ML20151K361
| ML20151K361 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/14/1988 |
| From: | Bird R BOSTON EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 88-079, 88-79, NUDOCS 8804210299 | |
| Download: ML20151K361 (10) | |
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Pilgrim Nuclear Power Station Rocky Hill Road Plymouth, Massachusetts 02360 Ralph G. Bird Senior Vice President - Nuclear BECo Ltr. #88 079 U.S. Nuclear Regulatory Commission Attn:
Documettt Control Desk Hashington, D.C.
20555 Docket No.
50-293 License No. DPR-35
Dear Sir:
This letter is submitted in response to the NRC Staff questions transmitted by NRC letter dated March 18, 1988 regarding the Pilgrim Nuclear Power Station Restart Plan.
Attachment I contains a restatement of the NRC question followed immediately by the Boston Edison response.
Please contact me directly if there are any questions regarding this letter.
As G.
ird PJH/bl Attachment ec: Mr. Hilliam Russell Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 l
Sr. Resident Inspector - Pilgrim Station l
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ATTACHMENT 1 i
BECO Resoonse to NRC Review of Pilarim Restart Plan NRC Ouestion i Volume 1 Chapter 2 of t'ne Restart Plan needs to be updated to reflect the recent organizational and personnel changes.
BECO Resoonse The recent organizational and personnel changes within the nuclear organization of Boston Edison Company will be described in a chapter on organizational and personnel changes in the Final Report of Management Self-Assessment of Readiness to Restart.
This report, which documents the results of the self-assessment, is a companion document to the Restart Plan and the Power Ascension Program. According to the current schedule, the self-assessment report will be issued in mid-May,1988.
1 NRC Ouestion 2 Under the new organization, how will the functions attributed to the Planning and Restart Group as defined in Volume 1 Chapters 2 and 3 be accomplished? For example, the Hork Planning and Estimating Branch provided each section with a full time planner designed to enable the section to improve planning and scheduling of its own work and coordinate and integrate its work plans and schedules with those of other sections and disciplines.
l BECO Resoonse l
Although the new Organization no longer has a group entitled "Planning and Restart Group", the functions attributed to that group have been retained, primarily in the Planning and Outage Management Department.
For example, there remains a full time planner (s) from the Planning and Outage Management Department assigned to each Department to enable each Department to improve planning and scheduling of its own work and coordinate and integrate its work plans and schedules with those of other sections and disciplines.
The Haterials Management Section was re-organized under the Plant Support Department.
In addition, each day at 0800 hrs, and 1500 hrs. coordination meetings are held to facilitate support services (e.g.:
Health Physics, Building services) for the day and to integrate the work which has been planned.
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NRC Ouestion 3 There are no action' items-in the appendices to schedule, indicate status, or track the program discussed in Volume 1. Chapter 4. of transferring fire protection surveillance currently performed by plant operators to the Fire Protection Group.
BECO Resnonse
-The transition of responsibility for the performance of fire protection surveillances from the plant operators to the Fire Protection Group'is scheduled after plant start-up outside the context of the Restart Plan. The plan which currently indicates the schedule and status and tracks this program is the Nuclear Fire Protection Group Long Term Plan.
This issue is tracked as item number seven in this plan.
The purpose in scheduling the transition after plant start-up is to ensure an orderly turn-over, undisturbed by start-up pressures.
1 In addition, fire protection personnel have focused existing resources on commitments which have been scheduled to be accomplished prior to plant restart.
The current schedule for transferring the responsibility for performing fire protection surveillances to the Fire Protection Group is December, 1988.
NRC Ouestion_4 There is no discussion in the Restart Plan on the adequacy or effectiveness of High Radiation Area control.
BECO Resnonse Effectiveness in the control of High Radiation Areas was identified as an area of concern by review of Radiological Occurrence Report (ROR) trends as described in the Radiological Action Plan (Action 02-603-02). Action was taken to restrict the handling of Locked High Radiation Area keys to Radiation Protection personnel for all work activities except non-routine plant operations. A process of continuous access point monitoring and double verification of door closure upon final exit has been initiated.
A directive from the Station Director to all site personnel has reemphasized the importance of individual responsibility and outlined the disciplinary policy for future violations.
Since implementation of these controls, the number of ROR's related to control of High Radiation Areas for the subsequent three months dropped by 90% compared to the previous three month period.
