ML20136E548

SALP Rept 50-271/85-99 for Nov 1984 - Oct 1985

ML20136E548
Person / Time
Site:	Vermont Yankee
Issue date:	12/31/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20136E540	List: ML20136E536 ML20136E548
References
50-271-85-99, NUDOCS 8601070049
Download: ML20136E548 (50)

See also: IR 05000271/1985099

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U. S. NUCLEAR REGULATORY COMISSION

REGION I

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

INSPECTION REPORT 50-271/85-99

VERMONT YANKEE NUCLEAR POWER CORPORATION

VERMONT YANKEE NUCLEAR POWER STATION

ASSESSMENT PERIOD: NOVEMBER 1, 1984 - OCTOBER 18, 1985

BOARD MEETING OATE: DECEMBER 2, 1985

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8601070049 851231 N

, PDR ADOCK 05000271

i G PDR

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TABLE OF CONTENTS

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Page

I. - INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . 1

A. Purpose and Overview. .................. 1

B. SALP Board Members. . . . . . . . . . ......... 1

C.- Background. . . . . . . . . . . . . ........ 2

II. CRITERIA-. . . . . . . . . . . . . . . . ...... 4

~ III. ~ SUMMARY OF RESULTS ............ ..... 6

A. Facility Performance. . . . . . . . . . . . . . . . . . . 6

B. Overall Facility Evaluation.. . . . ........... 6

IV. PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . . . . 9

A. Plant Operations. .................... 9

B. Radiological Controls . . . . . . . . . . . . . . . . . . 12

C. Maintenance and Modifications . . . . . . . . . . . . . . 16

D. Surveillance. . . . . . . . . . . . ........... 20

E. Emergency Preparedness. . . . . . . . . . . . . . . . . . 22

F. Security and Safeguards . . . . . . . . . . . . . . . . . 24

G. Refueling and Outage Management . . . .......... 26

H. Quality Assurance . . . . . . . . . . . . . ....... 28

1. Licensing Activities. . . . . . . . . . . . . . . . . . . 32

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V. ' SUPPORTING DATA AND SUMMARIES. . . . . . . . . . . . . . . . 35

A. Investigation, Petitions and Allegations. . . . . . . . . 35

B. Escalated Enforcement Actions . . . . . ........ 35

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C. Management Conferences. . ................ 35

D. Licensee Event Reports. . . . . . . . . . . . . . . . . . 37

TABLES

TABLE 1 - LISTING OF LERS BY FUNCTIONAL AREA .......... T1-1

TABLE 2 - LER SYNOPSIS ..................... T2-1

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TABLE 3 - ENFORCEMENT SUMMARY . . . . . . . . . . . . . . . . . . T3-1

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TABLE'4.- INSPECTION HOUR SUMMARY . . . . . . . . . . . . . . . . T4-1

TABLE 5 - INSPECTION REPORT ACTIVITIES ............. T5-1

TABLE 6 - SUMMARY OF LICENSING ACTIVITIES . . . . . . . . . . . . T6-1

, TABLE 7 - PLANT SHUTDOWNS . . . . . . . . . . . . . . . . . . . . T7-1

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I INTRODUCTION

A. 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 license performance based on this infor-

mation. SALP is supplemental to normal regulatory processes used to

erasure 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 operation.

A NRC SALP Board, composed of the staff members listed below, met on

December 2, 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 report.

This report is the SALP Board's assessment of the safety findings at the

Vermont Yankee Nuclear Power Station for the period of November 1, 1984

through October 18 1985. The summary of findings and totals reflect

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a twelve month assessment period, instead of the 18 month period recom-

mended by the previcus SALP Board. The abridged assessment period was

selected by Region I management due to the extended pipe replacement out-

age that began in September, 1985, and the need to better utilize inspec-

tion resources during the plant restart scheduled in the Spring of 1986.

B. SALP Board Members

R. W. Starostecki, Director, Division of Reactor Projects (DRP), Chairman

S. D. Ebneter, Director, Division of Reactor Safety (DRS)

W. Kane, Deputy Director, DRP

R. R. Bellamy, Chief, Emergency Preparedness & Radiological Protection

Branch, Division of Radiation Safety and Safeguards (DRSS)

E. C. Wenzinger, Chief, Projects Branch No. 3, DRP

L. E. Tripp, Chief, Projects Section No. 3A, DRP

L. H. Bettenhausen, Chief, Operations Branch, DRS

J.11. Joyner, Chief, Nuclear Materials Safety and Safeguards Branch, DRSS

V. L. Rooney, Senior Project Manager, Project Directorate No. 2, Office

of Nuclear Reactor Regulation (NRR)

B. Sheron, Deputy Director, Division of Safety Review and Oversight

(DSRO),NRR

W. J. Raymond, Senior Resident Inspector

Other Attendees

W. J. Pasciak, Chief, BWR Radiological Protection Section, DRSS

G. W. Meyer, Project Engineer, PS 3A, DRP

M. Shanbaky, Chief, PWR Radiological Protection Section, DRSS

P. K. Eapen, Chief, Quality Assurance Section, DRS

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C. Background

1. Licensee Activities

The plant was operating at 100% power at the start of the assessment

period at the beginning of core Cycle XI.

Two forced power reductions occurred during November 1984 due to

the loss of a single recirculation pump. The first occurred on

November 11, 1984 due to a failed tachometer on the "B" recircula-

tion pump motor generator. Full power operation resumed the same

day following replacement of the tachomoter. Five days later, a

second power reduction occurred due to the loss of the "A" recircu-

lation pump when an auxiliary operator inadvertently tripped the

motor control center 6A feeder breaker, causing a loss of the lube

oil pump. The lube oil pump was restarted and full power operation

resumed.

The plant remained at full power until February 6, 1985, when a

turbine trip and reactor scram occurred during the performance of

an I&C logic test on the core spray system. The plant remained

shutdown for 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> until the cause of the event, a faulty test

switch in the core spray system logic, was identified and replaced.

The plant returned to full power operaticns.

The annual emergency full scale exercise was cctiducted during the

assessment period. Participation in this event, in addition to the

NRC, included the states of Vermont, New Hampshire and Massachusetts,

FEMA and local emergency response organizations. The exercise is

discussed further in the report.

The plant began an end-of-cycle power coastdown in July, 1985. On

September 10, 1985, a third power reduction occurred due to the loss

of a recirculation pump, which tripped as a result of a false close

signal originating in the pump suction valve isolation circuitry.

The necessary repairs were made and the reactor coastdown continued

until September 20, 1985 when the plant was shutdown for the 1985-86

recirculation pipe replacement and refueling outage.

At the close of this assessment period, the core was completely

unloaded into the spent fuel pool, and the plant was preparing to

decontaminate the recirculation system piping. ,

2. Inspection Activities

One NRC resident inspector was assigned to the site during the en-

tire assessment period. A second resident inspector was assigned

to the site at the end of the assessment period as part of the NRC

staffing plan to place two residents at each operating site. The

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total NRC inspection hours for this twelve month period was 2653

hours (resident and region based) with a distribution in the ap-

praisal functional areas as shown in Table 4.

NRC Emergency Preparedness teams observed and participated in the

the emergency exercise on April 17, 1985.

A special team inspection of the licensee actions in response to

Generic 1.etter 83-28, Salem ATWS followup, was conducted on June

6-12, 1985.

A special team inspection of the licensee's corrective actions

for deficiencies identified in the receipt inspection program

was conducted on September 2-6, 1985.

Tabulations of Violations and Inspection Activities are attached

as Table 3 and 5, respectively.

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II. CRITERIA

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Licensee performance is assessed in selected functional areas, depending on

whether the facility is in a construction, preoperational, or operating phase.

Each functional area normally represents areas significant to nuclear safety

and the environment, and are normal programmatic areas. Special areas may

be added to highlight significant observations.

One or more of the following evaluation criteria were used to assess each

functional area.

1. Management involvement and control in assuring quality

2. Approach to resolution of technical issues from a safety standpoint

3. Responsiveness to NRC initiatives

4. Enforcement history

5. Reporting and analysis of reportable events

6. Staffing (including management)

7. Training effectiveness and qualification

However, the SALP Board is not limited to these criteria and others may have

been used where appropriate.

Based upon the SALP Board assessment, each functiona; crea evaluated is clas-

sified into one of three performance categories. The definitions of these

performance categories are:

Category 1. Reduced NRC attention may be appropriate. Licensee management

attention and involvement are aggressive and oriented toward nuclear safety;

licensee resources are ample and effectively used so that a high level of s

performance with respect to operational safety or construction is being

achieved.

Category 2. NRC attention should be maintained 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 achieved.

Category 3. Both NRC and licensee attention should be increased. Licensec

management attention or involvement is acceptable and considers nuclear safety,

but weaknesses are evident; licensee resources appear to b2 strainad or not

effectively used so that minimally satisfactory performance with respect to

operational safety or construction is being achieved.

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The SALP Board also assessed each functional area te 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 dete.-mine the recent trend for each functional

area. The trend categories used by the SALP Board are as follows:

Improving: Licensee performance has generally improved over the last quarter

nf the current SALP assessment period.

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Consistent: Licensee performance has remained essentially constant over the

last quarter of the current SALP assessment period.

Declining: Licensee performance has generally declined over the last quarter

of the current SALP assessment period.

