IR 05000293/1989005

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Insp Rept 50-293/89-05 on 890311-0410.Unresolved Item Noted Re Util Method for Disabling Annunciators in Control Room. Major Areas Inspected:Assessment of Licensee Mgt Controls, Conduct of Operations & Startup Testing
ML20245A566
Person / Time
Site: Pilgrim
Issue date: 06/09/1989
From: Blough A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20245A540 List:
References
50-293-89-05, 50-293-89-5, NUDOCS 8906220064
Download: ML20245A566 (67)


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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No.: 50-293 Report No.: 50-293/89-05 Licensee: Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199 Facility: Pilgrim Nuclear Power Station Location: Plymouth, Massachusetts Dates: March 11 - April 10, 1989- , Inspectors: C. Warren, Senior Resident Inspector T. Kim, Resident Inspector C. Carpenter, Resident Inspector M. Evans, Acting Resident Inspector, Pilgrim Station A. Howe, Acting Resident Inspector, Pilgrim Station i ' R. Laura, Resident Inspector, Nine Mile Point T. Rebelowski, Senior Reactor Engineer, Region I (RI)' M. Kohl, Reactor Engineer, RI , M. Dev, Reactor Engineer, R N. Conicella, Operations Engineer, RI T. Dragoun, Senior Radiation Specialist, RI G. Thomas, Reactor Engineer, Office of Nuclear Reactor Regulations,(NRR) T. Ross, Project Manager, NRR R. Starkey, Senior Operations Engineer, Region II G. Bethke, NRC Contractor G. Bryan, NRC Contractor F. McManus NR ontractor Approved by: A.RandyBloughf,.ief'

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Date' N Reactor Projects Section No. 3B Division of Reactor Projects 8906220064 890dd9 PDR ADOCK 05000293 G py L__'______________________________.________ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . . . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ ____:

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Inspection Summary: Areas Inspected: Restart staff inspection to assess licensee management con-trols, conduct of operations and. startup testing activities during the 5-25% power plateau of the licensee's Power Ascension Test Progra I Results: The report documents the licensee's successful completion of the Reactor Mode Switch Functional Test and Residual Heat Removal (RHR) System - Interleakage Tests (Sections 3.1 and 3.2). These tests were directly respon- i sive to the technical issues associated with NRC Confirmatory Action Letter 86-1 Unresolved Items: The licensee's method for disabling annunciators in the con-trol room is unresolved pending additional licensee review (Section 2.1).

! Strengths: l l l Material condition of rooms and equipment in the plant continued to be excellent (Section 2.2) , The licensee's Measuring and Test Equipment provides proper control over equipment to ensure that activities using instruments that fail calibra- '

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tion are properly dispositioned (Section 4.2)  ! The licensee's actions in response to the valve motor operator failure was thorough and technically sound (Section 5.1) Weakness: The engineering department appears not to have effectively evaluated the fail-ure rate and root causes for failures of airlock doors and interlock _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ - __

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TABLE OF CONTENTS

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Page Summary of Facility Activities.............................. 1 Operations (Modules 71707, 71710, 71715, 62703, 61726, 64704).................................................... 2 Startup Testing Activities (Modules 71711,72701,72508).... 7 Surveillance (Module 61726)................................ 10 Maintenance and Modifications (Modules 62703,62705)........ 12 Training (Module 41500)..................................... 13 Radiological Control s (Module 83750). . . . . . . . . . . . . . . . . . . . . . . 15 Followup on Previous Inspection Findings (Modules 92700, 92701,92703,93702)...................................... 18 Review of NRC Temporary Instructions (Module TI 2515/99).... 20 1 Review of Licensee Self-Assessment Activities (Module 40500)..... ...................................... 21 11. Management Meetings (Modules 30702,30703).................. 22 i Attachr ent I - Persons Contacted Attachment II - Licensee handout from April 3,1989 Restart Assessment Panel Presentation i

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DETAILS 1.0 Summary of Facility Activities At the end of the last report period, the plant was in cold shutdown fol-lowing the reactor scram which occurred on March 4,198 At 11:05 p.m. , on March 11, 1989, the licensee brought the reactor criti-cal. The licensee completed a test of the turbine control system on .' l March 12, 1989, in an effort to determine the root cause of the turbine j control system malfunction that occurred on March 4,1989. The malfunc- l tion did not reoccur during the tes l

On March 15, 1989, the licensee successfully completed the mode switch f functional test. The completion of this tes, closed a technical concern j associated with Confirmatory Action Letter 86-10.

l On March 31 and April 3,1989, the licensee successfully completed the high pressure coolant injection (HPCI) and reactor core isolation cooling (RCIC) system cold quick start tests, therefore completing their planned testing activities for the 25% power platea l

On April 3, 1989, the licensee requested to the NRC Restart Assessment Panel, NRC release to proceed with power ascension from 25% to 50% powe l The plant continued to operate at approximately 24% power throughout the ! remainder of the inspection period while awaiting NRC agreement to pro-ceed. (NOTE: Af ter the end of the inspection period, it was determined that an additional licensee presentation and Restart Assessment Panel review was needed, in light of a April 12, 1989, Reactor Core Isolation Cooling System event, prior to a release determination by NRC).

On April 10, 1989, the licensee revised the Power Ascension Test Program, as described in the August 31, 1988 Pilgrim Nuclear Power Station Power , Ascension Program. The shutdown from outside the control room test which I was to be the first testing activity conducted following NRC release to proceed to the 50% power plateau, will now be conducted following all other testing activities at the 50% platea , N . inspection activities during this report period were conducted by the onsite Pilgrim Restart Staff .ad by Mr. Clay C. Warren, Senior Resident Inspector and Restart Manager. The Pilgrim Restart Staff is composed of the Pilgrim resident inspectors, resident inspectors from other plants, NRC regional-based and headquarters-based inspectors and a NRC contracto On March 10,1989 at 6:00 a.m., the Pilgrim Restart Staff began 20 hour shift coverage in anticipation of plant startup. Around-the-clock shift coverage was discontinued on March 24, 1989 at 10:00 p.m., consistent with reduced testing activity. The restart staff was maintained on extended day shift coverage through the remainder of tt. inspection period.

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2.0 Operations

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2.1 Sustained Control Room Observations Based on around-the-clock on-shift observations from March 10, 1989 through March 24, 1989, the inspectors concluded that control room activities continued to be conducted in a safety conscious and pro-fessional manner. Communications .within the control room and via phone to other-plant locations' were generally conducted in a formal and precise manner. Plant evolutions and testing were controlled and i deliberate. Major evolutions were discussed with participating per- ] sonnel prior to the start of the test or. activity. Training. reactiv-ity manipulations were carefully controlled and were under the direct supervision of licensed operators. Shift turnovers were conducted in

a ' formal manne Information about system status and work in pro-L gress was conveyed to the oncoming shift through individual operator turnovers and pre-shift briefings. The off going Nuclear Watch Engi-neer (NWE) conducted pre-shift briefings which. covered problems encountered and upcoming evolutions in sufficient detail to ~ inform oncoming personnel of overall plant statu The oncoming Nuclea Operations Supervisor (N0S) also conducted shift briefings early in his shift covering plant status and planned evolutions for the shif Attendance at this briefing continued to consistently include repre-sentatives from the chemistry, health physics, maintenance and outage management group Shift staffing levels remained adequat The licensee began this period with a four-shift rotation consisting of three senior reactor operators (SR0s) and two reactor operators (R0s) per shift. During 1 the period, the licensee reduced the shift staffing. levels to the ;

normal complement of 2 SR0s and two R0s, while retaining the four 1 shift rotation. Newly licensed R0s with limited licenses, continued on-watch training and reactivity manipulations, and at the end of the report period, one R0 had completed the training requirements and had been issued an unrestricted licens The control room staff continued to exhibit appropriate concern for reactor safety. The operators stopped work to resolve problems and correct procedures during testing and other: evolutions whenever-appropriat The Technical Specifications were conservatively applied. The control room operators were attentive to_ their panels, _ alarms and indications and their response to alarms and system par-ameter trends was appro;-iate. The inspectors noted lit annunciators on the front panels and Iscussed them with the reactor operators on several occasions. The operators were aware of the status of the annunciator I

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l l The inspectors noted that communications among the operators and between the control room and other licensee groups (e.g., Instrumen-tation and Control) continued to be adequate. The inspectors noted l considerable improvement during the report period regarding opera- 1 tions shift personnel's knowledge of the status and progress of plant I maintenance activitie The Nuclear Watch Engineer (NWE). was observed making several calls per shift to maintenance management to obtain status report The level of detail regarding maintenance , status in the NWE and Nuclear Operations Supervisor (NOS) turnover l reports increased significantl i i The inspectors continued to routinely review various control ro I logs including the Limiting Condition for Operatione (LCO) Log, the J Disabled Annunciator Alarm Log, the Operations Sun avisor Log, the i Reactor Operator's Log, the Lifted Lead and Jumper Log, and the Com- .i ponent Leak Log. The inspectors noted that items were properly i logged and tracke ] During shift observation in the control room, an inspector identified l a concern regarding the licensee's process for disabling annuncia- 1 tors. Several system descriptions in the PNPS Final Safety Analysis l Report (FSAR) include the alarms associated with those systems, such I as High Pressure Coolant Injection (HPCI), Automatic Depressurization l System (ADS) and Core Spray. It appeared to tne inspector that dis-  ! abling any annunciator identified in the FSAR would essentially be a j modification to the system and a safety evaluation may be required per 10 CFR 50.59. Procedure 2.3.1 step VII, Disabling Annunciators, does not address performance of a safety evaluation and the inspector noted that none were performed. Procedure 1.5.9, Temporary Modifica-tions, step 3.2 defines a temporary modification so as to include i

" pulled circuit boards." Annunciator cards potentially fall into  i that category. The inspector discussed this concern with licensee management who stated the method for disabling annunciators would be reviewe This issue is considered unresolved (50-293/89-05-01)

pending further licensee and NRC revie Control room operators continued to receive good support from the shift technical advisors (STA) and administrative assistants. The STAS were used in developing failure and malfunction reports and up-dating various control room logs. The administrative assistants did much of the administrative paperwork and helped to reduce traffic in the control rorm.

