ML20149K043
ML20149K043 | |
Person / Time | |
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Site: | Pilgrim |
Issue date: | 07/22/1997 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
To: | |
Shared Package | |
ML20149K038 | List: |
References | |
50-293-97-03, 50-293-97-3, NUDOCS 9707290216 | |
Download: ML20149K043 (74) | |
See also: IR 05000293/1997003
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-3 - _ , .y , .- ENCLOSURE 2 i U.S. NUCLEAR REGULATORY COMMISSION . REGION I , f
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.) Docket No. 50-293 j . . Licensee No. DPR-35 l ' Report No.. 97-03 Licensee: Boston Edison Company 800 Boylston Street ; Boston, Massachusetts 02199 , i Facility: Pilgrim Nuclear Power Station i : Location: Plymouth, Massachusetts - Dates: 4/29 - 6/24/97 inspectors: Richard A. Laura, Senior Resident inspector Beth E. Korona, Resident inspector John H. Lusher, DRS EP Specialist James D. Noggle, DRS Senior Radiation Specialist Approved by: Richard Conte, Reactor Projects Branch 8 Division of Reactor Projects I ! l . l , s- 9707290216 970722 5~' l ' POR ADOCK 05000293 ) ' 'G. PDR <o e
_ - . .. ... - . . -- -.. * EXECUTIVE SUMMARY Pilgrim Nuclear Power Station NRC Inspection Report 50-293/97-03 This integrated inspection included aspects of licensee operations, engineering,- , maintenance, and plant support. The report covers resident inspection for the period'of April 29 through June 24,1997; in addition, this report includes the results of announced , . inspections by regional emergency preparedness and radiation specialist inspectors. Operations: 1 ' A thorough pre-evolutionary briefing was held ' prior to the start of dredging of the intake
I canal with emphasis placed on mitigating potential plant impact by establishing a dedicated
i watch in the intake structure and by continuously operating the travelling screens. Also, _ operators closely monitored the ultimate heat sink temperature and promptly followed the containment cooling technical specification requirements when inlet water temperatures ' reached 64.1 demees Fahrenheit. (Section 01.1) ; Three deficiencies were identified tours of plant areas, including the control room, such as an out-of-calibration standby gas treatment system flow indicator (i.e., F1-8127) located on control room panel C-7, a high pressure coolant injection system snubber which inadvertently had a nonconformance report tag hanging, and a small void existed in a fire - seallocated in the recirculation pump motor-generator set room. (Section 01.1) A potential weakness (IFl 97-03-01) was identified in the criteria used to develop the locked valve list contained in procedure 8.C.13 involving the SSW system header pressure ,
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switch root and isolation valves. (Section O3.1) I * An alert reactor' building tour' operator identified the isolation of the "A" loop of the ECCS reference leg backfill system. Operators responded to this discovery appropriately by entering the applicable tracking LCO, returning the system to operation, and revising the procedure. (Section O3.2) ; I 1
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M.aintenance: Knowledgeable operators and instrumentation and control technicians performed surveillance and maintenance activities in a controlled and professional manner, utilizing approved procedures and work packages. Personnel appropriately stopped a HPCl . -instrument functional test when the instrument did not reset per the procedure. The- ' subsequent actions to write an MR to adjust any packing leaks and to perform a calibration of the affected switches was' conservative and served to thoroughly verify operability. (Section M1.1) Positive progress'was made in the overall reduction of longstanding scaffold structures erected near safety related equipment in plant areas following the completion of RFO11. ~ Longer term decontamination and preservation efforts were planned in 1998 for the two
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RHR quadrant rooms. (Section M2.1) ii l i i I
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Electricians competently replaced SRM/lRM drive control relay coils and interfaced effectively with the supervisor who remained at the work site. The awareness of vendor related relay information by the electrician was considered a positive attribute. (Section M4.1) Based on a selected review of problem reports of issues relating to receipt and inspection activities, no past programmatic breakdown of receipt and inspection activities was evident. Performance issues similar to those in other plant departments were generally self identified with the initiation of problem reports. A tho,'ough BECo review was performed of an individual QC inspector who was directly involved with the improper acceptance of cracked safety related batteries and improper performance of inspection attributes of two swagelock fittings. No evidence existed that improper parts were installed in safety related applications that would result in inoperabilities. (Section M7.1) 1 Enaineerina: Operations, engineering, and maintenance personnel interfaced well to restore the "A" l reactor protection system bus and troubleshoot the motor-generator set following an RPS l trip and half scram. The system engineer was knowledgeable of industry problems in this area and provided valuable direction during the troubleshooting activity which discovered a miswired component provided by the vendor. Appropriate corrective actions were planned including a root cause analysis for the MG set breaker trip, a temporary procedure to gather additional data should another trip occur, and a Part 21 determination and ; discussion with the vendor. (Section E4.1) Plant Supoort: BECo continues to maintain a good emergency preparedness program. The emergency response plan and implementing procedures were current and effectively implemented. The emergency facilities, equipment, instruments and supplies were found to be ' maintained in a state of readiness. All required inventories were completed. A sampling of emergency response organization personnel training records indicated that training and qualifications were current. Reports indicated that quality assurance audits were thorough and that they satisfied NRC requirements. The licensee is effectively utilizing the CEPG and continuing to meet its offsite emergency preparedness commitments. (Sections P2 - P8) Good trending of plant system leakage and making improvements in the reduction of solid radwaste output from the plant were evident. Radwaste transportation procedures were adequate; there was frequent reference to regulations in lieu of detailed instruction. In addition, some of these references were incorrect. Oversight of the radwaste/ transportation program was not very effective. Audit coverage for both onsite and offsite radwaste processing and shipping activities was very weak. Self-checking of shipments was not formalized and lacked independence of review. Long-term lay up of the waste feed tank and floc recycle tank as abandoned equipment remained to be accomplished. (Sections R1 - R8) iii
. .. . _ . _ . ._ . _ _ _ _ ._ .- _ . . . * . , * A violation (97-03-02) was identified when a station services worker tied a radiologically . controlled area (RCA) door open without informing radiation protection personnel or - stationing a barricade to prevent inadvertent personnel ingress or egress. This problem in combination with a few previous ones which directly impacted plant equipment indicated a programmatic weakness in the waste control technician training program. (Section R1.2) Chemistry tech'nicians drew a gaseous ' sample demonstrating the reliability of the PASS system equipment. Very good procedural adherence was evident and one minor equipment work around condition was identified involving the gas vial holder. (Section R4.3) ,
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. TABLE OF CONTENTS EX EC UTIVE S U M M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii Summ ary of Pla nt Statu s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. OPERATIONS .................................................. 1 01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 01.1 General Comments ................................. 1 03 Operations Procedures and Documentation ..................... 2 03.1 Locked Valve List .................................. 2 03.2 Isolation of Reactor Vessel Level instrumentation Reference Leg Backfill System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 211. MAINTENANCE ................................................ 4 M1 Conduct of Maintenance .................................. 4 I M 1.1 General Comments ................................. 4 M2 Maintenance and Material Condition of Facilities and Equipment ...... 6 M2.1 (Closed) Inspector Follow ! tem (50-293/95-13-01): Plant Housekeeping and Scaf folding. . . . . . . . . . . . . . . . . . . . . . . . . . 6 M4 Maintenance Staff Knowledge and Performance . ... . . . . . . . . . . . . . . . 6 M4.1 Electrical Maintenance Activities on CR120A Ir dustrial Control Relays .......................................... 6 M7 Quality Assurance in Maintenance Activities .................... 7 ; M7.1 Receipt and Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 ' ill . EN G I N E E RI N G . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 E4 Engineering Staff Knowledge and Performance . . . . . . . . . . . . . . . . . . . 9 E4.1 Half Scram Due to Tripped "A" RPS Motor-Generator Set . . . . . . 9 IV. PLA N T S U PPO R T . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . 11 R1.1 Liquid.To-Solid Radwaste Processing . . . . . . . . . . . . . . . . . . . . 11 R1.2 (OPEN) Violation 97-03-02: Radiological Controlled Area Boundary Door ................................... 12 R2 Status of RP&C facilities and Equipment ...................... 13 R2.1 Onsite Radwaste Storage . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 R2.2 Laidup Radwaste Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . 13 R3 RP&C Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . 14 R3.1 Radwaste/ Transportation Procedures . . . . . . . . . . . . . . . . . . . . 14 j R4 Staff Knowledge and Performance in RP&C . . . . . . . . . . . . . . . . . . . . 15 R4.1 Radwaste Sampling and Characterization . . . . . . . . . . . . . . . . . 15 ' R4.2 Radioactive Material Shipping Documentation Review . . . . . . . . 15 R4.3 Post Accident Sampling System Operation . . . . . . . . . . . . . . . . 15 1 R5 Staff Training and Qualification in RP&C . . . . . . . . . . . . . . . . . . . . . . 16 I R5,1 Radwaste Transportation Training for Shippers and RP v 1 1 t
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d . . Te c h nici a n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 R7 - Quality Assurance in RP&C Activities ........................ 16 R8 Miscellaneous RP&C issues ............................... 17 R8.1 Updated Final Safety Analysis Report (UFSAR) . . . . . . . . . . . . . 17 F2 , Status of EP Facilities, Equipment, and Resources ............... 18 P3 EP Procedures and Documentation .......................... 18 P4 Staff Knowledge and Performance in EP . . . . . . . . . . . . . . . . . . . . . . 19 P5 - Staff Training and Qualification in EP . . . . . . . . . . . . . . . . . . . . . . . . . 20 P6 EP Organization and Administration ......................... 21 P7-- Quality Assurance in EP Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 P8 Miscellaneous issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 P8.1 Yankee Atomic Central Emergency Preparedness Group (CEPG) . 22 P8.2 Braintree Reception Center . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 V. M A N A G E M E NT M EETI N G S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 X1 Exit Meeting Summ ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 X3 Management Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 6 X4 Review of UFS AR Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 INSPECTION PRO CEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 ITEMS OPENED, CLOSED, AND UPDATED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 LIST OF ACRONYMS USED ......................................... 27 i l l l I < i i I i , vi j J
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... e. , REPORT DETAILS l
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: Summarv of Plant Status ,
I ' Pilgrim Nuclear Power Station (PNPS) began the period operating at approximately one *
. hundred percent rated core thermal power where it remained until May 24. Operators [ reduced power to approximately 50 percent on the 24th to perform a scheduled backwash ; of the main. condenser. Operstors returned the unit to-100 percent power on May 25,
l following the backwash.
; Operators maintained the teactor at 100 percent power until 10:28 on June 11, when.a generator core monitor trouble alarm actuated. Operators commenced a downpower by I
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reducing recirculation flow and took actions to verify the alarm per the alarm response procedure and procedure 2.4.158, Core Monitor Trouble. At approximately 75 percent
[ power, operators determined the signal was invalid. Operators then verified acceptable-
stator bar temperatures and,'at 12:20 that day, restored the reactor to approximately 100 percent power, where it remained though the rest of the period, a ,
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l. OPERATIONS 01- Conduct of Operations' ; .01.1 General Comments (71707)
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Using Inspection Procedure 71707, the inspector conducted frequent reviews of ongoing
{ plant operations. 'in general, the conduct of operations was professional and safety
conscious. During tours of the control room, the inspectors discussed any observed ' alarms with the operators and verified that they were aware of any lit alarms and the
reasons for them. . Any anomalies noted during tours were discussed with the nuclear
[ watch engineer (NWE).
