IR 05000271/1991099
| ML20127M184 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 08/01/1992 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20127M163 | List: |
| References | |
| 50-271-91-99-01, 50-271-91-99-1, NUDOCS 9301280132 | |
| Download: ML20127M184 (47) | |
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ENCLOSURE 1 U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)
FINAL SALP REPORT 50-271/91-99 VERMONT YANKEE NUCLEAR POWER STATION MARCH 17,1991 TO AUGUST 1,1992 BOARD MEETING DATES:
SEPTEMBER 14, 1992 AND
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DECEMBER 14,1992
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TAllLE OF SUMMARY OF RESULTS II.A Overview Overall, the plant activities were conducted in a safe manner. Continued superior performance was noted in the areas of plant operations, maintenance / surveillance and emergency preparedness. Radiological controls were observed to be good and improving. However, performance in the security, engineering / technical support, and safety assessment / quality verification areas declined.
Superior performance in plant operations and maintenance / surveillance was attributed to management involvement and oversight. The ability to correct material deficiencies in a timely manner, very good plant material condition, and sustained superior performance by control room operators contributed to safe and reliable plant operation. Although programmatic weaknesses in operator training and EOPs were identified, corrective actions have been effective and resulted in improvements and in the restoration of the licensed operator requalification (LOR) program to a satisfactory rating.
Noteworthy emergency preparedness performance was attributed to strong management support, prompt resolution of discrepancies, upgraded equipment, and responses to non-emergency events. Some minor reporting and interface problems detracted from the otherwise excellent performance.
The radiological control program performance was determined to be good with an improving trend noted. Program improvements were noted in quality assurance, staffing, and in the packaging and transporting of radioactive materials. Strengths included very good ALARA performance, particularly during the last outage, and management support and supervisory presence in the plant.
In contrast, the security program was assessed as adequate, a drop in pern mance rating since the last SALP. Despite plant and security management's increased attention to and oversight of the security program, programmatic weaknesses persisted throughout the period. Moreover, audits did not identify or cause effective corrective action for several programmatic weaknesses.
The quality of engineering support provided by onsite and offsite engineering was good.
Planning and engineering work for design changes and modifications, root cause analysis, and recommended corrective actions were usually of high quality. Some weaknesses were identified which contributed to a decline in performance in this area. These weaknesses included:
technical problems noted with 10 CFR 50.59 reviews; weak motor operated valve (MOV)
program implementation; and, poor technical evaluations of plant and material conditions.
Safety assessment / quality verification was good. However, performance declines in individual assessment areas were attributed to the failure of self-assessment programs to effectively identify fundamental issues in major program areas.
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II.B Facility Perfonnance Analysis Summary Rating, Trend Rating, Trend Functional Area Last Period This Period 1. Plant Operations
1 2. Radiological Controls
2, Improving 3. Maintenance / Surveillance
1 5. Security
3 6. Engineering and Technical Support
2 7. Safety Assessment / Quality Verification
2 Previous Assessment Period: 10/1/89 - 3/16/91 Present Assessment Period: 3/17/91 - 8/1/92
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PERFORMANCE ANAINSIS III.A Plant Operations Ill. A.1 Analysis Plant Operations was previously rated as Category 1.
Management involvement and the operational organization's conduct of scheduling, planning and oversight were noted strengths and served to ensure the continued high quality of day-to-day operations. The role of Operations Planning was a valuable management asset. The operational experience of senior control room operators remained high. The licensed operator requalification (LOR) program was evaluated as unsatisfactory. Corrective actions were effective as demonstrated during subsequent operator evaluations conducted by the NRC.
Management involvement and oversight at the station and corporate levels continued to be a licensee strength. Management involvement in plant activities was evident in the day-to-day conduct of plant operations, and contributed to good plant and personnel performance. A clear and strong safety orientation was routinely communicated to the plant staff, and management appropriately focused the organization's response to off-normal circumstances and significant i
issues. Conservative management of plant operations was exemplined by: delaying the progress I
of a reactor start-up to repair equipment leaks that did not exceed technical speciGcation limits l
in the drywell; the recovery from a loss of off-site power event and effective resolution of near l
term switchyard and service water related issues. Senior corporate and plant management routinely appraised operating crew and training personnel performance at the simulator
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throughout the LOR cycle. The issuance of a number of operationally-oriented guidelines involving operability, command and control, communications, and the conduct of on-shift training clarified management's expectations. The use of plant managers as Duty and Call Officers was effective in providing direction to the operating staff during back-shift operating periods.
Performance during this period was generally very good in the areas of operator professionalism, conduct of control room operations, and response to off-normal phot conditions. Operational errors were infrequent, caused no reactor scrams, and result.e:1 in only two inadvertent engineered safety features actuations. Operational assessments appropriately characterized emergency or off-normal situations during events, and Emergency Preparedness, Event Response and Emergency Operating Procedures (EOPs) were effectively implemented. Associated actions taken by control room and auxiliary operators were timely, and appropriate operator decisions were made. Some detractions from otherwise superior operator performance occurred, such as:
operator error that resulted in a reactor core isolation cooling system turbine trip during the loss of offsite power event; communication weaknesses with the regional power control authority, which delayed the restoration of off-site power; and, the improper restoration of reactor water level instruments which caused an emergency core cooling initiation (and injection) while the reactor head was removed. The licensee addressed each of these performance issues in a comprehensive manner.
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The licensee safely and professionally conducted outages. Excellent outage performance was characterized by effective planning and scheduling, and frequent presence of managers and supervisors in the field ensured the prompt resolution of safety issues. Good consideration of shutdown risk resulted in reliable decay heat removal during the refueling outage. Good coordination of outage and non-outage activities was demonstrated by the Outage Planning Group. Daily plant status meetings were effective in scheduling and prioritizing maintenance to promptly resolve equipment and safety concerns. - An example of poor coordination between operations and management occurred when contaminated fluid, found weeping from cracks in the drywell concrete pedestal, was not promptly brought to management's attention.
The performance and effectiveness of operations training programs were good and contributed
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to the safe operation of the plant; however, early in the period, deficiencies in the operator training program were noted. Weaknesses involved: not providing sufficient resources to i
maintain a systems approach to training (SAT) program; deficiencies in four of five critical-i elements required for a satisfactory SAT program; inadequate controls regarding the on-shift
training of plant operators, which could potentially have detracted from the monitoring of plant j
parameters; and, a self-identified lack of management awareness of training issues. Subsequent i
to identification, program deficiencies were corrected and the operator requalification training
program was determined by the NRC to be satisfactory. All fourteen operators who took the
requalification exam passed. Significant improvements in job performance measures, simulator scenarios, and exam questions were noted.
Licensed and non-licensed staffing levels and experience remained good. Three of the six shift
crews' staffing levels exceeded the technical specifications requirements by the addition of a spare auxiliary operator. During this period, a spare Shift Supervisor was maintained on the day shift to enhance staffing capabilities and to conduct special projects for the operations department. Overtime was controlled and within administrative limits. Support for ample availability of senior licensed individuals was evident in providing four reactor operators for the current Senior Reactor Operator (SRO) upgrade class, and in the recent re-alignment of the shift l
crews.
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weak. Deficiencies involving the quality of EOP appendices and support procedures, and the failure to ensure that all required materials were available to fully implement support procedures, were identified. In response to these problems, the licensee performed an acceptable root cause -
assessment and their initial response to the weaknesses was good. This assessment occurred late
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in the SALP period and the NRC's evaluation of corrective actions is pending.
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Housekeeping and the plant material condition remained very good, even during refueling and maintenance outages. A fire protection inspection conducted this assessment period indicated that the fire protection activities were effectively implemented. Cleanliness and personnel hazards identified in the drywell during the refueling outage were corrected by aggressive management involvement. Notable initiatives included the following: establishing the fire protection coordinator as a full time position; development of the Basis for Maintaining
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Operability Guideline, which represents a disciplined approach to resolving operability issues and aids in identifying timely corrective actions; implementation of an expanded housekeeping inspection program; and, an irradiated hardware disposal program.
In summary, the licensee continued to operate Vermont Yankee with a high regard for safety.
Effective management involvement and oversight continued to be evident in plant operations and
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was particularly noteworthy during the refueling outage. Operator experience, knowledge, and professionalism resulted in safe operation of the plant, despite some programmatic weaknesses
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l in training and EOPs. Effective corrective actions and program improvements in respone to identified weaknesses were observed during the period, as demonstrated by the restoration of the
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operator requalification program to satisfactory. Overall, strong conservative plant operations and very good plant material conditions remained a licensee strength.
Ill. A.2 Performance Rating:
Category 1
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Ill.B Radiological Controls III.B.1 Analysis
The previous SALP report rated this functional area as Category 2. Management involvement in assuring quality and staffing of the Radiation Protection (RP) organization was determined to be adequate. However, staffing weaknesses occurred during the outage. Radiation safety training program for both general employees and RP technicians was good, Resolution of technical issues from a safety standpoint was determined to be good. The ALARA program was
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considered a licensee strength. A broad-based radiological enhancement plan was implemented late in the period.
The Radiological Environmental Monitoring Program (REMP) and
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radiological effluent control programs were effective. The program for the packaging and transportation of radioactive materials was adequate,
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Radiological safety at the plant has been improved through performanc. cased self-assessment, staffing improvements, reorganization, better utilization of personnel, and improved monitoring and control of radiological activities. The assurance of quality in radiological protection programs was considered good and improving in some areas. Plant tours by RP supervisors and field observations by RP technicians during the refueling outage reflected a good effort to assure and improve the quality of radiological safety. Continued efforts, which stress attention-to-detail and target improvement in radiation work practices and RP procedure compliance, have been supported by management, although some events involving procedural noncompliance, personnel error, or inadequate control of radiological work in the field continued to occur.
The implementation of the radiological enhancement program has resulted in improved radiological
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.7 postings and field controls. This program, in part, contributed to the very good radiological housekeeping observed throughout the period. Efforts to minimize contaminated areas and control dose rates have contributed to efficient maintenance and operation of the plant.
During the previous assessment period, contract RP Technician staffing problems contributed -
to some examples of weak performance in the field. To resolve this issue, station management mounted an aggressive campaign, to attract and retain adequate numbers of qualified contract RP Technicians. These efforts were successful and performance during this 1992 Refueling Outage was much improved. Two qualified technicians were added to the permanent plant staff,
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which resulted in improved implementation of in-plant radiological control measures. The person who had been filling the Plant Health Physicist position was rotated to the Training Department which added a significant amount of plant experience to the qualifications of that group. The Plant Health Physicist position was temporarily filled by well-qualified individuals until a permanent assignment was made late in the period. Overall, staffing and qualifications were improved during the period.
As previously noted, RP performance during the 1992 refuelingLoutage was very good.
Technicians were assigned to satellite control points located near major work locations within the plant. By physically locating groups of well equipped RP Technicians near' work areas, the licensee improved its ability to direct, assess and coordinate radiological efforts in the field. RP Technicians remained well informed on changing radiological conditions _ resulting.from maintenance and plant operations. The use of satellite control points also removed some of the
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congestion and confusion from the main control point area. In addition, redesign of the main control point resulted in improved contamination control and communication with plant workers.
ALARA estimates were, in general, accurate. Following the' outage, RP personnel performed
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a detailed ALARA assessment which reviewed and explained dose expenditures and identified areas for improvement. ALARA performance was considered ve' y good.
r Licensee resolution of technical issues was' generally determined to be sound and thorough.
When the staff was challenged by events involving personnel errors or inadequate radiological controls, investigations of events were timely, technically accurate and appropriately biased toward greater personnel safety. Corrective actions for incidents generally reflected a clear understanding of safety issues.
The training program continued to be effective, although, some weakn' esses were noted in the area of respirator maintenance and testing.
Plant systems training was provided to RP Technician in a series of in_teractive performance-based sessions that incorporated lessons learned from plant events. RP personnel were technically competent and well aware of their duties and responsibilities. In addition, mock-up training was effectively used on jobs such as the recirculation pump seal replacement.
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Environmental Monitoring The licensee has conducted an effective Radiological Environmental Monitoring Program (REMP). Procedures were detailed and well written to effectively implement the REMP. The licensee implemented a very good quality control program to ensure the validity of the analytical measurements for the REMP samples. The instrumentation and equipment of the meteorological monitoring program were operable, properly calibrated and well maintained.
Effective radioactive liquid and airborne (gaseous and particulate) effluent monitoring and control programs were in place. Procedures were detailed and well written to effectively implement the effluent control program. Very good calibration techniques were implemented for the effluent radiation monitors. The licensee had a generally effective program to perform the surveillance tests on filter trains for the Standby Gas Treatment System (SBGTS).
During this period, the licensee established appropriate monitoring of the turbine building roof vents pathway and committed to duct the roof exhaust to the main stack during refueling outage 17. The dose assessment and engineering evaluation were technically sound and thorough and indicated that radiation exposure to the public will be reduced. Appropriate revisions to the Offsite Dose Calculation Manual were implemented.
Based on confirmatory measurements, the licensee had in place an effective program for measuring radioactivity concentrations in process and effluent samples.
Procedures were detailed and provided the necessary control of analytical performance through interlaboratory and intralaboratory QC programs.
The Quality Asmrance Audits performed by the QA Department were thorough and of good technical depth to assess the programmatic performance of the effluent, environmental and radiochemistry programs. Audit-identified findings and recommendations were appropriately resolved in a timely manner.
Radioactive Waste and Tran.sportation The licensee's program for processing and transporting radioactive material was observed to be good and improving during the period. The installation and use of a new resin processing system, and decontamination efforts in the radwaste truck bay, and disposal of radioactive material from the spent fuel pool were noteworthy achievements.
In addition, a large decontamination booth was put into service which provided many methods for efficient and radiologically safe decontamination of plant equipment. Turnover of licensee personnel may have contributed to some weaknesses in the radwaste training and quality assurance programs.
Overall, the station implemented a safe and effective program for radioactive waste processing and transportation of radioactive material and waste.
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in summary, the radiological control program performance was detarmined to be good and improvements were noted in many areas. Improvements were noted in quality assurance and staffing of the RP organization for both outage and non-outage periods. Training programs were generally effective and performance based. Technical issues were well managed from a safety perspective.
