ML20196L649
| ML20196L649 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/25/1988 |
| From: | Bird R BOSTON EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 88-099, 88-99, NUDOCS 8807080101 | |
| Download: ML20196L649 (23) | |
Text
-. - _ - _ _ _ _.
eosawsw Pilgrim Nuclear Power Station Rocky Hill Road Plymouth, Massachusetts 02360 Ralph G. Bird Senior Vice President - Nuclear June 25, 1988 BECo Letter #88-099 U.S.
Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555 Docket No:
50-293 License No:
DPR-35 Pilgrim Nuclear Power Station Request for Commencement of NRC Integrated Assessment Team Inspection and Transmittal of Schedules for Actions Prior to Restart
Dear Sir:
Boston Edison Company hereby requests that the Nuclear Regulatory Commission (NRC) commence its Integrated Assessment Team Inspection (IATI) of Pilgrim Nuclear Power Station on July 11, 1988.
Boston Edison provided the NRC with the results of its Restart Readiness Self-Assessment (RRSA) on May 26, 1988.
This letter provides the schedule for those matters identified in the RRSA which require completion of specific, well defined actions for restart.
Attachment I contains summaries of RRSA Chapter II. A items and schedules for remaining actions to be done before restart.
Attachment II is an integrated summary-level schedule for the remaining work and testing before restart.
This schedule is also the Target Schedule to be inserted into the Restart Plan, Volume 2, Rev. 2 as Appendix 2.
Attachment III is an errata sheet for the RRSA.
This sheet should be inserted into each of the copies of the report in your possession.
m 8807080101 880625 PDR ADOCK 05000293 O
a June 24, 1988 Docket No:
50-293 BECo Letter #88-099 License No:
DPR-35 Page 2 Please contact ne cr R. A.
Ledgett if you have any questions about the schedules ans status information provided in Attachments 1 and 2 or if you need additional information in preparation for commencing the IATI.
/ Attachments cc:
Mr. William T.
Russell Regional Administrator U.S.
Nuclear Regulatory Commission - Region I 475 Allendale Road King of Prussia, PA 19406 Mr. D. G. Mcdonald Projact Manager Division of Reactor Projects I/II U.S. Nuclear Regulatory Commission Mail Stop #14D1 One White Flint North 11555 Rockv!,lle Pike Rockville, MD 20852 Senior NRC Resident Inspector Pilgrim Nuclear Power Station
Mgtters that Recuire SDecific Action Before Restart Identified in Chapter II.A of the Self-Assessment for Restart ReDort The most important matters identified during the RRSA relating to plant and equipment performance, operational performance, management and organization that require specific action before restart vore described in Chapter II.A of the Self-Assessment for Restart Report.
Specific plans or actions co be implemented prior to restart are summarized below.
Actions already completed are designated "Complete." Dates under "Complete" annotations indicate the date the action was completed or the time frame in which the actions were taken.
Actions scheduled for completion between the date of this letter and restart have the completion date designated.
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RRSA SECTION II.A.1.a "The first portion of the process (for reporting deficiencies and initiating corrective action)
--a single reporting form and a corrective action clearinghouse
-- will be initiated prior to restart.
In the longer term, this activity will be expanded and integrated with PNPS information systems with the objectives of:
a) reducing the number of redundant corrective action tracking systems; and b) providing more readily accessible and usable management information tools."
DETAILED PLAN or ACTION AND SCHEDULE DATE FOR II.A.1.a 1.
The PNPS Housekeeping Manual hNs been Complete issued and im,*lemented.
Expanded (May, 1988) specific area owner assignments are contained in the manual.
2.
"Clearing house" was formed and began Complete operation to screen personnel, (Jun 13, 1988) administrative and material deficien-cies and to generate necessary documentation to effect correction (e.g. MR, PCAQ, DR, NCR, etc.).
The initial efforts of the clearing house are being focused on dealing with the backlog of items generated in the course of the self assessment as delineated in a and b below.
a.