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III SUMMARY OF RESULTS

A. Facility Performance

CATEGORY CATEGORY

FUNCTIONAL AREA LAST THIS Recent

PERIOD * PERIOD ** TREND ***

Plant Operations 1 1 Consistent

Radiological Controls 2 2 Consistent

Maintenance and Modifications 2 1 Consistent

Surveillance 1 1 Consistent

Fire Protection and

Housekeeping 2 N/A N/A

Emergency Preparedness 1 2 Improving

Security and Safeguards 1 2 Declining

Refueling and Outage 1 1 Consistent

Management

Quality Assurance 2 2 N/A

Licensing Activities 1 1 Consistent

• May 1, 1983 to October 31, 1984 (18 months)

• • November 1, 1984 to October 18, 1985 (12 months)

• • • Trend during last quarter of the current assessment period

B. Overall Facility Evaluation

During the previous assessment period, increased management attention

was necescary in the functional areas of Plant Operations, Radiation

Protection, Maintenance, followup of Appendix R modifications and site

0"sifty Assurance. More aggressive involvement was needed in Radiation

Protection to formalize the ALARA program, promptly resolve anomalies,

and improve the frisking policy. Actions to meet Appendix R requirements

needed to be aggressively completed in accordance with NRC positions.

The Maintenance area required strengthening of supervisory oversight and

QA/QC controls. The philosophy regarding plant operations in an anomalous

state needed to be more conservative.

Improvements were noted in the Operations, Maintenunce and Fire Protec-

tion areas during the current assessment period. Improvements were also

noted in the Radiation Protection area in the frisking program and in

the resolution of technical issues.

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While improvements were realized as indicated above, other programmatic

problems were noted by the NRC which were not identified by the licensee.

These included programmatic deficiencies identified as the result of NRC

followup of events such as the following: unplanned exposure (Radiological

Control), false receipt inspection records (Quality Assurance), and im-

proper plant access (Security). In the SALP Board's opinion, there is

a licensee mindset stemming from his expertise, vast experience and

generally good past performance, which results in a reluctance to ac-

knowledge weaknesses and hinders recognition of areas where improvements

can be achieved. There is an NRC perception that there is less than full

support and/or use by licensee management of the QA/QC function to pro-

vide a viable feedback to measure and review station performance. It

was noted that once the NRC communicates concerns to the licensee, man-

agement actions are generally responsive and thorough to address the is-

sues. The SALP Board has concluded that VY management needs to be more

aggressive in self evaluation, and more open and receptive to opportuni-

ties for improvement.

The strength of the licensee's management controls is most notable in

the conservative approach taken to assure safety in plant operations,

the planning and control of outage activities and design changes, the

effective housekeeping program, the completion of licensing actions,

and in the preventive maintenance and operational surveillance programs.

This assessment noted reductions in the numbers of personnel errors dur-

ing the performance of routine duties in the Surveillance, Radiological

Controls, Operations and Refueling functional areas. Licensee management

was effective in assuring an adverse trend did not develop to lower

performance.

Although the licensee met commitments to improve procedures and personnel

performance in the Maintenance area, previcus corrective actions were

insufficient to correct deficiencies in the onsite QC " peer" inspection

process for maintenance and other plant activities. Management attention

is required to assure corrective actions a'e r sufficiently detailed in

scope to not only correct the apparent problems when identified, but also

to promptly identify and correct other deficiencies that may lessen ef-

fective program implementation. Additional actions are also required

to improve vendor interface controls.

The overall performance in the support areas of Radiation Protection,

Security, and Emergency Planning was not as good as that in functional

areas that have a direct bearing on plant operating safety. Additional

management attention is warranted in these areas to assure: better over-

sight of the security contractor and effective program implementation;

the emergency response organization communication and control functions

are strengthened; and, detail and structure is added to the ALARA program.

The licensee should also review, in particular, the radiation protection

program procedures to assure they are sufficiently detailed to preclude

additional problems from occurring.

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The need for open and candid communication with the NRC staff was iden-

tified as an area requiring greater management attention during this as-

sessment period. While improvements have been noted, additional attention

to this item is required to assure licensee identified deficiencies are

promptly communicated to the NRC.

Although training was considered in the overall rating of each functional

area of this report, a summary is provided below from an overview stand-

point. Quality assurance activities affect the assessment in several

functional areas, but QA has also been included as a separate functional

area in recognition of observed problems, past history, and NRC inspec-

tion resources devoted to this area. A summary of activities in the Fire

Protection area is provided below to highlight the progress of actions

taken in response to problems noted the previous assessment. Assessment

of performance in the Housekeeping and Fire Protection / Appendix R Areas

are included in the Plant Operations and Licensing functional areas,

respectively.

Training

The licensee maintained a strong commitment to training in the licensed

and non-licensed programs as demonstrated by the plant specific simulator

and training labs now nearing completion and scheduled for initial

operation during the next assessment period. Actions are in progress to

achieve INPO accreditation for the licensed operator training program.

The generally low rate of personnel performance errors is indicative of

training program effectiveness in each functional area. Another indica-

tion of effectiveness is the generally high level of knowledge exhibited

by personnel in all disciplines.

Fire Protection

This area received a Category 2 rating during the last assessment due

to the licensee's incorrect implementation of Appendix R requirements

and their slowness in responding to the NRC once the deficient areas

were noted. Based on subsequent licensee responses to issues and actions

to complete a reanaly' sis of the Reactor building in November 1984, the

licensee demonstrated an increased sensitivity and responsiveness to Ap-

pendix R issues. The routine fire protection programs and plant house-

keeping remained an element of strength during this assessment period.

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IV. PERFORMANCE ANALYSIS

A. Plant' Operations (822 hours0.00951 days <br />0.228 hours <br />0.00136 weeks <br />3.12771e-4 months <br />; 31%)

1. Analysis

The area was rated as Category 1 during the previous period with

problems noted in response to NRC initiatives on procedure improve-

ments, the need to encourage attention to detail in the performance

of routine duties to reduce personnel errors, and, the need to take

a more conservative approach in response to apparent operational

anomalies.

Plant operations were monitored by the resident and regional in-

spectors during the assessment period. Improvements were noted in

all areas. A strong commitment to safety in plant operations was

evident in the licensee's response to apparent and potential equip-

ment problems. Although there were no instances during the period

involving operation under anomalous conditions, licensee responsive-

ness indicated that improvements can be expected in this area.

Plant and corporate management involvement in plant operational

activitics have been evident by plant visits, routine reviews of

logs, and tours of the facility. Management actions were completed

to stabilize supervision of the Operations Department, and the re-

structuring of the operations support staff should be beneficial

in developing resources from within the department. The transition

between Operations Supervisors occurred smoothly, and actions were

taken to define the incumbent's duties within the restraints of

Technical Specification 6.0 pending completion of a senior operator's

certification.

Plant operators have consistently shown a good overall understanding

of plant systems and status, and are sensitive to equipment problems

that may involve technical specification LCOs. Operators make con-

sistently conservative calls regarding equipment operability, and

questions regarding technical specification LCOs are discussed with

the NRC staff before they become compliance issues. Plant logs and

records are well maintained. Operations personnel and the Opera-

tions Supervisor in particular have displayed positive and conser-

vative approaches toward safety and regulatory compliance. The lic-

ensee demonstrated an aggressive and conservative response to equip-

ment problems and operability issues during the assessment period.

No generic or overall programmatic weaknesses were noted as a result

of the two sets of license examinations given during the assessment

period in January 1985 and in March 1985. Three of the four candi-

dates for upgrade to SR0 or Instructor Certification in January

failed due to weakness in theory and procedures. The five candi-

dates examined in March passed the written exam and demonstrated

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an appropriate depth of knowledge during the oral examinations.

Vermont Yankee has had training department organization changes

- within the last six months and is continuing to upgrade their

training program. The simulator installation has been delayed until

early 1986. The overall training program effectiveness for both

requalification and initial license training is expected to improve

greatly with the use of the simulator. ~

One area where management oversight of operator training was lacking

concerned the effort to implement the new symptom oriented emergency

operating procedures (EOPs) without full support from the operator

ranks. Operator questions regarding the new E0Ps were not fully

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answered a6d, even though the proposed procedures and plans were

adequate, that information was not adequately communicated to the

operators. .The operators did not receive sufficient training on

the new procedures to be familiar enough with them for implementa-

tion. There was inadequate management evaluation, sensitivity and/

or communication with licensed operators to identify their lack of

readiness to implement the new E0Ps. NRC action was required to

solicit further feedback from the operators regarding their readi-

ness to implement the E0Ps. When NRC identified the problem in this

area,.the licensee provided the' additional simulator training needed

to increase operator familiarity and confidence with the procedures

prior to their implementation. Continued management attention is

warranted in this area to assure operations supervision remains open

and responsive to operator feedback.

There were no violations identified in this area, and the one plant

trip during the period (LER 85-04) was caused by equipment failure.

There has been an observed improvement in the area of adherence to

procedures. No LCO violations were identified by either the licen-

see or the NRC during the assessment period. There were 6 in-

stances of personnel error noted during the period, but only 2 of

the 6 had operational significance. The number of personnel errors

is considered minimal and improvements in this area were noted.

This is indicative of an effective training program.

NRC staff observations of PORC activity during the assessment period

indicate the committee is serving its intended function. Good

technical discussions occur on issues requiring resolution and the

committee displayed the proper regard for nuclear safety issues.

PORC followup of outstanding items is appropriate and effective.

