ML20106G545
| ML20106G545 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 01/17/1995 |
| From: | Clark C, Gosekamp M, Mcelwee D VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | |
| Shared Package | |
| ML20006H539 | List: |
| References | |
| NUDOCS 9603110033 | |
| Download: ML20106G545 (13) | |
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ATTACHMENT 2 d
INVESTIGATION OF CERTAIN ANONYMOUS ALLEGATIONS CONCERNING THE ADVANcsc 0FF-GAS SYSTEM AT i 1 VERMCNT YANKEE NUCLEAR POWER STATICN !
I. Statement of Concern / Allecation On or about December 23. 1995, Vermont Yankee Nuclear Power Station (VYNPS) personnel were informed by the Brattleboro Reformer that the newspaper had received a copy of an undated anonymcus lener making cenain allegations concerning the function and management of the Advanced OE-Gas System (A0GS) at VYNPS. The full text of the tener was as follows:
Der.r M:d:m:
-I must repcrt Ic you : seicus sicistica of NRC requirenents :t Vennent Yankee.
"The :dvanced oEg:s system has been :llowed to deteriente over the ye:rs :nd :s : result 6e pi=t is discharging illegal : mounts of mdicacthity.
-In crde to s:ve mency pl=t =:nagers c:nce!!ed : pl:n by $e engineers '
to red:rbish de system dunng th: 1995 red:e!ing.
-The =ginee s $:t spoke cut :g: inst de =ne:111:g were punished and h:d a bad repert insert:d in deir personnel fde.
-Recendv de cEg:s svs=n w:s dee!:r:d out of openden be::use citical i monitcring equipm=t w:s net c:ifected properly 1:m told dis ccnditica has existed for mmy ye:rs.
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-Tne vice presid=t : Yank.m Atomic (YAEC) knows : bout dis, but has done ncthing be=use it would E::t de rec =t org-*+on ch:nges-he knows it could 2Ee= his job if he had to tell Vennent Y=kee m=:gers dat 6:y were not ope = ting ie pl=t cenectly."
It was reponed by the Reformer that this lener had been received by the New England Coalition on Nuclear Pollution, Inc. (NECNP) anc had been immediately fonvarded by NECNP to the Reformer and to the Govemors of the State of Vennent and New Hampshire, the Attorney General of the Commonwealth ofMassachusetts, and the United States Nuclear Regulatory Commission (NRC). No information was provided at that time and none has been developed since conceming the identity of the author of the letter.
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l On December 23.1995, when Vermont Yankee first learned of de allegations, an ;
immediate review was conducted by Vermont Yankee management to assess u any ' nmediate l safety concems. No e,idence was found during the initial review to substantiate that Vennont '
Yankee was discharging illegal amounts ofradioactivity. Thereafter, on December 29,1995, ;
an Investigation Team was appointed by the President of Vermont Yankee Nuclear Power Corporation (VYNPC), to funher investigate the allegations. The Team consists of i
- a. David K. McElwee Liaison Enzineer VYb?C Ferry Road i
- Brattleboro. Vermont 05301 l j b. Michael E. Gesekamp Engineering and Maintenance Trauung Supe
- visor l- VYNPC
. Ferry Road Brameboro. Vennont 05301
- c. C. Russell Clark Director, Quality Assurance and Vice-Chair of Vermont Yankee Nuclear Safety and Review Committee -
YAEC l 580 Main Street Bolton. Massachusetts 01740
- In addition. R. K. Gad m, of the firm of Ropes & Gray, One Intemational Place, Boston, Massachusens 02110, was requested to provide legal counsel and assistance to the j Investigation Team.
The Investigation Team was charged with investigating and detennining the facts surrounding the allegations of the anonymous letter and rendering a report to the President l ofVYNPC. By direction of the President of VYNPC, with the concurrence of the President l ' of Yankee Atomic Electric Company (YAEC), the Investigation Team was authorized unlimited access to all records and personnel of VYNPC, VYNPS and YAEC. During the course of the investigation, certain unrelated issues were identified which were reported to the Vice President, Operations.