The REMP and radiological effluent control programs were effectively implemented. The program for packaging and transporting radioactive materials remained good and showed some improvement since the last period.
III.B.2 Performance Rating:
Category 2, Improving III.C Maintenance / Surveillance Ill.C.1 Analysis The previous assessment for this functional area was rated Category 1. Both the maintenance and surveillance programs were well implemented and reflected the involvement of experienced and highly dedicated personnel. Management involvement ensured comprehensive procedure reviews, technically sound and thorough surveillances, and well planned maintenance.
Maintenance strengths noted during the last SALP period continued throughout this assessment period.
During this period, there was consistent evidence that the maintenance and surveillance performed at VY contributed to safe plant operation. Few significant operational events were attributed to conditions under the licensee's control. Response to component failures was effective as indicated by timely repair and lack of repetitive events. The success of the maintenance and test programs was reflected in high equipment availability.
Managers frequently made field observations to discuss failure mechanisms and to independently assess the status of repair. Emergent maintenance was discussed in detail at Plant Operational Review Committee (PORC) meetings and at daily operational planning meetings, and personnel and equipment resources were made available. Communications were effective between vendors and engineering staff during maintenance activities such as Emergency Diesel Generator (EDG)
overhauls, recirculation pump seal replacement, and the integrated emergency core cooling system test. Good quality control during receipt of equipment and the conduct of performance-based audits and receipt inspections contributed to successful maintenance.
Organizational changes in the Maintenance Department resulted in better definition of responsibilities and improved responsiveness to equipment problems. Good coordination with vendors and other plant departments was observed during plant response to off-normal conditions. The plant's staff consistently demonstrated technical expertise and a proper safety perspective. Permanent plant staffing in the electrical and mechanical engineering support of l
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10 maintenance increased and reliance upon contractors was reduced.
Over.11, Maintenance
Department staffing was sufficient to meet the challenges present during outages and responded i
well to equipment failures.
Maintenance packages were properly prioritized and adequately described technical requirements.
High reliance on worker knowledge and vendor expertise has resulted in excellent maintenance
and " ownership" of equipment. Some isolated occasions of workers not fully understanding j
maintenance requirements and test attributes resulted because the procedures did not contain sufficiently detailed instructions. Delays caused by the unavailability of quality documentation for parts for the alternate cooling tower fan, and enspecified test attributes and boundaries for
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emergency diesel generator jacket cooling, demonstrated poor preparation for preventive
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maintenance.
l The administrative controls for the performance of preventive maintenance during pows
operations using technical specification limiting conditions for operations (LCO) was adequate.
An L.CO-Maintenance Guideline adequately incorporated the qualitative safety principles
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discussed in NRC Inspection Manual technical. guidance.
Some weaknesses regarding documentation, justification, and the level of engineering review of the work pac < ages were
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identified during work on the emergency diesel generators and alternate coolis g towers.
l Notwithstanding these problems, the maintenance performed was good.
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j Successful completion of major maintenance activities ("B" EDG overhaul, recirculation pump seal replacements, on-line steam piping repairs, and refueling outage emergent work activities)
illustrated effective planning and scheduling.
Strong coordination between departments
contributed to well-planned and timely corrective maintenance and ensured the incorporation of
inservice inspection and post-maintenance test requirements. Management involvement, the j
communication of expectations regarding timeliness and personnel safety, and the implementation
of conservative repair efforts were evident. During the outage, the licensee responded well to scheduling challenges due to rework on motor-operated valves, reactor vessel reassembly, and the high pressure turbine system. The maintenance backlog was also well managed, such that corrective maintenance on safety-related equipment-was promptly completed and component
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failures as a result of inadequate maintenance were relatively few,
d Predictive maintenance programs such as thermography, vibration analysis, oil analysis, and erosion / corrosion inspections have generally proven effective as exemplified by the identification
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i of degraded conditions in feedwater heaters, the main transformer, and service water pumps and valves. However, occasionally components, such as the diesel driven fire pump, recirculation pump seals, and the "A" service water pump, were repaired after performance had already
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degraded, indicating that the prediction of eminent failure or end-of-useful life had not been fully
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successful. Increased attention to preventive and predictive maintenance by engineers and plant management was predominantly reactive in response to three consecutive failures of the "A"
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EDG, the inability to maintain high diesel availability, and end-of-life issues associated with
governors, relays, and instrumentation devices.
A Task Force assessment of the EDG maintenance program was instituted near the end of the assessment period.
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Several initiatives were undertaken to strengthen maintenance processes and equipment reliability. These included: the acquisition of equipment to improve the handling and rebuilding of control rod drive mechanisms (CRDM) and the installation of main steam line plugs; the installation of analog differential pressure transmitters and trip units for the primary containment isolation system; and, efforts to improve snubber, CRDM, and motor operated valve reliability and performance. In addition, the licensee has effectively begun use of a Maintenance Planning and Control system and continued their effort to implement a computerized scheduling and tracking program for surveillances.
Maimenance and surveillance caused few challenges to safety systems this period. One plant transient resulted from switchyard activities while connecting a battery to its DC power source, due to inadequate maintenance on the switchyard battery chargers and the failure to recognize the consequences of operating a DC bus without a connected battery bank. During shutdown operations, three engineered safety feature actuations occurred as a result of human errors, inadequate control, or procedural inadequacies. These events were few in number and of minor safety significance.
The surveillance program was well controlled and continued to confirm the operability of safety-related equipment.
Personnel demonstrated a high level of attention-to-detail, procedural compliance, and system knowledge during surveillance testing. Management contributed to quality during testing by being actively involved in the performance of the test and review of results. Technicians improved test procedures by initiating recommendations for procedural changes to clarify surveillance steps, improve calibration techniques, and better define test requirements. In addition, the biennial procedure review program incorporated content and format improvements and aided in the 3dherence to technical specification requirements. As a result, the number of missed surveillances decreased from the previous period. Still, a few missed sutveillances occurred because of weak administration or inadequate review of technical requirements, but these occurrences were self-identified and resulted in improved management of the surveillance program.
In summary, the maintenance and surveillance programs effectively contributed to the safe operation of the plant.
Excellent equipment performance following maintenance and
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troubleshooting has led, with few exceptions, to high equipment reliability and availability.
Nonetheless, the predictive maintenance programs were not fully effective in identifying end-of-life componut issues and concerns prior to equipment performance degradation. Management attention has been focused on resolution of EDG performance problems. Successful completion of several major activities illustrated the licensee's excellent ability to marshal the appropriate resources to correct material conditions and component failures. The skill, experience, and training of the maintenance staff continued to be a licensee strength.
III.C.2 Performance Rating:
Category 1 l
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Ill.D Emergency Preparedness III.D.1 Analysis The previous EP SALP rating was Category 1.
That was based on effective management involvement, ample Emergency Response Organization (ERO) staffing, effective ERO training, proficient exercise performance, and a good relationship with the States of Vermont and New Hampshire, the Commonwealth of Massachusetts, and the surrounding towns.
Two Unusual Events (UEs) occurred during the SALP period. Site management demonstrated safety-consciousness in responding to these events, although some relatively minor reporting problems occurred. Subsequent procedure changes and training comprehensively addressed this matter. A loss of off-site power due to a lightning strike was properly evaluated by the licensee as not requiring an emergency declaration. Also, effective response to an off-site event was demonstrated when a truck carrying unirradiated fuel collided with another vehicle. Timely licensee communications with the Commonwealth of Massachusetts and the fuel vendor contributed to effective response to this event. The nature of those events was properly communicated to the NRC.
The November 1991 full-participation emergency exercise benefitted from timely classifications, effective Technical Support Center (TSC) task prioritization, effective Emergency Operations Facility (EOF) command and control, excellent performance by the EOF dose assessment staff, and excellent provision of information to the States. Correction of prior concerns was evident.
There was, however, an exercise weakness concerning a failure to promptly take action to restore reactor water level, although the condition was recognized by the ERO and eventually self-corrected (by makeup flow). Licensee corrective action led to appropriate additional training, to revision of an Emergency Operating Procedure, and to closure of this concern.
Administration of the drill / exercise program was good. Two station drill / exercises involving all Emergency Response Facilities (ERFs) were conducted in 1991. Key ERO members (Site Recovery Managers, EOF Coordinators, TSC Coordinatots, OSC Coordinators and Dose Assessment staff) participated in walk-through training on an annual basis as a player or observer.
The November 1991 exercise was challenging, but significant changes to the September 1992 scenario were needed to properly test the Emergency Response Facilities and e
Media Center.
ERO positions were filled at least three deep. Classroom training was conducted throughout the year. The training program was well-defined. Lesson plans were properly controlled, accurate (
and detailed. ERO personnel received training augmented by walk-through drills; these drills were a program strength.
The Director, External Affairs maintained close interface with the Emergency Preparedness Coordinator (EPC) and was kept apprised of program status. Strong management support of EP was noted. Examples included system enhancements for the Emergency Response Data System i
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(ERDS), Safety Parameter Display System (SPDS), and Emergency Response Facility l
Information System (ERFIS). Also, station and corporate management maintained emergency response qualifications, reviewed and approved emergency plan and procedure changes,
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participated in drills and exercises, and interfaced effectively with State and local agencies.
The licensee's EP audit program was effective. The Technical Specification audit was combined j
with the 10 CFR 50.54(t) review, Annual audits were appropriate in scope, thorough, and i
received wide management distribution, Individuals with EP experience from other utilities were used to audit the technical aspects of EP. The audit reports were appropriately provided to State
and Commonwealth officials.
Audit team walk-through drills for Shift Supervisors were assessed as an audit program strength. The 1991 audit indicated that the corrective action
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process was not meeting expectations for correcting previously identified exercise areas for
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improvement; the EPC changed the tracking of these items and thereby established a control system that achieved timely resolution of those exercise areas for improvement.
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EP program administration was good. Emergency Plan Implementing Procedures (EPIPs) were
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generally well-stated and were properly reviewed, approved, and distributed.
Emergency response facilities, equipment, and supplies were well maintained. Licensee ERF surveillance reports were effective and discrepancies were resolved promptly. A modification allowed the control room simulator to drive ERFIS and thereby provided real-time operational data to the TSC and EOF staffs; this was a significant program enhancement. The EP program was
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administered by the EPC, who was supported by a full-time staff member with the responsibility
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for community relations and off-site training. Some coordination problems occurred in the
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licensing and security interfaces with EP. A procedure change did not adequately address an i
ERDS equipment modification and the EPC was not aware that, due to a conflict with weapons
training, annual EP training for the majority of the Security Department had not been held for 15 months.
In summary, the licensee's EP program was well implemented. Strengths included strong
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management support, prompt resolution of discrepancies, EP equipment upgrading, effective i
audits, maintenance of ERFs, excellent State and local interfaces, and. responses to non-I emergency events.
Exercise performance, training, and program administration were noteworthy. Responses to Unusual Events were good, with some minor exceptions.
III.D.2 Performance Rating:
Category 1
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Ill.E Security ill.E.1 Analysis
'r ased on The previous performance rating for this area was Category 2.
improvements in security effectiveness due to increased managemen'
apport for the security program. Some progress was made in effecting imr
/er program weaknesses were still apparent, particularly in the areas of acce ARC reporting requirements and documentation of events.
During this period, corporate management continued
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cces to improve the program, for example: the assessment system and alarr j
graded; the main access
.: for contractor assistance control center was extensively modified; and fundinc q,
in preparation for an NRC Operational Safeguards j
. son (OSRE) and specialized
tactical training for selected security personne'
ulted in the identification of weaknesses in the licensee's contingency resp <
che licensee's corrective actions led to improvements in contingency responr ioyment, as well as in the purchase I
of upgraded weapons.
Plant management demonstrated a m< p rogram oversight during this period. For example, plant management's coor R aght resulted in minimum impact on station activities, both during modificar[
Mcess control center and after it was returned to service. To strengthen the [
s n, the Chief of the contract security force was removed from the line posif g assist the licensee's security supervisor midway through the period. Addi' 5 e period, an individual with extensive experience in providing training to l'
ficers was hired by the contractor to administer the training program.
aining program was sound, with generally good lesson
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plans and adequate fcctiveness was demonstrated by relatively few personnel errors that could
. dequate training. Personnel errors that occurred during the period were pe
. Additionally, an organizational change was effected late in the period whic'
sition for a security manager. The change resulted in the security program F J sole responsibility of a line manager equivalent to with managers of othe-
. The position was filled by an individual who had former military secur; who was an auditor in the operational Quality Assurance Department of the
,ervices Division. The impact of these changes has not yet been assessed.
J security management's increased attention to and oversight of the security
., ram weaknesses persisted throughout the period. For example, the licensee's
.ractor identified an event early in the period that involved adverse performance on
. several security force members. Subsequent concerns with the licensee's handling vent, particularly, the licensee's lack of prompt and aggressive followup and failure to
. the event to the NRC, were viewed as a significant breakdown in a safeguards system and
.ek of management attention to licensed responsibilities. Other examples throughout the eriod included: (1) nine individuals who were improperly granted unescorted access to the
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14a Ill.E Security ill.E.1 Analysis The previous performance rating for this area was Category 2.
This rating was based on improvements in security effectiveness due to increased management attention to and support for the security program. Some progress was made in effecting improvements, however program weaknesses were still apparent, particularly in the areas of access authorization, NRC reporting requirements and documentation of events.
During this period, corporate management continued to provide resources to improve the
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program. For example,- the assessment system and alarm stations were upgraded; the main access control center was extensively modified and enlarged; and funding was also provided for contractor assistance in preparation for 'an NRC Operational Safeguards Response Evaluation (OSRE) and specialized tactical training for selected security personnel. The OSRE resulted in the identification of weaknesses in the licensee's contingency response capabilities.
The licensee's corrective actions led to improvements in contingency response and weapons deployment, as well as in the purchase of upgraded weapons.
Plant management demonstrated a more active role in program oversight during this period. For example, because of plant management's coordination and oversight, modifications to the main access control center and its return to service resulted in minimum impact on' station activities.
To strengthen the security organization and improve communications between the contract security force and the licensee, the Chief of the contract security force was removed from the line position and assigned to assist the licensee's secrrity supervisor midway through the period.
