security and Safeguards x
- 12. Audits, Reviews, and Committee Activities
~
x
- 13. Administration, QA, Records and Procurement x
- 14. Corrective Actions and Reporting x
1-C-1
SALP Cycle 2 CYCLE 2 INSPECTION HOURS
SUMMARY
Inspection Percent of Functional Area Hours TOTAL 1.
Plant Operations 448 21 2.
Refueling Operations 95 4
3.
Maintenance 47 2
4.
Surveillance and Inservice Testing 230 11 5.
Personnel, Training and Plant Procedures 75 3
6.
Fire Protection and Housekeeping 35 1
7.
Design Changes and Modifications-95 5
8.
Radiation Protection, Radioactive Waste Management and Transportation 483 22 9.
Environmental Protection and Confirmatory Measurements 60 3
10.
11.
Security and Safeguards
-102 5
12:. Audits, Reviews and Committee Activities 64 3
- 13. Administration, QA,-Records and Procurement 45 2-
- 14. Corrective Actions and Reporting 323 15 TOTAL 2159 l
I f
l l
l l-D-1 i
SALP Cycle 2 FUNCTIONAL AREA PERFORMANCE ANALYSIS f
r 1-E-1
SALP Cycle 2 1.
Plant Operations a.
Cycle 1 Two items of noncompliance (Infractions) were identified related to a failure to follow a plant startup procedure and a failure to verify operability of redundant equipment prior to removal of an ECCS pump from service. An additional item cited as a concern in the first analysis period involved the failure of two levels of supervision in the Operations Department to identify and effect timely corrective action for out of specification surveillance data.
b.
Cycle 2 (448 hrs., 21*(')
Three noncompliances.
(1) Severity V - System valve lineups were issued and in use without Manager of Operations approval; and, changes were made to valve lineup sheets without processing a temporary procedure change request.
(2) Severity V - Failure to meet approval and documentation controls for three jumper and lifted lead requests.
(Resulted from PAB potential enforcement finding).
(3) Severity VI - Retest / restoration section of MWR form was not-completed as soon as operational testing was completed.
(Resulted from PAB potential enforcement finding).
Item (1) above, use of unapproved valve lineupt, resulted from unique circumstances, had minimal safety significance and is not considered indicative of general practices. All items concern discrepancies in fulfilling administrative raquirements. None involved a loss of control over plant systerrs or components.
A change in personnel in the position of Operations Supervisor occurred since the Cycle 1 period. Three new R0 and two new SR0 licenses were issued during the review period.
Senior site management daily reviews of operations status is considered a strength, as well as the periodic tours of plant areas. Operations personnel sensitivity to even slight indications of leakage on the drywell leakage detection systems and resultant followup is considered indicative of a positive l
attitude for safe plant operation. Attention to and followup of resident inspector concerns in regard to plant operations has been responsive.
No adverse findings have resulted from routine resident inspector review of safety system operational readiness and overall plant status.
1-E-2
SALP Cycle 2 Performance Appraisal Branch (PAB) Inspection The PAB inspection conducted in April, 1981.found that the plant had an effective organizational ~ structure and a qualified staff. Corporate-support, plant housekeeping, procedure control and the general attitude of personnel were considered strengths. Areas that needed improvement included equipment status control, control of jumpers and lifted leads, the Operator's Log, trending, Administrative Procedure format and a definition of company goals and policies.
c.
Conclusion Category 1 I
t i
l l-E-3
SALP Cycle 2 2.
Refueling Operations a.
Cycle 1 No noncompliances were identified based on two inspections in the area. One item related to fuel assembly lower end plug wear was satisfactorily resolved.
b.
Cycle 2 (95 hours0.0011 days <br />0.0264 hours <br />1.570767e-4 weeks <br />3.61475e-5 months <br />, 4*s)
All phases of refueling operations were inspected by the resident inspectors. There were no inspections by region-based personnel during the period.
No noncompliancesspecific to refueling opera-tions were identified. One of three examples referenced in the Jumper and Lifted Lead noncompliance above concerned the failure of the shift supervisor to document authorization of changes to the refueling bridge frame mounted hoist. However, no loss of control over plant equipment occurred.
