ML20150E814

Mgt Meeting Rept 50-293/88-26 on 880627.Major Issues Discussed:Licensee Response to NRC Maint Team Insp 50-293/88-17,status of Licensee Evaluation of RHR Valve Yoke Cracking & Followup of Assessment of Readiness for Restart

ML20150E814
Person / Time
Site:	Pilgrim
Issue date:	06/30/1988
From:	Blough A, Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20150E809	List: ML20150E805 ML20150E814
References
50-293-88-26-MM, NUDOCS 8807150306
Download: ML20150E814 (4)

See also: IR 05000293/1988026

Text

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. U. S. NUCLEAR REGULATORY COMMISSION

Region I

Meeting No.: 50-293/88-26

Docket No.: 50-293

License No.: DPR-35

Licensee: Boston Edison Company

800 Boylston Street

Boston, Massachusetts 02199

f Facility Name: Pilgrim Nuclear Power Station

Meeting At: USNRC, Region I, King of Prassia, Pennsylvania

Meeting Conducted: June 27, 1988 p

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Reviewed By: uwu ~xc

Lawrence T. Doerfleiri,"Proj

[ ee ~/t Engineer

Lw (, 30 P;

/ Datd

Approved By: [k

A.' Randygrough, Chief

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Date

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Reactor Projects Section No. 3B

Division of Reactor Projects

Meeting Summary:

A management meeting was held at NRC Region I on June 27, 1988, to discuss the

following issues: (1) Boston Edison Company's (BECo's) response to NRC Main-

tenance Team Inspection 50-293/88-17, (2) the status of BECo's evaluation of

RHR valve yoke cracking, and (3) the status of BECo actions in followup of its

Self-Assessment of Readiness for Restart. The meeting lasted about two hours.

The Massachusetts Office of Public Safety, the Massachusetts Civil Defense

l Agency, and Massachusetts Attorney General's Office observed the meeting.

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9807150306 880630

PDR ADOCK 05000293

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. DETAILS

.1.0 Purpose

The management meeting was held at the request of the Boston Edison

Company (BECo) to discuss the following issues: (1) BECo's response to

NRC Maintenance Team Inspection 50-293/88-17, (2) the status of BECo's

evaluation of RHR Valve Yoke Cracking, and (3) the status of BECo actions

in followup of its Self-Assessment of Readiness for Restart.

2.0 Meeting Summary

The meeting was attended by those persons listed in Attachment I.

The meeting was opened with brief comments by NRC Region I Acting

Director, Division of Reactor Projects, Mr. Samuel J. Collins Mr. R. Bird

opened BECo's presentation and stated that BECo had finalized and was

delivering the following pertinent letters.

--

NRC Inspection Report 50-293/88-17 (Response), dated June 25, 1988;

and,

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Pilgrim Nuclear Power Station Request for Commencement of NRC

Integrated Assessment Team Inspection and Transmittal of Schedules

for Actions Prior to Restart, dated June 25, 1988.

These letters are enclosed as Attachments II and III, respectively.

Mr. Bird indicated that the licensee was requesting the team inspection

to commence on July 11, 1988. Mr. R. Anderson, Plant Manager, outlined

BECo's actions in response to the NRC Maintenance Team Inspection. He

indicated that the selection of maintenance program upgrades to be com-

pleted before restart was based on licensee evaluation of self-assessment

results, Material Condition Improvement Action Flan feedback, INP0 find-

ings, and NRC inspection findings. Relative to maintenance staffing,

Mr. Anderson indicated that full staffing had been achieved and current

efforts were focusing on hiring to permanently fill those positions cur-

rently staffed by contractors.

Mr. Anderson discussed the licensee's ongoing evaluations of cracking

identified on June 7,1988, in two motor-operated valves in the Residual

Heat Removal System. Mr. Anderson indicated that BECo would notify the

industry of the problem, as well as keeping NRC informed of the progress

of evaluations and repairs.

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. Mr. Ledgett provided an overview of the self-assessment process and stated

that the June 25, 1988 letter (Attachment III) provides status and

schedule for those self-assessment followup actions to be performed before

restart. Mr. Anderson outlined additional work, including extensive test-

ing, to be conducted before restart. He also stated that NRC Bulletin

88-05 response was an emergent issue under licensee evaluation.

3.0 Concluding Statement

Af ter a private caucus with the NRC participants, Mr. William T. Russell,

NRC Region I Administrator, summarized the meeting, thanked the licensee

for the information provided, and indictted that NRC would complete its

review of the information and inform the licensee of the results within

two weeks.

