ML20153D644

SALP Rept 50-293/85-99 for Oct 1984 - Oct 1985

ML20153D644
Person / Time
Site:	Pilgrim
Issue date:	02/18/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20153D628	List: ML20153D625 ML20153D644
References
50-293-85-99, NUDOCS 8602240206
Download: ML20153D644 (54)

See also: IR 05000293/1985099

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I U. S.: NUCLEAR REGU'LATORY COMMISSION

REGION I~

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! SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

INSPECTION REPORT 50-293/85-99

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BOSTON EDISON COMPANY

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PILGRIM NUCLEAR POWER STATION

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ASSESSMENT PERIOD: OCTOBER 1,-1984_- OCTOBER'31, 1985

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BOARD MEETING DATE: . DECEMBER 18,'1985

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TABLE OF CONTENTS '

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I. INTRODUCTION .................................................... ~1

A. Purpose and 0verview:....................................... 1

8. SALP Board Members ......................................... 1

C. Background ................................................. 2

II. CRITERIA ........................................................ 4

III. SUMMARY OF RESULTS .............................................. 6

A. Facility Performance ....................................... 6

B. Ove ra l l Faci l i ty Eval ua t i on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

IV. PERFORMANCE ANALYSIS ............................................ 9,

A. Plant Operations .......................................... 10

B. R a d i o l o g i c a l Co n t ro l s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

C. Maintenance and Modifications ............................. 20

D. S u rv e i l l a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 3

E. Emergency preparedness ............................. ...... 26

F. Security and Safeguards .... .............................. 28

G. Refueling and Outage Menagement ........................... 30

H. Li cen si ng Acti vi ti e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

V. SUPPORTING DATA AND SUMMARIES ...................................'35

A. Investigation and Allegation Review ....................... 35

B. Escalated En forcement Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

C. Management Conferences ..... .............................. 35

D. Licensee Event Reports .................................... 36

E. Operating Reactors Licensing Actions . . . . . . . . . . . . . . . . . . . . . . 37

TABLES

Table 1 Tabular Li sting of LERs by Functional Area . . . . . . . . . . . . . . T1-1

Table 1? LER Synopsis ............................ .............. T2-1

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Tt'le 3. Inspection Hours Summary ................................ T3-1

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Table 4 Enforcement Summary ..................................... T4-1

Table 5 Enforcement Data ........................................ ~TS-1

Table 6 Inspection Activities ................................... T6-1

Table-7 Plant Shutdowns ......................................... T7-1

FIGURE

Figure 1 Pilgrim Unplanned Plant Shutdowns . . . . . . . . . . . . . . . . . . . . . . F1-1

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I. INTRODUCTION

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A. Purpose and Overview

The Systematic Assessment of Licensee Performance (SALP) is an integrated

NRC staff' effort to collect the available observations and data on a i

periodic basis and to evaluate licensee performance based upon this.in-

formation. SALP is supplemental to normal regulatory processes-used to

ensure compliance with NRC rules and regulations. SALPlis intended to

be sufficiently diagnostic to provide a rational basis for' allocating

NRC resources and to provide meaningful guidance to the licensee manage-

ment to promote quality and safety of~ plant operation.

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An NRC SALP Board, composed of the staff members-listed below, met on

December 18, 1985, to review the collecticn of. performance observations

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and data to assess the licensee performance in accordance witn-the guid-

ance.in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Per-

fo rma nce" . A summary of the guidance and evaluation criteria is provided

in Section II of this report.

This report is the SALP Board's assessment of'the licensee's safety per-

formance at Pilgrim Nuclear Power Station for.the period October 1,-1984

through October 31, 1985.

B. SALP Board Members

Chairman:

R. Starostecki, Director, Division of Reactor Projects (DRP)

Members:

0. Ebneter, Director,-Division of Reactor Safety (DRS)

W. Kane, Deputy Director, DRP

E. Wenzirger, Chief, Projects Branch No. 3, DRP

J. Joyner,-Chief Nuclear Material Safety and Safeguards Branch, Division

of Radiation Safety and Safeguards (DRSS) (part time) -

R. Bellamy, Chief, Emergency Preparedness and Radiological Protection

Branch, DRSS (part time)

L. Tripp, Chief, Reactor Projects Section 3A,.DRP

M. McBride, Senior Resident Inspector t

W. Minners, Chief, Safety Protection Evaluation Branch, NRR

P. Leech, Project Manager, NRR

Other Attendees

J.^ Johnson, Chief, Operational: Programs Section, DRS

. G. Meyer,-Project Engineer, DRP

W. Pasciak, Chief, Effluent Radiation-Protection Section, DRSS (part time) l

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D. Sullivan, Performance Appraisal Section, Office of Inspection and

Enforcement (OIE)

13. Sharkey, Performance Appraisal Section, 0IE

W. Lazarus, Senior Emergency Preparedness Specialist, DRSS (part time)

C. Background

1. Licensee Activities

The SALP a;sessment period began during a recirculation piping re-

placement outage, ihe outage began in December 1983 and ended on

December 24, 1984. Fuel was reloaded into the reactor core in

November 1984. A hydrostatic pressure test of the reactor ccolant

system and an integrated leakage test of the primary containment

were' conducted in December 1984. On December 24, 1984, reactor

criticality was established and a slow startup sequence was initi-

ated. The reactor was briefly shut down on December 25, 1984, due

to fluctuating reactor water level instruments.

On January 1, 1985, the reactor was shutdown for seven days when

loose debris was detected in the standby liquid control system

(SLCS). Maintenance on leaking torus to drywell vacuum breakers

was also conducted during the shutdown. The reactor was restarted

on January 7, 1985 and reached full power on January 30, 1985.

The reactor was subsequently shutdown between February 9 and 15,

1985, to repair bearings in the "A" recirculation pump notor.

During the startup on February 15, a primary coolant system leak

was detected in a weld in the reactor vessel drain line. The

shutdown was continued until February 17, 1985 when repairs were

completed on the line.

The reactor scrammed on March 15, 1985 due to a sticking reactor

water level instrument manifold valve during a routine surveillance

test. While the reactor was shut down, maintenance was conducted

on the reactor water sample system (needed for a subsequent hydrogen

injection test) and on secondary containment dampers. The plant

was restarted on March 20, 1985, and operated until April 4, 1985

when the reactor scrammed due to high main turbine vibration. The

plant was returned to service on April 5, 1985.

On June 14, 1985, the reactor scrammed during low power maneuvers

due to an inadvertent high reactor water level isolation. The plant

was restarted on June 15 and operated until September 1,1985 when

the reactor scrammed following a generator load rejection. The

reactor was restarted five days later, following repairs to the "B"

recirculation pump seal. The startup was halted and the reactor

shutdown on September 5, 1985 for additional repairs to the "B"

recirculation pamp seal. On September 7, 1985, the reactor was

restarted and it operated until the end of the assessment period.

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A hydrogen injection experiment was conducted between May 9 and 13,

1985 to test the effect of. feedwater hydrogen on plant . radiation

levels. .The annual emergency preparedness _ exercise was' conducted

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on September 5, 1985. Hurricane Gloria was in the vicinity of.the

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plant on September 27, 1985. Wind speed. reached-75 miles per hour: -

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onsite. Power was reduced to less than 25% and the generator was

taken off.line. No. storm damage to the station occurred.

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2. Inspection: Activities

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Two NRC' resident inspectors-wsre assigned to the Pilgrim Nuclear-

Power' Station between October 1984 and July 1985. One resident

inspector was assigned between July and the end of the assessment

period. The total-NRC inspection effort for the period was 3793

hours, distributed in the appraisal functional areas as shown in

Table 3. This represents 3501. hours per twelve month pe. Ud.

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Team inspections were conducted during the assessment'pe'iad r to.

examine the following areas: *

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Plant readiness for-restart from the 1984. recirculation pipe

replacement outage,

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Emergency plan remedial drill,

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Emergency planning program,

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Health physics program,

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Licensee-vendor interactions,

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Annual emergency plan' exercise,

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Radiochemistry program (using the NRC mobile laboratory), and

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Refuel bridge damage ~ .

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Tabulations of violations and inspector activities are presented

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in Tables 4 and 6, respectively.

The area of fire protection was not rated this period since there l

was no overall . inspection of the program. ' Inspection hours in this

area were primarily limited to resident inspector observations in-

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the plant'. Housekeeping was. considered in each of the appropriate

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functional areas. '

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II. CRITERIA

Licensee performance is assessed in selected functional ar.eas, depending on;

whether the facility is in a construction, preoperational, or operating phase.

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Each functional , area normally represents areas significant. to nuclear. safety.

and the environment, and are normal orogrammatic areas. Special areas may

be added to highlight significant observations.

One or more of the following evaluation criteria were used to assess each

functional area.

1. Management involvement and control in assuring quality

2. Approach to resolution of technical issues from a safety standpoint .

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3. Responsiveness to NRC initiatives

4. Enforcement history

5. Reporting and analysis of reportable events

6. Staffing (including management)

7. Training and qualification effectiveness

Based upon the SALP Board assessment each functional-area evaluated is clas-

sified into one of three performance categories. The definitions of these

performance categories are:

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Category 1. Reduced NRC attention may be appropriate. Licensee management

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attention and involvement are aggressive and oriented toward nuclear safety;

licensee resources are ample and effectively used so that a high level of

performance with respect to operational safety is being achieved.

Category 2. NRC attention should be maintained at normal levels. Licensee

management attention and involvement are evident and are concerned with nuc-

. lear safety; licensee resources are adequate and reasonably effective so that

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satisfactory performance with respect to operational safety is being achieved.

Category 3. Both NRC and licensee attention should be increased. Licensee

management attention or involvement is acceptable and considers nuclear safety,

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but weaknesses are evident; licensee resources appear to be strained or not

effectively used so that minimally satisfactory performance with respect to

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operational safety is being achieved.

i The SALP Board also assessed each functional area to compare the licensee's

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performance during the last quarter of the assessment period to that during

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the entire period in order-to determine the recent. trend for each functional

area. The trend categories used by the SALP Board are as fol'ows:.

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Imoroving: Licensee performance has generally improved over the last quarter

of the current SALP assessment period.

Consistent: . Licensee performance has remained essentially constant over the-

last quarter of the current SALP assessment period.

