ML20155D939

Second Interim Director'S Decision DD-88-17 Under 10CFR2.206 Re Request for Proceeding to Modify,Suspend or Revoke Ol.Portion of Petition Re Mgt Issues Denied.Portion Re Emergency Preparedness Issues to Be Addressed Later

ML20155D939
Person / Time
Site:	Pilgrim
Issue date:	10/05/1988
From:	Murley T Office of Nuclear Reactor Regulation
To:
Shared Package
ML20155D937	List: ML20155D933 ML20155D939 ML20155D951
References
2.206, DD-87-14, DD-88-17, NUDOCS 8810120044
Download: ML20155D939 (9)

Text

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A 00-88-17 UNITED STATES OF AMERICA NUCLEAR REGULATORY C N ISSION OFFICE OF NUCLEAR REACTOR REGULATION OR. THOMAS E. MUPLEY, DIRECTOR ,

i IN TPE MATTER OF COCKET NO. 50-293 BCSTON EDISON COMPANY ) (10 C.F.R l 2.206)

(P!LGRIM NUCLEAR POWER STATION)  !

SECOND INTERIM DIREC_ TOR'S DECISION UNDER 10 CFR 4 2.206 1

J INTRODUCTION l

On Octcber 15, 1987, Massachusetts Governor Michael S. Dukakis and Attorney General James M. Shanren filed a Fetition on behalf of the Comonwealth of Massachusetts and its citizens (Petitioners) with the Nuclear  ;

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[ Regulatory Ccmission (NRC) requesting that the Director of the Office of i Nuclear Reactor Regulatico (NRR) institute a proceeding to modify, suspend, or i

revoke the operating license held by Bosten Edison Company (BECo. the l

licensee) for its Pilgrim Nuclear Power Station (Pilgrim). In particular, the '

l Petitioners requested th NRC to (1) modify the Pilgrim license to bar restart f

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! of the facility until a plant-specific probabilistic risk assessment (PRA) is l performed for Pilgrim and all indicated safety modifications are implemented,  !

t I (2) modify the Pilgrim license to extend the current shutdown pending the  :

outcome of a full hearing on the significant cutstanding safety issues and the

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development and ce7~tification by the Governor of adequate emergency plans, and l t

2 (3) issue an Order, effective imediately, to modify the Pilgrim license to l f

preclude the licensee ' rom taking any steps in its power ascension program l j until a formal adjudicatory hearing is held and findings of fact are made ]

cenrerning safety questions raised regarding Mltrim.

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On May 27, 1988, I issued an Interim Director's Decision in response to the Petition. I concluded that information identified in the Petition does not warrant the initiation of the recuested actions in rtgard to the probabilistic i

risk assesment and attendant plant modifications. Accordingly, I denied the

! request on this issue. I further stated that the management and emergency preparedness portions of the Petitien would be addressed in a subsequent response.

As noted in my Interim Cecision, the Petitioners alleged that serious f l

3 j menagerial deficiencies centinue to exist at Pilgrim. As the bases for their I Petition, the Petitierers cite (1) consistently low ratings in systematic asseswer.t of licensee's performance (9 ALP) reports; (2) the licensee's i

j inability to sustain performance improvecents (3) the licensee's poor enforcement  ;

record regardtrg the severity level and number of violations and (4) recent news i articles eencerning security prcblems and the use of excessive overtime. Docuvents I

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cited by tbc Petitioners irclude SALP Ceports Nos. 85-99 and 86 99 and various I i

inspection reports dated from 1985 to 1987. ,

j The Petitierers provided no substantial new information er evidence that was not known to the NRC when it issued the "Interim Director's Decision Under I

! f 10 CFR 2.206." C0-87-14, dated August /1, 1987, in response to the Petition l filed on July 15, 1986, by Passachusetts State Senator Willirm B, Golden and l othersalsoallegiYgdeficienciesinthelicensee'smanagement.

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The NRC staff's conclusions on the adequacy of management at the Pilgrim facility arise principally from the inspection efforts reflected in two documents (1) SALP Aeport No. 87-99, which covers the period of February 1, 1987, through May 15, 1988, and (2) the report on the Integrated Assessment Tean Inspection (IATI) performed in August 1988.

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O!SCUSSION a

The staff's cercerns with respect to management not only encompassed but  !