Document presently known material Aug 01, 1988 deficiencies (Management oversight and Assessment Team Field Notes, Peer Evaluator reports).
This is being accomplished by the Systems Engineering Division working with clearing house personnel.
b.
Cat.egerize and document non-Aug 01, 1988 material deficiencies.
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DETAILED PTAN or ACTION AND SCHEDUIA DATE FOR II. A.1.a c.
Following the initial trial period, this organization will be formally proceduralized.
The first part of the proceduralizing Aug 31, 1988 process will be to create a single reporting form ba6 ' on the experiences gained ir processing the work to date.
3.
QA Surveillance Upgrade Program will be implemented.
The scope of this upgrade program will extend beyond the established Appendix B requirements.
a.
Draft QA Action Plan to upgrade Complete the audit / surveillance process, b.
Train QA Division Manager in the Complete upgraded program.
(Jun 1988) c.
Train remaining QA Department Sep 1988 personnel in tpgrade program.
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BESA SECTION II.A.1.b "Priority actions are being directed to filling 32 (29] newly authorized, permanent Boston Edison positions within the Maintenance Section that are now staffed on an interim basis by contractors.
Ten of the positions are designated for supervisors and work planners.
Management has given advance approval and the highest priority for hiring in order to more effectively support team building within the Maintenance Section.
Additional items scheduled before restart include: (a) issuance of an improved / updated Maintenance Control
[Section] Manual, which will formalize many of the improvements presently in place, (b) revising the troubleshooting procedure to more clearly document work activities during and subsequent to a troubleshooting task; and (c) capturing remaining improvements in appropriate formal PNPS documents.
The Station Director and Plant Manager will continue to exercise close oversight of the maintenance function through restart, power ascension, and initial power operation to assure that management control is effectively maintained and improved.
In this regard, particular emphasis will be placed upon training and monitoring of responsible organizational elements to increase their familiarity with and attention to the work control process."
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DETAILED PLAN or ACTION AND SCHEDULE DATE FOR II.A.1.b A.
Initiate priority actions to fill Boston Edison positions in the Main-tenance Section.
As of June 23, 1988 eleven new employees have been hired in this effort.
B.
Revise / Issue Maintenance Control Procedures 1.
Procedure 1.5.3 (Maintenance ReqJest Procedure).
a.
Prepare draft Complete b.
Formulate and conduct training Complete c.
Implement procedure Complete (Jun 20, 1988) 2.
Procedure 1.5.3.1 (Maintenance Work Plan) a.
Prepare draft Complete b.
Formulate and conduct training Complete c.
Implement procedure Complete (Jun 20, 1988) 3.
Rewrite Maintenance Section Manual a.
Prepare drafts Complete I
b.
Review drafts Complet'c l
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Develop training Complete d.
Conduct train.ng Jul 1, 1988 I
e.
Develop Plan of Action for Complete l
implementation (Jun 24, 1988) l 1
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1-l DETAILED PLAN or ACTION AND SCHEDULE DATE FOR II.A.1.b 4.
Implement Instrumentation and Control (I&C) valve line up procedure.
- a. Draft procedure Complete
- b. Install Phase I tags Complete
- c. Develop and conduct training Complete
- d. Issue procedure Complete
- e. Develop plan of action for complete Complete tagging (Jun 23, 1988) 5.
Upgrade Environmental Qualification (EQ) procedure, a.
Approve draft procedure Complete b.
Develop training Complete c.
Conduct training Complete d.
Issue procedure Complete e.
Lift stop work order Comp. Tete (Jun 20, 1988) 6.
Implement Lifted Leads Procedure (1.5.9.1)
Complete a.
Approve draft procedure Complete b.
Develop training Complete c.
Conduct training Complete d.
Issue procedure (Jun 1, 1988) 6
DETAILED PLAN or ACTION AND SCHEDULE DATE FOR II.A.1.b 7.
Implement torquing procedure a.
Determine scope and receive Complete engineering input b.
Prepare draft procedure Complete c.
Review draft procedure Jun 27, 1988 d.