Attachments:

1. Meeting Attendees

2. GECo Letter to NRC dated June 25, 1938, NRC Inspection Report 50-293/88-17

(Response)

3. BEco letter to NRC dated June 25, 1988, Pilgrim Nuclear Power Station

Request for Commencement of Integrated Assessment Team Inspection and

Transmittal of Schedules for Actions Prior to Restart

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. ATTACHMENT 1

Meeting Attendees

U.S. Nuclear Regulatory Commission

W. Russell, Regional Administrator (Summary Only)

S. Collins, Deputy Director, Division of Peactor Projects (DRP)

R. Gallo, Chief, Operations Branch, Division of Reactor Safety (DRS)

J. Wiggins, Chief, Reactor Projects Branch No. 3, DRP

A. Blough, Chief, Reactor Projects Section No. 3B, DRP

L. Doerflein, Project Engineer, RPS 3B, DRP

B. Boger, Assistant Director for Region I Reactor, Office of Nuclear

Reactor Regulation (NRR)

D. Haverkamp, Chief, Reactor Projects Section No. 3C, DRP

N. Blumberg, Chief, Operational Programs Section, DRS

C. Warren, Senior Resident Inspector

Boston Edison Comnany

R. Bird, Senior Vice President - Nuclear

K. Highfill, Pilgrim Station Director

R. Anderson, Plant Manager

R. Swanson, Nuclear Engineering Manager

P. Hamilton, Compliance Division Manager

R. Ledgett, Director, Special Projects

E. Robinson, Manager, Nuclear Information

Commonwealth of Massachusetts

P. Agnes, Assistant Secretary of Public Safety

J. Hausner, Director, Nuclear Safety Energency Preparedness Program

G. Dean, Assistant Attorney General

Other Attendees

S. Sholly, MHB Associates

F. Jan, ASTA Engineering, Inc.

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ATTACHMENT 2

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easmausa

Pdgrim Nuclear Pcwer station

Rocky Hdi Road

Plymouth, Massachusetts 02360

June 25, 1988

se hV$ce'PrNident--Nuclear BECo Ltr. #88-98

U.S. Nuclear Regulatory Commission

Attn: Document Control Desk

Hashington, D.C. 205S5

Docket No. 50-293

License No. OPR-35

Subject: BRC Insoection Reoort 50-293/88-17 (Resoonse)

Dear Sir:

Attached is Boston Edison Company's response to the NRC Region I Haintenance

Assessment Team Inspection conducted from April 25 through May 5, 1988, at the

Pilgrim Nuclear Power Station (PNPS), Plymouth, Massachusetts and at the

Braintree, Massachusetts engineering office.

Boston Edison Company concurs with the NRC Assessment Team conclusions that:

1. No violations of regelatory requirements were identified during the

inspection.

2. Several program and performance strengths were identified.

3. Certain concerns, including some that were considered significant,

were identified.

These conclusions are consistent with the actions mandated by our Material

Condition Improvement Action Plan (MCIAP) and the independent conclusions of

our Restart Readiness Self-Assessment (RRSA) conducted between April 18, 1988

and May 2, 1988. Boston Edison Company has accelerated the actions necessary

to implement those MCIAP and RRSA items which will resolve the significant NRC

Assessment Team concerns.

Boston Edison Company will address prior to restart, concerns identified in

the areas of (1) maintenance program, (2) staffing, and (3) program

performance. The details and status of our corrective actions are discussed

in Attachment A. R. Ledgett and R. Blough agreed on 6/23/88 that submittal of

this letter by 6/27/88 is acceptable.

C> e ir 7 A 2 A D) /, L

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' Boston Edison Company Page 2

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License No. DPR-35

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,Pl ease do not hesitate to contact mb if there are questions or comments

regarding the attached response.

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RLC/bl

Attachment

cc: Mr. Hilliam Russell -

Regional Administrator, Region I

U.S. Nuclear Regulatory Commission

475 Allendale Rd.

King of Prussia, PA 19406

Sr. Resident Inspector - Pilgrim Station

Standard BECo Distribution

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ATTACHMENT 'A'

. Boston Edison Company BECo Ltr: 88-98

Pilgrim Nuclear Power Station Docket No. 50-293

License No. DPR-35

Insoettion Reoort 88-17 Resoonse

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Boston Edison has reviewed the concerns discussed in Section 1.2 of the NRC

Maintenance Assessment Team Report and concurs with the NRC Assessment Team

conclusions. .These conclusions are consistent with the independent actions

and conclusions of our Material Condition Improvement Action Plan (HCIAP) and

our Restart Readiness Self-Assessment (RRSA) conducted during the period of

April 18, 1988 to May 2, 1988. Boston Edison has accelerated the

implementation of those HCIAP and RRSA actions necessary to resolve the

significant NRC Assessment Team concerns. The areas of concern are:

Maintenance Program

Maintenance Staffing

Program Performance

I. Maintenance Proaram

The following is a summary of the actions taken in the area of the Maintenance

Program:

Boston Edison has taken action to more clearly define work control

practices in approved plant and department procedures as well as to

formalize the current plant work control practices for Haintenance.