Equipment problems occurred during the 1980 refueling outage that resulted in components being dropped over the core and spent fuel pools and caused minor damage to other components. One new control rod blade dropped over an. empty portion of the spent fuel pool when the hoist swivel broke. A second new control rod blade dropped and struck three irradiated fuel assemblies in the core when it became=
detached from the control rod handling tool. A LPRM string slipped out of its strongback during positioning over the core and. struck two fuel assemblies.
Licensee management responses to these events to analyze and correct deficiencies were considered appropriate.
Licensee controls over refueling operations and detailed planning for outage evolutions / activities is.followed through with the proper level of supervision.
Coordination and communications between departments appear to be effective.
In one instance, inadequate communications between Operations and Health Physics resulted'in a noncompliance for failure to post and barricade a High Radiation Area; however, this is considered to be an isolated occurrence based on resident inspector reviews of radiation protection controls established throughout the outage.
Planning and management of Reactor Water Cleanup System Class I piping repair, upon discovery of pressure boundary leakage mid-way through the outage, was conducted in a competent manner.
c.
Conclusion Category 1 1-E-4
SALP Cycle 2 3.
Maintenance a.
Cycle 1 One noncompliance (Deficiency) was identified related to a failure to issue a maintenance request for corrective maintenance to replace a hanger on the HPCI system.
The item was related to repair of identified hanger deficiencies resulting from IEB 79-02/14 review efforts. A job / work order package existed and proper controls'were in effect.
b.
Cycle 2 (47 hrs., 2*l,)
One inspection by region-based staff and routine inspections by resident inspectors resulted in two noncompliances.
(1) Severity VI - Failure to maintain documentation of safety related maintenance and inspection activities.
(2) Severity VI - Corrective maintenance was performed to replace the RHR SW P-8-1B ACB without an approved maintenance request being issued.
The third noncompliance in the Operations summary above, failure to document satisfactory completion of operational testing on the MWR form, could also be properly classified under Maintenance.
Performance Appraisal Branch (PAB) Inspection The PAB inspection conducted in April: 1981 identified four weaknesses in maintenance administrative procedure controls:
lack of cross references with other applicable procedures; lack of requirements for a maintenance procedure when work exceeded a craftman's skills; lack of requirements to terminate work when the work scope exceeds the maintenance request; and, conflicting requirements regarding who was responsible for specifying operational testing following completion of maintenance activities.
Strengths in the maintenance program included the maintenance record system and the weekly inspection rounds to monitor equipment operability.
The maintenance program was considered to have been satisfactorily implemented.
c.
Conclusion Category 1 1-E-5
SALP Cycle 2-4.
Surveillance and Inservice Testing a.
Cycle 1 One item of_ noncompliance (Deficiency) was identified concerning the failure to complete a data sheet during control rod insertion time testing. The Cycle I LER analysis noted a failure trend with MSIV position indication and a recommendation to followup on corrective actions was made. Maintenance on the MSIV position indicators during the 1980 refuel outage appears to have resolved the item due to the lack of problem recurrence.
b.
Cycle 2 (230 hrs., 11%)
The resident inspectors conducted routine reviews of safety-related surveillance testing in progress, as well as special inspections of the preparation for and conduct of a Type A Integrated Leak Rate Test during the 1980 annual outage. One item of noncompliance was identified.
There were no inspections cf the Surveillance or Inservice Testing programs by region-based inspectors.
(1) Severity V - Failure to obtain review and concurrence by two senior licensed individuals of changes to CILRT value lineup.
Region-based inspector reviews of the ISI area included a review of the program, NDE procedures, qualifications of NDE personnel and a review of the inspection results for UT examinations of reactor water cleanup-line welds and video tapes of the core spray spargers.
The inspection also included reviews of LP examinations, procedures and documentation review for removal of rejectable liquid penetrant indications from a recirculation system 4-inch bypass line. No items of noncompliance were identified.