] went beyond the specific items raised by the Petitioners. It is in this I broader context that the staff has evaluated actions taken by BECo to resolve management deficiencies.

i SALP Report No. 87-99 Results A. L

! On July 27, 1988, the staff issued its most recent SALP report, SALF f

Report No. 8/-99 (Enclosure A), which covers the period of February 1,1987 l a

l through May 15. 1988. The staff indicated that the licersee had made extensive  !

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efforts, including corporate ard site reorganizations, and had installed a new I t

jl management team. The rew management team undertook numerous projects and  !

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programs to improve the physical tendition of the plant and to enhance  !

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programatic performange. These management initiatives were generally successful in correcting de'iciencies in organization, staffing, and ypgrading '

of the physical condition of the p'. ant. The staff also indicated that the new f l

management team was effective in impreving progranTnatic performance in areas i j previcusly identified as havirg significant weaknesses. The staff further  !

1 l stated that the licensee's self-assessment process was effective in identifying other areas reeding further management attention.

I The Regional Administrator, Fr. Villiam Russell, acknowledged in the i

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letter transmitting the SALP repcrt that BECo had made extensive efforts to upgrade perfnrmance in functional areas that were previously assigned Category 3 ratings. These areas were Radiological Controls. Surveillance. Fire I Protection. Security and Safeguards, and Assurance of Quality. Only one vea

remaired with a rating lower than Category 2; a Category 3-Improving rating w. .

assigned to the Padiological Controls functional area. The use of "!mproving" in the rating indicated improvement in the organization, programs, and ,

i performance in the functieral area. (The definitient of the category ratings and detailed findings ir all the SALP functional areas are provided in Enclosure A.)  !

j Although the necessary positive results were becoming apparent at the l

j close of the assessment period, the ability to sustain the improved performance j had not yet been demonstrated. The NRC sta#f determineo that close monitoring 4

of the licensee's activities was necessary to ensure continued performance

improvement. This close monitoring required an assessment team inspecticn.

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j discussed below, to further measure the effectiveress and readiness of the BECo i

management crntrols, programs, ard persnnnel to support safety restart and  !

operation of the Pilgrim Nuclear Pcwer Station.

B. Integrated Assessment Team inspection Results The IAT! was T5nducted during the period of August P, through August 24

] 1988, and the inspection repcrt, dated September 7. 1088. is provided as

, Lnclosure B. The team inspection included an assessment of the organizational i

structure currently in place at the Pilgrim Nuclear Power Station. The i assessment also ircluded the administrative processes in place to control and f ccordinate the activities and actions affecting safe and reliable operation of

5 the Pilgrim facility. The adequacy of staffing, qualifications of personnel, and mechanisms to enhance and promote stability in the organization's technical and managerial staff.

The inspection team concluded that the current organization is well structured and provides for an apprcpriate distribution of responsibilities ,

) and accountabilities for the activities being perfonned by the functional l

) ur.its within the organization. This appraisal was not true for the former organization. The depth of managers in functional areas shculd contribute to stability in the organization by providing for the development of technical and managerial skills previously lacking. The current organizational structure prevides a framework for career growth that should help reduce chronic staffing vacancies that existed in the past. Redistribution of l

functicnal respcnsibilities and cepth in management throughout the organizatiun i

provides the framework necessary to enhance stability and to support safe and reliable operatien of pilgrim, t 4

The authorized staffing level is *mple, in contrast to previous staffing  !

i leve,s, and has been filled +c a degree acceptable to perform all the recessary i ,

activities and functions of the organizatien for all plant conditions, q ,

including operation.

The resumes and position descriptions o' key managers and selected j personnel throughoM tFe organization were audited by NRC inspectors during  :

) the IAT1. The educational and experience backgrounds of perscenel were f compared to the requirements of the positions held, as delineated in American National Standards Institute (ANSI) N18.1-1971, "Selection and Training of l

i Personnel for Nuclear Pcwer Plants," with a focus on the management experience i

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6 of key personnel. No deficiencies were identified relating to the qualification requirements of the ANSI standard. More significantly, there has been an increase of talented management personnel with extensive and successful management experience  ;

in key positions. The enharced mixtura o' qualified maragerrent and technical ,

personnel on the plant staff should result in a stable management team that was previously lacking.

