ML20206C354

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Forwards Rept Summarizing Results of Evaluation of Operation of Facility.Inpo Team Evaluations Found to Be Thorough
ML20206C354
Person / Time
Site: Pilgrim
Issue date: 11/06/1985
From: Moeller D
Advisory Committee on Reactor Safeguards
To: Fraley R
Advisory Committee on Reactor Safeguards
Shared Package
ML20206C347 List:
References
FOIA-88-198 NUDOCS 8811160242
Download: ML20206C354 (14)
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  • UNITE 38TATES i

/ NUCLEAR RECULATCRY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARD 4

  • ,, WASHINGTON,o,c.aossa November 6, 1985 Mr. Raymond F. Fraley Executive Director Advisory Corrnittee for Reactor Safeguards t Washington, DC 20555

Dear Ray:

As you know, I spent last week serving as an observer on an INPO Team that was conducting an evaluation of the operations of the Pilgrim Nuclear Power Station in Plymouth, Mass.

Enclosed for your information is a report summarizing some of the results of this experience. I continue to be impressed by the quality and thoroughness of the INPO Team evaluations and highly recumend that other ACRS members consider joining such an exercise at some future date.

Sincerely yours.

Dade W. Moeller Ar,RS Member

Enclosure:

Report l

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I 8811160242 001010 P Og_g9B PDR NG L--

Dade W. Mceller November 2, 1985

$UMMARY REPORT Participation in !NPO Evaluation of the .

Pilgrim Nuclear Power Station October 28 - November 1,1985

!. Introduction Through arrant?ments made by Mr. William R. Kindley, Deputy Director, Radiological Protection and Emergency Preparedness Division, Institute of Nuclear Power Operations, I participated as an observer during the second week (October 28-November 1,1985) of their evaluation of the Pilgrim Nuclear Power Station in Plymouth, Mass. The Pilgrim Station is a single unit Boiling Water Reactor, and has a net electric generating capacity of 655 MW. The Station was operating at 100-percent power during our visit.

!!. The Evaluation Team The INPO Evaluation Team consisted of 16 numbers, plus the Team Leader, two observers (a representative from TVA at Browns Ferry and myself), and 3R0s from two other utilities (Quad Cities and Big Rock Point). Included among the Team Members was a vendor (GE) repre-sentative on assignment as a loanee to INPO. The average age of the Team members was 35 years and they had an average of 8 years of civilian nuclear power plant experience, plus 4 years of Nuclear Navy experience.

Half of the Team members had either an RO or SRO license at at least one connercial nuclear plant. Essentially every Team member had a bachelor's degree; sore had advanced degrees.

!!!. Conduct of the Evaluation Specific subject areas covered during the evaluation are shown in Table !. As is customary, the Team members had full access to the plant, with individual members being assigned specific subject areas to cover. Overhalfofthememberssuitedupinprotectiveclothing(some

2 wearing respirators) at least one time during the two weeks to ent /

contaminated areas for specific evaluations. -

At the end of each day, observations and concerns were shared among Team members during briefing sessions. This led in many cases to the coordination of observations by different Team members. If after subsequent discussion with the Station contact for the specific subject area (andafterthecontacthadhadanopportunityforrebuttal)the concerns were shown to be well substantiated, they were elevated to the level of preliminary "findings" and ma r art of the dreft Team report.

On Friday. November 1,1985, these "findings" and recomendations for action were oiscussed with the Station Manager and his Staff, again with 6n opportunity for rebattal, as appropriate. On the afternoon prior to this presentation, each finding was discussed on a preifminary and confimatory basis with Kenneth Strahm, Vice President end Director.

Training and Education Division, and with Will!am Wigley, Manager, Training Assistance Department, INPO, to assure that each was well founded and could be su'stantiated.

IV. Observations and Coments Sumarized below are my coments and observations on the Team evaluation. My coments are general since ! prefer to leave to the INPO Team the decisions on the assignments of ratings as to the performance of the Plant staff. In this regard, it is important to note that Team members based their evaluations both on observations of the Plant st&f?

in their work capacities, and on the written records maintained at the Station. Tasks underway, and the specific procedures perfot1ned at the request of the evaluation Team, were carefully reviewed and critiqued.

Throughout the visit, the Plant staff provided their full and complete cooperation.

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1 My impressions of the pe;fonnance of the INPO evaluation Team wm very favorable. The Team members proved to be a spirited, hardworking. .

enthusiastic group. Departure from the hotel was routinely scheduled at 6:30 a.m., discussions at the Station extended beyond 6:00 p.m., and ,

I follow-up sessions continued at the hotel beyond 10:00 p.m. t l

1 In the way of specific connencs, I offer the following:  ;

i l 1. The INPO objective of seeking excellence in plant perfonnance is clearly a guiding factor in their evaluations. Although I compliance with regulatory sta.1dards is clearly required, this is definitely below the ultimate quality b. Sought. I l

2. Although the objective is a thorough evaluation of plant '

performance, the INPO Team appeared tn 9nderstand the necessity to try to avoid overjhelming the Station staff with more l

recorrrendations than they could handle. In some cases this was handled by grouping several recoernendations under broad headings.

