IR 05000029/1985099

Final SALP Rept 50-029/85-99 for Sept 1983 - Jan 1985

ML20129F837
Person / Time
Site:	Yankee Rowe
Issue date:	05/31/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20129F732	List: IR 05000029/1985099 ML20129F728 ML20129F848
References
50-029-85-99-01, 50-29-85-99-1, NUDOCS 8506070055
Download: ML20129F837 (49)

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ENCLOSURE 1 l

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-29/85-99 YANKEE NUCLEAR POWER STATION ASSESSMENT PERIOD: SEPTEMBER 1, 1983 JANUARY 31, 1985

' BOARD MEETING DATES: MARCH 19 AND 29, 1985 hDR A O 29 e PDR

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-SUMMARY................................ 37-TABLE 2 - VIO LATION SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 '

oTABLE-31-. INSPECTION REPORT ~ ACTIVITIES........................... 40

^ 1 TABLE)4-LISTINGOFLERSBYFUNCTIONALAREA.....................42

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TAB L E ' S - LE R SY N0 P S I S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3 1 TABLE 6 -. SUMMARY.0F LICENSING ACTIVITIES......................... 4 6

. TABLE 7 - UNPLANNED AUTOMATIC SCRAMS AND FORCED OUTAGES. . . . . . . . . . 49 ,

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'I. INTRODUCTION Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated

.NRC staff effort.to collect the available observations and data on a periodic basis and to evaluate licensee performance based on this infor-matio SALP is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's man-agement to promote quality and safe plant construction and operatio A NRC SALP Board, composed of the staff members li:,ted below, met on March 19 and 29, 1985 to review the collection of performance observations and data to assess the licensee's performance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance". A summary of-the guidance and performance criteria is provided in Section II of this repor This report is the SALP Board's assessment of the licensee's safety per-formance at the Yankee Nuclear Power Station for the seventeen month period of September 1, 1983 through January 31, 1985. The length of the review period is reflected in the number of inspection hours and in the scope of NRC observations and finding SALP Board Members Chairman R. Starostecki, Director, Division of Reactor Projects (DRP)

Board Members T. Martin, Director, Division of Radiation Safety and Safeguards (DRS&S)

E. C. Wenzinger, Chief, Projects Branch No. 3, DRP J. Joyner, Chief, Nuclear Material Safety and Safeguards Branch, DRS&S (Part Time)

T. Elsasser,. Chief, Reactor Projects Section 3C, DRP H. Eichenholz, Senior Resident Inspector P. Erickson, Project Manager, Operating Reactors Branch #5, NRR (Part Time)

L. Bettenhausen, Chief, Operations Branch, DRS W. Kane, Deputy Director, Division of Reactor Projects (DRP) (Part Time)

R. Bellamy, Chief, Emergency Preparedness and Radiological Protection Branch, DRS&S (Part Time)

Other Attendees K. Ferlic, Project Engineer, Reactor Projects Section 3C, DRP J. Schumacher, Reactor Engineer, Reactor Projects Section 3C, DRP M. Shanbaky, Chief, PWR Radiation Protection Section, DRS&S (Part Time)

T. Dragoun, Radiation Specialist, DRS&S (Part Time)

J. Prell, Reactor Engineer, DRS (Part Time)

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2 Background

, Licensee Activities-At the beginning of-the assessment period the facility was in cold shutdown to repair a main coolant leak on the pressurizer manway-that was: identified on August 27,'1983. The facility operated at full power from. September 4, 1983~until March 31, 1984,~ with the-V ._ exception of the following two unscheduled outages. On 0ctober 5, 1983, a manual reactor scram was initiated. in response to .the loss

of.the Z-126

115KV transmission line during a thunderstorm resulting in the loss of a main coolant pump.and feedwater. pump. On January 24;;1984, a reactor shutdown was initiated for a seven day outage to repair a.through wall. pin hole main coolant leak inLthe N Loop Steam Generator's' (SG) water box vent line. The power coast -

down to the Core XVI-XVII refueling outage began on March 14,= 198 ;

An Unusual Event was declared on January 24, 1984 as.part of the licensee's response to the discovery that the leak .in the steam - .

generator No. 4 water box vent line was non-isolable primary pres-sure boundary leakage. Their emergency response.inclue d full ac-tivation and staffing of the Technical. Support Center afford-

, selected plant personnel a realistic training exercis The facility was involved in a scheduled refueling and maintenance outage from March 31, 1984 until June 8,1984. Major activities during.the outage included refueling, extensive SG_ hot and cold leg inspections,-and implementation of Systematic Evaluation Program modifications (SEP). During the refueling period, the licensee identified severe _ degradation of 13 fuel rods in one of the fuel

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assemblies'. This~ occurrence was attributed-to a baffle spacer. flow jetting that induced' fretting of the fuel cladding.' The' licensee reported this problem to the NRC. Higher than normal coolant acti-L vity levels resulted during Cycle XVI operation.-

The facility started up from the refueling outage on June.6,~1984 and was phased to the grid on June 8, 1984. As a result of'a tur--

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bine-governor low oi1 pressure condition, the generator was taken off-line on June 9, 1984. The plant returned to the grid on June L 10, 1984, and reached full < power operation on June 17, 198 An unscheduled load reduction to 60% of full power occurred to repair a: defective Heater Drain Pump 'and a steam leak in a Feedwater Heater .

extraction steam line. The reactor was again at full power on June 21, 1984.

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The facility operated at full power from' June 21, 1984 until the end of the assessment period on January 31, 1985, with the exception

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of the.following.five unscheduled outages. On July 12, 1984 a ;

reactor automatic scram was initiated from an unknown cause. The licensee proceeded to cold shutdown for a seven day outage to effect F repairs to correct a leak in the No. 4 Main Coolant Pump check' valve n

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cover flange. On August 2, 1984, a reactor shutdown commenced for a two week outage to repair the damage caused by an electrical fire in a non-safety related 480 volt bus. A manual reactor scram was initiated on September 4, 1984 in response to the loss of the Z126 115kv transmission line caused by a fallen tree. On September 14, 1984, a reactor automatic scram occurred due to a main generator trip on actuation of its loss of field relay due to Static Exciter failure. A manual scram from 59% power was initiated on November 12, 1984 as a result of severe arcing of the main generator exci-ter's collector ring brushes. A four day shutdown was required to effect repairs to the collector assembly. Following the phasing of the generator to the grid on November 16, 1984 an automatic reactor scram occurred due to low level on two of the four SG's caused by operator erro In response to the switchgear room fire on August 2, 1984, the lic-ensee initially. declared a fire emergency that included response of the plant's fire brigad Subsequently, as a conservative meas-ure, the licensee' declared an Alert level emergency, staffed the response centers, and performed notification actions required by the emergency pla During this assessment period the station capacity factor was 77L 2. Inspection Activities One NRC resident inspector was assigned to the site during the en-tire assessment period. The total NRC resident and region-based inspection hours for this 17 month assessment period was 2466 hour0.0285 days <br />0.685 hours <br />0.00408 weeks <br />9.38313e-4 months <br />s-(1738 per year) with a distribution in the appraisal functional areas as shown in Table Two event related special inspections were conducte An inspection was performed by a regional specialist to review the licensee's ac-tions associated with the January 24, 1984 leak in the No.1 Loop SG water box vent line. In response to the August 2, 1984 fire in the switchgear room and the Alert Emergency declaration, an'NRC in-spection team was dispatched to the site to review the event details,

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the immediate and long term corrective actions, and plant' repair The resident inspector conducted a special inspection in the secur-

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ity area in response to multiple events involving inadequate com-pensatory measure NRC Emergency Preparedness Inspection Teams observed the annual emergency exercise on August 22, 198 In this period seven violations were issued including one Level III which occurred near the end of the last assessment perio Tabula-tions of Violations and Inspection Activities are attached as Table 2 and 3, respectively.

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I CRITERIA Licensee' performance is-assessed in selected functional areas depending on

- whether the facility is in operation or shutdown. Each functional area nor-mally represents areas significant-to nuclear safety and the environment, and

.are normal. programmatic areas. Special areas are added to highlight sig-nificant observations;.i.e., Design Control and Quality As'suranc .The following evaluation-criteria were used to assess each functional. are . Management involvement.and control in assuring qualit .- Approach.to resolution of technical issues from a safety standpoin . -Responsiveness to N'RC initiative : 4.~ Enforcement. histor . Reporting and analysis of reportable event . Staffing (including management). Training effectiveness and qualificatio Based upon.the SALP Board assessment, each functional-area evaluated was clas-sified into one of three performance categories. The definitions of these performance categories are:

Category Reduced NRC attention may be appropriat Licensee management-attention and involvement are aggressive and oriented toward nuclear safety; >

licensee.. resources are ample ~and effectively used so that a'high level of ,

performance with respect.to operational safety or construction is being-achieve Category 2.' NRC attention should be maintair.ed at normal levels. Licensee management. attention and-involvement are evident and are concerned with nuc-lear _ safety; licensee resources are adequate and reasonably effective so that satisfactory performance with respect to operational safety or construction is being achiev'e '

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Category- Both NRC and licensee attention should be increased. Licensee

' management attention or involvement is acceptable and considers nuclear safety,

~but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with' respect t operational. safety or' construction is being achieve The SALP. Board also assessed each functional. area to compare the licensee's

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performance during the last quarter of the assessment period to that during the entire period in order'to determine the recent trend for each functional area. ;The trend categories used by the SALP Board are as

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- Improving:

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Licsnsee performance has generally improved over the last quarter of the current SALP assessment' perio Consistent: . Licensee performance.has remained essentially constant over the last quarter of the current SALP assessment perio Declining: -Licensee performance has generally declined over the last quarter of the current SALP assessment perio . ,

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IIL SUMARY OF RESULTS

- Overall' Facility Evaluation During the previous assessment, increased licensee management attention was-identified as being necessary in the functional areas of Radiological

