IR 05000293/1985099
| ML20198H121 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/23/1986 |
| From: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Harrington W BOSTON EDISON CO. |
| References | |
| CON-#487-5029 2.206, NUDOCS 8605300124 | |
| Download: ML20198H121 (4) | |
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MAY 2 31986 Docket No. 50-293 Boston Edison Company M/C Nuclear ATTN: Mr. William D. Harrington Senior Vice President, Nuclear 800 Boylston Street Boston, Massachusetts 02199 Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP)
Report No. 50-293/85-99 This letter refers to the Systematic Assessment of Licensee Performance (SALP)
of the Pilgrim Nuclear Power Station for the period of October 1, 1984 through October 31, 1985, initially forwarded to you by our February 18, 1986 letter (Enclosure 1). This SALP evaluation was discussed with you and your staff at a meeting held in Plymouth, Massachusetts on March 5, 1986 (see Enclosure 2 for attendees). We have reviewed your March 26, 1986 written comments (Enclosure 3)
and herewith transmit the final report (Enclosure 4).
Overall, your performance in the operation of the facility was found acceptable although some areas were only minimally acceptable.
As projected in our letter of February 18, 1986, a special in-depth team in-spection was conducted from February 18 to March 7, 1986 (Inspection Report No. 50-293/86-06) to determine the underlying reasons for the poor performance discussed above. The team found that improvements were inhibited by (1) incom-plete staffing, in particular operators and key mia-level supervisory personnel, (2) a prevailing view in the organization that the improvements made to date have corrected the problems, (3) reluctance, by management, to acknowledge some
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problems identified by the NRC, and (4) dependence on third parties to identify problems rather than implementing an effective program for self-identification of weaknasses. We believe these findings confirmed the SALP Board conclusions.
We acknowledge your discussion of program and staffing improvements in plant operations, radiological controls and emergency preparedness. However, we believe th&L the success of your programs depends upon resolution of the four principal factors inhibiting improvement noted above which, in turn, depends heavily on n.anagement attitudes and aggressive followup. In this regard we request that you be prepared to discuss the scope, content and schedule of each improvement progran at a management meeting scheduled for 1:00 p.m. on June 12, 1986 at the NRC Regfon 1 Office.
8605300124 660523 3 DR ADOCK 0500 CFFICIAL RECORO COPY 26200ERFLEIN4/25/86 - 0001.0.0 05/22/86 ,4
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Boston Edison Company 2 The purpose of such discussions will be to better understand how BEco manage-ment is monitoring the programs and the milestones that have been established.
This meeting is the first of a series of periodic management meetings which will continue until it is clear to me that (1) your schedules are being met (2) real progress is being achieved and (3) it is highly likely that such progress will continue.
Sincerely, Origina1 Signed by Thomas E. MurleY Thomas Regional Administrator
Enclosures:
1. NRC Region I letter, to W. Harrington, February 18, 1986 2. SALP Meeting Attendees, March 5, 1986 3. BECo Letter, W. Harrington to T. Murley, March 26, 1986 4. SALP - Final Report
REGION I 631 PARK AVENUE
% . . . . ,o# KING OF PRUSSIA, PENNSYLVANIA 19 06 Docket No. 50-293 Boston Edison Company M/C Nuclear ATTN: Mr. William.D. Harrington Senior Vice President, Nuclear 800.Boylston Street Boston, Massachusetts 02199 Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP) Report No.
50-293/85-99 The Region I SALP Board has reviewed and evaluated the performance of activities at the Pilgrim Nuclear Power Station for the period October 1,1984 through October 31, 1985. The results are presented in the enclosed report. A meeting to discuss this assessment has been scheduled for 1:00 p.m. on March 5,1986.
The meeting is being held ori site so that appropriate senior corporate management and plant officials can discuss with us the strengths and weaknesses noted. It is our intent that the n:eeting provide a forum for a car:did. exchange. of views.
. We have found the 'overall perforraance at the Pilgrim Station to be acceptable
'during the 'recent assessment period. The steady upgradine of plant hardware has been noteworthy during this period. Notwithstanding these hardware improvements, there are areas.such as operations, maintenance, radiological control' sand emergency preparedness where marginal performance is of concern to NRC. During its review, the SALP Board found a recurrent theme of inadequate personnel staffing and inadequate supervisory oversight at the plant. A special concern we have is with regard to the chronic shortage of licensed reactor operators and the routine exceeding of NRC overtime guidelines.
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The enclosed review of SALP history for Pilgrim shows a pattern of performance that raises other questions. ' For instance, the areas .of operations and
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radiological centrols have shown essentially no improvement over the years.
In other areas, such as maintenance, surveillance and . emergency preparedness, there have been improvements followed by a slippage back to the lower level of performance in later ye,ars. This inability to improve performance, or sustain improved performance once achieved, is of concern to us, and we would like to discuss your views on the reasons for this.
In order to better understand the nature of your on-site efforts, we are conducting an in-depth team inspection. One of our objectives is to attempt to determine the underlying reason (s) for the poor performance discussed above and to ascertain whether or not they could have an adverse impact on the safety of plant operations. Likewise, the results of this inspection will be used to assess whether your corrective action programs are properly structured and focused to achieve the desired improvements.
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, Boston Edison Company N/C Nuclear 2 FEB 1 6 886 In preparation for the SALP meeting, please be prepared to discuss your evaluation of the situation. For the areas rated as Category 3, we request your comments in writing within 30 days of receipt of this letter. After the meeting and upon receipt of your response, your comments will be evaluated and we will provide you our conclusions relative to them after consideration of our results from the team inspectibn.
Sincerely, f f LC 0 Thomas Regional Administ Enclosures:
1. SALP Report 50-293/85-99 2. Pilgrim SALP History CC-W/enCI:
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' A. V. Morisi,-Manager, Nuclear Management Services Department C,. J. Mathis, Station Manager .
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Joanne Shotwell, Assistan.t Attorney General ,
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Paul Levy, Chairman, Department of'Public Utilities
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W. F. Nolan, Chairman, Plymouth Board of Selectmen ~
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Plymouth Civil Defense Director -
5enator Edward P. Kirby ,
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- Publ'ic Document Room (POR) -
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident inspector ,
Commonwealth of Massachusetts (2)
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bcc w/ encl:
Region 1 Docket Roon (with concurrences)
Management Assistant, DRMA (w/o er.ci)
DRP Section Chief
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T. Shediosky, SRI, Millstone 1&2 i H. Eichenholz, SRI, Yankee
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P. Leech, LPM, NRR O. Holody, RI J. Taylor, IE o
i SALP Board Members ! K. Abraham i
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Enclosure 2
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Meetigg_Attegdees M95t90_Edisgg_Cgepany S. J. Sweeney President and Chief Executive Officer #
W. D. Harrington Sr. Vice President J. P. Tyrrell Executive Vice President J. M. Lydon Executive Vice President J. E. Howard Vice President A. L. Oxsun Vice, President H. F. Brannan Quality pssurance Manager R. N. Swanson Nuclear Engineering Manager A. V. Morisi Assistant Director, Cutage Management C. J. Mathis Nuclear Operations Manager P. E. Mastrangelo Chief Operating Engineer E. Ziemianski Management Services Section Manager M. N. Broseo Maintenance Section Manager T. Sowdon Radiation Section Manager R. E. Silva Emergency Preparedness Coordinator D. J. Cronin Nuclear Material Services Manager B. Eldridge Chief Radiation Engineer J. A. Seery Technical Section Manager R. Sherry Chief Maintenance Engineer
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J. A. Kane Senior Radiation Engineer J. D. Keyes Regulatory Affairs Group Leader D. Sukanek Station Services Group Leader E. Graham Compliance Group Leader M. Pyle Radiation Protection Training Coordinator T. Sollenberger Radiation Protection / ROR*s C. Gustin Public Information R. Tin Public Information D. A. Mills CMGL C. Smith Hydro-Nuclear Services J. Crockford Patriot-Ledger F. Creane Enterprise Nogl ggt _Regul a t oty_Ggemi ssi gn T. Regional Administrator, Region I R. W. Starostecki Director, Division of Reactor Projects (DRP)
R. Vollmer Deputy Director,0ffice of Inspection and Enforcement T. T. Martin Director, Division of Radiation Safety and Safeguards W. F. Kano Deputy Director, DRP J. A. Zwolinski Project Director, Offico of Nucicar Reactor Regulation (NRR)
E. C. Wenzinger Chief, Projects Branch 3,DRP L. E. Tripp Chiuf, Projects Section 3A,DRP i
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Meeting _6ttgodees_1ggatidt J. R. Strasnider Chief, Projects Section 18,DRP P. H. Leech Project Manager, NRR M. H. McBride Senior Resident inspector R. L. Nimitz Senior Radiation Specialiat
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CCOTCM EEIOCN CEMPANY Enclosure 3 MOD CovLaTow CTast?
. sooTow. MassacMuervis 0219 9 ,
WILLGAM O. MARmlNGTO N
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March 26,1986 BEco Ltr # 86-037 Dr. Thomas Regional Administ-stor U.S. Nuclear Regulatory Comission Region 1 - 631 Park Avenue King of Prussia, PA 19406 License DPR-35 Docket 50-293 Response to Systematic Assessment of Licensee Performance (SALP) Report No. 85-99. Dated February 18. 1986
Dear Dr. Murley:
In accordance with your request to provide coments in writing for the functional areas rated as Category 3 in the subject report, please find our comments in the enclosure to this letter.
We appreciate the opportunity af forded to us at the SALP meeting of March 5, 1986, to exchange views candidly. We alzo appreciate acknowledgement of the numerous licensee strengths as noted within the SALP Report. We fully intend to strengthen our processes related to critical self-assessment and timeliness of corrective action. The resources of the Company will continue to be applied to whatever degree necessary such that Boston Edison can achieve and j sustain the performance objectives which have been established by the nuclear industry. We welcome continued input from the NRC.
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l l Should you have any questions or coments regarding this letter, please do not hesitate to contact me.
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Sincerely, I
W.D. Harringt i Enclosure i
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ENCLOSURE
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A. PLANT OPERATIONS Licensed Operator Staf fina/ Training At various meetings with the NRC, Boston Edison had previously agreed that staf fing levels'of lice'nsed reactor operators are substantially below that which are desired. Boston Edison agrees that continued management attention is required to prevent the operator shortage f rom becoming more acute. To that end several actions have already been
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implemented and others planned.
In December,1985, the Boston Edison nuclear training f unctions were reassigned to the recently established Management Services Section, the manager of which reports directly to the Nuclear Operations Manager.