. Operations management, particuirly the Chief Operating Engineer, L provided effective oversight of operations. Operations management continued to be observed touring the control room frequently and discussing plant status and evolutions with the Watch Engineer. Com-plete briefings were conducted with all shifts to identify and dis-cuss all procedure changes prior to implementatio __ _ i

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2.2 Plant Tour Observations The inspectors routinely conducted facility tours, both independently i and while accompanying equipment operators during routine round ; Licensee personnel interviewed during the tours, including Health l Physics (HP), security, operations, firewatches, and contractors, had experience in their positions and were knowledgeable about their work and duties. HPs were cognizant of work activities in progres ! Overall, the inspectors found that the material condition of rooms ( and equipment in the plant continued to be excellent. The inspectors J noted that the licensee continues to implement an aggressive house-keeping program. The inspectors observed very few oil or water leaks in the plant and the extent of contaminated areas was.well under con- i tro Housekeeping controls were being maintained during work in ' progress. However, one isolated discrepancy was noted. Several pieces of loose equipment were found laying near safety related ECCS l switchgea r. Loose equipment provides a potential for impact ' damage or impedes ready access to important plant components. The inspector discussed this issue with the cognizant systems engineer who took prompt corrective actio On April 3,1989, Mr. William T. Russell, Regional Administrator, Region I, toured Pilgrim Statio Mr. Russell was accompanied by licensee and NRC personne .3 Review of Plant Events 2. Inadvertent Actuation of LPCI Loop Select Logic On March 9,1989 at 12:20 p.m., with the reactor in th cold shutdown mode, the licensee experienced an inadvertent actuation of a portion of the low pressure coolant injec-tion (LPCI) loop select logic due to a personnel error dur-ing surveillance testing of the LPCI loop select logic relays. The actuation of the loop select logic resulted in signaling the "A" RHR loop injection line containment iso-lation valves (MO-1001-28A and MD-1001-29A) to close and the "B" RHs loop injection line containment isolation valves (M0-1001-28B and MD-1001-29B) to ope The RHR pumps did not start, however; the RHR keepfill system injected a small amount of reactor grade water into the reactor vessel.

i Upon hearing the relays actuating unexpectedly, the I&C technicians conducting the test notified the control room.

' The technicians were instructed to discontinue further testing and to restore the circuitry to normal. The LDCI injection valves were restored to their normal position I i

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The licensee held a critique of the event to determine root cause and to develop corrective actions which determined that prior to the actuation, I&C technicians were perform-ing surveillance test (TP 88-78) " General Electric CR 2820 , Time Delays for Automatic Depressurization Syrtem (ADS), ' Core Spray System (CS), RHR, and Reactor Protection System." The procedure required installation of rubber l insulators on a pair of contacts on the relay downstream of the CR 2820 relay being tested to prevent the logic system from actuating. It was determined that the I&C technicians improperly installed the insulators therefore causing the actuation. Maintenance management subsequently emphasized proper installation of insulators during an I&C worksho The inspector had no further question .3.2 Followup to the March 4, 1989 Reactor Scram

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On March 12, 1989, the licensee attempted to recreate the i events that led to the reactor scram of March 4,1989 (see ' IR 50-293/89-01, Section 2.3.7). The licensee had in-stalled special instrumentation to fully monitor the tur- I bine vacuum trip mechanical and electrical systems during l the conduct of Temporary Procedure (TP) 89-18, Monitoring i Turbine Trip Parameters. A normal reactor plant start up  ! was conducted, the turbine was rolled and incrementally loaded to 85 NWe. After about one hour of operation the turbine load was reduced to 10 MWe, then tripped per normal l plant procedures. The turbine was allowed to coast down to l low speed and automatically rolled on to the jacking gea i No abnormal conditions or events were noted on the special instrumentation. The bypass valves functioned as designe The root cause of events leading to the reactor scram on March 4,1989, was not determined from the conduct of this tes The events could not be repeated under controlled plant test condition .3.3 Malfunction of the Reactor Building Airlock Door Interlock At - 3:45 a.m. on April 1, 1989, with the reactor at 24% power, a malfunction of the reactor building airlock door interlock occurred which allowed both the inner and outer doors to be opened simultaneously. The_ watch engineer i directed two security guards to be posted in the airlock to assure both doors would not be opened simultaneously, thereby breaching secondary containment integrity. Failure and Malfunction Report (F&MR) No. 89-142 was generated and the licensee conservatively made a 10 CFR 50.72 notificatio ; _ - _ _ . - _ _ _ _ _ _ _ - _ _ _

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The reactor building airlock door ' interlock was repaired under Maintenance Request (MR) N . While troubleshooting, an interlock switch was found . broken and a wire was found disconnected. The switch was replaced, the wire was reterminated and the door interlock ' was retested satisfactorily at 1:00 a.m. on April 2,1989. The inspector found the repair and retest to he' adequate and had no further question At 4:35 on April 4, 1989, with the reactor at 24% power, a malfunction occurred again to the reactor building airlock door interlock which allowed both the inner and outer doors to be opened simultaneously for a period of-approximately 3 seconds. The breach of secondary contain-ment integrity was not reported to the watch engineer until 3:25 p.m. on April 5,1989. The watch engineer directed two security guards to be posted in the airlock to assure both doors would not . be opened simultaneously. F&MR N was generated and the licensee made a 10 CFR 50.72 notification. MR No. 89-50-32 was generated to trouble-shoot and repair the interlock. Also, Technical- Specifica-tion Tracking Action Statement was generate The safety significance of the failures is minor, since-(1) the duration of the events is very short . and (2) the - j doors have self-closing mechanism The inspector reviewed F&MRs generated over the past two years which involved failure of the reactor building access-doors and interlock. The inspector noted 'that ten F&MRs j had been generated. Five F&MRs dealt with the actual doors (86-025, 87-298, 88-103, 89-135, 89-140) and five F&MRs dealt with the door interlock (87-045, 87-550, 88-346, 3 89-142, 89-143). The inspector noted - that the reactor building airlock doors and interlocks have displayed a ' hi story of design or repair problems. -The engineering department appears to not have addressed the problems'in an adequate fashion i_n order to evaluate the failure rate and determine the root cause of the recurring' failure The inspector discussed with the licensee ' the expected i troubleshooting, repairs and retest that would be performed to the reactor building airlock door interlock under MR N i 89-50-3 The. licensee indicated that there would.be engi-neering involvement with the planning, troubleshooting, repairs, and retests to be done under this MR. The. i nspec-tor will review completion of _this work in a. future inspectio !

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2.4 Failure and Malfunction Reports (F&MR) The Failure and Malfunction' Report is used to document. and evaluate failures, malfunctions ' and abnormal operating: events. A' sample of

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I recently closed F&MR's'showed the F&MR's to be appropriately closed or dispositioned with management review performed . to ensure their , proper closecu No inadequacies were identified with respect to i open'or recently-closed F&MR' .0 Startup Testing Activities i 3.1 Reactor Mode Switch Functional Test ' The licensee had previo'usly installed a new mode switch in accordance' < with maintenance request (MR) 86-45-96 to address NRC concerns dis- . cussed in NRC Confirmatory Action Letter. (CAL) 86-10. Temporary Pro- i cedure (TP) 88-76, Startup Test for Primary Containment Isolation- ; System (PCIS) Monitoring, was developed to perform the PCIS ' func- 'l tional tes The purpose of the test was to ensure that the main steam isolation valves (MSIVs) would remain open, as designed, during-transfer of the mode switch from the RUN to STARTUP positio The inspector reviewed the temporary procedure for technical adequacy and discussed it with licensee personnel. The procedure _was tech-nically adequate and contained sufficient guidance to' ensure safe ; performance of the test. The inspector witnessed the test and dis- ! cussed the test results with the cognizant test personne The. R inspector noted 'that the test was performed by- qualified personnel ! in accordance with an approved test procedure, that the test.results met the test acceptance criteria, and the results were adequately documented. The licensee's Quality . Control (QC) coverage .for the test was adequat Based on the above review, the inspector determined that the licensee

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has adequately addressed the PCIS technical concerns associated with NRC CAL 86-1 , 3.2 RHR System Interleakage Tests i On April 10,1986, the licensee had experienced leakage from the- I reactor vessel past' closed Low Pressure Coolant Injection (LPCI) sys-- , tem injection containment isolation valves to the RHR system pipin The licensee had then declared the valves inoperable and shut down i the reactor. This leakage was a NRC concern in Confirmatory Action ! Letter 86-10 issued on April 12, 1966. In response to this concern ! the licensee repaired the valves, performed local leak rate testing prior to restart, and developed procedure 8.5.2.10, . Residual Heat i - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -_ .