.-Controls,-Design' Control and Quality Assurance, and Security and Safe-

-guards. Yankee has demonstrated notable strengths by maintaining a high level of cooperation with, and responsiveness to, these NRC past iden-

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tified concerns. Since the last assessment period, numerous improvements have been noted; however, additional or continuing NRC ~ concerns _ exist

, involving procedures and independent audit Our assessment during this period detected a declining trend in perfor-mance of work' activities associated with fire prevention controls al--

though-the combined area of Housekeeping and Fire Protection remained at a Category 1 ratin The remaining functional areas reflect a consistent'and strong-licensee

orientation toward nuclear safety.- Significant licensee actions were observed this period that reflect a firm corporate commitment to provide resources that have the potential to produce an even higher level of :

overall performance with respect'to operational safet The licensee exhibits very strong performance ~in most functional area However, ~in some , instances the. licensee has been slow to determine what action, if any, is needed in response to potential concerns identified by NRC. None of.these instances were considered-serious safety problems; however, the observation is that gentle prodding is sometimes needed so

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the licensee' will conduct the necessary evaluation. Examples of this Lproblem are found in the Operations, Radiological Controls,-and Security and Safeguards Section Training Review LTraining' is ossessed in each functional . area by direct observation of-performanca. . Currently, training is in the' state of transition. Train-ing resp >nsibilities-are being shifted from individual departments to the training department. With the exception of the functional areas involving Radiation Protection and Security, overall training effective--

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= Facility Performance Functional Area last Period This Period Recent Trend (Riy 1, 1982) (September 1, 1983-August 31,' 1983 January 31,1985)' : Plant Operations 1 1 Consistent'

- Radiological Controls 2 2 Consistent

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' Maintenance 1 1 Consistent

. Surveillance 1 1 Consistent . Fire Protection and

' Housekeeping 1 1 Consistent *

- zEmergency Preparedness 1 1 Consistent-

- Security and Safeguards 2 2 < Improving H.: : Refueling' 1 1 Consistent : Design Control / Quality Assurance: 2 2 Improving

- Licensing Activities 1 1 Consistent

'*A declining trend has been noted in the area of personnel adherence to Fire Protection _ procedure .

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I PERFORMANCE ANALISIS

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' Plant Operations (33%)

- Analysis The analysis of this area includes plant operations as well as

. operational support activities. .The' areas included: compliance with license and procedural requirements; response to operational events; corre:tive action-and reporting systems; control room environment;.

saft..y review committee activities; and staffing and training. The area was under routine review by resident and regional inspectors during the assessment perio The previo'us SALP identified _the need for the licensee to provide continued or additional direct management attention to activities involving: . tracking and control of in plant radiological condi-tions; maintaining adequate resources and up-to-date training aides; effective onsite review committee function; the use of Operations Memos in place of approved procedures; the uncontrolled posting of procedures and drawings; and improving analysis of deficiency items and event follow-up. The licensee continues.to demonstrate its

- responsiveness to _NRC concerns by providing effective, timely cor--

rective actions which prevented recurrence of the-above concerns-during this assessment perio Senior corporate management, project management personnel, and Yan-kee Nuclear Services Division engineering personnel frequently visit '

the station and maintain daily contact with the station for planning, operational review,;or event response. This involvement, in concert

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~w ith the day-to-day review of. station operation by onsite. senior management, provides a decision making process that is consistently _

at a level that ensures' adequate management: review. Plant operators and-licensee' management response to plant. events and conditions have generally demonstrated a strong and effective approach to resolution of~ technical issues. The management team demonstrates _a clear un-derstanding of the issues,_and exhibits a conservative, te'chnically-sound approach to safety issues. These characteristics were evi--

dent'in all abnormal events during this assessment period with the exception of one event. The only event viewed by the NRC as a de-

~v iation from the normally conservative manner in which the licensee responds to operational problems involved the cross-tyiag of all 2400 volt and non-emergency 480 volt buses when supplied from one station service transformer due to loss of a transmission lin '

In response.to NRC concerns the licensee immadiately curtailed-similar cross-tying operations until an NRC requested safety evalu-ation was completed. At the conclusion of the assessment period, the comp 1eted safety evaluation was being reviewe __

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lStrongmanagementinvolvementinimprovingplantoperations'and'

facilities has been evident. . Examples are: the construction of four new site buildings,~ improved health physics and chemistry

? facilities, implementation of a computerized open item tracking system, and significant improvements in plant cleanliness, house-keeping, and personnel safet iAdditional_ evidence of management commitment to quality operation-

'has been noted in the general performance of the Operations Depart-

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men Personnel errors are minimal, with those occurring usually:

being isolated instances that neither reflect programmatic breakdown '

nor result in enforcement action. The three (3) instances of'per-sonnel error identified by the licensee have resulted in: .a minor

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_-unplanned release due to improper valving; inadvertent rupture of'

a' diaphragm due to failure to follow a startup procedure; and a plant scram during startup due to the inadequate attention by con-

trol room personnel to steam generator level. ~ The performance level of plant. operators during routine and transient plant operations-reflects a conscientious attitude and concern for plant . safet '

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This attitude has contributed to the licensee's excellent safety _

- and availability recor ,

Licensed operators exhibit good knowledge of plant' status.but occa-sionally appear to be lax in adherence to administrative require- +

.ments-involving off normal conditions. ~.This is evident in_ failure to document equipment malfunctions -or off normal conditions in

.the shift turnover. process, the-post trip review process, and the control room log. Additional problems involving inadequate adherence to administrative controls and proceduras.have included i recurrent failures to initiate' maintenance when off normalLequip-

-ment operation is observed.- Improvements in operator attention to these activities-and details have been~ observed toward the end of this assessment' period. Management attention is necessary l to emphasize continued improvemen Onsite and offsite review committees'are properly staffed, provide-timely review, and function in accordance with established require-ment Both committees were observed to hold active and probing discussions ~on items of concern and plant events. - Routine attention-is directed at timely completion or updating status on open item The effectiveness of the offsite review committee was enhanced by

.the incorporation of experienced operations personnel from other nuclear _ utilities.and by participation of the Yankee Atomic Engi-neering staffs particularly in response to the fuel failure problem .

In response to the new 10 CFR 50.72 and 50.73 rules fo'r notification-and' event reporting, the licensee has established well stated ad--

ministrative controls. The station management places a strong en-phasis on prompt notification to the NRC, and applies a conservative

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approach in determination of reportable events. Licensee Event Re-

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D i" ports (LERs) are in general properly l identified, analyzed, and re-

- ported in-a. timely manner. An evaluation of LERs'was completed by

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the NRC's Office of Analysis and Evaluation of Operational. Data.

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Within the context of this review the licensee provided adequate event reports.- -However, the NRC has_had to request revisions to

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- ' several LER's- due to -incorrect or insufficient information.- Lic-c - -

' ensee responsiveness to NRC concerns in_this area have. increased

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the effectiveness of the review conducted by the Plant Operations

. Review Committee (PORC) for LERs, as well as non-reportable concerns

contained in Plant Information Reports. A lack of repeat events;  !

has been observed with the implemented corrective. action.- Continued

_ management attention is necessary to continue the improvement ;

- With regard to.the Operator' Licensing Program, the licensee has

' maintained a high success rate with four Reactor Operators-(RO) and one Senior Reactor Operator (SRO) receiving licenses in this perio The. licensee has displayed'a strong commitment to operator training and has completed preparation for a 1985 INPO accreditation of-the

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Yankee' Training Programs. The licensee has been effective.in

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screening and preparing licensed operator candidates. A review of

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- the Licensed Operator Requalification Program concluded that a good L program was effectively implemented. The use of an independent-auditor to evaluate.the requalification candidates has been bene-

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ficial to.the Yankee requalification effort. Although the licen-

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see's training program continues to.be upgraded with more compre-

. hensive training material, the' documentation of this-improved training material is approximately 50% complete with slow progress being made. The NRC is concerned that this lack of sufficient i reference material-detracts from providing for meaningful NRC_ad-ministered operator license examinations. In_the absence of.up ;

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graded material, alternative material needs to be supplied to the NRC to enable the development of quality operational, plant specific

- examinations. Additional management attention to this action-'is

. warrante Several additional areas are-of concern because of the potential

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for significant impact on plant operations. These areas require increased management attention or evaluation to prevent future ad-verse impact on plant operations. These areas are discussed belo Station staffing is adequate; however, due to numerous demands on the time of the various licensee operators, over reliance on-over- ,

time to meet watchstanding needs has been necessary. The use of overtime-has been in compliance with NRC requirements. However, the current depth of staffing level does not always provide'the licensee with the desired operational flexibility. Continued man--

agement attention is warranted in providing ample operational de-partment licensed staffin l . . _ _ _ .._ . . . .__ . . _ . _

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r 11-The majority of activity; relating to control room business normally-occurs in a location that is within a.few feet of both Control Room

' Operators, the Senior Control Room Operator, and.the Shift'Supervi-sor. This' condition,.with the relatively high background noise

. level,~ routinely ~ challenges the attentiveness of the operator Location of;the_ secondary alarm station in an unisolated space within-the control. room adds to the number.of personnel who must conduct business.inside-the control room. Other than for plant _up-set conditions, the-licensee has no formal' administrative means.for

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effectively limiting control room access or number of personnel lin

_ the Lcontrol room._ . However,' no operational problems can be attri-buted to the current control room ~ environment.- The licensee should consider incorporation of applicable findings of the ongoing control:

room design revie The use of.Special Orders in lieu of approved procedures requires-evaluation.' Currently, the licensee _is addressing NRC_ concerns for

.Special Orders which contain long standing items that should be in documents requiring management approva . Conclusion Category 1, consistent. The licensee continues to demonstrate a-

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strong and effective commitment to safety in the. plant operations are . Board Recommendation Licensee Emphasize to shift personnel the importance of adherence to admini-

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.strative' requirements involving off-normal conditions, especially-

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Provide' complete and comprehensive training material to the NRC for development of quality licensed operator examination NRC Reduce inspection in this area to minimum inspector coverage.

