ML20214F515
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| ML20214F515 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/08/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20214F494 | List: |
| References | |
| 50-293-86-99, NUDOCS 8705260125 | |
| Download: ML20214F515 (79) | |
See also: IR 05000293/1986099
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U.;S. NUCLEAR REGULATORY COMMISSION
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, REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
: INSPECTION REPORT 50-293/86-99
BOSTON EDIS0N' COMPANY
PILGRIM NUCLEAR POWER STATION.
ASSESSMENT PERIOD: NOVEMBER 1, 1985 - JANUARY 31, 1987
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BOARD MEETING DATE: MARCH 2, 1987
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TABLE OF CONTENTS' s
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Page 1
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1 0 ' INTRODUCTION ..................................................... I j
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l'1 Purpose.and Overview ................................. .....
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1.2 1SALP. Board Members .......................................... I- 1
1.3 Background .................................................. 2
2.0 CRITERIA .............................................. ....... .. -5
3.0 ~ SUMMARY OF RESULTS'.............................................. 7
3.1 Facility Performance .... .................................. 7'
3.2. Overall Facility Evaluation ................................ 8
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4.0 P E R FO RMAN C E ANA LY S I S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 l
4.1 P l a n t Op e ra t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
4.2 . Radiological Controls ..................................... 14.
4.3 Maintenance -.............................................. 19
4.4 Surveillance .............................................. 24
4.5 Fi re P ro t e c ti o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 7 -
4.6 Emergency Preparedness .................................... 29
4. 7 S ec u ri ty a nd Sa f eg ua rd s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
4.8 Outage Management and Modification Activities ............. 35-
4.9 ' Licensing Activities ...................................... 38
4.10 Engineering and Corporate Technical Support ............... 40
4.11 Training and Qualification Effectiveness .................. 43 i,
4.12 Assurance of Quality ...................................... 47 !
5.0 SUPPORTING DATA AND SUMMARIES ..................... ............. 52
5.1 Investigations and Allegations Review ..................... 52
5.2 Escalated Enforcement Actions ............................. 52
5.3 Management Conferences .................................... 52
5.4 Licensing Actions ......................................... 53
5.5 Licensee Event and Part 21 Reports . . . . . . . . . . . . . . . . . . . . . . . . 55
5.6 . Automatic Scrams and Forced 0utages ' . . . . . . . . . . . . . . . . . . . . . . . 57
TABLES a
Table 1 - Tabular Listing of LERs by Functional Area . . . . . . . . . . . . . . . . 58 '
Ta bl e 2 - LER Synop s i s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 9
Table 3 - Inspection Hours Summary .................................. 62
Tabl e 4 - En f orceme nt Summa ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63 i
Table 5 - Inspection Report Activities .............................. 68 I
Table 6 - Unplanned Automat c Scrams and Shutdowns . . . . . . . . . . . . . . . . ... 73 ;
. Table 7 - Pil grim SALP Hi story Tabul ati on . . . . . . . . . . . . . . . . . . . . . . . . . . . 76
FIGURES
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Figure 1 - Unit 1 Plant Operation Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . 77 l
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1,0 INTRODUCTION
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1.1 Purpose'and Overview
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The Systematic Assessment of Licensee Performance (SALP) is an inte- 3
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grated NRC ' staff effort to collect observations' and data on a per- i
iodic basis and to evaluate licensee performance. The SALP process j
is supplemental ~ to the normal regulatory processes ' used to ensure ;
compliance to NRC rules and regulations. It is intended to be suf- i
ficiently ' diagnostic to provide a rational; basis for allocating NRC
resources and to provide meaningful guidance to licensee management
in~ order to improve the quality and safety of- plant operations,
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An NRC SALP Board, composed of the staff members listed in Section - l
1.2 below, met on March.2,1987 to review the collection of perform-
ance observations and data in order to assess the licensee's perform-
ance at the Pilgrim Nuclear Power 3tation. This assessment was con-
ducted in accordance with the guidance in NRC . Manual Chapter 0516,
" Systematic Assessment of Licensee Performance". A summary of the
guidance and evaluation criteria is provided in Section 2.0 of this
report.
This report is the SALP Board's assessment of the licensee's safety
performance at the Pilgrim Nuclear Power Station for - the period
November 1,1985 - January 31,1987. The summary findings and totals-
reflect a fourteen month assessment period.
1.2 SALP Board Members
Chairman
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W. Kane, Director, Division of Reactor Projects (DRP)
Members
T. Martin, Director, Division of Radiation Safety and Safeguards
W. Johnston, Deputy Director, Divi _sion of Reactor Safety
W. Houston, Deputy Director, Division of BWR Licensing, NRR
R. Capra, Acting Chief, Projects Branch 1, DRP
J. Durr, Chief, Engineering Branch, DRS
L. Bettenhausen, Chief, Operations Branch, DRS ;
J. Wiggins, Chief, Reactor Projects Section IB, DRP ,
M. McBride, Senior Resident Inspector l
R. Auluck, Project Manager, NRR '
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Other Attendees
J. Strosnider, Chief, Materials and Process'Section, DRS
J. Lyash, Resident Inspector, Pilgrim
J. Schumacher, Senior Emergency Preparedness Specialist, DRSS~
N. Blumberg, Lead Reactor Engineer, DRS
R. Nimitz, Senior Radiation Specialist,_DRSS.
G. Smith, Safeguards Specialist, DRSS
1.3 Background
A. Licensee Activities
The unit began the evaluation period operating at 100 percent
.. power. ' On January 3,1986, a reactor shutdown was initiated to
investigate 1ncreasing main turbine generator bearing vibration.
Three days later on January 6, the reactor was restarted after
completion of main steam isolation valve (MSIV) adjustments and
bearing maintenance. During the startup the reactor scrammed.
from ten percent power on low vessel ' water level due to feed-
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water control valve leakage and operator error. Startup recom-
menced on January- 7 and full power was reached on January 10.
Leaking hydrogen ignited during the replacement 'of a regulator-
in the main turbine generator hydrogen supply system on ' January-
9. On January 16 an automatic scram occurred due to a spurious
reactor high pressure signal when a technician inadvertently
bumped an instrument, -The restart began two ' days- later on
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January 18 and the unit was operating at full power by January:
20. ' A severe vibration transient in .'a main turbine generator.
bearing forced reduction to ten percent power on January 29.
The unit was returned to full power following turbine generator
adjustments. On February 13, in response. to recurring residual
heat removal .(RHR) discharge ' piping high- pressure alarms, the.
licensee _ temporarily removed the B RHR system loop from service.
Severe water hammer damage was identified in the head spray por-
tion of RHR piping on March-7. The affected piping had not been
used for .several years and was subsequently removed and capped.
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On March.15, the reactor was shut down due to a leaking reactor
vessel instrument line weld. The weld . crack was located and
repaired. While shut down, a spurious primary containment group
1 isolation occurred. No cause for this isolation was identi-
fied. The reactor was restarted sixteen days later on March 31.
A main turbine hydraulic system oil leak resulted in a unit
shutdown on April 4. During the shutdown, a spurious primary
containment group 1 isolation occurred again. This isolation
caused an automatic reactor scram. Initial attempts to open the i
outboard MSIVs were unsuccessful.
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The reactor was taken critical o.n April 10. Recurring RHR sys-
tem discharge piping high pressure alarms prompted a' plant shut-
down on April .11. A third ' spurious primary containment' group' 1
isolation . occurred during the shutdown and' the outboard MSIVs
could not be reopened. This' isolation also caused an automatic
reactor. scram. NRC issued Confirmatory Action Letter 86-10 as
a result of these recurring events to maintain . the plant in a
shutdown - condition. until the NRC could review in detail, and
understand, the causes of these events and the licensee's cor-
rective actions. An NRC Augmented Inspection Team, consisting
of. headquarters and region-based personnel, was dispatched to
" the site on April 12 and reviewed the licensee follow-up to the
two isolations and scrams.
Operator licensing examinations were ' conducted during the . week:
of May 5. Two senior reactor operator (SRO) and five reactor
operator (RO) candidates were examined with only one RO failure
during the period. On May 15 three Boston Edison labor unions,
including operations and maintenance personnel, began a four
week strike. On June 30 the contractor security force went on
strike, returning on July 1. On July 25, Boston- Edison
announced ~ extension of the outage, into 1987. Outage activities
were' expanded to include refueling, installation of a new pro-
cess computer, installation of an analog trip system, completion
of Appendix R tradifications, and the implementation of signifi-
cant primary containment enhancements.
Several key licensee. organizational changes occurred during the
period. The ' Senior Vice President - Nuclear (VPN) was reas-
signed and his responsibilities' were assumed by the Chief
Operating Officer (C00). A new Senior Vice President-Nuclear
was hired late in the' period and assumed responsibility for the
nuclear organization in February 1987. The Plant Manager who
was in place .at the beginning of the assessment period was
replaced midway through the period. This new Plant Manager was
replaced in turn, following the end of the period.
B. Inspection Activities
A senior resident inspector was assigned to the site throughout
the assessment period. A second resident inspector was assigned
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in April, 1986. During the fifteen month assessment period,
6762 hours of direct NRC inspection were performed at Pilgrim.
This was equivalent to 5475 inspection hours per twelve-month
period. A detailed breakdown of the total inspection hours into
SALP functional areas is inc%ded in Table 3. A third resident
inspector was assigned to the site at the. end of the period.
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During the assessment period eight NRC team inspections were
conducted:
1. Safety system ~ functional readiness review
'2. Environmental qualification program review
3. Special Region I-diagnostic. team inspection
'4. Emergency planning remedial drill observation
5. Augmented. Inspection Team (AIT) review of two scrams 'from
low power in April 1986 and. recurring pressurization of the
residual heat removal system
6. Hadiological Improvement Program'(RIP) appraisal
7. - Anticipated Transient Without Scram Generic Letter 83-28
review
8. Annual emergency plan exercise observation
The.special Region I diagnostic inspection reviewed plant activ-
ities on a twenty-four hour basis for several weeks to ' determine
root causes for previous . poor performance. Operator licensing
examinations and an inspection'of the licensed. operator requali-
fication training program were also conducted.
Confirmatory Action Letter (CAL) 86-10'was issued at the time of
the AIT 'in April, 1986. CAL 86-10: . (1) confirmed guidelines
for the AIT, (2) confirmed that the licensee submit technical _
evaluations of the scrams and RHR pressurization events to the
NRC, and (3) stated. that NRC Regional Administrator approval
would be required prior to restart. Subsequently a series of
six meetings between NRC: Region I and licensee senior management
were held to discuss licensee progress on the AIT . technical
issues as well as other areas of concern. These meetings con-
tinued through~ the end of the assessment period. The Confirma-
tory ' Action Letter was ' subsequently extended to cover licensee
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actions to' correct significant programmatic deficiencies.
Tabulations of inspection activities and associated enforcement
actions are contained-in Tables 3, 4 and 5.
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2.0 CRITERIA
Licensee performance is assessed . in selected functional areas, depending .
.upon whether the facility is in a construction, preoperational, or oper-
ating phase. Functional areas normally represent areas significant ; to
nuclear safety and the environment. Some- functional areas may not be
assessed because'of little or no licensee activities, or lack of meaning-
ful c.bservationsi Special areas may. be added to highlight significant-
observations.
This report. also discusses " Training and Qualification Effectiveness",
" Assurance of- Quality"' and " Engineering and Corporate Technical Support"
as separate function areas. Although these topics, in themselves, are
assessed in the other functional areas through their use as criteria, the
three areas provide a synopsis.- For example, quality assurance effective- i
ness has been assessed on aiday-to-day basis by resident inspectors and as
an integral aspect of specialist inspections. Although quality work is
the responsibility of every employee, one of the management tools to
measure this effectiveness is reliance on quality assurance inspections
and audits. Other major factors that influence quality, such as involve-
ment of first line supervision, safety committees, and worker attitudes,
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are discussed in each area,
One or more of the following evaluation criteria were used to assess each
functional area.
1. Management involvement and control in assuring quality.
2. Approach to the resolution of technical issues from a safety stand-
point
3. Responsiveness to NRC initiatives
4.- Enforcement history'
5. Operational and Construction events (including' response to, analyses
of, and corrective actions for) !
6. Staffing (including management)
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7. Training and Qualification Effectiveness (
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Based upon the SALP Board assessment, each functional area evaluated is l
classified into one. of three performance categories. The definitions of
'these performance categories are -
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. Category 1. Reduced.'NRC attention.may be appropriate. Licensee manage-
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ment attention. and involvement are aggressive and' oriented toward nuclear
: safety; licensee resources are ample -and . effectively 'used so that-a high ,
level of performance with respect to operational safety is being achieved.
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' Category 2. . NRC : attention l should1 be maintained at normal levels. Licen - 1
see management attention - and involvement are . evident and are; ~ concerned-
with nuclear safety; licensee resources are. adequate and reasonably effec-
' tive' so .that . satisfactory. performance with respect . to nperational. safety -
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is being achieved.
m Category 3. I
Both NRC .and licensee attention - should be ' increased. : Licen -
see management attention or. involvement is acceptable' and considers- . . .
nuclear safety, but weaknesses ~ are evident; licensee . resources ' appear to !
be strain'ed or not effectively used so that minimally satisfactory ~per-
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formance with respect to operational' safety is being achieved.: l
. The .SALP Board also assesses a functional area to compare ' the licensee's
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performance during the last quarter of, the assessment' period to that dur-
n , ing the entire period (normally one year) in order to-determine the recent :.
trend for cach functional area. The SALP trend categories are as follows:
Improving: Licensee performance has generally improved over the last -
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part of-the SALP assessment period.
Declining: . Licensee performance has genera 11y ' declined over the last'
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part of-the,SALP' assessment period.
A trend.is ' assigned only when, in the' opinion of the .SALP board, the trend I
'is significant enough ~ to be considered' indi.cative. of. a likely change 'in f
the performance category in the near ftiture. For example,; a classifica- i
tion of '" Category -2,.. Improving" indicates the clear potential .for 'j
" Category 1" ' performance in the ne.xt SALP period.
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(3.0 SUMMARY 0F-RESULTS !
3.1 ' Facility Performance
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Functional Category. Category Recent
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, . Area s
;tastPeriod* This Period **' Trend
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1. Plant-Operations 3 -2 --
2. Radiological 3 3 --
? Controls
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-3. Maintenance ~ 2 2 --
4. Surveillance 2 3- ---
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5. Fire Protection ***
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Preparedness '
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7. Secerity and 2 3' -Inproving
' Safeguards:
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8. Outage Management, 1 l' --
Modifications and '
Technical Support !
Activities
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9. Licensing 1 2 -- I
Activities .f
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10. Training and
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2 Improvin'g
Qualification
Effectiveness !
11. Engineering and ***
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Corporate Technical
J . Support
12. Assurance of ***
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Quality
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** November 1, 1985 to January 31, 1987 I
***Not evaluated as a separate functional area l
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3.2 0_verall Facility Evaluation j
The 1985 SALP Board found that programmatic weaknesses existed in
several functional areas. . A special Region I diagnostic team subse- ,
quently monitored plant operations on a 24-hour basis and confirmed !
the 1985 SALP conclusions. Poor management control and incomplete I
staffing contributed to the poor performance. Improvements were j
noted during the current period, although the rate of change was j
slow. Several factors inhibited progress during the current period, -
including the lack of a clear sense of "who's in charge" onsite,
continuing management changes, and prolonged staffing vacancies.
During the last month of the period, the pace of change accelerated.
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The onsite organization had a dual reporting chain during much of the
period, with site disciplines reporting to both the Plant Manager and
the Director of Outage Management. This obscured the chain of com-
mand and weakened accountability. The dual reporting chain was elim-
inated during a site reorganization following the assessment period. i
Other concurrent organizational changes were also made that removed !
several functional areas from the Plant Manager's span of control. '
The effectiveness of these changes in developing a coherent site
management team has yet to be demonstrated.
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The Plant Manager was replaced midway through the period and the new l
Plant Manager was replaced in turn following the period. Similar
chahges occurred in senior corporate management. Responsibility for
the licensee's nuclear program was transferred from a Senior Vice
President to an Executive Vice President midway .through the period j
and transferred again to a new Senior Vice President following the
end of the period. These changes reflect BECo senior management's '
commitment to provide effective leadership for the nuclear
organization.
