IR 05000213/1985098

SALP Rept 50-213/85-98 for Mar 1985 - Feb 1986.Overall Performance Acceptable

ML20198H209
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	02/28/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20198H191	List: ML20198H187 ML20198H209
References
50-213-85-98, NUDOCS 8605300157
Download: ML20198H209 (76)

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t.NCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE JERFORMANCE INSPECTION REPORT 50-213/8f.-98 CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK NUCLEAR POWER PLANT ASSESSMENT PERIOD: MARCH 1, 1985 - FEBRUARY 28, 1986 BOARD MEETING DATE: APRIL 24, 1986

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SUMMARY OF RESULTS Facility Performance CATEGORY LAST CATEGORY THIS PERIOD (9/1/83- PERIOD (3/1/85- RECENT FUNCTIONAL AREA 2/28/85) 2/28/86) TREND Plant Operations 1 1 Consistent Radiological Controls 2 2 Consistent Maintenance & Modifications # 1 2 Consistent Surveillance 2 2 Consistent Emergency Preparedness 2 2 Consistent Security & Safeguards 1 1 Consistent Refueling /0utage Management 1 No Basis j Assurance of Quality 2 2 Consistent Training and Qualification ## 2 Consistent Effectiveness 10. Licensing Activities 1 2 Declining

1. Modifications were previously addressed under Assurance of Qualit ## Not previously addressed as a separate are Overall Facility Evaluation I

In general, the licensee aggressively and thoroughly resolves matters with immediate operational or safety significance. The Security area was particularly noteworthy in that, despite a long history of excellent performance, there was a continuing aggressive effort to improve perform-ance. In other areas, however, there have been recurrent problems with procedure adherence, personnel errors, attention to detail, and admini-stration of routine activities. Examples include numerous modification control errors, significant ALARA flaws, and untimely submittals of modification packages to the Plant.0perations Review Committee. The result has been satisfactory but generally lower SALP ratings. To im-prove overall performance, more effective management controls at all levels are needed to assure that repetitive problems are identified and corrected and that there is proper preplanning of work activities. The management attention to these activities that is evidenced in the Secur-ity area is typical of that needed in other areas to avoid a further decline in performanc . .

IV. PERFORMANCE ANALYSIS

Plant Operations (425 hours0.00492 days <br />0.118 hours <br />7.027116e-4 weeks <br />1.617125e-4 months <br />, 24%) Analysis This functional area encompasses operational activities, plant housekeeping and fire protection, operator and staff performance, review committee activities, event reporting, and corrective action The previous SALP rated plant operations as Category 1. In the last SALP, strengths were noted in the quality of operator performance, plant coordination of day-to-day evolutions, review committee ef-fectiveness, and problem identification programs. Weaknesses were noted in the operator requalification program, procedure adequacy and compliance, and the scope and timeliness of corrective actions for certain self-identified problem During the current SALP period, there were two region-based inspec-tions of this area. Plant operations were observed by the resident inspectors throughout the perio Operators carefully observed plant systems and conditions, and promptly identified developing problems to management. Through use of the computer-enhanced maintenance reporting and tagging system, operators efficiently tracked maintenance actions and implemented system tagging. Corrective actions were generally well planned and ready for prompt implementation. This team effort contributed to there being no error-related plant shutdowns during the perio The overall result was continuing effectiveness of the onsite team of management, operators and support staf Control room operators were evaluated as having a professional ap-proach to plant operations. Although the age and small size of the control room were noted as potential negative influences, plant operators were observed to limit access to control panel areas, maintain adequate control over extraneous noise, and perform their duties effectively using readily available procedures, drawings, and administrative aides. Also, the licensee instituted a dress code for plant operator Noteworthy housekeeping improvements were observed in the auxiliary feedwater room and in the recovery of several contaminated areas of the auxiliary building. However, limited permanent and temporary storage space onsite forces the licensee staff to accept occasional clutter, and wet or soiled conditions. Such was the case for the auxiliary water treatment facility in the turbine hall and contami-nated material storage in the spent fuel building lower level. Upon licensee identification of these degrading conditions, corrective action was implemented. A general upgrade of site facilities is in progres Improved facilities for outage personnel have been

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provide Construction of new facilities is underway, primarily for radioactive material processing and storage. Such efforts, along with a continued licensee initiative to recover and upgrade remote areas such as the waste treatment building, RHR pit, and pipe enclosures should result in further improvement of plant housekeepin <

The timeliness and thoroughness of corrective actions for some problems identified in Plant Information Reports (PIRs) were iden-tified in the previous SALP period as weaknesses. The licensee changed the PIR program to improve causal analysis and corrective

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actions. Staffing increases were approved, in part to help reduce the PIR backlog. Improvements were observed in the quality of PIR reviews, and the PIR backlog was reduced. Many PIRs are, however, returned for further corrective action and some (particularly those related to fire barriers) involve recurrent problems. Other recur- ,

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rent problems include late procedure reviews and self-identified radiological procedure violations. Licensee efforts to decrease

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personnel errors and procedure-related problems have been partially l

effective. The frequency of error-related operational events de-clined, but the frequency of fire protection door control problems rose (see LER trends cited in Section V). Such recurrent problems indicate lack of effective management involvement and follow through.

. An evaluation of LER quality, using a sample of 10 LERs issued dur-ing this assessment period, was made. In general, the licensee's

LERs were found to be satisfactory. The principal concerns iden-tified were inconsistencies in subsection content between the ,

selected LERs, incomplete corrective action plans in some LERs, and not addressing the possible consequences of events under different initial conditions. For instance, LER 85-29 reported a potential failure dealing with loss of the semi-vital motor control center (MCC-5). The LER safety assessment concentrated on the plant indi-cations and operator actions to mitigate the event but did not ad-dress the more severe potential consequence Overall, however,

the quality of LERs has improved.

i Licensee onsite and offsite review committees have been effective during this period. The Plant Operations Review Committee has a large workload including response to operational events, plant pro-cedures, modifications, license changes and corrective actions for Plant Information Reports. The PORC accomplishes detailed and ef-fective reviews. PORC members are frank and inquisitive, and man-agement is supportive of the open and detailed review conducted by this committee. Although the quality of PORC meeting minutes has improved, they do not always reflect the details of PORC discussions and often leave questions unanswered in the reader's mind. A large i number of multiple PORC reviews on individual topics and the length

! of PORC deliberations on certain reactive review efforts suggest weaknesses in the staff work performed prior to PORC submittal.

l This unnecessarily involves PORC in details and can adversely affect

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the PORC's focus on the overall safety impact of the issue under

, consideration. (A weakness related to the drain on plant supervi-sory activities created by lengthy PORC deliberations is described in the Refueling and Outage Management Section of this report.)

l One PORC related violation was identified: PORC concurred in the removal of Technical Specification required smoke detectors incident to a design change. This error was recognized by the licensee prior to implementation of the change.

l The offsite review committee (NRB) contributes effectively to safe l plant operation. Of particular note were the high quality and timely NRB reviews of plant modifications and the assessment tech-l niques used by NRB to evaluate staff performance annually. In ad-dition to routine audits, the NRB collects, trends and assesses performance indicators such as audit and inspection report findings, r event reports, and nonconformance reports to measure staff perform-anc A weakness identified by NRC concerned NRB involvement in assuring the quality of audits conducted by the quality assurance department. NRB evaluation of audit scope, content, and findings was noted as an area for improvement.

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No new operator license examinations were given during this period;

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no NRC assessment of that aspect was mad During this period, the licensee made progress on the upgrade program for licensed operator requalification. The upgrade and independent evaluation of certain licensed operators continued throughout the period. In January 1986, the licensee began a revised requalification program which integrates training into the operator shift rotation schedule. NRC review of

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l the preparations for implementation of this program identified no l

problem The program has improved the timeliness of operator

! feedback on procedural and hardware changes, and significantly in-

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creases the training time to allow more discussion of the subjects l

covere Three violations were identified in the Plant Operations area. None of these was a major violation. However, one of the three was for

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' failure to adhere to procedures, which is a continuing problem noted in the previous SALP.

l In summary, although the licensee has improved each area of weakness

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cited in the previous analysis, management attention is needed to l

further irrprove procedural compliance, LER quality, PORC efficiency, I and corrective action effectiveness. Overall, the rating in plant operations is weighted toward the operating staff's quality perform-ance in several operationally significant aspects of the analysi .

-2. Conclusion Rating: Category Trend: Consisten . Board Recommendation:

Licensee: Non NRC: Non l

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B. Radiological Controls (393 hours0.00455 days <br />0.109 hours <br />6.498016e-4 weeks <br />1.495365e-4 months <br />, 22%) Analysis The previous SALP rated this area as Category 2. Radiation control

. policy, procedures, and staffing were found to be program strengths, while weaknesses were noted in management control and effectiveness

'in monitoring program compliance, in ALARA controls at the job supervisor level, and in quality assurance (QA) for the radioactive material transportation program. During the previous assessment period,.several violations were cited relating to a potential per-sonnel overexposure during maintenance, and to QA problems in the radwaste are A recent appraisal of the Health Physics program at the site found that the overall program is a good one. Weaknesses continued in the ALARA program and in radwaste Q Program procedures are com-prehensive and generally well written. The Health Physics supervi-sory staff is adequately experienced and dedicated, and shows in-itiative in proposing and instituting measures to improve perform-ance. However, the recurrence of many minor, self-identified radio-logical control procedure violations is indicative of ineffective corrective actions in this area. These incidents do not appear to indicate any fundamental programmatic weakness, yet more extensive training and accountability of workers and technicians is warrante The licensee has shown improvement in some aspects of radiological controls. This improvement was noted in the methods used in con-tamination control and radiological surveillance during the 1986 outag These methods included innovative and effective techniques such as subdivision of the radiation controls areas into autonomous zones, and the use of closed-circuit television to monitor critical areas. These methods were also effective in controlling the flow of work and in keeping work areas generally clean and orderl Other improvements include selection and qualification of HP person-nel and attention to the experience and capabilities of the person-nel placed in charge of the work zone The Radiological Incident Reporting system instituted by the licen-see is working. Although management response to incidents identi-fled by the system was initially inadequate, recently instituted procedural changes appear to have led to improvement in this are These improvements include increased management attention to iden-tify root causes and measures designed to minimize the chance of recurrence of similar incidents. One example of lack of such re-sponse is an incident involving compacting of a' highly radioactive drum in a manner that violated plant procedures and resulted in internal and external exposure of workers, and extensive contamina-tion of the work area. This event displays a weakness in job pre-planning and adherence to good health physics practices. Management