Declining: Licensee performance has generally declined over the last quarter

of the current SALP assessment period.

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. III. SUMMARY OF RESULTS

A. Facility Performance

CATEGORY CATEGORY

LAST THIS RECENT

FUNCTIONAL AREA PERIOD * PERIOD ** TREND

1. Plant Operations 2 3 Consistent

2. Radiological Controls 3 3 Improving

3. Maintenance & Modifications 1 2 Consistent

4. Surveillance 1 2 Consistent

5. Emergency Preparedness 3 3 Consistent

6. Security & Safeguards 2 2 Consistent

7. Refueling / Outage Activities 1 1 No Basis

8. Licensing Activities 1 1 Consistent

July 1, 1983 to September 30, 1984

October 1, 1984 to October 31, 1985

B. Overall Facility Evaluation

Recovery from the recirculation piping replacement outage was conducted in

a slow, cautious manner with active. involvement of both onsite and corporate

management. The outage highlighted the licensee's commitment to upgrade plant

hardware. Replacement of the piping also resulted in an extensive plant de-

contamination program. Similarly, upgrading of plant hardware to satisfy NRC

regulations-regarding environmental qualification was noteworthy. When con-

sidering each of the functional areas assessed, the licensee's commitments

to a plant betterment program is evident. Notwithstanding the clear evidence

in hardware improvements, there are symptoms which are indicative of: problems

associated with personnel staffing and supervisory / management oversight.

These are discussed below.

One of the. significant outcomes noted during the SALP Board deliberations was

the recurrent issue of staffing. In the areas of operations, security, main-

tenance and radiological controls, the adequacy of staffing supervisory, pro-

fessional and crafts positions was noted to be weak. In a similar vein, the

oversight of BECo supervisors of work in progress by either BEco staff.or

contractors was noted to be insufficient. Whether this is due to a lack of

supervisors or lack of a policy to foster such work habits' by supervisors is

not clear. However, review of the enforcement history (Table 5) clearly high-

lights a number of recurring problems attributable to either poor procedural

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adherence, poor administrative practices or failure on the part of managers

and supervisors to ensure proper planning, scheduling and performance of re-

quired tests or maintenance. Similarly, a review of plant shutdowns (Table

7) shows that some of the four automatic scrars and five plant shutdowns can

be attributed to similar causes.

Another. observation relates to the lack of critical self-assessment. During

the assessment period, significant NRC interaction was required to identify

problems and subsequently to get appropriate corrective action. In some cases,

corrective actions tended to be superficial in that they addressed only the

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symptoms but not the underlying reason for the problem. A complicating factor

, in this regard is the management attitude toward perceived weaknesses; a de-

fensive posture is frequently taken with respect to NRC as well as licensee

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self-identified weaknesses. This defensive posture inhibits a thorough and

critical evaluation with subsequent delays in resolving the problem (s). Con-

sequently, problems tend to linger for long periods until drastic measures

are taken. The radiological improvement program is an example of a drastic

corrective measure. In response to an NRC order, BEco is developing a frame-

work for improved performance, but nonetheless, NRC oversight and action are

still required to assure proper development and implementation. For example,

the licensee repeatedly failed to correct a problem identified by the licen-

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see's independent radiological assessor until the NRC staff took action.

Similar problems have been observed in the ecergency planning program; the

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self-critique of the annual exercise was not thorough, the commitment to ade-

quate emergency facilities required NRC action, and lack of personnel con-

tinues to hinder program improvements. Another lingering problem is the ade-

quacy of licensed operator staffing.

In summary, there has been an improvement in plant hardware over the last

several years. However, the SALP results indicate that further improvements

are not readily achievable until the staffing / personnel situation is resolved.

This, in our view, can be accomplished by a more aggressive posture and fol-

lowup by management to ensure better training, procedural adherence, planning

and supervision of work.

Training

There are no training programs at Pilgrim that have been accredited by INP0

during the appraisal period. Over the year, there has been a continuing im-

provement in the number of senior reactor operators but this has resulted in

shortage of reactor operators which now is becoming acute. There were two NRC-

administered exams during the appraisal period. In December 1984, 4 of 7 SR0

candidates were licensed, 2 of 3 R0 candidates were licensed. The 3 SR0 and

1 R0 failures were retested in May 1985 with satisfactory results. This ex-

perience indicates that (1) the number of R0 candidates taking the exam is

very low and (2) the SR0 training program was deficient as evidenced by the

failure rate. The licensee has managed to overcome SRO shortages; unfortu-

nately, this was at the expense of R0s. The licensee's screening and/or

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training program for R0s is not effective in resolving this long standing l

problem. Consequently, operator overtime has been relied on to continue -

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operations and there is less flexibility to place experienced staff in support

organizations. During the next appraisal period, NRC audit of the licensed

operators' requalification program will provide further insights into training

effectiveness. Training of the non-licensed staff has not been specifically

inspected; INPO accreditation should assure that programs are in place. Sub-

sequent NRC inspections will focus on effectiveness as evidenced by operator /

worker practices in the plant. Based on the performance results noted in this

SAlp, there may be a need for additional training for first line supervisors

to properly manage and oversee activities. Such efforts are an effective

means of assuring adherence to procedures, minimizing personnel errors, and

identifying design weaknesses.

Quality Assurance

The assurance of quality is a responsibility of every individual at the plant.

One of the mechanisms available to managers is the use of a quality assurance /

control program to monitor work in progress and to audit programs. QA/QC per-

sonnel were actively involved in reviewing plant operations during the assess-

ment period. However, there was a lack of timeliness of plant managers and

staff to correct problems identified in the QA/QC findings. This lack of re-

sponsiveness indicates that management is not taking full advantage of the

QA/QC program. It is not obvious whether this is a result of poor attitudes

or insufficient resources; however, it does require senior management atten-

tion to resolve the problem.

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IV. . PERFORMANCE ANALYSIS

A. Plant Operations (1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, 29%)

1. Analysis

During the previous assessment period, problems were identified-in

the areas of safety system valveLposition monitoring, independent

verification of safety system conditions, uncorrected Quality As-

surance (QA): findings, and licensed operator staffing.

No subsequent valve position ~ concerns were identified _during the

current assessment period, indicating'that licensee corrective ac-

tions were adequate. Additional NRC effort was. required to obtain

an acceptable corrective action for the uncorrected QA findings

(termed by the licensee " Operational Surveillance" findings)._ Ad-

ditional NRC effort was also required.to. resolve the independent

verification concern. The operator staffing problem became more

l acute during the current assessment period and is discussed below.

The operators conducted routine power reductions-largely without

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incident, demonstrating their ability to handle the plant in a pro-

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fessional manner. Control room atmosphere was generally quiet with

nonessential business diverted-to an administrative annex. Ap-

proaches to safety issues were conservative and no significant

problems were icentified. -Weaknesses were identified in.the areas

of licensed operator staffing, corrective actions, and occasional

lapses in operator attention to detail.

A chronic shortage of licensed reactor operators grew worse during

the assessment period due to promotions, job transfers, and the

death of one individual. At the end of the assessment period, only

nine reactor operators and one-senior operator (functioning as a

! reactor operator) were staffing five' operating shifts. To compen-

sate for the shortage, operators routinely exceeded-the overtime

guidelines in NRC Generic Letter 82-12. Senior licensee management

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did not become aware of the full extent of operator overtime until

after one individual's time' card indicated that he worked 97 hours0.00112 days <br />0.0269 hours <br />1.603836e-4 weeks <br />3.69085e-5 months <br />

in a seven day period. A continuing weakness in the overtime ap-

r proval process caused operators to repeatedly (thirty-five instances)

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exceed overtime guidelines without station management's prior knowl-

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edge or approval. NRC concern about the implementation of.the '

overtime guidelines was discussed with -the licensee :in early 1985.

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The need for additional NRC action in this area demonstrates inade-

! quate'long range planning and. staffing, weaknesses in policy imple-

mentation, and lack of effective corrective action for a recurring

problem.

The lack of a sufficient number of licensed operators-has been a:

repeated NRC concern over the past four years. This concern was

discussed in the 1983 SALP report and highlighted in the.1984 SALP

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report. Despite these concerns,. senior-licensee management did not

act to ensure that an.adequa.e number of individuals with appropri-

ate backgrounds / capabilities entered.the reactor operator training

program pipeline. Finally, in the latter part of'this assessment

period, the licensee recognized that the operator shortage problems

would require -a substantial manpower commitment to resolve. As a

result, ten new staff ~ positions for licensed reactor operators were

added to the Opefations Department. Unfortunately, the effect of

this staffing increase will not be realized until the licensing

process'is complete in 1987. If additional attrition takes place;

or if the current candidates do.not pass the .next scheduled NRC'

license examination in May 1986, the operator shortage could con-

tinue into 1987 or beyond. Continued management attention to re-

cruiting, training, and retaining licensed reactor operators.is

imperative to prevent the current operator shortage from becoming

more acute.

The licensee instituted six shifts of senior reactor operatorsLdur-

ing the assessment period, demonstrating improvement in this area.

However, the licensed operator shortage may require the diversion

of some SRO's to operator positions, decreasing the SRO shifts to

five.

Imprnvement in the operations program such as reorganizing valve

lineup procedures, valve tagging,.and the development of operations-

oriented system drawings were planned by the licensee, but not im-

plemented during the assessment period due to. support staff limita-

tions. While the licensee previously increased clerical assistance

in the Operations Department to help with routine activities, pro-

fessional-level support remains minimal. The lack of professional

support coupled with the shortage of licensed personnel-(available

for collateral duties) has severely hampered operational program

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initiatives.

The quality of the licensee's operator training program was judged

acceptable, with seven senior reactor operators and three reactor

operators licensed during the assessment period. Three of the

senior operators and one operator failed portions of their initial

written examinations, but successfully passed subsequent makeup

exams. The material sent to Region I for preparation of the ;origi-

nal and makeup operator examinations was of poor quality and did

not identify all current plant modifications or procedure changes.

New operator and senior operator training lesson plans are being

developed in accordance_with INP0 performance elements. The new

lesson plans should improve training' program effectiveness. The-

licensee should expedite this development and finalize the lesson

plans prior to the next scheduled examination in May 1986. Con-

struction of a simulator is continuing and should be completed ~ by

late 1986 or early 1987.