! Management has updated a variety of procedures to provide policy for and i control and ccordiration of the activities and actions of the organization, ,

j The corporate policy relating to the Nuclea 'Jrganization contained in the ,

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Mission. Organization and Policy Marual includes, among other goals, striving t to achieve rising standards of per#cmance, dedication to r otecting the environment and public, and rigorous adherence to procedures. The other  !

.: procedures adecuately ic'er.tify corporate policy. organization, interfaces.

i functional requirements, responsibilities, accountabilities, and qualifications  !

j necessary 'or the control of activities and coordination of actions within the '

) crganizatien. This improved control and coordination has resulted in progress  ;

i in the functional sat.P areas that was previously inhibited. .

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) Several management meetings were observed during the IATI to assess the  !

1 l j interactions of managers and the effectiveness of the policies and procedures l being implemented. .Close observation of the functional arsas was made

.- l f toaugment+4ndingYandconclusiensontheeffectivenessoftheorganization,  !

i i managetcent controls, and comunications. These observations and interviews i l

also provided the team with insight into the worker's perception of management '

i l j policies, involvement, effectiveress, and the reselting effect en safety.

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1 The team members, through the observations and interviews, noted a i positive change in the attitude towara nuclear safety throughout the Pilgrim 1 organization. This change in attitude is evidence of corporate manqgement's ability to communicate policy and has resulted in improved performance of safety-related activities, These impPcvements were acknowledged in the most i recent sal.P report and the IATI report. The IATI observations support the conclusien that BEco management is effective in connuntcating e

I corporate goals and that mt.nageacnt oversight is ensuring that the geais are

aing supported and pursued.

The IAT! rescrt concluded that the licensee has an acceptable organi:ation that is adecuately staffed with cualified personnel, has j

$ mechanisms in place to enhance stability, and has concrols and pacqrams to '

1 support safe startup and creration of the. Pilgrim Nuf. lear Power Station, j 4

These conclusions are based on the above dise;ssion and supported by the l 1 i c'etails in the encicsures to this Decision.  !

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l 4 i C. Emergency Preparedness l'pdate l

t In the May 27, 1988 Interim Director's Decision, the emergency ,

a i preparedness portion of the Petitioner's recuest was deferred. The Decisi ,'

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stated, however, that the determination as to whether to restart Pilgrim will  !

involve consideratT5n of the energency planning issues identified by the l

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! Federal Emergency Management Agency (FEMA). l f Since that Cecisien, considerable progress has been made toward improving I i l l

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offsite emergency preparedness, including an updated evacuation time estimate study, the development of a shelter implementation pregram, the development of a training program for offsite emergency response personnel, and the renovation of the offsite emergency operations centers. Oraft plans for all seven of the emergency planning zone tcwns and reception center communities have been forwarded by the Comonwealth of Massachusetts to FEMA for informal technical review. FEPA has provided a review of six of the plans to the Comenwealth. In its letters of March 30, 1988 and August 12, 1088 FEMA has indicated thSt progress in improving offsite emergency planning for Pilgrim h3s been made. In addition, classroom training and hands-on training have been conducted for some emergency responders.

The NRC will continue to monitor the progrets of the licensee's efforts to assist Massachusetts and the local governments in improving their emergency response programs. Although progress has been made tcward improving emergency preparedress &t Pilgrim, the precess is not complete.

CONCLUSION For the reasons discussed in my May 27, 1008 Interim Director's Cecision and above, a decision cannot be made at this time regarding emergency preparedness issues. that porfT6n of the Petition will be addressed in a subsequent response.

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For the reasons discussed above, the infonnation identified by the i Petition dces not warrant the initiation of the requested actions in regard to  !

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the managerrent issues. Accordingly, the Petitioners' request for action l

\ 1 pursuant to 10 CFR 2.206 on this issue is denied, r

! As provided in 10 CFR 2.206(c), a copy of this Cecision will be filed l 3

i with the Secretary for the Comission's review. i t-J- -

Dated at Reckville, Maryland, this day of d b l988. l 1

l 1 FOR THE NUCLEAR REGULATORY CCWISSION ,

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as_ _ lia $2 f----_

Thomas E. Purley, Director Office of Nuclear Reactor Regulatien '

i Attachtrents: ,

A. SALP Report flo. 50-293/87-99 B. IAT! Peport tio. 50-293/88-21  :

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