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i Removal Temperature and Pressure Monitoring, to measure and evaluate valve leakage during the Power Ascension Test Program and subsequent operation. In procedure 8.5.2.10, temperature and pressure monitor-- ing of the RHR system is performed by taking local temperature and pressure readings in the system and comparing these to saturation conditions to determine if the potential for void formation exist i

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During this inspection period the inspector witnessed conduct of the test . during the 25% power plateau, and reviewed the test result No deficiencies were identified. However, the inspector noted that no trending of the test results was being performed to identify onset of high pressure steam leakage past the isolation valves. /1so, the procedure did not provide justification for the 15 degree F piping wall temperature differential used for comparing the limiting steam saturation temperature condition in the piping. The licensee repre-sentative stated that the procedure will be revised to incorporate a 1 trending requirement, and to provide the evaluation to support the use of 15 degree F piping wall temperature differential for compar- . ison. The inspectors will further review this item in a future  ! inspectio ] 3.3 Turbine Overspeed and Off-Line Testing The inspector reviewed and witnessed the conduct of procedure 8.2.1, Turbine Generator Testing. The procedure requires and General Electric recommends testing of the main turbine generator subsequent to dismantling for inspection, overhaul and reassembly. The test consisted of oil trips, two overspeed trips and valve functional testin The inspector found the test procedure to be adequate and noted that conduct of personnel during the performance of the test was satisfactory. All test results were acceptabl .4 HPCI Stop Valve Balance Chamber Adjustment The licensee performed procedure 3.M.4-81, High Pressure Coolant Injection (HPCI) Stop Valve Balance Chamber Adjustment, to verify stable opening of the turbine stop valve. The inspector witnessed the test and reviewed the test results. An auto quick-start of the HPCI system was simulated and stable opening of the turbine stop valve was verified. The test was satisfactory, and met the accept-ance requirements delineated in the test procedure and facility Tech-nical Specifications 3.5.C. The inspector had no questions.

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3.5 APRM Calibration Six average power range monitors (APRMs) average the output of 120 l local pcwer range monitor (LPRM) amplifiers and provide. continuous I indication of bulk reactor power level during power operatio Th j licensee performed procedure 9.1,- APRM Calibration, which provides , for calibration of the APRM channels to read proportional to the core l thermal power (CTP) by using APRM gain adjustment'. factors (AGAFs) j derived from the process computer CTP and actual APRM readings. The ] inspector reviewed several sets of APRM : calibration data. The - inspector noted that reactor engineering had collected "as found" l readings of all APRM channels and compared them with the process com- ' puter CTP. Also, the AGAFs obtained from the process computerwere - used to calibrate APRMs for "As Left" condition The test results were satisfactor .6 Core Thermal Power Evaluation The licensee performed procedure 9.3, Core Thermal. Power Evaluation which provides for the calculation of CTP based on measured thermo- l hydraulics data and compares the results with the CTP obtained from the process computer. The inspector verified a heat balance calcula-tion associated with the licensee's 25% . startup test program. .The i calculated value was within the acceptable limit (3%) of the CT I obtained from the process compute The methodology and the test' 1 result were acceptabl .7 Simulated Automatic Actuation / Cold Quick Start of the Reactor Core i Isolation Cooling (RCIC) System The licensee conducted a simulated automatic actuation (SAA) and cold quick start v.est of RCIC on March 30, 1989,- with the reactor at 25% l of rated power, in accordance with the Power Ascension Test Program !

   (PATP). The same test, procedure 8.5.5.1 (Part C), was conducted q earlier in the PATP with the reactor pressure at 150 psig to. meet the' :

technical specification requirements. The purpose of.the test.is to 3 demonstrate that RCIC starts upon auto initiation with no ' system ! pre warming and delivers 400 gpm at a discharge pressure of at.leas j 80 psig above reactor pressur Upon initiation, the RCIC turbine tripped within a few ' seconds. .The , licensee's immediate investigation determined no apparent problem L with the RCIC system. The only alarm associated with: RCIC system received in the control room was the " turbine stop valve close" ! alar Following the investigation, the licensee ' re-attempted c the : I test with the same result. The watch engineer terminated the test and proceeded with a manually initiated RCIC pump . operability test in accordance with procedure 8.5.5.1 (Part A). This test was com- i pleted successfull !

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The licensee's critique of the SAA/ cold quick test failure identified a procedural inadequacy: due to interlocks in the system control logic, the RCIC full flow return line isolation valve (M0-1301-53) could not be opened with the initiation signal present. Therefore, low pump flow and high steam pressure caused the turbine overspeed trip. This was not a problem during the SAA/ cold quick start test of RCIC et 150 psig due to low steam admission pressur The licensee subsequently revised the procedure to lift a lead to bypass the automatic closure signal for the M0-1301-53 valve on an initiation signal, thus allowing the operator to open the valve dur-ing initiation of the test. The test was then conducted successfully on April 3, 1989 with the revised procedure. The inspectors reviewed the results of the test and found no discrepancie .8 Simulated Automatic Actuation / Cold Quick Start of the High Pressure L alant Injection System (HPCI) The licensee conducted a simulated automatic actuation and cold quick start test of HPCI on March 31, 1989, with the reactor at 25% of rated power, in accordance with the Power Ascension Test Program (PATP). The same test, procedure 8.5.4.1, was conducted earlier in the PATP with the reactor pressure at 150 psig to meet the technical specification requirements. The purpose of the test is to demon-strate that HPCI starts upon auto initiation with no system pre- , warming and delivers 4250 gpm at a discharge head of 1225 roi The inspectors observed the entire evolution of the test including pre-test briefings by the test director and also by the shift watch engineer, control room activities, and field activities during the tes The inspectors determined that the pre-test briefings were thorough and comprehensiv Communications among various groups involved in the test; control roo;n personnel, I&C technicians and equipment operators at the HPCI area; were clear and appropriat The inspectors reviewed the results of the test and found no discrepancies.

l 4.0 Surveillance 4.1 Routine Surveillance Tests The inspectors observed the following surveillance tests: 8. Drywell to Torus Vacuum Breakers 8.A.9-1 Weekly Turbine Test 8.A.9-2 Turbine Bypass Valve Operability l 8.E.1-4 Core Spray Instrument Calibration f

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8.M.1-2 Intermediate Range Monitor (IRM)/ Average Power R&nge Monitor (APRM) Calibration 8.M.1-8 Turbine Control Valve Fast Closure

.8.M.1-12 Main Steam High Radiation Monitors 8.M.1-32 Analog Trip System (ATS) Trip Unit Calibration 8.M.2-2 Core Spray Logic Test 8.M.2-2. Reactor Core Isolation Cooling (RCIC) Steam Line High Temperature Instrument Functional Test and Calibration 8.M.2-2.10 Logic System Functional Test, Core Spray System A Drywell High Pressure Auto Initiation Trip 8.M.2- Source Range Monitor Functional 8.M.2-3. Control Rod Block A System Logic Test (Run Mode)

8.M.2-3. Control Rod Block B System Logic Test (Run Mode) 8.3. Control Rod Exercise - Weekly 8.5. Core Spray Pump Operability and Flow Rate Test 8.5. Core Spray Motor Operated Valve Operability Test 8.5. Low Pressure Coolant Injection (LPCI) Pump Operability and Flow Rate Test and Check Valve Test 8.5. LPCI and Containment Cooling MOV Operability. Test 8. RCIC Valve Operability Test 8.5. High Pressure Coolant Injection Valve Operability-8.5. RCIC Quarterly Test 8.5. RCIC Start From Remote Shut .in Station 8.7. Main Steam -Isolation Valve operability Test-Biweekly 8. Manual Start and Load of Each Diesel Generator APRM Calibration Based on observations of test performance and discussions with licen-see personnel, the inspectors determined that surveillance tests were generally well planned and controlled. Both licensee staff and man-agement appeared to exhibit a strong philosophy of procedural compli-ance. In addition, the inspectors noted that-licensee communications were good. Procedure deficiencies were corrected when identifie Unsatisfactory equipment' performance was identified and appropriat corrective actions were take .2 Measurement and Test Equipment (M&TE) The inspector reviewed calibration packages for two instruments tha had failed calibration to verify that all activities that had used - these instruments were properly dispositioned. The inspector traced pressure gage PIA 008-which failed calibration on January 4,1989, to two activi tie The inspector; reviewed procedure 8.4.1, : which was performed on December 24, 198 The ' licensee performed ' an adequate and timely review of procedure 8.4.1 and determined that no action was required since the instrument error did not cause any test result to exceed the equipment allowable tolerance. The results from all activities that utilized this instrument had been returned to- the tool management office by January 26, 198 . _ _ _ _ - _ -

