ML20206B770

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Recommends Util Provide Listed Addl Info Re 871015 Power Ascension Program
ML20206B770
Person / Time
Site: Pilgrim
Issue date: 12/07/1987
From: Marilyn Evans
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Blough A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20206B722 List:
References
FOIA-88-198 NUDOCS 8811160014
Download: ML20206B770 (21)
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December 7, 1987 MEMORANDUM FOR: A. R. Blough, Chief ,

Reactor Projects Section lA, PB1, ORP THRU: 0. J. Lange, Chief Boiling Water Reactor Section Operations Branch, ORS FROM: M. G. Evans, Operations Engineer -

BWR Section, Operations Branch, DRS

Subject:

PILGRIM NUCLEAR F0WER STATION POWER ASCENSION PROGRAM, DATED 10/15/87 Boiling Water Reactor Section has reviewed the subject document. Based upon this review, we recommend requesting the licensee to supply additional information regarding:

  • administrative controls for conduct of testing and review of test results. These include controls of the performance of testing; methods for recording, evaluating, reviewing and approving test data and results; and methods for identifying and correcting deficiencies noted in systems and procedures.
  • how the licensee plans to demonstrate that major plant transients, such as trips from high power and flow, will not induce MSIV closures, since the exact cause for previous spurious MSIV closures has not been fully determined.
  • how the licensee plans to demonstrate that the plant response to MSIV closure transients is still in accordance with design since the plant has experienced numerous previous MSIV closures. This should address the licensee procedures and personnel response to safely accommodate such transients.
  • in light of numerous LOOP events, how the licensee plans to demonstrate that the dynamic response of the plant to a LOOP event at power is in accordance with design. Additionally, whether licensee procedures and personnel response are appropriate to safely accommodate this transient.

. the addition of Rosemont 1153 transmitters during RF0 #7, Specific-ally, how the licensee plans to demonstrate the extent to which the transmitters are sensitive to pressure oscillations during major transients such that "ringing" of the output occurs which may result in unneces:,ary . challenges to safety systems. This has recen+1y occurred at other BWR's.

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memorandum for A. R. Blough 2 BWRS recommends conduct of a full MSIV closure test (75-100% power, planned or unplanned), a turbine trip test (75-100% power, planned or unplanned) and a LOOP tist (-30% power, planned) to demonstrate satisf actory dynamic response of the plant. ,

. If you have any questions or comments regarding the above recommendations

please contact me at extension 5184.

Ne , h4WO ,

M. G. Evans Operations Engineer BWR Section, Operations Branch Division of Reactor Safety cc:

R. Gallo, DRS

0. Lange, ORS
0. Florek, DRS M. Evans, DRS J. Wiggins, ORP i

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, ATTACHMENT 2 INSTRUCTIONS TO REVIEWERS OF THE PILGRIM RESTART ptAN I. Review Instructions The purposes of NRC review of the plan are (1) to assess its adequacy to correct identified concerns, and (2) to assist in planning for NRC inspections.

A. Review your assigned portion of tne plan and cetermine its aceouacy to address the applicable portions of the NRC Restart Panel Concerns List (Enclosure 1). Document any concerns that do not appear to be adequately addressed -- include your justification. Identify items that are not sufficiently detailed or where more information is needed -- write down as a request for additional information (See Enclosure 2).

B. List those items for which a verification inspection is recommended.

Discuss with your management whether the items shouid be verified by a specialist inspection from your division or should be forwarded to the Restart Panel for inclusion into the Readiness Team Inspection Plan.

C. Af ter reviewing completely your assigned section of the Plen, review the following lists:

Factors inhibiting progress, as defined by 1986 Diagnostic Inspection (See Enclosure 3).

Items specified by the Regional Administrator as general restart prerequisites (See Enclosure 4).

If af ter the above reviews, you have broad concerns regarding the adequacy of the Plan, provide those to your Restart Panel representa-tive to discuss with the Panel.

D. While reviewing the Plan, complete the Restart Plan review matrix for your assigned section. (NOTE: This m'trix will be provided at a later date.)