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0 Analysis'

'The previous SALP identified the need for.the licensee to conduct

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an evaluation of the primary vent stack monitoring system perfor-

.mance and implement effective corrective actions to resolve con-tinued equipment failures. The NRC concerns have received the prompt attention of senior corporate officials. Resolution has been y targeted in the licensee's corporate performance goals. A meaning-ful. corrective. action program'was. established with. detailed engi-neering evaluation recommendations being implemented at the end of-

this assessment period. ~ Routine updating of progress was made to-L the NRC. Although temporary repairs were made to resolve equipment

performance problems, the system was treated as inoperable per

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technical specification requirements for a.significant portion.of t

the period with alternative sampling performed. Although needing prompting by the NRC to initiate action, the licensee has been very responsive in' resolving this problem.

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There were.five inspections performed in the' area of Radiological 1 . Controls during the assessment period by region-based inspectors.

' The resident. inspector reviewed ongoing. radiological control acti-

'vities. Licensee. activities:in' Radiation Protection, Transporta-

' tion, and Radioactive Waste Management and Effluent Monitoring were inspecte ~

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The-radiation controls programs is typical of.that for an older,

'small, single reactor.-station. .The small HP staff is directed by a technically competent Radiation Protection Manager who. reports to the Station Technical Director. However,.there.is no apparent staff development program. This results in an-apparent lack of depth within the organization. This problem is clearly manifested when department supervisors are absen Programmatic weakness were observed regarding the radiation work F - ' permit procedure recordkeeping, and the respiratory protection pro-gram. There appears to be some evidence that several procedures

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were both poorly written and understood. Regarding radiation work procedures operations personnel on tours routinely failed to review

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and sign the RWP for high radiation. areas. During outages, onl the foremen in charge of the work crew reviewed the RWP requirements-and signed the acknowledgements. There was no confirmation that

.the entire work crew was. briefed regarding the radiation levels-or

- protective action required. The respiratory protection program was deficient in that there was no procedure for the respirator repai Nor was there a requirement to retain the physicians certification

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for-respirator users. Instead, a contractor representative's sig-nature was accepted as evidence of medical certification. These L problems resulted from the ambiguous nature of the procedures.

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Additionally, near the.end of the assessment' period an inadeq'uacy

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with procedures implementing the respirator fit program _was-identi-

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fied. The failure of the licensee to identify these weaknesses by self audit suggests a lack of adequate quality control of these programs. Management oversight appeared unable to adequately assess program-effectiveness and identify problems. However, once problems were identified by the NRC, the response of the station staff has-been' swift and thoroug .. Annual' audits of the station radiation protection program by the corporate' staff are generally complete and thorough. However the on-site Operation Quality Assurance (0QA) organization does not

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provide quality' control for the HP activities. .This lack of this-independent review is a.significant weakness in the overall program and contributes to the' licensees failure to self-identify HP. program weaknes A The licensee's records of inspection'of_high radiation ^ area access

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controls were not complete or well maintained. These areas are normally locked and secured to prevent unauthorized access by-per--

sonnel.~ However, evidence indicated that the areas had indeed been routinely checked as required but personnel failed to complete th required record Radiation protection procedures and policies were occasionally vio'-

lated._ In one instance, compressed gas bottles were removed from a radiologically controlled area for shipment off-site without a proper radiation survey. In another case, the' shift supervisors authorizing signature was not obtained prior to the issuance of a radiation work permit. Although, these incidents did not result in a significant safety hazard, they indicated lack of adherence

'to procedure In almost all cases, the licensee's~ approach to'the resolution of--

HP issues is technically sound and thoro' ugh. The coordination of onsite'HP activities during the annual emergency exercise was sig--

,, nificantly improved over the last SALP perio During excavation onsite for construction of a building,.the licen-see identified an area of old contaminated soil. Comprehensive radiological controls of the area were immediately establishe The source of contamination was identified and eliminated. The

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recovery from this ground contamination was completed promptly and t without inciden The response'to NRC initiatives concerning the weaknesses in the

.- respiratory protection program procedures was timely with-acceptable

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resolutions. Similar responsiveness was noted in reply to all other initiatives identified by NRC inspectors,

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- The authority of the radiation protection manager and the first line

- tupervisors are not well-define There is~a lack of clear authority,

_ statements in thel job descriptions for these position The. technical training and qualification of the HP staff. appear . .

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to be adequate. A defined program is implemented for a large por-tion of the staff.with the exception of respiratory repairs-techni-cians where no-job training had been provide .. .

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There is consiste'nt evidence of prior planning and assignment of-

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priorities by management to control the processing of radioactive

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waste. In response to program weaknesses identified early in-the assessment' period, a major effort by management resulted in well

~ stated, controlled, and explicit procedures for radwaste' handling.

l The annual corporate audits of the radwaste program are complete

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and thorough. However site Operations Quality Control was .not

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involved in verifying the classification and character.istics of

. radwaste as specified by. regulatory requirements. This' deficiency

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. 0QA-involvement in~providing quality control of other radwaste operations was minimal. This resulted in a program without any QA verification of the day-to-day radwaste operations.

~ The licensee's resolution of the safety issues regarding~the improper bra'cing and use of-poor quality shipping containers were technic' ally sound and thorough. A new dedicated building was' erected to process

- and store radwaste. The process control program was improved.as were the methods for handling and loading the radwaste. The licen-see's major commitment'of resources'to the upgrading of this area resulted in a significant program improvements. The staffing in the'radwaste program was increased by the~ addition of a radwaste

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coordinator and twol dedicated radwaste handlers. These~new posi-

tions have-clear authorities and responsibilities.

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management. - The procedures and policies for analyses, calibration, L and reporting.of effluent releases are strictly adhered to. Quality:

Assurance audits are generally complete, however, only one aspect i of the effluent control program is normally reviewed. A need for increased scope of audits is indicate Some weakness regarding the training and qualification program for chemistry technicians was observed. Although a defined program is

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- implemented for the staff, no training was provided to technicians for a 14 month period. During this period the licensee was aware

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that a major change to the tect al specifications for environmental surveillance was imminent. Thn. problem is discussed further in Surveillance, Section D of this report.

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,.-vo, ,,e-.- p v>---, , %, . -cr.,m,, ww n , e ,w,-.m + y- .~-...,-..,.v....,sre-w

. ....---e-...,- --e.-- , . _ - , , . - - + - - . - - - . ~ . -

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-The most significant progress that occurred during this period con-cerned the processing and transportation of low level radwast This is in contrast to the performance in this area during the past

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SALP period.which resulted in a Level III violation issued in thi assessment period. The licensee's action to resolve this problem s

was commendable. Similar problems did not occur during this as-sessment perio Corporate audits of transportation activities are complete, timely and thoroug '

There appears to be-an on going commitment-by the highest levels of management to assure a high level of quality and performance in this area. However, involvement by the 0QA needs sig'nificant improvement .At the end of the assessment period, one of the three Radiation Protection Engineer positions was vacant for approximately one months with the Health Physicist's position soon to'become vacan Considering the~small size of the staff and the lack of depth within this department, management attention to assure filling of the va-cant-positians on a priority basis is warrante . Conclusion

_. Category 2, consisten . Board Recommendations Licensee Review staffing levels of the radiologic ~al controls organization to provide -for increased supervisory dept Provide a staff development program to ensure backup for critical position ' ~ ~

Provide additional management and quality control oversight to

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allow for self evaluation and early identification and prevention:

of problem Conduct a thorough review of site radiological protection proce-

'dures, update as required and emphasize the importance of radio-logical protection procedure compliance to all personne NRC Continue routine inspection coverag _____ - - ____

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C. Maintenance (6%) Analysis The previous SALP identified problems included: failure to perform in-depth reviews of maintenance to determine root causes; a lack of in-depth reviews and trending of LER's resulting in a few in-stances of misclassification and failure to implement effective corrective action; and, failure to specify post maintenance test requirements and improper work sign of During the current SALP period, maintenance activities were rou-tinely reviewed by the resident inspector. This included a special maintenance inspection by the resident to assess the licensee's Maintenance Program for. trending, root cause analysis, and record i

systems that support these evaluations. One inspection by c re-gion-based engineering specialist was conducted to review the lic-ensee's failure analysis and repair process for a pin-hole pipe leak in the main coolant system. As in the preceding SALP period, no violations of NRC requirements were identifie Strong corporate and site management involvement and control in assuring quality continues to be evident in this functional are Frequent use is made of Yankee Nuclear Services Division (YNSD)

personnel for technical support and resolution of concerns related to plant maintenance and design change / modification activity. The licensee has demonstrated the initiative to strengthen this corpor-ate / site relationship by creating a new Maintenance Support Depart-ment consisting of engineers, all formally assigned to the Mainten-ance and I&C Departments. The intent of this department is to im-prove communication and enhance the control of work involving groups of various disciplines. In assuring quality, the maintenance man-agement provides consistent evidence of prior planning and appro-priate assignment of priorities; has maintained effective coopera-tion and coordination with the QA organization; has well stated and understandable policies; and, provides timely and thorough review of ongoing niaintenanc NRC observations have noted that safety related maintenance is given priority attentio QA inspectors will accompany safety related equipment that is sent to the factory for repairs in an effort to aide maintenance management oversight when close review of the ac-l

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tivity is warranted. Preventive maintenance (PM) is treated as a comprehensive progra Procedural controls for scheduling, imple-menting and doc'umenting the program includes both non-safety and safety related equipment. Since the licensee's maintenance philos-ophy is preventive in nature, maintenance supervisors are encouraged to schedule equipment for PM in an ongoing basis, and encourage re-lease of equipment from operational status for this purpos .