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12 i The inspector traced digital multimeter 186000E which failed cali-bration on May 6, 1988, to fourteen activities that had utilized this instrument since the previous calibration. The inspector reviewed i two procedures, TP 87-22 performed on December 3, 1987, and TP 87-264 performed on January 19, 1988. The licensee performed an adequate and timely review of both these procedures and determined that no action was ' required since the instruments were only used for an indication of power and not for specific value The results from all activities that utilized this instrument were returned to the  ; tool management office by September 8, 198 ! The inspector concluded that in accordance ' with procedure 1.3.36, Measuring and Test Equipment, the licensee was able to trace all activities which utilized a specific piece of test equipment and that the licensee was able to disposition activities that were affected by ' test equipment which failed calibratio However, the inspector , noted that procedure 1.3.36 does not specify a time limit in which  : the personnel responsible for activities affected by test equipment  ! which failed calibration must disposition the affected activity. The i licensee is in the process of revising procedure 1.3.36 to include a i time limit of five days for dispositioning of affected activitie The inspector had no further question .0 Maintenance and Modifications 5.1 Failure of the High Pressure Coolant Injection Steam Admission Valve M0-2301-3 On March 24, 1989, the licensee attempted to perform the cold quick start test on the high pressure coolant injection (HPCI) system with reactor pressure at 1000 psig. The test had previously been success-fully performed with reactor pressure at 150 psig, however the init-ial test at 1000 psig was unsuccessful due to the steam admission  ; valve, MO-7301-3 failure to ope l While troubleshooting MO-2301-3, the licensee discovered that the  ; valve operator motor had open circuited. The licensee's root cause l analysis postulates that the motor failure occurred when the set  ! screw for the close direction torque switch loosened allowing the torque switch setting to increase to the maximum valu With the , torque switch setting that high, the motor experienced locked rotor  ; conditions when the valve was previously operated for routine sur-veillance testing and that the state' windings failed at that time.

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j To determine the extent of damage to the motor operator the licensee j completely overhauled the operator gearbox and performed nondestruc- i tive testing on the operator housing and valve yoke. :These inspec-tions showed damage .to various gearbox components but no evidence of' damage to the operator housing or valve yoke'. The damage to' gear box' components consisted of gear tooth ~ galling and a bentL shaft. .All j damaged components were replaced during- the overhau < The valve was not disassembled as ' the manufacturer's maximum allow-

 .able torque value for the valve body and internals exceeded the maxi- .

mum locked . rotor torque output 'of the valve operator by a significant j ma rgi In addition the torque necessary to unseat the valve was 1 approximately one third of, the maximum' calculated value indicating no internal damag The torque switch set screws did' not previously 'have torque values specified, and, - because of .the materials involved, (stainless steel-screws and bronze), overtightening could cause thread damage. Licen-see contact with the. torque switch manufacturer and review of opera-ting experience at Pilgrim determined that this mode 'of failure is extremely rar The licensee is conducting inspections .of forty safety-related ' motor operated valves to ensure that the loose set screws which led to the motor failure of M0-2301-3 is'not a generic proble i After valve repairs to M0-2301-3 were completed, the licensee suc- i cessfully completed testing on the HPCI system and. declared the. sys-tem operabl The inspector has reviewed the licensee's actions in response to this equipment failure and found . them to be thorough 'and technically- I sound. The licensee successfully completed the cold _ quick' start test on March 31,1989 (see Section'3.8 of this report for amplification).

The inspector had no further question .0 Training i i The purpose of this inspection was to review the effectiveness of the licensee's licensed operator training program for both initial and requal-ification trainin ; I The inspector reviewed the licensee's Nuclear . Training Department (NTD) l program descriptions for.. initial qualification of licensed operators, i requalification of licensed operators' (procedure NTD 3.5),- documentation for initial qualification training of one licensed operator, documentation ;

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of requalification training for six licensed operators, and license I

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interdepartmental memorandum The inspector also interviewed eight licensed personnel, two shift technical advisors (who received the same training as licensed operators), members of the licensee training depart-ment staff, and licensee training and operations management personne The inspector also reviewed recent licensee event reports (LER's) where personnel or procedural error was a cause or contributor to the even The inspector concluded overall initial and requalification training pro-grams satisfied regulatory requirements and were well documente The program descriptions were adequc.te. The inspector noted one unclear description, however, in that the definition of an inactive license in the requalification program description (NTO 3.5) implied that an inactive senior reactor operator would be able to direct fuel handling activities without performing activation training for this duty. Licensee management , stated that this was not the intent of this definition and that no J inactive personnel had performed fuel handling activities. Licensee man- ' agement also committed to clarify this definition in the program descrip- , tion by April 21, 1989. The inspector concluded that the documentation of l program requirements for licensed personnel was thorough and noted that the licensee is developing an improved tracking system for completion of these requirement Documentation of the activation of an inactive license was found to be complet Qualification cards documenting com-pletion of requirements to convert a license restricted to the cold shut-down and refueling modes to all modes were clear and up to date. The inspector noted that the licensta is developing a computerized system to track documentation of shift time to maintain an active license. The sys-tem should be implen.ented by April 14, 1989. The inspector determined by l interviews with licensed operators that they knew the requirements to maintain an active status and were maintaining that status.

' The inspector selected four LER's and requested the licensee to demon- ) strate how these events were incorporated into the training program or to ' justify why they were no The inspector noted that one LER was not incorporated into training because the problem was not within the licensed i operators' task analysis and documentation was not available for the l remaining thre The licensee implemented reviews of eleven LER's for which there was no documentation including the three the inspector selec-ted. After further review, the inspector concluded that the current pro- l gram to incorporate LER's was adequate and that the LER's . had not been ' reviewed because the review system had been recently implemente i Based upon interviews of the licensed operators the inspector noted that ' they were competent within the scope of the areas reviewed, the training instructors were qualified, the training department was responsive to their needs, training materials were good, and simulator training was very good. The inspector also noted that the licensed operators did not seem to be aware of all methods available to provide input to the training pro-gram. The inspector further noted that there were mixed feelings among _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _

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the operators about the benefits of the communications training and. formal 1 communications requirements that' were recently implemented. They -did { indicate that the other departments they interfaced .with had recently a greatly improved the level of formality when' communicating' with - the j operators.

l The. inspetoe also concluded that first line operations and training man- I agers appear involved in operator training and frequently communicate with ~ each other about training issues. The inspector had no further question .0 Radiological Controls- . I 7.1 Organization and Staffing-3 Organization and staffing in the Radiological Section and the newl formed Radwaste and Chemistry Section were reviewed with respect to: i the requirements -in . Technical Specification Section 6.0 and ANSI-Standard N18.1-1971. Performance was determined from interviews with selected personnel and review of resume Within the scope of this review no violations were identified;; how-

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ever, major organizational changes have occurred. These changes and the licensee's stated intentions are described belo . Corporate Radiological Engineering Division This division is to be dissolved and the two functions reassigned. The current manager and two radiological engi-neers will be absorbed into the corporate Nuclear Engineer-ing Divisio The two remaining environmental engineers ; are being transferred to the Pilgrim site to.become part of i the Radiological Section. The. licensee stated tha . this : j change will provide better oversight- of the' environmental -! controls function, allow follow-up on changes to the' off- ) i site dose calculation methodology,- and prevent missed : effluent reports' to the NRC. The inspector had.no furthe ] question . ALARA

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In March 1989 the - ALARA supervisor, two ALARA specialists j and two HP technicians (a total of 5 personnel) were trans- 1 ferred from the Radiological Section to the' Work Package j Planning Division. . The. licensee stated; that this change ' will optimize ALARA performance .through . incorporation of- =! ALARA concepts into the early stages of work planning. The ~' inspector strongly concurred with this concept, but ~ noted that the loss of ALARA expertise and personnel from the Radiological - Section .might impact other worthwhile ALARA' effort ! _ _ _ - _ - _ _ _ - _ _ _ _ _ _ _ _ . _ _ - - .