This realignment was intended to allow the training functions to be even more in concert with the needs of the Station. In late January, 1986, the Operator Training Staf f within the training group was put under the direction of a more senior level, heavily-experienced, operations training individual. After careful consideration, and evaluation of the impact on the Operations Group it was decided to reassign one of our most highly knowledgeable licensed, senior reactor operators to assist in the management of the operator training functions. Working in conjunction with the Chief Operations Engineer, these individuals have revised *.he operator staf fing/ training plan with the objective of reducing the amount of time necessary to increase the number of licensed reactor operators while, at the same time, ensuring that the quality of the training program is not diminished. Initial emphasis has been placed on the tour
- qualification and continuing training portions of the program to ensure that the non-licensed nuclear plant operators are highly knowledgeable and productive while completing their on-watch time as a prerequisite to the hot-license portion of the program.
Recruiting ef forts have also been revamped as evidenced in the Company's ability to staf f ten positions (as mentioned in the SALP report) with a number of degreed and/or Navy nuclear-experienced personnel. Worthy of #.
mention also is the rigorous screening process used for candidate selection which, among other things, includes interviews by two independent review boards composed of senior level Station operations and training personnel.
The results of the recruiting and screening ef forts coupled with concurrent accreditation ef forts have provided Boston Edison with a high degree of confidence that this class of license candidates will be of the highest quality possible. It is also our intent to monitor attrition levels closely and initiate timely re-staffing efforts to ensure that adequate numbers of candidates are in the training pipeline. Finally, as discussed with the NRC, Boston Edison management is in negotiations regarding an apprenticeship program which is intended to provide structured development not only for operators but also for various other functional disciplines associated with nuclear power plant operations.
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Regarding the concern of excessive overtime, we believe that one of the
primary contributors to cause was insuf ficient attention paid to ensuring that the authorizations to exceed overtime guidelines were properly documented. Notwithstanding the above, the shortage of licensed operators contributed significantly to the large number of overtime hours worked. Until such time as additional candidates are licensed, the Company has taken actions intended to result in a more balanced distribution of overtime for licensed operators. These actions include the recalling of two licensed reactor operators who had previously transf erred to other sections and a restructuring of the shif t rotation schedule. Finally, our tightened administrative controls should be more effective in preventing unauthorized overtime.
Professional Support Staffing Boston Edison has completed an assessment of operational support for the Operations Group and has determined that more direct technical support should be provided to the Chief Operations Engineer. The Company is currently assessing the optimal way to provide this support and expects to arrive at a conclusion in the next few weeks. It is believed that the subsequent actions, along with the hiring of the Operations Section Manager will better enable the group to address the operational program needs as well as day-to-day operation of the Station. This support will also enable the group to elevate the priority of responding to quality assurance findings. Upper management has taken, and will continue to take, a firm role regarding positive response to the quality assurance program.
B. RADIOLOGICAL CONTROLS Boston Edison concurs with the observation of an improving trend as noted by the NRC during the last quarter of the assessment period.
Notwithstanding this trend, it is recognized that aggressive management attention must continue in order to achieve the desired performance objectives in this important functional area.
Staffing /0versight l
As discussed previously with the NRC, Boston Edison has endountered substantial difficulties in staffing several key positions within the Radiological Section. As a result, the Company has contracted with an executive search firm to assist in attracting qualified candidates for not only radiological positions, but also several other functional
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positions. These staffing efforts will be vigorously pursued.
I Regarding oversight of radiological work, it is our intent to reduce our reliance on contractor personnel. We plan to limit to the extent possible the use of contractor technicians to augment our permanent staf f during heavy workload periods. We have also implemented a requirement within our Outage Management organization to conduct interdisciplinary critiques prior to starting significant tasks which have substantial radiological risks.
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Beyond the line f unction-oversight of radiological activities. upper
management is kept informed of trends through monthly Radiolgical Occurrence Reports and Performance Monitoring Reports, thus providing for independent oversight of management's overall performance against several key performance indicators. ;
Correcti_ve. Action _ System Boston Edison continues to strive for improvements in the Radiological Occurrence Report (ROR) process. The associated procedure has been upgraded to improve the qua'lity and promptness of corrective actions.
The function of the independent on-site assessor will be preserved using either a qualified contractor or a member of the Radiological section who reports to the Radiological Section Manager and the Radiological Oversight Committee. ROR's are now trended to show relative performance and are analyzed collectively to determine generic or repetitive problems. We are also keeping personnel informed of radiological occurrences and corrective actions by integrating the ROR process into the day-to-day reporting / communications at the daily plant staff meeting.
Program 1sprovement Boston Edison concurs that there is much work to do in improving the ALARA program and proc 6dures. We believe that the full effects of the '
Radiological improvement Plan (RIP) have not yet been felt and will take considerable ef fort and perseverance particularly until the key management positions are filled.
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Self assessment of ef fective implementation of RIP improvements is being determined through the Radiological Oversight Committee (ROC). The ROC is providing this function as specified in its charter and performing systematic and comprehensive assessments of Pilgrim's mandated Radiological Improvement Program (RIP) implementation. As of November 26, 1985. when the program elements were nearing completion, the ROC instituted an ef fectiveness assessment review of the RIP by identifying the 14 sujor areas for improvement and assigning teams of ROC members to assess the implementation and ef fectiveness of these program improvements . To date, nine (9) assessments have been concluded and findings reported to corporate management. Additional assessments are -
ongoing, and this progest ~will continue in this manner until all 14 areas
' have been assessed, evaluated, and found acceptable, or until recommendat' ions have been submitted for further improvement, *
C. N EMERGENCY PREPARED'ES2 Annual Emerqency Exercise ,
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Boston Edison concurs that radiological emergency organization personnel f ailed to dkmonstrate adequate or appropriate exposure control for the re-entry teams. We believe that improveme.ts n in the re-entry process ,
have been made and will be evident during the upcoming remedial drill scheduled for April,1986.
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Soston Edison also concurs that the relocation of the EOF perscnnel to
- the alternate EOF, is of sufficient importance and has been addressed in a formal procedure, i Emergency Exercise Critinue Boston Edison concurs that the 1985 exercise critique should have focused more heavily on the appar.ent lack of adequate tensideration of simulated radiological hazards encountered by the re-entry team. In order to 4 improve the criticue process we plan to include .ocre stringent "self critique * criteria, concentrating more on ef fectivenesss of the r incividual aspects of the exercise instead of just looking at the overall success criteria and believing that the exercise went well.
Emercency Preparedness Group Staf fino Regarding program staf fing, a new Emergency . Preparedness Coordinator was
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appointed and has been actively engaged in the progrart since January 1, 1986. Additlonally, a new position of Assistant Energency Preparedness Coordinator has been established and the position has been filled. The Environmental and Radiological Health and Safety Group has been relocated f rom Braintree to Pilgrim Station to facilitate onsite assistance to the Emergency Preparedness Staff. Presently we are evaluating the need for additional support in this area. This evaluation has included visits to -
other utilities and should give us a better understanding of how others
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manage and implement their emergency preparedness program.
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U. S. NUCLEAR REGULATORY COMMISSION REGICN I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-293/85-99 BOSTON EDISON COMPANY PILGRIM NUCLEAR POWER STATION ASSESSMENT PERIOD: OCTOBER 1, 1984 - OCTOBER 31, 1985 BOARD MEETING DATE: DECEMBER 18, 1985 l
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SUMMARY OF RESULTS A. Facility Performance CATEGORY CATEGORY LAST THIS RECENT FUNCTIONAL AREA PERIOD * PERIOD ** TREND 1. Plant Operations 2 3 Consistent 2. Radiological Controls 3 3 Improving 3. Maintenance & Modifications 1 2 Consistent 4. Surveillance 1 2 Consistent 5. Emergency Preparedness 3 3 Consistent 6. Security & Safeguards 2 2 Consistent 7. Refueling /0utage Activities 1 1 No Basis 8. Licensing Activities 1 1 Consistent
July 1, 1983 to September 30, 1984
October 1, 1984 to October 31, 1985 B. Overall Facility Evaluation Recovery from the recirculation piping replacement outage was conducted in a slow, cautious manner with active involvement of both onsite and corporate management. The outage highlighted the licensee's commitment to upgrade plant hardware. Replacement of the piping also resulted in an extensive plant de-contamination program. Similarly, upgrading of plant hardware to satisfy NRC regulations regarding environmental qualification was noteworthy. When con-sidering each of the functional areas assessed, the licensee's commitments to a plant betterment program is evident. Notwithstanding the clear evidence in hardware improvements, there are symptoms which are indicative of problems associated with personnel staf fing and supervisory / management oversight.
These are discussed below.
One of the significant outcomes noted during the SALP Board deliberations was the recurrent issue of staffing. In the areas of operations, security, main-tenance and radiological controls, the adequacy of staffing supervisory, pro-fessional and crafts positions was noted to be weak. In a similar vein, the oversight of BEco supervisors of work in progress by either BECo staff or contractors was noted to be insufficient. Whether this is due to a lack of supervisors or lack of a policy to foster such work habits by supervisors is not clear. However, review of the enforcement history (Table 5) clearly high-lights a number of recurring problems attributable to either poor procedural
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adherence, poor administrative practices or failure on the part of managers !
and supervisors to ensure proper planning, scheduling and performance of re- !
quired tests or maintenance. Similarly, a review of plant shutdowns (Table I 7) shows that some of the four automatic scrams and five plant shutdowns can be attributed to similar causes.
Another observation relates to the lack of critical self-assessment. During the assessment period, significant NRC interaction was required to identify problems and subsequently to get appropriate corrective action. In some cases, corrective actions tended to be superficial in that they addressed only the symptoms but not the underlying reason for the problem. A complicating factor
'in this regard is the management attitude toward perceived weaknesses; a de-fensive posture is frequently taken with respect to NRC as well as licensee self-identified weaknesses. This defensive posture inhibits a thorough and critical evaluation with subsequent delays in resolving the problem (s). Con-sequently, problems tend to linger for long periods until drastic measures '
are taken. The radiological improvement program is an example of a drastic corrective measure. In response to an NRC order, BECo is developing a frame-work for improved performance, but nonetheless, NRC oversight and action are still required to assure proper development and implementation. For example, the licensee repeatedly failed to correct a problem identified by the licen-see's. independent radiological assessor until the NRC staff took action.
Similar problems have been observed in the emergency planning _ program; the self-critique of the annual exercise was not thorough, the commitment to ade-quate emergency facilities required NRC action, and lack of personnel con-tinues to hinder program improvements. Another lingering problem is the ade-quacy of licensed operator staffing.