LERs submitted during the analysis period included 26 in the Surveil-lance area and of those, 21 were due to component failure. The total number of component failures is not considered excessive and it is noted the identification of equipment failures and resultant LERs is expected for this area. An analysis of the events resulting from component failure showed (1) total number of components reported failed in Cycle 2 period is the same as reported in Cycle 1; and (ii) no predominant cause for failure' existed; rather, failure resulted from setpoint drift; normal wear; components reading EOL and miscellaneous causes.
a l-E-6
SALP Cycle 2 Resident inspector observations of technicians conducting surveillances, along with reviews of qualifications and training records, showed the I&C staff to be well qualified, experienced and familiar with.
plant equipment.
c.
. Conclusion Category 1 4
i i
l I
l-E-7 i
i L-
IVYNPC(VermontYankeeNPS)
SALP Cycle 2 5.
Personnel, Training and Plant Procedures a.
Cycle 1 (1) Training One inspection conducted during the Cycle 1 oeriod with no noncompliances or substantive adverse findings identified.
Licensee management was informed of the NRC's increased inspec-tion emphasis of non-licensed staff training during the Cycle 1 Management Meeting on June 27, 1980.
b.
Cycle 2 (75 hrs., 3*s)
(1) Training There were no inspections of the licensed operator training area by region-based inspectors during the period. A Health Physics Appraisal was conducted during Cycle 2 which encompassed training within the scope of the inspection areas.
Segments of the licensed operator training program were inspected by the resident inspectors and the non-licensed staff training area was reviewed by the PAB team (discussed below).
One Deviation from a licensee commitment was identified by the resident inspectors during a followup review of a PAB potential enforcement finding.
(a) Deviation (VI) - NUREG 0737 pass / fail criteria were not applied to a Reactor Operator annual evaluation (SR0 l
Audit) examination, nor was the operator retrained prior l
to resumption of licensed duties.
l No evidence of a systematic / programmatic breakdown was identified by resident inspector followup in the area.
Unique circumstances contributed to the instance noted above.
Two of five candidates for an R0 license were not successful in passing a licensing exam in March, 1980.
(2) Personnel No adverse findings were identified during resident inspector reviews of plant staff qualifications and staffing changes during the review period. A change to the plant organization structure was to have been effective on August 1, 1981 but was deferred on July 31, 1981 following NRC Staff review and deter-mination that prior NRC approval for the change was required.
l 1-E-8 l
SALP Cycle 2 1
Staffing of the STA programs with a permanent group of engineers occurred during the review period. The permanent STAS assumed-shift duties by June 1, 1981.
(3) Procedures Two noncompliances were identified during the period.
(a) Severity V - Fa11ure to properly document valve lineup valve postion changes; approval of an incomplete valve lineup; and issuance of procedures for safety class compo-nents in the wrong categories, with no PORC review.
(b) Severity V - Failure to review and approve an offsite vendor procedure for strontium analyses.
The first (Severity V) nonco gliance listed under Plant Operations above could also be properly classified under th4 section, since the use of procedures (valve check-off lists) that had not been approved for use by the Manager of Operations had been sanctioned by plant management.
Performance Appraisal Branch (pAB) Inspection The PAB inspection conducted in April, 1981 identified weakaesses in the licensed operator training program and significant weaknesses in the non-licensed staff training program.
The licensed training program appeared adequate to prepare candidates for the NRC licensing examinations. Weaknesses in the licensed program included the failure of a shift' reactor operator to complete program requalification requirements and the lack of written lesson plans for the licensed training and requalification training programs.
In the non-licensed staff training area, a written program which included schedules, goals, objectives and methods to evaluate the effectiveness of training had not been established for corporate-office personnel. The plant Training Department had not provided direction and guidance for departmental training programs. A written training program had not been developed for non-licensed operators.
Training programs had not been completed by all departments.
An additional weakness was identified in the program in conjunction l
with training in the area of design changes and modifications, as l
noted in Section 5.b of this report.
i 1
1-E-9 2
c
VYNPC(VarmontYankeeNPS)
SALP Cycle 2 NRR Performance Evaluation The licensee is knowledgeable of regulations, guides,. standards and generic issues. Has provided BWR owners group leadership. VY has a large analytical staff and is developing the capability to do their own reload analysis.
The licensee has an experienced management staff.
Engineering services are provided largely by YAEC which works well due to close organizational ties between YAEC and VYNPC. A large experienced technical staff is dedicated to support of the Vermont Yankee plant.
