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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N8911999-10-15015 October 1999 Forwards Rept of Changes,Tests & Experiments at Pilgrim Nuclear Power Station for Period of 970422-990621,IAW 10CFR50.59(b).List of Changes Effecting Fsar,Encl ML20217D3951999-10-13013 October 1999 Forwards Request for Addl Info Re Util 990806 Submittal on USI A-46, Implementation Methodology Used at Pilgrim Nuclear Power Station, Per GL 87-02 ML20217E1581999-10-0808 October 1999 Forwards Insp Rept 50-293/99-05 on 990726-0905.Three Violations Noted & Being Treated as Ncvs.Violations Include Failure to Assure That Design Bases Correctly Translated Into Specifications ML20217C3151999-10-0606 October 1999 Forwards Scenario Package for Pilgrim Nuclear Power Station Nrc/Fema Evaluated Exercise Scheduled for 991207.Without Encl ML20217D5591999-10-0505 October 1999 Documents Pilgrim Nuclear Power Station Five Yr Survey of Main Breakwater.Survey Has Determined That Pilgrim Main Breakwater Is Intact & Remains Adequately Constructed to Perform Designed Safety Function ML20217C8051999-10-0505 October 1999 Forwards Proprietary Results of Audiologic Evaluations for Jp Giar,License SOP-10061-3.Attachment Clearly Shows Requirements for Operator Hearing Ability Are Met. Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML20212J8301999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Integrate Performance Info & to Plan Insp Activities at Facility Over Next Six Months ML20216J9961999-09-29029 September 1999 Forwards Resume of Person Identified as Acting RPM in Licensee to NRC Re Notification That Person Named in License Condition 11 of 20-07626-02,is No Longer Employed at Pilgrim Station.Resume Withheld,Per 10CFR2.790 ML20212F7871999-09-24024 September 1999 Advises That Util 990121 Application for Amend Being Treated as Withdrawn.Proposed Changes Would Have Modified Facility UFSAR Pertaining to Values for post-accident Containment Pressure Credited in Pilgrim Net Positive Head Analyses ML20212H1381999-09-23023 September 1999 Submits Info in Support of Request Filed on 990730 to Grant one-time Exemption from 10CFR50,App E,Authorizing Biennial Full Participation Emergency Preparedness Exercise to Be Conducted in 2002 Instead of 2001 ML20212H1441999-09-23023 September 1999 Withdraws 990121 Request for License Change Re Emergency Core Cooling Sys Net Positive Suction Head,Due to Incorrect Datum Preparation ML20212C2861999-09-16016 September 1999 Forwards SER Accepting Licensee 981123 Request for Relief RR-E1,RR-E5,RR-E6 Pursuant to 10CFR50.55a(a)(3)(i) & Request for Relief RR-E2,RR-E3 & RR-E4 Pursuant to 10CFR50.55a(a)(3)(ii) ML20216F3451999-09-16016 September 1999 Forwards Summary Rept Providing Results of ISI Conducted at PNPS on-line & Refueling Outage (RFO 12) ML20216E7111999-09-0909 September 1999 Forwards License Renewal Application Including Form NRC-398 & Form NRC-396 for Jp Giar,License SOP-10061-3.Without Encls ML20216E5891999-09-0707 September 1999 Forwards Copy of Pilgrim Station Organization Structure. Encl Refelcts Changes in Upper Mgt Level Structure.Changes Were Effective 990901 ML20211M4501999-09-0303 September 1999 Informs That Pilgrim Nuclear Power Station Plans to Conduct Full Participation Emergency Preparedness Exercise with Commonwealth of Ma on 991207,IAW 10CFR50,App E,Section IV.F.2 ML20211M9161999-08-31031 August 1999 Submits Review & Correction of Info in Reactor Vessel Integrity Database (Rvid),Version 2,re Pilgrim Station ML20211J8391999-08-30030 August 1999 Forwards Rev 1 to Provisional Decommissioning Trust Agreement for Plant,Changing Portions of Agreement to Permit Up to Two Distributions & Clarify Formula for Distribution ML20211H5701999-08-27027 August 1999 Forwards Insp Rept 50-293/99-04 on 990610-0725.Two Violations Identified Being Treated as non-cited Violations ML20211C3381999-08-19019 August 1999 Provides semi-annual LTP Update,Including Schedule, Commitment