ML20206M905
| ML20206M905 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 08/14/1986 |
| From: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Opeka J CONNECTICUT YANKEE ATOMIC POWER CO. |
| Shared Package | |
| ML20206M911 | List: |
| References | |
| NUDOCS 8608260020 | |
| Download: ML20206M905 (3) | |
See also: IR 05000213/1985098
Text
,v
,,
Y .
AUG 141986
Docket No. 50-213
Connecticut Yankee Atomic Power Company
ATTN: Mr. J. F. Opeka
Senior Vice President - Nuclear
Engineering and Operations Group
P. O. Box 270
Hartford, Connecticut 06101 l
Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP) Report Number
50-213/85-98 and Your Reply Letter Dated June 30, 1986
This letter refers to the Systematic Assessment of Licensee Performance (SALP) of
the Haddam Neck Nuclear Power Plant for March 1, 1985 through February 28, 1986,
initially forwarded to you by our May 23, 1986 letter (Enclosure 1). This SALP
evaluation was discussed with you and your staff at a meeting held in Berlin, Con-
necticut on May 29, 1986 (see Enclosure 2 for attendees). We have reviewed your
June 30, 1986 written comments (Enclosure 3) and herewith transmit the final report
(Enclosure 4).
We appreciate your responses to staff comments and your discussion of plans to im- '
plement Board Recommendations and corrective actions. We acknowledge your position
on issues such as decontamination of areas, Appendix J resolution, feedwater iso-
lation valves, and the scheduled duration of the refueling outage.
After considering our discussions witn you et the management meeting and your re-
sponse letter, we have re-evaluated and revised the Emergency Preparedness (EP)
section of the SALP Report to clarify EP staffing, interactions among emergency
response facilities, and participation of the State and local communities. While
our rating in this functional area remains the same, the trend has been changed
from Consistent to Improving.
We have also modified the Refueling and Outage Management analysis to reflect out-
age planning identified in your written comments. This revision did not result
in a change in the associated SALP rating.
Your cooperation with us is appreciated.
Sincerely,
OMgTnal signea by
Thomas E. Mur. leg
Thomas E. Murley
Regional Administrator
8608260020 860814
PDR ADOCK 05000213
G pne
i
1
\
-_ - -
.
aMb ,? .
.
,
Connecticut Yankee Atomic Power Company 2
ggg14gggg
.
. Enclosures:
1.,c NRC Letter, T. E. Murley to J. F. Opeka, May 23, 1986
2. SALP Management Meeting Attendees, May 29, 1986
3. Connecticut Yankee Atomic Power _ Company Letter, J. F. Opeka to
T. E. Murley, June 30, 1986
-, . 4. NRC Region I Systematic Assessment of Licensee Performance (SALP)
Report ,No. 50-213/85-98
cc w/encls:
R. Graves, Plant Superintendent
D. O. Nordquist, Manager.of Quality Assurance
R. T. Lacdenat, Manager, Generation Facilities Licensing
E. J. Mroczka, Vice President, Nuclear Operations
Gerald Garfield, Esquire
Chairman Zech
Commissioner Roberts ,
Commissioner Asselstine
Commissioner Bernthal
Vandana Mathur, McGraw-Hill Publications (2 copies) (FINAL SALP REPORT ONLY)
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
,
State of Connecticut
bcc w/encls:
Region I' Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
Section Chief, DRP
T. Murley, RI
~
. J. Taylor, RI
K. Abraham, RI (2 copies)
F. Akstulewicz, LPM, NRR
SALP Management Meeting Attendees
,
i
,
/
RI:DRP RI:DRP RI:DRP RI:DRS RI:DRP RI:DRA
Kray/meo* McCabe* Wenzinger* Martin * Starostecki* Allan8 r ey
7/30/86
0FFICIAL RECORD COPY
- SEE PREVIOUS CONCURRENCE PAGE.
1
- - -
_ _ _ _
. _ _ _
< . ja ) ,
,
.
,
w
Connecticut Yankee Atomic Power Company 2 AUG 141906.
cc w/encls:
R. Graves, Plant Superintendent
D. O. Nordquist, Manager of Quality Assurance
R. T. Laudenat, Manager, Generation Facilities Licensing
E. J. Mroczka, Vice President, Nuclear Operations
Gerald Garfield, Esquire
Vandana Mathur, McGraw-Hill Publications (2 copies) (FINAL SALP REPORT ONLY)
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of Connecticut
bcc w/encls:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
Section Chief, DRP .
M. McBride, RI, Pilgrim
J. Shediosky, SRI, Millstone 1&2
T. Rebelowski, SRI, Millstone 3
F. Akstulewicz, LPM, NRR
Robert J. Bores, DRSS
,
i
.
,_.
