ML20082J176
| ML20082J176 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 08/02/1983 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20082J156 | List: |
| References | |
| FVY-83-83, NUDOCS 8312010404 | |
| Download: ML20082J176 (7) | |
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ENCLOSURE 4 VFMMONT YANKEE NUCLEAR POWER CORPORATION FVY 83-83 RD 5, Box 169. Ferry Road, Srattleboro, VT 05301 ENGINEERING OFFICE 1671 WORCESTER ROAD FRAMINGHAM, MASSACHUSETTS 01701
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TELEPHONE 617-872-8100 August 2, 1983 U.S. Nuclear Regulatory Commission Office of Inspection & Enforcement Region I 631 Park Avenue King of Prussia, PA 19406 Attention:
Richard W. Starostecki, SALP Board Chairman, Director Division of Project and Resident Programs
References:
(a) License No. DPR-28 (Docket No. 50-271)
(b) USNRC Letter to VYNPC, dated June 21, 1983; SALP Report
Dear Sir:
Subject:
SALP Report Comments We appreciated the opportunity to meet with you on June 28, 1983, to discuss the most recent Vermont Yankee SALP report. We feel that, in general, the report is a fair appraisal of our activities during the May 1982-April 1983 reporting period; however, there are a few areas within the report that require clarification and/or correction.
II. Summary of_ Results We take exception to your inference that changes in the Manager of Operations, Plant Manager and Operations Superintendent positions resulted in a degradation of performance in the functional area of plant operations. While it is true that changes were made in these key management positions during the appraisal period it is important to note that the three individuals assuming these positions have had at least nine years of Vermont Yankee specific experience. That, coupled with the fact that these people devote all of their pro-fessional time on the operation of the Vermont Yankee plant, resulted in very little perturbation of performance when these organizational changes were made.
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- gulatory Commission us 2, h83 VERMONT YANKEE NUCLEAR POWER CORPORATION 3
Your conc.lusion that performance of plant operations has degraded appears to result from one specific incident (Loss of Secondary Containment, March 21,1983) that is presently being reviewed anu the fact that a number of Unusual Events were declared during the past year. The fact is that the Unusual Events were declared as a result of a very conservative management policy of emergency declaration and reporting that was strongly reinforced following the Loss of Feedwater event on April 24, 1982. All of the declared events during the reporting period were very conservatively called and the events them-selves were of no consequence to the health and safety of either the public or plant employees.
IV. performance Analysis Section 1, Plant Operations, and Section 8, Refueling Both the Plant Operations and Refueling functional areas were rated a Category 2 performance based on a single loss of standby containment event that occurred on March 21, 1983. We question the double jeopardy approach that you have taken regarding this single event and the far reaching conclusions that you arrived at, particularly given that the event is still under review by your office. We are par-ticularly concerned with your conclusion that an adverse trend has developed in the area of adherence to plant procedures and policies.
Although the need to strictly adhere to plant procedures and company policy has had to be reinforced on several occasions, we have not reached the same conclusion that you have with respect to adverse trends. For example, we view the number of declarations of Unusual Events as adherence to company policy which dictates ultraconservatism in reporting to outside agencies, whereas you apparently view them as a degradation in operational performance.
We take strong exception to your stateme9 that plant management was not totally responsive to NRC initiatives.
It appears that our disagreeing with you on an issue is viewed as our being non-responsive, In the case of our disagreement over the use of manual isolation valves for containment, we complied with your conservative interpretation of our Technical Specifications. While we did not necessarily agree that your interpretation was more correct than ours, we did immediately respond and comply with your initiative.
In the second case that you cite concerning the isolation valves in the nitrogen make-up line, we feel that we took prompt and appropriate actions to restore the operabiliy of the valves until the valves could be replaced during the 1983 refuel outage.
/ Ju,S. Nyclear Regulatory Commission ust 2, 1983 VERMONT YANKEE NUCLEAR POWER CORPOR ATION Your qualitative assessment that there has been a notable turnover of personnel within the Operations Department resulting in a group of less experienced operators lacks evidence to support your conclusions.
We would like further clarification of this so that we know if you feel that our turnover rate has increased over previous years or if Vermont Yankee has a high turnover rate with respect to other operating nuclear power plants. We have not concluded that either is the case.
Our records indicate that during our 1981-1982 training period, there were 12 candidates for operator licenses,11 of whom received licen-ses.
Your report states that 10 of 16 candidates received licenses.
Again, we appreciate meeting with you to discuss the subject report and want to assure you that Vermont Yankee management has a very strong continuing commitment to the safe and efficient operation of our nuclear power facility.
Your assessment of our performance is helpful to us in carrying out our commit-ment. We will not always agree with your interpretaticas or assessment conclu-sions; however, we will always be responsive to your concerns of safety and/or compliance. We will continue to maintain a policy of conservative emergency declaration and reporting, but can only hope that the disproportionate attention that such events get do not in themselves lead to the conclusion that there is a degradation of performance at Vermont Yankee or that public confidence in our ability to safely operate the plant is eroded as a result.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION dm -
Warren P.
urphy Vice President and Manager of Operations WPM /dm
ENCLOSURE 5 - NRC Review of SALP Report Comments Provided in Vermont Yankee Nuclear Power Corporation I
Letter, August 2,1983
SUMMARY
OF RESULTS (SALP REPORT SECTION II)
The Region I staff has reviewed the comments in your letter regarding your exception to the inference that the changes in the Manager of Operations, Plant Manager and Operations Superintendent resulted in a degradation of performance in plant operations and your comment that the performance in the Plant Opera-tions area was considered degraded based upon the loss of secondary containment on March 21, 1983, and the fact that a number of Unusual Events were declared during the assessment period.