The licensee is technically strong and well staffed.
Independently reaches conclusions on safety issues without undue reliance on others.
d.
Conclusion Category 2 1
1-E-10
SALP Cycle 2 6.
Fire Protection and Housekeeping a.
Cycle 1 No items of noncompliance were identified based on one inspection conducted during the period.
The licensee was notified during the Cycle 1 June 27, 1980 Management Meeting of NRC's concern with one element of the Site Fire Brigade i
Training Program.
Specifically, the training program did not provide fire extinguishing practice on problems with a complexity similar to that which would occur at the plant site.
The Site Fire Brigade Training program was subsequently augmented to include such training.
b.
Cycle 2 (35 hrs., 1%)
No noncompliances were identified in either the Fire Protection or Housekeeping areas during the review period.
Plant housekeeping is considered an element of strength in the management control system.
One inspection was conducted by a region-based inspector in response to concerns raised by a licensee contractor, regarding the adequacy of fire stop materials used in approximately 6 cable penetrations at the site. Actions have been completed to resolve some of the issues raised by the contractor; however, final resolution of the item is pending completion of fire rating testing or the " Typical H" penetra-tion configuration, using the cable penetration sealant in use at the site. The results of the-fire rating testing will be reviewed by the NRC.
c.
Conclusion Category I 1-E-11
SALP Cycle 2 7.
Design Changes and Modifications a.
Cycle 1 No noncompliances were identified based on five inspections conducted in the area during the period.
b.
Cycle _2 (95 hrs., 5%)
One noncompliance was identified.
(1) Severity V - Failure to update operations valve lineup procedures to include newly installed instrument air valves.
The finding represented evidence of a program weakness, but is not considered indicative of a programmatic breakdown. One discrepancy was identified out of several modification packages reviewed.
Although an informal mechanism existed to identify procedural changes required following a modification activity, no formal provisions were incorporated in the design change and modification packages to assure procedural changes were completed prior to return of systems to an operational status.
No routine inspections of the Design Change and Modification Program were conducted during the review period by region-based inspectors.
Resident inspectors review of work completed under the Design Change Program for NUREG 0737 items identified no adverse findings.
Inspections were conducted of selected design changes and modifications by region-based Specialists from the Engineering Section.
l Three inspections were performed of modifications to the torus and reactor water cleanup (RWCU) systems. Torus modifications including review of specifications, procedures and documentation plus visual inspections of weld fitups and installation were covered. Torus T quencher weld radiographs were inspected.
For replacement of RWCU system piping inside of containment, coverage included welding mock-up, observation of welding work activities in progress and review of drawings and procedures.
An inspection was made into the cause of failure of a portion of RWCU piping connecting the waterbox of the last regenerative heat exchanger (Hx) to the first non-regenerative Hx.
The audit included a review of material certifications of the piping, review of other applications for identical pipe purchased from the same heat of material, visual inspection of a failed portion of the piping, review of welding procedures used for replacement pipe fabrication, discussion of service history of regenerative Hx, and witness of liquid penetrant examinations of portions of pipe adjacent to the failure area.
No items of noncompliance were identified.
j-E-12
- #'VYNPC (Vermont Yankee NPS)
SALP Cycle 2 Performance Appraisal Branch (PAB) Inspection The PAB inspection conducted in April, 1981 found the review and approval process regarding design changes and modifications adequate and well implemented to assure proper control.
The licensee review process applied to design changes and modifications exceeds the requirements of ANSI N45.2-11.
In addition to reviews specified in this standard, the licensee's program provided for reviews by a cognizant individual at the plant, various plant departments, the Manager of Operations, the Project Manager, the Operational Quality Assurance Manager, the NSD Fire Protection Coordinator and two NSD Engineering Department Managers. The procedures controlling installa-tion and testing provided an adequate review program prior to implemen-t tation of a design change or modification.
1 i
Weaknesses in the program included the lack of a formal training program to ensure that appropriate personnel were properly trained on newly completed design changes and the failure to promptly update drawings affected by pending or completed design changes.
c.
Conclusion Category 1 1
I-E-13
SALP Cycle 2 8.
Radiation Protection, Radioactive Waste Management and Transportation a.