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For example, the inspector identified that standby gas treatment (SBGT) system common flow instrument F1-8127 indicated 1150 scfm in lieu of 0 when SBGT was not running and the dampers were closed. F18127 is located on control room back panel C7. The nuclear watch engineer (NWE) initiated problem report no. 97.9335 to evaluate the condition and
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identify corrective actions, as needed. A subsequent l&C calibration determined that the flow transmitter and indicator were both out of calibration. The inspector concluded that operators missed the identification of this SBGT system indication anomaly during routine I panel walkdowns. ' Also, when touring the recirculation pump motor-generator (MG) set room located on the 51 foot elevation in the reactor building, the inspector questioned the operability of fire - penetration seal 65.21.02 due to a small void in the top of the seal. After determining the - seal was degraded but operable, the fire protection engineer initiated work request tag l : (WRT) 047714 to seal the void with adhesive caulk. The inspector' reviewed the t
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' Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized reactor inspection report outline.- Individual reports are not expected to address all outline topics. . I
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2 inspection criteria contained in Appendix A-7 of fire seal specification M-750 and independently confirmed the adequacy of the fire protection engineers operability decision. Lastly, during an inspection of high pressure coolant injection (HPCI) system components, the inspector observed an Nonconformance Report (NCR) tag hanging on a new safety related snubber installed during RFO11. As a result, quality assurance personnel initiated PR 97.1896 which preliminarily determined that the snubber was operable but the NCR tag had not been removed due to a personnel error. Other specific events and noteworthy l observations are detailed in the following sections. The inspector attended the pre-evolutionary briefing (PEB) held for dredging of the intake canal to the intake structure. The removal of approximately 30,000 cubic yards of sand was planned. Precautionary measures were discussed and implemented after the PEB such as stationing a designated intake structure watch and continuously operating all travelling screens. Operators were aware of the status of dredging operations and no problems were observed by the inspector. Also, operators closely monitored the salt service water (SSW) ; inlet temperatures which approached and on a few occasions exceeded an instantaneous reading of 65 degrees Fahrenheit during this inspection period. As previously committed to the NRC, BECo appropriately declared containment cooling systems inoperable and followed the technical specifications. BECo previously submitted a license amendment submittal to increase the SSW temperature limit to 75 degrees Fahrenheit. 03 Operations Procedures and Documentation 1 03.1 Locked Valve List a. Inspection Scone A general inspection of the intake structure was performed with special emphasis on the configuration of safety related equipment. Valves designated to be locked per procedure 8.C.13, Locked Component Lineup Surveillance, were verified. b. Observations and Findinas Valves required to be locked per 8.C.13 in the intake structure were verified to be correctly positioned and locked. Aware of a past service water operational performance inspection (SWSOPI) observation that the safety significance of the salt service water (SSW) header pressure switches was not always fully recognized, the inspector verified that each root and isolation valve for the four SSW header pressure switch were open. Each cf the two l SSW headers has two redundant pressure switches (i.e., PS-3828A&B and 3829A&B) l which sense a low header pressure and provides an input to start a SSW pump when l recovering from a loss of AC electrical power condition. The inspector noted that the l pressure switch root and isolation valves were not locked. 1 Procedure 8.C.13 did not require the aforementioned valves to be locked, but the inspector I noted that criteria "A" for requiring a valve to be locked specified that manual valves which, if out of position, could defeat safety related function, should be locked. Four examples were listed under criteria "A" in procedure 8.C.13 referenced process fluid valves 1 1 l l l
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3 (e.g. suction, discharge and drain valves) as opposed to instrument and pressure switches. The inspector also obtained copies and reviewed BECo engineering response memorandums 90-468 and 90-729 which provided guidance in the development of the locked valve list in procedure 8 C.13. The inspector expressed concern to the operations l department manager that although the examples of criteria "A" in 8.C.13 deal with process I valves, a literalinterpretation could encompass the SSW pressure switches root and isolation valves. Aside from the locked valve criteria contained in 6.C.13, the inspector notes the important design function of the SSW pressure switches. The operations and engineering department managers initiated a review of the criteria contained in 8 C.13. , The criteria "A" in 8.C.13 was sparse and open to interpretation, the planned review was ! intended to provide clearer guidance and to determine the need to lock the SSW system root and isolation valves. This issue will remain as an inspector follow item (IFl 97-03-01) pending further NRC and BECo review. l c. Conclusions i A potential weakness was identified in the criteria used to develop the locked valve list I contained in procedure 8.C.13 involving the SSW system header pressure switch root and ) isolation valves. (IFl 97-03-01) ! l 03.2 Isolation of Reactor Vessel Level Instrumentation Reference Lea Backfill System i i l a. Inspection Scope (71707) i l On May 5,1997, a reactor building tour operator identified the isolation of the "A" reference leg backfill system for the safety-related reactor vessel level instrumentation. The inspector reviewed the conditions surrounding this event and the discussed the completed problem report and corrective actions with operations management. l b. Observations and Findinas l l Following the discovery of the isolated reference leg backfill system, PR 97.9323 was I initiated and operators appropriately entered a tracking limiting condition for operation (LCO) in accordance with procedure 1.3.34, Conduct of Operation. The reference leg backfill system is not covered in the plant technical specifications, however this procedure addresses this system and requires a traking LCO be entered. At the end of fourteen days, procedure 1.3.34 requires entry into an active LCO to ensure certain actions are l taken to highlight the issue to operators. l Through discussion with the operations manager, the inspector learned that operators determined that the system had been out of service beginning on April 30, when the i system was taken out of service to troubleshoot flow blockage indications. Operators removed the system from service per procedure 2.2.80; Reactor Vessel Level, Temperature, and Internal Prersure instrumentation; Section 7.2, Securing the ECCS , Reference Leg Backfill System. Tnis section directed personnel to close HO-C2205A-1, the I inlet block valve to the reactor water level backfill supply to C2205. The system was isolated because the cause of the blockage was not known at the time. On a subsequent l shift, plant personnel determined a filter changeout was required. This filter change was l l .
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, ' , 4 performed per Section 7.3, Changeout of Reactor Water Level Reference Leg Backfill Filter Elements,.of procedure 2.2.80,
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' Operators appropriately backdated the tracking LCO to the date of the filter changeout and , restored the system to service in a timely manner, within the 14 day LCO time. The valve "was opened and both trains of the backfill system were walked down to verify proper alignment.
j After review of the associated documents and discussion with operations management, the
- inspector verified that the apparent cause of the backfill system isolation was an
incomplete procedure. Section 7.3 of 2.2.80 did not direct personnel to open HO- C2206A-1 to restore the system to operation after the filter changeout. This valve was closed per Section 7.2 when the system was isolated. Altnough filter changeouts have been performed in the past per this procedure, typically only Section 7.3 is performed. This section does not direct the clocure of the subject valve, therefore system restoration .is complete. The inspector ver~fied that appropriate corrective acticn was taken to prevent recurrence.
- Procedure 2.2.80, Section 7.3 was immediately changed to include a step to open/ verify l
- . open this valve, as well as the sister valve on the other train of the backfill system. This' l
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licensee identified and corrected procedure inadequacy is a non-cited violation in l accordance with Section Vll.B.1 of the NRC Enforcement Policy. ]
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c. Conclusi20.1 An alert reactor building tour operator identified the isolation of the "A" loop of the ECCS . reference leg backfill system. Operators responded to this discovery appropriately by
entering the applicable tracking LCO, returning the system to operation, and revising the procedure.
i ll. MAINTENANCE l M1 Conduct of Maintenance 9 l M1.1 General Comments
a. insoection Scoce (61726. 62707) Using inspection procedures 61726 and 62707, the inspector observed portions of
- - selected maintenance and surveillance activities to verify proper calibration of test
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Instrumentation, use of approved procedures, performance of the work by qualified personnel,-conformance to limiting conditions for operation, and correct system restoration
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following maintenance and/or testing. The following activities were observed:
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e 8.9.16.1 Manually Start and Load Blackout Diesel Via the Shutdown Transformer e - 8.M.2-2.5.1 HPCI Steam Line High Flow Isolation
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* . 5 b. Observations and Findinos Operators started and loaded the station blackout (SBO) dieselin accordance with procedure 8.9.16.1. The inspector discussed various portions of the procedure with the operators and found theni to be knowledgeable of the procedure and operation of the SBO diesel. For instance, when a local SBO diesel trip alarm was received during the course of the surveillance, operators expected the alarm and were knowledgeable of its cause. The inspector noted the Work-It-Now (WIN) team leader inspecting various locations on the diesel for leaks to verify that recent repairs were satisfactory. This showed attitude of ownership of the part of maintenance for the work they do. The inspector noted two - equipment deficiencies while at the SBO diesel, a minor oil leak on the oil supply line and a missing screw on a side access cover to conduit into the generator terminal box. The inspector discussed these items with the reactor operator who subsequently wrote work requests for the deficiencies. Operators took required readings and completed the surveillance in a professional manner. While l&C technicians w'ere performing Attachment 2 of 8.M.2-2.5.1, the HPCI steam line high flow instrumentation functional test, the first of two differential pressure indicating switches failed to reset after satisfactorily bringing in the expected elarm. The inspectors observed operations, engineering, and l&C actions following this failure and noted good communication and sound decision making. The surveillance was stopped and a maintenance request (MR) 19701738 was written to adjust packing leaks suspected on the instrument lines, specifically the bypass valve on the 3 way manifold for the instrument. In addition a re-brief of the surveillance was conducted to review expected alarms, communications protocol, and procedure progression. In order to verify that the problem I was not calibration of the instrument, l&C performed at applicable portions of Attachment 2 to the procedure which provides directions for a calibration test as well as a functional test. The inspector observed l&C technicians perform the calibration test in the cable spreading room and "B" quadrant in accordance with the approved procedure and MR. The procedure verified the calibration of both switches and discovered that the 3 way valve needed to be replaced. However, since I&C technicians returned the valve to its closed position following the calibration, the instrument was declared operable and the .l' LCO, entered to perform the original functional test, was appropriately exited following the satisfactory completion of the test. c. Conclusions Knowledgeable operators and instrumentation-and-control technicians performed surveillance and maintenance activities in a controlled and professional manner, utilizing approved procedures and work packages. Personnel appropriately stopped a HPCI ; instrument functional test when the instrument did not reset per the procedure. The subsequent actions to write an MR to adjust any packing leaks and to perform a calibration of the affected switches was conservative and served to thoroughly verify operability.
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* . * I . 6 l M2 Maintenance and Material Condition of Facilities and Equipment M 2.1 (Closed 1]nsoector Follow item (50-293/95-13-01): Plant Housekeepina and Scaffoldina, a. Insoection Scoce (62707) Two large and longstanding scaffolds were left erected near safety related equipment located in the "A" RHR quadrant room and the 51 foot elevation of the reactor building. Additionally, a g;.nerally slow clean-up of plant areas occurred following refueling outage (RFO) no.10 in thb summer of 1995. A review of these two issues was performed to determine the proper resolution. b. Observations and Findinas During routine tours of plant areas following the completion of RFO11 in April 1997, the inspector observed that the two aforementioned scaffolds were disassembled and removed. The removal of the scaffolds eliminated any potential interaction between nearby safety related equipment and the scaffold structure during a potential seismic event. Also, significant progress was made cleaning plant areas following the completion ; of RFO11 which was a noted improvement when compared to the cleanup efforts following RFO10. As the last phase of the material plant condition upgrade process, BECo planned to decontaminate and coat piping with preservation paint in the "A" and "B' RHR quadrant rooms. This effort is intended to greatly reduce the radiation dose rates and contamination levels to allow easier worker and management ingress and egress during routine plent activities. The inspector determined that IFl 95-13-01 was closed. c. Conclusions Positive progress was made in the overall reduction of longstanding scaffold structures erected near safety related equipment in plant areas following the completion of RFO11. Longer term decontamination and preservatico efforts were planned in 1998 for the two RHR quadrant rooms. M4 Maintenance Staff Knowled 9e and Performance M4.1 Electrical Maintenance Activities on CR120A industrial Control Relavs a. Insoection Scone (62707) The inspector observed electricians replace several coils in CR 120 relays in applications for SRM/lRM drive control relays. The relays provide control and indication of the drive positions, b. Observations and Findinas At the work site located in the reactor building, the inspector observed effective supervisory oversight of the work activities.- The work was performed using procedure
': : 7 -3.M.3-55, CR 120A Relay Maintenance, and maintenance request (MR) P9400734. The work consisted of replacement of the coil assembly in the relay and installation of a new, nonflammable contact arm retainer which was the subject of General Electric (GE) Service Information Letter (SIL) 220. The inspector visually examined the relay contact faces which appeared slightly degraded and questioned why the contact faces were not cleaned. The electrician informed the inspector that the relay vendor instructions caution against ; cleaning the relay contacts to minimize wearing of the silver coating on the contact faces. - The inspector obtained a copy of the vendor information (V-0383) which stated that filing or dressing of the contacts only results in loss of silver and reduces normal contact life. . The inspector had no further questions in this regard but considered the electricians awareness of vendor related information as a positive attribute, i When reviewing the vendor related instructions, the electrician informed the 6spector of a potential problem involving the spacing between each relay in panel C2214. The ; instructions specified that the relays should be mounted perpendicular to the panel with ! ' 11/16 inch gap between each relay. Some of the relays installed in panel C2214 had no' ' space between each other. The inspector questioned the electrician and supervisor how : .this potential conflict would be resolved. The electrical supervisor initiated problem report .j (PR) 97.2121 for evaluation and corrective actions. Engineering personnel contacted GE to j ' determined the reason for the specified 1/16 inch spacing. The basis for the gap was to. allow for thermal expansion of the re!ay; however, the relays mounted in panel C2214 were mounted on a track that allows the relays to move laterally. An engineering : evaluation was performed which determined the relays were operable. One PR action item was initiated to change the vendor related information. The inrspector interviewed the system engineer who indicated that the PR was still being evaluated for final corrective actions. C. Conclusions Electricians competently replaced SRM/lRM drive control relay coils and interfaced effectively with the supervisor who remained at the work site. The awareness of vendor related relay information by the electrician was a positive attribete. M7 Quality Assurance in Maintenance Activities M7.1 Receiot and Inspection l l a. Insoection Scoce (62707.92903) . 1 As a follow up to the receipt and inspection issues documented in Section M7.1 of NRC ! Inspection Report No. 50-293/96-06, the inspector reviewed various other past receipt and ; - inspection issues to identify any potential trends or weaknesses. The previous concern j dealt with a calibration anomaly of the "B" scale of the Rockwell hardness tester and a l violation was cited for BECo not taking adequate corrective actions in NRC Inspection - Report 50-293/96-06.
