ML20151V335
| ML20151V335 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 09/02/1998 |
| From: | Mulligan M AFFILIATION NOT ASSIGNED |
| To: | Victor Dricks NRC |
| Shared Package | |
| ML20151V302 | List: |
| References | |
| NUDOCS 9809140248 | |
| Download: ML20151V335 (6) | |
Text
_ _ _-._-_ _..____ _ _
i i
From:
' Michael Mulligan * <m. mulligan @worldnet.att. net >
To:
' Victor Dricks' <VL
Dearc. gov >,
'Raymond shadis' <s...
Detet 9/2/93 3:16pm
Subject:
Vermont Yankee; Engineering Safety Concern.
Mr. Dricks l
Recently many nuclear utilities have recognized the need to combine engineering resources. Somebody said that a single nuc plant, just can't go i
it alone. Considering VY's long term weakness in engineering, and the concerns raised in VY's latest SALP, is VY's engineering strategy of " going i
it alone*, swimming against the tide. The NRC seems to be saying that the l
bumpy road transitioning from YA to a fhily on site engineering organization is normal. The question is, do we have any objective historical information on successfbt transitioning of this type. Has anybody asked themselves at the NRC, could these engineering troubles be the beginnings of a type of engineering exhaustion with the group. /Je the engineers putting in to many l
hours? Has the NRC inspectors been proactive enough to ask the engineers, with the major owners having budget and rue troubles, are there enougl.
resources being provided to the VY engineers.
I request that the NRC do a safety study, a case study, on Vermont Yankee's Engineering Departments repeated reorganizations over the pau decade. There is not one place that the public can get an understanding on engineering, licensing and design problems, which fueled these reorganizations. You could make a case that th:s looks like Millstone before the shutdown, in that there was repeated plans for corrections and reorganizations that ended up just throwing paperwork at the employees, while desensitizing the NRC. Has
)
[
l the NRC ever met a reorganization they didn't like? These reorganizations are telegraphing to the public very important information on public safety.
Has the NRC considered analyzing plant reorganization and employee shifting jobs, as a method of predicting a decline in management / plant performance?
Is Vermont Yankee responding to a functionally defective regulatory agency who has yet figured a way out of the woods, but must look competent? I l
believe a reasonable person who had the history of this organization could
)
4 made a prediction on the direction of VY engineering and past industry wide l
lessons, which have been forgotten already, mike mulligan i-i l
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9809140248 980910
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PDR ADOCK 05000271 H
PDR ENCLOSURE 1 p
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e j,ReactorLicensus hapd/www.nrc.sw/OPA/smohip/ process.be 1
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i Evaluating Reactor Licensees As part ofits mission to protect public health and safety and the environment, the Nuclear Reg Commission (NRC) momtors and evaluates the safety performance oflicensees who operate more tha i
100 commercial nuclear plants in the United States, nis rigorous oversipt includes evaluating concerns, assessing operational events and experience, and reviewin evaluations and actions are based on publicly available information.g enrorcement actions. All Ni I
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ne process used to determine the level ofplant safety is comprehensive to ensure NRC has an accurate
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and objective understanding. It involves a number of NRC programs that continually examine plant operations, operational events and plant management. Two pror; rams-inspections and analysis of i
operational data-provide primary mformation that is used in et ser evaluations by the NRC's staff. About once every six months, NRC semor managers meet with the Commission to discuss the ?crformance of i
nuclear power plants based on the staffs evaluations. These meetings are held at NRC's acadquarters in l
Rockvil. e, Maryland, and are open to the public, t
INSPECTION PROGRAM i
NRC resident inspectors assigned to specific plant sites, augmented by specialists from headquarters i
regional offices, conduct year-round inspections oflicensee activities. Inspections are planned and i
aerformed both routinely and in response to events, enforcement, allegations or emergmg issues.
mspection findings and conclusions are documented in reports, which are reviewed and approved by the a
inspectors' managers. These reports and associated findings are available for review and analysis b l
NRC offices and by the public, s'
j ANALYSIS OF OPERATIONAL DATA PROGRAM j
In addition to the day to-day and special inspections, mechanical, electrical and other plant problems are carefully analyzed by the NRC. Reviews are conducted by the Office of Nuclear Reactor Regulation l
(NRR), which has primary responsibility for oversight of the inspection program for nuclear plants, and j
the Office for Analysis and Evaluation of Operational Data (AEOD).
ne NRR reviews reports from licensees, NRC inspectors and industry groups to assess their safety j
im ;>ortance, generic implications and the need for any immediate corrective action. AEOD screens ind ividual plant events or incidents to identify forerunners to potential severe accidents. In addition, 1
AEOD conducts an analysis of plant operating experience as reflected in eight performance indicators l
(PI). These indicators include data on unplanned automatic reactor shutdowns, equipment and safety system failures and worker radiation ex i
highlights trends in safety performanceposures. AEOD's findings are published in a repor both good and poor.