- To accomplish this, the ongoing comprehensive rewrite of the PNPS

Maintenance Section Manual was completed to more clearly describe its

purpose, intent, structure, and its relationship to other sthtion

directives and procedures. This rewrite incorporates INP0 Guidelines85-038, "Conduct of Haintenance at Nuclear Power Station", to enhance

maintenance practices at Pilgrim Station. Additionally, Boston

Edison performed a major rewrite of PHPS Procedure 1.5.3,

"Haintenance Requests", to incorporate improved administrative

controls. A new procedure, PNPS Procedure 1.5.3.1, "Haintenance Hork

Plan", was developed to be utilized in conjunction with the

Maintenance Request (HR) as an administrative tool to provide a Hork

Plan which further defines (details) the maintenance activity to be

performed.

Boston Edison has taken action to provide improved specifications for

unique and routine maintenance previously covered by Procedure 3.H.1-11,

"Routine Haintenance", to ensure adequate preparation of work packages for

such tasks.

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ATTACHMENT 'A'

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Insoection Reoort 88-17 Resoonse

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- To accomplish this, Boston Edison prepared, approved, and implemented

Procedure 1.5.3.1, "Maintenance Hork Plan". This procedure, used in

conjunction with the revised Procedure 1.5.3, "Maintenance Requests",

provides an effective means to specify unique instructions for

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routine maintenance tasks formerly covered by Procedure 3.M.1-11.

Maintenance Hork Plans are now required to centain specifically

defined steps for the performance and documentation of maintenance

activities. MRs written prior to the implementation of the revised

maintenance program, and which referenced Procedure 3.M.1-11, are

reviewed and approved by the Plant Maintenance Section Manager prior

to implementation to ensure that the intent of the revised

maintenance procedures is met.

II. Maintenance Staffing

Boston Edison conducted a review in the last quarter of 1987 of the authorized

staffing level. An integral part of this review included an estimate of

manpower resources required to meet and maintain the established performance

goals of the Maintenance Section.

Based on this review, the permanent full-time Maintenance complement has been

increased. Ten of these positions are supervisory positions. Revisedjob

descriptions have been developed for this expanded organization and hiring

efforts are aggressively underway.

Attention to the plant's material condition has been increased by the

expansion of the permanent complement of maintenance personnel, Attention has

been further enhanced by assignment of the Systems Engineering Division (SED)

to provide increased support to individual maintenance activities thereby

reducing the burden on maintenance personnel. The SED conducts in-depth

research for the majority of individual Failure and Malfunction Reports

(F&MRs).

The overall knowledge, experience, and performance levels of the Maintenance

staff is being improved. This is being accomplished by:

Recruitment of personnel with greater experience levels to fill

'Jacant and new positions.

Improved training.

Development of well-defined job descriptions.

Improved Maintenance management and supervision.

The experience level of the Maintenance staff has been further enhanced by

creating the position of Deputy to the Maintenance Section Manager. This

position has been filled by an individual with approximately 25 years of

experience in production aid planning for nuclear repair, overhaul, and

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refueling work,

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ATTACHHENT 'A'

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Ins;ection Reoort 88-17 Resoonse

(cont'd)

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III. Maintenance Performance

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Boston Edison, through programmatic changes, is implementing actions which

. will increase attention to detail as well as improve familiarity with various

elements of the work control process. The improvement in the maintenance

program described in Set. tion I above, in conjunction with the staffing

increase and upgrades, is designed to result in improved maintenance

performance.

The following is a summary of the actions taken to improve performance:

Boston Edison has taken action to ensure that MRs are both complete and

correct.

- The revision of Procedure 1.5.3 incorporated additional guidance and

requirements regarding the preparation, review, and approval of MRs

to ensure correctness and completeness. The Maintenance Summary

Control (MSC) form has been deleted. The function of the MSC has

been integrated into the new Maintenance Hork Plan (Procedure

1.5.3.1). Training has been conducted, with emphasis on the

appropriate method of processing a work plan and the need for the

documentation to be complete and accurate.

Boston Edison has taken action to control expansion or revision of the

originai work scope during maintenance in the field and to require

documentation of the actual work performed.

- To accomplish this, Procedure 1.5.3.1 specifies the controls

necessary to make revisions to the work package. Additionally, any

revision to the Work Plan must be reviewed and approved in the same

manner as the original document. The work performed will be

documented and will become a part of the completed maintenance

package.

Boston Edison has taken ar. tion to ensure that complete work packages,

including necessary instructions, are available at the work site.

- The revised maintenance program now provides the necessary guidance

and program controls to ensure that work packages, including the

necessary instructions, are available at the applicable work site

when maintenance activities are being performed.

Boston Edison has taken action to ensure that Maintenance provides

documentation of material used, maintenance and test equipment

information, and work performed (including torque values).

- The Hork Plan now requires this information to be documented by the

maintenance personnel and becomes a part of the completed work

package. The process develops a chronological history of the

individual activities.

• Boston Edison has taken action to improve storage and retention of

maintenance records.

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Insoection Reoort 88-17 Resoonse

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- Upon completion of a maintenance task, the final work package is

. returned to the responsible Staffing / Planning Engineer for review and

closure. It is then processed by Document Control for retention as a

complate package,

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Boston Edison has taken action to ensure proper documentation of post work

testing.