Develor
'"rl conduct training Jul 8, 1988 e.
Issue procedure Jul 15, 1988 8.
Implement valve stem lubrication procedure a.
Determine scope Complete b.
Determine lube types Jun 27, 1988 c.
Develop procedure Jun 27, 1988 d.
Develop and conduct training Jul 1988 e.
Issue procedure Aug 1, 1988 f.
Revise PM schedules Aug 1988 9.
Revise the troubleshooting procedure Aug 1, 1988 to more clearly document work activities during and subsequent to troubleshooting.
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DETAILED PLAN or ACTION AND SCHEDULE DATE FOR BOTH II. A.1.a & b The Work Prioritization Team function has Complete been proceduralized in the recently completed revision of PNPS 1.5.3, Maintenance Requests (MRs).
In combination with the Rotating Window concept, each system's status is periodically reviewed and station management focuses on the system's deficiencies.
Thus MRs of all priorities are evaluated and the items scheduled are those that support system performance and address plant reliability.
The Maintenance Section Manager has Complete addressed the issue of qualification to perform maintenance with Division Managers and Supervisors.
Maintenance tasks are assigned based on the satisfactory completion of the applicable training or the previous experience of the individuals.
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RRSA SECTION II.A.1.c "a.
Continue the process for hiring.
b.
Develop an integrated schedule for remaining surveillance and testing to meet restart using an inter-disciplinary' team.
c.
Continue addressing remaining maintenance work required for restart in the Plan-of-the-Day and assure that resources are focused on meeting scheduled dates."
II.A.1.d "Complete reviews, sequence, and schedule any additional testing identified by these reviews for completion prior to restart or during power ascension testing."
DETAILED PLAN or ACTION AND SCHEDULE DATE FOR II.A.1.c & d 1.
A detailed schedule for accomplishment Complete of fire barrier surveillances has been (May 26, 1988) issued and has been incorporated into the integrated schedule for work and testing.
2.
NED periodically issues a report to Latest version address "issues that could potentially dated:
delay restart."
Jun 20, 1988 3.
An integrated schedule for work and Complete testing has been' issued in sumnary (Jun 23, 1988) schedule form and is included as a separate attachment to the cover letter for this document.
The schedule incorporates remaining maintenance work, Logic System Functional Tests [LSFTs], fire barrier surveillances, and other surveillances L
and controlling paths.
4.
The process for hiring of personnel has been continued.
As of June 23, 1988 sixteen personnel have been hired for this department.
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DETAILED PLAN or ACTION ANC SCHEDULF DATE FOR II. A.1.c & d 5.
Review of testing for plant equipment and systems are being completed to confirm their readiness for reactor operation.
a.
Reviews of Logic Systems Aug 22, 1988 Functional Tests (LSFT),
Simulated Automatic Actuation Tests and Plant Design Change post work test procedures for adequacy.
b.
Review to verify the scope of Jul 7, 1988 planned power ascension dynamic testing.
The review process is as follows:
m.
Select relevant dynamic events, (operating tran-sients).
Define expected transient response, (system component and plant parameter).
Identify changes made, (Plant Design changes, major maintenance and emergent problems) which could potentially affect plant transient response.
Predict and evaluate potential impact on plant response due to failures, malfunctions or installation s
errors.
Evaluate completeness and adequacy of tests done or planned during power ascension to assure adverse impact, if any, could be detected.
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DETAILED PLAN or ACTION AND SCHEDULE DATE FOR II.A.1.c & d c.
Review to verify that plant Jul 22, 1988 systems will be tested and are operable before restart.
A list of surveillance and test procedu-res is being prepared for selec-ted systems.
The list includes Technical Specification surveil-lances and non-Technical Speci-fication required procedures which support operab 11ty.
The complete list of procadures will be reviewed to ascerta.
which procedures should be pe. formed before restart.
Considerations will include date last performed and whether work has been performed since the last test.
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RRSA SECTION II.A.2.a "a.