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8 b. Observations and Findinas The inspector reviewed the 'ollowing problem reports (PR) potentially related to receipt and inspection. interviewed various quality assurance and maintenance personnel involved with the issues and reviewed relevant procedures and documentation: * PR97.0464, February 12,1997, Cracked bolts. * PR96.9154, April 2,1996, Cracks found in replacement SRM/lRM selector switches. * PR96-219, June 19,1996, Fire door Jamb only had 3 holes vice 4 as required * PR96-0084, March 6,1996, Replacement Door 162 had hinges in incorrect l location * PR96-007, January 5,1996, Dragon valves inspection question * PR95-0493, January 31,1995, inconsistent receipt and inspection methodology , * PR95.0466, June 14,1997, incomplete inspection of Swagelock fittings ] * PR94.9440, September 20,1994, Cracks in batteries not found during I receipt and inspection ) * PR94-194, April 14,1994, EQ stab assembly purchase order questions i l Dased on the review, the inspector made several performance observations. First, two of the more significant problems involved PHs 94.9440 and 95.0446 and in both cases the same individual did not complete the required inspection activities. Specifically, PR94- 9440 documented an instance where sixty-three 125 vdc safety related batteries were accepted through receipt and inspection by performing a sample inspection of 20 batteries. Subsequently, after a system engineer identified cracking in the negative bus bar in one battery, further inspection revealed that 31 of the total 63 batteries had internal bus bar cracking. Additionally, the inspector also became aware that the QC inspector did not complete the required sample inspection of 20 batteries and only inspected 1 battery. That was evident because only 1 battery shipping box had been opened. The QC inspector neither detected the internal battery bus bar cracking nor completed the required inspection of 20 batteries. BECo initiated corrective actions including the development of a specific battery receipt and inspection checklist. New batteries were procured before installation into the plant. The most probable cause of the cracked bus bars was determined to be physical shock during shipping from the vendor. PR95.0466 documents an instance where the same QC inspector signed off that the attributes fo.r visual and/or dimensional checks when the swagelock fittings remained sealed in the suppliers sealed package. BEOo completed a thorough review in response to PR 95-0466 to determine the problem scope in this crea of receipt and inspection and implemented adequate corrective actions. The review of other BECo receipt inspector's work and identified no similarly significant problems; however, some errors were made by a contractor who no longer works at PNPS. The corrective actions in PR 95.0446 were largely directed to determine the extent of the problem which turned out to be an individual performance issue. BECo took disciplinary actions with the receipt inspector who was involved with both the cracked batteries and the swagelock fittings. During the review, various parts were placed in a hold status pending verification of proper receipt and inspection.
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9 l l The inspector made other observations including the corrective actions taken to address j the cracked SRM/lRM control switches discussed in PR 96.9154. BECo was unable to determine at what point the switches became damaged. The inspector considered it positive that electricians in the field identified the cracks and initiated a problem report. l BECo initiated discussions with the switch vendor who later determined that the switch l connecting screw was overtorqued probably causing the bakelite material to crack. BECo l and the vendor were unable to determine at what point the switch became damaged since l the switches passed BECo receipt and inspection. Although the cause was indeterminate 1 or unknown, the inspector identified that overall no lessons learned were developed from l the most probable cause(s) and that the l&C and quality assurance department inputs to ) the PR resolution were defensive in nature. The problem assessment committee (PAC) did ! not specify any further actions which the inspector considered to be a weakness. One l lesson learned was to brief I&C and electricians on the possible consequence of overtorquing fasteners on electrical devices. The BECo QA assessment team leader acknowledged the inspector's concern. The other problem reports reviewed adequately evaluated and initiated corrective actions as required. The inspector reviewed the BECo policy for on-the-job receipt inspector training which has been in effect since at least 1989 and identified no significant problems. l The inspector also reviewed quality assurance (QA) deficiency report (DR) 1955, dated l March 25,1992, which related to a concern of a noncertified individual who performed a receipt inspection on an SBM control switch as part of on-the-job training. The DR response documented that no physical discrepancies were found with the aforementioned SBM switch or a sample of other of his work. The inspector had no questions or concerns, c. Conclusions Based on a selected review of problem reports of issues relating to receipt and inspection activities, no past programmatic breakdown of receipt and inspection activities was evident. Performance issues similar to those in other plant departments were generally self identified with the initiation of problem reports. A thorough BECo review was performed of an individual OC inspector who was directly involved with the improper acceptance of cracked safety related batteries and improper performance of inspection attributes of two swagelock fittings. No evidence existed that improper parts were installed in safety related applications that would result in inoperabilities. Ill. ENGINEERING E4 Engineering Staff Knowledge and Performance E4.1 Half Geram Due to Tricoed "A" RPS Motor-Generator Set a. Insocction Egooe (37551,62707) On June 10, the "A" reactor protection system (RPS) motor-generator (MG) set tripped, causing a half scram. No control rods were inserted as a result of the half scram, as the other channel of RPS remained energized. The inspector reviewed the corrective
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* . l ; i 10 i maintenance performed and discussed these actions with e-lab technicians and the system l engineer to determine the adequacy of BECo's response and engineering involvement in the ; troubleshooting activity. j 1 b. Observations and Find:nas , The "A" and "B" trains of RPS are supplied by the "A" RPS MG set through electrical ) protection assemblies (EPAs) 1 and 2 and the "B" RPS MG set through EPAs 3 and 4, I respectively. In addition, a third backup supply through EPAs 5 and 6 is available to power i either RPS bus. The EPAs provide redundant, Class 1E overvoltage, undervoltage and ] underfrequency protection. Following the half scram, operetors appropriately placed the i "A" RPS bus on the backup supply and reset the half scram. ) l The inspector discussed the maintenance request (MR) and work performed with one of l the E-lab technicians and the system engineer and reviewed the completed MR 1970174e and troubleshooting procedure. The technicians methodically performed the troubleshooting activity in accordance with the approved procedure and MR. Initially the j problem was thought to be an EPA card problem, as discussed in GE service information letter (SIL) 496, Revision 1, Supplement 1, which addressed EPA logic card changes to correct a condition on the undervoltage and underfrequency circuits. However, the initial troubleshooting determined that the problem was related to an overvoltage condition. I As part of the troubleshooting activity, the E-lab technicians replaced both the spike- - I suppressor and voltage regulator for the "A" RPS MG set. After the new spike suppressor j ' and voltage regulator were installed, the new voltage regulator was damaged when the system was energized. The old voltage regulator was re-installed and the same problem occurred. The tech..cians visually verified the connections on the old spike suppressor j were the same as the new suppressor. Since only one spare voltage regulator was left in the warehouse, the NWE directed that the system engineer be contacted to help determine the cause of the problem. The system engineer responded to the site during the early morning hours on a weekend to assist the troubleshooting activity. Per the engineer's suggestion, the technicians performed a point-by-point verification of the new spike suppressor and discovered that it was incorrectly designed. After the modified spike suppressor and another new voltage regulator were installed, the MG set was restored with no further problems. The inspector questioned the reason for the original overvoltage condition since this troubleshooting, although restoring the system to an operable condition, did not find a root i ' cause. The system engineer acknowledged that the root cause was outstanding and confirmed that one is planned. The root cause determination will require a physical inspection of the old spike suppressor by either BECo or vendor personnel. In addition, the inspector inquired as to the Part 21 aspects of the miswired spike suppressor. Again, the system engineer was aware this aspect needed to be addressed and indicated that the vendor would be contacted. In addition to planning a root cause on the spike suppressor, the system engineer developed a temporary procedure to install instrumentation to monitor voltage and frequency on the MG set output breaker which would provide this information fotbwing a subsequent MG set isolation. This TP was in supervisory review at the conclusion of the report period.
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11 l l c. Conclusions Operations, engineering, and maintenance personnel interfaced well to restore the "A" ) reactor protection system bus and troubleshoot the motor-generator set following an RPS ) trip and half scram. The system engineer was knowledgeable of industry problems in this ! area and provided valuable direction during the troubleshooting activity which discovered a miswired component provided by the vendor. Appropriate corrective actions were planned including a root cause analysis for the MG set breaker trip, a temporary procedure to gather additional data should another trip occur, and a Part 21 determination and discussion with the vendor. I IV. PLANT SUPPORT R1 Radiological Protection and Chemistry (RP&C) Controls l R 1.1 Liouid-To-Solid Radwaste Processina a. Insoection Scope (86750) Through review of liquid radwaste processing documents, radwaste system walkdowns, and interviews with licensee staff, the incpector reviewed Pilgrim Station liquid radwaste processing and resulting solids generation with respect to requirements, b. Observations and Findinas The licensee monitors and trends liquid radwaste inleakage from the plant to help identify leakage sources. Currently, approximately one-half of liquids collected are from the turbine building equipment sump. Total radwaste inleakage averaged approximately 32 gallons per minute, with approximately 17 million gallons of water processed per year. Solid radwaste generated during 1996 was 3400 cubic feet, down from 5200 cubic feet in 1995. During this inspection, the licensee was modifying a cubicle in the radwaste building to install a Thermex ultra filtration unit designed to replace the radwaste diatomaceous earth flat bed filter units. The Thermex system is targeted for startup in early July 1997. This reverse osmosis system is expected to reduce the amount of solid radwaste from 1000 cubic feet of spent diatomaceous earth media to 200 cubic feet per year. UFSAR, process control program, and operating procedure changes remain to be completed. Currently, Pilgrim Station generates approximately 12-14 liners of solid radwaste per year. With the new Thermex system in operation, the licensee projects generation of 6-8 liners of solid radwaste per year. c. Conclusionq The licensee continues to provide good trending of plant leakage and making improvements in the re. duction of solid radwaste from the plant.
W4wmdae-a-+a aiGA Je ashe-4.w-wmer- ai-n -: ,.--,. ----w-- a .. . ; 12 R1.2 ' (OPEN) Violation 97-03-02: Radioloaical Controlled Area Boundarv Door a.- Insoection Scope (71750) - During tours of plant areas inside of the radiological controlled area (RCA), the inspector -verified proper radiological postings and boundaries. b.- Observations and Findinas On June 2,.1997, the inspector identified that the boiler room door, which forms part of , the RCA boundary,'was tied open with no barricade posted, warning sign or watch ; stationed. The inspector notified the radiological protection (RP) technician stationed at the ' redline area who was unaware of the door being tied open. The door wes immediately untied and closed. Technical specification (TS) 6.11 specifies that radiation protection procedures shall be adhered to for all operations involving personnel radiation exposure. , PNPS procedure no.1.3.114, Conduct of Radiological Operations, section 5.1, General - Requirements, specifies not to move or remove any radiological postings or boundailes unless directed by RP personnel to do so. The inspector determined that the action of - . . tieing open the boiler room door without permission by RP personnel was a violation (50- , ' 293/97-03-02) of section 5.1.1. of procedure 1.3.114. ' The RP technician initiated PR 97.2021 to initiate a review and develop corrective actions as needed. The RP technician determined that a waste control technician (WCT) in the station services department had tied the door open to allow the floor to dry after cleaning. The inspector expressed concern to the station services department manager that the WCT training for activities with the potential to affect plant equipment or controls was weak. During RF011 (April 1997) the inspector recalls that a salt service water pump became i inoperable when the electrical breaker was inadvertently bumped open during a cleaning- activity. Additionally, a plant transient (i.e.,100 to 70% rapid downpower) occurred on July 19,1995 when the lube oil sightglass on the "B" seawater pump motor became inverted during a cleaning and painting activity. The oil drained from the sightglass which wiped the motor bearing. Thece examples clearly demonstrate the potential for adverse plant impact during routine and nonroutine station services activities. The station services
t department manager acknowledged the inspector's concern.
The inspector was informed later in this inspection period of the BECo intent to improve .WCT training. Station services personnel interfaced with the training department personnel to formalize a specific WCT training plan. Training improvements were divided into short,
l' - intermediate and long term initiatives. The training was intended to include " plant impact"
_ training to highlight the various ways that plant equipment could adversely be impacted during station services activities thus causing a plant transient or scram. The inspector
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noted that executive level BECo management involvement was necessary to ensure the proper resources and oversight to provide more effective training in this area.
