ML20198H209
| 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: |
| References | |
| 50-213-85-98, NUDOCS 8605300157 | |
| Download: ML20198H209 (76) | |
See also: IR 05000213/1985098
Text
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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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TABLE OF CONTENTS
Page-
1.
INTRODUCTION..........................................................
1
A.
Purpose and 0verview.............................................
1
B.
SALP Board Members...............................................
1
C.
Background..... ...................................... ..........
2
II.
CRITERIA..............................................................
4
III. SUMMARY OF RESULTS....................................................
6
A.
Facility Performance.........................
...................
6
B.
Overall Facility Eva1aution......................................
6
IV.
PERFORMANCE ANALYSIS..................................................
7
A.
Plant 0perations.................................................
7
B.
Radiological
Controls.........................
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11
C.
Mai ntenance and Modi fi cati ons. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
15
D.
Survei11ance....................................................
18
E.
Emergency' Preparedness..........................................
20
F.
Security and Safeguards.........................................
22.
G.
Refueling and Outage Management.................................
24
H.
Assurance of Quality............................................
26
I.
Training and Qualification Effectiveness........................
28
J.
Licensing Activities............................................
30
V.
SUPPORTING DATA AND SUMMARIES........................................
32
A.
Investigation and Allegation Review.............................
32
B.
Escalated Enforcement Action....................................
32
C.
Management Conferences..........................................
32
D.
Licensee Event Reports..........................................
33
E.
Operating Reactors Licensing Actions. . . . . . . . . . . . . . . . . . . . . . . . . . . .
34
-TABLES
Table 1 - Tabular Listing of LERs by Functional Area
Table 2 - LER Synopsis
Table 3 - Inspection Hours Summary
Table 4 - Enforcement Summary
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Table 5 - Enforcement Data
Table 6 - Inspection Activities
. Table 7 - Plant Shutdowns
FIGURE
Figure 1 - Number of Days Shut Down Per Month
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I.
INTRODUCTION
A.
Purpose and Overview
The Systematic Assessment of Licensee Performance (SALP) is an integrated
NRC staff effort to collect information periodically and evaluate licen-
see performance.
SALP supplements the normal regulatory processes that
ensure compliance with NRC regulations.
It is intended to be sufficiently
diagnostic to provide a rational basis for allocation of.NRC resources
and to be meaningful-to licensee efforts to improve safety.
An NRC SALP Board met on April 24, 1986 to perform this SALP in accord-
ance with NRC Manual Chapter 0516, " Systematic Assessment of Licensee
Performance." A summary of the SALP guidance is provided in Section II
of this report.
This report assesses performance at the Haddam Neck Plant during the 12-
month period from March 1, 1985 through February 28, 19_86.
B.
SALP Board Members
Chairman:
W. F. Kane, Deputy Director, Division of Reactor Projects (DRP)
Members:
T. T. Martin, Director, Division of Radiation Safety and Safeguards,
(DRSS)
L. H. Bettenhausen, Chief, Operations Branch, Division of Reactor Safety
(DRS)
R. R. Bellamy, Chief, Emergency Preparedness and Radiological Protection
Branch, DRSS
E. C. Wenzinger, Chief, Projects Branch 3, DRP
E. C. McCabe, Chief, Reactor Projects Section 3B, DRP
P. D. Swetland, Senior Resident Inspector, Haddam Neck
C. I. Grimes, Director, Integrated Safety Assessment Project Directorate,
Office of Nuclear Reactor Regulation (NRR) (by telecon)
F. M. Akstulewicz, Licensing Project Manager, NRR
Other Attendees
M. M. Shanbaky, Chief, Facilities Radiation Protection Section, DRSS
T. F. Dragoun, Radiation Specialist
M._C. Kray, Reactor Engineer
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C.
Background
1.
Licensee Activities
At the beginning of this SALP period on March 1, 1985, the facility had
been operating at or near full power (600 MWe) since November 22, 1984.
Full power operation continued until March 12, 1985.
On March 12, the licensee began reducing load to 50% when a ground in
the "B" condensate pump motor caused a halon system discharge in the
switchgear room.
Later that day, a reactor trip from 50% power occurred
on high reactor coolant system pressure because load was being rapidly
reduced to compensate for a loss of feedwater control caused by a failed
open main feedwater (MFW) pump recirculation control valve.
On March
16, after return to 100% power, the plant was manually tripped due to
a large leak in the MFW piping between the "1B" feedwater heater normal
level control valve and its downstream isolation valve.
Following re-
placement of the ruptured section of MFW piping, 100% power operation
was resumed from March 20 until April 13, when load was reduced to 50%
to repair the "B" condensate pump motor.
Full power operation resumed
the next day.
On May 16, there was a manual reactor and turbine trip
from 100% power because two control rods dropped into the reactor core
during manual control rod movement.
No cause for the rod drops was
identified.
During the post-trip approach to criticality, main turbine
generator excitation problems delayed startup until May 18, when full
power was attained.
On August 18, the plant was shut down to replace
the leaking "A" MFW pump inboard seal.
Full power operation resumed from
August 21 until September 27 when the plant was shut down for Hurricane
Gloria.
No significant site damage was experienced during the hurricane.
The plant was returned to 100% power on September 30.
On November 3, an extended power coastdown to 90% power began.