Having completed its investigation, the Investigation Team now submits its report.
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II. Executive Summarv l
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Each allegation as described in the anonymous letter has been resiewed in detail l
by the Investigation Team. It is the Team's conclusion. based on review of documents and personnel interviews, that the allegations are entirely unicunded. The AOGS has and continues to operate as designed.
III. Concern Details and Investiention Results Allegation 1 To investigate the Erst allegation ("the advanced offgas system has been allowed to deteriorate over the years and as a result the plant is discharging illegal amounts of radioactivity"), the Investigation Team performed personnel inteniews and reviewed the following VYNPS records relating to the offgas radiation monitor suneillances and calibrations, offsite radiological monitoring results, AOGS maintenance requests:
- a. Chemistry Depanment Self-Assessment dated Januaq 5,1996
- b. Independent review of surveElances and calibrations as documented in a memo dated January 3,1996 from G.D.Weyman - Environmental Supenisor
- c. Review of maintenance work order logs for both open and closed work orders for the past year.
1 During the period covered by the review, no emissions above regulatory limits had been recorded.
In addition, the Investigation Team discussed the allegation with the State of Vermont, which maintains its own separate program for monitoring radioactisity around the site boundary. The State of Vermont reported that it has not identi5ed excessive emissions or any adverse trend through its Off Site Monitoring program. In addition, the State of l Vermont is noti 5ed when stack radiation monitors are being calibrated. The State told the Team that they have been satisfed with Vermont Yankee's practice of calibration of the l
subject equipment.
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i In addition. under NRC regulations (10 C.F.R. l 50.72), had "the plant . .di:-
charg[ed) illegal amounts of radioac-ivity," a " Licensee Event Report" (LER) would have
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been required to have been prepared and submitted to the NRC. The Investigation Team reviewed the LER log for the past five years and found none reporting the discharge impermissible levels of radiation via the off-gas stack.
Based on its review of the foregoing records, the Investigation Team concluded that there was no " discharge" of" illegal amounts of radioactisity. '
In addition to the above, through interviews with the people who operate and I maintain the system, as we!] as a review of the past years' maintenance records, there is no evidence of any system dete:ioration. '
On the basis of the foregoing, the Investigation Team concluded that the first allegation of the anonymous lener is unfounded.
Allegation 2 l
I To investigate the second allegation ("in order to save money plant managers -
cancelled a plan by the engineers to refurbish the system during the 1995 refueling"), the Investigation Team reviewed the records conceming work items proposed for and completed during the 1995 Refi2eling Outage (RFO) and it interviewed personnel involved with the !
RFO. The investigation revealed the following:
1 On November 18,1991, Operations Departmem Personnel detailed a proposed !
scope for a project to upgrade the AOGS in a memo to management. The primary objective of the project was to make the system easier to operate and maintain. There was an acknowledgment of the fact that control wiring diagrams (CWD's) needed to be verified prio~r to implementation orthe design change. Yankee Atomic Elecuic Company was contracted
' to provide an initial engineering ev,l mtion which was completed and delivered on February 11, 1994. The evaluation concluded that wiring verifications were a possfole, but not a necessary, first step in the process. Subsequent correspondence between Yankee Atomic and Vermont Yankee detailed the plans for the wiring verification as well as assigning the VY Project Manager. Routine engineering scoping and development activities occurred benveen March 1992 and March 1994 at which point a meeting was held to present the package, Engineering Design Change Request (EDCR)94-402, to management.