In summary, there has been an improvement in plant hardware over the last several years. However, the SALP results indicate that further improvements are not readily achievable until the staffing / personnel situation is resolved.
This, in our view, can be' accomplished by a more aggressive posture and fol-lowup by management to ensure better training, procedural adherence, planning and supervision of work.
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Trainino There are no training programs at Pilgrim that have been accredited by INP0 during the appraisal period. Over the year, there has been a continuing im-provement in the number of senior reactor operators but this has resulted in i
shortage of reactor operators which now is becoming acute. There were two NRC-administered exams during the appraisal period. In December 1984, 4 of 7 SRO
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candidates were licensed, 2 of 3 R0 candidates were licensed. The 3 SRO and
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1 R0 failures were retested in May 1985 with satisfactory results. This ex-i perience indicates that (1) the number of R0 candidates taking the exam is
' very low and (2) the SR0 training program was deficient as evidenced by the '
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failure rate. The licensee has managed to overcome SR0 shortages; unfortu-nately, this was at the expense of R0s. The licensee's screening and/or
- training program for R0s is not effective in resolving this long standing j problem. Consequently, operator overtime has been relied on to continue i
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worker practices in the plant. Based on the performance results noted in this SALP, there may be a need for additional training for first line supervisors to properly manage and oversee activities. Such efforts are an effective means of assuring adherence to procedures, minimizing personnel errors, and identifying design weaknesses.
Quality Assurance The assurance of quality is a responsibility of every individual at the plant.
One of the mechanisms available to managers is the use of a quality assurance /
control program to monitor work in progress and to audit programs. QA/QC per-sonnel were actively involved in reviewing plant operations during the assess-ment period. However, there was a lack of timeliness of plant managers and staff to correct problems identified in the QA/QC findings. This lack of re-sponsiveness indicates that management is not taking full advantage of the QA/QC program. It is not obvious whether this is a result of poor attitudes or insufficient resources; however, it does require senior management atten-tion to resolve the problem.
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IV. PERFORMANCE ANALYSIS A. Plant Operations (1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, 29%)
1. Analysis During the previous assessment period, problems were identified in the areas of safety system valve position monitoring, independent verification of safety system conditions, uncorrected Quality As-surance (QA) findings, and licensed operator staffing.
No subsequent valve position concerns were identified during the current assessment period, indicating that licensee corrective ac-tions were adequate. Additional NRC effort was required to obtain an acceptable corrective action for the uncorrected QA findings (termed by the licensee " Operational Surveillance" findings). Ad-ditional NRC effort was also required to resolve the independent verification concern. The operator staffing problem became more acute during the current assessment period and is discussed below.
The operators conducted routine power reductions largely without incident, demonstrating their ability to handle the plant in a pro-fessional manner. Control room atmosphere was generally quiet with nonessential business diverted to an administrative annex. Ap-proaches to safety issues were conservative and no significant problems were identified. Weaknesses were identified in the areas of licensed operator staffing, corrective actions, and occasional lapses in operator attention to detail.
A chronic shortage of licensed reactor operators grew worse'during the assessment period due to promotions, job transfers, and the death of one individual. At the end of the assessment period, only nine reactor operators and one senior operator (functioning as a reactor operator) were staffing five operating shifts. To compen-sate for the shortage, operators routinely exceeded the overtime guidelines in NRC Generic Letter 82-12. Senior licensee management did not become aware of the full extent of operator overtime until after one individual's time card indicated that he worked 97 hours0.00112 days <br />0.0269 hours <br />1.603836e-4 weeks <br />3.69085e-5 months <br /> in a seven day period. A continuing weakness in the overtime ap-proval process caused operators to repeatedly (thirty-five instances)
exceed overtime guidelines without station management's prior knowl-edge or approval. NRC concern about the implementation of the overtime guidelines was discussed with the licensee in early 1985.
The need for additional NRC action in this area demonstrates inade-quate long range planning and staffing, weaknesses in policy imple-mentation, and lack of effective corrective action for a recurring problem.
The lack of a sufficient number of licensed operators has been a repeated NRC concern over the past four years. This concern was discussed in the 1983 SALP repc-t and highlighted in the 1984 SALP m
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report. Despite these concerns, senior licensee management did 1<t
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act to ensure tnat an adequate number of individuals with appropri-ate backgrounds / capabilities entered the reactor operator training program pipeline. Finally, in the latter part of this asse,sment ,
period, the licensee recognized that the operator shortage. problems would require a substantial manpower commitment to resolve. As a -
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result, ten new staff positions for licensed reactor operators were added to the Operations Department. Unfortunately, the effect of this staffing increase will not be realized until the licensing process is complete in 1987. If additional attrition takes place or if the current candidates do not pass the next scheduled NRC license examination in May 1986, the operator shortage could con-tinue into 1987 or beyond. Continued management attention to re-cruiting, training, and retaining licensed reactor operators is imperative to prevent the current operator shortage from becoming more acute.
The licensee instituted six shifts of senior reactor operators dur-ing the assessment period, demonstrating improvement in this area.
However, the licensed operator shortage may require the diversion of some SRO's to operator positions, decreasing the SRO shifts to five.
Improvement in the operations program such as reorganizing valve lineup procedures, valve tagging, and the development of operations-oriented system drawings were planned by the licensee, but not im-plemented during the assessment period due to support staff limita-tions. Wnile the licensee previously increased clerical assistance in the Operations Department to help with routine activities, pro-fessional-level support remains minimal. The lack of professional support coupled with the shortage of licensed personnel (available for collateral duties) has severely hampered operational program initiatives.
The Quality of the licensee's operator training program was judged acceptable, with seven senior reactor operators and three reactor operators licensed during the assessment period. Three of the senior operators and one operator failed portions of their initial written examinations, but successfully passed subsequent makeup exams. The material sent to Region I for preparation of the origi-nal and makeup operator examinations was of poor quality and did not identify all current plant modifications or procedure changes.
New operator and senior operator training lesson plans are being developed in accordance with INPO performance elements. The new lesson plans should improve training program effectiveness. The licensee should expedite this development and finalize the lesson plans prior to the next scheduled examination in May 1986. Con-struction of a simulator is continuing and should be completed by late 1986 or early 1987.
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Lapses in operator attention to detail involved the use of nuclear instrumentation during refueling operations (bypassing one SRM and not continuously monitoring another SRM), the assessment of drif ting reactor protection system instrumentation (main steam line radiation monitors), and an inadvertent reactor scram from low power due to inadequate reactor water level control. Additional operator atten-tion could have prevented the loss of secondary containment integ-rity while the plant was at power. Circumstantial evidence indi-
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cates that increased operator attention might have prevented re-fueling equipment from being damaged during fuel movement at the end of the assessment period.
While the licensee's. response to NRC initiatives was generally ade-quate, considerable NRC effort was required to resolve control room-manning issues and to ensure that adequate corrective actions were taken following the discovery of refueling equipment damage. The response to these issues, which involved handling of personnel, contrasted to the licensee's usual approach to safety issues in-volving hardware. Hardware issues were typically approached in a manner which stressed safety. For example, the licensee set the main steam line high radiation monitor. trip points to conservative values between test runs during hydrogen injection experiments, be-yond technical specification requirements. Licensee management ac- ,
tions on personnel related issues as well as the failure to antici-
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pate the shortage in licensed reactor operators indicates inadequate management sensitivity to the effect of personnel decisions on plant operations.
A detailed evaluation of LER quality using a sample of 10 LERs is-sued during the assessment period was made using a refinement of the basic methodology presented in NUREG/CR-4178. In general, they found these LERs to be of acceptable quality based on the require-ments contained in 10 CFR 50.73. There were nine LERs submitted for this functional area; they were for a variety of causes. There were no adverse trends noted. .A generally conservative approach is taken in reporting under 10 CFR 50.73.
The 1984 SALP report expressed a concern about the large amount of time spend by licensee managers in safety committee duties. The licensee has taken steps to reduce the impact of the onsite Opera-tions Review Committee (ORC) by changing ORC membership and reducing the review workload. The plant manager no longer chairs ORC meet-ings, but continues to review and approve ORC recommendations. ORC workload will be decreased by identifying station procedures that do not need ORC approval. These efforts are important and should continue.
Licensee QA audit activities associated with operations were gener-ally adequate during the assessment period, demonstrating a continu-ing commitment in this area. QA staffing was maintained with few
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vacancies. However, licensee management was sometimes slow in re-sponding to QA survelliance and audit findings. This lack of re-sponsiveness indicates that management is not taking full advantage f of the quality assurance program. Senior licensee management has
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not ensured that management support for the QA process is evident and that plant personnel have the appropriate attitudes and resources to effectively respond to QA findings, maximizing the usefulness of the 01 program.
In summary, lack of effective management action on licensed operator staffing has permitted the number of licensed operators to drop to minimally acceptable levels. If the shortage worsens, plant opera-tions may be cisrupted. Tne staffing problems combined with a lack of alternative operational program support has delayed action on several operational improvement items. These items could improve operator efficiency and reduce the chance of safety-significant operator errors. Lack of operational support may have weakened the
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plant staff's attitude towarcs the QA program, also slowing the re-solution of QA findings. Although plant performance during the as-sessment period was acceptable, the board believes that these prob-lems are significant and that future plant performance and safety may be degraded without senior management action to strengthen this functional area. No significant weaknesses were identified in the licensed operator training program.
2. Conclusion Rating: Category 3.
Trend: Consistent.
The performance rating in this category is not intended to imply concern about individual operator performance. The rating is pri-marily a reflection of inadequate senior management response to personnel related matters such as licensed operator staffing, operations cepartment support, and control room manning.
3. Board Recommendation:
Licensee:
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Develop contingency and long term staffing plans for licensed operators.
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Assess the adequacy of Operations Department staffing and sup-port including: licensed personnel, support staff, and training staff.
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Assess the adequacy of maragement information systems for mid-level managers that could preclude problems such as unauthorized operator overtime. ,
NRC:
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Closely monitor status of licensed operator training program.
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Arrange for a corporate management meeting which includes senior licensee corporate management, upper Region I managenent, and representatives of the NRC program offices to discuss operations staffing problems.
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B. Radiological Controis (513 hours0.00594 days <br />0.143 hours <br />8.482143e-4 weeks <br />1.951965e-4 months <br />, 145)
1. Analysis During the previous assessment period, weaknesses were noted in the evaluatien of radiological incidents ALARA program, description of personnel authorities and responsfbilities, technician retraining program, alpha radioectivity monitorirg program, and radioactive waste transportation program. A Category 3 rating was assigned.
