ML20198P824
| ML20198P824 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/04/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20198P814 | List: |
| References | |
| 50-293-97-99, NUDOCS 9711120026 | |
| Download: ML20198P824 (7) | |
See also: IR 05000293/1997099
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Enclosure 1
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)
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PILGRIM NUCLEAR POWER STATION
Report No. 50 293/97 90
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BACKGROUND
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The SALP Board convened on September 25,1997, to assess the nuclear safety
performance of the Pilgrim Nuclear Power Station for the pedod from April 7,1996,
through September 13,1997. The Board was conducted pursuant to NRC Management
Directive (MD) 8,6 (see NRC Administrative Letter 93 20) The Board members were
James T. Wiggins (Board Chairman), Director, Division of Reactor Safety, Region I (RI),
Chcries W. Hehl, Director, Division of Reactor Projects, Rl, and Bruce A, Boger, Director,
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Reactor Projects 1/11, Office of Nuclear Reactor Regulation. The Board developed this
assessment for the approval of the Region 1 Administrator,
The performance ratings and the functional areas used below are described in NRC MD
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8,6, " Systematic Assessment of Licensee Performance (SALP),"
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11.
PERFORMANCE ANALYSIS - OPERATIONS
Overall performance in the operations area was generally good with improvements noted in
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the control of operational activities and in the performance of licensed operator candidates
during initial examinations. The threshold for problem reporting was progressively being
lowered but operators and managers missed several problem plant conditions during plant
rounds and tours, Also, procedure quality issues and instances of improper use of
procedures cor.tinued to be identified by NRC, in addressing these problems, corrective
actions were weak.
Operations control of plant activities improved as line management implemented lessons
learned from the previous refueling outage and from other past events reflective of a weak
interface between operations and maintenance Operations management and operators
were given more time for oversight of operational activities because production
responsibilities were transferred from the operations department to the work control
department. Shift turnover briefings improved due to more effective participation by crew
members Also, just prior to the start of the last refueling outage, the plant manager
conducted procedural adherence training with all site personnel to reinforce the importance
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of following procedures Effective oversight of vendor reactor fuel handlers led to a well
controlled reactor core offload and reload. Further, an improved control room environment
with less traffic and noise resulted from moving the administrative staff from the control
room to the operations support building. Collectively, these enhancements developed and
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implemented by line management contributed directly, with only few exceptions, to the
enhanced operator performance during the last outage.
Improvements made to the corrective action process resulted in a lower problem reporting
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threshold and a more thorough determination of root causes. Operators identified several
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significant equipment issues at an early stage, but some lesser significant problems were
overlooked. An operator identified a subtle but significant equipment problem involving a
through wallleak in the heat exchanger channel head of the "B" reactor building closed
loop cooling water system resulting in a plant shutdown for repairs. Despite the lower
problem reporting threshold, operators and line managers missed some configuration
control discrepancies and indicator problems in the control room. Also, two longstanding
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operator workaround conditions, that complicated post scram recovery efforts, were not
challenged by the operations staff.
Operators responded well to plant transients with few exceptions noted. An example was
the prompt operator response during a sudden insurge of seaweed on the intake structure
screens that resulted in a safe transition to a lower power level without damage to the sea
water pumps an improved response when compared to e similar event in the last SALP
period. Also, during the last refueling outage, operators responded effectively to two
significant events involving a main transformer f ailure and also a fullloss of offsite power
(Unusual Event). However, an operating crew f ailed to follow the abnormal procedure in
response to feedwater system regulating valve malfunction. Overall, the operational
transient history reflected positively on operator performance.
Operator training was generally effective, improvement was indicated by five of six
operator license candidates passing the NRC license examination. The increased use of
senior operating training personnel to analyze integrated crew responte to transients
contributed to more effective operations department self assessment. However, an
operator knowledge deficiency involving the generator out of phase block circuitry became
evident when several attempts were needed to resynchronize the generator onto the
electrical grid. The plant simulator did not model well the shrink and swell of reactor
vessel water level during power transient potentially impacting training effectiveness.
During the February 1997 scram, operators experienced shrink and swell that eventually
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led to the isolation of the High Pressure Coolant Injection system which complicated
recovciy actions.
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Despite efforts to improve, problems persisted in the area of procedure quality and use.
Procedure quality issues were contributing causes for an engineered safety feature
actuation, the unavailability of the station blackout diesel generator during a loss of offsite
power event, and the inadvertent isolation of the reactor vessel water level detectors.