Significant recurring program weaknesses were identified ir, some
functional arear, showing the effect of p'reviously identified long- {
term problems. Licensee management did not correct many of these >
problems until further prompted by the NRC, reflecting weak corporate
and site management control and an overburdened staff. Significant l .
staffing vacancies in the areas of radiological controls, maintenance l
and operations were evident through much of the assessment period, i
reflecting slow corporate and site management action. Many of the
vacancies were filled by the end of the period,, however.
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Good performance was noted in four areas: emergency planning, outage
management, corporate engineering support and licensed operator j
training. The success in these areas reflects a high level of cor- j
porate management attention and substantial resource commitments.
Plant hardware changes were also impressive, particularly the planned l
Mark I containment enhancements. The modifications go considerably !
beyond NRC recommendations and show a concern for nuclear safety, y
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In summary, performance improveronts are needed in- various functional
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areasLto-correct long standing problems. The lack 'of 'a clear organ- .
izational,' structure, recurring management changes, and chronic staff- 1
ing vacancies delayed the establishment of a stable licensee manage-
ment team at the_ plant and: inhibited progress' during the assessment
period. . However, performance appeared. to improve at the end 'of ' the
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>' period,. reflecting staffing improvements and resource commitments,
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.The NRC SALP' Board recommends .that followup. team inspections be con- l
ducted during the next assessment period to review plant operations l
with particular emphasis on those functional ~ areas with Category 3 l
performance ratings, i.e. , radiological controls, surveillance, fire -
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protection, and security and safeguards. ' The results of these-
inspections will be a significant factor in the NRC decision as to
readiness of the plant for restart.
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14.0 PERFORMANCE ANALYSIS
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4.1 Plant Operations (24%, 1603 hours).
y ..(1) ' Analysis
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Plant operations was assessed a's a Category 3 during the previous
SALP period. Problems included a chronic shortage of licensed re-
actor operators (R0s), lack of operator overtime control, and lack of
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professional support for the Operations Department. The administra-
tive control of operator overtime has significantly improved, reflec- I
ting licensee management attention. The R0 shortage and professional- )
staff support problems were addressed by management, but were not ;
resolved at the end of the period.
Five months of power operation occurred during the initial phase of
the SALP period. A maintenance and refueling outage started in April
1986 and extended to the end of the period.
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During this period, the operators' conducted routine power operations
effectively and responded to operational events in a professional
manner. Performance during two instances of closure of the main i
steam ' isolation valves (MSIVs) at power and during a severe storm l
with loss of offsite power ~, demonstrated the ability of the opera-
.tions staff to handle significant plant transients. Shift turnovers
were ! generally thorough. Operators took 'a conservative safety con-
scious. approach to technical specification limiting conditions for
operations (LCO). Strong control over plant activities during a
major union labor action was ' evident. Two scrams were linked to
operator error, one of which also involved equipment failure. The
second scram' occurred while the plant was shut down. -A third scram
was caused ' by personnel error (a maintenance technician) and was
linked to an equipment design deficiency.
Plant management,- the Nuclear Safety Review and Audit Committee
(NSRAC), and the Operations Review Committee (ORC) generally' exhib-
ited a conservative, safety conscious approach to events and issues.
Reviews were thorough and deliberate. Licensee evaluation of the RHR
pressurization events and the MSIV isolations during the AIT in' April
1986 were well structured and effective. An exception to this was
the ORC review of debris found in primary containment isolation
valves, i.e. the MSIVs. In this incident. the licensee decided to
rest 3rt the plant after a limited MSIV inspection. A thorough MSIV
eval ation was conducted only after NRC prompting. In addition, the
ORC review of. squib valve testing was initially limited. Following l
NRC involvement, the ORC review was conducted carefully and j
deliberately. "
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[. Some weakness was- noted in attention to' detail. ' Failure of the .j !~ ,
. licensee's " technical group to complete an adequate post trip' review 1
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and poor control room log keeping practices were examples. The
status of inoperable, nonsafety related equipment in the control room
was not always recognized and addressed by the control room staff. ll
T_his -latter problem may be the result of a weak working relationship ] l
between operations and maintenance personnel', which fostered'the view l
that ' inoperable . equipment of secondary importance would not be re- ]
paired. Relations -between Operations and Radiological Controls- '
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Department' personnel were also sometimes strained, reflecting a lack-
.of site management attention. Operations management control of high
radiation area' keys and attention to the implications of major system
isolations were also examples of sporadic problems. The isolation
difficulties reflected a lack of preplanning by the operations and
outage support staff.
The low number of licensed reactor operators (R0s) continued. The _
number of R0s standing watch decreased during the period, despite the
addition of four new licensed R0s to the Operations Department, The '{;
dilution of operating expertise combined with the low number L of '
operators, heightens concern in this area. The licensee has. signi-
ficantly increased.the size of the operations staff and established
an aggressive recruiting and training program in response to the R0
shortage. Although this demonstrated strong management action, the ,
long lead time required to train and license operators and a recent '
increase in R0 attrition will result in an RO shortage until at least i
1988. -The specific cause of the ' RO attrition is unclear, but its
resolution is important. The licensee has experienced senior reactor
operators who may be used to supplement the RO function. However,
the impact of the. RO shortage on plant operations is not desirable
because of the routine operator overtime it causes and the disruption
caused by placing staff personnel with licenses on ' shift to operate i
the plant. i
The shortage of professional support for the Operations Department -
continued to strain department resources. The Operations. Section
Head position was filled during the period. He has assumed some of
the administrative work load from the Chief Operating Engineer (COE)
allowing the COE cdded opportunity to directly oversee operator per-
formance, The licensee assigned two senior engineers to the Opera-
tions Department and reassigned (at the end of the period) the shift
technical advisors (STAS) to the COE. The effect of these actions l
was not clear, due to continuing collateral responsibilities outside
the department for most of the newly assigned individuals. Several .i
examples of incomplete or inaccurate system operating, alarm re- l
sponse, and emergency operating procedures indicated the need for
additional staff attention.
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The operator training program improved during the assessment period. i
Experienced licensed operators and a new licensee - training' coordi- l
nator have - been assigned to the training section showing strong .q
management' action. The licensee received Institute of Nuclear Power i
Operations (INP0) accreditation for all areas of licensed and. non- J
licensed operator training with the exception of the STA program. i
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NRC. license examinations in ~ May, 1986 had.'a high ' percentage of j
- successful candidates. The operator requalification program was i j
found acceptable. A plant; specific simulator was close to. completion' j
at the end of the period. 1
Licensee Quality A'ssurance findings associated with operations 'were
technically sound. Site management. response to ' these findings how-
ever, was sometimes slow and cursory in nature. Senior. corporate -
management action was taken only after significant NRC prompting on -,
this problem. The onsite QA audit staff was significantly increased I
near the end of the period.
Reportable events were acceptably handled by the control room staff. ,
Licensee event ; reports were generally clear. However, several LERs i
did not.contain complete information indicating the need for addi- ;
tional attention to this area by the technical support staff.. '
In summary, the lack of.' licensed operators and the lack of an effec-
tive operations support staff strained the Operations Department dur-
ing the' period. The licensee has'taken strong action to recruit and I
train ' new operators, during the period, however, the high R0 attri-
tion rate remained a significant problem. .. The effectiveness of
increases in professional staff support for the Operations Department
was ' also not demonstrated due to delays in transferring- personnel
into the department and their continuing collateral duties outside l
the department'. Lack of prompt senior corporate management action '
limited the effectiveness of QA audit findings. The licensed opera-
tor training program significantly improved during the per.iod.
NRC observations of plant operations were limited 'to the first five
months of the assessment period due to a plant shutdown which started ;
in April 1986 a-d extended throughout the period. However, these i
observations, including the 24-hour operations shift coverage pro-
u vided by the Region I diagnostic team inspection, indicated that the
plant was operated in a' safe manner. The effectiveness of the train-
ing of upcoming R0 candidate classes (as measured by the pass rate in
the next several NRC license exams), the retention of licensed staff,
and the effectiveness of the Operations Department support staff will
significantly affect future performance. 3
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t' -(2) Conclusion':
"'
' P.a t i n g': - Category 2-
Trend:
'
None
-(3). Recommendations,
Licensee: -- Co'ntinue efforts to Jrecruit, " train-'and. retain
licensed personnel.
NRC: --
Closely monitor 0perations Department staffing
levels.
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-- ' See Section 3.2
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14
4.2 Radiological Controls (11% 746 hours) -I
I
- This assessment covers radiation protection, effluent monitoring and a
controls, radwaste - shipping and environmental monitoring. The area ;
Lof radiological controls was evaluated as Category 3 .last period. '
l
Weaknesses _ identified last ' period are discussed in each sub-area.
]
Inspections this period focused on licensee corrective action for_. l
-
previous problems, planning and preparation for the outage and 'ade-- .[
quacy and implementation of the current: program. Health physics [
activities were- reviewed early in the ' period during a special diag- ;
nostic team inspection to determine the cause of' the licensee's SALP j
rating last period. A special team inspection in' the latter part of ;
the period reviewed licensee progress towards closing out an Order '
Modifying License issued last period.
Radiation Protection ,
.
b
Due to recurring problems resulting in unplanned personnel exposures,
an Order modifying licente was issued last assessment period. The j[
Order required that a cooprehensive review of the radiological con- q
trols program be perforr..ed and that problems identified be corrected ?
through a radiological improvement program (RIP). .;
l
NRC review this period found that the licensee took action to resolve
.
i
the ' previously identified problems, and to complete the Order-re- )
quired upgrade through implementation of the RIP program, j
;
However, review this ' period found that the implementation and effec- I
tiveness. of the program improvements were not' closely monitored by t
site management. ' Problems indicating this were: generation of weak
or inadequate. procedures to satisfy RIP commitments; lack of prompt,
comprehensive corrective actions to resolve identified problems; key )
vacancies in the organization were left open for an extended time '
period; poor and sometimes hostile communications between the radia-
tion protection group and- other station . groups, particularly the
operations group, was evident; accountability of group or individuals
for deficient conditions or actions was not vigorous; and an aggress- ,
ive goals program was not in place. As a result of these problems, l
the Order was not closed out. J
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Although the licensee had reorganized its Radiation Protection )
Organization last assessment period to provide for better oversight {
of in-field radiation protection activities, the failure to fill the
vacant Chief Radiological Engineer position in a timely manner was !
considered a significant detriment to establishing effective over-
sight of these activities. Tne position was open for about a year j
and reflects limited action by both :,ite and senior corporate manage- j
ment. The individual filling the position is responsible for manag- q
ing these activities. The position was filled late in the period, a
In addition, the licensee initiated personnel movement in the organ- l
ization to further 11nprove oversight of in-field activities. Staff- a
ing is considered adequate to implement the program.
Although the licensee essentially revised all program procedures to
improve their quality this period, NRC monitoring of the development s
of new and revised program procedures this assessment period con-
tinued to identify numerous problems involving establishnent of neak
and inadequate procedures. Repeated efforts by the NRC wre reqcired
to ensure adequate procedures were in place demonstrating a weak
licensee capability in the development of procedures.
l
The licensee subsequently took adequate action to resolve the prob- ;
lems. Contractor experts in the particular program areas (e.g. !
internal dosimetry) were requested to review program elements and
procedures. Improvements made were appropriate. Revised procedures
were field tested prior to use. Improvement in procedure quality was j
noted at the end of the assessment period. These procedures were j
adequate to implement program elements. l
l
The licensee completely revised the radiological controls corrective I
action program. The program now includes provisions for root cause
analysis and timely implementation of corrective action to prevent l
recurrence. Radiological Occurrence Reports generated by the program I
are tracked by computer. Summaries are provided to station manage-
ment. Although corrective actions were being identified, NRC review
found that, due to problems (e.g. inadequate communications), the i
actions were not fully implemented or were, in some cases, inadequate
due to weak root cause analyses. Two violations involving failure to
frisk vehicles leaving the site and inadequate high radiation area
controls were issued specifically due to failure to implement ade-
quate, timely corrective actions. The licensee's failure to ensure
adequate corrective actions for identified problems continued to be a
chronic problem demonstrating lack of adequate site middle and upper
management attention to personnel adherence to procedures and lack of
well thought out corrective actions.
r ,
.; . ,
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26.
. . .
The- licensee established and implemented a procedurally-described
~ ALARA (i.e., maintaining radiation doses As.J.ow As Reasonably-
D
Achievable) program.' However, NRC review of .this program found a
Tack of an aggressive ' goals program, . inadequate job monitoring pro-
-
visions, ' weak interfaces between the program and the radiation work
permit-. (RWP) program .and non-uniform implementation. The licensee.
corrected..the majority of 'the NRC concerns in a timely manner.
The licensee issued about eighteen procedures covering all major as- '
,
pects of the ALARA Program. However, interface .of the program with
L the RWP program continued to be weak. For example, 'NRC review of- !
'
fuel pool clean-up modification work found examples of unclear under-
-standing between the operational radiation protection group, .the
ALARA group, and the maintenance group regarding the method of work
performance. As a result, unneccessary discussions were held in a
high radiation area. -
Performance in the area of ALARA was non uniform. Despite problems [
with some jobs (e.g. fuel pool work), the ALARA controls on other l
work (e.g. drywell work) were commendable. Non-uniformity in program. !
implementation was ' attributed to lack of updating ALARA reviews when i
the job-scope'or work methods changed. Lack of uniform implementa-
tion of the ALARA program is considered a significant program
weakness.
The radioactive and- contaminated material control program has been m
upgraded. A management policy (Radioactive Material Control Plan)
was established. The plan demonstrated senior corporate management ;
commitment for controlling this material. A further indication of. i
management concern involved the extensive decontamination of the
plant. Major areas of the plant have been decontaminated allowing 3
!
entry without protective clothing. Licensee initiatives in .this area- i
were aggressive. d
1
Regarding facilities and equipment, the licensee is currently modify-
ing its access control point to better control access to process
buildings. About eight high sensitivity portal monitors have been
installed for personnel contamination monitoring. In addition to
4
this major work effort and equipment purchase, the licensee has pur- -{
i
chased several high sensitivity, state of the art whole body coun-
ters. These major investments in facilities and equipment demon- l
a
strate management's efforts to upgrade outdated facilities and 1
equipment. 1
Effluent Monitoring and Controls I
Reviews in this area last period identified problems with unmonitored
releases and failure to perform a surveillance for an effluent mon-
itor. A deviation from a licensee bulletin commitment and violation 1
were issued respectively. Reviews this period found that adequate ,
corrective actions were taken. l
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1
1
1
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Review this period indicated effective implementation of the effluent
monitoring and controls program. No violations were identified this
period. . Liquid and airborne release records, procedures, instrument
calibrations, audits, and Offsite Dose Calculations Manual implemen- i
tation were adequate. Three licensee event reperts (LERs) were sub-
mitted during this assessment period, all were of minor safety sig-
nificance. -Two of the LERs, however, indicated a potential minor
programmatic breakdown in the implementation of current effluent
Technical Specification surveillance requirements and new require-
ments brought about by Technical Specification changes. The licensee
has implemented a review of Technical Specification surveillance ,
!
requirements in order to ensure that all requirements are being and i
will be met.
During this assessment period the environmental monitoring program
was found to be generally adequate. However, problems were identi- j
fied in the licensee's environmental thermoluminescent dosimeter {
(TLD) . program. Commitments made by the licensee during previous '
assessment periods to improve the environmental TLD program were not !
implemented. Because of these problems, the validity of the environ- ;
mental TLD data cannot be assured. This indicated lack of management i
involvement in this area and a lack of understanding and thoroughness l
with regard to resolution of technical issues. l
Transportation
,
No problems were identified in this area last period. During this
period the licensee'_s transportation program has exhibited a decline
in performance. One' Severity Level III violation was issued as a
result of a shipment receipt inspection performed by the State of 1
South Carolina, which resulted in a $1000.00 Civil Penalty assessment i
by the State. A radwaste shipping package was found with a hole in
it at the burial site. This violation indicated a lack of quality
assurance involvement with radioactive waste transportation
activities.