Improvements have been acted in these areas during the current assessment period due to an extensive Radiological Improvement Pro-gram (RIP) instituted in 1955.
There were seven inspecticos conducted by radiation specialists this assessment period and periodic coverage by the resident inspectors.
Areas examined included: radiation protection; radioactive waste management anc transportation; effluent controls and monitoring; chemistry; and radiochemistry. There were three special inspections:
two to review circenstance's, licensea evaluation and corrective actions for unplanned personnel exposures; and an inspection of the licensee's iqalementation of N' REG-0737 J post-accident sampling, analysis, and monitoring requirements, An Order Modifying License was issuec in Novercer 1984 for correction of problems associated with an August .1984 unplanned personnel exposure during control rod drive work. An Enforcement Conference was held in January 1985 to discuss problems associated with a December 1984 unplanned personnel exposure curing sludge lanctng.
2. Radiation Protectior.
The licensee continued to experience oroblems in the area of self identification of problems and initiation of prompt, comprehensive corrective actions to resolve identified problems and prevent re-currence. The deficiencies appear to be associated primarily with the licensee's oversight of contractor activities. Examples are:
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In Decencer 1934, a centractor eTployee made an unauthorized entry to a tank to perform sludge lancing. The licensee's oversight of this high radiation area work was less than ade-quate in that: established high radiation area controls were
,
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not implemented, appropriate additional procedures were not established, nor was supervisory oversight of this activity effective. A Health Physics supervisor eliminated established high radiation area controls anc failed to revise a radiation work permft accordingly. This problem existed for several days prior to NRC identification. Effective licensee corrective actions were implemented in response to this incident after NRC concerns were identified.
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A second example involved the licensee's oversight of spent fuel pool work, NRC review of contractor cutting of highly radioactive components (e.g. control rod blades) found that:
unapproved contractor procedures were being used for the acti-vity; discrepancies exis'.ad between unapproved contractor and licensee approved procedures for the work; and personnel were not trained or qualified in all appropriate procedures. Simi-lar problems were identified during licensee and NRC review of two unplanned personnel exposures sustained by contractors during control rod drive work last assessment period. The licensee's corrective actions for fuel pool work were " job-specific" and not comprehensive. As a result, additional NRC
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effort was neeced to obtain an acceptable resolution of prob-
, , lems associated with this work.
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A third example involved failure to correct high radiation area surveillance deficiencies. The problem involved failure to clearly specify the Technical Specification required high radiation area surveillance frequency on radiation work permits.
This problem was brought to the licensee's attention on a num-ber of occasions. The licensee's final correc',1ve actions have
,
not yet been received and reviewed by NRC.
Due to the number and nature of problems identified in the radiu-logical controls area last assessment period, an Order Modifying License was issued. This Order required that a comprehensive review ,
of tne radiological controls program be performed by the licensee
'
and that the findings of this review be addressed by a Radiological Improvement Program (RIP). NRC monitoring of Order implementation found that the licensee performed an indepth review of the radio-logical controls and established a RIP to address deficiencies.
The RIP, as established, addresses fourteen major areas of the radiological controls program and includes in excess of 200 com-mitted primary action items. Although licensee senior management is closely monitoring status and progress of the action items, im-plementation and effectiveness are not closely monitored. Although no major problems were identified by the NRC in licensee implemen--
tation.of the Order, problems were noted with the RIP failure to address high radiation area access key controls and some failures to generate acceptable procedures to meet RIP commitments. Work is still ongoing with the most corrective actions scheduled to be implemented by December 1985. The licensee has considerable work yet to do in the area of ALARA Program establishment; procedures; management oversight; and corrective action system. The actions taken to date are indicative of senior management's effort to im- '
prove the radiological controls program at Pilgrim.
At the end of the assessment period, the licensee was actively re- '
cruiting to fill a number of vacancies. These included a chief radiological supervisor and the chief chemical engineer. The lic-
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ensee was using a large number (about one licensee to four contrac-tors) of contractor radiation protection technicians to implement radiological controls. Some problems were identified with contrac-tor technician efforts involving inadequate oversight of radiological work on a monitor tank.
Findings of radiological occurrence reports (ROR) were not always handled in a timely, comprehensive manner. Corrective actions for ROR findings were sometimes late and superficial. These problems were apparent in the areas of radiation protection procedure ad-herence and high radiation area key control. Repeat problems con-tinue to be identified by the licensee's Radiological Assessors.
In one case, NRC action was required to ensure that recurring prob-lems identified by the Radiological Assessor were corrected. The lack of timely corrective action indicates that mid-level management is either not prioritizing work effectively or does not have suf-
- ficient resources to respond to problems. The licensee is currently revising the radiological cecorrer.ce report procedure to address these problems and ensure act'on is taken to prevent recurrence.
The licensee has implemented :emporary measures to address this problem pending procedure revisions.
Occupational radiation exposures at Pilgrim continue high, 4,082 person-rem in 1984, due partly to a high radioactive source term in the plant. No major problems with the ALARA program were iden-tified during the assessment period, but the high levels of radi-ation in the plant makes ALARA practices particularly important at Pilgram.
During the current assessment period, the licensee conducted an ex-tensive decontamination program for large areas of the process buildings. This cleanup effort significantly improved the access to safety equipment and should continue. However, recontamination t of the clean areas is an ongoing problem. The licensee was develop '
, ing a long term program to address the recontamination problem at .
the end of the assessment period. More containments of water leaks are being used than in the past, but uncontained leaks of potentially radioactive water are still noted in the quadrant rooms of the re-actor building. Continued management attention will be required to develop a program that will prevent plant conditions from de-grading (as a minimum) and to continue to reduce area contamination levels. As long as ALARA practices are employed during decontami-nation activities, the benefits of better access to plant equipment i, should outweigh the radiation exposure costs of decontamination.
The radiation protection technician training program has been sig-nificantly upgraded, in response to RIP commitments. Training for radiation protection supervisors and contractor technicians has also been upgraded. These program now contain defined objectives and
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training outlines and appear effective. The retraining program for technicians is not well ceveloped. General employee training is aggressive.
3. Radioactive Waste Management and Transportation In response to the previously discussed Order Modifying License, the licensee performed a conprehensive review of the radioactive waste management and transportation areas. Minor deficieacies identified have been included in the licensee's Radiological In-provement Program. NRC review found that program improvements have been implemented on schedule. Improvements have been made in the areas of establishment of Program Policies; consolidation of radic-active waste storage areas; designation of approved storage loca-tion; and shielding and isolation of waste. In an effort to upgrade the quality of the radioactive waste shipping procedures, the lic-ensee is currently reviewing and revising them. These actions by the licensee should enhance the quality of his radioactive Waste Management and Transportation Program.
Overall, no significant problems were identified in this area. The licensee has oeen implementing a generally effective radioactive waste mar.agement and transportation program. 1 4. Chemistry / Radiochemistry and Effluent Monitoring and Controls The licensee was found to have an effective chemistry / radiochemistry ano effluent ronitoring and control p-ogram. As part cf the re-organization initiated as a result of the Radiological Improvement Program, the licensee has reorganized the chemistry Group and has createc and filled additional positions. Staffing was found to be adequate. Technician knowledge and understandirg cf procedures was apparent.
As part of the routine inspection program the licensee was requested to analyze split samples anc pre prepared samples (both radioactive and non-radioactive). Licensee technicians performed acceptable analysis of samples provided thereby demonstrating licensee cap-ability to perform satisfactory analysis of effluents.
The licensee experienced a number of unplanned releases this as-sessment period. Two involved releases of liquid and gaseous ef-fluents from a machine shop. A portion of a normally " clean" ma-chine shop was converted tc a hot machine shop without the benefit of an adequate review of the potential for unmonitored, uncontrolled release from the hot shop. In one event, liquid radioactive mate-rial was introduced into normally clean station sewage. In another event, the normal ventilation system in the shop released unmoni-tored contaminated air to the environment. Although the situation was licensee identified, the licensee failed to perform adequate
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reviews of normally uncontaminated systems in accordance with IE Bulletin 80-10. Suen reviews were to be performed to prevent ano readily detect situations similar to the one which occurred. The third release involved malfunction of sewage pumping equipment which led to an inadvertent overflow of sewage to storm drains. It was quickly repaired by the licensee. No apparent release in excess of allowable limits occurred during the three releases, A special inspection of the licensee's post accident sampling, an-alysis, and monitoring capabilities relative to NUREG-0737 require-ments found that the licensee met the requirements specified in the NOREG with few exceptions. This reflected good coordination between the engineering groups and the site. Some procedural deficiencies and a deviation involving a failure to install protective conduit on the drywell high range monitor detector cables were identified.
Training of technicians on the operation of the post accident pri-mary coolant and containment atmosphere sampling system was com-mendable as evioenced by demonstrated performance capabilities.
5. Summary In summary, the licensee continues to experience problems in the area of oversight of radiological work and self jdentification and resolution of problems to prevent their recurrence. Despite ongoing program improvements under the RIP, these problems indicate that weaknesses were still present in the radiation protection program.
Weaknesses in the identification and correction of problems indi-cates that upper management initiatives in this area are not fully understood by mid-level managers or that human resources may not be sufficient. Program improvements being made to satisfy RIP com-mitments should considerably improve the overall quality of the program.
6. Conclusion Rating: Category 3.
Trend: Improving.
7. Boa _rd Recomeendations Licensee:
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Upgrade the process used to self identify radiological problems to ensure timely resolution and prevent their recurrence.
Maintain independent reviews of the radiation protection pro-gram.
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Continue to vigorously-implement initiatives and/or recommen-dation contained in the Radiological Improvement Program.
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Fill identifiec vacancies and m'.nimize reliance or. contractor personnel providing oversight of radiological work
![R[:
Maintain increased inspection effort in this area. Hold a manage-ment meeting with the 'icensee to review the status and effective-ness of the Radiological Irtprovemer.t Program.
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,. 20
C. Maintenance and Modifications (820 hours0.00949 days <br />0.228 hours <br />0.00136 weeks <br />3.1201e-4 months <br />, 22*.)
1. Analysis
.
During the last assessment period, a lack of procedural guidance for electrical bus-transfers was identified as a weakness. The licensee plans to address this concern prior to the next refueling cutage. This action is considered timely. The SALP board also
,
recommended that the licensee continue initiatives in maintenance trending and tracking. While no significant additional actions have
' been taken in this area, no recurring maintenance problems were identified that indicate weakness in the licensee's trending program.