Stemming from these two arograms are other evaluative processes, described below, that NRC uses to j
j assess plant performance. '"hese vary in scope, frequency, level ofreview and duration.
j Plant Performance Reviews i
i At least semi annually, NRC staffin each of four regional offices bring together the findings of NRC i
inspectors, AEOD analyses and enforcement actions (i.e., penalties for heensee violations ofNRC months. D)ese assessments, called plant performance reviews (PPRs) plants require additional close attention for the next six months. Rese penodic reviews also are a
?rimary source ofinformation in assessing plant Meetings. The results of PPRs are made public. performance for the semi-annual Senio Integrated Performance Assessment Process (IPAP)
Independent of day-to-day oversight of nuclear plants by the resident inspectors, teams of senior NRC ENCLOSURE 2 Jtre
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, ReactorLicensets 1
hap://www.nrc.sw/OPA/gmo/tip/ process.hu i
inspectors conduct integrated rmance assessments at selected plants each year. The purpose is to Venfy that a licensee's actual rformance matches the perfonnance reflected in written records for the arevious two years. Findings om the IPAP provide direct input to the Systematic Assessment of licensee Performance (SALP) program that is described below. An IPAP report with final conclus include recommendations for future plant inspections and is made available to the public.
SALPs ne SALP evaluations employed by the NRC are conducted every 12 to 24 months to assess lon performance of each nuclearpower plant. The staffreview includes the use of boards comprised'g oftwo managers from a regional office and a manager from NRR. De board members review inspection results, enforcement actions that may have been taken against a licensee, and results of the latest PP IPAPs, performance indicators, licensee self-assessments, third party assessments and in-depth discussions with licensees. Typically, the board also visits the facility for a first hand assessment. The result of the SALP review is a report that assigns one of three ratings to a plant: I for superior performance,2 for good performance and 3 for acceptable performance. The ratings focus on four managers use the SALP findings to identify those area,s(at a p ant that req utre mereased mspection. functional areas: (1) plant operations, Generally, a plant receives a SALP review every 12-18 months. Plants whose performance is rated superior may have the period extended to 24 months before another SALP is performed. All SALP reports are made available to the public.
I Senior Management Meetings About two months before the semiannual Senior Management Meeting (SMM), the four regional l
administrators and the Director oiNRR discuss at a screening meeting the numerous staff assessments and inspection results for each plant nationwide. Results of PPRs, performance indicators, inspection findings and SALPs are considered at these meetings. If a plant's performance appears to be declining significantly, or if there are significant concerns about its performance, it will be placed on the agenda for discussion at the SMM.
The SMMs are chaired by the NRC's Executive Director for Operations and include all regional administrators, office directors and senior managers. To arrive at an objective evaluation of a o perational safety performance, the managers use a standard set of questions in five ar e:Tectiveness oflicensee self-assessment,2) operational performance (frequency of abnormal events),3) human performance,4) material condition (safety system reliability / availability and 5) engineering and prformance is of most concern and warrant increased NRC design. With this template of questions guiding discussions, the mana l
i These plants are placed on NRC's Watch List." Plants already on the Watch List that have demonstrated improved performance over an extended period may be taken off the list. Plants that have demonstrated superior performance are also identified.
The Watch List has three categories:
l
!) Plants removed from the list;
- 2) Plants authorized to operate that NRC will monitor most closely; and
- 3) Shutdown plants requiring NRC authorization to resume operations and which NRC will monitor closely.
After the Senior Management Meeting, the safety performance ofplants that are,placed on or taken off the Watch List are discussed at the semi annual public meetings with the Commission, generally during
. summer and winter timeframes. Also discussed are those plants whose performance is trending downward.
The NRC notifies the chief executive officers of the utilities operating those plants ofconcem to the m
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s. Ruetor Licensus hap://www. arc.gw/OPA/gmWpW.he I
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agency and indicates the need to conect weaknesses. Those having plants removed from the list and those which have demonstrated superior perfonnance are also nonfied.
July 199'6 Send Comments or Questions to ova @nre. uoy i
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.... ;. ~.. - - -
-..-.. ~.=. -.. -.- -.......
f.
l lh FROM:
ORIGINAL DUE DT:
/
/
TICKET NO: 0980187 DOC DT: 09/02/98 NRR RCVD DATE: 09/04/98 TO:
Victor Dricks FOR SIGNATURE OF :
- YEL l
DESC:
ROUTING:
Vermont Yankee; Engineering Safety Concern Collins /Miraglia Boger Sheron Roe Zimmerman NRR Mailroom ASSIGNED TO:
CONTACT:
DRPE Zwolinski' SPECIAL INSTRUCTIONS OR REMARKS:
For appropriate' action l
I 1
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.m
-- _ ~ -. -. - - -
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I 8
From:
' Michael Mulligan * <m. mulligan @woridnet.att. net >
To:
" Victor Dricks* <VLD@nrc. gov >, "Raymond shadis' <s...