Two Severity Level IV violations resulted from an onsite inspection i
performed approximately three months after the inspection by the
State of South Carolina. The violations involved failure to document
radiation surveys and failure to determine if certain waste types
shipped to the burial site were properly dewatered. Again, the vio-
lations indicated a lack of quality assurance involvement with radio-
active waste transportation activities, i
Licensee's response to the violations indicated the intent to perform
programmatic reviews as well as institute improvements in the radio-
,
active waste transportation program to correct the violations. This
was an indication of increased management attention and commitment to
this area during the period.
[f ..
18-
.o
. Summary-
L.
The licensee made numerous improvements in the overall quality of the
radiological controls program. These included substantial upgrade of
' program _ (e.g. ALARA Program) procedures, staffing .of key vacant'
positions, significant- reduction in the number and extent of contam -
inated. areas in the plant and development of a Radioactive Material
-
Control: Program. However, implementation -of the program continues to
be weak. In addition, when problems with program implementation or
adequacy are identified, corrective actions are . sometimes not ade-
b .quate. or not implemented resulting .in- the need for further NRC! ,
involvement.- In the area of effluent monitoring and control, the
L~
licensee implemented the new effluent technical specifications in' a
: generally acceptable manner, however, failure to take action on-.sig-
' nificant long standing deficiencies in the environmental TLD program
detracted from the good effort. In the area ,of 'radwaste transporta-
tion, a decline in performance from the previous period was noted,'
The decli.ne . was attributed to ineffective involvement by the QA
group.
(2) Conclusion
Rating: Category 3
Trend: None
(3) Recommendations
. Licensee: --
Aggressively supervise the radiological controls
program.
--
Establish and implement measures to verify pro .
gram implementation and implement corrective
actions for deficiencies.
--
Interactions with personnel outside the radiolog-
ical group should be significantly strengthened.
NRC: --
Continue increased inspection coverage in this
area.
--
See Section 3.2.
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19
4.3 Maintenance (18%,1196 hours)
(1). Analysis
Plant maintenance performance was assessed as a Category 2 dur-
ing the previous SALP period. Weaknesses were identified in the
control of vendor information,' repair of control room equipment
L
not required by - the technical specifications, scheduling of
second priority maintenance, scheduling of preventive mainten-
ance, and maintenance staffing. These problems have all been
addressed during the current period, but have not been fully
resolved.
During the current SALP period, ongoing maintenance activities-
were routinely reviewed. Inspection activities included exten-
sive review of maintenance programs and records and witnessing
of maintenance work in progress. Maintenance activities were
also reviewed in a safety system functional readiness review, a
Region I diagnostic team inspection, an Augmented Inspection
Team (AIT) team inspection, and a. special team- inspection to
review the licensee's response to Generic Letter 83-28.
Maintenance staffing remained a weakness. First line super-
vision vacancies in electrical, instrument and controls, and
mechanical maintenance sections . existed during most of the per-
iod. Qualified lower level personnel did not in many cases
apply- for the supervisor vacancies. This hindered the staffing
process and indicated a potential weakness in the licensee's
personnel recruitment and development practices. Lack of pro-
fessional support also limited the ability of the maintenance
organization _to respond to vendor, industry, and NRC informa-
' tion. While high. priority maintenance issues were~ effectively
reviewed, development of programmatic improvements such as
trending and preventive maintenance were impeded. The licensee
responded to these problems by establishing a Section Head level-
position responsible for maintenance and by adding three main-
tenance staff engineering positions. The_ licensee also plans to i
restructure maintenance management to reduce the work load of '
line supervision. In addition, contractors were being used
extensively to supplement the maintenance staff. The adequacy-
of maintenance staffing is a crucial issue that deserves con-
tinued plant and corporate management attention.
Extensive overhaul of the core spray and RHR pumps was accomp-
lished by a special vendor team. This team also supplied its
own QA staff. Review of the work indicated it was performed i
acceptably. All work was accomplished in accordance with licen- !
see approved procedures. {
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The: licensee's approach to maintenance . activities was cautious
,
and; conservative.' TJne-time equipment failure evaluations: -3
I , 7' '
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'
; ever, completion of ' evaluations was slowed due to limited tech- l
Enical resources'and root cause evaluations of recurring problems
were sometimes weak. ' M-sintenance trending of equipment problems.-
was limited in scope and .not always. effective. For example,
~
1
. recognition Lof the consequences of repeated failure of the
safety-related valve motor operators and , motor operatori valve
j
{
bolting occurred.only in- response to NRC questioning - The lack l
of a formal program of maintenance trending denied.the licensee ~i
' ' 'T important insights into equipment performance. and impeded
development _ of an effective preventive maintenance program.
O Programs in place for resolution of technical issues appeared to , '
be comprehensive. An example of a . recurring problem. however,
,
.was multiple recirculation _ pump motor generator. (MG) set (ATWS)
breaker failures. This is an important issue that deserves. 4
continued. site management attention. _ The physical condition ofL
equipment in the MG set breaker control cabinets was permitted
- to deteriorate. through exposure to water and debriss There was
evidence: of internal ' corrosion of relays and other components.
While the scheduling of '"A" priority maintenance was considered '
good, the scheduling of second and third priority ; maintenance !
was a weakness identified in the' previous SALP period. Although
the licensee staffed a maintenance planning section during the
last SALP period, maintenance planning 'and priorities continued
to be a problem. For example, 'the' prolonged downtimes on both
the shutdown cooling instrumentation and the feedwater system
limited operational flexibility unnecessarily. In addition, the.
licensee had difficulty in completing lower priority,-harder-to-
do jobs. The control air. dryer high moisture alarm in the con-
trol' room is faulty. This was identified in May 1983 and as of
February 1986 had not been repaired. The ."V" salt service water -
pump heaters have been inoperative since November 1985. The job-
has been incomplete because of a lack of "Q" documentation for' a
.
new motor. Each of these jobs are examples of maintenance for
'.. which 'there appears to be no one in charge and no clear resolu-
tion of problems associated with the job. Fire protection and
security equipment down time during the period was also excess-
ive, due in part to poor maintenance prioritization. Inadequate
planning in one case, caused an unnecessary engineered safety
feature (ESF)- system actuation during performance of an
Appendix R modification. The ' planning difficulties did not
hinder first priority safety-related work which was conducted j
promptly.
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'Duringi~the previous SALP period the maintenance ' backlog was
-identified as a significant . problem. . This problem continued l
into 'the early part of this SALP period with little corrective l
- action taking place. .Early in this 'SALP period, a diagnosite
; team inspection noted that in addition to the backlog._a high
percentage of old maintenance' requests (MR's) had been lost and
there was virtually no system for' tracking MR's. While high
priority maintenance was getting done, medium and low priority
jobs were being poorly tracked with'little to assure. that they
would be done in- a timely manner or be done at all contribut-
ing further to the already large backlog.
-To' correct these problems, the licensee established a- mainten-
ance planning section. The maintenance planning. section has
been effective in collecting and reviewing the large number of
backlog maintenance requests (MR) in the station. However, it
was only marginally effective in planning and scheduling daily
maintenance activities during much of the period because the
planning function had not been integrated into the work' recuest
process. This was due, in part, to a slowness in' the issuance
of instructions for the planning group and other maintenance
sections. These instructions had been under development ' for
most of the SALP period but had not been issued for use by the
end of the period. .The licensee started holding periodic inter-
disciplinary planning meetings and issuing-period planning docu-
ments near the end of the period, showing management attention
to this area. Recently, new computer-based scheduling tools
have been acquired, which aided the planning effort. Signifi-
cant progress in planning was noted during the last month of the
period, which indicates that management attention to this' group-
is beginning to'have its desired effect.
The licensee made substantia 1' progress in the area of control of
-vendor information during the period. A program was established
to compile vendor. manuals, validate the accuracy of the manual
content and assign control numbers. .However, vendor information
continued to be received by many individuals in the company,
some of whom may not always recognize the need to update vendor
manuals. Although the licensee plans periodic vendor manual
audits, the decentralized method of receiving and reviewing
vendor information appears weak and should be evaluated for
effectiveness.
The scope and administration of the preventive maintenance (PM) -)
program were weaknesses noted during the last assessment period. j
Subsequent management attention to this area was evident, al- l
though weaknesses were not fully resolved. Preventive mainten- i
ance procedures for safety-related motor operated valves and the )
emergency diesel generators have been established. Additional I
NRC prompting led to the development of a PM program for 480 VAC
molded case circuit breakers.
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An extensive motor operated valve (MOV) refurbishment program l
continued through the period. This shows initiative and demon- l
strates an aggressive maintenance management approach.. However, j
other MOV maintenance was sometimes ineffective, due to a lack
l
of detailed instructions and an over reliance on " skill of the !
craft" knowledge. For example the safety system functional j
inspection found that MOV torque and limit switches were not 1
being set consistently due to a lack of detailed instructions. 1
J
Difficulties in the procurement system were identified early in
the SALP. Problems with purchase order (PO) determinations and
the reliance on offsite groups for evaluation of the P0 caused l
extensive delays in the purchase of equipment. Problems were i
also observed in assuring that parts, once received on site, J
were promptly distributed to the correct people. To correct (
this problem, the licensee established an onsite procurement
group to expedite the purchase of materials for high priority ,
maintenance. Evaluation at the end of the SALP period has shown !
that the addition of this group substantially improved the !
licensee's ability to promptly obtain needed parts, reducing the q
time important equipment is inoperable. Currently, the procure- l
ment process in impeded by lack of staffing. The licensee has '
added contractor support to this group to help with the outage
workload and is considering further full-time staffing to assist
with the non-outage workload. The effectiveness of the procure- j
ment group is important to the long-term reduction of the main- !
tenance backlog.
Maintenance program procedures were weak. Many of the adminis-
trative procedures contained only minimal information. The ,
maintenance request procedure for instance discusses how to fill
out an MR but says little else about the process of handling 3
maintenance activities. There were no administrative procedures !
for the newly formed maintenance planning, scheduling and pro-
curement support sections.. At end of the SALP period the licen- !
see had written and was close to issuing newly established main-
tenance program procedures.
In summary, although maintenance actions were generally per-
formed adequately, maintenance organization staffing and work
prioritization and planning remained weaknesses through much of
the period. Vacancies in first line supervision and the short-
age of engineering support have affected performance in this
area. Maintenance program procedures need further development.
The new maintenance planning and procurement groups appeared to
be more effective at the end of the assessment period, reflec-
ting significant licensee resource commitments to these areas.
--
.-
.
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23
[.. .!
- -
(2) Conclusion
Rating: Category 2
Trend: None
(3) Recommendations .
Licensee: --
Improve communications between maintenance and
other site organizations.
--
Increase the effectiveness -of maintenanea~
!
planning. -l
--
Continue program improvements in the area of pre- t
ventive maintenance and vendor information i
control. '
,
--
Consider development of a monitoring 'rystem for
maintenance performance. '
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@C: None - ~
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p Surveillance we assessed as a .Cctegory 2 during the previous
N SALP period. . heak.wsses in the areas . of startup test schedu-
e ling, test adequacy,1 comp 11ance with procedural requirements and
i
,
response t abnormal? test results were obse hed.
During Lt 4 current assessment period, NRC- inspectors observed
'
testing, pierformed detailed reviews of procedures, and evaluated
n test results. In addition, reviews of prosram ' administration
and the measuring and test equipment-(M&TE) control program were
p A- reviewed. Sur{efilance testing was also evaluated during two
special team inspections.
Surveillance testing was generally con:fUcted in a: careful,
"' , safety conscious manner. Coordinatio'n bv60en the. control room -
. staff and persons conducting testing ~was facteworthy. Surveil-
y lance test procedures were generally fo1106ed.. Exceptions.in-
p 3
'
cluded explosive ' squib valve - tests, dacwontation. of system
.,
restoration, and independent verificatiot. These' exceptions
indicated that additional emphasis should be.placed on procedure
adherence, i ., ,
'
.No. centralized programmaticidescriptionc el the development,- :
maintenance 'and implementation of the $6cveillance test program l
existed. Responsibility for the reviou s.nd upgrading of pro-
ceduresi and the evaluation 6f respits .and~ trending were not
'
clearly defined and appeared distributed throughout the site-
'
organization. This programmatic ' weakness has been exacerbated
, ., .
by the command and control proble'rs evident in the existing site
e organizational istructure. The absencL off clear guidance and a
^
' technical focus for the program' contr%uted to development .of.
h,
procedures _which were not always st#Jard in format, did not
, ,,
, contain accurate referenc?s to technical specifications, and did
-
not always fully implemer.t
a
technical specifications requirements.
-
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' ' The system for- c6ntrol of 'turveillance scheduling was weak, i
M yed with this activ- i
. ; principally
ity was notbecade the key
a technical staff findividual
member. Thi invd weakness was reflec- !
ted in the sporadic perfn~cmance of the licensee's computerized -
'
scheduling system, the Master Surveillance Tracking System
7 $1STP). ' Similar problems were identPitt during the previous
#
assessment period.' During ,thir period ina! leak rate testing
'
'
.
'
, ,s of many primary containment isolatiol valves and calibration of
. safety-related undervoltage relays were not scheduled properly
#^ due to MSTP inadequacies. The MSTP was also ineffective in :
-
'
scheduling surveillance tests required based on operational con- ,
The licensee was slow to act in this
'
e ditions or plant events. !
0.' T area, despite repeatd NRC prompting.
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: Another recurring problem from the ' previous period. involved the
h; technical . adequacy- of- surveillance procedures. Several tech-
l
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- nically deficient tests were identified during the current per-
iod, including logic ' system functional testing. Repeated NRC l
b..
initiatives'were. required to'obtain meaningful corrective action
-
for some of these deficiencies. Subsequently, the licensee took
strong action' to identify and correct _ logic system functional
' test problems. However, other potentially deficient tests have
~
;
y not;been addressed.- In one instance, a technical specification
'
surveillance requirement-known to be deficient for about 6. years-
was -not addressed until it became a critical! path item- for the
~
~
current outage. Add.itional concerns.regarding the acceptability
of t'est' methods and test completeness were _ noted. In some cases
test procedures '.did not contain sufficient guidance and . con-
trolled documents within the- nuclear organization did not
specify many safety-related settings for electrical equipment,
' Although no examples of uncontrolled changes to the settings
%n; were identified, the latter problem could have allowed- safety i kg a related_ settings t to be changed: without a formal. plant design j f
change. ; Independent. verification of system restoration in test ,
procedures was_ inconsistent and in some cases . improperly .per- j
formed.
< _ 1
The . licensee's program- for _ control of measuring and test equip-
,
ment (M&TE) was ineffective. Out of calibration instruments
were notf properly segregated from useable instruments, As a
result, several instances of use of M&TE beyond its calibration
~
j
due date were noted. Eighteen examples of failure to conduct
investigations to determine the impact of out of calibration
M&TE were- identified during a single NRC inspection. These
concerns accentuated the ' need for additional site management -
attention to the M&TE control program.
i
'
,
The licensee has experienced ' continuing problems meeting the
as-found total local-leak rate acceptance criteria. The" largest
contributors to local leak rate. test (LLRT) leakage, the main ;
steam isolation valves (MSIV) and feedwater check valves, were ;
extensively overhauled during the 1984 outage. This licensee ;
initiative greatly reduced but did not eliminate MSIV leakage. '
The licensee has established a team to investigate problem com-
ponents, identify the root cause of the leakage, and recommend j
corrective action. These efforts show -initiative in addressing j
-a generic industry problem. Aaministrative control over LLRT. ?
activities improved during the period.
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In: summary, individual surveillance tests were well conducted
and controlled.' The response to recurring. local leak rate test . 1
(LLRT) failures was also positive. However, the licensee has
been slow to recognize and ' correct weaknesses in the control of.
the program and in the scheduling'and technical adequacy of.sur- i
-ve111ance tests. This lack of progress is reflected. in the '
large number of surveillance-related licensee event reports and
NRC violations issued lduring the current period. The control of-
-the program 'is. fragmented and not' always effective and ' appears j
to depend more .on historical past practice than . on . a : well - !
