ML20151T276
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| ML20151T276 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 07/27/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20151T273 | List: |
| References | |
| 50-293-87-99, NUDOCS 8808160306 | |
| Download: ML20151T276 (72) | |
See also: IR 05000293/1987099
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ENCLOSURE
SALP BOARD REPORT
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U. S. NULLEAR REGULATORY COMMISSION
REGION I
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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
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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
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4.11 Assurance of Quality ............................... 53
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 l
5.4 Licensing Actions .................................. 59 l
E.5 Licensee Event Reports ............................. 63
TABLES
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Table 1 - Tabular Listing of Licensee Event Reports by Functional Areas
Table 2 - Inspection Hours Summary l
Table 3 - Enforcement Summary '
l Table 4 - Pilgrim SALP History Tabulation
Table 5 - Management Meeting and Plant Tour Summary l
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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-
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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
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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
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reflect a 15 month assessment period.
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1.2 SALP Board Members
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Chairman
S. J. Collins, Deputy Director, Division of Reacter Projects (DRP)
Members
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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)
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G. L. Sjoblom, Acting Director, Division of Radiation Safety and
Safeguards (DRSS)
R. R. Bellamy, Chief, Facilities Radiological Safety and Safeguards
Branch, DRSS
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D. H. Wessman, Director, Project Directorate I-3, Office of Nuclear
Reactor Regulation (NRR)
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D. G, Mcdonald, Licensing Project Manager, NRR
C. C. Warren, Senior Resident inspector, Pilgrim Nuclear Power
Station (PNPS), DRP
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Other Attendees
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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 ;
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1.3 Background
A. Licensee Activities
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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
i modification of plant equipment. The licensee completed fuel
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
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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-
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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. )
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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 !
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residual heat removal system. License exemptions and modi- $
j fications to the fire protection program and equipment to bring i j4
the plant into full compliance with 10 CFA 50 Appendix R, and to
improve reactor level instrumentation were completed. The '
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facility Emergency Operating Procedures were also upgraded to -
incorporate Revision 4 of the Boiling Water Reactor Owners Group
Emergency Procedures Guidelines.
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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
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power was restored within 45 minutes. A second loss of offsite !
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
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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.
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On November 9, 1987, the licer.see as a conservative measure l
halted ongoing maintemce rnd modification work at the station
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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
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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.
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The fire was extinguished by the plant fire brigade with no
j olant damage noted, and the Unusual Event was secured. 1
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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- I
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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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.
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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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l On October 15, 1987, Massachusetts Attorney General l l James M. Shannon filed a 10 CFR 2.206 petition, on behalf of his
office and Governor Michael S. Dukakis, requesting an order to l;
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show cause why Pilgrim should not remain shutdown until a full l
adjudicatory hearing resolves the issues raised in the petition. !
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The petition cited evidence of continuing managerial, Mark I
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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 ;
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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
6~ Onsite Electrical Distribution Adequacy Review li
7. Emergency Operating Procedures Review !
8. Maintenance Program Review
9. In plant Radiological Controls Review
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An NRC Order issued in 1984 requiring the 1.icensee to implement
a Radiation Improvement Program was closed during the period 1
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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.
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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 ,
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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
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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
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3. Responsiveness to f4RC initiatives
4. Enforcement history
5. Operatinnal events (including respon<a to, analyses of, and correc-
tive actions for) '
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6. Staffing (including management)
Training and Qualification Effectiveness
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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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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.
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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.
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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
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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.
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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 1
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 l
efforts. As a result of these transitions some individuals are l
relatively new to their positions and in some cases do not have I
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 ,
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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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.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
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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,
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3.2 Facility Performance
Functional Category Category Recent
. Area Last Period * This Period ** Trend
1. Plant Operations 2 2
2. Radiological 3 :3 Improving
Controls
3. Maintenance ar,d 2 2
Modifications
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4. Surveillance 3 2
5. Fire Protection 3 2-
6. Emergency 2 2 Improving.
Preparedness
7. Security and 3 2
Safeguards
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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 l
Activities j
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November 1, 1985 to January 31, 1987
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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
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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.
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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 l
the full recovery from the. LOOP and resulted in inadvertent
manual shutdown of one of the emergency diesel generators. As a i
further example, operator communication during a dry run of the ;
remote shutdown test was also informal and not completely
-
effective,
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.