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The licensee is in the process of rewriting policier and proceduras to implement this change. In addition, the impact of this major change is being monitored by manage-ment to ascertain the effectiveness of the new approac This matter will be reviewed in a future inspectio . Radwaste and Chemistry Section The Radwaste and Chemistry Section was formed in February 1989 in an effort to consolidate the radwaste activities into one organization and to establish clear accountabil-ities for these activities. A temporary position of Rad-waste and Chemistry Section Manager was created with auth-ordty to organize the new section. Existing functions were transferred from Radiological Controls, Engineering, Oper-ations and Chemistry Sections to form the Radwaste Sectio Division manager positions were created and filled by tem-porary personne Other positions remain filled by the incumbents who were in o' ace prior to the reorganizatio A few engineer positions iemain to be fille The licensee stated that the reorganization resulted in an improved ability to continue routine processing of radwaste while undertaking a long range " betterment program." The inspector noted that the radwaste management team was experienced and had a clear understanding of the new re: possibilitie Performance of thic section will be reviewed during a future inspectio . Radiological Section As the result of several personnel transfers out of the Radiological Section as well as r.ew hires to fill vacant positions, the inspector reviewed the status of the section relative to the support of plant operations. New personnel were found to be qualified for their p0sition The changes and reorganizations have not had an apparent impact on the performance of the sectio The inspector had no further questions at this tim .2 Repair of the Fuel Pool Demineralized l The fuel pool demineralized (demin) is used to remove impurities from the spent fuel pool wate The resin used in the ~ demineralized becomes highly radioactive during use. Due to operational problems with this equipment, the licensee decided to remove the demin resin and inspect the resin tank internals. This work was done in phases between January and March 198 i . . _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ - _ - - - - - - - - - - - - - - - - -

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The inspntor reviewed the ALARA and radiological precautions that were then threcch interviews with personnel, review of records and

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inspection of the area. Within the scope of this review the inspec-ter determined that the work was well controlled. Highlights of this work.fol b The demin tank is . located in a shielded cubicle accessible only through a floor plug on the reactor building 91 foot elevatio On initial licensee entry in March 1989, the floor was found -to be covered with several irches of resi Contact dose rates were approximately 10 R/hr. The licensee - decided to remove. the floor resin to lower the worker exposures during the tank inspection 'and repair. The resin was washed into a floor drain. The floor ~ drain was tapped in the cubicle below the tank room so the resin could be pumped into ~ a container in the . radwaste are During the pumping, i the slip-on connection to the drain line was loosened by a surge o resin. This caused some contamination of the second vault but did not' result in personnel ha'zards. The connection was replaced with a threaded type and the work complete A training mock-up was used to prepare the workers to inspect' the resin tank. The inspection required only 20 minutes and resulted'in a 70 millirem dose to 2 worker The - damaged tank. internals were removed and repaired in the " hot machine shop" rather than working inside the tank. Special consider-ations resulted in maximum pre-assembly of repaired parts to minimize-worker time inside the tank. Removal and subsequent re-installation of repaired parts involved a total of 535 man-millirem. There were no skin contamination events nor intakes of radioactive material dur - ing this projec The inspector concluded that the planning, control and execution of this project indicated very good ALARA sensitivity under adverse t6diological conditon .3 Audits The inspector reviewed QA oversight during power. ascension testing activities through discussions. with- the QA. Manager, Audit Division Manager, Surveillance Division Manager and Senior QA Engineer. 'In l March, an indepth audit of radwaste shipping was performed (Report; L No. 89-02). Compliance with basic HP. requirements was confirmed.

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18-For the' year to date, 27 QC surveillance had been conducted. The schedule shows that the emphasis of these surveillance is directed toward operational tests of safety systems such as RCIC. and HPC However, each surveillance also includes an . evaluation of . adherence to HP/ALARA requirement ; Within the scope of tnis review, the. inspector determined that the licensee's conc'uct of QA audits and QC surveillance is' goo .4 ALARA The station has set the exposure goal at 225 man-rem for 1989.,;This includes exposures to be incurred during power ascension' testing and J the October mini-outage. Total exposures are. running slightly.' ahead

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of projection The' inspector attended the station ALARA committee' meeting on , April 6,1989, which discussed exposure. to date' relative. to depart-

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mental budget. Six of the 13 departments are running over budge Each of the 6 department managers described steps that will be taken ! to. reduce exposure to budgeted levels'. The committee chairman stated-that some redistribution of the exposure budgets will occur but..that the station goal of 225 man-rem remains fir The inspector concluded that ALARA efforts at all levels are-aggress . ive and notable progress is being made at reducing worker exposure .0 Followup on previous Inspectiop findings Unresnived Items (Closed) Follow Item (85-27-35) Provide a method to sample the exhaust stacks under post accident conditions. .The licensee's Nuclear Engineering ; Section has decided to use the existing sample rack and add shielding as l recommended in NUREG 0737. Scope Justification Authorization (SJA) 89-001 i has been generated to initiate a plant' design modification. Installation ; of this shielding will be reviewed in a future inspectio '

 (Closed) Unresolved Item (86-17-01) Review ' licensee followup of mode - !

switch problems. The licensee installed a new mode switch in accordance l with maintenance request '(MR). 86-45-96. Temporary Procedure (TP) . 88-76 l was developed to perform the Primary Cont'ainment Isolation System Func- i tional Test. TP 88-76 was reviewed, conduct of. the test.was witnessed and . the test results were ' found to be satisfactory as discussed'in Section '! 3, This item is closed.

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(Closed) Unresolved Item (87-53-05.1) Licensee to conclusively establish the actual cause of the actuation of the startup transformer differential lockout rela During the loss of .off-site- power event on November 12, 1987 an actuation ofL the startup transformer HU-1 differen-tial relay. occurred which tripped and locked out the startup transforme Because the cause -of the actuation could not _be readily established, sig-nificant delays were experienced in . returning the startup transformer t service due to investigation of the transformer uni The licensee evaluated the sequence of events that led up to the differ-ential . relay- lockout using oscillograph from the substation, breaker-operation, . relay targets received, and disturbance reports from REMVA The licensee determined that the startup transformer differential protec-tion logic actuated due to a back electro-motive force (backfeed) from the plant motors' supplied by the startup transformer combined with.a degrading frequency (motor coast down) which resulted in an increasing volts per-hertz indication to the differential protection relay. As a result', the HU-1 transformer differential relay operate The licensee concluded that the operation of the - startup ' transformer's differential relay, HU-1 was correct and acceptable for the incident .and -

conditions which occurred. Further investigation- was conducted with Westinghouse concerning the behavior of this relay under conditions of-motor backfee Alternate relay protection schemes, which would prevent differential relay operations due to overexcitation conditions were evaluated by. the licen-see. These schemes would " desensitize'! to some degree, the transformer differential relay scheme, it would also reduce the effectiveness of the-desired protection. The licensee has concluded that the existing relays 4 are nroviding a level of protection which saves -the transformer from damage due' to overexcitation, and therefore the existing . differentia relay scheme is to be maintaine In response to the November 1987 Loss of Offsite Power, the licensee has installed an Automatic Transient Recording System to monitor the. 345KV switchyard. This oscillograph will aid " the reconstruction and analysis of transient events experienced in th awitchyard and associated 345K transmission lines and possibly significantly reduce the time required to restore the startup transformer to service -after transient events. The inspector had no further question l l l , ________.__________.___A

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9.0 Review of NRC Temporary Instructions 9.1 BWR Power Oscillations (TI 2515/99).

The purpose of this inspection was to' assess the licensee's implemen-tation of.. the requested actions of' NRC Bulletin 88-07, BWR - Power -] Oscillations, including Supplement .1 to that bulletin. The 1icensee performed a detailed review of 29 station procedures and determined that 15 procedures required revisions to address- the power oscilla-tion issu No new procedures were required. - The inspector reviewed' the applicable procedures to verify that: they ' provide symptoms of power oscillations, cautions to avoid potentially unstable operating situations, and actions to terminate power oscillations ,1f they i occur. The inspector noted deficiencies in several procedures. Pro- i cedures 2.4.33,' Condenser Chloride Intrusion, and 2.4.40, Rapid i Increase in Off Gas Flow, require power reductions but the procedures-have not been revised to ' include cautions regarding core power instabilit Procedures 2.1.1, Startup from Shutdown, 2.1.14, Sta-- l tion Power Changes, 2.4.37, Turbine Control Msifunction, and 2.4.44, Loss of Drywell Area Cooling, were revised to include - cautions regarding core power oscillation but those- procedures used the te"- minology of " recirculation flow" and " core flow"'as being synorjmou The correct terminology is " core flow". The - licensee committed to review these procedures and make revisions as necessar The inspector reviewed. operator training lesson plans and determined that the training material properly addressed the power oscillation issue. Training was initially conducted for all licensed cperators , and shift technical advisors (STA's) for NRC Bulletin 88-07. Follow- i up training was conducted for NRC Bulletin 88-07 Supplement 1. As of , the date of the inspection, initial training. had been completed for ' all licensed operators and followup training has been completed for all but two active licensed operators and three inactive licensed operators. The licensee committed to complete followup. training for the two active licensed operators prior to exceeding 25% reactor power and the inactive licensed operators as time permit , i The inspector interviewed eight licensed operators and .two shift ! technical advisors to determine' familiarity. with power oscillations and the actions required to mitigate a power oscillation transien Generally, the personnel interviewed were familiar' with this topic