Descriptions,Progress Since Last Update & Summary of Changes.Rev Bars Indicate Changes in Status Since Last Submittal ML20210U7521999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opossing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U6691999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opposing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U5761999-08-18018 August 1999 Responds to Opposing Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts. Informs That for Sale,Nrc Responsible for Only Ensuring That Entergy Technically & Financially Qualified to Operate NPP ML20210U5151999-08-17017 August 1999 Forwards Notice of Withdrawal of Application for Approval of Indirect Transfer of FOL for Pilgrim in Response to .Approval No Longer Needed Since Beco Sold Interest in Pilgrim to EOI on 990713 ML20211B3841999-08-16016 August 1999 Forwards Response to NRC Second RAI Re Pressure Locking & Thermal Binding of SR power-operated Gate Valves ML20210U4831999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data Sheets for Period of 990101-0630,per 10CFR26.71(d) ML20210S0891999-08-0909 August 1999 Forwards Amend 11 to Indemnity Agreement B-48 Signed by Boston Edison Co & Entergy Nuclear Generation Co ML20210R6251999-08-0606 August 1999 Provides Supplementary Info on USI A-46 Implementation Methodology at Pilgrim Station,To Enable NRC to Perform Evaluation & Issuance of Plant Specific SER for Plant ML20210M9411999-08-0202 August 1999 Requests That NRC Treat Pending Actions Requested by Beco Prior to 990713,as Requests Made by Entergy.Ltr Requests That Minor Administrative Changes to License Amend 182 & Associated Ser, ,reflect 990713 Transfer ML20210H8761999-07-30030 July 1999 Requests That NRC Grant Exemption from Requirements of 10CFR50,App E,Section IV F,Which Would Authorize Rescheduling of 2001 Biennial Full Participation Emergency Preparedness Exercise for Pilgrim Station to 2002 ML20210H8661999-07-29029 July 1999 Provides Revised Response to GL 96-06 & Addresses NRC Insp Concern for Containment Penetration X-12.Info Submitted to Facilitate NRC Review & Closeout of Subject GL for Plant ML20216E2321999-07-26026 July 1999 Discusses GL 92-01,rev 1,suppl 1, Rv Structural Integrity. NRC Revised Info in Rvid & Releasing as Rvid Version 2 ML20216D4131999-07-22022 July 1999 Informs That J Conlon,License OP-11040-1,terminated Employment with Beco on 990703,per 10CFR50.74.Individual Will Not Participate in Util Licensed Operator Requalification Training Program ML20210E2231999-07-20020 July 1999 Discusses Arrangements Made by Dennis & M Santiago During 990615 Telephone Conversation for NRC to Inspect Licensed Operator Requalification Program at Pilgrim During Wk of 991004 ML20210C4151999-07-19019 July 1999 Informs That Util Intends to Submit Approx Eight Licensing Actions in FY00 & Eight in FY01,in Response to Administrative Ltr 99-02.Actions Are Not Expected to Generate Complex Reviews ML20210A9441999-07-14014 July 1999 Responds to Re Changes to Pilgrim Nuclear Power Station Physical Security Plan Identified as Issue 2,rev 14, Addendum 1,respectively.No NRC Approval Is Required IAW 10CFR54(p) ML20210F3711999-07-14014 July 1999 Informs NRC That Effective 990713,listed Pilgrim Station Security Plans Have Been Transferred from Boston Edison to Entergy & Are Still in Effect ML20209G2251999-07-0909 July 1999 Forwards Insp Rept 50-293/99-03 on 990419-0609.Five Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations,Consistent with App C. Several Individual Tagging Errors Occurred ML20209C4661999-07-0707 July 1999 Forwards SE Accepting Addendum on Proposed Change in Corporate Ownership Structure Involving Entergy Nuclear Generation Co ML20209C3851999-07-0606 July 1999 Forwards Redacted Draft of Decommissioning Trust Agreement Re Transfer of PNPS & NRC Operating License & Matls License from Boston Edison Co to Entergy Nuclear Generating Co ML20209C7761999-07-0606 July 1999 Submits Annual Summary Rept of Changes Made to QAP Description