Prior to restart, complete reviews and any necessary changes to provide improved control over valve position and to enable operators to more readily determine valve position status, b.
Prior to restart, revise the tagout procedure to limit the types and clarify the uses of specific tags.
c.
Prior to restart, develop a plan to implement the INPO good prac-tices for valve lineups and labe-lling in regard to instrument is-olation valves.
d.
Prior to startup, develop instru-ment-specific valve lineup sheets for all. safety system and criti-cal Balance of Plant systems."
DETAILED PLAN or ACTION AND SCHEDULE DATE FOR II.A.2.a 1.
Revision to PNPS Procedure 1.4.5, Aug 1, 1988 Equipment Tagout, is in progress.
Some specific improvements include:
a.
Elimination of the use of red danger tags to mark lifted leads, b.
Improved control over NWE and test tagging.
c.
Requirements to perform lineups following removal of equipment clearance tags.
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DETAILED PLAN or ACTION AND SCHEDULE DATE FOR II. A.2.a 2.
Operations has completed reviews of Aug 15, 1988 the valve position control procedure.
Prior to startup, each operating system will be given a complete valve lineup as close as practical to the actual startup date.
Subsequent to that lineup, periodic lineups at specified frequencies will be performed on all accessible components.
Additional improvements will be considered and implemented whenever necessary to improve operator control over and knowledge of valve positions.
3.
An instrument specific instrumentation Complete and control (I&C) valve lineup (Jun 22, 1988) procedure has been issued for safety systems and selected Balance of Plant instruments. This procedure was based on INPO good practices for valve lineups.
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RRSA SECTION II.A.2.b "Complete the revivw of the ESF actuation study and initiate positive actions to reduce the occurrence of unplanned ESF actuations."
DETAILED PLAN or ACTION AND SCHEDULE DATE FOR II.A.2.b 1.
Complete a' pre-restart test review to Jul 1, 1988 identify those tests needed to minimize problems most likely after start-up from a long outage.
2.
Conduct the pre-restart tests Aug 19, 1988 identified during the review of 1 above.
3.
Conduct a review of "Management Complete Lessons" in NUREG 1275 and evaluate (May 23, 1988) for applicability to PNPS.
4.
A review has been performed of Aug 19, 1988 training conducted on industry operating experience.
Training on thermal binding of large gate valves has now been included in the operator training program to be completed before restart.
S.
Inadvertent ESF Actuation Task Force Aug 1, 1988 will complete analysis, and corrective actions to disseminate lessons learned and prevent recurrence will be completed.
6.
Anti-spill Task Force will complete analysis of spill events and corrective actions will be implemented.
a.
Complete analysis of all spills Jun 27, 1988 in 1988.
1 b.
Convene task force to establish Aug 1, 1988 corrective actions and develop schedule to implement corrective actions.
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v RRSA SECTION t
II.A.2.c "No additional actions (to improve the formality of communications) are required for restart, although Boston Edison will initiate steps to apply appropriate portions of the standards for Control Room communication to I&C and other personnel identified for improvement."
DETAILED PLAN or ACTION AND SCHEDUI@ DATE FOR II. A.2.c 1.
Communications training for licensed Complete operators is complete.
(Apr 1988) 2.
Communications training for non-Aug 19, 1988 licensed operators is in progress.
3.
A Station Instruction (SI-OP.0006) has Complete been established for standards of (Nov 4, 1987) communications in the Control Room.
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RRSA SECTION II.A.2.d "Validate procedures revised during RFO-7.
Prior to restart,, complete training on procedures revised for modifications and implement the writers guide.
An upgrade of Operations procedures by the Procedures group is scheduled as a long-term effort."
DETAILED PLAN or ACTION AND SCHEDULE DATE FOR II. A.2.d 1.
Procedure validation is in progress.
Jul 15, 1988 As of 6/17/88, it is approximately 60%
complete for all procedures revised since April 1986.
2.
Conduct training on operations Aug 19, 1988 procedures revised for modifications implemented during RFO-7.
3.
