ML20151T276

SALP Rept 50-293/87-99 for 870201-880515.Mgt Initiatives Generally Successful in Correcting Staffing,Organization & Matl Deficiencies.Programmatic Performance Improvements Evident in Areas Previously Identified as Weaknesses

ML20151T276
Person / Time
Site:	Pilgrim
Issue date:	07/27/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151T273	List: ML20151T268 ML20151T276
References
50-293-87-99, NUDOCS 8808160306
Download: ML20151T276 (72)

See also: IR 05000293/1987099

Text

{{#Wiki_filter:- _ _ _ _ _ _ _ _ _ . , g . ENCLOSURE SALP BOARD REPORT = U. S. NULLEAR REGULATORY COMMISSION REGION I -- SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-293/87-99 BOSTON EDISON COMPANY PILGRIM NUCLEAR POWER STATION ASSESSMENT PERIOD: FEBRUARY 1, 1987 - MAY 15, 1988 BOARD MEETING DATE: JULY 5 and 6, 1938 , l p ADO K O O f[[ G .

. ' $ . TABLE OF CCNTENTS Page 1.0 INTRODUCTION ............................................. 1 1.1 Purpose and Overview ................................ I 1.2 SALP Board Members .................................. I 1.3 Background .......................................... 2 2.0 CRITERIA ................................................. 7 3.0 SUMMARY OF RESULTS ...................................... 10 3.1 Overall Facility Evaluation ........................ 10 3.2 Facility Performance .. ............................ 12 4.0 PERFORMANCE ANALYSIS .................................... 13 4.1 Plant Operations ................................... 13 4.2 Radiological Controls .............................. 18 4.3 Maintenance and Modifications ...................... 24 4.4 Surveillance ....................................... 29 4.5 Fire Protection .................................... 33 4.6 Emergency Preparedness ............................. 36 4.7 Security and Safeguards ............................ 38 4.8 Engineering and Technical Support .................. 43 4.9 Licensing Activities ............................... 47 4.10 Training and Qualification Effectiveness ........... 50 4.11 Assurance of Quality ............................... 53 t 5.0 SUPPORTING DATA AND SUMMARIES ........................... 57 5.1 Investigation and Allegations Review ............... 57 5.2 Escalated Enforcement Actions ...................... 57 , 5.3 Management Conferences ............................. 58 5.4 Licensing Actions .................................. 59 E.5 Licensee Event Reports ............................. 63 TABLES Table 1 - Tabular Listing of Licensee Event Reports by Functional Areas Table 2 - Inspection Hours Summary Table 3 - Enforcement Summary ' l Table 4 - Pilgrim SALP History Tabulation Table 5 - Management Meeting and Plant Tour Summary i i I - - -

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1 . 1.0 INTRODUCTION 1.1 Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an inte- grated NRC staff effort to collect observations and data on a per- iodic basis and to evaluate licensee performance. The SALP process is supplemental to the normal regulatory processes used to ensure compliance to NRC rules and regulations. It is intended to be suf- 1 ficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to licensee management in order to improve the quality and safety of plant operations. An NRC SALP Board, composed of the Staff members listed in Section 1.2 below, met on July 5 and 6, 1988 to review the collection of performance observations and data in order to assess the Boston Edison Company's (BECo) performance at the Pilgrim Nuclear Power i Station. This assessment was conducted in accordance with the guidance in NRC Manual Chapter 0516, "Systematic Assessment of Licensee Parformance". A summary of the guidance and evaluation criteria is provided in Section 2.0 of this recort. This report is the SALP Board's assessment of the licensee's safety performance at the Pilgrim Nuclear Power Station for the period i February 1,1937 - May 15,1988 . The summary findings and totals reflect a 15 month assessment period. i ' 1.2 SALP Board Members 1 Chairman i S. J. Collins, Deputy Director, Division of Reacter Projects (DRP) Members W. F. Kane, Director, DRP - ' , J. T. Wiggins, Chief, Reactor Projects Branch 3, DRP A. R. Blough, Chief, Reactor Projects Section 3B, DRP J. P. Durr, Chief. Engineering Branch, Division of Reactor Safety (DRS) G. L. Sjoblom, Acting Director, Division of Radiation Safety and ' Safeguards (DRSS) R. R. Bellamy, Chief, Facilities Radiological Safety and Safeguards Branch, DRSS D. H. Wessman, Director, Project Directorate I-3, Office of Nuclear , Reactor Regulation (NRR) D. G, Mcdonald, Licensing Project Manager, NRR C. C. Warren, Senior Resident inspector, Pilgrim Nuclear Power - Station (PNPS), DRP 4 . .

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' J. J. Lyash, Resident Inspector, Pilgrim NPS, CRP T. K. Kim, Resident Inspector, Pilgrim NPS, DRP T. F. Dragoun, Senior Radiation Specialist, DRSS G. C. Smith, Safeguards Specialist, DRSS R. M. Gallo, Chief, Operations Branch, DPS A. G. Krasopoulis, Reactor Engineer, DRS T. Kosby, Reactor Engineer, DRS 1.3 Background , A. Licensee Activities ' The plant has been shut down since April 12, 1986 for mainten- ance and to make program improvements and remained shut down throughout this assessment period. The reactor was defueled on February 13, 1987, to facilitate extensive maintenance and

modification of plant equipment. The licensee completed fuel i reload on October 14, 1937. The reactor vessel hydrostatic test and the containment integrated leak rate test were also com- pleted sut.cessfully.

Since the end of the last SALP period there have continued to be extensive management changes at Boston Edison that affect Pilgrim. The licensee hss aggressively recruited experienced personnel from outside sources. A new Senior Vice President assumed responsibility for the nuclear organization at the beginning of the period. The licensee's organizational struc- ' ture was also sig..ificantly altered several times. Recent changes have more clearly defined the permanent ensite organiza- ' tional structure. Essentially' all key management positions had , been filled with permanent employees by the close of the period. The licensee developed several integrated action and testing plans to evaluate the readiness of plant management, staff and

hardware to support restart. These include the Restart Plan, Material Condition Improvement Action Plan, Radiological Action Plan and Power Ascension Test Program. In addition, tne licen- see performed a self assessment near the end of the SALP period to identify plant issues cnd evaluate the effectiveness of implemented improvement actions. , 1 I . -

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l ,,. i - t ! 4 3 . . I - 4 i , L During the assessment period the licensee completed extensive

l plant hardware and procedure modifications. The licensee's ' i Safety Enhancement Program included addition of a third emerg- ency diesel generator, containment spray header. nozzle changes, [ installation of a backup nitrogen supply system, and additional t protection features for anticipated transient without scram, t i Steps were aise taken toward installation of a direct torus vent i system and installation of a diesel driven fire pump tied to the ! ' residual heat removal system. License exemptions and modi- ' $ j fications to the fire protection program and equipment to bring i the plant into full compliance with 10 CFA 50 Appendix R, and to j4 improve reactor level instrumentation were completed. The , facility Emergency Operating Procedures were also upgraded to - ' incorporate Revision 4 of the Boiling Water Reactor Owners Group ' Emergency Procedures Guidelines. ' ' - i j On March 31, 1987, the station experienced a loss of offsite , i power during a storm when a static line broke and fell onto the ' conductors at a location several miles from the site. Offsite i -f power was restored within 45 minutes. A second loss of offsite ! i power event occurred on November 12, 1987 due to excessive ice i j r,nd snow accumulation on' the transm'ssion system during a severe i ! winter storm. This event was comilicated by a lockout of the j plant startup transformer, the removal of one of the ! emergency diesel generators from service due to maintenance l concerns and the limited availabil;ty of instrument air. A t ' ! source of offsite power was reestablished about 21 hours after ! ] the initial loss. An NRC Augmented Inspection Team was

dispatched to the site in response to this event. I i

On November 9, 1987, the licer.see as a conservative measure l ' halted ongoing maintemce rnd modification work at the station { af ter determining that several incidents which occurred during i i the weekend of November 7 and 8, 1987, raised concerns regarding i l the control of ongoing work activities. The licensee's Senior ! Vice President-Nuclear directed that ongoing maintenance and j , i modification work onsite be suspended, and contractor craft '

personnel were instructed to 1 cave the site and were directed - not to report for work until November 12, 1987. The licensee ) subsequently formed eight teams of engineering and management

personnel to perform detailed evaluations of each incident prior j to resuming station work activities. 4 4 On February 11, 1988, the control room received a report of a I fire in a contaminated area of the machine shop. The licensee conservatively declared an Unusual Event. The fire was confined j to a small area and was identified as burning insulation from a ' ! h6at-treating machine which was being used in the machine shop. ! The fire was extinguished by the plant fire brigade with no j olant damage noted, and the Unusual Event was secured. 1 1 ) 1 ) i I

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4 , l Operator licensing examinations were conducted on two occasions during the period. A total of two senior reactor operators and 14 reactor operator candidates were examined with all candidates successfully completing the examinations. In December 1986, the Secretary of Public Safety for the Common- i wealth of Massachusetts (Charles V. Barry) submitted a report to Governor Dukakis assessing the status of offsite emergency pre- parciness for the Pilgrim station. The report identified several problems with the existing response program. FEMA per- formed a self-initiated review of the Pilgrim emergency response , plan and on August 5, 1937, provided its report to the Common- wealth. FEMA identified fix deficient areas and withdrew its interim finding that Massachusetts offsite emergency planning

and preparedness were adequate to protect the public health and safety in the event of an accident at Pilgrim. The NRC reques- ' ted the licensee to provide its plans and schedule for working with state and local organizations to resolve the deficiencies, i The licensee submitted an action plan to address the deficien- cies on September 17, 1987, A progress report issued October 15, 1987 by Charles V. Barry notes that, while substan- tial progress had been made in some areas, adequate plans for response to an accident at Pilgrim did not exist and substantial , work remained to be done. At the close of the assessment ' period, the licensee was actively working with the Commonwealth I and local agencies to address the deficiencies and upgrade the emergency plans. ,

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5 . B. Inspection Activities Confirmatory Action Letter (CAL) 86-10 was issued in April,1986 in response to a series of operational events. The CAL initially required that the licensee address these events, and was subsequently extended in August, 1986 to include resolution of programmatic and management concerns. In addition the CAL stated that the NRC Regional Administrator's approval would be required prior to restart. The CAL remained in effect through- out this assessment period. Considerable inspection resources were expended at Pilgrim dur- ing this assessment period. The resident staff has been main- tained at three inspectors. During the fifteen month assessment period, over 9698 hours of direct NRC inspection were performed (7758 hours on an annual basis). This represents a 43 percent increast above the previous

essment period, and is signifi-

cantly in excess of that normally allocated to a single unit site. A detailed breakdown of the total inspection hours into SAlp functional areas is included in Table 2. Senior NRC management involvement was substantial during the period. Early in the assessment period, a Ptigrim Restart Assessment Panel was formed which consists of senior management from the NRC Office of Nuclear Reactor Regulation (NRR) and Region I. The panel generally meets biweekly to coordinate the planning and execution of NRC activities, and to assess the results of these activities to provide an independent judgement of the plants readiness for operation. A serias of management meetings to discuss the licensee's progress and proposed pro- grams were also held. Frequent site tours by NRC Commissioners, the Director of Nuclear Reactor Regulation and the Regional Administrator were conducted. NRC senior management partici- -

pated in numeroua public meetings and interacted extensively with local, state and federal officials. The NRC conducted public meetings in Plymouth to receive public comments on the plan. The staff's assessment of the comments and concerns received on the Restart Plan was presented to the public during a followup public meeting. A chronological listing of manage- mant meetings and tours is included as Table 5. On July 15, 1986, Massachusetts State Senator William B. Golden and others filed a 10 CFR 2.206 petition regarding Pilgrim. Af ter review by the NRC, the contentions raised in the petition regarding containment deficiencies and inadequacies in the radiological emergens response plan were denied. A decision regarding the management deficiencies was deferred to a subse- quent response. This information was transmitted to the peti- tioners by letter dated August 21, 1987. Three of the petitioners filed an appeal in federal court on October 1, 1987.

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I l On October 15, 1987, Massachusetts Attorney General l l James M. Shannon filed a 10 CFR 2.206 petition, on behalf of his l l office and Governor Michael S. Dukakis, requesting an order to

show cause why Pilgrim should not remain shutdown until a full l adjudicatory hearing resolves the issues raised in the petition. ! The petition cited evidence of continuing managerial, Mark I ! - , containment, and emergency planning deficiencies and requests f ' that the licensee also be required to perform a probabilistic l risk assessment (PRA). In. a response dated May 27, 1988.- the

NRC denied the petitioners request that a PRA regarding the Mark ' I containment be required and deferred decisions regarding emergency planning and management issues. During the assessment period nine NRC team inspections were , conducted: j 1. Appendix R Fire Protection Program Review l 2. Plant Modification Program Review j 3. Plant Effluent and Environmental Monitoring Program Review -

4 Augmented Inspection Team (AIT) Review of the loss of off- l site power event on November 12, 1987 ! 5. Annual Emergency Plan Exercise Observation l 6~ Onsite Electrical Distribution Adequacy Review i 7. Emergency Operating Procedures Review ! 8. Maintenance Program Review 9. In plant Radiological Controls Review l An NRC Order issued in 1984 requiring the 1.icensee to implement a Radiation Improvement Program was closed during the period 1 based on the results of a special inspection and other program inspections which indicated that all terms of the Order had been

satisfactorily completed. Two operator licensing examinations } were also conducted. An enforcement conference was held on ! September 9, 1987 to discuss security related matters. Enforce- ' ment action on these issues is still pending. Tabulations of inspection activities and associated enforcement actions are contained in Tables 2 and 3. I , . . . m-

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! l 7 . ' . 2.0 CRITERIA

Licensee performance is assessed in selected functional areas, depending l l upon whether the facility is in a construction, preoperational, or opera-

ting phase. Functional areas normally represent areas significant to ' nuclear safety and the environment. Some functional areas may not be assessed because of little or no licensee activities, or lack of meaning- ful observations. Special areas may be added to nighlight significant observations. l This report also discusses "Training and Qualifim io Effectiveness",

i "Assurance of Quality" and "Engineering and Technica> .tsort" as separate j functional areas. Although these topics, in themsei.., are assessed in , > the other functional areas through their use as crit.c 's, the three areas provide a synopsis. For example, assurance of quality effectiveness has been assessed on a day-to-day basis by resident inspectors and is on integral aspect of specialist inspections. Major factors that influence qua'. 6y, such as involvement of first line supervision, safety committees, quality assurance, and worker attitudes, are discussed in each area. l I One or more of the following evaluation criteria were used to assess each l functional area. 1. Management involvement and control in assuring quality 2. Approach to the resolution of technical issues from a safety stand- point ' 3. Responsiveness to f4RC initiatives 4. Enforcement history 5. Operatinnal events (including respon<a to, analyses of, and correc- . tive actions for) ' 6. Staffing (including management) 1 7. Training and Qualification Effectiveness ' i i Based upon the SALP Board assessment, each functional area evaluated is classified into one cf three performance categories. The definitions of these performance categories are:

