Text

Notice of Issuance of Interim Director'S Decision DD-88-17 in Response to 10CFR2.206 Petition.Portion of Petition Re Numerous Deficiencies in Licensee Mgt Denied.Portion Re Emergency Preparedness to Be Addressed in Final Decision
	ML20155D951
Person / Time
Site:	Pilgrim
Issue date:	10/06/1988
From:	Wessman R; Office of Nuclear Reactor Regulation
To:	;
Shared Package
ML20155D937	List: ML20155D933; ML20155D939; ML20155D951;
References
	2.206, DD-88-17, NUDOCS 8810120046
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7590-01 UNITE 0 STATES NUCLEAR REGULATOPY COMMIS$10N BOSTON EDISON COMPANY PILGPfM NUCLEAR POWER STATION DOCKET NO. 50-293 NOTICE OF ISSUANCE OF INTERIM DIRECTOR'S DECISION Notice is hereby given that the Director Office of Nuclear Reactor Regulation, has issued a "Second Interim Director's Decision" concerning a request filed pursuant to 10 CFR 2.206 by Passachusetts Governor Michael S. Dukakis and Attorney General James M. Shanr.cn which requested that the Director of the Office of Nuclear Reactor.

Regulation (NRR) institute a proceeding to modify, suspend, or revoke the operating license held by Boston Edison Company (BECo the licensee) for its Filgrim Nuclear Power Station (Pilgrim).

On May 27, 1988, the Director of the Office of Nuclear Reactor Regulation issued an "Interim Director's Cecision under 10 CFP 2. 06" concluding ,

i that a portion of the request concerning tFe neeJ for a probabilistic risk assessment was denied. The portion of the petiticn covering management and emergency preparedness would be addressed in a subsequent response.

Thesecondrekonsaculminatedina"SecondInterimDecisionunder10CFR I 2.206" concerning numerous deficiencies in licensee msnagement and for reasons explained in the Cecision, that portien of the petition has been denied. A decision retarding emergency preparedness will be addressed in a final l

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decision. A copy of the "Second Interim Decision under 10 CFR 2.206 " 00-88-17 [

is available for public inspection in the Comission's Public Document Room, !

located in the Gelman Euilding, Lower-Level, 2120 L. Street, N.W., Washington.

O.C. and at the Local Public Document Room at the Plymouth Public Library, 11

. North Street, P1 pouth, Massachusetts 02360, i 1 ;

A copy of the Decision will be filed with the Secretary for the i l Comis: ion's review in acenrdance with 10 CFR 2.206(c). As provided in this ,

I regulation, the Decision will constitute the fin 11 action of the Comission, 4 :

25 days after issuance, unless the Comissicn, on its own niotion institutes ;

review of the Decision within that time period, i CatedatRockville, Maryland,thish day of

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FOR THE NUCLEAR REGULATORY COMMISSION !

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i Richard H. Wessman, Direc+.or

Project Directorate I-3 -

Divisien of Reactor Projects :/II 1 :

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j decision. A copy of the "Second Interim Decision under 10 CFR 2.206." 00-88-17 f ,f 4

is available for public inspection in the Comission's Public Document Room,

! located in the Gelran Building Lower-Level, 2120 L. Street, N.W., Washington.

0.C. and at the Local Public Document Poem at the Plymouth Public Library,11 f l North Street, Ply;rcuth, Massachusetts 02360. -

l A cepy of the Decision will be filed with the Secretary for the

! Comission's review in accordarce with 10 CFR 2.2C6(c). As provided in this !

regulaticr, the Decision will ccnstitute the final action Of the Comission, l 25 days af ter issuance, unless the Comission, on its own motion institutes review of the Decision within that time perico. - ;

Dated at Rockville, Maryland, this h ,-

b day of (dQ88. ;

j FOR THE NUCLEAR REGULATORY COMMISSION i i .

TN w Richard H. Wessman, Director ;

) Pro,iect Directorate I-3 <

1 Division of Peactor Projects 1/II !

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i *k NUCLEAR REGULATORY COMM18810N RE010N 1 L

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r 'JUL E71988 i

Occket No. 50-293 i Boston Edison Company

ATTN: Mr. Ralph G. Bird I . Senior Vice President - Nuclear Pilgrim Nuclear Power Station i RFD #1 Rocky Hill Road j Plymouth, Massachusetts 02360 Gentlemen:

Subject:

Systematic Assessment of Licensee Performance (SALP)

Board Report No. 50-293/87-99 -

] Enclosed for your review, prior to our scheduled meeting of August 25, 1988, i is the SALP Board Report for Pilgrim Nuclear Power Station covering the period 2 February 1,1987 through May 15, 1988.

1 1 In accordance with NRC policy, I have reviewed the SALP Board Report and j concur with the assigned ratings. Highlights of the report are set forth below:

1 3 1. Category 1 performance rating was assigned to Engineering and .

Techni;al Support which continued strong performance through the :

assessment period. (

j 2. Category 2 ratings were given in the functional areas of Surveillance, i

Fire Protection, Security and Safeguards and Assurance of Quality [

j acknowledging Boston Edison Company's extensive efforts to upgrade ,

performance from the previously assigned Category 3 ratings.

3. Category 3 Improving rating was assigned to the Radiological

! Controls functional area.

1 The ass $ ment of the Category 3 improving rating indicates that improvement in l the organization, programs and performance were noted in the Radiological 1 Controls functional area. However, in our view, the results of these l initiatives were coming to fruition at the close of the assessment period, and y

}, had not yet demonstrated the ability to sustain improved performance.

Additionally, on July 8, 1988, Region ! advised you that Pilgrim remains categorized by NRC Senior Management as a plant that requires continued close monitoring and demonstration of programs which establish and implement 1 performance improvements. This was done in conjuction with a letter from the j NRC's Executive Director for Operations to your Chief Executive Officer. We recognize the progress demonstrated to date as a result of your extensive

. efforts, however, continued vigilance on your part is necessary to achieve and sustain overall results. NRC will also continue its increased attention to

! your facility. In this regard, we will conduct an assessment team ins'pection 1 to further measure the effectiveness and readiness of your mant.gement controls,

! programs and personnel to support safe restart of the facility. Further, I i plan to shorten the current SALP assessment period to permit an additional j opportunity to measure the results of your programs.

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At the SALP man ment meeting, please be prepared to discuss your evaluation of our assessment and the status of your performance improvement programs.

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Additionally, we solicit written comments within 30 days af ter the meeting to enable us to thoroughly evaluate your respunse and .to pros ide you with ou?

conclusions relative to them. Specifically, you are requested to respond addressing actions planned to continue to improve performance in the l j Radiological Controls area.

J Your cooperation with us is appreciated. Should you have any questions l concerning the SALP report, we would be pleased to discuss them with you.

1 Sincerely, -

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William T. Russell Regional Administrator ,

Enclosure:

] As stated i i

cc w/ enc 1:

K. Highfill, Station Director

R. Anderson, Plant Manager

! J. Keyes, Licensing Division Manager

E. Robinson, Nuclear Information Manager R. Swanson, Nuclear Engineering Department Manager The Honorable Ecward J. Markey j The Honorable Edward P. Kirby ;

The Honorable Peter V. Forman l B. McIntyre, Chairman Department of Public Utilities Chairman, Plymouth Board of Selectmen j Chairman, Dumbury Board of Selectmen l

! Plymouth Civil Defense Director P. Agnes Assistant Secretary of Public Safety, Co monwealth of i J

Massachusetts ,

S. Pollard, Massachusetts Secretary of Energy Resources R. Shimshak, MASSPIRG j Public One een* Room (POR) 4 Local Pc ' 0# went Room (LPOR) !

{ Nuclear . . formation Center (NSIC) l NRC Residt.is m pector i

Commonwealth of Massachusetts (2)

Chairman Zech l

Commissioner Roberts

Commissioner Carr Commissioner Rogers i K. Abraham, RI (18 copies) 1

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Boston Edison Company 3 J(JL 3 7 g g bec w/ enc 1: -

Region ! Docket $oom (with concurrences)

M. Derkins, RI (w/o encl)

W. Russa!1, RI J. Allan, 4!

D. Holody, RI W. Xane, RI S. Collins, RI J. Wiggins, RI R. Blough, RI L. Doerflein, RI M. Kohl, RI W. Johnston, I'.I J. Curr, RI R. Gallo, RI W. Oliveira, RI S. Ebneter, RI G. Sjoblem, RI R. Bellamy, RI ,

R. Bores, RI J. Taylor, OEDO B. Boger, NRR R. Wessman, NRR

0. Mcdonald, NRR F. Akstu'ewicz, NRR Doard Members

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, I i ENCLOSURE !

i SALP BOARD REPORT l i

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SYSTEMATIC ASSE R 4ENT OF LICENSEE PERFORMANCE i i INSPECTION REPORT S0-293/87-99 [

BOSTON EDISON COMPANY :

j I PILGRIM NUCLEAR POWER STATION ,

': l 1 ASSESSMENT PERICO: FEBRUARY 1, 1987 - MAY 15, 1988 ,

j j BOARD MEETING DATE: JULY 5 and 6, 1988 I I

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O.. TABLE OF CONTENTS i Page 1.0 isTR00uC210s ............................................. 1 1.1 Purpose and Overview ................................ 1 1.2 SALP Board Members .................................. I 1.3 Background .......................................... 2 2.0 CRITERIA ................................................. 7 j 3.0 S U MMA RY O F R E S U LT S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 3.1 Overall Facility Evaluation ........................ 10 ,

1 3.2 Facility Performance ............................... 12 4.0 PERFORMANCE ANALYS!$ .................................... 13 l 4.1 Plant Operations ................................... 13 t

4.2 Radiological Controls .............................. 18 !

3 4.3 Maintenance and Modifications ...................... 24

! 4.4 Surveillance ....................................... 29 1 4.5 Fire Protection .................................... 33 4.6 Emergency Preparedness ............................. 36 4.7 Security and Safeguards ............................ 3B 4.8 Engineering and Technical Support .................. 43 -

) 4.9 Licensing Activities ............................... 47 j 4.10 Training and Qualification Effectiveness ........... 50 4.11 Assurance of Quality ............................... 53 i

5.0 SUPPORTING OATA AND SUMMARIES ......................... . 57 5.1 Investigation and Allegations Review ............... 57 -

5.2 Escalated Enforcement Actions ...................... 57

! 5.3 Management Conferences ............................. 58 ;

) 5.4 Licensing Actions .................................. 59 5.5 Licensee Event Reports ............................. 63 TABLES .

Table 1 - Taoular Listing of Licensee Event Reports by Functional Areas I Table 2 - Inspection Hours Summary Table 3 - Enforcesent Summary l Table 4 - Pilgrim SALP History Tabulation '

] Table 5 - Management Meeting and Plant Tour Summary ,

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m 1.0 I!4TR00VCTION - - l 1.1 Purpose and Overview l

The Systematic Assessment of Licensee Performance (SAI.P) is an inte-i; grated. NRC staff effect to collect observations and data on a per-1 i odi f. basis and to evaluate licensee performance. The SALP process

is supplemental to the normal regulatory processes used to ensure compliance to NRC rules and regulations. It is intended to be suf-ficiently diagnostic to provide a rational basis for allocating NRC ,

resources and to provide meaningful guidance to licensee management i in order to improve the quality and safety of plant operations. ,

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! An NRC SALP Board, ccmposed of the Staff members listed in Section 1.2 below, met on July 5 and 6, 1988 to review the collection of performance observations and data in order to assess the Boston Edison Co.reany's (BECo) performance at the Pilgrim Nuclear Power Station. This assessment was conducted in accordance with the i guidante in NRC Manual Chapter 0516, "Systematic Assessment of l

Licensee Performance". A sum.ma ry of the guidance and evaluation criteria is provided in Section 2.0 of this report. !

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

performance at the Pilgrim Nuclear Power Station for the period i February 1,1987 - May 15,1988 . The summary findings and totals +

t reflect a 15 moith assessment period.

1.2 SALP Board Members Chairman S. J. Collins, Deputy Director, Division of Reactor Prr jects (DRP)

Members i W. F. Kane, Otrector, ORP

J. T. Wiggins, Chief, Reactor Projects Branch 3, ORP A. R. Blough, Chief, Reactor Projects Section 38, ORP J, P. Ourr, Chief. Engineering Branch, Division of Reactor Safety (DRS)

G. L. Sjoblom, Acting Director, Division of Radiation Safety and j Safeguards (0RSS) i R. R. Bellamy, Chief, Facilities Radiological Safety and Safeguards i Branch, DRSS

0. H. Wessman, Director, Project Directorate I-3, Office of Nuclear Reactor Regu14t 6 (NRR)

O. G. Mcdonald, Licensing Project Manager, NRR i C. C. Warren, Senior Resident Inspector, Pilgrim Nuclear Power Station (PNPS), DRP 1

2 I Other A Eendees i J. J. Lyash, Resident Inspector, Pilgrim NPS, ORP T. K. Kim, Resident Inspector, Dilgrim NPS, DRP T. F. Dragoun, Senior Radiation Specialist, DRSS G. C. Smith, Safeguards Specialist ORSS R. M. Gallo, Chief, Operations Branch, DRS A. G. Krasopoulis, Reactor Enginear, ORS T. Koshy, Reactor Engineer, DRS

1.3 Background

A. Licensee Activities The niant has been shut down since April 12, I'd6 for mainten-ance and to make program improvements and resained shut down throughout this assessment period. The reac'.or was defueled on February 13, 1987, to facilitate extentive mainten.nce and

, modification of plant equipment. The licensee completed fuel reload on October 14, 1987. The reactor vessel hydrostatic test and the containment integrated leak rate test were also com-pleted successfully.

Since the end of the last SALP period there have continued to be extensive management changes at Boston Edison that affect Pilgrim. The licensee has aggressively recruited . experienced personnel from outside sources. A new Senior Vice President i

assumed responsibility for the nuclear organization at the

beginning of the period. The licensee's organizational struc-i ture was also significantly altered several times. Recent j changes have more clearly defined the permanent onsite organiza-t tional structure. Essentially all key management positions had been filled with permanent employees by the close of the period.

The licensen 6veloped several integrated action and testins plans to evaluate the readiness of plant management, staff and j

', hardware to support restart. The:s include the Restart Plan, l Material Condition Improvement Action Plan, Radiological Action j Plan and Power Ascension Test Program. In addition, the licen-4 see performed a self assessment near the end of the SALP period to identify plant issues and evaluate the effectiveness of implemented improvement actions.

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DuM ng the assessment period the licensee completed extensive !

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plant' hardware and procedure modifications. The iteensee's I Safety Enhancement Program included addition of a third emerg- >

j ency diesel generator, containment spray header nozzle changes, .

, installation of a backup nitrogen supply system, and additional :

{ protection features for anticipated transient without scram. l j Steps were also taken toward installation of a direct torus vent !

] system and installation of a diesel driven fire pump tied to the I

! . residual heat removal system. License exemptions and modi- l J

fications to the fire protection program and equipment to bring i l the plant into full compliance with 10 CFR 50 Appendix R. and to i j improve reactor level instrumentation were completed. The l facility Emergency Operating Procedures were also upgraded to .

incorporate Revision 4 of the Boiling Water Reactor Owners Group J Emergency Procedures Guidelines. ;

I 4 . On March 31, 1987, the station experienced a loss of offsite i i power during a storm when a static line broke and fell onto the !

! conductors at a location several miles from the site. Offsite ;

! power was restored within 45 minutes. A second loss of offsite power event occurred on November 12, 1987 due to excessive ice i

} and snow accumulation on the transmission system during a severe I

winter storm. This event was complicated by a lockout of the !

plant startup transformer, the removal of one of the ;

j emergency diesel generators from service due to maintenance !

l concerns and the limited availability of instrument air. A

! source of offsite power was reestablished about 21 hours2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months after ,

the initial loss. An NRC Augmented Inspection Team was l j -

dispatched to the site in response to this event. :,

On November 9, 1997, the licensee as a conservative measure

} halted ongoing maintenance and modification work at the station (

l af ter determining that several incidents which occurred during

! the weekend of November 7 and 8, 1987, raised concerns regarding [

' the control of ongoing work activities. The licensee's Senior i Vice President-Nuclear directed that ongoing maintenance and l l modification work onsite be suspended, and contractor craf t i j personnel were instructed to leave the site and were directed

not to report for work until November 12, 1987. The licensee j subsequently formed eight teams of engineering and management

personnel to perform detailed evaluattens of each incident prior

to resuming station work activities.

! On February 11, 1988, the control room received a report of a 1 fire in a contaminated area of the machine shop. The licensee i conservatively declared an Unusual Event. The fire was confined

to a small area and was identified as burning insulation from a j heat-treating machine which was being used in the machine shop.

! The fire was extinguished by the plant fire brigade with no l plant damage noted, and the Unusual Event was secured, i

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Op(Eator licensing examinations were conducted on two occasions during the period. A total of two senior reactor operators and 14 reactor operator candidates were examined with all candidates successfully completing the examinations.

In December 1986, the Secretary of Public Safety for the Common-wealth of Massachusetts (Charles V. Barry) submitted a report to Governor Dukakis assessing the status of offstte emergency pre-paredness for the Pilgrim station. The report identified several problems with the existing response program. FEMA per-

formed a self-initiated review of the Pilgrim emergency response

] plan and on August 5,1987, provided its report to the Common-I wealth. FEMA identified six deficient areas and withdrew its interim finding that Massachusetts offsite emergency planning and preparedness were adequate to protect the public health and i safety in the event of an accident at Pilgrim. The NRC reques-I ted the licensee to provide its plans and schedule for working ,

with state and local organizations to resolve the deficiencies.

The licensee submitted an action plan to address the deficien-cies on September 17, 1987. A progress report issued i October 15, 1937 by Charles V. Barry notes that, while substan-tial progress had been made in some areas, adequate plans for

. response to an accident at Pilgrim did not exist and substantial work remained to be done. At the close of the assessment period, the licensee was actively working with the Commonwealth 1 and local agencies to address the deficiencies and upgrade the j emergency plans.

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5 B. @ pection Activities C65firmatoryActionLetter(CAL)86-10wasissuedinApril,1986 in response to a series of cperational events. The CAL initially required that the licensee address these events, and was subsequently extended in August, 1986 to include resolution of programmatic and management concerns. In addition the CAL stated that the NRC Regional Administrator's approval would be required prior to restart. The CAL remained in effect through-out this assessment period.

Considerable inspection resources were expended at Pilgrim dur-ing this assessment period. The resident staff has been main-tained at three inspectors. During the fifteen month assessment period, over 9698 hours0.112 days 2.694 hours 0.016 weeks 0.00369 months of direct NRC inspection were performed .

(7758 hours0.0898 days 2.155 hours 0.0128 weeks 0.00295 months on an annual basis). This represents a 43 percent increase above the previous assessment period, and is signif t-cantly in excess of that normally allocated to a single unit site. A detailed breakdown of the total inspection hours into SALP functional areas is included in Table 2.

Senior NRC management involvement was substantial during the period. Early in the assessment period, e' Pilgrim Restart Assessment Panel was formed which consists of senior management from the NRC Office of Nuclear Reactor Regulation (NRR) and Region I. The. panel generally meets biweekly to coordinate the planning and execution of NRC activities, . and to assess the results of these activities to provide an independent judgement

. of the plants readiness for operation. A series of management meetings to l'scuss the licensee's progress and proposed pro-grams were also held. Frequent site tours by NRC Commissioners, the Director of Nuclear Reactor Regulation and the Regional Administrator were conducted. NRC senior management partici-pated in numerous public meetings and interacted extensively with local, state and federal officials. The NRC conducted public meetings in plymouth to receive public comments on the plan. The staff's assessment of the comments and concerns received on the Restart Plan was presented to the public during a followup public meeting. A chronological listing of manage-ment meetings and tours is included as Table 5.

On July 15, 1986, Massachusetts State Senator William B. Golden and others filed a 10 CFR 2.206 petition regarding pilgrim.

After review by the NRC, the contentions raised in the petition regarding containment deficiencies and inadequacies in the radiological emergency response plan were denied. A decision regarding the management deficiencies was deferred to a subse-quent response. This information was transmitted to ths peti-tieners by letter dated August 21, 1987. Three of the petitioners filed an appeal in federal court on October 1, 1987.

6 Om October 15, 1987, Massachusetts Attorney General Jiie's M. Shannon filed a 10 CFR 2.206 petition, on behalf of his office and Governor Michael S. Dukakis, requesting an order to show cause w5y Pilgrim should not remain shutdown until a full adjudicatory hearing resolves the issues raised in the petition.

The petition cites evidence of continuing managerial, Mark I containment, and emergency planning deficiencies and requests that the licensee also be required to perform a probabilistic risk assessment (PRA). In a response dated May 27, 1988, the NRC denied the petitioners request that a PRA regarding the Mark I containment be required and deferred decisions regarding emergency planning and management issues.

During the assessment period nine NRC team inspections were conducted:

1. Appendix R Fire Protection Program Review

2. Plant Modification Program Review

3. Plant Effluent and Environmental Monitoring Program Review 4 Augmented Inspection Team (AIT) Review of the loss of off-site power event on November 12, 1987

5. Annual Emergency Plan Exercise Observation

6. Onsite Electrical Distribution Adequacy Review

7. Emergency Operating Procedures Review

8. Maintenance Program Review

9. In plant Radiological Controls Review An NRC Order issued in 1984 requiring the licensee to implement I a Radiation Improvement Program was closed during the period based on the results of a special inspection and other program inspections which indicated that all terms of the Order had been satisfactorily completed. Two operator licensing examinations were also conducted. An enforcement conference was held on September 9, 1987 to discuss security related matters. Enfo:ce-ment action on these issues is still pending.

Tabulattens of inspection activities and associated enforcement actions are contained in Tables 2 and 3.

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2.0 CRITERIA C.

Licensee performance is assessed in selected functional areas, depending i

upon whether the f acility is in a coestruction, preoperational, or opera- t j ting phase. Functional areas normally represent areas significant to nuclear safety and the snvironment. Some functional areas may not be j assessed because of little or no Itcensee activities, or lack, of meaning-i ful observations. Special areas may be added to highlight significant observations. l This report al's discusses "Training and Qualificat.lon Effectiveness", l I "Assurance of Quality" and "Engineering and Techrh.a1 Support" as separate .

l functional areas. Although these topics, in themselves, are asressed in the other functional areas through their use as criteria, the three areas provide a synopsis. For examole, assurance of quality effectiveness has

]; been assessed on a day-to-day basis by resident inspectors and is an integral aspect of specialist inspections. Major factors that influence quality, such as involvement of first line supeevision, safety connittees, cuality assurance, and worker attitudes, are discussed in each area.

j One or more of the following evaluation criteria were used to assess each i j functional area.

1. Management involvement and control in assuring quality I 2. Approach to the resolution of technical issues from a safety stand- ,

point

3. Responsiveness to NRC initiatives ,

4 Enforcement history -

. 5. Operational events (including response to, analyses of, and corree- ;

)I tive actions for) :

j 6. Staffing (including management) i

7. Training arid Qualification Effectiveness !

l Based upon the sal.P Board assessment, each functional area evaluated is 4

classified into one of three performance categories. The definitions of ,

these performance categories are:

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Catecovy 1. Licensee management attention and involvement are readily_avident and place emphasis on superior performance of nuclear safety' or safeguards activities, with the resulting performance sub-stantially exceeding regulatory requirements. Licensee resources are

ample and effectively used so that a high level of plant and person-nel performance is being achieved. Reduced NRC attention may be '

appropriate, Category 2. Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are good. The licensee has attained a level of performance above that needed to a meet regulatory requirements. Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is j being achieved. NRC attention may be maintained at normal levels, i I Category 3. Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not suf- t ficient. The licensee's performance does not significantly exceed :

that needed to meet minimal regulatory requirements. Licensee i resources appear to be strained or not effectively used. NRC atten-tien should be Increased above normal levels.

The SALP Board also assesses a functional area to compare the lican-see's performance during the last quarter of the assessment period to that during the entire period in order to determine the recent trend for occh functional area. The SALP trend categories are as follows:

1 1 Imp r_ovino : Licensee performance was determined to be improving near i tne close of the assessment period. l

'j Declining: Licensee performance was determined to be declining near :

tne close of the assessment period and the licensee had rot taken i meaningful steps to address this pattern.

1 A trend is assigned only when, in the opinion of the SALP Board, the trend is significant enough to be considered indicative of a likely I change in the performance category in the near future. For example, ,

j a classification of "Category 2, Improving" indicates the clear i

, potential for "Category 1" performance in the next 5 ALP period, i

1 1 It should be noted that Category 3 performance, the lowest Category, I represents acceptable, although minimally adequate, safety perform-I ance. 7f at any time, the NRC concluded that a licensee was not achieving an adequate level of safety performance, it would then be incumbeat upon NRC to promptly take appropriate action in the l interest of public health and safety. Such matters would be dealt

with independently from, and on a more urgent schedule than, the SALP process.

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4 rising 3nrformance espectations. For example, NRC expects licensees t 4

to actively use industry-wide and plant specific operating experience !

J to effect performance improvement. Thus, a licensee's safety per- f formance wculd be expected to show improvement over the years in order to maintain consistent $ ALP ratings, j

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3.1 Oveaall Facility Evaluation a

i The 1985 $ Alp determined that programmatic and performance weaknesses i existed in several functional areas and that improvements were in-hibited by the lack of resolution of factors which in turn depended I heavily on managnent attitudes and aggressiveness of followup.

The 1986 $ ALP acknowledged that, although some improvements were .

I made, the lack of a clear organizational structure, recurring management changes, and chronic staffing vacancies delayed the establishment of a stable licensee management team at the plant and

){ inhibited progress during the period. These problems manifested i themselves as Category 3 performance ratings in the Radiological i Controls, Surveillance, Fire Protection, Security and Assurance of i Quality functional areas.

4 ihroughout this 1937-1988 $ ALP period the fact 11ty was maintained by EECO in an outage condition to make major plant f -:ility modifica-tions and complete a major equipment refurbishment program.

At the beginning of the assessment period the licensee made the most j significant of numerous personnel changes when a new Senior Vice #

President-Nuclear was hired and his presence established on site. l l Additional personnel and organizational changes continued throughout i j the assessment period with the most substantial reorganization being i

completed in February, 1983. Although the organization in its -

present form did not formally emerge until lata in the assessment

, period, many of the functional reporting chains have been in place 1 for some time and appear to be functioning well. Allocated staf firig l

} levels in the new organization are significantly higher than in the j past and the licensee has been generally successful in recruiting efforts. As a result of these transitions some individuals are l relatively new to their positions and in some cases do not have

! extensiu operating Boiling Water Reactor espertise.

I

] The licensee has been aggressive in addressing most areas of known '

j program weakness. However, implementation of certain program and ;

organizationel improvements was delayed due to the high priority ,

placed en proceeding with outage work. Surveillance p ro g ra,a '

responsibilities have been consolidated in the Systems Engineering i Group and program weaknesses have been addressed. Hardware issues in both the fire protection and security areas have been corrected and j performance in these areas has improved. Health Physics proyan

! problems identified in the previous $ ALP report continued to exist

during the first half of this assessment period, however recent

significant management attention and resource commitment to this area l

led to improved performance over the last part of the assessment i period. Maintenance program improvements were implemented only j l

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! i recentlCand their effectiveness remains under review. Licensee !

I developse t of the Material Condition Improvement Action Plan, j J Restart plan and performance of an extensive self assessment in :

) response to tha NRC August 1986 Confirmatory Action letter are evidence of the licensee s ability to self-identify. and understand i

f f acility performance and material condition. The action plans to !

in.plement these ne:essary improvements and management's ability to (

l effect lasting performance change remained under review at the close i

! of the assessment period, :

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i In summary, licensee efforts have been extensive including corporate !

! and site reorganizations and a new management team which has l

! undertaken numerous projects and programs to improve plant material j J condition and enhance programmatic performance. Management !

] initiatives have been generally successful in correcting staffing, !

i organization and matertal deficiencies. Programmatic performance ,

improvements have beta tvident in areas of previously identified [

signifitant weakness and tha licensee's self assessment process has' l' identified areas where furtiar management attention is warranted.

l I

J In light of the past inability to implement lasting programs which l result in long term improvements, a continued licensee management .

! omitment is nveced to confirm that past weakness have been !

! identified and sustain the overall improving. trend in performance. t i i 1

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.3.2 Fa c i l i t9'Se r fo rmar.c e Functional C.stecory Category Recent Area last Peried* This Period ** Trend

1. Plant Operations 2 2

2. Radiologicti 3 3 Improving Controls

3. Maintenance and 2 2 Modifications

4. Surveillance 3 2

5. Fire Protection 3 2 C. Emergency 2 2 Improving Preparedness

7. Security and 3 ? )

Safeguards

8. Engineerirg and 1 1 Technical Support

9. Licensing 2 2 ;

Activities ;

10. Training and 2 2 Qualification Effectiveness

11. Assurance of 3 2 Quality Outage Management ***

1 and Modifications Activities Ncvember 1, 1985 to January 31, 1987

- February 1, 1987 to May 15, 1988

- - Not evaluated as a separate functional area; findings relative to outage i activities are integrated into " Engineering and Technical Support", l "Maintenance and Modifications", and other functional areas as appropriate l l

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13 4.0 PERFORMANCEhALYSIS 4.1 plant Operations (2178 hours0.0252 days 0.605 hours 0.0036 weeks 8.28729e-4 months /22 percent)

(1) Analysis This functional area is intended to assess the licensee's per-formance of plant operations. Throughout this assessment period the plant was in an extended maintenance and refueling outage.

NRC observations of licensee performance during major plant activities included reactor core defuel and reload, the ,*eactor vessel hydrostatic test, and the primary containment integrated ,

leak rate test.

During the previous SALp period plant operations was assessed as a Category 2. Weaknetses identified includsd a shortage of licensed reactor operators and lack of professional support for the Operations Department. Although the licensee had taken actions to recruit new operators and improve the licensed oper-ator training program, the shortage of licensed reactor opera-

, tors (R0s) remained a significant problein. The effectiveness in professional staff support for the Operations Department was also not demonstrat'ed due to delays in transferring personnel into the department, and their continuing collateral duties outside the department.

During the current assessment period, the licensee's planning and evaluation of their readiness for refueling, the reactor vessel hydrostatic test, and the primary containment integrated leak rate test were well mana5ed. Strong Operations Department involvement was evident. plant management and the Operations Review Committee (ORC) exhibited a conservative, safety con- ,

scious approach to these milestones. ORC review of refueling '

readiness was conducted in a thorough and deliberate manner '

including line item verification of the reload checklist. One 1 exception was the licensee's use of Appendix G to the Final Safety Analysis Report to justify conditional operability of equipment needed for refueling. In this case plant management proposed to begin fuel movement with a Standby Gas Treatment System design deficiency uncorrected, by preparing an analysis supporting operability of the system under restricted condi-tions. Licensee management however, reconsidered this practice when concerns were raised by the NRC. Licensee senior manage-ment support for ORC decisions was visible throughout these major activities. Senior management's presence ano direct l involvement in activities also demonstrated their commitment to j safety and expectations of high standards to the plant staff.

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14 Tht-licensee has taken aggressive actions to resolve the short-age"of licensed operators. Improvements in recruiting and oper-ator training programs have resulted in a significant increase in the size of the operations staff. The number of licensed reactor operators (R0s) increased by 14 during the period to the ,

present total of 23 This contributed to a reduction in routine I operator overtime, which had been a chronic past ' -. The addition of tiew licenses to the operations sta7* positive.

However, additional operating experience will be required before j these newly licensed personnel are fully qualified. The high R0 1 attrition rate was a major factor in the RO shortage during tha l last assessment period. Increased management attention, reduced overtime, and higher morale have contributed to maintaining a I stable operations organization during this period. The licensee l currently maintains a staff of 20 equipment operators and eight i of the 20 are scheduled to enter a reactor operator license training class later this year. Continued management support in maintaining a sound and aggressive recruiting and training pro- ;

gram is required to prevent the recurrence of the operator !

sho,tage.

Despite the improvements in the staffing level, weaknesses con-tinued to exist in attention to detail and in communications.

Several procedural and personnel errors occurred during the refueling, the reactor vessel hydrostatic test, and the contain-ment integrated leak rate test. Immediate actions taken by the i operations staf f in response to incidents were not always cun-servative. For example, operators continued refueling without stopping to assess a pendant light which was inadvertently dropped onto the reactor core. Problems in the operations area that contributed to the licensee's work stoppage on November 9, 1987 included inadequate system turnover, valve lineup problems, and poor radwaste system operation practices. Some weakness in coordination and communications between the operations staff and other groups was noted during the loss of offsite power (LOOP) event on November 11, 1987. The lack of clear management directions both in and out of the control room, a somewhat frag-mented recovery effort, and poor communications may have delayed the full recovery from the LOOP and resulted in inadvertent manual shutdown of one of the emergency diesel generators. As a -l further example, operator communication during a dry run of the '

remote shutdown test was also informal and not completely effective.

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15 DuEdng previous assessments, informality and poor attitude had been identified as a weakness among the control room st:ff. The discovery by the licensee of non-job related reading material and a card playing machine in the control room in October, 1987 was a.further example of the lack of professionalism and implied inatttntiveness to duty. As a result of management attention to this issue, positive trends in the control room atmosphcre and conduct were noted during the last quarter of the assessment period. The significant increase in the size of the operations staf f, strict control of cperator overtime, and intensive com-munication training also aided licensee management's succe.ssful effort to improve operator professionalism. As an example, effective use of the simulator for training and implementation ,

of control room hardware improvements have enhanced the control room atmosphere.

Significant effort has been made by the licensee to provide adequate support staff in the Operations Department. The department was reorganized and the Operations Support Group was created to strengthen effectiveness in idsntifying and resolving technical issues affecting Operations. The Operations Support Group consists of three staff engineers and six shift technical

. advisor (STA) positions. The licensee has filled the group manager and senior staff engineer positions and is actively recruiting to fill the other staff engineer positions. Three additional STAS were hired and trained during this period which increased the total number of qualified STAS to six. This represents an increase of six in the allocated operations sup-port staff with four of the positions filled. The reorganiza-tion allowed the Chief Operating Engineer added opportunity to directly oversee :perator performance. Operations staff involvement in deveisping and implementing the Emergency Opera-ting Procedures was strong. The licensee's ongoing effort to develop a jumper and lifted lead log and a limiting condition of operation log are additional indications of improving staff support in the Operations Department.

The licensee's approach to problem investigation and root cause analysis improved significantly Juring the latter portion of the period. Event critiques led by the Operations Section Manager .

and root cause analyses performed by the onsite Syttems Engi-neering Group were thorough and aggressive. The critique pro-cess also instilled a leadership role for the Operations Department and promoted better communication among interdepart-mental groups.

16 Th$ operator training program continued to improve during' this as Essment period. NRC operator license examinations on May 25, 1987 and December 7,1987 had a 100 percent pass rate.

Utilization of the plant specific simulator in requalification training and the new Emorgency Operating Procedure training significantly enhanced the effectiveness of the training pro-gram. The licensee's effort to develop and implement the new Emergency Operating Procedures demonstrated high levels of senior management attention.

Reporttble events were generally handled acceptably by the con-trol room staff. The levels of detail, technical accuracy, and the overall quality of licensee event reports have improved during the period.

Monitoring and maintenance of plant chemistry is the responsi-bility of the Operations Department. The licensee's chemistry depaitment is responsible for plant chemistry, radiochemistry, and the facility radiological ef fluents control program. The chemistry organization was clearly defined, adequately staffed, and appeared to interface well with other plant groups including the radwaste organizat on. i Chemistry rrepresentatives are included in shiftly turnovers .with the control room staff.

Importent plant chemistry parameters are discussed with station management daily at a morning planning meeting. Surveillance ,

requirements were clearly established and performed on schedule.

The licensee is meeting Technical Specification requirements for radiological effleunt sampling and analysis. Effluent control instrumentation was maintained and calibrations performed in accordance with regulatory rerlui rement s . All release records were complete and well maintained. QA audits of this area were comprehensive and technically thorough.

The results comparison of NRC radioactivity standards submitted to the licensee for analyses indicated excellent performance by the licensee with all results in agree m t. During the analysis of the NRC radioactivity standards, the licensee's chemistry staff demonstrated a clear understanding of the technical issues. !

In addition, gested practices fortheprogram licensee was responsive improvements. The to NRC licenseesugs j chemicci measurement capability was also evaluated twice during i the assessment period. The results of the NRC chemical stand-ards indicated good performance with only four of 54 measure- l ments in disagreement. The licensee was responsive to NRC sug-gestions for program improvements in this area and also in the area of post accident sample analyses. 1.icensee management appears committed to providing adequate capital resources to the I

l 17 ;

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ChGij stry Department. The licensee possesses state of the art l chemical and radiochemical laboratory instrumen*,ation, and also ,

maintains a state of the art chemistry computer data base for maintaining and trending laboratory data. The licensee's chein-tstry training program was also reviewed this assessment peated.

Both the training and retraining pragrams appear to be acequate as indicated by the results of the NRC standards analyses.

In summary, the licensee's aggressive recruiting and training program has resulted in a significant increase in the si:e and effectiveness of the Operations Depar.tment staf f, the staffing improvement, strict control of operator overtime, appropriate management attention, and intensive communications training all have contributed to a recent trend in positive attitude and professional atmosphere in the control room. However, some

. weakness in attention to detail and procedural compliance were noted and require continued attention. The licensee's approach to problem investigation and root cause analyses has improved, and is generally prompt and positive. Overall performance in tnis functional area has improved, particularly during the last quarter of the assessment period.

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(2) Conclusion .

Ratino: 2 Trend: None Assigned O

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18 4.2 pladioloe'4 cal Controls (1064 houru12 percent)

(1) Analysis The radiological controls functional area is an assessment of licensee performance in implementing the occupational radiation safety, chemistry, radiological environmental monitoring and transportation programs. In November 1984, the NRC issued a

^

confirmatcry order requiring broad scope improvements in the ,

licenseet s Radiological Controls Program. During the previous assessment period this area was rated Category 3. The NRC review found that some improvement had been made in the radiation safety progaam. However, significant weaknesses were :

identified which inhibited further performance improvement, i These weaknesses included poor communications, ontagonistic working relatinnships, lack of personnel accountability, poor ALARA performance, ineffective corrective actions, and vacancies in key radiological safety supervisory and management positions. 1 As a result of these weaknesses the NRC confirmatory order was ;

not closed out. Weaknesses were also identified in implementa-tion of Radiolegical . Effluent Technical Specification sur-l veillance requirements and the licensee's environmental TLD program. During the previous asss ssment period, the licensee's transportation program exhibited a decline in performance with three violations being identified.

During the current assessment period there were nine inspections in this area of the occ pational radiation safety program. The inspections focused on oversight of outage work, establishment j of effective management controls for this area and efforts to l close out the NRC Confirmatory Order and associated Radiological ';

Improvement Plan (RIP). In addition, three inspections were performed in the chemistry,' transportation, and radwasta systems areas.

d Radiation protection The weaknesses noted during the previous assessment period per-sisted through the first half of this assessment period. How-ever, in November, 1987 an inspection found that performance had 4

improved to the point that the November 1984 NRC Confirmatory Order was closed out but, at the same time, acknowledged that additional improvements and continued management attention to ,

4 these areas were needed. Actions that are planned by the I licensee to continue to improve performance such as improved radiological awareness and increased staffing are' documented in !

< the licensee's Radiological Action Plan (RAP).

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{ Toward the end of this period, the Radiation Protection program l

organization and staffing levels, a weakness during most of the i d

assessment, improved. The organization, staffing levels, re-l

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spInsibilities, accountabilities, and interfaces are now well i de fTn ed. Station management attention to the areas of communi-cations, accountability, morale and the corrective action pro-cess over the last half of the period has improved working re- .

lationships and communications between other dep:rtments and l radiation protection, ,

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. The recently revised Radiation Protection organization is approximately 90% filled by permanent personnel. Although the organization and staffing are adequate to support the program, the position of Chief Radiological Engineer (Raciation protec-tion Manager) was recently restaf fed with a contractor, several ,

managers have limited commercial nuclear power experience, and many personnel are new to their pnsitions. Performance of this new organization will continue to be assessed i t- the future.

A well defined training and qualification program has been established. The program contributes to an adequate understand-ing of program requirements with few personnel errnrs. Training resources are adequate. The radiation ' protection training program is INPO certified. New training initiatives are in progress to sensitize management, workers and radiation pro- ,

tection personnel to assure they are aware of the need to minimize all occupational radiation exposure. Examples include training of management on ALARA for plant design changes and providing radiation awareness training to maintenance and operations personnel.

1 Licensee audits and assessments of program implementation and i adecuacy have improved. The audits and assessments, augmented by supervisory and management tours, have been generally ade-quate in following program implementation and identifying weak-nesses, particularly toward the end of the period. Technical specialists are used to augment the QA audit teams. Additional QC surveillance of problem areas (e.g., High Radiation Area key control) has been implemented. However the scope of licensee audits have been principally compliance oriented. There is I little external review of program adequacy and performance relative to the industry.

In the area of Internal Exposure Controls, no significant indi-vidual exposure cf personnel during the period was identified. l Also, during the major plant decontamination operation, exposure of workers to airborne radioactive material was well controlled.

Approximately 90% of the station is now accessible in street clothes. Licensee quantification of r.dionuclides contained in the NRC whole body counting phantom was good. The use of ,

sensitive whole body counting equipment combined with a I capability to analya the data reflects an adequate -bioassay l capability. Although performance in the area of Internal l

20 Exhsure Control's has improved, NRC review identified instances whe7e about 1000 individuals had terminated from the site during the period without receiving confirmatory whole body counts.

These termination body counts are not required by the NRC but are a normal good practice at most reactor sites and are recommended by Pilgrim site procedures. When brought to the licensee's attention they were unaware of the magnitude of these exceptions to the recommended practice, reflecting some weaknesses in oversight of this area.

During the assessment period three violatior.s occurred which involved improper control of High Radiation Areas. Although no unplanned exposures resulted, when examined individua .y, these violations clearly reflect one or more of the previcus assessment period concerns. In response, the licensee' made -

certain short term corrective actions and established a task force to review the concerns and develop 1cng term 'c orrective actions. The licensee corrective actions for the most recent High Radiation Area access control concerns were U propriate, however, these corrective actions were prescribed by memorandum.

The NRC has previously expressed concern regarding finpl e-mentation of regulatory requirements by memoranda rcther than by the use of formal, approveJ plant procedures. At the end of the assessment period, procedures were not yet revised to include.

these corrective actions. An additional weakness involved licensee attempts to resolve a concern with exposure reports in that, early in the period, NRC identified that the licensee had not sent a number of termination reports to individuals. The licensee instituted a corrective actio1 program, but this matter is still under NRC review.

During .the latter part of the assessment period, control, over-sight and coordination of in plant activities by the radiation protection department had significantly improved. The number of licensee technicians and first line supervisors was increased.

Coircident with this staffing increase, licensee management selectively reduced contractor work force, keeping the most competent performers. The augmentation of first line super-visors combined with the elimination of a large number of con-tract technicians resulted in improved management control and accountability within the department.

In the area of radiation exposure, oilgrim Station collective I worker doses, calculated as 5 year rolling averages, have his- l torically been among the highest in the nation. Some improve- '

ment was noted in the previous assessment period after a well documented ALARA program was instituted accompanied by a high' visibility exposure gr.als program. Licensee activities during this period resulted in a co11 active worker dose (1580 person- I rem) which was the highest of all domestic power reactors in

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19N. Analysis by station management attributes the exposures to7aiexpandedworkscopeduringtheprolongwdoutagewithabout 20% due to unplanned rework, poor contamination controls, and )

poor planning. Also, tno large number of workers (about 2000) on site during the outage cocpled with the high radiation source ,

terms and poor work habits in the plant contributed to the high 1 annual dose. During the initial part of this assessment period, NRC concerns included lack of understanding of day-to-dsy work activities due to poor maintenance planning and inaccurate description of work provided to radiation protection personnel which is incorporated into RWPs. Also, RWPs continued to be requested for work that was not performed. Improve-ments in this area were noted during the latter half of this assessment period.

Management efforts instituted to control exposure included hir-ing a large contractor staff to impicment ALARA on the job, assigning six Hp/ALARA coordinitors to work groups, and imple- ,

mentation of dose saving techniques recommended by the ALARA '

Committee. The effectiveness of the six coordinators was par-ticalarly evident in the areas of maintenance and operations.

For example, the use of glove bags to contain contamination dur-ing maintenance has been expanded. Contamination "spill drills" l re routinely conducted to prepare operations . personnel for !

cealing with future incidents so tnat the spread of contamina-tion can be minimized.

Ni,C review of the selected ALARA goals indicated that they ap-peared +.o not be challenging and there was no formal mechanism

~

to incorporate ALARA prirciples during the design of plant modifications. For example, during the outage the licensee was noted to have rebailt a number of large valves (e.g., RHR System) without considering the need to reduce stellite, a major i source of cobalt. During the latter part of the assessment l period, the licensee was attempting to formalize a program to I conduct ALARA reviews of plant design modifications during the i conceptual design phase. A goal of 600 person-rem was initially planned for 1988 even though most of the outage work ended in l February and a lower goal appeared achievable based upon '

anticipated radiological work. In addition, there was no long range planning evident to reduce the high general area dose rates at the station.

Radiological Environmental Monitorina Program Midway through this assessment period an inspection of the licensee's radiological environmental monitoring program (REMP) was conducted. The REMP is administered by the corporate Radiological Engineering Group. The licensee's REMP conforms to Technical Specification requirements. The licensee has made plans for improvement of the annual REMP reports, and improve-

.m . -

22 meb to the meteorological monitoring program even though the licTnsee's Technical Specifications contain no requirements in this area. In response to a program weaknesses identified by the NRC during the last assessment period, the licensee has eliminated the environmental thermoluminescent dosimeters TLD system which was in uw during the previous assessment period and is now using TLDs supplied by the Yankee Atomic Environ-mental Laboratory. Planned personnel expansion in this area is indicative of the licensee's commitment to continued improvement of the REMP.

Transportation One inspection of the licensee's transportation program was conducted midway through this assessment period. Two Severity Level IV violations were identified. Both violations related to shipments made during the presious assessment period. These violations suggested inattention to technical detail and riuality control in the preparation of radioactive shipment records.

However, during this assessment period the licensee increased quality control involvement in orocessing, preparation, pack-aging and shipping of solid radioactive waste. This indicated the licensee's clear understanding of issues relating to causes of the problems and, in addition, the implementation of cor-rective action. The licensee is meeting all commitments to the i NRC with regard to training in this area. The licensee has ;

implemented procedures which clearly define the roles of the departments involved in solid radwaste and transportation.

)

Procedures for processing, preparation, packcging, and shipping solid radwaste were adequate.

Summary In summary, there was an overall improvement in licensee Radia-tion Protection Program adequacy and performance, particularly during the last quarter of the assessment period. However man-agement attention is still required to exceed minimum regulatory requirements in the in plant radiation protection program. Com-munications and working relationships have improved. Facilities and equipment have been upgraded. Limited success in 1) upgrading the ALARA Program performance, 2) staff qualifications 4 and stability, and 3) aggressive long term corrective actions !

for High Radiation Area access control were noted. l In contrast, licensee performance in the areas of REMP and transportation reflects substantial improvement. These areas, if rated separately, woula receive the highest performance I rating category. Previous weaknesses regarding radiological l effluent technical specification surveillance and the environ - l mental TLD program have been corrected and plans made for ad- ;

ditional program improvements. The station has substantially .

upgraded quality control activities in the transportation area. -

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l 23 (2) Conclusion Rating: 3.

i Trend: Improving.

(3) Recommendations Licensee: 1. Continue strong senior management involvement in the in plant radiation protection program.

2. Strengthen the ALARA program and complete training on program implementation.

E: 1. Conduct a management meeting with the licensee to review radiological program status and ALARA program progress. .

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24 4.3 Mainte ce and Modifications (2347 Hours /24 percent)

(1) Analysis This functional area is intended to assess the licensee's per-formance in planning and implementing the station maintenance program, and in implementing and testing plant mcdifications.

The adequacy of modification design is evaluated under the Engineering and Technical Support functional area. This SALP period includes the results of the April 25 - May 5,1988 NRC Maintenance Team Inspecti6n. It does not include evaluation of the licensee's Restart Readiness Self Assessment, nor does it evaluate the licensee's response to the Maintenance Team Inspec-tion findings.

During the previous SALP period, plant maintenance performance was assessed as a Category 2 . Maintenance staffing was weak due to first line supervisory vacancies and lack of direct pro-fessional support, hacpering programmatic improvements.

The scheduling of "A" priority maintenance was good, however lower priority maintenance scheduling was weak as demonstrated by the large maintenance backlog. This was particularly evident in the areas of fire protection and security, resulting in equipment !

unavailability. The. maintenance planning group was effective in !

validating maintenance requests (MR), but was only marginally effective in planning daily maintenance activities. Maintenance program procedures were considered weak and contained only minimal information. No administrative guidance for the newly formed planning and procurement groups was in place, hampering their integration into the process.

During the current SALP period maintenance and modification activities were routinely monitored. Also seven special inspec- !

tions were conducted to evaluate the licensee's maintenance and modification control programs. An Augmented Inspection Team and a special electrical system team inspection also evaluated as-pects of maintenance program effectiveness. Near the close of the SALP period a special maintenance team inspection evaluated the licensee's effectiveness in implementing the program.

Licensee efforts to improve facility material condition during this assessment period have been highly evident. Overhauls of major plant equipment such as the Residual Heat Removal pumps, High Pressure Coolant Injection pump, and feedwater pumps were successfully completed. Commitment by senior licensee manage-ment to perform these and numerous other equipment overhauls is

'a positive indication that material improvement has been a licensee priority.

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l 25 ThCmaintenance section also provided strong support during the November, 1987, extended loss of offsite power recovery effort.

The' Maintenance Section Manager held meetings to ensure directed and coordinated efforts of the work force and developed plans for an organized approach. Inspector observation of maintenance task performance in the field indicates that workers are ade-quately trained in that they are generally knowledgeable of assigned activities and their impact on the plant.

Senior licensee management has acted to increase allocated main-tenance staffing, however staffing levels remained a weakness during much of the period. The significant burden of outage .

activity combined with this weakness continued to delay the progress of program enhancements. Early in the period, first line supervisory vacancies resulted in a reduction in oversight -

of field activities. Qualified licensee personnel did not apply for the positions. The licensee aggressively recruited indi-viduals from outside the organization and filled the vacan-:ies.

Three maintenance staf f engineer , positions were created and filled in an effort to provide maintenance department technical support.

These individuals concentrated largely on completion of outage tasks and therefore were not available to develop longer range maintenance program improvements. Late in the period the Main-tenance Section Manager and both the Electrical and Mechanical Division Manager positions became vacant. The licensee filled l these three vacancies immediately af ter the close of the SALP 1 period. Turnover and difficulty in recruitment of in-house personnel continues to be a significant problem at the mainten-ance supervisor l e*v e l . The licensee compensated for two of these vacancies by using contractors. These continuing super-visory staffing vacancies combined with maintenance management turnover resulted in a lack of stability and consistent direc-tion in the maintenance organization.

Communications between the maintenance department and other I organizational entities has improved significently. Early in the SALP period poor communication between the maintenance, radiation protection and operations departments resulted in a large number of radiation work permits requested but not utt-lized, and processing of equipment isolations for maintenance activities which were subsequently delayed. Maintenance prior-ities were not always consistent with operational needs. To I address these issues, licensee management assigned two experi- i enced radiation protection technicians to maintenance to assist l in job planning and to improve maintenance personnel apprecia- l tion of radiological considerations. Two senior reactor opera-tors were assigned to provide direct input to the planning pro- !

cess, and to act as liason between operations and maintenance. !

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26 ThNe actions resulted in substantial communications improve-ment, and more efficient processing of maintenance and modifica-tions tasks during the latter part of the assessment period.

During the period the licensee continued to devote resources to the improvement of the planning and scheduling function. Staff-ing of the maintenance planning group was augmented by the ad-dition of significant contractor support. At the close of 'he ;

SALP period all maintenance planning staff positions had been filled, with five positions filled by contractor personnel.

This group actively collected existing MRs and verified spare parts availability but was not effective in developing inte-grated maintenance schedules or ensuring consisteat high tech-nical quality in maintenance packages. Licensee management also creped the temporary Planning and Restart Group to assist in estaolishing outage scope and schedules. The functions of this group were later incorporated into the permanent line organiza-tion under the Planning and Outage Manager. The Planning and Outage Group appeared to be increasingly involved in developing and tracking longer term work schedules by the close of the SALP period. Continued attention to developing and implementing effective maintenance schedules, and to improving the detail and quality of maintenance work packages is needed.

In the previous SALP period, a large backlog of low priority maintenance had resulted in inoperable fire protection and security equipment, and reductions in operattunal flexibility due to equipment unavailability. During this assessment period, j the licensee has effectively focused attention on defining and I processing this large backlog of work. Recent completion of the i major outage activities allowed further reductions. Late in the period the licensee directed increased effort at improving general equipment condition. Management frequently toured the station, evaluating the ef fectiveness of these efforts. How-ever, because of a lack of sensitivity caused in part by con-centration on backlog reduction, less significant maintenance deficiencies and poor maintenance practices were not always promptly addressed. An example of this is the poor condition of station batteries identified during a NRC team inspection.

Severai routine inspections and a maintenance team inspection j near the end of the SALP period found that maintenance program I procedures and work instructions continued to be a significant l we aness. Work control and implementation practices were not clearly delineated in approved procedures or other directives as evidenced by the excessive delay in issuing the Maintenance Manual. Maintenance requests contained little detail of the as-found condition, repairs effected and post-maintenance test-ing performed. ~ This ~ hindered subsequent ~ root cause evaluations and reviews. Instructions provided to maintenance technicians

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27 offen.were not sufficiently detailed to ensure proper perform-ancy of the task, and to document activities such as placement of jumpers or lif ted leads. For example, a series of engineered ,

safety feature (E3F) actuations were caused by lack of adequate I instructions and planning of electrical relay replacements.

There was also no effective process for management review of completed maintenance packages. A number of improvements had been implemented such as maintenance package checklists, worker prejob briefings and use of a temporary procedure to document i lifted leads, but appropriate maintenance process procedures were not revised to reflect the changes. For much of the SALP period, actions taken in response to NRC concerns were directed at correcting problem symptoms and were not suf ficiently com-

prehensive in nature. The licensee deferred the formal ad- ;

dressing of program weaknesses in this area and the application of i nterim improvements has' been inconsistent and not wholly effective. Shortly af ter the assessment period, licensee a t-tention to this areas intensified and major prograr improvements we r- initiated.

,he licensee's post-maintenance *est program was not clearly defined. No clear guidance for & ;tablishment of post-mainten- ,

ance testing requirements existed. In one case MRs for exten-sive repair and retermination of electrical cables were desig-nated as not requiring retest, even though the repairs disturbed numerous circuits upon which logic testing had previously been completed. Late in the period the licensee took action to strengthen the post-maintenance testing process and to create a matrix of testing requirements.

The licensee implemented several aggressive maintenance initia-tives directed at improvement of component performance. Pre-ventive maintenance on all safety-related motor operated valves (MOV) and AC circuit breakers .was completed. However MOV pro-cedures were found to be weak in some areas. Circuit breaker maintenance was not extended to include any safety-related DC circuit breakers until prompted by the NRC, even though none had been performed during the life of the plant. While management

, commitment is evident, follow through on initiatives was occas-ionally incomplete. The increasing involvement of the Systems Engineer Group has had a positive impact on maintenance perform-uce , particularly the quality and promptness of . maintenance problem root cause analysis. The licensee also significantly increased staffing, training and management direction of the j Station Services Group resulting in improvements in the station decontamination and housekeeping programs.

. The licensee has implemented a Material Condition Improvement i Action Plan (MCIAP) which identifies many of the weaknesses described above. An independent monitoring group was estab-

,- a m - , g-, r wn,..eewar -en,-- - --~w.w ,-,-,,---w--,,...,ws.,_-m-,, n .,m._ ,.w--,,.,,m ,n-9-.- - - - , ----ne-,--.,ww m e .n n,-ve-.

28 lided by the licensee to monitor its effectiveness. This plan i s ]n' tended to result in significant maintenance program im-pr svements cver the long term. The hardware aspects of the Ml.IAP were ef fectively addressed, however, program and proced-ural enhancements were deferred. The licensee also implemented a maintenance performance indicators program. This program has assisted licensee maintenance management in better focusing on adverse trends and department performance.

As a result of good working relationships between the Site Engineer Group and the Modification Management Group, licensee control of modification implementation and turnover was strong.

A large number of complex modifications were completed during the period without significant problems. The program for con-trolling post-modification testing was generally effective.

However, technical review of post-modification test procedures was occasionally inadequate. Examples of this included the .

failure of testing to identify the incorrect installation of reactor water level instruments, and the appre 11 of several tests which either caused or would have caustd m. nticipated ESF actuatiens.

In summary, the licensee :ontinues to give high priority to improvement of plant material condition, although program weaknesses in several areas were evident. The licensee im-plemented informal process enhancements which resulted in more rapid improvement during the last months of the SALP period. A long range plan, the MCIAp, has been established to promote program im9rovements in the areas of identified weakness.

Licensee senice mans.gement attention to full and timely imple-mentation of this plan is necessary to assure that permanent improvements are achieved. Staffing problems and management turnover however, need to be resolved so that these problems do not continue to hamper licensee efforts.

(2) Conclusion Rating: 2 Trend: None Assigned (3) Recommendations Licensee:

Complete implementation of program inprovements and con-tinue staffing efforts.

Provide for staff continuity and development.

!LRC: None.

o

e 29 4.4 Survet Cance (1386 hours0.016 days 0.385 hours 0.00229 weeks 5.27373e-4 months /14 percent)

(1) An'a ly s i s The surveillance function:1 area is intended to assess the ef-fectiveness of licensee management in assuring the development and implementation of a comprehensive surveillance testing program.

Ouring the previous SALP perioo, surveillance was essessed as a Category 3. Testing was generally conducted in a careful, safety conscious manner, however no centralized management of the surveillance test program existed. Responsibility for pro-gram management was not clearly established. The system for control of surveillance scheduling was weak, principally because the key individual involved with this activity was not a tech-nical staf f member. The technical adequacy of surveillange procedures and the control of measuring and test equipment

. . (M&TE) were also found to be inadequate. The licensee's sur-veillance test program had not received adequate management attention. 1 During this SALP period surveillance testirig was roatinely ob-served and procedure technical adequacy was evaluated. One management meeting and several inspections were conducted to assess licensee efforts to correct the previously identified problems. An Augmented Inspection Team dispatched in response to a loss of offsite power also evaluated aspects of survail-lance program effectiveness. l Ouring the previous assessment period, the absence of strong centralized control and responsibility for surveillance program oversight contributed to continuing weaknesses, Eccly in this SALP period the licensee assigned responsibility for program maintenance and upgrade to the Technical Section Manager. The Systems Engineering Group within the Technical Section has become increasingly involved with development of program improvements. A Surveillance Coordinator position was estab-

, 11shed and staffed by a senior systems engineer to help provide needed focus. In addition, a coordinator was sssigned in each department responsible for surveillance test performance. Al-location of these resources has resulted in acceleration of program improvements and is an indication of management commitment.

-_ , -,__y _ . , , . _ _ _ _. __ -,, , _y,,

o

. l 30 Thblicensee has taken action to improve the technical adequacy of *~ surveillance test procedures. Technically inadequate test procedures were a recurring problem identified during previous SALP periods, requiring repeated NRC initiatives to obtain licensee corrective action. During the current assessment per-iod however, the licensee implemented an extensive effort to evaluate and upgrade s Jrveillance procedures. A team Composed of licensee Nuclear Engineering Department, Technical Section and Maintenance Section representatives was formed to address the problem. Initially the effort was intended to assure com-pliance with technical specifications. Licensee management expanded the upgrades however, to include testing of additional system design features beyond technical specification require-ments. This is an indication of the licensee's desire to estab-lish a more comprehensive program that goes beyond regulatory -

requirements. Implementation of the improved testin,g allowed the licensee to identify and correct several system performance problems. Another example of the licensee's intent to thor-oughly test major systems was the use of a temporary boiler to perform extensive testing of the High Pressure Coolant Injection and Reactor Core Isolation Cooling systems with non-nuclear steam. While substantial progress has been made, and existing procedures have been upgraded sufficiently to assure compliance with the Technical Specifications, some procedural weaknesses continue to be noted. For example, the inoperability of an emergency diesel generator during a loss of offsite power could have been prevented if surveillance procedures had recorded and evaluated more than the required minimum instrument readings.

Additionally, inadequate test procedures have caused unnecessary engineered safety features actuations.

The licensee began development of a new computer-based Master Surveillance Tracking Program (MSTP) in an attempt to resolve previously identified scheduling problems. Consicerable licen-see effort was expended on development of the new program. How-ever, late in the SALP period the licensee concluded that it was not viable due to problems with vendor-supplied computer sof t-ware. The licensee's Systems Engineering Group has initiated an interim manual tracking system, and is revising the previously used MSTP to compensate for the identified weaknesses.

~

Substan-tial time was expended in the unsuccessful attempt to implement the new MSTP, and therefore final resolution of the scheduling 1 problems has not been reached. However, it is evident that licensee nanagement is committed to improving the system, responsibility for implementation has been established and progress is being made. .

. _ _ _ . . . - . , _ _ . - - . _ - , . r, , ., - -.-._..,..~-,,,y

31 The licensee's-program for control of Measuring and Test Equip-mew (M&TE) has improved significantly. The licensee dedicated four full-time individuals to the upgrade of the M&TE control program. Instruments were collected, assigned unique identifi- ,

cation numbers and data was input to a computer-based tracking system. Control and implementation of the local leak rate test program have also improved since the last assessment period.

The significant improvement in these arcas is a clear result of maragement involvement.

Licensee personnel generally conducted testing in a careful, safety conscious manner. Major testing evolutions such as the .

reactor vessel hydrostatic test and the containment integrated leak rate test were well coordinated and executed. Occasional personel performance lapses in the quality of testing were noted, however. For example, instrument and controls tech-nicians failed to enable equipment sump level switches after calibration, causing sump overflow in the high pressure coolant injection pump room. During a similar drain system overflow incident operators did not perform requirad shiftly plant tours.

As a result contaminated water was allowed to accumulate. These instances may indicate some weakness in personnel training. .

The inservice inspection (ISI) program was effectively imple-mented. The licensee's ISI staff demonstrated a good under-standing ~ of technical issues. Management support of the ISI program is evident. For example, prompt action was taken to evaluate piping errosion and drywell liner corrosion in response to industry events.

In summary, the licensee has established appropriate responsi-bilities for management of the surveillance program. Sufficient senior management and technical resources have been allocated to affect the needed program improvements. Program responsibil-ities have been defined and assigned to the System Engineering Group. Tes'; procedure technical adequacy and control of M&TE were substantially improved in response to recurring NRC con-cerns. While strengthening of surveillance scheduling has been slowed due to computer program problems, progress is currently being made. Continued licensee management attention is neces-sa ry to assure implementation of ongoing improvements, aggres-sive evaluation and correction of remaining weaknesses and reinforcement of newly established work standards.

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

l

l 32 .