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13 c. Conclusions A violation (97.-03-02) was identified when a station services worker tied a radiologically controlled area (RCA) door open without informing radiation protection personnel or stationing a barricade to prevent inadvertent personnel ingress or egrass. This problem and a few previous ones, which directly impacted plant equipment, indicated weakness in the waste control technician training program. R2 Status of RP&C facilities and Equipment i I ' R2.1 Onsite Radwaste Storaae a. Inspection Scooe (86750) The' inspector reviewed the condition and radwaste storage inventory of the trash l compaction facility (TCF) and the low level radwaste storage facility (LLRWSF). i 'b. Observations and Findinas The inspector noted an accumulation of outage material staged for survey located inside- , the TCF as well as in'eight sea vans and six B 25 boxes located outside of the TCF. The LLRWSF was observed to contain 31 on-site storage containers (OSSCs) containing spent resin liners and filters. The inspector noted regular surveys outside the shielded walls of the facility indicated less than 0.2 Mr/hr. The inspector questioned the licensee about the significant amount of radioactive material i and packaged radioactive waste stored in the TCP and LLRWSF. The licensee indicated that there is currently a backlog in surveying radioactive material since the spring 1997 .efueling outage recently ended. The backlog of spent resin liners was a result of planning ~ ! to use an emerging volume reduction technology to process spent resins, j c. Conclusions The inspector noted that all of the sea vans and B-25 boxes were locked and controlled by RP technicians and that the radiation levels associated with the LLRWSF were below regulatory requirements. R2.2 Laiduo Radwaste Eauioment ! The inspector reviewed the status of formerly utilized radwaste processing equipment for safe long-term lay up. The waste feed tank and the floc recycle tanks were previously identified by the NRC as possibly containing waste material. During this inspection, the inspector checked progress with dispositioning contents of these two tanks. A maintenance request has scheduled opening and inspecting the waste feed tank on July 7, 1997. The floc recycle tank was still under engineering review. Licensee disposition of the waste feed tank and floc recycle tank is an inspection followup item (50-293/97-03- 03). 1 -
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i- R3 RP&C Procedures and Documentation- I l R3.1 Radwuste/Transoortation Procedures
- ' "e. Inspection Scoce (Tl 2515/133) ;
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Due to a major revision of Title 49 C#R 171-178 effective April 1,1996, a comprehensive - procadure review was conducted at the Pilgrim nuclear power p' ant. ! 'The foliowing procedures were reviewed:
1 1.15.3,' Rev. 3, " Process Control Program"
1.16 4, Rev.1, " Radioactive Material Processing, Packaging, and Shipping Quality Control Program"- ' 1.16.1, Rev. 3, " Spent Fuel Pool Inventory Control" 1.18.1, Dev. O, " Facilities Division Performance Assessment Program"
- 2.5.1.10,Mev. 6, " Transferring of Spent Bead Resin and Dewatering HlC Liners
LUsing Vectie (Pacific Nuclear) Dewatering Systems"
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; 2.5.1.11, Rev. 3, " Transferring of Sludge and Dewatering HIC Liners Using Vectra l (Pacific Nucleer) Dewatering Systems" l
4 2.5.1.14, Rev.1, Transferring and Dewatering Beadex Liners Using Vectra (Pacific l
' Nuclear) Dewatecing System"
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2.5.1.15, Rev. 2, " Filling, Dewatering, Closure, and Preparing for Disposal of Non- Compactible Material Using Vectra Foam Filter EL-142 High Integrity Container" 2.5.1.6, Rev. 3, " Dewatering the Spent Resin Tank From the Radwaste Trucklock" 2.5.2.17, Rev. 2, " Processing Liquid Radioactive Discharges"
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6.9-160, Rev. 32, " Rad;oactive Material Shipment Administrative Package Process"
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6.9-174, Rev.11,'Packeging Radioactive Material for Shipment" 6.9194, Rev. 9, " Loading Transport Vehicle for Radioactive Shipments"
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6.9-211, Rev. 9, " 10 CFR 61 Sampling" 6.9 213, Rev. 4, " Handling and Loading Procedure for Type B Shipping Casks" 6.9-218, Rev. 8, " Operation and Control of the TCF and the Hazardous Materials l Storage Area" 6.9-303, Rev. 2, " Operation of the Interim Low Level Radwaste Storage Facility"
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b. Observations and Findinas i l Procedure 6.9' 160 did not provide detailed instruction, but instead referenced DOT regulations. - Some of these references were incorrect. Other procedure errors were minor and were discussed with the licensee during a. detailed inspection debrief. c. Conclusions _ , Although' adequate, radwaste transportation procedures did not provide details in that they - had frequent reference to regulations and relied heavily on skills-of-the-trade. Some - references were incorrect, but did not result in any sliipment errors.
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, _. . _ _ _ _ . , ' * . .- ; .1 -- 15 R4 . Staff Knowledge and Performance in RP&C : R4.1 Radwaste Samol, ipa and Characterization , a. Insoection Scooe' Same as Section R1.1. Y ; " b. -Qbservations and Findinas 'The inspector verified that the transport characterization tables (A1/A2 values) had been , updated to reflect current regulations ~ . Five solid radioactive waste streams were sampled and characterized by an outside radiochemical laboratory.in September 1996. ' > ' . c. Conclusions ~ i . The waste stream characterizations were timely and appropriately utilized by the licensee to report radionuclide': activities of each radioactive material / waste shipment during the . 1996 - May 1997 timeframe. R4.2 ~ Radioactive Material Shionino Documentation Review a. insoection Scope Same as Section R3.1. b. Observations. Findinas and Conclusions .The inspector's review of selected radioactive material shipments made during 1997 indicated that the shipments met all regulatory requirements. As mentioned in Section R7 of this report, the second reviewer of each shipment reinitiated the shipping record contents page, which did not indicate what was reviewed. This area should be enhanced.
R4.3 Eost Accident Samolina System Ooeration
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a. insoeetion Scope (71750)
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The reliability.of the post accident sampling system (PASS) equipment was verified when - chemistry technicians drew a gaseous sample, b. Observations and Findinas
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The teci clans used very good procedural adherence while drawing the gaseous PASS - sample. t he PASS ' system equipment functioned 'as designed. Difficulty was experienced
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Lwith calibrating the laboratory gaseous analyzer equipment. The chemistry procedure ' provided general guidance for the calibration requiring the technicians to consult with a . '
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: l I j : 16 . l ' more experienced technical for advice. The chemistry personnel initiated a procedure change to provide more specificity for the analyzer calibration process. One small , ' chemistry work-around condition was observed when the technicians used a piece of duct tape to hold the gas vial positioner in place to engage a microswitch. The technicians initiated PR 97,1957 to evaluate the problem and obtain corrective actions to eliminate the l l work around condition. Overall, the PASS equipment worked as designed and the chemistry technicians used very good procedural adherence when collecting and analyzing a gaseous sample, c. Conclusions Chemistry technicians drew a gaseous sample demonstrating the reliability of the PASS system equipment. Very good procedural adherence was evident and one minor equipment work around condition was identified involving the gas vial holder. R5 Staff Training and Qualification in RP&C RS.1 Radweste Transoortation Trainina for Shicoers and RP Technicians I a. Insoection Scoce Same as Section R3.1 b. Observations and Findinas The two authorized shippers attended a regulations training courso in the fall of 1995 which fulfilled regulatory requirements. The RP technicians were provided a one-hour overview briefing on NRC Bulletin 79-19 on a biennial basis, however, inspector review of the training materialindicated that although NRC Bulletin 79-19 requirements were described, there was little training material that described the transport requirements pertaining to their RP duties. The licensee stated that training module T-TT-02-01-01 would be evaluated and necessary improvements made. c. Conclusions The licensee met the training requirements for radioactive material shippers and RP technicians. R7 Quality Assurance in RP&C Activities a. Inspection Scope Same as Section R1.1. b. Observations and Findinas The QA Plan has been revised and has reduced the periodic audit function of the radwaste/ transportation program to an annual collection and summary of QA surveillances
. - . - . _. . - - -. : : 17 for the program area. During 1996 there were a total of 60 radioactive material shipments , made of which, only two were reviewed by the QA group. During 1997 through this inspection period, there have been a total of 81 radioactive material shipments, with oaly two QA surveillances provided. QA audits of radwaste processing vendors were spotty, with some audits having been performed in the last 3 years and some not. BECo commitments to NRC Bulletin 79-19 were intended to establish and implement a management controlled audit function of all l transfers, packaging and transport activities. The licensee currently utilizes a self assessment or cross check to ensure each radioactive material shipment is correct. The inspector noted that both authorized shippers cross check each other, operate out of the same office, and report to the same supervisor and are not independent of the shipping operation. The inspector also noted that the cross checking consists of redundant initiating of the shipment iecord contents page. No formal l I checklist or other documentation of an independent review is made. c. Conclusions ' The licensee's audit program for the radwaste/ transportation program was found to be very weak. The licensee stated that the audit program for this program area would be l ' reevaluated. Reviews of radioactive material shipments are not independent of the radwaste shipping program and are not formally accomplished. The licensee indicated the intention of formalizing this review and utilizing other Services Division staff that are independent of the shipping office to provide the reviews. Oversight of the radwaste/ transportation program was not very effective. R8 Miscellaneous RP&C issues R8.1 Uodated Final Safety Analysis Reoort (UFSAR)
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a. Insoection Scoce
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The inspector reviewed current Pilgrim Station practices with respect to Sections 9.2 and 9.3 of the UFSAR. b. Observations and Findinas The inspector's review of the indicated sections of the UFSAR reflected current plant configuration and radwaste processing practices. One P&lD plant drawing (M235, UFSAR figure 9.31) did not indicate that the floc recycle tank had been abandoned in place and the licensee indicated that this correction would be made. Other sections of the UFSAR properly described the abandoned equipment.
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18 c, Conclusions Other than one drawing update that was needed, the UFSAR description of solid radwaste processing was accurate and correctly reflected current plant operations. P2 Status of EP Facilities, Equipment, and Resources a. insoection Scope (82701) Determine whether key facilities and equipment are adequately maintained and determine i whether changes made since the last inspection are technically adequate, meet NRC l requirements, licensee commitments, and are appropriately incorporated into the emergency plan and implementing procedures. b. Observations and Findinas I The inspector toured the technical support center (TSC), operational support center (OSC), and the emergency operations facility (EOF). The inspector found the emergency facilities and equipment to be adequately maintained. Survey equipment and dosimetry were within j .the calibration requirements. Additionally the inspector reviewed the TSC and EOF i ventilation test and found them to meet NRC requirements, c. Conclusion The facilities were found to be adequately maintained in a state of operational readiness. P3 EP Procedures and Documentation a. Inspection Scope (82701) Determine if significant or major changes have been made to the emergency preparedness program, assess whether these changes have adversely affected the licensee's overall state of emergency preparedness and have been appropriately incorporated into the licensee's emergency plan and implemMting procedures. Verify that major or significant changes to the emergency plan and implementing procedures have been reviewed, approved, and distributed in accordance with approved licensee procedures and NRC requirements before implementation. . b. Observations and Findinas The inspector reviewed Revision 18, of the Pilgrim Nuclear Power Station emergency Plan, changes to the emergency plan implementing procedure (EP IP) and emergency plan administrative procedures (EP-AD). The inspector noted a minor procedural weakness with procedure EP-AD-110, Emergency Preparedness Department organizational requirements which did not include the interface requirements with the central emergency preparedness group (CEPG) for the position descriptions of the Regulatory Regulations Group Manager and the Emergency Preparedness Manager. BECo agreed to provide more specificity of the - - - _ _ _ _ _ _ - . _ _. - - . -
: : 19 interface in the aforementioned procedure. The inspector also reviewed the 10CFR50.54(q) reviews for changes to the corporate radiological emergency plan and for the recent changes to the emergency plan and emergency plan implementing procedures. Additionally, the inspector noted that the licensee had reviewed, approved, and Jistributed in accordance with approved licensee procedures and NRC requirements before implementation. c. Conclusion l l The revisions to the emergency plan and emergency plan implementing procedures meet- the requirements of 10CFR50.54(q), and will continue to be reviewed during further l ' inspections. P4 Staff Knowledge and Performance in EP l a. Inspection Scoce (82701) Evaluate the effectiveness of the licensee's controls in identifying, resolving and preventing problems by reviewing such areas as corrective action systems, root cause analyses, safety committees, and self assessment in the area of emergency preparedness. Determine whether there are strengths or weaknesses in the licensee's controls for the identification and resolution of the reviewed issues that could enhance or degrade plant operations or safety. b. Observations and findinas The inspector reviewed the self-assessments for the last quarter 1996 and first quarter 1997. In the review of the last quarter 1996 self-assessment the inspector noted that the licensee had identified that there was a problem getting personnel to perform as controllers for drills. The licensee was taking corrective measure to ensure that upper management was kept informed of the problem, and that if the person could not participate in tSe drill as a controller, a qualified replacement would be provided, in the review of the first quarter 1997 self-assessment the inspector notec it at the licensee had identified that after the change of the Regulatory Relations Group Manager and changes of the Emergency Preparedness Group in 1996, the Regulatory Relations Group Manager, Emergency Preparedness Manager and other upper management personnel had visited the Civil Defense Directors and other risk community officials to ensure that commitments were being met, and that this had not been done since early 1996 and should be done on a more r.tgular basis. Additionally, the Emergency Preparedness Manager demonstrated the integrated action data base (IADB) and the emergency preparedness activity scheduling system (EPASS) tracking systems for the inspector. The IADB system is the station wide tracking system and is used to track the more significant programmatic issues. The EPASS system is used
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l 20 to track emergency preparedness drill / exercise and other EP issues. Both systems were easily accessible and provided the necessary data (e.g., date entered, description, a responsible person, due date, corrective measure taken for closure, etc.). The licensee also has the ability to inter link the training data base to the emergency response organization data base to ensure that all emergency response personnel on the duty roster are qualified. c. Conclusion Overall, the licensee effectively controls its emergency preparedness program and resolves , ' issues. P5 Staff Training and Qualification in EP i a. Insoection Scope (82701) Interview a small sample of individuals assigned key roles for emergency response to l determine whether they have been trained as required and understand their emergency I assignments, responsibilities, authorities, and changes to the implementing procedures. I l If changes have been made to the licensee's emergency preparedness program since the ' last inspection, determine whether responsible personnel are aware of the changes, understand them, and have been adequately trained to implement them, b. Observations and findinas The inspector interviewed and performed walkthroughs using scenarios with two emergency directors and two nuclear watch engineers to determine the effectiveness of emergency preparedness training. The scenarios were designed to require identifying and classifying at least two emergency classification levels one which was the General Emergency, therefore, requiring a protective action recommendation to be made, and the notification forms to be properly filled out. The emergency directors and nuclear watch engineers performed very well making the appropriate emergency action level : classifications in a timely manor, completing the notification forms properly and in a timely I manor, and followed the new protective action recommendation process, which implemented the NUREG-0654, FEMA-REP-1, REVISION 1, SUPPLEMENT 3, Criteria for ! Preparation and Evaluation of Radiological Emergency Plans and Preparedness in Support of Nuclear Power Plants, and made conect and appropriate corrective actions for the plant conditions presented, in a timely manor as established in the emergency plan. Additionally, the inspector interviewed the emergency planning trainer, reviewed the emergency response organization training records, reviewed the emergency plan overview and the dose assessment and protective action recommendations lesson plans and examinations. During the review of the emergency response organization training records the inspector found approximately 30 out of 675 personnel would not meet their training requirements as of May 31,1997, and verified with the emergency preparedness manager that these personnel were not on the duty roster which was issued May 30,1997. The lesson plans reviewed were complete, informative and up-to-date.
