ML20154R019
| ML20154R019 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 10/16/1998 |
| From: | Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Katz D CITIZENS AWARENESS NETWORK |
| References | |
| NUDOCS 9810260141 | |
| Download: ML20154R019 (7) | |
Text
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t October 16,1998 Ms. Deborah B. Katz, President Citizens Awareness Network, Inc.
P.O. Box 83
- Shelburne Falls, MA 01370
Dear Ms. Katz:
I am responding to the September 17,1998 letter from the Citizens Awareness Network, inc., which you presented to the U.S. Nuclear Regulatory Commission (NRC) during the Vermont Yankee SALP meeting at the Vernon Town Hall. In the letter, CAN questioned the validity of the NRC's SALP ratings for Vermont Yankee.
As you know, the SALP process was used to develop the NRC's conclusions regarding a licensee's safety performance. As was discussed with you following the SALP meeting, the NRC has suspended its SALP program for an interim period until the NRC staff completes a review of its nuclear power plant performance assessment process. At the
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end of this review, the NRC will decide whether to resume the SALP program or substitute something regarded as more effective. This decision to suspend SALP is part of an integrated plan to improve NRC's regulatory effectiveness.
- Relative to your concerns, the SALP report documents the NRC's observations and insights on a licensee's performance and communicates the results to both the licensee and the public. In addition, it provides a vehicle for dialogue with the licensee that focuses on plant performance. The SALP report includes selected examples of observations to illustrate the key assessments. ' As such, the SALP report is not intended to provide an
- exhaustive listing of all the NRC inspe'ction findings that were reviewed to determine the assessment.
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Vermont Yankee performance was assessed in four functional areas and was assigned a Category 2 rating in each. A Category 2 rating is characterized by normally well-focused
~ operations in the functional area that resulted in an overall good level of safety.
performance. This rating is not intended to imply that plant performance was error free.
The definition contained in NRC Management Directive 8.6 states that some deficiencies or
. problems may have existed, that some issues may have escaped self-identification, and that some corrective actions may not be completed. I have enclosed Management Directive 8.6 for your review.
The NRC has reviewed the information provided by CAN. We verified that this information was based on recent NRC inspection findings and observations made at the Vermut
. Yankee site, and had been included in the data package developed for this recent SALP
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assessment. As such, the SALP Board considered this information along with other relevant findings when implementing the~SALP process for Vermont Yankee.
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PDR ADOCK 05000271 G
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Ms. D. Katz 2
1 The SALP Board considered information about the plant's safety performance including inspection findings, licensee event reports, enforcement actions, the results of management meetings with the licensee, and the results of periodic plant performance reviews. In contrast to inspection reports that focus heavily upon identified problems, the SALP report ratings were a composite rating of performance based on the Board's balanced perspective of the issues and their safety significance.
In closing, I want to assure you that the issues that CAN raised regarding performance problems at Vermont Yankee were appropriately considered during the SALP process.
Further, we continue to believe that the functional area assessments accurately reflect Vermont Yankee's safety performance.
i Thank you for informing us of your opinion regarding Vermont Yankee's performance. We appreciate comment on our assessment processes and feel that such dialogue improves our understanding of the public's concerns and serves to better our reactor oversight activities. Should you have any additional questions, or if I can be of further assistance in this matter, please call me at (610) 337-5233.
Sincerely, Original Signed By:
Curtis J. Cowgill, Chief Projects Branch 5 Division of Reactor Projects Docket No. 50-271
Enclosure:
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Ms. D. Katz 3
l DISTRIBUTION:
Docket File (50-271)
PUBLIC HMiller, RI SCollins BBoger
' CThomas RCroteau CHehl, RI l
p DOCUMENT NAME: (G:\\ branch 5\\CANLTR.917
- PREVIOUS CONCURRENCE To receive a copy of this Mx.;,inde de in the box: "C" = Copy without attachment / enclosure
'E' = Copy with attachment / enclosure
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WAxeperf DATE 10/13 /98' 10// / 9'11 10/l3 /98 10/6 /98 NAME J4fffiller DATE (10/jg/98 10/.
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MA: Boa 83 Shoebume Falls,14A 01370 PS: 413439-5781E764 l
CT: 54 old Tumpska Road, Haddam, CT 06438 PM: 860 34s4431 vT:cJo BonIG4 Putney,vT 06344 PS:802487 4000 i
l NH: 9 Evens Road, Medbury, NH 03820 PM $03-742 4261 NY: 924 Rumet Ave. Swarcusa. NY 13203 315 472 8478/ 7923 C
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o QUESTIONS AND COMMENTS TO 141E NRC DURING THE SALP EVALUATION 9/16/98 Vemon Town Hall, Vemon VT CAN is concemed about the results of NRC's SALP evaluation of Vermont Ydnkee (VY) nuclear power station's performance. CAN strongly believes that the agency's 1997-1998 inspection reports point totserious weaknesses in Vermont Yankee's operation. Although NRC downgraded VY giving the reactor only a
- good' rating, many of the weaknesses and inadequacies documented in NRC specialinspections are serious and jeopardize the health and safety of.
