ML20033C663
| ML20033C663 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/14/1981 |
| From: | Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Corey A BOSTON EDISON CO. |
| Shared Package | |
| ML20033C664 | List: |
| References | |
| CON-#487-5009 2.206, NUDOCS 8112030603 | |
| Download: ML20033C663 (6) | |
See also: IR 05000293/1981020
Text
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- Docket No.' 50-293- 'OK Boston Edison Company ATTN: Mr. A. Corey /# g .y ! Senior Vice President //[, - 4- s Operations and Engineering 9 4 . 800 Boylston. Street .k NOVl 61b ~ p% K s. D M @ 'ose Q Boston,11A 02199 ~ Gentlemen: \\ Subject: Perfomance Appraisal Inspection 50-293/81-20 / Q (T? , This refers to the Performance Appraisal Inspection conducted by Mr. C. R. Oberg, . 10-14,198I, Office of Inspection and - and members of the Performance Appraisal Section of activities authorized by Enforcement, on July.20-31 and August NRC Operating License DPR-35 for the Pilgrim Nuclear Plant. This also refers e to the observations discussed with you or other members of your staff on July 30 and August 14, 1981, at the Boston Edison Company corporate offices. This inspection is one of a series of Performance Appraisal inspections being conducted by the Office of Inspection' and Enforcement. The.results of these inspections are used to evaluate, from a national perspective, the performance of your management control programs in support of Nuclear Safety. The enclosed report 50-293/81-20 identifies the areas examined during the . . inspection. Within these areas, the inspection consisted of a comprehensive
examination of your management controls over licensed. activities which included examination of procedures and records, observations of work activities, and interviews with managenent and other personnel. While the enclosed report includes observations which may result in enforcement actions, these matters will be followed by the IE F'egional Office. The enclosed- appraisal report also addresses other observations and the. conclusions made by the team for this inspection. Section 1 of the report provides further information regarding the observations and how they will.be utilized. Appendix A to this letter is an Executive Summary of the conclusions drawn for the eight functional areas inspected. . . Of-the eight areas inspected and evaluated, two areas were considered average;. , however, significant weaknesses were identified in these areas which will ' require management attention. Six areas were considered below average. -These ' were the.. areas of. committee activities, quality assurance audits, maintenance,
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corrective action systems, licensed and.non-licensed training, and procurement.
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' . . Comendably, the tean noted strong attention was provided by Boston Edison Company top management to those aspects of Pilgrim's operation associated with maintaining on-line electrical production. Ilowever, similar attention was not being provided to important areas of management controls which contribute to assuring public health and safety and which were found to be generally below average at Boston Edison. This unbalanced approach within top management was emphasized by fiRC at the exit briefing and will be discussed at a meeting with senior Boston Edison Company management to be arranged by the fiRC Director, Region I. As a result of the significant weaknesses identified in the six areas rated below average, you are requested to inform this office within 30 days of receipt of this report of the actions you have taken or plan to take to improve the management controls in these areas. Your response to this office and your actions regarding identified weaknesses will be followed by the Region I f4RC Office. In accordance with 10 CFR 2.790 of the Comission's regulations, a copy of this letter and the enclosed inspection report will be placed in the liRC's Public Document Room. If this report contains any information that you believe to be exempt from disclosure under 10 CFP. 9.5(a)(4), it is necessary that you (a) notify this office by telephone within seven (7) days from the date of this letter of your intention to file a request for withholding; and (b) submit within twenty-five (25) days from the date of this 7etter a written application to this office to withhold such infomation. If your receipt of this letter has been delayed such that less than seven (7) days are available for your review, please notify this office promptly so - . ' that a new due date may be established. Consistent with Section 2.790(b)(1), any such application must be accompanied by an affidavit executed by the owner of'thes information which identifies the document or part sought to be withheld, and which contains a full statement of the reasons on the basis which it is claimed that the infomation should be withheld from public disclosure. This section further requires the statement to address with specificity the considerations listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from yod in this regard within the specified periods noted above, the report will be placed in the Public Document Room. Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, 5l Norman C. Moseley, Director Distri: Division of Program Development es 7 r/f and Appraisal PDA r/f Office of Inspection and Enforcement PDR LPDR Enclosures: NW ], {{ ag;33; 7 3t Appraisal Repert 50-293/81 90 mc' > . . . A .P"ndix, - Executive Summa P g i ,, , . ..... . , , ,, ,,, ,,,,,,,,,, , ,,, ,,,, .g%.... 2 ..g1 =* .3 . tg. . en.... .. ... . .. .. . . .. .. ... ...... .. . 9 81 ,,,g, .
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V.-Stello, DED0 1 H.-R. Denton, NRR I - C.'Michelson, AE00 W. P. Haass, NRR. S. H. Hanauer, NRR H. Boulden, OIA .-. SALP J. R. Johnson,' NRC Senior Resident Inspector J. H. Sniezek, RRRI R.1:. DeYoung, IE ~H. D. Thornton, IE- N. C. Moseley, IE. J. M. Taylor, IE Regional Directors. NRR Project Managers % Region I Reading Room All Licensees E.-P. Wilkinson, INP0 D. Goddard, Oregon Dept. of Energy State of Massachusetts PDR LPDR NSIC NTIS- PAS Files . IE Files PAS Regional' Coordinators , T 4 1 . .- gu7u . _ - - _ _ - - -
. . Appendix A Executive Summarv A team of five NRC Inspection Specialists from the Performance Appraisal Section conducted an announced inspection at the Pilgrim Nuclear Power Station and Boston Edison Company corporate offices during the period July 20 - August 14, 1981. Management controls in eight areas were inspected. Of these, two areas were considered average and six' areas were considered below average. The numerous below average areas appeared to be the result of several factors, all affecting the existing management control systems. First, the Performance Appraisal Team found that management personnel were lacking in knowledge and understanding of the extent of their quality assurance program responsibilities. Thus there was limited management oversight and involvement in the control of activities in this area. This was aggravated by a reluctance of some management personnel to cross
over the established and traditional lines of communication and organization. Conflicts between groups were also identified that apparently were the direct result of a failure to communicate and bridge differences in the support of a common goal. Second, there was a lack of written policy involving training of personnel at corporate and site levels. Other written program deficiencies were identified. Third, there appeared to be a lack of emphasis by management to correct problems by the identification of generic causes and subsequent manage- ment follow-through to ensure effective corrective action. There was rapid response to some of the deficiencies identified during the PAS inspection; however, many of one problems identified had been previously reported to the licensee by QA audits and NRC inspections but were not corrected. It was noted that training record deficiencies were corrected before the end of the PAS inspection. This was a result of licensee commitments that were identified in an Immediate Action Letter (IAL) issued by Region I on July 31, 1981. And, finally, there was the apparent goal of top management to achieve superior on-line time at Pilgrim and gr.in national recognition of that accomplishment. While this is a legitimate objective, the results of such a course of action, untempered by safety considerations in the form of effective management controls could be detrimental to the health and safety 'of the public. Balanced against these problems, the Performance Appraisal Team found that management had realized that resources must be provided to ensure that the plant will operate safely as well as effectively. The team identified positive steps that had been taken in providing additional training instructors, additional personnel in the reactor operator qualification pipeline, plans for enlarging the QA staff, and an improved maintenance control system. These positive steps had partially resulted from a reorganization and a change in some management positions.
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, ' Appendix A (continued) 2- - The team _ also noted that:some of these reasons for below average ~ . , performance.were recognized by the licensee, and there were corrective actions;and plans in various stages of implementation. The following information is a summary of the inspection results of the. ~ -individual areas. Committee Activities: Below Average (Section 2). The significant. weak- nesses of the onsite Operations Review Committee were an inadequate - charter and failure to review internal audit reports, NRC Inspection- ' Reports and responses thereto, NRC Bulletins and Circulars, and the Fire Protection Plan. For..the_Noclear Safety Review and Audit Committee, the significant weaknesses'were an inadequate charter,. lack of awareness of- , . committee responsibilities by committee members,--and failure to review ' internal. audit reports. Quality Assurance Audits: Below Average (Section 3).- The most signifi . cant weaknesses could be divided into three broad categories: . failure to implement the program, failure of management to be responsive'to and support the program, and program inadequacies. In the first category, the licensee failed to meet schedule requirements- ~ - such as issuing various reports, verifying corrective action on out- standing deficiencies, and performing all the required audits. -Also there was the. failure to perform trend analyses, an inadequate scope on corrective action audits, and failure of the Nuclear Safety Review and t Audit Committee to perform adequate reviews of the program, audit reports, and deficiencies. L In the second category, management failed to respond.to-QA's need for resources to complete program requirements. They failed to take action . to resolve serious deficiencies ~in a timely manner, to encourage staff members'to be responsive to r'esolving deficiencies, and to create a-
healthy, constructive atmosphere between QA and the staff. ' The third category had one significant weakness: an inadequate method to escalate and resolve serious or controversial deficiencies. ' i . . i ' ~The strengths of the program included the excellent depth of audits and- l . - . , f surveillance inspections, the use of " Technical Specialists" to augment the audit staff for.their technical expertise on certain audit subjects,. and a positive _ attitude toward correcting problems identified.by the' f Performance Appraisal 1_nspection. With the corrective actions in place
- at the conclusion of the inspection and the proposed corrective action discussed _by the licensee representatives, the QA audit program should. be improved. , L Design Changes and Modifications: Average ~(Section 4). The licensee had established and implemented a program.to control safety-related design- changes and modifications. The Nuclear Operations Support Department - appeared to be effective in-managing and coordinating preparation and ~ p - ! .
