ML20214M821
| ML20214M821 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/22/1987 |
| From: | Bird R BOSTON EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| BECO-87-83, NUDOCS 8706010439 | |
| Download: ML20214M821 (7) | |
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$J aosnwsosont Executive Of fices 800 Boylston Street Boston, Massachusetts 02199 Ralph G. Bird BECo 87-83 Senior Vice President - Nuclear U. S. Nuclear Regulatory Commission Document Control Desk Hashington, D. C.
20555 License DPR-35 Docket 50-293 Response to Systematic Assessment of Licensea Performance (SALP) Report This letter is written in response to the April 1987 Systematic Assessment of Licensee Performance. He accept your recommendations and will incorporate them into our continuing corrective action plans.
The attachment summarizes our response to each of the licensee recommendations. He are ready to discuss any of these items with you or your staff at your convenience.
1 JC/ pac Attachments cc: Mr. R. H. Wessman, Project Manager Division of Reactor Projects I/II Office of Nuclear Reactor Regulations U. S. Nuclear Regulatory Commission a
7920 Norfolk Avenue Bethesda, MD 20814 U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Senior NRC Resident Inspector Pilgrim Nuclear Power Station 8706010439 870522 h
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Attachment l'-
1.
Plant Operation Recommendation:
Continue efforts to recruit, train, and retrain licensed
. personnel.
Response
The Operations Section is continuing its efforts to achieve the staffing goals which have been established.
The goals and scheduled completion dates were provided in our March 1, 1987 response to Management Meeting 86-41. These include a six section watchbill for the licensed personnel by the end of 1987.
2.
Radiological Controls Recommendations:
Aggressively supervise the radiological cor.trols program.
e Establish and_ implement measures to verify program implementation and implement corrective ac': ions for deficiencies.
Interactions with personnel outside the radiological group should be significantly strengthened.
Responses:
He recognize the need for improved management attention and e
effectiveness follow-up on the part of all station section managers 'and, most importantly, their supervisory staffs. He have taken significant action to ensure this occurs, The Senior Vice President has instituted an Independent e
Radiological Oversight Committee which provides critical self assessment of station radiological performance.
In addition, the Station Manager is a member of the ALARA Oversight Committee and chairs the ALARA Committee.
The Station Manager will continue to discuss the radiological groups' interaction with other plant sections at both the nuclear organization morning meeting and at the weekly staff meetings to improve communications. Signs of improved teamwork and cooperation are evident.
He have included ALARA performance as one of the criteria to be used in evaluating the performance of each management individual.
He have instituted a program where section managers are scheduled to spend time in the plant, monitoring and correcting radiological performance problems.
Management has assigned radiological goals for each section.
Corrective actions are taken as required.
Individual achievements are recognized by an ALARA Employee of the Month award.
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- 3.
Maintenance Recommendations:
Improve communications between maintenance and other site organizations.
Increase the effectiveness of maintenance planning.
Continue program improvements in the area of preventive maintenance and vendor information control.
Consider development of a monitiring system for maintenance performance.
Responses:
The Station Manager has discussed and will continue to discuss the maintenance interaction with other plant sections at both the nuclear organization morning meeting and at the weekly staff meetings. He will concentrate on policies, establishment of priorities, and increased effectiveness.
The Station Manager has established maintenance effectiveness measures with the Maintenance Section Manager.
These measures will include key indicators to measure performance and quality.
Additionally, they will include external surveys.
The Maintenance Section Manager has developed performance indicators to determine the effectiveness of program improvements in the area of preventive maintenance.
The vendor information control program will be evaluated to determine necessary improvements.
The Station Manager will utilize the key indicators developed above to provide a monitoring system for determining maintenance performance. Goals will be established and progress tracked monthly.
l The Maintenance Section holds two meetings each week with e
l station sections to solicit input on maintenance priorities and progress.
Significant reductions in the backlog of security and fire protection maintenance items are apparent.
4.
Security and Safeguards Recommendation:
High level corporate and site management attention at the recently established priority level for the security program upgrade should continue in order to implement commitments and develop an effective program.
Response
The new planning and control function will help senior management to ensure completion of the security program upgrades and aid in the timely implementation of security and safeguards program commitments. The current status and progress was recently provided in our May 6, 1987 Management Meeting 86-41 Status Report.
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- 5.