..
founded, systematic approach. This is a major weakness that '!
must .be corrected. The licensee's M&TE control program also -
rieeds improvement.
It should :be noted that. licensee ' performance in this functional
ar'ea _has ~ not degraded during this period. -The difference in
conclusions between this and the ~ previous period is due to re '
curring' problems .which focused concerns on underlying program
. weaknesses. Inadequate action by. site and corporate senior
management' during most of the period was also factored into the
rating decision. .Significant progress 'in one portion of the
' surveillance program,
'
i.e., Emergency Safeguards Feature L (ESF)
logic system functional testing, was apparent at the end of the
period.
(2) Conclusion
Rating: Category 3
Trend: None
(3) _ Recommendations
Licensee: --
Significant site and- corporate management atten-
tion . is needed to correct deficiencies in this
area.
--
Place a single qualified individual in overall
charge of the surveillance program.
NRC: --
Conduct a comprehensive inspection of- the sur- ;
e ve111ance and calibration program prior to. i
-
startup.
j
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4.5 Fire protection (6%, 413 hours)
(1) A_naly si s
The area of fire protection was not evaluated as a separate ,
functional area during the previous assessment period. However, '
the Region I diagnostic team inspection identified significant i
weakness in this area. During the present period several i
inspections reviewed this area. A management meeting was also
held during the period to discuss fire protection program
deficiencies.
The fire protection program has relied heavily on compensatory !
measures. This reflected a lack of site and corporate manage-
ment aggressiveness in maintaining and improving station fire .
protection equipment. For example, the diagnostic team inspec- l
tion noted there were over 250 outstanding maintenance requests !
(MR) on fire protection equipment. The inspection also noted
that there were 72 locations in the plant requiring fire ,
watches, many for broken equipment. Fire suppression systems in !
three of five plant areas (where these systems are required) had
been out of service for extended periods of time. In these
cases, the licensee relied on fire watches for long periods to
compensate for the out of service equipment. Although the fire
watches were an acceptable compensatory measure, the failure to
promptly restore fire equipment to service is a problem. Early
in the assessment period, a project engineer was assigned to
reduce *' ation dependence on compensatory measures. The effort-
initially resulted in improvement however continued identifi- :
cation of degraded components has more than offset this gain.
Personnel performing fire watch duties received little training
and as a result did not always perform the required tours. Site ;
management followup to this problem was weak, requiring signif-
~
icant NRC involvement. In one case the licensee identified 17
instances of missed watches in a 24-hour period, but took no
significant corrective action until prompted by the NRC. In ,
addition, the licensee had not decided by the end of the period i
whether previous guidance to the fire watches on fire fighting !
would be continued or revised. This decision should be made and
the fire watches trained appropriately.
Licensee site management has been ineffective in assuring the
quality of fire brigade training. Training records were frag- l
mented and poorly used. Many brigade members did not partici- ;
pate in brigade drills or quarterly training sessions as re- !
quired by NRC regulations. Drill objectives and assessments
were vague. Periodic drills were incomplete and poorly run.
personnel serving as brigade members were not fully trained in
use of the onsite fire truck, further indicating that the
brigade training was weak.
_ J
# .a
[e- W 28-
Fire barrier surveillance procedures were unclear and incom-
.plete._ ' Weak licensee action allowed this condition to exist for
a considerable period of ' time. The licensee'has recently imple-
mented.an extensive station fire barrier walkdown program. This-
' program has identified numerous barrier, penetration seals with
inadequatei documentation, degraded seals, ' and seals not. cur-
rently included in established surveillance procedures. . Con-
tinued effort is needed to address this long' standing problem.
The licensee took steps at th2 end:of the period to strengthen
the fire protection program. A new fire protection- management
position reporting' first to the Plant. Manager and 'later to the
Vice President of.. Nuclear Operations was. created and filled.
Staffing in-the area has been substantially. increased with indi-
. viduals assigned to provide fire brigade training oversight and
to maintain equipment and maintenance priority status. However,-
these actions were slow in coming and . program weaknesses were
still- present at the .end of the period. Recent fire protection-
problems include missed and inadequate NRC reports and a failure-
to compensate for . loss of redundancy in - the fire protection
system.
In summary, the licensee has been slow to strengthen the fire-
protection program. Problems included inadequate surveillance-
procedures, degraded fire barriers, inoperable' fire protection
system equipment, and poor quality fire brigade training. A1-
though action has been taken to address these concerns, the pro-
gram has suffered.from a chronic lack of attention and should be
closely monitored.
(2) Conclusion
Rating: Category 3
Trend: None
(3) Board Recommendations
Licensee: --
Significantly reduce the amount of inoperable
fire protection equipment in the station.
NRC: --
Schedule periodic topical meetings with the
licensee to discuss program improvements
--
See Section 3.2
i L-..m....c.
...
29'
4.6L Emergency Preparedness (4%, 249 hours)
(1) Analysi s
During the previous assessment period this area was rated. as
' Category . 3.
.
Programmatic weaknesses in the organization and
.
administration of the emergency preparedness (EP). program, an
inadequate emergency operations facility (EOF), and exercise
deficiencies resulted in marginally acceptable performance dur-
ing the 1985 annual exercise. Four Category A deficiencies were
observed offsite by the Federal Emergency- Management Agency.
(FEMA), and two onsite areas of concern were noted by NRC ob-
servers. A remedial _ exercise was held in October,1985 to re-
solve - the offsite deficiencies. Onsite areas of concern were
satisfactorily resolved during January and April of 1986.
1
During the current assessment period, one partial participation
exercise was observed, two routine safety inspections related to
follow-up of deficiencies identified during previous emergency
preparedness inspections were conducted and a remedial emergency
drill was performed to demonstrate effective control of radia-
tion exposure to re-entry personnel entering high radiation i
areas. .Throughout this assessment period the licensee has shown
-increased' responsiveness to NRC initiatives . and concerns as
-
evidenced by frequent discussions, meetings, work activities and
' successful closeout of all past open items. One area of inade-
'
quate corporate management attention was preoperational. testing
of the air filtration system at the EOF.
A partial participation exercise (including .NRC Region I parti-
cipation) was conducted on December 10, 1986. The licensee's
performance was significantly improved over the . previous exer-
cise. Actions by plant operators were prompt and effective.
Event ' classification was accurate and timely. Personnel were
generally well trained and qualified for their positions. No
significant deficiencies were identified.
The following factors have . influenced - the noted improved per- j
formance in the area of emergency' preparedness at Pilgrim. They a
are indicative of a high degree of licensee management atten- !
tion. j
-
Increase in EP staff from one part-time position to four
full-time positions.
-
Authorization to increase staff by three additional posi- i
tions (as of January 1987).
-
Contracting of an experienced EP consultant firm to assist
in everyday planning and exercise development. ,
;
.'{,.h
,
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30
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Completion of a new Emergency Offsite Facility ' (EOF), .
Technical Support Center (TSC), and Operations -Support
: Center (OSC) complex.
-
Participation in . management meetings, both in the ' region
4
-F and at Plymouth, to ensure intent and direction.
-
Participation at Exercise Entrance Meeting, and observation
' of the exercise, by both the Chief Operating Officer and
the President.
-
Increased training of key managers, ' assistants and staff.
-
Performance of several drills ~ and exercises to . test imple-
mentation of their emergency plan.
-
.The licensee has openly committed to a level of excellence,
and hes stated that their goal is to have the model EP-
program in NRC Region I.
'
-
7% ~ 11censee has made an extensive effort to gain the co-
operation of offsite officials and to provide the resources.
necessary to address offsite concerns even -though. efforts
to date have not been effective.
The licensees performance indicates that its training program
has ' been effective. Management involvement has been increas-
ingly effective, as ividenced by timely completion of corrective
actions and the addition of improved hardware and EP staffing.
The licensee has t qn responsive to NRC concerns and has made
considerable progra s in this area.
(2) Conclusion-
,
Ratirg:
n Category 2
Trend: None
(3) Board Recommendations
Licensee: Continue to pursue resolution of off-site issues.
,
NRC: None
!
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1
4.7 Security and Safeguards (4%, 282 hours)
The previous SALP identified serious NRC concerns regarding the
licensee's awareness of, and attention to, NRC physical security
objectives and the need for additional management attention to, and
support of, the security program to 1.1sure that the program was pro-
pe.rly implemented. The previous SALP also identified NRC's belief
that the licensee had initiated actions to resolve those concerns and
that the security program was receiving increased management atten- i
tion. However, shortly after the beginning of this assessment per- !
Tod, it became apparent to the NRC that, due to the number and com- 1
plexity of the identified problems and some other problems which were 1
then surfaced, far more extensive management attention and resources.
would be required. As evidenced during this assessment period, the
need for additional attention and resources by the licensee continued
until late in this assessment period. As a result, little physical ;
progress toward improving the program was accomplished by the licen- l
see during the period. I
1
Two routine unannounced physical security inspections and one special ~
inspection were performed by a region-based inspector during this
assessment period. Routine resident inspections continued throughout
the assessment period. Eight areas of significant concern involving
major long standing programmatic weaknesses were identified during a
special inspection in March,1986. That inspection was performed to
review the licensee's corrective actions on several long standing
problems previously identified by NRC. Three management meetings
between NRC and licensee management were conducted during the period
to review progress on correcting the identified programmatic weak-
nesses and of the security upgrade program implemented by the licen-
see to address those weaknesses. During a management meeting on
January 13-15, 1987, it was agreed that progress was being made;
however, corrective measures were not complete for any of the eight
areas of concern.
At the beginning of the assessment period there was only one member
of the licensee's staff assigned to security on a full-time basis. '
.
This resulted in minimal oversight of the contact security force,
insufficient input to management on program problems and decision
making by management based on that input. This caused inadequate
and/or ineffective corrective actions on identified problems and a :
general unawareness, on the part of the licensee, regarding program I
implementation and security force performance. During the assessment ;
period the licensee took steps to expand its security staff and, by i
i
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32
the end of- the assessment period, the licensee had a security staff
of seven. The impact. of the increased staff has not been fully
realized- since orientation .and training necessary to qualify newly
hired personnel. has not 'yet been completed. However, the licensee's
action to expand its security staff is an indication of its commit-
ment to improve .the security program.
The eight areas of significant concern identified in the March,1986
Special Inspection indicated major programmatic problems that affec-
ted many components of the security program. Due to the ineffective
and prolonged implementation of . corrective actions, the licensee
resorted to the use of long term compensatory measures, consisting
,
primarily of security force personnel. ' Because of the extensive use
of compensatory measures and because. the contract security force was
"
understaffed, security personnel were forced to work an excessive
amount of overtime. The NRC expressed concern about .the excessive
overtime being worked, and in July 1986, the NRC identified security
personnel that had worked as much as 88 hours in a 7 day period. At
that time the licensee implemented a system to limit personnel to a
maximum of 72 hours in a 7. day period. The licensee also implemented
plans to increase the size of the guard force.to further relieve the
overtime problem.
Prior to -and early in this assessment, resolution of NRC-identified
problems was often delayed due to an inadequate understanding of the
scope of. the problems, insufficient knowledge of how to solve the
problems and lack of corporate engineering and security support.
During the assessment period, problem resolution was given increased i
senior corporate management attention and increased corporate sup-
port; however, due to the magnitude of programmatic problems, reso-
lutions were not yet effected by the end of the period. Toward the
latter portion of the period and in recognition that the existing
problems were even larger in scope than had been previously thought,
the licensee escalated the priority under which the security program
upgrades had been placed.
Audits of the security program conducted by corporate security per-
sonnel were complete and thorough; however, corrective actions were i
not always effective due to the previously mentioned lack of onsite 1
security staff, poor communications and followup between the corpor-
ate staff and the plant staff _ and a general lack of understanding of
NRC performance objectives by the plant staff. To rectify these
problems, the licensee has assigned, on a full time basis, a member i
of the corporate security staff to the site. Another responsibility
of that individual is to conduct an ongoing surveillance / audit of the
program. The NRC did not assess the effectiveness of the licensee's
,
i
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*
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33 ;l
l
"
audit program improvements during this period. The security force i
training prograin appears to be adequate to address routine activities ;]
at this time as indicated by only two reportable instances of per- 4
sonnel error. In those instances, post orders were not adequate to (
assure a clear understanding of the required duties. However, with ]
the magnitude of changes being made, the licensee should. review the
training program to ensure that it remains current and . reflects
. actual security practices.
A total of seven security event reports, required by 10 CFR 73.71(C), '
were. submittedL to the NRC during this assessment period. Three' event-
-reports were necessitated by the licensee's findings of degraded
vital area barriers. Such degradations had been identified by NRC
during the previous assessment period .and 'a civ11 penalty had' been
assessed. The first degradation was found during a. licensee review
to. validate the integrity of all vital area barriers. This' review .
was. being conducted as a followup to the violation which resulted in
the civil-' penalty. The other two degradations of vital area barriers
that required reports occurred when openings were icproperly secured
during work on plant systems that penetrated the barriers. Two other
event reports were the results of bomb threats; another was. the.re-
.sult.of a guard.found sleeping on post; and the last was the result
of guards that were posted as compensatory measures for failed equip-
ment, patrolling in the wrong area. The quality-of the event reports
was significantly improved over the previous asse:,sment- period; the
reports were promptly submitted, consistent, clear and generally
thorough. Corrective actions on the'second -barrier degradation were
not totally effective since a similar event occurred the next day.
However, the licensee appears to have sinc.e applied ' effective con-
trols to prevent recurrence.
During the assessment period, the licensee submitted one change 'to
the security ' plan under the provisions . of 10 CFR 50.54(p) and re-
sponded to the miscellaneous amendments to 10 CFR 73.55, codified by
NRC in August 1986. The plan change was forwarded. to NRC Headquar-
ters because of potential policy implications and it and the licen-
see's. response to the miscellaneous amendments are currently under
review.
The . security program has been made a priority item. The licensee's
on-site staff has been expanded from one full time security member
to eight, including a group leader who has previous nuclear plant
security experience. The new group leader is rerpensible for secur-
ity only. Extensive engineering resources have been applied -to. cor-
rect deficiencies and upgrade the security systems. Corrective main-
tenance to equipment and hardware has been undertaken and is sched-
uled to be complete prior to restart of the plant. Additionally, the
1
e
i
.. . - - - . , . , , _ . . --. - . ,
.. .
m- p L 1, ..'
t ,
-r
;
- licensee has scheduled further upgrades-and enhancements for security
.cquipment and hardware in the future. .These actions and management's
' increased and sustained level of attention to the program during the
latter portion of the assessment period are evidence of the' licen--
'see's intent to implement a quality security program. ;
'
In surrmary, the licensee has initiated actions to upgrade the secur-
ity program however, at the conclusion of this rating period, the
. hardware upgrades were not complete and the expanded security organ -
ization had not been in place for an adequate time to evaluate its
effectiveness. At this time, the licensee security program must
,
still rely heavily on the use of compensatory measures, consisting
primarily of security personnel. . The compensatory measures are
necessary because of long term problems affecting many components of
the' security system.
<
(2) Conclusion
'
Rating: Category 3
' Trend: Improving
,
(3) Board Recommendations
,.
Licensee: --
High level corporate and site management atten-
tion at the recently established priority level
for the security program upgrade should continue
in order to implement commitments and develop an
effective program.
NRC: --
See Section 3.2 l
l
--
Periodically meet with licensee management to
!
assess progress in this area.
J
c
1
...?^
,
__ . ____----------A
r
, , i
,m ..
' 35'
1
'4.8 Outage Management and Modification Activities (17%,1170 hours)
~
. !
.
(1) Analysis
v , H
Outage management was assessed as a Category 1.during the pre-
vious _ SALP period. Completion of an extended recirculation
system piping replacement outage and the subsequent restart were
found.to be cautious and well controlled. A significant. lack'of
! housekeeping control during the 1984 outage was indicated by the
discovery; of debris in a safety-related system. . An additional
1984. outage housekeeping problem was discovered during the cur-
"
rent period, i.e. debris in the main steam line isolation valves
(MSIV).