__ _ _ _ _ _ - _ _ _ _ _

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The licensee demonstrates concern for plant reliability. Management will upgrade systems and components that prove to be difficult to

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maintain either due to age, inadequate performance, or unavaila-

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bility- of spare parts. The licensee's initiative in this regard was demonstrated during the current assessment period by the in-stallation of new sensing, control, and indication portions of the 1Feedwater Control System, and the installation of a new static ex .

citer for the unit generato As a result of the licensee's desire to correct and respond to maintenance deficiencies in the previous'

SALP. findings, senior station management has incorporated into supervisor QA' training added emphasis for deficiency recognition and stressed the necessity for improved personnel performance. This action has' aided in the acceptable and timely resolution of NRC and licensee concern The special maintenance inspection conducted during this assessment period identified no programmatic discrepancies. In early 1984, the licensee instituted the use of Failure Analysis-Reports. 'These <

reports are-initiated after instances of repeated failures. Man-agement attention is warranted to formalize use of these reports .f to aid in assuring.that equipment failures are evaluated for fre-quency-of occurrence and root caus j Increased sensitivity for thorough reviews using event analysis by '

the maintenance organization and the PORC has resulted in noted-improvemen In~this functional area four LER's were submitte i i

A review of the event details indicates that the corrective action-implemented by the maintenance organization was effectiv No ad-' .] .

verse trends were identified that would contribute to equipment l unavailability or improper performance as a result of maintenance-activitie ~ '

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The Maintenance, Instrument & Control Department, and' Maintenance

' Support Department continue to be staffed by experienced, qualified craft and supervisory personnel. Personnel turnover has tradition-ally been low. Vacancies are: filled in an expeditious manner.. Re-sponsibility for compilation ~and review of design change and modifi-

. cation documentation is assigned to the Maintenance Engineers. These

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engineers are also responsible for resolution of installation re-lated problems and the field supervision of work activities.- Since a relatively'small number of maintenance engineers perform a signi-

'ficant amount of work ~in the design change and modification area, management attention is warranted to insure sufficient maintenance-engineering resources are available to perform complete and timely reviews of quality related documentatio Training and qualification of maintenance personnel is a noted strength. This. allows the licensee.to continue reliance on using generalized procedures for routine work, and has generally resulted in few personnel errors. Although the existing training programs . . . .- . . . . . . . . . , . . . , , . . . . . , . . .

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for the Maintenance and I&C personnel are well defined and imple-mented, the licensee is in the process of increasing training pro-gram effectiveness to obtain INP0 accreditatio In general, the licensee has been responsive to NRC initiatives in-volving this functional area. Timely replacement of HFA relays with upgraded units in safety related applications was performed in re-sponse to IE Bulletin 84-0 Commitments made by the licensee in the Systematic Evaluation Program have been incorporated into site maintenance activities. Maintenance management is' currently con-sidering the initiation of a program for response time testing of reactor trip breakers during refueling outages to assess performance and detect unacceptable degradatio In response to the Salem ATWS event, the licensee has committed to establish a Vendor Interface Program to get updated information on all safety related component This technical information program is to be formalized by a pro-grammatic procedur The licensee has not been providing timely resolution to NRC con-cerns involving 10 CFR 50.59 and technical specification require-ments.for-jumper and lifted lead activities. Procedural controls inadequately address this topic. The procedure for jumpers'and lifted leads did not require a safety evaluation in accordance with 10 CFR 50.59, i.e., not requiring a written basis for why no unre-solved safety question existed and did not require an onsite safety committee review prior to implementation as required by Technical Specifications. NRC effort has been necessary to obtain resolution and additional management attention is still require . Conclusion Category 1, consisten . Board Recommendations Licensee Insure sufficient Maintenance Engineering resources are available with a formalized training program established for these engineer Implement a procedure to formalize the Vendor Interface Progra Resolve procedural deficiencies related to jumper and lifted lead activities.

i NRC i

Maintain effort at the current level with resident inspecto Prioritize region based inspections as needed to handle identified concerns.

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D. Surveillance (7%) Analysis Operational and refueling surveillance. activities were reviewed by the resident inspector during routine inspections. Four inspections were conducted by region-based inspectors in the areas of reactor coolant water chemistry sampling, inservice testing program, con-tainment leakage testing program, and nonradiological chemistr Significant NRC concerns identified in the prior SALP included steam generator cold leg ISI inspections and adequacy of the mechanical tube plugging of SG tubes. These issues were resolved during this assessment perio The licensee's. implementation of the surveillance program is per-formed in a dedicated manner by the various department Managers and reflects a high level of management involvement. When technical specification changes occur, the Plant Superintendent directs the implementing activity to ensure correct incorporation of require-ments into the progra Surveillance activities by the operations, radiation protection, reactor engineering, chemistry, instrumentation and maintenance groups were found to be in accordance with established procedures during routine reviews by the resident and specialist inspector The licensee's technical staff was well trained and knowledgeable of applicable surveillance and testing requirements. Activities are well planned, technically adequate, and properly controlled and documented. Surveillance test results continue to be evaluated in a thorough and accurate manne Records were well organized and retrievable. An inspection of the core physics surveillance testing following the refueling outage indicated the existence of a well established and implemented progra The number of reportable events for this. functional area (four) is not considered to be exceptional. One LER described a missed sur-veillance test due to personnel error; the corrective action was prompt and effective. The~other LERs involved a detected design inadequacy affecting a containment isolation pressure switch set-point, and component failures associated with excessive valve leak-age identified as part of local leak rate testing activitie Con-sistent with a routinely conservative approach when dealing with containment integrity issues, the licensee has committed to perform an evaluation of the valves exhibiting excessive leakage to deter-mine whether they should be redesigned or replace i l

Plant management is fully involved with surveillance related acti-vities as evidenced by the scope of'the testing programs. The lic-ensee is one of the few who have successfully leak rate tested the containment in as close to the "As-Found" condition as possibl ,

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This'is a direct indication of the effectiveness of the' licensee's

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containment penetration maintenance and improvement program. Addi-tionally, the .*.eam' generator eddy current examination program i

. routinely-tests far more tubes than required by Technical.Specifi '

cations. This is due in part to the responsiveness of the licensee to NRC initiatives involving inspection of cold leg side. tubes where Ldefects are known to exist.- As of the last refueling' outage, the

' licensee has completed a-full baseline inspection for cold legs..i .

all steam generators. The licensee is~ pursuing licensing action ,

sto resolve difficulties between its extensive sampling program and-Technical Specification acceptance criteria. These difficulties center on'the fact that actions mandated by current Technical Speci-fications do not provide for an ongoing trending of steam generator tube' degradatio .

Weakness.in the management control =and attention in the chemistry area was noted during this assessment period. Deficiencies identi-fied by the NRC-included: inadequate procedural controls for Tech-nical-Specification required sampling; lack of a retraining and re-qualification program for the laboratory personnel; failure to pro- a vide pre-implementation training on a major Technical. Specificatio amendment:(RETS); and, failure to perform required sampling and analysis because of poor requirement understanding. : Licensee man-agement ha's taken effective corrective action to improve performanc by this department. In August 1984, a new Chemistry Department Manager was assigned to-the facility. Programs are~being developed to-improve departmental performance and facilities. Laboratory.up-

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grading'.is in progress. . Continued management attention'to ensure-a continued positive trend is warrante ~ Conclusion Category 1, consisten L Board Recommendation Licensee Contiaue-efforts to resolve perceived incompatibility between cur-rent steam generator ISI sample size and Technical Specification-acceptance criteri Ensure continued improvement in Chemistry Department performance

'is achieve ;

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Maintain inspection program with resident inspector. Prioritize i-region based inspections to handle identified concern l l

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. Fire ~ Protection and Housekeeping (3%)

L ' Analysis During this assessment period, frequent observations of fire protec-tion and housekeeping activities were conducted by the resident in--

spector, with no region-based inspections performed. Previous SALP

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concerns were resolved indicating management. responsiveness to'NRC identified concern The. licensee was aggressive in improving plant cleanliness with management involvement eviden Notable achievements included:

-improved outside storage-conditions; cleanup of plant outside areas such'that they are neat and uncongested; elimination of almost

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.all temporary trailer facilities; and, implementation of a signifi-cant-turbine building housekeeping and appearance upgrade progra The prior planning and assignment of. priorities by licensee manage-ment is evident in program policy and procedures, with specific as-signments made to implement the stated requirements. QA-aedits were performed-in a timely and thorough manner. A unique feature of the

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. program utilizes the various' plant supervisors on a rotating basis,

-including s'enior station managers, to conduct monthly general plant-housekeeping and cleanliness control surveys. This ensures that adequate management attention is provided, with resolution of dis-crepancies and safety hazards performed in a systematic manne .The Fire Protection Coordinator (FPC) is responsible for the day-to-day implementation of the program, as well as performing the as-signed duties of the program's Training coordinator. The'FPC'is not full time, with the position staffed at about a 60% leve Consideration for staffing of the FPC at a full time level during

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periods of high site activity is encouraged. Overall, staffing'in this area is adequate, with contractor personnel utilized during periods of high site activity to. maintain a high standard of clean-

.liness. Security contractor management have increased the number of fire brigade personnel available on shift to address NRC concerns for brigade response capabilit The training program is well defined and implemented, and is con-sidered a program strength. Frequent backshift fire drills for the fire brigade are conducted. Fire detection and suppression systems were well maintained and controlled. Two'LERs were issued in this area and reflect removal of equipment from service to facilitate plant modification efforts. The-response of fire brigade and plant '

personnel to an August 2, 1984 electrical fire in the switchgear room was excellent. In addition, automatic fire detection and sup-pression equipment functioned properly. Subsequent recovery efforts demonstrated licensee knowledge of fire protection requirements and

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resulted in proper compensatory measures being implemented. The licensee's response to this event provided substantial evidence of a well managed and implemented fire protection progra However, weaknesses in the fire prevention program were identifie These involved: improper storage of flammable liquids; control of transient combustibles; and, control of hot work. These conditions suggest a-laxness in the established accountability mechanism and a lack of priority shown by supervisory personnel.to established fire protection policies and procedures. Fire watch personnel in-volved in hot work were not always attentive to ensure that ccm-bustible materials-were removed from the work areas. In one in-stance this lack of' attentiveness resulted in combustibles being ignited in a hot work area. Aggressive management attention is needed to ensure that personnel awareness is heightened for proce-dural adherence in the fire prevention area. In addition, increased field supervision of work activities by first line supervisors is warrante . Conclusion Category 1, consistent. Overall performance is consistent. House-keeping practices and conditions have shown an excellent improving tren However, a declining trend has been observed in the. area of fire protection due to deficiencies in personnel adherence to fire prevention procedure . Board Recommendation Licensee Encourage and assure adherence to established procedures and in-crease first line supervision in the field to direct and control work activities to prevent fire Consider removing all non-fire protection duties from the Plant Fire Protection Coordinator during refueling and major maintenance out-age NRC Maintain inspection program with resident inspector. Prioritize region based inspections to handle idertified concerns.