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Lapses in operator attention to detail involved the_use of. nuclear

instrumentation during refueling operations (bypassing one SRM and

not continuously monitoring another SRM), the assessment of drif ting

reactor protection-system instrumentation (main steam line radiation

monitors), and an' inadvertent reactor scram from low power due to ,

inadequate reactor water level control. Additional operator atten--

tion could have prevented the loss of secondary containment integ '

rity while the plant was at power. Circumstantial evidence'indi-

cates that increased operator attention might have-prevented re-

fueling equipment from being damaged during fuel movement at:tre

end of the assessment period. '

While the licensee's response to NRC initiatives was generally ade-

quate, considerable NRC effort was required to resolve control room

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manning issues and to ensure that adequate corrective actions were

taken following the discovery of refueling equipment damage. The

response to these issues, which involved handling of personnel,

contrasted to the licensee's usual approach to safety issuesLin-

volving hardware. Hardware issues were' typically; approached in a

manner which stressed safety. For-example, the licensee set the~

main steam line high radiation monitor trip points to conservative-

l values between test runs during hydrogen' injection experiments, be-

yond technical specification requirements. Licensee management-ac-

tions on personnel related issues as well as the ~ failuref to antici-

pate the shortage in licensed reactor operators indicates inadequate

management sensitivity to the effect of personnel. decisions on plant

operations.

A detailed evaluation of LER quality using' a sample of 10 LERs is-

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sued curing the assessment period was made using a refinement of

the basic methodology presented in NUREG/CR-4178. In general, they. ,

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found these LERs to be of acceptable quality based on the require-

ments contained in 10 CFR 50.73. There were nine LERs submitted ~

for this functional area; they were for a variety of causes. There

were no adversa trends noted. A generally conservative-approach

is taken in reporting under 10 CFR 50.73.

The 1984 SALD report expressed a concern-about the large amount of.

time spend by licensee managers in safety committee duties. The

licensee has taken steps to reduce the impact of the onsite Opera-

tions Revies Committee (ORC) by changing ORC membership and _ reducing

the review workload. The plant manager no longer chairs ORC-meet-

ings, but cantinues to review and approve ORC recommendations. ORC

workload will be decreased by identifying station procedures that

do not need ORC approval. .These efforts are important and should

continue. '

Licensee 06 audit activities associated with operations were,gener-

ally adr,uaca during the assessment ' period,' demonstrating a continu-

ing comn.it.nent in this area. QA staffing was maintained with.few

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vacancies. However, licensee managemen't was someti.ies slow in re-

sponding to QA surveillance and audit findings. .This-lack of re-

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sponsiveness indicates that management is not taking full . advantage

of the quality assurance program. . Senior licensee management has

not ensured that management support for the QA process is evident

and that plant personnel have the appropriate attitudes and-resources

to effectively respond to'QA findings, maximizing the usefulness

of theJQA program.

In summary,' lack of effective management action onLlicensed ' operator

staffing has permitted the number of licensed operators .to drop to

minimally acceptable' levels. If the shortage worsens, plant cpera-

tions may be disrupted. Theistaffing problems combined with a lack

of-alternative operational program support has' delayed action on

1 several operational improvement 1tems. These items could improve-

operator efficiency and reduce the chance of safety-significant

operator errors. Lack of operational support may have weakened the

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plant-staff's attitude towards the QA program, also slowing the re-

solution of QA findings. Although plant performance during the_as-

sessment period was' acceptable, the-board believes that these prob-

lems are significant and that future plant-performance and safety

may be degraded without senior management action to strengthen this

functional area. No significant weaknesses were identified in the

licensed operator training program.

2. Conclusion

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Rating: Category 3.

Trend: Consistent.

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The performarce rating in this category is not intended to imply

concern about individual operator performance. The rating is pri-

marily a reflection of inadequate senior management response to

personnel related matters such as licensed operator staffing,

operations department support, and control room manning.

3. Board Recommendation:

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Develop-contingency and long term staffing plans for licensed

operators.

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Assess the adequacy of Operations' Department staffing and sup-

port including: licensed personnel, support staff, and training

staff.

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Assess the adequacy of management information systems for mid-

level managers that could preclude problems such as unauthorized

operator overtime.

NRC:

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Closely monitor status of licensed operator training program.

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Arrange for a corporate management meeting which includes

senior licensee corporate management, upper Region I management,

and representatives of the NRC program offices to discuss

operations staffing problems.

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B. Radiological Controis (513 hours0.00594 days <br />0.143 hours <br />8.482143e-4 weeks <br />1.951965e-4 months <br />, 14%)

1. Analysis

During the previous assessment period, weaknesses were noted in the

evaluation of radiological incidents, ALARA program, description

of personnel authorities and responsibilities, technician retraining

program, alpha radioactivity monitoring program, and radioactive

waste transportation program. A Category 3 rating was assigned.

Improvements have been noted in these areas during the current

assessment period due to an extensive Radiological Improvement Pro-

gram (RIP) instituted in 1985.

There were seven inspections conducted by radiation specialists this

assessment period and periodic coverage by the resident inspectors.

Areas examined included: radiation protection; radioactive waste

management and transportation; effluent controls and monitoring;

l chemistry; and radiochemistry. There were three special inspections:

two to review circumstances, licensee evaluation and corrective

actions for unplanned personnel exposures; and an inspection of the

licensee's implementation of NUREG-0737 post-accident sampling,

analysis, and monitoring requirements. An Order Modifying License

was issued in November 1984 for correction of problems associated

with an August 1984 unplanned personnel exposure during control rod

drive work. An Enforcement Conference was held in January 1985 to

discuss problems associated with a December 1984 unplanned personnel

exposure during sludge lancing.

2. Radiation Protection

The licensee continued to experience problems in the area of self

identification of problems and initiation of prompt, comprehensive

corrective actions to resolve identified problems and prevent re-

currence. The deficiencies appear to be associated primarily with

the licensee's oversicht of contractor activities. Examples are:

--

In December 1984, a contractor employee made an unauthorized

entry to a tank to perform sludge lancing. The licensee's

oversight of this nigh radiation area work was less than ade-

quate in that: established high radiation area controls were

not implemented, appropriate additional procedures were not

established, nor was supervisory oversight of this activity

effective. A Health Physics supervisor eliminated established

high radiation area controls and failed to revise a radiation

work permit accordingly. This problem existed for several days

prior to NRC identification. Effective licensee corrective

actions were implemented in response to this incident after

NRC concerns were identified.

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--

A second example involved the licensee's oversight of~ spent

fuel pool work. NRC review of contractor cutting of. highly

radioactive components (e.g. control rod. blades) found that:

unapproved contractor procedures were~being~used for the acti-

vity; discrepancies existed between unapproved contractor and

~

licensee approved procedures for the work; and personnel were

not trained or qualified. in all appropriate procedures. Simi-

lar problemr were identified during licensee and NRC' review. ,

of two unplanned' personnel exposures sustained by-contractors

during control rod drive work last assessment period; . The 2

licensee's corrective actions for fuel pool work were " job- '

specific" and not comprehensive. As a result, additional NRC -

effort was needed to obtain an acceptable resolution of prob--

lems associated with'this work.

--

A third example involved failure to correct high radiation area

surveillance deficiencies. The problem involved failure to

clearly specify the Technical Specification required.high

radiation area surveillance frequency on radiation' work permits' .

This. problem was brought to the licensee's attention on a num-

ber of occasions. The licensee's final 2 corrective actions have

not yet been received and reviewed-by NRC.

Due to the number and nature of problems identified in 'the radio-- ,

logical controls area last assessment period, ian Order Modifying ,

License was issued. This Order required that at comprehensive review

of-the radiological controls program be performed by.the licensee.

and that-the findings of this ' review be addressed by a Radiological-

Improvement Program (RIP). NRC monitoring of Order implementation

found that the licensee performed an indepth review of.the radio-

logical controls and established a RIP to address deficiencies.

The RIP,-as established,' addresses fourteen major areas of the

radiological controls program and includes in excess of 200 com-

mitted primary action items. Although licensee senior management

is closely monitoring status and progress of the action items, .im- o

plementation and effectiveness are not' closely monitored. Although

no major problems were identified by the NRC in licensee implemen-

tation of the Order, problems were~noted with the RIP failure to

address high radiation area access key controls and some failures

to generate acceptable procedures.to meet. RIP commitments. . Work

is still ongoing with the most corrective actions scheduled to be

implemented by December 1985. The licensee has considerable work

yet to do in the area of ALARA Program establishment; procedures; >

management oversight; and corrective action system. .The actions

taken"to date are indicative of senior management's effort to im-

prove the radiological controls program at Pilgrim.

At the end of-the assessment period, the licensee was actively re-

-cruiting to fill a number ~of vacancies. These' included it chief

radiological supervisor and the chief chemical engineer. The lic-

_

_ _-__ _ _ - _ ______- _-__ _ ______-_ .-_ __ ___ _ _ _ -

_

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16

ensee was using a large number (about one licensee to four contrac-

tors) of contractor radiation protection technicians to implement

radiological controls. Some problems were identified with contrac-

tor technician efforts involving inadequate oversight of radiological

work on a monitor tank.

Findings of radiological occurrence reports (ROR) were not always

handled in a timely, comprehensive manner. Corrective actions for

ROR findings were sometimes late and superficial. These problems

were apparent in the areas of radiation protection procedure ad-

herence and high radiation area key control. Repeat problems con-

tinue to be identified by the licensee's Radiological Assessors.

In one case, NRC action was required to ensure that recurring prob-

lems identified by the Radiological Assessor were corrected. The

lack of timely corrective action indicates that mid-level management

is either not prioritizing work effectively or does not have suf-

ficient resources to respond to problems. The licensee is currently

revising the radiological occurrence report procedure to address

these problems and ensure action is taken to prevent recurrence.

The licensee has implemented temporary measures to address tl is

problem pending procedure revisions.

Occupational radiation exposures at Pilgrim continue high, 4,082

person-rem in 1984, due partly to a high radicactive source term

in the plant. No major problems with the ALARA program were. iden-

tified during the assessment period, but the high levels of radi-

ation in the plant makes ALARA practices particularly important at

Pilgram.

