ML20039A293
| ML20039A293 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck, Pilgrim File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 09/10/1981 |
| From: | Salvi W BOSTON EDISON CO. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML093430786 | List: |
| References | |
| NUDOCS 8112170015 | |
| Download: ML20039A293 (1) | |
Text
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EOSTON EDCON COMPANY S00 SovLsTON STREET 8 0 STO N, M ASS ACH U S ETTS O 219 9 PU'!LIO INFORMATION
[EPARTMENT September 10, 1981 Mr. Ronald Haynes Director, Region 1 U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Mr. Haynes:
Attached is a copy of a report on Pilgrim Station prepared by the Institute for Nuclear Power Operations, along with an F.Y.I.
advisory to local news media.
Copies have also been sent to Karl Abraham, Office of Public Affairs, Region 1, Nuclear Regulatory Commission and Richard Starostecki, Director, Division of Resident and Project Inspection, Region 1.
This information will be released to the public on 'Jednesday, September 16.
If I can be of any help, please don't hesitate to call.
Sincerely, g
7 Walter E. Salvi Manager, Information Services WES/cd Enclosure l
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_1DIyOUTInrOTEEI2On Attached is a copy of a report on Pilgri: Station prepared by the Institute for Nuclear Power Operations (INFO).
As you can see, this group of nuclear professionals found Pilgri: Station being
" operated and =aintained in a safe =anner by co=petent personnel."
INFO conducts these evaluations at all its member co=panies, every co==ercially-operated nuclear reactor in the United States.
As the organization states in its preface to the report, its purposes is to "=ake an overall deter =ination of plant operating safety, to evaluate =anagement systems and controls and to identify areas needing improvement."
By its =e=bership in INPO, Boston Edison supports those purposes.
Some of the area coming under praise from INFO vere:
o determined manage =ent planning and actions to improve conditions in cuch key areas as outage planning, housekeeping, =arking and identificacion of syste=s, control of spare parts and warehousing, control of plant =cdifications, and individual accountability o an effective fire brigade training program a well-developed operating and emergency procedures in the areas of format, content, and usability an aggressive ALARA program including pre-job planning o
o a minimal nu=ber of alarms in the control room Among opportunities for improvement were:
o For=al programs should be established to ensure that tasks assigned to specific individuals are acconplished.
o Manage =ent of the solid waste program should be improved to decrease the volume of waste produced.
o There is inadecuate work suau for the health physics group, the instrument and control group, and the technic 21 support group.
f o Controlled drawings should be updated in a timely =anner.
Some are not readable.
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Operator, training' on the purpose, scope and operational requirements o
of plant modifications should be provided before the system is restored to service.
In the vast majority of " opportunities for improvement", Boston Edison had already identified areas and was either working or had established plans to correct s
existing situation.
It is important to note that in no' case was there any compromise on safety-x.
n related issues.
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INFO was formed in 1979 by the nuclear power industry to establish benchmarks of excellence for the operation of the nation's nuclear power plants.
Sincerely,
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',1 Robert J District Manager, Plymouth Area s
Tel: Area Code (617) 746-0912
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Report August 1981
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SUMMARY
INTRODUCTION m
The Institute of Nuclear Power Operations (INPO) conducted its first evaluation of Boston Edison Company's Pilgrim Nuclear Power Station (PNPS) during the weeks of April 13 and 20,1981. PNPS consists of a 655 megawatt (electrical)
General Electric boiling water reactor plant. The station is located on Cape Cod Bay near Plymouth, Massachusetts. The unit was placed in commercial operation in December 1972.
PURPOSE AND SCOPE
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INPO conducted an evaluation of site activities to make an overall determination of plant operating safety, to evaluate management systems and controls and to identify areas needing improvement.
Information was assembled from dis-cussions, interviews, observations and reviews of station documents.
The team examined station organization, training, operations, maintenance, radiological and chemistry activities, and on-site technical support. Emergency preparedness was not included in the scope of the evaluation, nor were corporate activities, except as an incidental part of the station evaluation. As a basis for the evaluation, INPO used its own experience on best practices within the industry and written evaluation criteria which were furnished to the plant in advance.
The evaluation standards are high, and the findings and recom-mendations are not limited to minimum safety concerns.
DETERMINATION Wi_ thin the scope of this evaluation the team concluded the station is being operated and maintained in a safe manner by competent personnel. We noted a positive attitude among station and corporate management personnel toward improvements in station operation and management. The following beneficial practices and accomplishments were noted:
l o determined management planning and actions to improve conditions in i
such key areas as outage planning, housekeeping, marking and identifi-l-
cation of systems, control of spare parts and warehousing, control of plant modifications, and individual accountability o an effective fire brigade training program well-developed operating and emergency procedures in the areas of o
format, content, and usability o an aggressive ALARA program including pre-job planning o a minimal number of alarms in the control room.
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PILGRIM (1981)
I Page 2
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1 Opportunities for improvement were identified as follows:
Formal programs should be established to ensure that tasks assigned to o
specific individuals are accomplished.
Management of the solid waste program should be improved to decrease o
the volume of waste produced.
There is inadequate work space for the health physics group, the o
instrument and control group, and the technical support group.
Controlled drawings should be updated in a timely manner. Some are not o
readable.
Operator training on the purpose, scope, and operational requirements of o
plant modifications should be provided before the system is restored to service.
Recommendations are intended to augment the Boston Edison Company's efforts to achieve high standards in its nuclear operations. In taking corrective action, the company should consider the underlying significance of findings and recom-mendations. Boston Edison Company's responses to the report are considered appropriate to the findings presented.
To follow the completion of these responses, INPO requests written notification of status at six month intervals, until the next INPO evaluation.
Specific evaluation findings are in the accompanying Details, and information of an administrative nature is in the Administrative Aopendix. These findings were presented at an exit meeting in Plymouth, Massachusetts, on April 24,1981, and were further discussed along with the company responses on July 8,1981, in a meeting with corporate and station management.
The cooperation received from all levels of the Boston Edison Company is appreciated.
E. P. Wilkinson President
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PILGRIM (1981)
Page 3 BOSTON EDISON COMPANY Response Summary The management of Boston Edison Company was not surprised by the conclusion of the INPO team that the station is being operated and maintained in a safe manner by competent personnel nor by the note that there is a positive attitude among station and corporate management personnel toward improvements in station operation and management. We were also pleased that the team took notice of a number of beneficial practices and accomplishments and that it did not identify any items that we had not previously noted for action.
One reason for this is that for a little more than three years we have had an oversight committee of outside experts reviewing our operations from a cor-porate point of view. This committee, known as the Nuclear Review Group, visits Pilgrim and our headquarters on about a quarterly basis. It has free access to personnel and documents and reports its findings with recommendations to top corporate management. It has made substantial contributions in this area of identifying items for improvement in the operation.
Our responses to the specific recommendations are attached in the format requested.
Updates will be provided at six-month intervals. The first update will be submitted by February 1,1982.
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PILGRIM (1981)
Paga 4 DETAILS This portion of the report includes the detailed findings. It is composed of six sections, one for each of the major evaluation areas. Each wation is headed by a summary describing the scope of the evaluation and the overall finding in that
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area. The summary is followed by the specific findings, recommendations and utility responses related to each of INPO's evaluation procedures. The evalua-tion procedures that were used are listed in the ADMINISTRATIVE APPENDIX.
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ORG ANIZATION AND, ADMINISTRATION Station objectives, organizational structures, administrative controls, industrial safety, programs for quality assurance, and surveillance inspections and tests were reviewed.