I 1

(2) Com:1usion ,

RatIno: 2 Trend: None Assigned (3) Recommendations Licensee: Continue positive initiatives to upgrade surveillance ,

procedures and impliment improved surveillance track- '

ing programs.

i O

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33

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4.5 Fire Prttection (493 hours0.00571 days 0.137 hours 8.151455e-4 weeks 1.875865e-4 months /5 percent)

(1) Anilysis This functional area is intended to assess the effectiveness of the licensee's station fire protection program, and the adequacy of modifications and procedures established to ensure compliance with 10 CFR 50 Appendix R. During the last period this area was rated as a Category 3. The fire protection program suffered from a chronic lack of management attention. The licensee was not aggressive in maintaining the operability of station fire protection equipment, resulting in heavy reliance on compensa-tory measures. Fire barrier surveillance procedures were un-clear and incomplete. Personnel performing fire watches and serving on the fire brigade were poorly trained. Licensee senior management had taken steps at the end of the period to strengthen the program.

During this assessment period routine inspections monitored the progress of licensee improvement efforts, additionally two inspections were conducted to assess the status of the station fire protection program. In addition, a team inspection was performed to evaluate licensee compliance with 10 CFR 50, Appendix R. A management meeting was also held to discuss 'tre protection and Appendix R concerns.

The licensee demonstrated e high level of management involvement l in ensuring fire protection and Appendix R program improvements. )

A fire protection group was established near ti.e end of the last SALP period. During this period, staffing for the group was increased from one fire protection engineer to six permanent fire protection specialists. Frequent meetings with the fire protection group leader, and periodic status reports assisted senior licensee management in monitoring the group's progress.

In the area of Appendix R the licensee established a temporary project managemer.t organization. A senior project engineer was dedicated to provide focused oversight and support. The Appen-dix R project organization and the fire protection group worked closely together to coordinate activities.

The licensee has been successful in reducing the backlog of fire protection equipment maintenance, which hH contributed to a heavy reliance on compensatory measures. re , protection group and maintenance managers worked effectively together to reduce i the outstanding maintenance backlog, and to mait.tsin it at a j manageable level. Total outstanding fire prrtection maintenance :

was reduced from over 300 items to less than 50 items, and is I currently tracked by licensee management as a performance indicator.

34 The I tontrol and quality of fire brigade training have improved.

The' Tire protection group, with the assistance of the training department, developed and implemented a more comprehensive training program. A state certified instructor was hired to conduct the brigade training. The rumber of fire brigade drills conducted has substantially increased, and it appears that their effectiveness has improved. Through these actions the licensee has succeeded in developing a large core of trained personnel to serve as fire brigade members. Effective interaction and coor-dination between the fire brigade, the operations staff and local fire fighting companies was evident during several minor fire incidents occuring during the period, including a fire in the ma; hine shop which prompted declaration of an Unusual Event.

The licensee initiated, and the NRC has approved several fire protection 1,1 censing actions during the assessment period. In

- response to past instances of protlems with fire barrier ade.-

Acacy, the licensee's Appendix R project organization imple-mented a well conceived program to identify, inspect and repair plant fire barriers. These inspections resulted in the identi-fication of a significant number of deficient barrier seals.

Licensee management exhibited a conservative philosophy, estab-lishing compensatory fire watches for all plant barriers pending completion of inspections.

The licensee's approach to maintaining safe shutdown capability was found to assure redundant safe shutdown system trsin separa-tion, and to provide sufficient operational flexibility. To assure adequate separation the licensee performed a well docu-mented and thorough analysis, although procedures for use tf the safe shutdown equipment, and operator training in this area were found to be weak. The licensee has taken action to resolve I these weaknesses and has committed to demonstrate safe shutdown capability by performing a test during the power ascension program.

In summary, licensee management has taken strong action to establish and staf f an effective station fire protection organ-tration. Significant improvement in fire protection equipment material condition and fire brigade training has resulted.

Licensee response during this SALP period to Appendix R issues, particularly fire barrier seal problems, was prompt and effec- ,

tive. Continued management attention is needed to assure prompt )

completion of fire barrier seal repairs, to achieve further '

reduction of outstanding compensatory fire watches and to pro-vide a stable effective fire protection program.

1 I

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e 35 (2) CoIclusion Rating: 2 Trend: None Assigned O

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36 i 4.6 Emergen5 preparedness (176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months /2 percent) r (1) Analysis During the previous assessment period, licensee performance in ,

this area was rated Category 2. This was based upon a renewed l commitment by management for emergency preparedness and a sig-nificant improvement in performance.

During the current assessment period, one partial participation exercise was observed, two routine safety inspections were con-ducted, one special safety inspection specifically related to emergency classification was conducted, and changes to emergency plans and implementing procedures were reviewed.

Two routine safety inspections were conducted in November,1987 and January, 1988. These inspections examined all major areas within the licensee's emergency preparedness program. During the November, 1987 inspection, significant changes were examined l regarding the normal emergency preparedness organization. These changes resulted in essentially a completely new organization

, with the Emergency Preparedness Manager reporting to the Senior i Vice President. Functional responsibilities are divided into ,

on-site and off-site areas with coordinators for each. The licensee has filled the managerial oositions, as well as other working positions, with personnal experienced in emergency pre-paredness. In addition, the licensee has contracted with several consultants to help the permanent staff.

During the January, 1988 inspection significant changes were examined regarding the Emergency Response Organization (ERO) and

Emergency Action Levels (EAL's). The licensee has' committed to a complete restructuring of the ERO with a three-team d'ty rota-tion. Additionally, the licensee is revising the EAL's to be symptomatic, address human factors, and has integrated them with l the Emergency Operating Procedures. Significant facility changes made include the addition of a Computerized Automated {

Notification System to notify the ERO. ;

i

A partial participation exercise was conducted on -

December 9, 1987. The licensee demonstrated a satisfactory -

i emergency response capability. Actions by plant operators were i prompt and effective. Event classification, and subsequent Protective Action Recossendations, wre accurate and timely.

Personnel wera generally wil trained and qualified for their i positions. No significant deficiencies wre identified.

Several minor waknesses wre noted including insufficient depth in some positions to support prolonged operations, dose projec-tion discrepancies, delays in fielding onsite repair teams, and weak initial notification forms.

G

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37 l l

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Oudng- the response to a loss of offsite power event in l Nov4Tnbe r: 1987, some weakness in coordination and communication between licensee groups was noted. Vnile not required by the site emergency plan, the licensee eventually chose to partially activate the Technical Support Center (TSC) to aid in recovery efforts. The difficulties experienced by the licensee during the initial response and subsequent efforts to utilize the TSC indicate that licensee attention to preplanning response options to non-emergency events, such as discretionary activation of the TSC, may be appropriate.

1 During the February, 1988 inspection the licensee's actions in .

response to a declaration of an Unusual Event were examined. '

The licensee's classification was conservative and prompt. Mit-igation activities were effective. The licensee identified several problems associated with their actions including: fail-ure to completely follow procedures; untimely notification of event termination; and control room distractions due to the large volume of outside communications. The licensee promptly ,

identified these issues and instituted appropriate short-term j and long-term actions to prevent their recurrence, j The licensee is continuing to work closely with local and Commonwealth of Massachusetts officials to upgrade off-site emergency preparedness. The licensee has a large organization working on plan and procedure development, in conjunction with the appropricte local and Commonwealth agencies.

During this period, the licensee was granted exemptions for the 1987 full participation exercise and a deferral of the submittal l

of public information. These were based on the Commonwealth of -

Massachusetts requests to complete the local and Commonwealth emergency plans, implementing procedures and associated training prior to issuance of public 'information or demonstration of

capabilities, i

In summary, the licensee has demonstrated a commitment to emerg-ency preparedness. Managreent involvement is evidenced by the major on- site program t." ages being supported, commitment to !

the offsite level of emergency preparedness, and by timely y recognition of problems and subsequent corrective actions. The j licensee has been responsive to NRC concerns and is continuing i to make progress in these areas. l (2) Conclusion

! Ratino: 2 Trend: Improving ;

)

I

38 4.7 Securit t and Safeguards (641 hours0.00742 days 0.178 hours 0.00106 weeks 2.439005e-4 months /7 percent)

(1) Analysis This functional area was rated as a Category 3 during the pre-vious assessment reriod. NRC identified serious concerns regarding the implementation and management support of the security program. The licensee's proprietary security staff consisted of one full time and one part time member, resulting in weak oversight of the contractor. In addition, inoperable equipment contributed to a heavy reliance on long term compen-satory measures. Contractor security force overtime was also poorly controlled. Toward the end of the assessment period, the l'censee initiated actions to correct the problems. However, at the conclusion of the rating period the hardware upgrades were not complete and the expanded proprietary security staf f organ-tzation had not been in place for an adequate time for NRC to evaluate its effectivtness.

, Four routine, unannounced security inspections, one special

security inspection, and one routine unannounced material con-r.rol and accounting inspection were performed during this assessment period by region-based inspectors. Routine observa-tions were also conducted throughout the assessment period.

Durir.g this assessment period, the licensee aggressively pursued a planned and comprehensive course of action to 1 den *.ify and correct the root causes of the previously identified program-matic weaknesses in the area of physical security. To improve the overall performance of the security organization and the security program the licensee implemented several significant actions, including a commitment by senior management to support and implement an effective security program; establishment of a licensee security management organization on-site to direct and oversee program implementation; upgrading unreliable systams and ,

equipment to eliminate the previous heavy reliance on compensa- l tory measures that were manpower intensive; and revising the '

Security, Contingency and Training and Qualifications plans, and !

their respective implementing procedures, to make them current and clearer.

)

, Tne licensee's security management organization is now headed by I a section manager who reports to the Plant Support Manager, under the Station Director. Assisting the Security Section Manager are five supervisors with specific functional areas of I i responsibility (operations, administration, technical, compli- I ance and access autliorization) and a staf f assistant. Addi- )

tie,nfly, there are seven licensee shift supervisors who are !

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39 res][on.sible to monitor the performance of the contract security force arouna-the . lock. This represents an overall increase of seven supervisors over those which were in place at the end of

~

the last assessment period, and thirteen over that which was in place when the plant was shot down in April,1986. (At that time there was one supervisor who reported to a group leader with other, concurrent duties.) The licensee also established a full-time corporate security position onsite. The incumbent is responsible to audit th6 security program on a continual basis and to provide another perspective on its implementation. In addition, the licensee established, as supervisory personnel, the alarm station operators employed by the security force con-tractor, and significantly impreved the supervisor-to guard ratio. This expansion of the licensee's security organization represents a significant allocation in terms of resources and provides evidence of senior management's commitment to the program.

In addition to the organizational expansion, considerable capital resources were expended throughout the assessment period to upgrade, by modification or replacement, security systems and equipment. The entire protected area barrier, assessment sys-tem, intrusion detection system and protected area lighting were significantly improved. These improvements began early in the assessment period and wire, for the most part, complete at the end of the period with only minor fine tuning of the ney systems and equipment still required. Additional upgrades in access control aquipment and the security computer are scheduled. The improvements have already resulted in a sizable reduction in the number of compensatory posts and, therefore, a retWan in the 1 contract guard force. The above mentioned upgr. des termitted I the guard force to go on a 40 hour4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months work week rathur than the 60 i hour work week required during the major portion of the assess-ment period. In addition to the improved syster.s and equipment, the licensee has taken action to strengthen th9 security equip-ment corrective maintenance program and has initiated action to establish a preventive maintenance program to fu ther ensure the continued reliability of security systems and equipment. Open maintenance requests for security equipment are also now tracked as a performance indicator by plant management. These actions and initiatives are further evidence of senior management's commitment to the program.

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40 P

Our* fog the assessment period, the licensee submitted six changes to 'the Security Plan under the provisions of 10 CFR 50.54(p). .

One of these changes was a complete revision to upgrade the !

Security Plan and to revise the format to De consistent witn NUREG 0908. In conjunction with the Security Plan upgrade. the licensee also submitted revisions to the Safeguards Contingenwy Plan and the Security Force Training and Qualification Plan (complete revisions of these plans were submitted during March, 1988). The complete plan revisions were comprehensive, more consistent with current NRC regulations, and provided clearer documents from which to develop and modify implementing proced-ures. The plan changes were adequately summarized and appro-priately marked to facilitate review. Further, the licensee, prior to submitting the changes, communiceted with the NRC by telephone and requested meetings in legion I and onsite to ensure that the changes were approprf te, clearly understood, and in compliance with NRC regulations.

Audits of the Security program conducted by Corporate Security

] personnel and the onsite QA group during the assessment period were found to be very comprehensive and corrective actions were found to be prompt and generally effective, indicating a much improved understanding of program objectives. Because of the security program weaknesses identified toward the end of the previous SALP period, the licensee assigned to the site, on a full-time basis, a member of the corporate security staff with I responsibility for conducting continued surveillance and audit of the program. That initiative was reviewed and found to be a ,

very effective management tool to provide an independent assess-ment of the day-to-day implementation of the security ' program and another input to the overall security program upgr:de project.

r The security force training program appears to be adequate to address the activities of the security organization. The lican-see has taken actions to assure the training program remains current and reflects the changes and upgrades to +he security program. For example, to ensure more comprehensive management r oversight by licensee security shift supervisors, each received plant operational technical training in addition to security j program and other training. This training enables these super- 1 l visors to be more effective in interfacing with other plant

technical functions.

4 .

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4 That *were three apparent violations identified by the NRC dur- :

ing"this assessment period. All of the violations were the l i result of degraded vital area barriers. The licensee was noti- ;

fied of the apparent violations and an enforcement conference and a subsequent management meeting were held. These apparent i violations resulted from weak communications between the secur-ity and maintenance organizations, and a poor appreciation by ;

maintenance personnel of security requirements. Corrective actions were implemented by the licensee and they appear to be !

! effective. -

1 !

8 A total of six security event reports required by 10 CFR 73.71(c) were submitted to the NRC during this assessment per- ;

i iod. Three event reports were necessitated by the licensee's 4

findings of degraded vital area barriers. Similar degradations l

were also reported in the previous assessment period. Two of !

the degradations reported during this period were the result of I i maintenance work being performd on plant systems that pene-trated the barriers. The other resulted from a degraded vital area door. Another event report was necessitated by the re- ;

classification of an area of the plant as vital. The need for ;

, reclassification was identified as a resu1*. of the licensee's i i Vital Area Analysis and Barrier study. Anoth'er e'ent v report

! involved a guard leaving his weapon unattended The sixth event

{ report involved the loss of a set of security keys by a member j of the guard force. With the exception of the vital barrier >

' degradations earlier in the assessment period, no adve'rse trend l was indicated by the events which occurred during this assess- ;

i ment period. The licensee eventually implemented appropriate i

( measures to prevent recurrence of the vital area barrier degra-

! dation problems. The quality of the event reports was signif t-cantly improved over the previous essessment period indicating a i better understanding of program objectives and more care in 1 their preparation. They were clear, ccncise and contained suf-i ficient information to permit NRC evaluations without the need for additional information.

The licensee's program and procedures for the control and ac-l counting of special nuclear material were also reviewed during '

l this assessment period and were found to be adequate and gen-

erally well implemented.

W 4 In summary, the licensee has demonstrated a commitment to imple-

ment an effective security program that goes beyond minimum

compliance with NRC requirements. 'As a result of this commit-ment, the licensee security organization. has been expanded, significant capital rescurces have been expended to upgrade l security hardware, and equipment and program plans have been

< improved. Continued senior managemen' support and involvement

! in the security program is necessary to ensure that the momentum j

] dettonstrated during this assessment period is continued, i l

42 (2) ConElusion Rating: 2 Trend: None Assigned l

c.

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l 4.8 EnginehnsandTechnicalSupport(1215 Hours /13 percent) r (1) Analysis This functional area is intended to assess the adequacy of the licensee's technical and engineering support in the areas of !

plant design changes, routine operations and maintenance activ-ities. Engineering and Technical Support was assessed as a

Category 1 curing the previous SALP period. Good engineering support to the site was noted in the Environmental Qualification program and the design of several significant plant hardware i modifications. Technical evaluations were typically thorough .

J and demonstrated an adequate regard for safety. The engineering l approach to the Safety Enhancement Program (SEP) demonstrated an

excellent appreciation for underlying safety issues. A weakness . ,

in the lack of detailed design basis documents for plant equip- l

ment was also noted during the last period.

l During this assessment period, five special inspections includ- !

ing an Augmented Inspection Team focusing on a Isss of offsite power event, an electrical system team inspection, and a main-tenance team inspection were conducted and, in part, evaluated the licensee's performance in this area. The effectiveness of j the onsite Systems Engineering Group, and the Nuclear Engineer- i j ing Department's (NED) interactions with the site organization i

were routinely monitored.

Significant plant modifications were installed during this i assessment period, including the reactor water level instrumen- !

tation modification, a hydrogen water chemistry system, an l anal'og trip system, and a new plant process computer. Few prob- l 1

lems were identified with these projects, demonstrating the l strength of the enginearing work. Safety evaluations requ .ed l l by 10 CFR 50.59 for design changes and modifications were ;

1 generally thorough and conserystive. Safety evaluations fur SEP '

modifications demonstrated sufficient analysis and supporting l facts to conclude that there were no unreviewed safety ques- ;

tions. Highly quelified engineering staff and NED management j focus on safety have contributed to the licensee's performance .

! in this area. .

1 ,

i Offsite technical and engineering support was generally good as !

indicated by the successful design and implementation of signif- ;

~

icant plant hardware modifications. Continued effective use of i the Design Review Board was evident during this SALP period, i i !

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44 Th$ was demonstrated by high quality initial design reviews, anCroutine evaluations of completed modifications for syner-gystic ef fects. The expanded Field Engineering Section, the design implementation oversight arm cf NED, played a vital role in coordinating activities between the site organization and the NED. Engineering management was actively involved in icplemen-tation of modifications and addressing preblems. The Safety Enhancement Program, including extensive Mark I containment and station blackout modifications, were planned and implemented during this period. The engineering approach to the Mark I issues went considerably beyond NRC requirements and demon-strated a good appreciation of containment reliability issues.

The NED's involvement in the development of the new Emergency '

. Operating Frocedures (EOP) demonstrated significant management attention in this area. The licensee's communications with the NRC regarding the planning and implementation of the SEP and E0P projects were generally good. In addition to these modifica-tions, the licensee is preparing an extensive Individual Plant Evaluation (IPE) as part of the (SEP) using probabilistic and deterministic analyses. In support of these efforts, the licensee effectively managed contract engineering expertise to produce quality design changes and analyses. Throughout the l development ar.d implementation of the SEP senior manageaent's involvement and commitment to safety was apparent.

A team inspection was conducted during this assessment period to review the licensee's implementation of a fire protection pro-gram to meet the requirements of 10 CFR 50 Appendix R. The ;

licensee's aperoach to maintaining safe shutdown capaotlity was found to assure adequate redundant safe thutdown system train separation, and to provide sufficient operational flexibility.

The licensee's analyses were found to be well documented and thorough. NED's Appendix R project organi:ation and the onsite i fire protection group worked closely together to coordinate activities.

I Some weaknesses in the engineering design change process were :

noted. In one instance inadequate technical review of a design !

change by NED resulted in incorrect installation of reactor water level gauges. Additionally, the plant design change docu- q ment for the Standby Gas Treatment System did not specify ade- -

quate post work testing requirements. Further, as indicated in ,

2 the previous SALP, the lack of detailed design basis documents '

was a continuing problem this assessment period.

Examples l included lack of seismic qualification documents for the reactor I

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- h 45 buHding' auxiliary bay and for the hydraulic control units.

A1CE,' engineering failed to correctly translate containment accident temperature profiles into environmental qualification documents. However, the licensee has taken initiatives to further understand the design bases of the plant electrical distribution system as evidenced by the use of a new computer code to analyse electrical distribution equipment performance.

At times, corporate engineering support for plant maintenance activities' was limited. The NRC special electrical system inspection identified that the DC battery and electrical breaker maintenance activities were not supported by NED. The licen-see's initial response to the NRC's concern regarding the sur-ve111ance testing of the DC breakers was limited in scope and .

lacked engineering justifications on the sample size and the ,

acceptance criteria.

The increasing involvement of the ensite Systems Engineering Group (SEG) has had a positive impact on the quality of opera-tiens event analysis, the surveillance test per" eam, and on maintenance performance, particularly the quality of maintenance problem root cause analysis. At the beginning of the assessment period the licensee established the SEG under the Technical Section within the Nuclear Operations Department. The SEG was staffed largely with experienced contractors, but the licensee gradually expanded the group and replaced the contractors with permanent Boston Edison employees. At the end of this period, i the SEG had a total technical staff of 26 including 15 senior systems engineers. The increasing involvement by the SEG has promoted better intergroup interactions as the operations and >

maintenance departments have begun to value and rely on the SEG's contributions.

In summary, overall strong engineering support continued throughout this period. Major plant modifications were com-pleted with only a few minor p.oblems, demonstrating the quality of engineering work. The increasing involvement of the SEG has contributed significantly t) the quality of root cause analyses and in maintenance performance. However, overall performance in the areas of corporate engineering responsiveness and support ,

to site maintenance initiatives appears to need further licensee evaluation and improvement. Additional management attention is needed in developing long-term programs to provide better operational and maintenance support to the site.

9

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

, - , - -n - - - ,

46 (2) CorC?J us1on Raiing: 1 Trend: None Assigned e

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

During this period, the bssis for this appraisal was the lican-see's performance in support of licensing actions that were either completed or had a significant level of activity. These actions consisted of amendment requests, exemption requests, responses to generic letters, TMI items, and other actions.,

The licensee has exhibited a high level of managament involve-ment in major licensing initiatives; however nore routine licensing actions did not always receive substantive management action. An example of a high level of management involvement and initiative is the licensee's actions to improve the Mark I containment and implement other plant safety improvements intended to cope with severe accidents as part of' its Safety Enhancement Program (SEP). This program includes improvements to ever;ency operating procedures, modifications to containment spray nozzles, enhancements to water supplies that would be

, available in the event of a severe accident, the installation of a direct torus vent and the installation of a third emergency diesel generator. A number of the SEP modifications, such as the Station Blackout Diesel Generator are also useful in dealing with less significa*nt transients and events as opposed to severe accidents.

The licensee is in the forefront of the industry in the effort to deal with severe accidents and has expended substantial resources on the SEP. The licensee has been very active in industry owner's groups involved in severe accident initiatives. -

Although much of the SEP effort did not involve direct lic9n' sing actions, the staff did assess the safety significance of the licensee's modifications and inspected portions of the modifica- ,

tions. The licensee is commended for its leadership on the SEP ,

program. It should be noted that the staff is still continuing i its assessment of some of the details of the SEP modifications.

I

~

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

Several submittals were required, and the staff had to request detailed calculations to support the licensee's basis. In a technical specification change involving 10 CFR 50 Appenoix J requirements (Amendment 113), the licensee had to make numerous submittals in response to staff concerns .nd was required to correct errors in previous submittals identified by both the staff and BEco. The staff identified inconsistencies in pro- ,

posed changes to the technical specifications for the Standby Gas Treatt.ent System and Control Room High Efficiency Air Fil-tration System (Amendment 112) and revised submittals by the licensee were required. The extensive activities and resources required to correct problems identified in Confirmatory Action Letter 86-10 and subsequent management meetings has apparently impacted the licensee's overall performance in the licensing crea. These problems suggest a weakness in corporate manage-ment at the level that establishes priorities and coordinates i engineering and licensing activities for the utility.

The licensee has, however, submitted, and the staf f has ap-proved, a number of technical specification changes or exemption requests that demonstrated a high level of technical quality and management involvement. Examples include the schedular ex-emotion for conduct of the emergency preparedness exercise, Core ,

Reload ( Amendment 105), Control Rod Block Actuation ( Amendment i 110), and LPCI Subsystem Surveillance (Amendment 111). Where i

. NRC staff requests for additional information were made, the l licensee responses have been prompt and comprehensive, l I

The licensee has usually been responsive to NRC initiatives.

The licensee has been responsive to staff requests to track and control actions of mutual interest between NRR and the utility.

For example, the licensee has developed a tracking system to assist in the management of licensing actions and has provided i extensive resources to support NRC effort in updating the Safety !

Information Management System (SIMS) data base. Particularly noteworthy was the high quality of technical support provided for the staff's reytew of Emergency Operating Procedures- l l

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49 Thela .was evidence of improvement during the latter portion of the4 ALP period in the approach to the resolution of technical issues and responsiveness to NRC initiatives in the licensing area. This is in part due to recent organizational changes which have resulted in a closer relationship of the licensing and engineering groups. The overall staffing to support licen-sing activities is adequate and its effectiveness should be improved by the recent organizational changes. Recently a reduction has been evident in the number of caser of technical errors, lack of clarity, and incomplete information.

In summary, the licensee has exhibited strong management ,

involvement in several major licensing actions, but attention to more routine licensing actions has been inconsistent. The licensee has shown some improvement in the licensing area during the latter portion of the SALP period. The involvement of management in routine, as well as major licensing activities, is necessary. The continued strengthening of mid-level management and increased technical capability of licensing staff are necessary.

(2) Conclusion Rating: 2 l Trend: None Assigned I

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50 4.10 Trainin2L a.nd Quali fication Ef fectiveness (1) An'alysis Technical training and qualification effectiveness is being con-sidered as a separate functional area. The various aspects of this functional area were discussed and used as one evaluation criterion within the other functional areas. The respective inspection hours have been included in each one. Cons &quently, this discussion is a synopsis of those assessments. Training effectiveness has been measured primarily by the observed per-formance of licensee personnel and, to a lesser degree, ss a review of program adequacy. -

This area was rated as a Category 2 during the previous assess-ment period. The licensed operator training and requalification programs were found to be significantly improved. Assignment of knowledgeable staff had resulted in higher quality training materials, and more plant-oriented operator training. Mainten-ance, contractor and radistion protection personnel training were also adequate. Fire brigade and fire watch training had been significantly weak and contributed to poor personnel per-formance in the plant. Four of ten licensee training programs had received accreditation from the Institute of Nuclear Power Operations (INPO).

During this assessment period, inspectors routinely reviewed ongoing training activities and their effectiveness in assuring quality personnel performance. Two sets of reactor operator and senior reactor operator license examinations were administered.

An inspection to evaluate the adcquacy of the nonlicensed per-sonnel training program was also completed. Various other inspections reviewed training provided in the areas of emergency preparedness, radiation protection, security, maintenance, fire protection and modifications, l.icensed operator training effectiveness continued to improve throughout the period. Two sets of licensed operator examina-tions were administered to a total of two senior reactor opera-tors and fourteen reactor operators, with all candidates suc-cessfully completing the licensing process. Newly licensed operator familiarity with plant equipment and procedures was i considered a strength. Challenges facini, licensee management include completion of training for the large number of new, relatively inexperienced operators.- Site management is intent on assuring snat time spent by newly licensed operators in the control room during startup and initial operations, is used as effectively as possible to provide the maximum training benefit.

51 The*1natorial developed for operator training and submitted for NRC.ceview was generally good. However, for the first examina- I i

tion early in the assessment period, it was noted that some materials provided to the NRC did not reflect recent station '

modifications. This was because the modifications had recently i been completed and previous training had focused on the original systems. It was also noted during exams and by direct discuss- ;

ions with licensed operators, that training conducted on i recently implemented modifications, such as on the reactor water level and automatic depressurization systems, h3d not oeen fully effective. Operators were unf amiliar with the modifications, !

primarily because only on-watch training had been performed and [

because the training had been conducted prior to completion of f the modifications. Licensee management took prompt action to restructure the modifications training and committed to repeat 3 the training prior to plant restart. ;

The licensee completed installation of a plant specific simu- '

later during this assessment period, and used it extensively to enhance operator training, particularly in the area of emergency 1 operating procedures (EOP). The licensee implemented a compre- :

hensive E0P training program including a combination of simula-tor and classroom instruction. Licensee management assured the :

effectiveness of this training by performing pest-training evaluation of the operating crews on the simulator. The de-velopment of special criteria by which acceptable performance is t

! judged was a strong point of the E0P training program. Operator i performance weaknesses were identified by the licensee, and sup- !

plemental training was performed to resolve the problems. !

Licensee management also initiated a communications training

! program for operations personnel. This communications training l was implemented along with the E0P training and appeared to

! substantially improve operator performance.

3 Licensed operator performance during plant events such as a loss

of of fsite power, and an Unusual Event due to a fire in the machine shop generally demonstrated a good command of plant

equipment and procedures. However, some apparent weaknesses in

operator training were evident. For example, several opera-tional errors were made during reactor refueling despite inde-1 pendent verification requirements. On several occasions oper-j ators failed to properly perform routine surveillances, l

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52 ThT- 'nonlicen sed and contractor personnel training program appeared ef fective. The training staf f dedicated to this func-tion has been supplemented by the addition of contractors. The '

licensee initiated maintenance and radiological technician apprentice programs to assist in development of qualified lower level personnel. New training initiatives are in progress to sensitize management, workers and radiation protection personnel to the need to minimize all occupational exposure. For example, management traintag in ALARA for plant design changes and radia-tion awareness training for operations and maintenance personnel have been initiated. In addition, a Training Program Evaluation Committee was established to assure plant management involvement in ongoing development of nonlicensed training.

The licensee's program for fire brigade and fire watch training his been significantly improved. The station fire protection group and the licensee's training department have coordinated to expand the scope and enhance the quality of brigade training. A large core of qualified fire brigade members has been established.

Security force, emergency response and maintenance training appeared to be effective. No performance deficiencies directly attributable to training were identified in these areas during the period. INPO accredidation of all remaining training pro-gra'ms was received during the current assessment period, i

In summary, licensee management has been active in improving the ;

overall quality of the training program and has been responsive to NRC concerns. Licensed and nonlicensed training programs are effectively implemented. Of particular value is the use of the simulator, and other initiatives such as formal communications training and establishment of an apprentice program. Efforts ;

should be continued to strengthen operator training in the area of modifications and to ensure effective completion of training for newly licensed personnel.

1 (2) Conclusion Ratina: 2 Trend: None Assigned O

e

l 53 l

4.11 Assuranca of Quality -

r (1) Analysis During this assessment period, Assurance of Quality is being ,

considered as a separate functional area. Management involve-ment in assuring quality continues to be discussed and assessed as an evaluation criterion in each of the other SALP functional areas. The respective inspection hours are included in each one. Consequently, this discussion is a synopsis of the assess-ments relating te assurance of quality in other areas. Since this is an evalution of management's overall performance it conveys a broadce scope than simply Quality Assurance (QA) civpartment performance.

~

During the previous assessment period this functional area was ,

evaluated as a category 3. Licensee management had not been l effective in addressing recurring SALP concerns. Organization '

and staffing were considered weak. Licensee management correc-tive actions in response to Quality Assurance (QA) findings and NRC issues had not been timely or ,;omprehensive. QA department performance and engineeri,1g initiatives were considered a strength. '

Quality Assurance effectiveress has been assessed on a day-to-day basis. Three inspectioni focusing on the Quality Assurance i and Quality Control (QC) p*ograms were conducted during this period. In addition, the large number of management iaeetings held during the period provided an oppertunity for NRC manage-ment to assess licensee management's approach to resolution of '

issues.

l i During much of the period licensee senior management continued i to assess and correct organizational weaknesses through restruc-

turing and recruitment of experienced personnel, many from out-side sources. A new Senior Vice President assumed responsi- 1 bility for the nuclear organization at the be: iming of the period. In June, 1987 the Vice President-Nuclear Operations

resigned. That position remained vacant until January, 1988 when the Site 01 rector position was created and filled. Station management was reorganized several times, and significant

personnel changes were made~. Four individuals served as plant I manager during the fifteen month assessment period. In addition to modifying the line organization a tempora ry Planning and

i. Restart Group was created, working in parallel with the per-i manent plant staf f to provide outage planning oversight. This group 'was subsequently disbanded, incorporating its functions into the permanent organization. The Itcensee also replaced i

several mid-level managers- during this- assessment period in- 1

. ciuding the Operations Section Ma na'ge r , Maintenance Section l 1

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54 Manager, Radiological Section Manager and the Security Group Lerde r, In addition to changes in the line o*ganization several staf f assistant positions reporting to the Ser.ior Vice President were established to enhance senior management oversight of or-ganization progress. Although actions in this trea were imple-mented slowly, it was evident that senior licer.sa, management took a careful and deliberate approach to establishing the permanent organization and staff. Licensee management displayed the intent to fill open positions in the organization with the most highly qualified individuals available. This approach may have delayed sta f fing efforts and initially slowed licensee progress in areas such as maintenance and radiological controls.

Management policies and performance standards were strengthened and are clearly understood through mid-level management. How-ever, the new standards were not concurrently communicated or topted at the working level in some cases. As a result ex-

,ensive management involvement in routine activities is still required to assure acceptable performance.

A high level of management involvement and commitment was effec-tive in promoting improvement in several SALP functional areas which had previously been identified as significantly weak, This is particularly evident in the areas of fire protection and security where management acted to establish, staff and support expanded oversight groups. This strong ccmmitment is also evi-danced by the organization-wide increases in permanent staff, and the general reduction in reliance on contractors for augmen-L tation of line functions. One exception to this is in the area of maintenance where vacancies and reliance on contractors l continues. -

Licensee response to new NRC concerns raised during the period i was sometimes narrowly focused, and did not target resolution of .

root causes. For example, a high level of NRC management involvement was required to assure development of a comprehen-

! sive Power Ascension Test Program, and to resolve overtise con-4 trol deficiencies. Needed programmatic improvements in the area of maintenance were only implemented after prompting by the NRC.

This may reflect that available licensee resources were focused on areas of previously identified weak performance and on outage .

. completion schedules, In some instances the licensee's written '

] replies to NRC concerns have been vague, incomplete, and did not ,

a reflect the full extent of actions which had been taken at the '

acility, j a

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The*314ensee initiated several programs designed to upgrade per-sonnel and plant performance. The plant Emergency Operating Procedures (EOP) were upgraded, and extensive E0P and communica-tion training was conducted to enhance operator response capa-bilities during abnormal and emergency conditions. A fitness-for-duty program was also instituted and applied to all licensee and contractor personnel. In addition, implementation of the safety Enhancement Program and the station rhcontamination pro-gram improved the plant physical design and condition. The decontamination effort was particularly successful, resulting in increased accessability to plant areas and a general positive impact on personnel morale. ,

Licensee management took an active role in establishing long term plans to address identified weaknesss;. The Restart Plan, the Material Condition Improvement Action Plan (MCIAP), and the Radiological Action Plan (RAP) are examples. In th) case of the MCIAP a team of contractors was created to prostce ongoing independent assessment of the plan's effectiveness in improving plant material condition and maintenance practices. In the area of radiological improvements the licensee reinstituted the Independent Radiological Oversight Committee to provide senior management with feedback on RAP effectiveness. The licensee also implemented a self assessment process near the close of the period. This self assessment was intended to p ovide a struc-tured method by which licensee management could evaluate the '

progress made, and identify remaining weaknesses.

The licensee's Quality Assurance (QA) and Quality Control (QC) department continued to become more involved in station activ-ities. The onsite QA surveillance group was increased in size, and appeared to be actively involved in evaluating field activ-i ities. QA audit methodology was revised to enhance its effec-1 tiveness, and an aggressive audit schedule was established. The

! licensee made good use of technical experts during audits to supplement available departmental resources. QA department management tonk prompt action to focus attention on significant concerns. For example, a stop work order was issued in response to adverse trends and findings in the area of maintenance on environmentally qualified equipment. Corporate and site manage- n ment response to QA findings has also improved. Both the pro- '

gram controh and t, heir applicat;on were strengthened to ensure l timely response to QA identified deficiencies. Overdue response '

to these QA deficiencies are currently tracked as a performance indicator.

t

56 Throughout most of the assessment period, the Itcensee's corree-ttve action process was not always effective. A large number of pf5blem reporting devices exist, each with a unique origination, review and disposition process. This makes use of the coeree-tive action system cumbersome, and weakens accountability for followup and closecut. Lack of clear problem descriptions, and delays between origination and followup, hampers establishment of root cause and implementation of corrective actions. The licensee has reviewed the process and recommendations to facil- i itate improvements have been made. However, the recommendations were not implcmented during this period.

I In summary, licensee senior management has taken strong action -

to develop and staf f & viable station organization. High qual-ity personnel have been recruited to fill key management posit-ions. The reorganization and staffing process was not completed

, until late in the SALP period. As a result, progrets in some functional areas, and in forcinq management philosopy changes down to the worker and first line supervisor level has been hampered. The con'.inuing need for a high level of management J participation in routine activities occasionally prevents

}

managers from focesing on other needed program improvements. ,

i Overall, the licen'ee has been successfull in effecting signifi- !

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

(2) Conclusion Ratino: 2 Trend: None Assigned i

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, t 57 5.0 SUPPORTING OMA AND SU* ARIES 5.1 Investialtion and Allegations Review l l

Twenty allegations were received during this SALP period. Eleven of !

! the allegations were investigated and found either to be unsubstan-

tiated or to be substantiated but of no safety significance. Five ,

allegations were investigated and substantiated, however the licensee !

had either already instituted appropriate corrective actions or such f actions were promptly initiated 1:1 each case. Four allegations are :

currently under review. One of these four concerns the licensee's !

! program for control of overtime which is the subject of ongoing '

] reviews.

4 i One investigation was initiated during the assessme8t period as a j result of an allegation regarding a plant security vital area bar- .

rier. This investigation is continuing. .

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5.2 Escalated Enfo-coment Action 4

Confirmatory Action Letter (CAL 86-10) was issued in response to a l 9

series of operational events in April, 1986. CAL 86-10 requested I submittal of technical evaluations of these events and stated that '

NRC Regional Administrator approval would be required prior to j

! restart. The technica) issues identified in CAL 86-10 have been

, resolved. The CAL however was extended in August, 1986 and remains !

open pending resolution of broader management concerns identified in i the previous SALPs and subsequent inspection reports.

j Three violations were identified during the period for fatlure of the !

4 licensee to ensure the integrity of security vital area barriers. l

! These three violations have yet to be characterized by severity ,

) level, and are currently being considered for escalated enforcement

+

action. This action is pending conclusion of the 0! investigation i

) described in Section 5.1 absve. i An NRC Order issued in 1984 requiring the licensee to implement a

)} Radiation !aprovement Program was closed during the period based on

! the results of a special inspection and other program inspections

! which indicated that all terms of the Order had been saatsfactorily completed.

]

R_equest for Action Under 10 CFR 2.206 i

j On August 21, 1987, the Ofrector of the NRC Office of Nuclear Reactor Regulation signed an Interim Director's Decision in response to the July 15, 1986, 2.206 petition filed by Massachusetts $ttte Senator j William 8. Golden and others. The contentions raised in the petition i

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58 reg &rdi's a . containment ~ deficiencies and inadequacies in the radio-logical-emergency response plan were denied. A decision regarding the management deficiencies was deferred to a subsequent response.

Three of the petitioners filed 49 appeal in federal court on October 1, 1987.

On October 15, 1987, Massachusetts Attorney General James M. Shannon filed a 2.206 petition, on behalf of his office and Governor Michael S. Dukakis, requested an order to show cause why Pilgrim should not remain shutdown until a full adjudicator / hearing resolves the issues raised in the petition. The petition cites evidence of contL9uing managert al, Mark I containment, and emergency planning deficiencies. An interim NRC response was issued on May 27, 1988, just after the end of the SAlp period.

5.3 Manacement Conferences -

Periodic management conferences ano plant tours were conducted throughout the SALP period. NRC Commissioners toured the plant and met with licensee management on six occasions during the period. A total of nine senior management conferences were held onsite or at Region I. In addition to plant tours held in conjunction with onsite management conferences, senior NRC managees performed two plant

! inspections during the assessment period. NRC management partici-pated in four public meetings in the vicinity of the plant. Two of these public meetings were sponsored by the NRC and two by local comunities. Five meetings with state officials and legislative committees were attended by NRC managers. The NRC also testified before the United $tates Senate Labor and Human Resources Committee regarding Pilgrim at a public hearing held in Plymouth, MA in January, 1988. A chronological list of NRC management meetings and i plant tours conducted during the assessment period is contained in j Taole 5. In addition, a summary of licensing meetings has been j included in section 5.4(1).

l To coordinate the planning and execution of NRC activities and to !

assess the results of these activities a special Pilgrim Restart Assessment Panel was formed. The panel is composed of senior members 1 of the Region I and Headquarters staffs. This panel met bimonthly, with alternate meetings on site.

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59 5.4 Licensisi. Actions ,

y- ,

(1) NRR/ Licensing Meetings and Site Visits Date Subject ,

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May 21, 1987 Licensing Issues, Bethesda, MD August 4, 1987 Emergency Operating Procedure and I Direct Torus Vent September 24, 1987 Status of Pilgrim Restart / Schedule August 19-20, 1987 Multi-Plant Action Items !

August 24, 1987 Ongoing Fire Protection Reviews i December 10, 1987 Emergency Operatir.g Procedures Upgrade 4

January 14, 1988 Discussion in Bethesda, MD of the in- ,

I service test program development i '

j (2) Commission Briefinas !

! I Date Subject a February 12, 1987 Regional Administrators' Meeting ,

j (Pilgrim Included) :

1

] December 17, 1987 Briefing on Status of Operating Reac- i fuel facilities j tors and (Pilgrim !

l Included) !

f a :

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(3) Schtdular Extensions Granted Sub3ect Date i

Emergency Preparedness (EP) Exercise 12/09/87 Emergency Preparedness (EP) Exercise 05/11/88

, (4) Reliefs Granted 3

Subject Date ;

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! Inservice Inspection Reitef 03/26/87 (5) Exemptions Granted ,

. l Subject Date

Duplicate Yard Lighting 10/06/87 l

l 10 CFR 50 Appendix R-Operator Action 04/14/88 (6) License Amendments Issued Amendment No. Subject Date 98 New Design-Reactor 02/27/87 Control Rod Blades 99 Analog Trip system 03/03/87

. Surveillance Requirements

. 100 Maximum Average Planar 04/09/87 1 d

Linear Heat Generation Rate 101 Control Room Ventilation 06/23/87

! System i

102 Standby Liquid Control 08/05/87 i System 10 CFR 50.62 Rule 1

I 103 Administrative Changes 08/05/87 l per 10 CFR 50.4 l 104 Nuclear safety Review and ,8/25/87 f Audit Committee changes 105 Cycle 8, Core Reload 08/31/87 i

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(6) LGanse Amendments !ssued Aiendment No. Subject Date 106 Automatic Depressurization 09/04/87 System Tirer 107 Analog Trip System - 10/28/87 a Calibration Frequency i

108 Undervoltage Relay Require- 10/29/87 i ments ,

109 High Pressure Coolant 10/29/87

! Injection and Reactor j Core Isolation Cooling l

Requirements i

110 Red Block and Average 11/30/87

Power Range Monitors <

j Trip Functions 111 Low Pressure Coolant 11/30/87 Injection Requirements

! 112 Standby Gas Treatment 01/2C/88

& Control Room Air Filter Systems ,

l 113 Primary Containment 01/21/88 '

Isolation Values 10 CFA SO Appendix J Requirements l ;

1 j 114 Fire Protection - 03/08/88 l Appendix 4 to 10 CFR 50 i l Raquirements !

115 Security Requirements - 03/24/88 !

10 CFR 73.55 l

] 116 Modification of Reparting 05/10/88 4 Schedule Supplemental Dose l l Assessment & Meterological :

Summary .

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2 (7) Ot G r.Licensino Actions :

Action Date l t

Containment Leak Rate Monitor 02/19/87

.1 l 10 CFR 50 Appendix J Review 02/19/87 (Penetration X-21)

Generic letter 83-08, Mark I 02/27/87 1 Drywell Vacuum Breakers .

Recirculation Flow Anomaly 02/28/87 -

a Process Control Program (PCP) 03/03/88 i Review 1 Inservice Inspection Plan - 1986 03/16/87

) Refueling Outage Control Room ricor-Fire Seals 03/24/88 t

Smoke Seals - Conduit 03/24/88 Defects Westinghouse DC 04/13/88 i' Circuit Breakers Steam Binding - Pumps 04/15/88

?

Ptigrim SALP Activity 05/15/87 i

10 CFR 50 Appendix R Review 05/15/87 i

, NUREG-0737 Item !!.K.3.18 09/04/87 l ADS Actuation Study ;

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Offsite Ocse Calculation Manual 10/28/87 4 l

j Correct Performance of Operating 11/16/87 !

1 Activities i f i i Intergranular Stress Corrosion 11/25/47 l Cracking Augmented Inspection

] Program i Refueling Interlocks 12/17/87 I

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63 5.5 Licenset vent-E Reports (1) Ove7411 Evaluation Licensee Event Reports (LER) submitted during the period ade-l quately described all the major aspects of the event, including i all component or system failures that contributed to the event and the significant corrective actions taken or planned to pre-

' vent recurrence. The reports were thorough, detailed, generally well written and easy to understand. The narrative sections

typically included specific details of the event such as valve identification numbers, model numbers, number of operable redun-dant systems, the date of completion of repairs, etc., to pro-vide a good understanding of the event. The root cause of the event was clearly identified in most cases. Event information ,

was presented in an organized pattern with separate headings and

. specific information in each section that led to a clear under-standing of the event information. Previous similar occurrences were properly referenced in LERs as applicable.

The licensee updated two LERs during the reporting period. The updated LERs provided new information and the portion of the report that was revised was clearly denoted by a vertical line in the right hand margin, so the new information could be easily determined by the reactor.

However, in the past the licensee's threshold for reporting required monitoring. 4 LERs (87-021,87-022, 87-023, and 97-024) were submitted only after an audit by Region I. One of these LERs,87-021, was submitted 10 months af ter the event.

(2) Causal Analysis A review of the LERs indicates a number of problems, some recur-ring. In particular, loss of offsite power has been a continu-ing problem at Pilgrim. In addition. Pilgrim has experienced repetltive events associated with intdequate procedures; admin-1strative control problems assorteted with failure to conduct adequate reviews prior to maint.enance and required surveillances and inadequate guidance and cautions for technicians.

P 64 .

i Exemples of unclear procedures included LER-87-015 which de-scfTbes two events where RHR shutdown cooling was terminated by i spurious isolation. One isolation was attributed to a precedure i with inadequate instructions and cautions on installing jumpers; the other isolation was due to inadequate procedures which failed to describe the right number of jumpers. LER 87-016 i describes an unplanned actuation of primary and secondary con-tainment due to inadequate adv iistrative controls for the planned replacement of a relay coil, specifically lack of appro-priate precautions and guidance. Furthermore the event was !

compounded by supervisory error in researching drawings, wiring ,

4 arrangements and assigning maintenance priorities. ;

i Similarly, repeat problems can be illustrated by the following

two LERs. LER-87-018 described a f ailed coil in a -logic relay ,

which caused a Reactor Water Cleanup System isolation. The '

licensee conducted a technical evaluation of similar coils, identifying those requiring replacement. LER-88-005 describes an actuation of the Primary Containment Isolation Control System l 5

and Reactor Building Isolation Control System due to a failure a of a similar coil in another relay.

i j Our assessment of the 39 events in this reporting period ,

indicates

1 16 involved either administrative control deficiencies, inade- -

l Quate instructions, or inadequate procedures.

7 involved errors by non-licensed personnel.

1 As rnany as 8 may have involved design defects. ;

i -

As many as 19 may have been repeats of earlier or similar events {

j at Pilgrim. '

2 t j (Note: events may be assigned multiple causes) t

! In conclusion, the large number of events involving deficiencies in I 1

administrative controls, inadequate procedures and repeats of

earlier, similar events points tc the need for close monitoring of 4 the effectiveness of licensee management in these areas. !

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i TABLE 1 .

DiEULAR LISTING OF LERs BY FUNCTIONAL AREA 1 ;

j PILGRIM NUCLEAR Pow'ER STATION l l

i AREA CAUSE CODE I

j A B C D E X TOTAL. i

1. Plant Operations 1 -

1 - -

2 4 2 2 Radiological Controls - - - - - -

0

3. Maintenance and Modifications 4 -

1 7 6 1 19 j- 4 surveillance 4 - -

4 1 1 10 l 1 i

5. Fire Protection - - - - - -

0 ;

1

6. Ernergency Preparedness - - - - - -

0 !

7. Security and Safegeerds 1 - - - -

1 2

8. Engineering and -

4 - - - -

4 -

Technical Support L 1 >

l 9. Licensing Activities - - - - - -

0 n

j 10. Training and Qualification . - - - - - -

0 l i Effectiveness '

i l

11. Assurance of Quality - - - - - -

0 i

[

TOTAL 5 10 4 2 11 5 39 l

7 f

1 I Cause Codes: A - Personnel Error I L

8 - Design, Manufacturing Construction, or Installation Error C - External Cause l 0 - Defective Procedure -!

1 E - Component Failure !

X - Other I' l

j LERs Reviewed: 87-001-00 to 88-015-00 including 88-008 01 and 87-014 01 l I

l l

j!

i i 1 ,

i i !

1, 1 i

l !

i !

l l

(

) .

TABLE 2 1

INT >ECTION HOURS

SUMMARY

(02/01/87 - 05/15/88) [

! P!LGRIM NUCLEAR POWER STtTION ,

I' Hours % of Time ,

1, Plant Operations 2178 22 I 2. Radiological Controls 1262 13

.j 3. Maintenance and Modifications 2347 24 ;

4 Surveillance 1386 14 t

i j 5. Fire Protection 493 5 ;

1 6. Emergency Preparedness 176 2 !

l ;

j 7. Security and Safegurrds 641 7

) 6. Engineering ano 1215 13 .

] Technical Support !

I i

9. Licensing Activities -

l i 10, Training and Qualification - i

) Effectiveness

11. Assurance of Quality ,

l 1

j Totals 9698 I

Hours expended in facility license activities and operator license [

! activities are not included with direct inspection effort statist.ics. l t

i " Hours empended in the areas of Training and Assurance of Quality are !

I included in the et %er functional areas, l Inspection Reports included: 50-293/87-06 to 50-293/84-22 l '

l 1

l j

1 1

)

l

-i' 8

'_. TABLE 3

.- i

! ENFORCEMENT ,$f MARY (02/01/87 - 05/15/88) '

4

! PflGRIM NUCLEAR POWER STATION I

A. Number and Severity Level of Violations r

i 4 Severity t.evel ! 0 i i Severity Level !! 0 !

j Severity Level !!! 0 !

Severity t.evel 1V 21 .

Severity Level V 2 Deviation 0 l

l i Total 26' ;

B. Violations Vs. Function Area 1

j Severity Levels l

I 1 Functional Areas I !! I!! IV V Dev Total- ;

i 1. Plant Operations - - -

2 - -

2 -

l 2. Radiological Controls - - -

8 - -

8 Maintenance and Modification - - - 6 - -

6 ;

i 3.

i 4 Surveillance

1 1 i

! 5. Fire Protection - - -

1 1 !

! 6. Emergency Preparedness - - -

1 1 i j 7. Security Safeguards - - - - - - 3*

$ 8. Engineering and - - -

1 1 :

1 Technical $upport

9. Licensing Activities - - - - - - 0 l l 10. Training and Qualification - - - - - -

0 l i Effectiveness !

! 11. Assurance of Quality - - -

1 2 -

3 l Totals 26' l J j *Three securl+.y violations are being considered for escalated enforcement ;

action and have not yet tien categorized for severity.

t l

l l

l

O TABLE 4 Pilgrim SALP History Assessment Period , ,

1/80- 9/80- 9/81- 7/82- 7/83- 10/84- 11/85- 2/87 Functional Area 12/80 8/8.1 6/82 6/93 9/84 10/85 1/87 5/88 Operations 2 3 5 2 2 3 2 2 Radiological .

Controls 3 2 2 2 3 3 3 3

, Surveillance 2 2 2 1 1 2 3 2 Maintenance 2 3 2 2 1 2 2 2 Emergency Planning 3 1 1 1 3 3 2 2 i

Fire Protection 2 2 3 1 2 -

3 2 Security 2 2 2 2 2 2 3 2 Engineering and Technic 11 Support - - - - - -

1 1 Licensing - -

2 1 1 1 2 2 Training ,

Effectiveness - - - - - -

2 2 !

Assurance of Quality /QA 3 3 - - - -

3 2 Outage Management 3 2 2 -

1 1 1 -

1 4

s

- - - , - , . . - . ,-- - - - - . - , . , -,-m._-_,,-,w-,y,.m-gg-.. ,-. ,~ w_.. ..,-,,-----------e-~~,,

pv

l I-- TABLE 5

?- .

MANAGEMENT MEETING AND PLANT TOUR

SUMMARY

DATE SPONSOR TOPIC 02/02/87 NRC Management meeting at Plymouth, MA to discuss the status of licensee improvement programs (IR 87-08) 02/03/87 Massachusetts NRC Region I Administrator and other Region I Secretary of managers met in Boston, MA with several Energy Commonwealth administrators to discuss NRC activities regarding Pilgrim 03/09/87 Massachusetts NRC Region I Administrator and other members of Legislature the staff appeared in Boston, MA before the Massachusetts Jo'.nt Committee on the Investigation and Study of the Pilgrim Station at Plymouth (IR 87-16) 03/10/87 NRC NRC Chairman Zech toured Pilgrim accomp..iied by the Regional Administrator and attended a licensee presentation (IR 87-16) 04/27/87

Massachusetts NRC Region I Administrator and other members of Legislature the staff appeared in Boston before the Mass-

. chusetts Joint Committee on the Investigation and Study of the Pilgrim Station in Plymouth '

(IR 87-18) 05/01/87 NRC Management meeting at NRC Region I to discuss a surveillance program violation and program weaknesses (IR 87-23) 05/07/87 NRC 1987 SALP management meeting at Plymouth, MA 05/22/87 NRC NRC Commissioner Carr toured the plant and ,

attended a licensee presentation l 05/27/87 Plymouth Four NRC Region I management representatives Board of participcted in a public meeting in Selectmen Plymouth, MA 1 06/24/87 NRC NRC Commissioner Asselstine toured the plant and attended a licensee presentation '

i

I

.* j Table 5 2 ,

l l

DATE SpCNSOR TOPIC 06/29/87 NRC Management meeting at NRC Region I to discues the outage status, program improvements and )

licensee preparations for restart (IR 87-28) 07/23/87 Commonwealth The NRC Section Chief, Licensing Project Manager of Mass, and Resident Inspectors for Pilgrim met onsite with representatives of the Commonwealth to discuss the NRC inspection process (IR 87-27) 09/09/87 NRC Enforcement conference at NRC Region I to discuss several security violations (IR 87-30) 09/24/87 NRC NRC Director of the Office of Nuclear Reactor.

Regulation, the Region I' Administrator and other senior NRC managers met with the licensee in Bethesda, MD to discuss licensee activities and restart readiness (NRR meeting transcript) 09/30/87 NRC Enforcement conference at NRC Region I to discuss several security violations (IR 87-30) 10/05/87 NRC NRC Commissioner Bernthal toured the plant and attenced a licensee presentation 10/08/87 Commonwealth NRC Region I Administrator and other senior NRC of Mass. managers me't at Region I with representatives of the Commonwealth of Mass, and two private ci',12 ens to answer questions regarding the NRC inspection process (IR 87-45) 10/29/87 Ouxbury Board Four NRC Region I and NRR management of Selectmen representatives participated in a public meeting :

sponsored by the Duxbury Board of Selectmen, Ouxbury Emergency Response Plan Committee and the Duxbury Citizens' Committee on Nuclear Matters in Duxbury, MA 12/08/87 NRC NRC Region I Administrator toured the plant and met briefly with licensee management to discuss tour observations (IO 87-57) 9 P

Table 5 3 OATE SEONSOR T0pIO 01/07/88 United NRC Director of the Office of Nuclear Reactor States Regulation and the Region I Administrator Senator appeared before the Senate Labor and Human Kennedy Resources Committee regarding Pilgrim. The public hearing was held in Plymouth, Ma, 02/18/88 NRC NRC Region I and NRR managers conducted a public meeting in Plymouth, MA to solicit public comments on the licensee's Restart Plan 02/24/88 NRC Management meeting at NRC Region I to discuss the licensee's self assessment process to be used for determining restart readiness (IR 88-10) 03/10/88 NRC The NRC Director of the Office of NRR and the Region I Administrator toured the plant and interviewed licensee staff regarding the design basis for the direct torus vent modification (IR 88-07) 04/08/88 NRC Management meeting at NRC Region I to discuss the licensee's proposed power ascension test program '.4eeting Minutes 88-43) 04/22/88 NRC NRC Coiom). iner Carr toured the plant and attended a . ...see presentation (IR 88-12) 05/06/88 NRC NRC Commissioner Rogers toured the plant and attended a licensee presentation (IR 88-19) 05/11/88 NRC NRC Region I and NRR managers conducted a public meeting in Plymouth, MA to provide i responses to concents and concerns on the l Itcensee's Restart Plin raised during the '

2/18/88 public meeting (Meeting transcript) ,

l i

l 1 j 7* UNITED STATES l NUCLEAR REGULATORY COMMISSION l f*$

l y REG l0Nl

.gg! i l u srs ALLENDALE MoAD j

! t,, KING or enuss:A. PENNSYLVANIA M0e .

SEP 071988 Docket No. 50-293 l Boston Edison Company ATTN: Mr. Ralph G. Bird Senior Vice President - Nuclear i Pilgrim Nuclear Power Station RF0 #1, Rocky Hill Road Plymouth, Massachusetts 02360 Gentlemen: -

)

Subject:

NRC Region I Inspection Report No. 50-293/88-21, Integrated 1

- Assessment Team Inspection .

This refers to the Integrated Assessment Team Inspection (IATI) led by ;

Mr. A. Randy Blough of this office on August 8-24, 1988, at the Pilgrits Nuclear Power Station (PNPS), Plymouth, Massachusetts. The results of the inspection are documented in the enclosed inspection report. At the conclusion of .the inspection, an exit interview was held with you and members of your i staff to discuss the scope and the findings of the inspection. '

The purpose of this inspection was to perform an independent, .in-depth assess- 1 ment of the readiness of management controls, programs, and personriel to sup- !

port safe restart and operation of the facility. The inspection Teau performed !

an integrated evaluation of various functional areas, including operations, maintenance, surveillance, radiation protection, security, training, fire pro- l tection, and assurance of quality. Within these areas, the inspection con-sisted of interviews with personnel, observations of plant activities, and ,

selective examinations of procedures, records, and documents by the inspectors. l Within the scope of its review, the Team concluded with high confidence that Boston Edison Company (BEco) management controls, programs, and personnel are generally ready and performing at a level to support safe startup and operation of the facility. Those technical items requiring resolution or completion prior to restart are being addressed and tracked by BECo. The Team identified l a relatively small number of additional items for which actions or evaluations l

appear appropriate; BEco has made commitments in those areas, as detailed in ,

section 2.4 of the enclosed report. As a result of this inspection, the l Team concluded that there are currently no fundamental flaws in BEco's management structure, management performance, programs, or program l implementation that would inhibit its ability to assure reactor or public safety during plant operation.

l l

l

@ M NyVl$5 Og

Boston Edison Company 2 SEP 071988 If your understanding of any item detailed in Section 2.4 of the enclosed report differs from that stated, please contact Mr. Blough or me promptly. The NRC will review the status of these issues prior to any restart of PNPS.

The results of this inspection will be considered during the NRC staff's deliberations as it reaches its decision regarding a PNPS restart recommenda-tion to the NRC Commission.

No written reply to this letter is required. Your cooperation with us is appreciated.

Sincerely,

?YI ue . o Deputy Director Division of Reactor Projects

Enclosure:

NRC Region I Inspection Report No. 50-293/88-21 cc w/ encl:

K. Highfill, Station Director R. Anderson, Plant Manager J. Keyes, Licensing Division Manager E. Robinson, Nuclear Information Manager R. Swanson, Nuclear Engineering Department Manager The Honorable Edward J. Markey The Honorable Edward P. Kirby The Honorable Peter V. Forman i B. McIntyre, Chairman, Department of Public Utilities I Chairman, Plymouth Board of Selectmen Chairman, Duxbury Board of Selectmen Plymouth Civil Defense Director P. Agnes, Assistant Secretary of Public Safety, Commonwealth of Massachusetts S. Pollard, Massachusetts Secretary of Energy Resources R. Shimshak, MASSPIRG Public Occument Room (POR)

Local Public Document Room (LPOR) l Nuclear Safety Information Center (NSIC) l NRC Resident Inspector CommonwealthofMassachusetts(2) '

P. Chan, Commonwealth of Massachusetts S. Sholly, MHB Technical Associates l

+

. U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket No.: 50-293 Report No.: 50-293/88-21 Licensee: Boston Edison Company Pilgrim Nuclear Power Station RFD #1, Rocky Hill Road Plymouth, Massachusetts 02360 Facility: Pi1 grim Nuclear Power Station location: Plymouth, Massachusetts Dates of Inspection: August 8-24, 1988 Inspectors: (See Attachment E)

Approved By: n At.,m T. es m -h_w 97!S $

A.' Randy Slougn, Chief i '0a tit Reactor Projects Section No. 33 -

Division of Reactor Projects Inspection Sum ary:

Areas Insoected: Integrated Assessment Team Inspection to assess the degree of reaciness of licensee management controls, programs, and personnel to sup-port safe restart and operation of the plant. The scope of the inspection is further detailed in Section 2.2.

f<e sul ts:

The team concluded that licensee management controls, programs, and personnel are generally ready and performing at a level to support safe startup and operation of the facility. Results are further summarized in Sections 1.0 (Executive Summary) and 2.3 (Summary of Sindings).

1 l

l i

l TABLE OF CONTENTS I Page ,

1 A C R0 NY M S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv i 1

1.0 EXECUTIVE

SUMMARY

......................................... 1

2.0 INTRODUCTION

.............................................. 2 2.1 Background........................................... 2 2.2 Scope of Inspection.................................. 3 2.3 S u mm a ry o f I AT I R e s u l t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.3.1 Ov e r a l l S umm a ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.3.2 Summary of Results by Functional Areas. . .. . 5 2.4 Licensee Commitments................................. 9 2.4.1 Procedure Validation and Training.......... 9 2.4.2 Identifying Procedure Changes Requiring Training................................. 9 2.4.3 Tempora ry Modi fication s. . . . . . . . . . . . . . . . . . . . 9 2.4.4 Operations Review Committee................ 10 2.4.5 Maintenance................................ 10 l 2.4.6 3urveillance............................... 10 '

2.4.7 Formalizing Personnel Qualification Reviews.................................. 11 2.4.8 Mission, Organization and Policy Manual.... 11 2.4.9 Familiarizing Workers with Expected Radiological Conditions.................. 11 2.4.10 Control Room Human Factors................. 11 ;

3.0 D ETA I LS O F I N S P ECT I ON . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 3.1 Management 0versight................................. 12 3.1.1 Scope of Review............................ 12 3.1.2 Organization............................... 12 3.1.3 Staffing................................... 15 3.1.4 Qualifications............................. 16 3.1.5 Administrative Policy and Procedures....... 18 3.1.6 Communications and Observations............ 19 3.1.7 Conclusions................................ 20 i 1 1

_ _ _ . _ _ . _ _ _ . , _ . . . _ _ _ _ _ _ _ . , _ _ _ - - ~ . . _ . _ . _ _ . _ , , _ , _ . _ . . , , . . . _ _ _ _. _ _ _____ -. _ _

l l

l t

l l TableofContents(Continued) ,

- Page 3.2 Operations........................................... 21 3.2.1 Scope of Review............................ 21 3.2.2 Conduct of Operations...................... 21 3.2.3 Shift Staffing and Overtime Control s. . .. . . . 23 3.2.4 Procedure Validation....................... 24 3.2.5 Temporary Modi fication Control s. . . . . . . . . . . . 25 3.2.6 Required Reading Books..................... 28 3.2.7 Logs....................................... 29 3.2.8 Timely Update of Lifted Lead / Jumper Log.... 29 3.2.9 Tagouts and Operator Aids.................. 31 3.2.10 Plant Tours and System Walkdowns........... 31 3.2.11 Conclusions................................ 34 3.3 Maintenance.......................................... 36 3.3.1 Scope of Review............................ 36 3.3.2 Observations and Findi ng s . . . . . . . . . . . . . . . . . . 36 3.3.3 Conclusions................................ 50 3.4 Surveillance Testing and Calibration Control......... 52 3.4.1 Scope of Rev1ew............................ 52 3.4.2 Observations and Findings. . . . . . . . . . . . . . . . . . 52 3.4.3 Conclusions................................ 61 3.5 Radiation Protection................................. 63 3.5.1 Scope of Review............................ 63 3.5.2 Observations and Fi ndi ng s. . . . . . . . . . . . . . . . . . 63 3.5.3 Conclusions................................ 73 3.6 security and Safeguards.............................. 75

^

3.6.1 Scope of Review............................ 75 3.6.2 Observations and Findings. . . . . . . . . . . . . . . . . . 75 3.6.3 Conclusions................................ 8P.