Also, certain operational procedures were inadequate in that they potentially allowed
conditions outside the design bases such as for maximum and minimum flowrates for
containment cooling during a loss of coolant accident, instances of improper procedure
use occurred. Most notable was the failure of an operating crew to promptly shut down
the reactor on conditions of significant feedwater oscillations.
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The Operations area is rated Category 2.
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111.
PERFORMANCE ANALYSIS - MAINTENANCE
Performanca in the maintenanco area was generally gor,d with some improvements noted
in work control and in increased management presence in the field. Overall, the material
condition of the plant improved and safety related equipment .eliability continued to be
very good. Aggressive actions were usually taken for significant maintenance related
equipment problems. Problems with balance of plant eo@ent resulted in some
challenges to operators during normal operation and pow - :ductioris.
Self assessment results were generally effective in making improvemonts especially in the
area of personnel and management performance involved with the control of work
production for outages and on-line maintenance. The work control group assumed work
production responsibilities from operations allowing operations to maintain a safety focus
especially during the last refueling outage. Improved performance of maintenance and
surveillance activities was achieved, in part, because of an increased management focus
and a maturing work planning process that implemented past lessons learned. Examples of
well planned activities included a major on-line reactor core isolation cooling outage and a
temporary weld repair to a spool piece in a salt service water pipe. Good field work
implementation resulted from effective planning (including mock-up), supervisory oversight,
and a knowledgeable work force. An example of good management oversight of work
activities included the identification of a discrepancy with the dimension of a salt service
water pump shaf t gib key by a new maintenance supervisor. Fewer missed surveillance
tests occurred due to improvements made to the master surveillance test program.
The material condition of the plant has generally improved. Aggressive actions were
usually taken for significant maintenance related equipment problems. For example, a
careful and thorough code repair was made to correct the longstar. ding problem with the
"B" reactor building closed cooling water (RBCCW) heat exchanger channel head. The
corrective maintenance running repair backlog has steadily declined as a result of changes
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made to the work control process and increased management focus, in addition, the
reliabihty of safety related equipment remained very good. However some important
equipment problems did not receive appropriate attention. Balance of plhnt equipment
problems have challenged operators and resulted in some unplanned power reductions and
outages. As an example, feedwater regulating valve preventive maintenance problems
resulted in low power reactor water level oscillations necessitating a manual reactor scram.
Human performance in the maintenance area generally improved, but some problems
persisted. The maintenance staff performed very well during the last outage; workers
were noted to be experienced and stopped work when adverse conditions were identified
to obtain proper corrective actions. Pre-evolutionary briefings were detailed and conveyed
all the salient points of the work to be performed. Communications between the various
departments was generally good; operators and technicians generally remained aware of
plant conditions before, during and after testing. However, procedure quality and use
problems persisted. Several problems were noted with procedure content due to over-
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reliance on vendor manuals and information. The damage to all tour main steam line plugs
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and to one of the RBCCW pump seals resulted from an inadequate pros.,edure and work
planning guidance which generally referenced the vendor manual. Procedure use problems
inciuded an electrician using an incorrect crimping tool during the replacement of a safety-
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related motor actuator and a trip of one of the running residual heat removal pumps during
routine surveillance testing of its associated emergency bus. This later example also
reflected weakness in the interf ace between the maintenance worker and the operating
crew
The maintenance area is rated Category 2.
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IV.
PERFORMANCE ANALYSIS ENGINEERING
Engineering management oversight and involvement in plant activities remained generally
good but some performance problems arose. The site staff planned and scheduled
engineering work such that significant emerging equipment problems were addressed
generally in a timely manner, in addition, management attention resulted in the reduction
of the backlog of vendor manual changes and open problem reports. Some self
assessment activities improved specific aspects of engineering performance. Problems
were noted in the interfaces among the design, installation and the ALARA organizations
which resulted in additional dose being incurred by workers installing the emergency core
cooling system (ECCS) strainer replacement modification.
In general, engineers provided good support to operations and maintenance. Operacility
determinations were usually of good quality. The quality of root cause evaluatiens was
also generally good. However, in some instances, technical support fell short. For
example, the evaluation for digital upgrade modLcations to an instrument bus transformer
was found to lack sufficient scope and depth.
Overall, system engineer performance was good, but some problems arose. Improvement
was realized in the reliability of key systems such as the reactor core isolation cooling
systerr, and the high pressure coolant injection system. Also, the system engineer
provided valuable direction during troubleshooting activities associated with the reactor
protection system (RPS) motor-generator set after a recent RPS trip and half-scram.