-- - - . - . l , ' l : 21 '.. I c. Conclusion I 'Overall, the emergency preparedness training program is being effectively implemented. , P6 EP Organization and Administration a. Insoection Scope (82701) l . Determine if changes have been made to the emergency organization or management ! control systems, determine the effect of these changes on the licensee's emergency' . ; preparedness program and verify that these changes have been properly incorporated into , the emergency plan and implementing procedures. ! b. Observations and Findinas : Since the last inspection the emergency preparedness staff has had some major changes. The emergency preparedness manager reports to the regulator relations manager. .The emergency preparedness manager has the emergency preparedness readiness coordinator and the emergency preparedness planning coordinator reporting to him. 1 The emergency preparedness coordinator oversees onsite training, assists in offsite 1 training, coordinates drill and exercises, maintains the emergency response organization roster, and has 4 siren and communications engineers and 2 facility and equipment l' specialists reporting to him. Additionally, the coordinator interfaces with the Yankee Atomic Central Emergency Preparedness Group (CEPG) as necessary in performance of their duties and functions. I The emergency preparedness planning coordinator, coordinates offsite interfaces, oversees j the following: offsite training program requirements; onsite and offsite plans and procedures and administrative procedure maintenance; cooperate response plan, and the public information program. Additionally, the emergency preparedness planning coordinator interfaces with the Yankee Atomic CEPG in coordinating their performance of , ' offsite emergency preparedness activities. Further discussion of the Yankee Atomic CEPG activities will be discussed in Section P8. These changes in the emergency preparedness staff have been reflected in revisions 17, 17A and 18 of the emergency plan. The licensee has five emergency directors (EDs). All five of the Eds are in upper- management at the site. This demonstrates management's commitment to actively support the emergency response organization. The inspector reviewed other emergency - response organization positions and determined that all key positions were at least three deep and thus the licensee was meeting, and in most cases exceeding its goal of being at least two persons deep in the emergency response organization.
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. _ . _ .. ._ _ __ . . _ _ _ -. _. ' . 1 22 c. Conclut i2D - Overall, the inspector determined that the licensee has sufficient personnel in place to maintain the emergency preparedness program and to staff the emergency response organization. P7 Quality Assurance in EP Activities 'a. Insoection Scoce (82701)
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Examine independent and internal review and audit reports for the licensee's emergency preparedness programs since the last inspection to determine compliance with NRC requirements and licensee commitments. . b. Observations and Findinas . The inspector reviewed quality assurance group audit 96-08 EMERGENCY PREPAREDNESS PROGRAM, audit surveillances: 96-067,TSC and OSC Walk-through Training on Process Changes, 96-069 Emergency Preparedness Drill: Activation of TSC and OSC, and 96-071 . Emergency Preparedness Drill: Activation of Emergency Off site Facility (EOF). Audit report 96-08 identified one Problem Report 96.0428, Approval forms for scenario package 96-01 were missing, and one Recommendation Report 96.0095, Provide written policy on assignment of CEPG personnel in BECo ERO positions. There were no reoccurrences of items from previous audit reports, c. Conclusion
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The inspector found that the audits were comprehensive and thorough and identified areas requiring corrective measures. The audits satisfied 10CFR50.54(t) requirements. P8 Miscellaneous issues (82701) P8.1 Yankee Atomic Central Emeraency Preoaredness Group (CEPG) , a. Insoection Scope
f
To determine the effect of the licensee's reduction in the emergency preparedness staff
,
and the transfer of off-site emergency preparedness duties to the Yankee Atomic Central Emergency Preparedness Group (CEPG). b. Observations and Findinas The inspector reviewed pertinent licensee documentation and interviewed key members of the licensee's EP staff and CEPG personnel to determine the effect of the licensee's reduction in EP staff and utilization of the CEPG organization. The inspector also discussed . the licensee's support of offsite EP activities with the FEMA Region i Regional Assistance Committee Chairman (RAC) Chair person. _ _
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23 Boston Edison utilizes the services of the CEPG, which is a functional group of the Yankee Atomic Electric Company, to provide support to the licensee's emergency preparedness program. Boston Edison maintains overall responsibility for onsite and offsite EP programs with CEPG providing assistance as needed. All work performed by CEPG personnel is done under the direction of Boston Edison EP managers. The PNPS Emergency Plan (Rev.18) has been revised to reflect the assistance of the CEPG and the responsibilities of the EP managers for interfacing with the CEPG. The utilization of the CEPG is also indicated in EP administrative procedure EP-AD-110, " Emergency Preparedness Organization and Responsibilities," Rev. 3 (undated), however, it was noted that the responsibility for interfacing with the CEPG is not included in the position descriptions for the Regulatory Relations Group Manager and the EP Department Manager. The licensee entered into an agreement with Yankee Atomic for the services of the CEPG on June 1,1996, as reflected in purchase order LSP006591, Emergency Planning. The purchase order indicates that the services to be provided by CEPG include both onsite and offsite EP tasks. Prior to the formation of the CEPG, the EP staff consisted of 17 personnel including EP managers, emergency planners, siren and facility and equipment specialista, and clerical. The current Boston Edison EP staff consists of 10 personnel including 3 EP managers, 5 siren and facility and equipment specialists, and 2 clerical. The licensee EP staff is supported by 5 CEPG professional emergency planners of which 3 are Yankee Atomic employees and 2 are Yankee Atomic contractors. Four of the CEPG staff are currently working full time on Pilgrim offsite activities and one is working about 50% of his time on Pilgrim onsite assignments. The EP staff is also augmented by other Yankee Atomic contractors as needed for special activities such as the establishment of the new Braintree Reception Center. The CEPG staff report to the CEPG Manager for administrative purposes, however, Pilgrim EP tasks are performed at the direction of the licensee's EP managers. The CEPG Manager and the 5 CEPG support staff are physically co-located with the Boston Edison EP staff. The CEPG Manager estimates that approximately 50% of his time is devoted to supporting ! Boston Edison. The CEPG Manager and 4 of the 5 CEPG staff are former Boston Edison EP I employees or contractors who were involved in the licensee's offsite EP program. Thus i continuity has been maintained between the licensee EP department and the EPZ and I reception center town emergency management organizations. In addition, according to the EP Department Manager, the licensee's financial support for the offsite EP program has remained the same and has not been affected by the utilization of the CEPG organization. ; 1 The licensee has an effective assessment program for monitoring the performance of the i EP organization including the CEPG. As part of the assessment program, the EP Planning Coordinator reviews the EP program commitrr:ent list on a quarterly basis to assure that the onsite and offsito EP commitments are being met. The inspector reviewed the self assessment summary reports for the last quarter of 1996 and the first quarter of 1997 as well as the CEPG Manager's monthly status reports and a preliminary CEPG annual report. The self assessment report for 1997 identified the need for the RRG Manager and EP Department Manager to meet with local officials on a more frequent basis to strengthen the lines of communication.
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- - i 24 The inspector met with the FEMA Region i RAC chair at the FEMA regional offices on May 29i 1997, to verify the adequacy of the licensee's support to the offsite response - organizations supporting the Pilgrim emergency plan. The RAC chair had been briefed by Boston Edison on the CEPG concept and was familiar with it. The RAC chair expressed : satisfaction with the level and commitment of licensee support for offsite EP at Pilgrim. c. - Conclusion The inspector determined that the licensee is effectively utilizing the CEPG and continuing to meet its offsite EP commitments. P8.2 Braintree Reception Center . a. Insoection Sc. gag ! To review the licensee's actions for assisting the Commonwealth of Massachusetts in the . replacement of the South Weymouth reception center. b. ~ Observationa and Findinas . The inspector interviewed licensee and CEPG staff to determine the lice'isee's actions for assisting the Commonwealth of Massachusetts in replacing the South Weymouth reception center which was necessitated by the impending shutdown of the South Weymouth Naval Air Station. On May 27,1997, MEMA announced that the reception center in the Town of , Braintree at the Braintree High School had replaced the South Weymouth reception center. ) The licensee had been actively involved in the negotiations for the use of Braintree High School. . In addition, the licensee had assisted the Massachusetts Emergency Management - Agency (MEMA) in oreparing for the transition by revising the plan and procedures, j developing radio a.u newspaper announcements of the change, and in training the i reception center staff for the new facility. The inspector toured the new reception center and observed CEPG staff conducting tre'Wg of the various functional groups which staff the reception center. Discussions with N representatives during the tour confirmed that the licensee and the Commonwealth I hau .vorked closely together to establish the Braintree facility. Several factors contributed l to the selection of the Braintree reception center. It is located in the same general area as I the South Weymouth reception center and the majority of the staff are the same as the ; South Weymouth staff. In addition, Braintree High School is also a host school. ; l c. Conclusion i BECo actively assisted in a very timely manner the Commonwealth of Massachusetts in establishing the Braintree reception center as the replacement for the South Weymouth facility. l , , , , ,,,_y _
^
. '. 25 V. MANAGEMENT MEETINGS X1 Exit Meeting Summary i The inspectors presented the inspection results to members of licensee management at the I conclusion of the inspection on 7/15/97. The licensee acknowledged the findings presented. X3 Management Meeting Summary On June 5,1997, the NRC convened a management meeting with BECo managers at PNPS to discuss overall performance trends. Enclosure 3 contains the briefing notes presented to the NRC during the meeting. X4 Review of UFSAR Commitments A recent discovery of a licensee operating their facility in a manner contrary to the UFSAR description highlighted the need for aoditional verification that licensees were complying with Updated Final Safety Analysis Report (UFSAR) commitments. For an indeterminate - time period, all reactor inspections will provide additional attention to UFSAR commitments and their incorporation into plant practices and procedures. While performing inspections discussed in this report, inspectors reviewed the applicable portions of the UFSAR. No ; inconsistencies were noted. 1 s -
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26 7 INSPECTION PROCEDURES USED Ti 2515/133: Implementation of Revised 49CFR Parts 100-179 and 10 CFR Part 71 IP 37551: Onsite Engineering IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems IP 61726: Surveillance Observation l
, IP 62707: Maintenance Observation
IP 71707: Plant Operations IP 71750: Plant Support Activities IP 82301: Evaluation of Exercises for Power Reactors IP 82701: Operational Status of the Emergency Preparedness Program .lP 86750: Solid Radioactive Waste Management and Transportation of Radioactive Materials IP 92700: Onsite Followup of Written Reports of Non-routine Events at Power Reactor Facilities IP 92901: Followup - Operations IP 92902: Followup - Maintenance IP 92903: Followup - Engineering IP 92904: Followup - Plant Support i IP 93702: Prompt Onsite Response to Events at Operating Power Reactors ] ITEMS OPENED, CLOSED, AND UPDATED OPENED IFl 97-03-01 SSW pressure switch root valves not included in 8.C.13. VIO 97-03-02 RCA door found tied open. IFl 97-03-03 Disposition of Waste Feed Tank and Floc Recycle Tank as abandoned equipment. CLOSED IFl 95-13-01 Longstanding scaffolding left erected in RHR quadrant rooms UPDATED None ! -__._-_________O
; *, * . 27 LIST OF ACRONYMS USED ALARA As Low As is Reasonably Achievable , APRMs . Average Power Range Monitors BECo, ' Boston Edison Company _ l CEPG Central Emergency Preparedness Group ; CFR Code of Federal Regulations i CRD Control Rod Drive DOT U.S. Department of Transportation EAL Emergency Action Level- EOF Emergency Operations Facility EP Emergency Preparedness EPIC ~ Emergency.and Plant Information Computer , ERO Emergency Response Organization ESF Engineered Safety Feature FEMA Federal Emergency Management Agency gpm gallons per minute _ )' I&C Instrumentation and Controls IFl Inspection Follow-Up Item : IR Inspection Report LER- Licensee Event Report - LLRWSF Low level radioactive waste storage facility MEMA Massachusetts Emergency Management Agency MG Motor Generator MR Maintenance Request NCV Non Cited Violation NOV Notice of. Violation NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation . NUREG 0654 Criteria for Preparation and Evaluation of Radiological Emergency Response 1
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Plans and Preparedness in Support of Nuclear Power Plants, NUREG 0654 l FEMA-REP-1, Revision 1, EALs NWE Nuclear Watch Engineer OSC Operational Support Center
. PAR Protective Action Recommendation
PNPS. Pilgrim Nuclear Power Station- PR Problem Report QA -. Quality Assurance , RAC , Regional Assistance Committee
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'RHR- Residual Heat Removal RP Radiological Protection i RRG; _ Regulatory Relations Group l SRO Senior Reactor Operator TCF : Trash compaction facility J TM Temporary Modification ,TS Technical Specification '
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iTSC. Technical Support Center L. UFSAR _ Updated Final Safety Analysis Report
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- . . - . --_ - _ . _ . - - - - . _-. i 4 l I ; ., I * . 28 ENCLOSURE #3 ; ; I BECo PRESENTATION MATERIAL i FROM JUNE 5,1997 ONSITE MEETING 1 1 ) i
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. . .- .. . - - - - _ _ _ _ _ , . ~ ENCLOSURE 3 . l - l ! : Boston Edison : NRC PRESENTATION June 5,1997
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xanwammemseeemnewmemmensraumranswemammencesa PRESENTATION AGENDA
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elNTRODUCTION E.T. BOULETTE e OPERATIONS T.E. TREPANIER eMAINTENANCE W.J. DICROCE e PROCEDURE ADHERENCE T.A. SULLIVAN
- e PLANT SUPPORT C.S. GODDARD
e ENGINEERING J.P. GER ETY 1-2 . _
_
acnanuw ma-a -asau.- - nm w - anw n anwawac.u-, F x V INTRODUCTION < eWelcoming Remarks l l e NEA Update j i 1 manammmmaammarauwramaxmanammammannwu & M l ) , l l OPERATIONS Tom Trepanier Operations Manager ; i ! 3-4 ! ; -
. . - - - . . .. . _ .- . - - . : anamarmuun u - emmanm o Plant is at 100% power with no significant l
'
equipment challenges l
- eSuccessful Refueling Outage l
- Process changes successful- work release, I tagging, work control center, control room ! environment ,
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- Effective planning - shutdown safety plan Handled challenges well + Main Transformer failure l . Severe storm
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s License exam completed May 1997 l eSRO license class to begin July 1997 ===unwmame== mamma =====mweermamwwsamme AREAS OF CURRENT AND FUTURE h l l FOCUS e Procedural Adherence - Continue to lower threshold on procedure workarounds and procedure adherence (radwaste and off-normal procedures) e Reactivity Management -High energy cores ) e Self-Checking skills. 1 program has been highly successful in equipment operations - expanded to normal tours / turnover e Complacency - Use of independent peer assessments as a tool : - First completed - December 1996 l Second scheduled prior to end of 1997 l S-6 -.