Several areas were evaluated that indicate strengths within the Pilgrim Station organization. A well-qualified support staff is available, a sound quality control program exists and comprehensive overall surveillance schedulir.g and computer-based outage planning programs are being developed.
Areas for improvement are as noted in the following performance areas:
OBJECTIVES (INPO Procedure OA-101, Revision 1)
Evaluation was performed to determine how offectively goals and objectives are disseminated throughout alllevels of the station and how effectively they convey intended operational and maintenance directives. Areas reviewed included the station mission statement, supervisor accountability, availability of station mission documents, assessment programs and mecsurement of goals and objec-tives attainment. Determinations were made as follows:
The criteria of OA-101 were met.
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ORGANIZATION STRUCTURE (INPO Procedure OA-102, Revision 2)
Evaluation was performed to determine how effectively the organization manages the station to ensure safe, efficient operation. Areas reviewed included applicability of the organizational structure diagram, position descriptions for all station personnel, personnel performance evaluation, supervisor's span of author-ity, assignment of backup personnel for each plant management position and individual work load assignments. Determinations were made as follows:
The criteria of OA-102 were tnet.
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PILGRIM (1981)
Paga5 ADMINISTRATIVE CONTROLS L
(INPO Procedure OA-103, Revision 1)
Evaluation was performed to determine the effectiveness of the controls for administrative functions. Areas reviewed addressed the program of administra-tive controls for purpose, scope, responsibility, flexibility, level of administra-tive actions and program dissemination. Determinations were made as follows:
Finding (Reference Criterion E)
No clearly defined methods are established to ensure responsibilities and accountabilities assigned by station procedures are performed.
Recommendation Develop and implement programs or procedures that require periodic review for completion of those tasks assigned to individual positions or personnel classifications by station procedures.
Response
Boston Edison concurs with both the finding and recommendation and has recently formalized and computerized the Operations Review Commit-tee Follow List addressing safety-related concerns. The Integrated Work Management System when implemented, in 1982, will address the re-maining concerns.
QUALITY PROGRAMS (INPO Procedure OA-104, Revision 4)
Evaluation was performed to determine how effectively quality programs moni-tor and audit plant activities to promote accomplishment of the station mission.
Areas reviewed included management controls, accountability programs, pro-gram cross checks, program effectiveness, programs for corrective actions and manning. Determinations were made as follows:
Finding (Reference Criterion A)
Management controls are not in effect to require regular evaluation of some aspects of plant operations.
Specifically, the areas not being evaluated include the following:
o control room operations o plant chemistry and laboratory practices o security systems o procedures o safety, fire and emergency systems o effectiveness of the program for revic.v of in-house and industry events.
Recommendation Develop and implement periodic administrative or quality control review of the activities listed above to ensure quality performance in these areas.
PILGRIM (1981)
Paga 6
Response
In addition to the existing scheduled audits of these areas by the Quality Assurance Department to meet the requirements of the station Tech-nical Specifications and Section 18 of the Boston Edison Quality Assur-ance Manual, a surveillance inspection program will be implemented by the Operational Quality Assurance Group by March 1982. In addition, the Integrated Work Management System will also provide the manage-ment with an ongoing overview of the quality aspects of each task.
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W INDUSTRIAL SAFETY (INPO Procedure OA-106, Revision 1)
Evaluation was performed to determine the effectiveness of the station's safety program in providing a safe, orderly working environment.
Areas reviewed included the station's general and site-specific policy, management support for the safety program, and employee and management interface in safety matters.
Determinations were made as follows:
1.
Finding (Reference Criteria A, b, and C)
Commitment, support, and involvement in the safety program are not effectively achieved by management, the supervisory staff, or the employees. Specifically, safety meetings and plant fire drill exercises required by company procedures are not being performed.
Recommendation Comply with the published instructions and policies of both the Boston Edison Company and the Pilgrim Nuclear Power Station (PNPS) regarding safety committees and meetings and general employee fire drill exer-cises, specifically:
o Boston Edison Safety Manual (BESM) Safety Policy / Procedures (SP-2)-
Safety Committees o PNPS Nuclear Operating Department Procedure 1.4.17 - Safety Com-mittee and Meetings o BESM SP Fire Drill Exercise
Response
While the program is not formally documented, the incident ratio at PNPS indicates the safety consciousness of employees.
A policy statement will be issued and procedures revised to ensure compliance.
This effort will be completed by September 1981.
2.
Finding (Reference Criterion D)
Plant-specific work practices and safety considerations that affect employee safety are not always published and made available to every i
employee.
Recommendation Comply with the requirements of the Boston Edison Safety Manual regarding new employee safety training and job safety standards. Speci-fically, ensure each new employee is given a copy of the accMent
L PILGRIM (1981)
Page 7
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prevention manual and ensure compliance with the requirements of BESM SP-6 (Job Safety Standards).
Response
Boston Edison agrees that an accident prevention manual should be distributed or made available to all employees and Boston Edison will review the existing manual and reorder for distribution. This action will be completed prior to September 1981.
3.
Finding (General Criterion)
Industrial safety responsibility is a collateral duty of the Senior Nuclear Training Specialist. The demands of his primary duties do not permit him to devote the attention necessary to effectively administer the industrial safety program.
Recommendation Reassign responsibility for the industrial safety program to an individual trained in the subject and available to give it the necessary attention.
Response
Boston Edison agrees that the duties of the Industrial Safety Officer have evolved into a full-time requirement in view of the increasing modifications activity. A position description is being developed and a target date of September 1981 has been established for filling the position.
SURVEILLANCE PROGRAM (INPO Procedure OA-107, Revision 1)
Evaluation was performed to determine if an effective program exists to accomplish surveillance inspection and testing. Areas reviewed in the surveil-lance program included completeness, depth, acceptance criteria, results review, notification and control of off-standard conditions, suitable scheduling and training in proper use of surveillance procedures. Determinations were made as follows:
The criteria of OA-107 were met.
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PERSONNEL QUALIFICATIONS (INPO Procedure OA-108, Revision 1)
Evaluation was performed to determine if a program exists for providing qualified personnel to operate and maintain the station. Areas reviewed included the applicability of job descriptions for station positions, the programs for personnel promotion and selection, and the program for periodic review of all job descriptions. Determinations were made as follows:
The criteria of OA-108 were met.
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PILGRIM (1981)
Pqe8 TRAINING AND QUALIFICATIONS The following t_
u were evaluated: training organization and administration, training programs for licensed and non-licensed operators, shift technical advisors and other station personnel, training resources, and training program effectiveness. There were positive features noted in most areas. Of special note were the conscientious and capable training staff, management's support of training activities, and the structured annual oral examination administered to all licensed personnel. Improvements can be made in the areas discussed in detail below.
TRAINING ORGANIZATION AND ADMINISTRATION (INPO Procedure TQ-211, Revision 2)
Evaluation was performed to ensure that the shtlon has a clearly defined training organization that provides for assignment of responsibilities and delegates authority to accomplish those tasks assigned to the training group.
Areas reviewed included the organizational structure and practices, training staff size, ability and authority to schedule and provide required training, and the existence of and adherence to written training plans.
1.
Finding (Reference Criterion A)
A formal organizational structure which agrees with actual reporting requirements has not been published.
Recommendation Develop and publish an organizational structure that describes the functional and administrative relationships within the training group.
Response
The Training Manager's position, which was under development during the assessment, has been approved and candidates are being solicited.
To avoid confusion during the development, the anticipated organization change was not published. It will now be made formal prior to July 1, 1981.
2.
Finding (Reference Criterion D)
Training programs, as described in the training manual, have not been effectively implemented in the following areas:
o operations group training o maintenance group training o technical group training.