During the purrent SALP period, specialist inspections reviewed previous inspection findings and water hammer events that occurred in the high pressure coolant infection (HPCI) system. No signifi- >
cant problems were identified during these reviews or during routine resident inspections of this functional area.
- Licensee approaches to maintenance and modifications were generally thorough and continued to emphasize the identification of root causes to problems. Despite weaknesses in the areas of vendor in-teractions and prever,tive maintenance, the overall performance in i
this functional area was considered strong.
Good control was demonstrated over extensive online plant modifica-tions which have been conaucted with the reactor at power. With the exception of are security problem (See section G), significant plant modifications have been installed without incident during the current operating cycle.
!
A review of the licensee vendor interface program identified several weaknesses. The licensee program did not systematically address
correspondence from vendors other than General Electric. Additional problems involving the scope of reviews of vendor information, the 4 timeliness of the reviews, and the documentation of the reviews were identified. However, no significant equipment deficiencies were j identified resulting from these program weaknesses.
Licensee corrective actions for maintenance findings were typically
comprehensive and timely. Licensee actions to correct recurring problems appeared generally effective. Two isolated instances of untimely corrective action were identified during this period. In one case, the licensee did not plan to complete corrective action to prevent the defeat of safety systems during component isolations o
until 1995. Additional NRC effort was required to obtain timely action in this case. The licensee has also been slow to repair the backup 125V and 250V station battery chargers. These chargers have been out of service since the 1984 outage. This could be a problem
, if battery charger reliability degrades. The backup chargers are
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. 21 not required to be operable by the technical specifications. The licensee occasionally has been slow te repair equipment that was
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not required to be operable by the technical specifications, e.g.,
post accident monitoring equipment. The lack of timely response to out of service safety equipment (not covered by technical speci-fications) may indicate a weakness in scheduling Second and third priority maintenance.
Corporate management was actively involved in site activities. A site representative of the corporate engineering departnent helped coordinate engineering input to the site and minimized interface problems. One interface problem between the corporate staff and the site was identified. Contractors reporting to offsite licensee engineers improperly installed a test instrument on the high pros-sure coolant injection (HPCI) system, which made the system in-operable. The improper installation was found after the HPCI system failed a subsequent routine surveillance test. The licensee took prompt corrective action after the problem was identified.
Carporate management was actively involved in the assessment of HPCI yster hammer events. The engineering approaches used to evaluate and correct the water hammer problem were judged to be conservative and effective. In cuntrast, previous licensee responses to water hammers in the HPCI steam exhaust line were limited in scope and were not consistent with documented vendor recommendations.
At the end of the assessment period, the licensee brought mainten-ance and modification groups together under a newly created manage-ment position, the Maintenance Section Head. This action should help coordinate station activities and provide additional management oversight for the groups. The Chief Maintenance Engineer was ap-pointed to the Section Head position, creating a significant vacancy in the maintenance department.
The licensee also strengthened the maintenance program by adding three maintenance planner staff positions. These individuals are responsible for planning maintenance activities and coordinating maintenance logistics in the plant. First line maintenance super-visors will be freed of these duties and should be able to spend more time in the plant directly supervising work.
The backlog of outstanding maintenance requests has been reduced since the end of the last outage demonstrating licensee initiative.
Maintenance management tracks the open maintenance requests and actively seeks to reduce the second and third priority maintenance items. However, ongoing environmental qualification modifications to plant equipment have impacted Maintenance Department priorities, hampering efforts to reduce the backlog. The licensee has recog-nized a staffing weakness and is considering enlarging the mainten-ance staff, in part due to additional plant modifications scheduled during the coming years. This demonstrates licensee initiative in anticipating future maintenance staffing needs.
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Thelicensee'scommitment$oestablishingacomprehensivepreventive maintenance program was eviaent, although plant modification work l has prevented the completion of.some routine maintenance. Minor administrative weaknesses in the preventive maintenance program were
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I identified during the assessment period. Preventive maintenance scheduled for the next refueling outage for valve motor operators has not been proceduralized. Also, preventive maintenance for the emergency diesel generators which is currently supervised by a con-tractor had not been proceduralized. The licensee plans to formal-ize both programs during 1986. A weakness in the computer-based scheduling system for preventive maintenance was identified at the end of the assessment period. Continued licensee efforts are needed to ensure that the preventive maintenance program is adequately documented and implemented.
Maintenance worker training appeared adequate to support station activities with few errors. The maintenance training program is being formalized in preparation for INP0 accreditation, with program submittal expected by the beginning of 1986. Special training courses for maintenance staff included valve and motor operator training, fundamentals of pressure and temperature, and environmen-tal qualification-training.
2. Conclusion Rating: Category 2.
Trend: Consistent.
3. Recommendations None,
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D. . Surveillance (646 hours0.00748 days <br />0.179 hours <br />0.00107 weeks <br />2.45803e-4 months <br />, 17%)
1. Analysis The previous assessment period did not identify major deficiencies in the surveillance program. However, few surveillance tests were observed because a major outage coincided with the assessment period.
During the current assessment period, three specialist inspections were conducted in the areas of containment leak rate testing and startup physics testing. Post modification testing was reviewed during a special team inspection prior to startup from the 1984 outage. Routine resident reviews of surveillance testing were also conducted.
Procedures for containment leakage testing were clearly written and technically accurate. All phases of test activities, especially access to the reactor building, were well controlled by the Test Coordinator. Initiation of leak searches during temperature stabilization were prudent and timely. Water leakage discovered during the test was well controlled. QA/QC coverage of containment leakage testing activities was appropriately planned, technically useful, comprehensive, and well documented.
l- During power operation, performance was mixed. Strength was demon-strated by the successful completion of an unusually large number of compensatory surveillance tests required by ongoing environmental qualification modifications to plant safety equipment. The licen-see's approach to surveillance testing demonstrated a consistent concern for safety, particularly in the area of secondary contain-ment damper testing. However, weaknesses in the areas ~of startup test scheduling, test adequacy, compliance with procedural require-ments, and response to abnormal test results were also observed.
The licensee conducted a slow startup from the 1984 pipe replacement outage to provide time for extensive startup testing. While the startup test program demonstrated an organized approach to the startup, eight surveillance tests required by the technical speci-fications were not conducted in a timely manner. The tests were missed due to scheduling omissions and procedural deficiencies.
The scheduling omissions indicate a weakness in the licensee's com-puter scheduling system, the Master Surveillance Tracking Program (MSTP). While normally adequate to ensure that surveillance tests are conducted in a timely manner, the MSTP was not able to adequately schedule tests during a prolonged startup.
The procedural deficiencies involved the failure to completely test some safety system components. Deficiencies were identified in testing neutron instrumentation and certain other reactor protection system instrumentation. An additional example of an incomplete
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surveillance test procedure was reported in LER No. 85-26. The licensee's staff had difficulty in some cases determining which one of several overlapping test precedures fulfilled regulatory requirements. These problems indicate that additional effort should be made to verify the technical adequacy of surveillance test pro- l cedures.
Another problem with the startup tests involved the timeliness of followup to quality assurance (QA) audit findings. A QA finding identified two surveillance tests that did not meet technical specification requirements two months prior to the startup from the 1984 outage. The licensee did not resolve the finding until after the startup, which was within QA program timeliness guidelines but which demonstrated a lack of sensitivity to the finding. Subsequent NRC action could have been avoided if the finding was resolved prior to startup. Additional licensee attention should be given to en-suring that QA findings that involve regulatory concerns are re-solved in a timely manner.
Licensee personnel generally conducted surveillance tests in a com-plete and timely manner. However, deficiencies were identified during the assessment period which involved a lack of attention to detail. In one case, operators failed to correct known deficiencies in a station battery surveillance test procedure, which subsequently caused a technical specification surveillance test to be missed.
Lack of attention to detail was also evident in the inadvertent return to service of an uncalibrated local power range neutron monitor during surveillance tests. Arithmetic errors were noted in several salt service water system surveillance tests and a com-puter program error was identified which falsely lowered vacuum breaker leak rate results by a factor of sixty. Licensee corrective actions were prompt in each case, and nq problems of this type were identified during the latter portion of the assessment period.
The licensee did not always react promptly to abnormal surveillance test findings. The lack of action was usually related to delays in reporting abnormal results to the control room via the licensee's Failure and Malfunction Reporting system (F&MR). Delays in sub-mitting F&MR's to the control room caused secondary containment integrity to be lost for a day while the reactor was at power and caused a delay in conducting compensatory surveillance tests for an inoperable emergency diesel generator. A delay in submitting an F&MR on abnormal inservice inspection results for safety system pipe hangers delayed the licensee's response to those test results.
Technical evaluations of abnormal surveillance test results were generally thorough and demonstrated an adequate regard to safety.
Concern for safety was particularly evident when the licensee in-creased the frequency of secondary containment damper inspections after finding failed dampers during routine surveillance. However, in one case, considerable NRC effort was needed to resolve abnormal
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i surveillance test results,. In this case, the safety implications ;
of drif ting main steam line radiation monitors were not recognized by the' licensee. In Addition, the licensee was slow to correct a e potential weakness in the surveillance test program involving the uncontrolled removal of safety related instruments from service for
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calibration and testing, ,
i The inservice test (IST) program was not fully implerented during the assessment period. The deviations from the program submitted-to the NRC were minor, but indicated a need for additional attention to the program.
A new halon fire suppression system for the cable spreading rocm had not been declared operational at the end of the assessment period because of the lack of a surveillance test for several months.
<
Continued management effort should be directed to placing this sys-tem in operation.
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In summary, performance in this functional area was mixed, with
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strength noted in the conduct of compensatory surveillance testing -
for inoperable equipment and in the' conduct of the 1984 primary .
containment integrated leakage test. However, weaknesses were noted in the response to abnormal surveillance test results, in surveil-lance test procedural adequacy, and in startup test scheduling.
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Responses to NRC and QA findings in tnis area were sometimes si,ow.
Personnel performance errors contributed to most of these weaknesses. .
Additional emphasis on attention to detail would improve test time- ,
t liness and help minimize problems in this functional area.
,
2. Conclusion ,
Rating: Category 2.
Trend: '
{ Consistent.
3. Board Recommendation .
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Licensee:
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Develop better control of startup surveillance testing to en- .
, sure better timeliness and adequacy.
'
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Assure that measures exist to provide for prompt evaluation
} of abnormal test results and followup actions (if necessary).
NRC .