In March 1986, a reactor shutdown was initiated due to a reactor
vessel instrument line weld crack. The planning and control'of
the subsequent work, including engineering support, ALARA plan-
ning, and Operations Review Committee evaluations were well per-
formed. In April,- 1986 'a series of operational events resulted
'
9 in a protracted ' forced maintenance outage. Evaluations of the
operational events were performed in a deliberate manner,. focus-
ing on determination of root cause. Necessary repairs and mod- 1
ifications were carefully implemented. This_.' outage was con- '!
tinued for several weeks. in order to inspect and repair all. the'- l
residual heat . removal and core ' spray pumps. These activities j
were'also conducted in a safe, controlled manner.
The licensee decided, in July 19'86, to extend the ' April outage
into 1987 and include refueling, Appendix R modifications,- and
certain containment and station blackout enh.ancements. Other
major outage tasks included the installation of a . new plant
process computer; installation of an analog-trip instrumentation
system for safety-related reactor parameters; installation of a j
hydrogen generation. facility and a hydrogen injection system;
major overhauls of the emergency diesel generators, high press-
ure ' coolant injection turbine, reactor. core isolation cooling
turbine,. and the main turbine generator; reactor vessel . instru-
ment line modifications; control rod drive change outs; and a
large number of inservice inspections of safety-related and non-
. safety related piping. Because the refueling outage was init-
iated without the opportunity to preplan, the pace of activities
was initially slow. This cautious mnagement approach demon-
strated -a safety conscious attitude. Many outage activities
such as the inservice inspection program have also been well
'
run. The major increase in scope of inservice inspections in
the feedwater system and the drywell liner showed a prompt and
aggressive response to events at the other power plants,
d
l
b - . . . _ . . . . .
. .
1
36
C
l
As a result of these shutdowns, the reactor was in an outage for )
two thirds of the assessment period. The slow pace of progress j
made in correcting basic deficiencies in other functional areas, j
i .e. , fire protection, security, surveillance, maintenance, and 1
radiological controls, reflects an inability to effectively deal j
with these issues during outages. A poorly-defined onsite 'l
management structure during outages contributed to the lack of
progress. The assessment of this organizational weakness is not
included in this section, but is evaluated in Section 4.12, ,
" Assurance of Quality".
Major outage modifications such as installation of the analog
trip system and Appendix R enhancements were performed largely
without incident. However, increased attention to security
compensatory measures, isolations of major plant components, and
post work testing are needed. Although no specific problems
were identified the lack of programmatic guidance for post work
testing is a weakness that should be addressed. Also, the ad-
herence to post work test procedures should be improvec. Some
weaknesses wert identified in a contractor-installed modifica- )
tion to the en,ergency core cooling systems, suggesting the need l
for better BEco oversight of maintenance contractors. :
Plant Design Changes (PDC) were generally well controlled.
However, two potential _weaknesse's in the PDC process were iden- i
tified. The first problem was associated with a PDC for the
installation of a new refueling bridge, including refueling
interlocks. The Final Safety Analysis Report indicates that the
refueling interlocks have a safety design basis and are relied f
upon in the fuel handling accidant analysis. Although the
licensee does not currently classify this equipment as safety-
related, .it is clearly important and some QA involvement should
have been provided. Significant design and construction prob-
lems affecting both the bridge structural integrity and inter-
lock operability might have been avoided if more quality assur-
ance practices had been applied. The second problem involved
the use of a nonconformance report instead of a PDC for exten- i
sive residual heat renoval pump modifications. Although, in >
this case, either process could be used to control the work, the
apparent desire to avoid a PDC indicates that the process needs
to be reviewed by engineering management.
In summary, implementation of outage and modifications activ-
ities has been strong. Improvements should be considered in the
areas of security involvement with plant modifications, isola-
tions of major equipment, control of contractors, and post work
testing. The onsite outage management structure has been a
significant weakness that has probably hindered program improve- j
ments. The discipline engineering support for the outage was
good. Plant design change packages were adequate. However, the
lack of design reference documents is a continuing weakness that
should be addressed.
..; .,
,f' '
37
.. t.
~
'
(2)' Conclusion
Rating: Category 1
-Trend:
. None
:
(3) Recommendations
Licensee: None
,
NRC: None
i
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38
4.9 Licensing Activities
,
Licensing activities were assessed as a Category 1 in the previous
SALP period. During this 15-month rating period, the major licensing
reviews pertained to masonry walls design, qualification of automatic
depressurization system (ADS) accumulators, Generic Letter 83-28 ATWS
items, recombiner capability, fire protection, calibration frequen-
cies for instrumentation, a change in the K-ef fective limit for the
spent fuel pool, the annual time limitation on purging / venting of the
containment, and the safety parameter display system. Section 5.4
provides a list of active and completed issues. Following the
Commission's denial of a schedular extension beyond November 30, 1985 0
to complete environmental qualification of electrical components, $
BECo mounted an intensive effort which successfully met that
deadline. l
BECo's procedures for controlling its correspondence with the NRC
requires upper management involvement with all licensing activities.
In addition to the atten* to given to these matters by the engineer-
ing and operations executives, the chief operating officer is fre-
quently involved, thus amuring that top company management appre-
ciates their importance and a'llocates appropriate resources. l
During this rating period, the' licensee has been slow in providing
additional information needed by NRR to complete its review in
several areas. As an example, the licensee's responses to the
Detailed Control Room Design Review (DCRDR) and relief from the
requirements for purge and vent lines to be automatically closed on a
containment high radiation signal are overdue. The latest update of
the Pilgrim Long Term Plan (integrated schedule of plant modifica-
tions) is also overdue. As part of a reorganization of the engineer-
ing department, the licensing group was recently put under the man-
ager who is also responsible for the engineering group which provides
most of the analyses supporting licensing requests. This move has
resulted in more expeditious handling of licensing issues. Another
area where the licensee should have acted earlier is in the area of
the control room high efficiency air filtration system surveillance
requirements. The technical specification (TS) had been known to be
incorrect for several years but had not been corrected. This re-
flects a continuing weakness in processing administrative changes to
the Technical Specifications.
The licensee has a competent technical staff whose efforts are sup-
plemented by consultants as needed. Both management and staff per-
sonnel participate in the activities of industry organizations such I
as Boiling Water Reactor Owners Group (BWROG), Industry Degraded Core
Rulemaking (IOCOR) and Institute of Nuclear Power Operations (INPO) '
and thus benefit from sharing knowledge of technical issues and
operating experience. Consultation with the staff has also been
( i
1
;
)
39 !
frequent and' beneficial to both parties. As a result, the licensee's l
submittals and presentations normally demonstrate a clear understand- J
ing of technical issues and the proposed resolutions are conservative j
from a safety standpoint. A good example of this is the planning of )
provisions to assure containment . integrity in the event of an acci- j
dent. The licensee is planning several enhancements to the Mark I I
containment including modifications that would permit direct venting I
from the torus to the main stack, modification to the containment {
spray nozzle, firewater intertie to the residual heat removal system, !
and the addition of a third diesel generator. The licensee has also
taken the initiative to complete the BWR permanent hydrogen water
chemistry installation. Hydrogen water chemistry is an effective- !
method in arresting pipe cracking and the pipe crack growth rate. '
The licensee maintains a large licensing staff which nn usually been
responsive to NRC initiatives in a timely manner. The numerous i
changes in organization and personnel during this rating period and !
the necessity of dealing with higher priority matters related to the j
present outage have contributed to delays in providing additonal !
information requested by NRC (i.e., licensing matters such as single- i
loop operation, independent verification of valve and instrument set- i
tings, fire protection TS changes, inservice inspection relief re- !
quests, DCRDR and automatic closing of vent / purge valves on a high !
radiation signal). The licensee's quality of license amendment re- t
quests, especially the "no significant hazards consideration" im-
proved significantly after the " counterpart" meeting held on January
30, 1986 in Bethesda, where this topic was discussed in detail. The
licensee has responded promptly to various surveys conducted during
the reporting period. The licensee was an active participant at the
NRR counterpart meetings in January and October 1986.
In summary, management attention and involvement was aggressive in
certain areas. This was particularly evident in BECo's commitment in
Mark I containment enhancement modification and hydrogen water chem-
istry installation. However, weaknesses are present which inhibit
the licensing process, including: slowness in providing information i
to NRC to close licensing issues, late submittal of the Long Term
Plan, and slowness in clarifying and correcting the Technical Specif- l
ications. Towards the end of this rating period, some improvement in
the area of licensing activities was noticed. !
(2) Conclusion
Rating: Category 2
Trend: None
(3) Recommendations !
Licensee: None
NRC: None
}
_ _ _ _ _ _ _ _ _ _ _ - _ - - - - - I
,
, .
.]
;
. .
.
'
40 I
-!
'4.10 Engineering and Corporate Technical Support
(1) Analysis
During .this assessment per,iod, engineering and corporate tech-
nical support are being' considered as a separate functional area
.for the first time. The various aspects of this functional area
were discussed in other functional areas in this report and the }
respective inspection hours were included in each one. Conse-
quently, this is primarily a synopsis . of those assessments.
Offsite technical and engineering support. was generally good
during the period, as indicated by the successful completion of j
i
the Environmental Qualification (EQ) program and the design of
several significant plant hardwa** - modifications. . Engineering
management was . actively involved in site activities and re-
sponded promptly to NRC questions and concerns. An example of !
this interaction was the strong site support shown during the !
followup to the two scrams and residual heat removal. (RHR) '
pressurization events in April 1986. Additi.onal engineering
support for maintenance procurement was evident, which aided
site maintenance activities.
The licensee reorganized the Nuclear Engineering Department
(NED) at the ' end of the assessment ' period, shifting from an
engineering discipline - oriented organization to more of a site
support organization. The field engineering office was expanded
in the reorganization and the licensing group was placed in NED.
Following the assessment period, the compliance group was also
e
added to NED.
Significant plant modifications were designed and partially
installed during the period, including a new plant process com-
puter, an. analog trip system for reactor safety equipment, a
hydrogen water chemistry- system, and extensive 10 CFR 50
Appendix R fire protection modifications. Few problems were
identified with these projects, demonstrating .the quality of the .l
engineering work. In response to NPC concerns, engineering sup- '
port for the security and fire prots tion projects was increased
and this should help resolve long-standing hardware. problems in
these areas.
Engineering analyses were generally complete, technically sound,
and showed an adequate regard for nuclear safety. Two except-
<
ions were noted involving differenti.a1 relays for the emergency
diesel generators and an RHR block v61ve on a torus cooling
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line. In.these cases,.the engineering analyses were superficial
- and did not probe underlying safety issues. The initial engi-- ,
neering evaluation of single failures in the standby gas treat- 1
ment system also appeared limited. .The licensee was' responsive ,
to .NRC concerns in these cases and followup actions were good. '
i. In April 1985, the pi. lot p'oppets for the main steamline isola- j
tion. valves -(MSIVs) were found to be loose or detached l from
their stems. . While the intent.'of a previous 1984 design. modi-
fication affecting' the MSIV poppets 'was good,l there .was a . lack
of attention L to . detail and contractor oversight on the 'part of.
the licensee's persunnet at that. time. Specifically, the licen-
: see's personnel accepted the vendor's poor design'without ques-
tion, and then fully assembled eight MSIVs in 1984 without' ques-
tioning an improper set screw design to lock the pilot poppet to
1'
_
the: pilot poppet nut. This lack of attention to technical de-
tail led to an inability of the outboard 'MSIVs to promptly re-
open following several . reactor scrams causing unnecessary. chal-
1enges to the operators and the safety related. systems. This
problem did not af fect the ability of the MSIV's to fulfill
their safety functions, i.e., it'did'not prevent them from clos-
ing. While considerable thought and effort has been expended on
the current redesign of the set screw arrangement, the problem
could have been . avoided by a good engineering- effort at .the
'
outset. ,
Extensive Mark'I containment and station blackout modifications
were being . planned at the end of ' the assessment period. The.
engineering . approach to .the Mark I issues went ~ considerably
beyond NRC requirements and demonstrated a good appreciation of H
containment reliability issues. In addition to these modifica- '
tions, the licensee is preparing:an extensive individual plant
evaluation (IPE) as part of 'a safety enhancement program. This' l
evaluation will use probabilistic and; deterministic analyses to
identify the major contributors to the risk of- offsite release.
.
A team inspection was conducted during this assessment period
to review the licensee's' implementation of an EQ program to meet
the requirements of 10 CFR 50.49. This inspection occurred
after the Commission had denied the licensee's request for
exemption of the.10 CFR 50.49 compliance deadline. The 11cen-
see's engineering management was found to be aggressively. in-
volved in the EQ program, especially following the denial of the
exemption request. There was evidence of adequate prior plan-
..
'
-ning and assignment of priorities. There were well stated, con-
trolled and explicit . procedures for control of EQ act.ivities.
EQ records were complete, generally well maintained and easily
!
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7, f ;
* *
X 42
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retrievable. . The ' EQ files supporting equipment. qualification I
were brief; however, the licensee made good use of qualification j
. reference material- in a logical and .auditable manner. EQ-per- 1
, sonnel were knowledgeable in their responsibilities. They were-
responsive to NRC requests during the inspection, resolving NRC
'EQ questions in a timely manner. The licensee had an ample and
well trained staff in the EQ area. The autho'rities and respon-
sibilities for the EQ staff were well defined throughout the
organization.
3
.)
A safety system functional readiness team inspection, consisting i
of regional, headquarters, and NRC-contractor . 'staf f, closely
examined offsite engineering activities during the assessment' ?'
period. The team looked at the . engineering designs - for modifi-
cations' to several safety systems at the - plant. Overall, . the
team was impressed with the quality of current engineering
actions.
Two weaknesses in engineering support were the lack of detailed
design basis documents for' plant equipment and safety instrument !
settings and occasional failure to promptly implement the licen- I
see's corrective action program. QA support from NED was not
e
always timely, but this reflected more a lack.of senior manage-
ment action rather than a problem within NED. Also, the Engi- ,
neering Department's plant Design Change (PDC)l process was not 1
always used by site personnel, indicating that' the PDC . process 1
needs . to be reviewed by. engineering management. The expanded
onsite engineering presence from the enlarged field engineering
office and the new systems' engineering group should help resolve
each of these concerns.
In summary, good engineering support to the site was noted dur-
ing the period. Technical - evaluations were typically thorough !
and ' showed an adequate regard: for safety. The ' engineering
approach to the Mark. I containment ' issues demonstrated an ex-
ceptional . appreciation for underlying safety issues. The lack
of' detailed design basis documents is an important weakness that 2
deserves additional management attention. l
(2) Conclusion
Rating: Category 1 !
I
Trend: None j
-!
(3) Recommendations i
Licensee: None
,
NRC: None
,
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I
4.11 Training and Qualification Effectiveness
(1) Analysis
During this assessment period, training and qualification efiec-
tiveness is being considered as a separate functional area for ;
the first time. The various aspects of this functional area l
were discussed in other functional areas and the respective i
inspection hours have been included in each one. Consequently,
this discussion is a synopsis of those assessments. Training. i
effectiveness has been measured primarily by the observed per- l
1 formance of licensee personnel and, to a lesser degree, as a l
l review of program adequacy. !
Ouring the current assessment period, resident and specialist
inspectors routinely reviewed ongoing training activities and
their effectiveness in assuring quality personnel performance.
An operator licensing examination and an inspection of the
i licensed operator replacement and requalification . training pro- ! gram were conducted by region-based examiners. l. The licensed operator training and requalification programs have ! significantly improved and appeared to be functioning satisfac-
torily. Two senior reactor operator (SRO) and five reactor
operator (RO) candidates were examined with only one R0- failure
[ '
during the period. These results are improved over the previous
assessment period in which three candidates failed the initial
l examination and demonstrates the effectiveness of management I' actions in this area. Candidate weaknesses included equipment !. operation from alternate panels outside the control room, know- l 1 edge of control rod blocks, Emergency Operating Procedure entry
conditions, and applied thermodynamics. Strengths included
knowledge of emergency systems, instruments and controls, the
control room, and general familiarity with the plant. The oper-
ator training material was generally of good quality.
.