NRC inspectors noted in January 1985 that sixty-five plant procedures

remained unreviewed for a period of up to 17 months past their re-

quired biennial review date. The licensee acknowledged that this

problem was a continuing concern and noted that the backlog of

overdue procedure reviews which numbered 110 in November 1984 had

beer reduced to 30 in November 1985. This problem was first noted

as a concern during an NRC audit in 1980 and the recurrence of the

overdue procedure reviews is addressed further as a QA concern in

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Section H below. Licensee management attention is required to as-

sure PORC reviews of plant procedures are completed in a timely

manner.

NRC staff assessment of control room protocol during the assessment

period found that the control room environment is maintained in a

manner conducive to safe and efficient operation. The facility was

consistently maintained in a good condition of cleanliness. Good

plant housekeeping practices during routine and shutdown operations

were evident throughout the assessment period. The routine fire

protection program was maintained and well implemented during the

period. Fire detection and protection equipment were well main-

tained and controlled.

A detailed evaluation of LER quality using a sample of 8 LERs issued

during the assessment period was made by AEOD using a refinement

of the basic methodology presented in NUREG/CR-4178. In general,

they found these LERs to be of barely acceptable quality based on

the requirements contained in 10 CFR 50.73. There were two LERs

submitted for this functional area and both were caused by equipment

failures. There were no adverse trends noted. A generally conser-

vative approach is taken in the reports made under 10 CFR 50.73.

In summary, the strength of the licensee's management controls in

this area is best demonstrated by the conservative approach taken

to assure safety in plant operations whenever equipment problems

or operability issues arise. The long period of operation with only

one reactor trip (due to equipment problem) and the minimal number

and significance of personnel errors were especially noteworthy.

2. Conclusion

Rating: Category 1

Trend: Consistent

3. Board Recommendations

Licensee:

Continue to improve communications within the Operations Department.

Consider the use of PORC subcommittees for the review of plant

procedures to assure biennial review dates are met.

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B. Radiological Controls (351 hours0.00406 days <br />0.0975 hours <br />5.803571e-4 weeks <br />1.335555e-4 months <br />, 13%)

1. Analysis

The licensee's Radiological Controls Program was rated as Category

2 during the previous assessment period due to weaknesses in the

ALARA and contamination survey programs and problems in the trans-

portation program.

During the current assessment period, a major problem in the radi-

ation protection program area involving unplanned exposure during

Traversing In-Core Probe (TIP) room entry and several other weak-

nesses were identified. Six specialist inspections were performed

of the Radiological Controls Program plus periodic coverage by the

resident inspector. A civil penalty was proposed and a Confirmatory

Action Letter was issued regarding the TIP room unplanned exposures.

1.1 Radiation Protection

The unplanned radiation exposure of a technician in the TIP

room indicated procedures for control of exposures in locked

high radiation areas were informal and poorly defined. The

technician had not been adequately instructed in precautionary

actions or procedures to minimize radiation exposure if high

exposure rates were encountered. TIP room entry procedures

had not been provided despite suggestions from the NRC that

they were needed. Following the unplanned exposure, permanent

administrative control procedures regarding TIP room entries

and entries into other similar high radiation areas were pre-

pared by the licensee in response to NRC initiatives, including

Confirmatory Action ~ Letter 85-15.

Additional weaknesses were noted in licensee procedures con-

cerning radiation work permits and personnel dosimetry. Tech-

nically sound and thorough revisions were made by the' licensee

in response to these NRC concerns.

The need for a formalized "As Low As Reasonably Achievable"

(ALARA) program has been brought to the licensee's attention

on several occasions since the issue was identified during the

Health Physics Appraisal in 1980. Although the licensee's

piping replacement contractor had developed and was implement-

ing a formalized ALARA program to support piping replacement,

the licensee had not formalized a station wide ALARA program.

The ALARA program lacked an adequately stated and understood

management policy statement providing a commitment to ALARA.

The ALARA committee's charter did not define the term "high

radiation exposure jobs" within that committee's purview. For-

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mal procedures for ALARA instructions, preoperational briefings,

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use of engineering controls, practice in low radiation exposure

areas and scheduling tasks to reduce radiation exposures were

not in place. Outage activities (outside piping replacement)

, were governed by "VY ALARA Guidelines". Those guidelines were

not reviewed, approved and implemented as controlled plant ad-

ministrative procedures. Radiation workers were not aware of

the means to input ideas for dose reduction and improved health

physics practices provided in the guidelines. This long-

standing regulatory issue needs licensee management attention

to formalize and improve the station ALARA program. Requiring

a more structured and disciplined approach, in the SALP Board's

opinion,'could have avoided the unplanned exposure in the TIP

Room. Such a structured approach could have been achieved _with

a more formalized program.

Reviews of routine operations, planning and preparation for

the piping replacement outage and early outage activities.in-

dicated a generally effective radiation protection program was

being maintained. The radiation protection organization and .

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staffing level were generally adequate to support normal opera-

tions and the piping replacement outage. The licensee promptly

filled the Health Physicist vacancy (i.e., radiation protection

manager) when it occurred. With the exception of the Outage

ALARA coordinator (filled as a collateral duty by the Emergency

Response Coordinator), key radiation protection staff positions

were adequately staffed.

Selection, training and qualification programs for replacement

personnel in radiation protection were generally adequate and

contributed to generally acceptable personnel performance and

adherence to procedures.

Documentation of radiation protection activities was generally

complete, adequately maintained and available. Dosimetry

records were well-organized and available.

The total personnel exposure reported for the facility for 1984  !

was 603 manrems which is about average for BWRs of comparable

age and operational status.

1.2 Radioactive Waste Management / Effluent Controls

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The licensee maintained an effective radioactive waste manage-

ment and effluent controls program. Planned releases of liquid

radwaste were minimized as a result of prior planning by the

licensee to control liquid processing activities. There were

no unplanned releases during the assessment period.

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Staffing and functional positions were adequately identified,

authorities and responsibilities were defined, and a generally

adequate staff was available. Contractors performed specialized

radwaste treatment operations under defined authorities and

responsibilities. A generally effective annual retraining

program was maintained in applicable procedures, technical

specifications, and related administrative controls, which

contributed to a generally acceptable level of personnel per-

formance with few personnel errors.

Radioactive waste 'ranvgement and effluent control procedures

were generally coepleu., adequately maintained and available.

Minor technical inaaequacies noted during review of procedures

were adequately addressed and corrected by the licensee. The

licensee made technically adequate changes in procedures fol-

lowing an inadvertent Group 3 primary containment isolation

and start of the Standby Gas Treatment system during functional

calibration (Licensee Event Report 85-05).

1.3 Environmental Monitoring

On April 1, 1985, Amendment No. 83 to the licensee's Technical

Specifications became effective requiring changes to the lic-

ensee's Radiological Environmental Monitoring Program (REMP).

Management control of the transition from the previous Techni-

cal Specification requirements to the requirements of Amendment

No. 83 for the REMP showed evidence of planning and assignment

of priorities. A systemat'ic review of the changes to the REMP

was completed and a management action plan to implement changes

to procedures and practices was developed. The transition to

the requirements of Amendment No. 83 was completed in a gener-

ally timely manner.

REMP procedures were rarely violated. The loss of data from

an environmental monitoring station in January, 1985 due to

a failed sample pump appears as a continuation of previous

problems at the sample stations, but no adverse trends in pump

performance or the licensee's efforts to resolve the problem

were evident for this period. The licensee promptly reported

the events.

Review of the training and retraining program effectiveness

for the licensee's staff and contractors showed those programs

contributing to an adequate understanding of the work and ad-

herence to procedures with few personnel errors. An adequate

training program was provided in March, 1985 to ensure that

operations personnel were aware of the requirements in Amend-

ment No. 83. Contractor laboratory personnel received adequate

training in their duties.

..

_ ., .

'

,

15

1.4 Transportation

An effective transportation program was maintained during this

assessment period. Program improvements in the areas of qual-

ity assurance and training were noted. Quality assurance per-

sonnel assigned to shipping activities received effective

training in Department of Transportation and NRC requirements,-

waste burial site requirements and other technical areas asso-

ciated with radioactive materials shipments. The licensee ,

provided acceptance criteria, specific attributes and regulatory

limits on checklists used in quality control inspections of

transportation activities. General indoctrinations and speci-

fic training were provided to personnel assigned to radioactive

materials shipping activities. The training contributed to

understanding of shipping requirements, adherence to shipping

procedures and few personnel errors.

Quality assurance audits of the above areas were timely, thorough

and performed by technically qualified personnel. Actions taken

in response to audit findings were timely, technically adequate and

indicative of an effective program for identification and correction

of deficiencies in these areas.

2. Conc,1usion

Rating: Category 2

Trend: Consistent

3. Board Recommendation

Licensee

The ALARA program has not been effective in minimizing radiological

'

'

doses to the VY staff, as evidenced by the exposure of a worker in

the TIP room in August of 1985. It is the staff's opinion that the

lack of a structured ALARA program contributed to this prqqram in-

effectiveness. The Board finds that the recirculation piping re-

placement ALARA program is a good example of a structured ALARA

program, and recommends that this or a similar program form the

basis for a structured plant ALARA program.

'

, .-

,

'

.

l

!

--.

_ . -- -. _- -_ .. _ _ _ _ . .

_ _ _ . _ _ __ __. _ - _ _ _ _ _ _.

.

.. .

'

.