Vermont Yankee's workforce and the public, and raise concems about the prctechon of the site itself.
In April 15,1998 NRC staff proposed a fine of $55,000 against VY for 3 of 12 violations found during an inspechon. Between September 29 and November 20*, NRC conducted a special inspection to follow up on findings of a Stone and Webster architect / engineer team inspechon in Spring,1997. The team reviewed the reactor's design and configuration for safety systems as
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well as conformance with the utility's safety analysis report. (a document which outlines
- l measures taken to maintain the facility at an adequate safety' level). Given VY's violations and potential fine, the fact that these issues, as well as the inadequacy of VY design basis documentation, were omitted from the SALP is confounding.
In the June 4* Inspecton Report 50-271/98-04 NRC inspectors found problems in radiological protection at the reactor. NRC states that'a senior radiation protection technician was providing essentially allof the coordination and control for activities involving initiation of cutting of torus downcomers on March 31 1998.* The inspector stated that the cutting of the torus downcomers 3
was a majo' task, which involved a ' significant challenge to radiological controls". The r
technician was not provided with defined responsibilities or authorities for performing the function.
The inspector observed
- weaknesses in radiological control briefings, inter and intra-departmental communicatiorks, and the recognition and resolution ofIndustrial safety Issues.....' The inspector found 'InsufHclent radiation protection personnel available to provide sufNclentjob coverage...".
The inspector concluded that the licensee was ' ineffective in establishing sufNclent and positive radiological control technician coverage of signifscant work involving torus modifications as evidenced by de#clent brie #ng of affected personnel, and insufficient technician resources to' cover significant radiological work in p.rogress. Additionally industrial j
safety issues ~..... wore not immediately recognized and addressed by licensee *, until the j
inspector brought it to VY's attention.
THE E20*ERIMENTIS OVER i
Web site: www.s=*aha==*=es.org e mail: cangshayonet.com i
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The report states that
- accrued person-rom was approximately twice that originally estimated and the man-hours were approximately four times that originally planned for preparation work." There were problems with ALARA:
The shielding for the drywell was not effective. There was open, unshielded locations where on goitty work was to occur.
ALARA recommendations from previous outages were not tracked or incorporated. Staff didn't know if previous recom'mendations were implemented.
The ALARA' group was provided with outage man-hour estimates only about a month before refueling. There was Iltde time for determining the expected cost of the outage relative to personnel exposure or to re asses exposure reduction initiatives.
The inspector observed that "workerihad been directed to suit up in protective clothing to wait entry into the torus.'...this potentially created heat stress problems for workers.
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Subsequently the licensee determined that this practice was inconsistent with the lessons leamed from previous heat stress event _s." (underline added)
In the June 24* 1998 NRC Inspechon Report 50-271-04 NRC notes "two violations....the first violation involved a short circuit of one of the main station batteries during a test evolution that was in part, a result of inadequate oversight of that activity by staten personnel. in addition, NRC found " problems with control of contractors during the torus project...' The second violation involved a " vital area access controlproblern identlSed by the NRC." More clearly, this violation involved 5 out of 7 NRC inspectors compromising W's perimeter and entering the compound undetected. One inspector.was canying a mock gun. Wih NRC take further enforcement acton against W for this serious breech of security? '
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In a July 16* 1998, Special inspection Report 50-271/98-80 Notice of Violation and Exercise of Enforcement Discrebon, NRC found 5 violations including inadequate safety evaluation' inadequate corrective action for a design deficiency, inadequate design control for failing to control Design Ba' sis Document changes, reducing commitments conoined in the NRC Quality Assurance program with out prior NRC approval. A civil penalty was not authorized because among others "the violation was not reasonably linked to current performance". Did the NRC consider the weaknesses in radiological control evidenced in the last refueling outage (only four months prior to the Inspechon) in its assessment to penalize VY?. NRC halted Vermont Yankee activities during the rehab of the torus in order to require W to re-asses its radiological control activities and ALARA commitments. Is this action by NRC insignificant?
David Lochbaum of the Union of Concemed Scientist raises in a separate document concems about the above average number of scrams at W. The
- loose screw" scram in which certain valves wouldn't open, then valves wouldn't close, an emergency generator tumed on, power was lost, a fuel rod didn't insert property, and first there was too much water in containment then too little. NRC monitored Vermont Yankee struggling to gain control of the reactor. A team of NRC'special inspectors was sent to analyze the conditions that led to the acadent before W could retum to operation. Although each malfunction in and of itself many be innocuous, the fact that all these errors occurred in succession during one incident is troubling. It raises serious questens about Vermont Yankee" competence. NRC ltself raised in inspection Report that the problems Vermont Yankee faced during'the scram were systemic to the
, ' system. Had W pracbeed a defense in depth approach to reactor operatens, as is required by NRC, it could have anticipated many.of the problems it incurred and dealt with them in a more effective and timely manner.