11

Table of Contents (Continued) gagg 3.7 Training............................................. 83 3.7.1 Scope of Review............................ 83 3.7.2 -Observations and Findings.................. 83 3.7.3 Conclusions................................ 88 3.8 Fire Protection...................................... 89 3.8.1 Scope of Review............................ 89 3.8.2 Observations and Findings.................. 89 3.8.3 Conclusions................................ 90 3.9 Engineering Support.................................. 91 .

3.9.1 Scope of Review............................ 91 3.9.2 Observations and Findings.................. 91 3.9.3 Conclusions................................ 93 3.10 Safety As ses sment/Quali ty Veri fication. . . . . . . . . . . . . . . 94 3.10.1 Scope of Review....................,....... 94 3.10.2 Nuclear Safety Review and Audit Committee.. 94 3.10.3 Operations Review Committee................ 97 3.10.4 Quality Assurance Audit and Surveillance Programs................................. 102 3.10.5 Corrective Action Process and Programs..... 104 3.10.6 Conclusions................................ 115 4.0 UNRESOLVED ITEMS.......................................... 117 5.0 MAN AG EM EN T M E ET I N G S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 118 Appendix A - Entrance Interview Attendees...................... A-1 Appendix B - Exit Interview Attendees.......................... B-1 Appendix C - Persons Contacted.............'.................... C-1 Appendix 0 - Documents Reviewed................................ 0-1

. Appendix E - IATI Composition and Structure.................... E-1 Appendix F - Resumes........................................... F-1 Appendix G - September 1, 1988 Letter from NRC to Commonwealth of Massachusetts................................ -

G-1 Appendix H - September 6, 1988 Letter from Commonwealth of ,

Massachusetts to NRC............................. H-1 I 1

l l

l

ACRONYMS ALARA - As Low As Reasonably Achievable ANSI -

American National Standards Institute ASME - American Society for Hechanical Engineers BECo - Boston Edison Company BEQAM - Boston Edison Quai:ty Assurance Manual CAS -

Central Alarm Station CQI

- Commercial Quality Item CS -

Core Spray (System)

CST -

Condensate Storage Tank OC -

Direct Current DCROR -

Detailed Control Room Design Review DG -

Diesel Generator OR -

Deficiency Reports E0P -

Emergency Operating Procedures EO - Equipment Operator EPPI -

Electric Power Research Institute EQ - -

Environmental Qualification ESF -

Engineered Safety Feature .

ESR -

Engineering Service Request F&MR - Failure and Malfunction Reports FYI -

For Your Information ,

GET -

General Employee Training iv

Acronyms HP - Health Physics HPES -

Human Performance Evaluation System HSA -

Housekeeping Service Assistance IATI -

Integrated Assessment Team Inspection .

I&C -

Instrumentation and Control ICA -

Immediate Corrective Actions INPO -

Institute of Nuclear Power Operations IST -

In-Service Testing LCO -

Limiting Condition for Operations LL/J -

Lifted Lead / Jumper

LSFT -

Logic System Functional Test M&TE -

Measuring and Test Equipment MCAR -

Management Corrective Action Requests MCIAP -

Material Condition Improvement, Action Plan MC&AT -

Management Oversight and Assessment Team MOP -

Mission, Organization and Policy Manual MPC -

Maximum Permitted Concentration MR -

Maintenance Request MSC -

Maintenance Summary and Control MSTP -

Master Surveillance Tracking Program MWP -

Maintenance Work Plan NCR -

Nonconformance Report NED -

Nuclear Engineering Department NOP -

Nuclear Organization Procedures v

.\

1 l

Acronyms NRC - Nuclear Regulatory Commission NRR - Office of Nuclea'r Reactor Regulation NSRAC - Nuclear Safety Review and Audit Committee NWE - Nuclear Watch Engineer OMG -

Outage Management Group ORC -

Operations Review Committee P&ID -

Piping and Instrument Diagram PCAQ

- Potential Condition Advarse to Quality PDC Plant Design Change PI -

Pressure Indicator PM . -

Preventive Maintenance PNPS -

Pilgrim Nuclear Power Station ,

PCIS - Primary Containment Isolation System QA0

- Quality Assurance Department RCIC - Reactor Core Isolation Cooling RETS - Radiological Er:vironmental Technical Specifications RHR - Residual Heat Removal (System)

RO - Reactor Operator ROR -

Radiological Occurrence Report RP -

Radiation Protection RWP -

Radiation Work Permits l SAA -

Simulated Automatic Actuation SAS -

Secondary Alarm Station l

I v1

Acronyms SBLC -

Standby Liquid Control (System)

SDR -

Security Deficiency Reports SE -

Safety Evaluations SEG -

Systems Engineering Group SES -

Senior Executive Service SFR -

Supplier Findar Reports SGI -

Safeguards Information ,

SI -

Station Instruction SRO -

Senior Reactor Operator STA -

Shift Technical Advisor SVP-N -

Senior Vice President - Nuclear TM -

Temporary Modification TS -

Technical Specifications VP-NE -

Vice President - Nuclear Engineering WIP -

Wo 'kforce Information Program WPRT Work Prioritization Review Team i

i

)

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vii

i l

1.0 EXECUTIVE

SUMMARY

In response to NRC concerns over longstanding issues regarding the manage-ment effectiveness of the Boston Edison Company (BEco) in the operation of the Pilgrim facility, the licensee agreed to maintain the plant in a shutdown condition following operational events which occurred on April 11-12, 1986. The NRC confirmed the' licensee's agreement in Con-firmatory Action Letter (CAL) 86-10. The CAL, as supplemented in an August 27, 1986 letter, also confirmed that the licensee would develop a comprehensive plan to address those concerns and parform an in-depth self-assessment of .the effectiveness of that Plan. On June 25, 1988, the licensee reported it had completed these activities to the extent that an NRC review was appropriate. In order to assess the status and results of -

BEco's corrective actions, the NRC performed an independent review of the effectiveness of the licensee's management controls, programs and person-nel during an Integrated Assessment Team Inspection (IATI) conducted August 8-24, 1988.

The Team consisted of an SES-level manager, a Team leader, and members of the NRC Region I and Headquarters staff. The inspection team also included two observers representing and appointed by the Commonwealth of Massachusetts. These observers had access and input to all aspects of the inspection as provided by the established protocol. The areas reviewed during the inspection included operations, mai:tenance, surveillance, radiation protection, security, training, fire protection and assurance of quality. The Team reported directly to the Regional Administrator of Region I.

Overall, the Team concluded with high confidence that BEco management controls, programs, and personnel were generally ready and performing at a level to suoport safe startup and operation of the Pilgrim Nuclear Power ,

Station. Further, although the Team identified certain items which '

require licensee actions or evaluations, there were no fundamental flaws 1 found in the Itcensee's management structure, managaent performance, programs, or program implementation that would inhibit its ability to assure reactor or public safety during plant operation.

l 2

2.0 INTRODUCTION

This report detatis the findings, conclusions and observations of NRC's

Integrated Assessment Team Inspection conducted at the Pilgrim Nuclear Power Station (PNPS) on August 8-24, 1988. The results of this in: pec'. ion are to be considered during NRC staff's deliberations as it reaches its decision regarding a restart recommerdation to the NRC Commissioners.

I

2.1 Background

The NRC's 1985 Systematic Assessment of Licensee Performance (SALP) 1 found programmatic weaknesses in several functional areas at the Pilgrim Nuclear Power Station and noted that, nistorically, the licensee could not sustain pe-formance improvements once achieved. A special NRC Region I diagnostic team inspection was subsequently per-formed in February and March 1986 to evaluate facility performance.

This inspection, which included monitoring plant activities on a 24-hour basis, confirmed the 1985 SALP and concluded that poor management control and incomplete staffing contributed to the poor perforzance.

Following several operational events, Boston Edison Company (BEco) shutdown PNPS on April 11-12, 1986. The NRC subsequently issued a Confirmatory Action Letter (CAL) on April 12, 1986, and a supplement on August 27, 1986, maintaining the plant shutdown and requiring that the Itcensee obtain NRC approval prior to restart. The central issues in the CAL, as supplemented, involved the effectiveness of licensee management of the facility and technical concerns.

SALP evaluations continued during the shutdown, and improvements were noted during the 1986 SALP period, although the rate of change was slow. Several factors inhibited progress, including continued man-agement changes and prolonged staffing vacancies. Good performance was noted in four areas: emergency planning, outage management, corporate engineering support and licensed operator training. The success in these areas reflected a high leyv1 of corporate management attention and substantial resource commitments. The licensee also had made significant plant hardkare improvements, including Mark I Containment performance enhancements.

Consistent with the CAL and its supplement, BEco has addressed the specific technical issues, developed and submitted the Pilgrim i Nuclear Power Station Restart Plan and performed a detailed self-assessment of readiness for restart. The NRC staff reviews of these items are complete. The licensee has also submitted a Power Ascen-sten Test Program, for which the staff review is ongoing.

4

'I

, , . ~ , - - . , , _ _ - , _m. ..--

l .

3 .

NRC subsequently completed a SALP evaluation for Pilgrim covering the period February 1,1987 to May 15,1988. It concluded that 'icensee management initiatives are generally successful in correc* .ag staff-ing, organization, and material deficiencies. Programma ic perform-ance improvements were evident in areas previously id stified as having significant weakness and in areas that the licent ie's self-assessment process identified as warranting further nanagement attention.

The NRC Confirmatory Action Letter (CAL) of April 1986 required the NRC to perform a review to assess BEco's corrective actions. In con-junction with an augmented inspection program and as part of a con-

tinuing effort to monitor BECo's program improvements, tha NRC i planned this IATI to independently measure the effectiveness and readiness of the licensee's management controls, programs and per-sonnel to support s4fe restart of the facility. A Restart Readiness -

Assessment Report that includes staff assessment results will be 4

prepared by the NRC in conjunction with development of an NRC staff l recommendation regarding plant restart.

2.2 Scene of Insoection i The IAT inspection was performed to provide an independent, in-depth i assessment of the degree of readiness of licensee management con-trols, pro' grams, and personnel to support safe restart and operation i of the Pilgrim Nuclear pow-- Station (PNpS). The inspection covered i a variety of functional areas, including operations, maintenance, surveillance, radiation protection, security, training, fire protec-tien, and assurance of quality. Particular emphasis was placed on management effectiveness and on the status of the Itcensee's recent program improvements in maintenance. The inspection consisted of I interviews with licensee personnel, plant tours, observations of 1

plant activities, and selective examinations of procedures, records, and documents. The Team also directly observed ongoing plant activities on all shifts frca August 10-13, 1988.

i i The 15-member Team consisted of a senior manager, inspection team

leader, five shift inspectors, and several specialist inspectors from j both NRC Region I and the NRC Office of Nuclear Reactor Regulation

(NRR). Two representatives from the Commonwealth of Massachusetts were aise on the Team as observers throughout the inspection. The

, team roster and member resumes are attached as Appendices E and F to this report.

l Onsite IATI preparation, which included site familiarization and plant tours, was conducted during the week of July 18, 1984. The Team j was onsite full-time from August 8 through 19, 1984. Some IATI mem-J bers were on site during the documentation piriod of August 20-24,

! 1988. Attendees at the entrance and exit interviews are listed in

Appendices A and 8, respectively. Senior licensee managers contacted j during the course of the inspection are listed in Appendix C. Many j other persons at all levels of the organization were also contacted

or interviewed.

i

4 The licensee was not presented with any written material by the NRC during this inspection. The licensee indicated the.t no proprietary material was presented for review during this inspection.

2.3 Summary of IATI Results 2.3.1 Overall Summary The Team concluded, with high confidence, that licensee management controls, programs, and personnel are generally ready and performing at a level to support safe startup and '

operation of the facility. Technical items requiring reso '

lution or completion prior to restart are being addressed and tracked by the licensee. The Team identified a rela-tively small number of additional items for which licensee actions' or evaluations appear appropriate; during the inspection, the Itcensee made acceptable commitments in these areas. There are currently no ft.ndamenta! flaws in the licensee's management structure, managennt perform-ance, programs, or program implementation that would inhibit its ability to assure reactor or public safety dur-ing plant operation.

The inspection generally confirmed the results of the SAlp report for February 1,1987 through May 15, 1988, as well as validating the general SAlp conclusion that performance was improving at the end of the SAlp period. Further, licensee performance appeared to be consistent or improvirig in all functional areas examincd during the IAT!, with the current level of achievement for overall safety performance equal to or better than that described in the SALp. For maintenance and radiation protection, the performance is noticeably improved.

The inspection generally confirmed the effectiveness of various licensee self-improvement programs and of the Itcensee's self-assessment process. The Team identified relatively few issues that had not been previously identi-fied by the licensee. In the interest of continually

. improving its self-assessment process, the licensee should i evaluate those cases where NRC either identified new issues or assigned a higher sense of priority than identified by the licensee.

The inspection confirmed that important organization and attitudir.41 changes had occurred since 1986. Of particular concern to NRC during the diagnostic inspection in 1986 were several factors inhibiting progress. These included:

1

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l 1

1) Incomplete staffing, especially of operators and key ;

mid-level supervisory personnel; '

2) The prevailing licensee view tnat improvements to date had corrected the problems identified;

3) Reluctance by licensee management to acknowledge some problems identified by NRC; and

4) Dependence on third parties to identify problems rather than implementing an effective licensee program to identify weaknesses. ,

The Team found these inhibitors to be substan*.ially re- l moved, and noted that a significt.ntly improved nuclear safety ethic exists at management levels and is developing successfully at the worker level. I Based on a review of the management structure, staffing, goals, policies and administrative controls, the Team con-cluded that the licensee has an acceptable organization and administrative process, with adequate management and tech-nical resources to assure that the plant can be operated in a safe and reliabit manner during normal and abnormal con-ditions. Further, this performance-based inspection pro-vided an integrated look at overall management effective-ness in ensuring high standards of nuclear safety. The overall conclusions of this inspection confirm facility management effectiveness, especially its ability to perform self-assessment functions, to improve performance, and to raise nuclear safety awareness and attitudes throughout the i organization.

2.3.2 Summary of Results by Functional Area i l

Within each functional area, conclusions were reached '

including the identification of various strengths and weak- l nesses. These are summarized below. The basis for these

items, as well as the many significant observations made by

the Team, are explained in Section 3 of this report.

2.3.2.1 Operations Strenaths Experienced and knowledgeable senior licen-sed operators j

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6 Effective shift turnover Excellent plant housekeeping Weakness

-- Lack of thoroughness and attention to detail in validation and training of Emergency Operating satellite procedures 2.3.2.2 Fire Protection -

Strenoths

-- Effective program staffing and supervision Effective prioritization, control, and tracking of fire protection equipment matatenance Weaknesses

, , None 2.3.2.3 Maintenance Strengths Good organization and structure Thorough program procedures Clear maintenance section internal communi-cations and interactions

- -- Good control and support of field activities Weaknesses -

-- Examples of poor implementation of planning for post-work testing

-- Poorly controlled storage of Q-listed iteas ,

at two locations outside the warehouse ;

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7 2.3.2.4 Radiological Controls ,

Strengths Effective use of a maintenance health physics (HP) advisor

-- A well-organized training program Weaknesses

-- Examples of a lack of continuity and pro-

, ficiency in certain highly specialized jobs because of frequent technician rotation Indications of weak vertical comunications within the HP group 2.3.2.5 Surveill ance Strenoth .

Management comitment to improve an already

~

, satisfactory program Weakness

-- Incomplete resolution of proper frequancy I and scheduling of once-per-refueling outage i

tests 2.3.2.6 Security S tre na t.h, ,

Overall management attention Weaknesses *

. None 2.3.2.7 Training Stronaths

-- Excellent management support for operator i training programs I

1 8

-- Strong relations between the plant opera-tiens anci training departments Waakness

-- Lack of a defined process to assure timely

. identification and implementation of train-ing needs resulting from newly approved or revised procedures 2.3.2.8 Engineering Support

-- Not directly reviewed. No specific strengths or weaknesses identified 2.3.2.9 Safety Assessment / Quality Verification Strengths

-- Nuclear Safety Review and Audit Comittee (NSRAC) composition, plant tour- program, frequency and location of meetings, open forum, and focus of reviews 1

- -- Attitude and performance toward identifying problems -

Effective, meaningful communicstions between i the Quality Assurance and plant Operations '

departments Weaknessy

-- Operations. Review Committee does not perform an effective independent group review of

. operations and Technical Specification violatio,ns

-- Multiplicity of corrective action programs i without centralized tracking

-- Poor tracking of Potential Condition Adverse to Quality (PCAQ) reports i

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9 2.3.2.10 Management Oversight Strencths Well-defined organization, incorporating appropriate span-of-control and including

- highly qualified, experienced managers in key positions

-- Well-defined and well-conceived corporate goals Weaknesses None 2.4 Licensee Commitments During the IAT inspection, the licensee made certain commitments to the inspection Team. These commitments relate to licensee corrective or enhancement actions 31anned in response to Team findings or con-cerns. These commitments, summarized below, are discussed in more detail in subsequent sections of this report, shown in parentheses.

Commit.ments were confirmed during the exit interview. The status of these issues will be reviewed by the NRC prior to any restart of the plant (88-21-01).

2.4.1 Procedure Validation and Tr'aining (Section 3.2.4)

By restart, the licensee will confirm effective implementa-tion of all of f-normal and E0P satellite procedures that have been substantively revised during this outage.

2.4.2 Identifying Procedure Changes Requiring Training (Section 3.7.2.1)

Before restart, the licensee will implement a process to allow more timely identification of new procedures and procedure changes which require training.

2.4.3 Temporary Modifications (Section 3.2.5)

By restart, the licensee will either prepare'a justifica-tion for operation for each active temporary modification 4 or apply the temporary modification extension request process to all temporary modifications, including those with outstanding engineering service requests.

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l 10 2.4.4 Operations Review Committee (ORC) (Section 3.10.3)

Prior to restart, in order to strengthen its operational focus, the ORC will begin to: (1) review plant incident critiques; (2) review licensee event reports before their

- issuance to NRC; (3) review failure and malfunction reports on a regular basis; and, (4) provide for a monthly presen-tation and discussion of plant operations as a specific agenda item.

2.4.5 Maintenance

-- Before restart, the licensee will re-evaluate all priority 3 maintenance requests to ensure that they have been properly scheduled. (Section 3.3.2.4)

-- The licensee will complete training addressing the revised post-work testing program by September 9,1988.

(Section 3.3.2.6)

-- The .Itcensee will resolve the inability to align valves in the Torus Water Makeup Line in accordance with current operating procedures and drawings prior I to. restart. (Section 3.3.2.4)

-- The licensee will issue a procedure to provide appro-priate controls for the "Q" oil storage facility by September 7, 1988, and perform an eva$uation of the possible addition of "non-Q" oil to "Q" equipment and its potential effect. (Section 3.3.2.3)

-- The licensee will complete, before restart, the dis-position of a Potential Condition Adverse to Quality (PCAQ) identifying the need for a review of Commercial Quality Ites procurement documents for consistency with approved engineering specifications. (Section

, 3.3.2.3) .

2.4.6 Surveillance

-- Before restart, the licensee will review and evaluate the once-per-refueling-outage surveillance tests to determine if they, should be repeated to enhance the assurance of system operability and document the basis i for its decision. (Section3.4.2.1)

-- Before restart, the licensee will provide the tech-nical basis for the current test frequency of the Reactor Core Isolation Cooling (RCIC) System logic System Functional Test (LSFT) on the initiation logic.

(Section 3.4.2.2)

_ , - - . _ _ _ - , _ _ _ _ - , . _ . _ - , - . _ .-,7- -. -, - - , _ , -

11 2.4.7 Formalfting persennel Qualification Reviews -

The licensee wf11 verify before restart the qualifications of all personnel within the organization required to meet ANS! 18.1-1971; and, prior to completion of the power ascension program, will have a formalt:ed process in place to ensure future auditability. (Section 3.1.4) 2.4.8 Mission, Organization and Policy (MOP) Manual The licensee will issue M0p policy instructions prior to.

restart and the organizational position descriptions prior to completion of power ascension. (Section3.1.5) 2.4.9 Familiarizing Workers with Expected Radiological Conditions -

Before restart, the licensee will provide training and briefings to the appropriate plabt staff regarding expected .

radiological conditions r'esul*,ing from plant operation anc hydrogen addition. (Section 3.5.2.14) 2.4.10 Control Room Human Factors The licensee will evaluate control roca human factors dur-ing the power ascension program and include an update r'egarding the schedule and scope of "Paint, Label and Tape" items in ,their report to the NRC at the completion of the Power Ascension Program. (Section 3.9.2) 1

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

12 3.0 DETAILS OF INSPICTION The folkowing sections contain the scope of inspection, the detailed findings, and the conclusions for each functional area the Team assessed.

3.1 Management Oversight 3.1.1 Scope of Review The IATI assessed the organizational structure currently in place at the Pilgrim Nuclear Power Station (PHPS). The assessment also included the administrative processes in place to control and coordinate the activities and actions affecting safe and reliable operation of the PNPS. Other areas inspected included the adequacy of staffing, qualif t-cations of personnel, and mechanisms to enhance and promote stability .in the organization's technical and managerial staff.

Several management' meetings were observed by Team members to assess the interactions of managers and the effective-ness of the policies and procedures bei.1g implemented.

Continual observations were made and shared by Team members to augment findings and conclusions in the effectiveness of

, the organization, management controls, and cormunications throughout the functional areas. The Team members inter-viewed a cross-section of personnel at all levels of the organization to determine if the overall attitude toward performance of safety-related activities has improved.

These observations and interviews also orovided the Team with insight into the worker perception of management policies, involvement, effcctiveness and its resulting impact on safety.

3.1.2 Organization The NRC staff noted in the most recent SALP report N'o .

50-293/87-99 for February 1, 1987 through May 15, 1988, that an organizational transition had taken place. The

,. report also noted that several temporary changes including !

numerous changes in personnel, had been made to strengthen i planning, control and performance at PNPS. Many of these

temporary changes were incorporated into a permanent reor-ganization in February 1988. The Itcensee con..inued to re-fine the new organziation and control process through

I 13 July 1988, notified NRC of the reers nization, and subse-quently requested an amendment in August 1988 to the admin- l 1strative section of its Technical Specifications (TS) to l reflect the new cesanization, the notification and request were in accordance with the PNPS TS, Section 6.2.C.

"Changes to the Organt:ation," which allows organizational )

changes to be implemented without prior NRC approval, pro-vided notification is made and a subsequent license amend-ment request is submitted for NRC review and approval.

The organization assessed during this inspection is the subject of the licensee's amendment request dated August 1, 1988, and approved by the Senior Vice President -

Nuclear (SVP-N) on August 4, 1988. The discussion that follows does not describe in complete detail the entire organization, focusing instead on that portion that affects the functional areas being evaluated during this inspection (See Figure 1). The results of this inspection will be considered in NRO's review of the licensee's amendment request. ,

l I

The Team noted that the licensee has incorporated a balance between the number of management levels from the first-line supervisors ter the SVP-N and the span of control for each !

functional unit. The SVP-N has the Station Director, Vice i President - Nuclear Engineering (VP-NE), Emergency Pre- !

paredness Department manager and Quality Assurance Depart- i

. ment manager reporting directly to him. The two department I managers report directly to the SVp-N to assure that inde- l pendence and appropriate management attention are provided based on their functional requirements and responsibilities.

The committee charged with offsite safety, the Nuclear Safety Review and Audit Committee (NSRAC), reports directly to the SVP-H. The committee for onsite safety review, the Operations Review Committeo (ORC), reports directly to the ,

Station Director. The reporting of the offsite committee I to the SVP-N and the onsite committee to the Station I

Director are appropriate based on their responsibilities.

Details on these standing comuni ttee s , their functional requirements, responsibilities and accountabilities, are contained in Section 3.10 of this report.

The VP-NE has two department-level managers reporting directly to him. These departments are the Nuclear Engi- 1 neering Department and the Management Services Department -

both of which are located offsite. The Station 01 rector has four department-level managers reporting directly to nim: the Plant Support Department, Plant Manager (Opera-tions), Planning and Cutage Department, and the Nuclear Training Decartment, l

l

Chatroian, Board of Strectors sad C(0 I

5entor Vice President -

helear .

hciear Safety Review and Audit Cossnittee Director - Special Projects I 1 Quality Assurance burgency Planalog Station Director '

vice PrestJeet - Depertoest flanager Departuent Manager b clear Engleeering --

Plant Department Planalog 1 hclear haagement Operatleas Review Outage helear Eagleoerlag Ceausittee (Plant Manager)

Separtment stanager u services Department .

Departaent h aager ,

me.,er leuclear Trataing Plant Suppe.-t '

- Department Departs eat Manager Plaat Operattens H*"*9 I 5 '

Settlem h aager figure 1. 80510M [Dl53f4 COMPANY - PILCRitt ORCANIIAT!0li l

- --- _-- _ _ _ _ _ . _ __. _ ' ~ - - -_ _ _ _ _ _ _ _ _ _

15 i

The senine manager of the functional creas is at the departwo. level, which is then subdivided into section i levels aitd division levels. The first41tne supervisors, in ;

some cases senior supervisors, report to the division '

sanagers.

The station organization, now under a Station Directer who has no direct corporate (i.e., off-site) responsibilities, !

represents a substantial change from previous crganiza-tions. The current structure ws2 instituted to strengthec ,

management attention to plant activities. The narrowing of ,

the span of direct cone.rol und responsibility of the Plant :

i Manager allows a more focused managecent and control of operational activities, which should result in the enharv ,

ment cl safe and reliable operation. TP dep a r+ - u reporting to the VP-NE hav'd b6en restructur for , a even distribution of responsibilities.

The Team concteded that the current organitational struc~ i ture provides for an appropriate distribution (span) of responsibilities and accountabilities for the activities i

' being performed by the functional units within it. The depth (number) of managers in the functional areas shoula ,

contribute to improved performancfr and organizational stability by providing managers with increased opportun- i ities to participate in professional technical and manage- !

I ment development. programs and by increasing the framework '

for career grow 3h.

The Team also :encluded that the redistribution of func- I tional responsibilities aM increased depth in management l provides the framework necessary to enhance stability and i support safe and reliable operatior at PNPS, The evidence . i for these changes thus far has been management's effective- ]

ness in creating a much-improved nuclear safety ethic and in impreving the functional areas described in the subse-quent sections of this report, 3.1.3 Staffing The most recut $ ALP Report (No. 50a293/87-99) indicated that the allocated staffing levels were significantly higher than in the past. The Nuclear Organizatten is cur- l rently authorized a staffing lovel of 985. Approximately 90% of the authorized posi* ions are filled, of whi 6 86%

are licensee personnel; the remaining 4% comprise ceatract personnel. Licensee personnel fill all key positions frcm Section Mr.nat,e rs and above, with less than 15f. of the ;

remaining managers and first-line supervisor mothions !

filled by contre,cto rs or licensee oersonnel in acting !

capacities. !

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l 16 Increased staffing in all levels of the Radiological and Maintenance Sections are examples of how the licensee has provided the necessary management attention and resources to areas that need them. The increased staffing, specif-ically at th$ craft and technician level, appears suffic-isnt to allow for a planned and controlled preventive main-tenance program that should result in overall safety en-hancement. The increased staffing levels also allow for training on a routine schedule.

The Team ceayNded that the authorized staffing has been filled to a hvel acceptable for the licensee to perform all the necessary functions for all plant crnditions,

'. including operations. This finding is reinforced by the

.' evidence of improvements in the functional areas described in the subsequent portions of this report.

3.1.4 Qualifications The PNPS TS, Section 6.3, "Facility Staff Qualifications,"

requires that PNPS personnel meet the requirements of the American National Standards Institute (ANSI) N18.1-1971, ;

"Selection and Training of Personnel for Nuclear Power Plants." The TS also requires that the Radiation P;-otec- l tion Manager shall meet or exceed the qualifications of Regulatory Guide 1.8, "Qualification and Training for Personnel at Nuclear Power Plants, September 1975. <

The Team audited resumes and position descriptions of key managers and other selected personnel throughout the organ- l l

ization. Their educational and experience backgrounds were compared with the requirements delineated in ANSI N18.1-1971, with special attention on the management experience of key personnel. No deficiencies were identified relating i to the qualification requirements of the ANSI standard, t More significantly, the Team noted the staffing of key management positions with personnel having extensive and successful management experience.

During its review, the Team found that some resumes needed updating, and that no formal , detailed instructions or guidarce in establishing qualifications were availat e. The ,

Team reviewed a Quality Assurance Department (QAD) audit I l report of the organization's administrative controls which l was conducted June 22 through July 22, 1988 and which 4

resulted in similar findings. The report, At4tt Report l 88-23 "Administrative Controls," dated August 18, 1988, 1 l

17 indicated that personnel qualifications were audited by the QAD to determinc compliance with the ANSI N18.1 require-ments for the organizational positions held. No defici-encies were identified as the result of the QA0 audit. The report did, however, provide a recommendation consistent with the NRC inspector s finding. Specifically, Recommen- 1 dation No. 88-25-03, notes the need to update resumes, '

develop guidelines and procedures for documenting qualifi-cation status, and maintain retrievable files.

The licensee has committed to the Team to reverify the

. qualifications of all personnel within the organization to i confirm they comply with ANSI N18.1-1971 prior to restart :

and to have a process in place prior to completion of the ;

Power Ascension Program to ensure future auditability of personnel qualifications.

Within the scope of the NRC review, the Team deter-mined that the licensee's personnel are generally well cualified for the positions held within the organi:ation.

The licensee's commitment to reverification of all per-sonnel qualifications prior to restart will provide addi-tional assurance of full compliance relatino to personnel ~

qualifications.

The results of the IAll effort in assessing the adequacy of the staffing and qualifications of the PNPS organization is consistent with the overall facility evaluation in the most recent sal.P report (No. 50-293/87-99). It noted the addt-tion of management personnel who lack extensive commercial nuclear power plant operating experience. However, as noted above, recent changes have resulted in the addition i of personnel in key management positions with extensive and successful management experience, much of which is in ,

nuclear areas. Also, many mid-level management positions are held by individuals who have extensive Pilgrim NPS (or other boiling water reactor) experience. The Team con-cluded that the combination of commercial nuclear power plant operating experience in the organization with the increased management capability provides the qualifications riecessary to support safe and reliable operation at PNPS.

In the event of a restart authorization, licensee safety performance will be closely monitored by the NRC during the Power Ascension Program.

f 18 1

3.1.5

Administrative Policy and Procedures The licensee has a variety of procedures to provide policy, control and coordination of organization activities. Cor-parate policy is provided in the form of company Bulletins maintained in a Boston Edison Company Organizational -

Manual. The manual includes information about the corpor- l ate organization, its policy statements, corporate instruc- ,

tions, and committees which affect the entire company, !

including the Nuclear Organization. The corporate level ,

policy specifically affecting the Nuclear Organization is contained in. a Mission, Organization and Policy (M0P) manual.

The Nuclear Organization Procedures (NOPs) provide guidance l for the control and coordination of the Nuclear Organiza-tion. They include administrative procedures affecting the i entire organization, as well as procedures affecting func- !

tional portions of the organization. Each department also has , procedures in place specifically for its functional areas. The Team reviewed several NOPs to assure that the guidance provided was current, reflected the organization .

in place, and addressed coordinating activities within the ;

organization. The Team also reviewed department-level procedures to assure they included the current organiza- ,

tion, goals, department function, position descriptions, ;

qualifications required, responsibilities, and accounta-bilities.

The Team concluded that the procedures are, for the most part, current. They adequately identify corporate policy, ,

organization, coordination, functional requirements, l responsibilities, accountabilities, and . qualifications necessary for the control and coordination of actions i within the organization.

Thw Mission, Organization and Policy Manual (MOP) is not fully up to date; however, and is currently being revised to accurately reflect current policy and to include all the position descriptions within the organization. The licen-see has identified additional refinements in the organiza-tional positir.,n descriptions to assure consistency and to provide accurate definitions of responsibilities necessary to assure accountability. The licensee was previously aware of this and has been working to finalize the updates.

The licensee committed to issue the revised MOP which I

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19 8

includes updated policy prior to restart and to complete the organizational position description refinements before the end of the Power Ascension Program. This commitment is acceptable, based on the status of the other procedures previously discussed which assure adequate administrative controls. ,

3.1.6 Communications and Observations Corporate policy for the Nuclear Organization in the HOP manual includes, among its goals, the need to strive to i raise standards of performance, for dedication to protec-ting the environment and public, and for rigorous adherence to procedures. The Team, through its obse'rvations and interviews, noted a positive change in the attitude toward nuclear safety throughout PNPS. This change is evident in improved performance of safety-relattd activities. These improvements are indicated in the most recent SALP Report (No. 50-293/87-99), and progress in the other functional

areas is addressed in this inspection report. The Team also noted during interviews that the corporate goal of adherence to procedures has been conveyed to all levels of the organi: ation. These observations attest to manage-ment's effectiveness in communicating corporate goals and management's oversight in assuring that the goals are being pursued.

The Team noted that the licensee established several mech-anisms to assure adequate communications within the organ-

, ization. Meetings at ali levels of the organization are held on a routine basis. Plant meetings are held every morning to discuss plant status and to coordinate daily activities. Several of these meetings were observed by the Team to assess the interaction of the managers and the i resulting effectiveness. 'The Team concluded that the meet-

ings were effective and that safety-related activities are being planned, scheduled, and prioritized in accordance with their safety significance and plant status. These and 2 other observations by the Team indicate that teamwork at the site is evident. There are programs in place, such as the Workforce Information Program (WIP), For Your Informa-i tion (FYI), and Management Oversight and Assessment Team (MC&AT) to enhance management involvement, overall communi-cations, and management visibility in the plant.

I 4

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20 The Itcensee has also established a set of performance indicators to track performance issues, restart issues, ,

plant condition reports, and activity status. These per-formance indicators are used as a management tool to seasure the effectiveness and results of established programs.

The Team concluded, based on its evaluation of programs in place, that communications throughout the organization have improved, that teamwork is evident, and that corporate goals are being conveyed to all levels of the organization.

3.1.7 Conclusions The Team concluded that the licensee has an acceptable or-gant:ation and administrative process in ;ilace with ade-quate management and technical resources to assure that pnp 5 can operate in a safe and reliable manner during normal and abnonal conditions. This conclusion is based on the details discussed above, trie perfomance-based i inspection in the functional areas covered by the IATI, the '

overall consistency in the findings of ti.is inspection with the most recent SALP (No. 50-293/87-99), and the plan f6r a structured and controlled power ascension pre; gram prict to operation.

This performance-b d inspection of a wide range of func-tier.a1 areas provic. an integrated look at overall. manage-ment effectiveness in ensuring high standards of nuclear safety. The overall conclusions of this inspection confirm i facility management effectiveness, especially with respect to management's ability to perform self-assessment func-tiens, to make performance improvements, and to raise nuclear safety awareness and attitudes within the

l organization.

0

= _ . -- -.

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21 3.2 ' Operations 3.2.1 Scope of Review The Team evaluated operations by observing how supervisors, operators and staff performed in the control room and throughout the plant. The Team observed plant operations during backshifts from August 10 through August 13, 1988, and ruviewed staffing levels to determine if they were sufficient to support restart with minimal reliance on overtime. The ability to implement recently written E0P satellite procedures and the quality of these procedures were evaluated through a field walkdown of a procedure.

The implementation of administrative controls for opera-tions was evaluated through inspections .of overtime con-trols, temporary modification controls, operator-required reading, logkeeping, tagouts, and operator aids. The line-up of two safety systems was independently verified by the Housekeepiag was observed during frequent

! inspectors.

plant tours.

3.2.2 Conduct of 0 : rations The Team observed control room operations on all shi f ts .

They were conducted in a formal manner, with effective 4 communications between the operators and

supervisors, including repeat backs for certain functions. There was no i unnecessary traffic in the control room. Supervisnrs briefed 01t f t personnel on significant functions before j they occurred. Prior to energizing the recirculating pump i heaters, which could have produced smal e in the drywell, the watch engineer thoroughly briefed to the reactor oper-ater, equipment operator, and fire brigade leader.

The watch engineers, shif t supervisors, and reactor opera-l tors were knowledgeable about plant condi'. tons and ongoing

! work in the plant. Shift turnover briefings were thorough i and were followed by control room panel walkdowns. Attend-

]. ance at these briefings was inconsistent in that not all watch engineers include other shift personnel, such as i health physics shift workers in the pre-shif t briefing.

Thir Team observed that the health physics shift workeFs l reca(ve separate briefings. The Team discussed this prac- l tice with plant management, which stat fd that it was their l

) intent to include non-operations shif t workers in the pre-i shift briefirg and that they would review its implementa-tion.

]

4 l

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22 f

Control room operators received good support from the shift technical advisors (STA), administrative assistants, and other departments. The STA's were used in developing fail-ure and malfunction reports (FMR), and in the initial i followup of an E0P satellite procedure issue. The admin-1strative assistants do much of the administrative paper-work and help to lessen traffic in the control room. There was very good support of operations from other departments in understanding and di :iding the proper course of action in response to FMR events.

The Team accompanied several non-licensed equipment oper-

. ators (E0's) on their tours. The E0's performed their plant tours in accordance with Procedure 2.1.16, "Nuclear I Power Operator Tour." Readings were taken and recorded, as required. The operators also checked for abnormal condi-tions, such as vibrations, noise, leakage, odors, and inadequate ventilation. The E0's commented that they now have more time to check general plant conditions on their rounds .because the rounds are assigned to two E0's per shift. Previously, only one E0 made the plant tour. The E0's showed good regard for radiological protection and ALARA practices. The operators were vary familiar with the plant; systems, and components, and were knowledgeat,.e about their duties and responsibilities. Tne performance by these operators demonstrated the effectiveness of the ,

non-licensed training program. .

Watch engineers or operating supervisors acccmpany E0's on plant tours at least once per week. Operations management, 4 including the chief operating engineer and operations manager, were observed touring the control room frequently and discussing plant status and evolutions with the watch j

engineer.

) The Team discussed

the licensee's use of NRC's NUREG-1275, j "Operating Experience Feedback Report-New Plants" and ver-

' ified that licenset management had reviewed NUREG-1275 recommendations for applicability. BEco had independently initiated a number of improvements related to NUREG-1275 recommendations before they revigwed the report. This action was considered by the Team as a positive example of j the quality of BEco self-improvement efforts. Some self-

identified improvement items include operator communica-tions training, seminars to improve attention to detail, i splitting tours and revising tour sheets to improve equip-ment operator performance, and doing dry run training on i

1

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i l

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l the power ascension and alternate safe shutdown evolutions. !

Some improvement items resulting from the NUREG review l

! include seeking a more positive method of performing on-shift instructions, repeating all logic system functional i tests, and performing a comprehensive review of inadvertent ;

emergency safety feature (ESF) actuations. The ESF actua-tion review has resulted in several corrective actions.

In summary, the Itcensee conducted operations in a profess-ional manner. Operators are knowledgeable about their duties and plant conditions and management keeps an active and effective oversight of operations.

3.2.3 Shift Staffing and Overtime Controls The licensee's Senior Reactor Operators (SRO) are very experienced and strengthen the operations organtaation.

To take advantage of this experience, an extra SRO will be assigned to each shift during the Power Ascension Test Program. Only 8 Reactor Operators (RO) have unrestricted licenses because the 14 newly licensed RO's are limited pending on watch training and reactivity manipulations dur-ing' the Power Ascension Program. Therefore, the licensee -

will initially staff a' four-shif t rotation during plant.

restart. At an appropriate point after restart, the licen-see will go to a six-shif t rotation of two SRO's and two R0's per shift. There are also su f ficient non-licensed equipment operators to staff dx shifts. STA's will work a l five-shift rotation for at least the next year. These staffing levels are considered adequate.

It should not be necessary to work operators in excess of the overtime guidelines of NRC Generic Letter 82-12. Senior plant management has been active in restricting overtime, procedure 1.3.6.7, "Use and Control of Overtime at pNPS,"

adopts NRC guidelines, provides procedural controls for l overtime hours, and requires advance approval of overtime.

The inspector reviewed Operations Department overtime records for the period of July 6,1988 to August 16, 1988.

. During this period, there were only three occasions when staff worked greater than 56 hours6.481481e-4 days 0.0156 hours 9.259259e-5 weeks 2.1308e-5 months in a 7-day period. Our-ing this period, there was one instance of overtime in excess of NRC guidelines. This occurred August 1 and 2 when a radwaste worker worked 28 hours3.240741e-4 days 0.00778 hours 4.62963e-5 weeks 1.0654e-5 months in a 48-hour period.

This worker had approval to work up to 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months that week but did not have approval to exceed the 48-hour guideline.

This worker is not a licensed operator and was not doing safety-related work. The licensee identified this incident and counseled the individual on overtime requirements.

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24 3.2.4 Procedure Validation .

The Team walked down Procedure 5.3.26, "Reactor Pressure Vessel Injection During Emergencies," with a non-licensed equipment operator who had been trained in the procedure.

The procedure involved connecting a fire water crosstie to

, the residual heat removal (RHR) system. Minor procedure a errors were found. A drain valve labeled 1-0R-122 in the field is referred to as 1-0R-121 and the fire water storage tank low level alarm is referred to as annunciator 8-7, whereas it is actually 0-3. Also, the procedure instructs l the operator to "connect the local flow meter" without '

specifying the instrument number. The procedure was I actually referring to a strainer differential pressure l indicator, instrument number 33-PIO-4610, The operator did not simulate connecting this instrument and when questioned ;

'! by the Team, he st:ted that the step referred to flow meter FI 4609 which was already connected. Of more significance {

i was confusion caused by step IV.S.2.b. which instructs the i operator to install jumpers to defeat LPCI initiation and '

. PCIS isolation signals and operate LPCI injection v.alves 28 and 29. The equipment operator requested the assistance of j the watch engineer and the STA. These watchstar.ders 4

initially felt the jumper was not needed. The jumper is l

not directly related to LPCI valves 28 and 29, but is .

l; needed to provide a flow path for a fire pump and to pre-pare for contingencies in the E0Ps.

Procedure 5.3.26 was one of eight new procedures written by contractors and validated by contractors. All eight of

these procedures are therefore suspect and will be revali-i dated by licensee operations staff before restart. All other ECP satellite procedures and other abnormal operating procedures substantially changed during this outage will

, also be revalidated before restart.

The Itcensee did not perform any QA audits or surveillances on the writing of procedures by contractors. However, the licensee has performed surveillances of the procedure 1 1 validation process used on procedures other than the ECP l satellite procedures. Surveillances #87-9.3-9 and #88-1.

1-56 found that half of the procedures being revised and

) implemented in April and May 1988 were not being validated.

1 As a result of this finding, procedure 1.3.4-4, "Procedure Validation," was issued August 15, 1988. I

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25 There were also some training aspects to this procedure issue. The equipment operator was trained on Rev. O of 5.3.26 which did not include the instruction to connect the local flow meter, whereas the inspector used Rev.1. Lican-sed operators were trained on the control room portion of the E0P satellite procedures and equipment operators were trained in the procedural steps outside the control room.

The problem with the jumpers occurred at the interface between these operators. Following the procedures revali-dation discussed above, the licensee will provide addi-tional training as needed.

During a NSRAC meeting conducted on August 2,1988, .the committee discussed an open concern on the validation and upgrade of plant procedures. NSRAC concluded that they were concerned that all of the routine operating procedures had not been validated by one of the validation processes.

Following the meeting, the committee forwarded a concern to the SVP-N concerning the operating procedures necessary for long-term operation of the plant. The plant staff is scheduled to respond to NSRAC .on September 14, 1988. The NRC will review this re".conse during a subsequent inspec-tien.

3.2.5 Temporary Modification Controls The Team observed that current logs show that about 15 tem-parary modifications (TMs) are in effect, some of which date back to 1983. Fifteen is not an unusual or unmanage-able number of TM's, and represents a significant reduction 1 from previous conditions.

The Team reviewed nine TM's initiated 1987.and prior years and noted (1) only three of the nine modifications affected safety-related systems; ~(2) licensee safety evaluations ,

(SE) were filed in the TM package, which demonstrated the j interim configurations created were acceptable; and, '

(3) licensee actions to address the TM's by conversion to I permanent modifications were apparently based on engineer-

. ing service requests and plant cesign changes referenced in

, the TM packages. Team review of the SE's on a sampling basis did not identify any inadequacies. Further, the Team noted that reduction of the TM backlog has been a licensee priority.

r 26 Plant Procedure 1.5.9, "Temporary Modifications," allows temporary modifications to be open for six months and pro-vides a mechanism for active TM's to be extended. However, this mechanism is typically not used. Procedure 1.5.9 does not require a review of the TM for extension of the expira-tion date if an engineering service request (ESR) for a permanent design change is in effect for the TM. Of seven TM's reviewed, six had ESR's and therefore did not have a current approved extension date. The inspector indicated that good engineering practice would dictate continuance of the periodic reviews for all TM's, and Itcensee management agreed. The licensee committed to either prepare a justi-fication for operation for every. TM that is still open prior to startup or.to revise the procedure to apply the TM extension request process to all TM's, including those with outstanding ESR's.

TM 84-7/ was selected for detailed followup review to assess the technical adequacy of the change on a temporary basis and to evaluate the extent and timeliness of licensee followup actions to either remove the temporary modifica-tion or. convert it to a permanent change to the facility.

The modification involved the replacement of an FCR-type relay in cubical 72-754 of the DC motor control center for j

the RCIC 1301-22 valve. The valve is in the suction path

. f.*om the condensate storage tank (CST), is normally open -

fo - RCIC standby and initial operation, and will cycle closed on low level in the CST. After failure of the existing FCR relay (an open circuit coil), an HFA-type relay was installed on December 17, 1984 and made elec-trically equivalent to the original circuit. An HFA was used because an FCR relay was not available onsite. The change did not affect the normal function of the valve.

Engineering Service Request (ESR)85-368, dated !

July 22, 1985, requested engineering to convert the change j to a permanent modification, with a completion date of i November 22, 1985. ESR response memorandum NED 86-1275, dated December 31, 1986, rejected the ESR request to make the change permanent because of two concerns involving the I need to keep the wiring in the 72-754 cubical consistent l with other DC motor control centers (MCC) and the assumed i differences in the inrush and coil holding currents between l In rejecting the request, engi-the two types of relays.

! neering found that the change was acceptable on a temporary j basis, but recommended restoration of the original design.

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27

- A Potential Condition Adverse to Quality (PCAQ) Report (No.

NED 86-110) was issued to assess the deviations. Further engineering evaluation was requested by ESR 88-080, dated January 27, 1988, with action requested by May 1, 1988.

Further engineering review determined that the change would be acceptable as a permanent modification, which was made '

by FRN 87-80-52 to PDC 87-80 dated June 14, 1988.

The plant design change (PDC) modified the drawing to per-manently document the change and addressed the seismic ade-quacy of the HFA relay installation. The RFA relay was not ,

certified to be environmentally qualified since the 1301-22 !

valve is not'on the EQ master list and environmental qual- i ification (EQ) is not required. The POC also addressed the

- adequacy of the inrush and ho) ding cu.' rent characteristics of the HFA relay. The second engineering review found the HFA current characteristics to be better than those of the FCR relay. -

The Team discussed the bases for the original and final

- engineering determinations via telephone on August 17, 1988 ,

with engineering (NED) . The Team noted that engineering initially rejected the proposed design change based on i information indicating larger power consumption by the HFA '

J relays, and based on a concern that, if replacement of the FCRs with HFAs became a general practice, a problem could .

1 result in the increase in DC loads. Those concerns were 1 not realized since the FCR failure was a random one, and the operating current characteristics of the HFAs are i better than initially assumed.

} Based on the above, the Team identified no technical con-l corns with the licensee's dispositioning of the adequacy of i the modification, a

The Team noted that licensee action on the original 1985 ESR was not timely in either the preparation of the l

original ESR or the followup actions by NED in response to i the site request. However, the actions to respond to ESR 88-80 and disposition the issue in 1988 were greatly

improved, i

The Team audited the six tag outs for TM 84-22 and found that MCC B25 was missing two TM tags. Since this is a non safety-related modification which is about to be withdrawn, I this was not considered by the Team to be of safety signif-

) icance. It does indicate; however, the need to period-j ically recheck TM tagouts.

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I An additional concern is that in the following example the ,

Itcensee performed a TM without implementing the formal

' review and approval process. During a tour of the reactor building on August 8,1988, the Team noted that reactor pressure boundary leak detection system monitors C-19A and ,

C-198 had their doors propped open, and each monitor had a large fan tied to the opening. Investigation identified ;

that no temporary modification had been processed to evaluate and authorize this alteration. The licensee .

i stated that elevated temperatures in the cabinets result in !

failure of the monitor electronics and have been a long- '

standing problem. Engineering response to Engineering .

Service Request (ESR)85-462 implemented a reduction in ,

system heat-tracing temperature. This alteration did not ,

resolve the problem, and on August 6,1988, the licensee initiated ESR 88-553 requesting further engineering review.

Monitors C-19A and C-19B are required to be operable by l

Technical Specifications during power operations so that l l

some short-term action and long-ters resolution are needed.

Since the monitors are not currently required to be oper-able, the licensee has de-energized them and removed the fans pending evaluation.

In summary, even though the licensee has been aggressive in 1 reducing the number of TM's, there have been some lapses in j their control of temporary modifications. This indicates a need for continued licensee management attention to this !

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3.2.6 Required Reading Books i The Team reviewed the "Required Reading" books in the con-

! trol room. The books consist of three large binders that

! contain procedure changes. They provide a method for j promptly updating operators on plant and procedure changes, j Each piece of information in the book had a sign-of f sheet to ensure that all operations personnel read the material.

The Team noted that information in the books dated back to April 1988 and many of the procedure changes had not been ll; signed off as read by all personnel. This appears to indi-

cate that the program is not being monitored routinely by operations management. Material remaining in the book for long periods defeats the purpose of providing timely infor-j nation on changes to the operators. Conversely, if the changes are not important to operations personnel, it may

]j not be necessary to put them in the books.

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The Team discussed these observations with the Plant Opera-tions Section Manager. Some improvement us noted later during the IAT inspection, as a result.

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29 3.2.7 Logs The Team reviewed the implementation of the Technical Spec-ification Limiting Condition for Operations (LCO) log, the Disabled Annunciator Alarm Log, and the operations super-visor log procedures. The LC0 log was implemented August 18, 1988, by Procedure $1-0P.0008, "Limiting Conditions for Operations Log," dated July 25,1988, and was being used on a trial basis from August 8 to August 18, 1988. The only LCO entered after the log was implemented, LCO A-88-002, was properly entered, tracked, E and cleared. Procedure SI-0P 008 is being revised to incorporate lessons learned in its initial implementation.

The Disabled Annunciators Alarm Leg is controlled by Pro-cedure 2.3.1, General Action Alarm Procedures, Item VII.

The inspector observed eight disabled annunciator tags on control room annunciators. All eight were properly legged.

However, only two of the eight annunciators had a mainten-ant.e request (MR) issued. The shift supervisor informed the Team that disabled annunciators without MRs occurred due to plant conditions and will be returned to service before startup. The Itcensee audits disabled annunciators monthly under preventive maintenance (FM) Procedure S.A.24 "Audit of Control Room Annunciators and Instruments," which should assure that these annunciators are re' turned to ser-vice before startup.

There was little activity in the control room during this inspection, but the Team did observe the follcwing items properly logged in the operations supervisor's log: LCO's, Failure and Malfunction Reports, a fire drill, and spent fuel pool temperatures while the fuel pool pu.Tps were out of service for maintenance. However, as discussed in Section 3.2.8 below, changes in jumpers or lif ted leads were not logged in the operations supervisor's log.

The Team concluded that log keeping practices are generally adequate.

3.2.8 Timely Update of Lifted Lead / Jumper Log During a review of the Lif ted Lead / Jumper (LL/J) procedure and program implementation on August 16, 1988, the Team identified that the log was not being maintained completely up-to-date. Eight entries in the LL/J log involved lifted leads or jumoers installed on July 14, 1988, to perform .-

sain station battery work and testing per Maintenance Work t plan (P P) 87-46-173. All eight recuests were associated with the same WP. All log entries showed the LL/J request

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was still active on August 16, 1958. The Team found tha't the batteries had been returned to normal and LUJ request was closed out on July 29,1988, and that Maintenance Request 87-46-173 was completed on August 1,1988, inclu-sive of the post-work testing. Step 5.3.1.5 of Station Precedure 1.5.9.1, "Lif ted Leads and Jumpers," states that the person performing the LUJ request is to notify the Watch Engineer when the system is returned to normal by removing the jumpers or landing the lifted leads. The Watch Engineer is responsible for updating the LUJ log.

The findings were referred to operations personnel on August 16, 1988 for followup.

Licensee followup review confirmed that the work had been ccmpleted and the log should have been updated. The log was updated to show the correct status on August 16, 1988.

In response to the inspector's findings, the licensee con-ducted an audit of the log. The Itcensee's audit identi-fied (1) two instances where the log had not been updat9d, and (2) that operations personnel were not making entries in the Operation's Supervisor log when LUJ log entries were made. These matters were referred to the Ocerations Section for followup and corrective action. CA follo'wup and trending will be covered by QA Surveillance Report 88-94-61. ,

The licensee reported that the cause of the discrepancy was the failure of maintenance personnel to inform operations that the jumpers and lifted leads were cleared when the systems were returned to normal. Inspector interviews with the Maintenance Supervis c responsible for MR 87-46-173 noted that he failed to d' ;uss the closecut action on the LUJ request as a result of a misunderstanding on the status of the work package closecut during. shift turnover with another maintenance supervisor.

Team review concluded the inaccurate LUJ log had minimal (

significance and no impact on safe plant operations for these cases. There was no loss of control of the physical plant configuration. Plant operators would have reviewed the LUJ log as a prerequisite to plant restoration and startup. This review would have identified the coen log entries and the completed closecut actions. Further, licensee followup to the discrepancies identi.fied by the Team were prompt and appropriate. Based on the above, and in recognition that the jumper and Itfted lead log is a new e tracking system, no further NRC action is warranted at this I

ties. This area will receive further review during subseovent routine NRC inspections.

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i 3.2.9 Tagouts and Operator Aids The Team reviewed the licensee's administrative controls d

for use of protective tagging at PNPS. The Team reviewed Procedure No. 1.4.5, "PNP 5 Tagging Procedure," Revision 23, 1 shich is to be implemented September 1,1984, and noted that this precedure was revised to address concerns with

tag controls identified during the licensee's self-assess-l s.ent. Specifically, the procedure limits the use of Nu-

! citar Watch Engineer (NWE) tags; prohibits the use of dan-I gpr (red) tags for identification purposes on lifted leads; 1 . and requires documented monthly reviews, including field verification, of NWE, Caution and Master Danger tags and l tagout sheets. The Team reviewed the NWE and cautton tag 1 . logs and indepe'ndently verified that several NWE, caution, J danger, and master danger tags were properly filled out, j properly hung, and positioned as required on the compon-

. ents. No discrepancies were identified. Based on this l review, the Team concluded t, hat the Itcensee's control of q protective tagging was adequate and properly implemented.

i The Team also reviewed the licensee's control of operator sids as estabitsbed by Procedure No. 1.3.34, "Conduct of Operaticas." An operator aid is information in the form of sketches, notes, graphs, instructions, or drawings used by personnel authorized to operate plant equipment. The Team reviewed the operations and chemistry operator aid log and I

determined that it was maintained in accordance with the

! procedure. The Team noted that periodic licensee reviews I

and vertf tcation of the need for and placement of operator aids were documented. The Team independently verified propet posting of selected operator aids, and no unauther-ited aids were identified during the Team's plant tours.

Based on this review, the Team concluded t. hat t.be Itcen-i see's control of operator' aids was adequate, a

3.2.10 Plant Tours and Systes Walkdowns 3.2.10.1 Miscel.laneous Tour Otservations l

The IATI Team made frequent plant tours. The overall material condition of rooms and equip-

! ment was excellent. Particularly notable was cleanliness, fresh paint, and obvious decontam-ination efforts to make major portions of plart and equipment accessible. Component labeling and tagging was very good.

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The Team observed activities in progress. Per-sons interviewed on tour (HP, security, opera-tions contractor) had experience in their

, positions and were knowledgeable about their work and duties. HPs were cognizant of work activ-ities in progress. Housekeeping controls were being maintained duri6g work in progress.

The Team reviewed the status of indicators and controls on selected local panels. Controls and i

indications were operable and no deficiencies i were noted. Operating procedures required to be posted at the local panels were available and i adequate, based on Team review. .

i i The Team observed loose cable tray covers includ-ing one that was laying on top of an in-place cover. The licensee reviewed this finding and !

documented the review and corrective ' actions in l an engineering "white paper." This review deter-mined that loose covers do not compremise the design but that covers laying on top of in place cable tray covees could be a seismic concern. ,

i The misplaced cover found by the Teas was deter- !

I mined to not be needed. The licensee surveyed cable trays throughout the process buildings and

found additional loose co ters but no more that were completely unfastened and laying on top of I other covers. Corrective actions completed in-clude refastening the loose covers, removing the l sisolaced cover, revising procedure 5!-3G.1010

"$ystems Group System Walkdown Inspection Guide-line," to use periodic walkdowns by the systes engineering division to identify seismic con- -

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i cerns, such as misplaced tray covers, and prepar- l

. ing FMR liu.88-200, which will be used to deter- -

mine how to keep future raintenance and modifica-tion work from creating loose or misplaced covers. The Team concluded that the licensee's j

. response to this issue was thorough and adequate.

] The Team considers this issue resolved.

3.2.10.2 Diesel Generator Walkdown A walkdown of the 'A' diesel generator (OG) was

! completed on August 15, 1988, to verify opera-bility and stancby readiness of the emergency I power supply, and to coserve the general condi-1 j-tions in the DG area. The valve checkoff lists of Procedure 2.2.8, "Standby AC Power System '

(Diesel Generators)." were used as acceptable !

I criteria to establish the proper system valve

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j 33 positions. The procedure checklists wre also j reviewed for adequacy against Orawings M219 and M224, and by comparison with the physical plant during a walkdown of the diesel skid and room.

, Proper valve lineup was verified for the DG fuel oil and air start systems. This review confirmed i

that the 'A' 00 was operable in the standby mode. ;

l Cleanliness and the geners.1 condition of equip- I sent and components in the diesel rooms wre :

J excellent. Valve and component identification i j (tags) and labeling wre very good and showed significant improvement in performance in com-parison to past reviews. Several minor discrep-1 ancies were noted, as follows: (1)identifica- ,

tion tags were missing on valves 104C and 118, l j and the tag was loose on valve 105C; (2) valve 118 was required to be locked in .the closed i position and a chain and padlock were provided I for this purpose; however, the chain was suffic- l 1ently loose that the Team would have been able

. to defeat the lock and thereby move the valve; i j 3) the inner fire door granting access to the i i {A' OG skid had worn and damaged gaskets along l the closing surface and the door latching mech- . .

! anisms (dogs) were misaligned with the pcsition l 1 indicators; (4) no permanent lighting was instal- i led in the ' A' and 'l' diesel day tank rooms -- !

lighting, if installed, would aid operator re- !

views during plans tours; and, (5) two isolation i valves for pressure switches 4555A and 4556A were i not labeled with an 10 tag in the plant and were i not identified on system drawings or procedures. l J The valves wre properly positioned. Addition- !

] , ally, proper valve position is demonstrated l indirectly during the monthly functional test of l j the diesel air start systes.,

. i I These discrepancies wre noted by the Nuclear i Plant Operator accompanying the Team and wre j discussed with the duty Watch Engineer. Actions f were taken to document and correct the discrep-j ancies, including the issuance of' Maintenance Request 48-61-83 for the fire door. Inspector i followup review on August 16, 1988 confirmed that

{ actions wre in progress and had been completed

< to correct the tag on valve 105C and to properly l 1ect valve 118. Licensee response to the Team's findings was appropriate and timely. No other inadetuacies - re noted. l i l 1

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3.2.10.3 Standby Liquid Control System Walkdown J The Team walked down the standby liquid control i ($BLC) system using the valve checklist in Pro-

' cedure No. 2.2.24 "Valve Lineup for Standby i Liquid Control $ystem," and piping and instrument ,

j diagram (P&ID) M-249. This review was performed to verify the adequacy of the procedure checklist ,

! and P&lD, evaluate the valve labeling, evaluate '

the contrn) of locked valves, verify the opera- ,

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bility of instrument and support systems, and 4

assess the overall material condition of the sys- ;

i tem and general cleanliness of the area. The i J Team noted that the checklist control of vent and :

1 drain capped connections differed from other !

safety system procedures, such as those for the

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residual heat removal (RHR) and core spray (CS)

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systems. For example, an outboard verit valve on ,

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the C5 checklist would be "locked, closed and i j capped." The $8LC procedure only checks "locked, I

closed." No deficiencies with capped connections j were noted, however. The Team also noted that

the vent valve for pressure indicator (PI) 1159 i was not on the valve checklist. The licensee i agreed to ' review these observations to determine

! if the procedure needed to be revised. No cther l deficiencies or concerns were noted.

Overall, the Team found the valve labeling, mate-l

rial condition, and general cleanliness to be

! excellent.

l 3.2.11 Conclusions j

The operations staff conducted their activities in a pro-

] fossional manner. Operators were knowledgeable about their j

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duties and about plant status. The depth of emperience and knowledge of senior Itcensed operators is a strength and will be a major asset during restart. Shift turnover

.l . briefings by individual operhters and for the shift are J thorough; however, non-operations shift worker:, do not routinely attend these briefings. Site management, involve-ment in operations was evident by their frequent presence in the control room. $hift staffing levels are adequate and plant housekeeping was excellent N

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35 A weakness was noted in the validation and/or training of E0P satellite procedures. The licensee's commitment to confirm effective implementation of E0P satellite and off-

normal procedures before restart is responsive to NRC con-

, cerns, Administrative controls and log-keeping practices are generally adequate, although required reading materials are not being reviewed by all personnel on a timely basis.