Cycle 1 (1) Radiation Protectio _n Two items of noncompliance: One Infraction (IR 50-271/79-14) -
Failure to follow RWP procedure to control a special evolution (RV hydrolasing), resulted in using standard anticentamination controls in an area having IM dpm/ square cm contamination. One Infraction (IR 50-271/79-14)- Failure to perform beta surveys prior to start of RV hydrolasing activities. Surveys were directed to be taken by Department Supervisor, but were not completed by HP technician in charge of job.
The board considered licensee performance satisfactory in this area noting that a Health Physics Appraisal was planned for September 1980.
(2) Radioactive Waste Management One noncompliance:
Infraction (IR 50-271/79-10) - Failure to perform a grab sample analysis of plant stack effluents once every 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.
Resulted from incorrect interpretation of TS Section 4.8.C.1.d.
The board considered licensee performance satisfactory in this area.
(3) Radioactive Waste Transportation One noncompliance:
Violation (IR 50-271/80-03) and resultant Civil Penalty (S4000) - Failure to maintain dose limits at external surfaces of transportation vehicle in accordance with 00T regulations. Citation came following a clarification in the interpretation of 00T regulations indicating dose rate limites also apply to underside of transport vehicles. Another issue, same shipment, not cited, involved finding 3 mR/hr in cab of transport vehicle. Caused by inadequate instructions given by VYNPC to carrier, who changed cabs during transit, putting driver closer to load.
The board concluded licensee performance was satisfactory considering the nature of the items and circumstances involved.
Followup inspection under the Resident. Inspection Program was changed to verify corrective actions taken in accordance with the licensee's response to the Violation.
b.
Cycle 1 to Cycle 2 Gap (1) Radiation Protection One noncompliance:
Infraction (IR 50-271/80-05) - Two electrical i
maintenance personnel were observed working inside a high radiation area without RWP controls issued or in effect.
.1-E-14 s
SALP Cycle 2 c.
Cycle 2 (483 hrs., 22*)
4 (1) Radiation Protection Review of the radiation protection area was routinely conducted by the Resident Inspector, and identified one item of noncom-pliance:
Infraction (IR 50-271/80-15) - Failure to post or barricade a high radiation area.
A Health Physics Appraisal was conducted during the period of September 22 - October 2, 1980 (IR 50-271/80-14, not issued at this time). At the exit meeting, the HP Appraisal team forwarded the overall general comment that VY maintained a competent organization who were seriously pursuing work in a sound manner; however, in the area of radiation protection ALARA program, the following concerns were identified:
corporate involvement in committee that sets goals and
+
monitors progress towards goals for the ALARA program not effective.
ALARA concept expressed in licensee procedures should be
+
more specific toward action points which invoke the ALARA program.
Followup actions in this area is pending issue of HP Appraisal inspection report and licensee actions based on its content.
(2) Radioactive Waste Management One routine inspection by a region-based inspector was conducted during the period of March 24 - i%rch 27, 1981 in_ conjunction with a review of radioactive waste transportation activities (IR 50-271/81-07). The inspector identified no items of noncom-pliance in the rad waste management area at IR 81-07 exit meeting and none were identified during the routine inspections conducted by the resident inspectors.
(3) Radioactive Waste Transportation Two inspections were conducted in this area during the SALP Cycle 2 period.
Inspection 50-271/81-04 was conducted by a Region V inspector at the Nuclear Engineering Company, Inc., Beatty, Nevada disposal site during the period of January 26-29, 1981.
The inpection involved a review of a shipment of radioactive waste shipped 1-E-15
SALP Cycle 2 from VY consisting of a trailer transporting 153 fifty-five gallon drums of LSA radioactive waste. One item of noncompliance:
Violation, Level VI, (IR 50-271/81-04) - Failure to stencil or otherwise mark 9 of 153 packages " Radioactive - LSA" to identify the contents.
I Inspection 50-271/81-07 was conducted by a region-based inspector at VY site during the period of March 24 - March 27,1981. The inspection involved a review of rad waste transportation activities r
l during which one potential item of noncompliance was identified:
i Violation, Level IV, (IR 50-271/81-07) - Failure to satisfy all of the requirements for the possession of a general license to package and deliver radioactive material to a carrier for transport, in that the licensee did not maintain a functioning 1
quality assurance program.