Additionally, later in the period, an individual with extensive experience in providing training to law enforcement officers was hired by the contractor to administer the training program.
The contractor's training program was sound, with generally good lesson plans and adequate training aids. Its effectiveness was demonstrated by relatively few personnel errors that could be attributed to inadequate training. Personnel errors that occurred during the period were performance related. Additionally, an organizational change was effected late in the period which created a new position for a security manager. The change resulted in the security program being the direct and sole responsibility of a line manager equivalent to managers of other station programs. The position was filled by an individual who had former military security experience and who was a lead auditor in the operational Quality Assurance Department of the Yankee Nuclear Services Division. The impact of this last personnel change has not yet been assessed.
Despite plant and security management's increased attention to and oversight of the security program, program weaknesses persisted throughout the period. For example, the licensee's security contractor identified an event early in the period that involved adverse performance on the part of several security force members. Subsequent concerns with the licensee's handling of the event, particularly, the licensee's lack of prompt and aggressive followup and failure to report the event to the NRC, were viewed as a significant breakdown in a safeguards system and a lack of management-attention to licensed responsibilities. Other examples throughout the period included: (1) nine individuals who were improperly granted unescorted access to the
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f-
station; (2) failure to implement proper compensatory measures for an intrusion -
problem; (3) inappropriate reading material at duty stations; (4) poor se-j personnel and vehicles; (5) inadequate protection of safeguards informatior ate assessment of potential security events.
Several of these weakn<
s be programmatic and at least two were similar in nature to previously ide
. The
,
licensee failed to demonstrate aggressiveness and expertise in resolv
.s.
1 l
Security management continued to exhibit gooa interface with st-h
<hich resulted j
in a refueling outage without any interface problems. An im-
/
.s also displayed by plant employees toward the security program, primarily -
.(ention from plant management. This was also an indication of manageme-
[
program, i
Security force staf0ng was marginal, as evidenced bv j
ance on overtime to meet routine operational needs. This situation was exar
, refueling outage when the
'
.
need for compensatory measures, which are mar
.ncreased. While the licensee identified the need for additional manpower to i to the outage, the licensee was
,
not aggressive in ensuring that the contract f
Two licensee over-hire positions l
'
were created and filled during the period '
.mc staffmg problem, but these were
,
!
subsequently lost through attrition. D-aal overtime, members of the security force exhibited a professional demer good morale throughout the period.
Although the annual program au/ [
ebensive, in-depth and performance-oriented
l than during previous periods, - @
ogrammatic weakness and two findings, which
involved the modi 6cd acce' g d were identified by the audit team as potential regulatory issues, were 4"
iGcant by the licensee and, therefore, were not
properly pursued. One as since been corrected and the other remains under
>
j review by the NRC. '
e of possible problems in the licensce's auditing process.
[
Except for a fa; ka complete for-cause Fitness-For-Duty (FFD) test to two l
individuals, tb
,ed a generally effective FFD program. Corrective actions taken
by the licen<
,tial program weaknesses identiGed during the initial FFD program
review w-
,ective, indicating appropriate management attention. Members of the see-it access control duty posts were alert in identifying potential FFD
-
j progr
.
procedure for re[x3rting events to the NRC was clear and consistent with NRC
'
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ments. However, the licensee continued to have difficulty in evaluating events
.ning which events needed to be reported promptly. The licensee experienced four
,
i
. two were reported correctly, one was tardy, and one was not reported at all.
events were properly documented, but corrective action was not initiated in several
'
.volving the protection of safeguards information. This indicated a problem in the i
i i
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v
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e
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15a station; (2) failure to implement compensatory measures promptly for an intrusion detection system problem; (3) inappropriate reading material at duty stations; (4) poor search practices for
personnel and vehicles; (5) inadequate protection of safeguards information; and (6) inadequate assessment of potential security events.
Several of these weaknesses appeared to be
programmatic and at least two were similar in nature to previously identified weaknesses. The
!
licensee failed to demonstrate aggressiveness and expertise in resolving several of these problems.
,
Security management continued to exhibit good interface with station operations, which resulted in a refueling outage without any interface problems. An improved attitude was also displayed
by plant employees toward the security program, primarily due to increased attention from plant
,
management. This was also an indication of management attention to the program.
!
Security force staffing level was marginal, as evidenced by the continued reliance on overtime
to meet routine operational needs. This situation was exacerbated during the refueling outage when the need for compensatory measures, which are manpower intensive, increased. While the licensee identified the need for additional manpower to its contractor prior to the outage, the licensee was not aggressive in ensuring that the contractor met that need. Four additional i
positions were created and filled during the period to alleviate the staffing problem. Despite the i
substantial overtime, particularly during the outage, members of the security force exhibited a professional demeanor and generally good morale throughout the period. Additionally, they
'
performed their duties with a low rate of personnel errors.
i Although the annual program audit showed some improvement in that it was more comprehensive, in-depth and perfornnce-oriented than during previous periods, it did not identify the programmatic issues enmerated above. However, findings that were identified
,
were promptly and appropriately addressed. Two findings, which involved the modified access control center, were identified by the audit team as potential regulatory issues. Both of these
matters have since been resolved.
l The licensee maintained a generally effective Fitness-For-Duty (FFD) program except for a
failure in one event to administer a complete for-cause FFD test to two individuals. Corrective actions taken by the licensee to resolve potential program weaknesses identified during the initial
FFD program review were prompt and effective, indicating appropriate management attention.
!
Members of the security force in-plant access control duty posts were alert in identifying
potential FFD program violators.
!
The administrative procedure for reporting events to the NRC was clear and consistent with NRC reporting requirements. However, the licensee continued to have difficulty in evaluating events and in determining which events needed to be reported promptly.
The licensee
experienced four such events; two were reported correctly, one was tardy, and one was not i
reported at all. Loggable events were properly documenS 1, but effective corrective action was not apparent in several cases involving the protection of safeguards information. The licensee's corrective actions, for the most part, were limited to retraining the personnel involved on proper
handling of safeguards information. This limited approach did not address the programmatic problem which resulted in recurring events. This indicated a problem in the i
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.
licensee's system of tracking and analyzing loggable events. The probleir
,
previous SALP concerning the lack of details in documentation of logr
.ot observed during this period.
During this assessment period, the licensee submitted seven revisir program plans under the provisions of 10 CFR 50.54(p). With one excepti
.rected, the revisions were of good quality and technically sound.
In summary, the licensec maintained an adequate security
/
!
, rate management providal resources to improve the program and plant mana
/
.<cd better oversight,
'
f solicited corporate support, created a security manager'< / jf x other organizational
,
changes to strengthen the program. However, progr-
.es persisted. Despite an g
'
improved audit program, programmatic weaknesse'
ad and potential regulatory issues that were identiDed were not properly addr<
.nyces demonstrated increased
,
attention to security and management's commit
. rogram was evident. Although
,
staffing was marginal and the use of over'
the security force maintained a professional demeanor and performed the:
avely few personnel errors.
Ill.E,2 Performance Rating:
i Ill.E.3 lloard Comments
Programmatic prob! ems wb'
ng this period, despite increased management attention, suggest weaknes'
detection thus far. The licensee should conduct a comprehensive and ind nt of the security program and its implementation to identify root cause(s)
y program weaknesses. The results of the assessment should be discussed x
@
III.F Engir alcal Support lil.F.1 The-
.ed performance in this area as Category 1, with an overall conclusion that th<
ed to have a high quality engineering program. Support from onsite and
., was excellent. Engineering programs continued to be updated and improved.
. age planning and design were effective and timely. A problem with 10'CFR
, valuations for " changes, tests and experiments" was identified which appeared to aie to past practices or isolated cases. During this period, the quality of engineering
- sues, long-term safety improvements, modifications, outage planning, and engineering
,s and evaluations) activities of the licensee's onsite and offsite engineering organizations aued to be of generally high quality.
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16a
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licensee's system of tracking, analyzing and correcting loggable events. The problem addressed in the previous SALP concerning the lack of details in documentat'an ofloggable events was not observed during this period.
During this assessment period, the licensee submitted seven revisions to its security program plans under the provisions of 10 CFR 50.54(p). With one exception, which was corrected, the revisions were of good quality and technically sound.
In summary, the licensee maintained an adequate security program. Corporate management provided resources to improve the program and plant management demonstrated better oversight, solicited corporate support, created a security manager's position, and made other organizational
'
changes to strengthen the program. However, programmatic weaknesses persisted. Despite an improved audit program, some programmatic weaknesses were not identified. Plant employees demonstrated increased attention to security, and management's commitment to the FFD program was evident. Although staffing was marginal and the use of overtime was routine, the security force maintained a professional demeanor and performed their duties with relatively few personnel errors.
III.E.2 Performance Rating:
Category 3 III.E.3 Board Comments Programmatic nroblems which occurred during this period, despite increased management mention, suggest weaknesses that have escaped detection thus far. The licensee should conduct a con.prehensive and independent assessment of the security program and its implementation to identify root cause(s) of the continuing program weaknesses. The results of the assessment should be discussed with the NRC.
III.F Engineering and Technical Support III.F.1 Analysis The previous SALP rated performance in this area as Category 1, with an overall conclusion that the licensee continued to have a high quality engineering program. Support from onsite and offsite engineering was excellent. Engineering programs continued to be updated and improved.
Engineering outage planning and design were effective and timely. A problem with 10 CFR 50.59 safety evaluations for " changes, tests and experiments" was identified which appeared to be attributable to past practices or isolated cases. During this period, the quality of engineering (generic issues, long-term safety improvements, modifications, outage planning, and engineering analyses and evaluations) activities of the licensee's onsite and offsite engineering organizations continued to be of generally high quality.
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The engineering effort emphasized plant safety and reliability. For example, the licensee's response was good to a potentially unanalyzed high energy line break in the reactor building.
Although this specific condition was not applicable to Vermont Yankee, a potential equipment qualification concern, based on a similar event in the steam tunnel, was' identified. The licensee performed a comprehensive analysis to resolve this concern and demonstrated a strong emphasis on obtaining accurate design basis information. Other examples of good performance included upgrading earthquake response procedures and equipment, and installation of a remote video surveillance system inside the drywell.
Day-to-day engineering support by site, corporate, and Yankee Nuclear Services Division (YNSD) was good. The location of the Engineering Director on-site, and the delegated authority of the Technical Superintendent to authorize the use of engineering resources on an immediate basis assured quick responses to safety concerns; the conduct of failure analyses and investigations; and supporting operability determinations. An example was the use of YNSD metallurgical engineering expertise in responding to the " A" emergency diesel generator (EDG)
cylinder liner failures.
Good programs were established for resolution of longer term equipment issues.
These included: an extensive erosion / corrosion program that identified the need for, and timely accomplishment of, feedwater heater and steam piping replacements; an ongoing examination and repair program for condensate storage tank erosion, including the conduct of metallurgical and inservice inspection (ISI) evaluations; and the development of a comprehensive roof repair and upgrade program for facility buildings, including the EDG rooms. The resolution of the condensate storage tank corrosion issue was of particularly high technical quality.
Engineering and technical support personnel are. knowledgeable and provided keen technical insights for addressing reactor mode switch reliability, chemistry lab drain line corrosion, and enhancements to emergency response facility (ERF) information system capability.
The engineering department is fully staffed and has experienced a relatively low turnover rate.
Procedural adherence was very good, and personnel errors were infrequent. The design basis database, although only partially complete, provided ready access to design information in the event of a need for engineering and/or operational response. The system's utility was evident in the quick resolution of a standby liquid control pump net positive suction head problem.
Efforts begun prior to March 1991 to strengthen the design change program were continued under the licensee's " Commitment to Excellence Program (CEP)." The improvements have included: upgrading of the " scoping memo" process; more realistic scheduling of modifications; and a more intensive review and approval process. The effectiveness of the above improvements was evident by the absence of significant fiald changes during installation of modifications during the 1992 outage, and accomplishment of all scheduled modifications for this outage.
Enhancements to the safety parameters display system and the ERF information system were technically sound and reflected detailed engineering analysis which led to appropriate emergency plan implementing procedure (EPIP) modifications. However, less than adequate technical'
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t 8
^
review of an emergency response display system (ERDS) upgrade resulted in *
i made operational before appropriate modifications were made to the EPIPs. C e
corrective actions were appropriate.
- Despite the licensee's excellent performance in traditional enginee
.chnical
,
support to operational problems, in some cases, was inadequate. Ev actions in
.
response to Generic Letter (GL) 89-10 regarding motor operated v'
mconsistent
-
safety evaluations conducted under 10 CFR 50.59.
Safety evaluations did not consistently reflect good quality o-j agineering efforts.
'
Plant operational or material conditions that were not sys'
.ed included: (a) the
reviews relating to the seepage of contaminated wat'
. the concrete drywell
support pedestal were initially too narrowly focused
- a lack of understanding
of the issue; (b) the initial response to the identific j
.:ad and vessel cladding ISI indications lacked a comprehensive basis that C
[-
a not penetrate into the base
'
metal; (c) poor maintenance engineering perf j
.oping guidance for switchyard battery work resulted in a loss of off-site p-
, review involving the redirection i
of the service water flowpath resulted i
.o the EDGs. To eliminate these
weaknesses and strengthen the progra-
.nplemented a revised procedure and initiated a training program to enhance &
.:ty evaluations. More recent evaluations have been of higher quality and in/ U s emphasis on improving this area, i
i The lack of a coordinated Mr #
and poor evaluations caused an inaccurate k[
response (i.e. the wrong be orque switches) to be submitted to the NRC.
Following, and in respons OV inspection conducted in May 1991, a senior
-
engineer was assigned te ive in the project management oversight of concerns
$vctive engineering involvement was noted during the
!
in the MOV GL 89 '
,
refueling outage wh<
q ted a significant emergent work issue to resolve industry results of validatic
.-operated valve diagnostic equipment. A number of valves
'
were identified '
. confidence limits and were re-evaluated. This emergent work
i had a signific
, outage schedule; but, demonstrated a good safety orientation.
Engineerine an this matter with the NRC was also good.
Equipe aso received appropriate attention. The licensee's emphasis on these issue
,er concern for plant safety and reliability. The engineering efforts to res
. vere high quality. Some of the examples were as follows: 1) replacement
.
armer; 2) replacement of feedwater heaters 3A and 3B; and 3) metallurgical r
,ed to emergency diesel-generator "A" cylinder liner issues.
