ML20235R464
| ML20235R464 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/05/1988 |
| From: | Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20235R314 | List:
|
| References | |
| FOIA-88-519 NUDOCS 8903030314 | |
| Download: ML20235R464 (16) | |
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4 AUG 051999 MEMORANDUM FOR: Sa... e1 J.' Collins, Deputy Director Division of Reactor Projects -
THRU: James T. Wiggins, Chief Reactor Projects Branch No. 3.
A. Randy Blough Chief .~ p JJ I
Reactor Projects Section No. 3B ' -
FROM: Lawrence T.. Doerflein, Project Engineer Reactor Projects Section No. 3B
SUBJECT:
REVIEW OF BOSTON EDISON COMPANY'S RESTART READINESS SELF-ASSESSMENT This memorandum forwards a report of the results of the NRC staff review of the Boston Edison Company - (BECo) restart readiness self-assessment report and process. The review was conducted on site during June 20-24, 1988, by Glenn Meyer. - Senior Resident Inspector, Hope Creek; Frank Akstulewicz, PSTB, NRR; and myself (as team leader). Our conclusions, as stated in the report, were. presented to Messrs. R. Bird and R. Ledgett at the end of our review.
Overall, the NRC staff found that: (1) BECo's self-assessment process appeared thorough and the Management Oversight and Assessment Team was effective in
' screening a number of diverse inputs on plant and program status to develop and prioritize issues requiring resolution; (2) BECo has established, and plans to continue, various programs which are effective in assessing program and personnel performance; and (3) BECo has established plans and programs to i satisfy the Confirmatory Action Letter 86-10 requirement for checklists to assure all outstanding items are satisfactorily resolved and plant systems properly restored for operation. No new issues were identified during the review which would negatively affect conducting the NRC Integrated Assessment Team Inspection.
Lawrence T. Doerflein Project Engineer
Enclosure:
As stated Distribution (w/ enc 1):
Restart Panel Members Glenn Meyer Frank Akstulewicz 8903030314 890223
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lf ENCLOSURE l
Report on the NRC Review of Boston Edison Company's Restart Readiness Self-Assessment
- 1. Background and Introduction On April 12, 1986,. Pilgrim Nuclear Power Station (PNPS) shutdown due to a series of recurring technical problems. At that time, Boston Edison Company (BECo) agreed in Confirmatory Action Letter (CAL) No. 86-10 to obtain NRC Region I Administrator approval prior to plant restart. Subse- ,
quently, most of the technical issues causing the shutdown were resolved. I However, due to the number. and scope of outstanding performance related issues identified in .the 1985 Systematic Assessment of Licensee Perform-ance (SALP) and subsequent Diagnostic Team Inspection (50-293/86-06), the Regional. Administrator, extended the requirements of the CAL in a : letter dated August 27, 1986, to include submission of a written report documen-ting BECo's formal assessment of the readiness for restart operation.
On . May 26,1988, BECo submitted the Pilgrim Nuclear Power Station Self-Assessment of Readiness for Restart Report. The report summarizes the process and conclusions of BECo's self-assessment, focusing only upon the relatively discrete set of issues BECo management considered most import-ant and worthy of greatest attention at that time. On June 7, 1988, NRC-staff conducted an onsite, preliminary review of the basis for BECo's con-clusions as documented in the self-assessment report. A detailed review of BEC6's self-assessment process and the basis for the conclusions was conducted onsite June 20-24, 1988. The results of this detailed review are documented below.
II. Discussion and Evaluation The Pilgrim Nuclear Power Station Self-Assessment of Readiness for Restart Report summarizes the process and conclusions of BECo's self-assessment but limited the discussion to a relatively discrete set of issues con-sidered most important by BECo management. The objectives of the NRC staff onsite review of the self-assessment report and process were: to understand the contents of the self-assessment data base and BECo's methodology in reaching its conclusions; to determine if the self-assessment report satisfied the requirements of Confirmatory Action Letter 86-10; and to provide feedback to NRC management on the scheduling of the Integrated Assessment Team Inspection based on the status of BEco's cor-rective action programs and implementation schedules for those self-assessment issues requiring action prior to restart. The NRC review con-sisted of personnel interviews, staff observations, and record reviews.
The following discussion provides the NRC findings relative to the stated objectives and includes: an overview of the self-assessment process; a description of the Management Oversight and Assessment Team (MO&AT) and the programs and screening process used; and CAL 86-10 status.
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-Enclosure; 2 A. Self-Assessment Process Overview.