During the current assessment period, the licensee conducted an ex-

tensive decontamination program for large areas of the process

buildings. This cleanup effort significantly improved the access

to safety equipment and should continue. However, recontamination

of the clean areas is an ongoing problem. The licensee was develop-

ing a long term program to address the recontamination problem at

the end of the assessment period. More containments of water leaks

are being used than in the past, but uncontained leaks of potentially

radioactive water are still noted in the quadrant rooms of the re-

actor building. Continued management attention will be required

to develop a program that will prevent plant conditions from de-

grading (as a minimum) and to continue to reduce area contamination

levels. As long as ALARA practices are employed during decontami-

nation activities, the benefits of better access to plant equipment

should outweigh the radiation expos,re costs of decontamination.

The radiation protection technician training program has been sig-

nificantly upgraded, in response to RIP commitments. Training for

radiation protection supervisors and contractor technicians has also

been upgraded. These program now contain defined objectives and

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training outlines and appear effective. The retraining program for

-

technicians is-not well developed. . General- employee' training is

aggressive.

3. Radioactive Waste Management and Transportation

- -In response to the previously- discussed Order Modifying! License, .

c the licensee-performed a comprehensive review of the' radioactive

waste management and transportation areas. _iiinor. deficiencies

identified have been included in the license:'s Radiological.Im-

provement Program. NRC review found that program improvements have-

_

been implemented on schedule. : Improvements have been made'in the

areas of establishment of Program Policies; ransolidation of radio-

active waste storage areas; designation of, approved storage.loca-

tion; and shielding and isolation of waste. In an effort to upgrade

the quality of the radioactive _ waste shipping' procedures, the:lic-

ensee is currently reviewing and revising them. These actions by

the licensee should enhance the quality of his radioactive Waste

Management and. Transportation Program.

Overall, no significant problems were' identified in this area. :The

licensee has been implementing a generally effective radioactive

waste management and transportation program.

4. Chemistry / Radiochemistry and Effluent Monitoring and Controls

The licensee was found to have an effective chemistry / radiochemistry

and effluent monitoring and control program. As part of the re-

organization initiated as a result of the Radiological Improvement

Program, the licensee has reorganized the chemistry group and has

created and filled additional positions. Staffing was.found to be

adequate. Technician knowledge and understanding of' procedures-

was apparent.

.

As part of the routine inspection program the licensee was requested

to analyze split samples and pre prepared samples (both radioactive

and non-radioactive). ' Licensee technicians performed acceptable

analysis of samples provided thereby demonstrating licensee cap-

ability to perform satisfactory analysis of effluents.

The licensee experienced a number of unplanned releases this as-

sessment period. Two-involved releases of-liquid and gaseous ef-

fluents from a machine shop. A portion of a normally " clean" ma-

chine shop was converted.to a hot machine shop without the benefit

of an adequate review of the potential for unmonitored, uncontrolled

release from the hot shop. .In one event,. liquid' radioactive mate-

'

rial was introduced into normally clean station sewage. In another

event, the normal ventilation system in the shop released unmoni--

tored contaminated air to the environment. Although the situation

was licensee identified, the licenseeLfailed to perform adequate i

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reviews of normally uncontaminated systems in accordance with IE

Bulletin 80-10. Such reviews were to be performed to prevent and

readily detect situations similar to the one which occurred. The

-third release involved malfunction of sewage pumping equipment which

led to an inadvertent overflow of sewage to storm drains. It was

quickly repaired by the licensee. No apparent release in excess

of allowable limits occurred during the three releases.

A special inspection of the licensee's post accident sampling, an-

alysis, and monitoring capabilities relative to NUREG-0737 require-

ments found that the licensee met the requirements specified in the

NUREG with few exceptions. This reflected good coordination between

the engineering groups and the site. Some procedural deficiencies

and a deviation " volving a failure to install protective conduit

on the drywe'. ~ .igh range monitor detector cables were identified.

Training of technicians on the operation of the post accident pri-

mary coolant and containment atmosphere sampling system was com-

mendable as evidenced by demonstrated performance capabilities.

5. Summary

In summary, the licensee continues to experience problems in the

area of oversigh- of radiological work and self identification and

resolution of problems to prevent their recurrence. Despite ongoing

program improvements under the RIP, these problems indicate that

weaknesses were still present in the radiation protection program.

Weaknesses in the identification and-correction of problems indi-

cates that upper management initiatives in this area are not fully

understood by mid-level managers or that human resources may not

be sufficient. Program improvements being made to satisfy RIP com-

mitments should considerably improve the overall quality of the

program.

6. Conclusion

Rating: Category 3.

Trend: Improving.

7. Board Recommendations

Licensee:

--

Upgrade the process used to self identify radiological problems

to ensure timely resolution and prevent their recurrence.

Maintain independent reviews of the radiation protection pro-

gram.

--

Contir.ue to vigorously implement initiatives and/or recommen-

dation contained in the Radiological Improvement Program.

--

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--

Fill identified vacancies and minimize reliance on contractor

personnel providing oversight of radiological work.

NRC:

Maintain increased inspection effort in this area. Hold a manage-

ment meeting with the licensee to review the status and effective--

ness of the Radiological Improvement Program.

.

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20

C. Maintenance and Modificatic's (820 hours0.00949 days <br />0.228 hours <br />0.00136 weeks <br />3.1201e-4 months <br />, 22%)

1. Analysis

During the last assessment period, a lack of ,rocedural guidance

for electrical bus transfers was identified c a weakness. The

+ licensee olans to address this concern prior to the next refueling

outage. ibis action is considered timely. The SALP board also

recommended that the licensee continue initiatives in maintenance

trending and tracking. While no significant additional actions have

been taken in this area, no recurring maintenance problems were

identified that indicate weakness in the licensee's trending program.

During the current SALP period, specialist inspections reviewed

previous ins, action findings and water hammer events that occurred

in the high pressure coolant injection (HPCI) system. No signifi-

cant problems were identified during these reviews or during routine

resident inspections of this functional area.

Licensee approaches to maintenance and modifications were generally

thorough and continued to emphasize the identification of root

causes to problems. Despite weaknesses in the areas of vendor in-

teractions 4,id preventive maintenance, the overall performance in

this functional area was considered strong.

Good control was demonstrated over extensive online plant modifica-

tions which have been conducted with the reactor at power. With

the exception of one security problem (See section G), significant

plant modifications have been installed without incident during the

current operating cycle.

A review of the licensee vendor interface program identified several

weaknesses. The licensee program did not systematically address

correspondence from vendors other than General Electric. Additional

problems involving the scope of reviews of vendor information, the

timeliness of the reviews, and the documentation of the reviews were

identified. However, no significant equipment deficiencies were

identified resulting from these program weaknesses.

Licensee corrective actions for maintenance findings were typically

comprehensive and timely. Licensee actions to correct recurring

problems appeared generally effective. Two isolated instances of

untimely corrective action were identified during this period. In

one case, the licensee did not plan to complete corrective action

to prevent the defeat of safety systems during crmponent isolations

until 1995. Additional NRC effort was required , obtain timely

action ir. this case. The licensee has also been slow to repair the

backup 125V and 250V station battery chargers. These chargers have

been out of service since the 1984 outage. This could be a problem

if battery charger reliability degrades. The backup chargers are

.

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21

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not required to be operable by the technical specifications. The

licensee occasionally has been slow to repair equipment-that was

not required to be operable by the technical-specifications, e.g.,

post accident monitoring equipment. The lack of timely response

to out of service safety _ equipment (not covered by technical spect-

fications) may indicate a weakness in scheduling second and third

-

priority maintenance.

Corporate management was actively involved in site' activities. A

i site representative of the_ corporate engineering department helped

'

coordinate engineering input to the site and minimized interface

problems. One interface problem-between the corporate staff and

the site was identified. Contractors reporting to offsite licensee

engineers -improperly installed a test instrument on the high pres-

sure coolant injection (HPCI) system, which made the system in-

. operable. The improper installation was found after the HPCI system

failed a subsequent routine surveillance test. _The licensee took

prompt corrective action after the problem was identified.

Corporate management was actively involved in the assessment of HPCI

water hammer events. The engineering approaches-used to evaluate

'

and correct the water hammer problem were judged to be conservative

and effective. In contrast, previous licensee-responses to water-

hammers in the HPCI steam exhaust line were limited in scope and

were not consistent with documented vendor recommendations.

-

At the end of the assessment period, the licensee brought mainten-

ance and modification groups together under a newly created manage-

ment position, the Maintenance Section Head. This action should

'

help coordinate station activities and provide additional management

oversight for the groups. The Chief Maintenance Engineer was ap-

pointed to the Section Head positior., creating a significant vacancy

in the maintenance department.

The licensee also strengthened the maintenance program by adding

three maintenance planner staff positions. These individuals are

responsible for planning maintenance activities and coordinating

'

maintenance logistics in the plant. First line maintenance super-

visors will be freed of these duties and should be able to spend

more time in the plant directly supervising work.

The backlog of outstanding-maintenance req"ests has been reduced

since the end of the last outage demonstrating licensee initiative.

'

Maintenance management tracks the open maintenance requests-and

actively seeks to reduce the second and third priority maintenance

items. However, ongoing environmental qualification modifications

to plant equipment have impacted Maintenance Department priorities,

hampering efforts to reduce the backlog. The licensee has recog-

nize' a staffing weakness and is considering enlarging the mainten-

anct .aff, in part due to additional plant modifications scheduled

during the coming years. This demonstrates licensee initiative'in

anticipating future maintenance staffing needs.

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The licensee's commitment to establishing a comprehensive preventive

maintenance program was evident, although plant modification work

has prevented the completion of some routine maintenance. Minor

administrative weaknesses in the preventive maintenance program were

identified duiing the assessment period. Preventive maintenance

scheduled for the next refueling outage for valve motor operators

has not been proceduralized. Also, preventive maintenance for the

emergency diesel generators which is currently supervised by a con-

tractor had not been proceduralized. The licensee plans to formal-

ize both programs during 1986. A weakness in the computer-based

scheduling system for preventive maintenance was identified at the

end of the assessment period. Continued-licensee efforts are needed

to ensure that the preventive maintenance program is adequately

documented and implemented.