A new training plan for licensed operator training has been developed and is being implemented. The training manual has not been revised to reflect the new training plan.
Recommendation Identify the training programs and records described in the Training 1
Manual that are not being implemented.
Review these programs for I
applicability.
This review should include, but not be limited to, weaknesses noted in TQ-243, Criterion A; TQ-244, Criterion E; and 1
TS-701, Criterion D. Implement the training programs that result from this review.
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PILGRIM (1981)
Paga 9 nampana.
Boston Edison agrees with the recommendation. The Training Manual will be reviewed to determine applicability of non-implemented training programs and records.
Those programs and records identified as applicable will be implemented by May 1,1982.
TRAINING RESOURCES (INPO Procedure TQ-221, Revision 2)
Evaluation was performed to determine whether sufficient and adequate facil-ities, equipment, and materials are provided to support the training programs.
Areas reviewed included facilities, laboratories, workshops, office space, train-ing materials, aids and equipment, lesson development, and accommodations to support the trainers and trainees. Determinations were made as follows:
Finding (Reference Criterion F)
Lesson plans, reference materials and training aids do not exist for the complete implementation of the licensed operator training, licensed operator requalification training, and shift technical advisor training programs. A plan to produce these materials on an "as needed" schedule t
is being implemented.
i Recommendation Prepare the required training program materials in sufficient time to allow for review and practice use. In developing these training materials l
consider similar weaknesses in TQ-243, Criterion C; TQ-244, Criterion B; and TQ-245, Criterion D.
Management should establish goals and priorities to ensure that necessary materials are developed, reviewed and made avallanle for use in all scheduled training sessions.
Response
Boston Edison agrees with the recommendation and will complete all actions by May 1,1982.
TRAINING EFFECTIVENEES (INPO Procedure TQ-231, Revision 2)
Evaluation was performed to determine what measurements are made of the effectiveness of training programs in meeting training objectives and improving operational performance. Areas evaluated included programs for management j
evaluation of training effectiveness, measurement of trainee and instructor i
performance, and audits of trsining activities. Determinations were made as u
fonows:
The criteria of TQ-231 were met.
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Paga 10 NON-LICENSED OPERATOR TRAINING (INPO Procedure TQ-242, Revision 2)
Evaluation was performed to determine whether a training program has been established for non-licensed operators. Areas reviewed included the programs for initial and continued training of non-licensed operators who are not scheduled m
to become licensed operators. In addition, programs for initial training of non-licensed operators scheduled for eventual licensing were reviewed.
Determi-nations were made as follows:
1.
Finding (Reference Criterion A)
An initial training program for non-licensed Nuclear Plant Operators has not been developed.
The on-the-job training provided to prepare operators to become " tour-qualified" is unstructured and not effectively implemented.
Recommendation Develop and implement a training program that will prepare the non-licensed Nuclear Plant Operators for their assignments.
NOTE: "INPO Guidelines for Qualification Programs for Nuclear Power Plant Non-licensed Operators" (Document Number G PG-04) could provide a basis for the development of this program. Modifications of the INPO guidelines could be made to correctly address the duties and responsibilities of Pilgrim's " tour-qualified" watch stander during normal, off-normal or emergency operations.
Response
The course outline has been developed and is presently being imple-mented by the Training Department for the present class of non-licensed operators.
2.
Finding (Reference Criterion C)
The training program for Nuclear Auxiliary Operators is not fully implemented.
Recommendation Implement a structured training program that includes appropriate fundamentals and system checkouts for Nuclear Auxiliary Operators.
NOTE: INPO guidelines referenced above address the development of this program.
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Response
Boston Edison agrees and a course outline has been developed and materials are being prepared to implement the program. This program is scheduled to commence July 1,1981.
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PILGRIM (1981)
Paga 11 LICENSED OPERATOR TRAINING (INPO Procedure TQ-243, Revision 2)
Evaluation was performed to determine the effectiveness of the training program that prepares candidates for reactor operator and senior reactor operator (SRO) licenses. Areas reviewed included program content; base level of knowledge; training materials and source inputs; training in systems, plant fundomentals and operating practices; SRO training; and evaluation of trainees and the training program. Determinations were mada as follows:
Finding (Reference Criterion I)
A program of technical, supervisory, and administrative training to address the increased responsibilities of senior reactor operators has not been developed.
Recommendation Develop and implement a training program for senior reactor operators that addresses their increased duties and responsibilities.
NOTE:
"INPO Guidelines For Qualification Programs at Operational Units for Nuclear Power Plant Licensed Operators" (Document Number GPG-03) could provide a basis for this program.
Response
Boston Edison agrees with the recommendation and the program will be developed and should commence during the next requalification training cycle.
LICENSED OPERATOR REQUALIFICATION PROGRAM (INPO Procedure TQ-244, Revision 2)
Evaluation was performed to determine the effectiveness of the requalification program in maintaining a high level of skill and knowledge for each Reactor Operator and Senior Reactor Operator. Areas reviewed included development and use of training materials to upgrade licensed operators in funaamentals and to inform them of procedure changes, licensee event reports, plant modifica-tions, changes in station license requirements and changes in vendor information affecting operations. In addition, the policy on use of a training simulator, periodic program evaluation and provisions for inactive operator identification and requalification were reviewed. Determinations were made as follows:
Finding (General Criterion)
A system to prevent the potential compromise of the annual written examination has not been implemented. The same examination is given five separate times, once to each operating shift.
Recommendation
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Implement a system to reduce the probability of the compromise of the annual examination.
Response
Boston Edison does not believe the examination content is being compro-mised. However, a ::ystem using multiple examinations, variations of the same question or variation of question types will be implemented to
PILGRIM (1981)
Pags 12 reduce the probability of potential compromise of the annual written examination. The anticipated date for initiating this examination policy
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is January 1,1982.
SHIFT TECHNICAL ADVISOR TRAINING (INPO Procudure TQ-245, Revision 1)
Evaluation was performed to determine if a suitable training policy has been developed and implemented for shift technical advisor (STA) training and education. Areas of interest included a review of the STA program for college-level and site-specific instruction, simulator training, retraining provisions, and documentation of all training. Determinations were made as follows:
The criteria of TQ-245 were met except as noted in TQ 221, Criterion F in regard to requalification training.
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PILGRIM (1981)
Paga 13 OPERATIONS Organization and administration, conduct of shift operations, tagout practices,
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use and content of procedures, plant status controls, facilities and equipment, and shift turnover were reviewed. Several good practices were noted, including
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well developed operating and emergency procedures, a dedicated control room paging system, and the availability of alarm response procedures at each control panel.
Improvements could be made in the areas of tagout practices, conduct of shift operations, plant status controls, and shift turnover. These improvements are discussed in detail below.
ORGANIZATION AND ADMINISTRATION (INPO Procedure OP-301, Revision 3)
Evaluation was performed to determine the existence of a clearly defined operations organization that provides for the assignment of responsibility and delegation of adequate authority for accomplishment of required tasks. Areas reviewed included organizational structure, job descriptions, shift administrative assignments, written and oral instructions and orders, and miscellaneous adminis-trative programs. Determinations were made as follows:
The criteria of OP-301 were met.
TAGOUT PRACTICES (INPO Procedure OP-302, Revision 2)
Evaluation was performed to determine if established tagout practices ensure protection for personnel and station equipment. Areas reviewed included senior reactor operator approval of safety-related tagouts, double verification of tagged equipment for personnel safety, double verification of important safety-related components, tag coloring and numbering, and clearance log review.
Determinations were made as follows:
1.