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During the management presentation it became apparent that dere were still reservations by the VY Project Manager about what he labeled as the safety and effeciveness of attempting implementation of the design with the existing drawing c:: cts. A review of correspondence and inter.iews with involved parties indicates that there was a general feeling that the wiring issues were not of suficient magnitude to impede the prog ess of the design and in fact, wiring and print correcions were factored into the design scope. However, to address the concems of the VY Project Manager, the responsible Depar.=ent Manager assigned two experienced, uninvolved engineers to review the situation and make recommendations as to the viability of completing the project as originally intended. On June 3,1994, the reviewing engineers issued their report, which concluded that de project could continue with some minor adjustments to address the wiring and print issues.
The reviewing engineers conclusions were accepted by the Departnent Manager who then informed the Projec Manager of his decision. The Depan=ent Manager documented his expecations conceming the execution of the AOGS projec. At 6at time the Project Manager indicated that, in spite of his professional objecions to the directed course of action, he would aggressively pursue completion of the projem as recuested. The engineering package was delivered to VY on July 5,1994 and was expened to be 6nalized by the VY Proje= Manager and approved by September 15,1994 :
Contrarv to the expecations of the Department Manager, the engineering package was not completed on time. As a result,it was necessarf to reduce the scope of the project to address those components seen as reasonably achievable given the time constraints. On November 9,1994 a memo documenting the revised scope was issued bv the assigned Yankee Atomic Engineer. The revised scope retained the drawing revisions as well as some mechanically oriented tasks.
This Information Withheld From Pubhc Disclosure Tning to assure successful completion of the revised scope project and to eliminate any confusion between himself and the Project Manager, on November 30,1994, the Department Manager documented specific expectations for completion of the revised project.
On December 22,1994 the AOGS project was removed from the 1995 Outage Worklist because "we have repeatedly failed to deliver on completion dates and thereis no basis for confidence we will meet any given date at the moment." On January 24,1995 the AOGS
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package was resiewed and Management decided to dedicate additional resources two weeks and $100k, to car:v out work during the 1995 o stage that would prepare for package comple:icn during the 1996 outage. The Department Manager informed the Projec: Manage of the decisions on January 25,1995 On January 31,1995, the Projen Manager issued his comments on the decision to limit the scope of the AOGS projec:. The Depamnent Manager again discussed expec:ations and deadlines conceming the use of the additional resources committed by management. On February 7,1995 the Department Manager me: with the Projec: Manager to discuss some comments contained in the January 31,1995 memo on the decision to limit scope. In that memo, the Projec: Manager had questioned the ' safe:y" of the projec:. and he was asked speciscally about his safe:y comment. As recorded by the Department Manager, the Projec: Manager explained that the comment referred to " job safe:y, con 5dence in the outcome."' They also discussed the Projec Managers previous t
statement that there was no way he could accomplish anythmg useful with the two weeks and 5100k allotted by management. At that time the Department Manager informed the Proje=
Manager that he was removing him from the projec:.
l This Information Withheld From Public Disclosure :
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i j Following the removal of the Project Manager from the projec:. another VY Engineer assumed the role of Project Manager and completed wiring veri 5 cations. drawing revisions and correcion of wiring errors during the outage. A summary of the wtring veriscation projec was documented in a memo, May 3,1995.
l On August 17,1995 a memo was issued formally canceling EDCR 94-402. The projecs originally captured in the EDCR would instead be completed as Minor Modi 6eations
! and placed on the Major Projecs Worklist for consideration during future outages.
8 In context, the Investigation Team inte:prets the Project Manager's response to mean that he used " safe:y' to refer to either or both of the concepts (i) that initiating te unde::aking would not cause an enlargement of the RFO schedule or (ii) that unde:taking the project and incurring its costs would not result a Mure to achieve the benefits that had been expected. It is cler.r to the Team in context that the Project Manager was not refening to nuclear safety and it seems l-clear in context that the Project Marager was not refe: ring to worker safe:y. During the interview with the Project Manager, he specifically told the Investigstion Team that he did not have a safety concem regarding the AOGS and never had. Ordinarily, the Investigation Team would have reinte: viewed the Project Manager to re=ove any ambigui'y in his comment, but the point did not seem to warrant such efort.