16

C. Maintenance and Modifications (366 hours0.00424 days <br />0.102 hours <br />6.051587e-4 weeks <br />1.39263e-4 months <br />, 14%)

1. Analysis

.

This area received a category 2 rating during the last assessment

period due to maintenance personnel performance errors and the need

'to strengthen management oversight and QA controls in the maintenance

area. No significant problems were identified in the area of modi-

fications and the design change control program.

This area was under periodic review by the resident inspector, and

three inspections were performed in this area by region-based per-

sonnel during the current assessment period.

"

The design change control program remained a significant licensee

strength. Station, corporate and engineering procedures for design .

changes assure a .onsistently high level of review and management

.

involvement in the modification process. The program was well im-

,

plemented by qualified personnel who had good familiarity with the

administrative process and the facility. No programmatic deficien-

2 -

cies were noted. One violation identified during the period (IR

l 85-08) concerned the failure to control changes to surveillance and

operating procedures following a design change on the fire protec-

4

tion system, which resulted in the release of the modified system

for operations without the revised procedures. The finding appeared

to be an isolated incident.

The decision to replace piping in the recirculation /RHR systems was

made in 1983 after the initial detection of IGSCC. In the interim,

the licensee complied with NRC requirements regarding the repair

and reinspection of cracked welds. The licensee provided to the

i

NRC good supporting justification for the interim period of opera-

t

tion. The justificatio., !as based upon the latest available tech-

niques for the detection and sizing of IGSCC. These decisiens were

examples of continued management involvement in the cracking issue.

The planning evident regarding the pipe replacement indicated that  ;

p licensee management was heavily involved in the decisions which'iere 1

made. Staffing for the replacement project appears to be ample in

-

that there is a good representation of QA/QC, sufficient craft and

1*

.s

"

supervisory personnel to cope with contingencies, and adequate  !

y supervisory oversight. '

Modifications were previously completed to meet the Environmental

-

Qualification rule for a majority of the plant equipment required

,

'

for safe shutdown, and a schedule for qualifying additional equip-

l ment by November 1985 was established with the NRC staff in a timely

manner. Licensee evaluation to justify continued operations for

the interim period were adequate. Further licensee reviews during j

this assessment period identified additional qualification defi- 1

i

i

l

.

_k

4 8}+

i

_ _ _ _ , _

,

. _ __

, _ _ _ _ __. .._ _ _ __ __

!

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,

17

y ' ciencies that will require further action to assure EQ requirements

are met. None of the equipment deficiencies had safety significance

' and licensee etaluations to disposition the items for the interim

1'

-

(,periodwereadequate. Licensee management should assure that all

, EQ issues have'now been identified and corrected per the established

"; schedules.

'The effectiveness of the licensee's actions in response to Generic

Letter 83-28 (GL 83-28) entitled " Generic Implications of Salem ATWS

-

Event", and specifically, the areas of Equipment Classification,

Vendor Interfaces and Post Maintenance Testing were reviewed.

Overall, the licensee was. thorough in his actions, with one excep- *

tion as noted below. Licensee management recognized the need to

make improvements in the equipment classification program and com-

mitted to a December 1986 completion date for implementation of the

necessary changes.

In the area of vendor interface control, it was noted that the lic-

ensee's system did not always assure v'ndor information was current

>

and complete. This fact may impact preuntive maintenance, equip-

ment upgrading and replacement, and licencee notification of fail-

ures incurred by other users. Further lic e see action is warrr.ted

'

in this area to resolve the issue.

~

The routine preventive and corrective maintenance programs continued ~ ,

, to be well implemented by a qualified staff. An improvement has

been noted in this area regarding the correct performance of main-

9 tenance activities in accordance with the established procedures.

'

The. licensee was responsive to NRC concerns by reviewing and im-

proving refueling maintenance procedures as necessary to assure the

n correct performance of routine activities. The preventive mainten-

2

ance program continues to be well documented in both the I&C and

Maintenance areas. Staffing for the area is adequate and the Main-

tenance Superintendent position was permanently filled during the '

assessment period. Supervisor involvement in daily work activities

2

-

remained' consistent with previous observations and an element of

-

strength.

Maintenance of plant safety related equipment was consistently given

the right priority. Station personnel were effective in properly

'

diagnosing problems and performing the appropriate repairs to assure

!

' problems do not recur. Licensee evaluations regarding inoperable

or degraded components were consistently proper. Safety equipment

was properly controlled prior to and after removal from service.

Post maintenance testing was well implemented and procedures for

maintenance test activities were technically adequate. The proce-

dures provided criteria and responsibilities for review and approval i

of post maintenance testing and record keeping requirements. The l

licensee's post maintenance testing activities remained adequate

and effective in demonstrating operability of affected systems.

l

,

!

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_ - _ . . _ . ,---r--r,, . . ,- ,,< -m-- --%y - . ---.- ,

.

- ,, -

"

_

18

The good personnel performance in the maintenance and modification

areas indicated that training for these areas was effective in as-

suring thorough implementation of the programs.

One violation during this period (IR 85-22) concerned the failure

to maintain material procurement control of two replacement parts

in systems designated as safety related. The parts involved had

no safety significance. The licensee promptly responded to this

problem by revising its procedures and by upgrading the training

provided to stores personnel. The licensee further responded to

the issue by initiating a review to determine whether procurement

controls were maintained for other work. NRC review of this effort

was in progress at the end of the assessment period.

The licensee responded to IEB 79-02 and 79-14, and performed the

required actions in an acceptable manner. However, for IEB 79-02,

the licensee performed the tests and analysis only on seismic sup-

ports and not on dead weight supports. Because the contribution

of dead weight supports was not considered in the design analyses

for the seismic supports, the intent of the bulletin was not met

when these dead weight supports were excluded from the review. The

licensee's engineering evaluations were found adequate to assure

that a safety-factor of at least 2 existed for all supports of con-

cern. Modifications are scheduled to be completed during the shut-

down as part of the voluntary seismic reanalysis program that will

assure a safety factor of four is restored. A confirmatory action

letter (CAL) was issued to assure that the deadweight supports would

be adequately considered. These actions were necessitated by a lack

of licensee thoroughness in understanding and implementing actions

in response to the bulletin intent. Licensee management attention

is warranted on this item to assure the remaining pipe support is-

sues are resolved in a timely manner.

The licensee was responsive to NRC initiatives to review and improve

the control and QC inspection of routine plant maintenance activi-

ties. However, a QA audit performed early in 1985 identified de-

ficiencies in the onsite QC " peer" inspection process and licensee

management took actions to institute temporary interim controls to

assure proper documentation inspection practices. Actions to com-

plete long term program improvements were in progress at the con-

clusion of the assessment period. The recurrence of program defi-

ciencies in the peer inspection of maintenance activities is dis-

cussed further in Section I. below as a QA program issue.

In summary, activities in the Maintenance and Modification area were

completed by experienced personnel in accordance with well estab-

lished programs and procedures, with good regard for safety. Im-

provements can be realized by assuring thoroughness in design change

reviews, correcting program weaknesses in peer inspection process,

and strengthening vendor interface controls. An overall performance

improvement was noted in this functional area.

-. __ .-

.- .. - . - - -. . . _ . - . . =

..

'

. .;: _

'

{..n-

' *

.

19

2. Conclusion

Rating: Category 1

Trend: Consistent

3. Board Recommendations "

Licensee:

Complete actions on modifications indicated above to assure timely

-resolution of issues (Bulletins 79-02 and 79-14). Complete actions

to improve vendor interface controls.

-

.

-

-

.

. 20

D. Surveillance (69 hours7.986111e-4 days <br />0.0192 hours <br />1.140873e-4 weeks <br />2.62545e-5 months <br />, 3%)

1. Analysis

There were no significant concerns identified in this area during

the previous assessment period. The occurrence of personnel errors

during routine duties was identified as requiring management atten-

tion to assure no adverse trends developed.

The operational surveillance program was under periodic review by

resident and regional inspectors during the assessment period. One

inspection was conducted by a regional inspector in the preservice

and routine inservice inspection program areas, and of the program

for nondestructive examination of recirculation system welds. The

implementation of an operational surveillance program by an experi-

enced staff remains a significant strength.

Surveillance activities were completed in accordance with estab-

lished controls. Procedural adherence was good. Planning and

staffing were adequate, and the surveillance test program was well

implemented and maintained. Personnel were well experienced with

test activities and the associated testing procedures, and were

knowledgeable of the facility, its operation and the equipment under

test. There was generally good regard for administrative policies

and practices.

Supervisory review of test results was done well and was effective

in identifying problems for followup calibration or additional

maintenance. One violation in the area concerned the failure to

identify and correct discrepant I&C test results for stack gas

quarterly calibrations (IR 85-25). The item was an isolated inci-

dent and it does not detract from an otherwise excellent performance

record. The second violation identified in the area concerned the

failure to cycle a normally open isolation valve in the fire pro-

tection loop for the reactor building due to a typographical error

in the test procedure. The error should have been identified by

Engineering Support review of the procedure revisions and test re-

sults.

Surveillance procedures were generally well written, technically

adequate and provided the right amount of detail to assure correct

performance. The actions in progress to upgrade the format of I&C

procedures to better assure correct performance is notable. Sur-

veillance records were well organized, filed and casily retrievable

for independent review and followup of events or performance his-

tories. Test results were trended to detect the development of

equipment problems.

