ML20207F622
| ML20207F622 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 12/30/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207F617 | List: |
| References | |
| 50-029-85-98, 50-29-85-98, NUDOCS 8701060160 | |
| Download: ML20207F622 (57) | |
See also: IR 05000029/1985098
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ENCLOSURE
SALP BOARD REPORT
U.S. NUCLEAR REGULATORY COMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT 50-29/85-98
YANKEE ATOMIC ELECTRIC COMPANY
YANKEE NUCLEAR POWER STATION
ASSESSMENT PERIOD: FEBRUARY 1, 1985 - OCTOBER 6, 1986
BOARD MEETING DATE: DECEMBER 4, 1986
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TABLE OF CONTENTS
PAGE
I. INTR 000CTION......................................................... 1
A. Purpose and 0verview............................................ 1
B. SALP Board Members.............................................. 1
C. Background...................................................... 2
II. CRITERIA............................................................. 6
III. SUMMARY OF RESULTS................................................... 7
A. Facility Performance............................................ 7
B. Overall Facility Evaluation..................................... 8
IV. PERFORMANCE ANALYSIS................................................. 9
A. Plant Operations................................................ 9
B. Radiological Controls........................................... 13
C. Maintenance and Modifications................................... 17
D. Survei11ance.................................................... 21
E. Fire Protection and Housekeeping................................ 24
F. Emergency Preparedness.. ....................................... 26
G. Security and Safeguards................ ........ . ... ... 28
H. Refueling and Outage Management................................. 31
I. Assurance of Quality............................................ 34
J. Training and Qualification Effectiveness........................ 37
K. Licensing Activities............................. ...... . 40
V. SUPPORTING DATA AND SUMMARIES........................................ 43
A. Investigation and Allegation Review............................. 43
B. Escalated Enforcement Action.................................... 43
C. Management Conferences.......................................... 43
D. Licensee Event Reports.......................................... 43
E. Operating Reactors Licensing Actions............................ 44
TABLES
Table 1 - Tabular Listing of LERs by Functional Area
Table 2 - LER Synopsis
Table 3 - Inspection Hours SuTT.sr3
Table 4 - Enforcement Summary
Table 5 - Enforcement Data
Table 6 - Inspection Report Activities
Table 7 - Reactor Trips and Unplanned Shutdowns
FIGURES
Figure 1 - Number of Days Shutdown
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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 peri-
odic basis and to evaluate licensee performance based upon this informa-
tion. SALP is supplemental to normal regulatory processes used to ensure
compliance to NRC rules and regulations. SALP is intended to be suffi-
ciently diagnostic to provide a rational basis for allocating NRC re-
sources and to provide me?.ningful guidance to the licensee's management
to promote quality and safety of plant operation.
The NRC SALP Board, composed of the staff members listed below, met on
December 4, 1986 to review the collection of performance observations
and data to assess license. performance in accordance with guidance in
NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance."
A summary of the guidance and evaluation criteria is provided in Section
II of this report.
This report is the SALP Board's assessment of the licensee's safety per-
formance at the Yankee Nuclear Power Plant for the period February 1,
1985 through October 6, 1986. It is noted that the summary findings and
totals reflect a 20 month assessment period.
B. SALP Board Members
Board
S. J. Collins, Deputy Director, Division of Reactor Projects (DRP) and
Chairman
- W. F. Kane, Director, DRP
E. C. Wenzinger, Chief, Projects Branch No. 3, DRP
T. C. Elsasser, Chief, Reactor Projects Section 3C, DRP
H. Eichenholz, Senior Resident Inspector, Yankee Nuclear Power Station
T. T. Martin, Director, Division of Radiation Safety and Safeguards
(DRSS)
- R. R. Bellamy, Chief, Emergency Preparedness and Radiological Protection
Branch, DRSS
i *W. V. Johnston, Deputy Director, Division of Reactor Safety (DRS)
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- L. H. Bettenhausen, Chief, Operations Branch, DRS
G. E. Lear, Director, PWR Project Directorate No. 1, NRR
E. M. McKenna, Project Manager, PWR Project Directorate No. 1, NRR
Attendees
G. R. Klingler, Reactor Operations Engineer, Office of Inspection and
Enforcement
W. J. Lazarus. Chief, Emergency Preparedness Section, DRSS
M. M. Shanbaky, Chief, Facilities Radiation Protection Section, DRSS
T. F. Dragoun, Senior Radiation Specialist, DRSS
l * Indicates part-time Board members.
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C. Background
1. Licensee Activities
The facility operated at or near full power from February 1, 1985
.until April 26, 1985. On April 27, 1985 a load reduction to 15 MWe
was initiated to repair an extraction steam line leak. A second leak
was discovered and repaired during power ascension on April 29, 1985.
From April 30, 1985 until June 30, 1985 the plant was at essentially
full power, other than periods of minor power restrictions that re-
sulted from increased cooling pond water temperature.
The licensee determined on May 13, 1985 that a control rod movement
restriction was required to comply with Section I.A of Appendix K
to 10 CFR 50.46, that pertained to axial power distribution assump-
tions for the Loss of Coolant Accident analysis. Operation of the
core in a rodded condition (i.e., control rod Group C inserted below
83 inches withdrawn) continued until September 23, 1985, when the
restriction was removed in response to a licensee analysis that
provided an acceptable basis for unrodded core operations. The power
coastdown to the Core XVII-XVIII refueling outage began in August
3, 1985. Two plant milestones involving the 25th anniversary of
initial criticality and exceeding the previous operating record of
289 continuous days of operation occurred on August 19, 1985 and
September 1, 1985, respectively. On September 23, 1985 licensee
protective measures in response to Hurricane Gloria were implemented.
There was no impact on the facility and operations continued.
On October 19, 1985, with the plant in its 336th day of continuous
operation, the facility was shut down until December 10, 1985 for
its scheduled refueling and maintenance outage. Major activities
during the outage included refueling, steam generator tube inspec-
tions, installation of a new solid state reactor protection system,
main generator overhaul, and implementation of Systematic Evaluation
Program modifications (SEP). During the refueling period, the lic-
ensee identified degradation of a total of four fuel rods in three
fuel assemblies. These occurrences were partially attributed to
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baffle spacer flow jetting that induced fretting of the fuel clad-
ding. Higher than normal coolant activity levels resulted during
Cycle XVII operation.
The facility started up from the refueling outage on December 5,
1985, with the plant remaining in Mode 2 to facilitate contractor
work on turbine-related problems. A reactor scram from low power
occurred on December 9, 1985 as a result of a contractor employee
bumping a relay during post modification cleanup in the control room.
The plant achieved Mode 1 operation and was phased to the grid on
December 10, 19S5, but a nitrogen leak in the No. I station service
transformer required that the generator be taken offline for a
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period of time on December 11, 1985. The plant returned to the grid
with power escalation being halted on December 17, 1985 due to ex-
cessive leakage from the No. I heater drain pump. A subsequent
problem with a stuck closed No. 3 turbine control valve limited the
plant to 97% of rated power, which was achieved on December 23, 1985.
A plant shutdown to Mode 2 was initiated on December 28, 1985 for
repair of the No. 3 turbine control valve, with an unplanned auto-
matic scram occurring from a false high startup rate condition re-
sulting from maintenance being performed on the nuclear instrumen-
tation system. A failure of the No. 3 boiler feedwater pump (BFP)
and motor occurred while plant operators were preparing to return
the plant to operation from Mode 2 on December 29, 1985. The plant
returned to the grid on December 30, 1985 and, while undergoing a
reactor power increase, the main coolant Dose Equivalent Iodine
(DEI) level reached 74% of the Technical Specification (TS) limit.
Operator actions resulted in reduction of DEI levels to approxi-
mately 5% of the TS limit. Following the return to operation of the
failed BFP on January 4, 1986, the plant achieved full power on
January 7, 1986 and remained at that level until January 25, 1986.
On this date, a planned load reduction to 65% of rated power oc-
curred for repairs to the No. 2 heater drain pump due to excess
packing leakage and turbine valve testing. The plant returned to
full power on January 26, 1986.
The facility operated at or near full power from January 26, 1986
until the end of the assessment period on October 6, 1986, with the
exception of the following load reductions or outages. On January
31, 1986 an unplanned load reduction to 76% of rated power occurred
due to a leaking pump seal on the No. 3 BFP; a planned reduction
to 70% of rated power occurred on March 22, 1986 to perform main-
tenance on the Nos. 1 and 3 BFPs and turbine valve testing; and an
emergency load reduction to 78% of rated power was initiated by
plant operators when a loss of cooling water to th* generator hydro-
! gen cooler occurred. A low steam generator level automatic scram
occurred on June 1, 1986 due to a loss of both heater drain pumps
during a severe lightning storm. An unplanned load reduction to 75%
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' of rated power occurred cn June 13, 1986 in response to a leak in
l tne packing gland of the No. 1 BFP. The licensee proceeded to cold
shutdown on June 18, 1986 for an outage to effect repairs to a
leaking weld in a coupling located in containment on the No. 2 steam
generator's blowdown line.
, During this outage that lasted until July 1, 1986, the licensee
l identified the following anomalous conditions: 1) a main coolant
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hot leg isolation valve (MC-MOV-325) was found to have a failed
valve stem, and 2) four valves in the reactor coolant vent and
emergency feedwater systems had incorrect overload trip coils in-
stalled in their respective power supply circuit breakers. Also
, during this outage a valving error by a plant auxiliary operator
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resulted in the potential for a loss of shutdown cooling and severe
damage of the main coolant pump internals. A planned load reduction
to 50% of rated power occurred on September 20, 1986 to perform
maintenance on BFPs, to conduct condenser tube leak checks, and to
conduct turbine control valve testing. On October 4,1986 a low
control cir pressure condition occurred that subsequently resulted
in a reactor automatic scram on low steam generator levels. During
the plant startup later the same day, an operator error resulted
in a reactor automatic scram occurring when a main steam line non-
return valve trip / reset switch was inadvertently placed in the trip
position. The plant was at 75% of rated power at the end of the
assessment period on October 6, 1986.
During this assessment period the plant availability factor was 88%.
2. Inspection Activities
One NRC resident inspector was assigned to the site during the en-
tire assessment period. The total NRC resident and region-based in-
spection hours for this 20 month assessment period was 3057 hours0.0354 days <br />0.849 hours <br />0.00505 weeks <br />0.00116 months <br />
(1,834 hours0.00965 days <br />0.232 hours <br />0.00138 weeks <br />3.17337e-4 months <br /> on an annual basis) with a distribution in the ap-
praisal functional areas as shown in Table 3.
The resident inspector conducted one event-related special inspec-
tion that involved the review of the circumstances and licensee
corrective actions related to the discovery of inoperable motor
operated valves in the reactor coolant vent and emergency feedwater
systens.
During the period, NRC team inspections were conducted of the fol-
lowing areas:
a. Implementation of various items required by NUREG 0737 includ-
ing post-accident sampling and monitoring capabilities.
b. Evaluation of the annual emergency preparedness exercises con-
ducted May 15, 1985 and June 11, 1986.
c. Licensee's action to address the concerns identified in NRC
Generic Letter 83-28, in the areas of Equiprent Classification,
Post-Maintenance Testing, and Vendor Interface.
d. Compliance with 10 CFR 50, Appendix R safe shutdown capability.
e. An operational QA effectiveness inspection.
In this period five violations, including one Severity Level III,
were issued. Tabulations of Violations and Inspection Activities
are presented in Tables 5 and 6, respectively.