-- - - . . . . _ . _ __ . - - - . _ .- ____._ - __. : , : wumm entu mswwsnomuwwmmanwomwwswmmm tuna ' OPERATING WORKAROUNDS e Operating not Operatgr Workarounds
- e Recognized need to formalize proce=- .
. .
- Issued station procedure -
' Training scheduled : eTransient/Non Transient Categorization ' e Cooperation between Operations, Maintenance, l Engineering and other support groups ongoing and , improving
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1 l - - - . - - , , - - - - . - - - _ _ $ OPERATING WORKAROUNDS (Cont.)
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e Corrected most transient workarounds MO-220-3
- MO-S1 ,_
. RWCU Letdown e Outstanding transient workarounds Feedwater Regulating Valves - CRD system, "all rods in", and select matrix
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e Continue to strongly focus on eliminating challenges to operators and other personnel
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7-8 ._ ~ . .- - -. . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _- - -
. _. _._ __ . : , ' : , uwesenewsmumannwamutammmmaxwxmtsanew-=.aamanumzew assan
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CORRECTIVE ACTION PLAN '
e
o Contracted FPI - blueprint ; 'e Proceduralized process changes ;
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s" Error Free" policy ! eTrained all personnel on new process l l
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- CORRECTIVE ACTION PLAN (Cont.;l
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Status /Results
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- e Significant increase in number of Problem Reports
(28661st qtr.1997 vs.1366 total in 1996) e Significant decrease in threshold
. - More "near misses"
- SCAQ/non-SCAQ ratio has significantly decreased
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e Decrease in " events" concurrent with increase in Problem Reports
J l - 9-10
- _ __ __ _ - - . _ _ _-. _. _ _
: : wawamnwmmasaraummarmsunamataannuuvameraanammmsnmsna CORRECTIVE ACTION PLAN (Cont.) e Encouragement for High Self Improvement Performance Ratio (SIPR) eStill maturing
- - Confidence in our process
Common Cause Analysis (CCA) makes sense Continue to improve our self-assessment and self-improvement e Areas of focus:
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- Additional administrative burden ! Reduce backlog - real time turnaround
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1 EMMC5tBEEEEUIMM2 MEW 5EiWA2!PKEtrA&E1@@90 MOD 3E18Mmmesil5E18st32!sausu l SIGNIFICANT HUMAN PERFORMANC l PROBLEM REPORTS - NOVEMBER 1994 ; ' TO THE PRESENT
... . _ _ _ _ . . _ _ . . . _ _ . . _ . . - . . . _ . ~ . . _ . _ _ . . . . _ _ _ _ . _ _ _ _ _ . . . . u. j " ' .... .... - - - l ' . . '.,, - - .- ......... . . .. .. = ,l ; 111111111111111!!!!11111111111 11-12
.. - . _. . _ _ _ . : l : 1 uw-mawanasemmeauamwamr.arwAmeewwser-muas STATION SELF IMPROVEMENT l PERFORMANCE RATIO ! (SIPR) l . _ , I .. w - - .. : , . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . ; , ~ ~ ~ = _. __a - _.L __ __ _. __ _ _ . _ . _ _ __ _. . - .. * . . 1 i- - - _ . _ . _ - l ' "b'"".O"=l"2:Tlll"".l'm* ll0"1."l*;'.7 OL" u e==== sm=======we==========amuemmamar,m SUMMARY h !
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o Summary - process changes to unburden operating crews, focus on procedural adherence, self-checking, self-assessment, and self-improvements have lead to strong aerformance. Ourjob is to continue these mprovements. l l l 13-14 ,
- -- _ _ . . . .. .-. : xmmanaasmumr,nwwewanreauwmuummmmmmwarmeamm=cemun ; j i MAINTENANCE ! ! l Bill DiCroce Maintenance & Projects Manager
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sacemwamummmwaeastusasselwmarasanattamsaenmutansen
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MAINTENANCE IMPROVEMENTS e Background - Mid 1994, several occurrences focused attention to weaknesses in the Maintenance functional area e Maintenance improvement Plan developed and implemented e Results have been positive
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m,
y
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. -- - _.. _ _ . . _ . _ _ _ _ . _ . . _ _______ _ _ _ :. : avvmwmmmmuwmuwanvamusumunexowsmamamumsms ' HUMAN ERROR REDUCTION . .o Quality is the top priority. - Rework rate of 0.5 - 1.5%. Human performance error reduction of 32% kom 1995 to 1996 '
[ eWorkers routinely briefed by management -
that there is always enough time to do the job right, the first time ; l
oIncreased time dedicated to continuing 1 training eHuman performance matrix of Maintenance
i staff to identify individual trends !
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aumrmmemsnmawaawneumanaammmzawmuemmnmma IMPROVED WORK CONTROL PROCESS &
,
MAINTENANCE PRODUCTIVITY
i e More efficient work management and higher ,
productivity has resulted in a substantial backlog l
reduction [60% reduction between June 1995 to
- January 1997]
e Reduced maintenance request backlog resulted in:
- - Improved safety system reliability
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Reduced challenged to operators (316 day run following RFO-10)
- Reduced number of operating workarounds
17-18 .
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CORRECTIVE MAINTENANCE BACKLOG --o 1D00 A r i 8.*. "At * 'M dL m ,, m, , a, . min . A%/ y i g, rw !.O Dm , - 3 ya . ,,, ' s a = p - ?, f 4 A 20D ,,,,,,,.,,,,,,,,,,,,,. , .... . ..j4.g....... NOTI NO DAfAet41 DUE TO AFos11 . , . . .. . l 1 ! l , - ----, .--a-mana---ma.anann,-- p 1996 I \ SAFETY SYSTEM PERFORMANCE INDICATORS I . 1 i 19-20
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* ! _- .- 1996 SAFETY SYSTEM PERFORMANCE Residua; Heat Removal (RHR) Ibe Salety hystem perMmutnr.e 1% cat 0s is ceAned as the num of the unavadsbehty of the components in the %ybi'km d'# ring 3 ghen time [tefQd de/93*d by the 08)I%8f Of tr&nS in ft16 bystern. The convennt unavadsibil4 a the ratio of rne hours that the components were unaLie to perm their inte.ded forsten 's tw trmra the system Wat rSQtJ8 red f0 be avadabM ffJr sarcce Jf 8 3 Ti Af;;d8 a T ' .8 ' Unavailabihty Rato 0 04 YTD - YTD YTD Jan Unmv-Hrs Unmv-Rate Goa! 25.00 0 0168 0.030 3 003 - - fh Feb 25 00 0.030 E 0.0000 Mu 30.25 0.0060 0.030 o 02 - -- - " Apr 30.25 0 0052 0.030 - n .- ' May 30.25 0.0041 0.030 y a L Jun 30.25 0.0035 0.030 o 01 l _ ~ ' r y ~ ' ul J 30.25 0.0030 0.030 s Aug 30.25 0.0026 0.G30 o a 7 > n ' bCOG 1 > $ Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Sep 302.75 0.0230 0.030 Oct 302.75 0.0207 0.030 YTD Actual YTO Goal Nov 302.75 0.0188 0.030 C - Dec 302.75 0.0172 0.030 f w - . .- 1996 SAFETY SYSTEM PERFORMANCE High Pressure injection / Heat Removal Systems The saWy s(vern perfornunce incheator e do tnod r as the wim raf too unavailaanty of the compventa en the systern stating a gNeo hme genod Jeded by tre number of tram sn the system The component vrievaAacotty is the tatto of the hours that the coniponants were unable to putform then !rrtended furotion to N bours the sys'em was es.1vired te he evadab> for 5,e.twica 1%6 Vtum = 'JC 1'.f Unavailabinty Rate w% w YTD 0" YTD YTD Unav-Hrs Unav-Rate Goal g . Jan 10.3 0 013 0 015 Feb 23.5 0 019 0.015 f 002 ~ - Mar Apr 24 5 68.6 0 011 0 012 0 015 0 015 J,i 0015 - f ~ 'Maj 69 0 0 009 0.015 1 _., - ~ - -- 'Jun 81.3 0 009 0.015 f UU' , > Jul 86 8 0 009 0.015 ~ ~~- 0 005 - p ' ' -- Aug 87.8 0 00_7 0.015 r Jan Feb Mar Apr May 1 Aug Sep Oct Nov Dec Nov 89.1 YTD ActimI YTD Goal 0 006 J0.015 C Dec 89 1 0 005 !Oli5 af8 21-22
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. _ _ _ . _ _ . __ _ . . 1996 SAFETY SYSTEM PERFORMANCE EMERGENCY AC POWER Ttw sa50 tf setem performance mdeator s def'ned as tne num of the una rajabiitty of the components *n me sistem dunng a given t;me period d.wsoed by the nurrte 9f trains us the system. The component unavailabertv is ing rato of tr.e hours that trie ccmponents were unabe to perform their riended funct.oo to ti o hoursit.e system was requwod to be a'sailable for service W- A :.a s 00'4 . Unavailability Rato ' * " ^ " ' ' "* YTD YTD YTD 0 012 Unav Hrs Unav-Rate Goal Jan 0.00 0 0000 0.010 0 01 ~~ - Feb 0.00 0.0000 0.010 jn, . Mar 12.75 0.0060 0.010 g g Apr 12.75 0.0040 0.010 5 000s { j - - ' May 12.75 0.0035 0.010 - - .* - " Jun 12.75 0.0029 0.010 gom 7 - - _,_ Jul 12.75 0.0025 0.010 g . , - - r 7 - 'Aug 25.65 0.0044 0.010 , , ,, z^ 3 , . , q ' Sip 25.65 0.0039 0.010 0 = Q'1 ~ ' i 35.40 0.0048 0 010 Jan Feb Mar Apr May Jun Jul Aug Sep Od Nov Dec Oct Nov 35 40 0.0044 0.010 YTD Actual YTD Goal Dec 46 15 0 0050 0 010 C~l nrr t 1 1 :wwwsunununnunuantaumemanasmaxasumnueamuusasrsmusema l Y I l 1997 l SAFETY SYSTEM l PERFORMANCE INDICATORS i 23-24
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._. _ 1997 SAFETY SYSTEM PERFORMANCE Residual Heat Removal (RHR) 'ra 'a**ts ett a m ;>d y- ave *Westos i Ww4 at N u.m d the 9ede rwtWv Of '.'*a wgwr>ntits in tx s en dac9) 3 gen time ural twwJ e, the ev%r.J Per.s r, tN s,wr Tim carww ouvakreay a +8ee rathi j r., we tw tre t.crernemawa vare stanche o Murm ra.cr oferned fat:cr 1)!t e ren tae siste ri we ta $ireJ N ra avu%tw ica 1,c*we l ) Unavattability P. ate '.994 .3a i. 4-tua. . 2 -e04'4 r j OS YTD YTD YTD "" thav+t s unav-Rate Goal ,, _ Jan 38 90 0 0520 0 000 g j, Feb 295 00 0 4400 0 080 0.3 - 5 War 351 00 0 3170 0 080 .J # a I' l Apr 351 00 0 2377 0 000 ' 02 - M 0 080 l 1 ' ef ) Jun 0 000 '01 - ,k l Fl '- : ~ ~. _ . . . _ . . . 3 ' g 0. , a.a r us, u , ava a.i 4.e s., o. Nov o s,p ooso 4,, i od 0 080 no u , yro a.,, l w 00e0 ca ' Oec 0 080 i l r sgs t l . ._ 1997 SAFETY SYSTEM PERFORMANCE High Pressure injection / Heat Removal Systems Tne ust, syre.s ;ww.nu w nrhaw wet u tc, an of ibe .muaww, et % w,xmenu, in the % l'Hi1 dtJf>J A ) s*O IFP W.N#10, w .1rMi Oy the Muq+8 M 0 p R,e g e 1r.4 5, ftW . Ihe i # peut kqhd!db 4w $ T 4 '4i4 (# ItB hWN 1* At ther C. tr.$ Cf enf t /.#tYr td o%e hi paefsem the'"' m'dCM t.af tr M ?.e "'71*% !*4 b'pW Mn4 ikCJ'AC f:M Fits 1W.le IUt htfYn'M Unavailability Rate w em . e, s tw a .m. 3 una 00s YTD YTD YlD un v+ir. un ,ami. on.e Jan 23 0 0.031 0.015 ~ 1 Feb 23 0 0 011 0.015 Im0 T M ' a_r_23.0 0 011 OT[5 t T6 Apr 43 6 0 015 0 015 0 02 - - 4 May 0.015 Jun 0 015 ,,, . - r * # 0 015 ' * Aus 0 011 Sep 0015 0 # " "" # # M N * '* D Od . 0 015 Nov 0.015 yto Actuan YTD oces Dec I 0 015 O -we 25-26
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_ _ . _ 1997 SAFETY SYSTEM PERFORMANCE EMERGENCY AC POWER l Tne saht, s twm te s re smaux ,uen u as n suo i ms v.avern J w w 1.m s e tu %f41d dWf IP-f CUT [*J%M ufle DMat*strj e5 r.4 <s"ln 1J1N A gi@ te*# iow:wr,vaensis aW p ht u ik u Jed by the Mir'so,L f ven wev%r Ede'4vin vIT.e %fal4"Ecm :~ M.un % system erv19u M4 ft%fFd P314. Jv4F4M is serv';e Unavaltability Rate $$ $ $$ Y1D YTD YTD 0 012 Unev Hrs Unavaato Goal Jan 0 00 0.0000 0.010 0M ' ' " ~ '~~ ' Feb 0 00 0.000 03Id j0# ~ Mar 0 00 0.0006~dM g Apr 0 00 0.0000 0 010 ' o 00s - May 0.010 = Jun 0 010 ' O 008 - j - Jul 0.010 1 kug 0* ' 0.010 Sep 0.010 o -- Od 0.010 -'" F * " * * " "MN* **
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Nov 0.010 YTD W YTD M g 0 010 a ~ . , $
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1 OPERATING WORK AROUNDS i . - 3 .- 29 28 24 3 I3N 19 19 18 4 16 13 gg 12 3 - 0 0 5 5 $ . i i i i i i i 1/1 M M St M M M M M tort 11/1 12ft M M M M 7tt M M Hrt titt 12/1 OATI BY MONTH (199611997) l E RONN#sGREmIR O TRANSENT E OUTAM E OUTACFTRANSIENT l ve :c '4.iF Iv0tii& h $ dl1 )' @ M VI (I#I1 27-28
_ _ _ - _ _ _ _ _ _ . . -. .- . _ _ - -. - - . - . _ - . _ -- . - . - , y
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CONTROL ROOM DEFICIENCIES
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l GREATLY IMPROVED WORK FORCE .