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The Work Plan now requires the maintenance post work testing to be

identified, reviewed _ for adequacy, and results documented as part of

the completed work package.

These program improvements, coupled with the increased management focus and

direction, will ensure continued program improvement.

IV. Overview of the Revised Maintenance Proaram

The comprehensive rewrite of the Maintenance Section Manual for PNPS is

complete. The changes and additions more clearly. describe its purpose,

intent, structure, and its relationship to other station directives and

procedures. This rewrite incorporates INPO Guidelines85-038, Conduct of

Maintenance at Nuclear Power Stations, to enhance maintenance practices at

Pilgrim Station. ,

Boston Edison also performed a major rewrite (revision) of PNPS Procedure

1.5.3 "Maintenance Request" (MR) to incorporate stronger administrative

controls to identify problems, initiate, plan, track and accomplish station

maintenance with precise supervisory control on both safety-related and

nonsafety-related components, equipment, or structures. A new procedure, PNPS

Procedure 1.5.3.1 "Maintenance Work Plan" (MHP), was developed to be utilized

in conjunction with the Maintenance Request as an administrative tool to

provide a Work Plan which further defines (details) the work to be performed

including special tools, equipment, procedures, instructions, technical

documentation, expected exposure levels (if applicable) and to provide

feedback when work is completed. Revisions to MHPs will not change the intent

of the work scope originally approved. Revisions to the Work Plan will be

reviewed and approved in the same manner as the original document. The Work

Plan and the parent MR are the controlling documents for installation of a

modification or performance of a maintenance work activity. The Work Plan

specifies the requirements for examination, and testing, and includes the

applicable instructions, procedures and drawings. It also specifies

hold / witness points and provides for controlling the work in the event of a

nonconformance.

The highlights of these major revisions to PNPS Maintenance procedures are:

(1) the work documents are incorporated into a single work package for each

work activity, (2) the process of the Maintenance Hork Package provides

increased control in that the engineer who develops the package maintains

control during the process, (3) Management level review and approval of

i revisions, including Quality Control and Operations, are part of the process, '

and (4) the final package, along with copies of the required documentation is

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returned to the engineer for review, closure, and processing to Document

Control. These procedure revisions ha 9 been completed, reviewed, approved

and implemented.

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ATTACHMENT 'A' I

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Insoection Recort 88-17 Resonlig

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Boston Edison has conducted a series of formal training sessions for the

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Haintenance Managers, Supervisors, Maintenance Craft and selected personnel

from other sections that are directly or indirectly involved in the

processing, review, or examination of the new HR/HWP process. This training

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was completed on June 17, 1988, with program implementation on June 20, 1988.

To reduce the impact on production, and provide a smoother transition,

management oversight of the new HR process is being increased during the

implementation phase. In addition, the Quality Assurance Surveillance

Division will be conducting surveillance on the revised Maintenance Program to

monitor implementation and performance.

This response focuses primarily on the corrective actions taken to resolve the

concerns described in Section 1.2 of the Team Report. Other corrective

actions and program improvements have also been identified and are being

addressed by Boston Edison Management. Although some items are not designated

as RESTART actions, these items are incorporated into long term programs such

as the "Haterial Condition Improvement Action Plan" (HCIAP). Boston Edison is

continuing these actions / improvements with the goal of achieving and

sustaining the highest standards of maintenan:e performance.

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N ATTACHMENT 3

eosa wsw

Pilgnm Nuclear Power State

Rocky Hill Road

Plymouth, Massachusetts 02360

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Ralph G. Bird

',enior vice President - Nuclear

BECo Letter #88-099

U.S. Nuclear Regulatory Commission

Attn: Document Control Desk

Washington, DC 20,555

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Docket No: 50-293

License No: DPR-35

Pilgrim Nuclear Power Station Request for Commencement

of NRC Integrated Assessment Team Inspection and

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. Transmittal of Schedules for Actions Prior to Restart

Dear Sir:

Boston Edison Company hereby requests that the Nuclear

Regulatory Commission (NRC) commence its Integrated Assessment

Team Inspection (IATI) of Pilgrim Nuclear Power Station on July

11, 1988.

Boston Edison provided the NRC with the results of its

Restart Readiness Self-Assessment (RRSA) on May 26, 1988. This

letter provides the schedule for those matters identified in the

RRSA which require completion of specific, well defined actions

for restart.

Attachment I contains summaries of RRSA Chapter II. A items

and schedules for remaining actions to be done before restart.

Attachment II is an integrated summary-level schedule for the

remaining work and testing before restart. This schedule is also

the Target Schedule to be inserted into the Restart Plan, Volume

2, Rev. 2 as Appendix 2.

Attachment III is an errata sheet for the RRSA. This sheet

should be inserted into each of the copics of the report in your

possession.

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Docket No: ~ 50-293

BECo Letter #88-099 License No: DPR-35

Page 2

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Please contac.t me or R. A. Ledgett if you have any questions

about the schedules and status information provided in

Attachments 1 and 2 or if yon need additional information in

preparation for commencing the IATI.