as Described in QA Manual,Vol Ii.Rept Covers Period of Jul 1998 Through June 1999.No Changes Made During Period ML20196J7251999-07-0101 July 1999 Informs of Completion of Licensing Action for GL 96-01, Testing of Safety-Related Logic Circuits, for Pilgrim Nuclear Power Station ML20209B9411999-06-30030 June 1999 Discusses Deferral of IGSCC Welds to RFO 13.Deferral of Welds to Refueling Outage 13 Does Not Impact Acceptable Level of Quality & Safety Per 10CFR50.55(a)(3)(i) Since Plant in Compliance W/Exam Percentage Requirements ML20209B9431999-06-30030 June 1999 Provides Formal Notification That Closing Date for Sale & Transfer of Pilgrim Station Scheduled to Occur on 990713. a Wang Will Be Verbally Notified of Time of Sale Closing ML20196H2381999-06-29029 June 1999 Forwards SER Denying Licensee 980820 Request for Alternative Under PRR-13,rev 2 for Use of Code Case N-522 During Pressure Testing of Containment Penetration Piping ML20209B9791999-06-29029 June 1999 Forwards Rev 13A to Pilgrims COLR for Cycle 13,IAW TS 5.6.5 Requirements.Rev 13A Provides cycle-specific Limits for Operating Pilgrim During Remainder of Cycle 13 ML20209A8761999-06-28028 June 1999 Forwards SER Authorizing Licensee 990317 Relief Request to Use ASME Code Case N-573 as Alternative to ASME Code Section XI Article IWA-4000 for Remainder of 10-year Interval Pursuant to 10CFR50.55a(a)(3)(i) ML20209A8701999-06-25025 June 1999 Responds to NRC Request for Info Re Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure for Plant,Reporting Status of Facility Y2K Readiness Encl ML20210U5901999-06-25025 June 1999 Opposes Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts.Expresses Skepticism Re Claim by Companies That Consumers Will Benefit from Proposed Consolidation & four-year Freeze in Base Rates ML20209C3431999-06-22022 June 1999 Forwards Addendum 1,Rev 14 to Pilgrim Station Security Plan,Iaw 10CFR50.54(p)(2).Changes Proposed Have Been Implemented & Constitute Increase in Plant Defense Plan Commitments.Encl Withheld,Per 10CFR73.21 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217N8911999-10-15015 October 1999 Forwards Rept of Changes,Tests & Experiments at Pilgrim Nuclear Power Station for Period of 970422-990621,IAW 10CFR50.59(b).List of Changes Effecting Fsar,Encl ML20217C3151999-10-0606 October 1999 Forwards Scenario Package for Pilgrim Nuclear Power Station Nrc/Fema Evaluated Exercise Scheduled for 991207.Without Encl ML20217C8051999-10-0505 October 1999 Forwards Proprietary Results of Audiologic Evaluations for Jp Giar,License SOP-10061-3.Attachment Clearly Shows Requirements for Operator Hearing Ability Are Met. Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML20217D5591999-10-0505 October 1999 Documents Pilgrim Nuclear Power Station Five Yr Survey of Main Breakwater.Survey Has Determined That Pilgrim Main Breakwater Is Intact & Remains Adequately Constructed to Perform Designed Safety Function ML20216J9961999-09-29029 September 1999 Forwards Resume of Person Identified as Acting RPM in Licensee to NRC Re Notification That Person Named in License Condition 11 of 20-07626-02,is No Longer Employed at Pilgrim Station.Resume Withheld,Per 10CFR2.790 ML20212H1441999-09-23023 September 1999 Withdraws 990121 Request for License Change Re Emergency Core Cooling Sys Net Positive Suction Head,Due to Incorrect Datum Preparation ML20212H1381999-09-23023 September 1999 Submits Info in Support of Request Filed on 990730 to Grant one-time Exemption from 10CFR50,App E,Authorizing Biennial Full Participation Emergency Preparedness Exercise to Be Conducted in 2002 Instead of 2001 ML20216F3451999-09-16016 September 1999 Forwards Summary Rept Providing Results of ISI Conducted at PNPS on-line & Refueling Outage (RFO 12) ML20216E7111999-09-0909 September 1999 Forwards License Renewal Application Including Form NRC-398 & Form NRC-396 for Jp Giar,License SOP-10061-3.Without Encls ML20216E5891999-09-0707 September 1999 Forwards Copy of Pilgrim Station Organization Structure. Encl Refelcts Changes in Upper Mgt Level Structure.Changes Were Effective 990901 ML20211M4501999-09-0303 September 1999 Informs That Pilgrim Nuclear Power Station Plans to Conduct Full Participation Emergency Preparedness Exercise with Commonwealth of Ma on 991207,IAW 10CFR50,App E,Section IV.F.2 ML20211M9161999-08-31031 August 1999 Submits Review & Correction of Info in Reactor Vessel Integrity Database (Rvid),Version 2,re Pilgrim Station ML20211J8391999-08-30030 August 1999 Forwards Rev 1 to Provisional Decommissioning Trust Agreement for Plant,Changing Portions of Agreement to Permit Up to Two Distributions & Clarify Formula for Distribution ML20211C3381999-08-19019 August 1999 Provides semi-annual LTP Update,Including Schedule, Commitment Descriptions,Progress Since Last Update & Summary of Changes.Rev Bars Indicate Changes in Status Since Last Submittal ML20211B3841999-08-16016 August 1999 Forwards Response to NRC Second RAI Re Pressure Locking & Thermal Binding of SR power-operated Gate Valves ML20210U4831999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data Sheets for Period of 990101-0630,per 10CFR26.71(d) ML20210S0891999-08-0909 August 1999 Forwards Amend 11 to Indemnity Agreement B-48 Signed by Boston Edison Co & Entergy Nuclear Generation Co ML20210R6251999-08-0606 August 1999 Provides Supplementary Info on USI A-46 Implementation Methodology at Pilgrim Station,To Enable NRC to Perform Evaluation & Issuance of Plant Specific SER for Plant ML20210M9411999-08-0202 August 1999 Requests That NRC Treat Pending Actions Requested by Beco Prior to 990713,as Requests Made by Entergy.Ltr Requests That Minor Administrative Changes to License Amend 182 & Associated Ser, ,reflect 990713 Transfer ML20210H8761999-07-30030 July 1999 Requests That NRC Grant Exemption from Requirements of 10CFR50,App E,Section IV F,Which Would Authorize Rescheduling of 2001 Biennial Full Participation Emergency Preparedness Exercise for Pilgrim Station to 2002 ML20210H8661999-07-29029 July 1999 Provides Revised Response to GL 96-06 & Addresses NRC Insp Concern for Containment Penetration X-12.Info Submitted to Facilitate NRC Review & Closeout of Subject GL for Plant ML20216D4131999-07-22022 July 1999 Informs That J Conlon,License OP-11040-1,terminated Employment with Beco on 990703,per 10CFR50.74.Individual Will Not Participate in Util Licensed Operator Requalification Training Program ML20210C4151999-07-19019 July 1999 Informs That Util Intends to Submit Approx Eight Licensing Actions in FY00 & Eight in FY01,in Response to Administrative Ltr 99-02.Actions Are Not Expected to Generate Complex Reviews ML20210F3711999-07-14014 July 1999 Informs NRC That Effective 990713,listed Pilgrim Station Security Plans Have Been Transferred from Boston Edison to Entergy & Are Still in Effect ML20209C7761999-07-0606 July 1999 Submits Annual Summary Rept of Changes Made to QAP Description as Described in QA Manual,Vol Ii.Rept Covers Period of Jul 1998 Through June 1999.No Changes Made During Period ML20209C3851999-07-0606 July 1999 Forwards Redacted Draft of Decommissioning Trust Agreement Re Transfer of PNPS & NRC Operating License & Matls License from Boston Edison Co to Entergy Nuclear Generating Co ML20209B9431999-06-30030 June 1999 Provides Formal Notification That Closing Date for Sale & Transfer of Pilgrim Station Scheduled to Occur on 990713. a Wang Will Be Verbally Notified of Time of Sale Closing ML20209B9411999-06-30030 June 1999 Discusses Deferral of IGSCC Welds to RFO 13.Deferral of Welds to Refueling Outage 13 Does Not Impact Acceptable Level of Quality & Safety Per 10CFR50.55(a)(3)(i) Since Plant in Compliance W/Exam Percentage Requirements ML20209B9791999-06-29029 June 1999 Forwards Rev 13A to Pilgrims COLR for Cycle 13,IAW TS 5.6.5 Requirements.Rev 13A Provides cycle-specific Limits for Operating Pilgrim During Remainder of Cycle 13 ML20209A8701999-06-25025 June 1999 Responds to NRC Request for Info Re Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure for Plant,Reporting Status of Facility Y2K Readiness Encl ML20210U5901999-06-25025 June 1999 Opposes Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts.Expresses Skepticism Re Claim by Companies That Consumers Will Benefit from Proposed Consolidation & four-year Freeze in Base Rates ML20209C3431999-06-22022 June 1999 Forwards Addendum 1,Rev 14 to Pilgrim Station Security Plan,Iaw 10CFR50.54(p)(2).Changes Proposed Have Been Implemented & Constitute Increase in Plant Defense Plan Commitments.Encl Withheld,Per 10CFR73.21 ML20195G3721999-06-0707 June 1999 Informs That Proposed Indicators Failed QA Assessments for Digital Verification,Validation & Control of Software. Proposed Mod Can Be Completed on-line ML20195B5021999-05-27027 May 1999 Provides Suppl Info to 990203 Request of Beco That NRC Consent to Indirect Transfer of Control of Util Interest in License DPR-35.Request Described Proposed Merger of Bec Energy with Commonwealth Energy Sys ML20207D4681999-05-24024 May 1999 Provides Addl Info to That Included in Beco Ltr 98-123 Dtd 981001,addressing NRC Concerns Described in GL 96-06, Concerning Waterhammer in Reactor Bldg Closed Cooling Water Sys ML20195B9051999-05-20020 May 1999 Forwards Completed Renewal Applications for Listed Operators.Without Encls ML20206J4901999-05-0606 May 1999 Forwards Completed License Renewal Application,Including Forms NRC-398 & 396 for Sc Power,License OP-6328-3 ML20206P0711999-05-0606 May 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee, for K Walz,License SOP-10886-1.Encl Withheld IAW 10CFR2.790(a)(6) ML20206D3621999-04-27027 April 1999 Informs NRC That Final Five Sys self-assessments Required to Fulfill Commitment Made in 980828 Response to Insp Rept 50-293/98-04 Were Completed on 990422.Completion Was Delayed by High Priority Refueling Outage 12 Preparatory Work ML20205R9871999-04-21021 April 1999 Forwards Affidavit of JW Yelverton of Entergy Nuclear Generation Co Supporting Request for Withholding Info from Rept on Audit of Financial Statements for Year Ended 971231. Pages 16 & 18 of Subj Rept Also Encl ML20207B0891999-04-20020 April 1999 Forwards e-mail Message from Constituent,J Riell Re Y2K Compliance of Nuclear Power Plant in Plymouth,Massachusetts. Copy of Article Entitled Nuke Plants May Not Be Y2K Ready Also Encl ML20206A2741999-04-16016 April 1999 Dockets Encl Ltr Which Was Sent to AL Vietti-Cook Re Condition of Approval of Transfer of License & License Condition for DPR-35.Encl Resolves Issues Between Attorney General of Commonwealth of Massachusetts & Applicants ML20205P9131999-04-16016 April 1999 Submits Applicant Consent to Listed Condition of Approval of Transfer of License & License Condition for License DPR-35 & Affirmatively Request That NRC Adopt Listed Language in Order ML20205P9271999-04-16016 April 1999 Withdraws Motion for Leave to Intervene & Petition for Summary Or,In Alternative,For Hearing.Requests That NRC Adopt Condition of Approval of Transfer of License & License Condition Agreed to Beco & Entergy Nuclear Generation Co ML20205Q9231999-04-15015 April 1999 Forwards Proprietary & non-proprietary Addl Info in Support of Request to Transfer of Plant FOL & Matls License to Entergy Nuclear Generation Co.Proprietary Info Withheld,Per 10CFR2.790 ML20205P9631999-04-15015 April 1999 Provides Attachments a & B in Support of Request for Transfer of Plant Operating License & NRC Matl License from Beco to Entergy Nuclear Generation Co as Submitted in Ref 1. Info Provided in Response to Request at 990413 Meeting ML20205H9281999-04-0707 April 1999 Requests Withdrawal of Uwua Locals 369 & 387 Unions Joint Intervention in Listed Matter ML20205F3731999-04-0202 April 1999 Submits Addl Info Provided in Support of Request for Transfer of Pilgrim Nuclear Power Station Operating License & Matls License.State of Ma Order Authorizing Divestiture & Copy of Financial Arrangement Encl ML20204H3771999-03-26026 March 1999 Informs That Local 387,Utility Workers Union of America,AFL- Cio Voted to Approve New Contract with Entergy Nuclear Generation Co & Voted to Accept Boston Edison Divestiture Agreement ML20205D4231999-03-24024 March 1999 Forwards Decommissioning Funding Rept for Pilgrim Nuclear Power Station,In Accordance with 10CFR50.75(f)(1) 1999-09-09
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Boefort Ecusers ;
4 PHgrim Nuclear Power Station
LJ. OlMer Vice President Wolear end Staten t'4 rector December 17,1997 BECo Ltr. 2.97.132 l U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Docket No. 50 293 License No. DPR-35 i Completion of Roolv to Notice of V19]ation 97-80 01 Boston Edison Company (BEGc) provided an initial response to Notice of Violation 97-80-01 by letter dated October 17,1997, (BECo 2.97,104). That response provided the reasons for the specific procedural violations cited by the NRC and the corrective actions taken and results achieved. A sixty day extension was requested in order to conduct an in-depth root cause of the overallissue of procedural compliance at Pilgrim Station and thereby determine meaningful and effective corrective actions to preclude recurrence. A multi-discipline root cause team was formed to analyze the procedural compliance data contained in the Pilgrim Station corrective action data base, assess root cause, correlate the relationship to the previous and current procedural compliance corrective action activities, and recommend comprehensive solutions. A discussion of the team's findings and Pilgrim's corrective actions to preclude recurrence are enclosed.
This letter describes the following corrective actions to preclude recurrence:
- A 1998 organization goal for addressing procedure adherence will be developed and Individual department tasks for meeting the goal will also be developed. ,
- Establish a cross functional team for improving procedure structure and content, o Managers will be updated on the overall broad procedural compliance issues and with issues that may be unlaue to their area of oversight.
i y q, t ;G ,fb,b!N h 9712220397 9 7 PDR ADOCK 0 0 P
Details Qf the activites ti undertaken to implemen; these corrective actions are described in the enclosure, Should you have any questions or require further clarification, please do not hesitate to contact me.
. 1 L J. Olivier Enclosure Completion of Reply to Notice of Violation 97 80-01 cc w/ encl.
- Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Sen;or Resident inspector Pilgrim Nuclear Power Station Mr. Alan B. Wang Project Manager Project Directorate 13 Office of Nuclear Reactor Regulation Mall Stop
- OWF 14B2 1 White Flint North 11555 Rockville Pike Rockville, MD 20852
o
,. .- Enclosult Completion of Reply to Notice of Violation 97 80-01 On September 17,1997, the NRC lssued the 40500 team inspection results of the Pilgrim Station corrective action processes (NRC IR 97 80). The NRC identified three specific itsues relating to procedural compliance at Pilgrim Station that became NRC Notice of Violation (NOV) 97 80-01. Boston Edison Cornpany (BECo) provided an initial response by letter dated October 17,1997. In this response, the reasons for each of the Instances of procedural noncompliance were addressed along with the specific corrective actions taken or planned for each Instance. A sixty day extension to determine corrective actions to precit,de recurrence was requested and granted. The extension was needed to conduct an in depth root cause of the broader issue of procedural usage and why noncompliance with procedures remains an issue at Pligrim Station.
A multi-discipline root cause team was formed to analyze the procedural compliance data contained in the Pilgrim Station corrective action data base, assess root cause, correlate the relationship to the previous and current procedural compliance corrective action activities, and recommend comprehensive solutions. The root cause analysis findings and corrective actions to preclude recurrence are presented below.