Effectiveness of control has been achieved. Close attention to this trend indicator will continue as described in the Radiological Action Plan.
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EC_ Question 5 There are no action items assigned or discussion of trending performance and/or measuring effectiveness of the completed action items in Appendix 10, Issue 02-009, "Improve the radiological performance of Pilgrim Station personnel."
BECO Resoonse Improvement of the radiological performance of Pilgrim Station personnel is addressed in a continuing fashion by and comprehensively addressed within the Radiological Action Plan (RAP). This plan was prepared as a result of self-assessments at the completion of the prior Radiological Improvement Program effort.
The status of RAP actions are contained in Tab 7 to the Restart Plan, Volume 2, Rev. 1.
NRC Ouestion 6 How do the work stoppage during the week of November 9, 1987; the Loss of Offsite Power Augmented Inspection Team findings; and, th0 recent numerous Engineered Safeguards Feature actuations relate to the Haterial Condition Improvement Action Plan (MCIAP) as discussed in Volume 1. Chapter 4? Has BECo evaluated whether any changes to the MCIAP or other programs are necessary because of these events?
BECO Resoonse The first portion of this question pertains to how recent events relate to the Material Condition Improvement Action Plan.
As part of the investigations of the events leading to the work stoppage of November 9, 1987 and of the Loss of Offsite Power (LOOP)
BECo determined that common threads existed.
The common threads
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involved: (1) planning, and (2) supervision of the activities of station personnel. Many of the investigations following specific Engineered Safety Features (ESF) actuations have resulted in the identification of these same common threads.
Many of these recent events relate to the programmatic improvements of the long term MCIAP actions.
The actions related to improvement of the planning and supervision of activities are in progress and are scheduled to complete over the next several months.
The existing MCIAP issues and long term actions that will assist management in preventing or minimizing the occurrence of similar events are:
The long term or;anizational and staffing improvements outlined in thn actions of issue 03-001.
The performance standards improvements of issue 03-005.
The supervisory development policy of issue 03-011.
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o The management feedback and MR scheduling improvements identified in issue 03-012 and improvements to the MR process outlined in issue 03-013.
The maintenance planning improvements of issues03-016 and 019.
The work assignment improvements of 03-020.
Development of an automated maintenance data base in accordance with issue 03-027.
Preventive maintenance improvements of 03-028.
The second portion of question number 6 pertains to whether Boston Edison has evaluated the need to change the MCIAP or other programs because of these events.
BECo has evaluated whether changes to the MCIAP or other programs are necessary.
The results of those evaluations are summarized as follows:
a)
A Hork Stoppage "action plan" was developed using a data base file similar to the MCIAP and actions a7e in progress or
- complete, b)
The results of the BECo LOOP investigation and the AIT findings were incorporated into the Restart Plan Appendix 10 listing and the required actions are in progress or complete, c)
To date no required changes to the MCIAP in the above discussed areas have been identified, but reports of critiques and other problem identification processes are reviewed to identify possible programmatic items requiring MCIAP issue or action development.
M C Ouestion 7 Appendix 10, Issue 03-940-01 on the evaluation of procedures for receiving vendor supplied information and providing recommendations to correct identified problem areas has a due date of restart plus 240 days.
This milestone appears excessive for the indicated action. What is the status of improving control of vendor supplied information?
BECO Resoonse The Appendix 10 Action Item 03-940-01 encompasses all vendor technical information.
BECo has a veador technical information control program which is implemented by several groups and has been inspected by the NRC and audited by our QA Department with favorable results.
The elements of the vendor technical information program include the Operating Experience Review Program, which provides centralized control for vendor technical information generated by INP0 and our NSSS supplier (General Electric Company), the Regulatory Affairs and i
Programs Division's control of information generated by the WRC regarding plant equipment supplied by venc' ors, and vendor information from other sources which line organizations evaluate via existing processes.
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i The industry has endeavored for several years to' develop r
recommendations for integrated vendor technical information control.
l The approach we plan to.use will capitalize on the indu try's progress. We intend to consider key elements of the NUTAC (Nuclear 4'
Utility Task Action Committee) Vendor Equipment Technical Information l
Program (VETIP) INPO 84-010 dated March 1984.