,

Maintenance worker training appeared adequate to support station

activities with few errors. The maintenance training program is

being formalized in preparation for INP0 accreditation, with program

submittal expected by the beginning of 1986. Special training

courses for maintenance staff included valve and motor operator

training, fundamentals of pressure and temperature, and environmen-

tal qualification training.

2. Conclusion

Rating: Category 2.

Trend: Consistent.

3. Recommendations

None.

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D. Surveillance (646 hours0.00748 days <br />0.179 hours <br />0.00107 weeks <br />2.45803e-4 months <br />, 17%)

1. Analysis

The previous assessment period did not identify major deficiencies

in the surveillance program However, few surveillance tests were

observed because a major outage coincided with the assessment period.

During the current assessment period, three specialist inspections

were conducted in the areas of containment leak rate testing and

startup physics t esting. Post modification testing was reviewed

during a special team inspection prior to startup from the 1984

outage. Routine resident reviews of surveillance testing were also

conducted.

Procedures for containment leakage testing were clearly written and

technically accurate. All pnases of test activities, especially

access to the reactor building, were well controlled by the Test

Coordinator. Initiation of leak searches during temperature

stabilization were prudent and timely. Water leakage discovered

during the +.est was well controlled. QA/QC coverage of containment

leakage testing activities was appropriately planned, technically

useful, comprehensive, and well documented.

During power operation, performance was mixed. Strength was demon-

strated by the successful completion of an unusually large number

of compensatory surveillance tests required by ongoing environmental

qualification modifications to plant safety equipment. The licen-

see's approach to surveillance testing demonstrated a consistent

concern for safety, particularly in the area of secondary contain-

ment damper testing. However, weaknesses in the areas'of startup

test scheduling, test adequacy, compliance with procedural require-

ments, and response to abnormal test results were also observed.

The licensee conducted a slow startup from the 1984 pipe replacement

outage to provide time for extensive startup testing. While the

startup test program demonstrated an organized approach to the

startup, eight surveillance tests required by the technical speci-

fications were not conducted in a timely manner. The tests were

missed due to scheduling omissions and procedural deficiencies.

The scheduling omissions indicate a weakness in the licensee's com-

puter scheduling system, the Master Surveillance Tracking Program

(MSTP). While normally adequate to ensure that surveillance tests

are conducted in a timely manner, the MSTP was not able to adequately

schedule tests during a prolonged startup.

The procedural deficiencies involved the failure to completely test

some safety system components. Deficiencies were identified in

testing neutron instrumentation and certain other reactor protection

system instrumentation. An additional example of an incomplete

,

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24

surveillance test procedure was reported in LER No. 85-26. The

licensee's staff had difficulty in some cases determining which

one of several overlapping test procedures fulfilled regulatory

requirements. These problems indicate that additional effort should

be made to verify the technical adequacy of surveillance test pro-

cedures.

Another problem with the startup tests involved the timeliness of

followup to quality assurance (QA) audit findings. A QA finding

identified two surveillance tests that did not meet technical

specification requirements two months prior to the startup from the

1984 outage. The licensee did not resolve the finding until after

the startup, which was within QA program timeliness guidelines but

which demonstrated a lack of sensitivity to the-finding. Subsequent

NRC action could have been avoided if the finding wa; resolved prior

to startup. Additional licensee attention should be given to en-

suring that QA findings that involve regulatory concerns are re-

solved in a timely manner.

Licensee personnel generally conducted surveti tance tests in a com-

plete and timely manner. However, deficiencies were identified

during the assessment period which involved a lack of attention to

detail. In one case, operators failed to correct known deficiencies

in a station battery surveillance test procedure, which subsequently

caused a technical specification surveillance test to be missed.

Lack of attention to detail was also evident in the inadvertent

return to service of an uncalibrated local power range neutron

monitor during surveillance tests. Arithmetic errors were noted

in several salt service water system surveillance tests and a com-

puter program error was identified which falsely lowered vacuum

breaker ',eak rate results b9 a factor of sixty. Licensee corrective

actions were prompt in each case, and no problems of this type were

identified during the latter portion of the assessment period.

The licensee did not always react promptly to abnormal surveillance

test findings. The lack of action was usually related to delays

in reporting abnormal results to the control room via the licensee's

Failure and Malfunction Reporting system (F&MR). Delays in sub-

mitting F&MR's to the control room caused secondary containment

integrity to be lost for a day while the reactor was at power and

caused a delay in conducting compensatory surveillance tests for

an inoperable emergency diesel generator. A delay in submitting

an F&MR on abnormal inservice inspection results for safety system

pipe hangers delayed the licensee's response to those test results.

Technical evaluations of abnormal surveillar.ce test results were

generally thorough and demonstrated an adequate regard to safety.

Concern for safety was particularly evident when the licensee in-

creased the frequency of secondary containment damper inspections

after finding failed dampers during routine surveillance. However,

in one case, considerable NRC effort was needed to resolve abnormal

<

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surveillance test results. In this_ case, the safety implications

of drifting main steam line radiation monitors were not recognized ~

by the licensee. In addition, the licensee was slow to correct _a

potential weakness in.the surveillance-test program involving-the

-uncontrolled removal of safety related instruments from service for.

calibration and testing.

- The inservice test (IST) program was not fully implemented during

_

the assessment period. The deviations from the program submitted

to the NRC were minor, but indicated a need for additional attention

to~the program.

A new halon fire suppression system for the cable spreading room

had not been declared operational at the-end of the assessment

period because of the lack of a surveillance test for several months.

-

Continued management effort should be directed to placing this sys-

tem in operation.

In summary, performance-in this functional area was mixed, with

strength noted in the conduct of compensatory surveillance testing

for inoperable equipment and in the conduct of _ the 1984 primary

containment integrated leakage test. However, weaknesses were noted

in the response to abnormal surveillance test results, in surveil-

_

lance test procedural adequacy, and in startup test scheduling.

j Responses to NRC and QA findings in this' area were'sometimes slow.

Personnel performance errors contributed to most of these weaknesses.

Additional emphasis on attention to detail would improve test time-

liness and help minimize problems in this-functional area.

2. Conclusion

Rating: Category 2. ,

f

Trend: Consistent.

3. Board Recommendation

Licensee:

.

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Develop better control of startup surveillance testing to en-

sure better timeliness and adequacy.

--

Assure that measures exist to provide for prompt evaluation

of abnormal test results and followup actions (if necessary).

{ NRC

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E. Emergency Preparedness (310 hours0.00359 days <br />0.0861 hours <br />5.125661e-4 weeks <br />1.17955e-4 months <br />, 8%)

1. Analysis

During the-previous assessment period the licensee-was rated as-

Category 3 in Emergency Preparedness, due principally to observa-

tions made during the August 1984 exercise. Weaknesses were.iden-

tified in the preparation and plar.ning for the exercise and-in com-

'

mand and control in-the Emergency Operations Facility (EOF). Based

on the. performance during this exercise, a remedial-drill was held

in October 1984, to reassess the licensee's dose assessment cap-

abilities and decision making process.

During this assessment interval, the remedial drill was observed,

a routine EP follow-up inspection was performed, and the September

1985 exercise was observed. The remedial-drill demonstrated im-

provements in the areas of dose assessment and decision making,

which had been identified as weaknesses during the August 1984

exercise.

During the December routine inspection, two problems were identified

concerning implementation of provisions of the Emergency Plan.

(Failure to mail information brochures to the general public and

failure to perform an annual update-to the Emergency Plan and pro-

cedures). During the review of the scenario package submitted for

the 1985 exercise, it became apparent that the scenario package did

not contain sufficient detail. It was recommended the the exercise

be postponed in order to take time to clarify and complete the

exercise scenario. The licensee agreed to delay the exercise from

August 1 to September 5, 1985 to make the necessary improvements

to the scenario package.

During the exercise, two significant areas of concern were identi-

fled b: the NRC. The first involved a lack of evaluation or control

of rad ation exposure for re-entry teams sent into the plant for

various tasks. Serious overexposures would very likely have resulted

from tie actions taken if this had been an actual situation. The

second concern involved the fact that there were no procedures in

effect 'or relocation of the EOF to the alternate location, in spite

of the fact that the trailers which presently' function as the EOF

are positioned near the stack with no shielding or ventilation fil-

tering. Improvements were evident over the 1984 exercise, however,

a remedial drill was required to demonstrate the ability to evaluate

and control radiation exposures of re-entry team personnel. The

licensee has indicated that plans for construction of an off-site

EOF are nearing completion, which will help solve some of the con-

cerns relating to the facility.

In summary, some improvements in emergency facilities and in the

annual emergency exercise were noted during the assessment period.

However, performance was only minimally acceptable in this func-

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P

tional area-fortthe second year in a row. -Portions of the annual

exercise were unsatisfactory-and had to be demonstrated in a sup-

. plementary drill. The lack of ' thorough exercise critique was?a l

,_ recurring p'roblem. . Personnel errors were evident;during the' exer- .

cise and may reflect weaknesses .in program staffing and training.

!. 2. . Conclusion

'

,

Rating:  : Category 3.

. Trend: -Consistent.

3. Board Recommendation

Licensee: -

]

~ - -

Promptly implement plans for construction of off-site EOF.

t

!' --

Assess staff resource commitments for this area to assure that

it receives adequate attention between exercises and drills.

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F. Security and Safeguards (100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, 3%)

1. Analysis

During the previous assessment period, weaknesses in the'Itcensee's

oversight of the contractor security force were noted. No further

problems in this area were identified during the current period,

indicating that licensee supervision'of the contractor-guard force

has improved. The previous SALP report also identified a weakness

l~ in reporting. security events-to the NRC. .-Nine security event re-

!

ports were reported to the NRC during this assessment period demon-

strating an improvement in the reporting program.

l

During the curront assessment period, one routine unannounced

l physical security inspection and one special inspection were per-

formed by region-based inspectors. Routine resident inspections *

cor.tinued throughout the period. One severity level III violation,

for which a civil penalty was proposed, was identified as a result

of the special inspection.