Finding (Reference Criterion C)
A second verification is not performed for safety-related components and critical balance-of-plant equipment that are repositioned during maintenance, testing or change in operating mode. Use of OPER-38, Shift Turnover Sheet, as verification of system status, does not meet the intent of this criterion.
Recommendation Develop and implement a station policy of second verification for safety-related components and critical balance-of-plant equipment that do not have control room position indication. Modify existing procedures as necessary to define the systems and plant conditions requiring independent verification.
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PILGRIM (1981) jx Paga 14
Response
l This recommendation was being evaluated a.t the ' time of the INPO assessment as part of the TMI issues.. The requirements for second verification have been developed hnd will be implemented by August 1,1981.
2.
Finding (Reference Criterion G)
Although audits of active clearances placed for the watch engi. eer are done, audits of active clearances covered by maintenance requests are not being performed.
Recommendation
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Implement periodic audits of clearances covered by active maintenance requests similar to the audits currently in use for red tags issued by the watch engineer. These audits should include a check for adequacy of the tagouts, verification that tags are in place and equipment properly positioned, and status of the equipment or system covered by the tagout.
Results should be reviewed by appropriate supervisors within the opera-tions group.
Response
This recommendation is incorporated in the Integrated Work Manage-ment System and although not scheduled to be implemented until after the 1981 refueling outage, this particular portion will be implemented prior to startup.
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CONDUCT OF SHIFT OPERATIONS i
(INPO Procedure OP-303, Revision 3) l Evaluation of the conduct of shift operations was performed to determine if l
operator activities and the aids for these activities support safe and efficient operation of the station. Areas reviewed included observation of operations, station cleanliness and order, response to abnormal conditions, logkeeping i
practices, reliability of control room instrumentation, and operator awareness of plant conditions. Determinations were made as follows:
The criteria of OP-303 were met except as noted in TS-703, Criterion C and TS-704, Criterion I.
USE OF PROCEDURES (INPO Procedure OP-304, Revision 2) i l
Evaluation was performed to determine if procedure content and use are appropriate for conducting operations safely and reliably.
Areas reviewed
PILGRIM (1981)
Paga 15 included management policies for use of procedures and changes to procedures (short and long term).
In addition, procedures were reviewed for clarity, continuity, identification of " sequence required" actions, and suitable advisory information. Determinations were made as follows:
The criteria of OP-304 were met.
PLANT STATUS CONTROLS (INPO Procedure OP-305, Revision 2)
Evaluatior, was performed to determine if plant status controls are provided to ensure adequate equipment and system availability. Areas reviewed included management programs and policies that provide guidance for status control, actual practices in status control, responsibilities of senior IIcensed operators assigned to monitor and review status control, and provisions for status control under special conditions (e.g., outages, accident recovery or refueling). Deter-minations were made as follows:
Finding (Reference Criterion A)
A policy statement that includes several elements of status control was recently formalized.
However, it does not cover many elements necessary to ensure that all affected watch stations are kept current.
Recommendation According to the policy statement, it is understood that the associated guidelines will be formally incorporated into procedures by July 1981.
The new procedures should be expanded to include the following:
o equipment checksheets, status boards or other means to define requirements for each mode or plant condition o documentation at each affected shift level when status changes o formal assignment of an SRO for status change review and control o timely communication of status changes to all affected shift levels o periodic status monitoring and evaluation by management o provisions for status control during special situations, such as extended outages, refueling and post-accident recovery.
Response
The recommendations have been incorporated and will be in place by July 1,1981.
PILGRIM (1981)
Paga 16 OPERATIONS FACILITIES AND EQUIPMENT (INPO Procedure OP-306, Revision 2)
Evaluation was performed to determine if plant facilities and equipment are operated and maintained in a manner that ensures safe and efficient operation.
Areas reviewed included equipment service needs, effect of the working environ-ment on safe and efficient station operation, and adequacy of communications equipment. Determinations were made as follows:
The criteria of OP-306 were met.
SHIFT TURNOVER (INPO Procedure OP-307, Revision 1)
Evaluation was performed to determine if continuous, correct understanding of station conditions is maintained at all shift positions. Areas reviewed included programs and policies controlling shift turnover practices for individual shift positions, checklists, operating panel reviews and review of station activities in progress or planned. Determinations were made as follows:
Finding (Reference Criterion B)
Some operating shift positions do not have specific checksheets, or a similar mechanism, to guide the turnover process. A common check-sheet exists for several shift positions, but is limited in scope and does not include many items.
Recommendation Develop turnover checksheets, or similar mechanism, to guide the turnover process for the Watch Engineers, Nuclear Auxiliary Operators and Nuclear Plant Operators (tour men).
Broaden the scope of the check-sheets currently used by the Nuclear Operations Supervisors and Nuclear Plant Operators (control room operator). These shift turnover systems should include, but not be limited to, information pertinent to the watch station such as balance-of-plant equipment, jumper log review, testing in progress, and equipment out-of-service; and should provide a method for ensuring that plant status is understood.
Response
Boston Edison has begun to incorporate these parameters and will have the revision in place by September 1981.
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PILGRIM (1981)
Paga 17 MAINTENANCE Organization, corrective and preventive maintenance, administrative programs:
procedures, maintenance history, special processes, and maintenance facilities were reviewed.
The knowledge and experience of group personnel are a strength to the maintenance and instrument and control (I & C) organizations.
Additionally, there is a progressive approach by management which should contribute to performance of the maintenance function.
Areas where improvem.ents are recommended included preventive maintenance, maintenance procedures, maintenance history, control of test equipment, and maintenance facilities.
MAINTENANCE ORGANIZATION AND ADMINISTRATION (INPO Procedure MA-401, Revision 2)
Evaluation was performed to determine how effectively the maintenance and I & C organizations and administrative programs function to enhance perform-ance of maintenance tasks. Areas reviewed included organizational structure, reporting requirements and practices, staff size, training and retraining, use of position descriptions and span of control for supervisors. Determinations were made as follows:
The criteria of MA-401 were met.
PREVENTIVE MAINTENANCE (INPO Procedure MA-402, Revision 1)
Evaluation was performed to determine the effectiveness of the maintenance effort in optimizing equipment reliability and performance. Areas of review included governing procedures, equipment included in the program, type and frequency of preventive maintenance (PM), and effectiveness of program coordi-nation and control. Determinations were made as follows:
Finding (Reference Criteria A,B,D,E, and G)
Although some preventive maintenance activities are performed by various groups at the plant, a formal, comprehensive preventive mainte-nance program is needed.
Recommendation Develop and implement a formal, management-approved preventive maintenance program for mechanical, electrical, and I & C equipment.
The program should include the following:
o specific criteria for determining what equipment and instrumen-tation will be included
PILGRIM (1981)
Paga 18 o assignment of responsibilities for program development, imple-mentation, and review o development of individual preventive maintenance procedures for scfety-related equipment and instrumentation, and inspection guidelines for other equipment and instruments o establishment of realistic inspection or maintenance frequencies and appropriate types of PM activities.
Response
A plan and schedule to develop a program encompassing but not limited to the above recommendations is presently being developed. Implemen-tation of the plan is scheduled to commence in September 1981.
MAINTENANCE PROCEDURES (INPO Procedure MA-403, Revision 2)
Evaluation was performed to determine if existing maintenance procedures provide for quality and effectiveness of maintenance activities. Areas of review included an assessment of activities governed by procedures, methods of
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procedure development and revision, and content of procedures. Determinations were made as follows:
Finding (Reference Criterion A)
Vendor instruction manuals used extensively for control of work on safety-related and important non-safety-related equipment are not formally reviewed and approved.