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None. <
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N.- 26
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E. Emeroency Precaredness (310 hours0.00359 days <br />0.0861 hours <br />5.125661e-4 weeks <br />1.17955e-4 months <br />, 8%)
1. Analysis _
During the previous assessment period the licensee was rated as Category 3 in Emergency Preparedness, due principally to observa-
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tions made during the August 1984 exercise. Weaknesses were iden-
'
tified in the preparation and planning for the exercise and in com-mand and control in the Emergency Operations Facility (EOF). Based on the performance during this exercise, a remedial drill was held in October 1984, to reassess the licensee's-dose assessment cap-abilities and decision making process.
During this assessment interval, the remedial drill was observed, a routine EP follow-up inspection was performed, and the September. -
1985 exercise was observed. The remedial drill demonstrated im-provements in the areas of dose assessment and decision making, i
which had been identified as weaknesses during the August 1984 exercise.
'
Ouring the December routine inspection, two problems were identified concerning implementation of provisions of the Emergency Plan.
(Failure to mail information brochures to the general public and
' failure to perform an annual update to the Emergency plan and pro-
'
cedures). During the review of the scenario package submitted for the 1985 exercise, it became apparent that the scenario package did not contain sufficient detail. It was recommended the the exercise be postooned in order to take time to clarify and complete the exercise scenario. The licensee agreed to delay the exercise from August I to September 5,1985 to make the necessary improvements .
j to the scenario package.
i
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Durir.g the exercise, two significant areas of concern were identi-fied by the NRC. The first involved a lack of evaluation or control i of radiation exposure for re entry teams sent into the plant for
, various tasks. Serious overexposures would very likely have resulted fron the actions taken if this had been an actual situation. The
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second ccncern f rvolved the fact that there were no procedures in effect for relocation of the EOF to the alternate location, in spite
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of the fact that the trailers which presently function as the EOF are positioned near the stack with no shielding or ventilation fil-l tering. Improvemerts were evident over the 1984 exercise, however, a remedial drill was required to demonstrate the ability to evaluate and control radiation exposures of re-entry team personnel. The licensee has indicated that plans for construction of an off-site ,
EOF are rearing completion, which will help solve some of the con- '
cerns relating to the facility.
,
In summary, some improvements in emergency facilities and in the annual emergency exercise were noted during the assessment period.
However, performance was only minimally acceptable in this func- '
,_ _ ,. _ _ ,, . - . . ,, ,r--, m , -e v,- + ---
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s
's 27 tior.al area for the second year in a row. Portions of the annual exercise were unsatisfactory and had to be demonstrated in a sup-piementary drill . The lack of thorough exercise critique was a recurring problem. Personnel errors were evident during the exer-cise and may reflect weaknesses in program staffing and training.
2. Conclusion Rating: Category 3.
Trend: Consistent.
3. Board Recommendation Licensee:
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Promptly implement plans for construction of off-site EOF.
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Assess staff resource commitments for this area to assure that it receives adequate attention between exercises and drills.
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.o 28 F. Security and Safecuarcs (100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, 3*.)
1. Analysis
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During the previous assessment period, weaknesses ir the licensee's oversight of the contractor security force were noted. No further problems in tnis area were identified during the current period, indicating that licensee supervision of the contractor guard force has improved. The previous SALP report also identified a weakness in reporting security events to the NRC. Nine security event re-ports were reported to the NRC during this assessment period demon-strating an improvement in the reporting program.
During the curr.ent assessment period, one routine unannounced physical security inspection and one special inspection were per-formed by region-based inspectors. Rcutine resident inspections continued throughout the period. One severity level III violation, for which a civil penalty was proposed, was identified as a result of the special inspection. :
Licensee corrective actions for reportable events were scretimes weak. For example, six events were repcrted this year which in-volved the failure to promptly compensate for security equipment failures. The recurring problem demonstrates both a staffing de-f1clenciy and a lack of effective corrective action. Adoitional security program weaknesses were apparent during a review of open-ings ir. a security vital area barrier. These weaknesses inciuded inadecuate control over contractor construction activities &djac<ent to the barrier, an incomplete licensee evaluation of the barrier, and the use of material to repair a barrier opening that did not meet requirements. Previous licensee evaluations cf barrier integ-rity were conducted in 1982 and were inadequate. Considerable NRC attention, including escalated enforcement action, was required to obtain comprehensive corrective action. In both instances, the licensee failed to establish guidelines to implement security ob-jectives. In the first case, the licensee did not estabiish cri-taria for timeliness of cumpensatory actions, In the second case, no guidelines were established for judging acceptable site openings .
in security barriers. Licensee management should be more aggressive in establishirg guidelines and clarifying security program objec-tives.
Staf fing of the program by the licensee and the security contractor appears adequate with the possible exception of shift manning.
Shif t manning was increased at the end of the assessment period to ensure that tirely compensatory action is taken for security system equipment failures. The security contractor also increased shift supervision by adding a second supervisor to each shift. The secend shift supervisor provides the capability for patrolling the site i
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I to access pcr:onnel psrformance and the general status of security features. The security contractor provided several formal manage-ment training seminars to supervisory personnel during the assess-ment period. The security contractor also engaged a consultant to review its overall training program. These actions have apparently been effective as evidenced by improved morale and a significant reduction in security force personnel errors during this assessment pe-ind.
Hafntenance of security systems hardware and software received con-side 7able management attention during this assessment period. The licensee has assigned two dedicated instrumentation and calibration technicians to maintaining the system and provided two software and two nardware computer technicians on 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> call.
The annual security program audit appeared to be more comprehensive in scope and detail than previous audits. In centrast to previous years, the audit teams included a consultant with nuclear power plant security expertise. Previous audits were largely compliance oriented. Additional program effectiveness could be achieved by reviewing the security plan, procedures, and systems and by focusing on NRC security objectives during the audits. The security program was included in monthly QA surveillances. Monthly backshift in-spections were being conducted by the security supervisor and/or a corporate security investigator who was assigned to the site during this period. The corporate security investigator provided management with ancthe perspective on the effectiveness of the program and demonstrated management initiative.
In summary, weak corrective actions and a staffing deficiency were noted in this area. While improvements in contractor training and QA auditing were apparent, additional clarification of security objectives and empnasis on timely corrective action to meet these objectives is needed.
2. Conclusion Rating: Categcry 2.
Trend; Consistent.
3. Board Recommendation Licensee:
Clarify security program objectives and review causes for untimely corrective actions.
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G. Refueling and Outage Management (303.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, 8";)
1. Analysis Strong outage management was evident during the previous assessment period for the conduct of the 1984 pipe replacement cutage. Con-tinued good performance was noted during the current assessment period. The pipe replacement outage ended during the first quarter of the assessment period on December 24, 1905. As a result, no last quarter trend was noted for this functional area. Plant power was increased slowly over a period'of several weeks, demonstrating a cautious approach to the startup and a concern for safety.
A team inspection at the start of the assessment period reviewed the readiness of the licensee for startup from the outage. No major program deficiencies were identified during the inspection.
Strengths were noted in updating operator training, drawings, pro-cedures, and technical specifications to reflect plant modifications. .
Weaknesses in the turnover of modifications from the construction
to the preoperational test groups, verification of system configura-tion following preoperational testing, control over nonconforming material, and the lack of a station drawing for the air start system
' on the emergency diesel generators were noted. Licensee response to the inspection results was prompt and acceptable.
Numerous last minute changes were made to valve lineups for safety systems just prior to startup, in part due to the simultaneous close-out of many maintenance work packages. The last minute valve lineup verifications and changes were a significant burden on the plant management. No actual lineup problems were identified after these verifications indicating that, although rushed, they were successful. Additional planning in this area would minimize the impact of maintenance close-out reviews on the plant staff, con-tributing to more thorough reviews.
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The startup test program in December 1984 was well controlled and well doucmented. Startup test procedures, including physics testing procedures were technically sound. The reactor engineering staff was judged knowledgeable and responded readily to NRC suggestions for improvements in the testing program. The QA staff conducted a post fuel load core verification and agreed to participate in startup physics tests.
A significant lack of housekeeping control was indicated by the presence of articles of protective clothing and masking tape in the main and test tanks of the standby liquid control system (SLCS)
early in the assessment period. The debris likely fell into the tanks during the 1954 outage. A reactor shutdown in January 1985 was required while the SLCS system was flushed and the debris re-moved. The presence of loose items on the floor of the reactor
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building (protective clothing, trash, and loose tools) is a con-tinuing intermittent problem at the station. Management should increase the emphasis on housekeeping to help prevent SLCS type problems from recurring.
2. Conclusion Rating: Catego y 1.
Trend: No basis.
3. Board Recommendations None
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H. Licensing Activities 1. Analysis During the previous assessment period, the need to resolve inaccu-rate and inappropriate technical specifications was noted. Spect-fication changes were subsequently submitted to NRR regarding plant organization, a reactor water level trip setting, and primary con-tainment inerting makeup requirements. These changes demonstrate responsiveness to NRC concerns. However, continuing efforts are needed to clarify and correct the technical specifications. Licen-see responses to concerns about technical specification clarity were slow during the current assessment period and are discussed below.
Throughout the rating period the utility's management has demon-strated a high level of interest in licensing matters by active participation in the important issues. An example of this was the participation by the Senior Vice President'and other management in a briefing of NRR on BEco's efforts to environmentally qualify electrical equipment and the need for a schedular extension beyond March 31, 1985 for completion of this work. A senior executive signs all letters to the NRC, thus ensuring management involvement in licensing activities. The Senior Vice President-Nuclear fre-quently visits both the engineering offices and the plant site and the utility now has a vice president in charge at eacn of these locations.
The licensee's submittals during this period have been more complete technically than some in the past, which reflected the additional attention being given to them by review committees and licensing personnel.
The licensee's management and staff have demonstrated a clear un-derstanding of technical issues involving licensing actions. Sub-mittals normally exhibited conservatism from a safety standpoint.
On occasions when the licensee took the position that a modifica-tion would be of marginal benefit compared to its cost, it has pro-vided a sound technical approach accompanied by credible analysis to support its position. This was the case with implementation of automatic switchover of RCIC suction to the suppression pool when-ever the condensate storage tank level is low, as called for by NUREG-0737 Item II.K.3.22.
In order to develop acceptable resolutions to important technical issues, the licensee has frequently consulted the staff and this approach has proven beneficial to both parties. For example, in meetings with the staff concerning masonry walls, fire protection, environmental qualification of electrical equipment, and hydrogen addition to reactor coolant, the licensee provided clear presenta-tions of proposed solutions to these issues.