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L i l and the applicable plant procedure revisions. However, the inspector-noted that an SR0 and the STA from the same shift did not demonstrate- l adequate familiarity with symptoms of power oscillation ' events and

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the actions required to ' mitigate. power oscillations. . The licensee committed to re assess the knowledge level of the entire shift regarding power oscillations and to perform remedial training cf the entire shift if neede _ _ _ - _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _

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E l 21 i In summary, the licensee adequately implemented the requested actions of NRC Bulletin 88-07 and Supplement The training department developed lesson plans and conducted training which clearly addressed the concerns and required operator actions to avoid, detect and miti- i gate power oscillations. Generally, the licensed operators and shift ! I technical advisors were knowledgeable of the procedure revisions an ( understood the material presented by the training departmen .0 Review of Licensee Self-Assessment Activities j . The inspectors routinely monitored the licensee's inplace programs to ; assess facility and personnel performance. The licensee has implemented a formal peer evaluation program of routine personnel performance monitor-ing. The individuals selected for the peer evaluator program are selected i from the onsite organization, receive training on performance monitoring I techniques and are assigned to monitor specific activitie The peer evaluator _ provided twenty-four hour operations monitoring during the period March 12 through March 23, 1989. Routine audits of other facility activities were conducted throughout the inspection period. The peer evaluators held regular debriefings with audited organizations to l l discuss identified strengths and weaknesses. NRC inspectors ~ attended f I these briefings and observed that both positive and negative findings were I discussed in a frank open atmosphere. The audited organizations continue to be receptive to this process and the training, resolution and closecut of findings continues to be timely and thoroug I

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Management presence in the plant during this period remained relatively stable as compared to the last report period. Routine presence of middle and senior level management in the control room and in the plant continued J to be noted. Management oversight and control of routine and abnormal i activities continued to show that the licensee has set high performance I standard ;

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The licensee's quality assurance organization continued to implement a , special audit program for the power ascension program. The presence of 1 quality assurance and quality control personnel in the plant during the inspection period continued to be substantia Management efforts in assuring high standards of facility and personnel performance were evident throughout this inspection period. The licensee continued to be self-critical in this self assessment period and overall management performance was goo :

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11.0 Management Meetings An NRC Restart Assessment Panel meeting was held on April 3,1989, at the ; Pilgrim Nuclear power Station. NRC management from Region I and Head- ' quarters were onsite for the meeting and additional Region I and Head-quarters management participated via teleconference. The assessment panel received a presentation from the licensee on their assessment of the results of the 5 to 25% power ascension program. The licensee handout for the presentation is included as Attachment II to this repor At periodic intervals during the inspection period,. meetings were held with senior facility management to discuss the inspection scope and pre-liminary findings of the resident inspectors. A final exit interview was conducted on May 22, 1989. No written material was given to the licen-see that was not previously available to the publi l l _ ------- --- _ _

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Attachment I to Inspection Report 50-293/89-05 Persons Contacted R. Bird, Senior Vice President - Nuclear K. Highfill, Site Director R. Anderson, Plant Manager D. Eng, Outage and Planning Manager E. Kraft, Training Department Manager D. Swanson, Nuclear Engineering Department Manager D. Long, Plant Support Department Manager J. Alexander, Operations Section Manager i J. Jens, Radiological Section Manager I J. Seery, Technical Section Manager R. Sherry, Maintenance Section Manager L Olivier, Chief Operating Engineer J. Neal, Security Division Manager W. Clancy, Systems Engineering Division Manager F. Wozniak, Fire Protection Division Manager i l l l I

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ATTACHMENT II - BECO SLIDES FOR PRESENTATION TO NRC RESTART ASSESSMENT PANEL-ON APRIL 3, 1989

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PILGRIM STATION

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POWER ASCENSION PROGRAM l

. PILGRIM STATION HAS SAT;SFACTORIL COMPLETED THE POWER ASCENSION PROGRAM j TO THE 25% POWER LEVEL NRC HOLD POINT
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THE LINE ORGANIZATION HAS PERFORMED EFFECTIVEL THE PLANT AND PEOPLE ARE READY TO PROCEED TO 50% POWER FOR-SCHEDULED TESTIN ACTIVITIES REMAINING AT 25%

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PLANT ' STATUS a SLIDE 1h I

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, FINDINGS CONTINUE TO BE FORMALLY l

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DOCUMENTED AND DISPOSITIONED l l

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. REQUEST FOR INVESTIGATION RECOMMENDATION FOR IMPROVEMENT (RFI)
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MAINTENANCE REQUESTS (MRs)

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FAILURE AND MALFUNCTION REPORTS (F&MRs)(INCLUDES ROOT CAUSE ANALYSES)  ; i

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QUERSIGHT AND ASSESSMENT DECISION PROCESS l l l RECOMMENDATION TO NRC l t DECISION B

  . L SENIOR UICE PRESIDENT - NUCLEAR-    t (MO&AT CHAIRMAN)    i at RECOMMENDATION f

MANAGEMENT GUERSIGHT AND MD&RT INDIUIDURL

   +  INPUTS ASSESSMENT TEAM (MO&RT)

PEER EURLURTOR QA LINE MANRGEMENT ASSESSMENTS ASSESSMENTS RECOMMENERTIONS

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j SCOPE OF OUERSIGHT

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l I THE OUERSIGHT PROGRAM HRS PROUIDED EXTENSIDE FORMAL COVERAGE OF THE ; POIDER RSCENSION PROGRAM

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POIDER ASCENSION PROJECT (PEER EURLURTOR) i RSSESSMENT CONCLUSION: OBSERVED PERFORMANCE SUPPORT PROCEEDING IUITH TEST PROGRAM TO 50% POIDE ~ DISCIPLINES EURLURTED o OPER ATIONS o M A INTEN ANCE ' MECHANICAL ELECTRICAL l l&C l 0 RADI ATION PROTECT 10N 0 CHEMISTRY o SECURITY < 0 FIRE PROTECTION

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QUALITY ASSURANCE DEPARTMENT ASSESSMENT CONCLUSION: OBSERVED PERFORMANCE SUPPORTS PROCEEDING WITH TEST PROGRAM TO 50% POWER ,

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STRENGTHS AREAS TARGETED FOR ADDITIONAL IMPROVEMENT

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LINE MANAjglEMENT RECOMMENDATIONS l CONCLUSION: PERFORMANCE OF PLANT AND PERSONNEL SUPPORTS PROCEEDING TO THE 50%: POWER LEVEL PORTION OF THE TEST PROGRA TEST PROGRAM RESULTS

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. RESTART READINESS SELF ASSESSMENT STATUS of COMMITMENT ITEMS i

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L l . . RECOMMENDATION

1 BOSTON EDISON RECOMMENDS NRC APPROVE PROCEEDING WITH THE POWER ASCENSION PROGRAM TO THE 50% LEVE RECOMMENDATION BASED UPON SEPARATE ASSESSMENTS OF STATION PERFORMANCE INDICATING READINESS TO PROCEED BY:

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THE PLANT AND PERSONNEL ARE PERFORMING WELL. WE ARE FINDING THE THINGS THAT NEED TO BE ADDRESSED AND ARE TAKING APPROPRIATE ACTIONS TO RESOLVE THE WE ARE READY FOR THE NEXT STEP SLIDE 9 _ _ _ _ - - _ _ _ ~

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l t l i ATTACHMENT II (CONTINUED) -- BECD SLIDES FROM APRIL 3, 1989 l

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Status of Pilgrim Emergency Planning Issues From March 3, 1989 to Present i i l

Boston Edison Company J l

This report is being submitted on behalf of Boston Edison company in response , to a request from the NRC staff. It does not necessarily represent the views or opinions of the Commonwealth of Massachusetts or any of the local-governments around Pilgrim Station.

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STATUS OF EMERGENCY

   . PLANNING ISSUES Bridgewater Issue: E0C Renovations / Facility Equipment Placemen .

Proaress:

 * EOC renovations are complet .
 * EOC equipment is complete except for the provision of:
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  - miscellaneous office supplies Issue: Training Proaress:

Training of local officials:is continuing. One session was conducted 4 3/28/89. Two sessions are scheduled for 4/3/89, and.4/24/8 .y

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i STATUS OF EMERGENC PLANNING Bridaewater l Issue: E0C Staffing-for 24 hours I l Progress: l Complete as of 1/25/8 .

      -)

' 38 operational staff positiens required for extended response; all' <

      ~I are fille administrative support staff identified for extended response;:all .I I

are fille ~ Issue: Plans & Procedures  ; Proaress: Revised draft emergency plan and initial draft. implementing procedures were forwarded to MCDA and subsequently forwarded.-to' FEMA on Sept. 21, 1988. Results of the FEMA informal technical review ~ ; were received on 2/10/89. Corrective' action response has bee ! prepared and will be reviewed with the town during the week of 4/3/8 , r i i

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i l STATUS 0F EMERGENCY

PLANNING ISSUES

      -]

Bridaewater -

      -l Issue: Equipment     l
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Proaress:

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* Traffic control: complete
* Communications: complete except for:
 * 12 radio beepers for the Highway Department
      ..