. G. Bird

/ Attachments

cc: Mr. William T. Russell

Regional Administrator ,

U.S. Nuclear Regulatory Commission - Region I

475 Allendale Road

King of Prussia, PA 19406

Mr. D. G. Mcdonald

Project Manager

Division of Reactor Projects I/II

U.S. Nuclear Regulatory Commission

Mail Stop #14D1

One White Flint North

11555 Rockville Pike

Rockville, MD 20852

Senior NRC Resident Inspector

Pilgrim Nuclear Power Station

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Attachment 1

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Matters that Require Specific Action Before Restart

, Identified in Chapter II.A of the

Belf-Ascessment for Restart Report

The~ most important matters identified during the RRSA

relating -to plant and equipment performance, operational

performance, management and ozganization that require specific

action before restart were described in Chapter II.A cf the Self-

Assessment for Restart Report. Specific plans or actions to be

implemented prior to restart are summarized below.

Actions already completed are designated "Complete." Dates

under "Complete" annotations indicate the date the action was

completed or the time frame in which the actions were taken.

Actions scheduled for completion between the date of this letter

and restart have the completion date designated.

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RRSA SECTION

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II.A.1.a "The first portion of the process (for

reporting deficiencies and initiating

corrective action) --a single reporting

. form and a corrective actio'n clearinghouse

-- will be initiated prior to restart. In

the longer term, this activity will be

expanded and integrated with PNPS

information systems with the objectives of:

a) reducing the number of redunaant

corrective action tracking systems; and b)

providing more readily accessible and

usable management information tools."

DETAILED PI.AN or ACTION AND SCHEDULE DATE FOR II. A.1.a

1. The PNPS Housekeeping Manual has been Complete

issued and implemented. Expanded (May, 1988)

specific area owner assignments are

evntained in the manual.

2. "Clearing house" was formed and began complete

operation to screen personnel, (Jun 13, 1988)

administrative and material deficien-

cies and to generate necessary

documentation to effect correction

(e.g. MR, PCAQ,'DR, NCR, etc.). The

initial efforts of the clearing house

are being focused on dealing with the

backlog of items generated in the

cours9 of the self assessment as

delincated in a and b below,

a. Document presently known material Aug 01, 1988

deficiencies (Management

Oversight and Assessnent Team

Field Notes, Peer Evaluator

reports). This is being

accomplished by the Systems

Engineering Division working with

c1 caring house personnel,

b. Categorize and document non- Aug 01, 1988

material deficiencies.

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DETAIIED PLAN or ACTION AND SCHEDUIE DATE FOR II. A.1.a

c. Following the initial trial

period, thic organization will be

formally proceduralized. The

first part of thi'proceduralizing Aug E, 1988

process will be to create a

single reporting form based on

the experiences gained in

processing the work to date.

3. QA Surveillance Upgrade program will

be implemented. ,The scope of this

upgrade program will extend beyond the

established Appendix B requirements.

a. Draft QA Action plan to upgrade Complete

the e.udit/ surveillance process.

b. Train QA Division Manager in the Complete

upgraded program. (Jun 1988)

c. Train remaining QA Department Sep 1988

personnel in upgrade program.

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RRSA SECTION

II.A.1.b "Priority actions are being directed to

filling 32 (29) newly authorized, permanent

Boston Edison positions within the

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Maintenance Section that are now staffed on

an interim basis by contractors. Ten of

the positions are designated for

supervisors and work planners. Management

has given advance approval and the highest

priority for hiring in order to more

effectively support team building within

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the Maintenance Section.

Additional items scheduled before restart

include:- (a) issuance of an

improved / updated Maintenance Control

(Section) Manual, which will formalize many

of the improvements presently in place, (b)

revising the troubleshooting procedure to

more clearly document work activities

during and subsequent to a troubleshooting

task; and (c) capturing remaining

improvements in appropriate formal PNPS

documents.

The Station Director and Plant Manager will

continue to exercise.close oversight of the

maintenance function through restart, power

ascension, and initial power operation to

assure that management control is

effectively maintained and improved. In

this regard, particular emphasis will be

placed upon training and monitoring of

responsible organizational elements to

increase their familiarity with and

attention to the work control process."

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DETAILED PIAN or ACTION AND SCHEDULE DATE FOR II. A.1.b

A. Initiate priority actions to fill

Boston Edison positions in the Main-

tenance Section. As of June 23, 1988

. eleven new employees hve a been hired

in this effort.

B. Revise / Issue Maintenance Control

Procedures

1. Procedure 1.5.3 (Maintenance Request

Procedure). ,

a. . Prepare draft Complete

b. Formulate and conduct training Complete

c. Implement procedure Complete

(Jun 20, 1988)

2. Procedure 1.5.3.1 (Maintenance Work

Plan)

a. Prepare draft Complete

b. Formulate and conduct training Complete

c. Implement procedure Complete

(Jun 20, 1988)

3. Rewrite Maintenance Section Manual

a. Prepare drafts Complete

b. Review drafts Complete

c. Develop training Complete

d. Conduct training Jul 1, 1988

e. Develop Plan of Action for Complete

implementation (Jun 24, 1988)

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DETAILED PLAN or ACTION AND SCIIEDULE DATE FOR II.A.I.b

4. Implement Instrumentation and Control

r. (I&C) valve lirse up procedure.