However, the operators' response to the February 1997 plant trip was complicated by
i ome longstanding degraded equipment conditions. Actions were added to procedures
rather than solving the problem and eliminating significant operator workarounds. Also,
during the March 1997, transformer failure event, the use of SBO diesel generator was lost
due to insufficient procedural guidance. Additionally, the NRC identified several control
room equipment deficiencies that had not been identified by operators or system engineers,
indicating that there was a weakness in equipment monitoring activities.
Design change and modification work, including temporary modifications, was performed
well. Safety evaluations were generally of adequate scope and of good quality. While
there were interface problems in the design and installation of the ECCS strainer
replacement, the basic design and analysis work associated with that modification was
sound and the vendor controls were generally good. This was significant given the tight
time constraints to design, f abricate and install the strainers.
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The NRC identified several significant problems associated with engineering activities
directed toward maintaining the design and licensing bases of the plant. Some of the
issues found during a self-assessment of the service water system remained open for
several years. A number of those issues were addresse . initially, by the application of
engineering judgement, were not placed in a formal corrective action system and their final
resolution was not achieved as of the Spring of 1997. NRC review of some of the issues
showed that the plant had been operating outside its design bases and that the required
report to NRC had not been made. The untimely resolutions of these issues reflected a
weak implementation of the technical and safety review process. In contrast to the above,
the NRC found that engineering activities related to the core spray system, including a
vertical-slice review, had assured that the system was being maintained per its design.
The Engineering area is rated Category 2.
V.
PERFORMANCE ANALYSIS - PLANT SUPPORT
Performance in the plant support areas was generally good. Radiation exposures at Pilgrim
continued to be high. Some efforts towards permanent shielding and chemical
decontamination have been utilized with only limited effectiveness. ALARA (As low As is
Reasonably Achievable) planning was not effectively implemented during the design phase
of the Emergency Core cooling System (ECCS) strainer modifications resulting in limited
implementation of exposure reduction techniques. Another weakness was identified in the
ALARA area with respect to the accuracy of work hour estimates and tracking.
Radiological housekeeping was reasonably good; however, access to the residual heat
removal and core spray quadrant areas continued to be adversely affected by the
radiological conditions in these areas. Resolution of radiological problems such as for the
condition of the Residual Heat Removal (RHR) quadrant rooms in the Reactor Building has
been slow.
The solid radwaste processing program generally improved as evident by the inctalleHon of
the liquid radwaste filtration precess as an alternative to the conventional diatomaceous
earth filtration system. Licensee audits of the radwaste area were generally good, however
self assessment of the radwaste program was weak. For example, the periodic review of
offsite radwaste process vendors and shipment verification procedures were not
comprehensive in that activity coverage was weak, informal, and lacked independent
review.
Performance of the environmental monitoring and effluent control programs was excellent.
The emergency preparedness program was effectively implemented. The emergency
response plan and implementing procedures were current cnd were effectively
implemented. The emergency facilities were maintained in a state of readiness. Training
and qualifications of emergency response personnel were kept current. Quality assurance
audits were thorough and complete. A notable accomplishment this period was the
smooth and successful transfer of offsite emergency response reception centers.
The security program was generally wellimplemented. The security training program was
a program strength. Several security program upgrades were made demonstrating very
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good management support for this program area. Some performance problems were
attributed to the degraded condition of surveillance video camera equipment, which the
licensee was in the process of addressing.
The fire protection program was effectively implemented and housekeeping was generally
adequate.
The Plant Support area was rated Category 2.-
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ENCLOSURE 2
NRC INSPECTION PLAN
PILGRIM NUCLEAR POWER STATION
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OCTOBER 1997 - OCTOBER 1998
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Procedure 1
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CO 82301
Emergency Preparedness Exercise Evaluation -
11/3/97
Tl 2515/109
Engineering MOV Testing - GL 8910
12/8/97
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CO 37001
Engineering 10 CFR 50,59 Safety Evaluation
1/17/98
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CO 93801
Engineering SSFl Focusing on AE issues
1/17/98
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RI92903
Engineering Followup of AE Inspection
1/17/98
Extemal Occupational Exposure Control & Personal
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CO 83724
3/23/98
Dosimetry
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CO 62706
Maintenance Rule Inspection
4/27/98
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Solid Radwaste Management & Transportation of Rad
CO 86750
6/22/98
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Type Abbreviations:
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CO - Core Inspection Minimum Mandatory NRC Inspection Program (NRC
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Program Inspections, excepting Resident Core Activities)
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Regional Initiative
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Temporary instruction
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