One-for-one placements evaluations were generally effective, as were the material upgrade and
.: valuation (MAUDE) process.
The Failed Fuel Action Plan continued to be ad in an effective manner; engineering information reports continue to be widely
.ed and efforts to minimize steam leaks were aggressive.
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18a review of an emergency response display system (ERDS) upgrade resulted in this system being made operational before appropriate modifications were made to the EPIPs. Subsequent licensee corrective actions were appropriate.
Despite the licensee's excellent performance in traditional engineering areas, the technical support to operational problems, in some cases, was inadequate. Examples included: actions in response to Generic Letter (GL) 89-10 regarding motor operated valves (MOVs) and inconsistent safety evaluations conducted under 10 CFR 50.59.
Safety evaluations did not consistently reflect good quality or comprehensive engineering efforts.
Plant operational or material conditions that were not systematically evaluated included: (a) the reviews relating to the seepage of contaminated water from cracks in the concrete drywell support pedestal were initially too narrowly focused, and demonstrated a lack of understanding of the issue; (b) the initial response to the identification of reactor head and vessel cladding ISI indications lacked a comprehensive basis that the indications did not penetrate into the base metal; and (c) poor maintenance engineering performance in developing guidance for switchyard battery work resulted in a loss of off-site power. To eliminate these weaknesses and strengthen the program, the licensee implemented a revised procedure and initiated a training program to enhance the quality of safety evaluations. More recent evaluations have been of higher quality and indicate the licensee's emphasis on improving this area.
In December 1991, a senior engineer was assigned to and has been effective in the project management oversight of concerns in the MOV GL 89-10 program. Effective engineering involvement was noted during the refueling outage when the licensee created a significant emergent work issue to resolve industry results of validation testing.of motor-operated valve diagnostic equipment. A number of valves were identified as outside the 95% confidence limits and were re-evaluated. This emergent work had a significant impact on the outage schedule; but, demonstrated a good safety orientation. Engineering communication on this matter with the NRC was also good.
Equipment issues have also received appropriate attention. The licensee's emphasis on these issues indicates a proper concern for plant safety and reliability. The engineering efforts to resolve these issues were high quality. Some of the examples were as follows: 1) replacement of the main transformer; 2) replacement of feedwater heaters 3A and 3B; and 3) metallurgical expertise provided to emergency diesel generator "A" cylinder liner issues.
One-for-one component replacements evaluations were generally effective, as were the material upgrade and dedication evaluation (MAUDE) process.
The Failed Fuel Action Plan continued to be -
administered in an effective manner; engineering information reports continue to be widely distributed and efforts to minimize steam leaks were aggressive.
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Licensee Event Reports (LERs) were usually well written and contained adequate descriptions of the event. Generally, root cause analyses were technically correct, and satisfactory corrective actions were recommended. Where broader or in-depth analysis was needed, problems were referred to YNSD.
Corrective actions were generally satisfactorily developed for reactive issues; however, switchyard-related equipment was identified as requiring further engineering attention under a licensee program. A review of several LERs detected instances where engineering analyses and-evaluations were not always sufficiently comprehensive or properly focused. Examples included:
main generator regulator fidelity during on-line coastdown not identified as a long-term corrective action; and, a reactor scram caused by an inadequate maintenance guideline. A primary containment system actuation occurred due to a failed relay coil but could have been prevented by an established energized relay service life program. The lack of such a program could have been identified by a critical self-assessment of the engineering organization. The on-site engineering organization is primarily responsible for reportability decisions and LER generation. Failures to report, late reporting, and required information being incorrect or omitted were noted during this SALP period.
In summary, the quality of engineering support provided by the onsite and offsite engineering groups was good Planning and engineering work for design changes and modifications, root cause analysis, and recommended corrective actions were usually of high quality. The efficiency of modification implementation was indicative of a competent, well trained staff.
Communications were effective among various plant, corporate, and offsite organizations.
However, the safety assessment process had some weaknesses.
Although the licensee implemented a comprehensive corrective action plan, there was insufficient data to make a definitive assessment because this program was implemented late in the SALP cycle. Also, a number of issues were identified by the NRC that involved failure to report, late reporting, and/or missing information.12ck of attention in the technical depth of analysis in the initial response to NRC Generic Letter 89-10 was also noted.
III.F.2 Performance Rating:
Category 2 III.G Safety Assessment / Quality Verification Ill.G.1 Analysis The previous SALP rated this area Category 1. The licensee had improved an already strong area in licensing and in resolving technical issues. Submittals were timely, responsive to safety issues and of high technical quality. Quality verification programs were a strong area but had again improved since the previous period, especially in the area of corrective action programs.
Strong management involvement continued to be noted. The Board had commented that the licensee should evaluate the effectiveness of their program for dealing with employee concerns.
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During this period the licensee instituted an effective program for dealing with employee concerns, including: (1) team building efforts; (2) management training to focus supervisors on work-place environment issues and necessary communication skills; and, (3) ensuring that contractors were aware of the program elements and management's philosophy on addressing employee concerns. Senior management was committed to the establishment of a positive atmosphere for the resolution of employee safety concerns, and supervisors have responded in an appropriate manner to address such concerns. However, the licensee's evaluation of the Employee Improvement Suggestion and Safety Concern Program was not thorough in assessing their employees' understanding of the anonymity aspects of the program. Executive management ensured that corrective actions were put into effect to address this issue.
Regarding the contractor oversight concern of the previous SALP, the licensee has successfully caused its principal on-site contractor to restructure its organization to provide QA/QC independence.
Efforts to improve oversight and proper interface with the contractor were appropriate.
The licensee's self-assessment programs have not been fully effective in identifying fundamental issues in program areas. Specifically, the NRC reviews for training, EOP and MOV programs identified significant weaknesses early in the assessment period. Programmatic weaknesses in security also persisted. These individual program assessments are discussed in applicable sections of this report. Program improvements were noted in the latter part of the assessment period, demonstrating that the licensee's corrective action process for these areas has been effective. Some improvements in the security program have been accomplished, but deficiencies were still being found in the areas of Operational Safeguards Response Evaluation issues, organizational and personnel performance, and staffing.
Corrective action processes continue to be improved and further enhancements have begun. A new guideline was developed to describe staff use of the corrective action program and how various processes are integrated into the overall program. Trending and corrective action effectiveness reviews are being conducted. This program has been effective in correcting substandard or anomalous performance, once identified. Examples were switchyard and service water issues, missed surveillance tests, the failure of a residual heat removal valve to close due to a broken torque key, and quality related concerns caused by deficiencies in the performance of a contractor.
The leadership of the PORC and the members' probing discussions contributed significantly to the safe operation of the plant. The refueling outage pre-startup PORC meetings utilized a comprehensive strategy to encourage the identification (and resolution) of issues involving readiness to startup. The Nuclear and Safety Audit Review Committee also provided effective oversight. Root cause analyses tended to be of high quality and reflected good effort by both on-site and off-site engineering groups. As noted in Section III.F, failures to properly evaluate changes under the provisions of 10 CFR 50.59 to important plant systems were identified.
Program enhancements were on-going, with good performance noted towards the end of the assessment period.
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The monitoring of plant performance and the identiGcation of precursors of-
.,
]
have been effective. Strong performance by the Operations Planning Coc
.ge Planning Group and by PORC was noted as part of day-to-day moni'
The
aggressive use of the Emergency Response Facility Information System anagers and shift personnel continues to be an important tool for identif
,,lant and
'
equipment performance. The shift engineers and plant operators c
.ed selected t
systems, particularly in the areas of failed fuel, drywell leakr
. ions, coolant system conductivity anomalies, recirculation pump seal perfe
,n/ corrosion.
Licensing submittals were generally adequate, although v
.oted in some of the
'
evaluations and timeliness of responses.
SpeciGcaP were returned due to I
l inadequate justification for an exemption to the Alter-
. diversity issue and non-i speciGc information regarding the request for a chr
,'
aposition. Further, on one
occasion, the reply to a request for additional infc
,, the station blackout rule was
!
not timely in that it took approximately Ove me a generic letters and issues have i
been good.
j in summary, the licensee has a good SA ~
. ace at Vermont Yankee. Quality and
timeliness of licensing submittals hav-alth some noted exceptions. Responses to generic letters and generic issue' 4 PORC oversight has been excellent and
)
the monitoring of plant performa
.fication of precursors of potential problems have been effective. Resolutie 4 gnot always been effective as evidenced by the
persistence of programmatic 49 performance concerns were identified in several j
areas: poor maintenance e Y
presulted in the loss of offA pewer; and, safety evaluations that did not ' h dgood quality or comprehensive engineering. Based g
on the major program
't by the NRC this period, the licensee's self-assessment
-
programs have not ffective at identifying fundamental problems. Overall, l
management invo'
ed in all areas of SA/QV during this SALP period.
III.G.2 ating:
Category 2 i
>
d d
i a
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21a The monitoring of plant performance and the identification of precursors of potential problems have been effective. Strong performance by the Operations Planning Coordinator, the Outage Planning Group and by PORC was noted as part of day-to-day monitoring functions. The aggressive use of the Emergency Response Facility Information System by department managers and shift personnel continues to be an important tool for identifying anomalous plant and equipment performance. The shift engineers and plant operators effectively monitored selected systems, particularly in the areas of failed fuel, drywell leakage, turbine vibrations, coolant system conductivity anomalies, recirculation pump seal performance and erosion / corrosion.
Licensing submittals were generally adequate, although weaknesses were noted in some of the evaluations. Specifically, the requests were returned due to inadequate justification for an exemption to the Alternate Rod Injection diversity issue and non-specific information regarding the request for a change in PORC composition. Responses to generic letters and issues have been good, in summary. the licensee has a good SA/QV program in place at Vermont Yankee. Quality and timeliness of licensing submittals have been adequate, with some noted exceptions. Responses to generic letters and generic issues have been good. PORC oversight has been excellent and the monitoring of plant performance and the identification of precursors of potential problems have been effective. Resolution of problems has not alway, been effective as evidenced by the persistence of programmatic security issues. Performance concerns were identified in several areas: poor maintenance engineering which resulted in the loss of offsite power; and, safety evaluations that did not consistently reflect good quality or comprehensive engineering. Based on the mSor program reviews conducted by the NRC this period, the licensee's self-assessment programs have not consistently been effective at identifying fundamental problems. Overall, management involvement was observed in all areas of SA/QV during this SALP period.
III.G.2 Performance Rating:
Category 2 I
i
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IV.
SUPPORTING DATA AND SUMMARIES IV.A Licensee Activities Vermont Yankee operated safely this assessment period. Equipment and system availability and reliability remained high although the overall performance of the "A" emergency diesel generator degraded due to component failures. The plant was shutdown on September 8,1991 to replace the reactor recirculation pump seats due to end-of-life degradation, and on March 7, 1992 to enter Refueling Outage XVI. The plant experienced three reactor trips: (1) April 23, 1991, a loss of offsite power caused by maintenance in the switchvard resulted in a plant trip from 100 percent power; (2) June 15,1991, a loss of 345 kV power due to a severe electrical storm carsed a plant trip and loss of offsite power; and (3) March 7,1992, during the plant shutdown for Refueling Outage XVI, at less than one percent of rated power, a reactor scram occurred due to conta := in the reactor mode switch not fully engaging.
IV.B NRC Inspection and heview Activities Two NRC Resident inspectors were assigned to Vermont Yankee for the assessment period.
NRC team inspections were conducted in the following areas:
Augmented Inspection Team: April 25-29, 1991 with followup on August 6-22, 1991,
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that reviewed a loss of offsite power event which was caused by main'.cnance in the switchyard.
Training Program Evaluation: October 21-25,1991.
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Motor-Operatad Valve Inspection: May 20-25,1992.
Emergency Operating Procedures Inspection: February 24-28,1992.
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Electrical Distribution System Functional Inspection, First Week: July 20-24,1992.
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NITACllMENT SALP EVALUATION CRITERIA Licensee performance is assessed in selected functional areas signincant to nuclear safety and the environment. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observations. Special areas may be added to highlight signi6 cant obsen'ations.
The following evaluation criteria were used, as applicable, to assess each functional area:
1.
Assurance of quality, including management involvement and control; 2.
Approach to the resolution of technical issues from a safety standpoint; 3.
Enforcement history; 4.
Operational events (including response, analyses, reporting and corrective actions);
5.
Staffing (including management);
6.
Training and qualification.
Based upon the SALP Boarf assessment, each functional area eviduated is classified into one of three performance categories. The definitions of these performance categories are:
Cntecorv 1. Licensee management attention and involvement in nuclear safety or safeguards activities resulted in superior performance.
The NRC will consider reduced levels of discretionary inspection.
Q1tecory 2. Licensee management attention and involvement in nuclear safety or safeguards activities resulted in good performance. The NRC will consider maintaining normal levels of discretionary inspection.
Cntecorv 3.
Licensee management attention or involvernent in nuclear safety or safeguards activities resulted in acceptable performance. Performance at this level is of concern to the NRC because a decrease in performance will approach or reach an unacceptabic level. The NRC will consider increased levels of discretionary inspection. (if the NRC was to conclude that there was not an adequate level of safety performance, prompt and appropriate action would be taken separately from, and on a more urgent schedule than, the SALP process.)
The SALP report may include an appraisal of the performance trend in a functional area for use as a predictive indicator. Licensee performance during the assessment period is examined to determine whether a trend exists. Normally, this performance trend would only be used if both a definite trend is discernable and continuation of the trend would result in a change in performance rating.
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Attachment
The trend, if used, is defined as:
Improving: Licensee performance was determined to be improving during the assessment period.
Declinirig: Licensee performance was determined to be declining during the assessment period and the licensee had not taken meaningful s: cps to address this pattern.