-In early 1987, BECo performed a series of self-assessments to iden-tify/ verify problem areas and determine the desired conditions'. For each issue: identified, corrective actions to achieve.the desired con-dition; were established, specific closure criteria developed, and.
responsible managers assigned. The assessments resulted in the PNPS -
Restart Plan, the_ Material Condition Improvement Action Plan (MCIM),
and the. Radiological Action Plan (RAP). Specifically, _the . Restart Plan contained the programs, plans, and actions' considered necessary.
by. BECo management for the safe ' and: reliable restart and, continued operation;of.PNPS; It concentrated on specific activities to correct and prevent recurrence of weaknesses previously identified by NRC, the Institute of Nuclear Power Operations (INPO), and BECo. The Restart Plan also defined the basis for assessing restart readiness.
.The MCI AP . and RAP, containing both restart'.and long-term actions, established programs to achieve long-term improvement'in the material' condition and- overall. quality of maintenance and radiological con-trols at PNPS.
In October 1987, also in response to the NRC August 1986 letter, BECo submitted ; the Power Ascension Program. This program established an oversight and assessment team, consisting of six senior ' level man-agers, - to observe personnel and equipment performance during the Power . Ascension Program, perform assessments at specific hold points, and confirm readiness for continued operation. In January 1988, this Management Oversight and Assessment Team (MO&AT) became functional in an expanded role. The number of team members was increased to eight and it became responsible for conducting the self-assessment of read-iness for restart. A preliminary assessment by BECo line managers, with the results presented to MO&AT, was performed- February 22 to March 11, 1988 to confirm PNPS ' readiness to conduct the full-manage-ment ' self-as sessment. MO&AT conducted the restart readiness self-assessment (RRSA) from April 19 to May 2, 1988, which _ included: -team observations during plant and system walkdowns; personnel interviews; simulator- observations; line manager interviews ana presentations; and inputs from the peer evaluator, Quality Assurance (QA) surveil-lance monitoring and management monitoring programs. The results of this full assessment are documented in Self-Assessment of Readiness for Restart Report submitted by BECo on May 26, 1988. Details on the process used by MO&AT and the findings -and conclusions reached are discussed below. A chronological listing of the significant self-assessment milestones is attached.
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Enclosure 3 B. Managemen't Oversight and Assessment Team (MO&AT)'
The core of the BECo restart readiness self-assessment has been the :
Management .0versight and ' Assessment Team (MO&AT). The MO&AT.provided the ultimate review of the numerous. outage work completion programs, e.g., Restart. Regulatory Responses, MCIAP, RAP, etc., while con-currently using its own assessment of activities at Pilgrim to interact with the line~ managers -directly responsible for. the activities. More specifically,. during intensive meetings over
'approximately four. weeks, MO&AT reviewed the completion status of all functional elements of the Pilgrim Station based on the presentations-of the responsible managers. Despite the importance of this content review of the functional elements, an equally important aspect of the
_ MD&AT review -was- the process of the senior -- managers on MO&AT interacting with the responsible managers regarding the acceptance
-standards for the work and the manner in which it. was to be completed. The NRC staff judged ' this interactive process to' be a critical part' in' the changing of the previously held attitudes at Pilgrim,iwhich may have caused previous self-improvement programs at Pilgrim to be of only limited success and duration.
.The MO&AT is composed of eight senior managers, including the Senior '
Vice President - Nuclear, who acts as the Chairman. ._The staff found that the MO&AT members have responsibility in all functional areas, including . station operations, engineering, and qutlity assurance.
Further, three MO&AT members had been BECo managers prior to the arrival of the Senior Vice President - Nuclear, while the remaining five managers joined BECo subsequent to February 1987. Also, four of the MO&AT members had significant management experience in the Navy nuclear program. The s,taff judged the diverse backgrounds, experi-ence, and responsibilities of the MO&AT members to be an advantage in assessing the activities at Pilgrim.
To evaluate the MO&AT review process, the staff reviewed the RRSA, reviewed the records of the MO&AT meetings, and interviewed MO&AT members and - line managers regarding the MO&AT review process. In addition, parts of the MO&AT meetings were directly observed by other NRC inspectors during inspection 50-293/88-17 and by the resident inspectors. The most direct MO&AT/line management review occurred during a preliminary review from February 22, 1988 to March 11, 1988, and during a subsequent review from April 19, 1988 to May 2, 1988. A MO&AT member estimated that these review meetings had totaled approx-imately a hundred hours. Written records of these meetings are minimal as the prccess appears to have been largely oral.
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In addition to the line manager presentations, the MO&AT members re-ceived oral presentations and individually reviewed written reports concerning other BECo assessments, i.e., peer Evaluation Program, Management Monitoring Program, and QA Surveillance Monitoring Program L'
(discussed below). Further, an integral part of the MO&AT review.was
' ' the actual review of _ field. work and equipment conditions by MO&AT members The two MO&AT/line manager review pe'riods were preceded by planned equipment walkdowns, record reviews, interviews with _ plant personnel, and observations - of operating crew performance on the-simulator. Also, the MO&AT members followed up on line manager pre-sentations to confirm that field observations - were consistent with the managers' assessments. A MO&AT member estimated that he had spent two hours in the field for each hour in MO&AT review meetings.