NRC reviews of'the Inservice Inspection area found the program con-

tinues to be well established and implemented. No problems were

noted during the review of the licensee's program for baseline

- . . _ - . ._ _- - . . _ - . - ._ _

,

. ,

. .e . - - *

,

21

ultrasonic examination of the welds in the new recirculation system

piping. The ISI and PSI program was well staffed and implemented

by qualified personnel. The licensee maintained adequate control i

over ISI examinations by direct surveillance. l

The Operational Inservice Test program was also adequately estab-

lished and implemented by experienced personnel. The recent change

,-

' in program administration to use the Shift Engineers for results

review and evaluation is an improvement in the program that will

i.

aid in the timely identification of potential equipment problems.

Actions taken to resolve difficulties with portable vibration test

equipment enhanced program implementation.

• ~

Two events during the period (LERs 84-24 and 85-02) concerned missed

surveillances due to scheduling errors, which were relatively in-

significant when compared to the large numbers of surveillances e

scheduled and performed during the period. Two additional instances

of-personnel error were noted in LERs 84-23 and 85-05. Both events

concerned the generation of a PCIS Group III isolation signal while

calibrating the refueling zone radiation monitors. The events were

not operationally significant. Both events resulted from'inatten-

tion to details and not from deficiencies in training. An improve-

ment has been noted overall in performance of routine duties and

the reduction of errors.

The total number of reported events in the area was low and no

adverse trends or common causes were noted from the reported events.

2. Conclusion

Rating: Category 1.

Trend: Consistent

3. Board Recommendations

.

None

!

,

l

i

f'

'

!

, ,

. _ . . _ - _ ~ . . . _ _ . _ . , - . _ . _ . . . _ - - . - - - . _ _ _ _ _ _ . - - _ ,-- . _ _ -

.

-

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22

E. Emergency Preparedness (327 hours0.00378 days <br />0.0908 hours <br />5.406746e-4 weeks <br />1.244235e-4 months <br />, 12%)

1. Analysis

This area was rated as Category 1 during the previous assessment

period and no significant problems were identified.

During this assessment period, one routine inspection was conducted

and one full scale exercise, which included NRC Region I participa-

tion, was observed.

In reviewing emergency preparedness program changes, NRC identified

a need for improved definition of duties, responsibilities, and

lines of authority for onsite emergency response personnel. Several

areas of concern were also identified in the EP training program.

Several key emergency response personnel demonstrated difficulty

in performing dose assessment calculations and emergency classifi-

cations, and were unfamiliar with use of Emergency Plan Implementing

Procedures (EPIP). These programmatic weaknesses indicated that

this area had not received sufficient management attention or self-

evaluation. A review of the licensee's audit program and actions

on previous NRC inspection findings indicated that corrective ac-

tions were generally effective and timely.

Consistent with the above findings, the licensee's performance dur-

ing the full scale exercise in April 1985 indicated deficiencies

in tLe overall emergency organization. Specifically, weaknesses

were identified in the areas of command and control of the emergency

response facilities, dissemination of information, and communica-

tions/ flow of information. The licensee's performance was assessed

as marginally acceptable. The licensee has agreed to take actions

to: 1) clearly define responsibilities and authorities of emergency

response personnel in the Emergency Plan; 2) perform training of

emergency response personnel; 3) reassess the effectiveness of their

overall communications system for dissemination of information dur-

ing emergencies; and 4) to schedule a drill to demonstrate use of

the new EOF. I

l

The licenses has been responsive to NRC concerns as demonstrated

by completion of a major revision to the emergency response or-

ganization. Effective in September 1985, the Vermont Yankee Emer-

gency Management Organization was established and identified in the

)

Emergency Plan to more clearly define overall direction and control I

during emergencies. A drill was also held in September 1985 to '

demonstrate the new EOF and associated changes to the Emergency Plan.

No significant problems were identified during that drill. The new

EOF facility was declared operational on September 16, 1985, ahead

of schedule.

.

.. .-

'

.

23

2. Conclusion

Rating: Category 2

Trend: Improving

3. Board Recommendations

None.

.

-

..

~

.

24

F. Security and Safeguards (92 hours0.00106 days <br />0.0256 hours <br />1.521164e-4 weeks <br />3.5006e-5 months <br />, 3%) _

1. Analysis

During this assessment period, one routine and one special physical

protection inspection were conducted by region based inspectors.

Routine resident inspections continued throughout the period.

Three violations were identified during a routine security inspec-

tion. The licensee responded to these violations adequately with

both short and long term corrective actions. These actions included:

(1) replacement of various system components whose performance had

deteriorated; (2) review of the preventive maintenance program in

an effort to upgrade its effectiveness and implementation; (3) re-

view of the functional features and testing of the alarm and access

control systems to ensure compliance with industry standards; and,

(4) review of supervisory staffing and technical support for the

program. The comprehensiveness of these actions is a positive in-

dication of the licensee's responsiveness to NRC identified concerns.

Licensee management should ensure that these actions are carried

out in a timely and effective manner.

Two apparent violations resulting from an access control incident

on September 20, 1985 were the subject of an enforcement conference

on October 21. The nature of the problems brought into question

the adequacy of licensee management oversight of the security pro-

gram, and security personnel awareness of the objectives of the

program and its implementation.

After identification of the above problems and prior to the en-

forcement conference, the licensee formed a special task force to

evaluate the total security program and its implementation. While

this action and those listed above are noteworthy, it raises ques-

tions concerning the effectiveness of the licensee's audit program

(further discussed below) and the adequacy of day-to-day supervisory

and management oversight, which could have identified the trend,

particulcrly with respect to systems hardware, much earlier. The

failure by licensee management to detect this trend may be due in

part to the lack of fresh perspective regarding program implementa-

tion. Increased attention by corporate management to the overall

program and its effectiveness in meeting physical protection ob-

jectives is necessary.

The licensee's security audit program meets the commitments of the

NRC approved Security Plan, but recent NRC inspections identified

long standing program deficiencies which indicate that the audits

may not have been sufficiently comprehensive or detailed, or that

they focused only on the regulatory aspects of the program without

consideration of program objectives.

.

. ... -

~

, 25

Seven licensee security event reports, required by 10 CFR 73.71,

were submitted during the assessment period and were considered

adequate in terms of timeliness, completeness and compensatory

actions.

' Staffibg of the security organization is consistent with the re-

quirements of the security plan. However, the recently established

task force snould carefully assess supervisory staffing to determine

if it is adequate to maintain appropriate oversight of day-to-day

program implementation, and whether this responsibility is adequately

' identified and defined. The security force training and qualifica-

tion program ~is well defined and effective as evidenced by only one

identified event involving personnel error. That event is attributed

to inattentiveness rather than a training deficiency.

However, while security force personnel performed their assigned

duties well, their overall awareness and appreciation of physical

protection program objectives should be increased so that they are

,

able to more readily recognize weaknesses and bring them to man-

agement's attention. Some examples of problems that could have

been identified and corrected by the guard force included the large

number of nuisance alarms; the improper location of a trailer within

the protected area; and, the failure of SAS functions to be fully

redundant with CAS functions. Additionally, the sensitivity of all

plant personnel to existing security procedures should be increased,

particularly with respect to the use of access control hardware,

in order to reduce unnecessary alarms and associated response.

2. Conclusion

Rating: Category 2

Trend: Declining

3. Board Recommendations

Licensee:

Improve self evaluation and audit program to identify weaknesses

before they become program deficiencies. Increase corporate man-

agement attention to site activities to add fresh perspective and

oversight of program implementation. Increase the sensitivity of

plant personnel to security needs.

__

.,_ -- - -- .-

.

. s.. -

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26

G. Refueling and Outage Management (147 hours0.0017 days <br />0.0408 hours <br />2.430556e-4 weeks <br />5.59335e-5 months <br />, 6%)

l

1. Analysis

No significant concerns were identified in this area during the l

last assessment period and it was rated as Category 1. '

The plant was in the beginning of a planned 32 week refueling and I

maintenance outage for the last 4 weeks of this assessment period.

All phases of shutdown operational activities completed in prepar-

ation for the replacement of the recirculation piping were reviewed.

Plant activities completed and reviewed during this assessment

period included: receipt and inspection of new fuel; preparation

of refueling procedures; complete defueling of the reactor; inspec-

tion of vessel internal components; and, setup of the vessel for

decontamination and pipe replacement. Recirculation system decon-

tamination activities were in progress at the end of the assessment

period. A meeting was also held with licensee staff on July 17,

1985 to review the plans and procedures to control the replacement

of the recirculation system.

For the licencee's Cycle XI startup testing, including administra-

tive controis for the test procedures, test programs and QA surveil-

lar.ce during the startup testing, there was clear evidence of prior

planning in the test program. The startup physics tests were con-

ducted according to the approved written procedures by adequately

trained and qualified personnel. The test program outlined the

steps in the testing sequence, set initial conditions and prere-

quisites, specified calibration and surveillance procedures at ap-

propriate locations and referenced detailed test procedures and data

collection. Records were well prepared, complete, and readily re-

trievable. There were good QC coverage and audits of startup testing

activities.

Routine outage activities were well planned and controlled by the

proper level of supervision of station personnel. Plant staff was

effectively used to coordinate contractor activities. Daily staff

outage meetings are effective in maintaining good communication and

coordination between outage groups and planned activities. Planning

for the recirculation pipe replacement work was very thorough and

>

well done, particularly in the areas of the design change package,

its safety evaluation, and the ALARA program for the control of

work activities.