R DRP
~
P I.d; RI:RA
b:DRPy , 4
Kray/me'o cpa zinger S pcki A/ lpj hK Murley
- 30/86 yf fg 6 l g f i $
t// i
@ OFFICIAL RECORD COPY
g rt
c % .-.-
- , - - - . - , , , . - , , . 9
, . . -. - - -
,
y6
t
UNITED STATES ENCLOSURE 1
_ /p ** 4 C g.,'c,
NUCLEAR REGULATORY COMMISSION
,,. g c / }
- %y) - ,
f REGION I
631 PARK AVENUE
% ? 54G g
'%
KlNG OF PRUS$f A, PENNSYLVANIA 19406
"%,
.....c
MAY 2 31985
Docket No. 50-213
Connecticut Yankee Atomic Power Company
ATIN: Mr. J. F. Opeka
Senior Vice President - Nuclear
Engineering and Operations Group
P. D. Box 270
Hartford, Connecticut 06101
Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP) Report No.
50-213/86-98
On April 24, 1986, the NRC Region I SALP Board reviewed and evaluated the perfor- This
mance of activities associated with the Haddam Neck Nuclear Power A Station.
meeting has been
assessment is documented in the enclosed SALP Board report.
scheduled for May 29, 1986 at 1:00 p.m. at the site to disruss this assessment.
That meeting is intended to provide a forum for candid discussions relating to the
performance evaluation.
At the meeting, you should be prepared to discuss our assessment and your plans
to improve performance. Any comments you may have regarding our report may be
discussed. Additionally, you may provide written comments within 30 days after
the meeting.
The present SALP describes continued acceptable ove.rall performance; however, as
the enclosed recent SALP rating history summary shows, Haddam Neck SALP ratings
have generally declined since 1981-82. We particularly wish to discuss your views
on the reasons for the lower performance ratings.
Thank you for your letter dated March 13, 1986 informing us of the status of the
corrective actions resulting from our previous SALP report. A copy of your letter
is also enclosed.
Following our meeting and receipt of your response, the enclosed report, your re-
sponse, and a summary of our findings and planned actions will be placed in the
NRC Public Document Room.
Your cooperation is appreciated.
Sincerely,
J
Thomas E. Muri ~
Regional Administrator
.
h
- , ,
-
.%
.'
ENCLOSURE 2
HADDAM NECK SALP MANAGEMENT MEETING
BERLIN, CONNECTICUT
MAY 29, 1986
Licensee
W. Ellis, Chairman, Northeast Utilities
J. Opeka, Senior Vice President
G. Bouchard, Station Services Superintendent
R. Kacich, Licensing Supervisor
R. H. Graves, Station Superintendent
J. H. Ferguson, Unit Superintendent
P. Terragna, Manager, CPS &OC
D. O. Nordquist, Manager, Quality Assurance
G. R. Pitman, Chairman, CY Nuclear Review Board
G. Baston, Director, NS&OS
E. Mroczka, Vice President, Nuclear Operations
A. Hajek, Vice President, CPS &OC
R. Harris, Director, Nuclear Engineering Department
P. L'Heureux, Engineering Supervisor
S. Shea, Betterment Construction Superintendent
K. B. Hastings, Betterment Construction Supervisor
P. F. Santoro, Director, Generation Projects
W. C. Renfro, Director, Environmental Programs
L. Nadeau, Manager, Generation Projects
R. J. Schmidt, Supervisor, Special Programs / Reliability Engineering
R. E. Bireley, Generation Facilities Licensing
NRC '
T. E. Murley, Regional Administrator
R. W. Starostecki, Director, Division of Reactor Projects (DRP)
T. T. Martin, Director, Division of Radiation Safety and Safeguards (DRSS)
E. C. Wenzinger, Chief, Projects Branch No. 3, DRP
E. C. McCabe, Chief, Reactor Projects Section 3B, DRP
P. Swetland, Senior Resident Inspector
S. M. Pindale, Resident Inspector
C. I. Grimes, Director, Integrated Safety Assessment Project Directorate, Office
of Nuclear Reactor Regulation (NRR)
F. M. Akstulewicz, Project Manager, NRR
i
1
l _
_ _
, $- _.
~
"
=
ENCLOSURE 3
e $
CONNECTICUT YANKEE ATOMIC POWER COMPANY
B E R L I N, CONNECTICUT
g P o Box 270 HARTFORD. CONNECTICUT 06141-0270
TELEPHONE
203-665-5000
June 30,1986
Docket No. 50-213
B12127
Dr. Thomas E. Murley, Regional Administrator
Region I
U. S. Nuclear Regulatory Commission
631 Park Avenue
King of Prussia, PA 19406
Gentlemen:
Haddam Neck Plant
Systematic Assessment of Licensee Performance
The Staff recently forwarded the SALP Board Report (l) for the twelve (12)
month period ending February 28, 1986 for the Haddam Neck Plant. Subsequent
to receipt of the SALP Board Report, a meeting was held on May 29, 1986
between members of the Staff and members of Connecticut Yankee Atomic
Power Company (CYAPCO).
The purpose of this letter is to respond to and comment on the findings of the
SALP Board with particular emphasis on the Board recommendations for the
individual evaluation categories. Attachment A to this letter contains the
CYAPCO response to each of the Board's recommendations for the Haddam Neck
Plant.
CYAPCO takes very seriously the ratings and recommendations given by the
l
!
Board as an input into the continuing process of evaluating and improving our
overall performance in the operation c . the Haddam Neck Plant. As pointed out
- in the May 29, 1986 meeting, it is the desire of CYAPCO to return to the
'
situations which existed in previous SALP evaluation periods when all ratings for
the Haddam Neck Plant were Category 1. It is a positive aspect of the SALP
>
Board Ratings and meetings that a frank discussion and dialogue between the
Licensee and the regulatory agency allows any perceived weaknesses to be
identified and studied so that a meaningful effort may be made to correct any,
conditions which stand in the way of the Staff determination that our efforts in
operating the Haddam Neck Plant are anything less than aggressive, thorough,
and of a high level of performance.
i' /
(1) T. E. Murley letter to 3. F. Opeka, "SALP Report No. 50-213/86-98," dated
May 23,1986. .1)/30
- '
.
l
- -
.
.
'&
-2-
During the meeting of May 29, 1986 certain goals were expressed on the part of
CYAPCO which would be a part of our efforts to correct those facets of plant
operation which could deter the Staff from arriving at a Category I rating for all
categories. Chief among those goals was a series of meetings during the current
evaluation period, on a quarterly basis, with the first meeting in September 1986
and culminating in a pre-outage meeting to take place during the planning stages
of the next scheduled refueling outage for the Haddam Neck Plant. It should be
noted that with the present schedule for the Haddam Neck plant refueling
outage, the next SALP Board meeting will occur approximately one month prior
to the outage. It may well be possible to coordinate these meetings so that both
purposes are accomplished with a single visit.
As reflected in our comments during the May 29, 1986 meeting, we generally
concur with the Board's observations. We have previously taken or are now
taking steps to address all identified concerns by applying corrections to the
concerns which have been idritified, while seeking to identify the root cause of
any situations which have lead to a collective rating less than Category 1.
'
We trust that the actions presented in the attachment for addressing the
concerns of the Board and our general comments will be considered in subsequent
SALP evaluations. We will be updating you regarding the status of implementing
the corrective actions discussed herein prior to the next SALP evaluation.
Very truly yours,
CONNECTICUT YANKEE ATOMIC POWER COMPANY
h .%. % a
3. F. Opeka '
Senior Vice President
By: C. F. Sears
Vice President
-
,y. - -- -,y
- *
,
s ,
e
.~
Docket No. 50-213
Attachment A
Connecticut Yankee Atomic Power Company
Haddam Neck Plant
Response to SALP Report
.
l
.
i
l
l
'
'
June,1986
?
i
I
_ _. .,
_ _ . _ . _ _ _. . _ _ __ ._ _ _ _ _ .
- *
.
- . ,
- -
.
..~
!
i Functional Areat Plant Operations
.
Board Recommendation: None
Response:
CYAPCO wishes to take this opportunity to address several of the points made
by the board in the body of the narrative under the heading of Plant Operations,
j The report recognizes that the overall quauty of LER's has improved. This
improvement is the direct result of earlier identification of the need for an LER
and the prompt assignment of a responsible engineer. Additionally, a staff
4
,
engineer has been assigned the responsibility of final LER review prior to Station
Superintendent approval. We believe that LER quality and thoroughness will
continue to improve as a result of this increased preparation time and additional
staff engineer oversight.
In the area of PORC performance, we are currently evaluating the performance
of the PORC to identify areas that can lead to greater efficiency and
' effectiveness. The use of subcommittees to review material prior to the PORC
meetings will be encouraged. It is our intention also to consult with other plants
4
to learn from their good practices in the area of PORC performance.
In response to the Board's comments on housekeeping, we would like to point out
that a continuing emphasis by plant management is being placed on good
housekeeping practices. Frequent plant tours by supervisors focus attention on
areas deficient in housekeeping. The Haddam Neck Plant has a long standing
a
reputation for being a clean and well maintained site. In keeping with this
j
reputation, a site upgrade plan is currently in preparation. It is expected that
!
this plan will provide management with an integrated approach to site
! Improvement. Specific improvements include current radiation control areas
such as the residual heat removal pit and the pipe trenches which are expected
to be released for easier access by the end of 1986.
J
'
.
Our recurrent problems in the control of fire doors appear to now be under
control. Contractor employees, in particular, did not have an appreciation for
the importance of fire doors. This lack of attention led to several instances of
doors being left open or unlocked. In almost every case, these deficiencies were
identified and reported by plant employees. Contractor and plant employees
have been reminded of the fire door requirements. Also, it should be noted that
,
upon startup from the most recent refueling shutdown, a firewatch was
l established to provide surveillance of many plant areas.
l
I
4-
,s .
-
.
.o
Functional Area: Radiological Controls
Board Recommendation: Conduct a comprehensive management review of the
ALARA program to implement the changes necessary to achieve an effective
program.
Response:
The SALP Board failed to recognize that CYAPCO has returned a large amount
of previously contaminated areas to an uncontaminated (radiologically clean)
status. This new level of cleanliness has improved access to these areas, reduced
the radiation exposure, and reduced the potential for spread of contamination.
We feel that this was a significant accomplishment and should be recognized as
such.
Although two incidents attributed to a weakness in the Radiological Incident
Reporting (RIR) System were noted by the Board, the content of inspection
reports is evidence that the system and management hwolvement are improving.
We believe that the RIR system is working and will continue to reduce the
frequency of radiologicalincidents.
! The reoccurrence of minor, self-identified radiological control procedure
violations is being addressed. The recent improvement of the station RIR
System, besides increasing the reporting and documentation of these incidents,
also increases management awareness. The Station Health Physics department
has extended the zone coverage mode of operation to the non-outage period.
Health Physics technicians are assigned to the same zone for an extended period
which increases familiarity, ensures continuity, and increases accountability.
A significant amount of discussion at the May 29, 1986 meeting centered on
'
perceived weaknesses in the ALARA program. The ALARA goals program in
1985 was successful in that the annual goal for a non-outage year of 118 man-
rem was met with a total of 113 man-rem. The ALARA program was successful
in 1985 and during the early 1986 outage work in that higher exposures were
averted using exposure reduction techniques. Examples of exposure savings by
the ALARA program are:
o The 1985 ALARA goal program generated a growing awareness of the
exposure reduction efforts by the ALARA group members and the
workers themselves. Combined endeavors resulted in a year of less
power entries, more interaction with the Production Maintenance
Management System (PMMS), and pre-planning of work.
, o An extensive decontamination of containment was incorporated into
l
the outage schedule prior to the start of any work. This excellent
contamination reduction accomplished less restrictions for protective
clothing requirement. Also the ALARA group installed general area
shielding and ALARA control signs at the same time, initially
reducing general exposure area.
.- - - . - -- --_ _ . ,.- . - - - - - .
- _ - _ _ . . - - _ -
.. ,
.
.~
o The Cavity Drain Line replacement was indicative of an excellent
ALARA job completed at 53% of the goal. An early ALARA review
was prompted by the Plant Design Change Request being approved
months in advance of the job. The task leader was well informed of
the complete scope of the job which enabled an accurate ALARA
review, supervision of the job, man hour estimates and utilization of
ALAR A concepts.
o The use of video equipment to monitor high radiation dose rate jobs
resulted in a savings of more than 40 man-rem during the 1986
refueling outage. This type of system will continue to be used during
all major outages.
To implement a more effective ALARA process within the various functional
departments, an extensive Exposure Reduction Initiatives Program began in early
1986. Initial commitments on ALARA initiatives are being made by each
departrnent as a prelude for more internally generated initiatives in the future.
Extensive ALARA studies and comparative evaluations have been conducted to
determine the contributors to our man-rem totals. The man-rem goals program,
started in 1984, and the lessons learned in the last two years will be used to
structure the 1987 goals to be more effective and to increase ownership and
accountability.
The 1986 Exposure Reduction Initiatives Program is designed to address, among
other items, the issues identified in the SALP Report. Hence, the benefit of
another management review at this time is questionable. The SALP report
identifies key issues that CYAPCO recognizes and intends to address. An
ongoing evaluation of the 1986-87 ALARA program's effectiveness will be
conducted to provide the necessary timely self correction.
I
i
_ . _ _ _ _-
.. - - - - - _ . . _ . -- -.- .=- ._ - - . _ .
- . . . - -
.
,
!
..
1
Functional Area: Surveillance
Board Recommendation: Complete the ongoing surveillance upgrade program. l
- Response
i
'
l
'
CYAPCO's eight point program to upgrade surveillance which began in July,1984
,
is ~ scheduled for completion in July,1986. Those items remaining to be '
completed are primarily procedural enhancements. As the report by the Board
, noted, the upgrade program appears to be working as there were no surveillance-
error-related events or violations during this most recent SALP evaluation
period.
i We continue to rely on the cognizant line organization to determine and verify
! the technical adequacy of the surveillance procedures. Existing procedures
specify the responsibility of the QA Supervisor to include such items as
reviewing and approving proposed changes to the technical specification
!
surveillance database, performing a semiannual review to ensure that each
technical specification requirement has a surveillance procedure to implement
'
it, and ensuring that a surveillance procedure is performed at the required
frequency while identifying the correct technical specification reference.
.
- A portion of the narrative under the surveillance category discusses the status of
containment leak rate testing and discrepancies with 10CFR50, Appendix 3. The
- NRC noted that our letter of December 23, 1985 did not resolve existing
i discrepancies with the regulation. CYAPCO acknowledges that this is the case,
i but notes that it was not realistic to suggest that total resolution could be
achieved in the space of one operating cycle or with one submittal. A significant
l upgrade on integrated leak rate testing, local leak rate testing and Appendix 3
! conformance in general is in progress and will remain in progress for some time.
i Our December 23, 1985 letter was followed by a comprehensive submittal on
!
March 12,1986 detailing Haddam Neck's compliance with and requesting several
i exemptions from the requirements of 10CFR50 Appendix 3. Currently we are
finalizing our proposal for the scope and schedule for various hardware
t
modifications and completing additional analysis work to support permanent
exemptions from portions of Appendix 3. We do not believe that any immediate
safety problem exists, and we will continue to address this issue on a schedule
which reflects its priority in the context of other upgrades within the framework
of the Integrated Safety Assessment Program.
4
f
!
!
,
h
!
!
_ -_. _ _ - - _ . . _ _ _ _ _ . _ _ . _ _ ___ . _ . _ . . _ . _ _ _ _ . . _ . _ _ _ _ _ _ _ _ _ .
__ .. _ . _ ._ - - . _ _ __ .. _ ._ _ __
ls ' .
.
<
..-
1
>
Functional Areat Maintenance and Modifications
Board Recommendation: Provide effective management attention to the new
modification control process to assure that it is understood and properly
, implemented at all levels.
,
Response:
A statement by the Board requires clarification: "Had the feedwater system
, isolation valves been repaired during the first system outage on August 18, 1985,
'
- subsequent plant shutdowns for feedwater system repairs would have been
avoided".
' The inability of the Haddam Neck Plant to continue generating at reduced power
with an individual feedwater pump isolated has been known for several years.
4 CYAPCO was constrainted in the earlier years to spend available resources on
i
other items of higher priority. When financial resources were made available, a
j decision was made to replace the valves with an improved design to attack the
l problem at the root cause rather than treating the symptoms by merely replacing
the valve "in kind". The new valves were ordered and scheduled for installation
- during the 1986 refueling outage as the old valves were not considered
repairable. Had these new valves been available during the August 18, 1985
l shutdown, we would have considered installing them at that time.
l
- In the area of contractor performed valve repairs, CYAPCO believes that the
contractor valve specialty company performed exceptionally well on most of the
!
valves assigned to them. We believe that the valves referred to in the report
were repaired several times as a result of the design and application of the valve
. rather than of any poor performance of the valve specialist. We were satisfied
- with the performance of our valve specialists and agree with the Board's
comment that these events " appeared to be isolated cases in an otherwise
- effective program." The Haddam Neck Plant, although an older plant, continues
,
to maintain a favorable forced outage rate compared to the industry. Our
- intention to maintain this standing is reflected in our plans to upgrade the
j nuclear instrumentation over the next few years to remove, at considerable
- expense, a source of potential problems.
i
To address the problem of attention to detail in repair activity control and
recording documentation of maintenance activities, the Northeast Utilities
. Service Company (NUSCO) Training Department will provide training for
! Maintenance Department personnel. This training, which is currently scheduled
! to begin in September,1986, will place emphasis on understanding and following
station procedures, attention to detail in repair activity control and recording
i
documentation of maintenance activities.
CYAPCO recognizes that there exists a backlog of maintenance activities. Such
a backlog can be attributed to a variety of causes such as jobs on hold for parts
, or engineering approval, outages (where hi
' and the Interplant Maintenance Force (IMF)gher priority
assignments. work
We are takes with
working precedence),
a
consultant to identify performance indicators which can be used to ensure the
l Production PMMS program remains effective. We are trending non-outage open
j corrective maintenance work orders and the ratio of preventative maintenance
!
l
1
..
.
-
.
.-
and corrective maintenance work orders. The former indicator reflects the
backlog of maintenance activities while the latter is a measure of the effort to
reduce maintenance performed as a reactive rather than preventative effort.
CYAPCO was pleased to note that the Board, while pointing out that a backlog
exists, recognized that the existing backlog is effectively managed and that
recent implemented or approved organizational changes serve to further improve
the effectiveness of the program.
. - _ _ _ - - - _. -- - _ _ -
_
. . . _ . - . . - . . . - _
_
'
l' .
,
- .-
1
.
l Functional Area: Emergency Preparedness
l
Board Recommendation: Complete the installation of the hard-wired data
j transmission system, and review the effectiveness of automatic protective
j action recommendations.
Response:
!
The 1986 SALP rating of Category 2 with a " consistent" trend does not
) accurately reflect the state of emergency preparedness at the Haddam Neck
l Plant. During the past SALP period, CYAPCO performed well in its 1985
4
exercise, and also responded quite satisfactorily to the declaration of an " Alert"
} during Hurricane Gloria in September,1985. Since only minor deficiencies were
- noted in the SALP report and remedial efforts were aggressively implemented
- following the 1984 and 1985 exercises, we believe that an overall Category 1
- rating is deserved.
,
In paragraph 2 of Section E, it is reported that twenty (20) minor areas which
j require licensee attention were observed in the 1985 exercise and that "several"
j were repeat items. Our review of the inspection reports from the 1984/1985
exercises (Report #50-213/84-10 and 50-213/85-06) indicated that only three (3)
,
out of the twenty (20) minor deficiencies were listed in the inspection reports as
j repeat items. In actuality, one of these three (3) repeat items (50-213/85-06-12)
i
was not required by procedures or regulation at the time of the inspection and,
therefore, was not a repeat item. We do agree that the item is a good practice
j and have since reinstated it. However, we recognize the intent of this issue and i
i
will, as in the past, closely follow-up on all exercise critique items.
j Although the report states that emergency planning existing staffing meets
' needs, the nature and extent of the staffing commitment is not accurately
portrayed. EP staffing is corporate based, to ensure uniformity and consistency
i
between NU's two nuclear sites, Haddam Neck and Millstone. The Haddam Neck
I
on-site EP work is the equivalent of three (3) full-time corporate people and not i
,
one. This does not include the utilization of other Company staff for equipment >
and facilities surveillance, exercise preparation, training, and contractor
1
i involvement.
We are concerned by-the SALP report's portrayal of the emergency response
functions as " redundant activities in distant centers". Also, we are concerned
by the inaccurate statement that State and local plans include " automatic
protective action recommendations". These statements appear to be indicative
of some confusion in the NRC Staff's understanding of the emergency response '
i process at the Haddam Neck Plant, the State and local communities. The CY
emergency response facilities are not redundant, but are mutually supportive and
j have prudent backup capabilities with checks and balances. When the State EOC
is manned at the Site Area Emergency level or sooner, all utility protective
action recommendations (PAR's) are discussed prior to their implementation.
- The PAR's stated in the State Emergency Plan Classification scheme are prudent
i guidelines to decision makers and are used as input, for their evaluation on a
!
case by case basis. Also in fast moving events or if the State EOC is not i
manned, the PAR guidelines serve a valuable function for the local communities.
! In these ways, we believe the Connecticut system has greater planning depth and
, flexibility to protect public health and safety. The experiences in drills and
exercises has demonstrated the value of these systems. These systems are also
3 consistent with NRC/ FEMA criteria for decision making and prompt notification.
.
!
. , . . . -.__,...__.,,__.,,_..._,.,,,,.,__.,-._-,__,..__,_______...____-__m_,_ _____,,,__,,m.__._
,'* }.
.
Our internal critique of the 1985 exercise identified a problem associated with
some delays in data transmittal in the early part of the exercise. We did not
characterize this problem as a confusion of functional responsibilities. We
believe that the reason for this problem was the newness of some Control Room
staff and the accelerated time frame of the exercise. To this end, we have re-
emphasized the need, in training and in drills, for rapid data transmittal from the
control rooms. We believe that our April 1986 exercise at the Haddam Neck
Plant demonstrated this capability.
We agree with the need to ensure a timely flow of data from the Control Room,
but do not believe that a real-time hardwired system is the only solution,
particularly since the present CY process computer cannot support such a
system. The currently used " NESS" program is a manual input computer based
system. The back-up for the computer is a high speed telecopier system. We
believe that with a timely response by the on-call Control Room Data
Coordinator, and the development and use of a " human engineered" manualinput
to the " NESS" code, the delay problem in data transmittal will be markedly
improved. We have noted the NRC's suggestion that a "real time-hard wired"
system is recommended. We are now evaluating its effectiveness for the
Haddam Neck Plant. This evaluation will be completed by October,1986, and if
found necessary would be combined with the project to replace the CY process
computer.
,
.' .
.
l
l
.= ,
!
Functional Area: Security and Safeguards
Board Recommendation: None
Response: None
_-. - _ _ _ _ _ .
,.* }.
..
Functional Area: Refueling and Outage Management
Board Recommendation: Commit additional attention to the pre-planning of
outage activities, especially design changes.
Response
Some confusion exists as to the scheduled length of the refueling outage which
began January 4,1986. The outage was not scheduled to be 8 weeks. The
schedule going into the outage called for a duration of IIM weeks. It is a
CYAPCO practice to schedule outages using optimum times for each task length.
The use of optimum tasks times serves more as a goal and guideline rather than a
realistic estimate. Had the steam generator sleeving work not been required the
outage would have been scheduled as 8 weeks. A more realistic approach is
taken in requesting outages with the New England Power Exchange and the
request was for an outage of 14 weeks duration.
The steam generator sleeving operation was a first for the Haddam Neck plant.
CYAPCO was able to benefit from the experience of some of the same NUSCO
personnel involved in the sleeving previously carried out at Millstone Unit 2.
Problems with the steam generator decontamination can be directly attributed
to innaccuracles in the dimensions of the as-built drawings of the nozzles from
which nozzle dams were designed and constructed. Field verification of these
dimensions was impossible so the resulting problems could not have been avoided.
Most PDCRs were on site prior to the start of the outage lacking only PORC
approval prior to the start of the outage. Most of these PDCRs had been
prepared and sent to the plant earlier. However, an lacreased awareness by the
plant engineering staff of the need for in-depth review resulted in PDCRs being
returned to the originators for revision. As of January 6,1986 the status of the
32 PDCRs referenced in the report was as follows:
o Eight PDCRs had been approved by PORC
o Ten had been submitted for PORC approval
o Eleven were in the final stages of review by CYAPCO Engineering
o Three were stillin preparation at NUSCO
We are committed to improve on the submittal of PDCR packages to the plant
well before the start of refueling outages.
_ . . - . _ _ . . _ _ . . _ __ _ __ _ _ . _ _ . . ._._ _
+
'* .
- * . t
.
Functional Area: Assurance of Quality
,
!
!
Board Recommendation: Reevaluate the effectiveness of systems for self-
1
identification and resolution of problems.
1
i. Response:
,
The Board report for this section touches topics ranging from Radwaste
{ transportation problems to PORC effectiveness.
t
l Radioactive waste problems have been addressed by a multidisciplinary adhoc
j
committee from NUSCO, NNECO, and CYAPCO with the result being the
j
development of NEO 6.07 " Quality Assurance and Quality Control in Station
,
Radioactive Material Processing, Classification, Packaging, and Transportation."
.
This procedure comprehensively defines a Northeast Utilities Radwaste QA
1
Program. Approved March 25, 1986 and implemented at Haddam Neck Plant
j
June 10,1986, this procedure fills the gap which existed between the QA Topical
Report and the ongoing Radwaste QA efforts at the plants. Additionally,
NUSCO Quality Assurance auditors have received training at both off-site and
t
on-site locations.
,
CYAPCO has instituted a procedural requirement (ACP 1.2-11.1) for QA/QC
- personnel at the station to perform an annual review to ensure that the
1
surveillance procedures being used adequately implement the Technical
Specification requirements. Such a review will ensure that the Technical
l Specifications are reviewed to ensure that changes are reflected in appropriate
- surveillance procedures. This check is in addition to normal checks to revise
surveillance procedures whenever Technical Specifications are changed as the
j
result of a design change. In addition to this review, the individual department
3 heads are now required to perform an annual review as to the technical adequacy
- of their surveillance procedures to verify compliance ' with Technical
j Specifications. These maasures should improve the quality of the surveillance
i program.
j
We feel that the recent increased emphasis on post-installation testing for plant
! modifications will reduce (and hopefully eliminate) the errors associated with
j
them. The Haddam Neck Plant PORC, in particular, carefully scruitinized the
test plans for recent plant design change requests to ensure that they were
adequate. Several of the PDCRs were held up by the PORC until the test plans
- were upgraded.
I
i As stated in the report, this functional area is a synopsis of the assessments in
i
the other nine areas. The NRC analysis noted that although in general we
s
' perform activities very well, the review functions such as PORC, NRB, QC, and
QA should be more effective in self-evaluation to prevent problems and prevent
the recurrence of identified problems.
4
'
j
The responses for the other functional areas are addressing specific actions
j
4
which are being taken to minimize and/or eliminate problems in those areas. We
have also taken steps to improve the effectiveness of our self-evaluation
- techniques to prevent problems.
1
i
I
-- - - _ . - - - - _ -
, -' * }.
.
Functional Area: Training and Qualification Effectiveness
Board Recommendation: Reorient technical training programs to address
weaknesses identified in the functional areas.
Response:
The Nuclear Training Department has recently undergone a major reorganization
to meet the corporate goal of achieving " training excellence". The training staff
(which has tripled since 1984) is fully committcd and dedicated to the
development and delivery of superior quality training in all operator and
technical disciplines. We fully expect these efforts to result in performance-
based improvements of the job incumbents. Some of the changes that have been
implemented to re-orient operator and technical training include:
(1) Installation of the CY Simulator
o On-site acceptance testing was completed in mid-March.
o Availability of the simulator has resulted in significant enhancements
to Licensed Operator Training Program and provided opportunities to
support other station activities.
o Operations Department personnel used the simulator to validate the
new CY Emergency Operating Procedures based on the Westinghouse
Owner's Group Emergency Response Guides.
o The simulator is being used to support the Licensed Operator
Requalification Program. During 1986, simulator training will
comprise three (3) complete shift training cycles covering the new
Emergency Operating Procedures and operational transients. It is
anticipated that the simulatar will be used to support approximately
50 percent of licensed operator requalification training in future
years,
o The simulator has been integrated into both Reactor Operator and
Senior Reactor Operator Initial Training Programs. The simulator
portions of these programs, each consisting of approximately 200
hours, will begin August 24, 1986.
(2) Requalification as an integral part of shift rotation
o License Operator Requalification Training has been integrated into
the operator shift rotation schedule. Three (3) shift cycles have been
implemented since the integration began. Specific topics included:
-
Theory Review (classroom)
- Operational Events (classroom)
-
New Emergency Operator Procedures
(classroom and simulator)
Planned topics for upcoming cycles in 1986 include:
-
Standard Technical Specifications (classroom)
_ _ _ . _ . . .
4
,. l-
..
4
-
-
Plant Systems Review (classroom)
-
Operational Events (classroom and simulator)
-
Operational Transients (simulator)
(3) I&C Technician understanding of Technical Specifications
o The I&C instructional staff prepared and delivered in May a four hour
presentation of. Technical specifications to 100% of the CY I&C
Department's Technician staff.
(4) Radwaste transportation problems
o The Health Physics staff is preparing lesson plans in support of a 40
hour Radwaste Worker Training Program which is scheduled to be
delivered on June 30,1986.