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This report also assessed " Training and Qualification Effectiveness"
and " Assurance of Quality" as separate functional areas. Although these
topics, in themselves, are assessed in the other functional areas through
their use as avaluation criteria, the two areas provide a synopsis. For
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example, quality assurance effectiveness has been assessed on a day-to-
day basis by the resident inspector and as an integral aspect of special-
ist inspections. Although quality work is the responsibility of every
employee, one of the management tools to measure this effectiveness is
reliance on quality assurance inspections and audits. Other major factors
that influence quality, such as involvement of first-line supervision,
safety committees, and worker attitudes, are discussed in each functional
area.
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II. CRITERIA
Licensee performance is assessed in selected functional areas. Each functional
area represents areas significant to nuclear safety and the environment, and
are normal programmatic areas. The following evaluation criteria were used
as appropriate 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 functional area evaluated is clas-
sified into one of three performance categories. The definitions of these
performance categories are:
Category 1: Reduced NRC attention may be approprinte. Licensee management
attention and involvement are aggressive and oriented toward nuclear sz %ty;
licensee resources are ample and effectively used such that a high level of
performance with respect te operational safety is being achieved.
Category 2: NRC attention should be maintained at normal levels. Licensee
management attention anc involvement are evident and concerned with nuclear
safety; licensee resources are adequate and reasonably effective such that
satisfactory performance with respect to operational safety is being achieved.
Category 3: Both NRC and licensee attention should be increased. Licensee
management attention or involvement is acceptable and considers nuclear safety,
but weaknesses are evident; licensee resources appear strained or not effec-
tively used such that minimal satisfactory performance with respect to opera-
tional safety is being achieved.
The SALP trend categories are as follows.
Ircroving: Licensee performance has generally improved over the last part of
the SALF assessment period.
Declinino: Licensee performance has generally declined over the last part of
the SALP assessment period.
A trend is assigned only when, in the opinion of the SALP Board, the trend
is significant enough to be considered a precursor to a change in performance
category in the near future.
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III. SUPMARY OF RESULTS
A. Facility Performance
Last Period This Period
(11/1/83 - (2/1/85 -
Functional Area 1/31/85) 10/6/86) Trend
A. Plant Operations 1 1
B. Radiological Controls 2 1
C. Maintenance and Modifications 1 1
D. Surveillance 1 1
E. Fire Protection and Housekeeping 1 1
F. Emergency Preparedness 1 2
G. Security and Safeguards 2 2
H. Refueling and Outage Management 1 1
1. Assurance of Quality 2# 1
J. Training and Qualification
Effectiveness ## 2
K. Licensing Activities 1 1
- Previously assessed as Design Control / Quality Assurance
- Not Previously addressed as separate area
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B. Overall Facility Evaluation
Our assessment confirms your strong orientation towards plant safety,
technical strength, and staff experience which are considered
licensee attributes. Additionally, we acknowledge your initiatives
to address plant aging concerns and to increase the oversight and
effectiveness of your quality programs.
Management attention has resulted in your continued high level of
performance in eight of the eleven rated functional areas, as
illustrated by your successful initiatives to upgrade performance in
the Radiological Controls area. Our evaluation indicates that this
aggressive approach and high level of management involvement have not
been evident ~in the oversight of the security program, the effective-
ness of the licensed operator training program, and recent implemen-
tation of emergency plan actions.
As a result of this assessment, NRC activities in Category 1 functional
areas are eligible for reduced inspection effort. We will consider your
high level of performance and initiatives to address identified short-
comings in our prioritization of the inspection program for your
facility.
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IV. PERFORMANCE ANALYSIS
A. Plant Operations (655 hours0.00758 days <br />0.182 hours <br />0.00108 weeks <br />2.492275e-4 months <br />, 22%)
1. Analysis
The previous SALP rated plant operations as Category 1, with a con-
clusion that the licensee continued to demonstrate a strong and
effective commitment to safety in this area.
This functional area includes plant operations as well as opera-
tional support activities. During the current SALP period, there
was one region-based inspection of this area. Plant operations were
observed by the resident inspector throughout the period.
Plant operators and licensee management response to plant events
and conditions have generally demonstrated a strong and effective
approach to resolution of technical issues. The team effort, which
includes Yankee Nuclear Services Division (YNSD) project and engi-
neering personnel, demonstrates a clear understanding of the issues,
and exhibits a conservative, technically sound approach to safety
issues. Abnormal events during which these characteristics were
demonstrated included: 1) plant operations with degraded fuel clad-
ding, 2) the identification of a LOCA analysis deficiency, and
3) the discovery of an electrical loading problem. Plant staff
corrective actions were noted as aggressive in resolving the opera-
tional concerns. However, the YNSD Projects staff has at times de-
layed identification of impending operational problems, which has
resulted in unnecessary reactive conditions being imposed upon the
operating organization. A notable example of this was compensatory
measures required during 480V A-C bus cross-tie operations while
the plant was in a startup and shutdown condition. Management at-
tention to improve YNSD Projects response timeliness is warranted.
The general performance of the operations department reflects a
commitment to quality operation as evidenced by few personnel
errors and a low reactor scram (trip) rate of 0.15 scrams per 1000
critical hours while at power. This scram rate is significantly
belc,w the national average of about one per 1000 critical hours.
- Consistent evidence of prior planning and assignment of priorities
were apparent. When personnel errors occur they are isolated in-
stances that are not reflective of a programmatic breakdown. The
performance level of plant operators during routine and transient
plant operations reflects a conscientious attitude and concern for
plant safety. However, one event involving the opening of all four
main coolant loop bypass valves by the operators in an attempt to
mitigate decreasing main coolant temperature was a deviation from
their normally conservative manner in which they respond to opera-
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tional problems. Although their actions were contrary to Technical
Specifications (TS), an NRC-requested safety evaluation demonstrated
that the event was of minimal safety significance.
Continued improvement in licensed operator knowledge of equipment
status has been evident. Events involving failure to document equip-
ment malfunctions and failure to initiate corrective maintenance
have been essentially eliminated due to responsive management at-
tention to the prior SALP concerns in this area. Increased on-line.
maintenance to assess the consequences of off-normal indications
is occurring.
The licensee maintains a professional atmosphere in the control room
by prohibiting radios, television, and unrelated reading material,
which tends to minimize disruptive activities. In response to NRC-
initiatives, the licensee has developed formal administrative means
i for 1) effectively limiting control room access, and 2) specifying
expected conduct and performance policies for operational personnel.
A noted licensee strength is the nearly " blackboard" status for
control room overhead annunciators that is routinely maintained.
The licensee has established well-stated administrative controls ,
to provide notification and event reporting as required by 10 CFR
50.72 and 50.73. Licensec Event Reports (LERs) are, in general, pre-
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perly identified, analyzed, and reported in a timely manner. The .
NRC review of the licensee's LERs determined that they were of
above-average quality. Prior SALP concerns involving incorrect and
insufficient information in LERs have not recurred. The licensee
utilizes Flent Information Reports (PIRs) for addressinc non report-
able concerns. Quality is evident in the areas of causal analysis
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and corrective actions; however, report issuance timeliness rou-
tinely exceeds the licensee's established administrative controls.
The overall good quality of LERs is attributable to the increased
involvement and thorough reviews conducted by the Plant Operations
Review Committee (PORC) and management. Numerous meetings of the
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PORC were observed by the resident inspector, with proper question-
ing attitudes consistently observed that resulted in active and
probing discussions on items of concern and plant events. However,
, the PORC meeting minutes tend to lack an adequate level of detaii
- to reflect the details of the discussions that occur. Station man-
agement instituted training for the PORC members to improve their
sensitivity to responsibilities associated with procedural matters
and 10 CFR 50.59 evaluation adequacy.
Some of the initiatives undertaken in this assessment period by the
i Nuclear Safety Audit and Review Committee include 1) ensuring that
safety evaluations are performed in an adequate manner, and 2) im-
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proving committee-cognizance over the In-Plant Audit Program by
having members participate or monitor at least one audit to provide
a better understanding of the program.
A January 1986 NRC review of the licensee's initial operator lic-
ensing program found the administrative control systems to be ade-
quate. However, the training program and its administrative con-
trol systems have not effectively prepared large classes of candi-
dates to operate the facility as demonstrated by the low success
rate on NRC licensing examinations. During this assessment period
one class of operator candidates consisting of four reactor opera-
tors (R0s) and tnree senior reactor cperators (SR0s) were trained
to operate the facility, but only three of the candidates (43%)
were issued operating licenses.
Presently, station staffing is adequate. A five-shift rotation
schedule is used. Early in the assessment period the licensee as-
signed a spare shift supervisor and a senior control room operator
to facilitate operational flexibility. However, the current number
of licensed reactor operators requires reliance on overtime, at a
level that is presently in compliance with NRC requirements, to meet
watchstanding needs. The current class for R0 and SR0 licenses is
cocprised of five and three candidates, respectively. It appears
that even if all of the licensee's candidates are fully successful,
the overall depth of licensed operator staffing levels may not sig-
nificantly change because of the potential for attrition of current
operators.
The use of Special Orders in lieu of approved procedures was a prior
SALP concern. Recurrence of this issue has been identified in this
assessment period, which suggests insufficient management attention.
A plant procedures programmatic inspection, with specific emphasis
placed on plant operations, was conducted. This review, in conjunc-
tion with routine observations, identified issues that involve:
1) difficulties in determining that independent verification for
certain systems has been performed, 2) the need to increase the
emphasis on attention to detail as part of the procedure review
program, and 3) the need to insure that procedures are developed
for all planned operations. Over-reliance on special orders and
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weaknesses in procedural content may be due to the demands placed
on the operations department support staff that is currently being
relied upon to perform this important function, as that staff at
times appears to be taxed by a heavy workload.
During this assessment period, the licensee accomplished notable
milestones related to plant performance that involved reaching the
25th anniversary of initial criticality, the setting of a new plant
continuous operation record of 336 days without a shutdown, and
maintaining the olant in an on-line status for 539 out of the 613
days contained within the period. This represents a plant availa-
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bility of 88 percent and is significantly above the national average
of 69 percent. These accomplishments are indicative of the operat-
ing and support staff's overall quality performance.
2. Conclusion
Category 1.
3. Board Recommendation
None.
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8. Radiological Controls (507 hours0.00587 days <br />0.141 hours <br />8.382936e-4 weeks <br />1.929135e-4 months <br />, 14%)
1. Analysis
In the previous SALP report the licensee's performance in Chemistry
and Radiological Controls was rated as Category 2. Weaknesses were
identified in the areas of staff development, oversight of radwaste,
control of work in radiation areas, recordkeeping, and respiratory
protection programs. Three minor violations were cited. SALP Board
recommendations were made regarding: 1) supervisory staffing,
2) staff development, 3) self evaluation, and 4) radiological pro-
cedure review and compliance.
During this SALP period, region-based radiation specialists conducted
seven inspections in the following areas: radiation protection (3);
environmental monitoring (1); radiological chemistry (1); non-radio-
logical chemistry (1); and waste management (1). The resident in-
spector also reviewed selected program areas. No violations were
identified.
Site and corporate management directed a high level of attention
and resources towards resolving Radiological Protection (RP) program
weakness during this period. Substantial progress was made in the
area cf self-identification and resolution of problems. Management
has revised existing policies and established new policies that
firmly support a conservative approach to radiation protection. For
example, the Radiological Work Policy requires all personnel to
comply with all RP requirements and delineates disciplinary action
for noncompliance.
A major project was undertaken to replace the outdated RP procedures
by using assistance from the corporate technical staff with input
and review by the small highly experienced site staff. This re-
sulted in clear, well written draft RP procedures. Management de-
cided to enhance this effort by id ng en innovative approach of two
tiers of procedures - one simplified ievel for use by plant workers
with the second level providing detailed instructions for the radi-
ation department staff. This project is nearly complete.