Issue the Procedure Writer's Guide.
Jun 29, 1988 4.
The validation process has been Complete defined in TP 88-07.
(Jan 30, 1988) 5.
Specific procedural deficiencies as Aug 1, 1988 delineeted in the MO&AT Field Notes will be dispositioned.
6.
Improve human factors in EOPs and Complete satellite procedures.
7.
Human factors improvements in other procedures is not a restart issue and will be completed as a longer term project.
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RRSA SECTION II.A.2.e "Resolve deficiency reports [on Priority A drawings] prior to restart."
DETAILED PIAN or ACTION AND SCHEDULE DATE FOR II. A.2.e 1.
Independent review of Priority A Complete drawings was completed by the surveil-(May 07, 1988) lanco Monitoring Group.
Two DR's were issued.
2.
Conduct a survey of all Priority A Complete drawings and associated messages in "SEEK."
3.
NED review the accuracy and validity Jul 22, 1988 of each message in "SEEK" for Priority A drawings.
4.
Request removal of unnecessary "SEEK" Jul 22, 1988 messages.
5.
Complete drawings update.
Aug 15, 1988 6.
The effectiveness of having Priority A Aug 15, 1988 drawings updated and issued prior to operational turnover of a modification is the subject of a DR, (See Item #1 under II.A.2.e above).
The resolution of the DR, including completion of corrective actions constitutes the verification of adequacy of the process.
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RRSA SECTION II.A.3 "Prior to restart begin actions to institutionalize practices involving:
a.
Planning, scheduling, assignment, pre-job briefing, and control of maintenance; and b.
The event investigation and critique process, including the process for determination of underlying causes, and assigning and accomplishing identified actions.
After power ascension, eftarts will be directed to institutionalizing the peer evaluator process, and developing a long-term, issue oriented data base."
DETAILED PLAN or ACTION AND SCHEDULE DATE FOR II. A.3 Good practices in use that will be formally proceduralized:
1.
Specification of permissable or Jun 27, 1988 required times to conduct post work testing in Maintenance Requests.
2.
System Window Concept for maintenance.
Aug 30, 1988 3.
Describe work flow process.
Complete (Jun 20, 1988) 4.
Work Package Development Checklist.
Complete (Jun 20, 1988) 5.
MR Data Base accessability via the Jun 27, 1988 Prime computer at 12 terminal locations.
6.
Define Work Prioritization Team Complete concept.
(Jun 20, 1988) 7.
ALARA aspects of development of Jul 15, 1988 preoperational tests.
B.
System turnover process.
Jul 15, 1988 9.
New training material on NPA trash Jul 1, 1988 compactor operations.
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f DETAILED PLAN or ACTION AND SCHEDULE DATE FOR II. A.3 10.
Refresher academic training for Jul 1, 1988 license candidates.
11.
The practice of giving 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> NRC Jul 1, 1988 style written practice exams.
12.
Methodology to deal with testing of Jul 15, 1988 special projects such as Hydrogen Water Chemistry Control.
13.
The practice of providing NTD Jul 1, 1988 instructors on-shift for NRC license candidates.
14.
The practice of giving NRC license Jul 1, 1988 candidate NRC style walkthrough and oral practice exams.
15.
Glove bag use.
Aug 15, 1988 16.
Excavation practices.
Aug 15, 1988 17.
Prevention of excavations in the Aug 15, 1988 buffer zone.
18.
Pre-job briefings (in excess of RWP Complete requirements).
(Jun 20, 1988) 19.
Conduct of spill drills.
Jun 30, 1988 20.
The Fire Protection System status Jul 22, 1988 l
boards.
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Requirements for medical attent.on Aug 15, 1988 off-site.
22.
Inspections of work sites by super-Aug 15, 1988 visors.
23.
Personal safety responsibilities.
Aug 15, 1988 24.
Station overtime policy.
Jul 15, 1988 25.
Event critique procedure.
Complete (Jun 20, 1988)
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Self-Assessment of Readiness for Restart ReDurt Errata
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