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l On the basis of the foregoing, the Investigation Team concludei a.
Tne decision to cance! EDCR WO2. which resulted in the deferral of some of the work included in its scoce but not the cancellation of any work, was i
based on incomplete package development and was not motivated by I 6nancial consideration.
- b. There was no evidence that any employee was opposed to the cancellation of the EDCR (or deferral of some of the work) on the basis of safety. To the contrary, the only " safety' concem raised in connection with this issue was to the efec: that in order to promote con 5dence in the outcome, the drawing revision and validation should precede any design work, and this concern was I l- effec:ively satisfied by the deferral. In fac:, the Projec: Manager considered
! the cancellation of the projec: a major accomplishment on his part.
- c. No plan to refurbish the AOGS during the 1995 RFO to remedy excessive releases was cance!ed (or proposed).
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- d. No plan to perform any werk on tiie AOGS during the 1995 RFO was canceled "in order to save money."
- e. A projec: to rewire a small portion of the AOGS, to improve system l drawings, and replace some ope ationalinstrumentation on the AOGS during i
the 1995 RFO in order to enhance system maintenance was deferred because the engineering work prerecuisite to the pedermance of this work was not l completed on a schedule recuired for the work to proceed.
l f. To the extent that this allegation refers to a plan to correc:" deterioration,"
l there was no deterioration, as concluded above.
- g. To the extent that the design work was defened, this work had always been classised as optional work that would be useful to perform at some time but j was not critical to pederm during the 1995 RFO, and this work had no impact on system operation.
The Investigation Team concluded that, while certain design modiScation implementation was deferred, this deferral occurred because the Projec: Manager in charge of the work thought it should be defened and, ultimately, because he failed to execute instructions to perform the work concurrently with the drawing verification.
On the basis of the foregoing, the Investigation Team concluded that the second allegation of the anonymous letter is unfounded.
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l Allegation 3 To investigate the third allegation ("the engineers that spoke out against the l
cancelling were punished and had a bad report insened in their personnel file"), the l Investigation Team resiewed the personnel records of the engineers who had been involved L in the AOGS work proposed for, but then not pe: formed during, the 1995 RFO. and the l Vermont Yankee Safe:y Concerns & Improvement Program Log. In addition to the facts l recited above with respect to Allegation 2, these records revealed the following:
l a. There was a diference of opinion as to the manner in which the design change should progress.
- b. An independent team of engineers was requested to review the diferences l
l and preside a recornmendation. The reviewing engineers concluded : hat the l design could be implememed as originally scoped. However, ader the
! Project Manager was asked to prepare work packages and those packages I
were deemed to be incomplete, management determined that there was no longer suf5cient time to complete the packages in time for the then approaching outage. This resulted the deferral of the design change
! imple:nentation werk.
- c. There is no evidence of any " bad report" in any of the cognizant engineers
! file as a result of speaking out against the canceling of the original design.
This Informai'on Withheld From Public Disclosure
- f. No evidence that the VY Safety Concems & Improvement Suggestion
! Program was used to convey t safety concem.
l l This Information Withheld From Public Disclosure
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I Based on de above, the Investigaden Team conc!uded that:
- a. No engineer or engineers complained about the defecal of de AOGS RFO l
planned work on the grounds of radiological health and safer,r, j i
- b. The ? ojec: Manager responsicle for the preparation of the A0GS RFO work package disagreed with the proposal for the concurrent performance of drawing veri 5 cation and design modi 5 cation implementaden.
l c. Ader hasing been instructed nonetheless to prepare a package on this basis, l the Project Manager submitted a package that was de: ermined to be insuficiently complete to perform the work.
l This information Withheld From Public Disclosure I
- e. No engineer (or anyone else) was " punished" for expressing a view that the work should not be defered.