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e 8 l . Category 1. Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance sub- stantially exceeding regulatory requirements. Licensee resources are ample and effectively used so that a high level of plant and person- nel performance is being achieved. Reduced NRC attention - may be apprcpriate. Category 2. Licensee management attention to' and involvement in the performance of nuclear safety or safeguards activities are good. The licensee has attained a level of performance above that needed to meet regulatory requirements. Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved. NRC attention may be maintained at normal - level s. , Category 3. Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not suf- ficient. The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirements. Licensee resources appear to be strained or not effectively used. NRC atten- tion should be increased above normal levels. The SALP Board also assesses a functional area to compare the licen- see's performance during the last quarter of the assessment period to that during the entire period in order to determine the recent trend for each functional area. The SALP trend categories are as follows: Improving: Licensee performance was determined to be improving near the close of the assessment period. Declining: Licensee performance was determined tn be declining near the close of the assessment period and the licensee had not taken meaningful steps to address this pattern. A trend is assigned only when, in the opinion of the SALP Board, the trend is significant enough to be considered indicative of a likely change in the performance category in the near future. For example, a classification of "Category 2, Improving" indicates the clear potential for "Category 1" performance in the next SALP period. It should be noted that Category 3 performance, the lowest Category, represents acceptable, although minimally adequate, safety perform- ance. If at any time, the NRC concluded that a licensee was not achieving an adequate level of safety performance, it would then be incumbent upon NRC to promptly take appropriate action in the interest of public health and safety. Such matters would be dealt with independently from, and on a more urgent schedule than, the SALP process. s

- . . . . . . . . ... . - - .. 9' - It should also be noted that the industry continues to be. subject to rising performance expectations. For example, NRC ' expects licensees to actively use industry-wide and plant-specific operating experience ~ to effect performance improvement. TF ,,~. a licensee's safety per- formance would be expected -to show improvement over the years' in order to maintain consistent SALP ratings. i i l l

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. . . , 10 . 3.0 SUMMARY 3.1 Overall Facility Evaluation The 1985 SALP determined that programmatic and performance weaknesses existed in several functional areas and that improvements were in- hibited by the lack of resolution of factors which in turn depended heavily on management attitudes and aggressiveness of followup. The 1986 SALP acknowledged that, although some improvements were made, the lack of a clear organizational structure,- recurring management changes, and chronic staffing vacancies delayed the establishment of a stable licensee management team at the plant and inhibited progress during the period. These problems' manifested themselves as Category 3 performance ratings in the Radiological Controls, Surveillance, Fire Protection, Security and Assurance of Quality functional areas. Throughout this 1987-1988 SALP period the facility was maintained by BECO in an outage condition to make major plant facility modifica- tions and complete a major equipment refurbishment progran. At the beginning of the assessment period the licensee made the most significant of numerous personnel changes when a new Senior Vice President-Nuclear was hired and his presence established on site. Additional personnel and organizational changes continued throughout the assessment period with the most substantial reorganization being completed in February, 1988. Although the organization in its present form did not formally emerge until late in the assessment period, many of the functional reporting chains have been in place for some time and appear to be functioning well. Allocated staffing j levels in the new organization are significantly higher than in the cast and the licensee has been generally successful in recruiting efforts. As a result of these transitions some individuals are relatively new to their positions and in some cases do not have extensive operating Boiling Water Reactor expertise. The licensee has been aggressive in addressing most areas of known program weakness. However, implementation of certain program and organizational improvements was delayed due to the high p riority placed on proceeding with outage work. Surveillance program j responsibilities have been consolidated in the Systems Engineering ' Group and program weaknesses have been addressed. Hardware issues in both the fire protection and security areas have been corrected and performance in these areas has improved. Health Physics program problems identified in the previous SALP report continued to exist during the first half of this assessment period, however recent , significant management attention and resource commitment to this area led to improved performance over the last part of the assessment period. Maintenance program improvements were implemented only , ._ , - ---- - , - , , .- - . .. - , . - - . . - , - , .- - - --

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i l . . , 11- . .recently and their effectiveness remains under review.' Licensee development of .the Material Condition Improvement Action Plan, Restart Plan and performance of an extensive self assessment in response to the NRC August .1986 ~ Confirmatory Action letter are evidence of the licensee's ability to self-identify and understand facility performance and material condition. The action plans to - implement these necessary improvements .and management's ability to effect lasting performance change remained under review at the close- of the assessment period. In summary, licensee efforts have been extensive including corporate and site, reorganizations and a new management team .which has undertaken numerous projects and programs to improve plant material condition and enhance programmatic performance. Management initiatives have been generally successful in . correcting staffing, organization and material- deficiencies. Programmatic performance- improvements have been evident in areas of previously identified significant weakness and the licensee's self assessment process has identified areas. where further management attention -is . warranted. In light of the past inability to implement lasting programs which' result in long - term improvements, a continued licensee management , - commitment is needed to confirm that past weakness have been identified and sustain the overall improving trend in performance, l

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.. . . . . . - . -. . - . . . . - - - . j < ,. .s . . - .. 12' . . 3.2 Facility Performance Functional Category Category Recent . Area Last Period * This Period ** Trend 1. Plant Operations 2 2 2. Radiological 3

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Improving Controls 3. Maintenance ar,d 2 2 Modifications - 4. Surveillance 3 2 5. Fire Protection 3 2- 6. Emergency 2 2 Improving. Preparedness 7. Security and 3 2 Safeguards i 8. Engineering and 1- 1 Technical Support , 9. Licensing 2 2 Activities

10. Training and 2 2 Qualification Effectiveness 11. Assurance of 3 2- Quality Outage Management 1

and Modifications Activities j November 1, 1985 to January 31, 1987

February 1, 1987 to May 15, 1988

Not evaluated as a separate functional area; findings relative. to outage

activities are integrated into "Engineering and Technical Support", "Maintenance and Modifications", and other functional areas as appropriate , 1 ! , . - . - - - - - - . . - - - - - - - - - . . - - . - - - - - - - . --- -. ..-. -------.----- ----

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. . , ,, . 13 . 4.0 PERFORMANCE ANALYSIS 4.1 Plant Operations (2178 hours /22 percent) (1) Analysis This functional area is intended to assess the licensee's -per- formance of plant operations. Throughout this assessment perioc' the plant was in an extended maintenance and refueling outage, NRC observations of licensee performance during ~ major plart. activities included reactor core defuel and reload, the reactor vessel hydrostatic test, and the primary containment integrated leak rate test. During the previous SALP period plant operations was assessed as a Category 2. Weaknesses identified included a shortage of licensed reactor operators and lack of- professional support for- the Operations Department. Although the licensee had taken actions to recruit new operators and improve the licensed oper- ator training program, the shortage of licensed reactor opera- tors (R0s) remained a significant problem. The effectiveness in professional staff support for the Operations Department was also not demonstrated due to delays in transferring personnel into the department, and their continuing collateral duties outside the department. During the current assessment period, the licensee's planning and evaluation of their readiness for refueling, the reactor vessel hydrostatic test, and the primary containment integrated leak rate test were well managed. Strong Opuations Department involvement was evident. Plant management and the Operations Review Committee (0RC) exhibited a conservative, safety con- scious approach to these milestones. ORC review of refueling readiness was conducted in a thorough and deliberate manner including line item verification.of the reload checklist. One exception was the licensee's use of Appendix G to the Final Safety Analysis Report to justify conditional operability of equipment needed for refueling. In this case plant management proposed to begin fuel movement with a Standby Gas Treatment System design deficiency uncorrected, by preparing an analysis supporting operability of the sy s tem under restricted condi- tions. Licensee management however, reconsidered this practice when concerns were raised by the NRC. Licensee senior manage- ment support for ORC decisions was visible throughout these major activities. Senior management's presence and direct involvement in activities also demonstrated their commitment to safety and expectations of high standards to the plant staff. .- - -- .- . . . , . - - -

. . .. . . ' 14 . The licensee has taken aggressive actions to resolve the short- age of licensed operators. Improvemants in recruiting and oper- ator training programs have resulted in a significant increase in the size of the operations staff. The number of licensed reactor operators (R0s) increased by 14 during the period to the present total of 23. This contributed to a reduction in routine operator overtime, which had been a chronic past problem. The addition of new licenses to the operations staff is positive. However, additional operating experience will be required before these newly licensed personnel are fully qualified. The'high R0 attrition rate was a major factor in the R0 shortage during the last assessment period. Increased management attention, redut.ed overtime, and higher morale have contributed to maintaining a stable operations organization during this period. The licensee currently maintains a staff of 20 equipment operators and eight of the 20 are scheduled to enter a reactor operator license training class later this year. Continued management support in maintaining a sound and aggressive recruiting and training pro- gram is required to prevent the recurrence of the operator shortage. Despite the improvements in the staffing level, weaknesses con- tinued to exist in attention to detail and in communications'. Several procedural and personnel errors occurred during the refueling, the reactor vessel hydrostatic test, and the contain- ment integrated leak rate test. Immediate actions taken by the operations staff in response to incidents were not always con-- servative. For example, operators continued refueling without stopping to assess a pendant light which was inadvertently dropped onto the reactor core. Problems in the operations area that contributed to the licensee's work stoppage on November 9, 1987 included inadequate. system turnover, valve lineup problems, and poor radwaste system operation practices. Some weakness in coordination and communications between the operations staff and other groups was noted during the loss of offsite power (LOOP) event on November 11, 1987. The lack of clear management directions both in and out of the control room, a somewhat frag- 4 mented recovery effort, and poor communications may have delayed the full recovery from the. LOOP and resulted in inadvertent manual shutdown of one of the emergency diesel generators. As a further example, operator communication during a dry run of the remote shutdown test was also informal and not completely - effective, l 4 i - - . - . - - A

. . . * - 15 . . During previous assessments, informality and poor attitude had been identified as a weakness among the control room staff. The discovery by the ifcensee of non-job related reading material and a card playing machine in the control room in October, 1987 was a further example of.the lack of professionalism and implied inattentiveness to duty. As a result of management attention to this issue, positive trends in the control room atmosphere and conduct were noted during the last quarter of the assessment period. The significant increase in the size of the operations staf f, strict control of operator overtime, and intensive com- munication training also aided licensee management's successful effort to improve operator professionalism. As an example, effective use of the simulator for training .and implementation of control room hardware improvements have enhanced the control room atmosphere. Significant effort has been made by the licensee to provide adequate support staff in the Operations Department. The department was reorganized and the Operations Support Group was created to strengthen effectiveness in identifying and resolving technical issues affecting Operations. The Operations Support Group consists of three staff engineers and six shift technical advisor (STA) positions. The licensee has filled the group manager and senior staff engineer positions and is actively recruiting to fill the other staf f engineer positions. Three additional STAS were hired and trained during this period which increased the total number of qualified STAS to six. This ^ represents an increase of six in the allocated operations sup- port staff with fouc of the positions filled. The reorganiza- tion allowed the Chief Operating Engineer added opportunity to directly oversee operator performance. Operations staff involvement in developing and implementing 'the Emergency Opera- 4 ting Procedures was strong. The licensee s ongoing effort to 4 develop a jumper and lifted lead log and a limiting condition of operation log are additional indications of improving staff ' support in the Operations Department. The licensee's approach to problem investigation and root cause analysis improved significantly during the latter portion of the period. Event critiques led by the Operations Section Manager and root cause analyses performed by the onsite Systems Engi- neering Group were thorough and aggressive. The critique pro- cess also instilled a leadership role for the Operations Department and promoted better communication among interdepart- mental groups. .. - . . . - -

. . . - - . . .$ 16 . The operator training program continued to improve during this assessment period. NRC operator license examinations on May 25, 1987 and December 7,1987 had a 100 percent pass rate. Utilization of the plant specific simulator in requalification training and the new Emergency Operating Procedure training significantly enhanced ' the effectiveness of the training. pro- gram. The licensee's effort to develop and implement'the new Emergency Operating Procedures demonstrated high levels of senior management attention. Reportable events were generally handled acceptably by the con- trol room staff. The levels of detail, technical accuracy, and the overall quality of licensee event reports have improved during the period. Monitoring and maintenance of plant chemistry is the responsi- bility of the Operations Department. The licensee's chemistry department is responsible for plant chemistry, radiochemistry, and the facility radiological effluents control program. The chemistry organization was clearly defined, adequately staffed, and appeared to interface well with other plant groups including the radwaste organization. Chemistry representatives are included in shiftly turnovers with the control room staff. Importent plant chemistry parameters are discussed with station management daily at a morning planning meeting. Surveillance requirements were clearly established and performed on schedule. The licensee is meeting Technical Specification requirements for radiological. ef,fleunt sampling and analysis. Effluent control instrumentation was maintained and calibrations performed in accordance with regulatory requirements. All release records were complete and well maintained. QA audits of this area were comprehensive and technically thorough. The results comparison of NRC radioactivity standards submitted to the licensee for analyses indicated excellent performance by the licersee with all results in agreement. During the analysis of the NRC radioactivity standards, the licensee's chemistry staff demonstrated a clear understanding of the technical issues. In addition, the licensee was responsive to NRC sug- 4 gested practices for program improvements. The licensee's chemical measurement capability was also evaluated twice during the assessment period. The results of the NRC chemical stand- ards indicated good performance with only four of 54 measure- ments in disagreement. The licensee was responsive to NRC sug- gestions for program improvements in this area and also in the area of post accident sample analyses. Licensee management appears committed to providing adequate capital resources to the l i . . - . . . . . . .

