ML20141D471
| ML20141D471 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/26/1986 |
| From: | Harrington W BOSTON EDISON CO. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 86-037, 86-37, NUDOCS 8604080092 | |
| Download: ML20141D471 (5) | |
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BOSTON EDISON COMPANY 800 SovLaTON STREET BOSTON, M AssAcHusETTs 02199 WILLIAM D. HARRtNGTON etesten vies passessest
.,z.6s.e March 26,1986 BEco Ltr # 86-037 Dr. Thomas E. Murley Regional Administrator U.S. Nuclear Regulatory Commission Region 1 - 631 Park Avenue King of Prussia, PA 19406 License DPR-35 Docket 50-293 Response to Systematic Assessment of Licensee Performance l
(SALP) Report No. 85-99. Dated February 18. 1986
Dear Dr. Murley:
In accordance with your request to provide comments in writing for the functional areas rated as Category 3 in the subject report, please find our conenents in the enclosure to this letter.
We appreciate the opportunity afforded to us at the SALP meeting of March 5, l
1986, to exchange views candidly. We also appreciate acknowledgement of the numerous licensee strengths as noted within the SALP Report. We fully intend to strengthen our processes related to critical self-assessment and timeliness of corrective action.
The resources of the Company will continue to be applied to whatever degree necessary such that Boston Edison can achieve and sustain the performance objectives which have been established by the nuclear industry. We welcome continued input from the NPC.
Should you have any questions or conenents regarding this letter, please do not hesitate to contact me.
Sincerely,
(
W.D.Harringthn Enclosure 9604000092 % h 93 PLa ADOCK PDR G
ENCLOSURE A.
PLANT OPERATIONS Licensed Operator Staf fina/Trainino At various meetings with the NRC, Boston Edison had previously agreed 4
that staffing levels of licensed reactor operators are substantially below that which are desired.
Boston Edison agrees that continued management attention is required to prevent the operator shortage f rom becoming more acute.
To that end several actions have already been implemented and others planned.
In December,1985, the Boston Edison nuclear training functions were reassigned to the recently established Management Services Section, the manager of which reports directly to the Nuclear Operations Manager.
This realignment was intended to allow the training functions to be even more in concert with the needs of the Station.
In late January,1986, the Operator Training Staf f within the training group was put under the direction of a more senior level, heavily-experienced, operations training individual. Af ter careful consideration, and evaluation of the impact on the Operations Group it was decided to reassign one of our most highly knowledgeable licensed, senior reactor operators to assist in the management of the operator training functions. Working in conjunction with the Chief Operations Engineer, these individuals have revised the operator staffing / training plan with the objective of reducing the amount of time necessary to increase the number of licensed reactor operators while, at the same time, ensuring that the quality of the training program is not diminished.
Initial emphasis has been placed on the tour qualification and continuing training portions of the program to ensure that the non-licensed nuclear plant operators are highly knowledgeable and productive while completing their on-watch time as a prerequisite to the hot-license portion of the program.
Recruiting efforts have also been revamped as evidenced in the Company's ability to staff ten positions (as mentioned in the SALP report) with a 1
number of degreed and/or Navy nuclear-experienced personnel. Worthy of 3
mention also is the rigorous screening process used for candidate l
selection which, among other things, includes interviews by two independent review boards composed of senior level Station operations and training personnel.
The results of the recruiting and screening efforts coupled with concurrent accreditation efforts have provided Boston Edison with a high degree of confidence that this class of license candidates will be of the highest quality possible.
It is also our intent to monitor attrition levels closely and initiate timely re-staffing efforts to ensure that adequate numbers of candidates are in the training pipeline.
Finally, as discussed with the NRC, Boston Edison management is in negotiations regarding an apprenticeship program which is intended to provide structured development not only for operators but also for various other functional disciplines associated with nuclear power plant operations.
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-e Regarding the concern of excessive overtime, we believe that one of the primary contributors to cause was insufficient attention paid to ensuring that the authorizations to exceed overtime guidelines were properly documented. Notwithstanding the above, the shortage of licensed operators contributed significantly to the large number of overtime hours worked. Until such time as additional candidates are licensed, the Company has taken actions intended to result in a more balanced distribution of overtime for licensed operators.
These actions include the recalling of two licensed reactor operators who had previously transferred to other sections and a restructuring of the shif t rotation schedule.
Finally, our tightened administrative controls should be more effective in preventing unauthorized overtime.
Professional SuDoort Staffing Boston Edison has completed an assessment of operational support for the Operations Group and has determined that more direct technical support should be provided to the Chief Operations Engineer.