There are lapses in the licensee's control of temporary modificatters, particularly the absence of periodic reviews and scheduled completion dates for temporary modifications

covered by an engineering services request, .

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1 36 3.3 Maintenance 3.3.1 Scope of Review I

The licensee's maintenance program has undergone signifi-cant change during the past several months. Weaknesses had been identified during the SALP period ending May 15, 1988, and by Special NRC Maintenance Team Inspection 50-293/

88-17. During the present inspection, the licensee's main-tenance policies and program procedures were reviewed.

Maintenance activities were evaluated during the planning, implementation, postwork testing- and closecut stages.

Emphasis was placed on direct observation of ongoing work in the field. Interviews were conducted with personnel at '

each level within the maintenance department to determine .

their depth of understanding of program goals. The Team also assessed the size and significance of the licensee's maintenance backlog, and reviewed established licensee l performance indicators.

3.3.2 Observations and Findings 3.3.2.1 Management Policies and Goals l The Team reviewed the lic'ensee's Mission Organ-1:ation and Policy Manual, Nuclear Operations Procedures Manual, and Maintenance Section Manual. These dccuments describe the licensee's policy and performance goals for the maintenance

. program. The licensee has also established the .

Material Condition Improvement Action Plan (MCIAP). The MCIAP, which is described in the licensee's Restart Plan, is designed to achieve long-term improvement in the maintenance program.

In addition, maintenance performance indicators are being used by the licensee to evaluate the success of recent program changes and the allo-

ated maintenance staff has been increased sig-nificantly. Interviews with maintenance person-nel at various levels within the department indi-cate that the organization and management policies are generally well understood.

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37 3.3.2.2 Organization and Staffing The maintenance organization and staffing levels

' were reviewed. Interviews were conducted with :

division supervisort, and staff personnel to determine whether organizational relationships i

were well understeed. The current staffing status was evaluated, particularly in the super-visor, maintenance engineer, and planning post-tions, to determine whether staffing levels were adequate, responsibilities clearly defined, and i resources effectively used.

The maintcaance section consists of three pro-duction divisions (electrical, instrumentation i and control and mechanical), plus a planning division and an engineering group. All division

, manager positions and all first-line supervisor positions in the production divisions are filled I with licensee employees, except for two positions t in the equipment tool rocm, which are presently filled by contractors. Increased staffing at the .

t craft level in the production divisions has been l i . authorized. Instrumentation and Control (IM) l will increase from 22 to 30 positions; Electrical

! Maintenance will increase from 14 to 18 post-

) tions; and Mechanical Maintenance will increase from 27 to 33 positions. Staf fing of the plan-ning division has not beta ccapleted. Twelve contractor personnel are presently being used to cerform the plannin function, with assistance t from the Itcensee'gs outage maragement group.

This arrangszent is performing . acceptably, as ;

described in $ action 3.3.2.4 '

Team interviews with supervi sors and craft !

employees showed that per.sonnel clearly under-stand the new program and their area of respon-sibility. The interviews covered personnel with a wide range of experience in their positions, including those newly assigned. The Team noted; however, that the recently revised job descrip-tions for the section have not been disseminated to the staff. The Maintenance Manager stated that they would be issued in the near future.

, , _ . . . - . . . , , . _ . - - . - - , - - - - . - _ _ _ - - - .,-m- . - -m-,,-r m--

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i Two positions in the new maintenance section l organization, the Deputy Manager and the Radio-logical Advisor, are effectively being used. The l Radiological Advisor is a permanent staff post-

< tion and provides a focus for interface with the l Radiological Protection Group. Team observations ;

indicated that the Deputy Manager was effective t in scheduling and coordinating activities through his interface with other sections.

, The Team's review indicated that licensee staff- .

ing is ample to meet targeted production goals I without reliance on the use of excessive over- I time. While some variations occur, the percent

-l of overtime worked has been at or slightly above the operating goal of 20%, which equals a 48-hour work week. Work schedules for craft and super-visory personnel provide 1 day off in a 7-day period. The maintenance staff is working pri-marily en the day shif t, with night shif t cover- ,

age providtd for certain critical jobs in pro-gress. The licensee plans to provide around-l the-clock 8-hour shifts that will match the '

Operations Section rotating shift schedule, beginning with plant startup. Maintenance shift i coverage will continue through the power escala-I tien sequence and on a reduced Scale afterwards. <

Licensee staffing is sufficient to staff the shift schedule without reliance on excessive overtime.

j l New personnel ass' 9ed to the division manager

and production supervisor positions have adequate J prior experience in related assignments. The t

Team's observations of the first- and second-line supervisors in conducting their daily activities showed that the supervisory, oversight, and con-j trol functions were effectively performed. Based

, on these observatier,s, tha Team concluded that j, the newly hired supervitory staff does not have a i

negative impact on the quality of control over I maintenance activities.

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39 In summary, identified strengths in the present maintenance section organization include the use of the Deputy Manager and the Raciological l Advisor. The increase in supervisory positions i in the production divisions has been effective in l increasing oversight and control of work activ- i ities. While temporary staffing of the planning division with contractors is sufficient and pro- t i

vides for an effective planning function (as l measured by the quantity and quality cf mainten-ance packages produced), plans to staff these j* cositions with permanent licensee employees by ;

October 1988 should remain a management priority L to assure timely integration of the planning and l scheduling functions.

J Management has controlled overttne for the craft and supervisory pnattions, i Plans to provide for maintenance staffing during i and after restart on an S-hour rotating shif t ,

basis should provide continued effective over- I time control.

l l 3.3.2.3 Ccmmunications and Interfaces ,

Coseunicatic between the maintenance department <

. and other portions of the organization, particu- ;

larly operations and radiation protection, had previously been a weakness. The licenset has ;

taken successful steps towards improving c:mmunt-cation, both internal tc t.he maintenance depart- i ment and with other station groups.

The Team attended a variety of maintenance !

department status and turnover meetings. Based !

on observation of these meetings and interv14ws !

with maintenance personnel at each le rel of the i organization, the Team concluded that communica-tions internal to the maintenance staff are of- !

fective. Maintenance department managers were l cognizant of the status of activities and of l

. emerging problems. l The licensee has initiated several programs

~

l directly addressing the past weaknesses in I interdepartment communications. In an effort to taprove the interface with radiation protection and to raise worker sensitivity to health physics issues, t.he licensee created and staffed the maintenance Radiological Advisor position. Inter-views with a spectrum of individuals ir.dicated that this effort has had a positive impact on J

40 day-to-day working relationships and performance.

The licensee also formed the Work Prioritization Review Team (WPRT), composed of representatives ,

of various station departments. The WPRT pro-vides a forum for discussion of the relativo ,

t importance of each maintenance ites as it arises.

The WPRT has been effective in improving opera-i tion's department involvement with the a:ainten-ance process. The maintenance department is also involved in daily and weekly meetings intended to

! ensure coordination between station groups. Meet- .

ings attenced by the Team were generally effective.

. The need for continued efforts to improve comua-ications and interfaces were noted in some areas.

The licensee's Sto es Department practices are ~

- not always fully suppretive of specific 'ainten-ance department neen . For example, lubricating '

oil can only be withdrawn in bulk cuantities, l

such as a SS-gation drum. Typical maintenance

activities require use of only a fraction of this amount. Similar restrictions apply to materials

routinely used by the 14C, elect. 'ical, and mech-l anical maintenance divisions. This policy places the burden for control and storage of unused material on the individual requesting the with-I drawal. The Team noted that maintenance person-2 nel were routinely using a cabinet in the main- t tenance shop to store unused "Q" matert 1s. No

procedure existed to specify the appropriate con- 1 J trols for the storage area. The need for estab-i lishment of the storage cabinet had been dis-i cussed previously between the Quality Assurance Department (QAD) and maintenance. CAD believed '

t. hat the cabinet was not currently in use, while

. maintenance personnel believed that QAD had con-4 curred in its creation, demonstrating a lapse in inte rdepartment. communications. The Itcensee suesequently performed an inventory of the mate-i rials in the cabinet, and removed all non-Q and suspect satorials. Procedure 3.M.1-32, "Control

of 'Q' Hold Area " was subsequently issued to provide appropriate controls and surveillance of the cabinet.

l i

I 4

l 5

l

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

i

)

41 j

The Team also noted that partially used drums of both Q and non-Q lubricating oil and grease were being kept in a storage shed outside the process i

building. Several of the drums were not properly i sealed. No procedure addressing this storage '

area existed. Otscussiens with operations per-

, sonnel indicated that the difference between Q and non-Q drums of material was not clearly understood. Routine withdrawals and their equip-ment application were not recorded. In response.

i the licensee removed all non-Q ma,terials and l

committed to issue a procedure to establish ,

appropriate controls by September 7, 1988, in- l cluding provisions to ensure that the lubricants s

are traceable to their application in the field.

In addition, the Itcensee committed to evaluate '

the possible addition of non-Q oil to Q equipment ,

and its potential signtficance. ;

Ouring f'ollowup to this issue, the Team reviewed ;

Engineering Spectfication M-547, which document the procurement and receipt inspection require-ments for the purchase of lubricants as a Commer- '

cial Quality Item (COI). The Team noted that M-547 requires senpling and testing of each batch of material purchased as a CQ1. At the Team's ;

request, the licensee reviewed records and iden-tified two cases in which a CQI procurement order i had been issued which did not invoke this samp-ling requirement. The licensee subsequently issued a potential Condition Adverse to Quality '

(PCAQ) to initiate a review of CQIs issued for ;

consistency with approved engineering specifica- l tions. The Itcensee comitted to disposition -

this PCAQ prior to restart.

Overall communications betw'een the maintenance department and other groups within the organiza-tion are effective. However, the interface prob- ,

less discussed above, among the $ teres Depart- '

ment, QAD, and the Maintenance Department, indt-cate that continued attention is needed. ,

1

42 3.3.2.4 Maintenance Planning and Prioritization The licensee has estabitshed a Maintanance Plan- !

ning Division within the Maintenance Dyartment. '

The role of the Planning Division is clearly ,

delineated in approved maintenance procedures and ;

the licensee's Maintenance Section Manual. The Planning Division Manager posttten has been !

filled and the licensee is actively pursuing candidates for the eight allocated staff post-tions. When staffing efforts are complete, the division will consist of a work package olanning ;

group and a scheduling group. In the interim, j the licensee is utilizing twelve' contractor per- ,,

sonnel to perform the package planning function. l The licensee's Outage Management Group (OH3) is currently providing scheduling guidance. The l

licensee expects to complete the staffing effort

by October 1988. Team reviews indicate that the I present staff of contractors, in conjunction with CMG assistance, is functioning well.

4 i Implementation of the revised maintenance work process, p4rticularly the need 40 generate de- ,

tailed job-specific maintenance work plans (WP) I

. for each maintenance request (MR), has resulted in a heavy emphasis on the planning function.

The Team reviewed a large sample of completed j MWP's, and PM 's in the field. Interviews with craft personnel and first-line supervisors indi-cated that these individuals were knowledgeable about the new maintenance process requirements 4

and considered MWP's issued by Planning to be of

generally good quality. One weakness was noted

- in the area of post work testing specification, as discussed in Section 3.3.2.6.

The Team noted that the completion of job plan-j ning, and approval of the MWP are typically I

restraints to commencement of the activity. This results in the need to expedite the review pro-j cess, making scheduling difficult. It appears ,

that this is primarily attributable to the new- !

i l ness of both the program and the Planning staff.

) Other factors also contribute. For imample, the i

Itcensee's procedures currently do not provide a ,

! sinolified process for non-intent changes to the i

t l .

l

43 MWP after issuanee. MWP's re wire a complete re-review to incorporate minor changes. The lican-see stated that a revision to the program to include provisions for non-intant changes is planned for the future. The licensee's engineer-ing department is presently reviewing oach MR/MWP and approving the use of any replacement este-rials. This practice provides positive control of all materials, but delays issusnce of the MWP and is a significant drain on engineering resources. While these factors inhibit efficient planning, no instance of inadequate planning was identified.

Th1 licensee has created a WpRT to assist in the assignment of the proper priority to each MR.

The WPP.T meets daily and is composed of represen-tatives of various station groups, including maintenance, operations, outage management, con-struction management, and fire protection. It performs a multi-disciplined review of new main-tenance items to identify potential plant impact.

The IATI Team attended a WPRT meeting and ob- i served that discussions were properly focused and i prioiities were assigned appropriately.

The Team also inde. pendently reviewed outstanding maintenance requests for the RHR system and the electrical distribution system. This review focused on MR's not designated for completion before restart. The Team noted that MR 88-10-105 documented elsctrical ground and potential cable insulation damage in the circuit for pressure switch PS-1001-93A. This switch is environmen-tally qualifieb (EQ) and provides a safety-related interlock function for the automatic depressurization system. The MR had been sched- '

ult i for work af ter restart, leaving the switch EQ in an indeterminate st' ate. In response to the Team's question, the licensee rescheduled the MR for completion prior to restart.

44 The Team also no~ted that MR 38-10-26 documents that valve A0-8001 is currently open and cannot be closed using the hand switch. A0-8001 is installed in series with a check valve in the torus fill line. The check valve satisfies the primary containment isolation function for the

. line. While A0-8001 is not required for contain-

, ment isolation operability, it does serve as a redundant isolation valve immediately adjacent to the chsck valve. A0-8001 was originally designed to receive an automatic open signal on sensed low

, torus level. Because normal torus level is now maintained below the instrument low level sat-point, the valve continuously receives an open signal, thus preventing manual . closure. This condition has existed for at least several years.

The licensee has relied on closure of a manual block valve located in the turbine building to compensate for the problem. The Team' expressed concern that the distance between the containment isolation check valve and the rededant isolation valve have been unnecessarily extended outside the reactor building. In addition, a lineup that is inconsistent with the design drawings and operating procedures resulted. The WPRT had designated this MR as post-restart. In response

to the Team's concerns, the licensee initiated an Engineering Service Request (ESR) to identify an acceptable repair. The licensee comitted to resolve this item prior to restart.

These two examples of misscheduled MR's were discussed by licensee management with the WPRT.

In addition, the licensee committed to re-evalu-ate all priority 3 MR's before restart. The licensee's process for review and prioritita*. ton of MR's is thorough, and with the exception of the two instances described above, appears well implemented. The effectiveness of the licensee's planning and prictit zation t program is demon-strated by the overall decrease in the number of outstarding mainteN.wo tasks, their average age, and their significa':..

l 1

1 45 The licensee tracks several maintenance perform-ance indicators which are indicative of backlog status. Those performance indicators generally i display a favorable trend. The Performance Indi- l cator Report for August 9,1988, shows a total l backlog of 2177 open MR's, of which 746 are in a 1 test /ternover status. Of these, 220 cannot be l tested until the plant system becomes operable during startup. Of the 1431 remaining open MR's, the licensee has identified 652 requi ed for i restart. The physical work had yet to be done for 145 of these 652 MR's. Based on the above, and an average closecut rate of about 25 packages l per week, elimination of the restart backlog )

within 6 to 7 weeks appears to be manageable '

effort. The licensee's goal, in ' addition to ;

addressing the restart MR's, is to reduce the '

total number of open MR's from 1431 to less than 1000 by plant restart. The Team noted that this wo. u ld constitute an acceptable open MR backlog for an operating plant, and that the licensee's ;

goal was reasonable.

3.3.2.5 Control and Performance of Maintenance Inspection t'n tnis area was performed to deter-mine whether maintenance activities are being properly controlled through established proced- ,

ures, and the use of approved technical muuals, !

drawings and job-specific instructions. Mainten-ance activities were observed to determine how well the new program was being implemented.

The new maintenance program is primarily defined in Procedures 1.5.3, "Maintenance Requests," and 1.5.3.1, "Maintenance Work Plan," which were implemented on June 20, 1988. The procedures were reviewed and found to provide strong con-trols for identification, planning, performance,

. and closecut of maintenance tasks. Issuance and control of materials used for replacament/ repair I assure that requisite quality requirements are ]

maintained. Supervisory oversight of work in I progress ind the final review of work packages for completeness is a strength. Based on its review of the above procedures and observatiens of work in progress, the Team concluded that the newly defined program provides excellent control l and documentation of activities.

l l

46 The new pr gram and procedures formalize controls thht were previously in place, but inconsistently applied and not recognized by procedures. The procedures now require better documentation of the initial problem description, the repairs made, and the post-work test requirements. They require detailed work instructions, which should provide for consistent high quality in mainten-ance work packages. An additional insprovement in the maintenance procedures is that the mainten-ance work plan now provides for detailed documen-tation of installation and removal of lifted leads and jumpers (LL/J). This documentation assures preper performance of the task and is supplemented by the tracking provided in the LL/J :

Log initiated by the Operations Department per i procedure 1.5.9.1. )

To eliminate a previously identified weakness, the licensee his stopped using Procedure 3.M.1-11, "Routine Maintenance," which was found to be too general to adequately control work activities. Instead, detailed work instructions are provided by the work plans prepared in ac-cordance with Procedere 1.5.3.1. Further, the licensee has stopped using the Maintenance Sum- I mary and Control (MSC) form. The documentation )

provided by the form has been replaced by the detailed work plans, maintenance legs, and special process control sheets now required by 1 Procedures 1.5.3 and 1.5.3.1. l The maintenance activities and packages listed in Appendix 0 of this report were reviewed to verify proper implementation of program requirements.

The Team found that detailed work packages were prepared and in use in the field with adequate job specific instructions to accomplish the as-signed tasks. No ad-hoc cnanges of the work scope were observed. Pre-job briefings were conducted and were appropriate to outline the activities planned. Coordination and in-process communications with operations personnel were proper and ' assured good control of plant equipment.

47 s

. Maintenance personnel, including contractors,

have been trained in and were knowledgeable about the new program and procedure requirements. Al-though the new controls were deemed cumbersome by some, overall worker attitudes about the new procedures were positive. There is a general acceptance of the present program and a desire to "do the work right." Personnel performing the work were qualified, as verified by the training and qualification status board maintained in the maintenance shop.

Thr licensee has made progress in filling vacan-cies in the first-line supervisor positions with personnel having the requisite experience and expertise in the associated disciplines. The present supervisory staffing is adequate to cover work production whedules and provides adequate oversight. In an additional program improvement, supervisor review of wark packages is now re-quired by precedure to assure management review of packages for completeness. First-line super-visors were roettnely observed in the field di-recting work in progress. Supervisory involve-ment was effective to assure completion of work

. correctly, to help resolve technical problems, and to coordinate engineering support, as re-quired. The oversight function has been enhanced by the larger number of first-line supervisors who have been relieved of the excessive adminis-trative burden associated with planning and pack-age preparation.

The effectiveness of maintenance str.ff engineers and system engineers in supporting field activ-ities was particularly noted in the repairs for i the fuel pool cooling pump and the repair of RHR I discharge valve 288. The engineers are also used I in the root cause analysis of component failures. '

The repair of valves 28A and B involved the fabrication of new valve yokes, which resulted in a large and complicated work control process that was appropriately broken down into several work packages. Oversight and control of these jobs, which spanned several weeks, were notable. The quality of the final product was evident, as was the welding of the yoke subparts. Good inprocess

l 48 controls resulted in an acceptable root weld on the first attempt for valve 288. Although a problem was encountered in the fabrication of the yckes-(short by 3/8 inches), this item, consid-ered minor, was properly dispositioned by the licensee through Nonconformance Report (NCR) 88-99.

3.3.2.6 Post-Maintenance Testing Program The licensee's program for identification and implementation of post-maintsnance testing was considered weak during previous inspections.

During the current period, ,the Team reviewed the licensee's post-maintenance testing program pro-cedures and other approved test technical guid-ance. A sample of maintenance tasks was reviewed to determine if planned testing adequately demon-strated correction of the cited deficiency. Test-ing was observed in the field, and completed test documentation was reviewed for thoroughness.

The licensee recently implemented a major revis-ion to Procedure 3.M.1-30, "Post-Work Testing Guidance." The current revision establishes a conservative philosophy designed to ensure that prescribed testing verifies correction of the original deficiency, as well as potential prob-lems which could have resulted from performance of the task. Organizational and individual responsibilities are clearly defined. Procedure 3.M.1-30 incorporates by reference Station Instruction SI-MT.0501, "Post-Work Test Matrices and Guidelines." SI-MT.0501 serves to further ;

define the method by which post-work testing is !

to be specified and documented. It includes an !

Individual matrix for each type of component describing the possible maintenance tasks and the corresponding post work test requirement. Each

. matrix references an appropriate data sheet which provides more detailed testing guidance. Proced-ure 3.M 1-30, in conjunction with SI-NT.0501, is to be used by the Maintenance Planning Division, with needed technical input from other mainten-ance department and systems engineering depart-ment personnel, to establish comprehensive test-ing requirements for each maintenance request.

The testing program as described in these docu-ments is well conceived and is considered a strength. 1 l

49 The Team reviewed a sample of r.ngoing maintenance tasks and evaluated the technical adequacy of prescribed testing. In three of the examples re-viewed, the planned testing was not adequate to ensure proper performance of the task and com-plete correction of the problem:

(1) Testing identified for the replacement of the fuel pool cooling pump and motor under MR 86-109, included only motor current and vibration monitoring. No pump head / flow test was specified.

. (2) The package for replacemen.t of a safety-related 4160-VAC bus lockout relay under MR-88-110 initially contained only the general guidance which should have been used for development of detailed testing. Subse-quantly, suggested testing verified only a

, portion of the lockout relay functions.

(3) Post-maintenance testing following repair of a motor operated valve limit switch under MR 88-10-179 was also not adequate to ensure that the problem had been completely corrected.

In response to the Team's findings, the . licensee Maintenance Section Manager audited task-ready MR packages and identified one additional case of inadequately specified testing. In each of the above instances, the licensee subsequently de-veloped and performed adequate post-work tests.

Discussion with the personnel involved and main-tenance department management revealed that no training on the newly developed post-work testing procedures and guidance had been conducted. The licensee immediately briefed appropriate super-visors and workers on the program, and committed to complete formal training in this area .by September 9, 1988. A second potential contrib-utor to the problem in planning post-work tests is the press of business, particularly in the planning area, in that the planners are currently just able to keep pace with the schedule for field activities. Licensee management appeared to be sensitive to this issue. The Team reviewed an additional sample of in process ano completed MR's and did not icentify any further problems.

t

50

- Overall, the Team concluded that the licensee has -

established a thorough post work testing program demonstrating a sound safety perspective. Al-though'the program is generally well implemented, some problems were noted. The newness of the program, the current press of business, and some weakness in personnel training appear to be af-fecting its implementation. Therefore, this area requires contiquea licensee attention.

3.3.3 Conclusions The licensee has established a viable maintenance organiza-tion. Allocated staffing levels have been sQstantialli

. increased and are sufficient to support r.outine maintenance' activities. Of particular significance is the addition of first-line supervisory positions, and the creation of an expanded maintenance planning and scheduling division. The lie,ensee has been largely successful in filling previously vacant positions. One exception is the staffing of the maintenance planning division. While noite of the permanent staff in this area is in place, the licensee is effectively utilizing contractors to perform the function. Full staff-ing and training of the planning division is important to improving its overall effectiveness. Aggregate management and supervisory qualifications were also found to be adequate.

Newly revised maintenance and post-work testing program procedures provide significantly improved control and docu-mentation of field activities. They also result in an increased emphasis on detailed job planning. Observations by the Team indicate that implementation of the program is generally effective. .Some implementation problems are i evident; however, the problems affect production and not l the quality of completed work. Additional attention to post work test program application by the licensee is '

needed.

The licensee appears to have identified and properly pri-oritized outstanding maintenance tasks, with only minor exceptions noted. A process to ensure continued proper prioritization has been established. Both licensee senior management and maintenance section management are using a set of indicators to monitor performance, f l

i

l l

51 e

In summary, the licensee's current maintenance staff and program are adequate to support plant operations. Con-tinued close licensee management monitoring cf the newly implemented program will be required until additional expertence is gained. The long-term support programs, such as preventive maintenance, will require licensee enhance-ment to further strengthen performance.

4 9

l

52 3.4 Surveillance Testing and Calibration Control 3.4.1 Scope of Review The Team reviewed the licensee's administrative controls and implementation of the surveillance testing and cali-bration control program to assess its adequacy. As part of this review, the Team examined the licensee's corrective action to address past problems which included: effective-ness of test scheduling; the technical adequacy of proced-ures; and lack of centralized control of the program. The inspection consisted of a review of various procedures, drawings, and records; observations of testing in progress;

. and personnel interviews.

3.4.2 Observations and Findings 3.4.2.1 Master Surveillance Tracking program The Team reviewed the licensee's program for the control and evaluation of surveillance testing and calibration required by the Technical Spec.?-

teations (TS), inservice testing (IST) of pumps and valves required by 10 CFR 50.55.a(g), and calibration of other safety related instrumenta-tion not specified in TS. The program is pre-scribed by Procedure No. 1.8, "Master Surveil-lance Tracking Program." The Systems Engineering Division Manager has overall adminsitrative re-sponsibility for the Master Surveillance Tracking Program (MSTP). A plant Surveillance Coordinator has been assigned within the Systems Engineering Division to implement the program, which includes reviewing and approving ths various Itsts, sched-ules, and repo'rts generated by the MSTP, anr1 maintaining the MSTP data base. Each division has appointed a Division Surveillance Coordinator to interface with the plant Surveillance Coor-dinator. The plant Surveillance Coordinator l

. meets weekly with the Plant Manager to review the !

status of the surveillance program. ,

The purpose of the MSTP is to ensure the timely performance of all surveillance testing. The MSTP data base contains informatien such as:

commitment reference (TS, preventive maintenance,

. regulatory commitment, etc.); the applicable procedure number and title; scheduler interval and basis; the group responsible for performing l

53 s

the test / calibration; and the date last performed, the next due date, and the last date by which the surveillance test must be completed (plus 25%

date). Completed tests are rescheduled to ensure the combined grace period for any three consecu-tive tests does not exceed 3.25 times the spec-ified surveillance interval. The accuracy of the data base was verified by a contractor during the current outage. Procedure No.1.8 contains spec-ific controls on changing any of the data fields in the MSTP data base to maintain its accuracy.

In addition, a second contractor verification of the MSTP data base is scheduled to be performed in the near future. The Team selected several

. TS-required surveillance tests Lto ensure that they are in the MSTP data base, that approved procedures existed, and that the test frequency was proper. No discrepancies were identi fied with the data base during the Team's review; how-ever, the Team was concerned with a potential problem involving the scheduling of once per-operating-cycle versus once per-refueling-outage tests, as discussed below.

As part of its review, the Team examined the pro-cess established by Procedure No.1.8 to deter-mine its adequacy in ensuring that surveillance tests were properly scheduled and performed with-in the required time period. A "Division List" is issued to each division and to the Control Room Annex each Friday which provides a schedule of tests due for performance the following week. j A "Monthly Forecast" is also issued weekly to assist the .Section Managers in planning and '

scheduling resources. When a surveillance test is satisfactorily completed, the Control Room Annex copy of the Division List is signed off.

, Daily, the Planning and Scheduling Division transcribes the completion dates and updates the MSTP data base. A "Surveillance Day File Report" is issued daily to identify all changes made to the MSTP data base since the last time the report i l

was issued. This report is reviewed'by the Plant Surveillance Coordinator and used to verify pro-per transcription and data entry. "Variance l Reports" are issued wevkly to Section Managers to l

54 identify those surveillance tests that were scheduled, but not performed. A written explana-tion as to why the tests were not performed with-in the required time and why it's acceptable not to perform the test is sent to the surveillance coordinator within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of receipt of the Variance Report. A "Priority Notice" is issued for any surveillance test that has reached its deadline date (plus 25% date) and that has not been performed by that date to assist in the pre-vention of TS violations. Failure to perform a TS-reguired surveillance test on the deadline date requires submission of a Failure and Mal-function Report. The Team reviewed samples of each of the above reports, and their responses, and concluded that the program was adequate and contained sufficient checks to ensure that sur-veillance tests were completed within the required time.

Although the Team found the administrative con-trol and implementation of the MSTP to be ade- i quate, it noted a commitment by licensee manage- '

ment to improve the program. These improvements include: replacing the Division Lists with task cards to reduce the potential for transcription errors; adding an alert notice when a scheduled test is not performed; improving the scheduling of conditional surveillances; planning for the addition of a full-time surveillance engineer; and instituting an equipment history computer pregram capable of trending surveillance /calibra-tion results on individual components.

.The Team identified one concern during its review l related to the scheduling of once-per-operating- l cycle versus once-per-refueling-outage surveil- -

lance tests. The Pilgrim Technical Specifica-tions define an operating cycle as the interval

. between the end of one refueling outage and the i and of the t.4xt subsequent refueling outage. A rtfueling outage is the period of time between the shutdown of the unit prior to refueling and the startup of the plant after that refueling, j l

The T5 contains some surveillance requirements

that are specified to be performed once per oper-l' ating cycle, while there are others, such as testing the drywell-to-suppression-chamber vacuum breakers, which are to be performed during each

55 refueling outage. Also, all the safety-related instruments not specified in the TS are cali-brated once per refueling outage. As part of a previously identified issue, the licensee has defined once-per-operating-cycle to be 18 months; however, no . clarification has been provided for once per-refueling-outage. As a result, there are several once per-refueling-outage tests /

calibrations which were performed in 1986 and 1987 which are currently scheduled on the MSTP for the "next refueling outage," which is projected for some time in 1991.

Therefore, by strictly interpreting the defini-tions, the interval for some of the once per-refueling-outage surveillance tests could be as long as four or five years. The Team pointed out that this appears to be beyond the intent of the TS. The Team also noted that a licensee task force estab11thed to determine system operability prior to restart had also identified this issue 4 and recommended that evaluar. ions be. performed on -

the once per-refueling-outage surveillance tests to determine if and when they should be reper-formed. The licensee committed to evaluate the status of the once per-refueling-surveillance tests and provide justification for those tests not rescheduled, prior to restart.

3.4.2.2 Logic System Functional Test and Simulated Automatic Actuation Procedures The Team reviewed the procedures listed in Appendix 0 of this report to determine the ade-quacy of the licensee's performance of logic system functional tests (LSFT) and simulated automatic actuations (SAA). The review consisted of the indicated channel / train of the primary containment isolation system (PCIS) and the

- reactor core isolation cooling (RCIC) system LSFT

and SAA, and the diesel generator (OG) initiation LSFT. The procedures were reviewed against the system drawings to ensure that they were tech-nically adequate, that all relays and contacts were tested, that the procedures were properly approved, and that the tests were performed at The licensee uses a the required frequency.

series of overlapping tests to satisfy the LSFT i

~

56

~

and SAA. The Team noted that the licensee had a contractor review the adequacy of the LSFT and SAA tests during this outage. The contractor identified several deficiencies, which were cor-rected. The Team found that each procedure re-i viewed was technically adequate and that the testing sequence satisfied the Technical Specift- .

cation LSFT and SAA frequency and scope require-ments. The Team also noted that the format of ,

the procedures was adequate and included: en-vironmental qualification quality control (QC) witness points on . transmitter calibrations; double verification on lifting and landing leads; fuse holder fit checks; and !&C management review upon test completion prior to the NWE review.

During the review of the RCIC isolation subsystem LSFT, the Team questioned why there was no LSFT on initiation logic. The Team acknowledged that it was not required by TS Table 4.2.8, nor was credit taken for it in the FSAR. However, TS 3.,5.0.1 requires RCIC be operable (with reactor !

pressure greater than 150 psig and coolcat tem-perature greater than 365 degrees F) and the TS

, definition of system operability requires. that all subsystems also be operable. This would include the RCIC initiation logic. Also, the guidance provided by the Standard Technical Spec-ifications indicates that an LSFT on the RCIC initiation logic should be performed every six months. The Team noted that procedure Nc. 8.M.2-2.6.7, "RCIC Simulated Automatic Actuation," l actually performs an initiation logic LFST; how- i ever, it is scheduled at a once per-18-month fre- '

quency, while TS-required LSFT's have a frequency of' once per 6 months. This ites is unresolved pending a licensee evaluation of the adequacy of ,

the RCIC initiation logic LSFT frequency (88 -

02). The licensee committed to provide, bef. ore

! restart, the technical basis for the surveillance j

frequency.

3.4.2.3 Calibration Procedures The Team noted that the licensee established a series of procedures, known as the 8.E series, to i

calibrate the safety-related instrumentation not specified in the Technical Specifications. This 4

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

! 57

I instrumentation is normally used to record data necessary to complete TS-required surveillance tests or inservice testing of pumps and valves.

The 8.E procedures are scheduled on a once per-refueling-autage interval. l l

The Team performed a detailed review of Proced- ;

ures No. 8.E.11, "Standby Liquid Control System Instrument Calibration," and 8.E.13. "RCIC System Instrument Calibration." Overall, the Team found the technical content and format to be adequate; however, two discrepancies were identified. Pro-cedure No. 8.E.11 does not calibrate pressure j indicator (PI) 1159. This PI was installed dur-

. ing the current outage and is used in the per-i formance of Procedure No. 8.4.1, "Standby Liquid Control Pump Operability and Flow Rate Test." l The Team also noted that Procedure No. 8.E.13 does not calibrate PI 1340-2. This PI'is usad in .

the performance of Brocedure No. 8.5.5.1, "RC1C '

Pump Operability Flow Rate and Valve Test 91,000 psig." PI 1340-2 was installed and last cali-brated during the 1984 outage when pressure transmitter 1360-19 was replaced with a Rosemount Transmitter. The licensee indicated that the procedures would be revised to . correct the deficiencies. .

3.4.2.4 Surveillance Test Observations On August 16, 1988, the Team observed a portion of the performance of Procedure No. 8.M.2-2.10.

1-5, "Core Spray $ystem 'B' Logic Functional Test," Revision 13. The test was performed as -

part of the restoration of the "B" Core Spray System and as post work testing of relay 14A-K208. The test was observed to ensure it was performed in accordance with a properly approved ud adequate procedure. During the test, the '

I

Team noted that the technicians' performance was adequate. They conducted the test in a slow and i

deliberate manner and stopped when questions l' arose concerning mislabelled nameplates and the identification of some relay coil leads. In both l cases, the questions were resolved before they 1 proceeded. The Team noted that the !&C first-line supervisor monitored portions of the test.

The test was also monitored by QA personnel as part of the surveillance monitoring program. QA personnel indicated that they observe approxi-mately one surveillance test a week. !

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The test was stopped at Step 25 when the test results did not agree with the axpected results delineated in the procedure.' The step was sup- '

posed to verify the instantaneous pickup of the core spray pump start relay 14A-X128. Subsequent Itcensee investigation revealed that the instan-taneous pickup was removed as part of the de- i graded grid voltage modification (Plant Design '

Change (POC) 88-07). 1he Team noted that P0C 88-07 had not yet been closed; howevar, an impact review performed prior to installing the modif t- !

cation failed to identify Procedure 8.M.2-2.10. ;

,1-5 as being affected by the PDC. l I

1 The Team noted that one of the itcensee's self-assessment action items was to review the impact of POC's (installed since October 1987) on LSFT's. The Itcensee's review began on

- October 1987 because this was the ecnpletion dats l

of the contractor review noted above which ver-ified the adequacy of L5FT/5AA tests. The Team ,

noted that the contractor review produced an

. LSFT/5AA data base which cross references the

. safety-related component's tested to the appli- i cable L5FT/SAA test,. Tris data, was being used during the ;icensee's review. Four of the five PDC's involved in the iteenste's review of impact on LSFT's have been completed. The remaining PDC (88-07) was undar review when the problem with i the core spray LSFY was noted. Twenty-one pro-

' cedures have been identified as possibly being i affected by the p0C and are currently under review. The C5 functional test appears ts be the i only affected test run orior to complation of the

POC-procedure review.

The licensee indicated that a possible future improvement will be to use the L5FT/SAA data base i to determine the impact of a POC on prncedures before implementing the modificatirn, i

! 3.4.2.5 Measuring and Tcst Equipment

! The Team reviewed records, interviewed personnel, 1 and toured storage are&s to deterstne the ade-

! quacy of the licenue's progre.m for control of j measuring and test equipment (MCE). Administra-tive control of the program is established by I i Procedure No. 1.3.36, "Measurersnt and Test

Equipuent."

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59 The licensee has implemented a computerized sys' tem to issue and track MTE. This system will only allow issuance equipment to authorized per-sonnel, will limit the checkout period to only 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and will not issue MTE if the sticker calibration date does not match the calibration date in the computer. The system also issues a MTE traveler form to the user to identify usage on each plant device tested and each MTE range used. This data is later entered into the com- L puter to assist in evaluations if and when a piece of MTE is found to be out of calibration.

The Team reviewed two cases where MTE was out of calibration and noted that the evaluations per- '

formed were documented in accordance with proced-ures and appeared thorough. Thus far, only electrical I&C and electrical MTE are on the new computerized system; however, similar controls are be'ing manually implemented for mechanical equipment until it is incorporated into the new system.

The licensee currently has two storage areas for l MTE: one for electrical /I&C and one for mech-anical equipment. The Team toured each area and - "

noted that the equipment' was identified by a unique number and indicated calibration status.

The Team found that the equipment was properly

, stored and that MTE.out of-calibration, on hold I for repairs, or new equipment not yet in the sys-tem, were properly identified and segregated.

The licensee indicated plans to go to only one storage ar% and to increase the number of staff issuing and controlling the M&TE. ,

The Team also reviewed the system for recalling equipment for calibration. The recall tracking

. is performed in accordance with Procedure No.

1.8.2, "PM Tracking Program." The Team reviewed

, several equipment calibration stickers during its tour of the storage areas and during observations I of ongoing surveillance and maintenance activ-ities. No equipment past its calibration due date was identified.

The Team found the licensee's control of censur- !

ing and test equipment to be adequate.

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60 3.4.2.6 Inservice Testing of Pumps and Valve,s The Team reviewed the status of the licensee's program for inservice testing of pumps and valves in accordance with the ASME Boiler and Pressure Vessel Code,Section XI.

The licensee subsitted Revision IA to the inser- i vice test (IST) program on October 24, 1985. A [

meeting was held between BECo and the NRC on !

January 14, 1988, to discuss the licensee's pro- .

posed Revision 2 to the IST program. To minimize !

1mpact on the NRC review cycle, the licensee sub- ;

mitted an interim IST program, Revision 18, on :

March 14, 1988, to address concerns identified by .-

the NRC during review of Revision 1A. The Ifeen- [

see plans to submit Revision 2 after the Safety ,

Evaluation Report on Revision 13 is issued. Re- ,

. vision 2 is to maintain the upgrades made to the l program in devision 18 and increase the program scope by adding more components (e.g., relief ,

valves). l Control of the IST Program is established by Pro-cedure No. 8.I.1, "Acministration of Inse'vica Pump and Valve Testing." The Team reviewed the procedure and noted that while it defines the methodology for compitance to the IST program for pumps and valves, including analysis of test I data, direction on corrective action, and estab- :

lishment of reference values (additional guidance is contained in Procedure No. 8.I.3, "Inservice Test Analysis and Documentation Methods"), the organi:ational responsibilities and referenced IST program revision need to be updated. For example, the pump and valve testing is now sched-uled through the MSTP instead of the compliance group, and a Senior ASME hst Engineer has been hired to implement the program. The licensee

. acknowledged the Team's comments and showed it a draf t revision to Procedure 8.!, which 'is sched-uled to be implemented when Revision 2 is submit-ted. The Team reviewed the draft orocedure and noted that it provided additional dotati on:

61 responsibilities, definitions, test requirements, compliance requirements, evaluation, disposition, post-maintenance testing, and administration and records maintenance. The draft procedure also provides a listing of the pumps and valves cur-rently within the testing program and includes a cross-reference for individual test requirements to the approved PNPS procedure.

The Team noted that other improvements (planned or in pengress) to the IST program include revis-ing all the implementing procedures to upgrade

'them to Revision 2 and creating a position for a '

second ASME test engineer.

! The Team reviewed several pump and valve test results for the standby liquid control, core spray, salt service water and low pressure cool-ant injection systems to verify that the accept-ance criteria were met, that the results were properly evaluated and trended, and that the fre-quency of testing was increased when required.

The Team noted that Procidure No. 8.I contains controls to change the MSTP data base test fre-quency when the deviations fall within the alert range. The Team reviewed changes to various pump reference values to ensure that they were justi-fled and documented. The Team also checked the reactor building closed' cooling water, salt ser- i vice water, and standby liquid control system i pumps to ensure that the IST vibration data point i was properly marked. No deficiencies were iden-tified during this review.

. 3.4.3 Conclusions l Based on observations, personnel interviews, and the review of procedures and reco'rds noted above, the Team concluded i

that:

1. The licensee has established and is implementing an o adequate and effective program to control all surveil-lance activities at PNPS.

2. Rwsponsibility for imolementing the MSTP has been placed in a centralized, strong, forward-looking division.

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3. The licensee was adequately implementing the IST pro-gram for pumps and valves. The Team noted that there are several planned improvements to the program involving administrative and implementing procedures and staffing to upgrade the IST program.

4. !.icensee management is committed to improve the sur-veillance program, as evidenced by the upgrades planned or in progress in each area examined. These include: contractor data base reviews; increasing the scope of the IST program, increasing staffing; im-proved control over issuing and tracking M&TE; estab-lishing an equipnent history computer program; replac-ing the MSTP division lists with task cards; and improving conditional test scheduling.

5. With the exception of the few deficiencies noted above, the procedures were technically adequate.

6. The one concern identified was the licensee's need to resolve the once per-refueling-outage scneduling deficiency.

9

63 3.5 Radiation protection (RP) 3.5.1 Scope of Review.

The Team reviewed various aspects of the radiation protec-tion program during the inspection, with emphasis on the licensee's ability to safely support plant startup. Per- .

formance was determined from: observation of work in progress; periodic tours of plant areas; interviews with managers, supervisors, and technicians; and review of selected documents. The areas reviewed are as follows:

1) Organization and staffing;

2) Training, qualification and continuing education of RP .

to:hnicians;

3) General employee training; -

4) ALARA programs;

5) Control and oversight of work in radiological areas;

6) Control of locked high radiation areas; I

7) Adequacy of laboratory (count room) equipment;

8) Availability and adequacy of portable RP survey ;

equipment; i

9) Adequacy of gaseous and liquid release monitoring systen:s;

10) Clarity and consistency of RP policies and procedures; !

11) Audits.

3.5.2 Observations and Findings

. 3.5.2.1 Organization and Staffing ;

The organization of the radiation protection (RP) department has remained stable since the signift-cant changes which were made early in 1988. The j staffing level has remained constant and is ade-quate to support plant operations. The RP sec-tion manager described various enhancements i

64 planned for the supervisory staff. An outline for qualification as Radiation Protection Man-ager, .per Regulatory Guide 1.8, has been ap-proved. One or two division managers within the RP section will be expected to qualify as Radia-tion Protection Manager to provide depth in the organization. Incentives have been approved for achieving this qualification. In addition, the three division managers will rotate assignments for cross-traiaing purposes, and all will be encouraged to pursue advanced scholastic degrees.

These efforts are expected to begin in the near.

future.

The Team observed some indications of isolated morale probiems at the technician and first-line supervisor level which were attributed to several causes. Contributors include personnel and as-signment changes within the organiza. ion result-ing from rotation of radiation protection shift supervisors, an influx of new technicians, im-

. pending. implementation of a new rotating work schedule, and a perceived lack of management presence in the ' field. In addition, weaknesses may exist in communications within the RP organ-ization as evidenced by technician perceptions of a lack of technician input or review during the .

development or revision of RP policies and pro-cedures. In summary, and in spite of these dif-ficulties, the Team observed that the technicians and supervisors were generally enthusiastic and competent.

Another potential weakness results from the prac-tice of rotating technicians through job assign-ments each three to six months. Although this practice may have merit for familiarization and job exposure purposes it may prevent or signifi-cantly delay the development of a high profici-ency level in certain specialized technical areas, a concern particularly evident in the instrument repair and calibration facility. Here the RP technician is assigned to repair and cali-brate a wide range of instrumentation, including gas flow detector cells, sophisticated c:mputer-controlled automatic friskers, air pumps, and all alpha, beta, gamma and neutron survey meters.

The area supervisor stated that he was attempting to resolve this problem by requesting an exten-sten of the rotation cycle.

65 The RP section has 42 technicians, of whom 36 are ANSI 18.1 qualified. Only 21 have commercial experience. The section manager provided a shift ttaffing schedule for power ascension testing that will ensure that the experience will be adequately distributed among the individual shift -

crews.

3.5.2.2 RP Technician Training The RP technician training and qualification pro-gram is certified by the Institute of Nuclear Plant Operations (INPO), uses INPO guidelines for development of instructional material, and uses the INPO exam question bank. The training is conducted in three phases over a period of two years or less, depending on experience. Upon completion of Phase 2, the technician is con-sidered to be ANSI qualified and can issue radia-tion work permits. The third phase includes specialty task.s such as operation of the whole body counter and respirator fit testing.

Classroom training is provided at the offsite facility. The training facilities were adequate, well lighted, comfortable and equipped with prac-tice equipment. The Team observed that most of the basic survey instrumsnts were available, but laboratory-type gamma spectroscopy equipment, as well as ALARA mock-ups, were not available. This is typical of a single unit station. Most pre-sentations appea.*ed to rely on lectures with minimal use of audio-visual equipment. A review l of selected. lesson plans showed adequate tech- :

nical content.

Classroom training is followed by an in plant phase where the technician receives on-the-job training and demonstrates proficiency at various tasks. This is documented in a qualification folder. Qualified technicians will be provided with ongoing training on a six-week schedule.

This will be contingent on implementation of a new si x-s ect', on rotating work schedule. The l

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e 66 training department has begun drafting lesson plans which will cover a broad range of topics, including interpersonal skills training. The instructors must also complete formal qualifica-tions. They were recently required to begin spending a certain number of hours in plant be-tween training ' cycles. This keeps them abreast of changes occurring in the plant.

The Team concluded that this program is well-

. controlled and documented and is aided by a dy-namic first-line supervisor. The implementation and effectiveness of cycle training will be eval-usted in the future. The licensee's current ef-forts are directed at completing initial qual-ification for the entire staff.

3.5.2.3 General Employee Training (GET)

All general employee training and in-processing is conducted at the on-site training center over' a three-day period. Classrooms were spacious, comfortable, and well equipped. Ample training aids, as well as audio-visual equipment, were in evidence. A comprehcnsive student manual is 4 given to each trainee along with copies of appro- I priate regulations and regulatory guides. Basic training involves 20 contact hours, while radia-tien workers receive an additicnal 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . Res-pirator fit testing is also provided.

The two instructors associated with GET had com-plated the formal Staff Development program.

Both have extensive experience and are well qual-ified. Although their teaching techniques could not brobserved since no classes were in session during the week of this review, the Team con- l cluded that the training content provided ade- i qtlate direction to attendees. Both instructors spend time in the plant weekly to assess staff training needs.

The GET training is INPO certified. In addition, the training center offers five courses to all new supervisors. A new industrial safety train-ing program is under development. An instructor has been hired and will begin providing training in occupational safety during the first quarter of 1989.

67 The Team concluded that management support of GET training was good, that the training was effec-tively conducted, and that it made a positive contribution to safety.

3.5.2.4 ALARA Programs ALARA performance at this station hAd been a persistent weakness over several past SALP report periods.

The Team noted recent apparent improvement in upper management support for ALARA programs.

Examples of this support are reflected in the re-evaluation of the 1988 ALARA goal from 600 to 390 manrem and formulation of several plans to reduce exposures. Also, the licensee is assign-ing an experienced manager to survey INPO, Elec-tric Power Research Institute (EPRI), and several other nuclear stations to make a list of cost-effective exposure source term reduction tech-niques. The Station Director will then formulate

- a long-term program based on the findings of this survey. Another plan is to begin removal of abandoned in-place systems in 1989 which should remove unnecessary sources of exposure. A third project is underway to identify hot spots in plant piping and determine which of these could be reduced by flushing.

The ALARA staff also has plans to attend a train-ing course and visit other stations to observe effective techniques. This. staff is in the process of filling its final vacancy.

ALARA performance at the working level remains mixed. Licensing personnel developed a technique for conducting remote inspections of fire barrier penetra,tions using a flashlight mounted on a telescope. This concept may be applied in num-trous situations and has the potential for sig-nificant dose savings. On the other hand, in-stances of failure to effectively use low-dose waiting areas were observed during work. The AULRA division manager is working to increase the sensitivity of all workers and technicians to ALARA oractices.

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The Team concluded that licensee attention to ALARA programs has significantly improved in recent months. The effectiveness and implemen-tation of ALARA plans will be assessed in future NRC inspections.

3.5.2.5 Control of Work Ouring closure of a Confirmatory Order in the fall of 1987, NRC noted some improvement in the relations between the RP section and the other sections performing work. However, poor planning and lack of work control continued to be ob-served. During'this assessment, further improve-ment in resolving these weaknesses was observed. -

One indicator of poor planning is the number of i radiation work permits (RWP) issued but not used.

A review found that only a small fraction of -

RWP's issued are now unused. In addition, the. l use of "A" priority maintenance work requests by l the Operations. Department to expedite work has j decreased significantly.

The use of a Radiation Protection Advisor as-signed to the Maintenance department continues to be effective. This position was recently assumed by an experienced RP technician. He has intro-duced innovations, including frequent work group training sessions and installation of permanently situated boxes in the plant for contaminated tools.

The Planning Division is developing improved pro-cedures for planning work. This section is re-sponsible for coordinating with the RP and ALARA groups during the early phases of work planning.

This allows adequate time for RWP preparation and !

ALARA reviews. Responsible section managers !

stated that this early maintenance-HP contact will be procedural 12ed in September 1988.

The Team observed that on-the-job cooperation between workers and RP technicians was good. A minor problem was noted in that RP technicians in the controlled area appeared unprepared to deal ,

with a minor first-aid injury. Technicians were I

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69 uncertain in dealing with a worker with abrasions to his nose that caused bleeding. This was at-

tributed by the Team to a lack of training and clear policies. On the other hand, technicians appeared well prepared to handle more serious emergencies.

3.5.2.6 Control of Locked High Radiation Areas The licensee has previously incurred several violations for failure to properly control locked high radiation areas. This issue has been -

tracked as a NRC outstanding ites (87-li7-01). !

The licensee organized a task force to determine which lasting corrective actions would prevent a recurrence of these problems. Based on the find- ;

ings of the task force, the control procedures were revised to place basic responsibility on the .

RP technician who signs out the door ' key. Fur- l ther controls are provided by shift tours of all ;

locked areas and by upgrading locking devices. ;

Based on these actions, the Team concluded the ,

licensee had appropriately addressed concerns in this area.

3.5.2.7 Laboratory Equipment The adequacy and availability of RP laboratory equipment to support plant startup was reviewed.

The licensee has available two multichannel analyzers (Nuclear Data 6700), several beta counters (BC4), and several alpha counters (SAC 4). The radiochemistry laboratory has redundant equipment for backup. This equipment is required -

to perform 1*otopic analysis of air samples for j maximum permitted concentration (MpC). calcula- ,

tions, detection of degraded fuel, conditions, and to support .radwaste analysis. Procedures for the use of the equipment are available in the laborato ry.

The Team noted that, at the time of the inspec- ,

tion, several pieces of laboratory equips'ent were l awaiting repair or calibration. Ortl y one BC-4 i and one SAC-4 were operational in the lab. Both sultichannel analyzers were awaiting repair parts, the supervisor in charge attributed this to the lack of proficiency of the technicians due to the rotating work assignment. policy. This issue was discussed in Section 3.5.2.1.

70 3.5.2.8 Survey Equipment The availability of properly calibrated sv vey equipment was reviewed. Survey equipment 'n used i by RP technicians to measure dose rates, aM sur-face and airborne contamination levels, beluded in the review were the automatic persunel con-tamination detectors.

All equipment is calibrated and rcpaired in a facility on site, except for neutron survey meters. RP technicians are trained to perform all functions in the facility. The facility appeared to be adequately equipped to perform its

task. .

- Stocks of equipment ready for issuance appeared ample and the calibration / repair backlog was minimal. This readiness may have been aided somewhat by reduced outage activity. The Team noted an improvement in that the new manager of the group has recently impl.mented a computer program that shows the status of each piece of equipment, the data base for which is updated each time an instrument is issued. Information that is captured includes users of the meter, calibration due date, and failure mode if placed out of service.

The Team concluded that an adequate supply of calibrated instruments is on hand to support routine operations and abnormal conditions.

3.5.2.9 Monitoring Environmental Releases The operability o'f the environmental release monitors was verified. The two paths for a gas-eous release are the main stack and the reactor butiding vent. The monitors were found to be t

. operational and properly calib-ated, with approved procedures available. The equipment is

+ maintained by the Chemistry Group whilt the cal-culations of offsite dosos required by the re-vised Radiological Environmental Technical Spec-ifications (RETS) are performed by the RP section.

. l 71 l

1 The single Itquid release path monitor was oper- !

attonal. Due to elevated background radiation l 1evels 'at the sodium iodide monitor, a new system l has been installed parallel to the old system. ;

The new system 0111 offer increased sensitivity 1 and will be brought on line in the near future. l 3.5,2.1C Policies and Procedures 1 A sampling of RP procedures indicates that they are generally clear. The number of procedures controlling the RP department activities is extensive. However, the format varies from step-by-step instructions to a more general format.

, The PVp procedure is currently being revised to make the process less cumbersome and more useful.

In general, the RP technicians did not feel ade-quately consulted during the revision of proced- !

ures. This issue was discussed in Section '

3.5.2.1.

i The Team concluded that the RP procedures were l

, adequate to support startup.

3.5.2.11 Audits Previous inspections found the licensee's inter-nal audits and asssessments of the RP program were primarily compliance + oriented. Currently, these audits are completed in several ways. Sev- 1

' eral peer evaluators were trained to make on-the- )

job observations. A Radiological Assessor is l permanently assigned to *he staff reporting to the Senior Vit.:e President. The Management Over-

, sight and Assessment Team (MO&AT) does monthly plant tours. Also, the QA Department recently transferred in two experienced RP personnel. In i addition to the above audits and reviews, the Radiological Occurrence Report (ROR) system pro-vidas a method to capture input from workers and RP technicians.

A review of these efforts shows that a moderate level of success has been achieved in finding

. program weaknesses. However, the results have not been commensurate with the effort involved, i

The RP section manager stated that an effort is 1

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underway to shift the emphasis of these audits to performance rather than compliance. The audit performed by QA in November 1937 is being used as a model. Licensee efforts in this regard are expected to be long term and are adequate at this time to support plant startup.

3.5.2.12 Control of Radiciogical Shielding The Team reviewed the licensee's program for the installation, control, and removal of radiation shielding. This review concluded that the licen-see's program for control of radiation shielding is well documented and that implementation is

good.

The program guidelines are contained in PNP 5 Pro-cedure 6.10-008, "Installation and Removal of Shielding." Responsibility for implementation of the procedural requirements fall under the aus-pic65 of the Radiological Technical Support Division. The procedural requirements for con-l trolling this process appear well defined and cosprehensive. Licensee personnel responsible l l

for implementation of the procedure were well l versed on procedural requirements and current I

field installations. Licensee records of field

. installations were current, had been reviewed at the required intervals, and wcre accurate.

3.5.2.13 Health Physics Training The Team observed licensee personnel during a contamination control training exercise. The

, exercise simulated a spill of highly radioactive (3 Rom on contact) resin during transfer opera-

. tions. The scenerio document was well defined and included detailed timelines and instructions to the exercise controllers. The entire exercise was videotaped and replayed during the decriefing of participants. The exercise was well control-led and interviews with participants indicated that the individuals invclved considered it to be an effective training device. Lestics learned and feedback from participants n Ae red to be well disseminated.

\

73 3.5.2.14 Hydrogen Water, Chemistry System The licensee has installed a system to inject hydrogen gas into the feedwater to reduce the I potential for corrosion of reactor internal pip-ing. This process will result in fr. creased radi-ation levels onsite from increased radioactive ,

nitrogen isotope levels in the system. A review of the impact analysis showed that comprehen-sive plan to control exposures has been developed.

A test run in 1985 resulted in the installation of a 16-foot high 20-inch thick concrete shield around the turbine. Moreover, special controls are programmed into the computer that' controls the hydrogen injection. The cognizant engineer

. stated that these contrels are designed to pre-vent increased exposure either onsite or offsite.

. Team review of these calculations showed that doses may in fact be lowered.

The Training Department is developing a training program for the RP technicians to review the change in radiation levels that occur with opera-tions. This program was developed to refresh the RP technicians because of the extended shutdcwn and the increased levels of radiation in the snielded areas resulting from the addition of hydrogen. The RP section manager stated that a condensed revision of these presentations will j also be given to all maintenance and operations personnel prior to startup.

I 3.5.3 Conclusions I

The Team determined that progress has been made, that ade- ,

quate staff and management oversight is in place to achieve !

further progress, and that performance is adequate to sup- '

i port plant startup.

i. t.icensee strengths include a well-controlled and well-l organized training program for general employees and RP technicians. The use of an RP Advisor in the Maintenarice

Section, which had been effective in improving working l relationships, has led to further initiatives in training 1 and control of contaminated tools. The addition of this

position has also resulted in improved planning and control I of work.

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74 Notable progress was observed regarding upper management support and emphasis on ALARA. This attention is expected to result fa improving levels of performance over the next few years. Staff development programs for all levels of personnel, from technicians through managers, should con-siderably improve their level of performance. Control of technical problems, such as the radiological impact of

) hydrogen water chemistry and calibration status of survey meters, has improved.

A weakness was observed as a result of the rotational as-signment of Rp technicians that may affect their profic-iency in performing certain highly specialized jobs. An additional weakness concerns' the perception of poor var-tical commur.fcations between management and RP technicians

and workers. Although this issue has led to some incom-plete understanding of policies and some morale problems, 1

it has not significantly affected safety performance.

Additionally, vertical communication 2 within the RP organ-

) ization appeared somewhat weak. The Team detected a per-caption on the part of technicians that they have not been adequately involved in the changes being made in the RP Department policies and procedures. This perception ap-

, parently has 'resulted from Rp management not effectively communicating the bases for these changes to the staff, j There is also a perception that RP management is remote and 1 j not easily accessible. However, the Team determined that, despite this weakness, the attitude and safety approach of '

the RP Department staff has significantly improved and is

adequate to support plant operations.

The licensee advised that a training program is being developed to refresh RP . technicians concerning the change in radiological conditions on plant startup and the unique

. conditions to be created by the addition of hydrogen. A l

concensed version of this training will be provided to other radiation workers. Completion of this effort will be

reviewed in a future NRC inspection.

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3.6 Security and Safeauards 3.6.1 Scope of Review

~

Prior to the plant shutdown in April 1986, NRC had identi-fled serious concerns regarding the implementation and management support of the security program at Pilgrim. The licensee has been aggressively pursuing a comprehensive course of action to identify and correct the root causes of the programmatic weaknesses in physical security. The most '

recent SALP (50-293/87-99) covering the period February 1, i 1987 to May 15, 1988, determined that the licensee has demonstrated a commitment to implement an effective secur-

- . ity program. The 1.icensee's security organization has been expanded with the addition of experienced personnel in key positions, significant capital resources have been expended to upgrade security hardware, and equipment and program plans have been improved.

During the IAT inspection, all phases of the security pro-gram, including management support, staffing, organization, and. hardware aintenance, have been reviewed to assess the '

, effectiveness of the program imp'(mentation. The results i f of the review are described belov in general terms .to ,

exclude any safeguards information. ,

3.6.2 Observations and Findings l 3.6.2.1 Review of Security Program Upgrades l l The Team reviewed the progress made to date on the security program improvements committed to by the licensee as a result of previous NRC enforce- ,

ment action. The licensee was ' advised by the l Team that progress on these improvements will l continue to be monitored during future NRC

> inspections. Those commitments and their status ,

are as follows.

j Project Status Protected Area The upgrades of the perimeter perimeter barrier, intrusion detection i system, and assessment aid j system are complete.

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76 project Status Protected Area and Installation of upgraded Perimeter Lighting lighting is approximately 95%

complete. Four light stan- ,

chions remain to be instal-

. Ied. The lighting system as installed meets regulatory requirements.

Main and Alternate The designs for the new Access Control (upgraded) access control Points points are complete and new package search equipment is on site. Installation of new ,

package and personnel search !

equipment and full length turrstfles is scheduled for '

completion on September 28, 1988, in the site's main ac-cess point. Installation of new package search equipment l in the site's alternate ac-cass point is also scheduled for September 28, 1983.

Vital Area The vital area analysis, Analysis including walkdown of all ,

i vital areas to verify barrier integrity, and issuance of the report, is complete.

New Security The selection of the new Computer computer has been made and a purchase order for the com-puter has been issued. The

, licensee is currently working with the vendor on software options. The delivery of the new computer is scheduled for

, the first quarter of 1989, with installation to follow.

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3.6.2.2 Followup on Previously Unresolved Item (Closed) Unresolved Item (50-293/87-44-01):

Neighborhood checks for licensee employees being assigned to the site were not being consistently conducted as part of the access control program.

The neighborhood checks were not a regulatory requirement and it is a licensee-identified issue. During this inspection, the Team verified that the licensee has conducted a review and identified all site personnel who had not been subjected to neighborhood checks.. For these employees with less than three years of service with the licensee, neighborhood checks were sub-sequently conducted. For employees with more than three years with the company, a review of the personnel file was conducted and a memorandum was put into the file to indicate that the review was being made in lieu of the neighborhood check.

The acceptability of this alternative to the neighborhood checks was reviewed by NRC orior to its implementation and was found sa ti s facto ry.

3.6.2.3 Security Plac and Implementing Procedures

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The Team met with licensee representatives and discussed the NRC-approved Security Plan (the Plan). As a result of these discussions, and a review of the Plan and its implementing proced- :

ures, the Team found that the implementing pro-cedures adequately addressed the Plan's commit-ments. In addition, all security personnel interviewed demonstrated familiarity with the Plan, implementing procedures, and NRC's security program performance objectives.

3.6.2.4 Management Effectiveness - Security Programs - '

An in-depth review of the licensees management effectiveness was conducted by NRC in April and -

May 1988 and documented in Inspection Report No.

50-293/88-18. During that inspection, the Team concluded that the licensee has continued with .

its initiatives sad taken significant actions to {

further improve the effectiveness of the security organization. It was also concluded that the existing organization should provide the capa-bility to monitor the program properly.

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. 1 During its inspection, the Team independently 1 concluded that there is a strong management team in place based on the experience of the expanded proprietary security organization, the effective ,

interaction both between members of the se:urity l organization and with other departments, and the l effective oversight of the contract security <

organi:ation. I 3.6.2.5 Security Organization On August 16,1988, at 10:00 p.m., the security contractor for PNPS was changed from Globe .

Security Systems to the Wackenhut Corporation. .

The Team reviewed the licensee's and the contrac-tor's transition plans, and interviewed numerous management and union security personnel prior to the transition. Also, the Team was onsite during the transition for direct observations. The transition was somewhat simplified by the fact that all Globe employees that applied for posi-tions were retained by Wackenhut. The Team

, determined that, because of comprehensive transi-tion planning, the change in the contract secur-ity fores was accomplished without any compromise

, of sec'Jrity and with minimal disruption to se:ur- i ity operations, i 3.6.2.6 Security Program Audit The Team reviewed the monthly corporate audit )

reports. These audit reports were of good qual- 1 ity and were generated as a result of corporate oversight of the site security progrtm. The findings in these reports were minor and not indicative of any major programmatic problems.