{ (5) Engineer understanding of design change control procedures
.
o in order to improve knowledge and training in this area a job analysis
'
,
has been conducted for each of the engineering positions at CY to
,
' ascertain the extent of involvement with design change control
procedures and processes. This job analysis will be used to develop a
training program designed specifically for engineers. It will cover
the requirements and processes for modifications to the plant. This
training program will be implemented in the fall of 1986 and will be
a
included in the engineering training programs submitted for
accreditation by INPO.
l (6) General knowledge of the control of fire barriers (doors)
i
'
o in order to improve knawledge and training in this area the topic has
recently been added to the New Employee and General Employee
.
'
Training Programs. Also contractor personnel responsibilities
concerning the proper use of fire doors is now covered in the Safety,
'
Security and Emergency Plan Training Program for contract
personnel.
i
j
i
,
4
Y
l
--m , . - ,----..,.,-u ,---.,n,------.n n._.,.,n-,--,.,,-.----an, -,nen,_,.m,m- .n,. .n.,,n.,.,----_..--..n,r.,,r.--,
._ . . .
'
.s
,
,
~}
..
.
Functional Area: Licensing Activities
Board Recommendations: Take action to assure that licensing submittals are
3
adequately pre-planned, comprehensive, and reflect consideration for regulatory
deadlines. Aggressively pursue each open item to closure.
, Response:
A portion of the narrative under the surveillance category discusses the status of
containment leak rate testing and discrepancies with 10CFR50, Appendix 3. The
-
Staff noted that our letter of December 23, 1985 did not resolve existing
discrepancies with this regulation. CYAPCO acknowledges that this is the case,
but notes that it was not realistic to suggest that total resolution could have
4
,
been achieved in the period of one operating cycle or with a single submittal. A
significant upgrade of integrated leakrate testing, local leakrate testing and
Appendix 3 cor>formance in general, is in progress and will remain in progress for
, some time to come.
,
Our Decernber 23, 1985 letter was followed up with a comprehensive exemption
4
request in March of 1985 in accordance with requests from the Staff. Currently
we are finalizing our proposal for the scope and schedule for various hardware
modifications and completing analysis work to support permanent exemptions
from portions of Appendix 3. We do not believe that any immediate safety
problem exists, and we will continue to address this issue on a schedule which
reflects its priority in the context of other upgrades within the framework of the
Integrated Safety Assessment Program.
The NRC narrative on the licensing activities segment of the SALP report states
that activity has been at a very high level during the past SALP period.
,
CYAPCO strongly agrees with this statement, and believes that some of the
j difficulties notedin the writeup with respect to timeliness were the result of the
,
large and partially unanticipated level of activity. It also appears that additional
i
complications and potential misunderstandings resulted from implementing the
,
ISAP philosophy. It is clearly documented in the November,1984 ISAP policy
statement that suspension of previously existing regulatory deadhnes was
contemplated and expected, provided good cause was shown. Not surprisingly,
there were instances when interpreting and implementing this concept were
difficult.
,
Rather than dwell on this past SALP period, we believe it more constructive to
offer a few observations with respect to the present and future. Specifically, we
i believe that with the submittal of the plant specific probabilistic safety study,
and with the focus of NU's ISAP effort shif ting to the Haddam Neck Plant, an
excellent framework is in place to be responsive to the concerns identified in
,
this SALP report. Specifically, we intend to reach agreement with the Staff well
j
'
before the next refueling outage on what the scope of the outage modifications
will be, and what regulatory documentation must be generated to allow the
schedules determined as a part of the ISAP process to be institutionalized.
As discussed during the May 29, 1986 meeting, this process has the advantage of
facilitating timely processing of plant design changes for the 1987 outage, and
,
should facilitate implementation of our ALARA philosophy. Consequently, we
4
- . - _ , - - - - - - - - - - - - . -
, . - , [.
.
.-
believe that the ISAP will be a factor in improving our responsiveness to a
number of concerns identified by the NRC in this SALP report. With a
comprehensive ISAP report which will address all regulatory items, we believe
that CYAPCO will be responsive to the Board's recommendation that action be
taken to assure that submittals are adequately preplanned, comprehensive, and
reflect consideration for regulatory deadlines.
i*
ENCLOSURE 4
.-
ERRATA
.PLEASE BE ADVISED OF A CORRECTION IN THE SALP REPORT NUMBER.
OUR PREVIOUS CORRESPONDENCE REFERRED TO THE SUBJECT
REPORT AS 86-98 INSTEAD OF 85-98.
.
I
!
!
!
!
i
I
i
l
--._,.~,.._ - --.. ~ ~ - -
- ~- .-.-_.u.wwa .
,w -.+,-> w -.- u.._m,.e-s.w.~.w----s,-._,_na
4
4
$ 9
f
5
i
,e
t
i. t
I f
P
1
,
i
l
'
l
l
!
.
5
i
1 :
! I
l
t
t
I
t
f
i
t
!
,
i
1
,
h
P
r
1
t
i
t
,
f
h
,
?
$
,
I
i
.
? I
I
,
.,
I
r
6
'
4
fi
5
,
i
- N
r
l
P
T
p
r
f
I
r
(
4
.
k
l
s ._ _
'