Licensee corrective actions for reportable events were sometimes

weak. For example, six events were reported this year which in-

volved the failure to promptly compensate for security equipment

failures. The recurring problem demonstrates both a staffing de-

ficienciy and a lack of effective corrective action. Additional-

security program. weaknesses were appcrent during a review of open-

ings in a security vital area barrier. .These weaknesses included-

inadequate control over contractee construction activities adjacent

to the barrier, an incomplete licensee evaluation of the barrier,

and the use of material to repair a barrier opening that did not

meet requirements. Previous' licensee evaluations of barrier integ-

rity were conducted in 1982 and were inadequate. Considerable NRC

attention, including escalated enforcement action, was. required to

obtain comprehensive corrective action. In both instances, the

licensee failed to establish guidelines to implement security ob-

jectives. In the first case, the licensee did not establish cri-

teria for timeliness of compensatory actions. In'the second case,

no guidelines were established for judging acceptable site openings

in security barriers. Licensee management should be more aggressive

in establishing guidelines and ciarifying security program objec-

tives.

Staffing of the program by the licensee and the security centractor-

appears adequate with the possible exception of. shift manning.

Shift manning was increased at the end of the assessment period to

ensure that timely compensatory ' action is taken for security system  !

equipment failures. The security contractor also increased shift '

supervision by adding a second supervisor to each shift. The second

shift supervisor provides the capability for patrolling the site

!

l

i

.

.

29

to assess personnel performance and the general status of security

features. The security contractor provided several formal manage-

ment training seminars to supervisory personnel during the assess-

ment period. The security contractor also engaged a consultant to

revies its overall training program. These actions have apparently

been effective as evidenced by improved morale and a significant

reduction in security force personnel errors during this assessment

period.

Maintenance of security systems hardware and software received con-

siderable management attention during this assessment period. The

licensee has assigned two dedicated instrumentation and calibration

technicians to maintaining the system and provided two software and

two hardware computer technicians on 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> call.

The annual security program audit appeared to be more comprehensive

l in scope and detail than previous audits. In contrast to previous

l years, the audit teams included a consultant with nuclear power

i

plant security expertise. Previous audits were largely compliance

oriented. Additional program effectiveness could be achieved by

reviewing the security plan, procedures, and systems and by focusing

on NRC security objectives during the audits. The security program

was included in monthly QA surveillances. Monthly backshift in-

i spections were being conducted by the security supervisor and/or

l a corporate security investigator who was assigned to the site

during this period. The corporate security investigator provided

management with another perspective on the effectiveness of the

program and demonstrated management initiative.

In summary, weak corrective actions and a staffing deficiency were

noted in this area. While improvements in contractor training and

QA auditing were apparent, additional clarification of security

objectives and emphasis on timely corrective action to meet these

objectives is needed.

2. Conclusion

Rating: Category 2.

Trend: Consistent.

3. Board Recommendation

j Licensee:

Clarify security program objectives and review causes for untimely

corrective actions.

.

.

30

G. Refueling and Outage Management (303.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, 8%)

1. Analysis

Strong outage management was evident during the previous assessment

period for the conduct of the 1984 pipe replacement outage. Con-

tinued good performance was noted during the current assessment

period. The pipe replacement outage ended during the first quarter

of the assessment period on December 24, 1985. As a result, no

last quarter trend was noted for this functional area. Plant power

was increased slowly over a period 'of several weeks, demonstrating

a cautious a, oroach to the startup and a concern for safety.

A team inspection at the start of the assessment period reviewed

the readiness of the licensee for startup from the outage. No major

program deficiencies were identified during the inspection.

Strengths were noted in updating operator training, drawings, pro-

cedures, and technical specifications to reflect plant modifications.

Weaknesses in the turnover of modifications from the construction

to the preoperational test groups, verification of system-configura-

tion following preoperational testing, control over nonconforming

material, and the lack of a station drawing for the air start system

on the emergency diesel generators were noted. Licensee response

to the inspection results was prompt and acceptable.

'

Numerous last minute changes were made to valve lineups for safety

systems just prior to startup, in part due to the simultaneous

close-out of many maintenance work packages. The last minute valve

lineup verifications and changes were a significant burden on the

plant management. No actual lineup problems were identified after

these verifications indicating that, although rushed, they were

successful. Additional planning in this area would minimize the

impact of maintenance close-out reviews on the plant staff, con-

trituting to more thorough reviews.

The startup test program in December 1984 was well controlled and t

well doucmented. Startup test procedures,' including physics testing

procedures were technically sound. The reactor engineering staff

was judged knowledgeable and responded readily to NRC suggestions

for improvements in the testing program. The QA staff conducted

a post fuel load core verification and agreed to participate in

startup physics tests.

A significant lack of housekeeping control was indicated by the

presence of articles of protective clothing and masking tape in the

main and test tanks of the standby liquid control system (SLCS) l

early in the assessment period. The debris likely fell into the '

tanks during the 1984 outage. A reactor shutdown in January 1985

was required while the SLCS system was ilushed and the debris re-

l moved. The presence of loose items on the floor of the reactor

.

l

F

. 1

.

31

building (protective clothing, trash, and loose tools) .s a con-

tinuing intermittent problem at the station. Management should

increase the emphasis on housekeeping to help prevent SLCS type

problems from recurring.

2. Conclusion

Rating: Category 1.

Trend: No basis.

.3. Board Recommendations

None

i

i

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!

!

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____

O

.

32

H. Licensing Activities

1. Analysis

During the previous assessment period, the need to resolve inaccu-

rate and inappropriate technical specifications was noted. Speci-

fication changes were subsequently submitted to NRR regarding plant

organization, a reactor water level trip setting, and primary con-

tainment inerting makeup requirements. These changes demonstrate

responsiveness to NRC concerns. However, continuing efforts are

needed to clarify and correct the technical specifications. Licen-

see responses to concerns about technical specification clarity were

slow during the current assessment period and are discussed below.

Throughout the rating period the utility's management has demon-

strated a high level of interest in licensing mattere by active

participation in the important issues. An example of this was the

participation by the Senior Vice President and other management in

a briefing of NRR on BEco's efforts to environmentally qualify

electrical equipment and the need for a schedular extension beyond

March 31, 1985 for completion of this work. A senior executive

signs all letters to the NRC, thus ensuring management involvement

in licensing activities. The Senior Vice President-Nuclear fre-

quently visits both the engineering offices and the plant site and

the utility now has a vice president in charge at each of these

locations.

The licensee's submittals during this period have been more complete

technically than some in the past, which reflected the additional

attention being given to them by review committees and licensing

personnel.

The If:ensee's management and staff have demonstrated a clear un-

derstanding of technical issues involving licensing actions. Sub-

mittals normally exhibited conservatism from a safety standpoint.

On occasions when the licensee took the position that 1 modifica-

tion would be of marginal benefit compared to its cost, it has pro-

vided a sound technical approach accompanied by credible analysis

to support its position. This was the case with implementation of

automatic switchover of RCIC suction to the suppression pool when-

ever the condensate storage tank level is low, as called for by

NUREG-0737 Item II.K.3.22.

In order to develop acceptable resolutions to important technical

issues, the licensee has frequently consulted the staff and this

approach has proven beneficial to both parties. For example, in

meetings with the staff concerning masonry walls, fire protection,

environmental qualification of electrical equipment, and hydrogen

addition to reactor coolant, the licensee provided clear presenta-

tions of proposed solutions to these issues.

I

.

.

33

BECo has had a Long Term Plan (integrated schedule) in effect since

July 1984 which includes target dates for plant modifications re-

quired by NRC rules or orders (Schedule A) and other plant modifi-

cations, procedure revisions, or changes to staffing requirements

(Schedule B) for which BECo has committed to implementation dates.

With the exception of minor changes in several Schedule B items that

were agreed to by NRR, BECo has met all such requirements and com-

mitments during this assessment period, demonstrating management

initiative in this area. However, meeting the December 31, 1986

date for completion of control room design modifications is in doubt

since the licensee is overdue in establishing a date for submittal

of a supplement to its Detailed Control Room Design Review Summary

Report.

The licensee was prompt in responding to NRC requests for informa-

tion or gave logical reasons for delay and establishes a new date.

During this rating period, the licensee provided appropriate infor-

'

mation which enabled NRR to conclude its review of several important

issues. Among these were Radiological Environmental Technical

Specifications, the Mark I Containment Program, Environmental Quali-

fication of Electrical Equipment, the B-41 Appendix R Fire Protec-

tion Exemptions, Control of Heavy Loads over the Spent Fuel Pool,

and Post Accident-Sampling System (PASS) modifications. However,

the submittals for several other issues (notably hydrogen recombiner

capability and IST), which are in review, were very sicw in forth-

coming. The resolutions proposed have generally been acceptable,

but several have required considerable NRC effort to resolve.

An area where responsiveness could be improved concerns clarifica-

tions and corrections of technical specifications. These could be

proposed and handled more quickly if BECo's decision process were

modified to simplify its review of administrative changes. Cur-

rently, even minor changes in technical specification wording re-

quire several months to prepare and submit to NRR. Current techni-

cal specification problems include vaguely worded action statements

and incomplete definitiens. In some cases, the licensee uses stand-

ard technical specification requirements to interpret vaguely worded

station specifications. Also, the licensee could have shown more

initiative in requesting changes regarding surveillance technical

,

'

specifications that require additional testing (as compared to

Standard Technical Specifications) when components are made inoper-

able. This change could have resulted in less equipment testing

and wear when components were made inoperable during on-line EQ

modification work.

The licensee maintained a larpe licensing staff to deal with NRC

and other agency requirements. During this rating period, members

of the licensing staff participated in simulator training, the

l

Reactor Safety Course at MIT, and a course in licensing procedures.

<

.

.

34

In summary, there was consistent evidence of prior planning, man-

agement involvement, and thorough audits. Design work is generally

timely and complete records are usually available. The licensee

has generally proposed technically sound and conservattve resolu-

tions of the issues and these resolutions have been timely in most

cases. Acceptable resolutions to NRC initiatives are generally

proposed, but some responses have been slow in coming. Nevertheless,

only a few long standing issues remain to be completed. The com-

pletion of a long term plan reflects good planning and a respon-

siveness to NRC initiatives in this area.

2. Conclusion

Rating: Category 1.

Trend: Consistent.

3. Board Recommendation

None.

.

m

.- . . . ~. . . -

g ..

I

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-e

l' 35

i

!

V. SUPp0RTING DATA AND SUMMARIES

t i

A. Investigation and Allegation Revies ,

No investigations were conducted during the assessment period,

i

Three allegations were' received and reviewed. One was unsubstantiated.