Receipt inspections of new fuel were completed by experienced per-

sonnel, who were knowledgeable of the procedures, fuel assembly de-

sign and specifications, and the inspection equipment. Refueling,

in-vessel examination and inspection procedures were technically

adequate. Personnel displayed a good regard for nuclear safety.

Refueling, spent fuel pool activities, and other in-vessel mainten-

.

.

.. -

~

,

27

ance and surveillances were conducted by qualified personnel in ac-

cordance with the procedures and administrative policies. There

was good management and QA/QC oversight and management control of

contractors. Improved training effectiveness was demonstrated dur-

ing refueling activities, and training effectiveness was also evi-

dent in the new fuel inspections.

Problems with refueling equipment were minimal and the problems that

did occur were appropriately dispositioned. Discrepancies noted

during in-vessel examinations were followed through with the appro-

priate level of detail to assure proper dispositioning of potentially

significant problems. Licensee actions to evaluate and disposition

questions regarding the previous use of a certain decontamination

solution for the recirculation system were appropriate.

The supervision and control of refueling and maintenance outages

remains a significant management strength.

2. Conclusion

Rating: Category 1

Trend: Consistent

3. Board Recommendations

NRC

The above assessment was based on preparation for and the initial

phases of the outage. In view of the nature and length of the

outage, a readiness assessment team inspection should be performed

prior to plant restart.

___

. ._ =- - - .

.

.

.;. . %

• '

,

28

-

H. Quality Assurance (449 hours0.0052 days <br />0.125 hours <br />7.423942e-4 weeks <br />1.708445e-4 months <br />, 17%) -

1. Analysis

The area was rated as Category 2 during the previous assessment

period due to problems identified in the QA program, staffing,

training, and a QA program that was too narrow in scope and coverage.

Three inspections were performed in this area by region-bated per-

sonnel during the current assessment period, and the area was under

periodic review by resident and regional inspection personnel. The

specific problems identified in the previous SALP report were either

corrected or in process during this assessment period. Additional

QA problems were identified during the current assessment period,

and as a result, through discussions with the licensee onsite and

at an enforcement conference, the licensee formally committed to

make major changes to improve performance. Subsequent NRC inspec-

tions indicated that the licensee's program and management involve-

ment, when fully implemented, should correct the program areas.

The record storage program and procedures identifying records re-

_ quired to be maintained were satisfactory. An inspection identified

problems (violation IR 85-11) involving instances of inadequate re-

'

ceipt inspection and possible false receipt inspection records.

The inadequacies in the receipt inspection and storage program in-

cluded: inadequate receipt inspections of safety related material

,

'

which were-conducted because of inadequate procedures; receipt in-

spectors who were not provided adequate training, tools, or guidance

to perform their duties; a QA program evaluation of the area which

was of questionable effectiveness since it-failed to detect the

weaknesses identified by the NRC; a preventive maintenance program

for stored electrical items which was inadequate; and instances of

receipt. inspection reports which failed to accurately document the

characteristics inspected. None of these inadequacies resulted in

actual hardware failures or unsafe plant conditions. An investiga-

.

tion of this area by the NRC's Office of Investigations determined

that the false records were not knowingly falsified with the intent

to deceive, and there was no attempt by either workers or management

to cover up deficient materials. The NRC investigation did confirm

that, while licensee management had identified programmatic problems

in the receipt inspection area, that information was not quickly

identified to upper management levels for action, and corrective

actions were not initiated in a timely manner. These actions indi-

cated a lack of sensitivity to QA and potential compliance issues

by mid-level management and their supervision. Additionally, ac-

!

,

1

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

5

.

^

pp 2

.

'

,

29

e

i

-

tions taken during the March 1985 NRC inspection indicated that the

Station Staff was less than fully open by waiting until the receipt

inspection problems were identified by the NRC inspector before

discussing internal findings.

'

'

These problems led to several discussions with the licensee and an

enforcement conference. The licensee was responsive and committed

to broad QA corrective measures and management actions. A number

of corrective actions were implemented immediately after identifi-

'

cation of these problems during the NRC ir.spection. These actions

,

were considered appropriate by the NRC. A Task Force reported to

'

.

the Plant Manager on a number of recommendations for improvement

of the receipt inspection process. These recommendations included

extensive procedure revisions, inspection guidelines and staff

training placed in effect by August 1, 1985. These activities

showed thoroughness and initiative by the licensee in correcting

-

identified problems in the receipt inspection and storage program.

By the end of the assessment period, the revised procurement, re-

'

c ceipt, storage and handling program was greatly improved. Manage-

ment provided the needed guidance for performing receipt inspections

and was more involved in the program. Considerable improvement was

noted in~ licensee candidness and ccoperation with the NRC staff,

but additional improvements can be realized.

The NRC identified in 1980 that plant procedures were overdue in

their biennial reviews. Corrective actions were initiated at that

time to correct.the problem. An NRL inspection in January 1985

noted that the problem had not been.:orrected. The licensee ac-

,

knowledged that the problem was a cottinuing concern and a 1984

'

review of overdue procedures during a QA audit had also identified

.

the need for further corrective actions. This is indicative of a

'

- lack of effectiveness in the licensee's internal corrective action

program. This lack of effectiveness in corrective actions was also-

highlighted by a second problem in this area (IR 85-25), which con-

l cerned the inability to adequately correct deficiencies in the on-

site QC " peer" inspection program. Licensee initiatives to identify

problems in the program via a QA audit early in 1985 were notable.

However, the deficiencies noted in this audit in documenting in-

j spections of maintenance activities were a recurrence of problems

'

previously identified by the NRC in 1983. The failure to adequately

correct the deficie.'cies in the maintenance area, and on a plant-

wide basis, was indicative of corrective actions in 1983 that were

>

too narrow in scope and which lacked depth of perspective. NRC re-

i view of actions needed to correct this problem were still in pro-

,

gress at the end of-the assessment period.

License actions to correct programmatic deficiencies in the onsite

!

peer QC inspection process were in progress at the conclusion of

the period and interim measures to bring the program into compliance

)

1

.

~+ r y * ,+

r-wi-- .w - , - - - - e

.

., .

.

,

30

• vith established requirements for outage activities were effective.

.

sdditional licensee management attention is warranted to this item

to assure long term corrective actions are completed in a timely

manner and are effective.

The quality assurance program was effectively implemented in most

functional areas, as reflected in other sections of this report,

by the procedures and administrative requirements established and

implemented by qualified personnel. The effectiveness of the qual-

ity -ssurt':e program was most evident in the modification and de-

sign change program. QA audits of program implementation were ef-

fective in most functional areas, but improvement can be realized

in the security and receipt inspection areas by assuring these

programs are effective in meeting the stated objectives. The pro-

curement and vendor programs were well implemented.

Working level personnel generally exhibit a good attitude towards

QA, proper procedures and checklists are in use and the QA/QC func-

tions are adequately staffed with personnel with appropriate tech-

nical capabilities and training. The audit program, with some ex-

ceptions such as the receipt inspection program, is effective with

good followup corrective actions.

The problems in the areas of followup corrective actions as well

as receipt inspection, storage procedures and training for receipt

inspectors and the low level of management attention prior to NRC

identification are indicative of weaknesses in this functional area

that require management attention to improve performance.

2. Conclusion

Rating: Category 2

Trend: The Board could not establish a trend based on the infre-

quent inspection coverage. The Category 2 rating was the

result of improved performance noted late in the assessment l

period.

3. Board Recommendations

Licensee:

Complete program improvements in receipt inspection area. Continue

efforts to assure candid and open communications with NRC inspection

personnel.

Additional attention is needed to assure the onsite " peer" inspec- I

tion program long term improvements are implemented in a timely  !

manner and are effective in correcting the identified deficiencies.

Worker, supervisor, and mid-level management sensitivity to the QA

-..

'

.

<

• s

~*

.

31

program should be emphasized to assure program problems are promptly

identified and prioritized for correction. Actions should be

promptly completed to review the overall QA program implementation

to assure the requirements of YOQAP-I-A and 10 CFR 50, Appendix B

are met.

N*tC:

Provide additional review of long-term program improvements to

assure they are effectively implemented.

.

, . . T 7 9

.

'

.-

.

.

32

I. Licensing Activities (30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, 1%)

1. Analysis

Licensing

This area was rated as Category 1 during the previous assessment

period. The licensee's performance during this assessment period

was evaluated based on the following attributes: management in-

volvement and control in assuring quality; approach to resolution

of technical issues from a safety standpoint; and, responsiveness

to NRC initiatives. The inspection hours listed above represent

the NRC staff onsite inspection time required to review the proposed

license amendment for degraded grid protection.

Vermont Yankee Nuclear Power Corporation and Yankee Atomic Electric

Company management have an awareness of the various licensing issues

by virtue of extensive experience in the industry, technical exper-

tise and active participation in industry and professional organi-

zation activities. Management takes actions in a timely manner to

ensure safety issues are properly addressed. Examples of this at-

tribute during this report period are the preliminary discussions

and submittals related to activities in the present pipe replacement

outage. To assure quality during the pipe replacement outage, a

dedicated management team was assigned one and one-half years in

advance of the outage. Additionally, the fact that no emergency

technical specification changes have been requested during the

period evidences consistent planning by management to take into

account license requirements.

Vermont Yankee senior management has sought to identify for correc-

tive action, areas the project manager perceived as deficient, in

quality or timeliness of response, and has been effective in dealing 4

with areas so identified. Candid discussions between the project I

manager and licensee management has facilitated resolution of cer-

tain complex issues, such as recombiner capability (A-19).