3. The INPO Team appeared clearly to recognize potential limitations on their findings and recomendations. Since the Team spent only two weeks at the plant, at best their observations were  :

only a "snapshot" of total plant perfonnance. At the same time, I however, there is no reason to believe that conditions during the l two weeks would have been significantly different from those at i other periods of time.

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4. The mechanisms for feedback of operating experience were f carefully reviewed and assessed. This included, for example, a l detailed check to assure that the plant staff had implemented each l l reconsnendation contained in recently issued INPO Significant l l Operating Experience Reports. A key part of this evaluation was a l l

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My impressions of the performance of the INP0 evaluation Team were very favorable. The Team members proved to be a spirited, hardworking, ,

entnusiastic group. Departure from the hotel was routinely scheduled at 6:30 a.m., discussions at the Station extended beyond 6:00 p.m., and  !

follow-up sessions continued at the hotel beyond 10:00 p.m.  ;

In the way of specific comments, I offer the following: r

1. The INPO objective of seeking excellence in plant performance '

is clearly a guiding factor in their evaluations. Although compliance with regulatory standards is clearly required, this is definitely below the ultimate quality being tought. '

2. Although the objective is a thorough evaluation of plant performance, the INPO Team appeared to understand the necessity to try to avoid overwhelming the Station staff with more recomendations than they could handle. In some cases this was handled by grouping several recomendations under broad headings.

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3. The INPO Team appeared clearly to recognize potential limitations on their findings and recomendations. Since the Team spent only two weeks at the plant, at best their observations were only a "snapshot" of total plant performance. At the saine time, however, there is no reason tc believe that conditions during the i two weeks would have been significantly different from those at f other periods of time.  !
4. The mechanisms for feedback of operating experience were l
arefully reviewed and assessed. This included, for example, a detailed check to assure that the plant staff had toplemented each  !

recomendation contained in recently issued INP0 Significant  :

Operating Experience Reports. A key part of this evaluation was a ,

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4 review of training courses to assure that they include coverage of such events and provide proper inform 3 tion to the plant staff. .

5. The plant staff was actively working to assure that their training program will soon be qualified for accreditation by INP0.

This was an obvious stimulating effect on full implementation of the program. This included closa correlation of course content with the needs of the intended trainees. Although plant policy confirred a desire for most staff members to attend courses one week in every six, it was observed that this goal could be ,

attained, at best only about 50% of the time. This was due to the interferenceofvacationschedules(9drefuelingoutages(whenthe demands on support personnel negate allotting time for training).

6. Radiation protection and the implemente*, ion of the ALARA criterion are considered an important part of the Team evaluetion.  !

In this regard, it was interesting to note the wide range of ,

activities currently considered as potentially significant I contributors to better implementation of this criterion. These

, included a sound training program, prewentive maintenance, and the  !

upcoming implementation of a hydrogen chemistry program. It was universally agreed that, since a good ALARA program leads to greater effectiveness and efficiency in the conduct of the work at ,

aplant(andacorrespondingincreaseinproducvivity), itis [

definitely cost effective. l l

7. One personal observation of this evaluation was the importance  !

of good personnel management practices in plant cperations. It l would appear useful to add to future Evaluation teams people who (

have specific expertise in this area. l l

8. As in th: past, the question was raised whether INP0  !

evaluations result in safer operation of a plant. Since the INP0 i

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goals include better management of the piant, improved on-line perform.nce of individual systems, reduced occupational doses, and  ;

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enhanced feedback of operating experience, there is little doubt in my mind that the answer to this question is anything but "yes." An added benefit is the tremendous opportunity that the review provides for training not only the plant staff but also the participants and observers from the vendors, other utilities, and [

other organizations. ,

9. Near the end of my visit. I had an opportunity to met for several hours with Dr. Martin McBride, the NRC Senior Resident inspector. This oroved to be a most helpful exercise. Dr. McBride proved to be thoroughly familiar with operations at the Pilgrim Station and provided me with background infomation and insights that were valuable in helping me gain a u'etter understanding of the reasons behind some of the events and practices that we had l observed.
10. As a final coment. I believe that for ACRS membe's interested in detailed knowledge of main'enance and operational practices at nuclear power plants, participation as an observer in an INPO eva19. tion would be an extremely valuable source of information.

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TABLE ! ,

PROGRAM AREAS COVERED IN THE INPO EVALUATION 0F THE PILGRIM NUCLEAR POWER STATION L

1. Organization and Administration  !
2. Operations f
3. Maintenance l 4 Technical Support  !
5. Radiation Protection f
6. Chemistry l
7. Operating Experience ,
8. Training -

I, Note: Emergency planning, which is normally one of the Program Areas, was not covered in this evaluation. r

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n Feedwater Ibmp Trip On Iligh Reactor Pressure

- MSIV Iteactor Low Water Levd Isolation Signal Manual Bypass l10

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