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AING of PRUS$1A, PlNNSYLVANIA 1W101415
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Docket No. 50-271 hir. Warren Senior Vice President, Operations Vermont Yankee Nuclear Power Corporation RD 5, Box 169 Ferry Road Brattleboro, Vermont 05301
Dear hir. hfurphy:
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SUBJECT:
INITIAL SYSTEhiATIC ASSESShiENT OF LICENSEE PERFORhfANCE
(SALP) REPORT NO. 50-271/91-99
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On September 14,1992, an NRC SALP Board conducted a review to evaluate the performance of activities associated with the Vermont Yankee Nuclear Power Station. The results of this
assessment are documented in the enclosed initial SALP Report for the period between hiarch 17,1991 and August 1,1992. As previously agreed, we will hold a meeting with you
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and your staff on October 29,1992 at the Vernon Town Hall in Vernon, Vermont, to discuss
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the findings of this report. In accordance with NRC policy, this meeting will be open for public j
observation.
I During this SALP period, activities at Vermont Yankee were performed in a safe manner.
Vermont Yankee demonstrated superior performance
.in the plant operations, maintenance / surveillance, and emergency preparedness areas. Good performance was obsen'ed j
with respect to radiological controls (an improving trend was noted), engineering / technical
support, and safety assessment / quality verification.
However, performance in i
engineering / technical support, safety assessment / quality verification, and security declined from
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our previous assessments.
Programmatic security weaknesses persisted despite additional i
attention to the program by your staff. The performance decline observed in three of the seven
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functional areas raises concern about the effectiveness of your self-assessment programs Please j
be prepared to discuss your plans to improve the effectiveness of your performance assessment i
programs at the October 29,1992 meeting.
i Upon completion of our discussion of this SALP report on October 29,1992, we request that i
you provide written comments, including correction of factual information, within 20 days of l
the date of the meeting. The enclosed report and your response will be placed in the NRC Public Document Room.
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hir. Warren P. Murphy
Your cooperation with us is appreciated.
Sincerely, i
Thomas T. hiartin Regional Administrator
Enclosure:
Initial Systematic Assessment of Licensee Performance (SALP)
Report No. 50-271/91 99
REGION I==
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT NO. 50-271/91-99 VERMONT YANKEE NUCLEAR POWER STATION ASSESSMENT PERIOD:
MARCII 17, 1991 - AUGUST 1,1992 BOARD MEETING DATE: OCTOBER 29,1992
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SALP PROGRAM OlUECTIVES
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IDENTIFY TRENDS IN LICENSEE PERFORMANCE
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PROVIDE BASIS FOR NRC RESOURCE ALLOCATION
IMPROVE NRC REGULATORY PROGRAMS l
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FUNCTIONAL AREAS 1.
PLANT OPERATIONS 2.
RADIOLOGICAL CONTROLS 3.
MAINTENANCE / SURVEILLANCE 4.
SECURITY AND SAFEGUARDS 6.
ENGINEERING /TECIINICAL SUPPORT 7.
SAFETY ASSESSMENT / QUALITY VERIFICATION Vernwn! Yankee Shde 4
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EVALUATION CRITERIA 1.
ASSURANCE OF QUALITY, INCLUDING MANAGEMENT INVOLVEMENT AND CONTROL 2.
APPROACil TO TIIE RESOLUTION OF TECIINICAL ISSUES FROM A SAFETY-STANDPOINT 3.
ENFORCEMENT IllSTORY
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4.
OPERATIONAL EVENTS (INCLUDING RESPONSE TO, ANALYSES OF, REPORTING OF, AND CORRECTIVE ACTIONS FOR)
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STAFFING (INCLUDING MANAGEMENT)
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EFFECTIVENESS OF TRAINING AND QUALIFICATION PROGRAMS
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PEltFOllMANCE RATINGS CATEGOltYI SUPERIOlt PERFORh1ANCE - CONSIDER REDUCED INSPECTION CATEGORY 2 GOOD PERFORMANCE - CONSIDER NORMAL INSPECTION CATEGORY 3 ACCEPTAllLE PERFORMANCE - CONSIDER INCREASED INSPECTION TRENDS IMPitOVING PERFOlG1ANCE IMPROVING DURING ASSESSMENT PERIOD DECLINING PERFORMANCE DECLINING DURING ASSESSMENT PERIOD AND TIIE LICENSEE IIAD NOT TAKEN MEANINGFUL STEPS TO ADDRESS TIIIS PATTERN Verirsorat Yttruker Sistle 6 l
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SALP BOARD CHAIRMAN:
C. HEllL, DIRECTOR, DIVISION OF REACTOR PROJECTS (DRP)
MEMilERS:
W. HODGES, DIRECTOR, DIVISION OF REACTOR SAFETY R. COOPER, DIRECTOR, DIVISION OF RADIATION SAFETY AND SAFEGUARDS W. BUTLER, DIRECTOR, PROJECT DIRECTORATE I-3, OFFICE OF NUCLEAR REACTOR REGULXi' ION (NRR)
P. SEARS, PROJECT MANAGER, NRR J. LINVILLE, CIHEF, REACTOR PROJECTS BRANCII 3, DRP H. EICIIENIIOLz, SENIOR RESIDENT INSPECTOR Venrwn! Yankee Shde 7 l
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PLANT OPERATIONS e
STRONG CONTINUED AIANAGEh1ENT INVOLVEh1ENT
VERY GOOD PROFESSIONALISM
INFREQUENT ERRORS - VERY GOOD PERFORMANCE
SAFE EXCELLENT OIII' AGES
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- SAFE AND PROFESSIONAL CONDUCT OF OUTAGES
EARLIER REQUALIFICATION DEFICIENCIES CORRECTED
GOOD STAFFING LEVELS
WEAK MAINTENANCE OF EOP APPENDICES
VERY GOOD PLANT MATERIAL CONDITION
NOTAllLE INITIATIVES PERFORMANCE RATING CATEGORYl Vennont Yanker Shde X
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RAI)IOLOGICAL CONTROLS
EFFECTIVE RAI)IOLOGICAL ENIIANCEMENT PROGRAM e
SUCCESSFUL SELF-ASSESSMENT AND IMPROVED CONTROLS
IMPROVED STAFFING AND UTILIZATION
VERV GOOD ALARA OUTAGE PERFORMANCE
EFFECTIVE CONTAMINATION CONTROL
SOUND TIIOROUGII EVENT INVESTIGATION
EFFECTIVE PERFORMANCE-IIASED TRAINING
VERV GOOI) QC OF REMP AND CALIllRATION TECIINIQUES
APPROPRIATE TURilINE IlUILDING ROOF MONITORING
SAFE EFFECTIVE RADWASTE IIANDLING
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PERFORMANCE RATING CATEGORY 2, IMPROVING TREND Venowns Yankee Sthie V
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MAINTENANCE / SURVEILLANCE i
HIGil EQUIPAIENT AVAILAllILITY
MANAGEMENT FIELD OllSERVATIONS
GOOD QUALITY CONTROL
STAFFING MET OUTAGE CIIALLENGES
RELIANCE ON WORKER KNOWLEDGE
"OWNERSIIIP"
EFFECTIVE PLANNING AND SCIIEDULING
WELL MANAGED WORK llACKLOG
PREDICTION OF FAILURES NOT FULLY EFFECTIVE
INITIATIVFS UNDERTAKEN
WELL CONTROLLED SURVEILLANCE PROGRAM
CONTINUED STAFF SKILL EXPERIENCE AND TRAINING PERFORhbiNCE RATING CATEGORY l Vernwns Yanker Shde 10
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STRONG MANAGEhlENT SUPPOlG'
SAFETY-CONSCIOUS RESPONSE TO EVENTS
GOOD ADMINISTRATION OF EXERCISE /DRI.LL PROGRAM
PROMPT RESOLUTION OF PRIOR EXERCISE CONCERNS
CIIANGES TO SEPTEMllER 1992 SCENARIO
WELL DEFINED TRAINING USING WALK-TIIRU DRILLS
EXCELLENT STATE AND LOCAL INTERFACE
EFFECTIVE AUDIT PROGRAM
WELL MAINTAINED FACILITIES AND EQUIPMENT
LAPSED EP TRAINING FOR SECURITY MEMBERS PERFORMANCE RATING CATEGORYl-
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RESOURCES PROVIDED FOR PROGRAAI UPGRADES
CONTINGENCY RESPONSE WEAKNESSES
MORE ACTIVE MANAGEMENT OVERSIGIIT
ORGANIZATIONAL CIIANGES LATE IN PERIOD
PROGRAM WEAKNESSES PERSISTED
GOOD INTERFACE WITil OPERATIONS
MARGINAL STAFFING - SUllSTANTIAL OVEItTIME
ANNUAL AUDIT IMPROVED llUT NOT FULLY EFFECTIVE
GENERALLY EFFECTIVE FFD PROGRAM
CONTINUED DIFFICU111'Y IN EVALUATING EVENTS
PROFESSIONAL FORCE DEMEANOR - GOOD MORALE BOARD COMMENT ASSESS PROGRAM WEAKNESSES PERFORMANCE RATING CATEGORY 3 Ven wat nmker Slide 12
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ENGINEERING AND TECIINICAL SUPPORT
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QUICK RESPONSE TO SAFETY CONCERNS
GOOD PROGRAMS TO RESOLVE LONG TERM ISSUES
KNOWLEDGEAllLE STAFF - KEEN TECIINICAL INSIGIITS
CONTINUED STRENGTIIENING OF DESIGN PROCESS
EXCELLENCE IN "TRADl'I?ONAL" ENGINEERING AREAS
INCONSISTENT SAFETY EVALUATIONS
HIGII QUALITY RFSOLUTION OF EQUIPMENT ISSUES
REACTIVE ISSUES SATISFACTORILY CORRECTED
SOME LER ANALYSES NOT COMPREIIENSIVE
EFFECTIVE COMMUNICATION ACROSS ORGANIZATIONS PERFORMANCE RATING CATEGORY 2 Vernuma l'anker Sluir 13
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SAFETY ASSESSMENT / QUALITY VERIFICATION
EMPLOYEE CONCERN PROGRAh! IAIPROVEh1ENTS
SELF-ASSESSMENT PROGRAMS NOT FULLY EFFECTIVE IN IDENTIFYING FUNDAMENTAL PROGRAh! ISSUES
CORRECTIVE ACTION PROCESS IMPROVEMENTS
ONGOING ENIIANCEMENTS TO SAFETY EVALUATIONS
EXCELLENT PORC OVERSIGIIT
EFFECTIVE PLANT PERFORMANCE MONITORING
WEAKNESSES IN LICENSING SUllMI'I'I'ALS
GOOD RESPONSE TO GENERIC ISSUES
DECLINES IN ENGINEERING AND SECURITY
MANAGEMENT INVOLVED IN ALL AREAS PERFORMANCE RATING CATEGORY 2 Vernwns Yankee Shde 14
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PERFORMANCE SUMMARY
PLANT ACTIVITIES CONDUCTED SAFELY
SUPERIOR OPERATIONS AND AIAINTENANCE A'ITR111UTED TO MANAGEh1ENT INVOLVEhlENT
WEAKNESSES CORRECTED IN OPERATOR TRAINING AND EOPS
STRONG Eh1ERGENCY PREPAREDNESS MANAGEMENT SUPPORT - PROMirr RESOLUTION OF DISCREPANCIES
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RADIOLOGICAL IAIPROVEhlENTS - VERY GOOD ALARA
SECURITY WEAKNESSES PERSISTED DESPITE ADDITIONAL A'ITENTION
GOOD QUALITY ENGINEERING SUPPORT
PERFORMANCE DECLINES ATTRIBUTED TO TIIE FAILURE OF SELF-ASSESSMENT PROGRAMS TO EFFECTIVELY IDENTIFY FUNDAMENTAL ISSUES IN MAJOR PROGRAM
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PERFOltMANCE ANALYSIS SUMAIARY FUNCTIONAL AREA PREVIOUS O_UJtRIMI'
l. PLANT OPERATIONS
1 2. RADIOLOGICAL CONTROLS
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I Previous Assessment Period:
i October 1,1989 to March 16,1991 i
Current Assessment Period:
March 17,1991 to August 1,1992 l
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ENCLOSURE 5 NUCLEAlt POWEll COI1POIIATION o
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ENGINEERING OFFICE
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6 08)779-6711 November 18,1992 BW 92129 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
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References:
(a)
Licence No. DPR-28 (Docket No. 50-271)
(b)
Letter, USNRC to WNPC, Initial Systematic Assessment of
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Licensee Performance (SALP) Report No. 50 271/91-99, NW 92-185, dated 10/15/92 (c)
Letter, WNPC to USNRC, BW 92-116, dated 9/25/92
Dear Sir:
Subject: Vermont Yankee Response to the initial SALP Report No. 50 271/91-99 Vermont Yankee appreclated the opportunity to discuss the subject report with representatives of the U.S. Nuclear Regulatory Commission during the public meeting held in Vernon, Vermont on October 29,1992. We believe the Inlllal SALP Report presents a fair appraisal of our performance in most of the functional areas during the period from March 17,1991 through August 1,1992. Included in this response are minor corrections to the Initial SALP Report, new information which was not presented previously and our Ir@rovement initiatives to the concerns noted, in the area of Security we believe that we have made improvements during this report period which have not been given full consideration by your staff and are therefore detailed in this response.
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U.S. Nuclear Regulatory Commission November 18,1992 Page 2 Section Ill.A Plant ~)porations During the report period, Vermont Yankee conducted a routine refueling and maintenance outage. An important self assessment initiative was introduced for this outage to minimize risk to plant safety during the shutdown period. An independent
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review team consisting of qualified engineering professionals and a senior ilconsed Shift Supervisor revle./ed the proposed schedule, maintenance workscope, containment integrity, AC and DC power availability, water inventory and the t dequacy of core cooling from a reactor safety perspective. This safety review was performed prior to the refueling and maintenance outage and resulted in several significant improvements.
The issues mentioned in the report regarding operator training and Emergency Operating Procedures (EOP's) have been thoroughly address 6d. Effective corrective actions and program improvements are being implemented.
Section 111.8 Radiological Controls
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Vermont Yankee is in agreement with the NRC's evaluation that our radlological control program is good, with improving performance in many areas. We have made significant program improvements during the period and will continue our efforts in this area.
Section lil.C Maintenance / Surveillance In September 1991, Vermont Yankee implemented a computer based Maintenance Planning and Control system called MPAC to apply the benefits of computer technology"to our maintenance planning, inventory control, equipment history, purchasing and related administrative processes.