The Company is currently assessing the optimal way to provide this support and expects to arrive at a conclusion in the next few weeks.
It is believed that the subsequent actions, along with the hiring of the Operations Section Manager will better enable the group to address the operational program needs as well as day-to-day operation of the Station.
This suppcrt will also enable the group to elevate the priority of responding to quality assurance findings. Upper management has taken, and will continue to take, a firm role regarding positive response to the quality assurance prog ram.
B.
RADIOLOGICAL CONTROLS Boston Edison concurs with the observation of an improving trend as noted by the NRC during the last quarter of the assessment period.
Notwithstanding this trend, it is recognized that aggressive management attention must continue in order to achieve the desired performance objectives in this important functional area.
Staffing /0versight As discussed previously with the NRC, Boston Edison has encountered substantial difficulties in staffing several key positions within the Radiological Section. As a result, the Company has contracted with an executive search firm to assist in attracting qualified candidates for not only radiological positions, but also several other functional positions. These staffing efforts will be vigorously pursued.
Regarding oversight of radiological work, it is our intent to reduce our reliance on contractor personnel. We plan to limit to the extent possible the use of contractor technicians to augment our permanent staff during heavy worklead periods. We have also implemented a requirement within our Outage Management organization to conduct interdisciplinary critiques prior to starting significant tasks which have substantial radiological risks.
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Beyond the line function-oversight of radiological activities, upper management is kept informed of trends through monthly Radiolgical Occurrence Reports and Performance Monitoring Reports, thus providing for independent oversight of management's overall performance against several key performance indicators.
Corrective Action System Boston Edison continues to strive for improvements in the Radiological Occurrence Report (ROR) process.
The associated procedure has been upgraded to improve the quality and promptness of corrective actions.
The function of the independent on-site assessor will be preserved using either a qualified contractor or a member of the Radiological section who reports to the Radiological Section Manager and the Radiological Oversight Committee. ROR's are now trended to show relative performance and are analyzed collectively to determine generic or repetitive problems. We are also keeping personnel informed of radiological occurrences and corrective actions by integrating the ROR process into the day-to-day reporting / communications at the daily plant staf f meeting.
Program Improvement Boston Edison concurs that there is much work to do in improving the ALARA program and procedures. We believe that the full effects of the Radiological Improvement Plan (RIP) have not yet been felt and will take considerable ef fort and perseverance particularly until the key management positions are filled.
Self assessment of effective implementation of RIP improvements is being determined through the Radiological Oversight Committee (ROC).
The ROC is providing this function as specified in its charter and performing systematic and comprehensive assessments of Pilgrim's mandated Radiological Improvement Program (RIP) implementation. As ut November 26, 1985, when the program elements were nearing completion, the ROC instituted an effectiveness assessment review of the RIP by identifying the 14 major areas for improvement and assigning teams of ROC members to assess the implementation and ef fectiveness of these program improvements.
To date, nine (9) assessments have been concluded and findings reported to corporate management. Additional assessments are ongoing, and this process will continue in this manner until all 14 areas have been assessed, evaluated, and found acceptable, or until recommendations have been submitted for further improvement.
C.
EMERGENCY PREPARE 0 NESS Annual Emergency Exercise Boston Edison concurs that radiological emergency organization personnel f ailed to demonstrate r.dcqJate or appropriate exposure control for the re-entry teams. We believe that improvements in the re-entry process have been made and will be evident during the upcoming remedial drill scheduled for April,1986.
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Boston Edison also concurs that the relocation of the EOF personnel to the alternate EOF, is of sufficient importance and has been addressed in a formal procedure.
Emergency Exercise Critique Boston Edison concurs that the 1985 exercise critique should have focused more heavily on the apparent lack of adequate consideration of simulated radiological hazards encountered by the re-entry team.
In order to improve the critique process we plan to include more stringent "self critique" criteria, concentrating more on ef fectivenesss of the individual aspects of the exercise instead of just looking at the overall success criteria and believing that the exercise went well.
Emergency Preparedness Group Staffina Regarding program staf fing, a new Emergency Preparedness Coordinator was appointed and has been actively engaged in the program since January 1, 1986. Additionally, a new position of Assistant Emergency Preparedness Coordinator has been established and the position has been filled.
The Environmental and Radiological Health and Safety Group has been relocated from Braintree to Pilgrim Station to facilitate onsite assistance to the Emergency Preparedness Staff.
Presently we are evaluating the need for additional support in this area. This evaluation has included visits to other utilities and should give us a better understanding of how others manage and implement their emergency preparedness program.
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