The result will be a i
centralized approach to implement a VETIP at BECo.
The schedule for Appendix 10 Action Item 03-940-01 was developed considering the fact that the programs / processes listed above provided adequate interim assurance that vendor information has been sufficiently implemented to support plant operation.
Accordingly, our schedule of restart plus 240 days was based on the magnitude of the effort to fully implement an integrated VETIP, recognizing the competing priorities to support plant restart and consid6 ring the need to accomplish this effort with our own personnel.
NRC Ouestion 8 Appendix 10 Issue 03-905-08 discusses an evaluation of the motor operated valve failure analysis reports for adequacy. What followup actions and schedule will be developed from this evaluation?
BECO Response-The effectiveness evaluation of the MOV Program commenced in March 1988 upon the completion of the associated outage work activities.
This 4
review is scheduled to conclude June 17, 1988. The recommendations and improvement findings will be incorporated into the MOV Preventive i
i Maintenance Program for RFO-8. Should significant follow-up actions result from the effectiveness evaluation, a modified response to this question will be provided including both the recommended follow-up l
actions and schedule for implementation.
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f NRC Ouestion 9 i
Why is the schedule for Maintenance Group performance trending system, Appendix 10, Issue 03-906-02, tied to restart? What is the current i
status of this system?
BECO Resoonse This item should have been categorized as a CONTINUING item as defined in Appendix 10.
The Maintenance Group Performance Trending System has been implemented as a manEgement tool to focus awareness on the performance indicators, and is published on a weekly basis. Action l
item 03-906-02 was closed on 02/08/88, after repeated monthly j'
evaluations of coatinued effectiveness.
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NRC Ouestion 10 Hhile a few specific procedure updates appear as action items and the legibility of drawings is discussed in Appendix 10 Issue 06-003, how will BECo ensure all procedores and drawings have been reviewed for adequacy and updatoct (if necessary) orior to restart?
BECO Responig This question has two major elements.
The first element relates to procedural adequacy and the second element relates to drt. wing adequacy.
The BECo Response addresses each element separately.
Procedure Adeauacy The processes in place at the PNPS to ensure procedure adequacy for plant restart are (1) the procedure validation process, (2) the two year review process required by ANSI N18.7-1976 and (3) the recent administrative requirement that drawing changes be appropriately tied to the procedure change process.
Procedures are also reviewed for adequacy prior to implementation.
Drawina Adeauacy Drawing adequacy for the safe operation of PNPS is ensured by, (1)
Engineering procedures requiring design drawings to be updated to reflect design changes, (2) the records management system identifying for retrieval the current official revision of all drawings, and any outstanding design change modifications not yet incorporated, and (3) walkdowns of plant systems which have been performed to ensure drawings used on a daily basis by plant operations personnel are current and adequate.
i Desian Chance Drawina Uodate NED procedures require that drawing changes be issued through the Plant Design Change (PDC) process. After modification implementation, these drawings are updated to reflect the as-built design change and issued as an official "E" revision.
Additionally, the PDC lists drawings affected by the change (but not needed for modification implementation) so that these may also be updated and re-issued.
The PDC drawing update effort is prioritized so that drawings which may be used on a daily basis by plant operations personnel are updated first.
These so-called "Priority" drawings must be issued as an official "E" revision prior to operational turnover of the system.
Non-priority drawings are updated to reflect as-built design changes after system tJrnover.
System Halkdowns for Drawing Validation At the time these drawing update requirements were formally introduced (1984), it was recognized that previous design char.ges may not have been fully incorporated on official "E" revisions of drawings.
The effort to confirm drawing adequacy included walkdowns of certain Priority drawings used most frequently by operations and maintenance personnel (e.g. P&ID's).
The walkdowns resulted in the identification and correction of drawing discrepancies on these drawings.
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In addition, a specific procedure was developed to provide for a systematic review of all design changes from initial plant startup through refueling outage #6, Approximately 13,000 drawings have been revised under this program.
Records Management A system user has access to a complete picture of the curront design status of any plant structure, system, or component by use of the Document Control Centers managed by the Records Management Division.
Summary In summary, Boston Edison has undertaken a comprehensive series of measures (e.g., design change drawing update, records management and the corrective action program) which provide continuous controls to ensure drawing adequacy.