Recommendation Prior to use in safety-related or important non-safety-related work, vendor instruction manuals should be reviewed and approved in a manner equivalent to that provided for plant procedures. This review should consider applicability of the manual to the work to be ' performed, accuracy and suitability for controlling work, and established quality check points.
Response
The Integrated Work Control System, utilizing the Erection Control Sheet concept, will implement the above recommendations by requiring an Operations Review Committee review of processess required by vendor manuals not previously reviewed. These reviews will be required by September 1,1982.
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PILGRIM (1981)
F Page 19 WORK CONTROL SYSTEM L-(INPO Procedure M A-404, Revision 1)
Evaluation was performed to determine the effectiveness of the work control system in use at the plant. The system functions were checked to see if they define and authorize work to be performed by maintenance groups; provide for planning, scheduling and control of actual work; and provide a suitable record of work ;,erformed for future reference. Determinations were made as follows:
The criteria of MA-404 were met.
MAINTENANCE HISTORY (INPO Procedure MA-405, Revision 2)
Evaluation was performed to determine if maintenance history records are retained and used to improve equipment reliability and performance. Areas of review included assessment of equipment included in the program, content and accessibility of records, history review and evaluation methods, and procedures for program implementation. Determinations were made as follows:
Finding (Reference Criterion D)
Mechanical, electrical and I & C maintenance history records are maintained but are not reviewed on a systematic basis.
Equipment failures and "as found" out-of-specification instrumentation are not routinely evaluated. The potential necessity for more frequent preven-tive maintenance or calbration is not being recognized.
Recommendation A program should be instituted for the systematic review of maintenance history records. Reviews should be used to identify equipment perform-ance trends, adjust preventive maintenance frequency, and improve equipment reliability.
Response
~
This recommendation has been incorporated as a requirement of the Preventive Maintenance Program.
CONTROL AND CALIBRATION OF TEST EQUIPMENT AND INSTRUMENTATION i
(INPO Procedure MA-406, Revision 1) l
' ~
Evaluation was performed to ensure that available facilities and procedures provide for accurate test equipment and instrumentation.
Areas reviewed included identification, calibration, storage, issuance, usage, shipment and documentation. Determinations were made as follows:
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PILGRIM (1981)
Page 20
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Finding (Reference Criterion F)
Measuring and test equipment that is damaged or for which the calibration has expired is stored in the same location as operable, ready-for-issue equipment. Lack of segregated storage could lead to inadvertent use of inaccurate equipment.
Recommendation
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Damaged or uncalibrated measuring and test equipment should be separated from equipment that is ready for issue.
Response
This recommendation is currently being implemented.
CONTROL OF SPECIAL PROCESSES (INPO Procedure MA-407, Revision 1)
Evaluation was performed to determine if adequate controls exist for perform-ance of special processes. Areas of review included training and qualification of personnel, administrative controls, and control of equipment and materials.
Determinations were made as follows:
The criteria of M A-407 were met.
MAINTENANCE FACILITIES AND EQUIPMENT (INPO Procedure MA-408, Revision 1)
Evaluation was performed to determine if available facilities and equipment contribute to the performance of maintenance activities.
Areas reviewed included number, type and condition of tools and equipment; size and location of tool storage arees; adequacy of office and work areas; and the cleanliness and orderliness of maintenance facilities. Determinations were made as follows:
1.
Finding (General Criterion)
Spare parts for I & C work are not readily available. Recent efforts to relocate all I & C spare parts under control of the central warehouse system has contributed to this problem.
Recommendation Review existing spare parts support and take action to improve avail-ability of I & C spare parts. The following actions should be considered:
expediting inventory of spare parts and assignment of Boston o
Edison Company stock numbers
)
issuing updated computer printouts of spare parts inventory on a o
more frequent basis developing cross-reference information for locating identical parts o
in different plant systems.
PILGRIM (1981)
Paga 21
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Response
Boston Edison believes that the recent relocation of I&C spare parts to
=
the warehouse caused this finding.
The first two items are being expedited while the capability to implement the third is in place.
2.
Finding (Reference Criterion B)
Adequate tool storage is not available at suitable areas in the plant.
Recommendation Continue with present plans to stock and man tool issue stations within the plant.
Response
This effort is being supported and should be in place by September 1981.
3.
Finding (Reference Criterion C)
I & C office and work areas do not adequately conform to the needs of the organization. Normal access to the control room through the I & C shop disrupts work and may be a safety hazard for technicians due to crowded conditions. Office space for the I & C supervisor is inadequate and hinders effective work.
Recommendation An alternate means of access to the control room should be established and utilized to prevent disruption of activities in the I & C shop.
Arrangement of the shop should also be reviewed and adjusted to provide suitable office space and areas for storing and using prints.
Response
The planned administrative building expansion should vacate offices in the plant and allow for relocation of some of the facility.
In the meantime, a temporary trailer facility has been established.
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PILGRIM (1981)
Page 22
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RADIATION PROTECTION AND CHEMISTRY
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a Organization, administration, radiological protection, radioactive waste manage-ment and process water chemistry were reviewed. This portion of the evaluation was primarily an examination of plant programs and facilities as they function under normal operating conditions. It was concluded that the station's radiation protection and chemistry programs are being conducted in a manner that P
provides for sufficient controls to protect the public, plant workers and the environment.
A number of strengths were noted, including an aggressive, management-sup-ported ALARA program, well-organised contamination control points and the active pursuit of program and facility improvements by station health physics and chemistry personnel.
However, improvements could be made in the management of solid radioactive wastes, the adequacy and efficiency of facil-ities and the methods used for calibration and testing of radiological protection instrumentation as discussed below.
RADIATION PROTECTION AND CHEMISTRY ORGANIZATION AND ADMINISTRATION (INFO Procedure RC-501, Revision 1)
Evaluation was performed to determine the effectiveness of the radiation protection and chemistry organizations and associated administrative control mechanisms in providing the level of services required at the station under normal operating conditions. Areas reviewed included the formal organizational structure, procedures for conduct of operations, staffing levels, training and retraining programs, position descriptions, and management authority.
The radiation protection and chemistry groups are organized and administered in an effective manner. Both organizations are taking steps to increase technician staffing to support increased workload and, in the case of radiation protection, 4
to reduce the reliance upon contractor personnel. Planning for future needs appears adequate, and the staff is aggressively pursuing improvements in existing programs. Determinations were made as follows:
[
The criteria of RC-501 were met.
d ALARA PROGRAM (INPO Procedure RC-502, Revision 1)
Evaluation was performed to determine the effectiveness of efforts toward maintaining personnel occupational radiation exposure as low as is reasonably achievable (ALARA) at the station. Areas of interest included the company's ALARA policy, responsibilities for ALARA, level of review for the ALARA program, systems for setting ALARA goals and measuring progress, nd the overall scope of ALARA activities.
1 s
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PILGRLM (1981)
Pago 23 A formal ALARA program is in place at the station and is managed on a day-to-day basis by a dedicated ALARA group consisting of two ALARA engineers and one ALARA technician. A well documented, effective decision-making system is in use to perform cost-benefits analyses on ALARA efforts for major tasks as a part of pre-job evaluation and planning. The ALARA group is effectively pre-planning all radiological work on a task basis; however, improvements are possible for job tracking and trend analysis.
Determinations were made as follows:
Finding (Reference Criterion D)
The ALARA program does not include a system for establishing specific exposure goals for major tasks or a mettod for tracking exposure accumulation on such tasks to monitor progress against the goals.
Recommer4ation Expand the existing ALARA program to include a system for establishing exposure goals and monitoring exposure during major tasks.
The exposure goals and tracking system should also include provisions for evaluation and corrective action, when necessary, for exposure accumu-lation in excess of the goals.
Response
This aspect of the ALARA program is being developed and will be implemented during the 1981 refueling outage.
PERSONNEL DOSIMETRY (INPO Procedure RC-503, Revision 1)
Evaluation was performed to determine the effectiveness of the station's dosimetry program in measuring, evaluating and recording occupational radiation exposures.
Areas examined included the scope of the dosimetry program, procedural controls, dosimetry selection and use, system operation, and exposure records.
The station's external dosimetry program is efficiently organized and tightly controlled.
Clerical support is used effectively to minimize the paperwork burden on technicians and supervisors and to make the system easy to use from the perspective of station radiation workers. Exposure accumulation reports are being provided to plant personnel and supervisors on a daily basis. The dosimetry records group is in the process of converting paper exposure records files to a microfiche system with duplicate off-site storage for permanent records. Deter-minations were made as follows:
The criteria of RC-503 were met.
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TPILGRIM (1981)
's,, % Pag 2.24-RADIATION SURVEILLANCE AND CONTROL,-
-e d'
(INPO Procedure RC-504, Revision 1) s Evaluation wss performed to determine the effectiveness of the station's 's radiological surveillance program and radiological, work and material. control.
mechanisms in identifying radiological conditions to workers and management.[' '
Areas of interest included surveillance program procedures, sur%illance program '
scope, radiological conditions in the plant, surveillance meth'odology, manage-ment reviews, work and access controls and solid radioactive waste management.
Determinations were made as follows:
Finding (General Criterion)
[]
I The station is not as effective as possible in minimizing the amounts of solid radioactive waste generated and the volume of waste shipped,[.
offsite, specifically-
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o No pre-collection or post-collection segregation or sorting oficom,,-
. 5
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'I pactable waste is performed.
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o Unnecessary non-radioactive waste materials are not effectively e
restricted from entry into radiological controlled areas.
o The waste compacting method in use is inferior to that used atith'ef ~
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nuclear stations, resulting in lower than normal densities for com-pacted radioactive waste shipments.
Recommendation Develop and implement a program to reduce the amount and volume of compacted radioactive waste. Further, include information and tech-niques in station training programs, such as General Employee Training, to increase station personnel awareness of the problem.
L Items which should be considered include, but are not limited to, the following:
o provision of clean waste receptacles in radiological controlled areas and at the entrances to these areas o removal of all packing materials and protective covering from items before they enter a radiological controlled area o post-collection sorting of non-contaminated materials.
Additionally, the station should expedite placing in service the high density drum compactor recently purchased.
Response
A program to minimize the generation of potential radioactive waste has been initiated, and installation of the high density drum compactor is
~
anticipated to be completed prior to the refueling outage.
General Employee Training programs will include information for the control of potential radioactive waste.
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PILGRIM (1981)
Page 25 WASTE AND DISCHARGE CONTROL (Liquid)
(INPO Procedure RC-505, Revision 2) u Evaluation was performed to determine the effectiveness of the station's liquid waste control programs in minimizing the generation of liquid radioactive waste
~
and limiting releases to levels as low as is reasonably achievable. The program elements reviewed included procedures, effluent monitoring system design and function, clean systems sampling, and training.
The station is effectively controlling the generation, processing and release of liquid radioactive waste.
Determinations were made as follows:
The criteria of RC-505 were met.
RADIOLOGICAL SURVEY EQUIPMENT CONTROL AND CALIBRATION (INPO Procedure RC-506, Revision 2)
Evaluation was performed to determine the effectiveness of the station's radiological survey equipment control and calibration program in maintaining a
~
sufficient inventory of instruments and a high degree of accuracy for the radiological measurements made with these instruments. The evaluation covered procedures, storage conditions, reference standard traceability, operational r
response checks, and calibration methods. Determinations were made as follows:
Finding (General Criterion)
The methods employed for calibration and cperational response testing of radiation protection instruments are not adequate to ensure that the instruments will perform accurately over their full useful ranges. Survey instruments and rate meters are calibrated at only one point within the effective range of each calibration control and are not checked for linearity at additional points on each scale or decade of readout.
Pancake GM probes used on friskers are not efficiency-checked, and friskers are source-checked with radioactive standards which do not represent radioactivity levels near the station's contamination limit.
Survey instruments are not source-checked prior to use or on a routine schedule.
Recommendation The methods and procedures employed for calibration of portable radia-t!on protection instruments should be revised to incorporate the guidance given in Sections 4.1 and 4.2.2 of ANSI N323-1978, " Radiation Protection Instrumentation Test and Calibration."
As a part of calibration, each
~
frisker equipped with a pancake GM probe should be efficiency-checked f
with an appropriate radioactive standard. In addition, all replacement probes should be similarly checked immediately after installation on a calibrated frisker. Source checks performed on friskers should utilize a i
planchet source with activity levels at or near the plant's surface l
contamination limit.
l.
Instrument operational response checks should be performed prior to use of instruments or on a routine schedule. The response checks should include quantitative performtinee tests such as those described in Section
PILGRIM (1981)
Page 26 4.6 of ANSI N323, except that checking each scale or decade of readout
' cg J
should be based on the availability of sources, planned instrument use l
and consideration of ALARA principles. Instruments should be checked on those ranges which are of the most importance to the user.
Response
Procedures are being changed to reflect linearity response during cali-bration. A program for efficiency response determination of pancake probes will be implemented. Source checks performed on friskers will 3
include use of a source with activity levels at or near the station's 6-surface contamination limit. Quantitative performance checks will be i
performed based on planned instrument use and consideration of ALARA
_L.
principles. This effort should be completed by September 1,1981.
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PERSONNEL HEALTH PHYSICS INDOCTRINATION (INPO Procedure RC-507, Revision 2) 5 Evaluation was performed to determine the effectiveness of the station's health physics indoctrination program in informing personnel of the risks associated with radiation exposure and the available methods for minimizing exposure.
~
4 Areas reviened included management policy, scope and depth of the indoctri-nation, the training environment, and training documentation.
The health physics indoctrination program is presented as a part of general employee training and consists of videotape presentations supported by live j
fnstruction. Overall, the indoctrination program is structured and conducted in a
+
manner that achieves the objective of preparing personnel to work in radiological M
j controlled areas. Determinations were made as follows:
m The criteria of RC-507 were met.
j A
PROCESS WATER CONTROLS (INPO Procedure RC-508, Revision 2)
Evaluation was performed to determine the effectiveness of process water controls in maintaining the integrity of plant systems. Areas reviewed included j,
procedures; laboratory quality control; bulk chemical, cleaning agent and reagent control; training; and systems chemistry.
The station's chemistry control program is well managed and appears effective in minimizing corrosion. Deter-i minations were made as follows:
The criteria of RC-508 were met.
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PILGRIM (1981)
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Page 27
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- HEALTH PHYSICS FACILITIES AND EQUIPMENT (INPO Procedure RC-509, Revision 2)
Evaluation was performed to determine the effectiveness of the station's health physics and chemistry facilities and equipment in satisfying station needs and in contributing to safe and efficient plant operation. Areas of interest included the number and types of instruments and equipment,~ the protective clothing inven-tory, the design and working environment of facilities and the ease of access to and physical conditions of radiological controlled areas.
The radiological condition and cleanliness of controlled areas were good. Contamination control points were well organized to enhance the ease of access and egress for workers
. to and from contaminated areas. Determinations were made as follows:
Pinding (Reference Criterion C)
An inadequacy exists in the' design and working environment of'some health physics and chemistry facilities, specifically:
o The health physics and chemistry counting rooms lack adequate air conditioning to support the computer-based counting equipment in these spaces.
o Respirator cleaning, monitoring, storage, and issue facilities are widely separated, contributing significantly to problems in conducting l
a respiratory program, particularly during outages.
o The health physics instrument calibration facility and instrument ready room are overcrowded and inadequately equipped for instrument storage.
o Background radiation levels in the whole body counting facility are variable, and at times are too high for optimum operation of the in-l vivo counting equipment.
Recommendation Upgrade the ventilation supply and air conditioning equipment as neces-sary to ensure adequate temperature control of the counting rooms.
In addition, pursue the completion of the planned modifications of l'
available space to accommodate the respirator handling facilities and i
the instrumentation calibration and storage spaces. Consideration should i
be given to a similar weaktiess that exists in RC-506, Criterion B.
Further, pursue the station plan for relocating the whole body counting facility.
Note: At the time of the evaluation, the station had purchased addi-j tional in-vivo counting equipment and is planning to move the whole body counting facility to a building outside of the protected area where i
l background is expected to be lower and more stable. The move and the installation of the improved equipment should improve the counting performance of the facility.
Response
Modification to the heating, ventilation and air conditioning equipment for the health physics and chemistry counting rooms will be performed
PILGRIM (1981)
Pags 28
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expeditiously. Facility modifications for respirator handling,and instru-ment cali~ oration are being pursued and should be in place by September 1,1981. Relocation of the whole body counting equipment to an area outside the restricted area is continuing as planned.
RESPIRATORY PROTECTION PROGRAM (INPO Procedure RC-511, Revision 2)
Evaluation was performed to determine the effectiveness of the station's respiratory protection program in protecting personnel from inhalation of particulate matter, noxious gases and vapors, and from oxygen deficiency. Areas reviev'ed included policy and procedures, identification and control of airborne materials, selection and use of respirators, respirator maintenance and emer-gency capabilities.
The station is in the process of developing and implementing a comprehensive respiratory protection program. As an interim measure, respiratory protection equipment is being used wherever warranted by conditions, but credit is not being taken for protection factors when calculating MPC-hrs of exposure to airborne radioactivity. Both the existing program and the draft plans for the new respiratory protection program were reviewed during the evaluation. Deter-4 minations were made as follows:
Finding (Reference Criterion B)
The station does not have a formal program in effect to control entry to and work in confined spaces. Additionally, systems that supply breathing air for use in supplied-air respirators are not sampled to verify the air j
meets breathing air quality specifications.
Note: It is recognized that the station plans to incorporate breathing air i.
quality sampling in the new respiratory protection program.
l-Recommendation Develop and implement a program for entry into confined spaces. The
~
program should include identification of confined spaces, pre-entry testing, ventilation, respiratory protection, worker safety and routine monitoring of occupied spaces.
Service air systems should be sampled prior to use as breathing air and periodically thereafter.
The output of the self-contained breathing apparatus bottle charging station should be sampled as an item of routine maintenance.
Response
Implementation of the respiratory protection program will include both confined space and breathing air quality sampling and is scheduled for completion by September 1981.
PILGRIM (1981)
Paga 29 TECHNICAL SUPPORT On-site engineering support was evaluated in the areas of organization and administration, engineering functions performed, nuclear operating experience evaluation, plant modifications, and reactor engineering.
A good effort is being made by the Technical Group to implement plant management goals through specific tasks assigned in the areas of reactor engineering, I&C engineering, and chemistry.
The document control system being implemented by the on-site Information Resources Management Group is comprehensive and well organized. Improvements can be made in the following performance areas:
TECHNICAL SUPPORT ORGANIZATION AND ADMINISTRATION (INPO Procedure TS-701, Revision 1)
Evaluation was performed to determine if the technical group is capable of performing all assigned responsibilities, personnel are knowledgeable of their duties, a training program exists to enhance and develop the skills and knowledge of personnel, and non-technical personnel are utilized for non-technical tasks.
The criteria of TS-701 were met except as noted in TQ-211, Criterion D.
ENGINEERING SUPPORT (INPO Procedure TS-702, Revision 2)
Evaluation of the engineering support functions was performed. These functions included plant performance monitoring, communication with other support groups, control of important documents, and adequacy of engineering support facilities. Determinations were made as follows:
1.
Finding (Reference Criterion A)
A plant performance improvement program has not been developed to take advantage of the performance data currently being collected and monitored by the Shift Technical Advisors (STA).
Recommendation Develop a plant performance program.
The program should include modeling, data analysis, mechanisms for improving efficiency and rell-ability, and responsibility assignments.
Response
We concur with the need for a more effective plant performance improvement program. With STA training scheduled to be completed in July and the addition of two Performance Engineers by January 1,1982, this function will be re-emphasized and expanded to include the above.
PILGRIM (1981)
Paga 30 2.
Finding (Reference Criterion C)
Drawings are not revised in a timely manner to incorporate as-built information. In addition, legibility is not good on laminated copies of some controlled drawings and temporary as-built drawings.
Recommendation Develop a system to ensure that drawings are issued and revised in a timely manner. Efforts should also be made to improve the readability of drawings.
Rw We concur with the finding regarding timely updates of drawings and will address the issue as part of our efforts in the development of a post-work test plan.
Drawing legibility is a chronic problem for which corrective action was initiated about two years ago.
Efforts will continue in this area.
3.
Finding (Reference Criterion D)
The facilities availdte for document control are not adequate to support the necessary and expected effort.
Recommendation Review the long-term needs of the on-site Information Resources Management Group and provide additional work and storage space as required. Provide appropriate areas for use and protection of controlled drawing sets throughout the plant, especially in the I&C Shop area adjacent to the control room.
Response
The planned administration building expansion addresses some of this issue. Appropriate areas for use and protection of controlled drawings in the I&C shop area will be provided by January 1,1982.
NUCLEAR OPERATING EXPERIENCE EVALUATION PROGRAM (INPO Procedure TS-703, Revision 1)
Evaluation was made of the programs in place for analyzing in-house and industrywide operating events. The Nporting, review, and follow-up corrective actions for in-house events were examined, along with the method of dissemi-nating the information to appropriate personnel and the industry. For industry events, examination was made of the sources of information reviewed, the screening process employed in surveying events, and the disposition of events relevant to the plant. Determinations were made as follows:
1.
Finding (Reference Criterion B)
The program for review of industry events is not fully implemented at the plant. Two new procedures, Nuclear Operations Support Department (NOSD) Procedure 22.01 and Pilgrim Procedure 1.3.33, have been dis-tributed. However, these procedures do not assign specific responsi-bilities to determine information distribution and action at working levels and do not provide for a follow-up system on action items.
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PILGRIM (1981)
Paga 31 Recommendation
. Revise NOSD Procedure 22.01 and Pilgrim Procedere 1.3.33 to include responsibility assignments and a follow-up system to ensure that action items are completed. Provide training to effected personnel.
Response
~
We concur with the recommendations and will implement procedure changes and provide the necessary training for effected personnel. This action will be completed by January 1,1982.
2.
Finding (Reference Criterion C)
The program for review of in-house and ir.austry events does not include a provision for periodically evaluating its effectiveness. The present scope of quality assurance review does not address effectiveness.
Recommendation Modify the existing program for review of in-house and industry expe-riences to include periodic evaluations for effectiveness. These periodic evaluations should determine the depth of understanding by the group (s) receiving the information, i.e., operations, mechanical maintenance, electrical maintenance, instrument and control, etc. The program should be independently reviewed by knowledgeable individuals to ascertain that information is provided to the right people in a timely manner and corrective actions are being implemented.
Response
We concur with the need to evaluate the effectiveness of the operating experience feedback system. Since an independent review is essential to an objective review, we will assign the responsibility of performing these periodic reviews to an off-site group.
PLANT MODIFICATIONS (INPO Procedure TS-704, Revision 1)
Evaluation of the program for processing plant design changes was performed to determine if changes are implemented in a timely manner while maintaining the quality of plant systems, structures, and components.
Review of proposed modifications, prioritization, tracking, testing, verification of installation, and closecut of the design change package were examined.
Determinations were made, as follows:
1.
Finding (Reference Criterion B)
Effective coordination for design, installation, and testing of plant design changes is not evident.
Recommendation Establish more effective communicatiens among all groups, on-site and off-site, involved in the Plant Design Change Request (PDCR) process.
Designating an individual in each group to act as contact point for PDCRs een aid in establishing improved communications and coordina-tion.
i PILGRIM (1981)
L Paga 32
Response
We concur with the finding regarding more effective coordination among the on-site and off-site groups. We have addressed this issue as part of our overall effort to upgrade our Integrated Work Management System and its primary components:
Site Work Control System, Inter-departmental Work Request and Authorization Control System, and Plant Design Change Control System.
2.
Finding (Reference Criterion C)
PDCRs are not adequately tracked.
PDCR status cannot be readily determined from the time an approved request leaves the plant until it is installed and the design change is being closed out by the Management Services Group (MSG).
Recommendation Provide a method furnishing information to the MSG tracker at each stage in the PDCR package so current status of the PDCR can be determined.
Response
We concur with the finding of inadequate tracking. We have addressed this issue as part of the overall upgrade of our Integrated Work Management System.
3.
Finding (Reference Criterion F)
Entries in the Lifted Wire ind Temporary Jumper Log reflect the use of a temporary plant change mechanism to effect permanent plant modifi-cations. These changes are not reflected in plant drawings and other documents and the effect on subsequent plant design changes may be overlooked.
Recommendation Establish a review schedule of suitable frequency for evaluating entries in the Lifted Wire and Temporary Jumper Log. The review should be conducted by an individual or. group independent of operations and knowledgeable of subsequent plant mocifications. Entries exceeding a specified length of time in the log should be considered for processing as PDC Rs.
Response
We concur with the findings and plan to factor the potential for temporary modifications into our design input and review phases of the Plant Design Change Control System. We also plan to conduct a review of the jumper / lifted lead process to determine if adequate management controls are in place.
A periodic assessment of the entries will be considered as part of the review process.
4.
Finding (Reference Criterion I)
Effective operator training, drawings, revisions and procedure revisions that result from plant modifications may not be completed prior to placing modified systems in service. Posted Operations Review Com-mittee minutes do not effectively convey modification purpose, scope, or operating philosophy for most plant modifications.
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PILGRIM (1981)
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Page 33 The backlog of PDCR packages in the close-out stage creates the potential for systems being placed in service with inadequate infor-mation available for the operators.
Recommendation Provide operators with training, revised as-built drawings, updated procedures, and surveillance requirements regarding installed PDCRs on a formal basis prior to placing modified systems in service. Operator understanding of plant and procedure modifications should be periodi-cally evaluated. Initiate action to relieve the backlog of PDCR packages currently awaiting closeout by the MSG.
Response
We concur with the finding regarding a need to improve in'various phases of our Plant Design Changes Control System. We have initiated effortr to establish a more clearly defined and regimented post-work test plar, which will address at least those elements alluded to in the finding. It is planned to have this effort completed prior to startup from the 19E1 outage.
ON-SITE REACTOR ENGINEERING (INPO Procedure TS-705, Revision 2)
Evaluation of reactor engineering was performed to assess the use of appropriate procedures, computer programs and control of changes to them, and the support functions provided by the on-site reactor engineers during all modes of plant operation. Additional areas evaluated included communication with other groups that coordinate with the site reactor engineers, the dedication to the mainte-nance of fuel cladding integrity, and the involvement in refueling activities.
Determinations were made as follows:
The criteria of TS-705 were met.
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PILGRIM (1981)
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APPENDIX Page 1 ADMINISTRATIVE APPENDIX I.
LISTING OF AREAS EVALUATED ORGANIZATION AND ADMINISTRATION OA-101 Objectives OA-102 Organization Structure OA-103 Administrative Controls OA-104 Quality Programs OA-106 Industrial Safety OA-107 Surveillance Program O A-108 Personnel Qualifications TRAINING AND QUALIFICATIONS TQ-211 Training Organization and Administration TQ-221 Training Resources TQ-231 Training Effectiveness TQ-242 Non-Licensed Operator Training TQ-243 Licensed Operator Training TQ-244 Licensed Operator Requalification Program TQ-245 Shift Technical Advisor Training OPERATIONS O P-301 Organization and Administration OP-302 Tagout Practices OP-303 Conduct of Shift Operations OP-304 Use of Procedures OP-305 Plant Status Controls OP-306 Operations Facilities and Equipment OP-307 Shif t Turnover MAINTENANCE MA-401 Maintenance Organization and Administration MA-402 Preventive Maintenance MA-403 Maintenance Procedures M A-404 Work Control System MA-405 Maintenance History MA-406 Control and Calibration of Test Equipment and Instrumentation M A-407 Control of Special Processes MA-408 Maintenance Facilities and Equipment
PILGRIM (1981)
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APPENDDC Page 2 RADIATION PROTECTION AND CHEMISTRY RC-501 Radiation Protection and Chemistry Organization and Administration RC-502 ALARA Program RC-503 Personnel Dosimetry RC-504 Radiation Surveillance and Control RC-505 Waste and Discharge Control (Liquid)
RC-506 Radiological Survey Equipment Control and Calibration RC-507 Personnel Health Physics Indoctrination RC-508 Process Water Controls RC-509 Health Physics Facilities and Equipment RC-511 Respiratory Protection Program TECHNICAL SUPPORT TS-701 Technical Support Organization and Administration TS-702 Engineering Support TS-703 Nuclear Operating Experience Evaluation Program TS-704 Plant Modifications TS-705 On-Site Reactor Engineering 4
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n PILGRIM (1981)
APPENDDC Page 3 II.
BOSTON EDISON COMPANY PERSONNEL CONTACTED Manager of Nuclear Operations Staff Assistant Staff Assistant - Nuclear Safety Chief - Management Service Group Chief - Maintenance Group Chief - Technical Group Chief - Radiological Group Senior Plant Engineers Senior Compliance Engineer Senior Planning Engineer Senior Fire Protection Engineer Senior Reactor Engineer Senior Chemical Engineer Senior Instrument and Control Engineer Senior Maintenance Engineer Senior Nuclear Training Specialist Senior Quality Assurance Engineer Senior Quality Control Engineer Senior Reliability Engineer Senior ALARA Engineer Nuclear Watch Engineer Nuclear Operations Supervisors Nuclear Plant Operators Nuclear Maintenance Supervisors Instrument and Control Supervisors Operational Quality Control Group Supervisor Acting Supervisor, On-Site Information Resources Management Group Stores Supervisor Health Physics Records Supervisor Health Physics Supervisor Reactor Engineer Chemical Engineer Plant Engineers Quality Control Engineer ALARA Engineer Radiological Engineer 4
Shift Technical Advisors Nuclear Control Technicians Nuclear Auxiliary Operator Manager - Stores Department t
Quality Control Inspector Physician's Assistant Nuclear Ten:ning Sp?cialist Maintenance SV11s Instructor Waste Managaent Coordinator Health Physics Technicians i
Health Physics Clei k Training Group CletF Instrument and Control Clerk Tw4
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