The corrective actions were appropriate for the findings.

. 3.6.2.7 Records and Reports 1

The Team reviewed various security records, logs,

! and reports, including patrol logs, central alarm i station (CAS) logs, visitor control logs, and

! testing and maintenance records. All records, legs, and reports reviewed were complete and maintained as committed to in the Plan.

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79 3.6.2.8 Testing and Maintenance l r

i The Team reviewed the testing and maintenance records and procedures. The review disclosed

' that the preventive maintenance procedures were !

comprehensive and that the licensee now has in- l l

place a program that provides for prioritization i

of security maintenance by the security depart-sent. The maintenance support to the security department has improved as a result of the secur-ity department assigning priority to the mainten-ance work. The use of compensatory measures for

inoperative equipment is minimal. .

3.6 7 9 Locks, Xeys and Combinations The Team reviewed the installation, storage, re-tation and related records for all locks, keys and combinations and determined that the licensee was meeting the commit.ments in the Plan and its ,

implementing prscedures.- ,

j 3.6.2.10 Physical Barriers - Protected Areas l

The Team physically inspected the protected area j

barriers. It was determined by observations that the barriers were installed and maintained as described in the Plan. Progress on upgrading the barriers is addressed in Section 3.6.2.1 of this

! section. .

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3.6.2.11 Physical Barriers - Vital Areas The Team physically inspected the' vital area bar- !

]' riers and determined that the barriers were Installed and maintained as. described in the

-l Plan, s

) 3.6.2.12 Security System Power ,$upply j

The Teas reviewed the security system power sup-

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ply system and determined that it was in accord-ance with Plan requiruents. The Tea's noted that

as a result of the approval of a recent Plan revision, improvements for protecting the secur-

' ity power supply are underway, with work expected to be completed by September 28, 1988.

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80 3.6.2.13 Lighting The Team observed lighting within the protected area. All areas were lighted in accordance with commitments .in the Plan. Progress on upgrading the lighting is addressed in Section 3.6.2.1.

3.6.2.14 Compensatory Measures '

The Team reviewed the licensee's compensatory

measures and determined that their use to be con-sistent with the commitments in the Plsn. As a result of the security program upgrades addressed in Section 3.6.2.1, the need for compensatory measures for degraded security equipment has been dramatically reduced. Furtner reductions in the use of compensatory measures will occur as pro-ject upgrades are completed.

3.6.2.15 Assessment Aids The Team reviewed the licensee's use of assess-ment aids and determined by observation that the assessment aids are installed, functioning and maintained as committed to in the Plan. Progress on upgrading the assessment aids is addressed in '

Section 3.6.2.1, 3.6.2.16 Access Control - Personnel and Packages The Team reviewed the access control procedures for personnel and packages and determined that they are consistent with commi'eents in the Plan.

This determination was made by observing person-nel access processing during shift changes, visitor access processing, and by interviewing security personnel about package access proced-ures. The status of upgrades in tne access con -

, trol points is addressed in Section 3.6.2.1.

3.6.2.17 AccessControl-yehicles The Team reviewed vehicle access control proced-ures and observed vehicle searches at the Main Vehicle Gate. It was determined that vehicle searches were being conducted consistent with commitments in the plan.

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81 3.6.2.18 Detection Aids - Protected Area The Team observed penetration tests of approxi-mately 25% of the Itcensee's intrusion de:ection system on August 17, 1988. The remaining 75% was not tested during this inspection; however, pre-i vious test records were reviewed and the records indicated that the system was operating as de-scribed in the Plan and implementing procedures.

3.6.2.19 Detection Aids - Vital Area The Tean, observed the testing of intrusion detec-tion aids in selected vital areas and determined that they were installed and functioning as '

committed to in the Plan, i

'l l 3.6.2.20 Alarm Stations ,

The Team observed the operation of both the Cen-tral Alarm Station (CAS) and the Secondary Alarm Station (SAS) and found them to be in accordance ;

- with Plan comi tments. During tihe previous i inspection (50-293/88-16), a concern was identi-fied that the licensee was diverstag an alarm station monitor from se.curity duty to respond to 1 fire protection system and health physics alaras. '

i During the IAT inspection,- the Team noted improvements in that there is a marked decrease 1 in the number of nuisance alarms, as a result of l the removal of the fire door and health physics ,

doors from the security alarm system. l 3.6.2.21 Communications The Team observed tests of all communication capabilities in both the CAS and the SAS. The Team also reviewed testi .g records for the vart-

ous means of communications available to security

l. force members and found them to be as committed to in the Plan.

3.6.2.22 Training and Qualification - Genera 1' Requirements 1 The Team reviewed tne licensee's Training and J

Qualification Plan and toplementing procedures and determined that they were being implemented as cemitted to in the Plan.

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. l 3.6.2.23 Safeguards Contingency Plan Implementation Review The Team reviewed the licensee's Contingency Plan and implementing procedures and determined that all exercises were being performed by the secur-ity organization as committed to in the Plan.

3.6.2.24 Protection of Safeguards Information The Team reviewed the protection and handling procedures for $afeguards Information ($GI) and determined that the licensee had completed an inspection of each office onsite that handled and stored SGI. The inspection results indicated j

that the SGI assigned to each office was accoun-ted for and was being stored in accordance with established licensee procedures.

3.6.3 Conclusions A comprehensive review of the licensee's security program determined that the licensee has established and is imple-menting a significantly improved securitiy program ever that 4 which existed when the station was shutdown in April 1986.

Upgrades'to the security program include a greatly expanded proprietary, security organization, major installation of state-of-the-art equipment, improved security maintenance support, and upgrades to plans and procedures. .

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! 3.7 Training .

3.7.1 Scope of Review The Team ass assed the scope, quality, and effectiveness of the Itcensee s training programs. Included in this review I were the licensed and non-licensed operator training pro-grams and the programs for technical and general training of the plant staff.

j 3.7.2 Observations and Findings 3.7.2.1 Operations Training .

Operations Training Programs are outlined in PNPS .

Nuclear Training Manual, T-001, Part 3, and have received INPO accreditation. The Operations Training Programs include initial and requalif t-cation training' for licensed operators, initial and continuing training for non-licensed opera-tors, Shift Technical Advisor (STA) training, and SRO certification training. The Team reviewed these programs and discussed various aspects of the programs with members of the licenset's training and operation's staff. The Team re-viewed eight Operator and Senior Reactor Operator

, training receeds to verify compliance with Sec-tion 3.5.5 of the Training Manual. To evaluate the effectiveness of the training programs, the Team observed classroom and simulator training; interviewed licensed operators and senior opera-tors, non-licensed operators and STAS; reviewed several training evaluation and feecback forms from classroom and simulator training conducted -

during the current requalification cycle; and observed ongoing operations in the plant.

Overall, the Team determined that the Operations Training Programs are adeq'.a te and effective.

Classroom and simulator training observed ap-peared to be effective. Instructor preparation was good and the lessen plan content was com-plate. During observations of classroom training for PDC 88-07 involving the degraded voltage modification, the Team noted that the depth of knowledge being presented was adequate and stu-dont participation was encourageo. After cbser-ving the conduct of the annual simulator opera-ting exam, tne Team A 'td improved comunications

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between members of the operating crew. In addt-tion, the Team noted the simulator vnamination '

was also being observed by Itcensee upper manage-i ment. Otscussions with training and operations ,

personnel confirmed that strong upper management j attention and support for all aspects of the i licensed training programs is evident. Inter-views with licensed operators indicated that overall they are very satisfied that training programs are well-suited to their needs, and that the programs are responsive to their feedback.

Operators indicated that the training program has -

greatly improved over the pact year with the .

J incorporation of simulator training into the i i . requalification program.

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! Discussions with Operatier.s Training staff indi- {

l cated sufficient staffing to conduct training !

programs. Thirteen instructors are currently

{ receiving Senior Reactor Operator ($RO) certift- ;

cation training and are expected to be fully cer- i tified by the end of 1988. The use of experi-

. enced PNPS instructors instead of contractors for ;

the operations training programs should enhance !

the quality of the licensee's programs as well as !

contribute to the depth of in-house operational i

{. , expertise, ,

! l Recent additions to the licensed requalification ;

pecgram include the incorporation of Emerge.,cy l J Operating Procedure (EOP) proftetercy training. :

! This includes at least 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months devoted to E0P !

j review in tt. classrcos and/or simulator during !

j each 32-hour segment of the program. (Esch oper- i 3

ator notsally receives one segment of requalifi-cation training every five weeks.) Also, the esas structure at the end of each session has been modified to include written and simulatsr operating exams, which will aid the training

. staff in determining the effectiveness of the l programs on a more frequent basis. In addition,

! the trair.ing staff appears to carefully track I attendance in requalification training to assure that everyone required te attend is trained in

each module of the requalification progets.

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i l The operation's training staff appears to have a :

l very effective working relationship with the l j operations department. They meet to discuss i

training needs on a frequent bests. Through i

these meetings, the training department appears i d able to sufficiently track and schedule the !

licensed training either required or requested to l be completed prior to restart. In addition, the i operation's department often provided support ,

i during simulator examinations, j

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The Team reviewed the licensee's special training 1

program for the sixteen lie:ensed operators (14 R0's and 2 SR0's) who currently hold NRC licenses which are Itaited pending on-watch training dur-

! ing the Power Ascension Program. The Team dis-1 - cussed various aspects of the program with mem- !

bers of the licensee's training and operations ;

s'.a f f. The Team noted that the licensee has ,

t established a structured and supervised pro ram 1 to assure completion of NRC requirements to A low I

! . removal of the individuals' license limitations.

! Following a discussion with the Team regarding l

plans for ensuring that each operator performs a 2

sufficient number of reactivity manipulations, !

j the Itcensee representative stated that an at- ,

tachment to the special program woult.i be added to i

further clarify what constitutes en . acceptable J aanipulation. l l

2 The Team observed the operations department [

l staff on fuur days of consecutive shtft rotation. ;

1 These observations verified the overall effec- !

ttv.nesi of training. For e aspie, on-shift

] communications, an area of emphasis in simulator i

training, was formal and effective. However, i i during a walk-through with an equipment operator r j (non-licensed) of E07 Satellite Procedure 5.3.26, !

j the Teas noted several discrepancies in the pro- !

4 cedure. It also noted that the EQ and an 5R0 !

J aisunderstood a step in the procedure. Upon i l investigation of these problems, the licensee

{

determined that a decision to train only the E0's

and not the licensed operators on the field por-i tion of the satellite procedures contributed to (

the misunderstanding. These issues are discussed

)j in detail in Section 3.2.4 e

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. Additional Team followup of the problems found -

during the above-mentioned procedure walk-through identified a weakness in the licensee's method of determining the need for additional training on new procedures and procedure changes. The lican-see's current method incorporates review of ORC netting minutes to determine newly approved pro-cedures or procedure changes requiring training.

However, a de. lay of 30 to 45 days is not unusual i between the meeting and the distribution of for-1 mal minutes. For example, Procedure 5.3.26 had -

! been revised since equipment operator training l was conducted in March and April 1988. The CRC meeting minutes which addressed this procedure

. change had not been received by the training i -

departwent as of August 18, 1988, 42 days after the CRC meeting on July 6,1988.

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j The Teas discussed the issue with a licensee l

train!ng department representative who stated

.that the department recogni:ed this concern and 1 was preparing to implement, in October 1988, a more timely method for determining the needed training, Ouring the insoection, the licensee committed to accalerate impleuentation of certain features of i the impro-ed program, such that the training !

! department will become aware o' procedure changes :

J within approximately one day following the ORC t j meeting. This will allow the training staff the i opportunity to review the procedure changes and determine the need for training prior to issuance ,

of the approved procedure. If the training

department determines that training is required prict to issuance of the procedure, the depart-sent will have the ability to delay the proced- .

I ure issuance. The licensee representative stated '

that an internal work instruction detailing this process was being written and would be approved i by ORC within about a week. In addition, the I training staff will review their backlog of ORC l meeting minutes to determine which procedure i

changes have not been addressed and will take l appropriate action. These actions planned by the l Itcensee appeared very responsive to the Team's i concerns. '

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87 3.7.2.2 Technical and General Training i Nuclear Training Mann1. T-001, Parts 4 and 5 ,

outline the Itcensee's technical and general

training programs. Included are training pro-grams in maintenance, health physics, cheatstry, fire brigade, emergency plan, supervision, and ;

technical training for staff and managers. The ;

Team reviewed these programs and discussed var- l l fous aspects of them with members of the licen- l see's training, technical, and supervisory staff. l To evaluate the effectiveness of the training programs, the Team observed classroom instruc-tion; interviewed radiological controls and !

l radiological chemistry (radches) technicians, QA i l engineers and first-line supervi sion; reviewed '

cit.ssroom training evaluation and feedback forms; i and'cbserved ongoing work in the plant.,

k Overall, the licensee's training programs were f

found to be adequate. Classroom training ob- [

l served appeared to be effective and student '

participation was strongly encouraged. In-house .

j staffing fcr those training programs appearec [

more than sufficient. The following relatively j new training programs are indicative of licensee l j initiatives to develop employee ski,11s: l 1

apprentice programs for maintenance, health physics, and rad ches technicians; and, j --

technical training for newly assigned supervisors. 1 i

) Additional training programs currently being i developed in industrial safety and safety aware-J ' ness, along w'ith the licensee's CPR program, show i the licensee s positive attitude in tho:e areas. i I. The Tean's observations of work in the plant dur-1 ing this inspection verified the overall training

. effectiveness. However, inadequacies in mainten-

! ance post-work testing appeared to be the result of lack of training for the maintenance planning j group and first-line supervisors on the post work

. testing portien of the new maintenance program l (See Section 3.3.2.6).

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88 3.7.3 Conclusions The licensee's training programs appear to be very good.

Team findings in all functionti areas indicated overall effectiveness of the training implemented. Examples of areas where training may have needed to be conducted sooner include E0P satellite procedures and the post-work testing program. A weakness was identified in the licer. see's method of determining training needei for new procedurec and procecure changes.

The licensee appears to have made a strong commitment in the area of licensed operator training, as exemplif ted by increased stsffing, simulator use in requalification train-ing, strong interface between training and operations man-agement, and increased attention and support from vpper management. In addition, the creation of new programs for supervisors and apprentices reflects an effert by the licensee to effectively promote employee developeant.

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3.C Fire Protection i

3.8.1 Scope of Review ;

! The Team's evaluation of the fire protection program t i focused on the maintenance .of fire protection equipment, !

j the reliance on compensatory measures for degraded equip-ment, and the performance of personnel on the fire brigade .

1 and standing fire watches.

} 3.8.2 Observations and Findings l

' I Licensee senior management established a station goal of reducing the number of open fire protection corrective i maintenance requests (MR's) to 40 from a high of 300. This !

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. goal was reached in June 1988. This reduction is indica- l l

tive of the overall improvement of the material condition ;

a of fire protection equipment and systems. The number of ',

1 MR's began climbing two weeks before the IAT inspection, q and reached 63 during the second week of this inspection, j The increase was mainly for low priority MR's.

Fire protection MR's are tracked as a station performance indicator and this increasing trend received prompt senior j management attention. The licensee is currently contract ,

ing to bring in additional fire protection maintenance sup- '

] port by the end of August 1980. The fire protection man-ager meets daily with operations, maintenance and planning j sections to schedule MR's and doulop the station's work l

plan. The Team concluded that the Itcensee is giving j proper management attention to fire protection MR's. '

I a There are over 5,000 fire barrier penetration seals at PNP 5. The licensee's tagging system has been effective in !

identifying these penetrations, with no untagged penetra- l 1

tions or degraded penetration seals observed by the Team.

! The number of fire watch postings has been reduced from 145

! . a year ago to 45 prior to this inspection. Fifteen of

, these remaining postings will be eliminated by changes to the fire protection program which are currently being reviewed by NRC, Another twelve will be eliminated when the licensee completes Engineering Services kequest (ESR) j 84-339, "Alara delays on non-vital CAS alarms." This ESR

will provide a means to electronically monitor fire doors j without undue distraction of security personnel from their

. ortsary function. The remaining 18 fire watch pestings are j due to degraded equipment for which repairs are currently 1 being planned.

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i Secause T5's allow one individual to rove and cover more i than one fire watch posting, the number of people on shift committed to fire watch activities is substantially lower than 45. Two personnel per shift are assigned to cover these fire watches. In discussions with the Team, the fire ,

watches appeared knowledgeable about their duties. The I Team reviewed several fire watch postings in the plant and

identified no concerns. All fire watch rounds were com- !

pleted on schedule.

l The Team observed the on-shift fire brigade respond to an unannounced fire det11. .The drill scenario was a simulated l main transformer fire with a concurrent failure of the j deluge system. The brigade leader developed a successful i fire fighting strategy. The brigade members responded !

j promptly in full fire fighting gear. Communications be-tween the brigade and the control room appeared to be ade-j ouate. The fire brigade's first-line supervisors observed

. the drill on their own initiative. The fire protection j training instructor was also found to be knowledgeable and

enthusiastic about the training program.

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j 3.3.3 Conclusions

Effective management by the fire , protection manager and support by senior management are shown by the attention given to the, material condition of fire protection equip-i ment and reduced reliance on compensatory measures for !

degraded equipment. Completion of licensing actions and an i l ESR will further reduce the number of fire watch postings.

j There is good identification and control of fire barriers.

] Personnel assigned fire watch and fire brigade duties are

knowledgeable about their duties and perform them properly.

1 The fire protection division is well staffed to meet i program needs, i

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l 91 3.9 Enoineerino support 3.9.1 Scope of Review NRC found if censee engineering support to be strong in the past two SALP reports. Because of this history of good l

performance, engineering support was not selected as a specific area of focus for this inspection. Instead, observations relative to engineering support were made by the Team while it inspected the other functional areas.

3.9.2 Observations.and Findings The Team found that engineering support to the facility is generally very effective. In particular, the Systems Engineering Division functions well to meet plant needs.

Also, engineering support to maintenance has improved and is enhanced by the improved maintenance work process and the effective performance of the maintenance engineers.

The Team noted that a number of technical issues, including some NRC open items, as well as licensee-identified items. '

- require NED resolution before plant restart. .They are being tracked and pursued for resolution by NED.

During tours of the control room, the Team noted the mini-mal use of certain human engineering features, such as 4

color-codes, meter "banding" (e.g., marking of normal, alert, and fail positions on meter and gauge faces), and system lineup memory aids. Based on discussions with NED personnel, the Team determined that the licensee performed a detailed control room design review (DCRDR) and received a

comments on it from the NRC Office of Nuclear Reactor Regulation. A supplemental iteensee DCROR report is required four months after the end of the current outage.

Currently, the licensee's DCROR project has identified about 140 proposed human engin'eering improvements which are being evaluated and prioritized. A few were incorporated into design changes this outage. The Team noted that some of the remaining improvements were relatively simple, from !

an engineering perspective, but could significantly enhance control room human factors. The Team asked whether imple-mentation of some of these items could be accelerated rela- i tive to the other, more complex items which may require more detailed engineering and a plant outage to install.

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92 1 The licensee indicated that these simple improvements, categorized by the licensee as "Paint-Label-Tape," are included in the current 1989 budget. The licensee also committed to evaluate control room human factors during the Power Ascension Program and to include an update regarding the schedule and scope of these "Paint-Label-Tape" items in their report to NRC at the completion of the Power Ascen-sten Program. The licensee was very responsive on this issue. The Team noted that (1) licensee personnel have performed well in the simulator under NRC observation, and (2) there has not been any pattern of performance problems traceable to control room human factors. Thus, the Team concluded that the licensee's approach to this issue is acceptable.

The Team reviewed the licensee's program for the control of transient materials. This review included the licensee's methods for identifying, tracking and removing non-perman-ent equipment such as tools, gas bottles, and scaffolding located in plant areas where safety-related equipment is housed. The licensee currently assigns responsibility in this area to~the Systems Engineering Group (SEG). Station Instruction SI-SG.1010. "Systems Group Systems Walkdown and Area Inspection Guidelines," details the licensee's. program for controlling transient materials. Materials so identi-fied during weekly walkdowns by system engineers are docu-l mented and are either removed or their presence justified in writing. If the material is allowed to remain in the process building, a seismic missile hazard analysis is per-formed under Station Instruction SI-SG.1015 "Potential Seismic Missile Hazard," and appropriate measures are implemented to ensure that the materials are properly

. secured. The licensee is compiling a data base which identifie. transient materials which must be removed prior

! to startup. The program appears to be comprehensive and adequate.

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i During plant tours, the Team questioned th'e licensee con-corning the installation of splash shields and personnel

. barriers in the areas of safety-related instrumentation.

Specifically, the Team questioned the seismic responsa of the structures and the effect they may have on safety-related structures. ,

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93 The fire water spray shield was installed during the cur-rent outage. This plant design change was processed under current licensee procedures which require a seismic .

response analysis prior to modification approval. Person-nel barriers installed during the mid-1970's recently had seismic analyses performed on their current configurations.

. These analyses found them satisfactory.

Based on this information and on a review of licensee docu-mentation, the Team had no further questions.

3.9.3 Conclusions The Team concluded that engineering support continues to be effective and Identified no weaknesses. The licensee has committed to evaluate potential near-term improvements in control room human engineering during power ascension testing.

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94 3.10 $_afety Assessment /Ouality Verification ;

3.10.1 Scope of Review. i j The objective of this inspection was to evaluate the effec- l

, tiveness of the licensee's self-assessment programs. The >

inspection focused on determining whether these programs !

l contribute to the prevention of problems by monitoring and '

evaluating plant performance, providing assessments and i' findings, and communic: ting and following up on corrective action recommendations. The inspection consisted of a i documentation review, pe;sonnel interviews, and observa-i , ,

tions of meetings and work.

! 3.10.2 Nuclear Safety Review and Audit Committee ,

l The Nuclear Safety Review and Audit Committee (NSRAC) is an l independent body responsible for performing senior-manage- ,

ment-directed reviews of activities affecting nuclear i

safety. The N5RAC reports to the Senior Vice President - ,

Nuclear ($VP-N). Membership on the committee is composed i j of senior licensee management personnel augmented by consultants.

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4 The Team reviewed the NSRAC procedures manual, Technical l Specification 6.5.5, meeting minutes, audit reports, and -

1 associated NSRAC reports and correspondence. The Team also .

j attended a full NSRAC meeting at the station on f 2

August 2, 1988. !

! r A review of the committee meeting minutes for the period l J between January 1967 and June 1988 varified that Technical ;

. Specification requirements have been me', with respect to '

l the composition, duties, meeting frequencies, and responsi- '

bilities of the committee. The composition and charter of

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the comittee was significantly revised in February 1988.

1 The selection process for members was designed to assure a

broad-based, independent review of facility activities and to minimize the potential for cost and schedule pressures i ,

to influence the committee's reviews and findings. The I

current comittee is made up of ten members appointed by the SVP-N. Of the ten members, five are consultants, in-cluding the Committee Chairman. Only two members of the j connetttee hold line responsibility for operation of the i plant. Only one serber, also a consultant, belonged a year

{ ago. To enhance the perspective of the new memoers, the licensee implemented an annual training program. The Team

. was providec with a matrix indicating t,he experience of I

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95 current committee members relative to Technical Specifica-tion requirements ind verified the committee collectively -

possesses a broad based level of experience and competence.

The committee charter, as detailed in N$RAC Procedure 101-1, also coes not allow the use of alternate sobers, although these are allowed by the Technical Specifications. !

After a review of recent membership changes, and discuss- -

ions with the NSMC Coordinator, the Team verified that the -

collective competence of the committee membership has been maintained as changes were made.

NSMC currently conducts meetings approximately once a month. Since the beginning of 1988, seven meetings have ;

been conducted, six of which were held at the site. This l is significantly more than the once-per six-months m19tmum required by the Technical Specifications. Three additional ,

meetings are scheduled for 1988. In addition, individual i subcommittees may hold additional meetings at the site. .

N$RAC also intends to meet at the site in September with several Ley serbers of station management to review restart preparations and plans to provide its own independent recomendations for restart readiness. !

N$RAC uses subcomittees ef f ectively to review specific- !

areas of interest. Currently, six subcomittees are estab- i lished: (1) safety evaluations; (2) operations /mainten- ;

ance; (3) training / security / fire protection; (4) radiation !

control /chemisty/ emergency preparedness; (5) quality over- '

view; and, (6) engineering / technical. Each subcomittee is .

chaired by a N$RAC member, and is composed of additional !

personnel appointed by the committee. The subcommittees i provide reports to the full comittee during their sched- :

uled meetings. The subcomittees are especially useful is '

l performing documentation review to allow more time for open i discussions at the meetings. l l

A stronger N$MC involvement in station activities is evi- !

dont not only in the recent site meetings and effective use of subcommittees, but also in scheduled site tours and audit participation. The N$4AC has established a schedule for individual committee members to perform station tours '

and report the results to the full committee. N3RAC has also designated individual mesters to participate in se1ected QA audits throughout the year.

The Team reviewed selected audits condected under the cognizance of N$RAC, which are required by Technical Specifications. The audits reviewee were thorough, timely,

'and the noted deficiencies have teen corrected or are being tracked. The audit reports reviewed included a third party assassment of the adequacy of the QA program, and QA audits

. l l

l 96 l

of Technical Specifications, administrative controls, operations, chemistry, radiation protection, anr1 inservice testing. In addition, special audits were recently con- i ducted concerning shutdown from outside the control room, the salt service water system, and N5RAC activities.

The current committee has an effective formal tracking !

system for all "concerns" forwarded to sanagement and com- l eittee followup items. The "concerns" reviewed were {

clearly transmitted to the 5VP-N. However, review of l recent meeting minutes by NRC revealed that a amber of !

"recommendations" had been forwarded to the SVP-N, but a i formal response had not been received. The committee also i did not formally track resolution of these recommendations. !'

Further investigation by the N5RAC Coordinator determined that although the items had not been tracked, the specific -

recommendations had been implemented, or were incorporated into. anet.her corrective action process. '

r During N5RAC Meeting 88-04, conducted on May 24, 1383, the Operations and Maintenance Subcommittee presented a. report !

on the conduct of the Operations Review Committee (CRC). ;

N5RAC raised concerns over whether the CRC was fully meet- t ing the intent of its duties required in the Technical Specifications. The report identified four specific find-ings of deficiency. They included:

Inadequate method of reviewing changes to safety-related procedures; j

- Lack of ORC prepared reports resulting from CRC inves- !

tigation of a Technical Specifications violations; j

- Lack of specific review and reports of fact 11ty oper- l at. ions by CRC; and. l

- Latk of formality in the conduct of ORC meetings. l t

After the discussion, N5RAC concurred that the CRC perfors- '

ance issues should be formally raised as a concern to the SVP-N. The N5RAC concern (44-04-01) was transmitted to the :

SVP-N on May 27,1984. The concern stated that NSRAC's j overall assessment was that CRC's conduct and administra-tien needed substantial taprovement. Specifically, the concern stated that the established process did not appear to foster adequate depth and disciplins for substantive independent reviews. In addition, N5RAC noted that of the 40 meetings ccnducted in 1983 prior to the review, neither the Station Director nor the Plant Manager hac attenced, based on its revi w of the meeting minutes.

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97 4 ,

i l The N$RAC concern was responded to en June 22, 1988. In ,

. response, the Station Of rector initiated revisions to the l 1 CRC Charter and Procedure 1.3.4, "Frecedures," to accur- i l ately describe the specific methods by which ORC met the )

l procedure and operations review requirements. In addition, ,

, the Station Director attended an ORC meeting on !

June 22, 1988, and is considering additional initiatives to ;

! improve the conduct and administration of ORC activities. l N$RAC closed the concern at the August 2, 1988 meeting, but initiated a followup ites to continue to monitor ORC per-formance. In addition, N$RAC members were encouraged to attend ORC meetings as observers. NRC's review of CRC per- :

formance identified similar deficiencies and concluded that i j additional actions to strengthen some CRC functions were '

4 warranted (See Section 3.10.3). !

! Based on meeting attendance and review of recent meeting !

minutes, the Team noted that the NSRAC reviews have been l l thorough and focused on improving performance in areas ;

important to safety. During the August 2, 1g88 N$RAC meet- l ing, the Team noted that the discussions were frank and l

.l-open, with the reviews concentrated on recurring and emerg- 1 ing issues. The areas of emphasis have included 50.59 ,

reviews, ORC performance, corrective action programs, pro- ;

cedure adequacy, ard management depth, j i

Due to the limited number of "concerns" tasued by NSRAC !

since reviston of the committee in February 1988, the Team ;

I could not reach a conclusion on 'the responsiveness of the i j station organization to N5RAC. It appears at least in one l 1

case pertaining to ORC performance, that the response was l not comprehensive. However, all other "concerns" reviewed !

were responded to adequately.

l 3.10.3 Operations Revtew Committee ;

The function, composi tion, and responsibilities of the ;

i Operations Review Connittee (ORC) are described in PNPS '

' Technical Specification 6.5.A. In addition, pHP5 Procedure

! , 1,2.1, "Operations Review Committee," describes in great.or detail the authority and responsibility of tre CRC at the l

, Pilgrim Station. For this inspection, the Team reviewed :

the minutes of ORC meetings 84-40 through 44-60 (April 1,1984 through July 5,1984) and observed the con- l

i l duct of three regularly scheduled and two special ORC meet- ;

ings (CRC Meetings 84-80, 81, 42, 83 and 86). In addition, l

the Team interviewed various CRC members and alternates.

i l l 1 l

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98 l

The inspection focused on whether ORC operations satisfied current Technical Specification requirements; whether the ORC was meeting its responsibt11ttes identified in PNPS Procedure 1.2.1, and whether the ORC was responsive to recommendations for improvements identified during N5RAC and QA audits of its operations.

3.10.3.1 Compliance with Technical Specifications and Procedures By reviewing existing documentation, and through direct observation of ORC meetings, the Team has determined that the Technical Specification i

requirements for the CRC composition, quorum, meeting frequency, authority, and records are being sttisfied. During the period reviewed, the Team noted that the ORC reviewed plant proced-ure changes, plant design changes (pDCs), Field Revision Notices (FRNs), and Licensee Event 1

Reports (LERs), as well as proposed revisions to i the security pian, to the inservice inspection program, to the emergency plan and to fire pro-1 tection program implementing procedures. The ORC members and alternates are appointed by memor-andum from the Station Director and cannot serve 2 on the committee until they have successfully

completed the station ORC training course. There is also a required reading review program used by the Training Department as a retraining program for ORC members and alternates. The Team re-viewed the training course material and deter-mined that it had an appropriate emphasis on assuring safe operation as well as on regulatory requirements. .

The ORC at Pt igris: Station has been meeting reguiarly every Wednesday ard has a scheduled "special" meeting every Friday on an as-nsMed basis. The ORC mt an average of about twice a

. week, which is we11 above Technical Specification requirements.

While there was evidence in the minutes of dis-cussions about LERs, POCs or FRNs, the prepond-erence of the minutes described changes to pro-cedures. The Team saw no reference of CRC reviews of Failure and Malfunction Reports. The ORC has a system for following issues identified during discussions which requires a formal response to t.he CRC and a review of the response by tne CRC to assure that the response resolved the initial concerns.

99 !

l l

- The Team reviewed the closecut process for ORC !

followup items and determined that, in one case, l an item (88-58-01) may have been closed prema- !

turely. During a discussion among the Team, the l ORC Chairman, the Design Section Manager, and the Construction Division Manager, the ORC Chairman agreed that the item should be re.sened for addi-tional review. During ORC Meeting 88-82, the item was reopened.

By observing the ORC, the Team concluded that the committee members and alternates are concerned with assuring the safe c.eration of the facility.

Discunions focused on che impact of items on

- safety systems, as, well as whether the items being discussed met regulatory requirements or' constituted unreviewed safety questions. The Station Director also attended one of. the regu- !

larly scheduled ORC meetings during the inspec- l tion period.

. During its review, the Team identified two weak,-

nesses in the operation of the ORC. They are the Technical Specification (TS) review of plant operations (T.S. 6.5. A.6.e) and the TS require-ment to investigate violations and prepare a report coveri'ng the evaluation and recommenda-tions to prevent a recurrence (T.S. 6.5. A 6.1).

TS 6.5.A.6.e states that the ORC is responsibla for the review of facility operations to detect potential safety hazards while TS 6.5.A.6.1 states that the ORC is respinsible for investiga-ting all TS violations and for preparing a report covering the evaluation and recommendations to prevent a recurrence.

The Team noted that ORC routinely uses the review of LERs and Failure and Malfunction Reports (F&MRs) to sati sfy the TS required review of plant operations and TS violations. The Team also noted that the ORC has appointed the Compli-ance Division as a subcommittee to.the ORC and assigned it the responsibility of presenting selected Failure and Malfunction Reports as well as the preparation of all LERs, including any

100 involving TS violations. Copies of all LERs are provided to the ORC as a means of satisfying the TS requirements. Further, PHPS Procedure 1.2.1 ' permits the ORC Chairman to set the time-11 ness of subcommittee reports to the full ORC.

While the use of subcommittees to support ORC activities is acceptable, the Team believes that the method used by ORC in fulfilling its respon-sibilities as defined by TS 6.5.A.6.e and i needs improvement. In. particuiar, the Compliance Ohision has been issuing all LERs, including '

those discussing TS violations, prior to any ORC review of the product prepared. A review of 10 LERs disclosed that ORC review of the LER occurs usually a week to two weeks after the LER was formally sent to the NRC. While this may satisfy l the timeliness requirements of PNPS Procedure 1.2.1, it does not appear that the corrective actions proposed to prevent recurrence receives the full benefit of a timely multi-disciplinary review, as is intended by the composition and responsibilities of the ORC. The formal release .

of the LER involving a TS violation by the ORC l subcommittee without a formal -eview by the com- '

plete ORC is a weakness in meeting the require-ments of TS 6.5.A.6.i. .

During a review of F&MRs, which had not yet been reviewed by ORC, the Team noted that F&MR 86-266, which discussed a TS violation, had not yet been reviewed by ORC.

In this case, the vinlation was against an admin-istrative requirement in TS Section 6.8, and was not reportable as an LER. Therefore, the F&MR did not result in an LER or a special report.

The event occurred in September 1986,' and no reports have yet been submitted to ORC as i required by the TS. The licensee stated that the l F&MR was still open pending completion of the I remaining corrective action, and that then a report would be issued.

Both of these findings indicate that the ORC is not actively participating in the timely review of plant operations and does not appear to pro-

' vide meaningful input into the process.

101 3.10.3.2 Responsiveness to Audit Recommendations The Team reviewed both quality assurance (QA) audit findings and NSRAC reccamendations to determine ORC responsiveness to recomendations for improvements to its operations. In QA Audit Report 87-37, QA listed two recommendations accepted by the ORC. PNPS Procedure 1.2.1 was '

reviewed and the Team determined that PNPS Pro-cedure 1.2.1, Revision 21, contained the QA

. recommendations. The ORC was also audited by QA from May 22 through June 22, 1988. The audit generated one recommendation concerning the cross-referencing of ORC meetings with document references. Based upon discussions between the QA auditor and the Team, ORC has also accepted this recommendation.

In May 1988, the ORC received a li'st of four concerns from NSRAC based upon an audit review of the ORC. While the nature of the specific con- '

1 cerns are r:.ussed in detail in Section 3.10.3

'above, ths,. sre , summarized here. Spe-ifically, the NSRAC expossed concerns about the f311owing areas: (1) the ORC review of changes to safety-related procedures, (2) ORC investigation cf TS violations, (3) ORC review of facility op6ca- 1 tions, and (4) conduct of ORC meetings.

The concerns related to the ORC's investigation of TS violations and its review of plant opera-tions are paralleled by the Team 5 findings dis-cussed in Section 3.10.3.1 above. .

The NSRAC concern with ORC procedure reviews is being evaluated for long-term improvements but no definitive action is currently planned by the licensee. As for N5RAC concern #4, the meetings observed by the Team, were conducted in a manner i permitting formal and informal discussions of speci fic ' issues. A meeting agenda for regular ORC meetings was prepared and followed. The Team i concluded that the meetings were conducted !

acceptably.

Based on the above, the Team has dctermined that, in general, the ORC has been receptive to recem-mendations for improvement. However, the fact that the NSRAC concerns remain unresolved sug-gests that the ORC may have difficulty addressing more complex recommendations.

. . _ - - _ . - , - _ . ,,-__.e -_,_.___,__.__,.__,.___p-

__ -_, ,,,.--_,.---.v.-

l l l 102 The Team also observed that the quality of the '

meeting minutes could be improved by providing more discussion of the issues by the various ORC members as opposed to providing abstracts of the documents discussed.

Based upon 'a review of the ORC activities, the Team determined that there are weaknesses in. the implementation of responsibilities assigned to the ORC. In particular, the Team determined that weaknesses exist in the review of plant opera-

tions and the investigation of TS violations. l The Team has concluded that improvements in these two specific areas would result in a more effec-tive ORC. In response to the Team's concerns, the licensee agreed to take certain actions prior to restart to strengthen the operational focus of ORC. These actions are: (1) to review plant i incident critiques; (2) to review LER's prior to their submittal to NRC; (3) to review FW4R's on a regula basis; and, (4) to provide for a monthly presentation and discussion of plant operations l as a siccific agenda item. The Team found these

. licensee commitments responsive to its corcerns.

3.10.4 Quality Assurance Audit and Surveillance Programs The Team reviewed selected QA audit and surveillance reports, selecting specific findings, discrepancies, and observations for followup of the licensee's corrective action process. QA personnel, including the QA Department ,

(CAD) manager, and other station managers and engineers, were interviewed regarding the audit and surveillance pro-gram objectives and overall conclusions which can be drawn f rom the. audit and surveillance findings. The Team also reviewed the quarterly QA0 Trend Analysis report, and at-tended s.everal QA interface meetings. Portions of the Boston Edison Company Quality Assurance Manual (BEQAM) and applicatile station procedures were also reviewed.

The technical content and quality of the issues raised in the wlected audit reports were orcellent. The conduct of a W iormance-based radiological controls audit by outside consultants was noteworthy. Specifically, the Team re-viewed audits required under the cognizance of NSRAC, in accordance with the TS, and found that they are being per-formed as required. The Team determined that all defici-encies icentified in the audits were either closed or ade- l quately tracked by a formal system. l 1

103 ,

During the conduct of audits and surveillances, deficiency reports (OR) are issued by QA for conditions contrary to management policies and procedures, regulatory require-ments, or Itcensee commitments. A DR which reports a def tetency identified during a QA audit is issued at the time of the audit exit interview. The licensee has an effective system of requiring'a written response to the OR within a specified perf od, dependent on its significance, and for subsequent followup of corrective action. A system also exists for granting extensions through an escalation process to 9pper management.

QA prepares a monthly status report, including OR status, which is forwarded to senior management for appropriate actions. Review of the niost recent QA trend report indi-cated a decline in the OR backlog, an increase in the num-ber of DR's completed on time, and few extensions needed for OR closecut. The number of deficiencies reported by QA remained fairly constant. These are all indicators that licensee management attention to the corrective action process has had a positive impact.

I The licensee also effectively trends Immediate Corrective Actions (ICA), which are identified in audit and surveil- ~

1ance reports. These report conditions which could lead to 1 a DR, but which are corrected prior to the end of the audit ;

or surveillance. They also are tracked along with the OR's. The Team also found the tracking of recommendations from the audits and surveillances to be effective. I Approximately 45 QA surveillance reports concerning obser- I vations of surveillance testing were reviewed. The reports j were well planned, well documented, and thorough. Again, the tracking and followup of identified deficiencies were adequate. A minor concern of the Team involved QA followup to identified procedural inadequacies during surveillances.

In ten of the surveillance activites reviewed by NRC, technical procedure deficiencies were identified by QA, but since the technicians being observed halted the test and pursued a procedure change, no deficiency reports were issued. Further review found that the majority of the pro-cedure deficiencies were identified prior to implementation of new procedure validation program, and that QA0 has an open DR on the procedure validation process. QAD is con-tinuing to monitor the process. The Team had no further concerns.

104 Two QA Interface meetings were attended during the inspec-tion. The meeting attendees include representatives from QA, plant staff, and engineering. They meet weekly to review the status of various corrective action items, including DR's, Management Corrective Action Requests (MCARs) and Potential Conditions Adverse to Quality Reports (PCAQ's). The meetings have improved communications among the organizations and have contributed to the more timely resolution of corrective action items.

3.10.5 Corrective Action Process and Programs The Team reviewed the licensee's programs currently in place to identify, follow, and correct safety-related prob-less. A newly formulated Corrective Action Program "Clear- -

inghouse," and proposed revisions to corrective action pro-cess pro:edures were also evaluated with respect to the ,

current objectives and planned initiatives to improve cor-rective action program effectiveness. Samples were chosen from each of the programmatic areas where problem identifi-cation is routine and implementation of corrective measures is required. Each of these programs is discussed oelow.

The Team interviewed licensee personnel responsible for !

individual program management and implementation, 'as well I as the technical personnel accountable for problem dis-position and corrective action adequacy.

For all of the areas evaluated, the Team sought to deter-mine the effectiveness of the licensee's process for root cause analysis of problems, investigation of problems and causes for their generic applicability, and trending of findings to prevent their recurrence. Selected issues were analyzed to understand the technical problems, check how they were programmatically handled, and to determine whether the corrective measures were appropriate to the specific cases. The examples are cited in the following

. subparagraphs not only to illustrate the scope of licensee activities inspected, but also to support the conclusions I reached regarding the corrective action program effectiveness.

3.10.5.1 Failure and Malfunction Reports The Failure and Malfunction Report (F&MR) is a process by which failures, malfunctions, and abnormal operating events are reported, svaluated l and corrected to preclude repetition. The pro-cess is described in: Nuclear Organi:ation

= _ _ . . _ - _ - - - _ .

105 Procedure (NOP) 8305, the "Failure and Malfunc-tion Report Process;" PNPS Procedure Number 1.3.24, "Failure and Malfunction Reports;" and PNPS Work Instruction N8-3.2.12, "F&MR Trend Analysis."

Team review of licensee procedures verified that responsibilities are established for the F&MR process; reports are prioritized by safety sig-nificance; underlying root causes are evaluated; reports are tracked for completion of corrective -

action; and, trending for repetitive problems is performed. A report may be initiated by any licensee staff member for failures, malfunctions, and abnormal operating events identified during station operation. The Nuclear Watch Engineer ensures that adequate compensatory measures are implemented and the required notifications are performed. The Compliance Division Manager then reccamends a lead group to perform the investiga-tion and performs a reportability review. The appropriate department manager is responsible to ensure that the identified deviations are pro-perly resolved and that corrective actions are planned and effectively implemented in a timely manner. The department manager is also responsi-ble for the review and approval of the reporta-bility, root cause analysis, corrective action plans, disposition, and final closecut. A root cause analysis is performed for those F&MR's ,

determined to be significant. The term "signift- l cant" applies to a condition adverse to quality '

which merits further evaluation for cause and requires management attention to preclude recur-rence. The nonsignificant deviations are evalu-ated in a periodic trend analysis. ,

The Team identified several discrepancies in the admir.i stration of the F&MR process. Procedure 1.3.24 states that the Compliance Division Manager is responsible to present F&MR's that are designated significant or important. to ORC. As I discussed in Section 3.10.2, the Teps noted that j the ORC meeting minutes for the previous six months did not record the review of any F&MR's.

Further Team review found that a backlog of over

1 l

l 106 existed, and that no F&MRs had been submitted to ORC since February 3, 1988, except for those associated with an LER. Some of the F&MR's involved events which occurred in 1986. The licensee stated this was caused by personnel ,

resource constraints. The Team also found two i

closed F&MR's which appeared to meet the criteria '

established in Procedure 1.3.24 for being submit-ted to ORC, but which had not been submitted prior to closure. F&MR's88-127 and 88-76 were !

not reviewed by ORC, but involved recurring con-ditions, which is a criterion for ORC review.

In addition, many of the closed safety-related F&MRs were , denoted not safety-related by the Watch Engineer during the initial review process. i This mis-classification; however, did not affect l the processing and evaluation of the associated events for those F&MR's inspected. ,

The Team reviewed a listing of open and closed F&MR's and evaluated a sampling of closed reports to determine the completeness and effectiveness of the corrective actions. The total number of F&MR's initiated has been increasing over t N, last few years. The licensee has attributed tnis increase to a heightened sensitivity of personnel to critical self-assessment and to the identifi- l cation of ootentially reportable or significant !

events to management. The total number of open F&MR's has significantly decreased over the last ;

year.

I The root cause analyses performed for the F&MR's reviewed were found to be of excellent quality.

Each analysis thMed an event description, probable cause, acti u completed, recommended actions, and safety signti m v a The Systems Engineering Group's impact on this important process has been positive.

The Team reviewed the latest F&MR Trend Analysis i Report, which covered the period July through 4

Dec6mber 1987, and the applicable procedures.

The Team noted that the station's Technical Sec-tions did not specifically assign responsibility for the report's proposed recommendations. Fur- l ther review found that this program deficiency had been previously identified by the licenseo l and the NRC and that the licensee had initiated corrective action, Specifically, a review of all j previous trend rwoort recommendations was per-formed by the licensee to cetermine their status.

_ _ _ . _ , .. _ _ _ 1

107 l The review was completed in July' 1988, and 7A% of the recommendations were corrected. The remain-ing items are currently being dispositioned by the licensee to ensure effective long-term cor-rective action. In addition, the licensee has revised the F&MR procedures to include use of the Management Corrective Action Report (MCAR) as a vehicle for the Technical Section to report and correct negative trends identified in the re- !

ports. The most recent trend report resulted in t!,e issuance of two MCAR's, which the Team reviewed.

The Team also noted that the trend report focused

- its discussions primarily on indi.vidual problems rather than trend patterns and recurring fail-ures. The Team observed that the Technical Sec-tien would be more effective if it thoroughly evaluated trends and patterns, since 'the indi-vidual F&MR itself is adequate to evaluate iso-lated problems. In addition, the report did not provide any detailed discussion of personnel

' errors or procedural failures, although there were a large number in the report.

3.10.5.2 Potential Conditions Adverse to Quality As described by PNPS Nuclear Organization Proced-ure (NOP) 83A9, "Management Corrective Action Process," the potential conditions adverse to quality (PCAQ) report can be used by any licensee ,

member to document and report any actual or sus-pected conditions adverse to quality not reported by other report forms such as NCRs, ors, and F&MRs. In short, it is a process for anyone to elevate a concern to management to assure that j the concern will be evaluated and resolved. j As implemented, PCAQs are written from one department to another or from one section to another within a department. For example, Oper-ations (N00) could send a PCAQ to Engineering ,

(NED) asking for an evaluation of a specific l plant condition. In each case, the originating department is responsible for tracking each item l to resolution. According to NOP 83A9, a PCAQ is not formally closed until the originat ing depart-ment is satisfied with the proposed corrective action and the corrective action has been implemented. l l

i

i 108 The Team reviewed a listing of open and closed PCAQ's and also reviewed a sampling of individual PCAQ's to determine the completeness and effec-tiveness of corrective actions. As of August 19, 1988, there were about 250 PCAQs awaiting resolution. There is currently no cen-tral tracking system for all PCAQs, although licensee mansgement has begun initiatives in that area. In June 1988, the licensee began an effort to reduce the number of open PCAQ's and to estab-lish a central tracking system for PCAQ's with the QAD. As part of this effort, each department is reviewing unresolved PCAQ's to evaluate each one's' significance and its potential impact on .

restart. Based on discussions with responsible managers, the Team I?4rned that QAD has completed '

its review and concluded that none of the unre-solved PCAQ's concern equipment operability l issues or are of a significance level that re-quires action before restart. NOD has not com- !

plated its evaluation but expects to be finished i within two weeks. NED has been implementing a j routine review of each unresolved PCAQ and has been maintaining a list 6f PCAQ's needed to be resolved prior to restart. The review of out-standing pCAQ's is an item on the restart check-list maintained by the plant. Subsequent check-list review by' ORC also provides a decision point in the process to assure that all necessary evaluations have been completed.

Based on the above, the Team has concluded that the licensee is assuring that each PCAQ is being evaluated for its nuclear safety and equipment operability impact relative to the planned restart of the plant and that all PCAQ's needed for resolution before restart will be identified.

The ORC review of the PCAQ's on the restart checklist will provide another check to assure that resolution of PCAQ's needed for restart has occurred.

i 109 The Team selected several closed PCAQ's to deter-mine whether the proposed corrective action had satisfied the originating department's concerns and whether the corrective action was completed as required by station procedures. In general, all identified corrective actions described on the PCAQ's were completed; however, the documen-tation of the completed activity was, in many cases, limited and specific references were not provided. The Team stated that additional guid-ance on the level of documentation to be provided on the closecut portion of the PCAQ form could enhance clarity and auditability of the closure process. The Team also .noted that the PCAO sys-tem can allow ambiguity of FCAQ status in cases where a proposed action has been rejected by the originating office. For example, NEO rejected the response prepared by N00 to PCAQ NED-88-087.

A review of the N00 log showed the issue resolved (July 22, 1988), but further investigatten with persons affected indicated that the response was being rewritten and further corrective action was to be performed. The formal closecut process and status tracking for the PCAQ's needs improvement.

This finding parallels a similar finding of tile QA 03partment contained it; QAD 88-609, dated !

May 23, 1988.

3.10.5.3 Management Corrective Action Request ,

l The BEQAM and NOP 83A9, "Management Corrective l Action Process," describe the purpose of the Management Corrective Action Request (MCAR). The MCAR is a two-part corrective action document used to; (1) perform a root cause analysis of significant conditions adverse to quality and develop preventive action plans; and (2) request management to implement selected action plan to prevent recurrence of a problem. In lieu of a l Deficiency Report, an MCAR may be used to report and resolv6 deficiencies involving process or l policy issues which affect more than one depart- l ment and for which management Attention and l direction is required. /.n MCAR may also be used for tracking long-term corrective actions related to nonconformance reports (NCRs) and PCAQ's or for identification of adverse trends identified through trend analysis programs.

l l

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110 l 8

QA0 is assigned administrative control for the NCAR process. QAD logs the status, distributes copies, reports on delinquent MCAR's, and per-forms the closecut. QA0 also reviews each MCAR where the responsible department is different from the issuing department to verify that the assignment of the responsible department is appropriate.

l The Team reviewed the current status of open HCAR's cnd the administrative controls in place i to track and promptly resolve NCAR's. The latest I monthly status report, issued to the SVP-N on l August 1, 15?SS, from the QA0 Manager listed 30 open MCAR's. This list included two 1985 NCAR's and eight 1986 MCAR's. Approximstely 40% of the ,

MCAR's initiated since 1984 remain open. !

l The licensee has previously observed that in- '

creased management attention is required to close out MCAR's in a timely manner. For example, the most recent 0A0 trend analysis report, issued on Hay 23, 1988, recommended that the SVP-4. initi-ate action to closeout MCAR's QAD 85-2 and QA0 87-2, which address the large number of quality problem reports issued for "failure to follow procedures and "inadequate procedures."

Team attendance at several QA Interface meetings also noted that there is clearly increased management attention being directed to closecut the longstanding MCAR's.

The Team reviewect two open MCAR's to evaluate the effec *.iveness of the process. MCAR 86-06, issued

- in November 1986, involved recurring failures of the salt service water ($$W) pumps. the MCAR was issued as a result of an F&MR trend report find-ing. The MCAR resulted 1.1 a detailed root cause analysis by a consultant and the development of a long-term correctiva action plan, which is not yet complete. MCAR 88-02, issued in June 1988, concerned programmatic itiefficiencies in the PCAQ process. The itcensee is actively working on d9veloping an integrated list of the approxi-nately 250 open PCAQ's with a current status (see Section 3.10.4.2). This list is to be utilized to increase emphasis on closecuts. Review of these MCAR's did not identify any discrepancies in the process.

~

111 3.10.5.4 Clearinghouse Process The current procedure describing the corrective action process is NOP 83A9, "Management Correc-tive Action Process." This procedure discusses the respsnsibilities of the station departments in resolving identified deficiencies and report-ing the trends observed. The procedure also describes the various types of reports or docu-ments available to station personnel and specifi-cally defines their use.

As a result of the self-assessment evaluations and p.arformance improvement plans, the licensee determined that the existing corrective action processes were very complicated and that a '

streamlined procesc was needed that would provide an easy means of raising any concerns to manage-

.sent for resolution. A need was also identified for a specific entity which could monitor the performance of the station organization in imple-menting self-improvement recommendations, as well

- . provide the focal point for identified issues to be placed into the appropriate plant correc-tive action process. ,

In June 1988, the "Clearinghouse" was established to serve a number of needs. It was developed to assure that the licensee's restart assessment team observations had been entered into the regular corrective action process and, when necessary, that all necessary paperwork was pre- i pared for the resolution of any cytstanding l items. As of this inspection, 69 assessment items remain unresolved but have schedules iden-tified for their completion. Responses for approximately 69 additional items have not been received from the station organization. The balance of the original 449 items have been Itsted as closed. The Team did not evaluate the closecut process for any completed or closed items. l l

A second responsibility of the Clearinghouse wai l to streamline the corrGetive action process. As of this inspection period, revisions to the sta-tion procedures for imnrovements in corrective ,

I action processes have not been made. The current estimate for completion of the necessary proced-ure revisions was the end of August.

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While subject to revision during the required station procedure review process, the following is a discussion of the currut licensto philos-ophy 'concerning potential modification of the entrective action processes. Tne Team did not evaluate the effectiveness of these proposed in the overall corrective sction changes programs.

The Clearinghouse is currently revising chree !

existintj NOPs, creating a new NOP, and revising the BEQAM. The new NOP would define the role and responsibilities of the Clearinghouse, establish a new form for identifying real or potential plant problems, as well as for reporting employee-identifieci concerns or sel f-as ses sment recommendations for plant improvements. Tha new form would provide a simple method far raising.

issues, concerns, or recommendations to station ma nag eme r.t. Upon receipt of this fc 5, the Clearinghouse would review the issue described and integrate the issue into the regular plant corrective action processes for pesolution.

Another proposed chenge is a categorization of all the existing corrective action processes j identified in NOP B3A9 into three groups. One group, identified as corrective action processes, would include deficiency reports (OR), non-cort-formance reports (NCR), management corrective action requests (MCAR), failure and malfunction i reports (F&MR), radiological occurrence reports '

(ROR), security deficiency reports (50R). and supplier finder reports (SFR). These processes are used to identify and document plant defici-encies and to provide a means of tracking the resolution of identified problems.

A second group of controls would be categorized es normal work control processes. This group would potentially include maintenance requests (MR), huusekeeping services assistance (HSA).

procedure change notices (PC), and engineering ;

services requests (ESR).

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The last group currently being proposed includes all recommendations or findingts from the existing self-assessment programs. The information to be tracked in this group are recommendations for improving performance and would not bq used to identify programmatic deficiencies. Any identi-fication of deficiencies would be tracked using one of the processes described in the first group above. Examples of the types of recommendations to be tracked would be quality assurance audit findings and peer evaluator reports.

Changes would also be required fo- NOP 84E1, "Engineering Service Request (ESR) Process," and NOP 84A7, "Drawing Control," as well :s the quality assurance manual, in order te fully implement the revised program.

The licensee anticipates that all' necessary changes to station procedures would be completed by the end of Agust, with formal implementation of the program changes within )n additional 30 days.

3.10.5.5 Management Oversignt and Assessment Team (MC&AT)

In addition to the plant operations worsight !

provided by the ORC, the MO&AT also pruvides an I oversight review of plant operation:, by the nature of its responsibilities for overview of restart activitics. The MO&AT is composed of eight senior managers, which includes the Station Director, Director of Special Projects and Vice President Nuc1]ar Engineering. The SVP-N acts .ns the Chairman of the tiram. Further, three MC&AT members had been licensee managerc prior to the -

arrival of the SVP-N, while the remaining man- 1 agers joined the licensee subsequent to February 1987. .

The MO&AT taaintains its oversight of restart-related actisities and associated plant opera,-

tions through several scif-assessment programs.

These programs include but are not limited to the peer evaluator and management monitoring pro-grams. The Team noted that these programs were effective be evaluating plant activities.

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The Team determined that, in some ways, the responsibilities of the MO&AT parallels some of the responsibilities to review plant operations assigned to the ORC. In addition, the Team -

determined that the current role of the MO&AT is not credited by the ORC as a means of fulfilling its responsibilities to review plant operations, but it does provide a second, independent look at plant operations.

3.10.5.6 Engineering Service Requests (ESR's)

ESRs are tracking forms used by any licensee ;

department to request engineering assistance from the Nuclear Engineering Department (NED). Stand-ard practice within NED is to attach an ESR to all requests for assistance which may be already tracked under another corrective action tracting system, such as OR's, PCAQ's, etc. This is done to provide a means for the NED to track and monitor the progress of its work. When an ESR is opened or received, NED is to review the concern,

. determine a plan fer resolution of the item, which would include an evaluation relative to plans for plant restart. Unless the issue can be resolved wishin 30 days, a response to the origi-nating department is to be provided within 30 days which describes the above. In discussions with the Team, a management representative cf NED indicated that this practice has not always worked as planned and that additional emphasis is i being placed on assuring that the 30-day re- ;

sponses sre being sent in a timely 'ashion.

NED tracks all existing ESR's, determines what actions are required p*ior to restart, and rou-tinely evaluates the potential impacts of out-standing ESR's on the planned restart of the plant. In each case where NED determines that resolution of an ESR is not required to support restart, NED prepares documentation to support that position. This documentation undergoes several levels of review, including the Section Manager, Department Manager and the Vice Presi- j dont - Nuclear Engineering. Any open ESR asso- l ciated with unresolved PCAQ's or MCAR's is also reviewed by the ORC as part of its assigned ;

restart ch2cklist review. '

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l Based upon discussions with NED personnel, the Team concluded that ESR's are adequately tracked and that upper management is routinely informed l of potential problems in a timely fashion.

3.10.5.7 Human Performance Evaluation System The Team inquired as to the licensee's intentions in participating in the Institute for Nuclear Power Operations (INPO) Human Performance Evalua-tion System (HPES) program. The program is intended to assist licensees in the reduction of human error by encouraging personnel to report actual or potential situations which keep a per-son from outstanding performance. The licensee has designated an HPES coordinator, who is 4' the Training Department. The coordinator has seen trained by INPO and is currently preparing to implement the program. The coordinator has already become involved in the Incident Investi-gation and Critique process, and has reviewed the

. recent findings from the' licensee's ESF Actuation Task Force report. This program, once fully imple.mented, should provide additional valuable input into the corrective action process.

3.10.6 Conclusions l Overall, the Team determined the licensee's programs for safety assessment / quality verification to be adequate and improving. Based upon the areas inspected and examples raised, the Team concluded that:

1. The Nuclear Safety Review and Audit Committee is actively involved in the oversight of, facility opera- -

I tions. The committee is composed of experienced man- l apers with diverse experience and provides clear and ,

I valid input to the $1'P-N on safety-related activities.

2. Plant problems and deficiencies are being identified and entered into the appropriate corrective action ,

system.

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116 l

3. There are effective, meaningful communications between i the QA and plant operations departments, as well as good systems engineering invohement in evaluation and resolution of problems.

4. The weekly QA interface meeting has enhanced communi-cations at the station and improved the process of rasolving open issues.

5. The Operations Review Committee (ORC) has not been

. reviewing plant operations effectively so that mean-

ingful input to licensee management is being consist-ently provided. Recently, h&avy emphasis has been placed on administrative reviews of procedure changes and modifications, rather than reviewing plant opera-tiens. Also, ORC review of plant failure and malfunc-tion reports has neither been timely nor included all appropriate reports.

6. Multiple corrective action processes and multiple tracking systems detract from efficient functioning of the system. This has been identified by the licensee i and programs are being established to correct the l known deficiencies. l

7. The tracking and closecut of PCAQ's and MCAR's have !

I not been effective in the past. Also, a relatively large number of open PCAQ's exists. The licensee is taking action to resolve these problem.

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117 4.0 UNRESOLVED ITEMS An unresolved item is an item for which additional information is required in order to determine whether the item is _ acceptable, a violation, or a deviation. An unresolved item is discussed in section 3.4.2.2 of this report.

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5.0 MANAGEMEN7 MEETINGS !

At periodic intervals during the inspection period, the Team Leader held meetings with senior facility management to discuss the inspection scope and preliminary findings. A final exit interview was conducted on '

August 24, 1988. Attendees are itsted in Appendix B. At the exit meet-ing, the Team Leader described the preliminary inspection findings, including both the preliminary overall conclusions and the preliminary findings and observations in each functional area. The Team Leader also confirmed licensee commitments at the exit meeting. Then the Team Manager discussed how the Team findings will be used in NRC Restart Assessment Panel activities. Also, the Regional Administrator outlined the remaining step in the NRC staff process of evaluating Ptigrim restart readiness and developing staff recommendation.

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APPENDIX A -

Entrance Interview Attendees August 8, 1988, Boston Edison Comoany J. Alexander, Plant Operations Section Manager R. Anderson, Plant Manager H. Balfour, Training Section Manager -

R. Bird, Senior Vice President - Nuclear F. Famulari, Quality Assurance Department Manager

0. Gillispie, Nuclear Training Department Harager R. Grazio, Regulatory Section Manager

P. Hauilton, Compliance Division Manager K. Highfill, Station Director J. Jons, Radiological Section Manager ,

E. Kraft, Plant Support Department Manager R. Ledgett, Director Special Projects

0. Long, Security Section Manager A. Morisi, Planning and Outage Department Manager E. Robinson, Corporate Communication Information Division Head L. Schmeling, Program Manager J. Seery, Techn,1 cal Section Manager R. Sherry, Plant Maintenance Section Manager R. Swanson, Nuclear Engineering Department Manager E. Wagner, Assistant to Senior Vice President - Nuclear F. Wozniak, Fire Protection Division Manager United States Nuclear Regulatory Commission F. Akstulewicz, Senior Technical Assistant, Policy Developbent and Technical Support Branch, Office of Nuclear Reactor Regulation (NRR)

R. Blough, Chief, Reactor Projects Section No. 38, Division of Reactor Projects (ORP), Region I (RI)

5. Collins, Deputy Director, ORP, RI L. Doerflein, Project Engineer, ORP, RI T. Dragoun, Senior Radiation Specialist, Division of Radiation Safety

, and safeguards (ORSS)

M. Evans, Operations Engineer, Division of Reactor Safety (DRS), RI J. Lyash, Resident Inspector, Pilgrim Hucisar Power Station, ORP, RI

0. Mcdonald, Project Manager, Project Directorate I-3, NRR L. P11sco, Senior Operations Engineer, Division of License Performance and Quality Evaluation, NRR W. Raymond, Senior Resident Inspector, Millstone Point, DRP, RI L. Rossbach, Senior Resident Inspector, Indian Point Unit 2, ORP, RI G. Smitn, Safeguards Specialist. ORSS. RI C. Warren, Senior Resident Inspector, Pilgrim Nuclear Power Station, DRP, RI

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! Appendix A - Entrance Interview A-2 Attendees ,

Commonwealth of Massachusetts P. Agnes Assistant Secretary of Department of Public Safety P. Chan, Observer

5. Sho11y (MHB Technic'al Associates, Inc.), Observer O

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APPENDIX B Exit Interview Attendees August 24. 1988 Boston Edison Company J. Alexander, Plant Operations Section Manager R. Bird, Senior Vice Pref,ident - Nuclear F..Famulari, Quality Assurance Department Manager D. Gillispie, Nuclear Training Department Manager R. Grammont, Deputy Maintenance Section Manager .