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. a. Draft procedure Complete

b. Install Phase I tags complete

c. Develop and conduct training Complete

d. Issue procedure Complete

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e. Develop plan of action for complete Complete

tagging (Jun 23, 1988)

5. Upgrade Environmental Qualification

(EQ) procedure.

a. Approve draft procedure Complete

b. Develop training Complete

c. Conduct training Complete

d. Issue procedure complete

e. Lift stop Nork order Complete

(Jun 20, 1988)

6. Implement Lif ted Leads Procedure

(1.5.9.1)

Complete

a. Approve draft procedure

Complete

b. Develop training

Complete

c. Conduct training

Complete

d. Issue procedure (Jun 1, 1988)

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DETATIED PLAN or ACTION AND SCliEDULE DATE FOR II. A.1.b

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7. Implement torquing procedure

a. Determine scope a.nd receive Complete

, engineering inpat

b. Prepare draft procedure Complete

c. Review draft procedure Jun 27, 1988

d. Develop and conduct training Jul 8, 1988

e. Issue procedure Jul 15, 1988

8. Imp' lament valve stem lubrication

procedure

a. Determine scope Complete

b. Determine lube types Jun 27, 1988

c. Develop procedure Jun 27, 1988

d. Develop and conduct training Jul 1988

e. Issue procedure Aug 1, 1988

f. Revise PM dchedules Aug 1988

9. Revise the troubleshooting procedure Aug 1, 1988

to more clearly document work

activities during and subsequent to

troubleshooting.

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DETAIIID PLAN or ACTION AND SCIIEDULE DATE FOR BOTH II. A.1.a & b

l

,

The Work Prioritization Team function has Complete

been proceduralized in the recently

-

,

completed revision of PNPS 1.5.3,

Maintenance Requests (MRs). In combination

with the Rotating Window concept, each

system's status is periodically reviewed

'

and station management focuses on the

system's deficiencies. Thus MRs of all

priorities are evaluated and the items

scheduled are those that support system

performance and address plant reliability.

The Maintenance Section Manager has Complete

addressed the issue of qualification to

perform maintenance with Division Managers

and S Jpervisors. Maintenance tasks are

assigned based on the satisfactory

completion of the applicable training or

the previous experience of the individuals.

.

8

. _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _

0

.

a

BBSA'SECTION

II.A.1.c "a. Continue the process for hiring.

b. Develop an integrated schedule for

remaining surveillance and testing to

. meet restart using an inter-

disciplinary team.

c. Continue addressing remaining

maintenance work required for restart

in the Plan-of-the-Day and assure that

resources are focused on meeting

scheduled dates.",

II.A.1.d "Complete reviews, sequence, and schedule

any additional testing identified by these

reviews for completion prior to restart or

during power ascension testing."

DETAILED PIAN or ACTION AND SCHEDULE DATE FOR II. A.1.c & d

1. A detailed schedule for accomplishment Complete

of fire barrier surveillances has been (May 26, 1988)

issued and has been incorporated into

the integrated schedule for work and

testing.

2. NED periodically issucs a report to Latest version

address "issues 'that could potentially dated:

delay restart . " Jun 20, 1988

3. An integratect schedule for work and Complete

testing has been issued in summary (Jun 23, 1988)

schedule form and is included as a

separate attachment to the cover

letter for *:his document. The

schedule incorporates vemaining

maintenance work, Logic system

Functional Tests [LSFTs), fire barrier

surveillances, and other surveillances

and controlling paths.

4. The process for hiring of personnel

has been continued. As of June 23,

1988 sixteen personnel have been hired

for this department.

9

,

- .

4 -

4

DETAILED PIAN or ACTION AND SCIIEDULE DATE FOR II. A.1.c & d

5. Review of testing for plant equipment

and systems are being completed to

confirm their readiness.for reactor

'

-

operation.

a. Reviews of Logic Systems Aug 22, 1988

Functional Tests ( LS FT) ,

Simulated Automatic Actuation

Tests and Plant Design Change

post work test procedures for

adequacy. ,

b.. Review to verify the scope of Jul 7, 1988

planned power ascension dynamic

testing. The review process is

as follows:

-

Select relevant dynamic

events, (operating tran-

sients).

-

Define expected transient

response, (system component

and plant parameter).

-

Identify changes made,

(Plant Design changes, major

maintenance and emergent

problems) which could

potentially affect plant

transient response.

-

Predict and evaluate

potential impact on plant

response due to failures,

malfunctions or installation

errors.

-

Evaluate completeness and

adequacy of tests done or

planned during power

ascension to assure adverse

impact, if any, could be

detected.