Issue: Public Information Brochure . Proaress;  ; The wording of the initial draft of the entire Public Information , Brochure (PIB) was accepted by the Commonwealth on 12/7/ BECo final copy review sheet was signed by Bridgewater on 12/21/88. ;0n 1/4/89 MCDA called fo an additional town and Commonwealth review. The town comment deadline,  ! originally 1/18/89 was extended to 3/2/89. To the best of our knowledge, no  ; additional comments have been received, and that MCDA is assuming the towns- ' have no additional comments. Brochure will not be printed until written - authorization is received from MCDA per meeting of 12/12/8 :

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Bridgewater

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STATUS OF EMERGENCY i i' PLANNING ISSUES Bridgewater: l u Issue: Reception Center Renovations

 ~Proaress:

Reception Center Renovations: 'I Discussions with Bridgewater State College.about reception center enhancements to the building have been ongoing, and-the' Board of i i- Trustees voted to proceed with enhancements on-2/23/8 Implementation of the improvements is being coordinated with '; i Bridgewater State College, MCDA, and.the' Division of Capital Planning l Office. Work has been~ scheduled to begin immediately.after the.end I of the current academic-ter Equipment: q e Monitoring & decontamination': Bladder. delivered 3/21/B * Registration: Delivered l d e Dosimetry: Delivered

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STATUS OF EMERGENCY PLANNING ISSUES Carver Issue: EOC/ Facility Renovations / Equipment Placement Progress: EOC renovations complet . EOC equipment is complete with the exception of:

    * Provision of office supplies, paper, pencils, paper clips, et * Provision of a few additional chair . EHMD Renovations are scheduled to occur in early Spring when the building becemes availabl Issue: Training Proaress:

Training is continuing in Carver. Two sessions were conducted on 3/4/89 and 3/18/89. One more is scheduled for 4/2/8 Note: The training conducted on 3/18 had been rescheduled from 3/1 Carver Page 1 of 3 l 03/31/89 _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _

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STATUS OF EMERGENCY PLANNING ISSUES Carver

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Issue: EOC Staffing for.24 hours Proaress: 46' operational staff positions required for extended

  . response. 43 of these are fille administrative support staff positions required for extended-response. 6 of these are fille Issue:  Plans and Procedures Proaress:

Revised draft emergency plan and initial draft implementing procedures were forwarded to MCDA and subsequently forwarded to FEMA on 10/12/88. 'Results of the FEMA technical. review were received on 2/10/89. Corrective action response has been prepared and is currently under review with the town.

l Carver Page 2 of 3 03/31/89

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STATUS OF EMERGENCY PLANNING ISSUES Carver 111Mg: Equipment Proaress:

 * EWMDS: Delivered e Traffic control: Delivered e Dosimetry: Delivered e Communications: Delivered except for:
  - handheld radios for the Carver Police Dep litug:  Public Information Brochure Progress:

The wording of the initial draft of the entire Public Information Brochure (PIB) was accepted by the Commonwealth on 12/7/8 Carver final review of the BECo draft was signed on 12/20/88. On 1/4/89, MCDA called for an additional town and Commonwealth revie The town comment deadline, originally 1/18/89, was extended to 3/2/89. To the best of our knowledge, no additional comments have been received, and that MCDA is assuming the towns have no additional comment Brochure cannot be printed until written authorization is received from MCDA per meeting of 12/12/8 Carver Page 3 of 3 i 03/31/89 _ _ _ _ _ _ _ _ _

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STATUS OF EMERGENCY PLANNING ISSUES Duxbury Issue: E0C Renovations / Equipment Placement Proaress:

* EOC renovations complete
* E0C equipment is complete except for the provision of:

e VCR e Miscellaneous Office Supplies Issue: Training Proaress: Training is continuing in Duxbury. Two sessions were conducted on 3/14/89 and 3/15/89. One session is scheduled for 3/31/8 I

l l Duxbury Page 1 of 3 l

03/31/89 1

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STATUS OF EMERGENCY PLANNING ISSUES Duxbury liing: EOC Staffing for 24 hours Progress: 40 operational staff positions required for extended respons of these are fille administrative support staff required for extended response. None of these are fille Issue: Plans & Procedures Proaress:

  * Initial draft emergency plan previously provided to MCDA/ FEMA. Comments received have been incorporate * 41/44 procedures reviewed by agency head * Agency head procedure review committee has completed a review of 41/44 procedures and forwarded them to the RERP Committee Chair. The RERP Committee is scheduled to review all IPs then forward them to the Selectmen for review by 5/1/89. The Selectmen are scheduled to complete their review by 5/13/89.

i l Duxbury 03/31/89 _ _ - - - - _ - - _ - - - - -)

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STATUS OF EMERGENC PLANNING ISSUES Duxbury , Issue: Equipment Proaress:

   * EHMDS - Delivered     l
   * Traffic control - Delivered'
   * Dosimetry - Delivered    I
   * Communications - Delivered Issue: =Public Information Brochure
        :

I Proaress:

        )

The wording of the initial draft of the entire Public I Information Brochure (PIB) was accepted by'the Commonwealth.on  ; 12/7/88. The BECo final copy review sheet.was signed by Duxbury 1 in December 1988. On 1/4/89, MCDA called for an additional town and Commonwealth review. Duxbury returned comments on 1/16/89.' i Brochure will not be printed until written authorization is  ! received.from MCDA per 12/12/88 meetin ! l

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Duxbury 03/31/89 _ _ _ _ - - _ _ - _ - _ ___ -

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STATUS OF EMERGENCY PLANNING ISSUES Kinaston liing: E0C Renovations / Facility Equipment Placement Proaress: EOC renovations are complete EOC equipment is complete with the exception of:

 * Provision of table for facsimile machine
 * New maps 131ge: Training Proares1:

Training is continuing in Kingston. Four sessions were conducted on 3/10/89, 3/13/89, 3/15/89, and 3/23/89. One session is scheduled for and 4/5/8 Kingston Page 1 of 3 03/31/89 -

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  • a STATUS OF EMERGENCY PLANNING ISSUES Kinast0D ISlya: EOC Staffing for 24 Hours Procress:

46 operational positions are required for extended response. 43 of these are fille administrative support staff positions are required for extended response. 7 of these are fille gg: Plans and Procedures Progress: Revised draft emergency plan and initial draft implementing procedures were forwarded to MCDA, and subsequently forwarded to FEMA on 10/12/88. Kingston received FEMA comments from the Commonwealth 2/8/89. Corrective action response has been prepared and is under review by the tow i Kingston Page 2 of 3 03/31/89

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STATUS OF EMERCENCY PLANNING ISSUES Kinaston 111ge: Equipment Proaress: EHMDS - Delivered Traffic control - Delivered Dosimetry - Delivered Communications - Delivered except for:

 * 10 additiona' portable radios for the Police Departmen * Pager liing: Public Information Brochure Proaress:

The wording of the initial draft of the entire Public Information Brochure (PIB) was accepted by the Commonwealth on 12/7/88. On 1/4/89, MCDA called for additional town and Commonwealth review. The town has reviewed and approved the current PIS draft. Brochure will not be printed until written authorization is received from MCDA per 12/12/88 meetin Kingston Page 3 of 3 03/31/89 _ _ _ - _ _ _ _ _ _

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STATUS OF EMERGENCY l PLANNING ISSUES Marshfield  ;

       )

lisus: E0C Renovations / Facility Equipment Placement i Proaress:

* E0C building renovations are complet e All equipment has been delivered except:
 * 1 VCR      l
 * Miscellaneous office supplies
       ,

Issue: Training i Proaress: j Training is continuing in Marshfiel Two sessions were conducted on 3/9/89 and 3/14/89. Nine sessions are scheduled for 4/17/89, , 4/19/89, 4/20/09, 4/21/89 and 4/26/89, 5/3/89. Note: Two sessions I are scheduled for 4/19/89, 4/20/89, and 5/3/8 l l Marshfield Page 1 of 3 03/31/89 _ _ - _ _ _ _ _ -

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STATUS OF EMERGENCY PLANNING ISSUES  ; Marshfield l Issue: EOC Staffing for 24 Hours )

i Proaress: 38 operational staff positicns required for extended response. 26 of these are . fille administrative support staff positions required for extended response. One of these is fille Issue: Plans & Procedures Proaress: Initial draft emergency plan and initial draft implementing

 : procedures were forwarded to MCDA, and subsequently forwarded to FEMA on 8/8/88. FEMA technical review was received on 2/10/8 Corrective action response has been prepared and will be reviewed with the town on 4/4/8 !