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' . implementation ~of_ design change requests. The design phase performed by Nuclear Engineering Department was well documented. 'Significant weaknesses identified were the untimeliness of initiation of closeout- upon completion of design change, the large backlog of drawings pending revisions, and the lack of a written system to ensure that operators had: been trained and applicable procedures revised or written prior.to design change closeout or. system operation.
Maintenance: Belov Average (Section 5). .An approved procedure for the control of maintenance activities had been implemented. This procedure ^ ' . was well defined and broad.in-scope. All maintenance was performed and controlled by use of maintenance requests. Significant weaknesses s in the,overall maintenance program, however, were identified: lack of a meaningful, integrated preventive maintenance program; lack of written administrative procedures for control of as-built drawings and control of vendors manuals; lack of an effective training, program for maintenance personnel; and the large backlog of_ low priority maintenance. requests. Review of Licensed Activities (Plant Operations): Average (Section 6). The significant deficiencies were: a failure to communicate adequately with nonsupervisory operating _ personnel; failure to perform trend. analyses on Failure and Malfunction Reports and Licensee Event Reports; failure to involve reactor operators and supervisors in the review and revision of plant procedures; and failure to provide adequate training on plant modifications. Corrective Action Systems: Below Average (Section 7). The weaknesses in. this area involved a lack of an adequate program, failure to implement the existing program, and inadequate training on the existing program.- The most significant weaknesses included failure to have'either a software oriented corrective action system or a system that included such items; -> inadequate-training on existing systeme, failure to perform trend analyses on reported deficiencies; failure to have adequate followup on corrective actions, including QA verification and committee reviews; and poor documentation on deficiency reports and logs. Training: Below Average (Section 8). (1) Licensed Training: Significant problems were identified in the Reactor. Operator and Senior Reactor Operator training and . qualification records. . Training was-conducted using a training 4' manual that had not been reviewed by the Operations Review l_ Committee. The training manual, which was the' basis of the training program, was not adequately controlled, and lacked key ' l parts of the current training program.' The licensee training course did include the requirements of 10 CFR 55 and ANSI /ANS 3.1. While there was a shortage of instructor personnelLto-adequately 'p ' carry out the training program, plans existed to increase the size of'the training staff. Of primary _ importance was the lack ? of adequate management attention as evidenced by the. lack of a- L definitive training policy issued at the corporate level. ' - > r + - - . - . , . - . + > . - . .. ..,m- , , , - - - - - s ., .. . . , .
. , . .., % % - , . - _; . s- , , _. m ~ . . Appendix A.(continued) -4- '-= . s (2) Non-Licensed Training: Deficiencies were identified in the non- - licensed. training program both at corporate level and onsite. 'Although the basis.for a comprehensive traini6g program was in existence, it.was lacking direction from managemen,t and in most areas was not effectively implemented. Some;tecent~ improvements initiated ~by. corporate personnel had improved the, quality and quantity of. training provided. . The primary cause'of problems -, appeared to be the lack of management policy and/ followup. " , ~ Procurement: Below Average'(Section 9). The Written prog' ram for, ^ procurement, receiving-inspection, and storage was inadequate. There was a lack of awareness, training, and implementation of the writtsn- program. . Specific examples of improper storage of safety-related. materials were identified. , ' ~ . , , % e e t 4- l 4 ! . ) [ \\ n. , , e . ,. g{. , e ,, A s 1f f g ,
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