'
A new coordinator and an experienced senior licensed operator
were assigned to the licensed operator program during the per-
iod. These two individuals demonstrated a high level of commit-
ment to the training program during the period and have helped
make the requalification training more plant-oriented and have
increased the quality of operator training materials. These
'
improvements have improved plant operator attitudes about train--
ing by making the training more relevant to the tasks the opera-
tors encounter. A plant specific simulator neared completion at >
l the vendor's facility in Canada at the end of the period. The ) l
- - - _ - - - _ _ - _ _ _ _ - - - - - _ - - _ - _ - _ _ - _ _ _ _ - _ _ _ - - _ _ - _ - - _ - _ _ - _ _ _ _ _ - _ - - _ _ _ _ - _ _ -
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licensee plans to begin training . operating crews on the. simula-
. tor in Canada in March .1987, prior to disassembly :and shipment i
to the-plant. Eventually, the simulator will be installed in i
the licensee's training facility. This equipment represents a
major- commitment- of resources and will further strengthen the
training program. The reactor operator and senior reactor'oper-
ator training programs . were . accredited by INPO in June 1986.
Overall, the~ 11censee's commitment of resources' and personnel to
licensed operator training have been impressive. !
!U The good performance of licensed operators in the contro1 ~ room -
during the SALP period indicated ' that their training has been
.
effective. Only two plant scrams were -linked' to an ' operator ;
error. -One of these did not involve control rod motion because -i
the plant had been. previously shutdown. -.The control room staff
has consistently been aware of the status of important plant
equipment and emergency operating procedures. One weak area was-
L '
Radiological Environmental Technical Specificatiens (RETS)
'
'
' training of licensed operators. No specific training was pro-
vided. to the operators prior to RETS implementation in March
1986.
There are currently nine operator candidates scheduled for
license examinations in May 1987. Considering the low number of
experienced personnel available for shift duties, continued
corporate management attention to the operator training program !
is a necessity. j
1
Requalification
. .
training. was acceptable, although certain- i
managers' with active licenses did not always fully participate '
in the program and required remedial instruction to maintain I
active licenses. Written examinations were only of fair quality.
due to deficiencies in the preparation of the procedure. sec- .l
tions. Questions tended to elicit plant system rather - than i
procedure knowledge. The method for preparing, administering, .(
and evaluating oral examinations was also weak in that. it was j
not defined'in a procedure. i
Significant weaknesses were noted in fire brigade and fire watch
training as judged by personnel performance. Examples of -poor ]
performance included fire watches not going to the correct plant q
locations, fire watches not entering areas to look for potential j
fires, and the inability of fire brigade personnel .to operate !
the site fire truck. Training records were fragmented and poor- l
ly used. Brigade members were not trained and drilled at re-
quired frequencies. Brigade drill quality was poor, with - a
heavy reliance on simulation.. y
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45
Maintenance training appeared to be effective. One scram was 3
partially caused by a maintenance technician error and partially
caused by an instrument design deficiency. Dedicated training i
facilities for maintenance personnet were well equipped. A pro- '
gram of licensee and vendor conducted courses has been estab-
lished. The licensee has implemented job-specific training and
utilized mock-ups prior to beginning major maintenance or modif- j
ication activities. This practice resulted in smoother perform-
ance which contributed to lower personnel exposure. Maintenance )
a
training has continued during the outage, demonstrating a com- l
mitment to maintenance training.
{
l
Contractor training was adequate during the period with few l
examples of poor contractor performance. Although some training j
was provided to contractors during the period, the increasing
number of contractors onsite coupled with the low number of ,
experienced maintenance supervisors may mean that contractors I
will require more training to perform under licensee procedures ;
and controls. In addition, this training program should be
formalized.
The licensee's radiation protection personnel training and qual- ;
ification program appeared adequate. Properly trained and qual-
ified personnel were found to be controlling radiologically
significant work activities. No instances of inadequately
trained or qualified radiation protection personnel were ob-
served although problems with adherence to procedures were ob-
served throughout the period. Training records were complete
and properly maintained. The licensee received INP0 accredita-
tion in this area during the period.
No deficiencies in the General Employee Training (GET) and qual-
ification program were identified. The program included prac- l
tical demonstration requirements in use of protective clothes,
'
step-off pads, and personnel frisking technique's. Some problems !
with worker contamination control practices were noted this per- '
iod, however, they were attributed to worker performance prob- l
1 ems and not to the adequacy of the training and qualification ;
program.
j
During the period, INPO accreditation was received for the non-
licensed operator training program and for the licensed operator ,
and senior operator programs. The health physics technician '
training program was also accredited. The remaining progrems;
i.e., shift technical advisor, chemistry, me:Sanical mainten-
ance, electrical maintenance, 4nstrument and controls, and tech- 5
nical staff training; are in the final stages of the approval {
process. Site visits have been held for the latter programs and I
an INPO accreditation board meeting is scheduled for April 1987..
l
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The' licensee.has dedicated significant, resources-to the training
. program. ?The addition of the new coordinator and senior licen-
sed operator.to.-the license training programs.has beena signif-
M -
_ icant plus. Four of _ ten training programs have received INP0:
.
".
'
- accreditation, ' and the remaining -: programs are Lin i.hef final--
_
' stages.'. of. that . process. Fire protection' training was:aLsignif-
- -icant' weakness' that requires continuinglattention. In : summary, .
'
licensee training improved during the periodc
(,2)- Conclusion
l ' Rating: _ Category 2
o '
Trend: Improving
-(3) Board Recommen'dations
n. Licensee: None
:NRC: None
. .
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47 <
(
4.12 Assurance of Quality
(1)' Analysis
During this assessment period, Assurance of Quality is being
considered as a separate -functional . area. Management involve-
ment'and control in assuring quality continues to be one evalua-
tion criterion for each functional area.
The various aspects of the licensee's activities involving
assurance of quality have been considered and discussed .as an.
integral'part of each. functional area and the respective inspec-
tion hours are included in each one. Consequently, this dis-
cussion is a synopsis of the assessments relating to assurance
of quality in other areas. Since this is an assessment of'
management's overall performance in assuring quality it conveys
a broader scope than simply -Quality Assurance (QA) department
performance..
The NRC routinely evaluated licensee management and QA depart-
,
ment performance during the assessment period. Several team and
regional specialist- inspections also examined assurance of
quality in~ plant operations and maintenance.
Recurring problems were noted in various functional areas during
the per_1od. This indicated that licensee management was slow to
deal with the programmatic weaknesses identified in the previous
SALP report and in the Region I Diagnostic Team report. .Two
factors likely contributed to the slow response, the lack of a
stable management team during .the period and a weak onsite
organizational structure.
Significant organization and ' staffing changes were made at the-
Plant Manager and Senior Vice President-Nuclear l eve l .. The
Plant Manager was ' replaced midway through the period and the
new Plant Manager was replaced in turn following the period.
Responsibility for the nuclear program was transferred from a
Senior Vice President to an Executive Vice President midway
through the period and transferred again to a new Senior Vice
President following the end of the period.
The Plant Manager position was organizational 1y weak during the
period due to a parallel site outage reporting chain. During
outages, the site had a dual reporting chain with each site
discipline reporting to both the Plant Manager and the Director
of Outage Management. However, the responsibilities and author-
ities of these managers were poorly defined; this obscured the
,
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chain of command and weakened management accountability. As a
result, neither manager appeared to be able to take charge of
the plant and make essential program improvements. Following
the end of the SALP assessment period, the Outage Management
Group was placed under the Plant Manager. This consolidated the
reporting chain.
The dual reporting chain had been in place for several years.
The failure of corporate management to recognize its effect on
SALP improvement items and to take prompt, decisive action to ;
correct this situation earlier in the assessment period is a i
significant weakness. The Vice President of Nuclear Operations
moved to the site in the latter part of the period, providing
i
additional corporate presence. The site security and fire pro-
tection groups have been elevated and now report to the Vice
President of Nuclear Operations. Also, a new Senior Vice
President-Nuclear and his onsite staff assistant were hired at
the end of the period. The effectiveness of these changes in
developing a stable management team has yet to be demonstrated.
The licensee's quality assurance and quality control departments
appeared to be performing effectively. QA audits were timely,
thorough and produced technically sound findings. The licensee
plans to significantly increase staffing of the onsite QA audit
group. This should aid self identification of problems. NRC
reviews of warehouse control, receipt inspections and the inser-
vice inspection program confirmed the adequacy of quality con-
trol activities. The licensee showed considerable initiative in
the latter area, expanding the feedwater inspection program
significantly after a recent industry event. Additional initi-
ative was shown in the drywell corrosion inspection program.
The inservice inspection group was well staffed with qualified
and well trained individuals.
However, lack of corporate management action on certain QA find-
ings was a recurring problem which degraded the effectiveness
of the QA organization and required additional NRC attention
this period. The absence of initiative was highlighted by one
case in which a QA finding potentially affecting the operability
.
!
of the high pressure coolant injection system remained unre-
solved for over six months. This situation persisted even after
several reports indicating the overdue status of this and other i
important QA findings were issued to the Vice-Presidents and '
Senior Vice-President. Increased senior management attention
should be given to assure prompt and effective resolution of QA
findings.
I
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I~
. ..
49
Corrective actions in response to NRC issues were also not al-
ways timely or comprehensive. During the previous assessment .
period, management control of licensed operator overtime was a l
highlighted weakness. During the current period, the licensee
{
instituted overtime controls for all site personnel that were {
considerably more restrictive than NRC guidelines. This showed l
initiative and a safety conscious approach. However, the policy l
was poorly implemented as demonstrated by multiple examples of '
security, maintenance, and radwaste personnel who exceeded both
the licensee policy and the NRC guidelines for overtime without l
the knowlege and approval of site and corporate management.
Repeated NRC involvement was required to ensure that the licen-
see's overtime policy (an NRC commitment) was adequately imple-
mented. Considerable NRC effort was also required to obtain
comprehensive corrective actions to surveillance, fire protec-
tion, security, and health physics problems. Several extensions
for NRC commitments have been requested showing a weakness in
scheduling and completing NRC-related work. In some cases
multiple extensions of a commitment were required. In addition,
no response to the 1985 NRC safety system functional inspection
.
'
had been submitted by the licensee by the close of this SALP
period.
The licensee implemented a work control process during the lat-
ter part of 1986 which should aid tracking and completing NRC
commitments. Planners have been assigned to each section to aid
in establishing detailed schedules and manpower requirements.
In addition, the licensee implemented a backlog clearing program
for all issues identified prior to September 1986.
Onsite engineering resources were limited, hampering the licen-
see's ability to deal with technical issues promptly. An onsite .
systems engineering group was formed and partially staffed in !
January 1987. The onsite Nuclear Engineering Department field'
office was also expanded in January. Senior licensee management
acknowledged the need to establish the systems engineering group
in March 1986 during the Region I Diagnostic Team inspection.
The delay in forming this group slowed progress in this func-
, tional area. The offsite Nuclear Engineering Department ap- i i peared to be producing good results. For example, the environ-
mental qualification (EQ) program for electrical equipment run
i
by the engineering department was well documented and effective. ,
However, communication with the station was sometimes ineffec-
tive.
Poor drawing quality and weak control of procedure revision
l 1ssuance were noted during the period. Although no specific i j instances were identified this period, use of unreadable draw- ;
'
l ings or out of date procedures could lead to inadequate or l incorrect mainte..4:s and surveillance activities. Management , J attention in this area has been evident and should continue. 1 !
-
.. ;. 1
!
50
The licensee has undertaken several major programs aimed at
improving the quality of operations at Pilgrim, More plant per-
.
!
formance indicators will be monitored and trended. An extensive
station decontamination effort is in progress. Successful com-
pletion of the decontamination effort will significantly improve ,
the accessibility of plant safety equipment. !
Significant Mark I containment and station blackout enhancements ,
were initiated curing the period. Planned modifications include
installation of a third emergency diesel generator, a contain- !
ment vent, a crosstie between the station fire water system and !
the residual heat removal system, and an independent battery ,
bank that can feed AC loads. The modifications go considerably
beyond NRC requirements and show a commendable commitment to
safety. The licensee efforts to update the Emergency Operating ;
Procedures (E0P's) are also noteworthy.
i
Pilgrim licensee event reports (LER) were generally of good
quality. However, two weaknesses identified in the Pilgrim LERs
involve the requirements to 1) provide a discussion of personnel
and procedural errors, and 2) identify the manufacturer and
model number of failed components. Deficiencies in the
personnel / procedural error discussions prompt concern as to i
whether or not the causes of these type errors are being deter- ,
mined so that adequate corrective actions to prevent recurrence '
can be taken. The failure to adequately identify each component j
that fails prompts concern that possible generic problems may go i
unnoticed for too long a time period by others in the industry. j
i
Two strong points for the Pilgrim LERs are 1) the root cause i
discussions and 2) the discussions concerning the failure mode, l
mechanism, and effect of failed components. -
{
)
In summary, although the licensee has exhibited good performance ~
in certain activities such as outage control and engineering and
has displayed initiative in its safety enhancement program,
significut deficiencies still were found to exist in radiolog-
ical controls, surveillance, fire protection and security. Some
of these deficiencies have existed throughout the period and
have been identified in previous SALP reviews, and by the 11cen-
see's own quality assurance organization. The ambiguity of the
site organizational structure and the instability in the corpor-
ate and site management team have resulted in the licensee's
inability to address and resolve these long-standing problems
without repeated prompting and overview by NRC. Senior corpor-
ate management was slow in confronting the problems and in.
implementing corrective actions. Late in this assessment period
and immediately following it, the licensee took steps to address
its organizational weaknesses. However, the effectiveness of ,
these efforts in improving the licensee's performance remains a
matter of continuing NRC interest and concern.
_
o. .
. _
D Oi
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4
' '
(2)' Conclusion
"
Rating: Category 3 ..'~
'
,
, .
Trend: None
(3) Recommendations ..
Licensee: Continue senior management attention to identified
problems to. unsure that they are prothptly and effec- I
tively resolved.
NRC: See Section 3.2 1
-
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5.0 Sjyorting Dan ind ,Syparies ~
: ?
5.r *investignyn 'and -Allegations Retiew ./
~~
; a f
-Seven) aMegations f were received and ' evaluated during this SALP.
'
period. Three'ofathe,allegatGO were investhitedf found to be un-
-
.subst<ntiated ano closed. * Two allegations concerning possible
employee drug and,Ilcohol. abuse, were forwarded to!the licensee for
' action.' Subsequent NRC review concluded that the' claims were unsub-
$ stantiated.' One allegati6 regarding excessive security. force over-
time was investigated, substanticted and brought to the attention of p
^ -
licensee management-for resolution. This issue remained open at the -
'
'end of. the- assessment period- pending review of licensee corrective
actions. . The seventh allegation :is in the security area and is still
'f unde'r evaluation. "~ j /
(~.
'
,, ,
Noinv$stigatiinswereconductedduring'the' assessment. period.
,
5.2 Escalated Enforcement Action 1
,7 ; .
.
W '. ConfirreaMry . Action L'u$ter -(CAL) 86-10 was ' issued in response' to a , u> ~ .
-
series of~ operational events in April, 1986. CAL 86'10 requested '
~i
~ submittal of technical evaluations of- these events and stated..that
NRC Regional Administrator approval would be - required prior. to re-- 1
start. The technical issues ' identified in CAL 86-10 have largely '
been resolved. Tha CAL howev'er, war / extended ; in August, ~1986~ and
reaains? open pending, resolution of broader management. concerns
x . identified in the previous J AP and spbsequent ' inspection reports. )
..
"
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/
'
j
One Severity Leve11U1 ' violation was issued for 'a problem with the d
-transportation of radioactive materialsi ' A-:1vil penalty was issued j
4 ,
.by.the State'of South Carolina for this prbblem. '!
>
5.3fManagement Conferences - <
' l
.
j
' s
Periodic manageInent conferences were conducted on June .12,1986. July -l
30, 1986, September 9, 1986, November 24, 1986 and February 2,.1987.
At .the conferences, NRC: Region I end 1(censee senior management dis- -l a
cussed licensee progress on management _ and . technical issues. These )
seatings will continue into the next S!.LP period. ~{
.