Immediate Action Letter 81-17 was issued on April 1, 1981 requiring the licensee to review and evaluate the implementation of its QA program for waste packaging and delivery, and to revise the program as necessary to assure quality in this area and to provide adequate evidence of quality assurance.
]
There were no items of noncompliance identified by the resident inspectors as a result of routine inspections during this period.
d.
Conclusion i
Category 2 j
i
}
l 1-E-16
SALP Cycle 2 i
l 9.
Environmental Protection and Confirmatory Measurements I
a.
Cycle 1 No items of noncompliance. No inspections dedicated to environmental topics conducted during this period.
b.
Cycle 2 (60 hrs., 3%)
One routine inspection by a region-based inspector was conducted during the period of May 4 - May 7,1981 (IR 50-271/81-11). No items of noncompliance were identified.
No items of noncompliance were identified by the resident inspectors as a result of routine inspections during this period, i
As a result of LER Causal Analysis review, the resident inspectors are following licensee actions to improve Environmental Sample Station reliability as noted in Section 2.b of this report.
I j
One routine inspection was conducted by a region based inspector at the VY site during the period of May 4 - May 7, 1981.
The inspection involved the use of the RI mobile laboratory to conduct an independent measurements verification. One item of noncompliance was identified in the procedure area as noted in Section 5.b.(3) of this report.
c.
Conclusion Category 1 r
i I
I l
1 1-E-17
SALP Cycle 2 10.
Cycle 1 No items of noncompliance. No inspections dedicated to emergency preparedness conducted during this period, b.
Cycle 2 (57 hrs., 3%)
During this period a review of the Vermont Yankee Emergency Prepared-ness Program was conducted from Septembr 21 - 3eptember 26, 1980 in conjunction with the H.P. Appraisal progrm (IR 50-271/80-14, not issued at this time). The audit consisted of a review of five major areas of emergency response: administration, organization, training, facilities / equipment, and procedures. As a result of the inspection l
findings in the areas of emergency classification, dose assessment, i
projection, and the training of those individuals charged with making decisions in these areas, IAL 80-34, dated October 3,1980 was issued.
Subsequent to the IAL the licensee modified the applicable procedures and conducted training in emergency classification, dose assessment and projection, and protective action recommendations.
The licensees corrective actions in this area were verified by a resident inspector followup inspection (50-271/80-15).
Satisfactory completion of these findings as well as other findings in the remaining areas addressed in inspection 80-14 (not yet issued) would result in a viable program.
The resident inspectors witnessed the annual Emergency Plan drill in December 1980 and found licensee performance satisfactory.
The emergency plan has been upgraded in accordance with 10 CFR 50 l
and NUREG 0654. The licensee has requested an extension of the July 1, 1981 Emergency Public Notification System implementation date until November 30, 1981 (Ref. FVY 81-95, dated June 25, 1981). As noted in the licensee's submittal, NRC and FEMA staff reviews, community agreement finalization, and manufacturer delivery delays l
were cited as the causes for installation and operational completion-I beyond July 1, 1981. As of June 25, 1981 letters of agreement had been submitted to nearly every community and the licensee was engaged 1
l in followup discussions to consumate the agreements.
Essentially i
all of the equipment necessary to implement the program had been ordered and some received.
Final system installation, formal agreement consumation, final system checkout, and implementation completion is i
scheduled by November 30, 1981.
\\
.l j-E-18 i
SALP Cycle 2 The Emergency Prm,7aredness Implementation Appraisal Team is scheduled to review this area during the SALP Cycle 3 period.
c.
Conclusion Category 2 l
l l
l
[
I l
1-E-19 L
)
SALP Cycle 2
- 11. Security and Safeguards-a.
Cycle 1 During.this period, there were four items of noncompliance. Two infractions and two deficiencies - (IR 79-11): (1) Failure to have a required procedure; (2) Failure to follow ID badge issuance procedure; (3) Failure to have a tamper alarm on Gatehouse 2 access door -
protected area boundary, Gatehouse 2 continuously manned; (4) Failure to maintain Gatehouse 2 metal detector operable. The board did not recommend increased inspection frequency in this area based on no apparent trends established and generally good responsiveness of licensee to cited items (those not contested).