10

_ _ _ _ . - _ - -

, _ _ _ - _

G'

a

.-

DETAILED PIAN or ACTION AND SCliEDULE DATE FOR II. A.1.c & d

c. Review to verify that plant Jul 22, 1988

systems will be tested and are

operable before restart. A list

. of surveillance and test procedu-

res is being prepared for selec-

ted systems. The list includes

Technical Specification surveil-

lances and non-Technical speci-

fication required procedures

which support operabilicy. The

complete lis,t of procedures will

be reviewed to ascertain which

, procedures should be performed

before restart. Considerations

will include date last performed

and whether work has been

performed since the last test.

.

11

O.

n

.-

RRSA SECTION

II.A.2.a "a. Prior to restart, complete

-

reviews and any necescary changes

to provide improved control over

valve position and to enable

, operators to more readily

determine valve position status.

b. Prior to restart, revise the-

tagout procedure to limit the

types and clarify the uses of

specific tags.

c.. Prior to restart, develop a plan

to imple en* the INPO good prac-

tices f;; ,a'.ve lineups and labe-

111ng if w .ird to instrument is-

olation c',,es,

d. Prior to startup, develop instru-

ment-specific valve lineup sheets

for all safety system and cr-

cal Balance of Plant systems."

DJD'AIIID PIAN or AC'f]ON AND SCHEDULE DATE FOR II. A.2.a

1. Revision to PNP 5 Procedure 1.4.5, Aug 1, 1988

Equipment Tagout, is in progress.

Some specific in.provements include:

a. Elimination of the use of red

danger tags to mark lifted leads,

b. Improved control over NWE and

test tagging.

c. Requirements to perform lineups

following removal of equipment

clearance tags.

12 ,

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- --

_. _ _

.

.

o'

DETAILED PLAN or ACTIOd AND SCilEDULE DATE FOR II . A. 2 2 .4 ,

)

-

2. Operations has completed reviews of Aug 15, 1988

the valve position control procedure.

Prior to startup, each operating

system will be given a complete valve

,

lineup as close as practical to the

actual startup date. Subsequent to

that lineup, periodic lineups at

specified frequencies will be

performed on all accessible

components. Additional improvements

will be considered and implemented

whenever necessary to improve operator

control over and knowledge of valve

positions.

3. An instrument specific instrumentation Complete-

and control (I&C) valve lineup (Jun 22, 1988)

procedure has been issued for safety

systems and selected Balance of Plant

instruments. This procedure was based

on INPO good practices for valve

lineups.

,

,

e

13

m == q -#-- -w- .-a+%. --p 9 p g i+ wy- =

, _ .

-O

n

,-

RRSA SECTION

'

II.A.2.b "Complete the review of the ESF actuation

+ .

study and initiate positive actions to

reduce the occurrence of unplanned ESF

actuations."

'

,

DETAILED PIAN or ACTION AND SCHEDULE DATE FOR II . A. 2.b

1. Complete a pre-restart test review to Jul 1, 1988

identify those tests needed to

minimize problems most likely after

start-up from a long outage.

2. Conduct the pre-restart tests Aug 19, 1988

identified during the review of 1

above. -

3. Conduct a review of "Management Comple'te

Lessons" in NUREG 1275 and evaluate (May 23, 1988)

for applicability to PNPS.

4. A review has been performed of Aug 19, 1988

training conducted on industry

operating experience. Training on

thermal binding of large gate valves

has now been included in the operator

training program to be completed

before restart.

.

5. Inadvertent ESF Actuation Task Force Aug 1, 1988

will complete analysis, and corrective

actions to disseminate lessons learned

and prevent recurrence will be

completed.

6. Anti-spill Task Force will complete

analysis of spill events and

corrective actions will be

implemented.

a. Complete analysis of all spills Jun 27, 1988

in 1988.

b. Convene task force to establish Aug 1, 1988

corrective actions and develop

schedule to implement corrective

actions.

14

. . _ _ , __

^

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1

l

r. 1

'

.

RRSA SECTION

II.A.2.c "No additional actions (to improve the

-

formality of communications) are required

for restart, although Boston Edison will

initiate steps to apply appropriate

-

portions of the standards for Control Room

communication to I&C and other personnel

identified for improvement."

DETAILED PLAN or ACTION AND SCHEDULE DATE FOR II.A.2.c

1. Communications training for licensed Complete

operators is compKete. (Apr 1988)

2. Communications training for non- Aug 19, 1980

licensed-operators is in progress.

3. A Station Instruction (SI-nP.0006) has Complete

been established for standards of (Nov 4, 1987)

communications in the Control Room.

.

t

15

_ _

B

.

.'

RhJA SECTION

II.A.2.d "Validate procedures revised during RFO-7.