Ir;wovements in planning were noted during this period. The ALARA
reviews for all dose intensive Design Change Request work was com-
pleted prior to the start of the refueling outage. An infrequent
spent resin shipment was thoroughly preplanned and controlled re-
sulting in minimal personnel exposure and no site contamination.
Additionally, the impact of temporary changes to the radiologically
controlled area boundary was minimized through good planning.
Records are complete and well-maintained for routine radiation sur-
veys, routine chemistry surveillance, radioactive liquid waste pro-
cessing, radiological environmental monitoring and meteorological
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monitoring. A large main frame computer and record keeping system
dedicated to RP and chemistry has recently been installed on site
that will enhance recordkeeping capabilities.
The licensee routinely exhibits technical thoroughness in the resolu-
tion of radiation safety issues. A new on-site QC function was estab-
lished to oversee all phases of radwaste processing and radioactive
materials shipments. The QC personnel were specifically trained and
qualified for this dJty. Personnel exiting the radiological control
area on site are required to self-frisk, use an automatic hand and
foot monitor, and then pass through a sensitive portal monitor exit.
This multistep process provides a high degree of radioactive con-
tamination control. The Environmental Lab has conducted exhaustive
technical studies of the behavior characteristics of the Harshaw
TLD system used for personnel dosimetry. This approach results in
a high confidence in the reported personnel exposures.
Responsiveness to NRC initiatives in almost all cases has been timely,
technically sound and thorough. Previous NRC concerns regarding RP
department staffing levels and lines of authority have been resolved.
The need for procedural compliance was addressed by strong management
disciplinary action with contractor and permanent site personnel.
The RP prooram was understaffed and lacking experience at the begin-
ning of this period due to loss of the radiation protection manager
and two of four supervisory personnel. The impact of this loss of
key personnel from this small staff was aggravated by the lack of
a staff development program and cross-training of supervisors. A
systematic program was implemented to correct this situation, and
by the midpoint of this assessment period, all positions had been
refilled. New job descriptions with clearly assigned primary and
backup responsibilities were promulgated and a staff development
program was put in place. In addition, a permanent supervisory posi-
tion was added to coordinate various program improvements that are
uncerway and planned for the future such as the expanded use of com-
puters. The increased staff size and depth resolve the concerns
stated in the previous SALP.
A defined but informal training program is provided to RP supervisors
and technicians, which makes a positive contribution to understand-
ing of the work as evidenced by adherence to procedures with few
personnel errors. A policy change now permits only fully ANSI quali-
fied RP technicians to implement the RP program. The trainee posi-
tion called " tester" was abolished in a licensee initiative to
strengthen the technician performance level. The qualification pro-
gram for radwaste QC inspectors made a positive contribution to the
inspection activities and adherence to procedures.
The licensee has improved its chemistry and radiochemistry programs.
The licensee has a strong program to insure compliance with Techni-
cal Specification requirements for inplant and effluent sampling
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__ .
. .
.
, 15
and analysis. In particular, the licensee has paid particular atten-
tion to meeting its Radiological Environmental Technical Specifica-
tions (RETS), which were effectively implemented during this assess-
ment period. The review of the licensee's implementation of the RETS
indicated that procedures for control and monitoring of effluents
were very effectively stated and thoroughly carried out.
Initiatives to improve management oversight and to improve labora-
tory instrumentation and chemistry facilities were implemented. A
surveillance matrix, which is reviewed by two levels of management,
tracks the required sampling of radioactive and non-radioactive sys-
tems. However, for the nonradioactive systems that have a potential
for an unmonitored, unplanned release, there are no action statements
to provide guidance, if a priori criteria are exceeded. This is a
minor discrepancy associated with an otherwise excellent program.
Procedures for gaseous and liquid effluent controls and offsite dose
calculations are generally implemented properly. However, an un-
planned, unauthorized gasecus release occurred subsequent to purging
of a main coolant icop when the activated charcoal filter failed
to retain the gaseous iodine. Management took aggressive actions
to prevent a similar release including: lowering the alarm setpoint,
replacing the charcoal, and periodically determining the removal
efficiency for the charcoal. A timely and technically sound resolu-
tion to this issue was implemented. Previously, periodic in place
testing of charcoal filters had not been performed with the excep-
tion of the Control Room Emergency Ventilation System. Although not
required by Technical Specifications, such testing is considered
standard industry practice.
Procedures for chemistry surveillances have been implemented and
analyses performed as required. Technical Specifications require
analysis of main coolant and gaseous effluents following a 15 per-
cent per hour power change. The operators are aware of this require-
ment, and normally take action to insure compliance. However, in
one instance, the analyses were performed but results were not re-
ported to the control room. The licensee implemented a timely re-
sponse to this concern, including issuance of a written instruction
l to chemistry technicians to report these results to the control roo~
!
and revision to procedures to indicate appropriate notification
requirements. This is another indication of increased management
attention to the follow up and correction of identified problerts.
The licensee improved its chemistry staffing and qualification pro-
I gram during this assessment. This was demonstrated by documentation
of on-the-job training and retraining of chemistry personnel, in-
creased staff, and clearly defined position descriptions to address
major responsibilities. A number of these improvements were in re-
i sponse to industry and NRC initiatives. However, on its own initi-
l
ative, the licensee recognized the need and initiated action, to
develop managerial depth within the chemistry department.
. .
.
16
.
The licensee's ability to accurately measure radioactivity in ef-
fluents was confirmed by intercomparisons with the NRC using the
NRC Mobile Radiological Measurements Laboratory.
Weaknesses in the nonradiological chemistry program, identified dur-
ing the previous assessment period, included lack of a measurement
control program, lack of a retraining program for chemistry techni-
cians, and an unreliable and insensitive method for determination
of chloride in water. A new Chemistry Department Manager was assigned
to the facility in August 1984. During the current assessment period,
it was noted that significant improvements have been made. These
include: the use of control charts for chemical analyses, testing
of technicians by requiring them to analyze samples containing un-
knowns, and an improvement in laboratory facilities through the pur-
chase of new equipment that will provide for greater reliability
and sensitivity.
The licensee maintains well-stated, controlled and explicit proce-
dures for control of radiological environmental monitoring program
(REMP) activities and for the calibration of meteorological moni-
toring instrumentation. Records of REMP and meteorological monitor-
ing were complete, well-maintained and available. Procedures are
consistently followed. REMP sainpling stations were located as stated
by procedure, required sampling frequencies were met, and equipment
was calibrated as required. Positions and responsibilities are well-
defined for management of the REMP. Calibrations of meteorological
monitoring instruments are performed more frequently than required,
and reviewed calibration data have been satisfactory.
During the last SALP, the NRC made several recommendations in this
functional area to aid improvement in licensee performance. These
recommendations, promptly implemented by the licensee, were a blue-
print to improve radiological controls performance from consistently
average to exceptional. By the midpoin'. of the assessment period,
all recommendations had been fully implemented. This resulted in
a continuous improvement in licensee performance throughout the as-
sessment period. In the latter part of the period, the licensee also
implemented additional programmatic improvements on their own initi-
ative which even further improved performance in this functional
area. Significant programmatic improvement, coupled with a lack of
deficiencies and consistently strong performance in all associated
activitiu , indicates a strong licensee commitment to achieve and
sustain a high level of performance in this diverse functional area.
2. Conclusion
Category 1.
3. Board Recommendation
None.
.. __
. .
.
17
.
C. Maintenance and Modifications (601 hours0.00696 days <br />0.167 hours <br />9.937169e-4 weeks <br />2.286805e-4 months <br />, 20%)
1. Analysis
The previous SALP rated the licensee's performance as Category 1.
Positive findings were made in the areas of management involvement,
plant reliability, improved analysis of maintenance related events,
training and qualification, responsiveness to NRC initiatives, and
prioritization of safety-related maintenance. The licensee continues
to demonstrate responsiveness to NRC concerns in this functional
area by providing effective, timely corrective actions which pre-
vented recurrence of 10 CFR 50.59 and technical specification re-
lated problems in performing jumper and lifted lead activities.
During the current SALP period maintenance and modification activi-
ties were reviewed in four region-based inspections. The resident
inspector also examined activities in this functional area as part
of the routine inspection program.
The maintenance program inspections conducted during this period
identified no programmatic deficiencies and detected no trends of
maintenance problems. Active licensee management involvement in
the maintenance program is evident on all levels, with maintenance
-
practices being conducive to early detection of developing equiprent
problems In the process of planning maintenance work, the foreman
automatically reviews the maintenance history cards for the item
being repaired, thus detecting any developing trends. The mainten-
ance department, instrument and control department, and maintenance
support department continue to be staffed by experienced, qualified
craft and supervisory personnel. The attitude that maintenance per-
sonnel exhibit, and the generally good housekeeping conditions in-
volved while performing their work, are indications of good main-
tenance attitudes and practices.
The licensee is in the process of increasing the training program
effectiveness for I&C, mechanical and electrical maintenance per-
sonnel, as part of obtaining INPO accreditation. Training and quali-
fication of maintenance personnel is a noted strength, as evidenced
by the few personnel errors that occur.
The licensee continues to demonstrate concern for plant reliability
and safety. Appropriate equipment upgrading is being considered and
implemented for systems and components proving to be difficult to
maintain either due to age, inadequate performance or unavailability
of spare parts. A ten year plan, reviewed annually and updated or
modified as needed, was developed to identify these licensee con-
cerns. The licensee's initiative in this regard was evidenced by
the installation of a new solid state Reactor Protection Systerr and
the replacement or addition of core exit and reactor head thermo-
couples.
.-. - . _ _ _
. .
.
.
18
During this assessment period, the licensee performed some difficult
maintenance work. A main coolant pump suction valve stem failure
was identified during an unplanned maintenance outage that occurred
to perform repairs for a leak in a steam generator (SG) blowdown
line. The NRC viewed the licensee's corrective actions in response
to the stem failure as being representative of a conservative,
technically sound and thorough approach to resolving conditions
where the potential for adverse safety conditions exist.
Nine LER's were submitted in this functional area. A review of the
event details indicates that the corrective action implemented by
the maintenance organization was effective in that recurrent events
were not prevalent. No adverse trends were identified that would
contribute to equipment unavailability or improper performance as
a result of maintenance activities. The licensee's event analyses,
using PIRs, provided thorough reviews involving the PORC, and de-
scribed proper corrective actions to prevent the recurrence of non-
reportable events.
.
The NRC issued a Severity Level III violation in response to the
licensee's identification of the existence of incorrect overload
devices that resulted in the inoperability of four motor operated
valves utilized in the reactor coolant vent and emergency feedwater
systems. These incorrect devices were installed in October, 1985
during the refueling outage as part of implementing a design modi-
fication installed to address current regulatory issues and plant
betterment efforts. The licensee assembled a task force to determine
the root causes of the event and identify corrective actions. The
root cauce of this event was attributed to the ambiguous description
contained within the design and procurement documents provided by
YNSD project engineering personnel, with contributing causes in-
volving inadequate receipt inspection and insufficient post instal-
lation testing of the installed equipment. A civil penalty was not
proposed by the NRC because: 1) licensee identification and prompt
reporting occurred; 2) the corrective actions were prompt and com-
prehensive; and 3) good prior performance was evident.
The prior SALP recommended that the licensee ensure that sufficient
maintenance engineering resources in the Maintenance Support Depart-
l ment (MSD) are available with a formalized training program estab-
!