There was consistent evidence of prior planning and assignment of

priorities and decision making was consistently at a level that

ensures adequate management review.

Favorable evaluations from the technical reviewers are indicative

of the licensee's technical understanding of most issues. The Ver-

mont Yankee engineering staff, in concert with support from the

Yankee Atomic Electric Company, assures that most engineering work,

either done inhouse or performed under its direction by contractors,

adequately addresses complex technical issues. An example of the

licensee's initiative and technical capability is the staff's ap-

proval, on September 27, 1985, of the use of a fuel performance

code developed by the licensee. The review of this code for lic-

l

. _ - . . .. - . _ . . . . . . . - -

.

, .:;

.

,

33

ensing purposes required several years and extensive documentation,

and is the first case in which the staff has approved use of a fuel

. performance code not developed by a major fuel vendor. The licensee

'

frequently forms technical judgements independently from the indus-

try, and these judgements are well thought out and supported.

The licensee has _shown technical initiative and responsibility in

conducting a seismic upgrade program which has already resulted in

structural modifications to the hydraulic control unit assembly

rack. Schedular requirements for follow on improveme..ts to the in-

sert and withdraw lines are under consideration by the NRC staff.

The licensee demonstrated a clear understanding of issues, and

technically sound and thorough approaches in almost all cases. The

licensee completed a reanalysis of the Reactor Building in November

1984, in response to NRC concerns and submitted a report of his

'

findings to the staff for review. The results of this reanalysis

was the identification of areas where walls needed to be upgraded

to. fire walls. The licensee was installing penetration seals in

these walls and provided NRC with a closeout schedule for the en-

gineering modifications needed as a result of the reanalysis. The

licensee implemented acceptable interim compensatory measures until

, the modifications were completed. The licensee submitted a modified

set of exemption requt ts on April 24, 1985 that are presently under

.

review by NRR. Licensee actions in this area were responsive to

j

NRC concerns.

Open and effective communication channels exist between the NRC and

Vermont Yankee licensing staffs. Effective dialogue between the

staffs most times promote prompt and technically sound responses

to NRC initiatives. The licensee meets-most established commitment

dates or provides a written submittal explaining the circumstances

and establishing a new firm date. Despite the obvious problems of

communication and authority presented by the physical separation

of the licensee's plant and corporate staff in Vermont from the

'

licensing staff in Framingham, Massachusetts, licensing activities

are handled fairly well. This is in large part due to dedicated,

competent staffs at both locations. Conference calls with the stsff

are usually promptly established and include appropriate engineering

and plant personnel. The Vermont Yankee licensing engineer and/or

his management, in most cases, promptly and effectively resolve

-issues. The licensee has shown willingness to reallocate resources

in order to accomplish schedular improvements required by the NRC

(for example, NUREG-0737, Supplement I activities). The improvement

in the "no significant hazards consideration" determinations accom-

panying proposals for license amendment changes shows responsiveness

on the part of.the licensee. In summary, the licensee's responser

are generally timely, sound, thorough and viable.

I

.

I

h

- - . , _ _ , ,. . . , , -__ . , _ - . _ , , - - . , .-__ -

.

.; .

.

.

34

2. Conclusion

Rating: Category 1

Trend: Consistent

3. Board Recommendations

None.

,

- - - - -

.

., .

.

.

35

V. SUPPORTING DATA AND SUMMARIES

A. Investigations, Petitions and Allegations

1. Office of Investigation Report 1-85-008 dated 10/1/85 concerning

the potential willful falsification of receipt inspection records.

Receipt inspection record inaccuracies were found to be due to pro-

gram deficiencies rather than record falsifications.

B. Escalated Enforcement Actions

1. Civil Penalties

$50,000 civil penalty was proposed on 10/22/85 relating to the un-

planned TIP Room exposure described in NRC Inspection Report 50-

271/85-21

2. Actions Pending/ Resolved

IR 83-26 violation for failure to provide protection per Appendix

R, III.G.2 for equipment in the Reactor Building.

3. Orders

a. Confirmed Emergency Response Capability, 8/29/85

b. Confirmed E0P Implementation Date, 6/6/85

4. Confirmatory Action Letters (CAL)

a. CAL 85-06, Confirmed Actions on IE Bulletin 79-02 Seismic

Pipe Supports, 6/5/85

b. CAL 85-15, Confirmed Actions Following Unintended 8/9/85

TIP Room Exposure, 9/9/85

C. Management Conferences

a. S.TLP Management Meeting, 1/9/85

b. Mr. Stello, NRC Deputy Executive Director for Regional Operations

and Generic Requirements toured VY, met the staff and discussed

various topics of current interest, 3/4/85

c. Enforcement Conference to discuss NRC Inspection Report 50-271/85-11

results regarding receipt inspections, 4/17/85

d. Management Meeting with VY President to discuss recent issues,

5/23/85

e. Management Meeting to discuss analysis results for deadweight

supports on seismic class piping, 5/23/85

f. Management Meeting to discuss VY's response to the findings observed

during the annual emergency exercise, NRC Inspection Report 50-271/

85-27, 7/3/85

..'

---

..

.

.-

"

.

36

f

g. Management Meeting to discuss plans and preparation for recircula-

tion pipe replacement outage, 7/17/85

h. Management Meeting to discuss Receipt Inspection and Peer Inspection

Program Issues, 8/7/85

i. Enforcement Conference to discuss NRC Inspection Report 50-271/85-21

results regarding TIP Room controls, 9/4/85

j. Management Meeting to discuss NRC Inspection Report 50-271/84-11

findings regarding placement of containment high range radiation

monitors, 9/4/85

k. Management Meeting with VY President to discuss recent issues,

9/24/85

1. Enforcement Conference to discuss NRC Inspection Report 50-271/85-31

results regarding the 9/20/85 unauthorized security access, 10/21/85

.--_

.

.

..

.

.

37

0. Licensee Event Reports

Type of Events:

A. Personnel Error . . . . . . . . . . . . . . 4

B. Design / Mfg / Construction / Install Error . . . 0

C. External Cause. . . . . . . . . . . . . . . 0

D. Defective Procedure . . . .........1

E. Component Failure . . . . . . . . . . . . . 3

X. Other . . . . . . . . . . . . . . . . . . . 0

TOTAL 8

Licensee Event Reports Reviewed:

Reports 84-23, 84-24 and 85-01 to 85-06

!

Causal Analysis

Three sets of causally linked events were identified.

a. LERs 84-23, 84-24, 85-02, 85-03,85-05 and 14 LERs received during

the last SALP report period were due to personnel error. The

majority of these errors were in the area of Plant Operations,

Radiological Controls and Surveillance. An improvement has been

made in this area with the personnel errors occurring less fre-

quently this report period that last.

b. LERs 84-08, 84-14 and 85-01 involved failures in collecting the

weekly environmental air sample. One failure involved personnel

error while the other two incidents involved unrelated equipment

failures.

.. . .... . .- . - -_. . . - - . .

1

jc; .... ,

. .

,

.

T-1-1

'

.

, - .

TABLE 1

LISTING OF LERS BY FUNCTIONAL AREA

_ VERMONT YANKEE NUCLEAR POWER STATION

Area Number /Cause Code Total

A. Plant Operations 2E 2 .

B. Radiological Controls 1A 1E 2 .

C. Maintenance and Modifications None .

I D. Surveillance 3A ID 4 .

E. Emergency Preparedness None .

F. Security and f.afeguards None .

,

G. Refueling and Oatege Management None .

H. Quality Assurance None .

I. Licensing Activities None .

TOTAL 8

Cause Codes: A. Personnel Error

'

B. Design, Manufacturing, Construction or Installation Error

C. External Cause

D. Defective Procedure

E. Component Failure

X. Other

,

,

!

.

- - -- w.m =2-- ,=-.-----e_--,. #- w---, - - - - - , - -.-

--r+- - - - - ,

. ..

...

., .

.

.

T-2-1

TABLE 2

LER SYNOPSIS (11/1/84 - 10/18/85)

VERMONT YANKEE NUCLEAR POWER STATION

LER Number Summary Description

84-23 An inadvertent group 3 isolation occurred during normal operation

while testing the Reactor Building Ventilation and Refueling Radi-

ation Monitors when I&C technicians removed the monitor bypass while

a trip signal was still simulated on the monitor.

84-24 Monthly functional testing of the HPCI Torus Water Level system was

not performed due to an administrative oversight in scheduling.

85-01 During the weeks of December 31, 1984 and January 7, 1985, while

environmental air sampling at Station AT2.1, it was discovered that

a continuous air sample was not taken as required by TS 3.9.D.2.

The failed environmental air sampling pump was replaced with a re-

paired spare pump.

85-02 During normal operations on January 28, 1985, upon reviewing of the

master surveillance list, it was found that a quarterly calibration

of LPCI. low reactor pressure #3 channel was not performed during

the week of October 25, 1984 as required by TS Table 4.2.1.

85-03 Monthly river water samples scheduled to be collected during the

week of January 13, 1985 were collected I week late. This was a

result of personal error and contrary to the sampling period allowed

by TS 4.9.D.

85-04 Reactor Scram from 100% power on February 6, 1985 due to a failure

of the core spray test switch in the Core Spray Logic Blocking Relay

K24B.