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.. 33 BECo has had a Long Term Plan (integrated schedule) in effect since July 1994 which includes target dates for plant modifications re-quired by NRC rules or orders (Schedule A) and other plant modifi-cations, procedure revisions, or changes to staffing requirements (Schedule B) for which BECo has committed to implementation dates.
With the exception of minor changes in several Schedule B items that were agreed to by NRR, BECo has met all such requirements and com-mitments during this assessment period, demonstrating management initiative in this area. However, meeting the December. 31, 1986 date for completion of control room design modifications is in doubt since the licensee is overdue in establishing a date for submittal of a supplement to its Detailed Control Room Design Review Summary Report.
The licensee was prompt in responding to NRC requests for informa-tion or gave logical reasons for delay and establishes a new date.
During this rating period, the licensee provided appropriate infor-mation which enabled NRR to conclude its review of several important issues. Among these were Radiological Environmental Technical Specifications, the Mark I Containment Program, Environmental Quali-fication of Electrical Equipment, the B-41 Appendix R Fire Protec-
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tion Exemptions, Control of Heavy Loads over the Spent Fuel Pool, and Post Accident Sampling System (PASS) modifications. However, the submittals for several other issues (notably hydrogen recombiner capability and IST), which are in review, were very slow in forth-coming. The resolutions proposed have generally been acceptable, but several have required considerable NRC effort to resolve.
An area where responsiveness could be improved concerns clarifica-tions and corrections of technical specifications. These could be proposed and handled more quickly if BEco's decision process were modified to simplify its review of administrative changes. Cur-rently, even minor changes in technical specification wording re-quire several months to prepare and submit to NRR. Current techni-cal specification problems include vaguely worded action statements and incomplete definitions. In some cases, the licensee uses stand-ard technical specification requirements to interpret vaguely worded station specifications. Also, the licensee could have shown more initiative in requesting changes regarding surveillance technical specifications that require additional testing (as compared to Standard Technical Specifications) when components are made inoper-able. This change could have resulted in less equipment testing and wear when components were made inoperable during on-line EQ modification work. i The licensee maintained a large licensing staff to deal with NRC and other agency requirements. During this rating period, members of the licensing staff participated in simulator training, the Reactor Safety Course at MIT, and a course in licensing procedures.
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In summary, there was consistent evidence of prior planning, man-agement involvement, and thorough audits. Design work is generally timely and complete records are usually available. The licensee has generally proposed technically sound and conservative resolu-tions of the issues and these resolutions have been timely in most j
cases. Acceptable resolutions to NRC initiatives are generally proposed, but some responses have been slow in coming. Nevertheless,
. only a few long standing issues remain to be completed. The com-i pletion of a long term plan reflects good planning and a respon-
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i siveness to NRC initiatives in this area.
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2. Conclusion
, Rating: Category 1.
.
Trend: Consistent.
3. Board Recommendation
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None.
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V. SUPPORTING DATA AND SUMMARIES
{
A. Investigation and Allegation Review No investigations were conducted during the assessment period.
Three allegations were received and reviewed. One was unsubstantiated. l A second involved lack of control of core drilling in the reactor build- l ing floor. A citation was issued in connection with this concern. A third allagation involved health physics records. Documentation was
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l subsequently modified to resolve this concern.
B. Escalated Enforcement Actions 1. Civil Penalties A fifty thousand dollar civil penalty was proposed during the as-sessment period in connection with unidentified openings in a security vital area barrier. A special inspection by a regional specialist inspector identified weaknesses in control of centractor personnel, inspections of the barrier, and corrective actions.
2. Orders An Order Modifying License was issued on November 29, 1984 in con-nection with recurring weaknesses in the radiation protection pro-gram. The order confirmed implementation of an extensive Radio-logical improvement Program (RIP).
!
3. Confirmatory Action Letters l
A Confirmatory Action Letter was issued on October 26, 1984 in con-nection with recurring radiation protection program weaknesses.
The letter outlined licensee plans for evaluating and correcting these weaknesses.
C. Management Conferences Enforcement conferences were held on November 20, 1984, January 31, 1985, and August 27, 1985 in the Region I office. Weaknesses in the control and monitoring of neutron instrumentation during refueling were discussed during the first conference. An unplanned occupational radiation expo-sure was discussed at the second conference. The licensee's response to abnormal surveillance findings and a degraded vital area barrier were discussed during the third conference. Management meetings with Region I personnel were also held at the licensee's reque'st to discuss various program improvements One management meeting with NRR was held on March 26, 1985 regarding the licensee's request for schedular extension to November 30, 1985 for com-pletion of environmental qualification of electrical equipment important to safety.
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'.* 36 D. Licensee Event Reports 1. Tabular Listing Type of Events:
A. Personnel Errors ,
8. Design / Man./Const./ Install 10 C. External Cause 0 D. Defective Procedure 1 E. Management / Quality Assurance Deficiency 0 X. Other 20 Total 35 LERs Reviewed LER No. 84-13 to 85-27 2. Causual Analysis Two sets of common mode events were identified:
a. LERs 84-14, 84-15, 84-17, 85-06, 85-15, and 85-17 reported
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inadvertent safety system actuations caused by maintenance or surveillance activities.
b. LERs S5-02, 85-05, 55-16, 85-20 and 85-24 involved missed surveillance tests.
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E. Operating Reactor Licensing Actions 1. Schedular Extensions Granted March 28, 1985 - extension until November 30, 1985 for com-pletion of electrical equipment environmental qualification 2. Reliefs Granted August 8, 1985 relief from implementation of automatic switchover of RCIC suction per NUREG-0737 Item II.K.3.22 3. Exemptions Granted '
December 18, 1984 - exemption from certain requirements of Appendix R,Section III.G.
4. License Amendments Issued Amendment No. 81, issued October 9,1984; deleted License Condition 3.D " Equalizer Valve Restriction" Amendment No. 82, issued October 10, 1984; revised Technical Speci-fications relative to RPV thermal and pressurization limits Amendment No. 83 issued November 7, 1984; revised Technical Speci-fications for surveillance instrumentation on suppression chamber water temperature, torus water level, containment pressure and high radiation, and vents.
Amendment No. 84, issued November 27, 1984; revised Technical Spec-ifications to apply to Halon fire suppression system which replaced carbon dioxide system in the cable spreading room.
Amendment No. 85, issued December 17, 1984; added License Condition 3.1 requiring the installation of a post-accident sampling system and a containment atmospheric monitoring system by June 30, 1985.
Amendment No. 86, issued April 5, 1985; revised Technical Specifi-cations to permit changes in the normal full power background trip level for the main steam line high radiation scram and isolation setpoints to accommodate a short-term test of operation with hydro-gen injection into the reactor coolant.
Amendment No. 87, issued April 22, 1985; revised Technical Specifi-cations by reducing the maximum permitted oxygen concentration in the primary containment during plant operation from 5?; to 4?;.
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Amer.dment No. 88, issued August 14, 1985; revised Technical Speci-fications to reflect changes in reporting requirements per 10 CFR 50.72 and 50.73 and Generic Letter 83-43 and to recognize changes in title, organization and responsibilities.
Amendment No. 89, issued August 30, 1985; revised radiological ef-fluents sections of the Technical Spe,cifications to meet Appendix I requirements.
Amendment No. 90, issued October 9, 1985; revised Technical Speci-fications by changing the Reactor Low Water Level (inside shroud)
trip requirements.
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.. T-1-1 TABLE 1 TABULAR LISTING OF LERS BY FUNCTIONAL AREA PILGRIM NUCLEAR POWER STATION Area Number /Cause Code Total A. Plant Operations IB, 8X 9 B. Radiological Controls IX 1 C. Maintenance &
Modifications 3A, 68, 10, 2X 12 D. Surveillance 1A, 38, 8X 12 E. Fire Protection /
Housekeeping IX 1 F. Emergency Protection None 0 G. Security and Safeguards None 0 H. Refueling & Outage Management None 0 1. Licensing Activities None 0 Total 35 Cause Codes: A - Personnel Error 8 - Design, Manufacturing, Construction or Installation Error C - External Cause D - Defective Procedures E - Management / Quality Assurance Deficiency X - Other
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A.. T-2-1 TABLE 2 LER SYN 0pSIS (10/1/84 - 10/31/85)
PILGRIM NUCLEAR POWER STATION ~
LER Number Summary Description 84-13 Jet pump instrumentation nozzle indications 84-14 Inadvertent RPS actuation (bus transfer)
84-15 Inadvertent containment spray actuation 84-16 Loss of power to 120 V AC bus Y-4 84-17 Loss of offsite power - unplanned diesel generator start-84-18 Inoperable motor operator for LPCI injection valve MO-1001-28A 84-19 MSIV isolation during startup 84-20 MSIV isolation during startup, LPCI valve not fully seated 85-01 SLCS system inoperable due to debris 85-02 Missed surveillance tests 85-03 Completion of a shutdown 85-04 Reactor vessel drain line leak 85-05 Missed surveillance test 85-06 Reactor scram during surveillance test 85-07 Secondary containment dampers inoperable 85-08 HPCI system inoperable 85-09 Reactor scram on turbine high vibration signal 85-10 Secondary containment dampers inoperable 85-11 Absolute versus gauge containment pressure transmitters 85-12 HPCI system inoperable; 5/18 trip, 5/23 isolation 6/6 trip 85-13 HPCI isolation on false high steam flow signal
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T-2-2 LER Number Summa ry_ Ce scription 85-14 Reactor scram due to an inadvertent high water level isolation 85-15 Secondary containment isolation due to personnel error during during a surveillance test 85-16 Missed surveillance - reactor building vent gross radicactivity analysis 85-17 Secondary containment isolation due to personnel error during a surveillance test 85-18 Failure to meet technical specification requirements - inoper-able secondary containment damper 85-19 Secondary containment dampers inoperable 85-20 Failure to conduct compensatory surveillance tests for inoper-able 2A' diesel generator 85-21 Main steam line monitors "B" and "C" outside technical speci-fication limits 85-22 Hot shop ventilation contamination 85-23 HPCI system inoperable 85-24 Missed surveillance test - station batteries 85-25 Reactor scram after load rejection 85-26 Inadequate surveillance procedure for control rod position indication E5-27 LPCI injection valve inoperable
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T-3-1 TASLE 3 INSPECTION HOURS SUMMARY (10/1/84 - 10/31/85)
PILGRIM NUCLEAR POWER STATION HOURS % OF TIME A. Plant Operations ..................... 1100 29 8. Radiological Centrols ................ 513* 14 C. Maintenance & Modifications ..... .... 820 22 D. Surveillance ............... ......... 646 17 E. Emergency Prepareaness . ............. 310 8 F. Security and Safeguards .. .......... 100 3 G. Refueling & Outage Management ........ 303.5 8 H. Licensing Activities ...... ........ . **
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Total 3792.5 100%
Includes hours for nonradiological chemistry inspection.