MPAC provides the cornerstone for continuing maintenance program enhancements including reliability centered maintenance, maintenance rule implementation, and equipment performance trending.
We also initiated a System Analysis and Review Program (SARP) to evaluate balance of plant instrumentation maintenance activities and identify the optimum level of future preventative maintenance tasks. SARP focused on improving the overall reliability of plant systems by identifying critical components which could impact system performance and then defining the appropriate preventive maintenance tasks for these components.
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U.S. Nuclear Regulatory Commission November 18,1992 Page 3 The report mentions that occasionally repairs were required after performance of certain components had already degraded, indicating that failure prediction in these instances had not been fully successful. Your report also listed several examples of successful identification of degraded component conditions. We will continue our evaluation of preventive / predictive maintenance activities to become more effective in this area.
Section Ill.D Emergency Preparedness The report states that some coordination problems occurred during the period between emergency planning and other plant departments. Emergency plan training for security personnel was given as an example. An evaluation of this area is being undertaken as documented in Reference (c), and appropriate administrative controls will be implemented to improve inter-department communications as appropriate.
Section Ill.E Security Upon review of the SALP report in the area of Security, we believe there are sevetal additional areas that should be considered as part of your assessment of our performance. In addition, while the events described in the report are generally accurate, there are further details regarding many of the events and issues that should be considered to fully evaluate our perforrnance in this area.
During the prior SALP period, our performance was rated as Category 2, not!.g improved management support and communications with NRC Staff. Weaknesses were identified in the areas of access authorization, documentation of events, and reportability issues. Early in the current SALP assessment period a security event occurred, which after detailed investigation showed that although the root cause was personnel error, several management weaknesses existed that may have contributed to the event.
Based on our investigation, many key areas were identified for improvement.
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U.S. Nuclear Regulatory Commission November 18,1992 Page 4 One of the first areas which we evaluated was our Security Organization. To improve communications and awareness of daily security issues, we reorganized our security force by eliminating the Chlef of Security position. This reorganization allowed direct communication of issues between the security supervisors and the Vermont Yankee Security Manager. In addition, title changes were made to ensure there was no doubt which Vermont Yankee employees were responsible for security.
Daily meetings between the Vermont Yankee Security Supervisor and the Security Operations and Training Supervisors were initiated to ensure clear and timely focus on all issues facing our security organization. Other organizational changes included the establishment of a full time Access Control Coordinator, and a full time Security Technical Assistant. Both of these positions are responsible for key elements of our security program.
Later in the SALP period, we recognized that the changes initiated early in the SALP period had not fully met our objectives for improving program effectiveness and that additional management involvement was prudent for our security organization and a major reorganization was implemented. We established Security as a separate department reporting directly to the Technical Services Superintendent and headed-by a new position of Security Manager. This position now provides dedicated attention to the sole area of Security, where the previous position of Plant Services Supervisor had a divided focus on Security, Document Control, Stores and Inventory, and Administrative Services. The establishment of a separate Security Department now recognizes security as a functional area equivalent to other major functions, such as Operations, Maintenance, and Radiation Protection. The Security Supervisor position
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was restructured as the Security Operations Specialist to provide daily oversight of the security force and provide additional focus and attention to hardware and procedural issues. The position of Secu ity Manager has been filled with a very capable and experienced individual who has extensive military security experience and most recently held a position as a Lead Quality Assurance Auditor for Yankee Atomic Electric Company. h1 that capacity, he has performed audits and assessments of security programs at Vermont Yankee, Yankee Rowe, Maine Yankee, Seabrook, and Calvert Cliffs.
He also has strong motivational and communications skills, and consistently demonstrates a clear understanding of the requirements of an effective Security Program.
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U.S. Nuclear Regulatory Commission November 18,1992
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Page 5 During 1991, we implemented a very significant modification and addition to our access control gatehouse to upgrade our effectiveness in this area. The improved gatehouse includes state of the art design features such as turnstiles, duress alarm and lockdown capabilities, improved access control features, automated site accountability measures, separation of the entrance and exit pathways, and improved visibility and control throughout the building. In addition, the facilitu now provides office and meeting facilities for formal shift turnovers which were imp e Tiented during this SALP period. This project involved a commitment of over one miidon dollars and now is a facility we are very proud to show as the first symbol of Vermont Yankee's
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Security program that is visible as you enter the plant.
Other hardware upgrades, including our CCTV assessment system and alarm stations, were implemented throughout the SALP period.
We have completely replaced all on-site CCTV cameras with state of the art electronic equipment, and made many improvements to address env!ronmental issues including glare shields, camera angle adjustraents, relocation of cameras within the enclosures and a night focus on all cameras. These changes have improved the performance of the system such that the need for compensatory measures has been greatly reduced. We have also initiated a complete system upgrade that provides additional camera coverage and improved resolution. Additionally, we have purchased a video capture system, video sequencer and automatic alarm display system that will be in use by the end of 1992.
In conjunction with the establishment of a full time Access Control Coordinator position, we have fully implemented an access control program that complies with all NRC requirements and the NUMARC guidelines. Prior to allowing any organization to perform background investigations, we verify by audits and sampling of completed background investigation reports that the contracted organization fully understands our program and our expectations. Our staff has been diligent in follow-up verification of all access info' cation, even though the information is only accepted from a limited number of previously approved vendors. Although a complete five year background investigation is cond J 90 iir allindividuals, subsequent information received from the Criminal History Ch.M w elmes reveals details that were not previously obtained.
Upon receipt of any aderse itiformation, we take immediate, conservative action to suspend the access for those individuals until a comprehensive assessment of the background information can be completed. Although our access authorization
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U.S. Nuclear Regulatory Commission November 18,1992 Page 6 program is very detailed and thorough, it must depend to some extent on information supplied by individuals. It is our practice at Vermont Yankee to rescind access authorization if adverse information is discovered via the Criminal History Check that was not provided by the individual, as we believe this is a key indicator of an individual's trustworthiness.
We believe this is a program strength, and not a programmatic weakness as was indicated in the report.
The SALP report notes that during the annual audl+
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As we discussed during our meetinc on October 29,1992, one of the licensee identified findings involved a design detali of the upgrade to Gatehouse 2 which we fully believed had NRC concurrence based on several meetings held with NRC before construction was started on the Gatehouse. In addition, prior to opening the modified gatehouse, a tour. of the facility was provided by the Technical Services Superintendent to the on-site resident NRC inspectors where all design features were explained. We were nct aware of any concern with our approach until we submitted a change to our Security Plan that was not accepted by the NRC. The other licensee identified finding involved an issue which the NRC upon further review agreed was not a problem. In both cases, our response represented a careful consideration of the inding, and the responses were consistent with our understanding of the requirements ci an effective Security Program.
Although staffing of the contract security force was increaseo during the S/. A
period, the report incorrectly states that two over-hire positions were subsequently k a through attrition. Our staffing levels did not affect the overtime required during our most recent refueling outage. The regrt incorrectly concludes that the overtime was exacerbated during the Ntage by not hung additional personnel. We have always staffed the outage with two twelve hour shha. Any additional personnel hired for the outage would have worked this same schedule, it is our experience that twelve hour shifts with scheduled days off during a six week refueling outage do not lessen our security effectiveness. We remain sensitive to performance issues, and ensure through oversight, behavior observation, and employee feedback that all individuals remain fully fit for duty throughout the outage. We agree with the Initial
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U.S. Nuclear Regulatory Commission November 18,1992 Page 7
SALP Report's assessment that the security organization continued to exhibit a professional demeanor and good morale throughout the outage, and there were no performance related issues during the outage period. Our assessment of overtime following the outage has shown that current staffing practices have resulted in a reduction in non-outage overtime in 1992 by greater than 25% compared to a similar period in 1991.
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We agree that early in the SALP period, following the security event which j
resulted in four violations, we did not fully assess the significance of the event, and reached an incorrect conclusion regarding reportability. As described in our response
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to the violations, we have taken significant steps to improve our sensitivity in this i
regard. Although our past practice tended to fully verify a situation before reporting, we have taken steps to ensure that involved personnel will conservatively assume that
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a vulnerability exists and repod it as such if there is any identified potential for a reportable condition. Correctivo actions included additional training and counseling of Vermont Yankee managers and security force supervision, clear written
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requirements in job descriptions, and a revision to our reporting procedure and related
training to emphasize this expectation.
The discovery of inappropriate reading material at duty stations was a concern shared by both NRC and VY. Vermont Yankee agrees that inappropriate reading material is unacceptabb at security posts, and we took immediate steps by providing a clear written policy that such material was prohibited and to emphasize the necessity for security officers to remain attentive to their assigned duties. Ongoing oversight in
this area has shown a clear understanding of our position and uniform implementation of this policy.
j in the SALP report, the NRC noted that following an event where Safeguards
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information was not properly protected, we did not implement corrective action. While we have not been abh3 to determine why your staff was not aware of our corrective actions, we have verified that appropriate corrective actions were implemented. These actions included counseling of individuals, as well as retraining for all involved departments, it should be noted that this event occurred during the upgrade of Gatehouse 2, where literally hundreds of safeguards documents were in continuous use. Our Security personnel routinely checked the implementation of appropriate controls due to the size of this project. Upon self-identification of this event, prompt reporting and corrective actions were implemented.
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U.S. Nuclear Regulatory Commission November 18,1992 Page 8 As a result of our preparation for, and the OSRE evaluation conducted in October 1991, we have made significant improvements in our response capabilities. Prior to the OSRE evaluation, we hired an independent consultant to evaluate our capabilities, and assist us in documenting our response strategies. In addition, we identified several areas for improvement which were provided to the NRC upon their arrival for the evaluation. These improvements extend well beyond contingency response and weapons deployment to cover areas involving tactical training, physical plant modifications, and command and control issues. We have upgraded our strategies and completed extensive training to ensure our response capabilities will fully meet the challenges of a similar evaluation.
In addition to contingency response training, we have improved our overall security training program. Our current practices include mini-drill scenarios that are conducted on shift to challenge individuals as well as the entire shift complement.
These scenanos involve many of the contingencies which are included in the Security Plan as well as issues such as access control, vehicle search practices, and reportability determinations where hypothetical situations or controlled drills are presented to assess the security response capabilities. These mini-drills have proven to be an excellent method for individual Shift Supervisors, training personnel and Vermont Yankee security management to assess the performance of personnel, and allow for trending and analysis of the general performance of the entire security force.
We are currently expanding the scope of the training program to include on-shift assessment of our OSRE type response capabilities. In addition to this on-shift training, formal shift turnovers, an expanded employee concerns program, and creation of a " pass-on book" have significantly improved our communications, assessment, and training capabilities.
At our meeting on October 29, NRC requested additional details regarding an intrusion detection system problem.
The details of this issue are Safeguards information, and therefore, this information will be submitted to you in a separate letter.
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U.S. Nuclear Regulatory Commission November 18,1992 Page 9 Throughout the SALP period, Vermont Yankee continued to provide management attention to the security program through routine status reviews.
Additionally, meetings were held with NRC staff on July 2, August 27, and December 16,1991; March 3, and May 22, 1992. During these meetings Vermont Yankee focused on ensuring that NRC staff were fully cognizant of our plans and progress on all security issues. Based on this level of attention and communication, we fully believed that we were providing the proper level of resources and attention to the security program. We were, without question, very disappointed by the SALP report which cited a decline in performance and leaves knowledgeable readers with the impression that we have one of the worst security programs in the country. We do not believe that to be the case.
We embrace the Board recommendation to conduct a comprehensive and
' independent assessment of our security program. We anticipate that this assessment will be completed during the first quarter of 1993 and will be prepared to discuss the results with you as you have requested.
Section Ill.F Engineering and Technical Support Several improvements implemented during this report period were not recognized in the report. These include replacement of all four drywell coolers, replacement of the main station transformer, installation of a hardened containment vent, installation of improved instrument air dryers, replacement of several station service transformers, numerous seismic equipment upgrades, improved reactor feedwater nozzle ultrasonic inspection methods, and use of a cold critical configuration predictor called SHUFFLEWORKS, to monitor shutdown margin during fuel movement.
What was evaluated as a weak engineering review which involved the redirection of the service water flow path affecting emergency diesel generator operation, actually occurred in 1987, prior to this report period, and is not indicative of engineering reviews performed during this period.
As a result of earlier inconsistencies in the way we performed engineering reviews, and senior management recommendations, Vermont Yankee has developed and presented formal training courses focused on 10CFR 50.59,50.71,50.34 (Part b) and the FSAR. We believe that this program has substantially improved the quality of our engineering reviews.
Evaluations which reflect the current quality of engineering reviews include the tie in for the new supplemental fuel pool cooling system and the enhancement of the reactor building closed cooling water heat exchanger drain capacity.
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. c U.S. Nuclear Regulatory Commission November 18,1992 Page 10 Our analysis of the inaccurate MOV response (i.e. wrong bypass settings for torque switches) determined the root cause to be personnel error by the engineer researching Generic Letter 89-10, not the lack of a coordinated MOV program policy.
Further, the assignment of a senior engineer to this project was the result of our internal self assessment of the program conducted prior to the NRC inspection. This assessment was a comprehensive review of the entire MOV program and included a number of independent engineering consultants and industry MOV experts. Also, there was no safety impact as a result of the discovered error (the physical bypass switch settings were correct in the field; the submittat was incorrect) and the information was promptly ccrrected once discovered.
The primary containment isolation system actuation due to a failed CR120 relay was a random failure of a component which had never been assigned a service life by the vendor and had not demonstrated a physical limitation of service life. As a result of this failure, Vermont Yankee assigned a service life and has implemented a plan for replacement.
Section 111 G.
Safety Assessment /Ouality Verification Several self assessment initiatives were successfully conducted during this report period including MOV program implementation, radiological enhancement program, balance of plant instrumentation, design change process review, reactor vessel level instrumentation, refuel outage safety review, housekeeping inspection program, environmental compliance review program, industrial safety program, emergency preparedness, improved engineering reviews and equipment upgrades.
There are many more on-going self-assessment initiatives among the various plant departments. Given the goal of self assessment as "do the job right the first time",
problem prevention becomes a key element in any successful program. Renewed emphasis in self-assessment at Vermont Yankee is sure to have a positive impact on future performance.