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F. Emergency Preparedness (13%) ,

1. . Analysis During this assessment ~ period, there were three inspections of the-license'e's emergency preparedness activities'and one full-scale

, _ emergency exercise. -The licensee has been responsive to NRC initi- ,

atives and has been aggressive in implementing corrective actions-in previously-identified problem areas. Of the 59 open items iden-tified during'the= emergency preparedness appraisal-and inspection of the Public. Notification System,:58 were. effectively resolved on-

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schedule. The Safety Parameter Display. System ~has been installed

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.and-is presently-functiona ~

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No regulatory deficiencies were identified _during the full scale i exercise on. August 22, 1984. Nine areas were noted which were'

thoroughly planned and ' efficiently. implemented; some . areas for lic- .

_ensee improvement:were also identified both by the NRC and the lic-

.ense The training program has been effective. This was reflected both ,

during the annual exercise' and in . response to two emergencies. On January 24, 1984, an unusual event was promptly declared based upon the~ detection of a primary coolant leakage greater.than; Technical Specifications. The licensee's response to this event was in ac-cordance with their emergency plan implementing procedures. Al-though this event did not require an extensive response by the'_lic- _l ensee, the-licensee's performance. was in excess of the requirement

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in order to provide'an opportunity for.-training of personnel. 10n-August 2,1984, the licensee declared:an alert based on a fire in-the-switchgear_ room. . Although an alert level emergency declaration was probably conservative, since it was subsequently determined that~ !

-safety systems _were not affected, the licensee applied good judge- H ment in the identification of the emergenc I The involvement of corporate management in site' activities was noted during.both the performance of routine: inspections and:during the :

annual-exercises. Although there is only one individual on site 1

who is dedicated to emergency preparedness responsibilities, cor- ;

porate personnel contribute much effort to site emergency prepared- l ness activitie j The licensee continues to exhibit a high level of performance in i the emergency preparedness are l l

C Conclusion- l Category 1, consisten > ,

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3. Board Recommendatio Licensee Non ' '

NRC-Reduce priority regional ~ inspection effort in this are .

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I G. ' Security'and Safeguards (5%)-

1.' -Analysi :During the-previous SALP,~ three concerns were identified: recurring security computer problems, insufficient. oversight' in security plan implementation, and marginal nature of security facilities. 'As a-

. result, licensee performance in this area was downgraded to a Cate-

_ gory 2. ; Licensee corrective action during this current SALP~ period

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was not sufficiently aggressive to resolve these issues in a timely fashion. Although actions were initiated to have an independent-

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security organization analyze various aspects of the security program, other problems ~ developed before this evaluation was initiate In the current assessment period, two routine physical security in-spections were conducted by region-based inspectors. Routine resi-dent inspections continued throughout the assessment period and in-

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cluded a special inspection in which'one Severity Level _IV violation-was identified. The violation, involving the failure to' effectively implement compensatory measures during planned and unplanned _ system /

equipment outages, was indicative of a potentially serious program-matic weaknes Therefore, an enforcement. conference was conducted at the site on June 21, 1984. Short term corrective actions _initi-ated;by the licensee have been found effective to date. Some long term actions still are not completed but are on schedule for com-pletio p _The security organization experienced programmatic ~ difficulties in

meeting procedural requirements during the first half of-this as-sessment period. This was due to the extensive use of compensatory measures because.of system hardware failures-which resulted from Ja lack of maintenance. Some procedural requirements were vague and

, poorly understood by the security force. When the problem was-

' identified by the NRC,ethe licensee responded with prompt correc-tive. action. A comprehensive action plan was initiated to effect a general upgrade of hardware, procedures, and management oversigh i

'Significant program improvements were noted during the.last half-of the assessment period. These-included hardware performance, at-tention to maintenance, management oversight and, in particular, attention to meeting the objectives of NRC security program re-quirements. 'These program improvements are directly~ attributed to

' increased licensee management involvement in the progra , Corporate involvement is also evident in an improvement project for.QA audits of the Security Program. This project includes a J plan to allow for whole, or in part, inspections of' security to look at perceived problems as directed by plant managemen .- -. .

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The project is scheduled for completion in July,1985. 'The.. licensee has also involved the Instrumentation and_ Control (I&C) Department-directly in the security _ program. -This.has improved the liaison between;the groups _and;has.resulted in increased reliability of

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security systems. This has correspondingly reduced the use of security force personnel to compensate for systems' downtime. The

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. improvement _ 'ffected 'during ~ the later portion .of

the assessment period appear to have raised the morale of the security force-per-

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sonnel. More attention to-detail, appearance, and . improved profes-sional conduct were evident. -The licensee has shown initiative by committing resources to enlarge the present gatehouse facility which

'is envisioned to correct known inadequacies and improve security organization effectivenes LTraining and qualification of security force personnel appeared to-be effective. Increased awareness of, and adherence to,Eprocedures and knowledge of security program objectives has been demonstrate During the assessment period, the licensee submitted to Region I seven changes to Safeguards Plans under the provisions of.10 CFR-50.54(p). The changes were found to'contain numerous problems:

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some changes were not identified as such, some changes (identified -

-and not identified).were considered unacceptable,'and an overall summary was not provide Requested resubmittals were delayed be-yond the specified tium, even after prodding by the NRC. In one-case, a delayLin excess of six months occurred. The quality and timeliness of' security plan changes requires management attentio _

The licensee submitted three 10 CFR 73.71 security reports during this assessment period. None were indicative ~of repetitive prob .

lems. The three reports were timely,,well written and provided a clear. understanding of the event cause and compensatory measure:

take . Conclusion Category 2, improvin . Board Recommendation Licensee

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Continue to upgrade security system equipment and performance and maintain the current high level of site and corporate attention.

! NRC L

L Continue routine inspection program.

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27 H. Refueling (7%) Analysis A 10 week refueling outage (March 31, 1984 - June 8, 1984) was con-ducted during this assessment period. Preparations for refueling were reviewed by the resident inspector and included outage planning, procedural preparations, new fuel receipt and inspection. Through-out the outage period, resident inspector reviews were conducted in the areas of outage coordination, refueling operation, radiolo-gical controls and post refueling physics testing. Two inspections dealing with the Radiation Protection Program and ISI activities were conducted during the refueling outage period. In addition, the following unscheduled extended maintenance outages occurred in 1984:

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January 24 - February 1 (main coolant leak repair in steam generator No. I water box vent line)

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July 12 - 20 (leak repair on the No. 4 main coolant loop check valve)

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-August 2 - 15 (electrical bus 4-1 equipment damage repair that resulted from an electrical fault induced fire)

Activities during these outages were reviewed by resident and re-gion-based inspector This area continues to be a. noteworthy strength of the licensee as evidenced by the high level of attention both senior corporate and site management have placed on scheduling, planning, and control of activities both before and during outages. As in the past, a Senior Maintenance. Engineer was dedicated to outage planning. This has resulted in decision making consistently at a level that ensured adequate management review of activities. Daily planning meetings (twice per day) were effective in coordinating work accomplished and-identifying mechanisms to improve schedules on critical path work. The Assistant Plant Superintendent continues to be charged with overall outage planning responsibility with'a high degree of involvement from the Plant Superintendent and Technical Directo These individuals consistently used daily refueling and forced maintenance outages meetings to reinforce, in a non reactive manner, adherence to administrative policies that placed a priority on plant and personnel safet The licensee's response to unexpected problems during the outages has been exemplary. It is characterized by thoroughness and con-servatism with an ongoing attention to safety. The licensee tends to react positively to deficiencies in controlling work activitie The problems encountered during the outage were diverse: small bore

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i piping support deficiencies inside containment; fuel assembly flow l induced fretting; steam generator main coolant spill; imprope loading of a fuel assembly into the reactor vessel; damage to a fuel assembly in transit; and, inadvertent cross connecting of two incore flux paths. In handling these problems, the inplace corrective ac-tion systems promptly identified the four of the above items which were non-reportable concerns. Plant information reports were issue The onsite safety committee ensured appropriate corrective action was identified to prevent recurrence. The licensee's performance reflecting the reportable events that occurred during the refueling outage is contained in the Plant Operations section. No violations were identified during this assessment period as a result of re-

-fueling activitie The recent refueling outage reflected significant activity and in-cluded: turbine generator overhaul, 10 year ISI, refueling, steam generators No. 2-4 tube eddy current testing and plugging, secondary side inspections of steam generator Nos. 1-4, main generator exciter and regulator replacement, FW control system replacement, and many modifications and backfits - including the turbine building shear wall seismic modification for the Systematic Evaluation Progra In spite of this considerable workload, the licensee completed the outage safely and essentially on schedule. This was accomplished by augmenting the station staff with appropriate contractor help and assistance from the Yankee Nuclear Service Division staf Updating drawings and procedures to reflect facility modifications implemented during the refueling outage is a licensee strengt In addition, considerable resources are allocated to the development of a Pre-Startup Training Manual, which is utilized to qualify licensed plant operators on the various design changes and modifi-cations made during the refueling outag . Conclusion Category 1, consistent Board Recommendation Non e

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29 Design Control / Quality Assurance (12%)

Analysis The previous SALP identified this topic for consideration as a separate area to specifically address NRC and licensee actions that occurred in that' assessment period. Category 2 performance was assigned, with the most:significant concerns being: untimely reso-lution of' audit findings; unnecessary challenges to the short.ters

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design review effort; incomplete safety evaluation review of system modification; and, weakness.in the safety evaluations performed by

.the onsite review. committe During.this. assessment' period, nine region-based. specialist inspec-tions addressed the QA/QC interfaces in the areas inspected. One region-based specialist inspection reviewed the Quality Assuranc and Non-Licensed Training Programs. .The resident inspector con-ducted. regular observations of activities in this area throughout

.the period. Findings indicate correction of-several previously

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noted deficiencies and identification of several new ones' .