-

Prior to restart, complete training on

procedures revised for modifications and

implement the writers guide,.. An upgrade of

'

,

Operations procedures by the Procedures

group is scheduled as a long-term ef fort. "

DETAILED PLAN or ACTION AND SCIIEDULE DATE FOR II. A.2.d

1. Procedure validation is in progress. Jul 15, 1988

As of 6/17/88, it is approximately 60%

complete for all, procedures revised

since April 1986.-

2. Conduct training on operations Aug 19, 1988

procedures revised for modifications

implemented during RFO-7.

3. Issue the Procedure Writer's Guide. Jun 29, 1988

4. The validation process has been Complete

defined in TP 88-07. (Jan 30, 1988)

5. Specific procedural deficiencies as Aug 1, 1988

delineated in the MO&AT Field Notes

will be dispositioned.

6. Improve human fa'ctors in EOPs and Complete

satellite procedures.

7. Human factors improvements in other

procedures is not a restart issue and

will be completed as a longer term

project.

16

.

.'

RRSA SECTION

II.A.2.e "Resolve deficiency reports (on Priority A

.

drawings) prior to restart."

DETAILED PIAN or ACTION AND SCHEDULE DATE FOR II. A.2.e

,

1. Independent review of Priority A Complete

drawings was completed by the Surveil- (May 20, 1988)

lance Monitoring Group. Two DR's were

issued.

2. Conduct a survey of all Priority A Complete

drawings and associated messages in

"SEEK."

'

"

3. NED review the accuracy and validity Jul 22, 1988

of each message in "SEEK" for Priority

A drawings.

4. Request removal of unnecessarv ' SEEK" Jul 22, 1988

messages.

5. Complete drawings update. Aug 15, 1988

6. The effectiveness of having Priority A Aug 15, 1988

drawings updated and issued prior to

operational turnover of a modification

is the subject of a DR, (See Item #1

under II.A.2.e shove). The resolution

of the DR, including completion of

corrective actions constitutes the

verification of adequacy of the

_ . _ ,.. .... _ . _ ... .. _ P.F.o c e s s . . _ _ ,__,, _ , _ ,, , _ ___ _ , __, , , ,,,,_ , _ _ _ _

17

.-

.*

9

RRSA SECTIQH .

II.A.3 "Prior to restart begin actions to

. institutionalize practices involving:

a. Planning,' scheduling, ~ assignment, pre-

'

, job briefing, and control of

maintenance; and

b. The event investigation and critique

process, including the process for

determination of underlying causes,

and assigning and accomplishing

identified actiops.

After power ascension, efforts will be

directed to institutionalizing the peer

evaluator process, and developing a long-

term, issue oriented data base."

DETATLED PLAN or ACTION AND SCHEDULE DATE FOR II.A.3

Good practices in use that will be formally

proceduralized:

1. Specification of permissable or Jun 27, 1988

required times to conduct post work

testing in Maintenance Requests.

2. System Window C6ncept for maintenance. Aug 30, 1988

3. Describe work flow process. Complete

(Jun 20, 1988)

'"

Work Package Development Checklist.

~' ' ~

3. Complete

(Jun 20, 1988)

5. MR Data Base accessability via the Jun 27, 1988

Prime computer at 12 terminal

locations.

6. Define Work Prioritization Team Complete

concept. (Jun 20, 1988)

7. ALARA aspects of development of Jul 15, 1988

preoperational tests.

8. System turnover process. Jul 15, 1988

9. New training material on NPA trash Jul 1, 1988

compactor operations.

18

, _ - .

e

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i

DETAILED PIAN or ACTION AND SCHEDULE DATE FOR IT. A.3

.

10. Refresher academic training for Jul 1, 1988 l

license candidates. l

'

.

11. The practice of giving 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> NRC Jul 1, 1988

style written practice exams.

12. Methodology to deal with testing of Jul 15, 1988

special projects such as Hydrogen

Water Chemistry Control.

13. The practice of p'roviding NTD Jul 1, 1988

instructors on-shift for NRC license

candidates.

14. The practice of giving NRC license Jul 1, 1988

candidate NRC style walkthrough and

oral practice exams.

15. Glove bag use. Aug 15, 1988

16. Excavation practices. Aug 15, 1988

17. Prevention of excavations in the Aug 15, 1988

buffer zone.

18. Pre-job briefing's (in excess of RWP Complete

requirements) . (Jun 20, 1988)

19. Conduct of spill drills. Jun 30, 1988

20. The Fire Protection System status Jul 22, 1988

boards.

21. Requirements for medical attention Aug 15, 1988

off-site.

22. Inspections of work sites by super- Aug 15, 1988

visors.

23. Personal safety responsibilities. Aug 15, 1988

24. Station overtime policy. Jul 15, 1988

25. Event critique procedure. Complete

l (Jun 20, 1988)

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4

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-

Attachment 3

.

'

. Self-Assessment of Readiness foi- Restart ReDort Errata

Chances

Pace Line Report Correction

I-13 16 , 32 29

II-4 21. . 32 29

II-29 4 32 29

IV-9 21 32 29

IV-10 6 120 160

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IV-12 19 32 29

V-13 13 32 29

V-15 2 120 160

V-18 16 23 27

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