D.ndinas The corrective action program (CAP) Information data bsse was reviewed to determine the extent of organizational procedure non-adherence. These data show procedure non-adherence exists in every work unit, at all job levels in the organization.
Admin;strative tasks are cited three times more frequently than technical tasks.
A defense of quality, barrier matrix was developed to determine the barriers that are in place to ensure procedure compliance. The potential weaknesses of the barriers and the probability of failure of any of the barriers were assessed and reconciled to the data base. It was concluded the barriers that are most likely to be weak or potentially fall are management expectations and standards, supeNisory oversight, procedure complexity and construction, and time and resources to implement jobs correctly.
A survey of the organization corroborated the barrier analysis conclusions. This survey probed for agreeme,t or disagreement on each of the proposed barriers and solicited free form feedback. As a feedback question, the survey solicited an opinion on why procedure non compliance events occur and what management can do to correct the problem.
1
Root Causo Two prkr ;y causes have been identified for procedure non adherences at Pilgrim.
- The structure and content of procedures are complex and inhibit performing tasks in a timely and complete manner. Problem resolutions via procedural additions and/or repairs over the years have contributed to many of the cumbersome requirements.
- Manager and supervisor oversight efforts to resolve procedure adherence issues have been generally ineffective. Although action plans have been formulated to resolve the problem, they were not offective nor validated to ensure the 'ictions were solving the problem. Also, the emphasis on fotbwing procedures is not consistently carried through using coaching on implementation of esr.igned tasks nor is there sufficient accountability for procedure non-compliance. This prcvides an attitude of acceptance toward p ocedure non-compliance.
Several ancillary and outributing causes were also identified. Thi e ranged from the hierarchy of the p;ocedure system (Policies, Nuclear Organization Procedures (NOP8),
Proceduret, and Work Instructions) to training on updates and to perceived time pressure. While these concerns are related to the problem, they are of a contributing nature, generally limited in scope, and not the root of the problem. However, while the effort to correct the root causes is the major focus of the corrective actions to preclude recJrrente, elements of the contributing causes are included as part of the overall corrective action plan required to preclude recurrence. The contributing causes are:
. The content of procedures for new and revised versions is sometimes ineffectively communicated to the users, e A time / pressure perception exists in some disciplines when performing tasks.
. End user input is not universally used in procedure development and revision.
QQrrective Actions to Preclude Recurrence (CATPR)
The procedure non-adherence problem is the result of two primary root causes, a complex and confusing procedure structure, and ineffective oversight and corrective action validation at the manager and supervisory level. The corrective actions to preclude recurrence, therefore, are structured to address these causes and build on past corrective actions already taken or that are stillin progress.
2
CATPR 1 A 1998 organization goal will be established for improvement in procedure adherence.
The goal will be developed and instituted by February 1,1998.
The following tasks will be required for each department as part of this goal implementation:
e include procedure adherence as a required focus for the corrective action program (CAP) quarterly self assessment program. A report of department proceduro compliance and improvements experienced during the quarter will be required. The reports shall provide details of coaching and accountability actions. The reports will continue until satisfactory performance thresholds are achieved.
. Establish focus themes for procedure adherence and improvement meetings to be held on a bi monthly frequency. These meetings will follow the format similar to thad department safety meetings with procedural issues selected for discussion as caso studios based on department-specific issues.
- Department performance matrices will be developed and used in evaluating long term progress or possible recurrence of procedure non-compliance problems. The matrices will also be used by the managers to apply accountability and ownership.
CATPR 2 Some improvements were made from the previous effort to integrate the high level policies and nuclear organization procedures (NOPs). This work needs to continue.
Therefore, a cross functional and multi-disciplined team will be established to continue the effort to improve procedure structure and content. The team shall specify what content is required in procedures and establish a definition of procedure compliance.
Integral to this effort will be the task to work with department managers to cancel, combine, consolidate and re write procedures. The extent of input from the end users for the revised procedures will be determined by the respective department manager.
Team selection will be from all groups and all levels.
The team will ta'<e importance of the procedure relative to safety, reliable plant operatbn, and the incidences of procedural non-compliances into account when establishing t'io priority of procedures to be worked through this effdrt.