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response in that case was insufficient. Another incident identified by the licensee is more recent and involved the installation of hoses to a high integrity resin container for de-watering. In that incident, the couplings on the container and hook-up hoses did not matc Careful planning could have prevented this problem. Fur-thermore, the worker decided to remain in the high radiation area while investigating the problem, rather than exiting to seek assist-ance or to decide on the appropriate course of action. As a result, the worker exceeded his assigned exposure by a factor of about tw Management response to this incident was more prompt and more com-prehensive than in the case of the first example described. Inci-dents'such as those cited above are limited but recurrent instances of poor judgement, mainly on the part of the Health Physics techni-cians and the workers involve Weakness in the ALARA program was noted in previous SALPs and con-tinues to be a problem. Emphasis at the supervisory and technician levels appears to focus mainly on keeping exposures within estab-lished limits rather than minimizing them. The same emphasis ap-y pears to exist at management levels up through senior site and cor-

. porate management. Indications of this tendency are provided by incidents such as those described above. A common factor-in most of these incidents appears to be the desire to "get the job done" without sufficient regard for the radiological consequences. An-other indication of insufficient ALARA emphasis is the man-rem ex-posure record of the station. This record shows that the man-rem exposures have been consistently much higher than those of the in-dustry since at least 1979. These exposures have also been consis-tently higher than the licensee's own projections, particularly for outage-related wor Part of the reason for this relatively poor exposure performance is ascribed to conditions peculiar to the sta-tion. The reactor system design is old and does not provide as much component shielding as is found in more modern stations, thus lead-ing to relatively high radiation fields in the work area However, a recent NRC appraisal of the ALARA program indicated that this provides only a partial explanation for the poor ALARA performanc The appraisal revealed serious weaknesses in the ALARA program at all levels of management. There are extensive and well written ALARA procedures and policy statements, both at the station level and the corporate level. However, the ALARA program is essentially a paper program, with poor implementation and oversight, particularly by-corporate management. Pre-job planning is frequently incomplete and flawed, leading to unforeseen radiation exposures in attempts to take remedial actions. Pre-job planning is also frequently ill-timed, leading to inadequate lead time for review of these estimates by station personnel. Short lead times also allow insufficient time to consider all the ALARA measures that may be taken to reduce ex-posures. Furthermore, most high exposure outage jobs are performed by non-station personnel, such as contractors, and control of the number of people these contractors use and the man-hours expended

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in radiological areas appears to be poo There is extensive effort expended in documenting job performance, analyzing the reasons for exceeding goals, and proposing measures to improve performance.

1- However, such efforts appear to receive inadequate management sup-por Furthermore, most of the analyses do not clearly isolate and identify the root causes of the problem. Finally, the most dis-

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turbing aspect of this problem is that management action to take effective corrective measures was not apparen With regard to Effluent Control and Environmental monitoring, in-spections indicated that, while procedures are generally adequate and are followed, several minor examples of deficient procedures and instances of non-adherence to procedures were identified.

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reports, calibration procedures for meteorological sensors were not

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laboratory. Additionally, some records were found to be incomplete, and documentation was sometimes insufficient to determine that dis-crepant data had been reviewed. All of these findings had minor consequences but indicate weaknesses in the staff's implementation of QA program requirement In areas directly affecting effluent releases, such as radioactive releases, procedures and documentation were complete and adequate for controlling and monitoring effluents, and the QA program was sufficient to assure that all requirements and specifications were met.

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The implementation of the Radioactive Waste Handling Program (RWHP)

is generally adequate with regard to staffing and training of the station' staff responsible for the mechanics of the program. In these areas, positions are well defined and identified relative to responsibilities and authorities; and the training and qualification program makes a positive contribution to performance of work with few personnel errors. Some procedures were found to have weaknesses, but these were promptly addressed by the license The RWHP is also vulnerable relative to the assurance of quality.

In this area, quality assurance audits were found to lack sufficient

' thoroughness; quality assurance personnel were not sufficiently knowledgeable of shipping and radioactive waste disposal require-ments; and~the specifications of 10 CFR 61 were not fully imple-mer.ted by the quality assurance progra As a result, errors on the part of the radwaste handling department were not likely to be caught by QA review of shipment activities. For example, Iron-55 has been identified in the facility waste streams, but it was fre-quently omitted from consideration in waste manifests and shipping paper The repetitive omissions resulted in significant under-estimation of activities in radwaste shipments, and were also in-dicative of a breakdown in the responsibilities for assurance of l

quality in radwaste shipments.

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In summary, the licensee has improved some health physics practices, including better control and assignment of HP technicians, zone coverage within the radiologically controlled areas, and followup on self-identified radiation protection discrepancies. However, continuing problers in tha radwaste transportation and ALARA pro-grams were not ,as significant weaknesses in this area. Continued increases in workload, contractor personnel onsite and personnel-exposures during outages have emphasized the continuing poor ALARA practices. Althoegh improvements in some aspects of this functional area were noted, the overall assessment was that radiological con-trols performance nad declined since the previous SAL . Conclusion:

Rating: Category Trend: Consisten ,

3. Board Recommendation:

Licensee: Conduct a comprehensive management review of the ALARA program and implement the changes necessary to achieve an ef fective progra NRC: Continue normal inspection efforts eith special emphasis *

on the implementation of the ALARA progra *

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C. Maintenance and Modifications (314 hours0.00363 days <br />0.0872 hours <br />5.191799e-4 weeks <br />1.19477e-4 months <br />, 18%) Analysis The previous SALP rated maintenance as Category In a separate

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analysis area, modification activities were rated as Category Documentation and trending of maintenance activities and the backlog of plant maintenance work were previously noted as areas needing improvement, and significant programmatic deficiencies in the design change control area had resulted in escalated enforcement actio During the current assessment period, one region-based inspection reviewed the progress of NRC ordered design change control improve-ments. Two special inspections reviewed modification related prob-lems in the auxiliary feedwater and fire detection systems, and the resident inspectors reviewed maintenance activities throughout the perio The licensee has a strong preventive and corrective maintenance program. Automated tracking and scheduling of maintenance assists in controlling the large nember of preventive maintenance (PM) tasks performe Comprehensive and frequent program review and update reflects management commitment to the PM program and has resulted in a high degree of equipment reliability. One notable exception during this period was the performance of the main feedwater syste Several plant trips and shutdowns were directly related to main feedwater system problems and the inability to isolate portions of the system due to isolation valve leakage. Had the feedwater system isolation valves been repaired during the first system outage on August 18, 1985, subsequent plant shutdowns for feedwater system repairs would have been avoided. The licensee recognized the im-portance of feedwater system reliability as evidenced by the major overhaul during the 1986 refueling outag The instrumentation and control (I&C) and maintenance departments are manned by competent and motivated personnel. Although a backlog of maintenance activities remains, it is managed effectively by prioritization and overtime, and the licensee has implemented or approved new positions to improve the effectiveness of this organi-zatio The licensee is upgrading staff technical training, including general system and technical speciality training. Improved I&C technician training in the Technical Specification operability as-pects of maintenance and testing activities was implemented as a result of an event in which a variable low pressure scram channel of the reactor protection system was rendered inoperable during maintenance. Based on generally high quality performance on other

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maintenance activities, this maintenance error was judged to be an isolated case.

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During refueling outages, the plant staff is augmented by contractor and utility workers in order to accomplish the large number of maintenance activities. The licensee addresses the increased staf f size by upgrading certain technicians to supervisory position Repair activities during the 1986 outage were observed tc be pro-perly conducted with the exception that a high pressure safety injec- ,

tion pump failed during post-maintenance testing. The pump was not reassembled properly because of personnel error and inadequate pro-cedural update af ter pump modifications. Significant pamp rework was required as a result. Also, several contractor performed vaive repairs were repeated several times in order to achieve satisfactory results. These events appeared to be isolated cases in an otherwise effective progra Documentation of maintenance activities continued to be a weakness during this period. Poor documentation of rep & irs pievented accurate determination of the cause of failure and contributed to the late or incomplete submittal of several Licensee Event Reports (LERs 85-02, 05, 10). Also, a violation involving several instances of procedural noncompliance indicated inattention to detail in repair activity control and recording. No equipment operability problems were identified in these instance Three violations were identified in this area. None of these was major. While multiple instances of modification control problems were noted in one violation, these instances were not relate As a result of previously identified weaknesses and hRC enforcement action, the licensee implemented major changes to the modification control program. NRC review of modifications made during this SALP period have identified significant improvement in the documentation and control of design changes. Nevertheless, continuing modifica-tion control errors unnecessarily challenge the defense in depth concept incorporated in the modification process. NRC identified discrepancies with testing, procedure updates, material issue, technical specification changes, and documentation of field changes for recent modifications point out the need for further improvement in the implementation of plant modifications. In one exarrple, ap-proved rotests specified after emergency diesel generator air system modifications would not have verified all aspects of system opera-tio In summary, maintenance programs are ef fective overall and improve-trent has been noted in the modification control program. However, maintenance errors involving procedural compliance were identifie The backlog in and inadequate documentation of maintenance activi-ties continued to be weaknesses. Also, problems with the implemen-tation of modifications were note . .

2. Conclusion Rating: Category Trend: Consisten . Recommendations:

Licensee: Provide effective management attention to the new modifi-cation control process to assure that it is understood and properly implemented at all level NRC: None.

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D. Surveillance (230 hours0.00266 days <br />0.0639 hours <br />3.80291e-4 weeks <br />8.7515e-5 months <br />, 13%) Analysis Surveillance was rated Category 2 during the last SALP. Inadequate procedures and technician performance resulted in three events, one of which received a mitigated escalated enforcement action. In ad-dition, weaknesses in the scheduling of surveillances and resolution of containment leakrate. testing (CLRT) deficiencies were note Surveillance was observed by resident inspectors throughout this SALP period. The licensee continued the long term surveillance up-grade program initiated during the previous period. Procedural up-grades and technician training were successful as evidenced by no surveillance error-related events or violations being identifie Several nuclear instrument problems were identified early in this perio Accelerated testing, troubleshooting and repairs were suc-cessful in eliminating the inspector discussions with licensee technicians found them to be competent, knowledgeable of procedures, and conscientious in the implementation and evaluation of surveillance result The licensee's long term review of surveillance procedure adequacy is ongoing and scheduled for completion in mid-1986. Inadequacies are still being identified as exemplified by the licensee's failure to properly test 27 of 80 containment electrical penetrations be-cause the test procedure listed an incorrect valve lineup. In ad-dition, several reported missed surveillances (see LER chain in Section V of this report) occurred because procedures did not com-prehensively cover all Technical Specification requirements. Fur-ther, there was minimal involvement of Quality Assurance in the technical adequacy of surveillance procedures. In addition, as noted in Section V, 3 LERs addressed missed fire protection sur-veillance tests due to personnel error. One other problem involved the licensee's failure to implement all aspects of a post-accident systems integrity inspection commitment (LER 85-30). Upon NRC identification of this problem, the licensee fully implemented the commitmen During this period, an auxiliary feedwater initiation test failure pointed out the need for more frequent exercise / testing of sticking solenoid actuation valves as an action to prevent recurrence. Be-cause of licensee concerns about the acceptability of on-line test-ing of this system, it took over ten months to develop and implement the appropriate test procedure. Then, when the test was run, a similar initiation failure occurred. Weekly testing thereafter identified no further component failure .

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ness to previous NRC inspection findinge,. The licensee made efforts

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to formalize CLRT activities among its units and centralize the CLRT

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program under a governing corporate level procedure. NRC observa-i tion of CLRT activities shortly after the end of this assessment period identified improved test performance. With regard to open

inspection findings, the licensee's approach was not fully respon-sive. The licensee response to the previous SALP indicated that the open inspection items would be addressed in the last quarter of 198 The licensee position submitted on December 23, 1985, restated previous positions which did not resolve the existing dis-crepancies with 10 CFR 50 Appendix The licensee has a basically sound surveillance pregram which pro-  !

perly performs a large number of tests in a timely manner without challenging safety systems. There are, however, continuing problems with surveillance procedures, QA of surveillance activities, imple-mentation of commitments, and timeliness of corrective action . Conclusion Rating: Category Trend: Consisten . Board Recommendation Licensce: Complete the ongoing surveillance upgrade progra NRC Non ,

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E. Emergency Preparedness (166 hours0.00192 days <br />0.0461 hours <br />2.744709e-4 weeks <br />6.3163e-5 months <br />, 9%) Analysis The previous SALP rated this area as Category There were three j significant deficiencies which were identified during the full-scale )

emergency exercise in May 1984. These deficiencies, involving in-formation flow between the Control Room and Technical Support Centers (TSC), delayed declaration of Emergency Action Levels and demonstra- '

tion of technical support functions at the TSC, were addressed by a Confirmatory Action letter (CAL 84-10) on June 5, 198 )

During this period, one NRC inspection was conducted to review changes made to the Emergency Preparedness Program and to observe the March 30, 1985 annual full-scale emergency exercise. It war found that the corrective actions described in CAL 84-10 had been satisfactorily completed. During the 1985 exercise, the licensee demonstrated the new TSC which had been established within the Emergency Operations Center (EOF). Technical support activities were adequately implemented except that the development of approved emergency procedures was not demorstrated. There were no majcr de-ficiencies noted in the 1985 exercne; however, twenty minor defi-ciencies were identified, and several of these problems were recur- ;

rent items from the previous exercis The licensee's onsite emergency preparedness staff consists of one full time Emergency Planning Coordinator who is provided with emer-gency preparedness activitiet support by corporate and contractor personnel. NRC observation of emergency exercise activities pon-cluded that personnel were appropriately trained and qualified to perform their emergency functions. The licensee's performance demonstrated that they could implement their Emergency Plan and its implementing procedures adequatel The licensee's multiple locations for command and <:ontrol and tech-nical support functions provide independent assessment of emergency activities and backup technical support. However, redundant acti-vities in these distant centers are often confused by delayed or incorrect data, resulting in improper recomniendations or unnecessary requests for clarification, lhis vulnerability of errergency acti-vities to good real-time data comunication emphasizes the need for a hard-wired plant data transmission system. In the interim, the licensee has a dedicated data coordinator who responds to the emer-gency response team paging system and manually inputs plant data to the transmission network (NESS) available at the emergency oper-ating centers. Telecopiers are available to back up the NESS syste Also, the State and utility emergency plans incorporate automatic protective action recommendations (PARS) with the declaration of each Emergency Action Level (EAL). This makes event classification and EAL declaration particularly important, and different because

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f "g the class]fication may' carry with it inappropriate sheltering or i

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evacuation recommendation Resolution of these discrepancies re-

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quires coordination at all emergency,' centers, which could either delay event classification or result in overly conservative PAR , s

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No' actual events during this assessment period required the imple-mentation of the Emergency Progra Inspector observation of oper-ational occurrences such as plant trips and a February 1986 dropped 2 .

fuel' element event identified appropriate operator response, prompt

'l management support, and safe and conservatively planned recovery

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activitie In pEeparation for Hurricane Gloria in September 1985, tne licensee chose to fully man the emergency facilities, with pro-visions for extended implementa, tion of the emergency organizatio . The< storm passed through the area without any significant damage to plant systems. No deficiencies in emergency plan activities were

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noted by onsite N,RC observer In summary, thallicensee corrected some of the previously noted de-ficiencies and satisfactorily implemented the site emergency plan during the' annual exercise. No emergency planning weaknesses were identified during operational occurrence _ Conclusion-Rating: Category Trend: Consisten . Board Recommendation Licensee: Complete the installation of the hard-wired data transmis-sion system, and review the effectiveness of automatic protective action recommendation NRC: Non ,

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F. Security and Safeguards (79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br />, 5%) Analysis Previous SALP evaluations have identified consistently high perform-ance in this area. During this rating period, one routine physical security inspection and one routine material control and accounting inspection were performed by region-based inspectors. Routine resident inspections continued throughout the assessment perio No violations were identifie Management is involved in the physical security program and continues to be supportive. Resource planning continues to consider needs for improving quality by self-inspection techniques and ensuring comprehensive corporate audits. These efforts, combined with a positive management approach and clear, concise procedural controls, contributed to error-free performance by the security organizatio As a result, during three consecutive rating periods, no violations of NRC requirements have been identified. The decision making pro-cess for the security program, by management and supervisory per-sonnel, is effectiv Records are well maintained and availabl Security improvements noted during this rating period included the purchase of a new vehicle to enhance site perimeter patrols, in-stallation of new protected area fencing, paving a perimeter access road, purchase of additional security force shelters, completion of renovation of the interior of the security building, development of a slide presentation of security program features for use as a training /information aid, and the expansion cf the drill program in support of the Safeguards Contingency Plan. A total of 180 drills were carried out by the security organization during CY 198 These improvements demonstrate the licensee's continuing support of the progra As a new initiative, the licennee is utilizing the NRC's Regulatory Effectiveness Review Program generic findings from other licensed sites to improve the effectiveness of its security progra Im-provements to barriers, detection aids, and duress procedures have been implemented as a resul The licensee maintains dedicated technicians for support of security systems and equipment. The effectiveness of this is evidenced by the fact that only one security event during this period involved a hardware problem (four hardware-related problems were reported during the previous period). The problem caused the computer to be off-line for only 21 minutes, during which time repairs were effected. Compensatory measures were effectively implemented and the licensee's event report to the NRC was timely and comprehensiv _ _ . . - ..

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Staffing of both proprietary and contract security positions was effective. Sufficient, well-trained and qualified supervisors and

, security officers were assigned during the period. Morale and pro-fessional competence were observed to be hig Also noteworthy was the ability of security force members at all levels of the organi-zation to describe their duties and responsibilities, in detail and ,

without hesitation. This was done with enthusiasm and prid The licensee's consitment to continuously improve professional skills via the use of drills and job knowledge critiques strengthens the performance capability of the organization. Additionally, the lic-ensee provides funds for management /sepervisory attendance at pro-fessional seminars and training courses.

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There were two Security Plan changes submitted in accordance with 10 CFR 50.54(p) during this rating period. The revisions were re- *

viewed and considered acceptable. The changes were adequately sum-marized and appropriately marked on revised pages for clarit With regard to material control and accounting practices, the lic-ensee was in compliance with NRC requirement Procedures and prac-tices were adequate for the control of special nuclear materia Records and reports were complete, well-maintained and available.

! In summary, security and safeguards inspections by resident inspec- ;

tors and region-based specialists have identified exemplary program Security continues to be a noteworthy licensee strength, because of managocent support for program improvements, aggressive self evaluation, and prompt and effective preventive / corrective action . Conclusion Rating: Category Trend: ConsistenL

. Board Recommendation Licensce: Non I NRC: Non .

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G. Refueling and Outage Management (151 hours0.00175 days <br />0.0419 hours <br />2.496693e-4 weeks <br />5.74555e-5 months <br />, 9%) Analysis Previous licensee performance in refueling and outage activities

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has been Category 1. During this period, a planned 8-week refueling outage began on January 4, 198 By the end of the assessment period, delays-in installation of a new permanent reactor cavity seal, problems with decontamination of steam generator primary channel heads, and recovery of a fuel assembly dropped during re-fueling operations had extended the outage by approximately 25 day Refueling and outage activities were reviewed by the resident in-spectors and a region-based project inspector, including outage preparations and coordination, refueling operations, and recovery after the February 26, 1986 dropped fuel element even The licensee maintained 24-hour per day management level coordina-tors to follow outage activities and bring problems to management attention. Also, outage status meetings were held twice a day with

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all departments and critical jobs represented. The licensee's com-puter-based outage planning program was effective in tracking the details of job status, Strong licensee commitment to the mainten-ance and updating of this program was evident throughout the outag Consequently, it was readily recognized which critical path activi-ties were experiencing problems such that additional attention could

, be focused in that area. Under this closer scrutiny, the allotted time for some jobs was found to be incorrect. In particular, under-estimation of work package preparation, establishment of plant con-ditions, and coordination and documentation of system turnover re-quirements reflected inadequate pre planning of outage activitie As a result of deadlines and commitments, several plant modifica-tions were required to be implemented during this outage. These modifications included reactor vessel level indication, various Appendix R improvements, seismic support upgrades, and equipment environmental qualification replacements. Although the licensee has guidelines which require early submittal of plant design change packages, only 8 of 32 modifications were ready for implementation at the start of the outag In addition, the need for twenty other '

modifications was identified during the outage. Consequently, a major effort involving considerable engineering and supervisory effort was necessary, especially during the first month of the out-age, to assure the appropriateness of pre-approval release of modi-fication work packages and in the review and approval of the modi-fications as they became ready.

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. -. .,.,.r . . , . . . - , . . - . c .. - ,,y,, , . - . p --.4-, . ,,+.-

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, Although no safety-significant discrepancies in design change imple-mentation were noted as of the end of the assessment period, the high volume of modifications implemented prior to completion of the final design approval taxed those responsible for quality implemen-tation of field installations.

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Another negative aspect of the large expenditure of engineering and supervisory talents in design change package preparation and review, noted in Section C, was the diversion of these talents from their -

normal line organizational functions during the outage. Better pre-job planning, supervision, and coordination may have reduced or al-leviated such problems as were experienced with the steam generator (SG) TV camera setup, SG decontamination, and high pressure safety injection pump repair jobs. In addition, more direct management /

supervisory effort to reduce job-related radiation exposure might have reduced or eliminated the margin by which many outage jobs exceeded the man-rem exposure goals as detailed in Section The dropped fuel element on February 26, 1986 created a significant perturbation of outage activities. Recovery actions including dropped element inspection and recovery, core component damage evaluation and repairs, and re-analysis of the core reload pattern excluding the damaged elements were promptly integrated into the outage schedule. The licensee's cautious and deliberate approach to recovery action reflected a strong commitment to' plant safety at the expense of the outage schedule. However, the coordination of preparations for recovery actions such as production and testing of lift rigs could have been improved. In two instances, the re-covery efforts were delayed because lift rigs had not been prepared in parallel with procedure preparation. Overall, however, through-out the recovery process, management priorities were properly di-rected toward assuring the safety and quality of the recovery pro-cedures and training, and the alertness of the recovery tea In summary, although outage activities were carefully scheduled and tracked, notable inadequacies in job pre planning and coordination were identified. Extraordinary supervisory efforts were required to assure proper implementation of safety-related system modifica-tions. Those efforts challenged the level of quality assurance normally provided by supervisory oversigh . Conclusion Rating: Category Trend: No Basi . Board Recommendations Licensee: Commit additional attention to the pre planning of outage activities, especially design change NRC: Non . .. . _ __- _ - _ _ _ _ _ _ _ . .- - - ,

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26 Assurance of Quality Analysis During this assessment 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 area Licensee management emphasizes proper performance on the first try and that quality is each individual's job. Therefore, the QA or-ganization is not looked upon as the central control for quality; line management i However, for those individual errors which are not picked up by supervisory oversight, management has other tools to assure quality such as onsite (PORC) and offsite (NRB) review committees, quality control (QC) inspections, and QA audits. The

. success of this program is evident in the high quality performance of individuals noted in selected aspects of the operations, main-tenance, and security areas. On the other hand, individual errors which were not identified or corrected by quality assurance activi-ties were also noted in the radiological controls, surveillance, and modification area PORC and NRB were noted to be effective in their assigned' functions; however, these functions were notably reactive, and were not effec-tive in preventing the recurrence of certain procedural and modifi-cation-related problems. QA/QC coverage of backfit and Betterment Engineering projects was evident in the number of QA/QC findings required to be dispositioned during the 1986 outage. QC coverage of maintenance was not as extensive. Licensee improvement in QA/QC involvement in operational activities in progress and in the rad-waste transportation area was observed. However, NRC identification of ongoing problems with personnel errors, procedural adequacy, surveillance scheduling, and radwaste processing and shipment indi-cate a need for more effective self-evaluation. It was also noted in several areas that the corrective actions for NRC and self-iden-tified problems were not always effective in preventing recurrenc Control of fire barriers, missed surveillances, and inadequate ALARA controls were example QA audited activities in accordance with department schedule NRC review of audit reports found them to be generally effective. With the exception of one environmental audit program which omitted re-quired document review in the audit scope, no audit program defi-ciencies were identified. Nonetheless, the NRC noted that improve-ment in management involvement in audit scope, findings, and cor-rective action promptness was needed to improve the quality and effectiveness of the self-evaluation proces _

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In summary, the licensee performs many activities very well, pri-marily as a result of good individual and supervisory efforts. The review committees were effective from a reactive perspective and, to the extent employed, QA audits and inspections were satisfactor However, many minor problems were identified and several of these continued throughout the assessment period without effective cor-rective action. Management involvement in preventing problems, and assuring quality in all activities was noted as an area for improve-men . Conclusion

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Rating: Category Trend: Consistent 3. Board Recommendations Licensee: Reevaluate the effectiveness of systems for self-identification and resolution of problem NRC: Non _ ,. - .

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I. Training and Qualification Effectiveness

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 are .The various aspects of this functional area have been 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 adequac The discussion below addresses three principal areas: licensed operator training, non-licensed staff training, and the status of INPO training accreditatio The licensee's commitment to comprehensive and effective training programs at all organizational levels was evident in the ambitious program of training development and accreditation ongoing throughout this assessment period. At the end of the period, though no train-4 ing programs had been accredited by INP0, the licensee had reas-sessed the program goals and milestones to establish a " ready for

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accreditation" status in all operator, staff, and technician-pro-grams before the end of 198 No new operator license examinations were given during this perio The licensee continued to implement the upgraded licensed operator requalification program committed to as a result of significant weaknesses identified as a result of NRC audits during the previous period. In January 1986, a new requalification program was initi-ated, including requalification as an integral part of the normal operator shift rotational schedule. NRC review of the licensed operator upgrade program and the preparations for the new requali-fication program identified satisfactory completion of the licen-see's commitmerits. A site-specific simulator has been installed and should be operational in mid-198 .The licensee relies heavily on departmental on-the-job training to establish and maintain personnel technical qualification. General employee training (GET) provides safety, security, and health physics training. The security department was particularly noted as having an effective training orogram. Overall, the quality of operations, maintenance, and surveillance activities reflects training strengths in these areas. Weaknesses were identified in some functional areas such as: I&C technician understanding of Technical Specifications (maintenance); engineer understanding of

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design change control procedures (modifications); inattentiveness of the licensee's staff to minimizing radiation exposures, and quality control inspector knowledge of radwaste transportation; (radiological controls); and general knowledge of the control of fire barriers (plant operations). These weaknesses indicate the need for improved training in these area Another problem identified during this period related to weaknesses in licensee control over the examination process for GET. The fail-ure to establish formal examination controls during GET testing al-lowed the occurrence of an incident involving talking between ex-aminees during a GET exa The licensee responded adequately to this event by implementing more comprehensive examination controls for all training program In summary, the minimal number of personnel-error-related operational events reflects positively on the effectiveness of operating staff training. Likewise, strong licensee performance in security and maintenance are due in part to the effectiveness of training in these area It was also noted, however, that recurrent weaknesses in the ALARA, modification control and fire protection programs result from personnel errors and misunderstanding of program requirement These reflect negatively on the quality of training in these area . Conclusion Rating: Category Trend: Consisten . Board Recommendation Licensee: Reorient technical training programs to address weaknesses identified in the functional area NRC: Non ,

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

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J. Licensing Activities Analysis The basis of this appraisal was the licensee's performance in sup-port of licensing actions that were either completed or active dur-ing the current rating period. These activities consisted of amendment requests, exemption requests, responses to generic letters, TMI items, SEP and ISAP topics, and related action Licensing activity during the SALP period has been at a very high level. Although several licensing actions have been deferred for resolution under the Integrated Safety Assessment Program (ISAP),

twice the number of licensing actions have been completed during this 12-month rating period than were completed during the previous 18-month SALP period. In addition to the routine actions, major activities completed or ongoing include fuel reload (Cycle 14), steam generator tube sleeving, the voluntary ISAP initiative, environmental qualification modifications, exemptions for fire protection require-ments, and the requirements for an updated Facility Description and

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Safety Analysis (FDSA). At the start of the SALP rating period, there were 75 active licensing actions. During the rating period, 50 actions were completed and 29 new actions were adde Thus, at the end of the rating period, 54 active actions remain. The specific licensing activities reviewed are listed in Section V.E of this re-por In resolving technical issues, the licensee has exhibited a good understanding of licensing issues and has generally employed a con-servative safety approach. The licensee's applications or submittals were generally timely and acceptable resolutions were generally pro-posed. For example, the licensee's application for relief from some requirements for inservice inspection of reactor coolant pumps was well prepared and exhibited a conscientious effort to comply with the regulations. However, there have been some instances where the licensee's resolution of technical issues and responsiveness have been poor. Examples are: submittal of information concerning the reliability of the Auxiliary Feedwater System, and in support of Technical Specifications for degraded grid protection, facility overtime, RETS and STS conversio While the licensee's management has been notably involved in major licensing issues, there have been occasions when incomplete or un-timely submittals have caused the staff to request improved manage-ment oversight. Notable examples include the Cycle 14 reload and steam generator tube sleeving license amendment applications. The Cycle 14 reload application, dated December 11, 1985, lacked the necessary technical information which was subsequently provided on January 16, 1986. Similarly, the steam generator sleeving applica-tion was received December 6, 1985, but the technical justification (sleeving report) was not provided until January 7, 1986. The un-

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timeliness of the supporting technical material for the above ap- l plications created a significant burden on the staff to complete l the required licensing reviews to support the scheduled startup date

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of March 4, 198 Similar examples of untimely submittals of exemption requests for issues being addressed under ISAP have occurred near the end of this rating period. Notable examples include the schedular exemption requests for the fire protection modifications in the switchgear room (March 7, 1986) and for Appendix J (March 12,1986). Both examples reflect cases where approval / denial of these exemption requests were outage related issues yet the submittal of the requests occurred well into the outag We believe that the above examples demonstrate that the performance and management oversight of licensing activities were declining during the end of the rating period and that it does not appear to be at the level of previous rating period There also appears to be a tendency on the licensee's part to declare a position on issues without providing the follow-up needed to assure appropriate licensing actions are formulated to address the issu In particular, Appendix R, environmental qualification (feed and bleed), and other exemptions related to issues being considered under ISAP were filed close to the regulatory deadlines with significant technical issues yet to be resolved. Although the licensee had pre-viously addressed these areas, they had not aggressively followed through to assure the acceptability of their position In conclusion, management attention and involvement with matters of nuclear safety are evident, but there also is evidence that the quality of the licensing activities at the Haddam Neck Plant has decreased. During this rating period there were instances when amendment applications were either incomplete or untimely, and when follow-up activities were delayed. Requests for extension of sub-mittal dates were common, reflecting an inadequate level of pre-plannin . Conclusion Rating: Category Trend: Declinin . Board Recommendations Licensee: Take action to assure that licensing submittals are ade-quately pre planned, comprehensive and reflect considera-tion for regulatory deadlines. Aggressively pursue each open item to closur NRC: Non i

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V. SUPPORTING DATA AND SUMMARIES Investigation and Allegation Review ,

Two allegations were received during this assessment period. One alleged that the licensee exceeded Technical Specification (TS) rod insertion limits. No evidence was found to substantiate this allegation. The second allegation concerned an incident involving two examinees discuss-ing test material during a General Employee Training (GET) exam. This allegation was substantiated. Although this was shown to be an isolated case, a lack of clear instructions for exam conduct and an inadequate testing environment were found by the licensee to need corrective actio The licensee upgraded their examination administrative controls to cor-rect the deficiency and close out the allegatio The individuals in-volved passed a subsequent reexaminatio Escalated Enforcement Actions Civil Penalties There were no civil penalties issued during this assessment perio . Orders A memorandum and order, issued on November 20, 1985, granted an ex-tension from the November 30, 1985, deadline for environmental qualification of electrical equipmen The deadline was extended (

to January 4, 1986. Modifications needed to fully qualify the ex-empted equipment were implemented during the January-April,1986 refueling outag . Confirmatory Action Letters There were no confirmatory action letters issued during this as-sessment perio Management Conferences On March 25, 1985, an enforcement conference was held at the NRC Region I office to discuss Reactor Protection System (RPS) Loss of Flow trip channel problems and associated surveillance and proce-dural review . On October 31, 1985, a management meeting was held at the NRC Region I office to discuss the causal factors and corrective actions for auxiliary feedwater system wiring deficiencie .

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D. Licensee Event Reports Tabular Listino Type of Events: Personnel Errors 14 Design / Man./Const./ Install 5 External Cause 0 Defective Procedure 2 Component Failure 14 Other 2 Total 37 LERs Reviewed LER No. 85-03 to 86-09 Causal Analysis (Review Period 3/1/83 - 2/28/86)

Six sets of common mode events were identfied: LERs 85-14, 85-18, 85-22, 85-27 and 86-01 reported fire door control problems caused by personnel error LERs 85-12, 85-23 and 86-07 reported missed fire protection system surveillance tests due to personnel error LERs 85-04, 84-12 and 86-06 report failures of containment penetration local leak rate tests during three consecutive surveillance cycle LERs 84-28 and 86-02 reported main steam safety valve setpoint drift problem LERs 85-5 and 85-24 reported auxiliary feedwater system actu-ation problems caused by sticking solenoid-operated actuation valve LERs 84-10 and 86-04 reported problems with operability of the low pressure overpressure protection syste There was a small increase in the percentage (38% to 43%) of per-sonnel/ procedural error-related events since the previous assessment and a high level of component failure . . - . -- - _ -

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! E. Operating Reactor Licensing Actions Schedular Extensions Granted March 28, 1985; Extended the deadline for environmental qualifica-

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tion of electrical equipment to Ncvember 30, 1985.

. August 26, 1985; Extended the date of compliance with commission order (dated June 12, 1984) upgrading the Emergency Operating

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Procedures (E0P) at the Haddam Neck Plant to September 1, 198 . Reliefs Granted

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June 10, 1985; Relief granted from requirements of Section XI of r ASME Boiler and Pressure Vessel Code for volumetric examination of reactor coolant pump casing weld . Exemptions Granted April 11, 1985; Granted a six (6) month exemption from 10 CFR 50.71(e) requirements updating the Facility Design and Safety Analysis (FDSA).

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November 22, 1985; Conditionally extended the April 11, 1985 (FDSA l upgrade) to June 30, 1987, provided specified milestone FDSA sub-

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mittals are met.

l License Amendments Issued Amendment No. 62 issued on April 24, 1985, revised Technical Speci-

! fications to change the Power Dependent Insertion Limits curve to

[ allow greater flexibility in plant operations when reducing or in-

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l creasing power.

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, Amendment No. 63 issued on July 1, 1985, changed the completion date l

for Item III.D.3.4, Control Room Habitability, as specified in the commission's March 14, 1983, Confirmatory Orde Amendment No. 64, issued on August 12, 1985, deleted Technical Specification Environmental Qualification (EQ) requirements as cur-rent EQ and schedular requirements were incorporated into 10 CFR 50.49.

L Amendment No. 65 issued on September 3, 1985, revised Technical l Specifications by deleting the logic requirement of the Pressurizer l Low Water Level for the Safety Injection Trip.

l Amendment No. 66 issued on September 3, 1985, modified Technical i Specifications to add new Limiting Conditions for Operations and l Surveillance requirements for Post-Accident Instrumentation.

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Amendment No. 67 issued on September 3, 1985, modified Technical Specifications to change discharge pressure requirements for Emer-gency Core Cooling System (ECCS) pump Amendment No. 68 issued on September 5, 1985, approved Radiological Effluent Technical Specifications (RETS) which incorporated the re-quirements of Appendix I to 10 CFR 50 and deleted Technical Speci-fication Appendix B, Environmental Technical Specification Amendment No. 69 issued on October 16, 1985, modified Technical Specifications to restrict the volume of flammable liquids in the control room to no greater than one pin Amendment No. 70 issued on October 16, 1985, revised Technical Specifications to update the pressure and temperature limit curves for hydrostatic and leap. rate testing and for heatup and cooldown rate Amendment No. 71 issued on December 10, 1985, revised Technical Specifications to include restrictions on the excessive use of facility staff overtim Amendment No. 72 issued on February 19, 1986, revised Technical Specifications to allow testing of normally closed, non-automatic isolation valves that are part of the Post Accident Sampling System (PASS).

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TABLE 1 TABULAR LISTING 0F LERs BY FUNCTIONAL AREA HADDAM NECK PLANT AREA NUMBER /CAUSE CODE TOTAL Plant Operations 7A 3B 6E 2X 18 Radiological Controls none Maintena.;te & Modifications 2A 2 Surveillance 5A 2D 8E 15 Emergency Preparedness none Security and Safeguards none Refueling and Outage Management none Quality Assurance none Training none Licensing Activities 28 2 Totals 14A 5B 2D 14E 2X 37 Cause Codes A - Personnel Error B - Design, Manufacturing, Construction, or Installation Error C - External Cause D - Defective Procedures E - Component Failure X - Other

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TABLE 2 LER SYN 0PSIS HADDAM NECK PLANT LER N Summary Description 85-3 Nonconservative Loss of Flow Setpoint 85-4 NIS Overpower Setpoint Drift 85-5 Failure of Auto AFW Flow Valves to Open 85-6 Feed. Pump Suction Pipe Rupture

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85-7 Plant Trip due to Feedwater Recirculation Valve Failed to Open

j -85-8  : Cable Vault Ventilation System Inoperable 85-9 . Inoperable Fire Door 85-10 Service Water M0V Failure

.85-11 Multiple Dropped Control Rods

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85-12 Failure to Perform Fire Detection Surveillance 85-13 Misaligned Rod Analysis 85-14 Inoperable Fire Door 85-15 -

Spurious Load Runback 85-16 NIS Dropped Rod Setpoint Drift 85-17 Post LOCA Release Paths Outside Containment 85-18 Inoperable Fire Door p -85-19 Spurious Load Runback 85-20 Potential Unauthorized Access to a High Radiation Area

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85-21 Cable Spreading Area Fire Barrier Problems  ;

85-22 Inoperable Fire Barrier 85-23 Missed Fire Protection Surveillance Test

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T-2-2 LER No. Summary Description 85-24 AFW Initiation 50V Failure 85-25 Unplanned Gaseous Release-85-26 Partial Loss of Variable Low Pressure Scram Protection 85-27 Fire Barrier Penetrations 85-28 High Steam Flow Reactor Trips 85-29 More Probable Loss of MCC 5 85-30 Systems Integrity Inspection Missed 86-01 Inoperable Fire Doors 86-02 Main Steam Safety Valve Failures 86-03 Category C-3 Steam Generator Tube Inspection 86-04 Low Pressure Over Pressure Protection System Malfunction 86-05 Inoperable Switchgear Halon System 86-06 Containment Local Leak Rate Failures 86-07 Missed Fire Protection Surveillance 86-08 Improperly Tested Containment Penetrations 86-09 . Inadequate Service Water Flood Barriers

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TABLE 3 INSPECTION HOURS SUMMARY HADDAM NECK PLANT HOURS % OF TIME Plant Operations . . . . . . . . ... 425 24 Radiological Controls ......... 393 22 Maintenance & Modifications ...... 314 18 Surveillance . . . . . . . . . . . . . . 230 13 Emergency Preparedness . . . . . . . . . 166 9 Security and Safeguards ........ 79 5 Refueling & Outage Management ..... 151 9 Quality Assurance ...........

- - Training . . . . . . . . . . . . . . . . - - Licensing Activities . . . . . . . . . . - -

Total 1758 100 Note: Allocations of Inspection Hours vs. Functional Areas are approximations based on inspection report data. The Quality Assurance and Training analyses are a synopsis of the evaluations of Quality Assurance and Train-ing rating criteria in each functional are Consequently, inspection hours for Quality Assurance and Training are included in the other respective area _

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TABLE 4 ENFORCEMENT SUMMARY

, HADDAM NECK PLANT Severity Levels

FilNCTIONAL AREAS I -II III IV V DEV Total Plant Operations 3 3

. Radiological Controls 2 1 3 Maintenance & Modifications 1 2 3 Surveillance

. Emergency Preparedness

, Security Safeguards

' Refueling & Outage Management Quality Assurance Training Licensing Activities

. Totals by Severity Level 6 3 9

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l TABLE 5 ENFORCEMENT DATA HADDAM NECK PLANT Inspection- Inspection Severity Functional Report N Date Level Area Violation 85-08 3/15-29/85 V B~ Inadequate scope of environmental audit progra /8-12/85 IV B Failure to perform receipt in-spection of Radwaste QA systems and failure of PORC to review a Radwaste processing procedure 85-15 6/14-26/85 IV C Inadequate design change review such that a TS change was misse /14-26/85 IV A Onsite review committee failure to identify that a required TS change was misse /16-12/02/85 IV A Failure to follow procedures (multiple instances).

85-21 10/16-12/02/85 IV A Inadequate corrective action for previous violation /9-2/6/85 V C Inadequate processing of modifi-cation field change /9-2/6/86 V C Inadequate test plan for a plant modificatio /10-14/86 IV B Failure to compact radwaste in accordance with an approved procedur '

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TABLE 6 INSPECTION REPORT ACTIVITIES HADDAM NECK PLANT Inspection Inspection Areas Report N Hours Inspected 85-04 96 Radiological Controls 85-05 8 Management Meeting (Surveillance)

85-06 166 Emergency Preparedness 85-07 89 Routine Resident 85-08 54 Radiological Controls 85-09- 144 Radiological Controls 85-10 10 Management Meeting (Training)

85-11 66 Routine Resident 85-12 25 Security 85-13 137 Routine Resident 85-14 cancelled 85-15 30 Special Resident - (Design Change Control)

85-16 50 Fire Protection 85-17 36 Design Change Control 85-18 80 Requalification Program 85-19 99 Routine Resident 85-20 27 Special Resident (Auxiliary Feedwater)

85-21 152 Routine Resident 85-22 12 Management Meeting (Auxiliary Feedwater)

85-23- 19 _ Security 85-24 29 Chemistry

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T-6-2 Inspection Inspection Areas Report N Hours Inspected 85-25 113 Routine Resident 86-01 206 Routine Resident 86-02 70 Radiological Control

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86-05 40 Quality Assurance

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TABLE 7 PLANT SHUTDOWNS HADDAM NECK PLANT Shutdown Period Description Cause March 12, 1985 Scram from 50% powe High pressurizer Random Equipment fail-pressure trip due to rapid plant load ures reduction as a resut of a loss of feed-water flow to steam generators, which was caused by a broken control air lire to a feedwater recirculation valve. A main condensate pump motor short pre-viously caused a load reduction to 50%

powe March 16, 1985 Manual scram due to a main feedwater Equipment Failure pipe ruptur The reheater drain pump (design-related)

flow control valve directed flow against the pipe wall causing signifi-cant erosion of the pip May 16, 1985 Manual scram due to two dropped con- Equipment Failure trol rod (design-related)

August 18, 1985 Shutdown to replace a main feedwater Equipment Failure pump seal (pump isolation valve leakage forced a shutdown rather than a power reduction).

November 10, 1985 Scram due to spurious high main steam Both events were caused flow signal by a design deficiency /

abnormal operating November 21, 1985 Scram due to spurious high main steam conditions -- lower flow signal margin to the trip setpoint during coast-down operation allowed existing inter-channel interference to actu-ate the reactor pro-tection system (de-sign-related).

November 27, 1985 Shutdown to replace main feedwater Equioment Failure pump rotating assembly (pump isolation (maintenance planning-valve leakage forced a shutdown rather related)

than a power reduction).

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E Y N B R R Y 4 t L G P T V C 5 A P A U U U E C O E 6 A E A S O N D 8 J F 8 M A M J J 9 9 1

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ENCLOSURE 3

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NORTHEAST UTILITIES c,eme,& omces . smen som ee~n cemnecocut T . . . . . . . . . . '~

P O BOX 270

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H ARTFORc CONNECTICUT Of141-0270 k L J !!.[*.h U..'.'.C'. [ ~,; (203) 66s-s000 March 13,1986 Docket No. 50-213 50-245 50-336 Bl1979 Dr. Thomas E. Murley Regional Administrator Region i U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Gentlemen:

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. I and 2 Svstematic Assessment of Licensee Performance The SALP Board Reports (I) for the 18-month period ending February 28,1985, for Haddam Neck, Millstone Unit No.1, and Millstone Unit No. 2 were issued on May 20,1985. After a meeting between members of the Staff, Connecticut Yankee Atomic Power Company (CYAPCO), and Northeast Nuclear Energy 1985, Northeast Utilities (NU) submitted a Company (2)(NNECO)to the SALP on Board June 4,recommendations for each of the individual response evaluation categorie The purpose of this letter is to provide an update on the status of the implementation of the corrective actions discussed in our July 5, 1985 correspondence. Items which were completed as of the July 5,1985 response are not discussed in this letter. Attachment I to this letter contains the status of the corrective actions related to the Haddam Neck unit which were incomplete as of July 5,1985. The status of the corrective actions for Millstone Unit No. I and Millstone Unit No. 2 are contained in Attachments 2 and 3, respectivel (I) T. E. Murley letter to J. F. Opeka, Systematic Assessment of Licensee Performance (SALP), dated May 20, 198 (2) J. F. Opeka letter to T. E. Murley, Systematic Assessment of Licensee Performance, dated July 5,198 l J

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We are again taking this opportunity to offer some additional observations on our level of performance during the past year. In particular, we note that Northeast Utilities executive management is active in numerous industry initiatives, having made presentations at public meetings before the Commission as well as participating in meetings with senior Staff management. NU management personnel are active in, and in many instances chair, various industry groups addressing a wide range of nuclear issue Provided as Attachment 4 is a summary description of some of our attempts to further improve the quality of the regulatory process by previding the regulators with a continuing opportunity to become more f amiliar with our plants, procedures, and personne We trust that the actions presented in the attachments for addressing tne '

concerns of the Board will be useful in subsequent SALP evaluations. Feel free to contact us if any questions arise on these matter Very truly yours,

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CONNECTICUT YANKEE ATOMIC POTER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY ,

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Senior Vice President N

By: W. F. Fee Executive Vice President cc: C. I. Grimes A. C. Thadani l

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Docket No. %-213 Bf1979 Attachment 1 Connecticut Yankee Atomic Power Company Haddam Neck Plant Updated Response to SALP Report

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March,1986

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Functional Area: PLANT OPER ATIONS i

Board Recommendations: ,

t (A) Improve the quality and aggressiveness of self appraisal (B) Continue emphasis on operator requalification (C) Continue initiatives to improve procedural review (D) Assess the adequacy and timeliness of PIR/CR disposition UPDATE:

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(A) Increased management concern for self appraisal and self identification programs has resulted in an upgrading of several existing program d The Plant Information Reports (PIR) system is undergoing prodedural changes to place more emphasis on root cause analysis and corrective action. The improvements in the analysis of cause should make the PIR a more effective mechanis The Nonconformance Control Reporting system is functionally sound, but at times a backich exists due to overall workload. Quality Assurance (QA) '

reviewers have b9en instructed to put greater emphasis on ensuring that cause and corrective actions are adequately addresse The QA< audits are becoming more performance oriented. For example, technical specialists are used on QA audit teams, an engineering assurance function in the QA branch is being developed during the first quarter of '

1986, and the use of QA surveillances to review field activities has been ,

increase '

The Beneficial Suggestion program has been very successful, with '

employees making many excellent suggestions for improvement on a wide variety of topics. This is a unified system which includes Housekeeping, ALAR A/ Radiological Safety, Fire Safety, and Personnel / Industrial Safet An evaluation of required resources to handle the large quantity of suggestions wil: 50 performed af ter the 1986 refueling cutag The RaWe f cX i Incide5t Report procedure has been upgraded and includes a dese.jp xa - he responsibility of the individuals involved in preparing the repm I, the athods of filing the report, and the ac*. ions to be take ,

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The Station Housekeeping and inspection Program was expanded to include l department heads performing periodic inspectiorc. ~ l (B) The Connecticut Yankee Plant Reference Simulator officially began

" Customer Factory Acceptance Testing" at the Link Facility in Silver .

Spring, MD on August 5,1985. The trainer has since been delivered and its installation recently completed. Reverification testing is expected to be completed by the end of March,198 ..

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(C) Improvements in procedural review and adherence are continuing. A method currently in use at the Millstone site involving management review and reissue of appropriate standing memos to station personnel as a reminder of the importance of following procedures and, where required, initiating changes to procedures, was implemented at the Haddam Neck Plant ef fective March 31, 198 The new Emergency Operating Procedures (EOPs) are in final draft form, and the first stage of classroom training has been conducted. Validation is scheduled to be completed by the end of March,1986. Simulator training on the EOPs will start following validation with implementation scheduled for September,198 Annunciator response procedures for all applicable control room alarms have been complete (D) The Controlled Routing (CR) completion trend continues to improve. A comparison of 1985 to 1984 indicates a 29% decrease in the backlog of CRs even though there was a 19% increase in CRs issued. A similar trend exists with Plant Information Reports (PIRs), which shows a 26% improvement in the backlog of PIRs for the same time period. The data for 1986 CRs and PIRs has not been evaluate .

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Lunctional Area: RADIOLOGICAL CONTROLS l Board Recommendatio ts: l l

(A) Efferis should be made to strengthen management oversight and )

intradepartmental communications. An effective system for evnluating and correcting self-identified deficiencies should be develope ,

(B) The Ikensee should expedite efforts to seek a Techr.ical Specification Amendment for PASS containment isolation valves to allow resumption of full system surveillanc UPDATE:

(A) A task force's recommendations to improve coordination of work activities amongst departments were presented to the Station Superintendent, and are currently being implemented. Many of the recommendations have already been implemented and have been beneficial. During refueling outages, one individual from the operations department and one individual from the maintenance departrnent for each shift have been assigned, as their full time duty, to coordinate and keep abreast of the status of equipment and work on a daily basis. Health Physics (HP) technicians now use " zone coverage" to facilitate identifying the appropriate HP technicians. In house HP technicians, as opposed to contractor personnel, -

are used in the field as much as possible to develop familiarity and trust between maintenance and HP personnel. In addition, more first line supervision f rom HP and maintenance are active in the fiel (B) CYAPCO submitted a proposal to revise its Technical Specifications to allow for surveillance testing of normally closed, non-automatic containment isolation valves that are part of the Post-Accident Sampling System (PASS) on October 31, 1985. The proposed revision to Technical Specifications 1.8, Containment Integrity (definition) and new Table 3.11-2, Non-automatic Containment Isolation Valves, will allow testing of normally closed isolation valves in the PASS during operation modes 1,2,3, and 4 to ensure opera This revision was approved and issued by the Commission (1pilit as Amendment No. 72 to Facility Operating License N DPR-61 on February 19,198 __

(1) F. M. Akstulewicz, Jr. letter to J. F. Opeka, Technical Specifications to Permit Testing of the Post-Accident Sampling System, dated February 19,198 .

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Functional Area: SUR VEILL ANCE Nard Recommendations:

(A) Continue initiatives to upgrade surveillance procedure (B) Improve management control over items like CLRT issues in order to assure that resolution is not unduly delaye UPDATE:

(A) A previously existing initiative to upgrade the surveillance program is on schedule and is expected to be completed in June,198 (B) Management control over Local Leak Rate Testing (LLRT) and Integrated Leak Rate Testing (ILRT) has been strengthened by reshapini; our LLRT/lLRT program to achieve consistency and quhl.ity for all of NU's operating nuclear units. Nuclear Engineering and Operations Procedure, NEO 2.20, " Containment Leakage R. ate Testing Program," was issued on December 10,198 This procedure establishes the methodology Ahd interface responsibilities necessary to comply with 10 CFR 50 Appendix 3 requirements. Per the provisions of NEO 2.20, the Connecticut Yankee 1986 ILRT Plan was issued and is being implemented. The Plan delineates '

all NUSCO and -CYAPCO engineering responsibilities and logistical activities necessary to conduct the ILR A.s part of CYAPCO's effort to resolve containment leak rate testing concerns, a December 23,198) submitta!(2) addressed several unresolved containment leak rate testing issues. In addition, a comprehensive review of the status of the Haddam Neck Plant's conformance with 10CFR50, Appendix 3 is currently being performed and is scheduled to be submitted in March,198 (2) J. F. Opeka letter to T. E, Murley, Haddam Neck - 10CFR50, Appendix 3 Compliance, dated December 23,198 .

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Functinnal Area: FIRE PROTECTION / HOUSEKEEPING poard Recommendations:

(A) Maintain attention to fire barrier (B) Discuss with NRC the status of findings and corrective actions related to the Appendix R implementation progra UPDATE:

(A) Fire barrier integrity is , emphasized in General Employee Training, which is given to all employees. The instrument and Controls Department held a training session on control of fire doors and penetrations. All of the station fire doors that are referenced in the technical specifications have a new sign describing in detail the commitments on fire door (B) As a result of a comprehensive (3) review of CYAPCO's position relative to Sections ll!.G, 3, and L of 10 CFR 50, Appendix R, new exemptions and modifications were identifie Eight new subsequently filed on September 16, 1985(4) which exemption requests were incorporated the recommendations of the comprehensive review and the guidance provided by Generic Letter 85-0 The NRC Staff is presently reviewing the exemption requests and visited the Haddam Neck plant on .

December 10,1985 to personally inspect the affected fire area The non-outage related hardware modifications were completed on August 14, 1983 in accordance with 10 CFR 50.48 schedules. Some of the outage related work is expected to be completed during the present refueling outage. The need for schedular relief was identified in the September 16,1985 submittal for the extensive switchgear room modifications. Circumstances surrounding the need for relief have been discussed informally with the Staff during the past several weeks. A formal schedular exemption request was submitted on March 7, 1986.(5)

(3) W. G. Counsil letter to R. H. Vollmer, Appendix R Evaluation Status, dated June 18,193 (4) 3. F. Opeka letter to H. L. Thompson, Fire Protection, dated September 16, 198 (5) 3. F. Opeka letter to C.1. Grimes, Fire Protection - Schedular Exemption, dated March 7,198 ~

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Functional Area: EMERGENCY PREPAREDNESS Board Recommendations:

(A) Continue efforts to improve the coordination of emergency response activitie UPDATE:

(A) The systematic computational comparison between licensee dose models and those used by the state was completed on October 28, 1985. The results of the comparison have been transmitted to the State of Connecticut. This was the only unresolved item in this functional are .

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Functional Area: DESIGN CHANGE CONTROL /OUALITY ASSUR ANCE Board Recommendations:

(A) Continue implementation of DCC/CA program improvements and review the effectiveness of the QA/OC surveillance effor UPDATE:

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(A) In response to the December 13, 1984 Order modifying the Haddam Neck license,(6) the 355 Plant Design Change Requests (PDCRs) processed at the Haddam Neck plant from January 1,1979 through December 31,1984 were reviewed to determine if any involved design changes of potential safety significance. In addition,20,294 Work Permits / Orders from the same time period were reviewed. The Plant Design Change External Review Grou transmitted the group's final report to the NRC on September 6,1985.(p) /

included in that transmittal were the findings of the Connecticut Yankee Plant Design Change Task Group (CYPDCTG). A plan and schedule for the implementation of improvements in the design change process based on the recommendations November 6, 1985. 81 (o( the CYPDCTG were submitted to the NRC on NUSCO Quality Assurance conducted a review of the coverage and effectiveness of quality control surveillance activities at Connecticut -

Yankee during October,198 The plant monitor program, designed to assess the actual "in-process work," was determined to need more in-field verification of ongoing activities. Since 1984, the focus of the monitor program has been shifting more toward operating activities of a major type such as startup testin The percentage of monitors involving actual in the field verification has been steadily improving. The content of the monitor reports is currently s

being improved to provide a better description of the acti'vities observe (6) 3. M. Taylor letter to W. G. Counsil, Order Modifying License and Notice of Violation and Proposed Imposition of Civil Penalty, Docket No. 50-213, EA-84-ll5, dated December 13,198 (7) D. E. Vandenburgh letter to T. E. Murley, Connecticut Yankee Plant Design Change External Review Group Final Report, dated September 6,198 (8) 3. F. Opeka letter to T. E. Murley, Haddam Neck Plant Response to December 13, 1984 Order Modifying License, dated November 6,198 .

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The QA/QC activity surveillance program, which is intended to verify that quality controls have been established and maintained in the work areas, needed to be reinstituted, according to the review. More frequent performance of activity surveillances and routine participation by QA/QC personnel during preventive / corrective maintenance .and operational surveillances were suggested. The use of the activity surveillance program is being expanded by setting target goals for the number of surveillances to be performed in particular areas. This program is being incorporated into the tracking system for open items. Methods to improve the guidance for performing activity surveillances are still being assessed. Periodic trend reports are provided to management. All surveillances that result in a quality problem result in a Nonconformance Control Report (NCR). NCRs are trended monthly with a report to all department heads and to the Plant Operating Review Committee (PORC).

The assessment team concluded that the development and implementation of a strong QA/QC activity surveillance program would provide a useful management toolin the evaluation of overall work performanc t n

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Functional Area: LICENSING ACTIVITIES -

Board Recommendations:

(A) As indicated in Sections B and D, the licensee should aggressively pursue licensing resolution in the areas of 10 CFR 50 Appendix 3 compliance and, (B) Operation of the post-accident sample system at powe UPDATE:

(A) On December 23, 1985, CYAPCO submitted a letter (9) addressing the seven unresolved containment leak rate testing items which were identified in inspection Report No. 50-213/84-13.(10) As part of the Haddam Neck Plant integrated Safety Assessment Program (ISAP), CYAPCO is planning to provide the NRC Staff with a summary of the status of compliance with 10 CFR 50 Appendix 3 by March,198 (B) CYAFCO submitted a proposal to revise its Technical Specifications to allow for surveillance testing of normally closed, non-automatic containment isolation valves that are part of the Post-Accident Sampling System (PASS) on October 31, 1985. The proposed revision to Technical Specifications 1.8, Containment Integrity (definition) and new Table 3.11-2, *

Non-automatic Containment Isolation Valves, will allow testing of normally closed isolation valves in the PASS during operation modes 1,2,3, and 4 to ensure oper This revision was approved and issued by the Commission (abjlity.lli as Amendment No. 72 to Facility Operating License N DPR-61 on February 19,198 (9) 3. F. Opeka letter to T. E. Murley, Haddam Neck - 10CFR, Appendix 3 Compliance, dated December 23,198 (10) T. T. Martin letter to W. G. Counsil, inspection Report No. 50-213/84-13, dated October 17,198 (11) F. M. Akstulewicz, Jr. letter to 3. F. Opeka, Technical Specifications to Permit Testing of the Post-Accident Sampling System, dated February 19,198 . - - - . - - . . .

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Docket No. 50-20 5 BI1979 Attachment 2 Northeast Nuclear Energy Company Millstone Unit N Updated Response to SALP Report

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March,1986

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Functional Area: RADIOLOGICAL CONTROLS Board Recommendations:

(A) Evaluate specific training for first-level supervisors as a measure for improving adherence to requirement (B) Upgrade adherence to routine radiation protection requirements by individual worker UPDATE:

(A) & (B) The Nuclear Training Department acted to ensure that all station personnel were instructed on the importance of establishment, implementation, and maintenance of radiation protection procedure New Employee Indoctrination incorporates a section on Nuclear Engineering and Operations (NEO) Procedure familiarization, covering the main topics of each procedure. NEO 2.05, Radiation Protection and Maintaining Occupational Radiation Exposures As Low As Reasonably Achievable, is included in the trainin New employees who are potential radiation workers must take Level 1 Radiation Worker Training to receive in-depth instruction on specific -

radiological controls procedures. Instruction is given on the function, purpose, and use of Radiation Work Permits (RWPs) and on proper entry into and exit from radiologically controlled areas. Employees are required to pass (80% correct) a 50 question examination, of which 5-10 questions pertain specifically to radiological control Employees are also required to demonstrate proper entry / exit to/from a Radiologically Controlled Area including reading comprehension, and adherence to an RW General Employee Training is given annually and includes a two hour Level 3 Radiation Worker Requalification Program, to requalify employees as Radiation Workers. In the 1985 program, specific emphasis was placed on adherence to RWP requirements, including proper dress, documentation of radiation exposures, familiarity with the radiological environment, and documentation of all entrances into and exits from radiological area ., .

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Functional Area: SUR VEILLANCE Board Recommendation:

(A) Upgrade QA of critical surveillance testing such as containment integrated leak rate testin UPDATE:

(A) Millstone Unit 1 Engineering Department Instruction 1-ENG-3.01, Primary Containment Integrated Leak Test, was issued on June 3,1985. Detailed, plant specific information for planning and execution of the Integrated Leak Rate Test (ILRT), including training and inter-department involvement, is given. The procedure is to be reviewed and revised, if necessary, af ter receiving comments from the other NU nuclear units when they conduct ILRT Nuclear Engineering and Operations Procedure, NEO 2.20, Containment Leakage Rate Testing Program, was issued on December 10, 198 ENG-3.01 has recently been revised and refers to NEO 2.20 in appropriate sections. 1-ENG-3.01 is in conformance with NEO 2.20, and is more detailed in plant specific area ,

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Functional Area: FIRE PROTECTION / HOUSEKEEPING Board Recommendations:

(A) Address the cluttered yard conditio (B) Resolve Appendix R implementatio UPDATE:

(A) The Radwaste Reduction Facility has been completed and was in use as of September 27, 1985. This f acility will increase indoor storage capabilit In addition, the area near the Unit I transformer yard has been cleared of all stored materia (B) As a result of a comprehensive review (1) of Millstone Unit l's position relative to Sections Ill.G, 3, and L of 10 CFR 50, Appendix R, new exemptions and modifications were identifie Eight new exemption requests were subsequently filed on November 21, 1985(2) which incorporated the recommendations of the comprehensive review and the guidance provided by Generic Letter 85-01. The exemption requests are presently underg'RC review and additional information was requested by the NRC Staff.(

t Hardware modifications which are norFoutage related are scheduled to be completed by August 6,1986 in accordance with 10 CFR 50.48 schedwe Implementation of the outage related work is scheduled for the '987 ref ueling outag (1) W. G. Counsil letter to R. H. Vollmer, Appendix R Evaluation Status, dated June 18,198 (2) 3. F. Opeka letter to H. L. Thompson, Fire Protection, dated November 21, 198 (3) Conference Call between NUSCO and the NRC Staff on January 27,198 ., ,

Functional Area: EMERGENCY PREPAREDNESS Board Recommendation:

(A) Evaluate measures f or assuring timely completion of action item UPDATE:

(A) Lessons plans for emergency preparedness training have been developed and were implemented in the 1985 emergency training. This item has been closed out by the NRC Region 1.(4)

(4) 7. T. Martin letter to J. F. Opeka, inspection No. 50-423/85-39, dated October 10,198 .

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Board Recommendation:

(A) Improve self-assessment to identify items such as f ailure to follow through on commitments and design modification UPDATE:

! (A) Millstone Unit I commitment items have been incorporated into the Unit 1 Superintendent's assignment list, in an effort to improve tracking of commitment This list has high visibility and receives significant management attention in managing important projects on the unit. The list is updated approximately weekly, and is distributed to all Millstone Unit I department head ,

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Functional Area: LICENSING Board Recommendations:

(A) Improve management of licensing activities to avoid late response (B) Improve coordination of activities with NRR in regard to schedule, prioritization, and project statu .

UPDATE:

(A) Senior NU management is routinely and aggressively involved in the management of licensing issues. Additional resources have been added to the licensing staff to improve the timeliness of responses. Despite the emphasis on schedular performance, the quality of docketed submittals cannot and will not be compromised merely to meet a deadlin With respect to our performance in this area, we invite your attention to comments made by the Staff at a Commission briefing on ISAP on February 19,1986. The Staff stated to the Commission:

"So, in sum, we came up with 80 topics for Millstone Unit No. I and 70 topics for Haddam Neck as a result of our screening '

reviewin Shortly thereafter Northeast began submitting the topic reviews for Millstone Unit No.1, and between August 13th, 1985 and November 25th,1985, they submitted evaluations for each of the 80 topics that we identified for Millstone Unit No. I would note that that is probably the fastest response that I have ever seen to that large a number of issues. But there again we have to temper that judgment with the lead time that they had from the time that we originally envisioned the concept of ISAP. So they had done a lot of legwork. But they pulled it together very fast."

Later in the briefing, Mr. Stello commented:

"There's one other area that we probably ought to give a lot of credit to Northeast as a leader in how they go about doing their analysis. They have an enormous in-house staff, and involve the people in the plant, which has yet an additional benefit of doing the PRA, just the way they go about it, over and above having it done for you. And I think we ought to give them some credit for the way they go about it, because I do think they do a very good job."

(B) NU's licensing group has been coordinating activities with the Integrated Safety Assessment Program (ISAP) Project Directorate in order to implement the program. Activities have included timely submittals of the Millstone Unit No.1 Probabilistic Safety Study, deterministic reviews of all Millstone Unit No.1 ISAP topics and probabilistic risk oriented project evaluations, as well as several meetings on various aspects of the ISA ._ _ _ _ - - _ _

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Meetings on the Millstone Unit No. I Provisional to Full Term Operating License conversion were held with the ACRS during November and December 1985 to facilitate NRC/ACRS approval of the license conversion. License conversion activities are ongoing. Our view is that we have been responsive to this recommendation, and we welcome any additional feedback from the NRR Staf .

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Attachment 3 Northeast Nuclear Energy Company Millstone Unit No. 2 Updated Response to S ALP Report

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March,1986

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Functional Area: Pl. ANT OPERATIONS Board Recommendation:

(A) Upgrade controls over computer codes, particularly of associated qualification certification UPDATE:

(A) Phase II of the ef fort to upgrade the control of computer sof tware used by NUSCO for Category I engineering analysis is continuing. A Joint User Task Force was formed to review and upgrade existing procedures on quality related computer programs. The need for additional procedures and controls was identified. The required procedures have been draf ted, and are in the review proces .

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Functional Area: RADIOLOGICAL CONTROLS Board Recommendations:

(A) Continue recent emphasis on improving radioactive material transportation control (B) Assure better adherence to radiation protection procedures by worker UPDATE:

(A) The Radioactive Materials Handling Department was reorganized to facilitate better supervision and control of its activities. The Health Physics Supervisor is now responsible for the operation of this grou A specific packaging procedure for LSA boxes, RW 6012/20612/36012,

" Packing Non-Compactible LS A Containers," was developed and ef fective as of August 1,198 (B) The Nuclear Training Department acted to ensure that all station personnel were instructed on the importance of establishment, implementation, and maintenance of radiation protection procedure '

New Employee Indoctrination incorporates a section on Nuclear Engineering and Operations (NEO) Procedure f amiliarization, covering the main topics of each procedure. NEO 2.05, Radiation Protection and Maintaining Occupational Radiation Exposures As Low As Reasonably Achievable, is included in the training. New employees who are potential radiation workers must take Level 1 Radiation Worker Training to receive in-depth instruction on specific radiological controls procedure Instruction is given on the function, purpose, and use of Radiation Work Permits (RWPs) and on proper entry into and exit from radiologically controlled areas. Employees are required to pass (80% correct) a 50 question examination, of which 5-10 questions pertain specifically. to radiological controls. Employees are also required to demonstrate proper entry / exit to/from a Radiologically Controlled Area including reading comprehension, and adherence to an RW General Employee Training is given annually and includes a two hour Level 3 Radiation Worker Requalification Program, to requalify employees as Radiation Workers. In the 1985 program, specific emphasis was placed on adherence to RWP requirements, including proper dress, documentation of radiation exposures, f amiliarity with the radiological environment, and documentation of all entrances into and exits from radiological area . .

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Board Recommendations:

(A) Address the cluttered yard condition. Upgrade housekeeping in areas noted as candidates for improvemen (B) Resolve Appendix R implementatio UPDATE:

(A) As mentioned in the Millstone Unit I response to Fire Protection / Housekeeping recommendations, the Radwaste Reduction Facility has been completed. Deficiencies in other identified areas have been corrected. The enclosure building and equipment access hatch area have been cleaned. The area of the auxiliary building refueling water storage tank pipe chase has been cleaned, cofferdams have been built to prevent water f rom running down the wall, and the wall has been repainte The safeguards pump rooms have been cleaned and the wall in the "A" room has been repaire (B) As a result of a comprehensive (l) review of Millstone Unit 2's position relative to Sections Ill.G, 3, and L of 10 CFR 50, Appendix R, new exemptions and modifications were identifie Ten new exemption requests were subsequently drafted and are currently mdergoing internal review. The new exemption requests are scheduled to be submitted to the -

NRC in April, 198 The exemptions have incorporated the recommendations of the comprehensive review and the guidance provided by Generic Letter 85-0 Hardware modifications which are non-outage related are planned to be completed in accordance with 10 CFR 50.48 schedules. Implementation of the outage related work will be scheduled following receipt of the NRC SE (1) W. G. Counsil letter to R. H. Vollmer, Appendix R Evaluation Status, dated June 18,198 ., .

[unctional Area: EMERGENCY PREPAREDNESS

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Board Recommendation:

(A) Evaluate measures f or assuring timely completion of action item UPDATE:

(A) Lessons plans for emergency preparedness training have been developed and were implemented in the 1985 emergency training. This item has been closed out by the NRC Region 1.(2)

(2) 'I. T. Martin letter to J. F. Opeka, inspection No. 50-423/85-39, dated October 10,198 .

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. Functional Area: LICENSING Board Recommendations:

(A) Improve management of licensing activities to avoid late response (B) Improve coordination of activities with NRR in regard to schedule, prioritization, and project statu UPDATE:

(A) Senior NU management is routinely and aggressively involved in the management of licensing issues. Additional resources have been added to i the licensing staf f to improve the timeliness of responses. Despite the emphasis on schedular performance, the quality of docketed submittais cannot and will not be compromised merely to meet a deadlin (B) Our perspective is that the Millstone Unit No. 2 licensing engineer and the NRC's Project Manager for Millstone Unit No. 2 enjoy a very good working relationship. There is virtually daily communication between the NRC and NU in this regard with " face-to-face" update meetings at least quarterly in order to maintain clear communications and agreements on outstanding

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information requests and other licensing issues. Currently, the NRC and

! NU are working together to identify items to be worked on during the next -

year and a priority ranking for each. The mechanics are in place to ensure that timely and responsive input is provided to the NRC.

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Docket No. 50-336 Bf1979

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Attachment 4 Haddam Neck Piant Millstone Nuclear Power Station, Unit Nos. I and 2 Inputs to S ALP Evaluation Process

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March,1986

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The f ollowing items provide a summary description of various meetings, letters, or other transactions which we believe are relevant to the conduct of the SALP process for our f acilities. Only a summary of each of the pertinent elements is provided below. Further elaboration can be provided as desire o in April,1985 in order to f acilitate an orderly transfer of a senior management position, o,*r current and past Senior Vice President of Nuclear Engineering and Operations conducted a series of meetings with members of the Staff over a two day perio o in May,1985 we met with the Staff to discuss IGSCC inspection plans and results for Millstone Unit No.1. Additionally, we kept the Staff informed via letters and meetings, of the status of the inspection results dLring the outag o One of the elements of our corporate strategy regarding steam generators at Millstone Unit No. 2 concerns a chemical cleaning process used during the 1985 ref ueling outage. In May,1985 we met with the Staff to discuss the results of this cleaning process. Additionally, information concerning this process was made available to the indstry via available electronic network systems and owners group o in June, 1985 we hosted a meeting with the Region ! Regional -

Administrator, members of the Staff, and NRC consultants on the subject of the application of PRA techniques at Northeast Utilities. Discussion topics included technical details of our PRA techniques and the ISAP progra o in August,1985 we entertained a one-week visit by staff personnel from the 1.icense Qualification Branch, Division of Human Factors Safety and provided information on our Production Maintenance Management Syste The resulting Site Survey Report noted that we are " committed to acting quickly in solving problems; and to ensuring that extensive supervisory involvement is present in every phase of each maintenance activity."

o in August,1985, at the request of the Director of the Office of Inspection and Enforcement (IE), we hosted a meeting with members of the IE Staff to discuss the Pilot Outage Inspection Program. We discussed our experiences on work recently performed for the Haddam Neck Plant which was relevant to the formulation of the NRC Pilot Outage inspection Program, o

in September,1985 we entertained a visit by the Brookhaven Reliability Research Team and Mr. Carl Johnson of the NRC Division of Risk Analysis and Operations to gather information on reliability techniques which we have found to be effective at Millstone Unit No.1. This was in support of NRC Technical Specification Improvement Project and Maintenance and

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Surveillance Program. The resulting OSRR Project Team report noted that reliability activities at NU " appear to have strong management support and z

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NU has a formalized reliability program that is conducted by a dedicated group of individuals."

o in September,1985 we provided comprehensive long term maintenance records as input for the NRC Operational Safety Reliability Research Progra o During 1985, as an aid in personnel transitiors within the NRC, we

, entertained visits by the new project manager for the Haddam Neck Plant and the new Branch Chief of Operating Reactors Branch //5 for discussion of licensing issues concerning Millstone Unit No. I and the Haddam Neck Plan o in 1985 we were active participants in the AIF Committee on Reactor Licensing and Safety in both the steering group concerning the source term issue and the subcommittee on Technica! Specifications for input to the NRC Technical Specification Task Forc o NU has been an active member of the Industry Effort to resolve the USI-A-44, Station Blackout, issue. In this regard, the Industry, via the Nuclear Utility Management and Resource Committee (NUMARC) and the Nuclear Utility Group on Station Blackout, has been werking with the Staff towards a mutually agreeable resolution to this issu o During 1985, as chairman of the NUMARC working group on the issue of Engineering Expertise on Shift, executive NU management continued to work with NRC Senior Staff management and the Commission toward development of a mutually agreeable and workable policy statemen .

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