We have reviewed our more traditional self-assessment activities such as audits /surveillances and believe we have a balanced approach between a performance based and a programmatic based emphasis. The Quality Assurance department has recently reorganized, placing the Audit and QA Surveillance Groups under the same manager. This has already brought about more of a team oriented approach to verification activities at Vermont Yankee. Additionally, weaknesses discussed in the SALP will be evaluated for corrective actions as a part of the audit process. The reorganization, along with a more active and aggressive evaluation of proposed currective ections proposed by the plant will make this program even more effective.
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U.S. Nuclear Regulatory Commission November 18,1992 Page 11 g.
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_ The report states that a response to a Nuclear Regulatory Commission request
l for additional information relative to a submittal on Station Blackout was not timely in i
that it took approximately five months. In regard to this issue, the NRC did not provide j
any date by which a response was expected. The additional information requested j
involved the Vernon Hydro Station, which is owned by the New England Power j
Company. An analysis was performed by them, and the results were reviewed and
factored into Vermont _ Yankee's response' to the NRC's request for-- additional i
information.
Given these factors, we do not feel that the response time was
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unreasonable. The NRC was kept verballyinformed of our submittal schedule and our
progress throughout.
Vermont Yankee has an excellent record of providing timely responses to licensing l
Issues. During this SALP period a total of 125 Licensing Action items (LAl's) were j'
tracked and a total of 65 of these involved a required submittal to the NRC. The following is a summary of our survey of these 65 submittals:
j Number of submittals made early (before required due date).... 34
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Number of submittals made o_n time (by required due date)..... 30
Number of submittals made late (after required due date)...........1 The one late submittal involved a response to an NRC inspection report which was submitted one day beyond the requested 30 days.
Summary
. In summary, Vermont Yankee made significant improvements during the SALP period from March 17,1991 through August 1,1992, and many more are underway in the current SALP period. We assure.you that Vermont Yankee has and will continue to strive for superior performance in all SALP functional areas.
In the area of Security,we ask that you recognize our commitment of significant resources to enhance the Security Program at Vermont Yankee, and that our Security Program has improved over the previous SALP report period.
Significant improvements have been and continue'to be made including upgrades to our perimeter detection and assessment systems and our access control center.
Modificatioq of our Access Control Center has produced a very effective control point which has improved our ability to control access to the plant site, in consideration of -
the informhtion provided in this response letter, we respectfully request that you reconsider our performance rating in the functional area of Security.
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U.S. Nuclear Regulatory Commission November 18,1992 Page 12 In the event you may have questions or desire any additional information, please do not hesitate to contact us.
Very truly yours, Vermont Yankee Nuclear Power Corporation
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W Warren P. ht rphy Senior Vice President, Operations cc:
USNRC Region i Administrator USNRC Resident inspector - VYNPC USNRC Project Manager
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r ENCLOSURE 6 ASSESSMENT OF ADDITIONAL SECURITY INFORMATION PROVIDED BY VERMONT YANKEE 1.
LICENSEE: "During the prior SALP period, our performance was rated as Category 2,-
noting improved management support and communications with NRC Staff. Weaknesses were identified in the area of access authorization, documentation of events, and reportability issues. Early in the current SALP assessment period a security event occurred, which after detailed investigation showed that although the root cause was personnel error, several management weaknesses existed that may have contributed to the -
event. Based on our investigation, many key areas were identified for improvement."
NRC:
As correctly stated, a significant security event occurred on May 12, 1991, after the close of the previous SALP period. This event was not considered by the SALP Board for the previous SALP period. Therefore, this event and associated issues did not adversely impact the previous category rating. Had it been factored in, the rating might well have been different.
2.
LICENSEE: "One of the first areas which we evaluated was our Security Organization.
To improve communications and awareness of daily security issues, we reorganized our security force by eliminating the Chief of Security position. This reorganization allowed direct communication of issues between the security supervisors and the Vermont Yankee Security Manager. In addition, title changes were made to ensure there was no doubt which Vermont Yankee employees were responsible for security.
Daily meetings between the Vermont Yankee Security Supervisor and the Security Operations and Training Supervisors were initiated to ensure clear and timely focus on all issues facing our security organization.
Other organizational changes included the establishment of a full time Access Control Coordinator, and a full time Security Technical Assistant.
Both of these positions are responsible for key elements of our security program."
NRC:
Eliminating the security chief position did not prove successful.
Programmatic problems still persisted (refer to the fourth paragraph of the Security section of the SALP report), resulting in the licensee creating a position as Security _ Manager late in the period.
The Access Control Coordinator position was created in early 1988, not during this SALP period. A Security Technical Assistant position was created and filled on June 11, 1991, following May 1991 event. The position was made full-time and filled by the individual who had served i
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Enclosure 6
as the Access Control Coordinator, but he vacated-the position in May 1992, and the position remained vacant for the rest of the SALP period. It was recently filled by an individual without a nuclear power plant security background. The NRC agrees that the Access Control Coordinator position is a key element of the security program, but, since it was redefined and vacated in June 1991, it has been filled twice by individuals with clerical backgrounds and no prior nuclear power plant security experience.
3.
LICENSEE: "Later in the SALP period, we recognized that the changes initiated early in the SALP period had not fully met our objectives for improving program effectiveness and that additional management involvement was prudent for our security organization and a major reorganization was implemented. We established Security as a separate department reporting directly to the Technical Services Superintendent and headed by a new position of Security Manager. This position now provides dedicated attention to the sole area of Security, where the previous position of Plant Services Supervisor had a divided focus on Security, Document Control, Stores and Inventory, and Administrative Services. The establishment of a separate Security Department now recognizes security as a functional area equivalent to other major functions, such as Operations, Mai tenance, n
and Radiation Protection.
The Security Supervisor position was restructured as the Security Operations Specialist to provide daily oversight of the security force and provide additional focus and attention to hardware and procedural issues. The position of Security Manager has been filled with a very capable and experienced individual who has extensive military security experience and most recently held a position as a Lead Quality Assurance Auditor for Yankee Atomic Electric Company.
In that capacity, he has performed audits and assessments of security 1-programs at Vermont Yankee, Yankee Rowe, Maine Yankee, Seabrook, and Calvert Cliffs. He also has strong motivational and communications
skills, and consistently demonstrates a clear understanding of the requirements of an effective Security Program."
HRQ The latest organizational change is a good initiat;ve to focus more management attention on the program. The security manager position was
filled on June 22, 1992. The SALP period ended on August 1,1992.
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Therefore, the effectiveness of the Security Manager could not be assessed during the SALP period.
4.
LICENSEEl "During 1991, we implemented a very significant modification and addition to our access control gatehouse to upgrade our effectiveness in
this area. The improved gatehouse includes state-of-the-art design features such as turnstiles, duress alarm and lockdown capabilities, improved i
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Enclosure 6
access control features, automated site accountability measures, separation of the entrance and exit pathways, and improved visibility and control throughout the building. In addition, the facility now provides office and meeting facilities for formal shift turnovers which were implemented
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during this SALP period. This project involved a commitment of over one million dollars and now is a facility we are proud to show as the first symbol of Vermont Yankee's Security program that is visible when you enter the plant."
NRC:
The modified gatehouse is a definite improvement over what existed previously, and the SALP report credits the' licensee for that accomplishment. The modified gatehouse design was flawed in two major
respects: (1) a vulnerability existed in personnel search equipment that l
could have allowed circumvention, and (2) the last person controlling
access to the protected area was not located within a bullet-resistant
structure. Both flaws required subsequent modification and reflected an
incomplete understanding of regulatory requirements, i
5.
LICENSEE: "Other hardware upgrades, including our CCTV assessment system and j
alarm stations, were implemented throughout the SALP period. We have completely replaced all on-site CCTV cameras with state-of-the-art
electronic equipment, and made many improvements to - address
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environmental issues, including glare shields, camera angle adjustments, relocation of cameras within the enclosures and a night focus on all cameras. These changes have improved the performance of the system
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such that the need for compensatory measures has been greatly reduced.
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We have also initiated a complete system upgrade that provides additional camera coverage and improved resolution.
Additionally, we have
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purchased a video capture system, video sequencer and automatic alarm display system that will be in use by the end of 1992."
l NRC:
The licensee was given credit in the SALP report for the hardware l
upgrades that were made during the SALP period, including the assessment system upgrades. The need for assessment system upgrades
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was identified during the RER in 1985 and will not be completed until the
end of 1992.
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LICENSEE: "In conjunction with the establishment of_ a full time Access Control Coordinator position,.we have fully implemented an access control program that complies with all NRC requirements and the NUMARC
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guidelines. Prior to allowing any organization to perform background investigations, we verify by audits and sampling of completed background investigation reports that the contracted organization fully understands our
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program and our expectations. Our staff has been diligent in follow-up
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Enclosure 6
verification of all access information, even though the information is only accepted from a limited number of previously approved vendors.
Although a complete five year background investigation is conducted for all individuals, subsequent information received from the Criminal History Check sometimes reveals details that were not previously obtained. Upon receipt of any adverse information, we take immediate, conservative action to suspend the access for those individuals until a comprehensive assessment of the background information can be completed. Although our access authorization program is very detailed and thorough, it must depend to some extent on information supplied by individuals. It is our practice at Vermont Yankee to rescind access authorization if adverse information is discovered via the Criminal History Check that was not provided by the individual, as we believe this is a key indicator of an individual's trustworthiness. We believe this is a program strength, and not a programmatic weakness as was indicated in the report."
NRC:
The licensee established the Access Control Coordinator position in 1988, as indicated earlier. On March 16, 1992, the licensee implemented an access control program to comply with NRC requirements, as stipulated in 10 CFR 73.56 (personnel access authorization requirements for nuclear power plants). All licensed power reactors were required to comply with 10 CFR 73.56, referred to as the Access Authorization Rule, by April 27,1992. The licensee's new access control program has not yet been assessed by NRC.
The licensee has had a history of access authorization problems in this and prior SALP periods.
Such an event that was reported to the NRC occurred on August 5,1991. The event surfaced when the licensee received unfavorable results from criminal history checks for two individuals who had been granted unescorted access to the station. The derogatory information should have surfaced through the background investigations (BI) performed by the contract company. The NRC has long discouraged the licensees accepting bis at face value. As a result the
licensee reviewed 30 additional bis for employees of the contractor in question. The review resulted in finding seven other individuals who did not have satisfactorily completed bis. It was after this seven that the licensee began to verify by audits and sampling of completed Bis that contracted organizations fully understood its access authorization requirements.
The licensee's compliance with the NRC's access authorization rule should preclude previous programmatic problems in this area.
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Enclosure 6
7.
LICENSEE: "The SALP report notes that during the annual audit process, two licensee-identified findings were categorized as potential regulatory issues, but were not considered significant and not properly pursued. We believe this characterization is very inaccurate. All audit findings at Vermont Yankee are considered significant, carefully evaluated, and a written response must be accepted by the Plant Manager and the Senior Vice President, Operations, as well as an independent assessment of the adequacy of our response by our Quality Assurance staff."
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NRC:
In retrospect, the characterization "not considered significant," and "not properly pursued" were inappropriate. These phrases were removed from the SALP Report.
8.
LICENSEE:
As we discussed during our meeting on October 29,1992, one of the licensee-identified findings involved a design detail of the upgrade to Gatehouse 2 which we fully believed had NRC concurrence based on several meetings held with NRC before construction was started on the Gatehouse. In addition, prior to opening the modified gatehouse, a tour of the facility was provided by the Technical Services Superintendent to the on-site resident NRC inspectors where all design features were explained. We were not aware of any concern with o tr approach until we submitted a change to our Security Plan that was not accepted by the NRC. The other licensee-identified finding involved an issue which the NRC upon further review agreed was not a problem. In both cases, our response represented a careful consideration of the finding, and the responses were consistent with our understanding of the requirements of i
an effective Security Program."
l NRC:
There was only one "recent" meeting, in 1990, during which we can recall the gatehouse being discussed.
During that meeting, NRC personnel recall discussing the "last-person-controlling-access" issue with the licensee and questioning the new design regarding that feature. That
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feature of the new design was found flawed after the gatehouse was l
constructed and the licensee was made aware of that by the facility l
security inspector on February 24,1992, the first day of inspection 50-l 271/92-05, which was the first opportunity for the inspector to inspect the i
modified gatehouse.
At that time, the licensee indicated that it had l
implemented another method of controlling access to the protected area in l
lieu of assigning someone to the bullet-resistant structure. The licensee
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insisted to the inspector that the NRC, in several meetings, was made aware of the deviation and had approved it.- Despite the potential for misunderstanding from a meeting with the NRC, a clear understanding of the regulations is essential to an effective security program. It is clear in 10 CFR 73.55(d)(1) on where the last person controlling access to the
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l protected area must be located. Even though the licensee provided a tour l
for the NRC resident inspectors during which they explained all the design
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features of the gatehouse, resident inspectors are not security specialists,
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Enclosure 6
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did not review this design change and cannot be relied upon for acceptability of this deviation. The deviation was not " approved" by the
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NRC because it was not addressed anywhere in the security plan, which
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would have been necessary for NRC approval,
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The single barrier issue was reviewed by the NRC, after it surfaced as a licensee-audit finding during an NRC inspection in May 1992. It was determined to be acceptable on the basis that armed security officers permanently located in the area of deviation provide satisfactory compeasation. This exception to the double barrier criterion for vital areas is also not discussed in the licensee's NRC-approved physical
i security plan.
9.
LICENSEE: "Although staffing of the contract security force was increased during the
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SALP period, the report incorrectly states that two over-hire positions were subsequently lost through attrition. Our staffing levels did not affect the overtime required during our most recent refueling outage. The report incorrectly concludes that the overtime was exacerbated during the outage
by not hiring additional personnel. We have always staffed the outage with two twelve hour shifts. Any additional personnel hired for the
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outage would have worked this same schedule. It is our experience that twelve hour shifts with scheduled days off during a six week refueling
outage do not lessen our security effectiveness. We remain sensitive to l
performance issues, and ensure thorough oversight, behavior observation, and employee feedback that all individuals.emain fully fit for duty throughout the outage.