'
lished for these engineers. This recommendation emanated from NRC
concerns for the need to assure that complete and timely reviews
of quality related documentation are performed, and in recognition
of the important functions served by this resource in maintenance
! and modification activities. No additional resources, however, have
'
been allocated to the MSD during the assessment period. Currently,
the formalized training program for attaining, maintaining, and
upgrading MSD personnel oualifications includes attendance at formal
schools and seminars. However, the program does not appear to be
effectively implemented. The weaknesses regarding receipt inspection
,
1
- . - _-- ___ - _. - --
.
.
.
19
.
and post-modification testing of the above event involved both MSD
engineering and an apparent unfamiliarity with motor control center
equipment. The licensee's task force assigned to investigate the
Level III Violation has called for management review of the adequacy
of resources for implementation of design change modifications. Man-
agement attention is warranted to complete the MSD review and ad-
dress recommendations to assure its effectiveness.
The licensee's preventive maintenance (PM) program has been viewed
as a licensee strength. Initiating additional PM activity in areas
exhibited by industry experience, such as feedwater system check
valves, should be considered.
In general, the licensee continues to be responsive to NRC initi-
atives involving maintenance and modifications. Replacement of
Agastat GP series relays due to service life concerns was imple-
mented in a timely fashion in safety-related applications in re-
sponse to IE Information Notice 84-20. Commitments and implemented
activity by the licensee in areas of NRC concern have involved 10
CFR 50 Appendix R, post-accident sampling, grid undervoltage pro-
tection, Systematic Evaluation Program, EQ program, and Generic
Letter 83-28 modifications. The licensee also completed modifica-
tions to centainment isolation valves resulting from leak rate
testing identified deficiencies.
The program for control of technical manuals, as required by Generic
Letter 83-28, has been slow in developing. The technical information
program formalized by the licensee's programmatic procedure has
neither established the applicability and accuracy of manuals in
use nor ensured their control. Management attention to fulfill com-
mitments in this area is warranted.
Audits performed by the YNSD Quality Audit and Engineering Group
involving procurement, preventive and corrective maintenance, and
post-maintenance testing were conducted on a yearly basis, with the
use of comprehensive checklists noted. Deficiencies and observations
were documented, with responses reflecting timely and appropriate
corrective actions. QA/QC involvement in safety related activities
regarding design change processes and material procurement appears
( to be adequate. The recently established Quality Control (QC) group's
j responsibilities include a review of all maintenance requests (MR).
l
'
However, this QC review is performed prior to detailed planning of
the work which limits the usefulness of the review. QC inserts hold
points only for notification prior to the start of the work. During
the team inspection that reviewed QA/QC effectiveness, it was de-
! termined that proper documenting of maintenance was not being ac-
complished, with the QC function observed not to be aggressive in
identifying tnese deficiencies.
..
.- . _ _ _ _ . _ _ _ - _ . _ _
I
... ..
.
,
20
In response to recurrent fuel failure problems, a task force, which
was formed to investigate the situation during Cycle XVII operation,
has developed plans and programs necessary to eliminate future
failures. Initiatives included: 1) design and implementation of
baffle spacer plugs to preclude flow-induced fretting from occurring,
2) use of ultrasonic fuel inspection techniques to replace tradi-
tional fuel sipping methods to identify failures in second cycle
fuel bundles, and 3) factoring design features into future fuel to
strengthen the resistance of the fuel bundles to previously identi-
fled failure mechanisms. The licensee is currently monitoring Cycle
XVIII operation indications of cladding failure (which appear to
be second cycle fuel related) and will be assessing the need for
additional corrective measures.
In summary, maintenance and modification activities are observed
to be implemented in an outstanding manner. The plant, particularly
avith regard to equipment important to safety, performs with high
reliability. Forced entries into TS action statements because of
safety related equipment problems are rare. Proper regard for
equipment concerns, such as aging, poor performance, or maintain-
ability, and responsiveness to NRC concerns has been effectively
demonstrated. The modification-related breakdown associated with
the installation of incorrect overload devices for four valves was
determined to be an isolated occurrence that was not representative
of the normally observed high standard of licensee performance.
Improvements are needed to: 1) provide more effective integration
and involvement of QC in routine maintenance activities, 2) provide
a proper level of documentation for maintenance activities being
perforced, and 3) address resource and training issues in the MSD.
2. Conclusion
Category 1.
3. Board Recommendation
None.
.
21
.
D. Surveillance (284 hours0.00329 days <br />0.0789 hours <br />4.695767e-4 weeks <br />1.08062e-4 months <br />, 10%)
1. Anal: *is
Surveielance was rated Category 1 during the last SALP. Weaknesses
in the management control and attention in the chemistry area were
specific NRC concerns. This issue was resolved during this assess-
ment period by continued improvements in chemistry department per-
formance that resulted from strong management involvement at cor-
porate, plant, and department levels. Further discussion on this
item is contained in the Radiological Controls functional area. The
licensee's perceived incompatibility between current steam generator
in-service inspection sample size and Technical Specification ac-
ceptance criteria has been the subject of their continued efforts
in this assessment period, with the development of a Technical
Specification amendment request nearing completion that should aid
in resolving the issue.
During this assessment period, operational and refueling surveil-
lance activities were reviewed by the resident inspector during
routine inspections. Two inspe:tions were conducted by region-based
inspectors in the areas of surveillance testing and calibration con-
trol program and main coolant syr, tem structural integrity surveil-
lance requirements. NRC concerns were raised because of the opera-
tions department failure to conduct meaningful daily required chan-
nel checks for meteorological monitoring and steam generator blow-
down radiation monitoring instruments, as well as a failure to im-
plement a requirement to verify the position of the in-service main
coolant loop bypass valve (s) while in Mode 3. Two violations were
issued in response to the observed inadequacies. The licensee is
conducting a review of surveillance procedures in comparison to the
Technical Specifications to ensure that appropriate surveillance
requirements have been addressed and are properly incorporated into
procedures.
The QA/QC programs appear to be well-managed in this functional area.
The Quality Coatrol Group and the Operational Quality Group have
defined their areas of responsibility and they have actively pur-
sued an NRC-identified weakness that involved management review of
l QC inspection reports.
Management involvement and control in assuring quality was evident.
Department managers are responsible for the performance of surveil-
lance activities within their assigned areas. This ensures a high
level of management involvement by dedicated individuals. When
Technical Specifications changes occur, the plant superintendent
'
directs the implementing activity to ensure correct incorporation
of requirements into the program. Prior planning was consistently
y ,
.
22
'
evident, records were complete, well-maintained and available. Sur-
veillance testing activities are consistently performed according
to test procedures.
Technical personnel involved with preparing changes to Technical
Specification surveillance requirements were fully knowledgeable-
of the engineering aspects of what was viewed by the NRC as somewhat
unique existing surveillance requirements. The licensee has been
aggressive in obtaining an appropriate technical approach to re-
solving an examination problem with eddy current inspection of steam
generator (SG) tubes. During the routine reviews by the resident
and specialist inspectors the licensee's technical staff was found
to be well trained and knowledgeable, in almost all cases, of ap-
plicable surveillance and testing requirements. Staffing is ample,
with training and qualification programs making a positive contri-
bution to properly controlled and documented testing activities.
Surveillance test results continue to be evaluated in a thorough
and accurate manner. In many cases, the maintenance department pro-
vides ongoing performance trending of as-found equipment performance.
Almost without exception, technically sound and acceptable rEsolu-
tions to NRC and licensee-identified concerns are provided by the
licensee in a timely manner.
The nutter of reportable events for this functional area (four) is
not considered to be high. One LER described a missed surveillance
test on two containment isolation valves because of failure to in-
corporate the testing requirement into an appropriate procedure.
Another LER involved an inadequacy in the testing method for a valve
that is tested per the IST program. The remaining LERs identifiec
equipment inoperabilities due to component failures. In all cases
the licensee's corrective action was prompt and effective.
Licensee initiatives to identify problems are frequent, and reflect
a conservative approach whenever the potential for safety signific-
ance exists. Biweekly containment inspections, although not required,
are conducted in a thorough manner to provide early detection of
potentially adverse conditions involving main coolant system integ-
rity and equipment performance. This is of particular significance
in light of degraded fuel performance exhibited during this assess-
ment period. Equipment failures identified during surveillance
testing are aggressively reviewed for root cause, and if situations
warrant, thc licensee will increase the frequency of testing or
perform additional types of tests to isolate the problem. The lic-
ensee consistently performs eddy current testing on more than the
minimum number of SG tubes required by Technical Specifications.
The licensee continues to exhibit strong overall performance in this
functional area. Management attention to resolve identified weak-
ness involving operations department surveillances have resulted
in a positive trend toward the end of the assessment period. Sur-
,
, --..,mw.. ..w-...-- , , . . - - - , , - - , - - - - , - . , .y, , m . - - . , ,.. , . , . ,._ . - - , , . - . . .
_ _ _ . . .-. .
.. n
.
1
.
23
veillance testing control and performance trending used by the
various maintenance departments are considered a significant licen-
see strength.
2. Conclusion
Category 1.
3. Board Recommendation
None.
'I
k
i
e
!
r
I
i
',
l
. ,
,
24
.
E. Fire Protection and Housekeeping (162 hours0.00188 days <br />0.045 hours <br />2.678571e-4 weeks <br />6.1641e-5 months <br />, 5%)
1. Analysis
.
The previous SALP rated fire protection and housekeeping as Cate-
gory 1. That SALP identified the need for the licensee to provide
continued or additional direct management attention: 1) to encourage
and assure adherence to established procedures; 2) to increase first
line supervision in the field to direct and control work activities
to prevent fires; and 3) to remove non-fire protection duties from
the plant fire protection coordinator during refueling and major
maintenance outages.
During this assessment period, frequent observations of fire pro-
tection and housekeeping activities were conducted by the resident
inspector, with one region-based inspection performed. The licensee
continued to demonstrate its responsiveness to NRC concerns by pro-
viding effective, timely corrective actions to previous issues which,
with minor exceptions, prevented recurrence of the above concerns
during the current assessmant period. The licensee has demonstrated
initiative, as well as a strong and effective approach to the
resolution of technical issues, by instituting at the inception of
the 1985 refueling outage, a fire protection tour at the end of each
shift. The tours, which were conducted by refueling outage co-
ordinators or shift supervisors, were designed to identify inade-
quacies in the control of combustibles. This was in addition to
the observed high level of involvement by the Fire Protection Co-
ordinator in the ongoing outage activities.
Throughout this assessment period, housekeeping and plant cleanli-
ness were maintained at an excellent level. This was the result
of aggressive management involvement that was evident in their
routine station tours, identification of areas needing attention,
and the allocation of resources to both maintain and upgrade the
site facilities. Interdepartmental cooperation on a working level
has resulted in a number of previously contaminated areas becoming
recovered.
Fire brigade training in the area of tactics and hands-on equipment
use was viewed by the resident inspector as aggressive and well
defined. Backshift brigade drills were routinely conducted by the
Fire Protection Coordinator (FPC), with written performance ap-
praisal of the drill disseminated to the brigade members. A
training weakness in fire protection system knowledge that involves
the plant operators was identified on two occasions by the NRC.
Minimal involvement of the training department was noted regarding
assessment of the overall effectiveness of fire protection systems
training. The licensee provided timely resolution of NRC concerns
involving the qualification program for fire watch personnel.
. - - - - - - - - . .-. - . , - . - _ -
._.
- o ,
,
25
.
During the current assessment period, an NRC team inspection took
place to determine compliance with the 10 CFR 50 Appendix R require-
ments with respect to the plant's ability to safely shutdown in the
event of a fire. During this inspection, the plant's corporate and
site management exhibited aggressiveness to the resolution of fire
protection issues. It was evident that priority was given to prob-
lems requiring hardware fixes.