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Marshfield Page 2 of 3 l

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1 STATUS OF EMERGENCY PLANNING ISSUES i Marshfield l Issue: Equipment l

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Progress: EHMDS - Delivered Traffic control - Delivered Dosimetry - Delivered

       ;

Communications - Delivered except for: l

 * 2 CB radios for the Schoo Issue: Public Information Brochure    {

Proaress: The wording of the initial draft of the entire Public Information J Brochure (PIB) was accepted by the Commonwealth of 12/7/88. On 1/4/89, MCDA called for an additional town and Commonwealth revie The town comment deadline, originally 1/18/89, was extended to ' 3/2/89. To the best of our knowledge, no additional comments have been received, and that MCDA is assuming the towns have no additional comment Brochure will not be printed until written authorization is received from MCDA per meeting of 12/12/8 I i

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03/31/89

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STATUS OF EMERGENCY PLANNING ISSUES P_lymouth Issue: EOC Renovations / Facility Equipment Placement ,

       !

Progress: E0C renovations are complete. All equipment is in plac Issue: Training

Proaress:

Training is continuing in Plymouth. Thirteen sessions have teen conducted since 3/3/89. Twelve sessions are scheduled through April into mid-May, i Plymouth Page 1 of 3 03/31/89

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STATUS OF EMERGENCY PLANNING ISSUES Plymouth l liing: E0C Staffing for 24 Hours i I Proarest: There are 44 operational staff positions required for extended response. 32 of these have been fille l There are 8 administrative support staff positions ' required for extended respons of these have been fille l 111ME: Plans & Procedures )

i Proaress: l

 = Initial draft emergency plan previously provided to MCDA/ FEM Comments have been incorporate = 56*/57 procedures reviewed by agency head * 51/57 procedures reviewed by Selectme l l

Jordan Hospital has opted to use their own approved all-hazards

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emergency plan.

j Plymouth l Page 2 of 3 ! 03/31/89

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STATUS OF EMERGENCY PLANNING ISSUES Plymouth Ls_ing: Equipment

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Proaress: EHMDS - Delivered Traffic control - Delivered Dosimetry - Delivered j Communications - Delivered except for: e multi-frequency radio rack * 24 CBs for school Issue: Public Information Brochure

       :
       ;

Proaress:

The wording of the initial draft of the entire Public Information  ; Brochure (PIB) was accepted by the Commonwealth of 12/7/8 Plymouth i sign-off on BECo final copy of 12/88 was completed of 12/20/88. On ' 1/4/89, MCDA called for an additional > town and Commonwealth revie Comments were due back.to the Commonwealth by 1/18/89-and Plymouth complied with this request. Brochure will not be printed until written authorization is received from MCDA per meeting 12/12/8 i

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03/31/89

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STATUS OF EMERGENCY PLANNING ISSUES I Taunton

       )

Issue: EOC Renovations / Facility Equipment Placement PrDET911: t

 * E0C building renovations are complet I
 * Equipment delivery is complet lis_qe: Training i

Progress:  ! Training is continuing in Taunton. One session was conducted on 3/15/8 Three sessions are scheduled for. 4/5/89, 4/13/89, and 4/27/8 i l Taunton Page 1 of 4 l 03/31/89 I _ _ _ . _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ ~

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STATUS OF EMERGENCY PLANNING ISSUES-Taunton l' Issue: EOC Staffing for 24 Hours .l Proaress: . 40 operational staff positions required for extended response. 38 of.these are fille ,

        ,

10 administrative support staff positions required for-extended response. All of. these are fille Issue: Plans and Procedures Proaress: Revised draft emergency plan and initial draft implementing I procedures were forwarded to MCDA and subsequently forwarded to FEMA ! on 8/8/88. The results of the FEMA technical review were received on ' 2/10/89. Corrective action re'sponse has been prepared and will'be reviewed with the city during the week'of 4/3/8 ,

        -)

i i i i Taunton Page 2 of 4  ! 03/31/89 . _ _ _ - _ _ _ _ _ _ - ____ _-

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STATUS Or EMERGENCY PLANNING ISSUES i Taunton Issue: Eqiiipment i I Proaress: l Traffic control: Delivered I Communications: Delivered Issue: Public Information Brochure Proaress: The wording of the initial draft of the entire Public Information Brochure (PIB) was accepted by the Commonwealth on 12/7/8 Taunton signed review sheet of BECo final copy dated 12/88. On 1/4/89,'MCDA I called for an additional town and Commonwealth review. The town comment deadline, originally 1/18/89, was extended to 3/2/89. To the best of our knowledge, no additional comments have been received and that MCDA is assuming the towns have no additional comments. Brochure will not be printed until written authorization received from MCDA per meeting of 12/12/8 Taunton Page 3 of 4 03/31/89

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STATUS OF EMERGENCY PLANNING ISSUES l Taunton liing: Reception Center Renovations / Equipment Placement Proaress: Reception Center Renovations: Taunton State Hospital is designated as the reception center. Currently, the Cain Building is serving as the interim facility to be used'for registrations, monitoring, and decontamination. Layouts for-th building have been provided to Hospital-Administrators, MCDA, and Taunton Civil Defense. The' building has been cleaned and organized. Portable shower facilities and a portable generator are in place. Proposed final measures to establish a long term facility involve construction of a new building on hospital grounds. Discussions are underway with hospital administre, tors to define buildi1g parameter Equipment:

 * Portal monitors - Delivered
 * Monitoring & decontamination - Delivered
 * Registration - Delivered
 * Dosimetry - Delivered Taunton Page 4 of 4 03/31/89

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9 STATUS OF EMERGENCY PLANNING ISSUES Commonwealth

         !

Inut: Area II Improvements / Equipment Placement Proaress: Currently the Area II E0C is operationa Boston a Edison continues discussions with MCDA concerning l improvements to the facility and its equipmen I Issue: Commonwealth, County, and Federal Training i Proaress: Training is continuing with the Commonwealth, County, and Federal l agencie One session was conducted 3/27/8 i Commonwealth Page 1 of 5 03/31/89

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STATUS OF EMERGENCY PLANNING ISSUES Commonwealth Litug: Area II Staffing for 24 Hours Progress: 40 operational staff positions required for extended respons * positions are fille administrative support staff positions required for extended respons * positions are fille * HCDA Framingham has committed to providing support to fill all posi . ion Issue: Plans and Procedures Progress: The results of the FEMA informal technical review dated 1/31/89 of the Area II Plan have been received. Comments are being ' incorporated in an updated revision. Corrective action response has been prepared and is under review by Area II, MCD Area II Implementing Procedures have been drafted and were submitted t- 2/9/89 to FEMA for an informal technical revie Commonwealth l Page 2 of 5 03/31/89 _ - _ _ _ _ _

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STATUS OF EMERGENCY PLANNING ISSUES Commonwealth Issue: Equipment

        .

Progress:

   *: Traffic Control - Equipment has been identified and is
   ?n the process of being ordere * Monitoring /Decon - Equipment has' been identified and is in the process of being ordere * Dosimetry - All. dosimetry has been delivered except for:
    -

Transportation providers pending receipt of charger Dept of Environmental Managemen (Hyles Standish State Forest) pending receipt of traffic control equipmen MA: Public Information Brochure Progress: The wording of the initial draft of the entire Public Information-Brochure (PIB) was. accepted by the Commonwealth on 12/7/88. On 1/4/89, MCDA called for an additional town and state revie Comments were due back to the state by 1/18/89, however, the deadlin was extended to 3/2/89. To the best of our knowledge, no additional l comments have been received, and that MCDA is assuming the towns have ' no additional comments. Printing and distribution will begin when written authorization is received from HCDA per meeting on 12/12/8 Commonwealth Page 3 of 5 03/31/89 _ _-______ _ __________-. _ _ _ _ _ _ _ _ _ _ _ . _ - _ _ .____ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ - _ _ _ _

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STATUS OF EMERGENCY PLANNING ISSUES Commonwealth Issue: Reception Center Renovation / Equipment Placement Progress: Reception Center Renovations: Long term enhancements to the Hellesley DPH garage are currently being discussed with DPH and MCDA representatives. Planning meetings are held every Thursday morning at Area II for this purpos Equipment: e Monitoring & decontamination - M/D equipment delivered to facility 2/13/8 Bladder was delivered 3/21/8 Shower trailers were delivered 3/22/8 ) e Registration - Delivered a Dosimetry - On hand at BECo

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i Commonwealth Page 4 of 5 03/31/89 J _ _ . . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _

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STATUS OF EMERGENCY q PLANNING ISSUES i Commonwealth Issue: Transportation Provider LOA i Proaress: l

        !

All transportation provider resource commitment and ! response time data was reformatted in accordance with directions from the Commonwealth and compiled into updated letters of commitment. The letters of commitment have been signed by the transportation providers and are currently in the custody of MCD Issue: Transportation Provider Trainin . Progress: I Transportation provider training is continuing. One session is scheduled for 4/1/8 l l

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Commonwealth Page 5 of 5 l 03/31/89 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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