On Novem-
ber 10, an automatic reactor and turbine trip occurred due to a spurious
high main steam flow indication.
Coastdown operations subsequently re-
sumed until November 21, when a second high steam flow trip occurred due
to crosstalk between protection channels during system maintenance / test-
ing.
After measures were implemented to control this interference, and
upon completion of routine shutdown maintenance, startup began on Novem-
ber 22. During power ascension, MFW pump problems again occurred, result-
ing in reduced power operation until November 27, when the plant was shut
down to repair the "A" MFW pump.
Power operations resumed on November
30 and continued until January 4, 1986, when the unit was shutdown for
the planned eight-week refueling / maintenance outage.
Refueling and maintenance activities included the core XIV fuel shuffle,
installation of a new permanent reactor cavity seal, steam generator
channel head decontamination and eddy current testing, an integrated leak
rate test, and several secondary system overhauls, upgrades or repairs.
In addition, modifications supporting equipment qualification, fire pro-
tection, seismic support upgrades, and the TMI Action Plan were imple-
mented.
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On February 26, while lifting the reactor core upper internals prior to
fuel offload, a single fuel element stuck to the internals.
As the in-
ternals assembly was being moved laterally, the fuel element hit the in-
side of the core barrel and fell onto two fuel elements in the core.
Its top end slid around the vessel and came to rest on the opposite side
of the core barrel.
Although individual fuel rods in the fuel element
were damaged, no radioactivity was released.
The dropped element was
safely recovered on March 2.
By the end of the assessment period, delays
associated with the dropped fuel element recovery, and problems with the
steam generator decontamination, reactor cavity seal and main turbine
low pressure rotors had extended the outage by several weeks.
2.
Inspection Activities
One NRC resident inspector was assigned during the entire assessment
period.
A second resident inspector was assigned on September 23, 1985.
The NRC inspection effort (both resident and region-based) for the one-
year assessment period totalled 1758 hours0.0203 days <br />0.488 hours <br />0.00291 weeks <br />6.68919e-4 months <br />.
There were two special inspections during the assessment period: (1) to
review the circumstances and corrective actions related to design change
control deficiencies (smoke detector removal) identified during Phase
I of the Process Computer Replacement; and (2) to review matters related
to component malfunctions and cross-wiring in the automatic Auxiliary
Feedwater Actuation Systems.
In addition, there were two NRC Team In-
spections: (1) An Emergency Preparedness Team observed the annual emer-
gency exercise on March 30, 1985; and (2) A radiation safety team in-
spection evaluated the radioactive materials transportation program.
An inspection and findings summary is appended to this report.
Fire
protection was not inspected in-depth as in prior years.
Consequently,
due to the lack of (1) readily apparent problems and (2) substantive team
inspection effort, fire protection is not evaluated this period.
3.
Supplementary SALP Functional Areas
This report discusses " Training and Qualification Effectiveness" and
" Assurance of Quality" as separate functional areas.
Although these
topics, in themselves, are assessed 'n the other functional areas through
their use as evaluation criteria, a synopsis is provided by each of these
two areas.
For example, quality assurance effectiveness has been as-
sessed on a day-to-day basis by resident inspectors and as an integral
aspect of specialist inspections.
Although quality work is the responsi-
bility of every. employee, one of the management tools to measure this
effectiveness is the use of quality assurance inspections and audits.
Other major factors that influence quality, such as involvement of first-
line supervision, safety committees, and worker attitudes, are discussed
in each functional area.
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II.
CRITERIA
Licensee performance is assessed in selected functional areas, depending on
whether the facility is in a construction, preoperational, or operating phase.
The functional areas normally represent areas significant to nuclear safety
and the environment, and are normal programmatic areas.
Special areas may
be added to highlight significant observations.
The following evaluation criteria were used to assess each functional area.
1.
Management involvement and control in assuring quality.
2.
Approach to resolution of technical issues from a safety standpoint.
3.
Responsiveness to NRC initiatives.
4.
Enforcement history.
5.
Reporting and analysis of reportable events.
6.
Stafting (including management).
7.
Training and qualification effectiveness.
Based upon the SALP Board assessment, each functional area evaluated is clas-
sified into one of three performance categories.
These are:
Category 1.
Reduced NRC attention may be appropriate.
Licensee management
attention and involvement are aggressive and oriented toward nuclear safety;
licensee resources are ample and effectively used so that a high level of
performance with respect to safety is being achieved.
Category 2.
Normal NRC attention should be maintained.
Licensee management
attention and involvement are evident and are concerned with nuclear safety;
licensee resources are adequate and reasonably effective so that satisfactory
performance with respect to safety is being achieved.
Category 3.
Both NRC and licensee attention should be increased.
Licensee
management attention or involvement is acceptable and considers nuclear safety,
but weaknesses are evident; licensee resources appear to be strained or not
effectively used such that minimally satisfactory performance with respect
to operational safety is being achieved.
The SALP Board also compared the licensee's performance in each functional
area during the last quarter of the assessment period to that during the en-
. tire period in order to determine the recent trend.
The trend categories used
by the SALP Board are as follows:
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Improving:
Licensee performance has generally improved over the last quarter
of the current SALP assessment period.
Consistent:
Licensee performance has remained essentially constant over the
last quarter of the current SALP assessment period.
Declining:
Licensee performance has generally declined over the last quarter
of the current SALP assessment period.