E. Oraft an input tc the Readiness Report to briefly describe your review and to describt the basis for conclusions regarding acceptability of those portions of the Plan (SER Type Format - See Enclosure 5).

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Attachment 2 2

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II. Schedule:

-- ' Complete individual reviews and forward RAls to Project Section Chief January S  ;

Complete supervisory and management reviews and forward written results to Restart Panel January 18

-- Obtain licensee response to RAI February 1 ,

, L Review additional informat'en and finalize report February 15 l

  • nclosures:
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ENCLOSURE 1 TO ATTACHMENT _2 -

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1. OPERATIONS
a. Problem Overview The lack of licensed operators and an effective support staff has strained the Operations Department. A high operator attritica rate contributed to the problem. Communications between Operatiers per-sonnel and other groups has been poor,
b. Restart Question .

Have the Operations staffing, technical support and communication problems been resolved?

, c. Restart Assessment issues ,

1. Has an adequate staffing plan been developed for licensed per-sonnel? Have the causes for the high licensed operator attri-tion rate been resolved?
2. Does the Operations Department have a dedicated technical sup-port (systems specialists) group? Has this group proven its effectiveness in addressing operations concerns and upgrades?
3. Do operations personnel effectively interact with o'ther groups, particularly maintenance and health physics?
4. Are the training programs for licensed and non-licensed person-nel adequate? Was adequate +. raining provided on the modifica-tions completed during this outage?
5. Will the licensed operator exam schedules /results support BEco's manning goals.
6. Are the operating procedures adequate? Has the EPG rev 2/rev 4

, issue for the E0Ps been resolved? Have other procedures l (surveillance, maintenance) been updated and are they adequate?

O PILGRIM RESTART - 0001.0.0 11/29/80

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Pilgrim Restart 2

2. RADIOLOGICAL CONTROLS
a. Problem Overview Program implementation has been weak. Corrective actions have not always been timely or effective. Morale has been low and significant animosity evident between health physics and operations personnel,
b. Restart Questions
1. Does the health physics group effectively manage both routine and unusual health physics activities?
2. Are we satisfied with the Decon program? Housekeeping?
c. Restart Assessment items
1. Is health physics staffing adequate, particularly first line supervisors?
2. Are first line supervisors adequately controlling field activities?
3. How timely and effective are corrective actions to identificd problems? Do health physics personnel clearly understand their responsibilities?
4. Are keys to high radiation areas controlled, particularly by control rsos personnel?
5. Do health pav ;1cs personnel effectively interact with Operations Department / Maintenance personnel?
6. Is the licensee prepared for increaseo plant radiation levels caused by hydrogen injection?
7. Is radioactive ef fluent adequately controlled and monitored?

This has not been a problem, but should be reviewed p. ior to startup,

8. Are the calibration, QA, and preventive maintenance programs for the new environmental thermoluminescent dosimetry (TLD) system effective?
9. Closeout RIP concerns.
10. Review status of decontamination program.
11. Has BEco demostrated increased managsment attention and involve-ment in radiological controls improvements?

P!LGRIM RESTART - 0003.0.0 11/29/80

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. Pilgrie Restart 3 r

3. MAINTENANCE AND MOO!FICATIONS
a. Problem Overview Inadequate maintenance planning and staffing has resulted in a chronic backlog of second priority maintenance work. Also, the implementation of many new plant modifications which were installed

,' duri.99 the outage should be checked prior to startup.

b. Restart Ouestions -

Does the licensee have an adequate program to schedule and resolvt station maintenance, including second priority maintenance? Have recent statten modifications been adequately tested and turned over to the station?