Fire Prctection Recommendation:
Significantly reduce the amount of inoperable fire protection equipment in the station.
Response
Fire protection program improvements have been addressed in the following three key areas:
Improved fire protection management Personnel to properly monitor and supervise fire protection functions Administrative controls and data management.
The new Nuclear Fire Protection Group Leader brought on board in December 1986 has been given the full support of management to improve the fire protection program at Pilgrim Station. The new Group Leader has extensive management and technical experience in the nuclear industry and has been involved in Fire Protection projects. Accomplishments made toward achieving the following established goals are as follows:
- 1. Improved system availability
- A system status board is being maintained in both the control room and the fire protection office. This status board, which is updated daily, has been very useful in establishing control of system maintenance and availability.
- Establishment of routine and weekly maintenance priority meetings provides a platform to present priority maintenance items.
- Maintenance items are routinely monitored.
- These activities and others have been effective and have resulted in a reduction of outstanding maintenance requests from approximately 260 in January to about 85 last week.
- 2. Reduced reliance on compensatory measures
- A newly created fire watch management system assigns responsibility for resolving the condition requiring an assigned fire watch. A report, along with Nuclear Fire Protection Group coordination of initiation and retirement of fire watches has proven effective in controlling and reducing fire watch compensatory measures related to outstanding maintenance.
- 3. Fire brigade training
- Fire brigade training has been strengthened by the addition of a dedicated fire brigade instructor. He are rigorously enforcing brigade training requirements.
PT We have impr;;ved drill content and executicn, and we have improved equipment utilization.
- 4. Centralized control of fire protection
- The Fire Protection Group has developed plans and is scheduling activities toward achieving centralized control of fire protertion.
For example, a proposal is being developed to provide control of fire protection surveillances under one group.
The personnel added and systems implemented to support the goals established have proven to be effective and will continue to be refined. Attainment of these goals and completion of the Appendix "R" improvements will more than meet NRC Fire Protection Program objectives.
6.
Surveillance Recommendations:
Significant site and corporate management attention is needed to correct deficiencies in this area.
Place a single qualified individual in overall charge of the surveillance program.
Responses:
The Senior Vice President has initiated an independent study to analyze root cause for reportable surveillance test events.
Initiatives which are underway to address these causes are as follows:
- A validated data base will demonstrate Technical Specification procedure adequacy.
A state-of-the-art computer will manage the data base and generate test schedules reflective of plant conditions.
The Licensing Group will provide an interpretation of "once per cycle" requirements.
The technical adequacy of logic system functional testing and simulated automatic actuation testing is being verified.
Attention to procedural detail is being stressed under other broader station programs.
A training program is being developed for administrators and users of the new system.
Control of the surveillance data base and future changes will be centralized within the Technical Section.
The program will be managed by the Technical Section Group.
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- 7.
' Assurance to Quality Recommendation:
Continue senior management attention to~1dentified problems to ensure that they are promptly and effectively resolved.
Response:'
Senior managers will' periodically review the corrective action process and results. Appropriate accountability controls will be established to ensure prompt and effective results. The work management and prioritization controls being implemented by the new planning and control function will improve communication of problems and timeliness of resolution.
Individual accountability will be enhanced within this centralized scheduling framework. Actions to improve our awareness of and responsiveness to quality requirements include:
- Weekly meetings between the Quality Assurance Department-Manager and his staff and the Nuclear Operations Manager and his staff to discuss QA differences and rapidly resolve problems.
- The institution of a monitoring and reporting program for Quality Assurance recommendations.
- All supervisors are required to attend basic supervisory training where Quality Programs are emphasized.
- The use of extensions to Deficiency Reports and their resolutions have been discouraged, resulting in a more timely resolution.
- GET has been modified to place emphasis upon "doing it right the first time."
- The newly formed Systems Group and the improved staffing of the Site Engineering Office have demonstrated our improved ability to respond to technical issues and identify root causes in a timely manner and provide independent oversight.
- A pilot Balance-of-Plant quality program has been instituted to improve the overall station performance.
- Each section has an ass 1gned planner, resulting in the improved overall timeliness of responses.
8.
Emergency Preparedness Recommendation:
Continue to pursue resolution of off-site issues.
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Response
The Emergency Preparedness Coordinator will continue to utilize expertise to improve off-site emergency preparedness. The current effort for off-site plan improvements will continue in order to achieve resolution of identified issues.
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