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III. SUMMARY OF RESULTS
A.
Facility Performance
CATEGORY LAST
CATEGORY THIS
PERIOD (9/1/83- PERIOD (3/1/85- RECENT
FUNCTIONAL AREA
2/28/85)
2/28/86)
TREND
1.
Plant Operations
1
1
Consistent
2.
Radiological Controls
2
2
Consistent
3.
Maintenance & Modifications #
1
2
Consistent
4.
Surveillance
2
2
Consistent
5.
2
2
Consistent
6.
Security & Safeguards
1
1
Consistent
7.
Refueling /0utage Management
1
2.
No Basis
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8.
Assurance of Quality
2
2
Consistent
9.
Training and Qualification
2
Consistent
Effectiveness
10.
Licensing Activities
1
2
Declining
Modifications were previously addressed under Assurance of Quality.
Not previously addressed as a separate area.
B.
Overall Facility Evaluation
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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 performance.
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IV.
PERFORMANCE ANALYSIS
A.
Plant Operations (425 hours0.00492 days <br />0.118 hours <br />7.027116e-4 weeks <br />1.617125e-4 months <br />, 24%)
1.
Analysis
This functional area encompasses operational activities, plant
housekeeping and fire protection, operator and staff performance,
review committee activities, event reporting, and corrective actions.
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 problems.
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 period.
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 period.
The overall result was continuing effectiveness of the onsite team
of management, operators and support staff.
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 operators.
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 progress.
Improved facilities for outage personnel have been
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provided.
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 housekeeping.
<
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
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-
,
rent problems include late procedure reviews and self-identified
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radiological procedure violations.
Licensee efforts to decrease
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personnel errors and procedure-related problems have been partially
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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-
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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 consequences.
Overall, however,
the quality of LERs has improved.
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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
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number of multiple PORC reviews on individual topics and the length
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of PORC deliberations on certain reactive review efforts suggest
weaknesses in the staff work performed prior to PORC submittal.
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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.)
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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
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plant operation.
Of particular note were the high quality and
timely NRB reviews of plant modifications and the assessment tech-
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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,
event reports, and nonconformance reports to measure staff perform-
r
ance.
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
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was noted as an area for improvement.
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No new operator license examinations were given during this period;
no NRC assessment of that aspect was made.
During this period, the
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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
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training into the operator shift rotation schedule.
NRC review of
,
the preparations for implementation of this program identified no
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problems.
The program has improved the timeliness of operator
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feedback on procedural and hardware changes, and significantly in-
creases the training time to allow more discussion of the subjects
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covered.
Three violations were identified in the Plant Operations area.
None
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of these was a major violation.
However, one of the three was for
,
failure to adhere to procedures, which is a continuing problem noted
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in the previous SALP.
l
In summary, although the licensee has improved each area of weakness
!
cited in the previous analysis, management attention is needed to
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further irrprove procedural compliance, LER quality, PORC efficiency,
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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 analysis.
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-2.
Conclusion
Rating:
Category 1.
Trend:
Consistent.
3.
Board Recommendation:
Licensee: None.
NRC:
None.
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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%)
1.
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 area.
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 QA.
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 warranted.
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
outage.
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 orderly.
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 zones.
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 area.
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
match.
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 two.
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 involved.
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 work.
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 areas.
However,
a recent NRC appraisal of the ALARA program indicated that this
provides only a partial explanation for the poor ALARA performance.
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 poor.
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-
port.
Furthermore, most of the analyses do not clearly isolate and
identify the root causes of the problem.
Finally, the most dis-
,
!
turbing aspect of this problem is that management action to take
effective corrective measures was not apparent.
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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Specifically, an Environmental Review Board failed to audit required
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reports, calibration procedures for meteorological sensors were not
followed, and quality control samples were not sent to the vendor
!
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 requirements.
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.
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 licensee.
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 program.
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
papers.
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.
l
.
. . . -
-.
- - - . .
.. - - . _- . _ _ = _ _ - _ - - . _ -
.
14
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 SALP.
2.
Conclusion:
Rating:
Category 2.
Trend:
Consistent.
,
3.
Board Recommendation:
Licensee: Conduct a comprehensive management review of the ALARA
program and implement the changes necessary to achieve
an ef fective program.
NRC:
Continue normal inspection efforts eith special emphasis
on the implementation of the ALARA program.
1
(
F'
.
15
C.
Maintenance and Modifications (314 hours0.00363 days <br />0.0872 hours <br />5.191799e-4 weeks <br />1.19477e-4 months <br />, 18%)
1.
Analysis
'
The previous SALP rated maintenance as Category 1.
In a separate
analysis area, modification activities were rated as Category 2.
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 action.
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
period.
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
performed.
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 system.
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 outage.
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-
zation.
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
maintenance activities, this maintenance error was judged to be an
isolated case.
- -
-
-
-
- - -
-
- . -
-
-
-
- -
-
-
r
.
.
16
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 positions.
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 program.
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 instances.
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 related.
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-
tion.
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 identified.
The backlog in and inadequate documentation of maintenance activi-
ties continued to be weaknesses.
Also, problems with the implemen-
tation of modifications were noted.
.
.
17
2.
Conclusion
Rating:
Category 2.
Trend:
Consistent.
3.
Recommendations:
Licensee: Provide effective management attention to the new modifi-
cation control process to assure that it is understood
and properly implemented at all levels.