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. 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
4
involvement in developing and implementing 'the Emergency Opera-
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 l
analysis improved significantly during the latter portion of the l
period. Event critiques led by the Operations Section Manager
!
and root cause analyses performed by the onsite Systems Engi- l
neering Group were thorough and aggressive. The critique pro- I
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 I
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
!
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.
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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
,
_ _ _ _ - _ _ . . _ . _ _ _ . _ _ _ _ _ - - - _ . - _ _ - - . - - - - _ - - . _ . _ _ _ . _ _ _ _ _ _ _ _ . . - _ - _ _ _ _ _ _ _ . _ _ _ - - _ _ - _ - _ - - - . _-- .__- _--- _-. - _ _ . . _ _ . - - - _ . - _ _ _ . . - _ _ _ . - . _ . - - _ _
4 .
4 * . 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
l . 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 i
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
l
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, - _ . . - - - . - - . - , - - -
... ,. , , . --
- - _ , , ., , _ , , , , - - , - - . . - - ., - - - -. , , ,
_
.
-
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. 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.
1
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 I
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 I
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 l
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- I
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 .
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. 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) :
l
(1) Analysis 1
This functional area is intended to assess the licensee'_s per- l
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. I
Engineering and Technical Support functional area. This SALP l
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
,
l
major plant equipment such as the Residual Heat Removal pumps, l
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.
)
l
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, , - . . , -- , ,-,
- -- - - -- - ~ . - -- ,- < - '-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
I
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.
- _- __
. _ - -, - . . . .- ~ . - . -
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i
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. 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 l
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 l
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 l
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 l
and tracking longer term work schedules by the close of the SALP l
period. Continued attention to developing and implementing I
effective maintenance schedules, and to improving the detail and I
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
*
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.l
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* 27
l
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-
,
l
tention to this areas intensified and major program improvements
were initiated. ,
l
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- l
4
cedures were found to be weak in some areas. Circuit breaker j
-
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. 1
The licensee has implemented a Material Condition Improvement
Action Plan (MCIAP) which identifies many of the weaknesses l
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
.
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4.4 Surveillance (1386 hours /14 percent)
l
(1) Ana?ysis l
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 l
attention.
l
During this SALP period surveillance testing was routinely ob- 4
served and procedure technical adequacy was evaluated. One l
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 l
centralized control and responsibility for surveillance program l
oversight contributed to continuing weaknesses. Ea rly in this
SALP period the licensee assigned responsibility for program
1
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- l
location of these resources has resulted in acceleration of l
program improvements and is an indication of management j
commitment.
)
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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 I
and Maintenance Section representatives was formed to address 1
the problem. Initially the effort was intended to assure com- l
pliance with technical specifications,. Licensee management I
expanded the upgrades however, to include testing of additional ;
system design features beyond technical specification require- ]
4
ments. This is an indication of the licensee's' desire to estab-
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 I
J
the new MSTP, and therefore final resolution of' the scheduling
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.
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The licensee's prugram for control of Measuring and Test Equip- i
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 l
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 l
management involvement. I
!
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 l
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. l
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 I
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 l
'
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.
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. 32 l
(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
4
progress of licensee improvement efforts, additionally two
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 l
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-
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. 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 l
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
.. . , - . _ _ _ , ___ . _ _ . _ _ _ _ _._ _ , _ _ _ . _ _ , . . _ _ . . _ _ _ , , - . _ . _ _ _ _ _ , _ . _ , _
'
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. 35
.
(2) Conclusion
Rating: 2
Trend: None Assigned
- _ _ _ . ._ _ - _ - , - - _
. _ _ - - - ,_ .__._ _._.-... , . _ _ - . . _ . _ . . _ - - . . - - . - - .-
- . . . _ -
,
0
. . . .
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:
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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 ;
e
the November,1987 inspection, significant changes were examined ,
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
4 Vice President. Functional responsibilities are divided into
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
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. 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. I
(2) Conclusion l
i
Rating: 2
Trend: Improving
!
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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
2
a section manager who reports to the Plant Support Manager,
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
. _ . _ _
.
. .
. 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.
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. 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 l
The security force training program appears to be adequate to l
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.
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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.
_
,
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' 42
(2) Conclusion
Rating: 2
Trend: None Assigned
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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 i
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.
~ _ _
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. '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
.
2
Evaluation (IPE) as part of the (SEP) using probabilistic and
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-
4
gram to meet the requirements of 10 CFR 50 Appendix R. The
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
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. 45
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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 l
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 4
and in maintenance performance. However, overall performance
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 1
operational and maintenance support to the site.