A second involved lack of! control of core drilling in the reactor build-

l ing floor. A citation was issued in connection with this concern. .A

l third allegation involved health physics records. . Documentation was

subsequently modified to resolve this concern.

l

8. Escalated Enforcement Actions  :

1. Civil Penalties

A fifty thousand dollar civil penalty was proposed during the as-

~

,

sessment period in connection with unidentified openings in a

security vital area barrier. A special inspection by a regional

specialist inspector identified weaknesses in control of contractor

personnel, inspections of the barrier, and corrective actions.

2. Orders

An Order Modifying License was issued on November 29, 1984 in con-

nection with recurring weaknesses in the radiation protection pro-

gram. The order confirmed implementation of an extensive Radio-

logical Improvement Program (RIP). '

3. Confirmatory Action Letters.

A Confirmatory Action Letter was issued on October 26, 1984 in con-

.

nection with recurring radiation protection program weaknesses.

l The letter outlined licensee plans for evaluating and correcting

these weaknesses.

C. Management Conferences

Enforcement conferences were held on November 20, 1984, January 31, 1985,

and August 27, 1985 in the Region I office. Weaknesses in the control

l and monitoring of neutron instrumentation during' refueling were discussed

during the first conference. An unplanned occupational radiation expo-

sure was discussed at the second conference. The licensee's response

' to abnormal surveillance findings and a degraded vital area barrier were

discussed during the third conference. Management meetings with Region

I personnel were also held at the licensee's reque'st to discuss various

program improvements.

One management meeting with NRR was held on March 26, 1985 regarding the

licensee's request for schedular extension to November 30, 1985 for com-

pletion of' environmental qualification of electrical equipment important

to safety.

f

I .

,

.

.

36

D. Licensee Event Reports

1. Tabular Listing

Type of Events:

A. Personnel Errors ,

4

B. Design / Man./Const./ Install 10

C. External Cause 0

D. Defective Procedure 1

E. Management / Quality Assurance

Deficiency 0

X. Other 20

Total 35

LERs Reviewed

LER No. 84-13 to 85-27

2. Causual Analysis

Two sets of common mode events were identified:

a. LERs 84-14, 84-15, 84-17, 85-06, 85-15, and 85-17 reported

inadvertent safety system actuations caused by maintenance

or surveillance activities.

b. LERs 85-02, 85-05, 85-16, 85-20 and 85-24 involved missed

surveillance tests.

.

1

1

a

c- -

,

.* ,

.

37

.

1

E. Operating Reactor Licensing Actions

1. Schedular Extensions Granted

'

March 28,.1985- - extension until November 30, 1985 for com -

pletion of electrical equipment environmental

qualification

l

l

2. Reliefs Granted.

l .

I

August 8, 1985 - relief from implementation.of automatic

switchover of RCIC suction per NUREG-0737

Item II.K.3.22

3. Exemptions Granted

l December 18, 1984 - exemption from certain requirements of

I

Appendix R,Section III.G.

i

L 4. License Amendments Issued

, t

!

Amendment No. 81, issued October 9, 1984; deleted License Condition

3.D " Equalizer Valve Restriction"

Amendment No. 82, issued October 10, 1984;. revised Technical Spect-

fications relative to RPV thermal and pressurization limits

i

Amendment No. 83, issued November 7, 1984; revised Technical Speci-

fications for surveillance instrumentation on suppression chamber

water temperature, torus water level,. containment pressure and high

radiation, and vents.

l '

.

Amendment No. 84, issued November 27, 1984; revised Technical Spec-

l , ifications to apply to Halon fire suppression system which replaced

i carbon dioxide system in the cable spreading room.

I ,

Amendment No. 85, issued December 17, 1984; added License Condition

3.I requiring the installation of a post-accident' sampling system -

,

and a containment atmospheric monitoring system by June 30, 1985.

Amendment No. 86, issued April 5, 1985; revised Technical Specifi-

cations to permit changes in the normal . full power background trip

level for the main steam-line hign radiation scram and isolation i

setpoints to accommodate a short-term test of operation with hydro- ~

l

gen injection into the reactor coolant. '

'

Amendment-No. 87, issued April 22, 1985; revised Technical Specifi-

cations by reducing the maximum permitted oxygen concentration in t

the primary containment during plant operation from 5%-to 4%.

'

-s )

1

l .

.,

t

-. . . . _ , _ . . -

-.

_

.

38

Amendment No. 88, 1ssued August 14, 1985; revised Technical Speci -

fications to reflect changes in reporting requirements per 10 CFR -

50.72 and 50.73 and Generic Letter 83-43 and to recognize changes

in title, organization and responsibilities.

Amendment No. 89, issued August 30, 1985; revised radiological ef- '

fluents sections of the Technical Specifications to meet Appendix

I requirements.

Amendment No. 90, issued October 9, 1985; revised Technical Speci-

!- fications by changing the Reactor Low Water Level (inside shroud)

-trip requirements.

~

l

l

4

-

I

4

t

u

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l

'

l

l _ _ . -- __ _ - __ - - _- _ _ _ - _ _ _ _ - _ _ _ _ _ - _ _.

.. -. . . . - . . ~ - . - . - . .

, . . _. -

., -

4

1

'

T-1-1

1 -

.

' TABLE 1.

a i.

, TABULAR LISTING OF LERS BY FUNCTIONAL AREA '

. PILGRIM NUCLEAR POWER STATION '

,

<

t

'

Area Number /Cause Code Total

A. Plant Operations' 18, 8X

'

9

d

B. Radiological Controls IX 1

$: C. Maintenance &

Modifications 3A, 68, 10,'2X 12

l' .

D. Surveillance IA, 3B, 8X 12 e

i. E. Fire Protection /

Housekeeping IX 1 *

i

j F. Emergency Protection None O' ,

G. Security and Safeguards None , O '

< 's,

'

, H. Refueling & Outage

. Management None 0

1. Licensing Activities None O'

Total ' i lc i 35

9

-

'f

, r

4

'

Cause Codes: A - Personnel Error b

B - Design,-Manufacturing, Construction or Installation Error

'

C - External Cause t'

D - Defective Procedures ' *

E - Management / Quality Assurance Deficiency  :

X - Other "

.

-

,

,;

f

L .

-

i

5

'

. .,

)*

'

.

-._-_._-..-.__s ----------.-_---_.-____.-----_-__-.-x..____.

_

.

.

T-2-1

TABLE 2

LER SYNOPSIS (10/1/84 - 10/31/85)

PILGRIM NUCLEAR POWER STATION'

LER Number Summary Description

84-13 Jet pump instrumentation nozzle indications

84-14 Inadvertent RPS actuation (bus transfer)

84-15 Inadvertent containment spray actuation

84-16 Loss of power to 120 V AC bus Y-4

84-17 Loss of offsite power - unclanned diesel generator start

84-18 Inoperable motor operator for LPCI injection valve MD-1001-28A

84-19 MSIV isolation during startup

84-20 MSIV isolation during startup, LPCI valve npt fully seated

35-01 SLCS system inoperable due to debris

85-02 Missed surveillance tests

85-03 Completion of a shutdown

85-04 Reactor vessel drain line leak

85-05 Missed surveillance test

85-06 Reactor scram during surveillance test

85-07 Secondary containment dampers inoperable

85-03 HPCI system inoperable

85-09 Reactor scram on turbine high vibration signal

85-10 Secondary containment dampers inoperable

85-11 Absolute versus gauge containment pressure transmitters

85-12 HPCI system inoperable; 5/18 trip, 5/23 isolation 6/6 trip 4

!

85-13 HPCI' isolation on false high steam flow signal

!

,

n r

- . .- . -- . .. . . .. - - - _ . . -~

,

.:

.-

, .T-2-2

l

l

l

t

'

'LER Number Summary Description.

65-14' Reactor scram due to an inadvertent high water'1 eve 1 ~ tso'lation ~'

85-15 Secondary containment isolation due'to personnel error.during

during a surveillance test

,

! 85-16 Missed surveillance - reactor building vent gross' radioactivity  !

analysis

85-17 Secondary containment isolation due to personnel error-during

a surveillance test

85-18 Failure to meet technical specification requirements --inoper--

able secondary containment damper

85-19 Secondary containment dampers inoperable

85-20 Failure to conduct' compensatory . surveillance tests for inoper-

able zA' diesel generator .;

85-21 Main steam line monitors "B" and "C" outside. technical speci- t

fication limits  ;

85-22 Hot shop ventilation contamination

85-23 HPCI system inoperable

85-24 Missed surveillance test - station batteries

85-25 Reactor scram after load rejection

85-26 Inadequate surveillance procedure for control rod position

indication

'

85-27 LPCI injection valve inoperable

..

l

l

l

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! ~ .

.

.. .

.

.

T-3-1

TABLE 3

INSPECTION HOURS SUMMARY (10/1/84 - 10/31/85)

PILGRIM NUCLEAR POWER STATION

HOURS  % OF TIME

A. Plant Operations ..................... 1100 29

B. Radiological Controls ................ 513* 14

C. Maintenance & Modifications .......... 820 22

D. Surveillance ......................... 646 17

E. Emergency Preparedness ............... 310 8

F. Security and Safeguards .............. 100 3

G. Refueling & Outage Management ........ 303.5 8

H. Licensing Activities ................. ** **

__

Total 3792.5 100%

Includes hours for nonradiological chemistry inspection.

• • Hours expended in facility license activities not included with direct

inspection effort statistics.

1

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-_a__ -_____l

.

.

T-4-1

TABLE 4

ENFORCEMENT SUMMARY (10/1/84 - 10/31/85)

PILGRIM NUCLEAR POWER STATION

Severity Levels

FUNCTIONAL AREAS I II III IV V DEV Total

A. Plant Operations - - -

4 2 -

6

B. Radiological Controls - -

1 1 1 2 5

C. Maintenance & Modifications - - -

1

- -

1

D. Surveillance - - -

9 2 1 12

E. Emergency Preparedness - - -

2 - -

2

F. Security & Safeguards - -

1 - - -

1

G. Refueling & Outage Management - - - - - -

0

H. Licensing Activities - - - - - -

0

Totals by Severity Level 0 0 2 17 5 3 27

'

______ . - _ . .- - _ . - - - - _ _ - - _ . . - - - - - - - - - - - . - - - - - - - . - - - . - - - - - - - . - - - . - - - - -

. __ _

.