This effort will complete by June 30,1998, 3
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CATPR 3 Because of the varying nature of depaitment roles and responsibilities, the type of procedure non adherence differs for each department. Therefore, in addition to the broader organizational corrective actions to be taken, department-specific corrective actions will need to be determined and implemented at the department level. Therefore, the root cause team leader will explain to each group and department manager, the CAP data base trends, the survey results, and the results of the root cause analysis.
This will familiarize the managers with the overall broad procedural compliance issues and with issues that may be unique to their particular area of oversight. This activity will be completed by March 10,1998.
Ritgynlon of Pait Corrective Actions Although previous corrective actions have not resolved the problem of procedure compliance, these past activities were correctly focused albeit not in sufficient detail.
Our evaluation of these activities concluded most of the actions have been effective in resolving various aspects of the problem but suffered from a lack of cohesive programmatic assessment for determining how appropriate and effective the activities were for problem resolution. Thus, the activities were not necessarily ensuring resolution of the problem in total.
The following is a summary of some of the past and current corrective actions taken.
. Management expectations and personal accountability were discussed in small group meetings (in January and again in September 1997) with all personnel, e Procedural improvements were made on known problem procedures.
- Management oversight in the field was increased.
. An error rate performance indicator was developed.
- QA oversight was increased.
. An error matrix was developed and is maintained by the maintenance department.
. A month!y senior managers audit program was established.
. Root cause assessment improvements were made.
. Performance monitoring and trending improvements were made, e Failure Prevention Institute (FPI) training was provided for conducting more comprehensive root cause assessments, e The worker level self assessment process was strengthened with increased management participation and oversight.
- An Independent Oversight Team (IOT) was formed.
- Monthly human performance reports were developed.
- A culture index was conducted.
. The management oversight program was focused on conducting observations of performance related activities.
. Enhanced problem report cc ding was established, e A real time behavior based human error performance monitoring program was developed, e A procedure change process redesign effort was established.
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- The Mission Organization and Policies (MOPS), Nuclear Organization Procedures !
- (NOPs), and Administrative procedures were reviewed, revised and consolidated. .
e The OA deficiency report (DR) process was consolidated into the problem report (PR) process.
- The modification process was redesigned. (Completiori of the procedure revisions ;
and personnel training is expected to be ccmpleted on or before December 3., !
1997.)
- Root cause analysis and human error prevention training were expanded.
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- A procedure change team has re written the procedure change process. The revised process will provide for a broader class of field changes that allows work to continue without waiting for the full procedure change and issue process to be t completed. ;
I Please note, however, current rearictive language in the Administrative Section of the PNPS Technical Specifications needs to be revised to allow this field change procedure revision capability to take place. The needed proposed Technical Specification changes we;e submitted for NRC review and approval on September 19,1997 (BECo letter 2.97.096). Based on NRC feedback, this change is axpected to be approved near the end of the first quarter 1998.
The procedure change team reviewed the option of breaking out the change portion of the process redesign and Issuing other portions; however, the team feels it is best implemented in total. Therefore, this process revision has been placed on hold until approval of the Technical Specification change request.
i Summary We are committed to the corrective action process enhancements introduced at Pilgrim in the 1996 timefcame. The problem reporting thresholds have been sufficiently lowered, and the organization is becoming more comfortable in its use for recognizing and resolving problems.
However, we recognize that more attention is needed in the oversight of emerging problem trends highlighted by the corrective action program. In particular, the effectiveness of corrective actions taken or being taken requires continuous evaluation to ensure the problem is being resolved, in the case of procedural adherence, although myriad action plans to resolve the problem were developed, each met with limited success. The activities were managed at the task level by different individuals but were not being measured in a total programmatic sense for effectiveness at resolving the problem of procedural adherence across the station. Therefore, the corrective actions to preclude recurrence are assigned with actions at both the Vice President -
Nuclear / Station Director level and department manager / supervisor level. The Vice President Nuclear / Station Director will keep the issue highly visible, while the department managers / supervisors resolve the problems at the department level.
Monitoring of the problem will continue at all levels of management until evidence shows the problem to be resolved.
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