R. Gra:io, Regulatory Section Manager P. Hamilton, Compliance Division Manager K. Highfill, Station Otractor J. Jens, Radiological Section Manager E. Kraft, Plant Support Department Manager R. Ledgett, Director Special Projects

0. Long, Security Section Manager E. Robinson, Corporate Communication Information Division Head L. Schmeling, Program Manager, J. Seery, Technical Section Manager R. Sherry, Plant Maintenance Section Manager R. Swanson, Nuclear Engineering Department Manager S. Sweeney, Chief Executive Officer and Chairman of the Board E. Wagner, Assistant to Sen ir Vice Presicient - Nuclear F. Wozniak, Fire Protection Division Manager United States Nuclear Regulatory Commission F. Akstulewic:, Senior Technical Assistant, Policy Developraent and Technical Support Branch, Office of Nuclear Reactor Regulation (NRR)

R. Blough, Chief, Reactor Projects Section No. 3B, Division of Reactor Projects (ORP), Region I (RI)

B. Boger, Assistant Director for Region I Reactors NRR S. Collins, Deputy Director, ORP, RI L. Doerflein, Project Engineer, ORv, RI W. Little, Office of Special Projects, RII J. Lyash, Resident Inspector, Pilgrim Nuclear Power Station, ORP, RI

0. Mcdonald, Project Manager, Project Directorate (PO) I-3, NRR W. Raymond, Senior Resident Inspector, Millstone Point, ORP, RI L. Rossbach, Senior Resident Inspector, Indian Point Unit 2, ORP, RI W. Russell, Regional Administrator, RI C. Warren, Senior Resident Inspector, Pilgrim Nuclear Power Station ORP, RI R. Wessman, Director, PD I-3, NRR

Appendix B - Exit Interview B-2 Attendees .

Commonwealth of Massachusetts P. Agnes, Assistant Secretary of Department of Public Safety P. Chan, Observer G. Minor (MHB Technical Associates, Inc.), Observer r

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APPENDIX C Persons Contacted R. Anderson, Plant Manager R. Bird, Senior Vice President - Nuclear F. Famulari, Quality Assurance Department Manager K. Highfill, Station Director E. Howard, Vice President - Nuclear Engineering E. Kraft, Plant Support Services Manager A. Morisi, Planning and Outage Manager R. Swanson, Nuclear Engineering Department MTnager S. Sweeney, Chairman of the Board and Chief Executive Officer In addition, the Team interviewed a large number of managers (in:1uding virtually all section and division managers), engineers, supervisors, and craft personnel in each inspection area.

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APPENDIX Q Documents Reviewed

PHPS, Nuclear Training Manual, T-001, Parts 3, 4 and 5

PNPS, Special c >s*.-Sts tup Training Program, Appren d August 9, 1988

PNPS Technical fp+ ricas

Boston E.iw e , icelear v iestun, Organization and Policy Manus)

1 . l e r. r b , a .. : cw .n . :

' .4 ate r i Joe :-n 1:rr r. ". A : tion: Alan a Got.on Edisco O W 'n i.< ...e Msnual Audit Repms -

.n eviev inc1' ding the followin;: 87-40, 88-02, 87-63, 8S-10, 4d-20, 5.~ %y U-4o, 88-04, and 88-17

Potential Corditions Adva. se to Quality (PCAQ) Repons -- Sampling review including N00 57 '3, NF.' . 86-71, BE0 87-255, 50 88-57, 50 88-58, 50 88-48, N00 87-02, N00 87-?" NED 88-087, 50 88-59, 50 88-12, N00 88-120, j NED 88-90, 50 B'.-52., and SS 88 22

Manegement Corrective A . ston Requests (MCAR's) -- Sampling review includ- l ing QA0 85-2, QA0 57-2. 84-06, and 88-02 I

Licensee Emn* Re, a or* s (LER's) -- Sampling review including 87-21,88-008

]

thru 88-01*, Ed-C'6,.nd Q -017 Maintenance Requesta (MR's) -- Sampling. review including 88-11-6,88-110, 88-10-179, 88-A6-300, 88-14-16, 88-45-183, 68-45-181, 88-46-194, 88-10-26, 88-10-105, 88-10-69, 88-10-71, 88-10-80, 88-10-141, 87-10-282, and 87-10-283

Maintenanca Activitie;/Packaggs -- Sampling review including 88-3-26, 88-19-109, 88-46-213, 86-10-86, 87-46-173, 88-13-20, 88-46-438, 88-2-12

86-20-47, 88-45-152, 88-45-176, 88-3-62, 88-63-276, 88 45-190, 88-1-31, 88-14-16, 88-46-194, and 88-10-114

Meeting Ninutes for ORC Meetings 88-40 through 88-63

Failure and Malfunction Report 86-266

NED Procedure 16.03, "Corrective Action Program" l

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Appendix D - Documents Reviewed 0-2

QAD Trend Analysis Report for the First Quarter of 1988 - QAD 88-609

PNPS Work Instructicn N8-3.2.12, F&MR Trend Analysis

Memo from J. Seery to R. Grazio, Appointment of Compliance Division as ORC .

Subcommittee,. June 23, 1988

Memo from R. G. Bird to K. L. Highfill, NSRAC Concern from May 24, 1988 NSRAC Meeting - May 27, 1988

Memo from K. L. Highfill to R. G. Bird, Response to NSRAC Action Item 88-04 June 22, 1988

Memo from J. A. Seery to R. Flannery, ORC Meeting Minutes Distribution List - dated May 6,1988

Procedure 1.2.1, Operation Review Committee

Procedure 1.3.24, Failure and Malfunction Reports

Procedure 1.3.2.6, Response to Deficiency Reports

Procedure 1.3.4, Procedures

Procedure 1.3.33, Operating Experience Review

Procedure 1.3.37, Post Trip Reviews

Procedure 1.3.38, Plaat Performance Monitoring Program

Procedure 1.3.63, Conduct of Critiques and Incident Investigations

Procedure NOP 83A9, Management Correctii.'e Action Proccss .

Procedure NOP 83A13, Deficiency Report Process

Procedure NOP 83A14, Nonconformance Reoort Process

Procedure NOP 84A1, Surveillance Monitoring Program

Procedure NOP 84A11 Annual Independent Review of BEco's Quality Assurance Program

Procedure NOP 85A. \ , Nuclear Organization Performance Monitoring and Management Information Program

Procedure NCP 88A1, Performance Standards and Evaluation Guidelinss for Pilcrim Station

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Appendix 0 - Documents Reviewed 0-3

Procedure NOP 8305, The Failure and Malfunction Report Process

Procedure NOP 8401, Operating Experience Review Program

Procedure 1.4.5, PNPS Tagging

Procedure 1.5.3, Maintenance Requests

Procedure 1.5.3.1, Maintenance Work Plan

Procedure 1.5.7, Emergency Maintenance.

Procedure 3.M.1-30, Post-Work Testing Guidance

Procedure SI-MT.1000, Maintenance Section Manual ,

Procedure SI-MT.0501, Post-Work Test Matrices and Guidelines

Procedure 3.M.1-11.1, EQ Maintenance Process: Repair / Replacement

Procedure 3.M.3-1, A5/A5 Buses 4KV Protective Relay Calibration / Functional Test and Annunciator Verification

Procedurc 3.M.3-8, Inspection / Troubleshooting Electrical Circuits

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Procedure TP 88-40, 480 VAC Contactor Testing

Procedurv TP 88-22, Pre-Operational Test of the New Degraded Voltage Relays and Modified Lead Shedding Logic

Procedure FW THI-1, Post Work Test Matrix and Guidelines, Revision A

Procedure 3.H.4-14, Rotating Equipment Inspection, Assembly and Dis-assembly, Revision 6, dated April 4,1938

Procedure 8.Q.3.4,125/250V DC Motor Control Center Testing and Mainten- l ance

Precadura 2.2.85, Fuel Pool Cooling System .

Procedure 3.M.1-15, Vibration Monitoring for Preventive Maintenance and Balancing, Revision 5, dated June 12, 1988

Procedure 2.2.8, Standby AC Power System (Otesel Generators), Revision 20 dated January 13, 1984

Procedure ARP, Panel C39, Fuel Poel Cooling System, Revision 0, dated January 30, 1988 l 1

Procedure 2.2.83, Reactor Cleanup System, Revision 22, dated June 20, 1988

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Ek 7 Appendix 0 - Occuments Reviewed 0-4

Fire Watch Computer Listing, dated Au3ust 4,1988

Fire Protection Maintenance Request Computer Listing, dated August 9, 1988

Pilgrim Station Performance Indicators, dated August 10, 1988 and August 17, 1988

Procedure 8.9.29. "Inspection of Fire Barriers," Revision 1

Temporary Modification i.og

Temporary Modificati.on Status Report to R. Anderson from F. Mastrangvio, dated August 4, 1988

Procedure 1.5.9, "Temporary Modifications," Revision 12

Procedure 1.5.9.1, "Lifted Leads and Jumpers," Revision 0

Procedure 1.3.34, "Conduct of Operations"

Procedure 2.1.16 "Nuclear Power Plant Operator Tour," Revision 54

' ertima Book Ov

Procedure 1.3.67, "Use and Control of Overtime at PNPS"

Advance Overtime Requests for Week Ending August 6, 1988

PNPS 1-ERHS-VIII.8-4-0. Turbine Building Shield Wall Design

Confidential Memo #13, to J. P. Jens from K. L. Highfill, dated July 19, 1988, "Training Drogram for Radiation Protection Manager"

Procedure 6.1-209, "Radiological Jccurrence Reports"

Radiological Work Plan for A and B Recirculation Pump Seal Welds

Procedure 6.1-012. "Access Control to High Radiation Areas"

Selected RP Technician Training and Qualification Folders, Lesson Plan, Quiz:es and Training Guides )

Selected Radiation Work Permi's from March 1988 to August 1988

Maintenance Request 87-20-84

Appendix 0 - Documents Reviewed 0-5

Procedure 8.M.2-1.5.3.4, "Primary Containment Isolation Logic Channel Test

- Channal 82," Revision 8, dated September 24, 1987

Procedure 8.M.2-1.5.7, "Group I Primary Containment Isolation Valve Test-ing," Revision 5, dated November 7,1987

Procedure 8.M.2-8.2, "Calibration of ATS Transmitters Rack C2206," Revis-ion 2, dated June 30, 1988

Procedure 8.M.1-32.4, "Ar;alog Trip System - Trip Unit Calibration - Cabi-not C2229-82," Revision 5, dated April 4, 193,8 -

Procedure 8.M.2-2.10.8.5, "Otesel Generator 'A' Initiation By Loss of Off-Site Power Logic," Revision 8, dated Novenber 6, 1987

Procedure 8.M.2-2,10.8.3, "Of esel Generator ' A' Initiation By Core Spray Logic," Revision 12, dated April 9, 1988

Procedure 3.M.3-1, "AS/A6 Buses 4KV Protective Relay Calibration /

Functional Test and Annunciator Verification," Revision 23, dated August 13, 1988 ,

Procedure 8.M 2-2.6.7, "RCIC Simulated Automatic Actuation," Revision 6, dated February 5, 1988

Procedure 8.5.5.1, "RCIC Pump Operability and Flow Rate Test at 1000 psig," Revision 24, dated June 4, 1938

Procedure 8.M 2-2.10.7 "RCIC Automatic Isolation System Logic," Revis-ion '1, dated Novemoer 7, 1987 8.M.2-2.6.1, "RCIC Steam Line Hi Flow," Revision 13, dated Procedure June 9, 1988

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Procedure 8.M.2-2.G.3, "RCIC Steam Line Hi Temperat' ire," Revision 12, dated July 17, 1987

Procedure 8.M.2-2.64, "RCIC Steam Line Low Pressure," Revision 16, dated l

! June 20, 1988 i.

Procedure 8.M.1-32.5, "Analog Trip System - Trip Unit Calibration Cabinet C2233A, Section A," Revision 2, dated December 7, 1987

, Procedure 8.E.11. "Standby Liquid Control System Instrument Calibration,

l Revision 9, dated September 2,1967 Procedure 8.E.13 "RCIC Systes Instrument Calibration," Revision 14, dated June 26, 1938

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l Appendix 0 - Occuments Reviewed 0-6 ,

Procedure 8.4.1, "Standby Liquid Control Pump Operability and Flow Rate Test," Revision 19 dated April 9, 1988 i

a Procedure 1.8, "Master Surveillance Tracking Program," Revision 9, dated August 15, 1988

Procedure 1.3.36, "Measurement and Test Equipment," Revision 4, dated March 9, 1988

Procedure 8.I.1, "Administration of Inservice Pump and Valve Testing,"

Revision 4, dated August 15, 1986

Procedure 8.I.3, "Inservice Test Analysis and Documentation Methods,"

Revisten 6, dated May 11, 1988 l

Ora h ;s

PNPS Elementary Diagram MIN 34-9 (Revision E1): Primary Containment Isolation System

PNPS Elementary Diagram MIN 28-12 (Revision E14): Primary Containment Isolation System

l.

PNPS Elementary Diagram MIN 36-7 (Sh.10, Revision E7): Primary Contain- ,

ment Isolation System ,

PNPS Elementary Diagram M1H 36-7 (Sh.11, Revision ES): Primary Contain-ment Isolation System

PNPS Elementary Diagram MIN 41-10 (Reviston E2): Primary Containment Isolation System 1

PNPS Elementary Diagram MIN 38-11 (Revision E2): Primary Containment Isolation System 4

PNPS Elementary Diagram MIN 35-7 (Revision E4): Primary Containment Isolation System

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PNPS Elementary Diagram MIG 11-11 (Revision Ell): RCIC System

PNPS Elementary Diagram MIG 12-12 (Revision E5): RCIC System i

PNPS Elementary 01agram M1G 14-9 (Revision ES): RCIC System I

PNPS Elementary Diagram mig 15-9 (Revision E8): RCIC System

PNPS Elementary Diagram mig 16-7 (Revision E5): RCIC System

PNPS Elementary Diagram MIK 4-11 (Revision E10): Core Spray I

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l Appendix 0 - Documents Reviewed 0-7 ,

PNPS Schematic Otagram E-548 (Revision EO): Containment Atmosphere Isola-tion Control ,

PNPS Schematic Otagram E-38 (Revision E6): 4160V System Breakers 152-504 and 152-604

PNPS Schematic Diagram E-35 (Revision E3): 4160V Auxiliary Relays and Miscellaneous Schemes

PNPS Schematic Diagram E-27 (Revision E7): Diesel Generator

PNPS Schematic Diagram E-17 (Revision E7): Schematic Meter and Relay

. Otagram 4160 Volt System

PNPS Schematic Diagram M6-22-14 (Sh.1; Revision Ell): Diesel Generator "A" X107A Engine Control

PNPS Relay Setting Drawing ES-200 (Sh. 1, Revision E3): 4160 Volt Switch-gear Relay Settings

PNPS Relay Setting Drawing ES-200 (Sh. 3, Revision E2): 4160 Volt Switch-

, gear Relay Settings PNPS P&ID M245 (Revision E13): RCIC System, Sh. 1 l

PNPS P&ID M246 (Revision E10): RCIC System, Sh. 2

PNPS P&ID M249 (Revision E12): Standby Liquid Control System i

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APPENDIX E IATI Composition and Structure Team Manager Samuel J. Collins Team Leader A. Randy Blough Technical Assistant Clay C. Warren Administrative Assistant Mary Jo 010onato Operations Lawrence W. Rossbach (Lead)

Shift Inspectors Lawrence W. Rossbach William J. Raymond Loren R. P11sco Lawrence T. Doerflein Francis M. Akstulewicz Radiological Controls Thomas F. Dragoun Maintenance _ Jeffrey J. Lyash William J. Raymond Surveillance Lawrence T. Deerflein -

Security Gregory C. Smith Fire Protection Lawrence W. Rossbach Assurance of Quality Loren R. Plisco Francis M. Akstulewicz Training and Management Daniel G. Mcdonald Effectiveness Michele G. Evans Report Coordinatoe Tae K. Kim Commonwealth of Steven C. Sho11y Massachusetts (Observers) Pamela M. Chan I l

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APPENDIX F .

NRC Integrated Assessment Team Insoection (IATI)

Members Resumes This appendix shows IATI summary resumes of the team members and Common-wealth of Massachusetts observers. The resumes outline the nuclear experience of team members.

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l Appendix F F-2 .

NAME: FRANCIS M. AXSTULEWICZ ORGANIZATION: United States Nuclesr Regulatory Commission Office of Nuclear Reactor Regulation Policy Development and Technical Support Branch TITLE: Senior Technical Assistant EDUCATION: B.S., Nuclear Engineering EXPERIENCE: Fourteen Years of Nuclear Experience as Follows:

Two and Ona-Half Years - Shielding Engineer - Bechtel Power Corporation One Year - Technical Analyst - Office of Material Safety and Safeguards (NRC)

Eight Years - Nuclear Engineer - Office of Nuclear Reactor Regulation (NRC)

Two Years - Project Manager - Haddam Neck Plant, Office of Nuclear Reactor Regulation (NRC) 0,ne-Half Year - Present Position l SPECIAL l

, QUALIFICATICNS: Completion of NRC Fundamental and Advanced BWR Systems Training Course and BWR Simulator Course l SPECIAL '

ASSIGNMENTS: Member of Fire Protection, Health Physics and Otagnostic Team Inspection at Haddam Neck

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Appendix F F-3 NAME: A. RANDOLPH SLOUGH ,'

ORGAN!ZATION: United States N:4 clear Regulatory Commission, Region !

Division of Reactor Projects ;

TITLE: Chief, Reactor Projects Section No. 3B I EDUCATION: B.S., U.S. Naval Academy, 1973 (Graduated with Honors)

Navy Nuclear Engineer Officer Course, 1977 NRC Inspector Technical Training Program,1940 Various technical and management courses in USN and USNRC, l such as QA, Reactor Engineering, Reactor safety, Suoervis-in9 Numan Resources, EEO, Management Workshops EXPERIENCE: Fifteen Years Nuclear Exportence a: Follows:

1985-Present United States Nuclear' Regulatory Commission (USNRC) --

l Reactor Projects Section Chief. Manage safety inspection programs for three commercial reactor facilities. S t.pe r-vise nine nuclear engfneers. Provide formal assessments of utility management effectiveness and safety performance. '

1982-1935 USNRC -- Senior Resident Inspector at operations phase and preoperational phase nuclear power plants. Planned, super-

)] vised, and performed inspections of at.nagement controls and j -

activities important to nuclear safety. Coordinated specialist inspector efforts. Formally rep?rted findings .

and recommended appropriate enforcement. !

1972-1092 USNRC -- Resident Inspector. Planned, perfomed, anci do:u- i mented inspections of all functieaal areas at a dual-unit operating re ctor site. ,

i

! 1973-1979 U. S. Navy Nuclear Power Program. Duties included super-l visory positions in nuclear plant operations, baintenance :

i and trcining. Perfonned auditt and coorcinated plant self- ,

assessmei.t. Was responsible for a comples, in-plant >

nuclear scaining program for up to 300 students. Shipboard l

duties included Main Propulsion Assistant: responsible for !

41) reactor and main propylsion systems, all radiological i controls and plant chemistry. Collateral duties included

j. QA Of ficer, and Nuclear Weapons Safety / Security Officer.

SPECIAL

QUALIFICATIONS: Qualified BWR Inspector, NRC Region I,1980 Qualified Nuclear Engineer 07ficer, Naval Reactors,1977 l

)l SPECIAL i i ASSIGNMENTS: Team Leadert NRC Integrated Performance Assessneent foam

! Inspection, Oyster Creek, 1987 l Team Leader, NRC Team Inspection of Oyster Creek Contain-ment Vacuum Breakers Event '987 :

{ Particioated in various other plant readiness inspections, '

1984-1985

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Appendix F F-4 ,

NAME: PAMELA M. CHAN ORGANIZATION: Massachusetts Energy Facilities Siting Council (Since 12/87) i TITLE: Engineer / Utility Analyst EDUCATION: B.S. M.E. Pennsylvania State University EXPERIENCE: Five Years Nuclear Experience as Follows:

1987 United States Nuclear Regulatory Comi s sion , Region !!!,

Reactor Inspector 4

1985-1987 Nuclear Power Services - Construction 1984-1935 Cee.bustien Engineering -

Nuclear Systeas Services; Field !

Service Engineer 1982-1934 Stone & Webster Engineering Corporation - Power Division System Engineer - Turbine Plant Systems SPECIAL QUALIP! CATIONS: Background in Maintenance and Quality Assurance SPECIAL .

! ASSIGNMENTS: Participated in several team inspections while at NRC -

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1 Appendix F F-5 .

1 NAME: SAMUEL J. COLLINS .

ORGANIZATION: United States Nuclear Regulatory Commission, Region I

. Division of Reactor Projects TITLE: Deputy Ofrector l

EDUCATION: Bachelor of Science, Maine Maritime Academy 4 Business Program, Southern Vermont College EXPERIENCE: Seventeen Years Nuclear Experience in Design, Construction, Operations, Inspection and Management as Follows:

1987 - Present Deputy Director: Division of Reactor Projects, USNRC, .

Region !

1986 - 1987 Deputy Director (Detail): Division of Reactor Projects.

USNRC, Region I As a member of the Senior Executive Service, responsible for division management; the conduct of inspections and evaluations of assigned NRC programs for all pcwer and non power reactors within Region I.

1985 - 1986 Branch Chief: Reactor Prefects Bran.h No. 2. USNRC, Region I Responsible for project management, staffing and budget considerations, including inspections, implimentation of -

SALP, resident inspection and enforcement for eleven assigned power reactor sites in operation and under construction.

4 1984 - 1985 Section Chief: Reactor Projects Section No. 2C, USNRC, Region I i

Responsible for implementation of the routine and reactive inspection program at six assigned power reactors during new construction, testing and operation.

1983 - 1984 Senior Resident Inspector: Operations, Yankee Nuclear

. Power Station. DRP, USNRC, Region I Supervised; inspection and event respgnse program at opera-ting Vestinghouse PWR power reactor facility.

1980 -1983 Resident Reactor Inspector: Operations Ver.nont Yankee Nuclear Power Station, ORP, USNRC, Region I. Field inscoctor at ocerating General Electric BWR power reactor

, facility.

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Appendix F - Samuel J. Collins F-6 4 Private Industry: ,

1971 - 1980 Tenneco Corporation, Newport News Shipbuilding. Various

positions as contractor to U.S. Navy Nuclear Program ;

including: I 1

Preject Manager - SSW 5 team Generator Chemical Cleaning Project Chief Test Engineer - Chairs &n and NNS representative to Joint Test Group for $5W overhaul and construction l

Shift Test Engineer - Shift supervisor for reactor overhaul and refueling l Shift Test Engineer - Shift supervisor for reactor new construction i

Mcchanical Test Engineer - Shift mechant:al test for reac-l ter new construction Reactor Design Engineer - Design support for reai:to. new construction SPECIAL i

GUALIFICATICNS: Senior Executive 3ervice Candidate Development Prograt, USNRC, 1986 - 1987 Qualiited BWR Resident Inspector l Qualifted PWR Resident Inspector j Qualified SSW Shift Test' Engineer '

Third Enginese License, USCG l SPECIAL i i

ASSIGNMENTS: 1988 - Team Manager, Pilgrim Integrated Assessment Restart Team Inspection ;

1987 - 1988 - Chairman, Pilgrim Restart Assessment Panel 1

4 1987 - 1988 - Region I Representative, NRC Training Ad- ;

q visory Group I I 1987 - Chairman, Differing Professional Opinion Peer Review l Group i 1987 - Chairman, Comanche Peak Task Force Review Group

]

1986 - Team Leader, Nine Mile Point 1 and 2 Diagnostic Tears i

Inspection -

! 1985 - Team Leader, Peach Bottom 2 and 3 Diagnostic Team Inspection l

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J Appendix F F-7 NAME: LAWRENCE T. 00ERFLEIN ORGANIZATION: United States Nuclear Regulatcry Commission, Region I ,

Division of Reactor Projects TITLE: Project Enginee.'

EDUCATION: BS Electrical Engineering US Naval Academy, 1973 1

Fifteen Years Nuclear Experience as Follows:

EXPERIENCE:

Aug. 1985-Present Project Engineer Oct. 1953-July 1935 Senior Resident Inspector, Fit: Patrick Nwelear Power Plant l Nov.1930-Cet 1980 Resident Inspector, Fit: Patrick Nuclear Power Plant June 1973-Oct. 1980 US Navy SPECIAL j i

QUALIPICATICNS: Certified NRC BWP. Inspector ,

Cualf f ted Chief Naval Nuclear Engineer l SPECIAL ASSIGNMENTS: Limerick Readiness Assessment Team l Pilgrim Augmented Inspection Team O

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NAME: THOMAS F. ORAGOUN ORGANIZATION: United States Nuclear Regulatory Commission, Region I Division of Radiation Safety and Safeguards TITLE: Senior Radiation Specialist EDUCATION: Rensselaer Polytechnic Institute, and Union College D00 , Staff College, Battle Creek, Michigan EXPERIENCE: Twenty-Tnree Years of Nuclear Experience as Follows:

4 1983-Present NRC - Senior Radiation Specialist r

1983-1969 General Electric Company, which included the following:

4 Qualified s Operations Engineer and E00W at Navy Prototype (3 Years)

- Senior Engineer en Trident Prototy:n Constru:ti:n

]

Project (5 Years) .

i 4 -

Health Physicist responsible for service work, both !

domestic and foreign by Large Steam Turbine Division (6 Years) 1965-1969 Cornell University - Taught Radiation Protection Subjects l

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_ - . , _ _ _ _ . - . . , , ,,_ . . - - _ _ . .._,-y,-,--_ - - -rv... - . _

Appendix F F-9 :

NAME: MICHILE G. EVANS ORGANIZATION: United States Nuclear Regulatory Commission, Region !

Oivision of Reactor Safety !

4 TITLE: Operations Engineer ;

! EDUCATION: B.S., Chemical Engineering, University of Pennsylvania EXPERIENCE: Four Years of Nuclear Erperience as Follows:

1 Aug 1987-Present operations Engineer, Boiling. Water Reactor Section - Con- l duct review and inspection of Power Ascension Programs at l Pilgrim and Nine Mile Point 2. Currently in training to

qualify as BWR Operator Licensing Examiner r

July 1984-Aug 1987 Reactor Engineer, Test Programs Section - Conducted review I and inspection of preoperational test programs at Kope i l Creek and Nine Mile Point 2, and 'tartup Testing Programs !

at Limerick 1, Shoreham, Hope Creek and Nine Mile Point 2. '

i SPECIAL t

, QUALIFICATIONS: USNRC Certified SWR Inspector t

! i j Engineer in Training (State of Pennsylvania) ;

j SPEC 1AL '

Currently participating in the Women's Executive Leadership ASSIGNMENTS: f Program for Management Development i 4

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NAME: JEFFREY J. LYASR ORGANIZATION: United States huclear Regulatory Commission, Region I Division of Reactor Projects !

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TITLE: Resident Inspsetor - Pilgrim Nuclear Power Station EDUCATION: B.S., Mechanical Engineering, Drexel University l EXPERIENCE: Six Years kuclear Experience as Follows: ,

Two and One-Half Years - NRC Resident Inspector - Ptigria Nuclear Power Station One Year - NRC Resident Inspector - Hope Creek Generating Station One Year - NRC Reactor Engineer - Region !

One and One-Half Years - Pennsylvania Ptwar and Light Company - Test Engineer - Susquehanna Steam Electric l Station SPECIAL I

QUALIFICATICNS: Meritorious Service Award as NRC Resident Inspector cf the Year 1987-1988 i

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{ Appendix F F-11 l

NAME: 0/,NIEL G. MC00NALD, JR. l

ORGANIZATION: United States Nuclear Regulatory Commission (USNRC) -

Office of Nuclear Reactor Regulation TITLE: Senior Project Manager i EDUCATION: 8.5., Management, $henandoah College l A.A., Engineering, Solano College ;

EXPERIENCE: Thirty-One Years Nuclear Experience as Follows:

1982-Present Senior Project Manager - Manage and coordinate all NRC .

i licensing functions on assigned operating reactor facil-ities which have difficulties or complexities with manage- 1 ment and operation. (NRC) i 1982(3 Months) Reactor Engineer (Instrumentation) - Technical evaluations i of instrumentation and control systems or licensee appli- ,

cations and operating reactor modifications. Assist in ,

developing regulatory requirements and estabitshing staff

! policy. (NRC) ,

i s

1980-1982 Staff Member - Conduct, direct and coordinate assessments I

of critical technologies in the context of national secur- 1 J ity. Previde technical support to the Nuclear Regulatory '

Commission. (Los Alamos National Laboratory)

)

j 1979-1980 Reactor Inspector (Electr.ical) - Inspects reactors under 3

construction and in operation. (NRC) ;

1978-1979 Senior Electrical Engineer - Technical evaluations of

electrical, instrumentation and control systems. Assist in i developing staff policy. (NRC) i 1973-1978 Reactor Engineer (Instrumentation) - Technical evaluation for Itcense applications and operating reactors. (NRC) l l 1966-1973 Senior Technical Associate - Field engineer in nuclear j weapons test programs. (Lawrence Livermore Laboratory ;

l

(LLL)) .

1964-1966 Senior Electronic Engineering Coordinator - Design of con-1 trol, interlock and instrumentation systems for critical assembly machines, test reactors and containment vaults.

l (LLL) 1960-1964 Electronics Designer - Design of conaunication, personnel

) warning, closed circuit TV and radiation monitoring systems. (LLL) i l

1 L___ . _ _ . _ _ . _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _

Appendix F - Daniel G. Mcdonald, Jr. F-12 1957-1960 Senior Electronic Technician - Fabricated and assisted in the design and development of prototype electrical and electronics equipment. (LLL) 1953-1957 Electrical specialist - Four year apprenticeship with Department of Navy. (Hare Island Shipyard) i 9

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Appendix F F-13 NAME: LOREN R. PLISCO ORGANIZATION: United States Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Licensee Performance and Quality Evaluation TITLE: Senior Operations Engineer EDUCATION: B.S., Systess Engineering, U.S. Naval Academy EXPERIENCE: Eleven Years Nuclear Experience as Follows:

19G7-1988 Senior Operations Engineer, NRC:NRR 1986-1987 Senior Resident Inspector - Susquehanna Steam Electric Station 1983-1986 Resident Inspector - Susquehanna Steam Electric Station 1932-1983 Reactor Eng'neer, Region I 1977-1982 US Navy Nuclear Power Program SPECIAL

QUALIFICATIONS: Certified NRC BWR Inspector

Qualified Naval Nuclear Engineer Officer SPECIAL j

ASSIGNMENTS: Susquehanna 2 - Operational Readiness Assessment Tr.c..

Inspection

]

Limerick 1 - Operational Readiness Asssess, tent Team Inspec-tion Hope Creek - Operational Readiness Assessment Team Inspec-tion .

! Salem - ATWS Inspection TMI Management Integrity Inspection I

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4 Appendix F F-14 i

NAME: WILLIAM J. RAYMCND t

ORGANIZATION: United States Nuclear Regulatory Commission, Region I Division of Reactor Projects TITLE: Senior Resident Inspector - Millstone Nuclear Power Station

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i EDUCATION: 8.5. Physics M.S. Nuclear Science and Engineering l

l j EXPERIENCE: Eighteen Years Nuclear Experience as Follows:

1 j -

1975-1988 NRC Reactor Operations Inspector I -

SU&T, Core Physics, Refueling, Pre & SU&T for BV, CC1, ,

IP3, MP2

]

Project Inspector - Beaver Valley, Ginna and Susque-

a

, hanna TMI Recovery Team - Accident Response and Containment Entry Senior Resident Inspector - Vermont Yankee and Mill-stone t

1972-1975 Startup Engineer, Babcock & Wilcox, Oconee 1 anc 2 and Three Mile Island, Unit 1 1970-1972 Reactor Operator, VPI Research Reactor SPECIAL l QUALIFICATIONS: VPI Reactor Operator License l Certified NRC Licensed Operator Examiner - 1986 l SPECIAL I

{' ASSIGNMENTS: IAEA Assist Visit to Brazil CNEN - 1981 l j Team Leader Salem ATWS Event - NRC Fact Finding - 1983 l Salem ATVS Generic Issue Review Team - 1983 i NRC Response to Crystal River Evert - 1981 i

. Assist Visit to Region V - WNP2 Startup Readiness - 1982 Team Inspections - Shoreham 1982 and Pilgrim 1986 Operator Briefings of TMI Event - 1979 l

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Appendix F F-15 3 .

NAME: LAWRENCE ROSSBACH ORGANIZATION: United States Nuclear Regulatory Commission, Region I Division of Reactor Projects TITLE: Senior Resident Inspe: tor - Indian Point Unit 2

EDUCATION: 8.$., Nuclear Engineering l EXPERIENCE: Sixteen Years of Nuclear Experience as Follows:

Six Years, NRC Resident Inspector and Senior Resident Inspector Two and One-Half Years, Program Manager for NRC's prepara-tion to review a high level waste repository license -

application Two and One-Half Years, NRC Project Manager and Reviewer for Uranium Mills i

Five Years, Systa.is Design Engineer at Archite: ural l Engineering-(AE) Company l

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Appendix F F-16 NAME: STEVEN C. SHOLLY ORGANIZATION: MHS Technical Associates (Observer for the Commonwealth of Massachusetts .

TITLE: Associate Consultant EDUCATION: B.S. in Education (1975); Graduate Course Work in Geo-environmental Studies (1976-1977)

EXPERIENCE: Seven and One-Half Years Nuclear Esperience as Fo11ews:

1985-Present MHB Technical Associates, San Jose, CA - Work in Risk '

Assessment, Quality Assurance, Operating Events Analysis, and Design and Construction Assessment 1951-1955 Union of Concerned Scientists, Washington, C.C. - Work in generic safety issues, risk assessment and emergency planning SPECIAL ASSIGNMENTS: - Member of NRC Peer Review Group, NUREG-1050 (1984)

- Participated in NRC Concainment Performance Design Objective Workshop (1986) ,

- Participated in NRC/LLNL Workshop on Safety Goals Implementation, Presentation on Seismic Risk !

Assessment (1987)

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Appendix F F-17 i

NAME: GREGORY C. SMITH ORGANIZATION: United States Nuclear Regulatory Commission, Region I Division of Radiation Safety and Safeguards TITLE: Safeguards Specialist EDUCATION: B.S. Education, California State College Various additional courses including: Technical Writing, Quality Assurance Auditing, Statistics, Reactor Design and Layout. Radiological Accident Assessment, Radiological Emergency Response, BWR Technology, Transportation of Radioactive Materials, Advan'ced Neutron Nuclear Materials Assay, Safeguards Chemical Analysis of Nuclear Materials, Nondestructive Assay of Nuclear Materials, Nondestructive Assay of ,

Fissionable Material, Accident / Incident Investigation and Intrusion Detection Systems EXPERIENCE: Twenty-Two Years Nuclear Industry Experience as Follows:

1977-Present . Safeguards Specialist, Physical Protection Inspector and Safeguards Auditor (USNRC) 1966-1977 Westinghouse Electric Corporation. Bettis Atomic Power Laboratory - Production Engineer, Nuclear Materials Aud- !

itor, Nuclear Meterials Analyst, Reactor Development Technician f

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4 Appendix F F-18 l

2

, NAME: CLAY C. WARREN .

i ORGANIZATION: United States Nuclear Regulatory Commission, Region l' Division of Reactor Projects TITLE: Senior Resident Inspector - Pilgrim Nuclear Power Station i EDUCATION: 8.5., Natural Sciences,'Louisianna state University a

j Industrial: 1986 - USNRC Inspector Qualification Program t 4

1985 - Training Program on the General Electric BWR-6 nro-duct Ifne and received NRC Senior Reactor Operator: License i . :

1982 - GE Boiling Water Reactor (BWR) Senior Reactor Oper-

]

4 ator Certification training at the General Electric BWR !

l Training Center

1980 - Shif t Test Engineer training program at General '

Oynamics Corporation. Electric Boat Division. Successfully ,

completed the Naval Engineering Officer exam administered l by Naval Reactors.

Military: Navy Nuclear Prototype Training ;

Navy Nuclear Power School Electronics Technicians School EXPERIENCE: Fifteen Years Nuclear Experience as Follows: l Jan 1987-Present United States Nuclear Regulatory Commission, Senior :

Resident Inspector ;

Jan 1986 Jan 1987 Resident Inspector June 1984-Jan 1986 shift Supervisor, Gulf States Uttitties Company, River Bend i Nuclear Station !

Jan 1981-June 1964 Control Operating Foreman, Gulf States Utilities Company,

l River Bend Nuclear Station June 1979-Dec 1980 shift Test Engineer, General Dynamics Corporation, Electric . 1

. Boat Division i Jan 1971-June 1979 Electronics Technician - Reactor Operator, United States . j Navy i l

SPECIAL !

QUALIFICATIONS: USNRC Senior Reactor Operators License .

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Appendix F - Clay C. Warren . F-19

^

SPECIAL ASSIGNMENTS: Nine Mile Point 2 Operational Readiness Assessment Team Inspection 3

reach Botton - Special Team Inspection March 1986 l i l

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.i M WITEDSMTt3 APPENDIX G a \ NUCLEAR REGULA10RY COMMIS$10N I s nnason l l I 47e ALLINOALa ROAD l i MING oF PRtestA. PeNNeVLVANIA 1edee ,

01 SEP 1988 . . l The Commonwealth of Massachusetts !

Executive Office of Pubite Safety i ATTN: Mr. Charles V. Barry l One Ashburton Place

, Boston, Massachusetts 02108

)

Dear Mr. Barry:

l This nfers to our letter of July 13, 1988, ngarding the Commonwealth of !

1 Massachusetts' participation in the Integrated Assessment Team Inspection i

(IATI) conducted at the Ptigrim Nuclear Power $tation.

As the NRC Senior Manager responsible for the inspection I would like to ac-knowledge the conduct of the designated state representatives Ms. Pamela J. Chen <

and Mr. Steven C. Shelly as being professional and contributing to the perfor- !

sance of the inspection.

The established protocol (enclosed) provided to you on June 1,1925, clarifid by our letter of July 13, 1988, and discussed directly by myself with l Mr. Peter Agnes of your staff on August 9,1988, provides for collection and

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coordination of the concerns from the various interests within the Commonwealth, i As stated in our July 13, 1988 letter, the NRC placed the burden on the Common-i wealth's npresentative to present the many views, be they from the local 1 governments or f rom the State's Attorney General's of fice, to the NRC fo=

i consideration during development of the inspection scope. In this regard, we understand that Mr. Agnes conducted a public meeting on August 4,1988, witn a i designated state representative to the IATI present.

On August 9,1988, having nceived no issues from the Commonwealth as an additional input to the existing inspection plan, I contacted the Assistant Secretary of Public Safety directly and was assured that: no formal input to i the IATI inspection plan would be submitted by the Commonwealth, the d

Commonwealth would work through the designated representatives for any issues I and that issues brought to the Commonwealth's attention were no dif ferent than

! those previously noted. Also, the team leader has notified me that at no time

! during the inspection did he receive immediate notification of any different I state observation or concluston as would be called for under Protocol ,

Guideline 3 if any such diffennces were identified during the inspection.

t

) Since the IATI exit meeting conducted on August 24, 1988 which vss attended by i Mr. Agnes and Ms. Chen, the Ct,emonwealth has empressed on several occasions j both to the media and at public meetings that technical issues and management concerns continue to exist. These statements appear inconsistent with the i

{

Commonwealth's response to repeated NRC nquests for IATI inspection scope i j input and moreover inconsistent with the Commonwealth views expressed at the

, !ATI exit meeting. !

l l I In order to better understand and address the areas of concern, the NRC !

! requests that in accordance with the protocol agreement accepted by the l l' Commonwealth, as Orovided for by Guideline 3, that the Commonwealth make l available in writing those conclusions or observations that are substantially

! different from those of the NRC inspectors in order that the NRC can take the j necessary actiont, to meet its reguletory responsibilities.

i _ - - __.

G-2 Mr. Charles V. Barry 2 0i SEF G88 It is necessary that the Coseenwealth's response be provided to the NRC Region I by September 6, 1988, to be considered in conjunction with the documentation of the results of the recently completed IATI. This request was discussed with Mr. P. Agnes of your staff on August 26 and August 31, 1988.

If you have any questions regarding tr.3 above matters, please contact me at (215 337-5126 or the State Liaison Officer for Region I, Ms. Marie Miller at (215 337 5246.

Sincerely, M eputy Director Division of Reactor Projects

Enclosure:

As Stated cc w/ enc 1:

R. Bird, Senior Vice President - Nuclear K. Highfill, Station Director R. Anderson, Plant Manager J. Keyes, Licensing Division Manager E. Robinson, Nuclear 1r. formation Manager R. Swanson, Nuclear Engineering Department Manager The Honorable Edward J. M2rkey ,

The Honorable Edward P. Kirby The Honorable Peter V. Forman B. McIntyre, Chairman, Department of Pubite Utilities Chairman, Plymouth Board of Selectmen ,

Chat man, Ouxbury Board of 5electmen Plymouth Civil Defense Director P. Agnes, Assistant Secretary of Public Safety, Commonwealth of ,

Massachusetts i

5. Pollard, Massachusetts Secretary of Energy' Resources I

R. Shinshak, MA55P!RG Public Document Room (POR)

Loral Pubite Document Room (LPOR)

NuclearSafetyInformationCenter(N5IC)

NRC Resident Inspector CommonwealthofMassachusetts(2) l bec w/ encl:

Region ! Docket Room (with concurrences)

5. Collins, DRP J. Wiggins, ORP R. Blough, ORP L. Doerfietn, DRP R. Beres, OR55 O. Mcdonald, PM, NRR l 1

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Ge3 ENCLOSURj .

j Guidelines for, Accompaniment on the Intecrated Assessment Team Inspeetten The following are guidelines for accompaniment during NRC's Pilgrim Integrated ;

Assessaent Team Inspection. )

The observer is to make arrangements with the Itcensee for site access 1.

training and badging.

2. The observer shall be available throughout the inspection and will accom-pany NRC inspectors. Communication with the licensee will be through the appropriate NRC team member, preferably the team leader.

3. When the conclusions or observations made by the Cosmonwealth of Massachusetts observer are substantially different from those of the NRC inspectors, Cosmonwealth of Massachusetts will make its observations immediately known to the inspection team leader and available in writing l to the NRC and the licensee, in order that WRC can take the necessary l actions to meet its regulatory responsibilities. These ccmunications will be pubitely availabtr, sistlar to NRC inspection reports, l

4. NRC inspectors are authorized to refuse to permit continued accompanteent

' by the Commonwealth' of Massachusetts observer if his conduct interferes l with a fair and ortlerly inspection. )

l

5. The Commonwealth of Massachusetts observer in accompanying NRC inspectors will not normally be provided access to proprietary information. No license material say be removed from the site or Itcensee possession I without NRC approval.

6. The Ceasonwealth of Massachusetts observer in accompanying the NRC inspectors pursuant to these guidelines does so at his own risk. The NRC will accept no responsibtitty for injuries and exposures to harmful substances which w.y occur to the accompanying individual during the inspection and will ashoe no liability for any incidents associated with the acceepaniment.

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September 6, 1988 samuel J. Collins, Deputy Director Division of Reactor Projects N.R.C. Region one 475 Allendale Acad King of Prussia, Pa. 19406

Dear Mr. Collins:

This is in reply to your letter dated September 1, 1944, completed the regarding IATIcommonwealth's participation in the recently inspection.at Pilgrim Station.

The Commonwealth's observers, Mr. Sholly and Ms. Chan, generally concur with the findings of the IATI team. The commonwealth's observers followed the prescriptions of paragraph three of thw ' Quid =11nes For Accompaniment On The Integrated Assessment Team Inspection

by communicating their observations, concerns and comments about matters constdered during the inspection to appropriate N.R.C. personnel during the inspection.

about the IAT: at The only additional comment we wish to add this time is a recommendation by Mr. Sholly, that in view of of a satellite 207, the difficulty in one case with implementation all new plaat procedures that there beforeshould restart.be an effort to valida:e Any specific reaction we may have to the written IATI report will, of course, have to await our review of the document. -

However, as I pointed out during the recent S.A.L.P.

! messing, the Commonwealth reserves the right to disagree with 1 the 1ATIconclusions findings. drawn by the N.R.C. or the licensee about the I

For example, notwithstanding what might be considweed unmistakable evidence of progress by Boston Idioon Company, the Commonwealth remains skeptical of the licensee's readiness to restart at this time. In addition to our concerns abaut offsite emergency preparvdnvas which have been outlined recently in letters to Mr. Henry Vickers of P.E.M.A., Regional Administrator William Pusse11, and to the A.C.R.S. Ad Koc Subcommittee on the restart of Pilgrim, the Commonwealth is concerned that mediocre scoreo by the licensee during the last 91ri:::,::es unc l

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Secuol Collino, N.R.R.

september 6, 1988 j Page Two ;

S.A.L.P. period coupled with a history of poor performanco by the licensee have not been taken seriously enough in the staff's evaluation of readiness to restart. If the licensee is unable to achieve S.A.L.P. scores that rven equal the national average for licensed commercial nuclear power plants in this country while Pilgrim remains shutdown, why should wa believe that the plant is ready to restart?

eome of ~1r other concerns, which transcend the scopo of the , at outlined in our letter to the A.C.R.G., a copy of ;

whict 16 forwarded to you tomorrow.

We appreciate your acknowledgment of the professionaliom exhibited by Mr. Sholly and Ms. Chan during the IATI and the cooperation extended to them by the team members and the l licensee.

l cI ly, Uh

/

. W. Agnes, Jc.

Assistant of Public Safety Secretary( )

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October 15, 1987 -

FEDERAL EXPRESS Director of the Office of Nuclear Reactor Regulation U.G. Nuclear Regulatory Commission Washington, DC. 20555 RE: Enclosed 10 C.F.R. S 2.206 Petition concerning the Pilcrim Nuclear Power Station

Dear Sir:

Enclosed is the Petition of Michael S. Dukakis, Governor and James M. Shannon, Attorney General for the Institution of a Proceeding Pursuant to 10 C.F.R. S 2.202 to Modify, Suspend, or Revoke the Operating License Held by the Bosten Edison Company For The Pilgrim Nuclear Station, which I am filing on behalf of myself and Governor Michael S. Dukakis.

Very uly you ,

psb n' Jame# M. Shannon j Atta :ney General 1 i

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UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION PETITION OF MICHAEL S. DUKAKIS, GOVERNOR AND JAMES M. SHANNON, ATTO. 'CY GENERAL FOR THE INSTITUTION OF A PROCE:, DING PURSUANT TO 10 C.F.R S2.202 TO MODIFY, SUSPEND, OR REVOKE THE OPERATING LICENSE HELD BY THE BOSTON EDISON COMPANY FOR THE PILGRIM NUCLEAR STATION Dated: October 15, 1987

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UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION PETITIOtt OF MICH AEL S. DUKAKIS, GOVERNOR AND JAMES M. SHANNON, ATTORNEY GENERAL FOR THE INSTITUTION OF A PROCEEDING PURSUANT TO 10 C.F.R S2.202 TO MODIFY, SUSPEND, OR REVOKE THE OPERATING LICENSE HELD BY THE BOSTON EDISON COMPANY FOD. THE j PILGRIM NUCLEAR STATION 5

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Dated: October 15, 1987 e

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TABLE OF CONTENTS I. . INTRODUCTION . . . . . . . . . . . . . . . . . . . . . 1 II. EVIDENCE OF SERIOUS MANAGERIAL DEFICIENCIES . . . . . 3 A. OVERVIEW . . . . . . . . . . . . . . . . . . . . . 3

3. 3ECo'S PAST PERFORMANCE . . . . . . . . . . . . . 4 BECo's SALP Evaluations . . . . . . . . . . . . . 5

, 3ECo's Regulatory Violations . . . . . . . . . . . 7 C. RECENT INDICIA OF BECo'S PERFORMANCE LEVEL . . . . 9 BECo's 1987 SALP Report . . . . . . . . . . . . 10 Recent Reports of Violations . . . . . . . . . . 12 III. EVIDENCE I.iA INDICATES THAT A PLANT SPECIFIC PRA FOLLONED 3Y IMPLEMENTATION OF ANY INDICATED SAFETY MODIFICATIONS SHOULD BE REQUIRED PRIOR TO PILGRIM'S RESTART . . 12 IV. EVIDENCE OF INADEQUATE EMERGENCY PREPAREDNESS . . . 15 1 CONOLUSION . . . . . . . . . . . . . . . . . . . . . 21 I t

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i UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION PETITION OF MICHAEL S. DUKAKIS, GOVERNOR AND JAMES M. SHANNON, ATTORNEY GENERAL FOR THE INSTITUTION OF A PROCEEDING PURSUANT TO 10 C.F.R 52.202 TO MODIFY, SUSPEND, OR REVOKE THE OPERATING LICENSE HELD BY

. THE BOSTON EDISON COMPANY FOR THE PILGRIM NUCLEAR STATION

.i I. INTRODUCTION L Governor Michael S. Dukakis and Attorney General James M. Shannon, pursurnt to 10 C.F.R. 52.206, hereby request thtt the Director of the Office of Nuclear Reactor Regulation institute a proceeding pursuant to 10 C.F.R. $2.202 to modify,

, suspend, or revoke the operating license held by Boston Edison

, Company ("BEco." or "the Company") for the Pilgrim Nuclear j

, Power Station ("Pilgrim") in Plymouth, Massachusetts. This petition is filed on behalf of the Commonwealth of Massachusetts and its citizeas. The Governor and the Attorney General base this request on evidence of continuing serious managerial deficiencies at the plant, on evidence that a plant

. specific probabilistic risk assessment ("PRA") as well as the t

implementation of any safety modifications indicated thereby 1 2 l should be required prior to Pilgrim's restart, and on evidence I

that the state of emergency preparedness does not provide reasonable assurance that adequate protective measures can and i l

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will be taken in the event of a radiological emergency during operations at the Pilgrim plant. The Governor and the Attorney Genraral submit that this evidence, as set forth below, demonatrates the necessity of Nuclear Regulatory Commission

("NRc") action pursuant to 10 C.F.R. $2.202.

'i j Further, the Governor and the Attorney General believe that

.i the public interest requires that the NRC exercise its authority under 10 C.F.R. S2.202(f)1/ so the.t BEco, is prevented from proceeding any further with the restart of Pilgrim2 ! until a formal adjudicctory hearing has been held and findings of fact are made concerning the safety questions surrounding the continued operation of the Pilgrim plant. In particular, the Governor and the Attorney General request that i

the NRC issue an order, effective immediately, modifying BECo's

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operating license to preclude BEco. from taking any steps in i

, 1/ 10 C.F.R. 2.02(f) provides:

When the Etecutive Director for Operations, during an energency as determined by the ELO, or tiie Director of Nuclear Reactor Regulation, ;

Director of Nuclear Material Saftty and t

Safeguards, Office of Inspections and Enforcement, as appropriate, finds that the

, public health, safety, or interest so requires i or that the violation is willful, the order to show cause may provide, for stated reasons, that

, the proposed action be temporarily effective l pending further review. 4 3/ At each step of BECo's so-called "power ascension" l program there is an increase in the probability of an eccident at Pilgrim as well ss in the potential coasequences of such an accident. See Affidavit of Steven C. Sholly (attached hereto as Ittachment 1).

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e ' a it- power ascension progrr.m until the hearing is held and the -

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findings are made.

II. EVIDENCE OF SERIOUS MANAGERIAL DEFICIENCIES

- Recent events at Pilgrim indicate that BECo. has not 1 corrected the long-standing managerial shortcomings thst have j plagued the plant. In the areas of security, radiological cont rols, pe rsonnel niunagement , and corporate culture, the

! management of Pilgrim continues to be seriously flawed. As a result, Pilgrim poses an unreasonable risk to public health ano safety. Its continued operation under the present >

circumstances is inimical to public health and safety.

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. A. OVERVIEW i

l Pilgrim commenced commercial operation in June, 1972, when i BEco. received an operating license for the plant. During the !

intervening fifteen year period of operation by BEco., Pilgrim 1 has had a capacity factor of approximately 50 percent,1/

.! which compares quite unfavorably with the average for all New !

England nuclear plants of approximately 67 percent.A!

1/ The "capacity factor" for a plant is performance in terms of the power it has a measure of actually delivered

' I over a period of time relative to the power it was capable of dq11vering over that same period of time. It is calculated by dividing the actual number of kilowatt hours produced by the plant in the period of measurement by the product of the plant's rated kilowatt capacity and the number of hours in the 1

period. I 4 . l 4 4/ Electric Council of New England, New ?.ngland Nuclear News, i TJune, 1987) (Attached hereto as Attachment 2). j l

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B. SECo's PAST PERFORMANCE The plant has been out of service since April, 1986, when the NRC, in Confirmatory Action Letter 86-10, ordered a shutdown after recurring oporational problems at the plant.E/

Pilgrim has been beset with managttrial proble.ns f rom the l J

outsot. BEco. has consistently received low ratings in the NRC's Systematic Assessment of Licensee Performance ("SALP")

Pilgrim has been identified by the NRC as one of the l

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' worst run and least safe plants in the countrv5/ and BEco, was ordered to initiate performance / management improvement programs in 1982, and 1984.2/ BEco. has been the subject of a long line of enforcement actions as a result of regulatory violations. While,the NRC's efforts to spur BECo. to a higher

- level of performance have, on occasion, met with some initial success, a review of BEco's performance record, however, shows that all such successes have been short lived. Indeed, BEco.

1/ Confirmatory Action Letter 86-10 was clarified and expanded in an suhsequent letter, dated August 27, 1987, from the NRC Region 1, Regional Administrator to BECo's Chief Operating Officer. (attached 1;ereto as Attachment 3). In this letter, BEco. was informed that:

i In light of the number and scope of the i outstanding issues, I (the Regional Administrator) am not prepared to approve

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restart of the pilgrim facility until you a (BECo.) provide a written ieport that documents 3Sco's formal assessment of the readiness for restart operation.

6/ Boston Globe, May 28, 1986. ;

order Modifying License Effective Immediately, 47 !

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Fed. Reg. 4171 (January 28, 1987). j l

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J appears to have an organic inability to manage Pilgrim in an effective and safe manner.S/

- BEco's SALP Evaluations **

, [ BECo. has consistently received low ratings in SALP '

! j reports.A/

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! 1/ Although it is the failings of BEco's management of the !

, , Pilgrim plant which are the subject of this petition, it is i significant that findings have been made in other settings that :

j confirm SECo's managerial deficiencies and indicate that they !

extend to the other aspects of its business. See e.g., Boston '

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Edison Company, Massachusetts Departmsnt of Public Utilities q Docket No. 87-1A-A (1987) (imprudence in operation of oil fired )

generating unit). Of particular relevance to the notion that i

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BEco. responds to the identification of deficiencies with half-hearted (although sometimes quite showy), short-term

! solutions that treat the symptoms, not the disease, is the i

series of decisions by the Massachusetts Department of public Utilities that address BEco's need to consider and develop new sources of power in the afterma*.h of the 1)81 cancellation of the construction of the Pilgrim II nuclear unit. Boston Edison Coqpany, MDPU 906 (1982) (ordering BEco. to develop a new plan to meet its future power needs); Boston Edison Company, MDPU i

No.86-270 (found reason to believe BEco lacked commitment and/or skill to fulfill public service obligation).

3, 9/ The SALP process is the mechanism by which the NRC on a periodic basis systematically assesses the overall performance

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of a licensee. For each assessment period (generally 12 cc 18

] j months) a Board of NRC officials evaluates, in accordance with preestablished attributes and rating guidance, the licensee's 1 performance for each of the various, preestablished functional i

areas and rates the licensee's performance in each area. The

! . Board also compares the licensee's performance for the current

period with that of the previous assessment period and identifies, for further followup and inspection, any areas i uhere the licensee's corrective action to improve performance

has not been fully effective.

1 Arizona Public service company, (Palo Verde Nuclear Generating j Station, Unit 2), DD-86-8, 24 NRC 151, 156 (1986).

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In 1980, BEco, received ratings indicating significant weakness in three of the nine functional areas evaluated. The most l ren?nt SALP Report, seven years later, indicates that conditions have not improved but rather have worsened. BECo.

received ratings indicating significant weaknesses in five of I

, the twelve functional areas evaluated. It has only once t

'j received a SALP Report without a rating indicating a

]l. significant weakness. On all other occasions, it has received reports indicating significant weaknesses in at least two functional areas. (See Appendix I: BEco. SALP History Tabulation) of particular significance, every time Quality Assurance has been assessed as a separate functional area during a SALP review, BEco. has received the lowest possible rating. These findings are indicative of the ineffectiveness of BEco's management. They are a measure of its inability and/or its lack of commitment to run the plant in a effective and safe manner.

Although BEco. has at one time or another received the lowest possible rating in all but three of the twelve functional areas covered by the NRC's SALP process, these individual poor SALP ratings are not the most troubling aspect '

of BEco's SALP record. Instead, the most troubling and telling ,

facet of BEco's SALP record is the Company's distinct inability to maintain any period-to-period performance improvements.

BECo. has at one time or another improved its SALP performance !

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, in eight functional areas. However, it has not been able to !

sustain the increased level of performance in seven of those eight areas. In all but one instance, BEco's improved performance proved to be short-lived and its performance subsequently fell back to lower Scvels. This is not surprising 1

J as an ever recurring theme in NRC evaluations of BEco's

's t performance is that NRC oversight and prompting is necessary at every stage of Pilgrim's operation.M ! The increased NRC attention (i.e., oversight and prompting) that a "3" rating calls for has, on occasion, produced better performance by BEco. Hosever, when that level of attention returns to that norm, BECo's performance falls below the norm. BEco's SALP track record is proof of the proposition that BECo. by itself

! has not effectively operated Pilgrim and that the short-term solutions it has adopted in response to criticism have ;

invariably permitted the reoccurrence of the original problems.

- BEco's Regulatory Violations **

BECo., an enforcement action record that is a mirror of ite j SALP Report record. It has had at least one Severity Level III

., violation during each of the past six years. U / (See 4

M/ E.g., 1987 SALP Review at 8; 1986 SALP Review at 7.

1j,/ As set forth in 10 C.F.R. Part 2, Appendix C; General !

Statementof Policy and Procedure for NRC Enforcement Actions, j regulatory violations are categorized into five descending '

levels of severity. Level III corresponds with "violations

, that are cause for significant concern."

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Appendix II: BECo. VIOLATIONS TABULATIONS - SEVERITY LEVEL III VIOLATIONS) In the area of Security and Safeguards, BEco. had a Severity Level III violation in all but one of the years between 1981 and 1986. In 1982, a civil penalty in the amount 1

.i of $550,000 -- at the time the largest penalty to have ever been assessed by the NRC -- was levied against BEco. for

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serious plant operations violations and for submitting false i

i information to the NRC.12! While the number of such Severity Level III violations discovered at Pilgrim has not exceeded two in any single year since 1981, the number of Severity Level IV violations per year has more than doubled in the past few years.

BEco's enforcement action record also mirrors its SALP

! Report record in demonstrating BEco's chronic recidivism. It has been cited five times for Radiological Controls violations involving waste shipment packaging requirements.11/

It has been cited five times for 5ecurity and Safeguard

! violations involving the control of sensitive material such as keys to vital areas, sacurity plans, and firearms.1d/

l 12/ U.S. General Accounting Office, Reoort to the Honorable Alfonse M. D'Amato, U.S. Senate: Nuclear Regulation Efforts to Ensure Nuclear Power Plant Safety Can Be Strengthened

, IGMi-RCED-87-141 August, 1987), pp. 36-37.

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! 13/ See NRC Enforcemtnt Sunimary Tables taken f rom various SALP

! Reports (attached hereco as Attachment 4).

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i C. RECENT INDICIA 0F BECo'S PERFORMANCE LEVEL The most recent indicia of the level of BEco's performance in managing pilgrim are consistont with its past performance.

. They confirm the notion that BEco. appears to be organically incapable of managing a auclear facility. Notwithstanding the i frequent incantation by senior management of a program for the t

j "pursuit of excellence," the addition ef new personnel and the i expenditure of large sums of money,IE/ the available evidence indicates that BEco. has not changed. Its 1987 SALP Peport shows that the company continues to merit the lowest possible ratings in many functional areas. BEco. continues to be !

incapable of maintaining performance gains. On the basis of

, news reports, it appears that BEco's management of the Security

! and Safeguards function la deteriorating, not improving.

Fur'.aer, on the basta of statements made by NRC of ficials at a recent meeting, the NRC has received and is investigating allegations that the company may be compromising safety by

. overworking its or its contractors' employees in an effort to

! return the plant to service soon, This evidence suggests that l BEco's claim to be approaching readiness for restart may

15/ E2 L., NRC Docket No. 50-293, official Transcript of NRC 6Tfice of Nuclear Reactor Regulation, "Meeting With Boston Edison Ret pilgrim Status and Activities Leading to Restart

IteaJiness," pp. 13-14, 18-20 (September 24, 1987) (hereinafter 59 M./24/87 aphen J.NRC/BEco.

Sweeney,Readiness p re sT3ent Meeting").

and Chief(Testimony Executive Submitted officer, by Boston Edison Company, to the U.S. House of Repetsentatives, Subcommittee on Energy Conversation and power of the Committee on Energy aid Commerce July 16, 1986, pp. 4-5 (attached hereto as "Attachmont 5").

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4 be hasty and misleading.15/

- BEco's 1987 SALP Report **

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on April 8; 1987, the NGC released a SALP Report for BECo.

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, which was based on the results of various inspections and ;

l ovaluations conducted at Pilgrim over the period from

.I November 1, 2985 through January 31, 1987. Ratings were given

'.I-; for BEco's parformance in twelve functional areas. In keeping with its pat record, BEco. received the lowest possible ,

ratings in five of the twelve functional areas.12# It received the highest possible rating in only two functional areas.11/ The picture painted in the SALP report is one of a plant with "(p)oor management control," an "obscured ... chain of command and weakened accountability," and "(s)significant i

recurring program weakness ... in some functional areas, showing the effect of ... long-term problems."1A#

I 16/ 3Eco's claim of readiness should be measured against its adoption of 9/24/87 NRC/BEco. Readiness Meeting, e. 43. This i tendency to ignore reality in the operation of the plant has

] been previously found to be undesirable.. See Boston Edison j company, MDPU NO. 1009-F (1902) (BEco. denied where evidence

established that it had imprudently underestimated tne

, , necessary time requireo ( ) perform outage tasks).

17/ T!.e five areas were Radiological Controls, Surveillance, 4

Ytre Protection, Security and Safeguards, and Assurance of Quality.

4 A8/ The two a:eas were: Outage Management, Modifications, and Technical Support Activities and Engineering and Corporate Technical Support.

4 19/ 1987 SALP REPORT at 8.

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Of particular importance to this Petition, were SALP I '

ratings in three areas where BEco had previously improved its peeformance. In the functional areas of Surveillance, Fire Protection, and Licensing Activities, BECo. had in the past

. irqproved its ratings between periods -- in fire protection, it i

l had gone from a "3" to a "1" between its third and fourth SALp ,

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.{ Reports -- but by the time of the review for the 1987 SALP

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. Report, its performance had fallen back to earlier levels.