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c. Restart Assessment items
1. Is maintenance staffing adequate, particularly first line super-visors?
2. Are the maintenance scheduling and parts procurement groups above to support both first and second priority maintenance? ,
3. Are administrative procedures for the maintenance program in place and effective? '
4. Does the Maintenance Department resolve maintenance co'ncerns from other licensee groups (such as operations, fire protection, and security) in a timely manner?
5. Does the licensee control and implement vendor recommendations?
6. Is the preventive maintenance program documented and effective?
7. Have modifications been adequately tested and incorporated into controlled drawings and procedures?
8. Has the maintenance backlog beon reduced to an acceptable level?
9. Mas BEco demonstrated improvement in maintenance planning?
10. Has the material condition of the plant improved? Has the decon effort improved access to key areas?
11. Are the maintenance procedures technically adequate?
12. Review hydrogen injecsion system modification.
13. Review / accept Mark I containment mods. (SEP program)

P!LGRIM RESTART - 0005.0.0 11/29/80 s _ - - - . - -

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. 14. Has the coordination between maintenance and operations /HP personnel improved?

15. Has BEco prioritized plant modifica:'ans and deMostreted the capability to accomplish scheduled work?

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, PILGRIM AESTART - 0006.0.0 i

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4. SURVEILLANCE i:

- 4. Problem Overview Improper surveillance test scheduling and technical"ly incomplete tests have been recurring problems. The surveillance program was dispersed througnout the site organization. This hampered efforts

- to control and update the tests.
b. Restart Question -

Does the licensee have 1 acceptable centralized, clearly defined,

' forward-looking surveillance program?
c. Restart Asses", ment Items
1. Review the revised surveillance test scheduling program.

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!s information in the surveillance test data base up to #

date?

Does the program relate technical specification surveil-lance requirements to specific licensee tests?

Are the n w tech spec changes covered by procedures /

programs?

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Are tests properly scheduled during: a) changing plant modes, b) extended startup sequences, c) operating cycles following long shutdowns?

Check that all tests required by the technical specifica-tions to be conducted once per cycle, once per operating cycle, or once per refueling outage are completed prior to startup.

-- Are all local leak rate tests scheduled on a component  ;

basis? i

2. Review the technical adequacy of surveillance procedures in the following areas: -

ECCS lonic system functional tests l Analog trip systcm testing l ECCS flow rate testing .l

-- Protective relay and breaker testing  ;

A sampli1g of other surveillance tests required by the technic'al specifications and FSAR.

PILGRIM RESTART - 0007.0.0 11/29/80

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3. Is the surveillance program controlled by a centralized, tech-

, nically knowledgeable person or group? Is there an ongoing program to review and improve surveillance test.s?

4 Will BE o demq, strate systems adequacy for restart by an inte-r., grated functi6nal test program?

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i PILGRIM RESTART - 0008.0.0 11/29/80 1

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5. FIRE PROTECTION a, problem Overview

" The fire protection program has been unoerstaffed and chronically neglected. This caused poor fire barrier control and surveillance,

. poorly performed surveillance on other fire protection equipment, an insensitivity to out-of-service equipment, and inadequate fire brigade training. .

b. Restart Question
i. Does the licensee have a program to maintain fire barriers, fire pro-(, tection equipment, and fire protection personnel training?

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c. Restart Assessment Issues
1. Is fire protection staffing adequate?
2. Are fire barriers identified and checked at appropriate fre-quencies?
3. Is the fire protection maintenance backlog controlled? Has the amount of inoperable fire protection equipment been reduced? Has the reliance on compensatory measures been minimized?
4. Are the fire brigade members qualified and adequately trained?

Are simulation and prompt 1.1g minimized during fire brigade drills?

5. Are administrative procedures in place to ensure that fire protection notifications are made in a timely manner?
6. Are surveillances for fire protection equipment appropriately conducted?
7. Resolve Appendix A/ Appendix R issue.
8. Complete App R exemption request reviews.
9. Are any required FP tech spec changes completed and appropriate procedures in place?

e PILGRIM RESTART - 0009.0.0 11/29/80

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Pilgrim Restart 8

6. SECURITY
a. problem Overview The security program has been understaff ed and characteristically

.: neglected. This caused a heavy reliance on compensatory measures for out-of-service equipment and routine, excessive overtime.

b. Restart Question Does the licensee have an a;tive security program that emphasizes

,, equipment operability and control over overtime?

c. Restart Assessment issues
1. Are licensee ard contractor security staffing levels adequate?

Is overtime controlled and held to a minir -'

2. Is the security maintenance backlog controlled. Is ,$ut of ser-vice equipment minimized?
3. Are CAS and SAS activities controlled and consistent with post orders?

4 Security equipment modifications and upgrades should be substan-tialy completed and reviewed. Reliance on compensatory measures should be minimal.

5. Have the recent security allegations been res99}4d?

O PILGRIM RESTART - 0011.0.0 11/29/80

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7. TRAINING AND QUALIFICATION
a. Problem Overview ,

Past training has been adequate, with the exception of fire protec-tion training.

b. Restart Guestion Has the training program during the outage been adequate to support
  • plant restart? -
c. Restart Assessment issues
1. Have operators received adequate refresher training to compen-sate for the long shutdown? Are they aware of new and existing technical specification requirements? Have they been trained on

. the new Emergency Operating Procedures (EOP's)?

2. Have operators been trained on recent plant modifications, such as the analog trip instrumentation, the safety enhancement pro-gram, the epic computer (including the safety parameter display system), and the hydrogen injection system?
3. Are the fire brigade members qualified and adequately trained?

Are simulation and prompting minimized during fire brigade drills?

4. Is the training for non-Itcensed personnel, in particular the management and technicsl new hires, adequate?

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PILGRIM RESTART - 0012.0.0 11/29/80

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Pilgrim Restart 10

8. ASSURANCE OF QUALITY
a. Problem Overview A significant lack of agressiveness and control was previously noted in site and corporate management. A poorly-defined organizational structure weakened onsite manag. ment. QA findings were not promptly resolved, due to slow senior coprorate management action. Repeated prompting and overview from the NRC was needed to get the licensee to address long-standing problems, such as overtime control. In -

addition, safety equipment access has'been severely limited due to excessive radioactive contamination.

b. Restart Questions Is the current management team effective in identifying and resolving problems? Is tha licensee's plant decontamination program effective?
c. Restart Assessment Items
1. Does the licensee have an adequate staf fing plan to support site and corporate activities?
2. Has BEco established a stable management team? .
3. Are personnel aware of theh* organizational responsibilities?

Are workers aware of the recent organizational changes and pro- t gram changes?

4. Are senior site and corporate management visible onsite? Do they routinely tour the site to review plant conditions and ongoing work? Are problems appropriately escalated to senisr management and are they responsive?
5. Has 8Eco demonstrated ef fective management attention in ensuring resolution of identified problems? Are QA findings resolved in a timely manner?
6. Are review committees effective?
7. Have the quadrant rooms and other plant areas containing safety equipment been decontaminated so that the areas are reasonable '

accessible in street clothes? Does the licensee have a long term program to maintain accessibility?

8. Are overtime controls for $4fety related work effective?

G PILGRIM RESTART - 0013.0.0 11/29/80

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pilgrim Restart 11 1

9. STARTUp PREPARATIONS The following issues associated with startup preparation should be reviewed. .-
4. preparation for the remote shutdown and cooldown test sequence. Both

, training and practice drills should be reviewed.

b. The startup checklist should be evaluated for completeness,

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c. The licensee's restart test progrf, should be evaluated to ensure adequate testing of modifications.
d. Has the integrated test program been developed and is it adequate?

Has the power escalation sequence been developed and does it contain e.

adequate NRC hold points?

10. EMERGENCY PREPARE 0 NESS
a. problem Overview On-site emergency planning is acceptabic; however, in light of the Barry Report to the governor, and the Senator Golden 10 CFR 2.206 petition, FEMA Region I has performed a self-initiated review of the state and local emergency plans. On 8/6/87, in a report forwarded to the NRC, FEMA concluded that Massachusetts offsite radiological emergency planning and preparedness are inadequate to protect the public health and safety in the event of an accident at Pilgrim.
b. Restart Question This requires a decision as to whether the deficiencies are such that restart will be allowed, and the deficiencies corrected under a 120 day letter, or whether they must be corrected prior to restart,
c. Restart Assessment Issues The planning deficiencies must be corrected through plan changes submitted by the Commonwealth to FEMA for review; a remote possibility at present.
11. CONTAINMENT ENHANCEMENTS
1. NRR to review containment modifications (SEP program) for accepta-bility.
2. Containment Spray rusty nozzle issue needs to be resolved. -

p!LGRIM RESTART - 0015.0.0 11/29/80

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ENCLOSURE 2 TO ATTACHMENT 2 Samole Recuest Format For Restart Plan Information I. Review Area: (List Restart Plan Volume. Section, Title)

II. Please cascribe now the Restart Plan addresses the following concerns:

9 A. (Clearly Descrice Eacn Concern.)

B.

C.

6 III. Please provide the following additional information to clarify or amplify statements in the Restart Plan.

A. (Clearly Describe Information Needed.)

B.

C.

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. ENCLOSURE 3 TO ATTACHMENT 2 2

CHRONOLOGICAL LISTING OF .

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SIGNIFICANT EVENTE -

> DATE EVENT 12/18/85 SALP Board meeting for period 10/1/84-10/31/85 Board found recurrent theme of inadequate .

personnal staffing and inadequate supervisory oversight,at the plant.

-Board also found that the licensee was unable to improve performance, or sustain it once achieved, in several functional areas.

2/18/86 Initial SALP report issued. Indicated special in depth team iaspectio:s would be conducted to determine underlying cause of licwnsee poor SALP performance.

2/18/86- Diagnostic Team Inspection confirmed SALP 3/7/86 Board conclusions.

The inspection found four principal factors inhibiting progress:

1) incomplete staffing, in particular operators and key mid-level supervisory personnelt
2) prevailing visw in the organization that the improvements made to date have corracted the problems:
3) reluctance, by management, to acknowledge some problems identified by the NRC i and k 4) dependence on third parties to identify problems rather than implementing an i-effective program for self-identification f M vlaknesses.

3/5/86 SALP cunagement meeting with BEco.

4/4/86 During routine shutdown the plant tripped due to a spurious Group I containment isolation. The outboard MSIVs could not be reopened inmediately f ollowing the trip.

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What will we look for to see that the situation has improved at Pilgrim in preparation for restart? .

In general terms, we will look for:

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1. A stable and effective management team at the plant.  ;

,' 2. Management vacancies are filled and licensed reactor Operator and senior reactor operator positions are filled.

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3. The work backlog is under control and a system is in place to track the backlog.

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4. Solid improvements have been made in long-standing problem areas such I as radiation protection, fire protection and plant security.
5. Solid improvements have been made in che offsite emergency planning weaknesses. ,

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Finally, we will expect to see that 8Eco is deva c v , its own internal high 5 standards of performance and the means for self critical analysis relative to i those standards. Of course, there will be detailed inspe:tions of many specific issues within these general areas, f

- l That concludes my testimony, Mr. Chairman.

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ENCLOSURE 5 TO ATTACHMENT 2 DOCUMENTATICN GUIDANCE FO . RESTART 'LAN REVIEW .

L The following guidance and format is provided to assure consistent docu-mentation of reviews of the Pilgrim Restart Plan.

I. Areas of Review (Sucearize the general subject area of the plan being reviewed).

. II. C ri teri,a

(!d tify criteria applied in review, such as Regulations, Standards, 1

FSkk, QA Manuti, Standard Review Plan, Licensee Commitments etc.)

III. Review and Fir.J1ngs (Describe -hat was reviewed, ie/.luding ancillary documents and conclusions reJthed. indicate clearly whether or not pa f rams are acceptable.

Identify linkages to SALP findings, Diagnostic Inspection of 3986, other inspection efforts or licensing reviews, as appropriate).

IV. Additional Information Needs (If required)

Identify additional information needs and basis for need. This may be:

l. Additional inspection areas
2. Issue requiring additional info mation from licensee (RAI).

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