MORALE AND INVOLVEMENT
.
! e Critical Maintenance activities now performed
in-house
- e Prolects that were historically out-sourced now
, performed in-house whenever practical to <
maintain in-house knowledge of new systems
. (e.g., RFO-11 Construction Power Modification,
Switchyard breaker replacements, Turbine Performance Monitoring System, Refueling Team)
t 1
29-30 . . _ _ _ - _ . __ . ___. . - - --
._ _, ; l , .: ' am a-amma-amemanaamcam aammmmumna p - GREATLY IMPROVED WORK FORC
j MORALE AND INVOLVEMENT (Cont.)
. 4 eZero grievances in the Maintenance area ; during 1996 indicating improved i management / labor relations * Multi-disciplined teams (e.g., WIN team, project i teams, RFO -11 clean-up team) improving
'
. interdiscipline, craft level communication and
- understanding 1
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l %3Cd/ MICE &%&TATM3OM$tt$4NU%l/WG$23kDMJEMS$5ffidt4EM%QQ11!MOK4%%#ML1
. INCREASED SUPERVISOR INVOLVEMENT &
OWNERSHIP OF WORK SCHEDULE '
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e Supervisors develop and approve schedule with l
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work control personnel resulting in realistic man-loading which avoids scheduling pressures
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eimproved schedule adherence has resulted in excellent preventative maintenance execution
i .
31-32 . _ _ . . - , - . - - - -
, 1 : 1 MAINTENANCE MSTP PERFORMANCE INDICATOR j ( DEFERRAL RATE FOR PREVIOUS SIX MONTHS ) l ,. I '2 33 I >- 12 l * - # ,,, .1. k, 1 - = ., ' - 1 , , , 78 ' ~ l No. 21 , _ % "i ... .. . . . . . . . . ' . - 1rl M 3r1 #1 M M 7t1 M M fori 11/1 131 1r1 2/1 M M 1:; i ,r. , c ,, w ,, m===uw neemme==wmmumaanmeammumwa=== MAINTENANCE ORGANIZATIONAL h IMPROVEMENTS eimplemented l&C and Maintenance lead
.
technicians to reduce the burden on supervisors thereby allowing more opportunity for the i supervisor to monitor and coach in the field l e Created a PM/RCM Coordinator to focus our efforts on reducing the PM deferral rate and incorporate RCM into our PM program
>
33-34 l __-__-_____--_-_______---___.-__--_____-_____-__--
- .. - -. -- . . : ' :
,
mmmeumwwaraemanenwnwnwunm:numwwsrmnwnummm
-
AREAS OF CURRENT AND FUTURE FOCUS
I e Procedural adherence and usage improvements
- Identified by our corrective action and self-assessment programs
4
Actions are in progress or planned as follows: . Incorporated an administrative procedure training I ' module into Maintenance training in the fall of 1996 with inclusion into the continuing training program i
-
I 1
. A
- - m - em m - - - - -3a. - m m - - - -, -
,
PROCEDURAL ADHERENCE AND USA IMPROVEMENTS (Cont.) Identified industry leaders in Maintenance simulators for STAR and procedure usage
i
training and have assigned project supervisor to develop construction plan and schedule
, "
o Conducted repeated work control training sessions for plant and support personnel based on lessons learned during work control process maturation
35-36
_ _ - _ . . . _ - . - -- . . - . . - _ . . . - - : ' ! wantnewmwwwww.<rmeamaammmwewcassuwnmemnarara PROCEDURAL ADHERENCE AND USAGE IMPROVEMENTS (Cont.) .
- . Developed / implemented procedural usage
JPM type testing for Maintenance
- 3ersonnel. Used during l&C and
i Waintenance lead technician selection i process
Plan to expand the use of craft personnel to rewrite procedures from training and mock-up environments in order to improve
i procedure quality
I
! 1 !
I 20%28b%WWMfA51%EDC415@SO48HSSWM33ES%E9*,3AM3@%ICMW32MtOWJOPIAC314JJAMS
i MAINTENANCE ORGANIZATIONAL
- IMPROVEMENTS
I ,
e Developing plan for a Maintenance support organization to improve our:
'
Corrective action program responses Procedure quality improvement capabilities e Developing plan for an in-house Maintenance Projects Team to improve our: - Project implementation and planning - Vendor interface and oversight
l
37-38 ..- - - . ._.. - .. - ._. - _ _ . _ _ _ _ _ _ _ _ _ - _ .
- __ - -. -. . _ - . _ - .- : . : mawanawrmwawum::xmnummawawammu;mnus wwmmanua MAINTENANCE ORGANIZATIONAL IMPROVEMENTS (Cont.) ! ' e Develop Air-Operated Valve (AOV) program to: - Identify and categorize safety significant AOVs Perform design basis review as needed Establish PM & diagnostic requirements ;
a f e
nummaan nwnana n m monwaanna munn.-a, SUMMARY OF IMPROVEMENTS &
! '
eThe improvements completed have raised the i performance of the PNPS Maintenance
- organizations (Maintenance,1&C, Work
Control) and provide a solid foundation. The results demonstrate our organization's : progress. Our commitment to continuous
-
improvement drives us to constantly re-evaluate our position and develop new ! strategies that ensure superior performance. ' i l 3940
. -, . . . . _ _ _ : : susmuumwm eeuwwa:amwnxvwmmwssnannsmatw:carrenan
3
' PROCEDURAL ADHERENCE ;
. ,
1
-
! Ted Sullivan
, Plant Manager J
1 !
l o.maeawmwwaure manmaanamamammwwwnwa $ 4 PROCEDURAL ADHERENCE
- e Measures I
. e Methods of Quantification
e Procedure Quality issues 1 e Self Identified Weakness ! eimprovements e Procedure Improvement Process Team
'
! 41-42 I
. . . . . . -- . - : : mswwuwwxwareneanmana:atumranunmanmxemmwanmessw i PROCEDURAL ADHERENCE MEASURE o Problem Reports Pro dure Quality Human Performan l . e Self-Assessments I Performan Assessment Program o Human Performan Matrix
.. eLessons Leamed l
e Simulator Performan
i 1
St?Muut1lR'#DL%wJGDC4%#MLMJ%fMM3tVRiniD%iG4M%"AMMntsM:,54tMRIG%Ah1 PROCEDURAL ADHERENCE MEASURE (Cont.)
.
eJob Performan Measures (JPMs) Technical and Operator Programs equality Assurance Oversight . Audits
'
Surveillan s DRs e Human Performan Monitoring Program 43-44 ! - - -
. .- _ .- . _ - . _ .. . .. - _ - _. . _ _ _ _ _ _ - _ " ,
4
! unswunwan rsw.umwaswwnmv.mumnuunwnssmsmesmnwanun HOW IS PROCEDURAL ADHERENCE
- BEING QUANTIFIED
;
- eCorrective Action Process
; * Problem Reports . Trending and Tracking . Common Cause Analysis eObservation Reports * Results fed back for inclusion into
'
Self-Assessments
i e Monthly Human Performance Reports i . 1 i i
' ' 'r '- - '8 d d
i
HOW IS PROCEDURAL ADHERENCE BEING QUANTIFIED (Cont.)
. '
* Self-Improvement Performance Ratio (SIPR) * Inappropriate Action Report
* Trend Analysis . Human Performance Ratio .Significant Human Performance Problem Reports
! , !
45-46 _,
. - . _ :
i
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-
INAPPROPRIATE ACTIONS PROCEDURE NON-COMPLIANCE ,
1
l
< . . - _ - . _ . . . _ . . . _ _ _ , . _ . _ . _ - - . . . _ _ . . . . _ . - . _ _ _
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:auaenaameuxmmawnamcammmumramwwwawneammmau INAPPROPRIATE ACTIONS
.
PROCEDURE NON-COMPLIANCE l eJanuary 1997 - April 1997 e148 Inappropriate Actions e 10 of 148 ( 7%) Technical . (93%) Administrative I , Examples: - Operator failed to follow the requirements of 8.C.13 for installation
'
of valve locking device (Technical) l ! - Wrong revision to PNPS 3.M.4-48.2 was used (Administrative) 47-48
-.- . _ . . - .. . _ _ - - _. s t , axemummwnwanzmummwarauxemumwwwawuuurenewmuu INAPPROPRIATE ACTIONS PROCEDURAL DEFICIENCIES
4 i
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- mnan - - ~ ~ -na - - _ n anma nsman. INAPPROPRIATE ACTIONS &
i
PROCEDURE DEFICIENCIES eJanuary 1997 - April 1997 -e129 Inappropriate Actions
! e44 of 129: (34%) Technical
(66%) Administrative
i
Examples: -H2 trailer pressure too low when swapping to new trailer (Technical) -Incorrect note referenced (Administrative)
.
49-50 . _ . .
.. - --. -. -. ._-_ _ _ : 1 I ) NW3C#kM3M.2&MD3h5W2WM4M$iM'fM^f3!X1fA%8'f%"lWGB tMD%%D$30M%R*C%d%4MhM!)PZ4628MVJ SIGNIFICANT HUMAN PERFORMANCF PROBLEM REPORTS - NOVEMBER 1994
~
TO THE PRESENT i. . _ . _ - . _ . - . . . - _ . - . . - . - . _ - ~ . . _ . . . . - - . _ ~ - . ...-7 ... i f
l .
I I e. , e* ' *...e F 6- waim. .' e*= a' mi j ' . . . . .e.......,e....e - e. =e., .. e , , , , , ..._ ,ee. ! l ...... .. .......