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, 17 . Chemistry Department. The licensee possesses state- of the . art chemical and radiochemical laboratory instrumentation, and also maintains a state of.the art chemistry computer data : base for maintaining and trending laboratory data. -The licensee's chem- . istry training program was also reviewed this assessment period. Both the . training and retraining programs appear to be l adequate as indicated by the results of the NRC standards analyses. In summary, the licensee's aggressive recruiting and training program has resulted in a significant increase in the size and ~ effectiveness of .the Operations Department staff, the staffing improvement, strict control of operator overtima, appropriate managernent attention, and intensive communications train)ng all have contributed to a recent trend in positive attitude and professional atmosphere in. the control room. However, some weakness in attention to detail and procedural compliance were noted and require continued attention. The licensee'_s approach to problem investigation and root cause analyses has impro'ved, and is generally prompt and positive. Overall performance in this functional area has improved, particularly during the last quarter of the assessment period. (2) Conclusion Rating: 2 Trend: None Assigned , - . . . . - - - . - - - . - - - - - - . . . . . - - . - - - - - - - . -- . - --- -. - . . . - - - . - . . - . - . . - -

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18 . - 4.2 Radiological Controls (1064 hours /12 percent) (1) Analysis The radiological controls functional area is an ' assessment of licensee performance in implementing the occupational radiation safety, chemistry, radiological environmental monitoring and- transportation programs. In November 1994, the NRC issued a confirmatory order requiring broad scope ' improvements in the licensee's Radiological Controls Program. During the previous assessment period this area was rated Category 3. The NRC review found that some improvement had been made in the radiation safety program. However, significant weaknesses were identified which inhibited further performance improvement. These weaknesses included poor communications, antagonistic working relationships, lack of personnel accountability, poor ALARA performance, ineffective corrective actions, and vacancies in key radiological safety supervisory and management positions. As a result of these weaknesses the NRC confirmatory order was not closed out. Weaknesses were also identified in implementa- tion of Radiological Effluent Technical Specification sur- veillance requirements and the licensee's environmental TLD program. During the previous assessment period, the licensee's transportation program exhibited a decline in performance with three violations being identified. During the current assessment period ther are nine inspections in this area of the occupational radiation safety program. The inspections focused on oversight of outage work, establishment of effective management controls for this area and efforts to close out the NRC Confirmatory Order and associated Radiological Improvement Plan (RIP). In addition, three inspections were performed in the chemistry, transportation, and radwaste systems areas. Radiation Protection The weaknesses noted during the previous assessment period per- sisted through the first half of this assessment period. How- ever, in November, 1987 an inspection found that performance had improved to the point that the November 1984 NRC Confirmatory Order was closed out but, at the same time, acknowledged that additional improvements and continued management attention to these areas were needed. Actions that are planned by the licensee to continue to improve performance such as improved radiological awareness and increased staffing are documented in the licensee's Radiological Action Plan (RAP). Toward the end of this period, the Radiation Protection program organization and staffing levels, a weakness during most of the assessment, improved. The organization, staffing levels, re- .- - . -- - -

". , ' .- l 19 . i ! sponsibilities, accountabilities, and interfaces are now 'well defined. Station management attention to the areas of communi- cations, accountability, morale and the corrective action pro- cess over the last half of the period has improved working re- lationships and communications between other departments and radiation protection. The recently revised Radiation Protection organization. is approximately 90%. filled by permanent personnel. Although the organization and s'.affing are adequate to support the program, the position of Chief Radiological Engineer (Radiation Protec- tion Manager) was recently restaffed w'th a contractor,. several managers have limited commercial nuclear power experience, and many personnel are new to their positions. Performance of this new organization will . continue to be assessed in the future. A well defined training and qualification program has been established. The program contributes to an adequate understand- ing of program requirements with few personne? errors. Training resources are adequate. The radiation protection training program is INP0 certified. New training initiatives are in progress to sensitize management, workers and radiation pro- tection personnel to assure they are aware of the need to minimize all occupational radiation exposure. Examples include training of management or ALARA for plant design changes and providing radiation awareness training to maintenance and operations personnel. Licensee audits and assessments of program implementation- and adequacy have improved. The audits and assessments, augmented by supervisory and management tours, have been generally ade- quate in following program implementation and identifying weak- nesses, particularly toward the end of the period. Technical specialists are used to augment the QA audit teams. Additional QC surveillance of problem areas (e.g. , High Radiation Area key control) has been implemented. However the scope of licensee audits have been principally compliance oriented. There is little external review of program adequacy and performance < relative to the industry. I In the area of Internal Exposure Controls, no significant indi- vidual exposure of personnel during the period was identified. Also, during the major plant decontamination operation, exposure of workers to airborne radioactive material was well controlled. Approximately 90% of the station is now accessible in street - clothes. Licensee ;uantification of radionuclides contr.ined in the NRC whole brdy counting phantom was good. The use of sensitive whole body counting equipment combined with a capability to analyze the data reflects an adequate bioassay capability. Althougn performance in the area of Internal , - _ . . - - - . - - . - , - - - ... ,. , , . - - _ , , ., , _ , , , , - - , - - . . - - , - - - -. , , , -- .

_ . - , . 20 . Exposure Controls has improved, NRC review identified instances where about 1000 individuals had terminated from the site during the period without receiving confirmatory whole body counts. These termination bcdy counts are not required by the NRC but are a normal good- practice at most--reactor sites and are recommended by Pilgrim site procedures. When brought to the licensee's attention they were unaware of the magnitude of these exceptions to the recommended practice, reflecting some weaknesses in oversight of this area. During the assessment period three violations occurred which involved improper control of High Radiation Areas. Although no unplanned exposures resulted, when examined individually, these violations clearly reflect one or more of the previous assessment period concerns. In response, the licensee made certain short term corrective actions and established a task fc ce to review the concerr,s and develop long term corrective actions. The licensee corrective actions for the most recent High Radiation Area access centrol concerns were appropriate, however, these corrective actions were prescribed by meLorandum. The NRC has previously expressed concern regarding imple- mentation of regulatory requirements by memoranda rather than by . the use of formal, approved plant procedures. At the end of the assessment period, procedures were not yet revised to include these corrective actions. An additional weakness involved licensee attempts to resolve a csncern with exposure reports in that, early in the period, NRC identified that the licensee had not sent a number of termination reports to individuals. The licensee instituted a corrective action program, but this matter is still under NRC review. During the latter part of the assessment period, control, over- sight and coordination of in plant activities by the radiation protection department had significantly improved. The number of licensee technicians and first line supervisors was increased. Coincident with this staffing increase, licensee management selectively reduced contractor work force, keeping the most competent performers. The augmentation of first line super- visors combined with the elimination of a large number of con- tract technicians resulted in improved management control and accountability within the department. In the area of radiation exposure, pilgrim Station collective worker doses, calculated as 5 year rolling averages, have his- torically been among the highest in the nation. Some improve- ment was noted in the previous assessment period after a well documented ALARA program was instituted accompanied by a high visibility exposure goals program. Licensee activities during this period resulted in a collective worker dose (1580 person- rem) which was the 51ghest of all domestic power reactors in . . _ _ ._. . _ _ _ _ _ _ _ _ _ . _ _ . _, .-

__ . - _ _ - _ . - . 21 . 1987. Analysis by station management attributes the exposures to an expanded work scope during the prolonged outage with about 20% due to unplanned rework, poor contamination controls, and poor planning. Also, the large out.ber of workers (about 2000) on site during the outage coupled with the high radiation source terms and poor work habits in the plant contributed to the high annual dose. Du. ing the initial part of this assessment period, NRC concerns included lack of understanding of day-to-day work activities due to poor maintenance planning .and inaccurate deaription of work provided to radiation protection personnel which is incorporated into RWPs. Also, RWPs continued to be requested for work that was not performed. Improve- ments in this ar a were noted during the latter half of this assessment period. Management efforts instituted to control exposure inchded hir- ing a large contractor staff to implement ALARA on the job, assigning six Hp/ALARA coordinators to work groups, and imole- mentation of dose saving techniques recommended by the ALARA Committee. The effectiveness of the six coordinators was par- ticularly evident in the areas of maintenance and operations. For example, the use of glove bags to contain contamination dur- ing maintenance has been expanded. Contamination "spill drills" are routinely conducted to prepare operations personnel for dealing with future incidents so that the spread of contamina-

tion can be minimized. NRC review of the selected ALARA goals indicated that they ap- peared to not be challenging *and there was no formal mechanism to incorporate ALARA principles during the design of plant modifications. For example, during the outage the licensee was noted to have rebuilt a number of large valves (e.g., RHR System) without considering the need to reduce stellite, a major ! source of cobalt. During the latter part of the assessment period, the licensee was attempting to formalize a program to conduct ALARA reviews of plant design modifications during the conceptual design phase. A goal of 600 person rem was initially planned for 1988 even though most of the outage work ended in February and a lower goal appeared achievable based upon anticipated radiological work. In addition, there was no long range planning evident to reduce the high general area dose rates at the station. ' Radiological Environmental Monitoring Program Midway through this assessment period an inspection of the licensee's radiological environmental monitoring program (REMP) was conducted. The REMP is administered by the corporate Radiological Engineering Group. The licensee's REMP conforms to Technical Specification requirements. The licensee has made plans for improvement of the annual REMP reports, and improve-

. . . 22 . ments to the meteorological monitoring program even though the licensee's Technical Specifications contain no requirements in this area. In response to a program weaknesses idertified by the NRC during the last assessment period, the licensee has eliminated the environmental thermoluminescent dosimeters TLD system which was in use during the previous assessment period and is now using TL0s supplied by the Yankee Atomic Environ- mental Laboratory. Planned personnel expansion in this area is indicative of the licensee's commitment to continued improvement of the REMP. , Transportation One inspection of the licensee's transportation program was conducted midway through this assessment period. Two Severity Level IV violations were identified. Both violations related to shipments made during the previous assessment period. These violations suggested inattention to technical detail and quality control in the preparation of radioactive shipment records. However, during this assessment period the licensee increased quality control involvement in processing, preparation, pack- aging and shipping of solid radioactive waste. This indicated the licensee's clear understanding of issues relating to causes of the problems and, in addition, the implementation of cor- rective action. The licensee is meeting all commitments to the NRC with regard to training in this area. The licensee has implemented procedures which clearly define the roles of the departments involved in solid radwaste and transportation. Procedures for processing, preparation, packaging, and shipping solid radwaste were adequate. Summary In summary, there was an overall improvement in licensee Radia- tion Protection Program adequacy and performance, particularly j during the last quarter of the assessment period. However man- agement attention is still required to exceed minimum regulatory i requirements in the in plant radiation protection program. Com- munications and working relationships have improvcd. Facilities and equipment have been upgraded. Limited success in 1) upgrading the ALARA Program performance, 2) staff qualifications 1 and stability, and 3) aggressive long term corrective actions ! for High Radiation Area access control were noted. In contrast, licensee performance in the areas of REMP and transportation reflects substantial improvement. These areas, if rated separately, would receive the highest performance rating category. Previous weaknesses regarding radiological effluent techn' cal specification surveillan:e and the environ- mental TLD pragram have been corrected and plans made for ad- ditional progiam impro/ements. The station has substantially upgraded quality control activities in the transportation area. - - - -

i . - . 23 . (2) Conclusion Rating: 3. Trend: Improving. (3) Recommendations Licensee: 1. Continue strong senior management involvement in the in plant radiaticn protection program. 2. Strengthen the ALARA pregram and complete training on program implamentation. @RC: 1. Conduct a management meeting with the licensee to review radiological program status and ALARA program progress. -

. . . i + . . 24 . 4.3 Maintenance and Modifications (2347 Hours /24 percent) (1) Analysis 1 This functional area is intended to assess the licensee'_s per- formance in planning and implementing the station maintenance i program, and in implementing and testing plant modifications. The adequacy of modification design is evaluated under the. Engineering and Technical Support functional area. This SALP period includes the results of the April 25 - May 5, 1988 NRC Maintenance Team Inspection. It does not include evaluation of I the licensee's Restart Readiness Self Assessment, nor does it , evaluate the licensee's response to the Maintenance Team Inspec- tion findings. During the previous - SALP period, plant maintenance performance was assessed as a Category 2 Maintenance staffing was weak . due to first line supervisory vacancies and lack of direct pro- fessional support, hampering programmatic improvements. The .- scheduling of "A" priority maintenance was good, however lower priority maintenance scheduling was weak as demonstrated by the large maintenance backlog. This was particularly evident in the areas of fire protection and security, resulting in equipment unavailability. The maintenance lanning group was effective in validating maintenance requests (MR), but was only marginally effective in planning daily maintenance activities. Maintenance program procedures were considered weak and contained only minimal information. No_ administrative guidance for the newly formed planning and procurement groups was in place, hampering - their inaegration into the process. I During the current SALP period maintenance and modification activities were routinely monitored. Also seven special inspec- tions were ondacted to evaluate the licensee's maintengnce and modification coritrol programs. An Augmented Inspection Team and a special electrical system team inspection also evaluated as- pects of maintenance program effectiveness. Near the close of the SALP period a special maintenance team inspection evaluated the licensee's effectiveness in implementing the program, l Licensee efforts to improve facility material condition during this assessment period have been highly evident. Overhauls of , major plant equipment such as the Residual Heat Removal pumps, High Pressure Coolant Injection pump, and feedwater pumps were successfully completed. Commitment by senior licensee manage- ment to perform these and numerous other equipment overhauls is a positive indication that material improvement has been a licensee priority. ) , , - . . , -- , ,-, -- - - -- - ~ . - -- ,- < - '-v ' -

9 . . 25 . The maintenance section also provided strong support during the November, 1987, extended loss of offsite power recovery effort. The Maintenance Section Manager held meetings to ensure directed and coordinated efforts of the work force and developed plans for an organized approach. Inspector observation of. maintenance task performance in the field indicates that workers are ade- quately trained in that they are generally knowledgeable of assigned activities and their impact on _the plant. Senior licensee management has acted to increase allocated main- tenance staffing, however staffing levels remained a weakness during much of the period. The significant burden of outage activity combined with this weakness continued to delay the progress of program enhancements. Early in the period, first line supervisory vacancies resulted. in a reduction in oversight of field activities. Qualified licensee personnel did not apply for the positions. The licensee aggressively recruited indi- viouals from outside the organization and filled the vacancie2 Three maintenance staff engineer positions were created and filled in an effort to provide maintenance department technical support. These individuals concentrated largely on completion of outa.ge ' . tasks and therefore were not available to develop longer range maintenance program improvements. Late in the period the maw tenance Section Manager and both the Electrical and Mechanic 61

) Division Manager positions became vacant. The licensee fil'e ed i these three vacancies immediately af ter the close of the SAlp period. Turnover and difficulty in recruitment of in-house < personnel continues to be a significant problem at the mainten- ance supervisor level. The licensee compensated for two of ' these vacancies by using contractors. These continuing super- visory staffing vacancies combined with maintenance management turnover resulted in a lack of stability and consistent direc- tion in the maintenance organization. Communications between the maintenance department and other organizational entities has improved significantly. Early in the SAlp period poor communication between the maintenance, radiation protection and operations departments resulted in a large number of radiation work permits requested but not uti- 11 zed, and processing of equipm:nt isolations for maintenance activities which were subsequently delayed. Maintenance prior- ities were not always consistent with operational needs. To i address these issues, licensee management assigned two experi* enced radiation protection technicians to maintenance to assist in job planning and to improve maintenance personnel apprecia- tion of radiological considerations. Two senior reactor opera- tors were assigned to provide direct input to the planning pro- r cess, and to act as liason between operations and maintenance. - _- __ . _ - -, - . . . .- ~ . - . -

' . .. i 26 . These actions resulted in substantial communications improve- ' ment, and more efficient processing of maintenance and modifica- tions tasks during the latter part of the assessment period. ' Ouring the period the licensee continued to devote resources.to the improvement of the planning and scheduling function. S ta f f- ' ing of the maintenance planning group was augmented by the ad- dition of significant contractor support. At the close of the SALP period all maintenance planning staff. positions aad been i filled, with five positions filled by contractor personnel.