The numerous issues raised in special inspechons by NRC contradict the SALP's finding of " good'. The report appears to exclude Stone and Websters analyses, NRC confirmation of non-compliance with NRC regulations, the systemic nusmanagement involved in the engineering analyses that control the operabon of the reactor, the serious weaknesses in radiological control and compromised security (to name a few).
Given the inspecten reports, how can NRC justify its " good' rating for Vermont Yankee?
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Subject:
Coments on Vermont Yankee SALP Author: Davel Date:
9/4/9812:23 PM Debby:
i I reviewed the Vermont. Yankee SALP report issued by the NRC on Augsut 28,1998, and have the following ^ comments:
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- l. In the transmittal letter, the NRC commended VY for senior management involvement that resulted in improvements to plant performance. According to NRC, "Particularly noteworthy was management's implementation of the Configuration Management Improvement Project, which improved identifcation of design and licensing issues."
In reality, this apparent postive is a negative. Had management at VY been doing its job all along, there wo' ld not have.been such a dire need for improvement at the facility.
u Additionally, this NRC summary curiously omits several key facts. For example, on
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October 9,1996, the NRC sent VY a letter demanding that VY review the adequacy and.
availability of design information. VY responded under oath or aflirmation in early 1997 that it had everything under control. In summer 1997, an NRC design inspection team found significant problems with the residual heat removal system at VY and concluded that VY would have not been able tofind these design problems, it was only after the enforcement conference to discuss these violations that VY aedelerated the pace ofits configuration management improvement project. Thus, VY's management is reactive rather than pro-active. Pro-active management is good. Reactive management is not so good.
- 2. Section 11 of the SALP report rated the Operations Area at VY as 2. The NRC stated that " Operators performance in response to abnormal conditions and plant transients was also very good with few exceptions."
The SALP report stated that " operator followup actions complicated the recovery" from a reactor scram in June 1998. In addition, " Placing two 'down-scale' average power range monitors (APRMs) in service, and poor coordination of switchyard activities are 4
two examples of human performance errors that led to reactor scrams."
According to the NRC's NUREG-1272 Vol. 9 No.1, the average BV(R plant experienced 1.81 reactorscrams in 1991,1.78 in 1992,1.62 in 1993,1.41 in 1994, and l.46 in 1995. Roughly one-third of these reactor scrams ' were manually initiated for planned outages.
l VY had at least two (2) reactor scrams caused by operator error during this SALP j
period and another reactor scram was complicated by operator error. VY had more reactor scrams casued by operator error than the average BWR plant had caused by all reasons.
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.,y In addition, theNRC stated that VY operations took 14 days to make a 4-hour report of a problem to the NRC. This is not performance that is "very good with few execptions."
- 3.Section IV of the SALP report rated the !!ngineering Area as 2. The NRC stated that
" engineering personnel were knowledgeable.:
By letter dated Augiist 27,1997, the NRC stalTtransmitted Design Inspection Report 50 271/97-2,01 to Vermont Yankee 6he transmittal letter stated that "the team concluded that it was unlikely that [ Vermont Yankee personnel] would liave uncovered some of the issues identified in this report."
That design inspection report documented serious design problems with the residual heat removal system. Given that the NRC thought that VY stafTcould not uncover serious design problems, it is not apparent that a 2 rating is justined.
The NRC reported they found "inctTective radiological oversight of work,"
"insuflicient radiation protection stamng," " notable performance deficiencies," and
." radiological briefings of workers conducted prior to the start of work were ineffective."
The NRC reponed that " senior licensee management suspended work" during the recent refueling outage after the NRC identified numerous radiation protection problems to them.
Afler resuming work, the NRC repored that poor planning and execution " caused some airborne radioactive materials to be exhausted into the reactor building."
4 if these misadventures represent " Good" performar.ce, what would be " bad" performance. The NRC had to step in and force VY management to correct serious
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problems during the outage. That is NOT goo d performance on VY's part.
The NRC must have graded VY using a very generous curve. I cannot understand operators can cause more reactor scrams than the industry experiences and get a " Good" rating or how Engineering can be incapable of finding design problems and get a " Good" rating or how Plant Support cannot'self identify radiation protection problems and get a
" Good" rating. Using the same grading system, I'd assess NRC's performance on this SALP report as " Good."
Dave Lochbaum Union of Concemed Scientists
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