The licensee made several modifications to achieve compliance with
Appendix R separation requirements, and the licensee incorporated
several diverse means of achieving a plant safe shutdown in the
event of a fire, including a new dedicated Safe Shutdown System.
The licensee also had developed adequate procedures, including de-
tailed repair procedures for cold shutdown equipment, and had
demonstrated competence in the use of these procedures. Good
planning and training were evident with respect to these procedures.
The inspection team's conclusion was that the licensce's fire pro-
tection program is adequate and a major contributing factor is the
rapport maintained by the fire protection staff and management and
the increased awareness of the plant's personnel of fire protection
Concerns.
In summary, the fire protection and housekeeping programs continue
to receive aggressive management attention, as evidenced by: 1) the
implementation of effective and timely corrective actions to arrest
the declining trend in the fire protection area at the end of the
last SALP period, and 2) the excellent level of housekeeping condi-
tions found throughout the facility. This area remains a licensee
strength.
2. Conclusion
Category 1.
3. Board Recommendation
Licensee: Provide increased involvement by the training department
in fire protection system training.
NRC: None.
t
. . _ _ _ . _ _ _ . _ _
_ . . . _ _ _ _ _ _ . _ _ _ . _ _ . _ _ _ . - _ _ _ . . _ . _ . _ ,______ , -_. - ,. -
_ _ - -
3 -
,
26
s
F. Emergency Preparedness (445 hours0.00515 days <br />0.124 hours <br />7.357804e-4 weeks <br />1.693225e-4 months <br />, 15%)
1. Analysis
During the previous assessment period licensee performance in this
area was rated as Category 1 (consistent), based upon performance
during the annual exercise, and a high degree of management involve-
ment in emergency preparedness, as evidenced by training, respon-
siveness to identifying and correcting program deficiencies, and
in response to actual events.
During the current assessment period, one partial-scale exercise
and one full-scale exercise were observed, a routine safety inspec-
tion specifically related to follow-up of previous deficiancies was -
conducted, and changes to on-site and off-site emergency plans were
reviewed. In addition, a new Emergency Operations Facility was com-
pleted and fully operational ahead of schedule. Licensee management
undertook a rigorous training program, including drills, to ensure
all required personnel were familiar with facility operation.
For the majority of the assessment period there has not been a per-
manently assigned site Emergency Preparedness Coordinator (EPC) for
the Yankee Nuclear Power Station. On-site duties have been performed
by an individual detailed from the Yankee Atomic Electric Company
corporate office in Framingham, Massachusetts, for the purpose of
upgrading emergency planning capabilities. A permanent site Emer-
gency Preparedness Coordinator was assigned as of August 25, 1986.
One LER was submitted by the licensee in this area, which involved
a failure of PORC to review a change to the Emergency Plan. This
item was identified during an in plant QA audit, with prompt and
effective corrective actions taken in response to the root cause
involving a lack of adequate corporate level administrative controls.
During the partial-scale exercise conducted on May 15, 1985, the
licensee demonstrated a good emergency response capability. Person-
nel were generally well-trained and qualified in their emergency
response roles. Command and control at each emergency response
facility were effective. Protective action recommendations for the
general population were accurate. No significant deficiencies were
identified.
A review by the resident inspector of a medical emergency drill
conducted in September 1985 to assess the emergency medical team
response to on-site medical emergencies, radiation protection con-
siderations, security requirements, and interfaces with off-site
support services (i.e., ambulance and hospital) determined that the
activities reflected a properly planned, executed and audited drill.
The emergency medical response capability remains a licensee
strength.
_ _ _ . _ _ - _ - . _ _ _ _ - . - - _ . . - -
. - - -- - _ _ . _ . -.
O *
.
27
e
During the full-scale exercise conducted on June 11, 1986, the lic-
ensee demonstrated an adequate emergency response capability. How-
ever, some significant deficiencies were identified. As the emer-
gency escalated, turnover of authority was not clear. Protective
action recommendations made to Vermont and Massachusetts were pri-
marily based upon dose projection data without consideration of
potential degradation of plant and core conditions. The licensee's
post-exercise critique was noted to be somewhat superficial and did
not cover the significant deficiencies identified by the NRC in-
spection team. Following clarification of the NRC concerns, more
, aggressive licensee managem?nt attention was focused on issues the
NRC believed would result in improvement of the licensee's emergency
response capabilities. However, the above previously mentioned
deficiencies suggest the need for continued management involvement
to assure that resolution is provided via the licensee's established
corrective action plan.
2. Conclusion
Category 2.
3. Board Recommendation
Nont.
.
.----.-.a . -,---_ - -- - - -- - - -.- , - , - . , , .
*e .. - - - -. , - - - . . - - , , , , y - ---, - - - .- - - --.-- ..--- . ~ , -,,-.,n ---.
a u
.
28
4
G. Security and Safeguards (154 hours0.00178 days <br />0.0428 hours <br />2.546296e-4 weeks <br />5.8597e-5 months <br />, 5%)
1. Analysis
During the previous SALP period, the licensee's performance in this
area was Category 2 (improving). An area in need of improvement was
identified as developing a better understanding of NRC performance
objectives in the implementation of co:spensatory measures.
During this assessment period, two rmannounced inspections were
performed by a region-based inspectcr. Routine resident inspections
continued throughout the assessment period. No violations were
identified.
An NRC Regulatory Effectiveness Review (RER) of the security program
was conducted on July 28 - August 1,1986. The preliminary findings
presented to the licensee at the completion of the review included
weaknesses in barrier features, assessment aids and detection aids
that required the immediate implementation of compensatory actions
by the licensee. During the RER followup inspection, a programmatic
weakness was found in the area of security recordkeeping practices.
Records were determined not to be readily available or easily re-
trievable, and were not centrally stored. The majority of the
weaknesses further derronstrated a continuing need for a better
understanding of NRC security program objectives by licensee and
contractor security management. The licensee should have identified
and corrected many of the deficiencies found by the RER team and
during' inspections (such as the records problem discussed above).
While no violations of NRC requirements were identified during this
assessment period, and several program improvements were implemented
to respond to NRC-identified weaknesses, there is still room for
additional improvement.
The licensee's responses to NRC findings were generally prompt and
effective. There was evidence of continuing management attention,
both corporate and plant, to program needs in terms of facility,
equipment, and program upgrades. While these largely involved the
expenditure of capital resources, the program upgrades included an
increase in maintenance support for security equipment and the de-
velopment and implementation of a more comprehensive audit and sur-
veillance program. The prior upgrading of some systems, and the
continuin; in:rease in maintenance support for the systems, have
resulted in a substantial reduction in the need for compensatory
measures. However, management attention to overall program effec-
tiveness was still not tiufficient, as evidenced by the large number
of access control area door alarms. The licensee has identified the
necessary long term hardware fixes, but plant management has not
been aggressive in obtaining plant personnel cooperation in pre-
cluding the need for security force response to compensate for
equipment inadequacies.
__ _ _ - _.
. .
.
29
,
The recently developed (June 1985) licensee audit and surveillance
program represents a substantial improvement over the previous audit
program, in that it focusas on compliance with the licensee's com-
mitments contained in the NRC-approved security program plans and
the licensee's implementing procedures. Improvements in the detec-
tion, identification, and implementation of audit deficiencies was
observed by the NRC. However, the compliance-oriented nature of
the audit program places insufficient emphasis on overall improve-
ment by not measuring program effectiveness.
The licensee submitted three security event reports during the
assessment period, in accordance with 10 CFR 73.71. For one event,
which involved a loss of certain systems due to a power surge, an
amended report was requested (and received) by NRC to understand
better the circumstances and impact of the event. Another event,
which involved servicing systems that had been properly compensated,
did not require reporting. The third event involved the loss of a
portion of a document that had been categorized as Safeguards In-
formation. It 'was later determined that the document was erroneously
categorized. While each event was promptly reported, each report
indicated deficiencies in licensee management's understanding in
regard to the NRC requirements. Enhanced performance by site lic-
ensee management is required.
The security contractor has an adequate number of supervisory per-
sonnel on shift who appear to be well qualified. Staffing of the
security force appears to be adequate for normal conditions. However,
the use of overtime was required in August when it became necessary
to man several compensatory posts unexpectedly. The security force
was not up to its full complement, and the required working of
overtime had a noticeably deleterious effect on the existing poor
morale, caused by extended labor negotiations between the security
contractor and the force. An NRC inspection at that time found that,
despite the generally low morale condition, the force remained
dedicated to its duties and responsibilities. Licensee management
attention should be directed toward maintaining the force at its
full complement to avoid complications when unexpected circumstances
stress the security organization.
l The training and qualification program for the security force is
i carried out in accordance with the NRC-approved plan. The program
l includes on-the-job evaluations of security force members by the
I
contractor's supervisors and effective feedback to the training
function. Members of the security force are knowledgeable of their
[
1
duties and responsibilities and carry them out in a professional
manner. In response to an NRC recommendation, increased emphasis
on armed response drills was noted during this assessment period.
!
'
These training experiences should continue in order to further en-
hance the capabilities of the security organization.
l
t ._ __ -. _
. _. . -- -_ - - - --- - - - - - - -
._ _
q
. .
.
30
,
During the assessment period, the licensee submitted five revisions
to security program plans to NRC, under the provisions of 10 CFR
50.54(p). Some requested changes reflected a lack of understanding
of the provisions of the regulations; however, prompt resolution
was provided by the licensee upon NRC identification of unacceptable
conditions. Although latter submittals have shown improvement,
continued management attention is necessary to provide complete and
accurate descriptions and summaries of changes to ensure that there
is no decrease in the effectiveness of previous NRC-approved plans.
Although the security program is adequate, program implementation
and oversight is compliance oriented. Neither licensee nor security
contractor management has demonstrated understanding of program ob-
jectives. As a result, program improvements have been minimal and
management oversight is not fully effective.
2. Conclusion
J
Category 2.
3. Board Recommendation
i None.
!
l
l
l
i
- _ . _ - .. . _ _ _ . . _ _ _ _ _ _ _ __ _ _ _ _ _ . . ~ _ _ . _ . _ _ _ . _ . _ , _ _ _ . _ _ _ _ _ _ ______ _ _ _ ._ _ _ _ _ _
_
,
e 4
0
31
,
H. Refueling and Outage Management (142 hours0.00164 days <br />0.0394 hours <br />2.347884e-4 weeks <br />5.4031e-5 months <br />, 5%)
1. Analysis
The previot.; SALP rated refueling and outage management as Category
1, with thir functional area considered to be a notable licensee
strength.
During this assessment period, a refueling outage began on October
19, 1985. Preparations for refueling were reviewed by the resident
inspector and included outage planning and procedural preparations.
Post refueling physics testing was the subject of two region-based
inspections.
One unscheduled extended maintenance outage occurred between June
18 and July 1, due to a leak on a steam generator blowdown line and
the failure of a valve stem on a loop isolation valve. These acti-
vities were reviewed by the resident inspector.
Management involvement and control in this functional area continues
to be a licensee strength. A high level of attention by both senior
corporate and site management is provided in scheduling, planning,
and controlling activities associated with plant outages. During
the current refueling outage, the assistant operations manager (SRO
licensed) was detailed to act as the refueling outage coordinator.
A senior control room operator and a reactor engineer were assigned
to provide back shift coordinator coverage. Proper and detailed
shift turnovers were observed to occur. The outage planning and
coordination organization resulted in decision making consister.tiy
at a level that ensured adequate manapn ent review of activities.