Date:
9/2/98 3:16pm l
Subject:
Vermont Yankee; Engineering Safety Concern.
Mr. Dricks Recently many nuclear utilities have recognized the need to combine engineering resources. Somebody said that a single nuc plant, just can't go it alone. Considering VY's long term weakness in engineering, and the concerns raised in VY's latest SALP, is VY's engineering strategy of " going it alone", swimming against the tide. The NRC seems to be saying that the bumpy road transitioning from YA to a fully on site engineering organization is normal. The question is, do we have any objective historical information on successful transitioning of this type. Has anybody asked themselves at the NRC, could these engineering troubles be the beginnings of a type of engineering exhaustion with the group. Are the engineers putting in to many hours? Has the NRC inspectors been proactive enough to ask the engineers, with the major owners having budget and rate troubles, are there enough resources being provided to the VY engineers.
I request that the NRC do a safety study, a case study, on Vermont Yankee's Engineering Departments repeated reorganizations over the past decade. There is not one place that the public can get an understanding on engineering, licensing and design problems, which fueled these reorganizations. You could make a case that this looks like Millstone before the shutdown, in that there was repeated plans for corrections and reorganizations that ended up just throwing paperwork at the employees, while desensitizing the NRC. Has the NRC ever met a reorganization they didn't like? These reorganizations 1
are telegraphing to the public very important information on public safety.
Has the NRC considered analyzing plant reorganization and employee shifting i
jobs, as a method of predicting a decline in management / plant performance?
Is Vermont Yankee responding to a functionally defective regulatory agency who has yet figured a way out of the woods, but must look competent? I believe a reasonable person who had the history of this organization could made a prediction on the direction of VY engineering and past industry wide lessons, which have been forgotten already. mike mulligan i
}'
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4 Y
l FROM:
ORIGINAL DUE DT:
/
/
TICKET NO: 0980187 DOC DT: 09/02/98 NRR RCVD DATE: 09/04/98 10:
'FOR SIGNATURE OF :
- YEL DESC:
ROUTING:
l Vermont Yankee; Engineering Safety Concern Collins /Miraglia Boger I
Sheron Roe Zimmerman NRR Mailroom l-ASSIGNED TO:
CONTACT:
DRPE Zwolinski SPECIAL INSTRUCTIONS OR REMARKS:
l l
'For appropriate action l'
5 lr
/
f
\\
Fromt
' Michael Mulligan' <m. mulligan @worldnet.att. net >
To:
" Victor Dricks* < VLD@nrc. gov >, 'Raymond shadis' < s...
Date:
9/2/98 3:16pm
Subject:
Vermont Yankee; Engineering Safety Concern.
Mr. Dricks Recently many nuclear utilities have recognized the need to combine engineering resources. Somebody said that a single nuc plant, just can't go it alone. Considering VY's long term weakness in engineering, and the concerns raised in VY's latest SALP, is VY's er'gineering strategy of " going it alone*, swimming against the tide. He NRC seems to be saying that the bumpy road transitioning from YA to a fully on site engineering organization is normal. The question is, do we have any objective historical information on successful transitioning of this type. Has anybody asked themselves at the NRC, could these engineering troubles be the beginnings of a type of engineering exhaustion with the group. Are the engineers putting in to many hours? Has the NRC inspectors been proactive enough to ask the engineers, with the major owners having budget and rate troubles, are there enough resources being provided to the VY engineers.
I request that the NRC do a safety study, a case study, on Vermont Yankee's Engineering Departments repeated reorganizations over the past decade. There is not one place that the public can get an understanding on engineering, licensing and design problems, which fueled these reorganizations. You could make a case that this looks like Millstone before the shutdown, in that there was repeated plans for corrections and reorganizations that ended up just throwing paperwork at the employees, while desensitizing the NRC. Has the NRC ever met a reorganization they didn't like? Dese reorganizations are telegraphing to the public very important information on public safety.
Has the NRC considered analyzing plant reorganization and employee shifting jobs, as a method of predicting a decline in management / plant performance?
Is Vermont Yankee responding to a functionally defective regulatory agency who has yet figured a way out of the woods, but must look competent? I believe a reasonable person who had the history of this organization could made a prediction on the direction of VY engineering and past industry wide lessons, which have been forgotten already. mike mulligan i
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