4 b.
Cycle 2 (102 hrs., 5%)
Three Physical Protection inspections were conducted by region-based inspectors during the evaluation period.
The items of noncompliance identified during these inspections are set forth below:
80-11 (July 28 - August 1,1980) - Five items of noncompliance.
~
(1) Security procedure not consistent with Security Plan (Deficiency).
(2) Isolation zone not maintained (Infraction).
(3) Failure to test door alarm (Infraction).
(4) Failure to document security assistance arrangement (Deficiency).
(5) Failure to implement key control procedure (Infraction).
80-21 (November 30 - December 1,1980) - Two items of noncompliance.
(1) Security Officer failed to have annual physical examination (Level V).
(2) Failure of annunciator panel to indicate status of standby power source.(Level V).
81-06 (March 16, 19 and 20, 1981) - One item of noncompliance.
(1) Licensee - designated vehicle left unattended and unlocked, with keys in the ignition (Level V).
l-E-20
SALP Cycle 2 A review of the items of noncompliance indicated that they do not
^
represent a major breakdown in management control, there were no repeat items during the inspection period, and t he licensee was found to be responsive to NRC findings and acted quickly to correct the identified problems.
4 Performance Appraisal Branch (PAB) Inspection The PAB inspection conducted in April, 1981 identified the following:
}
Strengths within the security organization included a well organized and implemented training program, a stable guard force, and close interaction with offsite support agencies. Weaknesses included lack of proper visitor control within the protected area, incomplete portions of background investigations, and failure to audit the i
security statements obtained for contractor personnel.
As a result of resident inspector followup on PAB inspection areas of concern, the following noncompliance was identified:
Violation, Level V, (IR 50-271/81-08) - Visitors were not escorted at all times within the licensee's Protected Area. This item was discussed with licensee management on April 10, 1981 and immediate corrective j
action was taken by the licensee.
c.
Conclusion Category 2 i
I i
3-E-21
VYNPC (Vcrmont Yankee NPS)
SALP Cycle 2
- 12. Audits, Reviews and Committee Activities a.
Cycle 1 No items of noncompliance were identified in this area during the
. Cycle 1 period. One inspection was conducted in the Committee Activities area with no substantive adverse f.indings.
b.
Cycle 2 (64 hrs., 3%)
The resident inspectors conducted periodic reviews of Committee Activities during routine inspections and followup actions, no items of noncompliance were identified.
No inspections were conducted in this area by region based inspectors.
The resident inspectors conducted periodic audits of the management l
review area during routine inspection and followup actions. The discrepancies noted did not represent a major breakdown in management control, were mostly nonrepetitive in nature and licensee corrective action was responsible and timely.
Performance Appraisal Branch (PAB) Inspection The PAB inspection conducted in April, 1981 identified the following:
Quality Assurance Audits: Weaknesses in the prcgram included lack of management direction and guidance, failure to assess the effective-ness of the audit program, a high turnover rate in audit personnel, and the failure to implement an effective auditor training program.
Committee Activities: Both the plant and corporate review committees consisted of well qualified members. The committees appeared to be accomplishing their assigned responsibilities in an effective manner.
The practice of holding the semiannual corporate committee meeting at the plant was considered a strength. Weaknesses included the lack of detail in the committee charters and failure to review a number of sources of potential Technical Specification violations.
As a result of resident inspector followup on PAB inspection areas of concern, the following item of noncompliance was identified:
i Violation, Level VI, (IR 50-271/81-08).
Contrary to 10 CFR So, Appendix B requirements, the Operational Quality Assurance Department did not provide procedures or written instructions with appropriate quantitative or qualitative acceptance criteria for the conduct of random informal surveillance of plant activities.
c.
Conclusion Category 2 1 -E-22
SALP Cycle 2 W
- 13. Administration, A. Records, and Procurement a.
Cycle 1 Ten URIs were opened in the Management Control area during this period - all items resolved. A concern was expressed in the Operations area - no similar items have been identified.