As stated earlier, MO&AT received significant inputs from many diverse programs. A description of the programs which contributed to_the overall assessment process are described in turn.
- 1. Line Manager presentations The restart readiness self-assessment began with responsible line managers assessing the readiness of their functional area.
The results of these assessments were formally presented to MO&AT during the preliminary review February 22 to March 11, i 1988, and a subsequent review April 19 to May 2,1988, and were i the basis of BECo's self-assessment. MO&AT supplemented the line manager assessments during- the presentations with the team's own observations based on plant tours, personnel inter-views, and information from the peer evaluator, management monitoring and QA surveillance programs to develop a list of issues requiring further followup action. Those issues requir-ing corrective action prior to restart are identified in Section II.A of BECo's self-assessment report. ;
i The areas to be covered during the line manager presentations were specified by memorandum. The presentations were an oral report of the current status of all actions required for re-start, major open areas and areas of uncertainty, and the ac-tions in place or needed to address the open areas or areas of uncertainty. Specifically, the presentations addressed: re-start plan, MCIAP and RAP status; the status of INPO action <
items; and updated evaluation of the Systematic Assessment of l Licensee Performance (SALP) 86-99 concerns which also included relevant portions of any- subsequent NRC inspection report and )
relevant BECo experience since the SALP; and the line managers overall observations or conclusions concerning readiness. Dur-ing the rareliminary review, the presentations were made by the
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a Enclosure 5 seven department managers. The subsequent review involved pre-sentations by twenty managers. The NRC staff interviewed several line managers who gave presentations and MO&AT members who participated in the presentations to evaluate the process.
Each of the managers indicated that the presentation sessions
.were thorough and rigorous; that MO&AT was well informed on plant problem areas and asked probing questions; and that the
. developed list of issues represented the weaknesses and poten-tial problem areas at PNPS.
Based on the NRC staff review, which consisted largely of in-terviews, the staff concluded that the line manager assessments forming the basis for BECo's self-assessment were appropriately supplemented and verified by MO&AT; and that ~ the presentations and process appeared thorough.
- 2. Peer Evaluation Program The. Peer Evaluation Program .is a BECo ' initiative 'to have know-ledgeable personnel review work in progress .within ;their field of expertise. Seven different functional areas are~ covered.
Although specifically created to. review work during the power ascension phase, BECo senior management stated that the program -
is tentatively planned to be extended indefinitely. to evaluate -
routine operations. The staff reviewed the program to evaluate its effectiveness thus far and its potential to assess work during reactor operations.
The staff found that the program included 14 evaluators, who had been nominated by their supervisors and accepted by the program coordinator in late 1987. These evaluators received 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of training and performed two practice evaluations with the train-ing staff. The staff reviewed Nuclear Organization Procedure (NDP) 88A1, Performance Standards and Evaluation Guidelines, which represents the specific standards which the evaluators utilize, and found the procedure to be thorough and a suitable standard for evaluation. A second set of eight evaluators was being trained to augment these 14 evaluators.
The staff interviewed three evaluators and found that although they had initially been skeptical, the evaluators appeared to be highly supportive of the Peer Evaluator Program. The evaluators acknowledged that evaluating the work of others within their field had potential problems, but all evaluators interviewed stated that the process was workable. In discussions with an evaluator and the Senior Vice President - Nuclear, the staff confirmed that the Senior Vice President - Nuclear had inter-vened in one instance to resolve a personnel conflict and to L reaffirm the intent of the evaluation program.
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Enclosure 6 L Based on discussions with the program c.cordinator, attendance .at
- an evaluator meeting,iand review of records, ' the staff found' that the : evaluator's .- findings are documented and sent to the responsible line manager for . corrective action. . The findings' are tabulated.and trended according to procedure, personnel,.and
. plant equipment problems and ; strengths. MO&AT members receive reports with finding summaries and trend analyses. As of June 20, 70f evaluations had been performed and had ' found 74 problems.
'The staff reviewed a sample of evaluator findings and found'them to ' be substantive, . specific descriptions of work'_' practices either not meeting the intent of ex1 sting procedures or in need of upgrading. In previous . discussions with the staff, MO&AT members stated that work needed to meet . rising standards. The staff noted that this theme had been effectively communicated to the evaluators during their training - and was evident' in the evaluators' findings. Also, in later evaluations of the follow-up. items resulting from the MO&AT review, the st'aff- noted. that problems-in field activities documented in'some followup items' had been earlier identified in evaluator findings. .However, due to the nature of the MO&AT review, the staff could not aetermine whether the followup items came directly from the Peer Evalua-tion Program or from MO&AT member observations or line manager presentations.