- Hours expended in facility license activities not included with direct inspection effort statistics.
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T-4-1 TABLE 4 ENFORCEMENT SUMMARY (10/1/84 - 10/31/85)
PILGRIM NUCLEAR POWER STATION Severity Levels FUNCTIONAL AREAS I II III IV V DEV Total A. Plant Operations - - -
4 2 -
B. Radiological Controls - -
1 1 1 2 5 C. Maintenance & Modifications - - -
- -
0. Surveillance - - -
9 2 1 12 E. Emergency Preparedness - - -
2 - -
F. Security & Safeguards - -
- - -
G. Refueling & Outage Management - - - - - -
H. Licensing Activities - - - - -
-
Totals by Severity Level 0 0 2 17 5 3 27
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T-5-1 TABLE 5
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ENFORCEMENT DATA PILGRIM NUCLEAR p0WER STATION Insp. Insp. Severity Functional No. Date Level Area Violation 84-36 11/1-11/85 IV Plant- Failure to conduct an adequate Operations shift turnover for control room personnel during refueling IV Plant Failure to continuously monitor Operations source range monitors during refueling 84-39 11/21- IV Surveillance Failure to promptly identify 12/31/84 conditions adverse to quality (i.e. failure to initiate Failure and Malfunction Reports)
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84-41 12/10-13/84 IV Emergency Failure to diseminate emergency Preparedness planning information IV Emergency Failure to update the emergency Preparedness plan and procedures 84-44 12/18-19/84 III Radiological Failure to follow radiation work Controls permit instructions and failure to establish a procedure for a remote reading teledosimetry system 85-01 1/1-31/85 V Plant Failure to maintain control room Operations staffing at levels required by 10 CFR 50.54 IV Surveillance Failure to test the containment cooling subsystem immediately when the low pressure coolant injection system was inoperable 85-03 2/1/85- IV Surveillance Failure to conduct surveillance 3/4/85 tests for the reactor protection system (six examples)
IV Surveillance Failure to conduct rod block surveillance tests (five examples)
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T-5-2 Insp. .Insp. Severity Functional No. Date level Area Violation IV Plant Failure to promptly correct con-Operations ditions adverse to quality (i.e.
failure to take timely action on Quality Assurance surveillance findings)
V Surveillance Failure to use the most current revision of a surveillance test procedure V Surveillance Failure to calibrate test equip-ment within the calibrated period 85-06 3/5/85- V Plant Failure to maintain an uncali-4/1/85 Operations brated local power range monitor in a bypassed state IV Maintenance Failure to conduct a dioctyl phthalate test of HEPA filters following maintenance on the standby gas treatment system 85-13 5/20-24/85 V Radiological Failure to have the Operations Controls Review Committee (ORC) review two radiological procedures and failure to control work in the fuel pool with a maintenance request Deviation Radiological Failure to conduct an adequate Controls review of systems that could generate an uncontrolled, un-monitored radioactive effluent release, as recommended in IE Bulletin 80-10
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85-17 6/13/85- IV Surveillance Failure to conduct a surveillance 7/15/85 surveillance test of the 250 V battery system required by the technical specification and to follow station procedures for additional battery tests IV Radiological Failure to specify high radiation Controls area surveillance frequencies on radiation work permits
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T-5-3 Insp. Insp. Severity Functional No. Date loval Area Violation Deviation Surveillance Failure to conduct inservice tests as specified in an NRC submittal 85-20 7/16/55- IV Surveillance Failure to maintain the trip 8/19/85 level setting for the "B" and
"C" main steam line high radi-ation monitors within technical specification limits 85-21 7/16/E5- IV Surveillance Failure to maintain secondary 7/30/55 containment IV Surveillance Failure to test alternate safety system when an emergency diesel generator was found to be inoperable IV Surveillance Failure to initiate Failure and Malfunction Reports as required by station procedures 85-24 8/6-S/85 II: Security Failure to maintain an adequate vital area barrier 85-26 6/20/85- IV Plant Failure to procerly authorize 9/23/85 Operations excessive licensed operator overtime as required h.' station procedures (thirty-f. e instances)
85-27 9/16/85- Deviation Radiological Failure to install a protective 9/20/85 Controls conduit
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T-6-1 TABLE 6 INSPECTION ACTIVITIES (10/1/84 - 10/31/85)
PILGRIM NUCLEAR POWER STATION Inspection Inspection Report No. Hours Areas Inspected 84-28 259 Plant readiness for restart, team inspection 29, 30, 31, 32 ---
Cancelled 33 174.5 Resident inspection, plant operations 34 ---
1994 SALP Report 35 88 Emergency preparedness, remedial drill 36 41 Special inspection, source range monitor operation during refueling activities 37 18 Operator license examination 38 64 Containment integrated and local leak rate testing 39 402 Resident inspection, plant startup follow-ing a recirculation pipe replacement outage (see also inspection no. 85-01)
40 46 Startup test program 41 75 Emergency preparedness program 42 29 Startup physics testing 43 --
Cancelled 44 13 Special inspection, radiological controls for desludging the "C" monitor tank (see also inspection no. 85-02)
85-01 293 Resident inspection, plant startup follow-ing a recirculation pipe replacement outage (see also inspection no. S4-39)
02 58 Special inspection, followup on radiologi-cal controls actions (see also inspecticn no. 84-13)
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,, i Inspection ' Inspection Report No. _ Hours Areas Inspected 03 179 Resident inspection, plant operations 04 38 Physical security programs 05 24 Nonradiological chemistry program
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06 195 Resident inspection, plant operations 07 64 Special inspection, followup on radiologi-cal controls actions, bulletins and cir-culars, and high reading TLDs 08 134.5 Resident inspection, plant operations 09 138 Vendor-licensee interface 10 ---
Cancelled 11 216 t Resident inspection, plant operations 12 27 Plant modifications and operations
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13 70 Radiological controls program 14 50 Followup on previous inspection findings, plant operations 15 xx Operating license examination
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28 Special inspection, unauthorized mainten-
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ance and modification activities on the high pressure coolant injection (HPCI)
system 17 98 Resident inspection, plant operations 18 37 Followup to HPCI waterhammer events and pipe snubber inspection program 19 147 Emergency preparedness, annual exercise 20 s 132.5 Resident inspection, plant operations 21 24 Special inspection, review of licensee response to two abnormal surveillance test
results
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T-6-3 Inspection Inspection Report No. Hours Areas Inspected 22 35 Radiological controls program 23 -109 Radiochemistry program, mobile laboratory 24 12 Special inspection, review of licensee response to a degraded vital area barrier 25 6 Enforcement Conference, concerning NRC inspection nos. 85-21 and 85-24 26 86 Resident inspection, plant operations 27 140 Post accident sampling system and related accident monitoring system review 28 148 Resident inspection, plant operations
.29 114 Special inspection, refuel bridge damage followup
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TABLE 7 PLANT SHUTOOWNS Shutdown Period Description Cause Dec. 11, 1983 to Refueling and recirculation pipe ---
Dec. 24, 1984 replacement outage.
Dec. 24, 1984 Startup from the outage. ---
Dec. 25, 1984 Shutdown from low power due to Design (trapped air possible erratic indication of reactor in instrument lines) or water level instruments during the procedure weakness (venting startup. Trapped air in instru- instrument lines following ment reference legs is a long an extended outage not ade-standing problem. quate).
.Jan. 1, 1985 to Shutdown due to the presence of Poor housekeeping (SLCS)
Jan. 7, 1985 debris in SLCS and for maintenance and component malfunction on torus to drywell vacuum (vacuum breakers).
breakers.
Feb. 9-15, 1985 Shutdown to replace failed recir- Component malfunction and culation pump bearings. The bear procedure weakness (response ing failure was caused by a loss to a hi/lo oil level alarm of pump lubricating oil inventory. not adequate).
Tne oil loss was caused by a leak in an oil packing gland that sur-rounds a cooling water line.
Feb. 15-18, 1985 Shutdown to repair a leaking weld Component malfunction.
in the reactor vessel drain line.
March 15-20, 1985 Scram from 100*. power on a false Design weakness (instrument high reactor pressure signal valves prone to stick) or caused by a sticking instrument personnel error (valve valve. The shutdown was continued overtightened).
to complete maintenance on the reactor water sample system and secondary containment dampers.
June 14, 1985 Scram from less than 10*6 power due Personnel error.
to a high reactor water level isolation during low power maneuvers.
April 4-5, 1985 Scram from 85?. power due to a Design weakness (turbine false turbine high vibration trip logic is o_ne out of signal, n).
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e to T-7-2 Shutdown Period Description Cause Sept. 1-5, 1985 Scram from 32% power due.to high Design weakness (portions reactor pressure following a of switchyard must be washed generator load rejection. The live).
load rejection was caused when a ground fault occurred in the sta-tion switchyard during washing ac-tivities. The fault was caused by a buildup of ocean salt on switchyard insulators. A leaking recirculation pump seal was re-placed while the reactor was shut down.
Sept. 5-7, 1985 Shutdown to replace an additional Design or maintenance leaking recirculation pump seal. weakness.
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FIGUPI 1. Pilgrim Unplanned Reactor Shut Downs *
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1 h 2 E;s ' 5 N T Shut Down
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N N N N
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N N N N N N N N N \ N N 0 \ \ \ \
DEC JAN FEB MAR APR MAY JUN JUL AUG 1984 1985 SEP OCT
- December Number of24, shut 1984.
downs per month. The recirculation pipe replacement outace ended on
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o PILGRIM SALP HISTORY Assessment Period OPS RADCON MAINT SURV EP FP SEC REFL QP LIC 01/01/80 - 12/31/80 2 3 2 2 3 2 2 3 3 N 09/01/80 - 08/31/81 3 2 3 2 1 2 2 2 3 N 09/01/81 - 06/30/82 3 2 2 2 1 3 2 2 N 2 07/01/82 - 06/30/83 2 2 2 1 1 1 2 N N 1 07/01/83 - 09/30/84 2 3 1 1 3 2 2 1 N 1 10/1/84 - 10/31/85- 3 3 2 2 3 N 2 1 N 1
L' - . . - . _ . . . _ . . _- . . . _ _ . . - _ , ,,......__,,.;.,,,.__.._.~._,,_.__.._,,,.,_.m.. . . . . , . . . . _ , . . . - -