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pr- u--unna--ann----a-a-mmne e.en "JW F 1 HUMAN PERFORMANCE RATIO 1 1 03-------'---- - - - - - - - - - - - - + - - - - - - - - - . - - - - - - - - - - - - - - - - - l
I i
0 26 . e.,------------------------------------------ ---- -~'
l ] s. --+- Human Pertwmawe Reen
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j 02 L ---- "-- - - - - - - - - - g 1 M HPR- - - - - - - - - - - - - - - - - - - - - - -
-- - - - - - 4 ' 's. . , ...s,,'s I '* o ss .- --- ------- - - %,; . . ,,,,------ ,------------ --- -4 .. , , ' St.- -------- -- ---- --- -- - - -- l'Do er . , - ---- -- ---- --{ l a../ 1 5...., o ne .. . _ - - - - - - - - - - - - - - _ - ------- =- -t . - V h86 A+46 On606 Co.M pef 98 Asc es hes Aess On698 Decret Psl> 07 Apr-97 The graph depeem be rate af mywBent human getuemenee prohaem reparen tu be had numba et menedy Inasien perfamience repene ele =esed improvement m ede eres e assueted by a desseerg Immen perhrmenee nose A new teseew to berg estaeaghed flue is fio esenni beenrg er he twerheid ftw utenaryme human portrmenos peshMene 1 , 51-52 _ _
. _ _ _ _ _ _ . --. _. . - . ._ .- : I mmwaeumanummmwennuznummeauawamumusammwnume STATION SELF IMPROVEMENT
.
PERFORMANCE RATIO
i (SIPR)
._ _ _ . _ _ _ _ . _ _ . . _ _ _ _ _ _ . . _ _ _ _ _ _ . _ _ _
3 ,
I ' .. j, - ______________1 e " . ________ _______________ ) , _ _ _ . __ r _ _ ..: _ _ _ _.! l '"
, _ ._. __. __ .. __ __ ._ __ .. .
.. e m r , a e e ,, s y ;- l W ; W i IR t i " a E i ! .. - . . - - - - , - - ~t===.:,::::::: 't%==::: Orr armummmmmanumawannammenwammemamasasema PROCEDURE QUALITY ISSUES
'
sCommon Cause Analysis (CCA) Level of detail within procedures, complexity of the task, safety significance and skill of the craft Simplify the procedure revision process Required training of personnel to optimize
.
level of detailin procedures
l Procedure revision tracking and trending
53-54 . _ _ . . .._ _ _ . _ . _ _
-- -_ . - - - .. . - . . . - - .. -.. _ _ . - - - ' s anzumnowwwannwmansuummmmnuummwaramwavanamwn . PROCEDURE QUALITY ISSUES (Cont.)
o Administrative Procedures
l e Upper Tier procedures:
Nuclear Organization Mission, Organization & Policies (MOPS) - Nuclear Organization Procedures (NOPs)
i , i i- ,
ACEO@@AUGM*XJM 4Wic.1RYf15EtsktAUCsirr$4GYtw st!?;&i412ML1DfjMar##GFsaws pulmtra SELF-IDENTIFIED WEAKNESSES
,
e Administrative procedures
- e Level of detail- commensurate with the task
. e~ Procedure revision process
eTraining of personnel on administrative procedures
4
55-56 , --. --
. . - .. . . - - . _ _ . . _ _ _ - ! I wwtnuutnurmwasswmamecnassunsarsesmura;wassan mza;nnsnaa , ACTIVITIES PERFORMED TO ENSURE
l PROCEDURAL ADHERENCE 3
o Plant Manager communicates expectations e Focused administrative training e Hands on simulator training - both Technical & Operations
- e Small specific training sessions
.
Work control process e Plant status update conducted by department managers
, i ! . i
1TJWiet antF#16mmSh@MN/ Ante &4HMmpK2 fat 112$ 23tR!MD%TMC4LMMETJ!fsc ACTIVITIES PERFORMED TO ENSURE PROCEDURAL ADHERENCE (Cont.) eJPMs faulted on specific tasks
- e Radwaste procedures
eValidation of procedures prior to infrequently
.
performed evolution e Simulator procedure validation e Monitor activities in the field
,
- Feedback to self-assessment system
'
57-58
.- . .. -- - -. . ..
!
' t ,
'
amarannawmmauswawa wmanwaansmwmmu m wnmus nmstaten
'
PROCEDURE IMPROVEMENT TEAM PROCESS : e Multi-disciplined Team - Customer Focus ; - Worker Level l
-
eGoals: - Reduce level of effort required to produce quality ;
i
procedures Improve usability of procedures for normal operations l Optimize cycle time to develop new and to modify procedures Improve quality of procedures (determine appropriate i
>
level of detail)
i
; --------, m,--m- PROCEDURE IMPROVEMENT TEAM -em. fJ
~
PROCESS (Cont.? eobjectives: ! - Identify required process changes l - Train organization on new process by end of . September 1997 Implement new process
.
/ 5940
9 I awo wanammiussummmmwmsswanam msuwananmcww.en ec atanm PROCEDURE IMPROVEMENT PROCESS ' TIMELINE einitial meeting May 21-22,1997 e Develop standards June 1997 e Add detail to process June 1997 ; eWriters guide modified July 1997 eTest and revise process September 1997 eTrain on new process & September 1997.
, link with hardware upgrades -
!
4
i
' , i
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.
4
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4
1
.
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l s '
PLANT SUPPORT l !
! Clair Goddard
Nuclear Services Manager
L 61-62
l
._ _ _ _ _ _ . . __ i i manwinwanmeareanammmusmwnswasnwammmm wa nwrmmm PLANT SUPPORT - RP AND ALARA e Areas identified for improvement 4 Radioactive material control Station ALARA performance
J
"'"MA515A'dfiWMXfsitiAN5Nf# L eWorker involvement and Training )
,
- Cross-functional self-assessment and benchmarking Radiation protection work practices team Site-wide training by VPNO/SD, Plant Manager and RPM l
.
e improvements in the Tool Control Process ) Tools available for workers Eliminated need to move tools outside RCA eTechnician Performance and Accountability eImproved Monitoring Capability Small Article Monitors (SAMs) Locking all Radioactive Material Seavans ' 63-64
_ _ _ _ _ _ _ - _ _ _ . . _ _ _ _ _ _ _ - _ - . - - - . . - , - - - _ _ _ _ _ _ _ _ _ _ _ . ! xmmmaxeanamumwamunravamumzensmmmnamwnnwanman POSITIVE RESULTS ACHIEVED e No loss or transfer of radioactive material to unlicensed parties e Onsite radioactive material events have significantly decreased from more than 30 in RFO-10 to 3 (none actually RAM) total in 1997 which included RFO-11 : i
.
i
meenneawaweaumurmr.amammannamuuamusmammum
[ ALARA PROGRAM PROGRESS l e Dose Reduction Action Plan (DRAP) drives
- improvements to reduce dose
. e 1996 was the lowest dose year in the history of
- Pilgrim Station (116 Rem)
'
2 outages (1 planned,1 forced)
! Pre-outage work i e Outage dose is still high but DRAP provides i long-term plan for reducing source term.
- Active since mid-1995
l - 115 items completed ! ' Over 1200 rem estimated to be saved over the
- remaining life of the plant
! l .
65-66 . -. . - . . - . . ..
. _ _ _ _ . _ . _ _ _ _ _ . _ . . _ . . _ _ . _ _______ , t i 1 -i marr-mmumsm. r ru se - - m o Recirc System Chemical Decontamination (saved > 150 Rem in RFO-11) eZinc injection eTorus de-sludging - allowing access to the Torus Compartment. e Permanent shielding in the RHR quads and on the recirculation risers in the drywell NESG supportlownership integral to this success e Fuel Pool Cooling System hydrolaze e MOV Sentry remote monitoring system
,
o Remote temperature / vibration monitors for RHR and
l Core Spray pumps ! e Remote Camera and Dosimetry Monitoring Systems '
e 70% Reduction in Hot Spots from 63 (mid-1995) to 18
l (currently)
i
ammmuawswummmu aa,unamnaeumawramnusman - ONGOING INITIATIVES
! e Chemical Decontamination of RHR loops in 1998
- *Thermex system to replace Flatbed Filters (3rd qtr.1997)
less exposure due to retirement of Flatbed Filters less solid radioactive waste generated
'
improved water quality
'
sCameras for High Rad areas
-
e Reactor Water Cleanup Septa replacement
e RWCU and Chemical Decontamination
- e Fuel Pool Cooling System Decontamination
e Future' Chemical Decontamination of the Recirc System
'
e Permanent shielding of torus shell, drywell, scram headers
67-68 , ,- , . . - ,- - - - . . . - .. _ - -
- _ _ . . i e 4m w wnwimua n.ormwa n uttuu rmumswsnSexuwmnwnuta rs.cm u r ta WHAT DOES FUTURE LOOK LIKE7 l l e Non-Outage years < 80 Rem ~~ ~ ~ ~ o Refueling Outage Years < 250 Rem 1 l i l l
, 4
-.- w.a mnaem mxmww as . ~ - awmumame
'
e New Redline (Access Control Point) and PRORAD Iraprovements More space and PRORAD terminals - State-of-the-art portal monitors i Full-service dosimetry office I ' PRORAD programming improvements Over 1000 electronic dosimiters in inventory - Implemented use of SAMs for material release Alternate access / egress points on turbine deck and makeup demin j area e Modified RWP Process to increase efficiency while maintaining radiological safety Reduced number of RWPs by 2/3 Standardized RWP format Expanded use of general RWPs to include access to contaminated areas , Changed the briefing process to focus on the briefing itself rather i than the computer input - Allowed field revisions to RWPs ; .~ 69-70
,
_. _ _ _ . . _ _ __ _ ._ t i , numcunwea$nw w - y mm o Other process improvements Participation in multi-disciplined teams < Dose goal was developed based on solid work scope information - Implemented lead RP technician positions ALERT training for contractors: practical rather than classroom o Performance Results 4 - Lower threshold for initiating prs facilitated identifying issues associated with electronic c osimetry . Radioactive material outside RCA reduced from > 30 to 3 , , . 15 CRDs replaced in 16 h'o'urs witnoutincident .
I
r*M*Gl?tN3&13ELYst/Mt#%41m*E$@%WM27#CMU1W4COv#4tE;TtWW&3fMs%2f24%T&TU$m40 OPPORTUNITIES FOR CONTINUED
. IMPROVEMENT ,
e Outage dose continues to be our biggest challenge
'
eInterdisciplinary communication needs improvement (e.g., ALARA on Strainer Project)
.
Worker input sessions PDC process changes will enhance ALARA/NESG interface e Opportunities exist to reduce radwaste e Comprehensive Solid Radwaste Program Improvement Plan Perform detailed assessment utilizing industry peers Improve procedure quality
4
71-72
_. . . s 8 l n,_, _nc. -,---n------- , _ f) l PLANT SUPPORT - SECURITY ' . e Areas identified for improvement - Self-assessment capability Reliability of security system hardware
.
Maintenance i
'
1 + Upgrades ! , i l
, m .nrs w a n n a.un w a a u a m w w m w a m u er a m m m a n e c m a
SECURITY PROGRAM IMPROVEMENTS e Security improvement Plan Detailed self-assessment utilizing industry peer and QA )ersonnel Vianagement reviews e Self-assessment program improvements
, Strengthened management involvement
Broader scope e Eliminated self-screening companies with few exceptions eMaintenance support of security equipment strengthened e Security hardware improvements Communications equipment - Sector post environmental enclosures Photo Imaging System Personnel Access Data System (PADS) and Nuclear Personnel System (NPS) Replacement of cameras will commence in 1997 _ 73-74
! ,
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.
ENGINEERING
!
I ! John Gerety l Deputy Nuclear Engineering Manager ! l L
1 80ka3IM*2*#rMA*JCMMbw)TTMJPA11$tMECOM.640$E0mtMhvDafTJW436GYMAMERM DESIGN BASIS RECONSTITUTION REVITALIZED e Utilize Major Programs - A-46 Setpoint Project ECCS Design Bases Review 1 - Equipment Qualification l 1 - MOV Project (GL 89-10) ! i' eldentify needs to support ongoing and future modification work e Establish an effective framework to capture ! information 75-76
- _ _ - .- -
,
* . 1
.
t
"
~~vm .mamnnewwum=,aanam-nuinwn--- FSAR REVIEWS IMPROVE DOCUMENT & QUALITY
, s
- e Preliminary review completed
e No operability issues identified e Discrepancies identified have been
'
documented and will be incorporated into the
i next FSAR update
1
a
i . l ! .
Y Y kN hYY $tY s b $ h $1 Yh s.$Y
COMPLEMENT CHANGES TO OPTIMlZ l
- WORK FORCE ;
1 e NESG workforce remained stable during this ) evaluation period eTeams being formed to identify ways to improve efficiency i eGoal to keep engineering work in-house with the exception of specialty analysis e Continue to improve vendor oversight I l 77-78
J
m er - - -- m n -.n~
. : '
- e
; ' ENGINEERING SELF-ASSESSMENT $
!
: RESULTS : 'e Calculations - No technical issues identified
- that would invalidate conclusions
j e Procedure Adherence - Training conducted to
; correct problems identified in the PDC closeout , , process l 1 !
> .
1
4
r
!, ! , --- - ,----,- @
ENGINEERING SUPPORT PERSONNEC
l
(ESP) TRAINING ENHANCEMENTS eTopics identified by the NESG Departments eTraining Committee coordinating requests and
'
feedback ; I ._ , 79-80
}}