1 Accordingly, the Investigation Team concluded that the third allegation of the l anonymous letter is uriounded.
Allegation 4 To investigate the fourth a!!egation ("Recently the offgas system was declared out ofoperation because c:itical monitoring equipment was not calibrated properiy. I am told this l condition has existed for many years"), the Investigation Team reviewed Operations l Depamnent log for equipment out of service, Chemistry Departments procedures and results l ofpast calibrations and suniellances of" critical monitoring equipment." Since it was unclear to the Investigation Team which " critical monitoring equipment" the letter was referring to,
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the team reviewed any equipment in the AOGS 6at had "recently" been out of senice. The records revealed de following; a.
With respec: to the radiation monitors, there was no esidence of any missed calferation, equipment out of senice, or missed surveillances.
- b. The AOGS remained operable at all times.
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1 Du:ing a recent unplanned shut down. there was a question en the operabili I
of the AOGS Hydrogen Detectors. Because of the questions raised, the hydrogen de:ec: ors were technically declared out of senice. However, evaluations demonstrated that, in fact, the hydrogen de:ec: ors were always func:ional and at no time did they not perform as designed. It should also be noted that the hydrogen detectors do not de:ect or monitor any form of radioac:ivity. The hydrogen detectors de:ect hydrogen that may be present in the system. They have no bearing on the operability of the radiation monitors to perform theirintended func: ion.
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A review of the hydrogen de:ector issue found a discrepancy benveen the Ver:nont Yankee procedure and the Technical Speci5 cations with respect to l the calibration gas. Tnis was identifed internally, communicated to the NRC, .
and is comple:eiy documented in Event Report 95-0681.
Based on We above, the Investigation Team concluded that the fourth allegation t
was incorrect and unfounded as stated, in that " critical monitoring equipment" was not found to be out of calibration and that "this condition" had not " existed for many years." In addition, the Investigation Team concluded that the fourth allegation was without basis insofar as it might be interpreted to be an assenion that the matters mentioned in the earlier allegations (and found to be without basis) had recuned.
Allegation 5 Given the invalidity of the Erst four allegations contained in the anonymous letter, the Investigation Team concluded that the fifth allegation ("The vice president at Yankee Atomic (YAEC) knows about this, but has done nothing because it would affect the recent organization changes-he knows it could affect his job if he had to tell Vennent Yankee managers that they were not operating the plant correctly") was also necessarily without basis. In substance, the fifth allegation contends that an unnamed officer concealed his
" knowledge" of certain " facts" constituting improper operation of VYNPS. Hasing l
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f i concluded that the "fac:s' of P Pendon did not e. dst. no ofEcr could have had
" knowledge' of them.
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IV. Conclusions i
l On the basis of the foregoing, the Investigation Team concludes that:
- a. The anonymous allegations are without basis in their entirety;
- b. At no time was VYNPS operating in violation of regulatory requirements with respect to the AOGS; l c. At no time was any adverse personnel action or any other action taken j
against the engineers involved in the AOGS system on account of their
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having raised a safetyissue;
- d. At no time did any ofHeer of VYNPC or YAEC (or anyone else involved in l the operation of VYNPS) suppress information relating to safe operation of the AOGS on account ofconcern aboutjob status;
- e. No further investigation is required or appropriate to close out the allegations; and i
- f. No corrective action is required on account of the allegations or this j mvestigation.
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Respectfully submitted, o_ v ht & , _
D. K. McElwee
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Nf. E. dosekamp [/
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Dated: January 17,1995.
f Distribution:
Dr. J. Gary Weigand Dr. Andrew C. Kadak .-
President President Ver:nont Yankee Nuclear Power Corp. Yankee Atomic Elec:ric Company Ferry Road 580 Main Street Brattleboro, Ver:nont 05301 Bolton, Massachusetts 01740 Mr. Donald Reid
, Vice-president Vermont Yankee Nuclear Power Corp.
Ferry Road Brattleboro, Ve::nont 05301 t ,
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