)
On January 20, 1987 a management inseting was conducted . in the NRC I
: Region I office to discuss ongoing ' problems with the licensee's' fire '
protection' program. ,
*'
Several additional meetings were held. between NRC: Region I personnel j
-
and. the licensee to' discuss progr3n improvements in the area of 1
], , emergency planning and security.
gf
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53
..
~
'5.4';LicensingActions-
'
.A ,
..(1) NRR/ Licensing Meetings and Site Visits-
.
, ,
m
': N , October 22-23, 1985 --
' Site visit-- Safety Systems Readiness.
; - Q _ l November.'4-8, 18-22, 1985 Review
-t "4 " January 13-14, 1986 --
. Site visit to discuss. licensing issues
, p
_
s
rJanuary 30, 1986 -
Counterparts' meeting with Boiling Water
7 DivisionI(BWDI). licensees
'
March 3-5,:1986 Site visit; SALP and licensing issues
'
-
t
t.c L March 6-7, 1986 -
Site visit with Region I Team
Inspection
-March 25, 1986
'
-
. Meeting on leaking instrument line.
from reactor. vessel'
1
March 31 -' April 1, 1986'- Site visit on Appendix R
'
April 16-18,.1986' -
Site visit with'AIT team
May19,.1986L. Region I on' Restart Issues
'
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'
i
g. .JuneL10,.1986 -
Public meeting at Plymouth
-June 11, 1986 -
Braintree-to discuss licensing issues j
l June 12, 1986 '-
Region'I to discuss restart issues '
with BEco
June'-25,.1986
'
-
Meeting on Appendix R schedular
requirements-
i
. July 30,,1986. -
' Region I'to discuss restart issues I
with BECo i
September 9-10, 1986 -
Site visit and discussion of
licensing issues
i
October 16, 1986 -
Counterparts meeting with BWDI
,,.
licensees )
1
1
November 24,- 1986 -
Site visit and management meeting with i
BEco
)
' Janua ry 20, 1987
.
'
-
Region I to discuss Fire Protection l
Issues with BEco i
>
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. . . . . i . . _. . . . .
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(2). Commission Briefing
None
(3). Schedular Exemption Granted
December 1, 1986'
~
-
On- licensee's request for exemption
from Appendix J, Section III. A.6(b) to
the extent that Type A test be conduc-
ted 18 months after the previous test.-
.(4) Reliefs Granted
February 12, 1986 -
Partial relief from visual examination-
guidance in GL 84-11- (Inspections of-
BWR stainless steel piping)
(5) Exem;:tions Granted
None
(6) License Amendments Issued'
Amendment No. 91, issued December 3,1985; raises the K-effec-
tive -limit of the spent fuel storage pool from 0.90 to 0.95.
Amendment No. 92, issued February 4, 1986; changes ' TS Table
3.1-1, " Reactor Protection System Instrumentation, Requirements".
Amendment No. 93, issued March 17, 1986", Removal from TS, the - i
details of.the AISI Program. l
.
~l
Amendment No. 94, issued May 28, 1986; Reactor Pressure Vessel
Pressure / Temperature limits to accurately reflect' neutron
exposure.
Amendment No. 95, issued May 28, 1986; Removes TS Section 6.15.
" Environmental Qualification"
Amendment No. 96, issued July 1, 1986; Correcting the . ASTM
Standard reference for diesel fuel oil.
Amendment No. 97, issued August 6, 1986; changes the calibration ,
frequency for reactor level, reactor pressure, and drywell i
pressure surveillance instrument channels.
,
'{ _
g
n y
'
l
:. -; -:
T
55
<*
.l
'(7)' TMI Items (Active) )
i
1. A.1.1 - Engineering Expertise on Shift i
1.C.1- Emergency Operating Procedures
q
I.C.6- Guidance on Procedures for Verifying Correct -1
Performance of Operating Activities
I.D.1- Detailed Control Room Design Review
I.D.2 Plant Safety Parameter Display System
'
II.E.4.2(7) Automatic Isolation of Purge and Vent Valves on
Containment High Radiation
II.K.3.18 Automatic Depressurization System Logic
-(8) Other Licensing Actions (Active or Complete) 4
* Visual Examination Requirements of GL 84-11
*IE Bulletin 80-11
* Flame' Spread Classification for Floor Covering Materials
IST Program
* Modification of Vacuum Breakers
Salem ATWS Followup
- ISI Program
1
Fire Protection Program
* Spiral Unloading
Long-Term Plan
* Thermal Sleeve Cracking
I
* Complete
5.5 Licensee Event and Part 21 Reports
(1) Overall Evaluation
During this evaluation period 36 Licensee Event Reports (LER)
were submitted in compliance with 10 CFR 50.73. Four of the
reportable events were scrams involving control rod motion. The
fifth scram was discussed in LER 86-008. Three of these scrams
. were caused by personnel error and two were caused by spurious
MSIV closure. Two additional spurious MSIV closures with the
reactor in shutdown were also reported via LER.
!
,
j
j
7 /
!. ; .
'
,
56
!
~
,
. L An evaluation. of ;the content and quality' of a ' representative
sample of the Licensee Event Reports (LERs) submitted by Pilgrim .
I during L the November 1, '1985 ' to January 31,1987 Systematic
Assessment of Licensee Performance (SALP) period was performed
'using a refinement of the basic methodology presented in NUREG-
1022, Supplement No. 2. This is the .second . time the Pilgrim
LERS have been evaluated using this methodology. The results of
this evaluation indicate improvement in that the Pilgrim-LERs
are above average in quality.
Three reports were submitted in accordance with.10 CFR' Part 21
requirements during the period. .These reports identified 'inade-
quacies in the residual heat removal system (RHR) pump minimum
flow logic design, standby gas treatment system (SBGTS) design,
and defective safety related cable.
(2) Causal Analysis
i
During the previous assessment period, common causal chains were
identified involving inadvertent' afety system actuations and
missed surveillance tests. Surveillance testing continued to be
a problem during this period. Four common causal chains were
identified'during the current SALP period
Surveillance Test Program Adequacy
Six LER's (293/85-28, 85-32, 86-04, 86-12, 86-14, 86-19) de-
-
scribe surveillance tests which did not fully implement tech-
nical ' specification requirements. Five LERs (293/85-32, 86-15,
86-16,86-22,86-26) document missed surveillance tests.
..
Fire Protection -
j
J
,
Five LERs (293/85-34, 86-20, 86-23, 86-24, 86-25) concerning
degraded fire protection components and inadequate fire protec-
tion compensatory measures were submitted.
,
' Design Deficiencies l
!
Two LERs (293/86-13, 86-21) and two Part 21 reports were sub-
mitted due to discovery of design deficiencies in safety related
systems, i
. Spurious MSIV Closures '
Four LERs (293/86-07, 86-08, 86-09, 86-10) submitted include l
spurious primary containment group I isolations. In two cases ;
the isolation of the main steam isolation valves (MSIVs) resul-
ted in a reactor scram at power.
i
!
1
Z l
lI .' ;
,..e _j)!U r U "
..y ' -
.
57 >
d
. j
>
5.6..' Automatic Scrams,and Unplanned Shutdowns
(1)IAutomatic ScramsL
<
! The. unit 1. experienced- five unplanned. automatic ' reactor scrams
"'
:during:. .this evaluation ' period,. four of which involved rod;
motien. .See Table 6 for details. -l
. . . . .
j
'
.(2)'; Unplanned Shutdowns' ;
* -
..
.
.. I
The' licensee . entered five unplanned outages and one signific'a nt
' -
unplanned power reduction during the period. See Table 6. for ]
- ' details.
!
-
'
4
.
l
.
;
!
!
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'!
i
1
>
!
!
#
v '
,;,.. .. ..
,
58
[ TABLE 1
TABULAR LISTING OF- LERs BY FUNCTIONAL AREA
, PILGRIM-NUCLEAR POWER STATION
: AREA-
_CAUSE CODE
'i f
A B C D E X TOTAL.
H 1. ' Plant Operations 1 2 1 - -
8 12
2. Radiological Controls - - - - - -
0
3 .' Maintenance. -
1
- -
1 2 4
L4.- Surveillance - - -
1 2 9 12
. 5. LFire Protection 1 2' -
1 -
1 5'
6. Emergency Preparedness - - - - - -
0
7. Security and Safeguards - - - - - -
0
. 8. Outage Management and
Modification Activities - - - - - ' -
0
9. ~ Licensing Activities - - - - - -
0-
10. ' Engineering and Corporate - -
2' -- - -
1 3
4
. Technical Support
"
11.. Training and Qualification
Effectiveness - - - - - -
0
12. Assurance of Quality - - - -
'
- -
0
o
TOTALS 2 7 1 2 3 21 36
--
Cause Codes: A - Personnel Error
e . B - Design, Manufacturing, Construction, or Installation Error ( '
i
C - External Cause
D - Defective Procedure
E - Component Failure
X - Other
7
.
l
a
,
;g '\
; s .
'
l
59 j
s
i
TABLE 2 l
LER SYNOPSIS (11/01/85'- 01/31/87)
;
^
i , .
PILGRIM NUCLEAR POWER STATION, d
q
$
-
LER. EVENT' CAUSE . .
's
NUMBER. DATE _ CODE SUMMARY DESCRIPTION !
85-028-00 l10/10/85- X- INADEQUATE SURVEILLANCE PROCEDURE
"
FOR STANDBY GAS 1 TREATMENT SYSTEM
85-029-00 10/18/85- X HIGH PRESSURE C00LANT INJECTION l
SYSTEM AND ANTICIPATED TRANSIENT l
WITHOUT SCRAM SYSTEM INVERTERS !
IN0PERABLE
<
'85-030-00 ~10/30/85 X INADEQUATE RECIRCULATION POMP-
START PROCEDURE
'
'
85-031-00 10/29/85 X FAILURE TO MEET MINIMUM SHIFT
. CREW COMPOSITION
85'032-00
-
11/25/85 B MAIN STEAM LINE HIGH FLOW SWITCH
SETPOINT' DRIFT
J 85-033-00- 11/27/85 ~X- . MAIN STACK AND RBV MISSED.
'
SURVEILLANCE TEST
85-034-00 '12/31/85 B ~-TECHNICAL SPECIFICATION REQUIRED'
FIRE DAMPERS FOUND DEGRADED-
86-001-00 01/06/86 A ONPLANNED REACTOR SCRAM ON LOW-
WATER LEVEL DUE T0.0PERATOR ERROR
86-002-00 01/16/86 X REACTOR SCRAM DUE T0' PRESSURE
SWITCH SENSITIVITY
86-003-00 02/11/86 E 480 V SAFETY BUS INADVERTENTLY'
DEENERGIZED DURING MAINTENANCE
'
86-004-00 02/20/86 X STANDBY LIQUID CONTROL SYSTEM
, DECLARED INOPERABLE WHEN
SQUIB VALVES NOT TESTED INSITU
86-005-00 03/07/86 B HEAD SPRAY PIPING LEAK IN TORUS
ROOM
86-006-00 03/16/86 B WELD LEAK ON REACTOR WATER LEVEL
INSTRUMENT LINE
. . . ,
60
.LER EVENT. CAUSE
. NUMBER DATE ' CODE ~ SUMMARY DESCRIPTION
86-007-00 03/22/86 X MAIN STEAM LINE ISOLATION WHILE
REACTOR SHUTDOWN-
86-008-00' 04/04/86 X REACTOR SCRAM AND MAIN STEAM
ISOLATION VALVE (MSIV) RESET
PROBLEMS
86-009-00L 04/11/86 X IN SERIES PRIMARY CONTAINMENT-
ISOLATION VALVES MD-1001-28B
AND 29B INDICATING LEAKAGE PAST
SEATS
86-010-00 04/15/86 X MAIN STEAM LINE ISOLATION WHILE
REACTOR SHUTDOWN
86-011-00 04/19/86 X LEAKAGE PAST MSIV'S IN EXCESS
OF LLRT CRITERIA
86-012-00 05/16/86 X INSUFFICIENT ONCE/ CYCLE HPCI
SURVEILLANCE PROCEDURE
86-013-00 05/30/86 B USE OF NON-SEISMIC GENERAL
ELECTRIC TYPE CFD RELAYS
=
86-014-00. -06/10/86 X INSUFFICIENT ONCE/ CYCLE RCIC
SURVEILLANCE PROCEDURE
86-015-00 06/13/86 X PRIMARY CONTAINMENT LOCAL LEAK
RATE TESTS OVERDUE
'86-016-00 06/21/86 E BUS AS, BUS A6 AND STARTUP
TRANSFORMER DEGRADED VOLTAGE
RELAY CALIBRATIONS OVERDUE
1
86-017-00 07/01/86 X CONTAINMENT ISOLATION VALVE
LOCAL LEAK RATE TEST FAILURES ]
l
86-018-00 06/29/86 X GENERAL ELECTRIC AKF FIELD f
BREAKER FAILED TO TRIP i
'
AUTOMATICALLY
86-019-00 07/15/86 X INSUFFICIENT MONTHLY ATWS ,
SURVEILLANCE PROCEDURE
)
86-020-00 08/20/86 D UNIDENTIFIED FIRE BARRIER WALLS
AND PENETRATIONS
'
,
> !
' "$9 . ' *L
61
<
[ '
, lLER . EVENT CAUSE
NUMBER DATE. CODE SUMMARY DESCRIPTION
86-021-00 08/27/86. .B STANDBY GAS TREATMENT SYSTEM
DELUGE SYSTEM SINGLE FAILURE
MODE
~86-022-00 08/29/86 E MISSED TECHNICAL SPECIFICATION
SOURCE LEAK CHECK SURVEILLANCE
q
L86-023-00 09/12/86 A MISSED FIRE WATCH AND FIRE
'
WATCH PATROLS
,
86-024-00 10/07/86 X NON' FIRE. RESISTANT COATED
STRUCTURAL STEEL
86-025-00 11/11/86 B MISALIGNMENT. 0F THE FIRE
SUPPRESSION WATER SYSTEM
. 86-026-00 10/29/86 D FAILURE T0 PERFORM RADIO-
ACTIVE MATERIAL SURVEILLANCE
TEST OF STANDBY GAS TREATMENT
SYSTEM AND LIQUID RAD. EFFLUENT
'
MONITOR
'86-027-00 - 11/19/86 C LOSS OF 0FFSITE POWER DUE TO
SEVERE WINTER STORM,
'
' 86-028-00 12/23/86_ X FAILURE TO RECOGNIZE THE-EFFECTS
OF ELECTRICAL ISOLATION RESULTING
IN ESF ACTUATION
86-029-00 12/23/86 X LOSS OF 0FFSITE POWER WHILE WASHING
SALT FROM YARD INSULATORS
o
. -
4
i
!
i
_
, a
'
o- :. ]
.
^
l
[ 62 i
TABLE 3~ q
1
INSPECTION HOURS SUMMARY (11/01/85 - 01/31/87) 1
PILGRIM NUCLEAR p0WER STATION'
Hours % of Time
1. Plant' Operations 1603 24
2. Radiological Controls' 746 '11
3. Maintenance 1196 18
,
4. Surveillance 1103 16
5. Fire Protection' 413 6
6. Emergency Preparedness- 249 4
7. . Security and Safeguards -282 4
8. .' Outage Management and Modification 1170 17
Activities
9. Licensing Activities * --
10. Engineering and Corporate ** --
Technical Support
11. Training and Qualification ** --
Effectiveness
12. Assurance of Quality ** --
Totals 6762
'
*
Hours expended in facility license activities and operator license
activities are not included with direct inspection effort statistics.
;
**
Hours expended in the areas of Training, Assurance of Quality and
Engineering and Corporate Technical Support are included in the other
. functional areas.
.
'
4
i
}
.
y
, 63
m
TABLE 41
' ENFORCEMENT SUMMARY (11/01/851- 01/31/87):
,
PILGRIM NUCLEAR POWER' STATION
<
.