This group actively collected existing FRs and verified spare parts availability but was not effective in developing inte- grated maintenance schedules or ensuring consistent high tech- . nical quality in maintenance packages. Licensee management also created the temporary Planning and Restart Group to assist in ' establishing outage scope and schedules. The functions of this group were later incorporated into the permanent line organiza- tion under the Planning and Outage Manager. The Planning and Outage Group appeared to be increasingly involved in developing and tracking longer term work schedules by the close of the SALP l period. Continued attention to developing and implementing effective maintenance schedules, and to improving the detail and quality of maintenance work packages is needed. In the previous SALP period, a large backlog of low priority maintenance had resulted in inoperable fire protection and . l security equipment, and reductions in operational flexibility d due to equipment unavailability. During this assessment period, ) the licensee has effectively focused attention on defining and l processing this large backlog of work. Recent completion of the

major outage activities allowed further reductions. Late in the period the licensee directed increased effort at improving general equipment condition. Management frequently toured the station, evaluating the effectiveness of these efforts. How- ever, because of a lack of sensitivity caused in part by con- centration en backlog reduction, less significant maintenance i deficiencies and poor maintenance practices were not always ' promptly addressed. An example of this is the poor condition of station batteries identified during a NRC team inspection. Several routine inspections and a maintenance team inspection near the end of the SALP period found that maintenance program ' procedures and work instructions continued to be a significant weakness. Work control and implementation practices were not clearly delineated in approved procedures or other directives as evidenced by the excessive delay in issuing the Maintenance Manual. Maintenance requests contained little detail of the as-found condition, repairs effected and post-maintenance test- ing performed. This hindered subsequent root cause evtluations and reviews. Instructions provided to maintenance technicians

. , _ _ _ _ - -

1 , .l .- l 27

of ten were not sufficiently detailed. to ensure proper perform- ance of the task, and to document activities such as placement { of jumpers or lif ted leads. For example, a series of engineered safety feature (ESF) actuations were caused by lack of adequate j instructions and planning of electrical relay replacements. ! There was also no effective process for management review of completed maintenance packages. A number of improvements had been implemented such as maintenance package checklists, worker prejob briefings and use of a temporary procedure to document

lifted leads, but appropriate maintenance process procedures j were not revised to reflect t te changes. For much of the SALP { period, actions taken in respuse to NRC concerns were directed at correcting problem symptoms and were not sufficiently com- prehensive in nature. The licensee deferred the formal ad- ' dressing of program weaknesses in this area and the application of interim improvements has been inconsistent and not wholly , effective. Shortly af ter the assessment - period, licensee at- tention to this areas intensified and major program improvements were initiated. , The licensee's post-maintenance test program was not clearly defined. No clear guidance for establishment of post-mainten- ance testing requirements existed. In one case MRs for exten- i sive repair and retermination of electrical cables were desig- ' nated as not requiring retest, even though the repairs disturbed numerous circuits upon which logic testing had previously been completed. Late in the period the licensee took action to strengthen the post-maintenance testing process and to create a matrix of testing requirements, i The licensee implemented several aggressive maintenance initia- tives directed at improvement of component performance. Pre- " ventive maintenance on all safety-related motor operated valves (MOV) and AC circuit breakers was completed. However MOV pro- , cedures were found to be weak in some areas. Circuit breaker j 4 maintenance was not extended to include any safety-related DC l - circuit breakers until prompted by the NRC, even though none had been performed during the life of the plant. While management commitment is evident, follow through on initiatives was occas- ionally incomplete. The increasing involvement of the Systems Engineer Group has had a positive impact on maintenance perform- ance, particularly the quality and promptness of maintenance problem root cause analysis. The licensee also significantly increased staffing, training and management direction of tho Station Services Group resulting in improvements in the station decontamination and housekeeping programs. The licensee has implemented a Material Condition Improvement Action Plan (MCIAP) which identifies many of the weaknesses described above. An independent monitoring group was estab- ! - - - - - - - . - . . - -

. _ . _ .- . . 28 . 11shed by the licensee to monitor its effectiveness. This plan is intended to result in significant maintenance program im- provements over the long term. The hardware aspects of the MCIAP were effectively addressed, however, program and proced- ural enhancements were deferred. The licensee also implemented a maintenance performance indicators program. This program has assisted licensee maintenance management in better focusing on adverse trends and department performance. As a result of good working relationships between the Site Engineer Group and the Modification Management Group, licensee control of modification implementation and turnover was strong. A large number of ccmplex modifications were completed during the period without significant problems. The program for con- trolling post-modification testing was generally ef f ec tive . However, technical review of post-modification test procedures was occasionally inadequate. Examples of this included the failure of testing to identify the incorrect installation of reactor water level instruments, and the approval of several tests which either caused or would have caused unanticipated ESF actuations. In summary, the licensee continues to give high priority to improvement of plant material condition, although program weaknesses in several areas were evident. The licensee im- piemented informal process enhancements which resulted in more rapid improvernent during the last months of the SALP period. A long range plan, the MCIAP, has been established to promote program improvements in the areas of identified weakness. Licensee senior management attention to full and timely imple- mentation of this plan is necessary to assure that permanent improvements are achieved. Staffing problems and management turnover however, need to be resolved so that these problems do not continue to hamper licensee afforts. (2) Conclusion Rating: 2 Trend: None Assigned (3) Reconmendations . Licensee: Complete implementation of program improvements and con- - tinue staffing efforts. Provide for staff continuity and development. - NRC: None. .

.. ' . 29 . . l 4.4 Surveillance (1386 hours /14 percent) l (1) Ana?ysis The surveillance functional area is intended to assess the ef- j fectiveness of licensee management in assuring the development ' and implementation of a comprehensive surveillance testing program. During the previous SALP period, surveillance was assessed as a Category 3. Testing was generally conducted in a careful,. 1 safety conscious manner, however no centralized. management- of the surveillance test program existed. Responsibility for . pro- gram management was not clearly established. The system for I control of surveillance scheduling was weak, principally because the key individual involved with this activity was not a tech- ! nical staff member. The technical adequacy of surycillance prccedures and the control _of measuring and test equipment (M&TE) were also found to be inadequate. The licensee's sur- veillance test program had not received adequate management attention. During this SALP period surveillance testing was routinely ob- 4 served and procedure technical adequacy was evaluated. One management meeting and several inspections were conducted to ' assess licensee efforts to correct the previously identified problems. An Augmented Inspection Team dispatched in response , ! to a loss of offsite power also evaluated aspects of surveil- lance program effectiveness. During the previous assessment period, the absence of strong centralized control and responsibility for surveillance program oversight contributed to continuing weaknesses. Ea rly in this SALP period the licensee 1 assigned responsibility for program maintenance and upgrade to the Technical Section Manager. The Systems Engineering Group within the Technical Section has become increasingly involved with development of program improvements. A surveillance Coordinator position was estab- lished and staffed by a senior systems engineer to help provide needed focus. In addition, a coordinator was assigned in each , department responsible for surveillance text performance. Al- location of these resources has resulted in acceleration of program improvements and is an indication of management j commitment. ) - - - - - - - - - - - - - . -- - . - - - - . - - - - -

-- H . t . 30 . 'I The licensee has taken action to improve the technical adequacy of surveillance test procedures. Technically inadequate test procedures were a recurring problem identified during previous SALP periods, requiring repeated NPC initiatives to obtain licensee corrective action. During the current assessment per- 1 iod however, the licensee implemented an extensive effort to evaluate and upgrade surveillance procedures. A team composed , of licensee Nuclear Engineering Department, Technical Section and Maintenance Section representatives was formed to address 1 the problem. Initially the effort was intended to assure com- pliance with technical specifications,. Licensee management expanded the upgrades however, to include testing of additional system design features beyond technical specification require- ] ments. This is an indication of the licensee's' desire to estab- 4 lish a more comprehensive program that goes beyond regulatory requirements. Implementation ~ of the improved testing allowed the licensee t.o ident.ify and correct several system performance problems. Another example of the licensee's intent ;.o thor- oughly test major systems was the use of a temporary boiler to ) perform extensive testing of the High Pressure Coolant Injection and Reactor Core Isolation Cooling systems with nor,-nuclear i steam. While substantial progress has been made, and existing procedures have been upgraded sufficiently to assure compliance - with the Technical Specifications, some procedural weaknesses continue to be noted. For example, the inoperability of an emergency diesel generator during a loss of offsite power could have been prevented if surveillance procedures had recorded and evaluated more than the renuired minimum instrument readings. Additionally, inadequate test procedures have caused unnecessary , j engineered safety features actuations.. ' The licensee began development of a new computer-based Master Surveillance Tracking Program (MSTP) in an attempt to resolve

, previously identified scheduling problems. Considerable licen- see effort was expended on development of the new program. How- ever, late in the SALP period the licensee concluded that it was not viable due to problems with vendor supplied computer soft- , ware. The licensee's Systems tingineering Group has initiated an ' interim manual tracking system, and is revising the previously ~ used MSTP to compensate for the identified weaknesses. Substan- l tial time was expended in the unsuccessful attempt to implement the new MSTP, and therefore final resolution of' the scheduling J i problems has not been reached. However, it is evident that licensee management is committed to improving the system, responsibility for implementation has been . established and progress is being made. c - . . .

'

. I 31 . I The licensee's prugram for control of Measuring and Test Equip- ment (P4TE) has improved significantly. The licensee dedicated four full-time individuals to the upgrade of the P4TE control ' prngram. Instruments were collected, assigned unique identifi- cation numbers and data was input to a computer-based tracking system. Control and implementation of the local leak rate test program have aise improved since the last assessment period. The significant improvement in these areas is a clear result of management involvement. Licensee personnel generally conducted testing in a careful, safety conscious manner. Major testing evolutions such as the ri .ctor vessel hydrostatic test and the containment integrated , leak rate test were well coordinated and executed. Occasional personel performance lapses in the quality of testing were noted, however. For example, instrument and controls tech- nicians failed to enable equipment sump level switches after calibration, causing sump overflow in the high pressure coolant 1.jection pump room. During a similar drain system overflow inciden- operators did not perform required shiftly plant tours. As a re: ' contaminated water was allowed to accumulate. These l instance >ay indicate some weakness in personnel training. . The inservice inspection (ISI) program was effectively imple- mented. The licensee's ISI staff demonstrated a good under- standing of technical issues. Management support of the ISI program is evfdent. For example, prompt action was taken to evaluate piping errosion and drywell linee corrosion in response to industry events. In sun mary, the licensee has established appropriate responsi- I bilities for management of the surveillance program. Sufficient senior management and technical resources have been allocated to affect the needed program improvements. Program responsibil- ities have been defined and assigned to the System Engineering Group. Test procedure technical adequacy and control of PATE ' were substantially improved in response to recurring NPC con- cerns. While strengthening of surveillance scheduling has been l slowed due to c;mputer program problems, progress is currently being made. Continued licensee management attention is neces- sa ry to assure implementation of ongoing improvements, aggres- sive evaluation and correction of remaining weaknesses and reinforcement of newly established work standards. l . - - - - - - - -

' . . . 32 . (2) Conclusion Rating: 2 Trend: None Assigned (3) Recommendations Licensee: Continue positive initiatives to upgrade surveillance procedures and impliment improved surveillance track- ing programs.