The statements made regarding the staffing changes were not intended as a comment on the experience, qualifications or capabilities of the individuals assigned to the positions, nor on the manner in which the staffing changes were effected.
The statements were not intended to suggest that the subject
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personnel did not devote sufficient time to their duties.
In fact, the SALP f
Report reflects that the staffing changes were made gradually (to the extent that it was within the licensee's control to do so) to provide for a smooth transition in the Operations chain-of-command.
However, during the assessment period, there were changes in key plant manage-ment positions, wlth the attendant assumption of new duties and responsibil-ities by the individuals involved. The SALP assessment identified two specific weaknesses (as stated in Performance Section IV.A) wherein improvements in performance could be realized: (1) a greater emphasis on personnel adherence to established procedures and policies; and (ii) a more aggressive approach to evaluate and resolve equipment problems.
The statement made in the Summary of Results section of the SALP Report was that the staffing changes m_ay have im-pacted performance such that the observed weaknesses may improve as the esta-blished organization settles in (emphasis added). The causal linkage between the staffing changes and observed weakness (ii) above is more clear cut and this will be addressed first.
The criticism regarding the lack of aggressiveness in the resolution of plant equipment problems is based primarily on the problems experienced with contain-ment (riitrogen supply) isolation valves. The first failure of the valves occurred in June,1982, but were not resolved until March,1983, after what is considered excessive prompting by the NRC.
In regard to weakness (1) discussed above, there is no clear causal link between the staffing changes and the adverse trend regarding personnel adherence to established policies and procedures. The thrust of the NRC's comment in this area was that based on NRC observations of personnel performance in previous assessment periods and as highlighted by the multi-level disregard for admini-strative controls on March 21, 1983, there was a demonstrated need for manage-ment to reemphasize adherence to established controls.
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In addition, plant management's responses to the March 21 event were led by the NRC staff toward a detailed review of the event and a full appreciation for its significance.
Further, the NRC staff was compelled to obtain offsite management involvement in the event review to raise the licensee's sensitivity to the event.
The initial response to the event reinforces the NRC concern regarding the lack of aggressiveness in the resolution of plant problems.
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PERFORMANCE ANALYSIS (SALP REPORT SECTION IV)
PLANT OPERATIONS AND REFUELING The Region I staff has reviewed the comments in your letter regarding:
the NRC rating of both Plant Operations and Refueling functional areas based on the March 21, 1983, loss of secondary containment; the NRC statement that the plant management was not responsive to NRC initiatives; the NRC statement that there had been a notable turnover of personnel within the Operations Department; and the NRC statement that 10 of 16 operator license candidates passed NRC examina-tions.
Regarding the rating of both Plant Operations and Refueling areas based on the March 21, 1983, loss of secondary containment, the SALP Board specifically con-sidered the question of double jeopardy during its assessment of both functional areas and, by its perogative, considered it appropriate to apply the event to both areas since the operational staff is the same for both.
Further, the operational constraints facing the shift crew on March 21 (degraded working con-ditions in the Reactor Building due to lack of ventilation) were not so burden-some so as to make the ensuing actions by the shift crew a failure specific to refueling activities. The attitudes and failures on the part of the shift crew which led to the unauthorized bypass of a safety function could have occurred during a different plant operational mode.
Regarding the responsiveness of plant management to NRC initiatives regarding the inoperability of containment isolation valves, it is true that plant and corporate management complied with the staff position regarding the use of manual valves as substitutes for containment isolation valves. However, the compliance was reached after much discussion of the issue and in the face of potential escalaud enforcement action.
Regarding the actions taken by plant management to restore operability of the containment isolation valves, the eventual replacement of the valves occurred after the third (February 1993) failure of the valves, about seven months after the first (June 1982) failure.
Given the extensive discussions involved in June 1982, it appears that plant management's attitude toward operability and reliability of the valves " turned-around" only after the third valve failure. Based on the above, plant manage-ment cannot be regarded as totally responsive to NRC initiatives, particularly since those initiatives began in June 1982.
i Regarding your comments relative to the turnover of personnel, our statement was not based on comparisons with any other facility, but was based on observa-i tions of changes in this assessment period when compared to previous periods.
Observations were made at the time the SALP Report was drafted in June, 1983.
The observations were viewed as losses from the Operations ranks during the assessment period as follows:
(i) an SR0 with 13 years experience transferred l
to another plant department; (ii) an RO with 13 years experience transferred I
to another plant department; (iii) an SR0/ Shift Supervisor with 14 years exper-ience transferred to another plant department; (iv) an SRO/ Manager with 14 years experience resigned from the company; and, (v) an SR0/ Shift Supervisor with 13 l
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4 years experience transferred in May to a position in the corporate office.
How-ever, after two months at corporate, this individual returned to the Operations ranks in a management position. Thus, at the time that the SALP Board convened, 4
there appeared to have been a loss of five individuals with 67 years of collec-tive experience from the Operations ranks.
During the previous three assessment periods, there were a total of three senior licenses lost from the Operations ranks, representing 32 years of collective experience. When the observations from this assessment period are compared to any single previous period, there
. appears to have been a notable turnover of personnel.
The SALP Board did not intend in any way to: make a negative comment regarding the qualifications and capabilities of the current group of operators; imply that the personnel changes adversely affected the assessment of performance in the respective functional areas; or criticize VY management control over personnel turnover.
Regarding your comment relative to the number of operator license candidates who received licenses we have reviewed the examination records maintained by the Region I Operator Licensing Section and have determined that, for the calendar year 1982, 16 license exams were given to VY personnel,10 of which i
resulted in passing grades.
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