'
A. Number'and Severity Leveloof Violations
Severity Level I- 0
J Severity. Level II' 0
Severity Level III 1
*
Severity. Level IV 21
Severity-Level.V. 6
Deviation 1
Total 29
B.- Violations Vs. Functional-Area
Severity Levels
Functional Areas I II III IV V Dev Total
1.- Plant Operations - - - --
1 -
1
2 .- Radiological'Controis -
'
-
1 3 - -
4
3. Maintenance- -- - -
1 - -
1
4. Surveillance' ' - - -
6 -3 -
9
5 '. . Fire Protection- - - -
5 -
I'~ 6
6. Emergency Preparedness - - - - - -
0
7. . Security Safeguards - - -
1 1 -
2-
'8. Outage Management and
'
Modification Activities - - -
1 1
-
2 j
,
9. Licensing Activities - - - - - -
0
r
,' '
10. Training and Qualification
. ~ Effectiveness' - - - - - -
0
.11. Assurance of Quality'- - - -
4 - -
4
12. Engineering and Corporate
Technical Support - - - - - - -
'
Totals
~
0 0 1 21 6 1 29 'i
4
f L
p s
4,_ _.,c
n.
-64-
,
.h'
,, TABLE 4 (Continued)
-C. Summary
<
-Inspection. ;
Report Severity Functional
- Number Level' Area'- -Violation
85-32 V- Surveillance. Instrument channel tests
were'not being performed
monthly-for the reactor
building vent and: stack waste-
gas monitors.
85-32- V Security Dilure to perform a
i. Safeguards proper search of a: package
brought-into the ' protected
area.
86-01 V Plant- Post trip review 86-01.and i
Operations 86-02 lacked required 1
recorder charts. Inadequate j
control room log entries on1 i
disabled annunciators. I
1
86-04 III Radiological A waste shipment of solid
Controls metallic oxides on non-
compacted trash lacked
3
required strong packaging and j
quality control measures, I
a
86-06 IV Surveillance Replacement squib charges {
were installed in the' standby J
liquid control system from a "
batch that had not been tested j
during a manual initiation of
the Standby Liquid Control
System.
1'
. 86-10 IV Radiological Radiation surveys of packaged j
Controls irradiated reactor components
were not documented on
appropriate radiation survey
forms and maps.
86-10 IV Assurance of Quality control measures were
Quality not taken in transferring
radioactive waste shipments,
i
r, c-
,
") (
'
p. a-
.' ,
'
65
,
, TABLE 4 (Continued)
. C .1 Summary-
'
- Inspection
'r Report Severity. Functional
Number -Level Area Violation
86-14- 'IV . Assurance of Previously identified-
Quality inadequacies involving
, '
surveillance testing of the
high pressure coolant
injection system were not
corrected'for six' months. !
L 86-14 V Surveillance Failure to properly control
measuring and test equipment.
t
' 86-21 IV Surveillance Battery rated load discharge '
Test procedure was not
updated to reflect system
alterations and restorations.
86-25 IV Assurance of Failure and Malfunction
Quality. Report was not completed
by engineering personnel after l
they identified deficient' '.
station fire barriers.- !
1 86-25 V . Surveillance ~ Surveillance tests were
performed without' independent"
l
verification of system response
and system restoration.
,s
- 86-25' Deviation Fire Protection Failure to comply.with the
commitment to conduct
quarterly fire brigade drills
for all fire brigade members.
86-34 IV Security Improper package search and
,, Safeguards inadequate follow up. i
86-36 IV Fire Protection Fire brigade members had not
received the required
training.
86-36 IV Fire Protection Fire watches . failed to perform
the required hourly patrol of
the motor generator set room.
,
. .
\
66
TABLE 4 (Continued) j
i'
C. Summary
Inspection
Report Severity -Functional
Number level Area Violation 7
-
86-37 IV Fire Protection Inadequate fire brigade drill.
I
86-37 IV Modifications Safety-related modifications i
were not performed in I
accordance with applicable s\\ {
design requirements.
86-38 IV Fire Protection Adequate procedures and -
drawings had not been
established for the station ,
fire water system. I
i
86-44 IV Radiological Failure to implement a
Controls radiological control procedure
for checking vehicles leaving
the site.
87-01 IV Surveillance Failure to adhere to the '
procedure governing
surveillance testing of the
Post Accident Sampling
System (PASS) system. ,
87-01 IV Maintenance Lack of procedure guidance on '
'
maintenance of the heat
tracing control circuit relays
for the PASS system.
87-03- IV Fire Protection Failure to take required
action for inoperable fire
protection equipment.
87-03 IV Radiological Failure to control a master !
Controls key to all locked high
radiation areas.
87-03 IV Assurance of Failure and Malfunction
Quality Report not completed after
a safety-related bus transfer
did not occur during a
-surveillance test.
i
l
h c. < c. e
67:
TABLE 4 (Continued)
C.- Summary
Inspection
Report. Severity Functional
j 1
Number Level ~ Area- Violation
87-04: IV Surveillance A surveillance test on Standby
Gas Treatment System failed'to
'
meet the intent of the Tech
Spec requirements. )
87-04 IV Surveillance Failure:to calibrate measuring
and test equipment.
Modification
'
_
87-04 -V Performing. post-modification
test on the refuel bridge
>
'without approved procedure
'
changes.
87-04' IV Surveillance Master test program procedures
do not adequately address-
surveillance test and post'
modification test programs.
,
!
-
\
l
l
l
!
!
I
i
i
.;
)
i.
1
I
r: j "
. .
l
i
68-
f1
i
TABLE 5
l
INSPECTION REPORT ACTIVITIES (11/01/85 - 01/31/87) !
l
PILGRIM NUCLEAR POWER STATION
{
Report
Number Inspection Dates Inspection Hours Areas Inspected '
85-30 10/22/85-11/22/85 674 Office of Inspection
and Enforcement Safety j
System Functional '
Inspection
85-31 11/05/85-12/06/85 106 Routine Resident
Inspection
l
'
85-32 11/17/85-11/22/85 43 Radiological Controls
Program associated with
spent fuel pool re-
racking
85-33 -- --
Cancellect
85-34 12/02/85-12/06/85 31 Inservice Testing 1
Surveillance' Program for j
pumps and valves 4
85-35 12/09/85-12/13/85 209 Implementation of
7
Environmental
Qualifications Program
85-36 12/07/85-12/31/85 40 Routine Resident
Inspection h
<
85-37 12/16/85-12/20/85 40 Fire Protection !
Program
I
86-01 01/01/86-02/17/86 128 Routine Resident l
Inspection !
86-02 01/13/86-01/17/86 117 Radiological Controls
Program / Follow-up !
. inspection to 85-32 !
86-03 01/22/86-01/24/86 40 Emergency Preparedness
Program :
!
;
1
i
I
1
,.
'
;;, #
69
.
. TABLE 5'(Continued)
i Report. i
Number Inspection Dates Inspection Hours Areas Inspected- !
.,.
~'
86-04 01/02/86 8 Inspection of radioactive.
waste ~ shipment from'.
Pilgrim by'a
representative of the
South Carolina'0epartment
of Health and
Environmental Control
86-05 -- --
Cancelled- i
'86-06 02/18/86-03/07/86 962 Diagnostic special-team
inspection of overall l
plant operations I
!
.86-07 03/09/86-04/28/86 266 Routine Resident
Inspection
. . . I
86-08
.
03/17/86-03/21/86 34 . Security & Safeguards ' !
.
I
86-09. 04/28/86-05/02/86 51 Radiological. ,
Environm' ental Monitoring l
Program j
L86-10 03/24/86-03/27/86 40- Radioactive Waste I
Packaging and
Transportation Program-
86-11 05/12/86-05/16/86 40 Corrective maintenance
on'the Main Steam
Isolation Valves, . ;
Residual Heat Removal 1
system valves and
'
installation of high
density spent fuel pool i
storage racks
'
86-12 03/24/86-03/28/86 57 Plant modifications
involving analog trip 1
system
86-13 04/03/86 15 -
Eniergency preparedness
program j
86-14 04/28/86-06/02/86 225 Routine Resident
Inspection i
Mii_
,
, ,
7j
:; >
", ,
4 ..
70
_
TABLE 5 (Continued)'
' Report
!' Number - Inspection Dates- Inspection Hours Areas' Inspected
y 86-15 05/05/86-05/08/86 --
Reactor Operator-
,
.
1
-
Examination
.86-16: 04/14/86-0417/86 28 Radiological controls
program associated with
post accident sampling
and analysis
86-17 04/12/86-04/25/86- 574 Augmented special
safety team inspection
on operational events
[. 86-18 --- --
Cancelled
86-19 . 10/20/86-10/24/86 206 Special health; physics
inspection on' upgraded !
radiation protection .!
program
l
'86-20' -- --
Cancelled
86-21- 06/02/86-07/07/86- 346 Routine resident
inspect 1on
'86-22 0'6/12/86 22 Management Meeting
86-23.- -- --
. Cancelled
1
86-24- ' 08/04/86-08/08/86 169 Quality Assurance and' '
Quality Control over-
view - Equipment classi- !
fication and vendor
interface ,
86-25- '
07/08/86-08/04/86 350 Routine resident
inspection !
86-26 -- --
Cancelled
86-27 08/04/86-08/08/86 43 Maintenance program
'86-28 08/04/86-08/08/86 20 Safeguards program
86-29 08/05/86-09/08/86 231 -
Routine resident
inspection
!
, !
l
\
- _ -_ - __ - ._- -- -- __
~ "
e ...
-
71"
p L
,
. TABLE 5 (Continued)
It . Report
'
. ,
j
Number Inspection Dates- Inspection Hours Areas Inspected
86-30 07/30/86 8 Management Meeting
.86-31 09/08/86-09/12/86 60- Nuclear engineering: . 1
program associated with -
seismic stress analysis
[p of safety.related pfping
. .
,,
(: 86-32 09/09/86 8 Management Meeting V
86-33 '09/30/86-10/03/86 34 Emergency preparedness
program.
86-34- 09/16/86-10/20/86. 248 Routine resident.
inspector _j
86-35 09/29/86-10/02/86 29 Radioactive effluents l
program '
[
a
86-36-
'
10/20/86-10/24/86 50 Fire protection program
86-37 '10/21/86-11/24/86
-
275 Routine. resident-. !
. inspection 1
g -;
86-38.-
'
'11/12/86-11/14/86 53 Special inspection of !
: fire' protection program- j
:86-39 12/09/86-12/11/86 160 Annual emergency
preparedness exercise 1
86-40 '11/25/86-12/31/86- 160 Routine res5 dent :l
l- inspection {
86-41 11/24/86 8 Management Meeting !
!
86-42 12/08/86-12/12/86 28 Security.and Safeguards l
,
program
l-
l
-
!
, ;
i
I
' '
.
. -. __ ______ _ _ _ ______ _ ___ _ _ _ i
r - , ,
77- r
'
.
g:g 2
',h f
*
72 J
1 ,
TABLE 5 (Continued)
ReportL ~
Number- ' Inspection Dates Inspection Hours Areas Inspected
'86.43' '12/15/86-12/19/86 35- Maintenance-program
concurrent with outage-
4
management
'86-44- 12/17/86-12/19/86- 28' - Radiological controlsj
'
,
1
> program
Y 86-45'
'
09/03/86-11/07/86 --
Reactor' operator-
requalification
examination
'87-01 01/05/87-01/09/87- 64. Plant modifications
involving reactor water
level instrumentation-
'
system and reactor-
c '
,
coolant hydrogen
injection' system
87-02. 01/05/09-01/09/87' 34 Surveillance program
and local leak-rate
.; - testing-
, .87-03 01/01/87-02/20/87 228 Routine-resident-
inspection
87-04- 01/12/87-01/16/87 104 ' Surveillance / Maintenance-
programs.1
1 ' 87-05- 01/12/87-01/16/87: 33 Inservice-inspection-
and surveillance
program
7-
4
I
.
Y
'l_
-
E
-
- - _ ~
, -
i 73
i
TABLE 6 1
UNPLANNED AUTOMATIC SCRAMS AND SHUTDOWNS (11/01/85 - 01/31/87)
!
PILGRIM NUCLEAR POWER STATION -
l
Power Functional l
Date Level Description Cause Area j
:
01/03/86. 100% Main turbine generator Equipment failure - --
{
bearing vibration random l
required a controlled i
plant shutdown for i
repairs s
i
01/06/86 Restart f
i
01/06/86 10% Reactor scram on ves- Operator error and Operations j
sel low levei during inadequate main- j
restart'. Caused by tenance - excessive <
operator inattentive- leakage past feed- ]
ness while manually water regulation I
controlling level and valves ;
leaking feedwater
regulation valves
(LER 86-001) j
01/16/86 100% With the unit in a Technician error Maintenance l
l half scram configura- and design i
tion for inaintenance deficiency-
changeout of a hypersensitive ;
reactor high pressure pressure switches 1
l switch, slight bump ' l on the second pressure I- switch caused a false i high reactor pressure I
scram (LER 86-002)
f '
01/29/86 100% A recurrence of main Equipment failure - --
turbine generator random i
bearing vibration !
problems resulted
in a forced power
reduction to 10
percent power
,
o I w _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _J
~
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'
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L
, ;m- -.
-
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i !
s- 74
,
3
,
TABLE 6 (Continued)
Power ~ Functional
Date. -Level. -Description- Cause Area
03/07/86~ 100%- Weld leak in- the 4" Equipment failure .0perations '
head spray:pipin.g
. required a controlled ,
shutdown to facilitate
repairs. . (LER 86-005)
03/12/86 ' Restart
' L
-03/15/86 80% ' Increasing unidenti- Equipment failure - --
-fied drywell.. leakage random
W required reactor
shutdown.. The licen-
.see:found and repaired
a weld leak'on reactor
.i. water level instru-
. mentation line,
i
(LER 86-006). j
03/31/86- Restart- I
04/04/86 :100% A controlled reactor Equipment --
shutdown due to the- failure <-
detection of small' oil- random
-leak in the turbine
' hydraulic' control
system. (IR 86-07)
04/04/86 5% During a' controlled- Equipment failure - --
reactor shutdown, spurious actuation
automatic closure of the MSIVs-
of the Main Steam i
Isolation Valves
,*
'(MSIV) initiated
a reactor scram
(LER86-008)'
04/04/86 0% Following the rea'ctor Operator error Operations
scram described above,-
'
.- a second scram signal
was received due to
the scram discharge '
volume (SDV) high
level signal'
(LER 86-008)
04/09/86 Restart
i
i
/
m
% ' r-
75
T '
TABLE 6 (Continued)'
Power Functional
Date ' Level. Description .Cause Area
"h '04/11/861 :93%1 Indicated leakage from Equipment failure'- --
'
,
the reactor water random-
recirculation system
a through the 'B' loop
.
Residual Heal Removal.
'(RHR)Systeminjection
valves forced a shut-
down for maintenance
,
04/11/86 10% During a controlled Equipment failure - --
reactor shutdown, spurious actuation
automatic closure of the MSIVs
-
of the MSIVs
initiated a
reactor scram '
(LER 86-008/IR 86-07)
04/12/86 0%- A Confirmatory Action
Letter 86-10 was issued
, regarding~the April.4
,. and April 12.MSIV iso-
lations and the RHR
injection. valve leakage,
.The Confirmatory Action-
Letter was: subsequently
extended-to cover
correction offsignifi-
cant ~ programmatic
deficiencies. =In July i
1986, the licensee I
decided to continue the
shutdown into 1987 and
conduct. refueling,
install certain Mark I
containment enhance- ;
ments, and complete !
10 CFR 50 Appendix R '
fire protection
modifications' .
Restartlof the unit.is l
pending NRC authori- !
zation in accordance -
' '
with Confirmatory
Action Letter 86-20,
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FIGURE 1
PLANT OPERATING SUMMARY
Operating ;
1 5 10 15 20 25 30 Days
.{
Nov 85 *********************************************** 30' l
q
Dec 85 ************************************************
31
-l
-Jan 86 ***** *************************************** 28 f
5
Feb 86 *********************************************
28
{
Mar 86 -********** ****
11
Apr 86 ***** ********
6
May 86 0
Jun 86 0
Jul'86 0
Aug 86 Extended Refueling 0
Sep 86 and 0
'Oct 86 Maintenance Outage O
Nov 86 0
1
Dec 86- 0
1
Jan 87 0.
1 5 10 15 20 25 30 1
1
DAY OF THE MONTH
.. **** Power Operation
;
;
1
:
I
l ,
.
l.
}}