NRC:
None.
i
l
t
l
I
.
.
18
D.
Surveillance (230 hours0.00266 days <br />0.0639 hours <br />3.80291e-4 weeks <br />8.7515e-5 months <br />, 13%)
1.
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 noted.
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 identified.
Several nuclear instrument problems were identified early in this
period.
Accelerated testing, troubleshooting and repairs were suc-
cessful in eliminating them.
inspector discussions with licensee technicians found them to be
competent, knowledgeable of procedures, and conscientious in the
implementation and evaluation of surveillance results.
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
commitment.
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 failures.
l
.
.
/
~13
NRC inspection of previous CLRT activities identified weaknesses
including the quality of Type A test techniques and the responsive-
ness to previous NRC inspection findinge,.
The licensee made efforts
,
to formalize CLRT activities among its units and centralize the CLRT
'
,
program under a governing corporate level procedure.
NRC observa-
tion of CLRT activities shortly after the end of this assessment
i
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 1985.
The licensee position submitted on December 23, 1985,
restated previous positions which did not resolve the existing dis-
crepancies with 10 CFR 50 Appendix J.
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 actions.
2.
Conclusion
Rating:
Category 2.
Trend:
Consistent.
3.
Board Recommendation
Licensce: Complete the ongoing surveillance upgrade program.
NRC
None.
,
i
_
_
_
_. . _ _
_ _ . . .
- . . _
._
,___m
. _ _ _ .._,. -
.
20
E.
Emergency Preparedness (166 hours0.00192 days <br />0.0461 hours <br />2.744709e-4 weeks <br />6.3163e-5 months <br />, 9%)
1.
Analysis
The previous SALP rated this area as Category 2.
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, 1984.
)
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 exercise.
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 adequately.
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 system.
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
'
'
'
'
j
.
'
,
,
.
.
/
1
'
-
.
l
,
21
,
,
f
"g
the class]fication may' carry with it inappropriate sheltering or
i
evacuation recommendations.
Resolution of these discrepancies re-
-
quires coordination at all emergency,' centers, which could either
'
delay event classification or result in overly conservative PARS.
s
,
~
'
No' actual events during this assessment period required the imple-
mentation of the Emergency Program.
Inspector observation of oper-
ational occurrences such as plant trips and a February 1986 dropped
fuel' element event identified appropriate operator response, prompt
2
'l
.
management support, and safe and conservatively planned recovery
activities.
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 organization.
'
The< storm passed through the area without any significant damage
.
to plant systems.
No deficiencies in emergency plan activities were
noted by onsite N,RC observers.
'
,
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 occurrences.
_
2.
Conclusion-
Rating:
Category 2.
Trend:
Consistent.
3.
Board Recommendation
Licensee: Complete the installation of the hard-wired data transmis-
sion system, and review the effectiveness of automatic
protective action recommendations.
NRC:
None.
,
H
e
,
- m
.~,
-
,
_ . _ _ _ _ _ ,, . , - - .,
,
y
_ . .
, ,
y,_,,
.
.
.
,
.
22
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%)
1.
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 period.
No violations were identified.
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 organization.
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 effective.
Records are well maintained and available.
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 1985.
These improvements demonstrate the licensee's continuing support
of the program.
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 program.
Im-
provements to barriers, detection aids, and duress procedures have
been implemented as a result.
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 comprehensive.
_ __.
.
.
-
..
,
.
.
.
.
23
,
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 high.
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 pride.
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.
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 clarity.
With regard to material control and accounting practices, the lic-
ensee was in compliance with NRC requirements.
Procedures and prac-
tices were adequate for the control of special nuclear material.
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 programs.
Security continues to be a noteworthy licensee strength, because
of managocent support for program improvements, aggressive self
evaluation, and prompt and effective preventive / corrective actions.
2.
Conclusion
Rating:
Category 1.
Trend:
ConsistenL
.
3.
Board Recommendation
Licensce: None.
NRC:
None.
.
I
?
e
j
>
r
-,
,
-
-.4
-
..
.
- - -
,-
+- ,
.
- . ..
24
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%)
1.
Analysis
Previous licensee performance in refueling and outage activities
has been Category 1.
During this period, a planned 8-week refueling
,
outage began on January 4, 1986.
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 days.
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 event.
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
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 outage.
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 activities.
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 outage.
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.
,
.
-.
.,.,.r
.
. , . . . - , . . - .
c ..
-
,,y,,
, . - .
p
--.4-,
. ,,+.-
-.
-
.
.
,
.
25
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.
,
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 B.
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 team.
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 oversight.
2.
Conclusion
Rating:
Category 2.
Trend:
No Basis.
3.
Board Recommendations
Licensee: Commit additional attention to the pre planning of outage
activities, especially design changes.
NRC:
None.
.
..
.
_ __- _ -
. . -
. - .
-
-
_ _ _ _ _ _ _
.
.-
- - ,
-
.
.
,
.
26
H.
Assurance of Quality
1.
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 areas.
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 is.
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 areas.
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 recurrence.
Control of fire barriers, missed surveillances, and inadequate ALARA
controls were examples.
QA audited activities in accordance with department schedules.
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 process.
.
_
l
'
.
,
27
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 satisfactory.
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-
ment.
-2.
Conclusion
'
Rating:
Category 2.