Daily planning meetings, held twice per day, were effective in co-
ordinating work accomplished and identifying mechanisms to improve
schedules.
Activities related to refueling and outage activities were verified
to be performed in accordance with approved procedures, with records
being complete, well maintained and available. The assistant plant
superintendent continues to be charged with overall outage planning
responsibility. His high level of dedication, attention to detail,
and proper concern for adherence to administrative policies place
a priority on plant and personnel safety. This is a notable
strength that contributed significantly to the licensee's excellent
performance in this functional area.
The license's response to unexpected problems during the outage is
viewed as a continuing strength. Thoroughness and conservatism,
with an ongoing attention to safety, characterized the licensee's
approach to resolving technical issues. Identified oeficiencies in
controlling work activities resulted in prompt corrective action.
Problems and issues encountered during the outage were diverse. In
. - . ,
a .
.
,. 32
handling these problems, the inplace corrective action systems
promptly identified the non-reportable concerns. Plant ir. formation
reports have been utilized to assess the events with the onsite
safety committee ensuring appropriate corrective action was identi-
fled to prevent recurrence. During the refueling, the NRC observed
that further-licensee action is needed to strengthen procedural
controls associated with maintenance, surveillance and operational
activities used to ensure that containment integrity is maintained
when required.
Licensee staffing levels were ample to perform the refueling acti-
vities, with supervisory involvement in field operations evident.
Augmentation of the station staff with appropriate contractor help
and assistance from the Yankee Nuclear Service Division staff was
implemented by the licensee. Effective integration occurred between
plant and contractor personnel, especially within containment where
aggressive supervision of contractor radiation protection techni-
cians was provided. The training and qualification efforts of the
licensee in preparing and conducting refueling outage activities
made a positive contribution to the safe conduct of the refueling
outage. Pre-refueling reviews of guidelines and procedures involving
normal and abnormal or emergency conditions, with the use of train-
ing check off sheets, was implemented well in advance of the initi-
ation of the refueling outage. A general plant safety meeting was
used to review previous refueling incidents by plant managers to
prevent recurrence. Personnel errors were minimal, reflecting an
understanding of the work and adherence to procedures. Effective
feedback was provided to operating personnel when it was observed
that nen- fuel could be lifted with only a partial latching of the
lifting tool. Proper attention to detail and recovery operations
by the licensed operators controlling the activity is credited with
preventing the occurrence of a dropped fuel bundle event.
At the completion of the refueling outage, updated drawings and
procedures that reflect facility modifications are made available
to support startup and subsequent plant operations. A Pre-startup
Training manual was developed and utilized to qualify licensed plant
operators on the various design changes and modifications made
during the ref.aling outage.
In summary, the licensee's performance in this area continues to
be a noteworthy strength. Active involvement of corporate and site
managers, with quality performance of personnel involved in outage
i
I
activities, has resulted in safe and timely completion of outage
activities.
2. ' Conclusion
Category 1.
, o
C
33
.
3. Board Recommendation
None.
!
i
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l
l
r
!
. .
.
34
,
I. Assurance of Quality
1. Analysis
During this assessmer,t period, management involvement and control
in assuring quality is being considered as a separate functional
area in addition to being one of the evaluation criteria for the
other functional areas. Consequently, this discussion is a synopsis
of the assessments relating to quality work conducted in other areas.
In addition, the prior assessment period included as a separate area
the topic of Design Control / Quality Assurance (QA), which was as-
signed a Category 2 performance rating. The licensee has adequately
addressed previous NRC concerns which included: 1) adequacy of de-
sign control and safety evaluation review; 2) evaluation of training
effectiveness for non-licensed training; and 3) performance of the
Operations Quality Group (0QG). However, prior NRC concerns with
the licensee's implementation of their quality control (QC) inspec-
tion program, did not result in effective corrective measures.
The emphasis for the performance of quality resides with the indi-
viduals performing the work activities involved in operating, main-
taining, and modifying the plant. Licensee management efforts appear
to be directed towards QA/QC involvement that enhances quality by
feeding bad VM related observations without removing the primary
responsibilities of the workers in ensuring quality. To this end,
the licensee's programs have been very effective in most areas, as
evidenced by plant and personnel performance factors. Programmatic
deficiencies have not been identified by the licensee or the NRC
that have adversely impacted on the safe operation of the plant.
Performance of onsite and offsite review committees continues to
be viewed as a licensee strength in performing their assigned func-
tions. The licensee uses PIRs and LERs as effective corrective
action systems to address licensee identified deficiencies and aid
in preventing future loss of quality performance.
The QC group has been in existence for ten months and consists of
a supervisor and three inspectors with plans for an additional in-
spector by 1987. The responsibilities of the QC group include moni-
toring of various plant maintenance, modification, surveillance,
administrative and radwaste activities to verify adherence to qual-
ity assurance requirements. In addition, inspectors occasionally
accompany equipm nt shipped offsite for repairs to insure quality
care and work are maintained at the repair facility. The licensee's
QC group has also established provisions to in:.rease the QC staff
during outage periods with personnel from the corporate office.
The QC group has exhibited strong performance in the radwaste ship-
ping area by providing 100% coverage. Another positive initiative
was the cross-certification of permanent QC personnel on at least
two inspection disciplines (most actually have three areas of ex-
pertise).
e
O s
O
35
.
In the previous SALP report the NRC recommended that the licensee
review the existing quality control inspection program and proce-
dures to identify areas of disagreement, and formally document and
implement the desired program with appropriate controls. An opera-
tionally oriented QA effectiveness team inspection conducted at the
end of this assessment period found that the corrective action for
previously identified deficiencies was not effective in some areas.
The licensee's QC inspection of maintenance and surveillance acti-
vities was not implemented in accordance with procedures that es-
tablish requirements, provide acceptance' limits, and include in-
spection responsibilities. Weaknesses in supervisory reviews for
quality control inspection reports and establishment of hold points
were also identified.
The QA effectiveness team inspection had further findings which are
indicative of a potential weakness in QA/QC management involvement.
These included: 1) the lack of management review of all Quality
Control Inspection Reports (QCIRs); 2) the lack of understanding
the significance and method of completing the final review section
of the QCIRs; 3) the excessive delay in revising procedures; 4) the
failure to identify that inspection procedures were not implemented
as written; and 5) management's position that the QA program did
not apply to certain consumables. The findings of the QA team as-
sessment are not indicative of a programmatic breakdown, but do in-
'
dicate that more intensive management involvement in this area is
warranted.
The audit program is conducted in accordance with the licensee's
procedure and published schedule. Licensee initiatives to improve
effectiveness of the program have included: 1) improved offsite
review committee cognizance of the audits; 2) increased staffing
and use of plant related expertise for the audits; 3) incorporation
of audit findings in trending reports; and 4) reports of audit de-
ficiencies and observations that have gone uncorrected for more the-
six months, highlight items which require management attention. The
licensee's station staff has remarked positively about audit program
improvements, and considers that they are providing a more meaning-
ful self-evaluation process.
The licensee's Quality Audit and Engineering Group has been success-
ful in establishing a program to track, trend and evaluate NRC
findings, LERs, nonconformance reports, PIRs, audit observations
and deficiencies, and QA surveillance deficiencies. As of July, 1986,
QC group inspection deficiencies were incorporated into the Quality
Assurance Department's Trending program. Semi-annual trending re-
ports are issued to all levels of licensee management. Other indi-
cations of related improvements in management involvement and con-
trol in assuring quality include the following licensee initiatives:
1) utilization of yearly performance-oriented corporate goals in
i
. .. .
.
36
,
all areas of operations; 2) development and use of plant quarterly
.
performance statistical trends; and 3) comparing industry-wide plant
performance.
To more clearly define the fitness for duty program, the licensee
has issued a revised drug and alcohol policy effective October 1,
1986. This policy incorporates drug and alcohol testing of.all
employees at annual physicals and a strict prohibition against the
sale, use, or possession of drugs or alcohol on licensee property.
Also, licensee employees are not to report for work under the in-
fluence of either drugs or alcohol. The policies also cover both
visitors and contractors requiring unescorted access to the plant
site. In a related matter, the licensee's plant management, super-
visory and senior technical personnel attend fitness for duty and
behavior observation training given by a behavior observation pro-
fessional on a once per year basis.
In summary, management involvement and control in assuring quality
continues to be aggressive in providing the proper level of over-
sight. On an overall basis, the QA and QC staffs were monitoring
all licensee activities at a high degree of involvement and con-
tinued positive performance trends were generally noted. The fol-
lowup of identified deficiencies exhibited thoroughness as well as
exceeding the frequency required by their program. The trending
analysis is used to identify those areas where performance improve-
ment is needed and as such it is proving to be a valuable management
4
tool. Also, QA audits have gained wider worker acceptance as the
type of auditing technique becomes more meaningful with respect to
the evaluation of quality and performance. The only exception tc
an otherwise exemplary performance is the one inadequate corrective
action associated with the concerns expressed in the previous SALP
'
period. In this area, focused management attention is warranted
in developing and implementing program procedures for the QC in-
spection activities that are responsive to NRC requirements with
respect to proper documentation of inspection activities.
2. Conclusion
Category 1.
3: Board Recommendation
None.
.
--n.., , . n . . - . - - - - , . -, - , . , -o -y ,.c - --- , .--- --a , , . - - - _ - - , . _ . - . - , _ . - . - , - - - - - - -
-
.
-.
_
,-
37
J. Training and Qualification Effectiveness
1. Analysis
During this assessment period, Training and Qualification Effective-
ness is being considered as a separate functional area for the first
time. Training and qualification effectiveness continues to be an
evaluation criterion for each functional area.
The various aspects of this functional area hate 1een considered
and discussed as an integral part of other functional areas and the
respective inspection hours have been included in each one. Conse-
quently, this discussion is a synopsis of the assessments related
to training conducted in other areas. Training effectiveness has
been measured primarily by the observed performance of licensee
personnel,-and to a lesser degree, as a review of program adequacy.
The discussion below addresses three principal areas: licensed
operator training, non-licensed staff training, and the status of
INPO training accreditation.
'
l
In the area of licensed operator training, the licensee maintains
a relatively small training staff and relies on^ contractor support
to perform a large portion of initial operator instruction, all
simulator training and most of the candidate evaluations conducted
prior to NRC examinations. The review cf the licensed operator
training program detected significant weaknesses that have nega-
tively impacted on the ability of the licensee to successfully
prepare candidates for NRC examinations. Continued and additional
management attention is warranted to provjde corrective measures
to: 1) improve training effectiveness upon identification of can-
'didate weaknesses during all evaluation phases of the training
program, and 2) provide aggressive training department oversight
of training programs, including contractor involvement, to insure
,
adequate standards of instruction are maintained.
l I
!
The licensee ha:, taken actions to improve the quality of candidates
entering the licensing program and to improve the screening of can-
didates during the training program., Candidates will be required
to become more involved with plant evolutions as part of their
training. An additional licensee initiative involves the implementa-
i tion of a new hiring policy that requires a Bachelor riegree in en-
gineering or engineering technology for an individual to be eligible
for vacant auxiliary operator positions. The first hire under this
policy occurred in August, 1986. ,
,
Training material was identified as a training weak' ness in the prior
SALP and no significant improvement has been noted during the as-
sessment period. Some recently prepared training material has become
out-of-date due to plant modifications. The licensee has committed
to have a complete and accurate set of training mateffal by March
!
l
I
l
!
, - - _ - - . _ _
, .-
_ _ .
ee' e
.
.