Management involvement and control in assuring quality has shown improvement in this-period. This involvement has aided in correct-ing untimely resolution of audit findings. Licensee audits are-be--

coming increasingly comprehensive, with corrective actions being both timely and responsive. The Quality Audit and Engineering Group is establishing a program to-trend audit and NRC findings, LERs, plant' inspection reports, and nonconformance reports. A computer-ized open item tracking system is'used by site and corporate organi-zations to provide a formal control and accountability for correc-tion'of NRC concern Increased management awareness and involve-ment in site activities has resulted from the licensee's partici-pation in the Combined Utility Assessment Program. This onsite

_ management evaluation has been effective in identifying deficiencies of concern to the NRC and has resulted i_n initiation of appropriate corrective action.

o In the area of design control and safety evaluation review, both strengths and weaknesses are apparen Heavy reliance on Yankee Nuclear Services Division staffing has generally resulted in timely and conservative responses to SEP and IE Bulletin issues. The lic-ensee demonstrates good understanding of the issues and provides a sound and thorough approach to resolution of identified problem Corrective actions to resolve the prior SALP concerns have not been totally successful, in that, the NRC and the licensee have identified deficiencies in design efforts and safety reviews. Examples were:

uthe licensee's response to'IE Bulletin 79-02, Pipe Support Base Plate Designs Using Expansion Bolts; failure to' establish design criteria

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.on planned implemention of the post accident' hydrogen recombiner capability; and installation of a pressurizer code safety valve with a lift setpoint-in excess of~the Technical Specification tolerance Although-improvements have been made, additional: management atten--

tion is necessary to improve performance.in this area.

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-.During review'~of the design control / quality assurance area in this assessment period,-th'ree additional concerns were identified: -QC-

" peer" inspections, non-licensed training,.and=the Operations Qual-ity Group (0QG)..

"A major generic problem, identified during the programmatic QA re-

- view conducted toward the end of the period, involves the lack of-an-independent quality inspection program. The. licensee has relied

.,

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Lupon a " peer" quality control inspection program. This practice-was not' formally documented and is contrary to the existing licensee ,

procedure for quality control inspections. As a result, this item was classified as a violation. However, the current program does-appear.to be very effective. Management attention is required to

, review current practices and identify those areas of procedural-disagreement. -The' desired program should then be formally docu-mented and implemented with appropriate control A review of the training and qualification program for.non-licensed ,

personnel has identified a deficiency involving the lack of a formal '

implementation of the licensee's program for evaluating training effectiveness. Positive indications of management's attempt to-provide improvements in this area include-seeking INPO accreditation for its variousLtraining programs, upgrading the STA training re-quirements, and initiating action for the possible transfer of training responsibilities currently performed by selected operating departments to the Training Departmen Early in the assessment period, the licensee had increased the allo-cated positions for the onsite staff of the Operations Quality Grou '

(0QG) from two to five and assigned the OQG Manager to the Yankee site on.-a part time basi One of the QA inspector positions re-- '

mained vacant for almost the entire assessment period and was only recently filled'by a temporary. contractor. In addition to the

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licensee's 0QG staff being increased, the audit function was trans-ferred from OQG to another QA grou However, the 0QG group sup-

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. plies approximately one-half man years of effort for the performance of the auditing program at other utilities. Further reduction in l the 0QG staffing resulted during the refueling outage when the senior QA Engineer was temporarily assigned non-QA duties without  !

compensation being~provided for his routine ISI QA duties. The

1. '

current 0QG staff size does not allow intensive involvement in any L one particular area without sacrificing coverage in other areas.

L This condition became particularly evident when extensive effort L was required by the station staff to obtain QC inspection coverage l

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as part of the preparation and disposal activities for accumulated-spent' ion exchange' resins. Management evaluation on the effect o lDQA staff size on QA program coverage is' warrante .

. 0verall, the licensee ~has made satisfactory progress in resolving deficiencies in1the design control / quality assurance area. Concerns from the previous SALP period are adequately being addressed; some problems identified during this assessment period still require-resolution. Continued management attention and followup.is neces-

'sary-to ensure the improving trend continue Conclusion Category 2,-improvin . Board Recommendation Licensee

. Continue to improve safety evaluation review and evaluations by onsite review committe Provide'a documented quality control-inspection program for site-

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activities, initiate evaluations of training effectiveness and evaluate 0QA staff size in relation:to QA program coverage require-ment Review the existing quality control inspection program and proce-dures to identify areas of disagreement. Formally document and -

implement desired program with appropriate control NRC-Maintain-inspection effort at the current leve ?

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m . . _ . , _ .. _ _ _ , ,..- _ . _ _ . _ _ ___ _ _ -. _ ._ _ ._ . - , . - _ _ . . - _ . _ - _

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'J. Licensing Activities ~(4%)'

. Analysis'

During the previous-' assessment period, weaknesses were' identified

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in.the following areas: maintaining an appropriate level of commu-nications with the NRC Project' Manager; licensee performance in th development and QA reviews of: safety analysis assumptions; and, lack of a compiled source of plant conditions assumed in the safety analysis for use by the licensee's_ staf This evaluation represents the combined inputs of the Operating Reactor' Project Manager and those technical reviewers who expended significant amounts of effort on Yankee licensing actions during

-

the current assessment. perio In addition, the evaluation contains appropriate observations of the resident inspector as a result of monitoring licensing activity, reviewing implementation of System-atic Evaluation Program commitments, and licensee actions required by NRC I&E Bulletins.' '

'

The basis for this appraisal was the licensee's performance in sup-port of licensing; actions that were either completed or had a sig-

-nificant level of activity during the current assessment perio These actions,. consisting of amendment requests, exemption requests,

responses to generic letters, TMI items, and other actions,.are described in Table , . Licensing actions show consistent evidence of extensive prior plan-ning and work prioritization by the licensee as exemplified by the recent postponement of. its Appendix K exemption request to allow more effort to be assigned to outstanding TMI and generic. issue ,

The willingness to focus:on the license amendment process is an excellent example of the licensee's_ efforts to ensure high quality and to work as efficiently and effectively as possible with the NRC staf Significant improvement has been observed in operating within safety analysis assumptions. Only a single event (LER 84-02).

, was identified by the licensee where plant operations could have potentially been in deviation with the analysis. This improving trend.is attributable to a high level of management involvement that resulted in an appropriate assignment of priority and resource

allocation. ' Continued improvement is expected with the distribution and:use.of a recently published compiled source of safety analysis assumption Senior management involvement has further been apparent by their implementation of the Yankee Project Organization and a computerized Commitment Tracking and Responsibility System. These initiatives have enhanced licensee management participation in and cognizance of current and. anticipated licensing action k ;

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, 33 Licensee's applications and responses are sound and viable. .How-ever, justifications of no significant hazards consideration for;

Sho11y" determinations in.some cases require a significant amount - ,

of additional effort by the NRC Project Manager to determine'the

safety significance because submittals do not contain detailed jus-tification. The basis for proposals with unique. solutions or that rely on existing equipment, procedures, Land /or-operator' action must '

be provided for adequate review of unreviewed safety-question .

Improvement in this area is warranted. The licensee has demonstrated '

a cooperative spirit by: agreeing to modify certain_of its practices to. ensure quality products such as reducing the number of unrelated ,

-topics in each proposal amendment. Licensee submittals are generally considered to be technically adequate. However, concerns have risen- ,

regarding the thoroughness of the technical work. Of particular concern are the changes submitted for proposed amendments that.in-volve many unrelated issues _and the changes submitted under Section 10 CFR 50.54(p) (see Section G, Security and Safeguards).

The analysis of the licensee's reportable events is contained in Plant Operations. YAEC licensing personnel provided timely'notifi-cation to the NRC Project Manager of unplanned plant shutdowns or significant events. The licensee is very responsive to follow-up inquiries by the NRC staff. The NRC staff has noted substantial improvement in event reportin This: improvement is -attributed .to management attention in this area, as well as the licensee's desire ,

-to ensure that the NRC staff is kept fully appraised of plant status

-

and licensing activitie '

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u Generally the YAEC responses to NRC requests are timely and com- ,

, -

pl ete.' -However, a-few selected items such as proposed Technical Specifications .for TMI issues (Generic Letters 82-16 and 83-37) have

.not been-timely. In'.this case the licensee has assigned-this acti-vity a, lower priority in its schedul The prioritization of work, including NUREG 0737 issues, have been discussed with the licensee by the staff. . A timely resolution of'this matter is anticipate In general, the licensee's submittals are typically of high quality -

and fully responsive to NRC staff initiatives,.especially in the SEP areas, most-TMI Action Plan Items and Equipment Qualification-issues. NRC onsite inspection indicated implementation of SEP areas involving water control structures, bypass of thermal overload de-vices, and surface coatings ' inspection program was lacking in thoroughness and dept During reviews of IE Bulletins actions and responses, some weak-nesses were identified by the NRC in both responsiveness and ap-proach to resolution for Bulletins 79-02, 83-07, and 84-03. Pre-venting future inadequacies in this area will necessitate management attentio t

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34 4 IL -Conclusion

- Category 1, consistent Board Recommendation-Licensee Focus attention in all NUREG 0737_ technical specification efforts to provide.near term accomplishment of these tasks, and upgrade-performance in addressing NRC concerns identified in I&E Bulletin ,

Increase attention to providing basis for no significant hazards justification on licensing action Assure accuracy and thoroughness of all licensing submittals in-cluding 50.54(p) item NRC-Non A i

- , v

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a d '.;

. V .' SUPPORTING DATA"AND St#WARIES A'. Investigations, Petitions and4 Allegations Non ~ Escalated Enforcement Actions

. Civil Penalties Non ' Actions Pending/ Resolved A Radwaste Shipment Violation cited by the South Carolina Department of Health and-Environmental Control on July 28,1983 was resolved by the NRC with Notice of Violation i.ssued on January, 6, 1984 Orders

'

Order modifying license dated June 12, 1984, confirming licensee

'

commitments and actions for TMI related requirements contained in-NUREG 0737, Supplement ' Order modifying license dated August 23, 1984, confirming licensee commitment to upgrade emergency response capability with an improved EOF.