Trend:
Consistent
3.
Board Recommendations
Licensee: Reevaluate the effectiveness of systems for self-
identification and resolution of problems.
NRC:
None.
- -
-
_ ,.
-
.
.
.
,
.
28
I.
Training and Qualification Effectiveness
1.
Analysis
During this assessment period, Training and Qualification Effective-
ness is being considered as a separate functional area for the first
time. Training and qualification effectiveness continues to be an
evaluation criterion for each functional area.
,
.The various aspects of this functional area 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 adequacy.
The discussion below addresses three principal areas: licensed
operator training, non-licensed staff training, and the status of
INPO training accreditation.
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-
ing programs had been accredited by INP0, the licensee had reas-
4
sessed the program goals and milestones to establish a " ready for
accreditation" status in all operator, staff, and technician-pro-
-
grams before the end of 1986.
No new operator license examinations were given during this period.
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-1986.
.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
-
w
m
t-
=r
-
w,
w r w-
w -
w-
ww
ey
pe-
_
.
.
,
.
29
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 areas.
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 exam.
The licensee responded adequately to
this event by implementing more comprehensive examination controls
for all training programs.
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
areas.
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 requirements.
These reflect negatively on the quality of training in these areas.
2.
Conclusion
Rating:
Category 2.
Trend:
Consistent.
3.
Board Recommendations.
Licensee: Reorient technical training programs to address weaknesses
identified in the functional areas.
NRC:
None.
,
,.
_ . - , , - , - , . ,
- - - - ,
, . . . -
- . , . .
'
.
,
30
J.
Licensing Activities
1.
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 actions.
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
-
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 added.
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-
port.
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 conversion.
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-
-
.
i
31
timeliness of the supporting technical material for the above ap-
,
plications created a significant burden on the staff to complete
the required licensing reviews to support the scheduled startup date
'
of March 4, 1986.
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 outage.
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 periods.
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 issue.
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 positions.
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-
planning.
2.
Conclusion
Rating:
Category 2.
Trend:
Declining.
3.
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 closure.
NRC:
None.
i
'
-
.
32
V.
SUPPORTING DATA AND SUMMARIES
A.
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 action.
The licensee upgraded their examination administrative controls to cor-
rect the deficiency and close out the allegation.
The individuals in-
volved passed a subsequent reexamination.
B.
Escalated Enforcement Actions
1.
Civil Penalties
There were no civil penalties issued during this assessment period.
2.
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 equipment.
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 outage.
3.
Confirmatory Action Letters
There were no confirmatory action letters issued during this as-
sessment period.
C.
Management Conferences
1.
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 reviews.
2.
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 deficiencies.
.
.
33
D.
Licensee Event Reports
1.
Tabular Listino
Type of Events:
A.
Personnel Errors
14
B.
Design / Man./Const./ Install
5
C.
External Cause
0
D.
Defective Procedure
2
E.
Component Failure
14
X.
Other
2
Total
37
LERs Reviewed
LER No. 85-03 to 86-09
2.
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
a.
control problems caused by personnel errors.
b.
LERs 85-12, 85-23 and 86-07 reported missed fire protection
system surveillance tests due to personnel errors.
c.
LERs 85-04, 84-12 and 86-06 report failures of containment
penetration local leak rate tests during three consecutive
surveillance cycles.
d.
LERs 84-28 and 86-02 reported main steam safety valve setpoint
drift problems.
e.
LERs 85-5 and 85-24 reported auxiliary feedwater system actu-
ation problems caused by sticking solenoid-operated actuation
valves.
f.
LERs 84-10 and 86-04 reported problems with operability of the
low pressure overpressure protection system.
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 failures.
-.
.
-
.
--
- _ -
>
.
.
,
.
,
34
i
!
E.
Operating Reactor Licensing Actions
1.
Schedular Extensions Granted
March 28, 1985; Extended the deadline for environmental qualifica-
.
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
Procedures (E0P) at the Haddam Neck Plant to September 1, 1986.
,
2.
Reliefs Granted
,
June 10, 1985; Relief granted from requirements of Section XI of
ASME Boiler and Pressure Vessel Code for volumetric examination
r
of reactor coolant pump casing welds.
3.
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).
.
November 22, 1985; Conditionally extended the April 11, 1985 (FDSA
l
upgrade) to June 30, 1987, provided specified milestone FDSA sub-
mittals are met.
'
l
4.
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-
,
l
creasing power.
!
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 Order.
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
Specifications to add new Limiting Conditions for Operations and
i
l
Surveillance requirements for Post-Accident Instrumentation.
!
!
- . -
.
.
. _.
- - -
- - - -
.
-. - - . - - .--
'
.
.
35
,
Amendment No. 67 issued on September 3, 1985, modified Technical
Specifications to change discharge pressure requirements for Emer-
gency Core Cooling System (ECCS) pumps.
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 Specifications.
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 pint.
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
rates.
Amendment No. 71 issued on December 10, 1985, revised Technical
Specifications to include restrictions on the excessive use of
facility staff overtime.
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).
..
.
.
,
.
TABLE 1
TABULAR LISTING 0F LERs BY FUNCTIONAL AREA
HADDAM NECK PLANT
AREA
NUMBER /CAUSE CODE
TOTAL
A.
Plant Operations
7A
3B
6E
2X
18
B.