. . . 33 . 4.5 Fire Protection (493 hours /5 percent) (1) Analysis This functional area is intended to assess the effectiveness of the licensee's station fire protection program, and the adequacy of modifications and procedures established to ensure compliance with 10 CFR 50 Appendix R. During the last period this area -was t rated as a Category 3. The fire protection program suffered from a chronic lack of management attention. The licensee was - not aggressive in maintaining the operability of station fire protection equipment, resulting in heavy reliance on compensa- tory ' measures. Fire barrier surveillance procedures were un- clear and incomplete. Personnel performing fire watches and serving on the fire brigade were poorly trained. Licensee senior management had taken steps at the end of the period to strengthen the program. , During this assessment period routine inspections monitored the progress of licensee improvement efforts, additionally two 4 inspections were conducted to assess the status of the station fire protection program. In addition, a team inspection was ' performed to evaluate licensee compliance with 10 CFR 50, Appendix R. A management meeting was also held to discuss fire protection and Appendix R concerns. , The licensee demonstrated a high level of management involvement ! in ensuring fire protection and Appendix R program improvements. ' A fire protection group was established near the end of the last ' SALP period. During this period, staffing for the group was increased from one fire protection engineer to six permanent fire protection specialists. Frequent meetings with the fire , protection group leader, and periodic status reports assisted senior licensee management in monitoring the group's progress. , In the area of Appendix R the licensee estabituad a temporary . project management organization. A senior pro, < engineer was ] dedicated to provide focused oversight and support. The Appen- dix R project organization and the fire protection group worked , closely together to coordinate activities, , f The licensee has been successful in reducing the backlog of fire orotection equipment maintenance, which had contributed to a heavy reliance on compensatory measures. Fire protection group and maintenance managers worked effectively together to reduce the outstanding maintenance backlog, and to maintain it at a ., l manageable level. Total outstanding fire protection maintenance i was reduced from over 300 items to less than 50 items, and is currently tracked by licensee management as a performance indicator. i $ 1 4 - - - - - - - - - - - . - .

r4- .. . . . 34 ] . The control and quality of fire brigade training have improved. The fire protection group, with the assistance of the training department, developed and implemented a more comprehensive training program. A state certified instructor was hired to conduct the brigade training. The number of fire brigade drills 1 conducted has substantially increased, and it appears that their . effectiveness has improved. Through these actions'the licensee ' has succeeded in developing a large core of trained personnel to serve as fire brigade members. Effective interaction and coor- dination between the fire brigade, the operations staff and local fire fighting companies was evident during several minor fire incidents occuring during the period, including a fire in , ' the machine shop which prompted declaration of an Unusual Event. The licensee initiated, and the NRC has approved several fire protection licensing actions during the assessment period. In response to past instances of problems with fire barrier ade- quacy, the licensee's Appendix R project organization imple- mented a well conceived program to identify, inspect and repair plant fire barriers. These inspections resulted in the identi- fication of a significant number of deficient barrier seals. 6 Licensee management exhibited a conservative philosophy, estab- lishing compensatory fire watches for all plant barriers pending completion of inspections. The licensee's approach to maintaining safe shutdown capability I was found to assure redundant safe shutdown system. train separa- , . tion, and to provide sufficient operational flexibility. To - assure adequato separation the licensee performed a well docu- mented and thorough analysis, although procedures for use of the safe shutdown equipment, and operator training in this area were found to be weak. The licensee has taken action to resolve these weaknesses and has committed to demonstrate safe shutdown capability by performing a test during the power ascension j program. In summary, licensee management has taken strong action to . establish and staff an effective station fire protection organ- l ization. Significant improvement in fire protection equipment ' material condition and fire brigade training has resulted. Licensee response during this SALP period to Appendix R issues, particularly fire barrier seal problems, was prompt and effec- tive. Continued management attention is needed to assure prompt completion of fire barrier seal repairs, to achieve further reduction of outstanding compensatory fire watches and to pro- vide a stable effective fire protection program. , , - i .. . , - . _ _ , ___ . _ _ . _ _ _ _ _._ _ , _ _ _ . _ _ , . . _ _ . . _ _ _ , , - . _ . _ _ _ _ _ , _ . _ , _

' l 1 . 35 . . (2) Conclusion Rating: 2 Trend: None Assigned - _ _ _ . ._ _ - _ - , - - _ . _ _ - - - ,_ .__._ _._.-... , . _ _ - . . _ . _ . . _ - - . . - - . - - .-

- . . . _ - , 0 . . . . l 36 .

\\i 4.6 Emergency Preparedness (176 hours /2 percent) (1) Analysis During the4 previous ~ assessment period, licensee performance in this area was rated Category 2. This was based upon a renewed , commitment by management for emergency preparedness and a tig- , .nificant improvement in performance. During the current assessment period, one partial participation exercise was observed, two routine safety inspections were con- ducted, one special safety inspection specifically related to emergency classification was conducted, and changes to emergency plans and implementing procedures were reviewed. Two routine safety inspections were conducted in November, .1987 and January, 1988. These inspections examined all major areas -

within the licensee's emergency preparedness program. During

the November,1987 inspection, significant changes were examined e , regarding the normal emergency preparedness organization. These changes resulted in essentially a completely new organization

wia.h the Emergency Preparedness Manager reporting to the Senior i Vice President. Functional responsibilities are divided into 4 on-site and off-site areas - with coordinators for each. The licensee has filled the managerial positions, .as well as other working positions, with personnel- experienced in emergency pre-

paredness. In addition, the licensee has contracted with several consultants to help the permanent staff.

During the January, 1988 inspection significant changes were examined regarding the Emergency Response Organization (ERO) and Emergency Action Levels (EAL's). The licensee has committea to a complete restructuring of the ERO with a three-team duty rota- tion. Additionally, the licensee is revising the EAL's to be symptomatic, address human factors, and has integrated them with the Eme gency Operating Procedures. Significant facility ! changes made include the addition of a Computerized Automated 3 Notification System to notify the ERO. .i

A partial participation exercise was conducted on ' Deceniber 9,1987. The licensee demonstrated a satisfactory emergency response capability. Actions by plant' operators were prompt and effective. Event classification, and subsequent -

Protective Action Recommendations, were accurate and timely. Personnel were generally well trained and qualified for their positions. No significant deficiencies were identified. Several minor weaknesses were noted including insufficient depth . in some positions to support prolonged operations, dose projec- , . tion discrepancies, delays in fielding onsito repair teams, and ]- weak initial notification forms. > 'l \\ 1 I i ,, _ _ _ _ _ , . , __ .4 , - _ , _ _ _ , _ - , _ - ,,em _ ,, ,. ,._ ,, ,, _ , o.,,..-__.___- ,

.- - . ..

. . y . 37 . During the responto to a loss of offsite power event in , November,1987, some weakness in coordination and communication i between licensee groups was noted. While not required by the site emergency plan, the licensee eventually chose to partially activate the Technical Support Center (TSC) to aid in recovery efforts. The difficulties experienced by the licensee during - the initial response and subsequent efforts to utilize the TSC indicate that licensee attention to preplanning response options to non-emergency events, such as discretionary activation of the TSC, may be appropriate. During the February, 1988 inspection the licensee's actions'in response ta a declaration of an Unusual Event were examined. The licensee's classification was conservative and prompt. Mit- igation activities were effective. The licensee identified several problems associated with their actions including: fail- ure to completely follow procedures; untimely notification of event termination; and control room distractions due to the- large volume of outside comt..unications. The licensee promptly identified these issues and instituted appropriate short-term and long-term actions to prevent their recurrence. ' The licensee is continuing to work closely with local and l Commonwealth of Massachusetts officials to upgrade off-site emergency preparedness. The licensee has a large organization working on plan and procedure development, in conjunction with the appropriate local and Commonwealth agencies. During this period, the licensee was granted exemptions for the 1987 full participation exercise and a deferral of the submittal of public information. These were based on the Commonwealth of Massachusetts requests to complete the local and Commonwealth emergency plans, implementing procedures and associated training pr:or to issuance of public information or demonstration of capabilities. In summary, the licensee has demonstrated a commitment to emerg- ency preparedness. Management involvement is evidenced by the I major on- site program changes being supported, commitment to the offsite level of emergency preparedness, and by timely ' recognition of problems and subsequent corrective actions. The licensee has been responsive to NRC concerns and is continuing , to maka progress in these areas. (2) Conclusion i Rating: 2 Trend: Improving - -. _ - _ , _ . . . . - . . _ . _ _ _ . . ,__

. . . . .

.

. . , 38 .. 4.7 Security and Safeguards (641 hours /7 percent) , (1) Analysis This functional area was rated as. a Category 3 during the pre- vious assessment period. NRC identified serious concerns regarding the implementation and management support of the

security program. The licensee's proprietary security staff " consisted of one full time and one part time member, resulting ) in weak oversight of the contractor. In addition, inoperable equipment contributed to a heavy reliance on long term compen- satory measures. Contractor security force overtime was also poorly controlled. Toward the end.of the assessment period, the licensee initiated actions to correct the problems. However, at the conclusion of the rating period the hardware upgrades were not complete and the expanded proprietary security staff organ- ization had not been in place for an adequate time for NRC to evaluate its effectiveness. Four routine, unannounced security inspections, one special security inspection, and one routine unannounced material con- trol and accounting inspection were performed during this assessment period by region-based inspectors. . Routine observa- tions were also conducted throughout the assessment- period. , During this assessment period, the licensee aggressively pursued a planned and comprehensive course of tetion to identify and

correct the rcot causes of the oreviously identified program- ' matic weaknesses in the area of physical security. To improve ! l the overall performance of the security organization and the , security program the licensee implemented several significant

! actions, including a commitment by senior management to support and implement an effective security program; establishment of a licensee security management organization on-site to direct and

j oversee program implementation; upgrading unreliable systems and i equipment to eliminate the previous heavy reliance on compensa- ' tory measures that were manpower intensive; and revising the Security, Contingency and Training and Qualifications plans, and their respective implementing procedures, to make them current ' , and clearer. ' l The licensee's security management organization is now headed by a section manager who reports to the Plant Support Manager, 2 under the Station Director. Assisting the Security Section Manager are five supervisors with specific functional areas of , responsibility (operations, administration, technical, compli- ance and access authorization) and a staff assistant. Addi- tionally, there &e seven licensee shift supervisors who are , , a . - . . . . . . . m. . . .

. _ . _ _ . . . 39 .

i responsible to monitor the performance of the contract security force around-the-clock. This represents an overall increase of . seven supervisors _over those which were in place at the end of j the last assessment period, and thirteen over that which was in place when the plant - was shut down in April, 1986. (At that time there was one supervisor who reported to a group leader with other, concurrent duties.) The licensee also established a ' full-time corporate security position onsite. The incumbent is j responsible to audit the security program on a continual basis and to provide another perspective on its implementation. In addition, the licensee established, as supervisory personnel, the alarm station operators employed by the security force con- tractor, and significantly improved the supervisor-to-guard ratio. This expansion of the licensee's security organization represents a significant allocation in terms of resources and provides evidence of senior management's commitment to the program.

In addition to the organizational expansion, considerable j capital resources were expended throughout the assessment period l j to upgrade, by modification or replacement, security systems and

equipment. The entire protected area barrier, assessment sys- tem, intrusion detection system and protected area lightir.g were J significantly improved. These improvements began early in the assessmert period and were, for the most part, complete at the i end of the period with only minor fine tuning of the new systems . , and equipment still required. Additional upgrades in access control equipment and the security computer are scheduled. The , l improvements have already resulted in a .*zable reduction in the j nuiaber of compensatory posts and, therefore, a reduction in the ! contract guard force. The above mentioned upgrades permitted the guard force to go on a 40 hour work week rather than the 60 hour work week required during the ma.jor portion of the assess- l ment period. In addition to the improved systems and equipment, , the licensee has taken action to strengthen the security equip- ment corrective maintenance program and has initiated action to

establish a preventive maintenance program to further ensure the ! continued reliability of security systems and equipment. Open , ' maintenance requests for security equipment are also now tracked as a performance indicator by plant management. These actions

i and initiatives are further evidence of senior management's ' ) commitment to the program. i ,'

, j e d U

. . ! . . , 40 . During the assessment period, the licensee submitted six changes , to the Security Plan under the provisions of 10 CFR 50.5((p).

One of these changes : was a complete revision to upgrade the Security Plan and to revise the format to be consistent with NUREG 0908. In conjunction with the Security Plan upgrade, the licensee also submitted revisions to the Safeguards Contingency - , Plan and the Security - Force Training and Qualification Plan (complete revisions of these plans were submitted during ' March, ' 1988). The - complete plan revisions were comprehensive, more consistent with current NRC regulations, and provided clearer documents from which to develop and modify implementing proced- ures. The plan changes were adequately summarized and appro- priately marked to facili_ tate review. Further, - the licensee, prior to submitting the changes, communicated with the NRC by telephone and requested meetings in Region I and onsite to ensure that the changes were appropriate, clearly understood, and in compliance with NRC regulations. a 4 Audits of the Security program conducted by Corporate Security 't personnel and the onsite QA group during the assessment period were found to be very comprehensive and corrective actions were found to be prompt and generally effective, indicating a much improved understanding of program objectives. Because of the

security program weaknesses identified toward the end of the previous SALP period, the licensee assigned to the site, on a t full-time basis, a member of the corporate security staff with

i responsibility for conducting continued surteillance and audit of the program. That initiative was reviewe9 and found to be a

very effective management tool to provide r.: independent assess- . ! ment of the day-to-day implementation of the security program I , and another input to the overall security program upgrade i project.

l The security force training program appears to be adequate to address the activities of the security organization. The licen-

) see has taken actions to assure the trairing program remains ~ ] current and reflects the chin,es and upgrades to the security j program. For example, to ensure more comprehensive management i oversight by licensee security shift supervisors, each received ,

plant opera tional technical tra ining in addition to security program and other training. Thir, training enables these super- visors to be more effective in interfacing with other plant I technical functions. ,

. .. .. 41 . There were three apparent violations identified by the NRC dur- ing this assessment period. All of the violations were the result of degraded vital area barriers. The licensee was. noti- fled of the apparent violations and an enforcement conference and a subsequent management meeting were held. These apparent violations resulted from weak communications between the secur- ity and maintenance organizations, and a poor appreciation by maintenance personnel of security requirements. Corrective actions were implemented by the licensee and _they appear to be effective. A total of six -security event reports required by 10 CFR 73.71(c) were submitted to the NRC during this assessment per- iod. Three event reports were necessitated by the licensee's - findings of degraded vital area barriers. Similar degradations were also reported in the previous assessment period. Two of the degradations reported during this period were the result of maintenance work being performed on plant systems that pene- trated the barriers. The other resulted from a degraded vital area door. Another event report was necessitated by the re- classification of an area of the plant as vital. The need for reclassification was identified as a result of the licensee's Vital Area Analysis and Barrier study. Another event report involved a guard leaving his weapon unattended The sixth event reocrt involved the loss of a set of security keys by a member s r the guard force. With the exception of the vital barrier degradations earlier in the assessment period, no adverse trend was indicated by the events which occurred during this assess- ment period. The licensee eventually implemented appropriate measures to prevent recurrence of the vital area barrier degra- dation problems. The quality of the event reports was signifi- cantly improved over the previous assessment period indicating a better understanding of program objectives and more care in their preparation. They were clear, concise and contained suf- ficient information to permit NRC evaluations without the need for additional information. The licensee's program and procedures for the control and ac- counting of special nuclear material were also reviewed during this assessment period and were found to be adequate and gen- erally well implemented. In summary, the licensee has demonstrated a commitment to imple- ment an effective security program that goes beyond minimum compliance with NRC requirements. As a m ult of this commit- ment, the licensee security organization has been expanded, significant capital resources have been expended to upgrade security hardware, and equipment and program plans have been improved. Continued senior management support and involvement in the security program is necessary to ensure that the momentum demonstrated during this assessment period is continued.