With respect to the functional area of Security and Safeguards, the 1987 SALP Report discussed continuing hardware problems, BEco's excessive reliance upon contractors, and management's failure to give this area sufficient

> .' attention.22/ The report noted that BEco's corrective l actions for deficiencies in this area had not generally been

! effective and referenced three degradations in vital area l

[ barriers that had occurred during the evaluation period.11/ l 5

20/ Id. at 31-34.

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21/ The Commission's requiations define a "vital area" as any l area which contains:

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. any equipment, system, device, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. Equipment or j systems which would be required to funccion to !

i protect public health and safety following such I failure, destruction, or release are also I considered vital areas. 10 C.F.R. 573.2(h) and (1) (emphasis added). Such areas are *o "be located within a protseted area such that access to vital equipment requires passage through at least two physical barriors." 10 C.F.R. l 573.50(b)(1). Access into a protectad area is to be controlled through the checking of authorization and identity at entry control points i

to which barriers surrounding the protected area "channel persons and material." 10 C.F.R l

573.45(b)(1)(1) and 73.50(c).

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- Recent Reports of Violations **

s on the basis of nsas reports and statements made by NRC officials at a recent meeting, it appears that BECo. has suffered from at least four significant Security and Safegua ds lapses in the past six months: a misplaced guns a misplaced set of sensitive keys; a "serious degradation in a vital area

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barrier;" and ineffectite identification cards.12/ While all

'j four alleged lapses would be significant, the latter three

would be a particularly strong indication of BEco's failure to learn from its past mistakes -- nearly identical lapses have occurred in the past.SA/

Purther, allegations have recently been made which NRC i

stated at a recent meeting that they are investigating that i

BECo. may be compromising worker and/or plant safety by requiring excessive overtinie.SA!

III. EVIDENCE THAT INDICATES THAT A PLANT SPECIFIC

! PRA FOLLOWED BY IMPLEMENTATION OF ANY INDICATED

! SAFETY MODIFICATIONS SHOULD BE REQUIRED TO

! PILGRIM'S RESTART.

1 Pilgrim is a GE Merk I design plant. As such, it has a primary contairiment which, by nearly unanimous agreement, has i

an extremely high probability of failure in the event of

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. 22/ Eoston Globe, September 4, 1987, p. 1: Boston Globe,

' September 9, 1987, p. 21; Boston Herald, September 10, 1987,

p. 24.

I3/ See 1985 CALP Reoort, p. 40s 1963 SALP Report, pp. 41-43; iT82 5IEP' Report, p. 38 (included in Attachment 3 hereto).

Ad/ Boston Globe, September 29, 1987, p. 21.

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1 certain accidents.E ! This characteristic is especially critical since Mark I design reactors, such as Pilgrim, do not j have the backup of a secondary containment structure which can withstand any significant position pressure. ( " PilR s" ) .E! In

,; fact, Pilgrim's so-called "containment building" is not really designed to perform a backup function. It has "blow panels" l

) which in some design and most severe accidents would activate r

. and create a ready path for hazardous radioactive materials to escape into the environment.E ! The combination of an i

extremely vulnerable primary containment structure, a secondary i

a containment not designed to provide an effective backup, and the large population in the immediate vicinity of PilgrimE !

' compel the Governor and the Attorney General to request that the NRC modify the Pilgrim operating license to b&r restart I

j until a plant specific probabilistic risk assessment ("PRA") is performed for Pilgrim and all indicated safety modifications are implemented. Until this occurs, the operation of the plant l

would pose an unreasonable threat to public health and

! safety.E! !

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. M/ See comment, HUREG-1150, Reactor Risk Reference Document, Draft for Feb. 1987, at 4-33, 4-39.

l i 26/ Affidavit of Steven C. Sholly (attached hereto as l Attachment 1).

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9 The Governor and the Attorney General are aware that the i NRC has to date declined to order mitigative modifications for Mark I design plants.2AI They submit, however, that the

, evidence presented here -- the combination of extremely vulnerable containment structures and a large population ;

surrounding the plant -- precludes application of NUREG-ll50's j finding that the probability of a large reactor accident with .

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i early fatalities is extremely remote. The NUREG-ll50 findings

[ do not reflect the amalgam of risks posed oy Pilgrim.

BEco. has proposed a numbar of modifications as remedial ;

actions for the plant's design deficiencies.11/

These 4 actions do not, however, address the inherent defects of the

{ plant's design in any real way. The Governor and the Attorney l General do, however, submit that through its so-called "safety l

enhancement program," BEco. has put the question of the appropriate modifications to be made to remedy the defects of 4

i the Mark I design in issue.

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Ja/ E.o., Boston Edison Company (Pilgrin Nuclear Station),

DD-87-14, __ NRC __,(1987) (slip at 31-32).

11/ Letter with enclosures dated July 8, 1987, from Mr. Ralph G. Bird, Senior Vice Prtsident-Nuclear, Boston Edison Company, to Mr. Steven A. Varga, Director, Division of Reactor ,

projects, I/II, Nuclear Regulatory Commission (attached hereto as Attachment 6).

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j IV. EVIDENCE OF INAD, EQUATE EMERGENCY PRSPAREDNESS Within the past twelve months, two authoritative assessments have been made of the Pilgrim P.adiological l Biaargency Response Plan and the state of emergency preparedness l uithin the Emergency Planning Zone ("EPZ") for Pilgrim.22/

Doth conclude that the plan and the state of preparedness "are 1

not adequate to protect the health and safety of the public in I

j the event of an accident at the Pilgrim Nuclear Power Station."22/

Both also concluded that the plan and the state of preparedness have significant deficiencies and suggest I

potential remedies for those deficiencies that will require a substantial commitment of time, resources and i

j cooperation.2d/ BEco.' has not quarreled with these conclusions.EE/ The Governor and the Attorney General submit !

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that these conclusions compel immediate action by the NRC. The

) l l 2,2/ FEMA, "Self-Initiated Review and Interim Finding for the Pilgrim Nuclear Power Station, Plymouth, MA" (August 4, 1987)

(hereinafter "FEMA Self-Initiated Review"); Secretary of Public 4

Safety, "Report to the Governor on Emergency Preparedness for an Accident at the Pilgrim Nuclear Power Station" (December 16, 1986) (hereinafter "3arry Report").

I 13/ PEMA Self-Initiated Review at 1-2; 3arry Report at 74.

34/ FEMA Self-Initiated Review, pp. 12-13, 19, 22, 29-32, j j 43-44; Barry Report, pp. 47-55.

l J5/ 9/24/87 NRC/BEco Readiness Meeting", pp. 49-54.

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I authoritativo expert agencies 15/ agree that there is no censonable assurance that the public car or will be protected in the evant of an accident at Pilgrim. It is, thus, incumbont upon the NRC to take action immediately to insure that no steps i are taken by BECo. which could increase the likelihood or the consequences of an accident.22/

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' A. THE PLANNING AND PREPAREDNESS DEFICIENCIES IDENTIFIED BY FEMA AND THE MASSACHUSETTS EXECUTIVE OFFICE OF PUBLIC SAFETY The deficiencies of the Radiological Emergency Response Plans for Pilgrim are manifold. Although the analyses of FEMA and the Massachusetts Executive Office of Public Safety do not reach the same conclusions on all issues, the following areas

of substantial deficiency have been identified by both agencies:

l. the lack of any articulated evacuation plans for public and private schools as well as day care centers;

2. the lack of any articulated evacuation plans for the special needs population; i

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{ 16/ FEMA is explicitly recognized by the Commission as the export Federal authority on questions of nuclear power plant offsite emergency preparedness (Memorandum of Understanding, 50

. Fed. Reg., No. 75, 15,486 (April 18, 1985) and the Commission is evpressly required to base its findings on off-site 1 en.ergency issues on FEMA's conclusions concerning such issues.

I 10 C.F.R. S50.47(s)(3). The Hassachusetts Secretary of Public l Safety oversees the Massachusetts Civil Defense Agency and Office of Emergency planning, which pursuant to M.G.L. c. 147,

$1 is responsible for the Commenwealth's emergency activities.

17/ Each step of BEco's pow 1r ascension plan corresponds with

. a substantial increase in the probability o.' an accident at Pilgrim. Affidavit of Steven C. Sholly (attached hereto as Attachment 1).

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3. the lack of any articulated evacuation plans j for the transport dependent population;

4. the lack of identifiable public shelters for the beach populations

5. the lack of a reception center, as required

. in the plan, for people evacuating by the

. northern route;

.! 6. the lack of real progress in planning and the diminutioningpestateofemergency preparedness._3_

These are critical deficiencies. The plans do not even 3 purport to provide any measure of protection for significant numbers of people: pre-school and school age children; those 4

who require special measures to transport; and those without ready access to private transportation. They fail to address the significant beach population in an adequate fashion. They I do not incorporate currcat or reliable evacuation time I estimates ("ETEs"). Nor do they incorporate a delineated

'l inventory of identified and identifiable shelters which are accessible to the public. Moreover an integral component of the current plans -- a northern reception center 11 l

,' 38/ FEMA Self-Initiative Review, pp. 12-13, 19, 22, 29-32,

43-44; Barry Report, pp. 47-55.

! 39/ The lack of a reception center for those evacuating to the 1

I north is as wor 61some as the more general planning failures.

The lack of a northern reception center indicates that even if i,

ovacuation from the Ep2 were successful -- a heroic assumption in light of the assorted planning deficiencies -- those who

' received and followed instructions to evacuate to the north would find no facilities available at their designated destination. According to FEMA, approximately 60,000 people weald be left without facilities at which to register, be monitored and decontaminated if necessary. TEMA Self-Initi9ted Revi_ew at 19.

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~~ is missing altogether. Finally, offsite exercises and drille -- the most effective means of assuring preparedness --

have not been held in years.

B. THE CURRENT STATUS OF PLANNING AND PREPAREDNESS I

l The specific functional deficiencies in the first four I areas enumerated above, as well as the functional areas in

! which work must be done before any determination can be made if adequate plans can be developed, encompass the entire set of tasks required for adequate planning and preparedness:

1. Identification / Estimation of populations; i

! 2. Identification / Estimation of resources;

3. Develop plans for emergency actions to be taken for each population with potentially

available resources;

4. Obtain commitments for required resources;

5. Provide education /information to public; 1

, 6. Conduct exercises / drills, t

! At present, it appears that the school /daycare population

} has been identified but that the special needs and transport dependent populations have not. DEI Preliminary estimates of j .l the resources potentially available to evacuate these populations have now been obtained, but neither plan development nor obtaining commitments of resource availability can proceed in the absence of reliable ETEs.d1!

, 10/ Executive Sunmary of the Reoort on Emergency Preoaredness i

For an Accident at Pilgrim Power Station) (October 15, 1987)

, (hereinafter "Barry Report Update"), p. 2.

41/ Id. at 2.

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] While BEco. has recently -- August 18, 1987 -- delivered an ETE study to the Commonwealth's public safety officials,12/

the document is still being reviewed by those officials and preliminary analysis has uncovered shortccraings that will

necessitate further work. It is, thus, unlikely that final j ETEs will be available within the immediate future for use in j developing specific plans.32/ This shortcoming is critical.

1 l A consequence of the unavailability of reliable ETEs is that

,; emergency planning is effectively on hold. Even when the task of identifying / estimating populations and resources is completed, radiological emergency planning cannot in any real sense proceed without reliable ETEs and a trcffic management l plan. As FEMA and the NRC well recognize, a realistic set of f

1 ETEs is an essential element of a workable emergency plan. See Cincinnatti Gas & Electric Company (Wm. H. Zimmer Nuclear Power Station, Unit No. 1), ALAB-727, 17 NRC 760, 770-71 (1983).

I With respect to the beach population, preliminary

, population estimates and sheltering data have been provided to

.! the Commonwealth's public safety officials but, at least in the

-4 case of the sheltering survey, these materials have been found T

1 42/ KLD Associates, Pilgrim Station Evacuation Time Fstimates

and Traffic Management Plan Update (Final Draft for Review)

August 18, 1987.

i f}/ Barry Report 9pdate, p. 2.

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to be inadequate for planning purposes. EI l Again, plan development and resource availability commitments, ianch loss public education /information ef forts and exorcises / drills, cannot proceed usefully without reliable final. ETEs and sheltering data.E/

No replacement site for a northern reception center has l been foundE! and no determination h9 yet been made whether i an emergency plan incorporating only two reception centers !

would provide an adequate assurance of protection.E!

J

,4 4/ Barry Report Update, p. 2; Letter with enclosures from Robert J. Boulay, Director, Massachusetts Civil Defense Agency, dated September 18, 1987, to Ralph C. Bird, Executive Vice President-Nuclear, Boston Edison Company (attached hereto as Attachment 7)

, j 5 4_5,/ Barry Report Update, p. 2; See also FEMA Self-Initiated j Review at 26-27:

li Before FEMA and the RAC can make a determination on this (whether protective actions for thebeach population are or readily can be made adequate) i it must receive the following information:

i

'l 1) an updated geographical description of the 4

beaches and their capacity; 2) a detailed

. analysis of the beach population, including the 4

number of permanent and temporary residents and

the number of day visitors, together with their

. .j geographical dispersion; 3) an updated estimate of the length of time it would take to evacuate l

l the beach populations and 4) a list of suitable

'] 1 buildings available for sheltering the beach

population at each beach, including the

capacities of these buildings and their

! distances from the beaches. If these buildings

! are not open to the public, the plans must clearly state how they will be made accessible and letters of agreement must be obtained as appropriate.

46/ Id.

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H/ 9/24 NRC/BEco. Readiness Meetino, p. 52. But see FEMA Self-Initiated Review at 19 (The use of only two reception centers "is not likely to be logistica11y faasible.").

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Finally, in the absence of new plans, public information/ education efforts and exercised / drills cannot, by ;

drifinition, occur. There are no plans to inform the public of cxercises, r.;uch less tt exercise. Although the provisions of

.; 10 C.F.R. Part 50, Appendix E, Section IV.F. require that a j full participation biennial emergency preparedness exercise for

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, Pilgrim be held this year, the NRC is presently considering a

request from BEco. for a one-time exemption from that requirement to allow the exercise to be postponed to the second quarter of 1388.30/ -

IV. CONCLUSION In light of all of the foregoing deficiencies of the current state of emergency planning and preparedness, as well 1

as the substantial questions raised herein concerning the managerial ability of the licensee, BECo., and the safety of i

the Pilgrim reactor, the Governor and Attorney General submit j that the NRC must take action pursuant to 10 C.F.R. $2.202 to l insure that BEco, does not take any action that could increase either the risx or the consequences of an accident at Pilgrim.

Since that Pilgrim is a GE Mark I design reactor, and the EPZ population at this plant is among the highest in the country, it is evident that the deficiencies in emergency i

planning end preparedness are significant for Pilgrim. These 3,8/ Letter with enclor.utes dated September 18, 1987, from Mr. Ralph G. Bird, Senior Vice President-Nuclear, Boston Edison i Company, to NRC (attached hereto as Attachment 8).

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i deficiencies are so substantial and their potential ramifications are so significant, that it is' impossible to conclude that any interim compensating actions have or can be taken. The NRC's regulations leave it no course other than I insuing an order modifying Deco's license to extend the current i

shut down pending the outcome of a full hearing on the j

significant outstanding safety issue and the development and certification by che Governor of adequate emergency plans.dAI Respectively submitted, 3

James M. Shhnnon Attorney General o

Commonwealth of Massachusetts

Michael S. Dukakis j Governor 1

Commonwealth of Massachusetts Dated: October 15, 1987 i

$ 19/ Compare 10 C.P.R. 550.54(s)(2)(ii):

... In determining whether a shutdown or other i enforcement action is appropriate, the Commission

, shall take into account, among other factors, whether the licensee can demonstrate to the Commission's satisfaction that the deficiencies in the plan are not significant for the plant in

.. question, or that adequate interim compensating

! actions have been or will be taken promptly, or

' that there are other compelling reasons for l continued operation.

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APPENDIX I: BECo, SALP HISTORY TABULATION Inspec. Plant Radiol. Maint. Surveil. Fire Emergen, j Period Oper. Control Prot. Prepared i

1 01/01/80 2 3 2 2 2 2

, 12/31/80 09/01/80 3 2 3 2 2 1

. , 08/31/81

. 09/01/81 3 2 2 2 3 1 06/30/82 07/01/82 2 2 2 1 1 1 06/30/83

, 07/01/03 2 3 1 1 2 3 09/30/84 10/01/84 3 3 2 2 -

3 j 10/31/85 11/01/85 2 3 2 3 3 2

01/31/87 Inspec. Secur. Out.Mgt. Licen. Eng/ Corp Train Quality i Period Safegds Mod.Act Activ. Tech.Sup Qual.Ef Assuran 01/01/80 2 3 - - -

3 j 12/31/80

.I 09/01/80 2 2 - - -

3 08/31/81

, 09/01/91 2 2 2 - - -

06/30/82

. 01/01/82 2 -

1 - - -

06/10/03 07/01/83 2 1 1 - - -

09/30/04 10/01/84 2 1 1 - - -

10/31/95 11/01/85 3 1 2 1 2 3

, 01/31/S7

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I APPENDIX II: BECo. VIOLATIONS TABULATIONS SF,V8RITY LEVEL III VIOLATIONS: 9/1/81-1/31/87 runeLionni Area 1981 1982 1983 1984 1985 1986 1987 l 1

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Plant Operations 3 1

! R6diol Wical Controls 1 2 l

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Mainenance ,

Surveillance l Fire Protection j 2 L crgency Preparedness 1

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l S turity/ Safeguards 1 1 1 1 Outage Mgt ...

l Licensing Activities

Training . . . Eff' ness r.ssurance of Quality l l

Enginet-/ Corp. Support

! ! BECo. VIOLATIONS SY SEVERITY LEVEL: 9/1/81-1/31/87 i '

! Severity Level 81/02 82/83 83/84 84/85 85/87 l

l l 1 I II 1 j III 7 1 1 2 1 t IV 9 9 18 17 21 ,

V 20 20 6 5 6 j VI 2 '

; Deviations 2 3 1 3 1

. Total Violations 40 33 26 27 29 i

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'l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION EEE0tlF.LIrlECOMMISS10N i

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, in the matter of '

BOSTON EDISON COMPANY Docket No. 50 293 4

(Pitim Nuclear Power Station, Un!t 1)

AFFID AVIT OF STEVEN C. SHOLLY Steven C. Sholly, being on oath, deposes and says as follows:

i 1. I am an Associate Consultant with MHB Technical Associates,1723 Hamilton Avenue, Suite K, San Jose, California,95125. A statement of my professional l qualifications is attached hereto and marked Attachment A. In brief, I have more than six years experience in the review, analysis, interpretation, and application of probabilistic risk assessment to the analysis of safety issues

related to commercial nuclear power plants, including issues relsted to

radiological emergency planning I have sented as a member of the peer j review group for the NRC publication NUREG 1050 (1984) (Probabilistic Risk l 61sessment (PRA) Reference Document, September 1984), and have more 4

.l recently served as a member of the Containment Performance Des /gn

! .ObjectNe Workshoo, the Panel on AGRS Effectfveness (1985), and the Severe Accident Policv Imolementatiqa Edgmal Events Workshoo (1987). l have I

. previously testified as an expert witness on prob",bilistic risk assessmeint and emergency planning matters in NRC proceedings on the Catawba Units 1 and 2, Indian Point Units 2 arid 3, and Shorehain Unit i nuclear plants, and also in j the Public inquity regarding the proposed Sizewell.B nuclear plant in the United I Kingdom. in addition, I hava co authored two major reviews of source term )

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2-and risk estimate issues published in NRC reports NUREG 0950 and NUREG-1150. I have also performed reviews of variou's technical aspects of the Shoreham, IJmerick, Indian Point, Si70well, 7jon, Seabrook, Millstons-3, and Oconee 3 probabilistic risk assessments and the Vermont Yankeo Containment Scfaty Study.

2. MHB Technical Associates ('MHB') has been requested by the Nuclesr Safety Division, Department of the Attomey General, The Commonwealth of i Massachusetts, to evaluate the increase in risk resulting from a startup prograra for return to power from the current refueling and modifications outage for the Pilgrim Nuclear Power Station, Unit 1 (PNPS 1).

3. In its current configuration (refueled) and considerin0 the duration of the current shutdown, Pilgrim currently poses very little risk to the public heafth and safety. This is due to the multiplicity of systems theoretically available to inject water into the reactor vessel and due to the low decay heat level present in the

, fuel, in the event of a core heatup transient with the plant in its current i : configuration, censiderable time would elapse between initiation of coolant loss

and the onset of fuel damage, time during which measures could be taken to initiate coolant makeup and/or other recovery and mitigative actions.

Moreover, in theory a longer time period is available within which to imp!ement

. offsite protective actions due to the slower accident progression time 4

compared with accidents at higher power levels.

l

4. Boston Ed: son Company (BECO), the licensee for Pilgrim, currently envisions I restart power ascension program with a minimal number of hold points. In brief, BECO proposes t'1 institute hc!ds on restart (pending approval from NRC

{ in accord with Confirmatory Action Letter No. 8610), recovery from ieactor -

. moce switch testing prior to conducting a test for shutdown from outt,lde the i

control room, and prior to movement of the scram set point above 95% power.

(Sts Boston Edison Company, ?)(g[Im Nuclear Pcwer Station Restart Plan, pages IV 29 to IV-31.) The d6, tails of the power ascension program in Attacnment 13 of the EJJ.g!)_n1.Rygtear Power Station RestarLElsa have not yet )

] been provided.

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5. My cuirent underatending o,' tho 13tiCO power escension program is that the program would result in a relatively rapid ascension from the current shutdown condition to full. power operation. In co doing, the risk to the public health and '

safety posed by operations at the Pilgrim plant will be increased merkedly, !

6. 1he Commission has concludcd generally that the risks hom 5% power [

{ operation are negligible. @*a. for example, SECY 84155,12 April 1984, and attachmecs; and letter dated *.5 June 1984 from Nunzio J. Palladino to Hon. !

i .

Edward J. Markey, and attsaments.) The evaluations upon which the !

j Commission has drawn these cc ictusions, however, were for plants with very f

! little operating history and no spont fusi pool inventory. Clearly, Pilgrim is t i

l different in this regard, with a substantiallong ha!f life fission product inventory present in both the refueled reactor core and the spent fuel pool. Moreover, !

t these evaluations did not consider the unique risks posed by accidents resulting from extemally initiated events (specifically, in this case, seismic !

l ,

events). In my opinion, tne presence of more than 1100 spent fuel assemblies, [

l prior operation of two thtrds of the core at equivalent full powsr for most of an !

operating cycle, and the mkher of external events render the circumstances at l

) , Pilgrim sufficiently different from those previous $., evaluated for 5% power l operation that the previous evaluations understate, perhaps significantly, the l risk poseo by operation of Pilgrim at 5% of full power. This conclusion is j further supported by the likelihood that the primary containment will not be l j inerted until operation above 5% power is commenced, in my opinica, tirtually l

j any severe accident at 5% power with the containment de inerted will result in l

} j early containment failure (due to hydrogen burn or hydrogen detonat'on in the (

l , .) primary conte!nment, and/or other causes). l 3 :

'! 7. As power level increases, risk to the public it: creases. This is due to several l factors, including a marked increase in volatile fission product inventory and a marked increase in decay heat level, which results in accident progression times which are much shorter than at low power levels. This reduces the i

1 amount of time available for implementation of recovery and/or mitigation 1

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I actions and reduces the amount of time avalleblo to implement offsite

. protective measures.

8. A full scopo probabilistic risk assessment for the Pilgrim plant has been in progress for several years. It is my understanding that this study is neart

completed. It is my expectation that this study will identify seismic initiating

events as a significant contributor to core melt frequency (i.e., contr;buting 10%

or more to core mit frequency from all causes). This expectation is based on my familiarity with seismic risk assessments performed on similar designs and i i performed on other plants in the general region of Pilg-im (e.g., Shoreham, Seabrook Units 1 and 2, Mi!! stone Unit 3, and Umedek Units 1 and 2).

Seismica!!y initiated accident sequences are accompanied by potentia!!y severe impacts on offsite emergency response even when there are fully-approved and operational emergency plans. In the case of Pilgrim, the current status of emergency planning is such that there is not adequate assurance that protective actions can and will be taken in the event of an accident. Given the more severe conditions of a seismicallyinitiated accident scenario, this conclusion is all the more applicable.

9. A study of risk et 25% power for the Shoreham nuclear plant, which possesses a nuclear steam suppty system which is grossly similar to Pilgrim, indicates that

, the core melt frequency for operations at up to 25% of full power may not differ dramatically from the core melt frequency at full power. The 25% power PRA

, estimates a core melt frequency of 2.8 x 10 5 por reactor year. (Sag, E.T.

Bums. S. Mays, and T. Mairs, ProbabllIstic Misk Assessment o.' the Shoreham Nucles? >cwer Station: Initini Power Ocaration Limited to 25% of Full Power,

,} Delian Corporation, prepared for Long Island Ughting Company, April 1987, 1 page 412.) The full power PRA anaNses for Shoreham estimated a core melt I frequency of about 6.5 x 10 5 per reactor year. [ Sag, Science Applications, l Inc., Final Renort Probabilistic Misk Assessment. Shoreham Nuclear Power Stall.on, prepared for Long Island Ughting Company,24 June 1983, page 4; and V. Joksimovich, et al., Malor Common-Cause Initiatina Events Studv:

Shoreham Nuclear Power Station. NUS Corporation, NUS Report No. NUS-

} 4617, prepared for Long Island Ughting Company, February 1985, page 18) 1

,,..-.-.-...-Y...-..-.................. - . . . . . . . . .. N . l 5

This represents less than a factor of three difference in the likelihcod of a core melt accident at 25% power versus full power. Although this asussrrent is for Shoreham and not for Pi!Orim, it suggests that the likelihood of in accident is

not merked'y different for 25% power versus 100% power.

10. Further, a limited ocope PRA of Shoreham at 5% power was prepared for

{

' ULCO. This ctudy, which did not include external ownts, concluded that the ,

core rnelt frequency for 5% power operctica was about 4.9 x 10 4 por rcactor-I year. (Sea, Delian Corporation and Science Applicat!ons, Inc., ProbabillitIq

8lsk Assessment. Shoreham NyWar Power Station. Low PQwer Ooeration Uo to 5% of Full Power. prepared for Long island Ughting Company, draft, May i 1984, page 78.) This indicates that core melt frequency at 5% power is

. significantly reduced from 25% power or full power, by a factor of roughly 20,

! but not nearly as significantly reduced as previously predicted by the NRC staff, which predicted a reduction factor of 1,000 or more.1/ Moreover, the 5% !

power reduction factor of 20 is an underestimate since the 5% power estimates !

do not include external events.

11, The 5%, 25%, and 100% power PRA studies for Shoreham indicate, in my i l coinion, that the core power level for Pilgnm will have at best a moderate I impact on the likelihood of an accident. Considering the uncertainties involved, ,

, the likelihood of an accidant may be nearly indistinguishable at the various

. power levels indicated above. Moreover, the Shoreham resdts are lower than

! the core melt frequency estimates for many other plants. A Brookhaven j National Laboratory review of the Shoreham PRA for internal events ontf !

estimated a core melt frequency of 1 x 10 4 per reactor year. An average value for full scope PRAs completed to date is of the order of 3 x 10 4 per reactor- l year. !

3 '

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F 1/ The NRC staff, in SECY 84156, predicted core melt frequency reduction factors

Sam, !

for varicus classes of BWR accidents ranging from 1,000 to 100,000.SECY-641 i cage ?? Thus, in the aggr3 gate, the NRC staff would have ( "ed a core melt i freque.uy reduction of at least 1,000, compared with the Sh< ,,, a value of 20, r The results for Shoreham indicate a reduction factor approximately 50 times less than the NRC staff expected based on engineering judgment.

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12. mese results are espscla!!y significant for e plant w: th a containment design :

, similar to Pilgrim, N!gdm employs a steel Mark I pressu,e suppression l j cont?inment. Such containments have been estiinated in a variety of studios l

{ aponsored by IDCOR, NRC, arid utilities to have en earty containment failure

j probability - given a severe accident - in a range from 10 90%.1his meano l j that there is a significant chance that, gNen a severe accidsnt, the accident will

1 be accompanied by a large early release of radioactivity to the environment. !

I i i !

j I 13. The Pilgrim plant, like all Mark I containment design plants, also employs a j

{ ,

secondary containment, usually referred to as a reactor building. This t

structure is not designed to withstand the high internal pressures which would

) eccompany a severe auident, and is unlikely to survive in a leak. tight condition :

fo!!owing primary containment failure. High pressure in the secondary containment due to a severe acc; dent would be produced by a combination of blowdown due to primary containment failure, primary containment leakage, j ,

primary containment venting, and buming of combustible gases. Indeod, Mark i 1

} l plants are designed with both internal and extemal ' blow out panels' which l

j are dodgned to relieve pressure, in the case of Pilgrim, there are blow out j i

i panels at the refueling deck elevation which relieve pressure directly to the l I environment. In my opinion, there is little basis for assuming that releaces from :

the priman/ containment will be significantly mitigated by the presence of the f

l secondary containment, i 1 [

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13. Based on the above considerations, it is my opirilon that Pilgrim Unit i should

{

not be restarted until the offsite emergency response plans are upgraded and j evaluated to adequately protect the public health and safety. Further, it is my

) ; recommendation that BECO be required to promptly submit the Pilgrim {

q j probabilistic risk assessment study to the NRC for public review and evaluation j ; prior to restart. The review of such a study should indicate whether there a

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I rernain significant operational risks which must be amelioilated in order to orovide adequato protedinn to th pubF0 hoa'th and safoty.

Gteven C. 3ilolly /

Associate Consultant /

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'.b s."-,thf' \i. .'W KNOW1.EDOMENT we m g,;3 . m m .-e - -- - - fr - - 7;::- _- _---- ;

$ng o. _

y ) on this tne/ 9 day of /7/- d 19/Z. before me.

Couny ot.. 4, -

s. * *'d A dab -

ine undersigned Notary Public personalfy appeared!

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OFFICIAL SEAL .

C parsonally known to me

'. I heuer e . a NtA proved to me on tne basis of satista: ton escence

, . ; i. ee ine ,e,.on<. n.no ,,ea m e< , a , .

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. w -.. m.m m n.ini witnininstrument. nd ackno.iedged inat 4, n

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executed it. ll WtTNESS my nand and of f acial seal.

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1 ATTACHMENT A ,

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] PROFES$!0NAL QUALIFICATIONS OF ST M N C. SHOLLY

$TEVEN C. SHOLLY

! MHO Technical Associates WJ l'smilton Ave.1ue

$ulte K !

San Jose, California 95125 t (496)2662716 .

I i

i i EM4R_!ENCE:

Saptember 1985 - PRESENT 1

{ Associato - MHB Technical Associates, San Jose, California _

1 Associatn in energy consulting firm that specializes in tachnical and i aconoinic assessments of energy production facilities, especially nuclear.

for local, state, and federal governinents and private organizations. MH8 is extensively involved in regulatory proceedings and the preparation of

,~

studies and reports. Conduct research, write reports, participate in i discovery process in regulatory proceedings, develop testimony and other t i .

documents for regulatory proceedings, and respond to client inquiries.

Clients have included: State of California, State of New York, State of :

1111nois.

! l j February 1981 - September 1985 '

i :

Technical Research Associate and Risk Analyst - Union of Concerned Scien- (

tists. Wasnincton, D.C.

I Research associate and risk analyst for public interest group based in l lI Cambridge Massachusetts, that specializes in enmining the impact of ad- !

vaaced technologies on society, principally in the areas of arms control !

l

~

1 and enercy. Technical work focused on nuclear power plant safety, with i 1 emphasis on probabilistic risk assessment, radiological emergency planning and preparednes s, and generic safety issues. Conducted ;

research, prepared reports and studies, participated in administrative ;

i proceedings before the U.S. Nuclear Regulabry Cosmission, developed ;

testimony, anlayzed NRC rule-making proposals and draft reports and ;

prepared comments thereon, and responded to thquiries from sponsors, the I

} general public, and the media. Participated as a member of the Par.el on

" ACAS Effectiveness (1985), the Pinel on Regulatory Uses of Probabilistic l 4

Atsk Assessment (Peer Review of NUREG-1050n 1984), Invited Observer to i M.tC Peer Review meetings on the source term reassessteent (8MI 21041 1983-1984), and the Independent Advi-sary Connittee on Nuclear Risk for the Nuclear Risk Task Forca of the Nations 1 Association of Insurance

) , Comissioners (1981).

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January 1980 - January 1981 Project Director and 11esearc_h_ Coordinhi:or _ Three Mile Island _ Public

[nterest Resource Center, Harrisburg, Pennsylvania - ,

Provided administrative dire.ction and coordinatad research projects for a pubite interest group based in liarrisburg, Pennsylvania, centered around

' issues related to the Three Mile Island Nuclear Power Flant. Prepared fundraising proposals, tracked progress of U.S. Nuclear Regulatory Com-mission, U.S. Department of Energy, and General Public Utilities activi-ties concerning cleanup of Three Hile Island Unit 2 and preparation for

restart of Three Mile Island Unit 1, and monitored developments related g to emergency planning, the financial health of General Public Utilities.

. and NRC rulemaking actions related to Three Mile Island.

July 1978 - January 1980 Chief Biological P.*ocess Operator - Wastewater Treatment Plant, De rry Townsnip Municioal Autnority, Hersney, Pennsylvania Chief Biological Process Operator at a 2.5 million gallon per day ter- '

tiary, activated sludge, wastewater treatment plant. Responsible for bi-ological process monitoring and control, including analysis of physical, chemical, and biological test results, procees fluid and mass flow man-agement, micro-biological analysis of activiated sludge, and maintenance

' of detailed process logs for input into state and federal reports on treatment process and effluent quality. Received certification from the l Connonwealth of Pennsylvania as a wastewater treatment plant operator.

. 'i Member of Water Pollution Control Association of Pennsylvania Central Section, 1980.

July 1977 - July 1978 1

l Mstewater Treatment Plant Operator - Borough of Lemoyne, Lemoyne, Penn-

sylvania

! Wastewater treatment plant operator at 2.0 million gallon per day sec-ondary, activatcd sludge, wastewater treatment plant. Performed tasks as assigned by supervisors, including simple physical and chemical tests on wastewater streams, maintenance and operation of plant equipment, and maintenance of the collection system.

, September 1516 - June 1977 Science Teacher - West Shore School District, Camp Hill, Pennsylvania l

faught Earth and Space Science at ninth grade level. Developed and im- l pienented new course materials on plate tactonics, environmental geology, )

, and space science. Served as Assistant Coach of the district gymnastics team. i 4

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!.y t%+.tr 1975 - June 1976 Science Yeacher - Carlisle Area .tchool District. Carlisle, Pennsylvania !

raught Earth and Spaca Science and Environtrental Scienco at ninth grade 4

lavel. Devnloped and implemented now course materials on plate tecton- ,

tes, environmental geology, noisa polluticn. water pollution, and energy. !

S rted as Advisor to the Science Projects Club. '

EU(MIOlit R.S., Education, majors in Earth and Space Science and General Science, !

minor in Environmental Education. Shippensburg State College Shippens- '

Mrg, Pennsylvania,1975.

Graduate coursework in Land Use Planning. Shippensburg State College, i Shippensburg, Pennsylvania, 1977-1978. i EBJ,I_ CATIONS:

1. "Determining Merca111 Intensities from Newspaper Reports," Journal of Geological Education Vol. 25. 1977. ~

r i 2. A Critique of: An Independent Assessment of Evacuation Times for Three '

i W Island Nuclear Powe r Plant, Three Mile Island Public Interest

Resource Center. Harrisburg, Pennsylvania, January 1981.

3.

A t'rief Review and critique of the Rockland County Radioloaical Emercency 17epaiecness Plan. Union of Concern 2d 5cientists, prepared for~ Rockland i j

CounFy Emergency Planning Personnel and the Chairinan of the County Legis-j 4

, 14ture, Washington D.C.. August 17. 1981.

) 4.

i

' The Necessity for a Promot Public Alertino Caoability in the Plume Expo- i

}

liiiTlathwny EPZ at Nuclear Power Pl'ir.t Sites. UniJn of Concerneo Scieft-

~

}

tif ts, Critical Mass Energy Project, Nuclear Information and Resource f i i Service, Environmental Action, and New York Public Interest Research !

j i Group, Washington, D.C., August 27, 1981.

t l

! . 5. "L'aton of Concerned Scientists, Inc., Comments on Notice of Proposed i l Kulewking. Amendment to 10 CFR 50 Appendix E.Section IV.D.3.* Union of l Concerned Scientists, Washington. D.t;.. October 21, 1981. *

! I 0.

' 'The Evolutten of Emergency Planning Rules " in The Indian Point Book: A J

triafing on the Safety Investitation of the Indian Point Nuclear Power

{ PTants, Anne Witte editor, un' on of Concerne<t scientists (Washington. '

]

57Tand New York Pubitc Interest Research Group (New York, NY),1982.

, 1. ' Union of Concerned Scientists Coenents. Proposed Rule.10 CFR Part 50,

i Emergency Planning and Preparedness:

tions 46 F.R. 61134

Union of Concerned Exercises. Clarification of Regula-Scientists Washington, D.C.,

1 Janusry 15, 1982 *

!, 4 I l l '

m . - _ , - - . . . . .

, . .. . . . . . . . . . . . .. i

8. Testimony of Robert D. Pollan d and Steven C. Sholly before the Sub-comitten on Er.e rgy and the Environment. Comittee on Interior and insular Affairs, U.S. Heuss of Representatives, Middletown, Pennsylvania, March 29, 1982, svallable from the Union of Concerned Scientist 3.

9. 'Unica of Concerned Scientists Detailed Cuments on Petition for Rulemak-ing by Citizen's Task Force, Enurgency Planning,10 CFR Parts 50 and 70, Socket No. PRii 50-31, 47 F.R. 12639," Union of Concerned Scientists, h shington. 0.C. Hay 24, 1982.

10. Supplements to the Testircony of Ellyn R. Weiss Esq., General Counsel, Uninn of Concerned Scientists, be fore the Subcommittee on Energy Conservation and Power Comittee on Energy and Comerce, U.S. House of Representatives. Union of Concerned Scientists Washington, D.C., August 16, 1982.

11. Testimony of Steven C. Sholly. Union of Concerned Scientists, Washington, 11.C., on behalf of the New York Public Interest Research Group, Inc., be-fore the Special Comittee on Nuclear Powar Safety of the Assembly of the State of New York, hearings un Legislative Oversight of the Eniergency Ra-diologic Preparedness Act Chapter 7CS, Laws of 1981 September 2,1932.

12. "Ccements on ' Draft Supplement to Final Environmental Statement Related to Construction and Operation of Clinch River Breeder Reactor Plant' "

Docket No. 50-537 Union of Concerned Scientists. Washington. 0.C.,

September 13, 1982. *

13. "Union of Concerned Scientists Coments on ' Report to the County Cemis-i stoners', by the Advisory Comittee on Radiological Emergency Plan for Columbia County, Pennsylvania," Union of Concerned Scientists, Washing-ton, D.C., September 15, 1982.

14. "Radiological Dergency Planning for Nuclear Reactor Accidents," pre-l sented to Kernenergie Onte.antald Congress, Rotterdam, The Netherlands, Union of Concerned Scientists, Washington. 0.C., October 8,1982.

15. "Nuclear Reactor Accident Consequences: Implications for Radiological '

Emergency Planning," presented to the Citizen's Advisory Comittee to Re-view Rockland County's Own Nuclear Evacuation and Preparedness Plan and

! Nneral Disaster Preparedness Plan, Union of Concerned Scientists. Wash- )

. 1 ington, D.C., Novsaber 19, 1982.

16. Testirony of Steven C. Sholly before the Subcomittee on Oversight and I i

Investigations. Comittee on Interior and Insular Affairs, U.S. House of Representatives. Washington, D.C., Union of Cort arned Scientists, Decem-i her 13, 1982.

11. festirony of Gordon R. Thompson and Steven C. Sholly on Comission Ques-tion Two. Contentions 2.1(a) and 2.1(d). Union of Concerned Scientists and New York Public Interest Research Group, before the U.S. Nuclear Reg-ulatory Comission Atomic Safety and Liceasing Board, in the Matter of Consolidated Power AuthorityEdison Company of the State of hewofYork New York Indian((Indian Point UnitPoint 3) Unit 2) and the Docket Nos. 50-247-SP and $0-286-SP, Dece-ber 28, 1982. *

,;___ 7 ..

2 i

] j i

1 i 18. Tes;tmony of Steven C. Sholly on the Consequences of Accidents at Indian

]

Point (Comission Question One and Board Question 1.1 Union of Concerned !

Scientists and New York Pubite Interest Research Group, before the U.S.

1 I

Nuclear Regulatory Comission Atomic Safety and Licenslag Purd. in the ;

ittter of Consolidated Edison Company of New York (Indian Point Unit 2) i 4nd the Power Authority of the State of New York (Indian Fotnt Unit 3),

Docket Nos. 50 247-$P and 50-286-SP, February 7 1983, as corrected i i februc.ry 16, 1983.

1 l'

19. Testimony of Steven C. Sholly on Comission Question Five. Union of Con- l i

corned Scientists and New York Public Interest Researd Group, before the i

! U.S. Nuclear Regulatory Comission Atomic Safety and Licensing Board, in l

the Matter of Consolidated Edison Cc,apany of New York (Indian Point Unit !

? 2 and the Power Authority of the State of New York (Indian Point Unit i i

3 , Docket Nos. 50-247-SP and 50-266-$P, March 22, 1983.

I I

} ' 20. "Huclear Reactor Accidents and Accident Consequences: Planning for the i Worst " Union of Concerned Scientists Washington. D.C.. presented at i Critical Mass '83. March 26,1983. l l

l 21. Testimony of Steven C. Sholly on Emergency Planning and Preparedness at j j commercial Nuclear Power Plants Union of Concerned Scientists. Washing- '

ton, D.C., beford the Subcomittee on Nuclear Regulation. Comittee on l

4 Environment and Pubite Works. U.S. Senate April 15. 1983. (with "Union !

of Concerned Scientists' Response to Questions for the Record from Sena- '

tor Alan K. Simpson." Steven C. Sholly and Michael E. Faden). ;

I j 22. "PRA: What Can it Really Tell Us About Public Risk from Nuclear Ac- !

cidents?.* Union of Concerned Scientists. Washington. 0.C.. presentation to the 14th Annual Meeting. Seacoast Anti-Pollution League May 4.1983. I 1

l 23. "Probabilistic Risk Assessment: The Impact of Uncertainties on Radi-4 ological Emergency Planning and Preparedness Considerations " Union of l Concerned Scientists. Washington. 0.C. , June 28.1983.

i l

24. "Response to GA0 Questions on NRC's Use of PRA." Union of Concerned $ct-

) :

entists Washington, D.C.. October 6,1983, attachment to letter dated i 6

October 6,1983, from Steven C. Sholly to John E. Bagnulo (GA0 Wening- !

, ton,D.C.).

t

25. The act of "External Events' on Rasioloaical Emeroency Response Plan-

'nTne nsfeeratfons. Unton of concerned 5clentists. Washtngton. D.G., De-comer ZZ. 1953, attachment to letta. dated December 22. 1983 from j j Steven C. Shelly to NRC Comissioner James K. Asselstine.

I '

26. Sizewell '8' Public Inquiry. Proof of Evidence on: Safety and Waste Man-asement laelications of the Sirewell PWR, Gordon Thompson. with supporting evidence by 5teven 5hoDy. on behalf of the Town and Country j

' Planning Association. February 1984, including Annen G. 'A review of Probabi,istic Risk Analysis and its Application to the Sizewell PWR."

Steven Shelly and Gordon Thompson. (August 11. 1983). and Annex 0 "Emergency Planning in the UK and the U5: A Comparison.' Steven Sholly 1

and Gordon Thogson (October 24,1983).

i 3

i t

i

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

l l

4

27. Testimny of Steven C. Sholly on Emergency Planning Contention Number Eleven. Union of Concerned Scientists Washington 0.C., on behalf of the Palmetto Alliance and the Carolina Environmental Study Group, before the U.S. Nuclair Pegelatory Commission Atomic Afety and Licensing Bosrd, in the Matter of Duke Power Company, et. al. (Catawba Nuclear Stetion. Units 1 and 2), Doi ket Hus. 50 413 and 30-414. April 16,1984.

P3. "Risk Indicators Relevant to Assessing Nuclear Accident Liability Premi-ws," in Prelirainary Report to the Independent Advisory Committee to the NAIC Nucl' ear Risklask Force, Deccher 11, 1984, Steven C. Sholly. Union ol' Concerned Scion: sts. Washington. 0.C.

29. "Union of Concerned Scientists' and Nuclear Information and Resource Ser-vice's Joint Comments on NRC's Proposal to Bar from Licensing Proceedings the Consideration of Earthquake Effects on Emergency Planning," Union of Concerned Scientists and Nuclear Information and Resource Service, Wt.sh-ington, D.C., Diane Curran and Ellyn R. Weiss (with input from Steven C.

Sholly). February 28, 1985. *

30. "Severe Accident Source Terms: A Presentation to the Comissior.t;rs on the Status of a Review of the NRC's Source Term Reassest. ment Study by the Union of Concerned Scientists," Union of Concerned Scientists, Washing-ton. 0.C., April 3, 1985. *

31. "Severe Accident Source Terms for Light Water Nuclear Power Plants: A

' Presentation to the 1111...,is Department of Nuclear Safety on the Status of a Review of the NRC's Sou.ce Term Reassessment Study (STRS) by the l Union of Concerned Scientists," Union of Concerned Scientists.

Washington. 0.C., May 13, 1985.

32. The Source Term Debate: A Review of the Current Basis for Predicting Se-vere Accident Source Terms with 5pecial Emphasis on tne NRC Source Term Reassessment Program (NUREG-0956), Union of Concerned Scientists. Cam-bridge, Massachusetts, 5teven C. Sholly and Gordon Thorrpson, January 1986.

i

33. Direct Testimony of Dale G. Bridenbaugh, Gregory C. Minor, Lynn X. Price, and Steven C. Sholly on behalf of State of Connecticut Department of Pub- j I lic Utility Control i

Prosecutcrial Division and Division of Consumer Counsel, regarding the prudence of expenditures on Millstone Unit !!!,

February 18, 1986.

34. Implications of the Chernobyl-4 Accident for Nuclear Emergency Planning i i for the State of New York, prepared for the State of New York Consumer

! Protection Board, by MHB Technical Associates,, June 1986.

35. Review of Vermont Yankee Containment Safety Study and Analysis of Untainment Ventino Issues for the Vermont Yankee Nuclear Power Plant, prepared for New England Coalition on Nuclear Pollution, Inc., Decemoer 16, 1986.

i I

I

i

36. Affidavit of Steven C. Sholly before the Atomic Safety and Lt. censing Board, in the matter of Public Service Company of Ne9 Hampshire, ei: al., regarding Seabrook S t a ti or. Unitt 1 and 2 Off-site Emergancy Planning Issues, Docket Nos. 50 443-OL ti 50-444-OL, January 23, 1987.

J7. Direct Testimony of Richard B. Hubbard and Steven C.

Sholly on bahalf ef California Public Utilities C( mmis sion , rugarding Diablo Canyon Rate Case, PG&E's Failure to Establish Its Committed Design QA Program, Application Nos. 84-06-014 and 85-08-025, Exhibit No.

10,S35, March, 1987.

38. Testimony of Gregory C. Minor, Steven C. Shelly et. al.

i ,

on behalf of Suf folk County, regarding LITCO's Reception Centers (Plarning Bas!s), before the Atomic Safety and Licensing Board, in the matter of Long Island Lightir?

Company, Sh6raham Nuclear Power Station Unit ', Docket .

No. 50-32 2- JL-3, April 13, 1987.

39. Rebuttal Ttstimony of Gregory C. Minor and Steven C.

Sholly on uehalf of Suffolk County regardir.g LILCO's Reception Centers (Addressing Testimony of Lewis G.

Hulman), Docket No. 50-322-OL-3, May 27, 1987.

40. Review Reference of Selected Aspects of NUREG-1150, "Reactor Risk D o c u m e.7 t , prepared for the Illinois Department of Nuclear Safety by MHB Technical Associates, September 1987.

Available from the U.S. Nuclear Regulatory Commission, Public Document Room, Lobby, 1717 H Street, N.W.,

Washington, D.C.

)

t I 8 I,

t

t . _ . . . . . . .

k l 3

h ., Now

< 1 . F.ngland 8 J

,' j. .jjNuclear 2 !

N*' ~

s4cws JUNE 1987 (Apnt osta)

CO:DiECirlCUT YANKELI 01 A:.ril 16, thw plant shutdown becauso of problerns with turbine control vdivo #4. After ,

charaistr/ holds and a load runback, the plant reached full power (04%) on April 21st. -

The I: stitute for Nuclear Powar Operations (INPO) will conduct its annual critique of plant }

operations baginning on June. 8th.

l' 4,

! HAltlE YANKEE j Maine Yankee shutdown for refueling is proceeding generally according to schedule with etertup expected in early June. Wry small cracks found in the disks of both low pressure turbine rotors have necessitated the replacement of one and the repair of ths other.

YANKEE Yankeo began its 18th refueling on May 2nd. The list cycle of the plant produced more

! than 2 million megawatthours over a 17 month period with a capacity factor of 93 percent.

1 Pit.GnlM i, Pilgrim remained off line during the month, i Visi'MONT YANKEE l On April 4 Vermont Yankee came down in power and took the turbine off line to repair .

A srnall steart, leak in a main steam drain line. The plant came back on line the same day !

and operated at full power for the remainder of the month. -

j -

j

) Mil.i.5 TONE 1 & 2 l Milktone Unit 1 operated routinely for the month of April. A scheduled refueling outage wi'l Legin in mkblune and last for appruximately 10 weeks. Millstone Unit 2 operated reutine-l -

t/ excspt for a trip on April 16 due to a generator exciter field circuh breaker opening on

/ piosumed bistable transformer fault Indication. Instruments in place to monhor the suspect l blsmble. The unit returned to service after a 20 hou outage on April 18, i i

l f,llLt. STONE 3 l i I Millstone Unit 3 returned to service after a scheduled outage. After startup on April 11,

'hs unit tripped on the next day while at 10 percent powpr Isvol due to steam generator i

!ov. evel when turbine driven food pump oscillated. Feedwater regulating control valve j faild to open on demand due to a enntrol air leak. The unit returned to service on April j i 14 after bein0 out for 29 hours3.356481e-4 days 0.00806 hours 4.794974e-5 weeks 1.10345e-5 months .

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- l

'***** AUG9.719R6 Oorket No. 50-293

'~V f Seiten Edison Company M/C Nuclear

/,173 : Mr. James M. Lydon Chief Operating Of ficer p .

fi M 80L Goylston Street .

00ston, Massachusetts 02199 Gentlemen:

Subject:

Confirmatory Action i.etter 86-10 fhis letter is to provide further guidance ori the requirements we expect to be met prior to the restart of the Pilgrim plant. We acknowledga receipt of Boston Edlion Company's (BECO) letter of June 16, 1986, in response to C1SITirmatory Action latter (CAL) 86-10. Your actions with regard to the issues in CAL 86-10 appear to be thorough and tech.iically sound.,..My staf f has a few remaining questions, which have been discussed with your staff and which will be documented in Inspection Report 50 293/36-25.

!a addition to the specific plant hardware issues involved with CAL 86-10, several other issues have been identified that require resolution prior to restart of the Pilgrim plant. Senetfie technical issues of eeneern includet everdue surveil-ly igt, malfunction of recirculation motor cenerator set field breakers, seismic ggtli f1_ cation of e ercency diesel __ generator di f f erential relays, and completion of d223pah _ R modi f i c a t i o n s . Please_be prepared to discuss th15e issues at our next gana jement meeting at the plant on Septemoer 9. 1986. 13 would also lite to near at thi s meetino th.9 scepc and stgus of a l l your er,ggghe,;}l a ted to restart of i

,f,ddrim.

S.tqts. (b) .Theit, _i ncofl BE the role ude (the results of your six week action plan for improve-a )CO sreview a f e ty committees._ includina g e Precram For-l E2ctlJnge_ !a s k Force. in__assessina readiness for restart, and (c) tne readiness of

,th,e plant and corporate staff to support plant startup, testing, and operations.

{n 1,'oht of the number 4nd scent of the outsMndino issues. I 4m not creeared to adrove restart of t'hMUi m facility until veu erewide a writtam rammet th2e dgc_pents OECO's _ formal asjessment of the reag,inoss for restart operation. This assessment should include your detailed chech. 1st for assuring that all out-4 star' ding items have been satisfactorily resolved and that plant systems have been

. j restored and prepared for operation. A formal restart program and schedule should

! I also be submitted for NRC review and approval. This program should include hold j points at appropriate f tages such as criticality, completion of anode switch test-i ing, and at specific allestones during ascension to full power. Authorization to l proceed beyond each hold point will be contingent upon 6.y approval and will be based on my staff's evaluation of the operational performance of the plant. We will have substantially augmented NRC inspection coverage during this restart

. period.

l 2,ltf ie ol a n to submit your readiness assessment and vestart o,rlogr,.a_m and schedule l

0,,13tst f orty-five days __bef ore your olinned startue fro 9 the cuy, rent eutaen. My dectsien on restart will be based in part on our review of these documents.

,__._,_,____._m _.

w

._ _ e . . .. . . . .e . . . e.. . . . . . .

2 You' . cooperation is appreciated.

Sinceroly, (t.t- $ g Thomas E. Murley Regional Administrator CCt L. Oasen, Vice President, Nu: lear Operations A. E. Pedersen, Station Manager Paul Levy, Chatraan, Department of Pubite Utilities Faward R. MacCormack, Senior Regulatory Affairs and Program Engineer Chairman, Board of Selectmen Flymouth Civil Defense Director The l'onorabis E. J. Markey J. D. Keyes ,,

Sent. tor Edward P. Kirby The lionerable Peter V. Forman Sharon Pollard Public Document Room (POR)

(ocal Public Document Room (LPOR)

Nuclear Safety Information Center (N5!C)

NRC Resident Inspector .

Comme,nwealth of Massachusetts (2) r i

l t

1 - '

l 1

e% w w w t a

'M, UNirgoticTis

. ._.4 l' ,

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$1- . NUCt.G AH REGULATORY COMMISSION o Q Lj;- .j REGION I j ' 6.it ?Ame AvtNul S.9 O j stNo of PaumA.psNNsRVAN64 teNe

) -

APR 0 819W

00:ket No. 50 293 3oston Edison conpany M/C Nue. lear ATIN: Mr. Ralph Bird -

' Senior Vice President - Nuclear dC0 Boylston Street i

Sos.cn. Massachusetts 02199 i

Ger tler.tn:

S ubj e ct,:

Systematic Assessment of Licensee Performance ( $ ALP) Repor-t No. 50 293/86-99 i..i R e g i o r.

l $ ALP Ecare has reviewed and evaluattd the performanca of activ-ities at t,h thecugh Je99ary e pilgrim Nuclear Pcwer Stat, ton for the ptsriod November 1,1985 31,1987.

A teting te eisesst The results are present.ed ir, the enclosed rep:rt.

4: t ca.e. this assessment T*e rieting .i'.1 be held en will be scheduled for a mutually accept-se /-e ::rperate ma94;erent anc olanter efficials near the st*, e so that apprcp ria te et.n discuss wi t,h .: s the It en;ths 49d eai.essts noted.

It is owe intent that th is efeting be cc=bined

.ith the cariccic e.anage ent eeeting to review imprev e.9ent prog ram status, h **e

$Al,Pareas. Board icentified significant recurring progra m weaknesses ir :: e J '.e:tional

.e e aise note:. Irprevements, such as in the area of e mergency preparedness, slow curing e.ost cfko theever, the sal.P assessment Boarc 'ound the rar.e of such change was pericd.

We recegnize that the Boston Edisen company (BEco) has made significant staff-ing and M*cware cw.itments to impreve performance at the Pilgrim Statien and we believe they are beginning to have a posit 1%e impact.

NRC it tooting for progress in correcting the previcusly As you are aware.

identified ler; te*9 tre "

e t l e s 4 *, the Pilgrir $tation prior to clant restart, :articularly te t :n

'.r:stenti areas witn a Category 3 rating.

I In : e: 4 ration f or the $4.P nett,ing, please ce . prepared t.s discuss your evalua- .

t,1cn cf our assessment and the status of ycur performance' improveeert preg'4 5.

Any tenents you may have regarding our report say be dis cussed at the meet,ieg.

A::!,%eallyv.you may provice written co.t ents within 20 days af ter the meet-ing. Follensing our meeting and receipt of your written response, the enclosed report, your response, aed a summary of our findings ar.1 stanned act. ions viii.

ce tisceo in the NRC Public *ccument Room.

63 e

.T_A9 L.z 4 jyFORCEM!r T $U.&. WARY (11/01/85,- 01/31/87J

,PILG_R!M NUCLCAR POWER STATION

. A. Nypber and $ eve ity Level of Viciations

( 5everity Level ! 0

!' Severity Level !! 0

. Severity Level I!! l Severity Level IV 21 Severity Level V 6 Costation 1 7: 41 Y

5. '*:'attens Vs

. . va:tte-al Area l

Severft'.* Lese * $

.-:11ema'. 1 ett I !! !;I iv v Utv Tetal l l

: 'a t 0:e a:t: s - - - -

1 1 1 0 :a: :1:;tcal C: te:1s 1 3 - - 4

, 3 va'nteaan:e - - -

1 1

, :. 5.riet11ance . - -

6 3 -

9

$. :' e 8 rete::t:m - - - 5 -

l 5

( i e gem:y : e:a e:.ess - - - - - -

0 1 !*:. ity $adeg.ar:s - - -

1 1 -

2

{

. ,l

!. Cstage Managerer.: anc

, .:ctft.tation .u .

A::ivities - - -

1 1 -

2 l

.; 9. Lt:ensing A:tivities - - - - - -

0 e

i

.

ra ing ar.: Csalific.'1: 1 Effe::1veness - - - - - -

0

: :.-a.:e :* .e i y - - - 4 - - a

i ; *et- ; a

;: :: a e

,

e : r :ai 5.:::

4's c . ; 21 6 1 2E

64 l I.A.!):.E 4 (10.n t i n u e c),

i

c. s.:..wa ry Inso etten Pecor Severity Functional '

Numb.c t.e v e l A_rf a

_ , , _ Vf ol ation C5-32 V Surveillance Instrument channal tests wire not being performed r.onthly f'or the recetor e butiding vent and stack waste gas sonttors.

!!-32 V Se:w !ty Failure t o perform a Safe;.a cs croper se aren of a package becusht i nto the pretected area.

!!-C: y :' ant

a aticas Dost tria review 86-01 anc 66-02 la: (ec re::wirac recorcea .:ba -t s . Inadecuate cor. trol a sem 1c; entries ca.

di sabl ed ar.r.wnc '.aters ,

f(-04 ::: Re:1cle;tcal C: te:is A wa s te s tit: e a. of solid metallic calces on nen- p 1

o pactec tra sh lacked

! requirec . strong packagieg aa.:

avality control measuras.

if-06 V

$cve111ae:e 1 Replacese 1t scufb charges were inst.alled in the stan::,

itquid tettrol syste- fr: a !

batch tha t had not been teste.

eweing a nanval intstatten c f ,

i i 'the Stancey Liquid Centrcl

?

System.

i l if-;0 !V 1

i Ra:toic;ical Raciatter surveys of packagee

\

- Cont.rol s irractated reactor compenents

! were net cocu .ented on i appropriate radiation survey

' forms anc macs.

it-1; : '.

- Ass. ae.:e of

' Quality c ontrel : easu-es we"e

".i't- e.ot tak e- 'n transf t-ries racica:t' ve wa ste shi;eerts l

i I l

__ _ - i

i l

l 65

'l TABLEa(Continjael)

C. S un.ta ry InspectiCn flep irt $everity Functional

.N u.

. e.a.r. .

(evel Area Violaiton _ -

!(-14 lV Assurance of Previously identified Quality inadequacies involving surveillance testing of the high pressure coolant injection system were not correctefJ for sin acuths.

36-14 V Surveillarce Failure to properly centeci r.easuring and test equittent.

3(-2; :/ Su ve'.11&nce Battery r att: * :40 discha rge Test pr:c ecure was rot upcate: te aflect syster alteratiens are restorati:ns.

ii. 5 lv Assurante of Fa t ture a nc Palfunet on

ss11:v Reccat wa s n:t completed by engine tri a.g personnel a f te*

they iden tified deficient station f ire barriers.

> if-21 V $ w ev ei l l a n c e" Surveillance tests were ,

perforeec witnewt in=ecen:ent verification of system res :Pse anc systen restoration.

it-25 Cev'.atten Fire 8 rete:ti:e Failure to comply with tre com.titaen t to conduct Quarterly fire brigade cri'. *. : ;

l for all fire brigade me*be's.

j , j

!!*3 !V 5ecurtty Improper package search anc ,

1

- $afeguards inadequate follow up. f i 56-16 IV Fire prote:tien Fire brigade members hac r.;t received the required

' training.

!!-2( *

.. Cars :te:ti;a ~ ' r t w a t c a.e s ' t il e d t's ; e ': *-

the retuired hourly ;4 trel 0 8 the motor generator Set r::P-g 1

4

'*[ l^ [ ,

--L

I l

66 !

l

AEL E 4 ( C on t i nu,e_el C. Su.*ary lo gar.t19n Evnc, t Severity Functional

(,e v e l A ea Viol 4tica

, p,ogey Fire Protection Inadequate fire brigade drill.

$$-37 IV Fodifications Safety-related sodifications 86-37 IV were not performed in accordan ce with applicable design requirements.

ire Prctecticn Adecuate procedures and 55-25 IV drawings had not been estabits had for the station fire wat er s;,stes.

'Y taciclegical Failu e se 1-;7ement a i !!-44 radiolog ical cortrel proce u e Oc-trels f or chec king ver.icles lea sing the site.

37-01 IV Ss <eillance Failure :e acrece te the prececure gcverning

surveill.ince- tes 6ing of tse Post Ace Idens Sarno11ng

' Syste.- (:3AS$ ) system .

IV

a i n t.e n a nc e Lack of ;>rocedure guidance on 37-01 maintenance of the heat tracing contro1 circuit reias s for the T8AS$ system, IV Fi e Fratect, ton

Failure to ta to required i"-03 action for inoperable fire C*

protection ecutpoent. .

f ;'

27-03 E IV Radiological Failure to control a master

? Ccet cis key to all Iceked ni;h j

ractation areas.

s?-03 IV Assurarce cf Failu o and M.alfunct on 0 aty Re:c ,r.st ce".oistec afte-a saf ety-related bus *.rar s'e-etc ret occur during a j 1UrV e il 1 & nc e *.e s*. .

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67

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QBl.Ea(Continued)

C. Sumary laspection Report Severity Functional N,g-y e *_ Level Area Violation 27-04 IV Surveillance A surveillance test on Standby Gas Treatment Systern failed to meet the intent of the Tech

$pec requirements.

87-04 IV Surveillance Failure to calibrate measuring

- and test equf zeent.

E7-0: V Mccification Perfoming post-medt fication l test or. the rifuel bridge withou as:-:ved precedure changes.