J 4
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(2) Conclusion
Rating: 1
,
Trend: None Assigned
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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
.
resources on the SEP. The licensee has been very active in .l
'
industry owner's groups involved in severe accident initiatives.
J
Although much of the SEP effort did not involve direct licensing
i
actions, the staff did assess tha safety significance of the i
licensee's modifications and inspected portions of the modifica- l
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.
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1
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 ;
4
Informnion Management System (SIMS) data base. Particularly l
! noteworthy was the high quality 'of technical support provided l
'
for the staff's review of Emergency Operating Procedures. l
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There -was evidence of.. improvement during the latter portion -of' l
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
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4.10 Training and Qualification Effectiveness
(1) Analysis
Technical training and qualification effectiveness =is being con-
I
sidered as a separate functional area. The various aspects of
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-
4 formance of. licensee personnel and, to a lesser degree, as a 4 review of program adequacy. '
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
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. 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- i
pendent verification requirements. On several occasions oper- I
ators failed to properly perform routine surveillances. l
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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
simulator, and other initiatives such as formal communications i
'
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,
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(2) Conclusion
Rating: 2
Trend: None Assigned
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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- l
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
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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- l
4
cluding the Operations Section Manager, Maintenance Section '
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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.
.
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- 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 l
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,
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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 '
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5.0 SUPPORTING DATA AND SUMMARIES
"
!
5.1 Investigation and Allegations Review
i
4 Twenty allegations were received during this SALP period. Eleven of j
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 .
i
actions were promptly initiated in each case. Four allegations are r
currently under review. One of these four concerns the licensee's ,
program for control of overtime which is the subject of ongoing ;
reviews. '
j One investigation was initiated during the assessment period as a f -
result of an allegation regarding a plant security vital area bar-
rier. This investigation is continuing.
'
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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 r
resolved. The CAL however was extended in August, 1986 and remains l
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 ;
e
action. This acticn is pending concluston of the OI investigation l
l described in Section 5.1 abov4.
;
An NRC Order issued in 1984 requiring the licensee to implement a i
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 l
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
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,
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, ,
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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) I
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(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 l
; Appendix J Requirements
l
.
114 Fire Protection - 03/08/88
Appendix R to 10 CFR 50 1
Requirements
115 Security Requirements - 03/28/88 l
10 CFR 73.55 l
'
116 Modification of Reporting 05/10/88
Schedule Supplemental Dose
!
Assessment & Meterological
Summary
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(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.
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_. . _ . - - _ . - _ - _ _ _ _ . _ . _ . . _ _
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a 64
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 . i
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: l
-
16 involved either administrative control deficiencies, inade-
quate instructions, or inadequate procedures.
i
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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. i
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(Note: events may be assigned multiple cause:) I
1
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 .
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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
X - Other 1
'
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LERs Reviewed: 87-001-00 to 38-015-00 including 88-008-01 and 87-014-01 -!
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.- ,. - ~ . . . _ _ _ . _ . - - . _ . . . . . . . , . - - - - , - _ , . - , ~ _
-
.- _ , , . - - - , , - . , - - _ _ _ . , - , , - ,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 ** - -
ll
Effectiveness
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
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. . . _ _ , . _ _ _ , . ._ , , , _ , _ . , _ . , _ . - , . . - - _ , _ , _ _ _ . , . , _ . - . . . . . , . , . ,-._..,__,__.m...- _ , _ _ . _ _ . _ , _ , - , - _ . _ . - , , , , _ . _ _ _ _ _ .
-
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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
l
2. Radiological Controls - - -
8 - -
8
3. Maintenance and Modification - - -
6 - -
6
4. Surveillance - - -
1
- -
1
5. Fire Protection - - -
1
- -
1 l
6. Emergency Preparedness - - -
1
- -
1 1
7. Security Safeguards - - - - - -
3* l
8. Engineering and - - -
1
- -
1
Technical Support
9. Licensing Activities - - - - - -
0
10. Training and Qualification - - - - - -
0 i
Effectiveness 1
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
l
Planning 3 1 1 1 3 3 2 2 4
l
Fire Protection 2 2 3 1 2 -
3 2 j
Security 2 2 2 2 2 2 3 2 I
Engineering and l
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 -
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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
.
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... 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 l
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)
.
!
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_ _---. _ __
,
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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)
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