85-05 On April 2, 1985, during a refuel floor alarm functional calibration,

a group 3 primary containment isolation and standby gas treatment

initiation occurred due to personnel error.

85-06 On June 6, 1985, a break in the tubing in the system II Drywell

Hydrogen /0xygen Analyser resulted in a loss of Primary Containment

Intagrity for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> through the 1/4" diameter sample line.

. . _ ._.

p: ,

., .

..

~

.

T-3-1

TABLE 3

s VIOLATIONS (11/1/84 - 10/18/85)

VERMONT YANKEE N!!rLEAR POWER STATION

A. Number and Security Level of Violation

Severity Level I O

Severity Level II 0

Severity Level III 1

Severity L2 vel IV 7

Severity Level V 3

Deviation 0

Under Review 2

Total 13

B. Violation Vs. Functional Area

Severity Levels

i FUNCTIONAL AREAS I II III IV V DEV

A. Plant Operations

B. Radiological Controls 1

C. Maintenance and Modifications 1 1

D. Surveillance 2

E. Emergency Preparedness

F. Security and Safeguards *2 - TBD 3

G. Refueling and Outage Management

H. Quality Assurance 3

I. Licensing Activities

TOTALS 1 7 3

• 2 violations -Severity Levels To Be Determined

_

. - - _ . . .. ,-. . _ . _. . . . . , - . _ _

km

, .

,

.

.

T-3-2

C. Summary - Enforcement Data

Inspection Inspection Severity Functional

Report No. Date Level Area

85-06 1/28-2/1/85 IV QA Failure to take the neces-

sary corrective action to

improve the timeliness of

plant procedure reviews

85-08 2/5-3/4/85 IV M/M Failure to revise operating

and surveillance procedures

upon completion of fire

system modifications

V SURV Failure to test a testable

valve in the flow path of

the vital fire water system

85-11 3/11-15/85 IV QA Inadequate receipt inspec-

tion and storage program

for safety related systems

85-19 5/20-24/85 IV S/S Failure to complete alarm

recording requirements

IV S/S Failure to control CAS

security

IV S/S Duplication of CAS function

in SAS

85-21 8/9/85 III HP Failure to adequately train

(CP) HP technician for entry into

TIP room

85-22 6/3-12/85 V M/M Failure to properly control

the installation of safety

related replacement parts

85-25 8/5-9/20/85 V SURV Failure to identify dis-

crepant results during sur-

veillance testing

IV QA Failure to implement cor-

rective actions to preclude

recurrance of deficiencies

in the peer inspection

program

. - - . . ..

-

p .:

. , .

'

. _ . .

.

T-3-3

,

Inspection Inspection Severity Functional

Report No. Date Level Area

85-31 9/24-26/85 TBD S/S Failure to control access

to protected area

.

TBD S/S Failure to control. detection

aids

e

r

w

-

P

.

?

!

.- , , . . . . . . _ - . _ , ,

IIl..

a: ~*- ,

.--

T-4-1 '-

.  !.

., .

"~

TABLE 4'

'

INSPECTION HOURS SUMMARY (11/1/84 - 10/18/85)

,

~~ a VERMONT YANKEE NUCLEAR POWER STATION ,

s

s~ ,

m s ,,

HOURS  % OF TIME

A. Plant Operations . . . . . . . . . . . . . '. . 822 31

'

B. Radiological Controls. . . . . . . . . . . . . 351 13

,

"C. Maintenance and Modifications. . . . . . . . . 366 14

-

D.

-

Surveillance . . . . . . . . . . . . . 69 3

.s ., .

- ,

F E. Emergency Preparedness . > . . . . . . . . . . 327 12

F. Security and Safeguards. '. . . . . . . . . . . 92 3

G. Refueling and Obtage Management. .. ..... 147 6

~

-

. . ~s

H. Quality Assurance. . . . . . . . . . . .... 449 17

I. Licenstwi Activii'.ies

"

. . . . . ........ 30

'

1*

,

TOTAL 2653 100

%

-

s,;

• Most hours expended in facility licensing activities and operator license activi-

ties are not included with direct inspection liour statistics. The 30 hrs. reported

above resulted from an onsite inspection in support of a TAC on Degraded Grid

Protection. ,

,

\

\

'

\  !

,

i

.

U

.(

i k

,

4

s

"

a- a '

,

'l

w

> 'N

a , t

57*-

p --

. _

g d' Y "A %.#[t"w,* J

h.-iM. V -

. _- -

-

k*jl ,

.- 4

g w .

! 3 j? #

T-5-1

4

1

~ '

..

( (

'

,

s E

TABLE 5

'

. INSPECTION REPORT ACTIVITIES (11/1/84 - 10/18/85)

' l.

, , VERMONT YANKEE NUCLEAR POWER STATION

'

-

.

s

~ %; Inspection Inspection

g- ~ Report No. ,

Hours Areas Inspected

'

.,

84-22' [-

,,

88 - 1 Routine, Resident

~

i 84-24 72 Radiological Controls

1-

\n ,84-25- -

--

. SALP

'

'

84-26' 41 3 Routine, Resident

85-01 m,

--

License Exams

,

n .c ,

s 85-02 108- Routine, Resident

n" 'Ic ,

'85-03 '

24 Radiological Controls

'

,

85-04 . 111 Special Safety IEB 79-02 & 79-07

l

'

85-05 g, 32 . v Radio',ogical Controls

3

d 85'-06 ;78% Plant Procedures

'

'

85-07 56 Startup Testing

N- , ,

s '

85-08 135 '

Routine, Resident

". 3

, 4 ~ i,85-09 125 Emergenct Preparedness

., J:l9

'

<* 85-10 94 Routine, Resident

y

85-11 75 QA Records-Storage Program, Procurement,

Receipt Inspectiva Program s

85-12 License Examinations

'

--

85-13 158 Emergency Drill

85-14' 125 Routine, Resident

85-15 24- Enforcement Conference  ;

i ,,

85-16 s

--

Number Cancelled

l

' .j

t

4

h

j-

• -

e

e ~. ^*

.

.

T-5-2

Inspection Inspection

Report No. Hours Areas Inspected

85-17 72 Radiological Controls

85-18 113 Routine, Resident

85-19 28 Safeguards

85-20 177- Routine, Resident

85-21 5 Radiological Controls

85-22 165 Special Inspection IEB 83-28-Salem ATWS

85-23 122 Routine, Resident

85-24 34 Radiological Controls

85-25 170 Routine, Resident

85-26 146 Quality Assurance Program

85-27 14 Management Meeting 7/3/85 EP Drill Concerns

85-28 37 Radiological Controls

85-29 36 Degraded Grid TAC

85-30 139 Routine, Resident Outage Activities

85-31 14 Security Event Followup

85-32 35 Surveillance / Modification

_. _ - - - . _ . - . _ - - _ . . - -

O

. .

,

..

.

.

T-6-1

TABLE 6

SUMMARY OF LICENSING ACTIVITIES

1. NRR/ Licensee Meetings

--

February 13, 1985, Project Status Briefing

--

February 14, 1985, LOCA Analysis Methods

--

July 16, 1985, Fire Prevention, Appendix R,Section III.G Exemption

Requests

2. NRR Site Visits

--

April 1-4, 1985, Detailed Control Room Design Review,In-Progress Audit

--

October 15-17, 1985, Pipe Replacement Outage

3. Commission Briefing

None

4. Schedular Extension Granted

None

5. Reliefs Granted

None

6. Exemptions Granted

None

7. License Amendments Granted

--

December 4,1984, Amendment No. 84, Main Steam Line Low Pressure Setpoint

--

January 23, 1985, Amendment No. r~, HPCI Automatic Suction Transfer

--

February 21, 1985, Amendment No. 86, Main Steam Line High Flow Setpoint

--

April 1,1985, Amendment No. 87, Alternative Staffing Requirements

--

June 6, 1985, Amendment No. 88, Suppression Pool Temperature Limit

--

July 9, 1985, Amendment No. 89, Snubbers

--

October 9, 1985, Amendment No. 90, Shift Staffing, Organization Chart and

Condensate Tank Level Limit

8. Emergency Technical Specifications Issued

None

L I

_._ _ .

.. _ -_ _ _ _ . . __

, ,.. ..

e

,

T-6-2

1

9. Orders Issued

--

August 29, 1985, Order Cu. firming Licensee Commitments on Emergency

Response Capability

10. NRC/ Licensee Management Conferences

'

'

None -

t

4

%

+

c

,- - v- -._ , . - . . , - ,,,_y ... 3 , ,e.._ . - .,.-.e,-,.,,,-,w.-%,,,--,,,,,.p_,, , . , ,y.-__w,,,,y,,, ,_,, , a- , _ , - -g w, , , ,yms ._-, ,

- _. . - -

?,r"-

-

-

. T-7-1

+ .

. TABLE 7

PLANT SHUTDOWNS

Date Description Cause

November 1, 1984 Beginning of assessment

period plant at 100% power

February 6, 1985 Automatic Scram Main turbine trip and reac-

tor scram due to an inad-

vertent trip signal caused

by a faulty test switch in

the Core Spray Logic.

February 7, 1985 Startup - Continue to full

power operation

'

September 20, 1985 Scheduled shutdown. Shutdown for 1985/86 re-

circulation pipe replacement

and refueling outage.

-

l

4

--

,. p 9 .- e .

w---w ee-n- re-w+e--a w *

-p-7 T-vr' 'T' 7 "- "TM'' * **#"" ' ' * ""* ' '