No inspections were conducted in the QA/QC area during Cycle 1 SALP period and the Records area was not recognized in SALP Cycle 1 evaluation. A concern over the licensee's use of in process inspection /
surveillance instead of hold points as specified in YOQAP was referred to NRR for disposition (UNR 79-18-01).
The NRC position was forwarded to the licensee in June 1980 as noted in IR 50-271/80-09. The licensee has incorporated the NRC position into applicable areas and is developing procedural controls to implement corrective action as noted in IR 50-271/81-13. Resident inspector followup in this area will continue.
b.
Cycle _2 (45 hrs., 2%)
No region-based inspections were conducted in this area during the SALP Cycle 2 period.
The resident inspectors identified no items of noncompliance during routine inspections and reviews in this area. The Administration and Records program currently in place at Vermont Yankee appears to be a strength in this functional area.
The VYNPC corporate and site organizations are currently being reviewed for changes in line functions and individual assignments within the organizations have been revised within the SALP Cycle 2 period. The resident inspectors have reviewed these changes upon implementation and consider the j
personnel assignments to be a positive change.
Performance Appraisal Branch (PAB) Inspection l
The PAB inspection conducted in April,1981 identified the following:
Procurement: An adequate program had been established to control l
procurement activities.
Procurement personnel were considered well qualified. Weaknesses included the lack of adequate storage facilities and a weak audit program.
As a result of resident inspector followup on PAB inspection areas of concern, the following noncompliance'was identified: Violation, Level V, (IR 50-271/81-08) - Contrary to 10 CFR 50, Appendix B and ANSI N45.2.2-1972, AP 0803 allowed items classified as Quality Level B to be stored in areas of a lower grade, and items designated to require Quality Level B storage were found stored in a Quality Level C storage area.
1-E-23
SALP Cycle 2 The licensee is currently constructing a new warehouse facility to upgrade storage capability at the site, completion is scheduled for late fall 1981.
c.
Conclusion Category 1 1 -E-24
SALP Cycl @ 2 4
- 14. Corrective Actions and Reporting a.
Cycle 1 Based on the results of five inspections in the Reporting area, no adverse findings were identified during the SALP Cycle 1 period.
The corrective actions area was not addressed during this period, b.
Cycle 2 (323 hrs., 15%)
The resident inspectors identified no items of noncompliance during routine inspections in this area. The licensee aggressively pursues operational problems and cooperates fully with the NRC in reporting potential plant problems. The quality of corrective actions is a noteworthy strength. More attention is warranted in the administrative area of tracking open items and commitments. As a. result of technical issue followup it has become evident that in many cases older items have not been tracked to completion and documentation of corrective actions was not available. The inspectors note that the licensee has initiated a computer tracking system to upgrade to manual methods currently in service.
No region-based inspections were conducted in this area during the SALP Cycle 2 period.
The licensee attempts to meet the NRC mandated response dates, or properly ;' quest extensions. The licensee has been responsive to NRC requests for additional documented information and does not hesitate to enlist the services of consultants to pursue corrective actions, as evidenced by pursuit of resolution to identified problems, such as RWCU system piping failures and hydrogen burn in A0G system.
Performance Appraisal Branch (PAB) Inspection The PAB inspection conducted in April, 1981 identified the following:
Corrective Action System: The corrective action system was defined in procedures and implemented. Weaknesses in the system included the failure to trend problems for generic implications and failure to implement a program to prevent recurrence.
The results of resident inspector followup on PAB inspection areas of concern is documented in VY IR 50-271/81-08 and trend analysis by the licensee is subject to further review by the NRC.
-E-25 j
SALP Cycle 2 NRR Performance Evaluation The quality of the licensee's responses and submittals is generally thorough and complete. The timeliness of responses is adequate, the licensee generally notifies the Project Manager in advance of deadlines.
Consideroole effort is required to obtain an acceptable response or submittal for situations in which differences of position exist between staff and licensee.
The licensee is responsive to staff requests to the extent plant availability or operation is not adversely impacted.
VY responds promptly to telephone requests and rarely makes unnecessary requests for emergency Tech Spec changes.
Long standing open items are limited to situations where well under-stood differences of position exist between the licensee and staff, or instances where higher priority NRR work has displaced work on other items.
c.
Conclusion Category 1 1 -E-26 L
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