[ ,, 4., Confirmatory Action Letters (CAL)

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if Confirmatory Action. Letter No. 84-08, dated April 26, 1984, con-L firming actions required of the licensee in response to NRC identi-L ' fled deficiencies in the Respiratory Protection Progra Management Conferences

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SALP Management Meeting at the Yankee Nuclear Power Station on November 9, 1983.-

Enforcement Conference at the Yankee Nuclear Power-Station on June 21,

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1984; in regard to a violation of Security Plan requirements _ identified

'during Inspection 84-0 Management Meeting at the Yankee Nuclear Power Station'to review the Operator Requalification Program on November 7, 198 ,-

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36 Licensee Event Reports

Type of Events:

.1 Personnel Error.................................... 5-l Design / Mfg /Const/ Install Error. . . . . . . . . . . . . . . . . . . . . 5 l : Exte rnal ^ Cause. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

. : Defective Procedure................................ 2 ' Component Failure................................. 16 ther.............................................. 5

~ Licensee Event Reports Reviewed:

Reports 83-28 to 83-43 and 84-01 to 84-18 Causal Analysis LERs 83-29 and 83-32-involved the loss of one of eight incore ther-

~

nocouple inputs =to the Saturation Monitor due to failure of reactor vessel head connector LERs 83-31, 83-34, and 83-39 are events that involve removal of

'

-equipment or systems from service to facilitate installation of-modifications to upgrade equipment performance or enhance facility operatio LERs 83-33, 83-41, 83-43, 84-00, 84-14, and 84-18 are events due to personnel errors. Reportable events involving errors were about equally distributed in the plant operations, radiological controls, maintenance and surveillance functional area LERs 83-35 and 83-42. occurred as result ~of electrical contact prob-lems: involving the ratemeter card of the No. 4~ Steam Generator

. Blowdown Monito LERs 83-37 and 84-15 involve the loss of the Z-126 transmission line due to trees falling against the line.

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TABLE 1-INSPECTION HOURS SUMMARY (9/1/83 - 1/31/85)

YANKEE NUCLEAR' POWER STATION HOURS % OF TIME Plant Operations......................... 819 33

- . Radiological Controls.................... 260 10 Maintenance.............................. 139 6 Surveillance............................. 164 7

' Fire Protection and Housekeeping.......... 74 3 Emergency Preparedness................... 314 13 Security and Safeguards.................. 136 5 Refueling................................ 176 7 Design Control / Quality Assurance......... 293 12 * Licensing Activities...................... 91 4 i

Total 2466 100%

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• Inspection effort only .

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TABLE 2 VIOLATION (9/1/83 - 1/31/85)

YANKEE NUCLEAR POWER STATION

- Number and Severity Level of Violations Severity Level I 0 Severity Level II 0 Severity Level III 1 Severity Level IV 3 Severity Level V 3 Deviation 0 Total 7 Violation Vs. Functional Area Severity Levels FUNCTIONAL AREAS I II III IV V DEV Plant Operations Radiological Controls 1 1 l' Maintenance

. Surveillance 1

' ' Fire Protection and Housekeeping Emergency Preparedness Security and Safeguards 1 Refueling Design Control / Quality Assurance 1 1 Licensing Activities Totals 1 3 3

,

,. - -- , . , , - - - , , - . +

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39 Summary Inspection- Inspection Severity Functional Report N Date Level Area Violation 83-14 9/1-10/21/83 V B Failure to monitor equipment for radiation / contamination prior to release from the control area IV I Failure to determine cause and implement corrective actions for instrumentation required by Technical Specifications 83-16 -11/18/83 III B Failure to use a strong tight container in shipping radioactive waste 84-05 4/16-20/84 IV B Failure to maintain and-implement written procedures for maintenance of respira-tors and training of per-sonnel-84-06 3/14-5/3/84 IV G Failure to provide proper-compensatory measures when security eqiipment is inoperable 84-20 10/1-11/19/84 V D Failure to c.snduct a re-quired surveillance test on a containm nt isolation valve 85-01 1/14-18/85 V I Failure to fol'.ow procedure requirements fo.' quality control inspect: ins of maintenance acti ities

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TABLE 3 INSPECTION REPORTS ACTIVITIES (9/1/83 - 1/31/85)

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, YANKEE NUCLEAR POWER STATION Ihspection- Inspection Areas

< ~ Report N Hours : Inspected 83-13 62 '

Emergency Preparedness PNS and EPIA Followup 83-14? 98 Routine, Resident 83-15- 110 Routine, Resident'

l 83-16- 6 Radioactive Waste Shipment

> _

84-01 255 Routine, Resident

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84-02 10 Special-Failure Analysis and Steam Generator Water

[- Box Pipe Replacemen Emergency Preparedness EPIA Followup

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I 84-04 60 Radioactive Waste Management Program 84-05' 32 Radiation Protection Program

'84-06 31 -Special, Security Program-84-07- 286 Routine, Resident Refueling 84-08 26 Inservice-Inspection Program 84-09 32 .iecurity and Safeguards

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84-10 --

License Examinations'

84-11 24 Ccntainment Leak Rate Testing

'84-12 28 Emergency Preparedness 84-13 193 Rou'.ine, Resident

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84-14' 143 Response to IE Bulletins

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84-15 36 Radiation Protection Program 84-16 --

Enforcement Conference Meeting - Security Issues l.-

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. -

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at - -

[ 41

- Inspection -Inspection Areas Report N Hours Inspected I-84-1 ' .Special, Review Incident involving Switchgear Electrical Fault and Fire 84-18 170 Emergency Preparedness - Emergency Drill >

84-19 -

30- Degraded Grid Voltage Procedures

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-84-20 193 Routine, Resident 84-21> 53 Security and Safeguards 84-22- 52 Radioactive Waste and Transportation Activities 84-23 :108 Routine, Resident 84-24 --

Inspection Number Cancelled 84-25' 24= -Nonradiological Chemical Program

. :85-01 104 Quality Assurance 85-02 90 Routine, Resident 85-03 ---

License Examinations

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TABLE 4 TABULAR LISTING OF LERS BY FUNCTIONAL AREA YANKEE = NUCLEAR POWER STATION Area Number /Cause Code Total Plant Operations 1A 2B 2C 10E 2X 17 Radiological Controls IA 2E 3 4 Maintenance 2A 1D 1E 4 ' Surveillance 1A 1B 2E 4 Fire Protection 2X 2

, Emergency Preparedness 1E 1X 2 Security and Safeguards 0

< Refteling 1B 1 Design Control / Quality Assura.nce

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1B 1 Licensing Activities ID 1 TOTALS SA 5B 2C 2D 16E SX 35 l

l Cause Codes Personnel Error Design / Mfg /Const/ Install Error

External Cause Defective Procedures

- Component Failure

' Other l.

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TABLE 5 LER SYNOPSIS (9/2/83 - 1/31/85)

YANKEE NUCLEAR POWER STATION

'LER'No. Type . Summary Description 83-28 30' day During heatup in Mode 3, a leak caused by steam erosion in a piping elbow of a high. pressure steam drain line was discovered 83-29 30 day The Saturation Monitor failed while in Mode 2 due to the failure of incore thermocouple G-10's connector on the Reactor Vessel head 83-30 30 day Body to bonnet flange leak on Main Steam Condensate Drain Line Valve AS-V-641 due to a failed gasket 83-31 30 day Primary Meteorological Monitoring System removed from service for data transmission subsystem modification-83-32 30 day The-Saturation Monitor failed while in Mode 1 due to the failure of incore thermocouple F-7's connector on the Reactor Vessel Head 83-33 30 day Primary Vent Stack Noble Gas Monitor failure due to moisture in the detector caused by personnel error due to lack of a procedure and training 83-34 30 day Fire System yard hydrants 14 and 15 inoperable to facili-

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tate construction of an addition'to the Waste Disposal Building 83-35 30 day No. 4 Steam Generator Blowdown Monitor failure due to buildup of dirt and tarnish on electrical contacts within the socket of the ratemeter card 83-36 30 day Control Rod No. 11 primary position indicator channel inoperable due to a loose connection 83-37 30 day Loss of Z-126 transmission line due to fallen tree with a resultant manual reactor scram 83-38 30 day Momentary failure of the No. 2 Vital Bus Inverter while in Mode 1 due to improper assembly of its transfer switch during manufacturing L

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-LER N Type - Summary Description 83-39 30 day Cable Tray House and Non-Return Valve Enclosure fire detection system out of service to facilitate implemen-tation of a design change involving system improvements 83-40 30 day- Primary Meteorological Monitoring System lower level wind direction instrumentation inoperability due to transmitter failure-83-41 30 day While' performing troubleshooting, the No 3 Emergency bus was inadvertently de-energized.by a personnel error in-volving the opening of a slide link in the undervoltage relay circuitry 83-42 30 day No. 4 Steam Generator Blowdown Monitor failure due to improper contact between the circuit board and socket