38
1987. The training programs for non-licensed operator, licensed
operator, and licensed operator requalification received INPO ac-
creditation in March 1986. Since accreditation is relatively recent,
no candidates have completed the approved program. However, a lic-
ensing class entered the accredited program in the summer of 1986
and will complete the program in April, 1987.
During this assessment period, non-licensed training proved to be
effective as evidenced by very few personnel errors. The licensee
relies heavily on department on-the-job training to establish and
maintain personnel technical qualification. Notable training and
qualification effectiveness strengths were: 1) use of department
managers as GET/Requalification training leaders to cover those
areas of their expertise; 2) strong performance by plant operators
in procedural implementation of safe shutdown system use in accord-
ance with 10 CFR 50 Appendix R; 3) quality control inspector knowl-
edge of radwaste transportation requirements
program to familiarize all emergency response;personnel
and 4) a vigorous
in effective
use of the new E0F.
Weaknesses in training and qualification effectiveness were identi-
fled in some areas; e.g., 1) maintenance support engineers' under-
standing of equipment performance and receipt inspection require-
ments, as well as ineffective implementation of their training pro-
grams; 2) inadequate training and its effectiveness assessments for
fire protection systems knowledge; and, 3) inattentiveness of the
maintenance staff to completion of documentation requirements of
MRs, in conjuction with insufficient identification by QC inspectors
that program requirements were not being met.
The licensee continues to aggressively pursue the training program
accreditation with INPO. On October 17, 1986, just subsequent to
the end of this assessment period, the licensee had submitted and
INP0 had accepted the Self Evaluation Reports for: maintenance (I&C,
mechanical, electrical), chemistry, radiation protection, shift
technical advisor, and technical staff and managers. The INP0 site
accreditation team visit is scheduled for June,1987.
!
l
In summary, problems persist in preparing personnel for NRC license
' examinations. The overall program for the candidates as well as the
quality of training material continues to be marginal. In contrast.
i
'
the training of licensee personnel to perform a variety of assignec
responsibilities appears to be very effective. There is a low in-
,
cidence of personnel errors, few of which could be directly attri-
i
butable to shortcomings in the training program. A number of lic-
! ensee initiative > during this assessment period indicated managerial
interest in various aspects of training at many levels. The short-
comings in preparing licensed operators for NRC examinations appears
to be a notable exception to an otherwise effective overall training
program.
-.
.
-- .
.
39
..
2. Conclusions
,' Category 2.
3. Board Recommendation
Licensee:
-
Closely monitor trainee progress in the licensing program and
provide for an assessment of the quality of instruction and
evaluation provided by contractors.
-
Complete and update training material.
,
, -
'__ _ , _ , . . , _ _ _ _ _ _ _ _ _ ... .- - --
~ ,
.
40
K. Licensing Activities (107 hours0.00124 days <br />0.0297 hours <br />1.76918e-4 weeks <br />4.07135e-5 months <br />, 4%)
1. Analysis
This evaluation represents the combined inputs of the Operating
Reactor Project Manager, technical reviewers, and the resident in-
spector.
During the SALP evaluation period, YAEC continued to show excellent
management overview in the area of licensing activities. The licen-
see does not have a formal integrated implementation schedule plan.
However, the licensee has a system for establishing priorities on
issues such that both licen:ee and NRC resources are focused on the
most significant issues. Also, the licensee has a system for co-
ordinating manpower requirements, equipment procurement and engi-
neering changes for outage planning. The licensee has been ogen in
discussing their priorities for both completion of licensing issues
and for their implementation with NRC and has been receptive to NRC
comments. The NRC has noted evidence of prior planning, in particu-
lar, timely submission of the incore detector operability TS pro-
posed change and also the early submittal of a proposed change to
the TS relating to the next reload (Spring 1987).
Licensee management has taken an aggressive role in an effort to
achieve resolution of long-standing issues such as the SEP reviews. '
Upper management involvement in establishing priorities and in
reaching technical resolution has been evident.
Early in the reviec perioc, some problems were experienced with
respect to providing sufficient information to support the no sig-
nificant hazards considerations determination and, on occasion (such
as proposed change 192), for the proposed changes themselves. Im-
provement has been noted in this area over the period.
The Yankee plant is unique in many aspects and the licensee often
relies on the long operating experience and simplicity of design
to justify alternative approaches to resolution. Because of the age
and size of the plant many generic resolutions of issues are not
appropriate and thus more work is required by both the NRC and YAEC
to complete the reviews. In general the licensee has been able to
satisfy the intent of NRC requirements in plant-specific applica-
tions. For example, the licensee has installed a safety parameter
display system (SPDS) which is relatively simple, acceptable to the
NRC and effectively used by the plant staff.
l The licensee has developed an approach for resolution of SEP exter-
! nal event reviews which relies on the recently installed dedicated
l shutdown capability and on the results of their probabilistic safety
l study. This approach should result in efficient use of resources
to obtain maximum safety benefit.
l
l
l.
l
l
l
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.-_ . - .
.
.
41
->
Clear understanding of the issues and sound technical approaches for
resolution have been evident in the areas of fire protection, re-
sponse to GL83-28 concerns (Salem ATWS) and for the many proposed
changes to the Technical Specifications.
In the detailed control room design review, the licensee did not
initially perform a sufficiently detailed function / task analysis
particularly of instrumentation and control requirements. The lic-
ensee did not appear to recognize the importance of this analysis
in.the overall review and was reluctant to implement remedial ac-
tions. While progress has been made recently through meetings and
licensee submittals, this aspect is not yet resolved.
.The issue of bus undervoltage protection has been prolonged. The
NRC safety evaluations have clearly indicated the staff's position
regarding testing of both the first and second level of protection.
The licensee did not resolve the safety issues dealing with the
first level of protection, even after they were identified by the
staff. Several rounds of correspondence have occurred and the issue
is still not settlec.
A problem regarding adequacy of minimum starting voltages in the
electrical distribution system for safety-related equipment was
reported by the licensee some time after this generic issue had been
originally resolved. One of the underlying reasons for this prciblem
was an assumption by the YNSD engineering staff regarding pump motor
rating which had not been adequately verified on site.
Some of the issues mentioned above originated prior to the rating
period and may have been complicated by turnover of licensing per-
sonnel both at YAEC and the NRR organization. However, more atten-
tion to detail, improved communication within YAEC, and enhanced
verification activities by the licensee may be appropriate.
In April, 1985, the licensee implemented a plant level organiza-
tional change that impacted on existing Technical Specifications.
,
As of the end of the current assessment period an appropriate lic-
ensing action has not been submitted. Additionally, as indicated
in Section G, Security and Safeguards, the licensee has not been
fully responsive to the prior SALP's concern involving changes sub-
mitted under Section 10 CFR 50.54 (p). Additional management atten-
tion in these areas is warranted to prevent future inadequacies from
developing.
The licensee continues to respond promptly to NRC staff initiatives.
During this performance period, the licensee worked with NRC to
resolve a substantial number of multiplant, TMI and plant specific
issues. Actions completed included environmental qualification of
electrical equipment, GL83-28 issues, as well as a large backlog
of TS changes. In addition, significant progress has been made in
! !
!
. _ _ . , __.
w .
.
42
o
the areas of SPDS, Regulatory Guide 1.97 (Post Accident Monitoring),
e
and SEP issues. All issues on fire protection are essentially re-
solved and implemented.
The licensee has been cooperative in providing information through
conference calls, meetings, and submittals. In addition, periodic
meetings are held between the NRC Project Manager and the YAEC
licensing representative to discuss licensing issues. Generally,
issues have been resolved in a timely manner.
The licensee performs most of their engineering, including the re-
load analysis, in-house. Staffing levels seem satisfactory for the
level of work required.
The analysis of the licensee's reportable events is contained in
the plant operations section of this report. Only a single event
(LER 85-01) was identified by the licensee where plant operations
could have potentially been in deviation with the safety analysis.
This event involved the identification of a LOCA analysis deficiency
which was compensated for by the insertion of selected control rods.
The licensee provided timely resolution of this issue in a technic-
ally sound and thorough manner that reflects their conservative
approach whenever the potential for safety significance exists. Re-
views of licenset responses required by NRC I&E Bulletins have
improved in response to management attention to previously-identi-
fled weaknesses in this area.
In sur. mary, the YAEC organization has performed well in the licens-
ing area during the report period as evidenced by the large number
of completed actions. Strong management involvement has been noted;
however, continued management attention should be focused on the
areas noted above to maintain the high performance level.
l
2. Conclusion
Category 1.
3. Board Recommendation
l
None.
i
,
l
,,
.
43
.
V. SUPPORTING DATA AND SUMMARIES
A. Investigation and Allegation Review
There was one allegation during this SALP period. It involved the licen-
see's policy on use of prescription narcotic medicine by members of the
contract guardforce while on duty. Currently, the licensee's contracted
security force has appropriate policies covering the use of prescription
medicines. No violation of NRC requirements was identified.
B. Escalated Enforcement Action
1. Civil Penalties
There were no civil penalties issued during this assessment period.
2. Orders
There were no orders involving escalated enforcement action during
this assessment period.
3. Confirmatory Action Letters
There were no confirmatory action letters issued during this as-
sessment period.
C. Management Conferences
On July 22, 1986, an enforcement conference was held at the NRC Region
I office to discuss the installation of undersized trip coils in the
circuit breakers for motor-operated valves located in the reactor coolant
system vents and emergency feedwater system.
D. Licensee Event Reports
1. Tabular Listing
Type of Events:
A. Personnel Errors 11
B. Design / Man./Const./ Install 3
C. External Cause 0
D. Defective Procedure 2
E. Component Failure 7
X. Other 0
Totals 23
LERs Reviewed
LER No. 85-01 to 86-13
1
l
-
44
2. Causal Analysis
The following sets of common mode events were identified;
a. LERs 85-02 and 86-11 reported missed or incorrectly performed
surveillances.
b. LERs 85-09, 85-10, 86-04, 86-12, and 86-13 reported a total
of five reactor trips (two at power and three while in startup).
Of these, three reactor trips (all while in startup) involved
personnel error.
c. LERs 85-08 and 86-06 involved inoperabilities of steam genera-
tor blowdown monitors
d. LERs 85-04, 85-06, 85-07, 85-08, 86-04. 86-06, and 86-08 are
events due to component failures.
E. Operatino Reactors Licensino Actions
1. Schedular Extensions Granted
None.
2. Reliefs Granted
None.
3. Fva-" inns Gre.ted
October 2, 1986 Exemptions to Section III.G of 10 CFR Part 50 Ap-
pendix R (Fire Protection)
4. Orders
A confirmatory order was issued on July 5,1985, modifying the
license regarding additional licensee commitments on emergency
response capability (Supplement 1 to NUREG-0737)
5. License Amend ents Issued
Amendment E3 issued on July 1,1985, Technical Specifications on:
a) typographical corrections / clarifications, b) removal of references
to 3 loop operation, c) NUREG-0737 clarification items, d) Inte-
grated Plant Safety Assessment Report items, and e) Radiological
,
Effluent TS clarifications.
Amendment 84 issued on October 1, 1985, Technical Specifications
on a) pressurizer code safety valve capacity / snubbers, b) degraded
grid voltage, and c) main coolant vents.
o
,
45
Amendment 85 issued on October 31, 1985, Technical Specifications
on pressurizer safety valve setpoint tolerance.
Amendment 86 issued on November 8, 1985, Technical Specifications
on containment isolation surveillance.
Amendment 87 issued on November 18, 1985, Technical Specifications
on ECCS surveillance intervals.
Amendment 88 issued on November 27, 1985, Technical Specifications
on refueling.