67 Ca IV Surveillance Mastee ram procecures ce not test --:ly acdress ace ,ue survet lar: test at:d gest 9 modificat - test progra.:.

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p %, niN:, or paum A.esNNsVLVANIA 1H;C 4 '

w n me RECElVEL 00cket No. 50-293 MAY ? O ~"

Soston Edison Company N/C Nu: lear ATTN: Mr. William O. Harringtoa Senior Vice President, Nuclear E. P. O

800 Doy1ston Street } _...... , _ , g Doston, Msssachusetts 02199 18 Gentlemen:

Subject:

Systematic Assessment of Licensee Performance (SALP)

Report No. 50-293/85-99 This letter refers to the Systematic Assessment of Licensee Performance ($ ALP) of the Pilgrim Nuclear Power Station for the period of October 1,1984 through October 31, 1985, initially forwarded to you by our February 18, 1986 letter (Enclosure 1). This SALP evaluation was discussed with you and your staff at a meeting held in Plymouth, Massachusetts on March 5,1986 (see Enclosure 2 for attendees). We have reviewed your March 26, 1986 written comments (Enclosure 3) and herewith transmit the final report (Enclosure 4).

Overall, your performance in the operation of the facility was found acceptable although some areas were only minimally acceptable.

As projected in our letter of February 18, 1986, a special in-depth team in-spection was conducted from February 18 to March 7,1986 (Inspection Report No.50-293/86-06) to deter-iine the underlying reasens for the peor performance discussed above. The team found that improvements were inhibited by (1) incom-plete staffing, in particular operators and key mid-level supervisory personnel, (2) a prevailing view in the organization that the improvements made to date have corrected the problems, (3) reluctance, by management, to acknowledge some problems identified by the NRC, and (4) dependence on third paaties to identify problems rather than implementing an effective program for self-identification of weaknesses. We believe these findings confirmed the SALP Board cortclusions.

We acknowledge your discussion of program and staffing improvements la plant i

operations, radiological controls tnd emergency preparedness. However, we

. . believe that,the success of your programs depends upon resolution of the four principal fagters inhibiting improvement noted above which, in turn, depends heavily on asnagement attitudes and aggressive followup. In this regard we request that you be prepared to discuss t te scope, content and schedule of each improvement program at a management meeting scheduled for 1:00 p.m. en June 12, 1986 at the NRC Region ! Office.

l T-4-1

\

b'6-TA,5;E 4 ENFOREvEN7 $U WARY (10/1/34 - 10/31/85)

PILGRIM NUCLEAR POWER STATION seve <ty Leveli M CT!0NAL AR!A$ 1 11 111 H ! QD Total A. Plant Operations - - -

4 2 -

4 B. Radiological Controls - -

1 1 1 2 5 C. Maintenance & Mc:tfications - - -

1 - -

1 D. $wevet11ance - - -

9 2 1 12 l

E. Emergency Prepare: ness - - -

2 - -

2 F. Security & Safeguares . - -

1 - - -

1 G. Refueling & Ottage Management - - - - - -

o H. Licensing Activities - - - - - -

0

etals b) !sse i t , 'e.e'

. C C 2 17 5 2 27 i

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l I

I i

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i F

. - , - - . - - . - . , _ _ - - , , - - . ---.--,,...-_n. _ , . _ _ . - - , , _ , . - , . _ -

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TA*f.E 5 ENT0RCEfENT DITA P!t.fiRIM NUOLEAR DOVER STATION Insp. Inso. Severity Functional No. Oate level Area Violation 84-36 11/1-31/85 IV Plant Fai1ure to conduct an adequate Operations

. shif t turnover for control room personnel curing refueling IV Plant

, Ope ra tier. s Failure to continuously mondter source range moniters during refueling 84-39 11/21- IV Surveillance Failure to promptly identify 12/31/84 conditions adverse to quality (i.e. f ailure to 111tiate Failure and Malfunction Reports) 84-41 12/10-13/84 IV Etergency g Frepare: ness Failure to diseminate emergency planning information IV Ere en:y Failure to u;date the emergency

re: a; s: ass clar a d pr::e:wres 84-44 12/1E-1S/54 I:: Radiological Failure to follow radiation work Controls permit instructions and failure to establish a procedure for a remote reading telecesimetry system F5-01 1/1-31/85 V Plant C;e r a *,i ce s Failure to maintain control room st,affing at levels required by 10 CFR 50.54 IV Surveillance Failure to test the containeent cooling subsystem 1eenediately when the low pressure coolant injection system was inoperable 85-03 2/1/85- IV Sw veillance Failure to conduct surveillance 3/4/E5 tests for tne reactor pectecti:n system (sin esauples)

!V Surveillance Failure to conduct red block g surveillance tests (five esaeples) 1 W- ..

i

/

f T-5 2 D

Insp. Insp, Severity Functional No. Date Levei A-e Vielatten IV Plant Failura to prowntly correct con-Operations ditions idverse to quality (i.e.

failure to take timely action on Que11ty Assuranca surveillance findings) a' V surveillance railure to same tone most current revision of s eaweillance test pror,edure Mr V Surveillence Failure to calittrate test equip-ment within the calibrated period 85-06 3/5/E5- V Plant Failure to maintain an uncali-4/1/55 Operations t, rated local power range monitor in a bypassed state IV Mainterance failure to conduct a diocty) phthalate test of HEPA filters f( > i' maintenance on the stk. treatment system 85-13 5/20 24'85 V Radiological Failure to have the Operations Ocu,rols Review Co-mittee (CR ) review twc radic1cgical procedures ard

- failure to control wort in the fuel pool with a saintenence request ,

Ceviation Radiological Failure to conduct an adequate Controls review of systems that could generate an uncontrolled, un-monitored radioactive effluent release, as recomtended in IE Bulletin 80-10 85-17 6/13/95- IV Survet11ance 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 spesify high radiation Controls area surveillanca frecuencies on radiation work permits k

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I n f .i t Insp. Severity Functionai

.9m Date Level area viciation Deviation Survet11ance Failure to conduct inservice tests as specified in an NRC submittal 35 20 7/16/85- IV Surveillance railur.: to maintain the trip 8/19/85 level setting for the "8" and "C" sain stena Itae high radt-

, ation monitors within technical

' specification limits 35-21 7/16/85- IV Surveillance Failure to maintain secondary 7/30/85 containment IV Su' vet 11ance 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-Ei&5 !!! 5ecurity Failure to pairtain an adequate l

vital area barrier 85-26 5 20/EE- IV Plant Failure to properly authorize 9'23/55 Operations excessive iteensec operator

- overtime as required by station

- procedures (thirty five instances) 85-27 9/16/S5- Deviation Radiological Failure to install a protective 9/ ;/E5 C trols concait f

S 9

. . . . . m. . . . . . . . - .

- p .e ne fe, UNifED$TATES

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NUCLEAR REGULATORY COMMISSION s, wy[/ f

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t 8 RE 010N 1 sa ruz avtNue h ,... uw2 cp enussia. eav mv. win two Oocket No. 50-293 g g g gggg U " q c. , ,

Ooston Edison company M/C Muciaar ATTH: tir. William D. Harrington '

Senior Vice President, Nuclear .

000 Soylston Street

, Ooston, Massachusetts 02199 W, g, ' '

. Gvntlemen:

Subject:

Systematic Assessment of Licensee Performance ($ ALP) Report No. 50-293/

64 34 and Your Reply Letter 8Eco 85-031 Dated February 12, 1985 Thank you for your reply to SALP Report No. 50 293/84 34 In your letter you pre-sented additional infomation concerning assessments and requested we recomicer some of the assessments to better account for the assessment period's extraordinary circumstances (i.e., thz extended outage for piping replacement).

Based on our discussions with you at the January 23, 1985 sanagement meeting and the information paesented in your reply letter, the SALP Board found it appropriate to ravise the declining trend of the Category 2 rating for fire protection / house-ke< ping to a Category 2 rating witt. a consistent trend. We feel this is appropriate as we may not have properly accounted for tne extended outage in our evaluation k for trend. However, we continue to feel that the extent of contamination that existed throughout the plant was inconsistent with a Category 1 rating. The en-closed SALP Report has been supplemented to reflect this change. The SALP Soard

.- also found that the other ratings should remain unchanged.

With regard to the current status of your operations, we acknowledge the ieproving trend of your performance in the plant operations and maintenance areas and on-courage you to continue your ef forts in these areas. Further, we note the orogress beiag sace in implementing your recently established Radiological improvement Pro-gram and encourage your efforts to decontaminate the plant, to reduce plant radi-

- ation levals, to enhance sversight of the radiation protection prograia, and to establish support for the program by plant personnel. 7

.! Your Cooperation with us is appreciated.

Sincerely, titt - b Thomas E. Murley Regional Administrator

c 38 s

.TQ L_?_,)

VIOLATION SWHARY (7/1/83 9/30/84)

PILGRIH_N11 CLEAR POWER STATION

[ A. Number and Severity Level of Violations Severity Level ! O d Severity Level II 0

Severity Level !!! 1 Severity Level !Y 18 Severity Level V 6 Oeviation

_1 Total 26*

8. Violations Vs. Fu.9ctional Area Severity level

', Functional Areas I !! III IV V OEV A. Plant Operations 2 5

8. _R_adiological Controls" 1 7 1 1

C. M_aintenance 2

D. _ Surveillance 1

E. Fire Protection and Housekeepino F. toercency Preparedness

, G. Sepvrity and Saftowards 6 H. Refuelina and Outace Menace *ent I. Licensine Activities __

Totals

1 18 6 1 "Tottis do not includa three apparent violations and one accarent deviation in the area of radiological controls that were identified during inspection 84-25.

NAC enforceeent action was under reviea at the end of the assess.eent period.

.a 39 C.

M an Inspection Inspection Severity Laport No. Functional Oate level Area Violation M 19 8/16-10/3/83 V A Failure to review and up-date special orders

)

1 V

., A Failure to vent piping from the high point in the core spray system

'l 83 20 8/8-12/83 IV

'I I Failure to follow a Radi-atton Work Permit 83-21 8/22-24/83 V A Failure to schedule 'exter-nal audits V A Failure to document deft-ciencies in deficiency reports 83 23 10/4-11/7/83 IV D Failure to conduct an in-service test on a high pressure coolant injection (HPCI) valve IV C Failure to review a proce-dure for procuring safety-

related items.

83 24 11/8-12/31/83 IV A i Failure to record reactor

vessel cool cown rate 4

84-03 1/20-27/84 !!!

I I Failure to label a container '

of licensed material, use extremity dosimetry, anc t instruct workers on raci-ation levels ,

84 04 2/7 3/12/84 IV

' A Failure to maintain a pro-cedure for the proper operation of the cantain-ment atmospheric dilution system 8b06 2/13-17/84 IV B Failure to follow a radi- l ation work permit i

i 40 Irispection Inspection Savarity pfortNo. Functional Oate Mvel Area Violation 04 11 4/23 27/84 IV C Failure to miintain a pro-cedure for controlling welding slag

84 13 4/24-27/84 IV E Failure to properly review and approve contractor cro-t.edures involving transpor-

tation of radioactive ratarials IV B Failure to comply with the requirements of a certifi-cate of Compliance for a transport package V '

B Failure to properly document a quality assurance progran for transport packages OEV i 3 Failure to fulfill a trans-portation training commit-ment 84 14 5/9-11/84 IV B

Failure to instruct workers on the presence of racio-t active materials

IV B Failure to survey radiation hazards

' IV E Failure to isolement cro-i cedures consistent with 10 CFR to

. , 84-22 7/15-20/44 IV G Failure to control a security key card IV G Failure to maintain photo ID badges IV G Failure to respond to two vital area alares IV G Failure to .naintain one guard radio ano ore offsite I comunications net coeracle i

I

l

1 .

1

i 41

'l Inspection Inspection Severity Report No. Functional Date Level Area Violation IV G Failure to maintain effac- '

tive compensatory measures.

IV G Failure to maintain effec-tive compensatory measures.

?

+ 84 25 8/G-10/84 *

,4 8 Failure to perfers radiation surveys il 8

i Failure to instruct workers '

on radiation hazards 8 Failure to properly approve procedures 8

Failure to is lesent recem-sendations in Aegulatory Guide 8.8 84 26 0/28-10/8/84 V A Failure to properly approve -

QA program related proce-dures

,J

,! i 1

.?

"Apparent violations and deviations.

i end of the assessment period. Enforcement action was under review at the I l

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e, NUCLEAR REGULATORY COMMi&SION asoio u utpaea Ave va

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SEP1 4 533 a::.et so. 50-293 3;rton *:ise* C:?:asy M/C Nw: lear Af7N: M* William D. Havaington Se-tor vi:e President, Nuclear RECElVED

33 5:ylst:r Street

.] 5:stee, .wassa:nusetts 02199 SET 1515'3 "j Ge'.tle*en: VV. D. H.

, u; j.

5'.E.'!:T : $YSTEMATIC A55555*.!NT OF LICENSEE PERFORMANCE ($ALD) ine ht: Regi:n ! SAL: E:a*c :enew:ted a review on August 25, 1983, ane evaluatee tne :e*f:rtaa:e of a:tivities asse:iate witn the Pilgrim Nuclear P:=e* Stati:n.

ine *esults o' this assess ent are cc:wmentec in tne enclose: SAL: 6:a*: Pe::*t.

A teetts; ras :ee* s:re:wie: for Se:te-:e* 21, 1993, at Braintree, Ma. t: .

C's asi tnis assess?ent.

At t*e *P**ing, yew sn:Wla De Dre:ar:1 to dis:Uss Our assess *ePt aSe yCy*

O'ans 10 '* ve Ce*f:rPaa:e. Any *:P*ents ):V ?ay nave regarding :w* *t*:rt Say : "is:Ws3e at tre meetirg. AO itionally, yCu may pecvi:e writter ::tre*ts

. ** tein 23 cays af

er tse meeting.

P:II:=iag CWe meeti*g and recei t of yoWP resterse, the e**lesed Pt: Ort, ):6' res::Pse, am: a sg.?tary c' cwe fin:ings and plannec a:tions will te plate: in lf) *e NE: Dweli: Co: ween R e c e. .

l

.' V: * ::::eration is a: pre:iate:. !

sinterely, i I i n

[ .

.s I ; 1:na : . aroste:Ai !

.'l SALP Searc Cnair an, Dire: tor Division of Proje:s anc

'fl

'1 Relicent Programs I '

i I"*Iosare: As Siate:

} :: w'ea:1: .

A V. Marisi, Ma9ager, hu: lear 0:erations Supoort C J "athis, Stati:n Manager i' e

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4 TA8!,5 4 V10LAT!0NS (7/1/82 - 6/30/83)

\.

s P!l, GRIM NUC(EAR PC'n'IR STATION i

/

.; . A. Numbe' and,$everity 1.evel of Violations

! 5everity i.evel I 0

'.':- " )

. Severity Level !! 0 Severity Level III 1

. Severity Level IV 9 Severity Level V 20 Deviations 3 .

Total Violations 30 Total Deviations 3 B. Violatiens Vs. Functional Area Seve ity t.evels

. FUNCTICNAL AREAS ! !! III IV V OEV

... .) ' 1 Plant Oeeratiens 4 8 2 Radiolecical Centrols 1 7 1

' 12,, ,

'. 3. Maietenance 1 I i 1. Surveillance .

L , fire Protection /Wousekeeeinc ,

3 1

6. (mergency Presaredness

7. 3 2 Security and $4 fecuerds 1 f

'! 8. Refueling

, 9 t.icensine Activities l

1 Totals 0 0 1 9 20 3

! Total Violations = 30 Total Desistions = 3 r

O O Y

s

, t

.- 40 TABLE a (Continued) -

. Sun:a ry a farpe: tion Inspection Nel Require-Cate Sub.4eet ments Severity 82-19 m

A June 14 - Blocking open a fire T.S. V

'\

August I door without proper 5 controls Failure to evaluate 7.5. V 5

' fire loading prior to acving combustibles into safety related area

Failure to translate 100FR50 V 1 cesign bases into App. B drawings Failure to perfem 100FR50.59 V 1 i

an acequate safety evaluattor. prior to

) changing a station

- _ . _ - valve 11neum procedure 1 Failure to maintain T.S. V 5

.j a tire d(co? position continuously annuncisted I

Failure to perfom Fire 0 5

! daily checks of non-4 Prote: tion l-

.I alamec fire coors Review as committee to the l NRO 82 22 August 2 -

Failure to make a T.S. IV 2 prompt notificatica Failure to make a 20CFR50 V 1

l. 50.72 notification Failure to perfom a T.S. IV 1 leak rate test required by the LC0 for an !

incoe sele Vacuum Bretker Alare System i

) '

I q P

S

-- , _ - . - - , . , , ,-_...--,w- --- , . , , , . - , , - , - . - . , , , , - - - - . . , , ~ - -

= l 41

)

TABLE 4(Continuedl Su.:aary Inspection Insaection Recuire' No. Date Subject ments Seve ity A en F2T lectemeer 7 - Failure te7evise Licensee 0 2 October 18 procedures for radio- Response

active discharges as to

) committed to the NRC Viol a?.i on it 81-19-01 82-29 October 19 - Improper ecuipment T.S. V 1 Novemeer 15 tagging Failure to prope ly

set a main steam safety valve Failure to properly 10CFR50 IV 1 control distriDution App. B of the Q-List Failure to use proper Security V 7

'fi methocs of access control Plan 1

~

Failure to prevent Security IV 7 unauthorized entry into Plan

.i vital area or followup on a security ceficiency N/A(1) January 31 Safeguards information 100FR73.21 III 7 1983 not properly controlled 1

resulting in a loss af copy of the site physical Security Plan 4

[ 83-03 January 25 Failure to perform T.5.

reeruary a V 2(1)*

j chemistry is.piti Failure to assure that 100FR50 V 1 training certification App. I forms were completec prior to watch assignment Failure to procaely T.S. Y 1(5)*

4 contral hign pressure gas cylinters

.~!

[

42 Ta9LE & (Conti3ej H23u ,,

Inspecticn Inscection Raouire-No. Date $utj eej eents Severity A en

. 83-07 March 22- Failure to imole- T.S. V 2(3)*

} April 18 ment a station cro-cedure for inspection

{

and cleaning of the 553T System inlet plenum 83-08 May 9 - Failun to conduct T.5. V 2 .*

May 13 an audit of the Radiological Environ-mental Monitoring Program report whtn recuired 83-09 April 4 - Accepting, in receipt 10CFR50 V 1

.; May 3 inspection, material App. B n not in conformance v with the P.O. Require-ments Failure to r.aintain 10 FR50 IV 1

,' the Q-List App.B ,

Failure to uncate the 100FR50.71(e) V (2) 1 FSAR 1 Failure to perform !ES 79-09 0 3 preventive mainten- Cemitme nt l ance as cormitted to the NR:

i

} 83-10 April 19 - Safeguares inforsation 100FR73.21 IV 7 not properly cent.rollac

~

May 23 Security access card Security IV 7 Ley not prcperly con- Plan

t. rolled 2 ..

I W

uai 'to s7ATEs j -

' .h#'%Il NUCLEAR REGULATORY COMMISSION neoloN t

./*h@E

$3 5,'% ( ,

jf 1 en ians avswa amo or eau m.p NN$4V ANIA WC4

" huv1 $ s3

' Occ.et No. 50-293 Uess on Edison Company M/C Nuclear AffN: Mr. William D. Harrington lentor Vier. President, Nuclear ev0 Boylston Street j fW uon, M asachusetts 02199 o i j Gentleren:

' $wbject: Systematic Assessment of Licensee Perfemance ($ ALP) 4 This letter and its enclosures document NRC's assesseent of the perferrance of i licensed activities at the Ptigrim Nuclear Power $tation for the peried Septe=:er 1, 1981, to June 30, 1982. The enclosed $ ALP Report, dated August 12, 1982, includes performance assessments for each of the nine fwnctional areas which These individual assesstents were discussed with you and your were evaluated.

staff by Mr. R. W. Starostockt of thit of fice on Septector 1,1992, at tne Boston Edison Cee.pany offices in Braintra, M.

Our overall assesseent of the perfomance of NRC licensed activities at the Pilgrim facility is that improvement has occurred since Therethe ecwor;anizatienal appears to te and personnel changes which took place eariter this year.

a satisfactory level of management attention and involveme matters.

h Ve recognize that ef forts are underway to incrove the canagetent safety. These changes systems and utilization of resources at the Pilgrim facility.

and plans are documented in the Perfomance leprovement Plan which we missed to the NRC on July 30, 1982. d. Althougn several months before some of these improvements will be comolet perfomance has improved recently, some shortcomings have been noted and we have incluced them in this report. In particular, we believe accitional at.tention is warranted on your part in the a*eas ofWe day to-day will plant c: era-be increasing our tiens and fire protect. ion / prevention activities.

attention to these areas to ascertain if identified weaknesses are teing

! corrected.

In the meeting of September 1,1982, the NRC staf f benefited f rom ycur co--ents concerntng ee $ ALP Program and the functional 20, area1982 performance and have assessmvnts.

I inclucee

,' I have also reviewed your letter of SeptemberThe SALP Board also consicerec responses to your cceents in this package.

your concerns and I had the benefit of their input. The reswits of these

. consicerations are presented below.

\/

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un1 10LAf!0NT M /41 - 6/30/82,},

Pfl. fir!M NUttEAR POWER STAT!CN

, .Ihf

-.g i

A. Am6er ted taverity level of Vlotatiens

['k' '

4.

Interia fiRC Polfey Severitylevel (Septacber 1.1981. March 9,1982) 3 v Hty Laval !

n' '*g$'

lenHty Level !!

O f 'f: Severity Level !!!

O 6

%y 1 SettH ty Leysl !Y 5 beHty Level V 17 ktHty Level VI 2 Det14 tion 1 l EUelicy Severity levels (March 10, 1982 - June 30, 1982*)

keHty Level ! 0 kt 4 N"Hty Level !!

Mty level !!! O 1

ktHty Level Iy 4 kidty Level y 3 M14 tina j 4

I"4ITielettens 38

Total Deviatiens 2 8 Anettenal Area

% ' l. IM1 . Merch 9. 1982 Severity Levels

! !! !!! !V V V! CEV O O 3 3 5 0 0 b l8 0 0

' 1 1 3 0 1 4

turvetit 0_ 0 0 0 2 0 0 vi _0 0 0 1 1 1 0 s.. ,3

- ___0_ _0 0 -.

0 5 _0 0 h 1...s_tsymp rc_. 0. 1 0 0 0 0 gg,gg 0 0 _

1 0_ 0 0 0

' 50NMtLtLeg n,,a . ,

TAllt t 5 iCentinuedl B. Vfolattens Vs. functional Ann

(2) Harch 10,1982 - June 30,1982*

! severity te .ii WNCTIONAL AREA $ I !! !!! TV V CEV

,.f 1. Plant Ceerstions 0 0 0 1 1 1 2._ dadielcaical Centrols' 0 0 0 1 0 0 1.,Nafntenance 0 0 0 1 0 0 4 Surveillance 0 0 0 0 2 0

5. N ew Protectfen* 0 0 0 0 0 0

1. trertency Precaredness 0 0 0 0 0 0 i (

L _ Security 4 Safeevards 0 0 1 0 0 0

~

82 _','Refu'el'i n's ' ~ 0 0 0 1 0 0 L .L.feenstnc Activities 0 0 0 1 0 0 Totals 0 0 1 4 3 1 Total Violations = 38 Total Oeviations = 2 I

Oces not include the following reports, not yet issued:

. 82 Resident Inspector 42 20 - Special Health Physics S

36

-==

i

\.

i 1 7ABl.E _ 5,(Con ti nu_ed),

C. Su i.lary Inspaction Inspection

,qou_ , Cate Subject Req. Sav. Area I

81-18 June 15 - Failure to have an ocarable 10 CFR III 1 (9).

Sept. 30 cor.bustible gas control system 50.44 (multiple exarules of design arters, procedural and drawing errors,)andinadequatesafety rivicwt 81-18 June 15 - Failure to inform the NRC of T.S. !!! 1 (9)e Sept. 30 the erroneous statecent that an installed systers rwt the require-cents of 10 CTR 50.44 - Matarial False Stateetnt 81-19 August 18 - Failure to follow statica pro. T.S. Y 1 Sept. 30 cadurt

. 81-19 August 18 - Fa11urt to perform a safety 10 CFR !Y 1 Sept. 30 evaluation prior to disabling 50.59 protection for an MR purp 81 21 August 31 - Failure to post a high radia- T.S. IV 2 Oct. 2 tion area

, 31-21 August 31 - Failure to tdhers to radiation T.S. Y 2 Oct. 2 protection Jrcescures fer

' radiation work pennits.

81 11 August 31 - Failure to post copies of 50V's 10 CFR Y Z j

Oct. 2 involving radiation protaction 19 j 81 21 5est. 16 - RCIC centainment isolatten vs1ves T.S. !!! 1 i sept.17 wrt left open when their centrol instrumentation was inopet able 8'.24 0,C. 1. 1951- Operation at drywell terceratures 10 CTA W 1 Jan. 13. 1982 above FIAA description without 50.59 acequate safety evaluatiens r,1-24 tee, t. 1981- Failurt to adequately prepart and T.S. V 1(4)

JLA 18. 1982 terlenint precedures ter ccping with high crywill terceratures

/

37

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'aspection Inspecticn hk Data jgfeet 81-8 Dec. 1, 1981 Rec. sey.

. A rti i Jan. 18, 1982 Failure to pr@ptly evaluate and 10 CR Y i corrtet conditions adverse to quality 50 App 8 1

81 24 1 Dec. 1, 1981-Jan. 18,1982 Security parly access card keys not pro-controlled Security !!! 7 81 24 Dec. 1, 1981- Plan Jan. 18, 1982 Ccebustibles were not ricoved from area near het work T.S. Y 5 81-24 Dec. 1, 1981.

Jan. 18, 1982 Irpreper equiprent tagging T.S. Y 81-25 1(3) cet. 15 -

Oct. 10, 1981 Failure to have all CRC rubers present at a pre refueling T.S.

k Y 8

' meeting 81-25 July 20, 1981

. Transported radioactive esterials with liquid in drums 10 CR !!! 2 81-J5 Nov. 1 - 30.41 Nov. 30 Control / Storage of cartustible gas cylinders was not in steerd- T.3. V 5 ance with station procedurts 81-35 Nov. 1 -

Nov. 30 Failure ment to establish precedures for t tnd isole~ T.S. V 5 of coseustible scrap,he centrol waste, debris 81-35

. 4 Nov. 1 -

Nov. 30 Failure to establish and isole- T.3 ment procedurts for the control V 5 I

81 33 of cartustible oil Nov. 1 -

Nov. 30 Control of foreign material during repairs to M5!Y's was not T.S. V 3 in accordance with precedurt 81-M Nov. 30,1381 Dec. 4, 1981 A mistar sunet11ance schedule was not established T.S. VI A

$145 Nov. 30, 1931-Dec. 4, 1581 T.S. kene. ants ware net preserly entered into centro 11ed volas T.S. VI 9 (1) h 38 Eiiins;;2 - - - - -

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2 TABL U (Continue;Q C. S naary In sp. t f un Inspwci.fon Lou, . Cate Subfect Rec. . Sev. Ares .

81-36 Nov. 30, 1981- Program and precedures w re not 10 CR y 3 (5) * .

1 Dec. 4, 1981 established for hottsekeeping and 50 Aco I systas cleaning that meet the QM j

standards stated in the QA Manual

'. 82-01 Jan. 18, 1982- Workers wre not properly in. 10 CR V 2 Feb. 28, 1982 structed of the storage and 19.12 transfer of radioactive resins 82-01 Jan. 18, 1982 Procedures wru not adequately T.S. V 5 Feb. 28, 1982 established ud frelemented to provide required nurters of IC8A units for fighting fires 8242 Jan. 1 - Uncalibrated brush Mcorders 10 CR Y 4 p Jan. 15. 1982 were used during RPS surveillance 50 App 8 4

, 82-02 Jan. 1 - Maintenance activitieJ wre per- T.S. IV 3 Jan. 15, 1982 forved without asing approved

procedures 82 02 Jan. 1 - Instnmentation was not calibrated T.S. Y 4 Jan. 15, 1982 at fnquency specified in station procedures 42-02 Jan. 1 - Improper control of access to security !!! 7 j l Jan. 15, 1 M2 Vital Areas plan I P2-04 Jan. 25 - Failure to i gtement procedures T.S. Y 4(1)*

Jan. 29,1982 for LUtt and drawing change revisions 82-04 Jan. 25 - Orsvings and procedures did not 10 CR IV ' 1 l Jan. 29,1982 identify the as-built condition 50 App I of valvas in pipil3 systws M-C'l Feb. 1 - Untitely cornettve action to 10 CR Y 1 Feb. 5, 1982 internal CA Audit ceficiency 53 App B Reports l

C243 Feb. 10 - Training and recual progra for Comittrant CEV 2 ,

i Feb. 12, 1982 personnel who operate and grunt IES 79-19 l radioactive wtste not iclecented l as ccomitted

39

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TA51.E 5 Montinued i C, SUmany Inspv.tfon Inscoction h_ Oate j M/A Feb. 12, 1982 Sub.fect Promet Notification System flee.

10 CFR Sev. Aree (strens)notinstalledby 50.54

!!! 6 February 1, 1982 i 82-10 March 1 -

4 r11 4, 1982 Perfor red tagad maintenance on vs1ve with attached T.S. Y 1 (3)

82 10 March 1 - Pldnt shielding study med.

april 4, 1982 (truck lock dcor panel) not NURIG '

cosipleted as stated in 0737 ctY 6 response to NRA

!! 11 Feb. 25 - An unautherfred adjustrwnt was Feb. 28, 1982 10 CR IV 4 rede to a leaking flange during 50 49 J the coeduct of the PCILRT 4

82-12 4r11 5 - ,

May 9, 1982 Failure to follow actions re- T.S. !Y 1 qutred by T.S. with fnoperable i reactor vessel water level ;

instrumentation 82-13 4r11 12 - L

- Inadecuate design control, fcr 10 CR IV t 4ril 16,1982 interfaces and verification 50 Acp 8 9 (5) * !

[ 82 16 May 10 -

June 13, 1982 Failure to lock or control access T.S. IV 2 to a h19h radiation area (stuck TIP drive)

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8 I

I Testimony Subaltted by I Stephen J. $weeney 1

' President and Chief Executive Officer l loston Edison Cempany to the U.S. House of Representatives Sutcomittee on Energy Conservation ans Po er I

of the Comittee on Energy and Comerce July 16, 1986

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INT 1000Ct!CN Scited Edison Ccmpany appreciates the ecportunity to address a nud er of issues involving the Pilgrin Nuclear Pcwer Station which are of concern to this c0mittee, the Nuclear Regulatory Comission and to me i Dersonally. At the cutset let me strest that most of the issues ratted by l the NRC in various re;crts and by this comittee were of concern to me more than a year ago and that corrective actions were underway as early as l septecer 1985. As discussed in the follcwing pa;es, tnote actions are reeting with success.

In t0 day's environment, public concern accut nuclear power 15 heightened sutstantially. Public confidence in the technotc;y and the institut10ns involved with it is at a Icw point, i Botten Edisen C:e:any has a great deal of work to do in this envircncent to gain cutlic c nfidence in our ability to manage and run Pilgrim Station. I corsonally will not ce satisfied until we havc achieved a level of public and regulatory C0nfidence that allcwt Pilgrim Station to

placc a cng the besc. He have made an internal Comitment to measure

curselves against the test, which is a significant change in no. =e are 8

approaching cur current prcblems.

As will be evident in reviewing cur testinony, we were historically l

{

plagued by not locking cutside to measure our success and to uncertate tne intensive self. criticism necessary to assets perforrance hcnettly and cbjectively. That has Changed. he are rioving in a new directiCn, cne Date$

en rising standards of excellence ahich are set, not by regulat10n. tut cy tne perf:rrance cf these plants jugged to to areng the test.

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- - - m 2-It should be noted that the concerns we are addressing today are different from these for whicn we were fined in 1982. The issues than .ere safety related and failure to ccgly with regulations. Tcday, the issues

. are not directly related either to compliance or to safety. They instead involve a rising standard of performance going far beycnd mere ccmpitance eith rules to a much broader dimension in the regulatory process. That new l

direntien 11 ene that dictate'? .vmparlsent and success is measured by

! relative gerf:rmance. We enderte it.

tefere discussing cur current activities. Itt me offer ert:ectives

n three time frames.

The first time fra e is 1972 to 1979 and Three Mlle Island. .

ujer cana;etent thertc ming then was the failure to reccgnize fully that .

f

, the c:erational and managerial demands placed on a nuclear ;cwer :lant are very different frcm those Cf a conveational fossil fired power plant.

!:st:n [siten structured its nuclear cegantratten as Cart of a traditi:nal

erating arm. While many ee?ters of the Pligrim Statten organt:atien rec:gnized the differences in the technolegles, they had imited success in ar;uteg for the resources necessary to meet a set of standards that al:*ea:y

.ere rising fairly rapidly, This was also a perted of poor quality fuel

.Meh resulted in significant internal radiological problems that affecte the :lant for years.

Then came Three Mlle Island, Frca March 1979 untl) early 1932 tre late structure, uncer one vice preticent, atte?pted to deal with the c:st-THI detants en c:erattens anc en;intering, while at the sa?e tire M5uing a c:nstruction gerni fc a sat:n: unit at 711gt h Statice the Staf# increaseg gra atically to 220, 3 0 aac then aJO :e::le. I: =11 aa 9rets:Fatle .cr(1 cad f:r tre stru: gre aa: =e : aid a c:stly :e'al!/ ';r P:

9*'1912 t e; i t .- $550,000 in early 1952

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.I f From 1982 until mid-1985, we operated with a new arid leproved management structure that recog.itted the unique natur9 of nuclear power plants and the demands of the post-TH! period. We comm1tted the financial and human rascurces necessary to upgrade equipment and hardware and to j install various improvement programs to meet NRC concernt. More than

$300 ml1116n went into hardware improvements, the staff grew from 400 to nearly 600 people and the organization was restructured under a tenter vice i

l

! president end two vice presidents. We achieved a significant reature of

, success for'htch we were recognized by the NRC and in the plant's outstanding operatinti performance in toth 1983 and 1985, But in managing the equipment improvements and the new management

, systems and programs we put in place, we didn't focus encugh on what 45

. going on outside the company in the industry and within the NRC, What we i didn't see because we were to internally focused was the fact that the i; industry itself and the NRC vere locking under, tehtnd and around all of tne i

hardware and managemeat programs reaching for escellence.

1

In our case, not seeing that put ut in a defensive posture, he l

weren't 14 ntifying weaknesses that were inhibiting continued improvement ourselves. We weren't being self-critical, others had to tell us what was j wrong. We weren't holding managers accountable enougn for the end result of i

an action or inaction. We weren't worting well enough together.

! Those proclems were very real, very serious and of great concern to me and to the Soard of 01 rectors, I W arme particularly concerned atout management perforr.ance, not management systems and programs, but the results I

of thote systems and programs as reasured ty effeCitvenett. In Sid 1935. I IN *

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asted the Vice Preticent of Nuclear C;erattent to investigate my conce"s.

.nien he snared, are titue a report. 45 ne pro; rested tncougn ene ::w:f. . e

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anc ethee managers beg:n identifying needs. In september 1985, we lacreases tne operator staff by a third. In Decemter, us reorganized plant management to isprove reporting relationshipt and build in greater accountatt t t ty.

l .

In February 1936, the NRC lstued their recort. Thay said the sare I

thing: We had attitude problems that were seriously interfering with our

! aglitty to get the results we thould be seeing given our financial and human I 1

rescurce conent tments.

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gy March, we had tsken a number of other actions, all of entch are

- detailed in the following pages. We began eliminating those old attttuces tut were not serving us well and began to inject the nuclear organtratten l .ith the skills and perspectives necessary to achieve a measure of i cerfcrmance which would place us 4xng the test. In the same time frate e I

I l nee further human rotource ccamitments. We increased our emergency i i

planning complement five-fold, we increased the numter of radiological l

l tscnntclans 35 cercent and we implemented an accrentice program for the i

j Icag.ters develcceent of skilled personnel.

The shutdown on April 12 gave us an cecertunity to accelerate that l

I l :Pange. A different approach to prceles tolving was taken. It stressed a i

! more deltterative and Integrated effort at identifying root causes and

{ taktn1 corrective action. In early May a new plant manager and a new t , ..

g icerittens seCtien head were trought on teard, nearly rounding out a new 16

eAce' Diant management team. Of the 16.11 were new in their positicms in -

the cast 3 months and 5 were new to the company. We have new perspectivet He nave peccle with strong nuclear navy tackgrcundt, peccle with NRO Hs;ection eagerience and pecole .ho grew up professionally not in cc9ve9tional f; ggt). fired gcuer plants, but in nuclear plants.

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i On May 27, having accepted that management is just as important as Squipment, we took the unprecedented step of giving the now plant manager and his new team additional time, while the unit was shut down, to become

/culliar with the issues, to accelorate the development of new programs and, mst importantly, to infuse the organization with attitudes and behavior that will make those programs work. These are attitudes that demand

', self-criticism, demand accountability, demand teamwork and demand results i

i which go far beyond mere compilance with a set of rules, regulations and technical specifications.

> Excellence is our goal. But excellence is, after all, an attitude unich accepts nothing less. Achieving excellence will not be easy; we know

, tnat. We know our problems. We have made the human .*esource and financial

,' corrrnitment to solve them. We know what has to be done and we are doing it.

1 As a result, I am confident we will, in time, demonstrate to you, to the

.! Nuclear Regulatory Commission and the public that we have responded i

effectively to the concerns which are shared by all of us.

As a final point, I know that an important question on the minds of 4

) many people is "why should Boston Edison be believed today gisen the i problems over the years at Pilgrim Station?"

I hope I already answered that question in part. It is perhaps the most difficult question and can only be answered fully by performance over Jl tima. But in closing I would underscore two major differences today from

- the past. The first is our forceful acceptance of the need for us to maasure our performance against an ever increasing set of standards set by ttose plants judged by industry and the NRC to be among the best.

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'i The second is the fact that we have adopted the basic principles ud criteria for good management that are applied to the nuclear navy. They a.J the sama principles and criterla that are in evidence at all of the top rata, plants.

i c' This is a demanding industry with a vital role in the social and d

'1 economic health of the country. It operates in a demanding regulatory 1

climate as evidenced by this hearing today. For us as a company with A

, , single unit to succeed in this environment means that we must impose on ourselves the highest standards of performance found in the industry.

~

.' J! We i

are doing just that.

{

. The balance of this filed testimony is arranged in the order of the six sections on which you requested information in your letter of July 2, 1986. We have repeated your request at the beginning of each section.

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B NHoh G. sird July 8, 1987 Se : . :e vn :o ...: n*

l BECo L:r.87-111 4 Me, Steven A. Varga, Olree:Or t Olvision of React:r 8rojects, I/II

} Unitec S:ates Nuclear Regula 3ry Ccmmission l Wasnin;::n, O. C. 20!!5

.i l License CPR-35

'I Occket 50-293

c. INFCRMATION REGARDING 8I! GRIM STATION

$aviiY ENHANCEMENT PRCGRAM

Reference:

NRC Le :er, 3recosed Enhancement to tne Mark I Containment -

! Pilgeta 5:a:!cn, sa ed Acril 30, 1987 Cear Mr. Varga:

! As agreed during July 1. 1987 discussions te: ween Frank Miraglia. USNRC, I

and Jenn Fulten. Sos::n I:tson Cemeany (SECo), .e are submit:Ing :nt s res:ense

~ to your letter ic SECO ca:e: Acril 30, 1987. Enclosec for your information is

. a cetailec :escri:tten of :ne Safety Ennancemen; 3regram (SEP) naraware i :nanges nat 5EC nas volun:artly elected to Imolement for Pilgrim Nuclear Power Statten (PNRS). The cesertation of procacural changes anc corsennel

! training will be furnisnec uncer se:arate cover, a current imclementa: ten senecule for :ne SEP r,cotf!ca: tens will slso te furnished secarately. A I concition is tnat tne modificattens scheduled during the current outage 30 nc:

! re utre ort:r ;cvernmental accroval. Sheuld :nis c:ncitten not ce me: f

acy

! of :nese voluntary mocifica:!cns, with :ne result :nat the current t imolementation s:necule mus: :e extenced, enen SECo will be unaole to im:lemen: :ne affecte. eccift:ations curing tne current cutage.

.' Accittenal documen:ation will te avallante f:r review ey the NRC Staff a:

SECo's Sraintree offices or tne PNPS site. C gni: ant SEOs personnel wil' :s

'. i j available at tnote loca:1:ns for ciscussten witn t.9e Staff.

l Carrent evaluati:ns of 9e tenefit from tne SE8 mocifications are case:

i i primarily ucon entensive, al:ncugn 1:111 preliminary, analyses and Qualita: ve engineertag jac;ments. Final cuantitative analysis must, in accordance

witn tne s: ateo long :erm ;:11 of tne SEP, awal final identificaticn of i mocifications anc :: mole:'en of the Indivicual Plant Evaluation (IPE).

8EC: understancs :na: :9e N:C intenes to issue later this year a generic letter re:ut*'ng all clants :o :erfcrm an IPE as par: Of :ne e

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tare cf tne C:matti':n 1 Seve a Ac:!:ea: :::':y 5:stenen:. anon : 4:

"equiremen- !$ 111ge:. 5(*: es ec 1 c Ocm0!e!e !?e l85 anc Orem:: y fant :94 resg :s avaliacle in at:Or:ance altn .90 revie, at: Cast Ore 5*-1:ec cy tre i

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3!4tte feel free :: con:act me 0F !*.sar: dcw4r3. cf my 1:aff at (61;)

343-39CC 'f cu ave any: ses:!:6s ::.9:e--: ; : e ma::ar a:: ettec in :nts c'!t ret: ente.

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inclesures cc: Nuclear Regulat:ry Cenmission Cocument Centrol Oesk

.'i Washing;:n, 3. C. 20555 l

1 Nuclear Regulatory Ccmmission

', Region !

. 631 Park Avenue

! King of Prussia, PA 19406 Senior NRC Resident Inscactor ,

i Pilgrim Nuclear Pcwer Statien

, 1 Mr. R. H. Wessman, Project Manager

! Oivision of React:r Projects, I/II

.j Office of Nuclear React:r Regulation 8 U.S. Nuclear Regulat:ry C:mmission 7920 Noodolk Avenue Bethesda MD 2C814 1

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EXECUTIVE

SUMMARY

OF THE PROGRESS REPORT ON EMERGENCY PREPAREDNESS FOR AN l

i ACCIDENT AT PILGRIM NUCLEAR POWER STATION a

. I. EXECUTIVE

SUMMARY

On December 16, 1986, I transmitted to the Governor a comprehensive report on safety at Pilgrim Nuclear Power Station. This is a progress report about the activities by state and local government, the Boston Edison Company, the U.S. Nuclear Regulatory Com-ission and the Federal Emergency Management Agency since that time to address the concerns we found.

In April of 1986, operation of Pilgrim Station was halted because of several mechanical problems. The U.S.

j

.i Nuclear Regulatory Commission has ordered that the Boston

. Edison Company keep the plant shut until a variety of <

'l corrections regarding the management and operation of Pilgrim Station have been made. As of this date, Pilgrim remains closed, although Boston Edison has asked the NRC for permission to restart the facility.

In my December, 1986 repo:t, I concluded that Radiological Emergency Response Plans for the Pilgrim

. facility were not adequate to protect the public health and

safety. I further identified serious problems regarding the j management of the power plant and the engineering safety of

the reactor. In my view, these three issues -- emergency planning, plant management, and reactor safety -- were so serious and the weaknesses and deficiencies so severe that I i recommended that the plant should not be allowed to restart

' unless and until these concerns hed been satisfactorily addressed.

There has been a considerable amount of activity at all lovels to address these concerns since my report was issued.

In some cases substantial progress has been made. In particular, the Massachusetts Civil Def ense Agency and Of fice of Emergency Preparedness has devoted all available staff and resources to the effort of developing the best possible emergency response plans.

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MCDA/oEP has instituted a planning process at the state and local level and revisions are well under way. In addition, a new system has been installed for off-site

. notification in the event of an accident at Pilgrim Station.

. We now have the advantage of a new Nucient Safety-Emergency Preparedness Program and a professional staff which for the i first time is dedicated to off-site emergency preparedness and pisnning. This new program and staff are the result of

, , i the Governor's initiative in the Fiscal Year 1988 budget.

i The Governor has requested additional funds for the new

. program as a supplementary appropriation for the current fiscal year.

lonetheless, I continue to make the finding that adequate plans for response to an accident at Pilgrim Station do not exist, and I reaffirm my earlier position that the Pilgrim facility should not be allowed to restart until such plans have been fully developed and have been demonstrated to be workable and effective through a graded exercise of all plans and facilities.

This finding is based on the fact that in every critical

,g area in which I found a deficiency t: exist in my December, 3386 report substantial work remains :o b., done before a

> determination of adequacy can be made. For example, analysis j of a new Evacuation Time Estimate and Traffic Management Study by state and local authorities is still underway. The i ETE is one of the most critical pieces of information in the l' entire process and the foundation of effective emergency planning, our preliminary review of the ETE suggests that

] more resources are required to successfully implement the i traffic management plan. The shelter survey which was 1 prepared by Boston Edison has been returned to the company for further study betsuse is was found to be woefully

^f l inadequate.

Plans and implementing procedures for special needs J'

J ' populations remain incomplete, and it may be necessary to

.! undertake an additional survey of people who would need assistance in emergency response or to do further statistical analysis of this matter. The development of implementing

} procedures and the identification of resources to care for school age populations also requires additional work. In regard to the adequacy of reception centers, the question of

' need for a facility to serve people in the northern portion of the EPZ romains open. We cannot make decisions on the need for or identification of a third reception centar until Boston Edison has provided us with an analysis of the adequacy of the existing two reception facilities.

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With regard to plant management, we have seen nunerous changes in Boston Edison's personnel and organization for m.inagement of Pilgrim Station. The most notable change is the appointment of Mr. Ralph G. Bird as Senior Vice President, Nuclear, who directly reports to the company's

. Yet despite these changes, I cannot

! chief executive say at this time that officer.the management problems have been fully u For example, we are concerned about recent d.

} resol.

incidents including violation of NRC regulations in the area of plant security, and allegations of excessive overtime worked by utility employees. We are also concerned by Boston Edison's action to refuel Pilgrim Station without having

') responded to my objections and the objections of several state legislators.

The Systematic Assessment of Licensee Performance (SALP)

! perfomed by the NRC is the most comprehensive studyThe andlast report on nuclear management at Pilgrim Station.

SALP report was issued on April 8, 1987 and it showed since l

l deterioration the last report.

in several aspects of nuclear managementUntil a similarly management under the new organization has been conducted and the above concerns resolved, I cannot say that our management

~j concerns have been addressed, With regard to reactor safety issues, we have carefully f reviewed Boston Edison's "Safety Enhancement Program" (SEP) .

I The Generic SEPLetter" has been from undertaken Mr. Robertstructures since the Bernero issuance ofsuchthe NRC of a "Draf t as theconcerning Pilgrim safety at Mark I containmentWe have two major concerns in the area of containment.

l reactor safety.

First, despite the fact that the NRC letter was prompted by a finding that there was a high probability of Mark Iconta the NRC has yet to adopt Moreover, an official position according to NRC regarding Region I safety enhancement.

Administrator Will(am Russell, with whom my staf f and other l state officials met at NRC's regional offices.in King of Prussia, Pennsylvania on October 8, 1987, enhancement of the i

Mark I containment at Pilgrim is not an issue that the NRC

' believes must be finally resolved before restart.

Our second concern is the uncertainty that continues to exist about at least one No feature of the Boston Edison SEP, the direct torus vent. concensus has been reached on l creates unreviewed whether installation of the torus vent i

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1 safety issues or if the torus vent is authorized, how it will 4

ho used in the event of a severe nuclear accident.

The findings of my Deceinber,198G report have been 3 strengthened by two other analyses of safety at Pilgrim Station. The Special Joint Legislative commission to Study j

9 Pilgrim Station has issued its report which further In studies addition,

' and documents many of the same cafety concerns.

.] the Federal Emergency Management Agency has issued a

'_i

Self-Initiated Review of plans for response to an accident at l Filgrim Station. Based on several of the issues raised in my l report FEMA has changed its interim finding and now agrees 4

that the off-site plans for an accident at Pilgrim are not adequate.

FETA has transmitted their new finding to the Nuclear However, the NRC has yet to indicate

-, Regulatory whether or notCommission. development of adequate off-site plans will be i a condition to the restart of Pilgrim. We are not satisfied with the view recently expressed by the NRC Region I staff

' that emergency planning problems must be "addressed" before restart. Such problems must be satisfactorily resolved j

before restart. Off-site response plans are just as g

important as nuclear management and reactor safety in protecting the public from an accidental release of radiation.

1 Therefore, for these reasons -- the absence of adequate emergency response plans, lack of demonstrable assurance that management problems have been solved, and. uncertainty about the safety of the Mark I containment structure -- I continue j

to find that Boston Edison has not met the heavy burden of a

showing readiness to restart the Pilgrim Nuclear Power i Plant. I also continue to believe that it remains to be seen if adequate emergency response plans can be developed and if

)

all other safety issues can be resolved to our satisfaction.

1 Finally,Irecommendthatinligh$ofthenumberof outstanding issues and their complexity, and Boston Edison's evident determination to press ahead with the effort to restart, that there should be a full scale public hearing by of the NRC before any decision is made regarding the restart l Pilgrim Station.

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e October 14, 1987 CHARLES V. BARRY SECRETARY OF PUBLIC SAFETY f.

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~. THE COMMOilWEALTH OF MASSACllUSETTS

! axacutiv.I DEPARTMENT

cm otraws: Aavergggas:=cv,aena >m .

l Flu .:tN0'it'd. IdASE017014 117 MICHAEL. s. OU.tAKis RoaERT J. 800 LAY C 2 f1444 , PR&Cion September 18, 1987 1

. ?. -

! Mr. Ralph Bird d ' Senior Vice President l Boston Edison Company

! 800 Boylston Street Boston, Massachusetts

Dear Mr. Bird:

My staff has reviewed the August, 1987 "Study to Identify Potential Shelters in EPZ Coastal Region of the Pilorim Nuclear Power Station," which was prepared for you by Stone and Webster.

We find that this study is deficient in several resoects and

., that additional work is required to provide information to j local officials which is sufficient to support development of implementable shelter utilization plans. I have attached a copy of a memorandum prepared by my staff which detatis our

, specific concerns regarding this study.

If you have any questions or. observations reoarding our i evt.luation, please contact Buzz Hausner of.my staff.

l Thant< you for your cooperation in this matter. -

Sin obert ulay

..h Director Q -

cc: Assistant Secretary, Peter W. Agens, Jr.

Deputy Director, John L. Lovering Mr. Buzz Hausner 5

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suhs THE COMMONWEA1.TH OF MASSACHU'3ETTS At" % -

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EXECUflVE DEPARTHtNT ,

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. Illa *d. S. 00N*.:Us Mo8ERT J. 80VL AY PW".TbM DAICf04 TO: . DIRE OR DOULAY

,FROH: BUZ USNER . -

t .IN RE: SHELTER SURVEY OF PILGRIM EPZ PREPARED BY BOSTON EDISON COMPANY

DATE: SEPTEMBER 11, 1987 -

We have made a preliminary review of the shelter survey of the Pilgrim EPZ which was prepared by the Boston Edison Company and its consultants. While this document compiles some very useful data, we feel that more work must be done to estimate the effectiveness of shelter as a protective action.

Our principal concern is that we must be able to put data in the i hands of local officials.which are sufficient for the development

of shelter utilization plans for all areas of all five

~'

. communities within the Pilgrim EPZ. With this in mind, we have the following comments.

The survey only covers an area approximately one mile wide along the coast. The shelter capabilities of the entire EPZ must be surveyed and reported.

- The survey does not separate out those structures which j could "most reasonably" be used as shelters from those

where shelter is less appropriate.

it would help to have a separate list or

I ForinstanceIngsandfacilitiesforeachtown, pubile build

, including an estimation of the actual useable shelter i space and protecgfve factors for shelter under

government authority. ,

- Hany of the shelters listed, such as jewelry stores and pharmacies are. clearly not suitable for public shelter. In a severu emergency, every available resource will of course be put to use. However, to develop an implementable shelter utilization plan, local officials must be able to match estimated needs with the most appropriate resources available,.

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5. - Director Boula '

Page 2' .

Regarding protection of the beach occulation, the survey Jientifies shelters within.a mile of the coast but does not indicata the distances that beach goers would have to travel to find shelter. In addition, the

survey must demonstrate that adequate proximate shelter is available for the total population at' the individual beaches.

For instance, Ouxbury beach is about seven miles long .

A and the survey should indicate the distance peonle at Saquish Head are required to travel to reach adequate shelter. Further, an implementable shelter utilization plan must demonstrate that the nearest shelter would not be full to capacity before the people at the most remote"points of the beaches arrived.

The survey must identify adequate shelter which is handicapped accessible.

The survey does not distinguish between available space and usable space. For instance, residents of Plymouth have indicated to us that some basements listed in the survey are no more than crawl spaces 4 Crawl spaces

! cannot be considered for public shelter. Further, in

, most buildings, a good deal cf floor area will be

" occupied by machinery, counters, office furniture, et cetera. The survey must identify accurately the actual useable shelter space available in each structure.

Stone and Webster uses a FEHA nuclear attack value of ten square feet per person to estimate the potential

, population which can be sheltered. Local' Civil Defense Officials may wish to allocate more space -- uo to twenty square feet per oerson -- in their utilization

} plans. The value used in the survey overestimates the a potential capacity of various buildings. We doubt.that j 17,000 pecole can be sheltered at Duxbury High School, 1

' or that 89,700 can be sheltered at the 5 Cordage Park Buildings. '

The survey must demonstrate that public shelters are

free from asbestos and other environmental hazards.

The report estimates residential "sheltering capability" in individual communities as between 53%

and 81%. These figures indicate that a significant number of residents do not have adequate domestic shelter and emphasize the need for a full study of public shelter capacities throughout the entire EPZ.

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d," . Director Boulay i Page 3 4

l' 3 Further, even if it can be established that the vast majority of residences offer adeouate shelter, local

officials must be prepared to offer public shelter of a known protective capability to residents who demand

. assistance. ,

This report makes no definitive statement of what constitutes adequate shelter to protect people from the effects of a radioloolcal release from Pilorim

-1 Station. This is necessary to determine what 1 facilities are most appropriate for a 1 peal shelter utilization plan and to determine the public shelter

, needs of each community.

, In summary, we wTuld say that this survey is a useful beginning but that much mora work is required before we can assess our ability to develop implementable shelter utilization plans consistent with the public safety concerns in Secretary Barry's

, report to the Governor.

. cc: Assistant Secretary Peter W. Agnes, Jr. -

l Deputy Director John L. Lovering -

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1 g 30570N ED6CN becuthe Offges Boo Boylston street l Boston, Masuchusetts o2199 I .hl,sh G. Bird September 17,1987

- Sonici Vice Presdent - Nut fear BECo Ltr. #37-146

'I U.S. Nuclear Regule. tory Commission

} Document Control Desk 1 Hashington, D.C. 20555

! Docket 50-293 l License No. OPR-35 l

Subject:

Boston Edison Company Request for Exemption from 10 CFR Part 50, Appendix E.Section IV.F.

Dear Sir:

f' In accordance with 10 CFR section 50.12(a) Boston Edison Company requests i

that the Nuclear Regulatory Comission (NRC) grant a one-time exemption from i

i the requirements of 10 CFR Part 50, Appendix E, Section j

for the Pilgrim Nuclear Power Station (Pilgrim) to be conducted in the second The schedule for future biennial exercises will not be quarter of 1988.affected by this one-time exemption, but rather will continue to pro such exercises will be conducted every second year (i t . the following I' biennial exercise will be held in 1989).

I The proposed deferral of the full participation exercise has been discussed

..i; with the Commonwealth of Massachusetts (Commonwealth) and lo response officials.

proposal.

- ].1 The request will not affect the onsite exercise at Pilgrim planned for 1

December 9, 1987.

The requested exemption is necessary bectuse the Commonwealth, the local governments within the ten-mile plume exposure pathway emergency planni t

(EPZ) and the two emergency reception center communities are at present engaged in irplementing numerous improvements in their These offsite emergency preparedness programs, with the assistance of Boston Edison.

iuprovements include revision of the emergency plans of the local governme revision of the Massachusetts Civil Defense Agency (HCDA) Area II plan as j

as the Commonwealth's state-wide plan, the development of revised related procedures, the development and implementation of training programs for

, officials and emergency personnel, and the upgrading of Em 3

Centers (EOC's).

to accomplish these improvements, and the work is expected to continue th

! the remainder of the year and early 1988.

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t U.S. Nuclear Regulatory Commission Page 2

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h. vic'; of these extensive ongoing efforts, tha ComNuealth and the local r;overninnts have indicated that they are not able to participate in an

.warciso during calendar year 1937. Ihreover, it is apparent that under these circunstances, conduct of the full participation excrcise will be much more affectivo after the ongoing improveuwats have been implem2nted. In granting one-tirm exemptf ens authorizlag daferral of exercises for licensed plants in th9 past, th NRC has s ecognized that the most effective and beneficial exerc'sas arc those which include the full-scale participation of State and i locai governments and that it is appropriate to defer an exercise until

. prograsa revisions or facility improvainents have been completed.

, Since the last full participation biennial exercise at Pilgrim, Boston Edison

.j has held an onsite exercise at Pilgrim in December 1986; has held

- quarterly onsite drills in March, June and August of 1987; and has scheduled

- its Annual onsite exercise for Decembar 9,1987 (in which the Comonwealth wili exercise various offsite objectivos as descrioed in BECo Ltr. #87 -147 "Scheduling of Pilgrim Onsite Exercise"). The previous exercise and drills have included limited participation by the Comonwealth, and the March and June 1987 drills included limited participation by several of the towns. The towns within the EPZ have also cooperated in the full scale siren test reviewed by FEMA, which was conducted on September 29, 1986. In addition to its activities involving Pilgrim, the Commonwealth has also participated in full participation exercises at the Yankee Nuclear Power Station in June 1986 and is scheduled to participate in a full participation exercise at the l

Vermont Yankee Nuclear Generating Station during the week of November 29, 1987.

} This request meets a number of the special circumstances listed in Section l 50.12(a)(2) .

, First, granting the request will provido only temporary relief from the applicable regulation and the licensee has made good faith efforts to comply with th.) rogulation. Over the past year, Boston Edison has assisted

Comnonucalth and local authorities in a variety of ways to accomplish as many improvements as possible in their offsita emergency response programs. For I exagle, Boston Edison has developed substantive information for the enhancament of those programs. The major products of this effort include the "Pilgrim Station Evacuation Time Lstimates and Traffic Hanagement Plan Update" l

- (August 18, 1987) prepared by XLD Associates, Inc. and "A Study to Identify Potuattal Sholters in the EPZ Coastline Region of Pilgrim Nuclear Power

, Station" (August 1987) prepared by Stone & Hebster Engineering Corporation, as

.] well as information generated in surveys to identify the special needs and l transsortation dependent populations within the EPZ.

. In addition, Boston Edison is providing assistance to the local governments in thJ1r offsite emergency program enhancement efforts in accordance with the Massachusetts Civil Defense Act of 1950 (Chapter 639, Section 15. Acts of 1950 as a m ded). This assistance includes the provision of two professional planm.rs to work under the direction of the officials of each town within the EPZ in upgrading its plan, procedures and training; one t

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U. S. !!uclear Regulatory Commission o Paga 3

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I su/essicn41 planner to assist uch reception ceater community; and four pioressional planners working under the direction of HC0A in the upgrading of

i: he IWJu Arel II and Commonwealth program. In the first hal' of 1987, Boston idl3o.. piovided introductory emergency trainiig i to atout 350 personnel within

he fin tcwns in the EPZ and enhanced introductory training modules are l cur.'oltly being prepared for ieview by th9 HC0A prior to furt.i.er try wentation. The planners provided by Boston Edison have also begun to I !vepire task-based modules for training of specific categories of emergency 1 parsee si and will be available to participate in the training programs. In 7 addition. Boston Edison is executing agreements with each of the five towns witi.In the EPZ, as well as the two reception center comunitiss, for i assistance in the renovation of their EOC's. Moreover, four of the five EPZ

. towns and both reception center communities, to date, have accepted BEco's of.Nr of funding support for full-time civil defense staff positions.

]

. Second, literal coitpliance with the regulation would not serve its underlying purpose and would result in undue hardship to Conmanwealth and local cuergency response agencies by requiring an exercise of portions of the offsite emergency plans that are in the process of significant revision and improvement. This would necessarily involve disruption of the ongoing process of implementing these changes, and consequently, the imposition of additional costs and delay in accomplishing the planned improvements. The NRC's emergency exercise requirements clearly were not intended to disrupt the

ord;rly implementation of improvements in such manner.

t j Finally, because granting the request will allow work to proceed without disruption, it will result in a not benefit to the pubile health and safety.

The NRC has acknowledged that flexibility is appropriate in applying emergency planning requirements. This flexible approach is especially appropriate in i

this case, where granting the request will facilitate more prompt and effective impicmentation of improvements.

For all these reasons, Boston Edison asks that NRC grant the requested

.1 exe.; tion. In accordance with 10 CFR $170.12(c), a fee of one hundred and fif ty dollars ($150.00) will be electronically mailed to your offices. If you should require any additional information in connection with this request, please contact either myself or Mr. Ron Varley of my staff (telephone: 617 -

9 424-3832).

.4 .

? alph G. Bird

! pal./dlw i

r 4 a o U. S. ?!uclear Regulatory Comission Page 4 cc: Dr. Thomas E. Hurley, Director ,

Office of Ndclear Reactor Regulation 1 U.S. Nuclear Regulatory Comission ~

The Phillips Ru11 ding

?bthington, D.C. 20555 Mr. R.ll. Nessman, Project Manager Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation U.S. Nuclear Regdlatory Comission '

7920 Norfolk Avenue 6ethesda, MD 20814 Hr. Richard Krim, Assistant Associate Director FEMA 500 C Street - Federal Plaza Washington, D.C. 20472-Mr. Edward Thomas FEHA - Region 1 J. H. McCormack Post Office and Court House Boston, MA 02109 Mr. Peter Agnes, Jr.

Connonwealth of MA Assistant Secretary of Public Safety 3 1 Ashburton Plae.e - Room 2133 Boston, MA 02108 U. S. Nuclear Regulatory Commission

Region 1 - 631 Park Avenue ,

, King of Prussia, PA 19406 Senior NRC Resident Inspector Pilgrim Nuclear Power Station

. Rocky Hill Road Plymouth, MA 02360 Henry Vickers, Regional Director :

FEln - Region 1 l j

. J.H. McCormack Post Office and Court House Boston, MA 02109 ,

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ML20155D951

Text

Subject:

Enclosure:

1.3 Background

SUMMARY

SUMMARY

Subject:

Enclosure:

SUMMARY

2.0 INTRODUCTION

SUMMARY

2.0 INTRODUCTION

2.1 Background

Dear Mr. Barry:

Enclosure:

Dear Mr. Collins:

Dear Sir:

Subject:

Subject:

Subject:

Reference:

SUMMARY

SUMMARY

Dear Mr. Bird:

Subject:

Dear Sir:

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