Radiological Controls
none
C.
Maintena.;te & Modifications
2A
2
D.
Surveillance
5A
2D
8E
15
E.
none
F.
Security and Safeguards
none
G.
Refueling and Outage Management
none
H.
Quality Assurance
none
I.
Training
none
J.
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
--
-- _
.
- -
-
-
-
-
. _. -
.
..
..
.
. . -
-
. . -
-
- - - - - .. __-
.
-
.
, .
TABLE 2
'
LER SYN 0PSIS
HADDAM NECK PLANT
LER No.
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
~
85-7
Plant Trip due to Feedwater Recirculation Valve
Failed to Open
1
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 85-12
Failure to Perform Fire Detection Surveillance
'
85-13
Misaligned Rod Analysis
85-14
Inoperable Fire Door
Spurious Load Runback
85-15
-
85-16
NIS Dropped Rod Setpoint Drift
85-17
Post LOCA Release Paths Outside Containment
85-18
Inoperable Fire Door
-85-19
Spurious Load Runback
p
85-20
Potential Unauthorized Access to a High Radiation Area
,
85-21
Cable Spreading Area Fire Barrier Problems
85-22
85-23
Missed Fire Protection Surveillance Test
,
4
.
1
w
s
e -
evw-,-
w, , - - - . , e
-
w,-
,-ww
e-
r-
- --
--
---v
,r-,-
wm- . , - .w
--
- - - -
-,e
-ns
.
- . ,
,
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
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
.
.,
.
.
TABLE 3
INSPECTION HOURS SUMMARY
HADDAM NECK PLANT
HOURS
% OF TIME
A.
Plant Operations . . . . . . . .
425
24
...
B.
Radiological Controls
393
22
.........
C.
Maintenance & Modifications
314
18
......
0.
Surveillance . . . . . . . . . . . . . .
230
13
E.
Emergency Preparedness . . . . . . . . .
166
9
F.
Security and Safeguards
79
5
........
G.
Refueling & Outage Management
151
9
.....
H.
Quality Assurance
-
-
...........
I.
Training . . . . . . . . . . . . . . . .
-
-
J.
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 area.
Consequently, inspection hours
for Quality Assurance and Training are included in the other respective
areas.
_
.. . - - - - -
. . - -
, _ _ . . . . .
_._
.
.
. . . . . . _ _ . _ - . . . _ . .
.
._
m
.- _. . _
-
.
,
'.,%
d
TABLE 4
-
ENFORCEMENT SUMMARY
HADDAM NECK PLANT
,
Severity Levels
FilNCTIONAL AREAS
I -II
III
IV V DEV
Total
A.
Plant Operations
3
3
.
B.
Radiological Controls
2
1
3
C.
Maintenance & Modifications
1
2
3
D.
Surveillance
E.
.
F.
Security Safeguards
,
'
G.
Refueling & Outage Management
H.
Quality Assurance
I.
Training
J.
Licensing Activities
.
Totals by Severity Level
6
3
9
.
A
1
-er.-
- - , - - , - , , _ , . -
. ~ , . , - - - , . - - - = - - - - , - ~ - -
,
--
-, -
,- -
w---
-- , - ,
, - - . , -
~ , _ ,
-
,
_
I
-
.
I
,
TABLE 5
ENFORCEMENT DATA
HADDAM NECK PLANT
Inspection-
Inspection
Severity Functional
Report No.
Date
Level
Area
Violation
85-08
3/15-29/85
V
B~
Inadequate scope of environmental
audit program.
85-09
4/8-12/85
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 missed.
85-15
6/14-26/85
IV
A
Onsite review committee failure
to identify that a required TS
change was missed.
85-21
10/16-12/02/85
IV
A
Failure to follow procedures
(multiple instances).
85-21
10/16-12/02/85
IV
A
Inadequate corrective action for
previous violations.
86-01
1/9-2/6/85
V
C
Inadequate processing of modifi-
cation field changes.
86-01
1/9-2/6/86
V
C
Inadequate test plan for a plant
modification.
86-02
2/10-14/86
IV
B
Failure to compact radwaste in
accordance with an approved
procedure.
'
.
.,
-
.
TABLE 6
INSPECTION REPORT ACTIVITIES
HADDAM NECK PLANT
Inspection
Inspection
Areas
Report No.
Hours
Inspected
85-04
96
Radiological Controls
85-05
8
Management Meeting (Surveillance)
85-06
166
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
,
.
,
T-6-2
Inspection
Inspection
Areas
Report No.
Hours
Inspected
85-25
113
Routine Resident
86-01
206
Routine Resident
86-02
70
Radiological Control
.
86-05
40
Quality Assurance
,
1
,
'
l
-
.
.
,
1
s-
,
TABLE 7
PLANT SHUTDOWNS
HADDAM NECK PLANT
Shutdown Period
Description
Cause
March 12, 1985
Scram from 50% power.
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%
power.
March 16, 1985
Manual scram due to a main feedwater
Equipment Failure
pipe rupture.
The reheater drain pump (design-related)
flow control valve directed flow
against the pipe wall causing signifi-
cant erosion of the pipe.
May 16, 1985
Manual scram due to two dropped con-
Equipment Failure
trol rods.
(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 signals.
by a design deficiency /
abnormal operating
November 21, 1985
Scram due to spurious high main steam
conditions -- lower
flow signals.
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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1
ENCLOSURE 3
.
,
.
NORTHEAST UTILITIES
c,eme,& omces . smen som ee~n cemnecocut
T
P O BOX 270
. . . . . .
. . . .
'~
. . . . . . . . . . ~ . .
.
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
Company (2)(NNECO) on June 4, 1985, Northeast Utilities (NU) submitted a
response
to the SALP Board recommendations for each of the individual
evaluation categories.
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, respectively.
(I)
T. E. Murley letter to J. F. Opeka, Systematic Assessment of Licensee
Performance (SALP), dated May 20, 1985.
(2)
J. F. Opeka letter to T. E. Murley, Systematic Assessment of Licensee
Performance, dated July 5,1985.
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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 issues.
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 personnel.
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 matters.
Very truly yours,
,
CONNECTICUT YANKEE ATOMIC POTER COMPANY
NORTHEAST NUCLEAR ENERGY COMPANY
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3 p f peka
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Senior Vice President
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By: W. F. Fee
Executive Vice President
cc:
C. I. Grimes
A. C. Thadani
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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:
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(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:
_
(A)
Increased management concern for self appraisal and self identification
programs has resulted in an upgrading of several existing programs.
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 mechanism.
The Nonconformance Control Reporting system is functionally sound, but
at times a backich exists due to overall workload. Quality Assurance (QA)
'
reviewers have b en instructed to put greater emphasis on ensuring that
9
cause and corrective actions are adequately addressed.
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
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1986, and the use of QA surveillances to review field activities has been
increased.
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The Beneficial Suggestion program has been very successful, with
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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 Safety.
An evaluation of required resources to handle the large quantity of
suggestions wil: 50 performed af ter the 1986 refueling cutage.
The RaWe f cX Incide5t Report procedure has been upgraded and includes
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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 taken..
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The Station Housekeeping and inspection Program was expanded to include
department heads performing periodic inspectiorc. ~
(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,1986.
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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, 1986.
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,1986.
Annunciator response procedures for all applicable control room alarms
have been completed.
(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 evaluated.
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Lunctional Area: RADIOLOGICAL CONTROLS
Board Recommendatio ts:
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(A)
Efferis should be made to strengthen management oversight and
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intradepartmental communications.
An effective system for evnluating
and correcting self-identified deficiencies should be developed.
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(B)
The Ikensee should expedite efforts to seek a Techr.ical Specification
Amendment for PASS containment isolation valves to allow resumption of
full system surveillance.
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,
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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 field.
(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 (1pility.
as Amendment No. 72 to Facility Operating License No.
DPR-61 on February 19,1986.
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(1)
F. M. Akstulewicz, Jr. letter to J. F. Opeka, Technical Specifications to
Permit
Testing
of
the
Post-Accident
Sampling
System,
dated
February 19,1986.
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Functional Area: SUR VEILL ANCE
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Nard Recommendations:
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(A)
Continue initiatives to upgrade surveillance procedures.
(B)
Improve management control over items like CLRT issues in order to
assure that resolution is not unduly delayec.
UPDATE:
(A)
A previously existing initiative to upgrade the surveillance program is on
schedule and is expected to be completed in June,1986.
(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 10,1985.
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
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all NUSCO and -CYAPCO engineering responsibilities and logistical
activities necessary to conduct the ILRT.
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,1986.
(2)
J. F. Opeka letter to T. E, Murley, Haddam Neck - 10CFR50, Appendix 3
Compliance, dated December 23,1985.
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Functinnal Area: FIRE PROTECTION / HOUSEKEEPING
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poard Recommendations:
(A)
Maintain attention to fire barriers.
(B)
Discuss with NRC the status of findings and corrective actions related to
the Appendix R implementation program.
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 doors.
(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 identified.
Eight 1985(4) exemption requests were
new
subsequently filed on September 16,
which incorporated the
recommendations of the comprehensive review and the guidance provided
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 areas.
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 18,1934.
(4)
3. F. Opeka letter to H. L. Thompson, Fire Protection, dated September 16,
1985.
(5)
3. F. Opeka letter to C.1. Grimes, Fire Protection - Schedular Exemption,
dated March 7,1986.
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Functional Area: EMERGENCY PREPAREDNESS
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Board Recommendations:
(A)
Continue efforts to improve the coordination of emergency response
activities.
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 area.
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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 effort.
UPDATE:
.
(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)
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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 (o( the CYPDCTG were submitted to the NRC on
November 6, 1985. 81
NUSCO Quality Assurance conducted a review of the coverage and
effectiveness of quality control surveillance activities at Connecticut
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Yankee during October,1985.
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 testing.
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 observed.
(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 13,1984.
(7)
D. E. Vandenburgh letter to T. E. Murley, Connecticut Yankee Plant Design
Change External Review Group Final Report, dated September 6,1985.
(8)
3. F. Opeka letter to T. E. Murley, Haddam Neck Plant Response to
December 13, 1984 Order Modifying License, dated November 6,1985.
.
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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 performance.
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Functional Area: LICENSING ACTIVITIES
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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 power.
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,1986.
(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 No.
DPR-61 on February 19,1986.
(9)
3. F. Opeka letter to T. E. Murley, Haddam Neck - 10CFR, Appendix 3
Compliance, dated December 23,1985.
(10)
T. T. Martin letter to W. G. Counsil, inspection Report No. 50-213/84-13,
dated October 17,1984.
(11)
F. M. Akstulewicz, Jr. letter to 3. F. Opeka, Technical Specifications to
Permit Testing
of
the
Post-Accident
Sampling
System,
dated
February 19,1986.
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Docket No. 50-20 5
BI1979
Attachment 2
Northeast Nuclear Energy Company
Millstone Unit No.1
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 requirements.
(B)
Upgrade adherence to routine radiation protection requirements by
individual workers.
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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 procedures.
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 training.
New
employees who are potential radiation workers must take Level 1
Radiation Worker Training to receive in-depth instruction on specific
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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 controls.
Employees are also required to demonstrate proper entry / exit
to/from
a Radiologically Controlled Area including reading
comprehension, and adherence to an RWP.
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 areas.
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Functional Area: SUR VEILLANCE
Board Recommendation:
(A)
Upgrade QA of critical surveillance testing such as containment integrated
leak rate testing.
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 ILRTs.
Nuclear Engineering and Operations Procedure, NEO 2.20, Containment
Leakage Rate Testing Program, was issued on December 10, 1985.
1-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 areas.
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Functional Area: FIRE PROTECTION / HOUSEKEEPING
Board Recommendations:
(A)
Address the cluttered yard condition.
(B)
Resolve Appendix R implementation.
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 capability.
In addition, the area near the Unit I transformer yard has been cleared of
all stored material.
(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 identified.
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.(
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Hardware modifications which are norFoutage related are scheduled to be
completed by August 6,1986 in accordance with 10 CFR 50.48 schedwes.
Implementation of the outage related work is scheduled for the '987
ref ueling outage.
(1)
W. G. Counsil letter to R. H. Vollmer, Appendix R Evaluation Status, dated
June 18,1984.
(2)
3. F. Opeka letter to H. L. Thompson, Fire Protection, dated November 21,
1985.
(3)
Conference Call between NUSCO and the NRC Staff on January 27,1986.
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Functional Area: EMERGENCY PREPAREDNESS
Board Recommendation:
(A)
Evaluate measures f or assuring timely completion of action items.
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 10,1985.
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Functional Area: REFUELING AND OUTAGE MANAGEMENT
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Board Recommendation:
(A)
Improve self-assessment to identify items such as f ailure to follow through
on commitments and design modifications.
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
commitments.
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 heads.
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Functional Area: LICENSING
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Board Recommendations:
(A)
Improve management of licensing activities to avoid late responses.
(B)
Improve coordination of activities with NRR in regard to schedule,
prioritization, and project status.
.
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 deadline.
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
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reviewing.
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. 1.
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 ISAP.
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Meetings on the Millstone Unit No. I Provisional to Full Term Operating
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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 Staff.
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Dgeket No. 50-336
B11979
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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 certifications.
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 process.
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Functional Area: RADIOLOGICAL CONTROLS
Board Recommendations:
(A)
Continue recent emphasis on improving radioactive material transportation
controls.
(B)
Assure better adherence to radiation protection procedures by workers.
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 group.
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 1,1985.
(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 procedures.
'
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
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 controls. Employees are also required to demonstrate proper
entry / exit to/from a Radiologically Controlled Area including reading
comprehension, and adherence to an RWP.
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 areas.
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Functional Area: FIRE PROT.ECTION/ HOUSEKEEPING
Board Recommendations:
(A)
Address the cluttered yard condition. Upgrade housekeeping in areas noted
as candidates for improvement.
(B)
Resolve Appendix R implementation.
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 repainted.
The safeguards pump rooms have been cleaned and the wall in the "A" room
has been repaired.
(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 identified.
Ten new exemption
requests were subsequently drafted and are currently mdergoing internal
review. The new exemption requests are scheduled to be submitted to the
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NRC
in April,
1986.
The exemptions have incorporated
the
recommendations of the comprehensive review and the guidance provided
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
SER.
(1)
W. G. Counsil letter to R. H. Vollmer, Appendix R Evaluation Status, dated
June 18,1984.
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[unctional Area: EMERGENCY PREPAREDNESS
'
Board Recommendation:
(A)
Evaluate measures f or assuring timely completion of action items.
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 10,1985.
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Functional Area: LICENSING
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Board Recommendations:
(A)
Improve management of licensing activities to avoid late responses.
(B)
Improve coordination of activities with NRR in regard to schedule,
prioritization, and project status.
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 deadline.
(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
,
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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,
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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
.
9
March,1986
a
c
,
.,
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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 desired.
in April,1985 in order to f acilitate an orderly transfer of a senior
o
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 period.
in May,1985 we met with the Staff to discuss IGSCC inspection plans and
o
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
outage.
One of the elements of our corporate strategy regarding steam generators
o
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 groups.
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
program.
in August,1985 we entertained a one-week visit by staff personnel from
o
the 1.icense Qualification Branch, Division of Human Factors Safety and
provided information on our Production Maintenance Management System.
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."
in August,1985, at the request of the Director of the Office of Inspection
o
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,
in September,1985 we entertained a visit by the Brookhaven Reliability
o
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
Surveillance Program. The resulting OSRR Project Team report noted that
,
reliability activities at NU " appear to have strong management support and
z
y
.
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
Program.
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
Plant.
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 Force.
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 issue.
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 statement.
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1
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