, . - 42 ' (2) Conclusion Rating: 2 Trend: None Assigned l I J 'c . - - - - - - - - - -

. s . 43 . 4.8 Engineering and Technical Support (1215 Hours /13 percent) (1) Analysis This functional area is intended to assess the adequacy of the licensee's technical and engineering support in the areas of plant design changes, routine operations and maintenance activ- ities. Engineering and Technical Support was assessed as a Category 1 during the previous SALP period. Good engineering support to the site was noted in the Environmental Qualification program and the design of several significant plant hardware modifications. Technical evaluations were typically thorough and demonstrated an adequate regard for safety. The engineering approach to the Safety Enhancement Program (SEP) demonstrated an excellent appreciation for underlying safety issues. A weakness in the lack of detailed design basis documents for plant equip- ment was also noted during the last period. During this assessment period, five special inspections includ- ing an Augmented Inspection Team focusing on a loss of of fsite power event, an e!ectrical system team inspection, and a main- tenance team inspection were conducted and, in part, evaluated the licensee's performance in this area. The effectiveness of the onsite Systems Engineering Group, and the Nuclear Engineer- ing Department's (NED) interactions with the site organization were routinely monitored. Significant plant modifications were installed during this assessment period, including the reactor water level instrumen- tation modification, a hydrogen water chemistry system, an , analog trip system, and a new plant process computer. Few prob- l lems were identified with these projects, demonstrating the i strength of the engineering work. Safety evaluations required l by 10 CFR 50.59 for design changes and modifications were . generally thorough and conservative. Safety evaluations for SEP modifications demonstrated sufficient analysis and supporting ' facts to conclude that there were no unreviewed safety ques- i tions. Highly qualified engineering staff and NED management focus on safety have contributed to the licensee's performance in this area. ' ' Offsite technical and engineering support was generally good as indicated by the successful design and implementation of signif- icant plant hardware modifications. Continued effective use of the Design Review Board was evident during this SALP period.

~ _ _ .. . . '44 ! . , , This was demonstrated by high quality initial design reviews, , and routine evaluations of completed modifications for syner- gystic ef fects. The expanded Field Engineering Section, the

' design implementation oversight arm of NED, played a vital role , in coordinating activities between the site organization and the NEO. Engineering management was actively involved in 1:nplemen- tation of modifications and addressing problems. The Safety Enhancement Program, including extensive Mark I containment and station blackout modifications, were planned and implemented during this period. The engineering approach to the Mark I issues went considerably beyond NRC requirements and demon- strated a good appreciation of containment reliability issues.- The NE0's involvement in the development of the new Emergency Operating Procedures (EOP) demonstrated significant managaent attention in this area. The licensee's communications with the , NRC regarding the planning and implementation of the SEP and E0P projects were generally good. In addition to these modifica- tions, the licensee is preparing an extensive Individual Plant Evaluation (IPE) as part of the (SEP) using probabilistic and 2 l . deterministic analyses. In support of these efforts, the i licensee effectively managed contract engineering expertise to j produce quality design changes and analyses. Throughout the i development and implementation of the SEP senior management's. involvement and commitment to safety was apparent.

A team inspection was conducted during this assessment period to , review the licensee's implementation of a fire protection pro- gram to meet the requirements of 10 CFR 50 Appendix R. The 4 licensee's approach to maintaining safe shutdown capability was found to assure adequate redundant safe shutdown system train separation, and to provide sufficient operational flexibility. The licensee's analyses were found to oe well documented and

thorough. NED's Appendix R project organization and the onsite fire protection group worked closely together to coordinate activities. Some weaknesses in the engineering design change process were

noted. In one instance inadequate technical review of a design

change by NED resulted in incorrect installation of reactor water level gauges. Additionally, the plant design change docu-

! ment for the Standby Gas Treatment System did not specify ade- quate post-work testing requirements. Further, as indicated in the previous SAlp, the lack of detailed design basis documents was a continuing problem this assessment period. Examples included lack of seismic qualification documents for the reactor l i , . . .

- . - . . . .. . .. .. .. - . . 3 . . , 45 . t 1 i building auxiliary bay and for the hydraulic control units. . Also, engineering failed to correctly translate containment , accident temperature _ profiles into environmental qualification documents. However, the licensee has taken initiatives to -1 - further understand the design bases of the plant electrical , distribution system as evidenced by the use' of a new computer ' ] code to analyse electrical distribution equipment performance, j At times, corporate engineering support for- plant maintenance - activities was limited. The NRC special electrical system inspection identified that the DC battery and electrical breaker maintenance activities were not supported by NEO. The licen- l see's initial response to the NRC's concern regarding the sur- veillance testing of the DC breakers was limited in scope and-

lacked engineering justifications ' on the sample size ~ and the acceotance criteria. The increasing involvement of the onsite Systems Engineering Group (SEG) has had a positive impact on the quality of opera- tions event analysis, the surveillance test program, and on 2 maintenance performance, particularly the quality of maintenance problem root cause analysis. At the beginning of the assessment . period the licensee established the SEG under the Technical ! Section within the Nuclear Operations Department. The SEG was- staffed largely with experienced contractors, but the licensee

gradually expanded the group and replaced the contractors with permanent Boston Edison employees. At the end of this period, ' the SEG had a total technical staff of 26 including 15 senior ' , systems engineers. The increasing involvement by the SEG has promoted better intergroup interactions as the operations and . ' i maintenance departments have begun to value and rely on the 1 SEG's contributions. ' I l In summary, overall strong engineering support continued . throughout this period. Major plant modifications were com-

pleted with only a few minor problems, demonstrating the quality of engineering work. The increasing involvement of the SEG has contributed significantly to the quality of root cause analyses 1 and in maintenance performance. However, overall performance 4 in the areas of corporate engineering responsiveness and support j to site maintenance initiatives appears to need further. licensee ] evaluation and improvement. Additional management attention is needed in developing long-term programs to provide better i operational and maintenance support to the site. 1 J 4 , - < i 4 i i -

. - . . ' , . 46 . (2) Conclusion Rating: 1 Trend: None Assigned , < l l l l 1 - l l

. . ,. . . . 47 i . 4.9 Licensing Activities 1 , (1) Analysis The licensing functional area is intended to assess the licen- see's effectiveness in assuring a technically accurate and up-- . to-date licensing basis, and the licensee's responsiveness to , NRC and industry concerns. During the previous assessment period licensing was evaluated as a Category 2.

During this period, the basis for this appraisal was the licen- ' see's performance in support of licensing actions that were ' either completed or had a significant level of activity. These actions consisted of amendment requests, exemption requests, ' responses to generic letters, TMI items, and other actions. The licensee has exhibited a high level of management involve- , ment in major licensing initiatives;' however more routine licensing acticns did not always receive substantive management action. An example of a high level of management involvement. and initiative is the licensee's actions .to improve the Mark 'l containment and implement other plant safety improvements intended to cope with severe accidents as part of its Safety - Enhancement Program (SEP). This program includes improvements j to emergency operating procedures, modifications to containment spray nozzles, enhancements to water supplies that would be , available in the event of a severe accident, the installstion of i a direct torus vent and the installation of a third emergency diesel generator. A number of the SEP mcdifications, such as the Station Blackout Diesel Generator are also useful in dealing with less significant transients and events as opposed to severe

accidents. The licensee is in the forefront of the industry in the 'ef fort to deal with severe accidents and has expended substantial .l . resources on the SEP. The licensee has been very active in ' industry owner's groups involved in severe accident initiatives. J Although much of the SEP effort did not involve direct licensing actions, the staff did assess tha safety significance of the i i licensee's modifications and inspected portions of the modifica- tions. The licensee is commended for its leadership on the SEP program. It should be noted that the staff is still continuing its assessment of some of the details of the SEP modifications. ' l l

- . . . . . 48 ' 4 . The technical quality of more routine licensing actions (such as i some Technical Specification amendmects and exemption requests) l has been sporadic. Several fire protection licensing actions o have required numerous submittals and frequent interchanges with the staff. For example, the licensee revised its technical l position twice in the determination of the appropriate basis for ' an exemption request involving the lack of 3-hour fire proofi.ng for structural steel in the Reactor Building Torus Compartment.

Several submittals were required, and the staff had to request i detailed calculations to suppcrt the licensee's basis. In a technical specification change involving 10 CFR 50 Appendix J ' requirements (Amendment 113), the licensee had to make numerous i submittals in response to staff concerns and was required to correct errors in previous submittals identified by both i;he staff and BEco. The staff identified inconsistencies in pro- , posed changes to the technical specifications for the StandL Gas Treatment System and Control Room .High Efficiency Air Fil- tration System (Amendment 112)n and revised submittals by the' licensee were required. The extensive activities and resources required to correct problems identified in Confirmatory Action I etter 86-10 and subsequent management meetings has apparent jy impacted the licensee's overall performance in the licensing , area. These problems suggest a weakness in corporate manage- i ment at the level that establishes priorities and coordinates a engineering and licensing activities for the utility ' ! The licensee has, however, submitted, and the staff has ap- proved, a number of technical specification changes or exemption

' requests that demonstrated a high level of technical qual'ty and 3 management involvement. Examples include the schedular ex- , emption for conduct of the emergency preparedness cr.ercise, Core j Raioad (Amendment 105), Control Rod Block Actution (Amendment ( 110), and LPCI Subsystem Surveillance (Amer; cent 111). Where NRC staff requests for additional informnion were made, the i licensee responses have been prompt and ramprehensive. The licensee has usually been resmnsive to NRC initiatives. j , The licensee has been responsive to staff requests to track and ' control actions of mutual interes' between NRR and the utility, i For example, the licensee has developed a tracking system to assist in the management of licensing actions and has provided ' , extensive resources to support NRC effort in updating the Safety Informnion Management System (SIMS) data base. Particularly 4 ! noteworthy was the high quality 'of technical support provided for the staff's review of Emergency Operating Procedures. ' i i i

l 1 i - - - . . . . - - - - - - - -

. -- ~ , -.. - . . --.

. ! . - ..

I c, 49 -

, ~ l There -was evidence of.. improvement during the latter portion -of' the SALP period in the approach to the resolution of technical i issues and respoasiveness to NRC initiatives in the licensing ~ ., area. This is in part due to recent organizational changes ' which have resulted in a closer relationship of the licensing and engineering groups. The overall staffing to support licen- i sing activities is adequate and ~ its effectiveness should be f improved by the recent organizational changes._ Recently a reduction has been evident in the number of cases of. technical

., errors, lack of clarity, and incomplete information. _ ' l In summary, the_ licensee has exhibited strong managerrent- 4 involvement in several. major licensing ~ actions, but attention to- more routine licensing actions has been inconsistent. The licensee has-shown some improvement in the licensing area during , the latter portion of the SALP period. The involvement of

' management in routine, as well as major licensing activities, -is - necest:ry. The continued strengthening of mid-level management l and increased tes!.nical capability' of licensing staff are

necessary. i (2) Conclusion Rating: 2 j ! 1 Trend: None Assigned

a i 1 1 1 E l )

I 4 .I i i J ! .

.. _ _ _ _ _ _ _. .- .. .. .. 50 .

, 4.10 Training and Qualification Effectiveness (1) Analysis Technical training and qualification effectiveness =is being con- sidered as a separate functional area. The various aspects of I this functional area were discussed and used as one evaluation criterion within the other functional areas.- The respective ! inspection hours have been included in each one. Consequently, this discussion is a synopsis of those assessments. Training , effectiveness has been measured primarily- by the observed per- formance of. licensee personnel and, to a lesser degree, as a 4 review of program adequacy. ' 4 i This area .was rated as a Category 2 during the previous assess- ' i ment period. The licensed operator training and requalification

programs were found to be significantly improved. Assignment of ' knowledgeable staff had resulted in higher quality training ! materials, and more plant-oriented operator training. Mainten - ance, contractor and radiation protection personnel training. ! , were also adequate. Fire brigade and fire watch training had i i been significantly weak and contributed to poor personnel per- formance in the plant. Four of ten licensee training programs i had received accreditation from~ the Institute- of Nuclear Power j Operations (INPO). 1 - .During this assessment period, inspectors routinely r'eviewed

ongoing training activities and their effectiveness in ' assuring quality personnel pe-formance. Two sets of reactor operator and , senior reactor opcNtor license examinations were administered.

An inspection to evaluate the adequacy of the nonlicensed per- sonnel training program was also completed. Various other inspections reviewed training provided in the areas of emergency ,' preparedness, radiation protectico, security, maintenance, fire protection and modif1;:ations. ) Licensed operator training effectiveness continued to improve throughout the period. Two sets of licensed operator examina- tions were administered to a total of two senior reactor opera- l i tors and fourteen ' reactor operators, with all candidates suc- ' cessfully completing the licensing process. Newly licensed operator familiarity with plant equipment and procedures was

considered a strength. Challenges facing licensee management include completion of training for the large number of new, , j ' relatively inexperienced operators. Site management is intent on assuring that time spent by' newly licensed operators in the control room during startup and initial operations, is used as effectively as possible to provide the maximum training benefit.

1 N , e . . . . . . - - - . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

. . . 51 . The material developed for operator training and submitted for NRC review was generally good. However, for the first examina- tion early in the assessment period, it was noted that some materials provided to the NRC did not reflect recent station modifications. This was because the modifications had recently been completed and previous training had focused on the original systems. It was also noted during exams and by direct discuss- ions with licensed operators, that training conducted on recently implemented modifications, such as on the reactor water level and automatic depressurization systems, had not been fully effective. Operators were unfamiliar with the modifications, primarily because only on-watch training had been performed and because the training had been conducted prior to completion of the modifications. Licensee management took prompt action to restructure the modifications training and committed to repeat the training prior to plant restart. The license.e completed installation of a plant specific simu- lator during this assessment period, and used it extensively to enhance operator training, particularly in the area of emergency operating procedures (EOP). The licensee implemented a compre- hensive E0P training program including a combination of simula- tor and classroom instruction. Licensee management assured the effectiveness of this training by performing post-training evaluation of the opeNting crews on the simulator. The de- velopment of special criteria by which acceptable performance is judged was a strong point of the EOD training program. Operator performance weaknesses were identified by the licensee, and sup- plemental training was performed to resolve the problems. Licensee management also initiated a communications training program for operations personnel. This communications training was implemented along with the E0P training and appeared to substantially improve operator performance. Licensed operator performance during plant events such as a loss of of fsite power, and an Unusual Event due to a fire in the machine shop generally demonstrated a good command of plant equipment and procedures. However, some apparent weaknesses in operator training were evident. For example, several opera- tional errors were made during reactor refueling despite inde- pendent verification requirements. On several occasions oper- ators failed to properly perform routine surveillances. l , -

- _ . . - . . . 52 . The nonlicensed and contractor personnel training program appeared effective - The -training staff dedicated to this func- tion has been supplemented by the addition of contractors. The licensee initiated maintenance and radiological technician apprentice programs to assist ,in development of qualified' lower level personnel. New training initiatives l are in progress to sensitize management, workers and radiation protection personnel to the need to minimize all occupational exposure. For example, management training in ALARA for plant design changes and radia- tion awareness training for operations and maintenance personnel have been initiated. In addition, a Training Program . Evaluation - Comn.ittee was established to assure plant management involvement in ongoing development of nonlicensed training. The licensee's program for fire brigade and fire watch training has been significantly improved. The station fire protection group and the licensee's training department have coordinated to expand the scope and enhance the quality of brigade training. A large core of qualified fire brigade members has been established. Security force, emergency response and maintenance training appeared to be effective. ho performance deficiencies directly attributable to training were identified in these areas during the period. INPO accredidation of all remaining training . pro- grams was received during the current assessment period. In summary, licensee management has been active in improving the overall quality of the training program and has 'been responsive to NRC concerns. Licensed and nonlicensed training programs are effectively implemented. Of particular value is the use of the i simulator, and other initiatives such as formal communications ' training and establishment of an apprentice program. Efforts should be continued to strengthen operator training in the area of modifications and to ensure effective completion of training for newly licensed personnel, i (2) Conclusion Rating: 2 Trend: None Assigned

__ - . ,. . 53 . 4.11 Assurance of Quality i (1) Analysis _ During this assessment period, Assurance of Quality is being considered as a separate functional area. Management involve- , ment in assuring quality continues to be discussed and assessed

as an evaluation criterion in each of the other SALP. functional areas. The respective inspection Lours are included in each one. Consequently, this discussion is a synopsis of the assess- i ments relating to assurance of quality in other areas. Since this is an evaluation of management's overall performance it conveys a broader scope than simply Quality Assurance (QA) department performance. 4 During the previous assessment period this functional area was evaluated as a category 3. Licensee management had not been effective in addressing recurring SALP concerns. Organization

and staffing were considered weak. Licensee management correc-

tive actions in response to Quality Assurance (QA) findings and NRC issues had not been timely or comprehensive. QA department performance and engineering initiatives were considered a strength. Quality Assurance effectiveness has been assessed on a day-to- !

day basis. Three inspections focusing on the Quality Assurance and Quality Control (QC) programs were conducted during this

period. In addition, the large number of management meetings ,i held during the period provided an opportunity for NRC manage- ment to assess licensee management's approach to resolution of I issues. During much of the period licensee senior management continued to assess and correct organizational weaknesses through restruc- turing and recruitment of experienced personnel, many from out- - side sources. A new Senior Vice President assumed responsi- bility for the nuclear organization at the beginning of the period. In June, 1987 the Vice President-Nuclear Operations resigned. That position remained vacant until January, 1988 j when the Site Director position was created and filled. Station ' management was reorganized several' times, and significant personnel changes were made. Four individuals served as plant i manager during the fifunn month assessment period. In addition to modi fying the line orge a:. tion a temporary Planning and Restart Group was created, working in parallel with the per- manent plant staff to provide outage planning oversight. This , i group was subsequently disbanded, incorporating its functions into the permanent organization. The licensee also replaced several mid-level managers during this assessment period in- cluding the Operations Section Manager, Maintenance Section ' 4 i ' t - - - .

O 6 0 54 . Hanager, Radiological Section Manager and the Security Group Leader. In addition to changes in the line organi:ation several staff assistant positions reporting to the Senior Vice President were established to enhance senior management oversight of or- ganization progress. Although actions in this area were imple- mented slowly, it was evident that senior licensee management took a careful and -deliberate approach to establishing the permanent organization and staff. Licensee management displayed the intent to fill open positions in the organization with the most highly qualified individuals available. This approach may have delayed staffing efforts and initially slowed licensee progress in areas such as maintenance and radiological controls. Management policies and performance standards were strengthened and are clearly understood through mid-level management. How- ever, the new standards were not concurrently communicated or adopted at the working level in some cases. As a result ex- tensive management involvement in routine activities is still required to assure acceptable performance. A high level of management involvement and commitment was effec- tive in promoting improvement in several SALP functional areas whicn had previously been identified as significantly weak. This is particularly evident in the areas of fire protection and security where management acted to establish, staff and support expanded oversight groups. This strong :ommitment is also evi- denced by the organization-wide increases in permaner.t staff, and the general reduction in reliance on contractors for augmen- tation of line functions. One exception to this is in the area of maintenance where vacancies and reliance on contractors continues. Licensee response to new NRC concerns raised during the period was sometimes narrowly focused, and did not target resolution of root causes. For example, a high level of NRC management involvement was required to assure development of a comprehen- sive Power Ascension Test Program, and to resolve overtime con- trol deficiencies. Needed programmatic improvements in the area of maintenance were only implemented after prompting by the NRC. This may reflect that available licensee resources were focused on areas of previously identified weak performance and on outage completion schedules. In some instances the licensee's written replies to NRC concerns have been vague, incomplete, and did not reflect the full extent of actions which had been taken at the acility. . . - . -

. . . 55 - The licensee initiated several programs designed to upgrade per- sonnel and plant performance. The plant Emergency Operating Procedures (EOP) were upgraded, and extensive E0P and communica- tion training was conducted to enhance operator response capa- bilities during abnormal and emergency conditions. A fitness- for-duty program was al:o instituted and applied to all licensee and contractor personnel. In addition, implementation of the Safety Enhancement Program and the station decontamination pro- gram improved the plant physical design and condition. The decontamination effort was particularly successful, resulting in increased accessability to plant areas and a general positive impact on personnel morale. Licensee management took an active role in establishing long term plans to acdress identified weaknesses. The Restart Plan, the Material Condition In'provement Action Plan (MCIAP), and the Radiological Action Plan (RAP) are examples. In the case of the MCIAP a team of contractors was created to provide ongoing independent assessment of the plan's effectiveness in improving plant material condition and maintenance practices. In the area of radiological improvements the licensee reinstituted the Independent Radiological Oversight Committee to provide senior management with feedback on RAP effectiveness. The licensee also implemented a self assessment process near the close of the period. This self assessment was intended to provide a struc- tured method by which licensee management cculd evaluate the ' progress made, and identify remaining weaknessn. The licensee's Quality Assurance (QA) and Quality Nntrol (QC) department continued to become more involved in station activ- ities. The onsite QA surveillance group was increased in size, and appeared to be actively involved in evaluating field activ- ities. QA audit methodology was revised to enhance its effec- tiveness, and an aggressive audit schedule was established. The licensee made good use of technical experts during audits to , supplement available departmental resources. QA department management took prompt action to focus attention on significant j concerns. For example, a stop work order was issued in response i to adverse trends and findings in the area of maintenance on i environmentally qualified equipment. Corporate and site manage- ment response to QA findings has also improved. Both the pro- gram controls and their application were strengthened to ensure timely response to QA identified de#1ciencies. Overduc response to these QA deficiencies are currently tracked as a performance { indicator, i l

_ _ _ . .. -. . . . _ , . i . . . 56 , 4 1 Throughout most of the assessment period, the -licensee's correc-

' tive action process was not always effective. A large number of- problem reporting devices exist, each~ with a unique origination, review and disposition process. This makes use of the correc- tive action system cumbersome, and weakens accountability for

' ! followup and closeout. Lack of clear problem descriptions, and ] delays between origination and followup, hampers establishment i of root cause and implementation of corrective actions, The , l licensee has reviewed the process and recommendations to facil- i itate improvcments have been made. However, the recommendations { were not implemented during this period. i In summary, licensee senior management has taken strong action- ' to develop and staff a viable station organization. High qual- ' ity personnel have been recruited to fill key management posit-- ! ions. The reorganization and staffing process was not completed

! until late in the SALP period. As a result, progress in some functional areas, and in forcing management philosopy changes ! i down to the worker and first line supervisor level has been hamperd. The continuing need for a high level of management l pa..;cipation in routine activities occasionally prevents

, manager; from focusing on other needed program improvements. , - Overall, the licensee has been successfull in effecting signifi- i

cant performance improvements in many areas. A high level of- [ < management involvement is required to ensure that the initiated improvement' continue and are sustained.

(2) Conclusion I Rating: 2 , t Trend: None Assigned ' 1 . ]

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. _ - .-. .. .. t l . . , ! 57 . t l

5.0 SUPPORTING DATA AND SUMMARIES - ! " 5.1 Investigation and Allegations Review i Twenty allegations were received during this SALP period. Eleven of j 4 the allegations were investigated and found either to be unsubstan- l tiated or to be substantiated but of no safety significance. Five . allegations were investigated and substantiated, however the licensee , j had either alreaoy instituted. appropriate corrective actions or such . actions were promptly initiated in each case. Four allegations are r i currently under review. One of these four concerns the licensee's , program for control of overtime which is the subject of ongoing

reviews. ' f j One investigation was initiated during the assessment period as a result of an allegation regarding a plant security vital area bar- - rier. This investigation is continuing. [ ' i 5.2 Escalated Enforcement Action

Confirmatory Action Letter (CAL 86-10) was issued in response to a i series of operational events in April,1986. CAL 86-10 requested 7 j submittal of technical evaluations of these events and stated that ( ! NRC Regional Administrator approval would be required ' prior to j ! restart. The technical issues identified in CAL 86-10 have been resolved. The CAL however was extended in August, 1986 and remains l r i open pending re W utiot if broader macagement concerns -identified in

i the previous SALFs and tubseqt.ent inspection reports. Three violations were identifled during the period for failure of the - licensee to enstre the integrity of security vital area barriers.

These three violations have yet to be character 12ed oy severity ' level, and are corrent.ly being considered for escalated enforcement

action. This acticn is pending concluston of the OI investigation l e l described in Section 5.1 abov4.

An NRC Order issued in 1984 requiring the licensee to implement a Radiation Improvement Program was closed during the period based on the results of a special inspection and other program inspections 1

which indicated that all terms of the Order had been satisfactorily completed. ' 1 Request for Action Under 10 CFR 2.206 l l On August 21, 1937, the Director of the NRC Office of Nuclear Reactor i Regulation signed an Interim Director's Decision in response to the j July 15,1986, 2.206 petition filea by Massachusetts State Senator 1 William B. Golden and others. The contentions raised in the petition 1 l J . i . - . - , .--,n----., ,. - - - _ _ , , , . ,

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. . . 58

, l regarding containment deficiencies and inadequacies in the radio- logical emergency response plan were denied. A decision regarding the management deficiencies was deferred to a subsequent response. Three of the petitioners filed an appeal in federal court on October 1, 1987. On October 15, 1987 Massachusetts Attorney General James M. Shannon filed a 2.206 petition, on behalf of his office and Governor Michael S. Dukakis, requested an order to show cause why Pilgrim should not remain shutdown until a full adjudicatory hearing resolves the issues raised in the petition. The petition cites evidence of continuing managerial, Mark I containment, and emergency planning deficiencies. An interim NRC response was issued on May 27, 1988, just after the end of the SALP period. 5.3 Management Conferences Periodic management conferences and plant tours were conducted throughout the SALP period. NRC Commissioners toured the plant and met with licensee management on six occasions during the period. A total of nine senior management conferences were held onsite cr at Region I. In addition to plant tours held in conjunction with onsite management conferences, senior NRC managers performed two plant inspections during the assessment period. NRC management partici- pated in four public meetings in the vicinity of the plant. Two of these public meetings were sponsored by the NRC and two by local communities. Five meetings with state officials and legislative committees were attended by NRC managers. The NRC also testified before the United States Senate Labor and Human Resources Committee regarding Pilgrim at a public hearing held in Plymouth, MA in January, 1938. A chronological list of NRC management meetings and plant tours conducted during the assessment period is contained in Table 5. In addition, a summary of licensing meetings has been included in section 5.4(1). To coordinate the planning and execution of NRC activities and to assess the results of these activities a special Pilgrim Restart Assessment Panel was formed. The panel is composed of senior members of the Region I and Headquarters staffs. This panel met bimonthly, with alternate meetings on site, , 1 l l ' J i i 1 - .

. . i 59 i . 1 5.4 Licensing Actions ' (1) NRR/ Licensing Meetings and Site Visits Date Subject May 21, 1987 Licensing Issues, Bethesda, MD August 4, 1987 Emergency Operating Procedure and Direct Torus Vent September 24, 1987 Status of Pilgrim Restart / Schedule August 19-20, 1987 Multi-Plant Action Items " August 24, 1987 Ongoing Fire Protection Reviews December 10, 1987 Emergency Operating Procedures Upgrade January 14, 1988 Discussion in Bethesda, MD of the in- service test program development (2) Commission Briefings Date Subject J February 12, 1987 Regional Administrators' Meeting ' (Pilgrim Included) December 17, 1987 Briefing on Status of Operating Reac- l tors and fuel facilities (Pilgrim Included) f i l

N

. . . 60 . (3) Schedular Extensions Granted Subject Date Emergency Preparedness (EP) Exercise 12/09/87 Emergency Preparedness (EP) Exercise 05/11/88 (4) Reitefs Granted Subject Date Inservice Inspection Relief 03/26/87 (5) Exemptions Granted Subject Date Duplicate Yard Lighting 10/06/87 10 CFR 50 Appendix R-Operator Action 04/14/88 . (6) License Amendments Issued Amendment No. Subject Date 98 New Design-Reactor 02/27/87 Control Rod Blades 99 Analog Trip System 03/03/87 Surveillance Requirements 100 Maximum Average Planar 04/09/87 Linear Heat Generation Rate 101 Control Room Ventilation 06/23/87 System 102 Standby Liquid Control 08/05/87 System 10 CFR 50.62 Rule 103 Administrative Changes 08/05/87 per 10 CFR 50.4 104 Nuclear Safety Review and 08/25/87 Audit Committee changes 105 Cycle 8, Core Reload 08/31/87

- _ . . -. . 61 . (6) License Amendments Issued . F Amendment No. Subject Date 106 Automatic Depressurization 09/04/87 System Timer 107 Analog Trip System - 10/28/87 Calibration Frequency

108 Undervoltage Relay Require- 10/29/87 ments 109 High Pressure Coolant 10/29/87 Injection and Reactor Core Isolation Cooling Requirements 110 Rod Block and Average 11/30/87 Power Range Monitors Trip Functions 111 Low Pressure Coolant 11/30/87 Injection Requirements '

112 Standby Gas Treatment 01/20/88 ' & Control Room Air Filter Systems i 113 Primary Containment 01/21/88 ' Isolation Values 10 CFR 50

Appendix J Requirements . 114 Fire Protection - 03/08/88 Appendix R to 10 CFR 50 1 Requirements 115 Security Requirements - 03/28/88 10 CFR 73.55 l ' 116 Modification of Reporting 05/10/88 Schedule Supplemental Dose Assessment & Meterological ! Summary I j

. . . 62 . (7) Othe- Licensing Actions Action Date Containment Leak Rate Monitor 02/19/87 10 CFR 50 Appendix J Review 02/19/87 (Penetration X-21) Generic Letter 83-08, Mark I 02/27/87 Drywell Vacuum Breakers Recirculation Flow Anomaly 02/28/87 Process Control Program (PCP) 03/03/88 Review Inservice Inspection Plan - 1986 03/16/87 Refueling Outage Control Room Floor-Fire Seals 03/24/88 Smoke Seals - Conduit 03/24/88 Defects Westinghouse DC 04/13/88 Circuit Breakers Steam Binding - Pumps 04/15/88 Pilgrim SALP Activity 05/15/87 10 CFR 50 Appendix R Review 05/15/87 NUREG-0737 Item II,K.3.18 09/04/87 ADS Actuation Study Offsite Dose Calculation Manual 10/28/87 Correct Performance of Operating 11/16/87 Activities Intergranular Stress Corrosion 11/25/87 Cracking Augmented Inspection Program Refueling Inttrlocks 12/17/87

. . . 63 , 5.5 Licensee Event Reports (1) 'Overall Evaluation Licensee Event Reports (LER) submitted during the period ade- quately described all the major aspects of the event, including all component or system failures that contributed to the event and the significant corrective actions taken or planned to pre- vent recurrence. The reports were thorough, detailed, generally well written and easy to understand. The narrative sections typically included specific details of the event such as valve identification numbers, model numbers, number of operable redun- dant systems, the date of completicn of repairs, etc., to pro- vide a good understanding of the event. The root cause of the event was clearly identified in most cases. Event information was presented in an organized pattern with separate he 'ir.gs and specific information in each section that led to a cla;r under- standing of the event information. Previous similar occurrences were properly referenced in LERs as applicable. The licensee updated two LERs during the rep:rting period. The updated LERs provided new information and the portion of the report that was revised was clearly denoted by a vertical line in the right hand margin, 50 the new information could be easily determined by the reactor. However, in the past the licensee's threshold for reporting required monitoring. 4 LERS (87-021, 87-022, 87-023, and 87-024) were submitted only af ter an audit by Regien I. One of these LERs, 87-021, was submitted 10 months af ter the event. (2) Causal Analysis A review of the LERs indicates a number of problems, some recur- -ing. In particular, loss of effsite power has been a continu- ing problem at Pilgrim. In addition, Pilgrim has experienced repetitive events associated with inadequate procedures; admin- istrative control problems associated with failure to conduct adequate reviews prior to maintenance and required surveillances and inadequate guidance and cautions for technicians. I -

_. . _ . - - _ . - _ - _ _ _ _ . _ . _ . . _ _ . ., , 64 a Examples of- unclear procedures' included . LER-87-015 which' de- scribes two events where RHR shutdown cooling was terminated oy spurious isolation.~ One isolation was attributed to a procedure with inadequate. instructions.and cautions on= installing: Jumpers; the other isolation was due to inadequate. procedures which failed to describe the . right number of . jumpers.' LER 87-016 . describes an unplanned actuation of. primary and' secondary con- tainment due to inadequate administrative controls for the planned replacement of a relay coil, specifically lack of appro ~ nriate precautions and guidance. Furthermore the : vent was compounded.by supervisory errve -in researching drawings, wiring arrangements and assigning maintenance priorities. Similarly. repeat problems can be illustrated by the following two LERs. LER-87-018 described a failed coil in a logic relay which caused a Reactor Water Cleanup System isolation. The. licensee conducted a technical evalur N of similar coils, identifying those ~ requiring replacement. LER-88-005 describes . an actuation of the Primary Containment Isolation Control System i and Reactor Building Isolation Control Syster; due to a failure ) of a similar cd l in another relay. Our assessment of the 39 events in this reporting period indicates: - 16 involved either administrative control deficiencies, inade- quate instructions, or inadequate procedures. i 7 involved errors by non-licensed personr.el. - - As many as 8 may have involved design defects. As many as 19 may have been repeats of earlier or similar events - at Pilgrim. (Note: events may be assigned multiple cause:) In conclusion, the large number of events involving deficiencies in administrative controls, inadequate procedures and repeats of i earlier, similar events points to the need for close monitoring of q the effectiveness of licensee management'in these areas. . - - - -

. ~. _, . _ 4 . L al .. , . TABLE'1 ' TABULAR LISTING OF LERs BY FUNCTIONAL AREA , PILGRIM NUCLEAR POWER STATION AREA CAUSE CODE ~ ~ ~ - - A B C 0 [ X TOTAL 1. Plant Operations 1 1 2 14 - - - 2. Radiological Controls - - - - - - 0 3. Maintenance e.id Modifications 4 1 7 6 1 19 - 4. Surveillance 4 '4 1 1~ 10 - - 5. Fire Protection - - - - - - 0 6. Emergency Preparedness - - - - - - 0 , 7. Security and Safeguards 1 ' 1 -2 - - - - 8. Engineering and 4 4 - - - - - Technical Support 9. Licensing Activities - - - - - 0- , 10. Training and Qualification 0 - - - - - - Effectiveness 11. Assurance of Quality - - - - - - 0 TOTALS- 10 4 2 11 7 5 39

Cause Codes: A - Personnel Error B - Design, Manufacturing, Construction, or Installation' Error C - External Cause D - Defective Procedure E - Component Failure 1 X - Other ' LERs Reviewed: 87-001-00 to 38-015-00 including 88-008-01 and 87-014-01 - 1 l f .- ,. - ~ . . . . . - - . _ . . . . . . . , . - - - - , - _ , . - , ~ _ .- _ , , . - - - , , - . , - - _ _ _ . , - , , - ,m , ,_. ,. -

% as m1-r . ._2 _J

a m a . .. .= . t TABLE 2 INSPECTION HOURS SUMMARY (02/01/87 - 05/15/88)~ , PILGRIM-NUCLEAR POWER STATION - Hours % of Time 1. Plant Operations 2178 22 , 2. Radiological Controls 1262 13 3. Maintenance and Modifications 2347 24 4. Surveillance 1386- 14 5. Fire Protection -493 5 6. Emergency Preparedness 176 2 ' 7. Security and Safeguards 641 7 8. Engineering and 1215 17. Technical Support . 9. Licensing Activities

- 10. Training and Qualification

- - Effectiveness ll 11. Assurance of Quality a* - - Totals 9698 -

Hours expended in facility license activities and operator license activities are not included with direct inspection effort statistics. Hours expended in the areas of Training and Assurance ~of Quality are

included in the other functional areas. , 1 Inspection Reports included: 50-293/81-06 to 50-293/88-22 4 i s i . . . _ _ , . _ _ _ , . ._ , , , _ , _ . , _ . , _ . - , . . - - _ , _ , _ _ _ . , . , _ . - . . . . . , . , . ,-._..,__,__.m...- _ , _ _ . _ _ . _ , _ , - , - _ . _ . - , , , , _ . _ _ _ _ _ . -

. l @ , . TABLE 3 ENFORCEMENT SUMMARY (02/01/87 - 05/15/88) PILGRIM NUCLEAR POWER STATION A. Number and Severity Level of Violations Severity Level I 0 Severity Level II 0 Severity Level III 0 Severity Level IV 21 Severity Level V 2 Deviation 0 Total 26* B. Violations Vs. Function Area Severity Levels Functional Areas I II III IV V Dev Total 1. Plant Operations - - 2 - - - 2 2. Radiological Controls - - - 8 - - 8 3. Maintenance and Modification - - - 6 - - 6 4. Surveillance - - - 1 - - 1 5. Fire Protection - - - 1 - - 1 6. Emergency Preparedness - - - 1 - - 1 7. Security Safeguards - - - - - - 3* l 8. Engineering and - - - 1 - - 1 Technical Support 9. Licensing Activities - - - - - - 0 10. Training and Qualification - - - - - - 0 Effectiveness 11. Assurance of Quality - - - 1 2 - 3 Totals 267

• Three security violations are being cor sidered for escalated enforcement

action and have not yet been categorized for severity.

.

• *

. TABLE 4 Pilgrim SALP History Assessment Period 1/80- 9/80- 9/81- 7/82- 7/83- 10/84- 11/85- 2/87 Functional Area 12/80 8/81 6/82 6/33 9/84 10/85 1/87 5/88 Operations 2 3 3 2 2 3 2 2 Radiological Controls 3 2 2 2 3 3 3 3 Surveillance 2 2 2 1 1 2 3 2 Maintenance 2 3 2 2 1 2 2 2 Emergency . Planning 3 1 1 1 3 3 2 2 4 Fire Protection 2 2 3 1 2 3 2 j - Security 2 2 2 2 2 2 3 2 Engineering and Technical Support - - - - - - 1 1 ' Licensing - - 2 1 1 1 2 2 Training Effectiveness - - - - - - 2 2 Assurance of Quality /QA 3 3 3 2 - - - - Outage Management 3 2 2 1 1 1 - -

__ .. .f .p . 9 TABLE 5 MANAGEMENT MEETING AND PLANT TOUR ~ SUMMARY DATE SPONSOR TOPIC 02/02/87 NRC Management meeting at Plymouth, MA to discuss the status of licensee improvement programs (IR 87-08) 02/0?/87 Massachusetts NRC Region I Administrator and other Region i Secretary of managers met in Boston, MA with several Energy Commonwealth administrators to discuss NRC activities regarding Pilgrim 03/09/87 Massachusetts NRC Region I Aduinistrator and other members of legislature the staff appeared in Boston, MA before the Massachusetts Joint Committee on the Investigation and Study of the Pilgrim Station at Plymouth (IR 87-16) > 03/10/87 NRC NRC Chairman Zech toured Pilgrim accompanied by the Regional Administrator and attended a l licensee presentation (IR 87-16) 04/27/87 Massachusetts NRC Region I Administrator and other members of Legislature the staff appeared in Boston before the Mass- chusetts Joint Committee on the Investigation , ! and Study of the Pilgrim Station in Plymouth (IR 87-18) 05/01/87 NRC Management meeting at NRC Region I to discuss a surveillance program violation and program j weaknesses (IR 87-23) J 05/07/87 NRC 1987 SALP manageme1t meeting at Plymouth, MA 05/22/87 NRC NRC Commissioner Carr toured the plant and attended a licensee presentation 05/27/87 Plymouth Four NRC Region I management representatives Board of participated in a public meeting in Selectmen Plyn.outh, MA 06/24/87 NRC NRC Commissioner Asselstine toured the plant and attended a licensee presentation . l

v c.

. ~'@ p . Table 5 2 ... , DATE- SPONSOR TOPIC 06/29/87 NRC Management meeting at NRC Region I to discuss the outage status, program improvements and licensee preparations for restart (IR 87-28) 07/23/87 Commonwealth The NRC Section Chief, Licensing Project Manager of Mass, and Resident Inspectors for Pilgrim met onsite with representatives of the Commonwealth to discuss the NRC inspection process (IR 87-27) - 09/09/87 NRC Enforcement conference at NRC Region I to discuss several. security violations (IR 87-30) 09/24/87 NRC NRC Director of the Office of Nuclear Reactor. Regulation, the Region I Administrator and other senior NRC managers met with the licensee in Bethesda, MD to discuss licensee activities and restart readiness (NRR meeting transcript) 09/30/87 NRC Enforcement conferance at NRC Region I to discuss several security violations (IR 87-30) 10/05/87 NRC NRC Commissioner Bernthal toured the plant and ' attended a licensee presentation 10/08/87 Commonwealth NRC Region I Administrator and other senior NRC of Mass. managers met at Region I with representatives of the Commonwealth of Mass. and two private citizens to answer questions regarding the NRC inspection-process (IR 87-45) i 10/29/87 Duxbury Board Four NRC Region I and NRR management of Selectmen representatives participated in a public meeting sponsored by the Duxbury Board of Selectmen, 1 Ouxbury Emergency Response Plan Committee and the Ouxbury Citizens' Committee on Nuclear Matters in Ouxbury, MA l 12/08/87 NRC NRC Region I Administrator toured { the plant and met briefly with licensee { management to discuss tour observations (IR l ' 87-57) .

_ _ . _ __ _ _ _ _---. _ __ , o .s-. o; s. Table 5 - 3 DATE SPONSOR TOPIC 01/07/88 United NRC Director of the Office of Nuclear Reactor States Regulation.and the Region I Administrator. Senator appeared before the Senate Labor and Human Kennedy Resources Committee regarding Pilgrim. The~ public hearing was held in Plymouth, Ma. 02/18/88 NRC NRC Region I and NRR managers conducted a public meeting in Plymouth, MA to solicit public comments on the licensee's Restart Plan 02/24/88 NRC Management-meeting at NRC Region I to discuss the licensee's self assessment process to be used for determining restart readiness (IR 88-10) 03/10/88 NRC The NRC Director of the Office of NRR and the Region I Administrator toured the plant and interviewed licensee staff regarding the design basis for the direct torus vent modification (IR 88-07) 04/08/88 NRC Hanagement meeting at NRC Region I to discuss the licensee's proposed power ascension test program (Meeting Minutes 88-43) 04/22/88 NRC NRC Commissioner Carr toured the plant and attended a licensee presentation (IR 88-12) ,

05/06/88 NRC NRC Commissioner Rogers toured the plant and ' attended a licensee presentation (IR 88-19) 05/11/88 NRC NRC Region I and NRR managers conducted a public meeting in Plymouth, MA to provide responses to comments and concerns on the licensee's Restart Plan raised during the 2/18/88 public meeting (Meeting transcript) l I i . - - - - - - - - - - - --. . ____ - _-_,--. .____ _ --

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