Amendment 89 issued on November 30, 1985, Technical Specifications
on degraded grid voltage (second level).
Amendment 90 issued on December 16, 1985, Technical Specifications
on ECCS leakage.
Amendment 91 issued on January 15, 1986, Technical Specifications
for train coolant system inspections.
Amendment 92 issued on May 14, 1986, Technical Specifications for
SIT, steam generator blowdown monitors, etc.
On May 14, 1986, notice of denial of changes on: 1) isolated loop
charging, 2) reference to TS 4.0.5, 3) control room ventilation TS,
4) use of temporary door in airlock, and 5) removal of tritium
sample requirements.
Amenament 93 issued on May 20, 1986, Technical Specifications for
spent fuel pit movements.
Amendment 94 issued on May 28, 1986, Technical Specifications for
main steam line low pressure isolation trip.
Amendment 95 issued on June 5,1986, Technical Specifications for:
a) containment high range radiation monitors, core exit and vessel
head thermocouples, containment pressure and water level monitors,
and b) containment hydrogen monitor.
Amendment 96 issued on June 9, 1986, Technical Specifications on
blank flange.
Amendment 97 issued on June 17, 1986, Technical Specifications on
containment breathing air system isolation.
Amendment 98 issued on August 20, 1986, Technical Specifications
on RETS Reporting Requirements.
Amendment 99 issued on September 23, 1986, Technical Specifications
on changes to RETS.
A .
.
TABLE 1
TABULAR LISTING OF LERS BY FUNCTIONAL AREA
YANKEE NUCLEAR POWER STATION
CAUSE CODES *
Area A B C D E Total
A. Plant Operations 2 1 2 5
B. Radiological Controls 1 1
C. Maintenance and Modifications 4 1 1 3 9
D. Surveillance 1 1 2 4
E. Fire Protection and Housekeeping 1 1
F. Emergency Preparedness 1 1
G. Security and Safeguards 0
H. Refueling and Outage Management 0
I. Assurance of Quality
J. Training and Qualification Effectiveness 0
K. Licensing Activities 2 _ _ _ _
2
TOTALS: 11 3 0 2 7 23
- LER Cause Codes (Assignea during NRC review.)
A - Personnel Error
B - Design, Manufacturing, Construction, or Installation Error
C - External
D - Defective Procedure
l E'- Equipment Malfunction
!
,
!
.
1 e. 9 k.'
6-
TABLE 2
LER SYNOPSIS (2/1/85 - 10/6/86)
YANKEE NUCLEAR POWER STATION
LER NUMBER SUMMARY DESCRIPTION
85-01 Determination of Inappropriate LOCA Methodology Assumption
-85-02 CS-V-621 Not Tested in Accordance With The ISI Program
85-03 Fuel Degradation (Assemblies B-696I, B-688 and A-679 In Core Posi-
tions ,,-9, H-8, and K-5)
85-04 Pressurizer Safety Valve PR-SV-181 (S/N BW 07972) Setpoint Greater
Than TS
,
85-05 Switchgear Room Fire Barrier Inadequacy
85-06 Condensate Pump Trip Circuit Inoperable
85-07 Nuclear Instrumentation Channels 7 & 8 Low Power Set Points In-
85-08 No. 4 Steam Generator Blowdown Monitor Inoperative
85-09 Reactor Scram During Startup due to Maintenance Personnel Error.
85-10 Inadvertent Reactor Scram During Maintenance Activity
86-01 Technical Specification Violation Concerning the Yankee Emergency
Plan
86-02 Insufficient Implementation Procedures For the Offsite Dose Calcu-
lation Manual
4
86-03 Failure to Comply with a Technical Specification Action Statement
86-04 Reactor Scram - Loss of Heater Drain Pumps
. 86-05 Dose Equivalent I-131 >1.0 Microcuries Per Gram
.
86-06 Inoperable No. 3 Steam Generator Blowdown Monitor
86-07 480 VAC Busses Cross-Tie Electrical Loading Problem
86-08 No. 1 Main Coolant Pump Suction Valve Stem Failure
86-09 Incorrect Overload Devices for Four Motor-0perated Valves
._ - .- . -. ,
_ _ - _ _ _ - _ _ _ _ _ _ _
= M
i
T-2-2
.
LER NUMBER SlM4ARY DESCRIPTION
86-10 Potential Loss Of Shutdown Cooling
86-11 Containment Isolation Valves Missed Surveillance
86-12 Plant Trip on Low SG Level Due to Loss of Control Air
86-13 Reactor Scram due to Operator Error
l
l
t
t
. _ _ _ . _ .
_
< -k
.
4
TABLE 3
INSPECTION HOURS SUMMARY (2/1/85 - 10/6/86)
YANKEE NUCLEAR POWER STATION
HOURS % OF TIME
A. Plant Operations 655 22%
B. Radiological Controls 507 14%
C. Maintenance and Modifications 601 20%
D. Surveillance 284 10%
E. Fire Protection and Housekeeping 162 5%
F. Emergency Preparedness 445 15%
G. Security and Safeguaras 154 5%
H. Refueling and Outage Management 142 5%
I. Assurance of Quality NA NA
J. Training and Qualification Effectiveness NA NA
K. Licensing Activities * 107 4%
Total 3057 100%
- Inspection effort only.
l
t
_ _ __ _ . _ . _ . - -
- - - - _ _ _ _ _ _ _ _ _ _ _ _
< (' k
.
6
TABLE 4
ed
ENFORCEMENT SUMMARY
YANKEE NUCLEAR POWER STATION
Severity Levels
FUNCTIONAL AREAS I II III IV V DEV Total
A. Plant Operations 1 1
B. Radiological Controls
C. Maintenance and Modifications 1 1
D. Surveillance 2 2
E. Fire Protection and Housekeeping
G. Security and Safeguards
H. Refueling and Outage Management
I. Assurance of Quality 1 1
J .' Training and Qualification Effectiveness
K. Licensing Activities
1 2 2 5
_-
..
r
-
7
%
.
'-
TABLE 5
ENFORCEMENT DATA
YANKEE NUCLEAR POWER STATION
Inspection Inspection Severity Functional
Report No. Date Level Area Violation
85-07 3/21-4/26/85 V D Failure to establish a
written procedure that pre-
-
scribes the required quali-
tative assessment for in-
strumentation channel checks
required by the Technical
Specifications for meteoro-
logical monitoring system.
86-02 1/7-2/14/86 V D Failure to establish a
written procedure that prc-
scribes the required quali-
tative assessment for in-
strumentation channel checks
required by the Technical
Specifications for steam
generator blowdown monitors.
86-08 6/10-10/8/86 IV A Failure to maintain at least
one main coolant loop bypass
valve closed while in Mode
3 and failure to conduct
a required surveillance test
on these valves.
86-09 6/26-7/2/86 III C Installation of undersized
trip coils in circuit
breakers for motor-operated
valves located in the reac-
tor coolant system and
.
86-17 9/29-10/3/86 IV H Failure to follow procedures
requiring quality control
for maintenance activities.
!
.- - -_ ___ . ._ ,_ ._ -
- g
6
i
u
TABLE 6
INSPECTION REPORT ACTIVITIES
YANKEE NUCLEAR POWER STATION
Inspection Inspection Areas
Report No. Hours Inspected
85-04- 110 Routine Resident
85-05 160 Post-Accident Sampling System
85-06 30 Startup Physics Testing
85-07 114 Routine Resident
85-08 163 Emergency Preparedness Exercise
F5-09 72 Radiation Protection Prorrr,
'
85-10 40 Radiological Environmental Monitoring Program
85-11 141 Routine Resident
85-12 135 Generic Letter 83-28, Salem-ATWS Concerns
85-13 34 Safe Shutdown System Building Construction
85-14 181 Routine Resident
85-15 137 Routine Resident
85-16 7. Radiation Protection Program
85-17 31 Physical Security
85-18 156 Routine Resident
85-19 12 Licensing Review (on-site) of P.C. 186
85-20 37 Maintenance Program
85-21 27 Nonradiological Chemistry Program
85-22 --
Operator Examination
85-23 74 Radiation Protection Program
85-24 126 Routine Resident
l
f
, . - - - . - - - -e. , , . - - - c. < -
-, . --.. ., - - . , -,,
.
i :o
e
- f. T-6-2
Inspection Inspection Areas
Report No. Hours Inspected
85-25 135 Appendix R
86-01 42 Refueling and Startup Testing
86-02 99 Routine Resident
86-03 18 Licensed Operator Training Program
86-04 37 Radioactive Waste Management
86-05 196 Routine Resident
86-06 83 Emergency Preparedness Exercise
66-07 --
Operator Examination
86-08 200 Routine Resident
86-09 49 Reactor Coolant System Vents-Special Inspection
86-10 19 Emergency Preparedness
86-11 32 Surveillance Testing and Calibration Control Program
86-12 74 Radiation Protection Program
86-13 --
Not Used
86-14 35 Physical Security
86-15 --
Not Used
86-16 58 Radiological and Chemical Confirmatory Measurements
, 86-17 124 Operational QA Effectiveness
,
l
- _ _ _ . - _ _ .
. . . _ _
r
t" 'h
I
c
TABLE 7
REACTOR TRIPS AND UNPLANNED SHUTDOWNS
YANKEE NUCLEAR POWER STATION
Power Proximate Root
Date Level Cause Cause
12/9/85 <2% Unit Trip Personnel error maintenance. Contractor
employee inadvertenly bumped an RPS relay
while cleaning within the control room's
main control board.
12/28/85 <2% Unit Trip Personnel error - maintenance and opera-
tions. False high startup rate trip caused
when maintenance personnel performed a
functional test in conjunction with
troubleshooting. The root cause was per-
sonnel failure to recognize performance
of the test while at <15% power will resuit
in a plant scram.
6/1/86 100% Unit Trip Equipment failure - random cause. Loss
of both heater drain pumps resulted in a
low steam generator level reactor scram.
The pumps were damaged in a lightning storm.
6/18/86 100% Shutdown Equipment failure - mechanical defect
(under review). Shutdown to repair a
leaking weld in a coupling on the No. 2
steam gerator's blowdown line.
10/4/86 100% Unit Trip Equipment failure - random cause. Low
control air pressure condition caused by
a component failure subsequently resulted
in a plant scram on low steam generator
levels. A contributing cause was inade-
quacies in guidance in a recovery procedure
involving feedwater control valve lock-up.
10/4/86 <2%' Unit Trip Personnel error - operations. Control
room operator error resulted in RPS trip
, when the non-return valve trip / reset switch
'
was inadvertantly placed in the trip posi-
tion during a plant startup.
I
. . . , _ - - . _ . . . _ . , _
_ _ _ - . .-
( 1
c: :o
I
c
FIGURE 1
NUMBER OF DAYS SHUT DOWN
YANKEE NUCLEAR POWER STATION
I
February, 85 l
l
March, 85 l
l
April, 85 l
l
May, 85 l
l
June, 85 l
l
July, 85 l
l
August, 85 l
l
September, 85 l
I
October, 85 I i 13 Days Shut Down Cycle XVII-XVIII Refueling Outage
i
November, 85 1 30 Days Shut Down l Cycle XVII-XVIII Refueling Outage
i
December, 85 l l 9 Days Shut Down Cycle XVII-XVIII Refueling Outage
l
January, 86 l
1
February, 86 l
l
March, 86 l
l
April, 86 l
l
l May, 86 l
1
June, 86 I i 13 Days Shut Down
1_
July, 86 l_I 1 Day Shutdown
i
August, 86 l
l
September, 86 l
1_
October, 86 1_l I Day Shutdown
. ., . . . . . ., __ _ - ._, -