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contacts for the ratemeter card 83-43 30 day Surveillance test for the SI Accumulator time delay relay missed due to scheduling error

- 84-01- 30 day Loop 1 Steam Generator water box vent line through-wall pin hole main. coolant leak resulting in an unusual Event and a plant shutdown 84-0'2 30 da Systematic Evaluation Program (SEP) Topic VI-10.A review resulted in discovery of-an Emergency Diesel Generator

response time surveillance procedural inadequacy caused by. failure'to reflect an updated LOCA analysis contained in license amendments 84-03

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30 da Two containment isolation valves, VD-SOV-301 and 30'2 failed to actuate automatically at < 5 psig during Type A Integrated Leak Rate Test (ILRT) due to a design inade-quacy involving 'a failure to account for.an operating

. vacuum 84-04 .30 day During core alterations fuel assembly B-636 was discovered to be damaged by flow-induced fretting at the baffle side of core position C-9 S

84-05 --

Unassigned

'84-06 .30 day Type B & C leak rate testing identified components with

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leakages:in excess.of technical specification limits 84-07 '30 day Support Deficiencies of portions of small bore piping systems inside containment identified during Cycle XVI-

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XVII refueling outage Review for SEP Topic III-6 with cause determined to be related to'an original construction error by the architect / engineer

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_ _ _ _ _ _ _

, _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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LER N Type Summary Description 84-08 30 day During the refueling outage, actuation of the three Emergency Diesel Generators occurred due to loss of power to the station resulting from switchyard maintenance inspection procedural inadequacy 84-09 30 day During the refueling outage, actuation of the No. 1 Emergency Diesel Generator due to a loss of power to the No. 1 emergency bus due to failure of contractor personnel to lift a lead in control circuitry 84-10 30 day Type B & C leak rate testing identified components with leakage in excess of technical specification limits 84-11 30 day Safety Valve PR-SV-182 exceeded technical specification tolerance due to manufacturer setting valves to ASME Code and not procurement document; system function not compro-mised j

84-12 30 day Reactor scram from full power with cause of trip specified as indeterminable 84-13 30 day Switchgear room fire involving 489V Bus 4-1 resulting in Alert and plant shutdown; electrical fault attributed to failure of contact retainer ring on breaker finger cluster 84-14 30 day Two inadvertent initiations of ECCS with plant in Mode 3, with the first being due to indeterminable cause and second due to failure of the No. 1 Main Coolant Loop Pressure Channel; as well as Low Pressure Safety Injection Accumulator System inoperability due to improper installa-

, tion of a swagelock cap depressurizing the Accumulator  ;

below the technical specification limit '

h l

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84-15 30 day Loss of the Z-126 transmission line due to a fallen tree ,

with a resultant manual scram l

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84-16 30 day Plant scram from full power initiated by actuation of the Main Generator loss of field relay by overload trip of the static exciter's supply transformer 84-17 30 day Manual reactor scram from 61 percent power due to ob-y served Main Generator rotor collector ring arcing 84-18 30 day Automatic reactor scram during startup initiated by low water level on 2 of the 4 steam generators; cause attri-buted to personnel error of a licensed operator

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TABLE 6 SU N RY OF LICENSING ACTIVITIES

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YANKEE NUCLEAR POWER STATION NRR Site Visits June 1984 Procedures Generation Package October 1984 Detailed Control Room Design Review (DCRDR) In-Progress Audit Schedular Extensions Granted June 8, 1984 10 CFR 50.44 (c)(3)(ii) Hydrogen Recombiner Exemption October 23, 1984 Exemption request from Annual Emergency Preparedness Exercise schedular requirements not required due to re-vision of Appendix E January 11, 1985 NUREG 0737 Supplement 1- Modification of Order for sub-mittal date for DCRDR Summary Report Relief Granted January 3, 1984 Inservice Inspection Requirements Exemptions Granted and Denied October 5, 1983 Exemption from 10 CFR 50.44(c)(3) (ii) Hydrogen Recom-biner Capability - Denied January 17, 1984 Inservice Inspection Exemption from requirements for Personnel Performing Hydrostatic Exams - Denied

~0ctober 30, 1984 Exemption from seismic and redundancy requirements of 10 CFR 50.44 (c)(3)(ii)- Granted

- 5. License Amendments Issued and Denied Amendment No. 81, Inservice Inspection, January 3,1984 Amendment No. 82, Core XVII Refueling, June 5, 1984 Proposed Technical Specifications to delete certain cycle dependent vari-ables - Request denied February 9, 1984

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47 TMI and Other Actions Action Completion Date TMI Item II.K.3.17 Outages of Emergency Core Cooling Systems- August 8, 1983-TMI Item II.B.1 Reactor Coolant System Vents August 19,1983 Change to Security Plan Approval September 12, 1983 Equipment Qualification Approval September 27, 1983 Low Power Physics Test Problems October 5, 1983 TMI Item II.F.2 Inadequate Core Cooling Instrumentation October 24, 1983 Generic Letter 81-21 Natural Circulation Cooldown October 25, 1983 Solid Waste Process Control Program Approval November 2, 1983 Main Steam Line Break Analysis Approval for Cycle XVI November 30, 1983 TMI Item II.K.3.1. Auto Power Operated Relief Valve-Isolation December 13, 1983 TMI Item II.K.3.2 Report on Power Operated Relief Valves December 13, 1983 TMI Item II.K.2.17 Potential for Voiding in RCS During December 22, 1983 Transient Review of Asymmetric Loss of Coolant Accident Loads February 1, 1984 Seismic Qualification of Auxiliary Feedwater System February 23, 1984 Reactor Vessel Examination (ISI) Approval February 28, 1984 Seismic Analysis of Modified Spent Fuel Storage Pool March 30, 1984 Approval TMI Item I.A.1.1 Shift Technical Advisor Long Term May 14, 1984 Requirements Reanalysis of Main Steam Line Rupture Event June 5, 1984 TMI Item I.C.1.2.1 Inadequate Core Cooling Guidelines June 7, 1984

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TMI Item I.K.2.13 Thermal Mechanical Report June 13, 1984 t

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Action Completion Date Generic. Letter 83-28 Item 4.3 Auto Shunt Trip for Scram August 9, 1984 Breakers Hydrologic Issues October 30, 1984 Appendix G Curve Shift December 3, 1984 Degraded Grid Voltage Protection for Class 1E Systems January .4,1985 DCRDR In Progress Audit Report January 7, 1985 Water Chemistry Issues ' January 10, 1985

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TABLE 7 l l l UNPLANNED AUTOMATIC SCRAMS I I I l 1 I I I Date l Power Level (%) l Cause l l l 1 l l 1 I l l 10/5/83 1 100% ILoss of Z-126 115KV Transmission Line l I I 1[ Manual Scram] ]

l l l 1 I 7/12/84 l 100% IUndetermined cause i I I I i 1 9/4/84 1 100% ILoss of Z-126 115KV Transmission Line l

~ I 1[ Manual Scram] l I I I I 1 9/14/84 1 100% IMain Generator Loss of Field Relay Due l

.I I Ito Static Exciter Overload l 1 -

1 -

1 I i 11/12/841 59% lArcing in Main Generator Exicter's i I I ICollecting Ring Brushes [ Manual Scram] l l l 1 l 1 11/16/841 12-13% l Low Level on 2/4 Steam Generators I l I l l I I I I I I I FORCED OUTAGES l l l l l I Date 1 Power Level (%) l Cause l r- l 1 l l

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l 1 1 I

, 1 1/24/84 1 100% lThrough Wall Pin Hole Main Coolant Leakl i-I 1 lin No. 1 Steam Generator Water Box Vent!

l I lLine i

.

I I i 1 j l 6/9/84 1 25% l Turbine Governor Low Oil Pressure I i

I I l Condition 1 I I i 1

'. l 7/12/85 l 100% INo. 4 Main Coolant Pump Check Valve t

I l l Cover Flange Leak [

I I I I l

! l 8/2/84 l 100% l Electrical Fire in 480 Volt Bus 1 I I I I i 11/2/84 1 59% IArcing in Main Generator Exciter's [

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, i 1 lColleting Ring Brushes l l I I l i I I I l

( I I l

TATES ENCLOSURE 2

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- I NUCLEAR REGULATORY COMMISSION REClON I

• h ,#,[ 631 PARK AVENUE

%, KING OF PRUSSIA, PENNSYLVANIA 194o6 Docket No. 50-29 APR 0 81985 Yankee Atomic Electric Compa ATTN: Mr. L. H. Heider Vice President of Operations 1671 Worcester Road Framingham, Massachusetts 01701 Gentlemen:

Subject:

Systematic Assessment of Licensee Performance (SALP) Report N /85-99 The NRC Region I SALP Board has reviewed and evaluated the performance of activi-ties at the Yankee Nuclear Power Station for the period of September 1, 1983 through January 31, 198 enclosed SALP Board Report The datedresults Marchof29, this assessment are documented in the 198 A meeting to discuss the assess-ment is scheduled for April 30,1985, at 11:00 a.m. in the Region I offic At the SALP meeting, we request that you be prepared to disr.ess our assessment and your plans to improve performance in those areas warranting improvement. The meeting is intended to be a dialogue wherein any comments you may have regarding our report may be discusse Additionally, you may provide written domments within 20 days after the meetin Your cooperation is appreciate

Sincerely, i

.

Thomas E. Murley I Regional Administrator

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Enclosure: SALP Report No. 50-29/85-99  !

cc w/ encl: l N. N. St. Laurent, Plant Superintendent j J. E. Tribble, President i J. A. Kay, Senior Engineer - Licensing  !

Public Document Room (PDR)

l Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC) l NRC Resident Inspector ,

I Commonwealth of Massachusetts (2)  !

'lh