NRC Ouestion ?.1 There is no action item or discussion in Volume 1 or Volume 2. Appendix 10, Issue 07-001 of scheduling and tracking the technical training of BECo security personnel.
This appears necessary to ensure the new hires can b6 fully utilized and, in the interim, assigned duties and responsibiliJies commensurate with their training and qualifications.
EECO Resooaig The Nuclear ',ecurity Section has developed a training program for security menagement outside the context of the Restart Plan.
The program was designed specifically for the Security Shift Supervisors.
However, other BECo and contractor security supervisory personnel also attend the training.
This training covers the following subjects:
PNPS Security Plan Safeguards Contingency Plan Security Force Training and Qualification Plan Implementing Procedures (for the three plans)
Safeguards Event Report (10 CFR 73.71)
Protection of Safeguards Information (10 CFR 73.21)
Outies and Responsibilities of the Contract Security Force Supervisory Training (commensurate with their Duty Positions)
The completion date for training all current Security Shift Supervisors is scheduled for April 29, 1988.
The new Administrative, Compliance and Technical positions were filled with individuals who were already quriified and experienced in their respective positions. Additionally, the more recent hires to fill the Security Shift Supervisor positions all have a nuclear security background.
Existing security supervisory personnel are qualified for the positions they fill, i
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F-NRC Ouesti @_12 Mith respect to Appendix 10 Issue 07-002-11, what is the new completion schedule for the access control modifications?
BECO Response The planned access control modifications at the Main Access Point which include installation of x-ray equipment for package searches and full longth tJrnstiles for added protection are scheduled for completion by September 30, 1988.
NRC Ouestion 13 There is no action item or discussion in Volume 1 or Volume 2 Aopendix 10, Issue 10-002, of a training plan for management and technical new hires.
EECO Resoon.s1 Boston Edison is in the process of restructuring and expanding its supervisory and management training programs outside the context of the Restart plan.
The new structure includes four component programs:
New 2xempt Orientation New Supervisor Orientation Management-Supervision Initial Management-Supervision Continuing New management employees are required to participate in New Exempt Orientation, normally within the first three months of their employment. The content of this program includes, but is not limited to the following topics:
Nuclear Organization Safety Administration Fire Protection Plan Recorde Management Housekeeping Policy Nuclear Regulatory Affairs Conduct of Operations Quality Assurance & Corrective Action Radiological Protection /ALARA Planning and Scheduling This program is instructed by the subject matter experts and is designed to give the staff sufficient skill and knowledge to permit them to function efficiently.
They are also given the name of a cor, tact person in each area should they require assistance.
New supervisors will also participate in the New Supervisor Orientation program and Management-Supervision Initial training.
The format of the New Supervisor Orientation progra.n is the same as the New Exempt Orientation program.
Management-Supervision Initial is a fcrmal program to teach basic supervisory skills.
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Management-Supervision Continuing is offered to all managers and supervisors on an "as-needed" basis.
Identification of the different programs is accomplished normally through the use of a needs assessment form which Nuclear Training circulates to coincide with the company's annual developmental reviews.
The results of the assessment are analyzed and an annual plan esttblished based upon the frequency of response and perceived need.
On the technical side, we have an INPO-accredited program entitled Technical Training for Staff and Managers.
This program is coordin 7 -
by the Technical Training Section and is targeted for a wide variety of technical personnel.
In addition to initial training, there is a program of continuing training that ranges in length from 8 to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> per year.
E C Ouestion 14 The NRC disagrees with the change made in Appendix 11, Page 19, and has concluded lesson plans are necessary for the EAL training.
(Based on our February 22 teleconference, we believe BECO concurs with our position).
BECO Resoonse Lesson plans for training on the new EAL's are currently being prepared.
This training will be conducted during Session VIII currently scheduled for May 2,1988 of the Licensed Operator Requalification Training (LORT) Program.
NRC Ouestion 15 Appendix 2, "Level I RFO-7 Schedule" and Appendix 5 "Performance Excellence Indicators" need to be periodically updated and distributed to interested parties.
BECO Response Various indicators, including the Performance Excellence Indicators, and others now useful to management are updated weekly.
These various indicators are widely distributed and displayed on site bulletin boards.
The status of these performance indicators will be included in the Final Report of Management Self-Assessment of Readiness to Restart which will be provided to the NRC and interested parties.
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