We agree with the initial SALP Report's assessment that the security organization continued to exhibit a professional demeanor and good morale throughout the outage, and there i
were no performance related issues during the outage period.
Our
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assessment of overtime following the outage has shown that current
staffing practices have resulted in a reduction in non-outage overtime in 1992 by greater than 25% compared to a similar period in 1991."
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NRC:
The SALP report statement "that two positions... were subsequently lost through attrition" is incorrect and has been deleted. The licensee contends that additional security personnel would not have reduced the amount of overtime. However, the NRC continues to believe that limited staffing exacerbates the overtime issue and challenges the performance of security l
force members.
10.
LICENSEE: "We agree that early in the SALP period, following the security event which resulted in four violations, we did not fully assess the significance of the event, and reached an incorrect conclusion regarding reportability.
As described in our response to the violations, we have taken significant steps to improve our sensitivity in this regard. Although our past practice tended to fully verify a situation before reporting, we have taken steps to ensure that involved personnel will :onservatively assume that a
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Enclosure 6
vulnerability exists and report it as such if there is any identified potential for a reportable condition. Corrective actions included additional training and counseling of Vermont Yankee managers and security force supervision, clear written requirements in job descriptions, and a revision to our reporting procedure and related training to emphasize this expectation."
NRC:
The licensee's stated corrective actions for this event had not been completed as of November 6,1992.
The SALP period ended August 1,1992. Therefore, the NRC has not been able to assess fully the corrective actions.
11.
LICENSEfa "The discovery of inappropriate reading material at duty stations was a concern shared by both NRC and Vermont Yankee. Vermont Yankee agrees that inappropriate reading material is unacceptable at security posts, and we took immediate steps by providing a clear written policy that such material was prohibited and to emphasize the necessity for security officers to remain attentive to their assigned duties. Ongoing oversight in this area has shown a clear understanding of our position and uniform implementation of this policy."
NRC:
The fact remains that inappropriate reading materials were found by the NRC in both the central alarm station (CAS) and secondary alarm station (SAS), two very important security posts. The licensee did not have a clear policy to prohibit such materials from security posts. However, the contractor did have such a policy, but it was apparently not being enforced by the licensee or the contractor. Improved oversight of the security force was the result of this event.
12.
LICENSEE: "In the SALP report, the NRC noted that following an event where Safeguards Information was not properly protected, we did not implement corrective actions. While we have not been able to determine why your staff was not aware of our corrective actions, we have verified that appropriate corrective actions were implemented. These actions included counseling of individuals, as well_ as retraining for all involved departments. It'should be noted that this event occurred during the upgrade of Gatehouse 2, where literally hundreds of safeguards documents were in continuous use. Our Security personnel routinely checked the implementation of appropriate controls due to the size of this project.
Upon self-identification of this event, prompt reporting and corrective actions were implemented."
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Enclosure 6
NRC:
There were eight separate loggable events that occurred at various times during the period that involved poor or inadequate control of Safeguards Information. The causes of some of the events were closely related; consequently proper tracking, trending and comprehensive corrective actions by the licensee could have reduced the number of events. The event discussed by the licensee was a 1-hour reportable event and was appropriately addressed by the licensee.
13.
LICENSEE: "As a result of our preparation for, and the OSRE evaluation conducted in October 1991, we have made significant improvements in our response capabilities. Prior to the OSRE evaluation, we hired an independent consultant to evaluate our capabilities, and assist us in documenting our response strategies.
In addition, we identified several areas for improvement which were provided to the NRC upon their arrival for weapons deployment to cover areas involving tactical training, physical plant modifications, and command and control issues. We have upgraded our strategies and completed extensive training to ensure our response capabilities will fully meet the challenges of a similar evaluation."
NRC:
The OSRE raised questions concerning the licensce's defense tactics for the station. The licensee has made some improvements in this area, but has not been very aggressive in that force-on-force drills were not conducted until September 1992, almost one year after the OSRE evaluation. See Attachment A from recent inspection report no. 50-271/92-23 (November 6,1992).
14.
LICENSEE: "In addition to contingency response training, we have improved our overall security training program. Our curreat practices include mini-drill scenarios that are conducted on shift to challenge individuals as well as the entire shift complement.
These scenarios involve many of.the contingencies which are included in the Security Plan as well as issues such as access control, vehicle search practices, and reportability determinations where hypothetical situations or controlled drills are presented to assess the security response capabilities. These mini-drills have proven to be an excellent method for individual Shift Supervisors, training personnel and Vermont Yankee security management to assess the performance of personnel, and allow for trending and analyses of the
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general performance of the entire security force.
We are currently expanding the scope of the training program to include on-shift assessment of our OSRE type response capabilities.- In addition to this on-shift training, formal shift turnovers, an expanded employee concerns program, and creation of a " pass-on book" have significantly improved our communications, assessment and training capabilities."
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NRC:
The licensee was credited with making improvements in these areas.
However, the comprehensiveness and effectiveness of the licensee's approach, as implemented, has not been fully assessed.
15.
LICENSEE: "At our October 29,1992 SALP Management Meeting, NRC requested additional details regarding an intrusion detection system problem. The details of this issue are Safeguards Information, and therefore, this information will be submitted to you in a separate letter."
NRC:
The information provided by the licensee was basically the same as in the LER submitted to the NRC following the event. It did not convey a different perspective.
This event had little bearing on the SALP assessment; however, the licensee's actions following identification of the event demonstrated a lack of aggressiveness in verifying a potential vulnerability within its security system. The licensee relied on a vendor to verify the vulnerability, nearly 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after it was first identified.
The licensee had the capability to verify the vulnerability immediately.
16.
LICENSEE: "Throughout the SALP period, Vermont Yankee continued to provide management attention to the security program _ through routine status reviews. Additionally, meetings were held with NRC staff on July 2, August 27, and December 16,1991; March 3, and May 22, 1992.
During these meetings Vermont Yankee focused on ensuring that NRC staff were fully cognizant of our plans and progress on all security issues.
Based on this level of attention and communication, we fully believed that we were providing the proper level of resources and attention to the security program. We were, without question, very disappointed by the SALP report which cited a decline in performance and leaves knowledgeable readers with the impression that we have one of the worst i
secunty programs in the country. We do not believe that to be the case."
l NRC:
Throughout the period, the licensee was made aware of these performance
issues, but the licensee did not appear to comprehend the severity of the events or the N'RC's concern. Because of the nature of the events and the OSRE findings regarding the performance issues, the number of meetings l
with the NRC would not be unusual. However, the meetings need to bc l
put in perspective:
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The meeting on July 2,1991, was an enforcement conference, l-l (2)
The meeting on August 27,1991, was a forww-up to the enforcement conference during whbh the licensee provided its planned corrective actions.
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Enclosure 6
i (3)
The meeting on December 16,1991 was to discuss overall licensee
performance in operating the plant. There was only a brief formal presentation on Security.
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(4)
On March 3,1992, two licensee representatives met with the
NRC-Region I Division Director and Branch Chief responsible for j
security while they were in Region I for a scheduled meeting with
the NRC to discuss deficiencies in licensed operator training.
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(5)
The meeting on May 22, 1992, was prompted by the NRC to
i discuss previously identified performance issues.
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LICENSEE: "We embrace the Board recommendation to conduct a comprehensive and independent assessment of our security program. We anticipate that this
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assessment will be completed during the first quarter of 1993 and will be prepared to discuss the results with you as you have requested."
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NRC:
The response is appreciated and the NRC stafflooks forward to discussing the results of the independent assessment with the licensee.
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l A'ITACilMENT A TO ENCLOSURE 6
I 6.0 Security Training i
l During this inspection, the inspector met with licensee and contractor security personnel to discuss and review security training activities that had been initiated since the
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Operations Safeguards Response Evaluation (OSRE) that was conducted at the station in
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October 1991. Licensee post-OSRE activities included, but were not limited to, weapons l
upgrade and associated training, and tactical training. The inspector's findings in those areas follow:
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6.1.1 Weapons Unerade and Trainine a
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The inspector verified, through a review of training documentation, that all armed j
security personnel had been trained and certified before being equipped with..e
upgraded weapons in June 1992.
The inspector also' observed - r
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l familiarization training for the shotgun and handgun. No deficiencies w.
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identified.
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6.2 Tactical Traintne
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Based on documentation provided by and discussions with the licensee, the.
i licensee's actions to address tactical training initiatives since the OSRE were as
follows:
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6.2.1 Adversary and resoonse force tactical training; On February 20,1992,
the licensee's on-site security contractor. conducted this training for 11 security officers who volunteered to serve 'as adversaries during
contingency drills involving armed intruders.
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6.2.2 Adversary instructor trainine course: On April 21-23,1992, the license j
sent three contractor security personnel to another nuclear station for this j
training. The training was provided by an independent contractor, a
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6.2.3 Training the trainer - tactical resnonse procedures course: On June 29-j 30,1992, the licensee again sent three contractor security personnel (one j
of whom attended the previous adversary instructor training) to another j
nuclear station for training. This course consisted of(1) understanding the
role of the response. force in a physical protection system,-
(2) fundamentals of tactical response requirements, (3) use of table-top
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' drills to evaluate response procedures and deployment strategies, and I
(4) use of limited scope exercises to understand inherent difficulties and l
potential problems associated with contingency responses. The training-l~
was conducted by an independent contractor.
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Attachment A to Enclosure 6
6.2.4 Iactical training: During August 1992, the licensee's security contractor conducted this training for the entire security force.
The training consisted of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of classroom training, 3-4 hours of table-top
exercises, and limited scope drills. These drills consisted of walking through a field test of the armed responders' matrix, but did not include the use of firearms or engagement in real-time tactical maneuvers.
i 6.2.5 Force-on-force drills: On September 28-30,1992, the licensee used a consultant to evaluate the security force's performance during force-on-
force drills. About 60 percent of the force actively participated in 12
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drills, each with a different scenario. Another 25 percent were observers y
from the on-duty shift or escorts for adversary players. Fifteen percent l
of the force were not involved in any drills, as players or observers.
Since the force-on-force drills in late September, no tactical drills had been conoucted, nor had the licensee formulated a schedule or methodologv for
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conducting tactical drills. When this was questioned by the inspector, the licensee i
committed to reevaluate its approach to and frequency of tactical drills and to
provide the NRC with a drilling schedule within a short period following this inspection.
This matter is considered an inspection followup item (IFI 50-271/92-23-01) and will be reviewed during a subsequent inspection.
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O ENCLOSURE 7 SALP BOARD REPORT REVISION SHEET PAGE LINE DID READ NOW READS
25/26 did not identify did not identify or cause effective programmatic weaknesses corrective action for several and potential regulatory programmatic weaknesses.
issues were not properly addressed.
Basis: To be consistent with changes made to the Security functional evaluation (pages 15,16)
wherein improvement in VY's audit program is recognized, although that same program failed to identify programmatic issues that were in turn identified by the NRC.
8 modified; modified and enlarged; Basis; To provide additional information.
15/16 plant management's because of plant management's coordination and oversight coordination and oversight, resulted in minimum impact modifications to the main access on station activities both, control center and its return to during modifications to the service resulted in minimum impact main access control center on station activities.
and after it was returned to service.
Basis: Revised to clarify management's role in minimizing impact on station activities.
17/18 organization, the Chief organization and improve communications between the contract security force and the licensee, the Chief Basis Provided amplifying information.
26 equivalent to with equivalent to managers managers Basis: Original statement was a typographical error and deleted.
28 an auditor a lead auditor Basis: Provided additional information.
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e Enclosure 7
PAOF, LLNE DID READ blow READS
29 of these changes of this last personnel change Basis: Clarify which change had not been evaluated during this SALP,
1 implement proper implement compensatory measures compensatory measures for promptly for an an Basis: Revised for clarification.
6 resolving these resolving several of these Basis: Added to clarify statement.
1I staffing was marginal, as staffing level was marginal, as evidenced by the persistent evidenced by the continued reliance reliance on overtime on overtime Basis: Word change to improve sentence.
15 Two licensee over-hire Four additional positions were positions were created and created and filled during the period filled during the period to to alleviate the staffing problem.
alleviate the routine staffing problem, but these were subsequently lost through attrition, Basis: Original statement in error, corrected.
17 overtime, members overtime, particularly during the outage, members
!! asis: To emphasize peak period of overtime.
18/19
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Sentence added: Additionally, they performed their duties with a low rate of personnel errors.
Basis: Added to describe general performance of security force.
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Enclosure 7
PAGE IINE DID READ NOW READS
19-24
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Paragraph rewritten.
Basis: Substantial rewrite of paragraph to recognize improvement in VY's audit program, but also to show that the program failed to identify programmatic issues identified by the NRC.
25 Except for a failure to The licensee maintained a generally administer a complete effective Fitness-For-Duty (FFD)
fitness-for-duty (FFD) test program except for a failure in one to two individuals, the event to administer a complete licensee maintained a for-cause FFD test to two generally effective FFD individuals, program.
Basis: Sentence reworded for better focus on the program vice one event.
35/36 but corrective action was but effective corrective action was not initiated in several not apparent in several cases cases involving involving Basis: Additional information that was not known to the NRC for the initial SALP report.
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The licensee's corrective actions, for the most part...
Basis: Additional statements to clarify our assessment of the nature of corrective actions.
1 analyzing loggable events analyzing and correcting loggable events Basis: To correct an editorial oversight in the initial SALP report.
11/12
...and potential regulatory Phrase deleted, issues that were...
Basis: To be consistent with change to page 15, line 19-24
15/16
- and, (d) the review Delete example.
involving the redirection...
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B_a.sjs:
Although this example was identified in this SALP period, the inadequate safety evaluation occurred in 1987.
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Enclosure 7
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PAGE LINE DID READ NOW BEADS
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20/21 The lack of a coordinated Sentence deleted.
l MOV program policy...
flasis The NRC acknowledges that this error can be viewed as an isolated personnel error.
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22 Following, and in response in December to the NRC's MOV inspection conducted in
May
l Basis: Revised to correct misstatement that the assignment of a senior engineer was a direct
result of the NRC's MOV inspection.
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evaluations and timeliness evaluations.
of responses.
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Sentence beginning Deleted sentence.
"Further on one..."
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Basis: Allowable response time for the request for additional information was not defined by
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NRC regulations.
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