.

T-5-1

'

TABLE 5

ENFORCEMENT CATA

PILGRIM NUCLEAR p0WER STATION

Insp. Insp. Severity Functional

No. Date Level Area ~ Violation

84-36 11/1-11/85 IV Plant .

Failure to conduct an adequate

Operations . shift turnover for control room i

personnel during refueling

IV Plant Failure to continuously monitor

Operations _ ' source range monitors during

,

refueling

84-39 11/21- IV Surveillance Failure to promptly identify

12/31/84 conditions adverse to quality

(i.e. failure to initiate Failure

and Malfunction Reports)

84-41 12/10-13/84 IV Emergency Failure to diseminate emergency

Preparedness planning information

, IV Emergency -Failure to update the emergency

j Preparedness plan and procedures

84-44 12/18-19/84 III Radiological Failure to' follow radiation work

Controls permit instructions and failure

to establish a procedure for a

, remote reading teledosimetry

system

'

!

85-01 1/1-31/85 V Plant Failure to maintain control room

Operations staffing

at levels required by

10 CFR 50.54

4

IV Surveillance Failure to test the containment

cooling subsystem immediately

when the low pressure coolant

injection system was inoperable

85-03 2/1/85- IV Surveillance Failure to conduct surveillance

3/4/85 tests for the reactor protection

system (six examples)

l

Surveillance '

'

'

IV Failure to conduct rod block

surveillance tests (five examples)

, -

____.__.______m._~__ _.___.______________._.____.__.-__.__________.________.______..m__.____a________l-_. '_____.___._ __ _ ____ _ _ _._ _ ._______ _ .._u__.___._____m__

o

.

T-5-2

Insp. Insp. Severity Functional

No. Date Level Area Violation

IV Plant Failure to promptly correct con-

Operations ditions adverse to quality (i.e.

failure to take timely action

on Quality Assurance surveillance

findings)

V Surveillance Failure to use the most current

revision of a surveillance test

procedure

V Surveillance Failure to calibrate test equip-

ment within the calibrated period

85-06 3/5/85- V Plant Failure to maintain an uncali-

4/1/85 Operations brated local power range monitor

in a bypassed state

IV Maintenance Failure to conduct a dioctyl

phthalate test of HEPA filters

following maintenance on the

standby gas treatment system

85-13 5/20-23/85 V Radiological Failure to have the Operations

Controls Review Committee (ORC) review

two radiological procedures and

failure to control work in the

fuel pool with a maintenance

request

Deviation Radiological Failure to conduct an adequate

Controls review of systems that could

generate an uncontrolled, un-

monitored radioactive effluent

release, as recommended in IE

Bulletin 80-10

85-17 6/13/85- IV Surveillance Failure to conduct a surveillance

7/15/85 surveillance test of the 250 V

battery system required by the

technical specification and to

follow station procedures for

additional battery tests

IV Radiological Failure to specify high radiation

Controls area surveillance frequencies

on radiation work permits

.

_ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _

.

. .

T-5-3

Insp. Insp. Severity Functional

No. Date Level Ar ea Violation

Deviation Surveillance Failure to conduct inservice

tests as specified in an NRC

submittal

85-20 7/16/85- IV Surveillance Failure to maintain the trip

8/19/85 level setting for the "B" and

"C" main steam line high radi-

ation monitors within technical

specification limits

.

85-21 7/16/85- IV Surveillance Failure to maintain secondary

7/30/85 -

containment

IV Surveillance Failure to test alternate safety

system when an emergency diesel

generator was found to be

inoperable

IV Surveillance Failure to initiate Failure and

Malfunction Reports as required

by station procedures

85-24 8/6-8/85 III Security Failure to maintain an adequate

vital area barrier

85-26 8/20/85- IV Plant Failure to properly authorize

9/23/85 Operations excessive licensed operator

overtime as required by station

procedures (thirty-five instances)

85-27 9/16/85- Deviation Radiological Failure to install a protective

9/20/85 Controls conduit

1

i

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_

. , . _ .. .,_

.

,

, ,

-

T-6-1

TABLE 6 {

INSPECTION ACTIVITIES (10/1/84 - 10/31/85)

PILGRIM NUCLEAR p0WER STATION

Inspection Inspection

Rep;rt No. Hours Areas Inspected

_

84-28 259 Plant readiness for restart, team. inspection

29, 30, 31, 32 ---

Cancelled

'

33 174.5 Resident inspection, plant operations

34 ---

1984 SALP Report

35 88 Emergency preparedness, ra ec'ial drill

36 41 Special inspection, source range monitor

i operation during refueling activities

37 18 Operator license examination

, 38 64 Containment integrated and local leak rate

testing

<

39 402 Resident inspection, plant startup follow--

ing a recirculation pipe replacement outage

.

(see also inspection no. 85-01)

'

40 46 Startup test program

41 75 Emergency preparedness program

42 29 Startup physics testing

43 --

Cancelled

, 44 13 Special inspection, radiological controls

i for desludging the "C" monitor tank (see

.also inspection no. 85-02)

i

85-01 293 Resident inspection, plant startup follow-

ing a recirculation pipe replacement outage

(see also inspection no. 84-39)

.

<

02 58 Special inspection, followup on radiologi- ,

, cal controls actions (see also inspection

no. 84-13)

1 .

, _ . , , ,,,,_e , - , . , , , _ _ . . , , ., y . , , , .. ,, , . -

_

.. .-

4

e.

e.

.T-6-2

-

Inspection Inspection

. Report No. Hours Areas Inspected

03 179 Resident inspection, plant operations

04 38 physical security programs

05 24 Nonradiological chemistry program

06 195 Resident inspection, plant operations

07 64 Special inspection, followup on radiologi--

cal controls actions, bulletins and cir-

culars, and high reading TLDs

08 134.5 Resident inspection, plant operations

09 138 Vendor-licensee interface

10 ---

Cancelled

11 216 Resident inspection, plant operations

12 27 Plant modifice.tions and operations

13 70 Radiological controls program

14 30 Followup on previous inspection findings,

plant operations

'

15 xx Operating license examination

16 28 Special-inspection, unauthorized mainten-

ance and modification activities on the-

high pressure coolant injection (HPCI).

system-

17 98 Resident inspection, plant operations

18 37 Followup.to HPCI waterhammer events and

pipe snubber. inspection progrTm ,

19 147 Emergency prepa-edness, annua. exercise

20 132.5 Resident inspection, plant operations-

21 24- Special inspection, review of licensee

response to-two abnormal surveillance test-

results

~

L'<_.- -,n -

a

,

.

T-6-3

Inspection Inspection

Report No. Hours Areas Inspected

22 35 Radiological controls program

23 109 Radiochemistry program, mobile laboratory

24 12 Special inspection, review of licensee

response to a degraded vital area barrier

25 6 Enforcement Conference, concerning NRC

inspection nos. 85-21 and 85-24

26 86 Pcsident inspection, plant operations

,

27 140 Post accident sampling system and related

accident monitoring system review

28 148 Resident inspection, plant operations

29 114 Special inspection, refuel bridge damage

followup

_

.

.

T-7-1

TABLE 7

PLANT SHUTDOWNS

Shutdown Period Description Cause

Dec. 11, 1983 to Refueling and recirculation pipe ---

Dec. 24, 1984 replacement outage.

Dec. 24, 1984 Startup from the outage. ---

Dec. 25, 1984 Shutdown from low power due to Design (trapped air possible

erratic. indication of reactor in instrument lines) or

water level instruments during the procedure weakness (venting

startup. Trapped air in instru- instrument lines following

ment reference legs is a long an extended. outage not ade-

standing problem. quate).

Jan. 1, 1985 to Shutdown due to the presence of- Poor housekeeping (SLCS)

Jan. 7, 1985 debris in SLCS and for maintenance and component malfunction

on torus to drywell vacuum (vacuum breakers).

breakers.

Feb. 9-15, 1985 Shutdown to replace failed recir-' Component-malfunction and

culation pump bearings. The bear procedure weakness (response

ing failure was caused by a loss to a hi/lo oil level alarm

of pump lubricating oil inventory. not adequate).

The oil loss was caused by a leak

in an oil packing gland that sur-

rounds a cooling water line.

Feb. 15-18, 1985 Shutdown to repair a leaking weld Component malfunction.

in the reactor vessel drain line.

March 15-20, 1985 Scram from 100% power on a false Design weakness (instrument

high reactor pressure signal valves prone to stick)"or-

caused by a sticking. instrument personnel- error (valve

valve. The shutdown was continued overtightened).

to complete maintenance on.the

reactor water sample system and

secondary containment dampers.

June 14, 1985 Scram from less than 10% power due Personnel error. l

to a high reactor water level '

isolation during low power

maneuvers. j

April 4-S, 1985 Scram from 85% power due to a . Design weakness ~(turbine

false turbine high vibration trip logic;is one out of

signal. n).

)

,

d

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

c-

e

G

9

T-7-2

Shutdown Period. Description Cause

Sept. 1-5, 1985 Scram from 32% power due to high Design weakness (portions

reactor prassure following a of switchyard must be washed

generator load rejection. The live).

load rejection was caused when a

ground fault occurred in the sta-

tion switchyard during washing ac-

tivities. The fault was caused

by a buildup of ocean salt on

switchyard insulators. A leaking

recirculation pump seal was re-

placed while the reactor was shut

down.

Sept. 5-7, 1985 Shutdown to replace an additional Design or maintenance

leaking recirculation pump seal. weakness.

_

. _ _ - _

.

,

-h. p '

3

FIGUPI 1. Pilgrim Unplanned Reactor Shut Downs

20

.

-

_ . .

.

.

10 _.

^

1 \ 2

" ;s ' 5 N X

Shut Down

~ \ \ 1

\

N N 5 N

,

N N N N

N N N \

\ \ N N

O N \ \ \

DEC JAN FEB MAR APR MAY JUN JUL AUG SEP OCT

1984 1985

• Number of shut downs per month. The recirculation pipe replacement outage ended on

December 24, 1984.

?

_ _ _ _ _ _ _ _ _ - _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ __