ML20065K829

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Systematic Assessment of Licensee Performance Notes Re Facility Evaluation for Aug-Dec 1980
ML20065K829
Person / Time
Site: 05000000, Pilgrim
Issue date: 12/31/1980
From:
NRC
To:
Shared Package
ML082180535 List:
References
FOIA-82-261 NUDOCS 8210080145
Download: ML20065K829 (10)
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PILGRIM Evaluation Period: OA/01/A0 12/11/80 I.

General The licensee implemented a major organizational and personnel change s

toward the end of the evaluation period, in September, 1980.

These

,~"y, Q changes were designed to strengthen management controls and improve overall plant operations.

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Since the SALP management meeting on March 11, 1981. the licensea took a n.' ^ <. ;

number of other actions to improve performance. Major efforts include the hiring of consultants to assist in revising work control programs and

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the development of a computer based system to track action items and M

6; commitments. There is also evidence of more thorough reviews of plant inf.O:. ;p events to determine root causes, increased review and revision of cperatini f(^T?yj procedures, and increased training effort.

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Specific

'm Contention 0 C,.y;.'.g

'GJ: Q "The Pilgrim. facility displayed evidence of weaknesses in five functional areas.

These areas were: refueling, reporting, radiation protection,

_,... L.',gj emergency preparedness, and managerrent controls."

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  • i.pid These contentions are addressed as follows:

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Refueling (See Contention A)

Reporting (See Contention B)-

Radiation Protection (See Contention C)

Emergency Preparedness (See Contention D)

L Management Controls (See Contention E) l Contention A

" Weaknesses in refueling activities were characterized by several items of noncompliance, including escalated enforcement, concerning movement of fuel without secondary containment integrity and inadequate corrective actions for identified procedure discrepancies."

1.

Basis Reference i

L On March 8,1980, irradiated fuel was moved within IE Report i

the spent fuel pool without secondary containment 50-293/80 integrity. This event exceeded a Limiting Condition I

for Operation.

The activity was conducted without the

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consent of the Watch Engineer which is in violation of l

station fuel handling procedures.

In addition, the

. auxiliary electrical system, including emergency I

power, was aligned other than as prescribed by plant

's procedures.

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PDR FOIA UDELL82-261 PDR l

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As a result of previous fuel handling errors exper-IE Report icnced in December, 1979, procedure revisions were 50-293/80-09 necessary to prevent recurrence. However, an inspection conducted in January, 1980 identified that the required revisions to the procedure were not yet made. These procedural discrepancies, however, did not contribute to the problems experienced on March 8, 1980.

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2.

NRC Action I

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The inspection following the March 1980 event identified IE Report R.;j four items of noncompliance, two of which are directly 50-293/80-09

@'. c related to refueling operations: moving fuel without

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secondary containment in effect; and, failure to follow

[C'3 a refueling procedure requiring the consent of the Watch Engineer.

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An Immediate Action Letter was issued confirming 3/11/80 NRC

'y g-l the licensee's commitments to perform prompt Region I

&q corrective action.

letter (IAL 81-07)

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3D,S eM A followup inspection was performed in April,1980.

IE Repcrt f? %

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No items of noncompliance were identified.

50-293/80-13 R:29 M fd A civil penalty was imposed in April, 1981 for NRC letters 7/8/80,

'd the March 1980 event.

10/30/80 and i

4/21/81.

EA80-38 l

3.

Licensee Corrective Action 1

WhentilelicenseerecognizedtheviolationonMarch IE Report 10, 1980, further fuel movement was immediately sus-50-293/81-09 pended and a prompt report was made to the NRC.

In response to the items of noncompliance, the licen-Licensee

'4 see revised procedures, performed additional train-letters of ing, and increased management control of refueling 8/1/80 and 11/19/80.

activities.

Contention B "The licensee had cases of inadequate Licensee Event Reports an.d

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responses to IE Bulletins."

References 1.

Basis

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This weakness is symptoma.ti.c.of improper management controls which is discus' sed in Contention "E".

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Problems with LER's more closely linked to ty roper management controls are, therefore., addressed m..,

therein.

Three areas are discussed below which catagorize some of the other problems associated

,.5:. p.j with improper licensee reporting.

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a.

The licensee identified that the following reports yh were not made within the required time frame:

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.; x Failure to report Reactor Scram LER 80-26

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.?"'J P Condenser delta T limit exceeded LER 80-74 v.:.

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Fire Detection Equipment Inoperable LER 80-75 6shlt i e,;.X%

b.

The resident inspector discovered that an APRM IE Report Y

~; ".:24 instrument setpoint drift had not been reported 50-293/80:

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to the NRC as required.

This event resulted in an item of noncompliance.

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Licensee w'ritten responses to I.E. Bulletins did not WM[jg always fully address NRC concerns or were not entirely

. hily;gG accurate.

This resulted in requests from the NRC e

M for additio.,a1 information, action, and revised

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responses.

Examples of inadequate responses to I.E.

i.edQ4 Bulletins include:

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IEB79-27-LossofNon-Ciass1-EInstrumentationandControl Power System Bus Durina Operation Because of inadequate initial response, the licensee IE Report' was required to submit an additional response to 50-293/80:

item 2 of this bulletin to address:

l plans for making changes to existing procedures

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plans for providing additional procedures for previously existing equipment and

. s.m newly installed alternate control shutdown panels a proposed schedule for completing these items IEB 80 Degradation of BWR Scram Discharge Volume Capacity Item 3 of this bulletin required that facility pro-IE Report cedures specify certain requirements for SOV vent 50-293/80:

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and drain valves.

The licensee's response did not address those r. equi.rements.

4 IEB 80 BWR Jet Pump Failure The licensee's surveillance procedure for taking IE Report u<

dati to identify,*et pumps degridation did not 50-293/80-2) include all of the data required by the Bulletin.

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2.

NRC Action

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.QCi In each instance where an inadequate report was identified, the licensee was required to take

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corrective action as appropriate, ard the resident

_ 'S incpector followed the progress of that action.

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Enforcement action was taken for identified items of

.p. (:jj noncompliance.

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Licensee Corrective Action n rcn..

..Mc G At the SALP Management Meeting, senior licensee management expressed concern over past reporting

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_. 'M.Ei deficiencies, and expressed a desire to improve their T is k i communications with the NRC.

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-ing{gt jfh The licensee develo. ped a computer tracking system 9 EMS

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to commitments to the NRC, which includes reports, NisiG) aq 62 Reports and responses to the NRC issued from the ad.hi*

corporate offices are now reviewed by station management for accuracy piior to being released by the corporate office.

Contention C "Thb Radiation Protection Program was characterized by numerous items of noncompliance and program weaknesses, many of which were identified' during the health physics appraisal team inspection."

References 1.

Basis The Health Physics Appraisal 'n January 1980 identified IE Reports,

several weaknesses in the Int.rnal Exposure Control 50-293/80-0 Program and the personnel selection and training program.

and 80-29 Examples of these weaknesses included:

the lack of a technically knowledgeable individual assigned to the Internal Exposure Control Program; weakness in

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personnel training and qualifications; lack of procedures; lack of adequate facilities; lack of in plant surveillance; and faiiare to ensure 1

consideration of engineering controls. Additionally,

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there were no formal training or retraining pro-e

5 grams for members of the plant health physics staff and ainimal effort was exercised to determine the qualifications of contractor supplied haalth

.m jfl physics personnel.

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The Hea~ith Physics Appraisal identified seven items

'ifG of noncompliance with regard to the requirements EM of 10 CFR Parts 20 and 50, and the Technical

_.. t j,- s Specifications.

Examples included:

failure to 4.y),3 perform evaluation and surveys of airborne radia-tion areas; personnel exceeding the 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> control pyg).

measure for airborne radioactivity; MPC hour

?p determinations not being performed for personnel

. c~Wds in high airborne radioactivity areas; intake of

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radioactive material evaluations not being performed; Qj and, failure of the licensee to properly post and g%.w,.y.l control entry into high rat'iation areas.

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2.

NRC Actions in 5.yv

%Af A management meeting was held on March 11, 1981 IE Report F#7M at which time the weaknesses and items of noncom-50-293/81-09:

QYEh pliance were addressed. A special inspection to followup on the Health Physics Appraisal is iggj

..p ggy Q;Q2 scheduled for August 1981.

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QQ 3.

Licensee Corrective Action "" 7 l3.e w The licensee took corrective actions in response Licensee

.x to the items of noncompliance identified in letters of 4-IE Reports 50-293/80-05 and 80-29. The licensee 8/29/80, committed to develop a formal training / retraining 2/5/81 and program for health physic: 7:rsonnel.

Staff mem-5/11/81.

.bers received formal training on internal

.,b dosimetry and are re-evaluating the internal

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exposure control program. Necessary equipment was ordered; procedures are being revised or.

developed as the situation dictates.

Contention D

" Escalated enforcement was taken to correct identified weaknesses and inadequacies in several emergency response procedures."

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Basis References The HP Appraisal inspection of January, 1980 also Report included a review of the licensee's Emergency 50-293/80-05 Preparedness.

Several deficiencies associated

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wit.h the licensee's ability to organize and

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mobilize personnel in the event of an emergency were identified.-

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6 The present equipment configuration for emergency environmental monitoring in conjunction with existing procedures were found to be inadequate since there was an inability to detect, measure and project radiation levels and radionuclide concentrations in air equiva-lent to the lower limits of the Protective Action Guides.

l-The procedures for declaring an emergency were based

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solely on the results of a rapid protected area p*;

'o survey.

The survey method was inadequate and de-pendence upon it was considered unacceptable.

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9 Several emergency plan implementing procedures were 4j?M;i found to be outdated due to changes in personnel jj W and facilities.

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,$;;s The emergency plan training program, as written K.

in the Pilgrim Station Training Manual, was not being implemented.

The 1979 radiation emergency f [_.-

plan training was not performed in accordance with the tr.aining manual.

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..A The state of readiness of emergency equipment Mb

%-Y appeared to indicate some maintenance

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problems, e.g., items missingland, out of i48]

calibration.

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There was a lack of clear assignment of emergency I

duties and responsibilities for radiation j

protection and emergency repair / corrective actions.

l Subsequent to this evaluation period, a regional IE Report inspection following up on a resin spill of 50-293/81-04 January 17, 1981, indicated that the licensee failed to take adequate action to implement I

interim corrective measures addressing radiation protection during emergencies which were previously i

identified in the January, 1980 HP Appraisal.

Neither routine nor emergency procedures addressed the special considerations for preventing or limiting exposures during emergency situations.

2.

NRC Action An Immediate Action Letter was issued in February, 2/27/80 NRC

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1980, to confirm the licensee's commitments to Region I correct the concerns identified in the HP Appraisal.

letter l

(IAL 80-06) l

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A special regional inspection was performed in IE Report May, 1980 to confirm implementation of the 50-293/80-23 J. V licensee's commitments.

.5 An Immediate Action Letter was again issued in 2/10/81 NRC February, 1981, to confirm the licensee's commit-Region I rent to correct items identified as a result of letter

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the resin spill event.

(IAL 81-09) 5 3.

Licensee Corrective Action T $ $i'4 D ' 7;f.

The licensee revised procedures, conducted IE Report

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training and procured additional equipment in 50-293/80-23

f..A response to the IAL of February 27, 1980.

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S-C$fk The licensee committed to revising additional IE Report W.g procedures, conducting additional training, and 50-293/81-04;

QMg updating system drawings.

2/10/81 NRC Region I

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letter H

(IAL 81-09) gT3g bh Contention E j$2N@

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" Licensee management. control weaknesses were indicated by inadequate Wh Z:T r& W evaluation of several events to prevent recurrence, instances of inadequate kWDM) made to the NRC.", and instances of inadequate implementation of co corrective actions

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Basis References Two items of noncompliance were identified which IE Reports related to inadequate management controls:

failure 50-293/80-09

-to pr. ovide a station procedure for operation of and 80-20.

the electrical distribution system with the auto-close feature of the EDG output breakers defeated; and failure to ensure that no main-tenance was performed after the containment inspection prior to the Containment Integrated Leak Rate Test.

At least six LER's issued by the licensee during LER Numbers the evaluation period identify inadequate manage-80-23, 80-36 ment controls.

In LER 80-36, licensee management 80-39, 80 failed to insure that hourly fire watch tours 80-68 and were performed as required for inoperable smoke 80-72.

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detectors. Another example is LER 80-39, wherein the product of APRM instrument tolerance limits permitted prior to recalibration allowed the setpoint to drift beyond the required Technical Specification i

prevented this situatio6.' contro1 would have i

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limit.

Adequ. ate management

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A review of many LER's indicated lack of thorough-LER's/

ness in evaluating failures to prevent similar (Earlier l

causally-linked events.

This is indicated by the Related number of events, similar and recurrent, which list LER'.)

only replacement or repair of a failed component as 80-18, 80-41 corrective action without pursuing the cause for (79-38, the failures. This problem is demonstrated by 79-42),

e LER's 80-63 and 80-77.

In LER 80-63, it was 80-25 (79-52) reported that the containment atmosphere sampling 80-65 (80-33) system was declared inoperable due to moisture 80-86 (79-53, in the line. The cause of the moisture was 80-74) l corrected; however, action was not taken to prevent 80-79 (80-47)

.i moisture accumulation from rendering the system 80-80 (80-69)

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inoperable. The same problem was again reported in 80-60 (00-58)

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LER 80-77.

Following this second occurrence, 80-53 (80-34)

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management took action to insure proper system 80-77 (80-63)

>6 operation even in the event of moisture accumulation, 80-59 (Amend.

~M 42 to Tech.

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Specs.)

80-61, 80-93 4

.j (80-45) 17 80-21, 80-31, "N

80-42, 80-92 gp (80-09) 7dj 3

^@)3 57:3 Approximately 50% of the LER's-issued during this All 1980 32 evaluation period list 'other' as the cause. This LER's cause is chosen over personnel error, manufacturing /

- 2 construction / installation error, external causes, defective proced'ures, and component failure.

This large percentage listing 'other' as the cause may indicate inadequate review to determine the root cause and possibly could hinder appropriate corrective actions being recommended to prevent a

recurrence.

As a result of inadequate management control, IE Reports several licensee responses / actions taken as a 50-293/80-24, result of IE Bulletins did not address all specific 80-25, 80-26, aren of concern. This resulted in requests by the 80-27 and NRC for additional information, action, and/or revised 81-02 reports.

Specific examples were previously discussed in Contention "B".

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The licensee's management controls for followup and IE Reports implementation of commitments made to the NRC were 50-293/80-29,,

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found to be inadequate.

The licensee did not imple-80-30; ment commitments made concerning the TMI Task 11/18/80 NRC

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Action Plan; specifically, limiting overtime hours of Region I operators; and, limiting total times for operation letter (IAL

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9 of the containment vent and purge system.

80-40) 11/28/80 NRC Region I Letter (IAL 80-50) f 2.

NRC Action An item of noncompliance resulted in the imposition NRC letters 7

of civil penalties issued as a result of the fuel of 7/8/80, i

handling incident of March, 1980. This was pre-10/30/80 and viously discussed in Contention "A".

4'21/81.

Y Two Notices of Deviation were issued for failure to IE Report

,i; meet commitments.

50-293/80-30 Q

Immediate Action Letters were issued to confirm 11/18/80 NRC licensee's commitments to correct three TMI Region I

?j items, and control overtime for operators.

letter (IAL 80-49);

fa 11/28/80 NRC Region I letter (IAL

';s,

. S 80-50)

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-M At the SALP management meeting held,in March,1981 IE Report

, -;;i the concerns in the area of management controls 50-293/81-06 tf.4 were reviewed in depth with the licensee.

3.

Licensee Action The licensee responded to the identified items of noncompliance and deviations with actions designed to corregt the specific deficiency and to prevent its recurrence.

This consisted primarily of revising procedures where required, and properly training personnel.

l In addition, a' major reorganization and personnel LER 80-54 l

change was effected on September 1, 1980.

The (old) position of Nuclear Operations Department l

Manager (offsite) was deleted. A (new) position of Nuclear Operations Manager - Pilgrim Station (onsite station manager) reports directly to i

the VP-Nuclear.

Two Deputy Nuclear Operation Managers were assigned in place of the previous Assistant Station Manager. The previous staff under the former NOD Manager was reorganized into a separate Nuclear Operations Support (NOS)

Depart' ment. Additional staff assistants to the Station Manager were added.

The HP staff was also expanded to include'an ALARA gropp.

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These changes were made to strengthen management controls and improve overall plant operations.

Daily staff meetings are held onsite with senior supervisors on a regular basis to discuss plant status and problems.

Onsite Review Committee

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meetings are usually held once per week.

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