The program coordinator discussed corrective actions which had resulted for some of the problems identified by the evaluators.
Although no formal system existed to specifically close out and track corrective actions on the evaluators' findings,- the pro-gram coordinator stated that work was -underway to establish a clearinghouse to funnel the findings into existing corrective action systems. Despite the past lack of a formal corrective action system to handle findings developed during the .self-assessment process, it was evident that corrective actions had occurred as line managers ' responded to correct the identified problems.
The staff noted that although program discussions included engi-neering/ technical support as a functional area and an engineer-ing evaluator had been trained, the NDP did not include stand-ards for this area and no evaluations had been performed yet.
The program coordinator acknowledged that progress in this area had not been equal to the other areas more directly related to j field activities, but he stated that future evaluations in l engineering were still planned. j i
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The staff concluded that the Peer Evaluation Program .was a well thought-out effort: with ' good management support' to identify problems in work in the field. The staff. concluded that the selection and training of the evaluators had been effective.
The staff judged that the program could be used effectively to -
evaluate plant activities during reactor operations. Further, the staff concluded that the Peer Evaluation- Program provided good potential for improving the standards - and attitudes of field workers, because knowledgeable co-workers provide inde-pendent evaluations of the work performed to the workers and their supervision.
- 3. Management. Monitoring Program The Restart Plan and the Self-Assessment for Readiness for-Restart Report (RRSA) refer to management monitoring processes
'which BECo has been using to identify plant deficiencies _ and to correct identified problems as well as. improve general house-keeping at the plant. The management monitoring processes men-tioned in the reports listed' above, began in August 1987. The initial program called the Management Monitoring Program was designed to use at least first-line supervisors for direct management observations of the performance of station. personnel as well as the material condition of the plant. While the pro-gram required that a record be made of the observations, the followup of any identified items was left to. the responsible technical group. There was no formal closecut process estab-lished to assure the timely completion of identified items.
During the period November 1987 through March 1988, a subset of the program members participated in a special management review of control room operations. During this period, the management monitoring team observed control room operators 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day with the intent of improving the performance of control room operators in the control room.
During March and April 1988, the structure of the management monitoring process was modified from-the use of individual manager observations to a team observation concept. The program was subsequently renamed the Management Watch Program (MWP) and the focus of the program was directed primarily to maintaining the material condition of the plant and general housekeeping matters. The first management tour under the revised program occurred on April 5, 1988.
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' The MWP consists of ' a team of six to eight first-line super-visors from different organizational units under the direction of a team. leader. Once a week, the team of ~ managers performs a'-
one' to two hour inspection of, specific areas-in the plant. Fol-
. lowing each management tour or. inspection,. the team leader pre-pares a tour report which identifies the . specific areas reviewed during the inspection tour and assigns responsibility for assur-ring that any identified' deficiencies are ' corrected. Unlike the earlier version of the program, the MWP .contains a. formal requirement to respond to a MWP coordinator following resolution of each item. Further,- failure to correct items' is also~ mon-itored and brought to. senior station management attention, as the need arises.
The MWP is not currently a program defined by fo' rmal plant pro-cedures. The station management has directed that a formal pro-cedure be prepared which defines this program but no completion date for this effort was available.
During this -review, the NRC staff was able to directly observe a regular MWP inspection tour (identified as Management Tour-88-11). The team leader for this tour was the principal opera-tions engineer. The other members of the. team included the maintenance supervisor, the -health physics supervisor, the con-struction management supervisor, the chief chemical engineer,
' the manager of the systems engineering division and the station services supervisor. Although he is not a routine tour member, the station director participated in this particular inspection tour.
Tour =88-11, which lasted about one and one-half hours, inspected the refueling floor and elevations 81 feet and 74 feet of the reactor building. These areas contain equipment for fuel hand-ling, the standby liquid control system and reactor building ventilation. This staff concluded that the tour was very.
thorough in its inspection of the material condition of the plant. Any findings were discussed within the group and, in particular, with the responsible supervisor to assure that the findings would be resolved promptly. A report of the tour find-ings and required followup actions was issued by the team leader.
Based on the staf f's review, it appears that the Management Watch Program is an effective tool for use by station management in identifying deficiencies in the material condition of the plant or for general housekeeping matters. Current management attention and support for the program is high and the formal followup process provides an adequate method for tracking the resolution of all MWP findings.
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- 4. lQua11ty' Assurance (QA) Surveillance Monitorihg Program The purpose of the QA Surveillance Monitoring program is to ob-serve routine operating activities using compliance-to' Scad"r and performance based ' surveillance. The frogram, which E was initiated in 1984, .is described -in the Boston Edison Quality Assurance Manual (BEQAM) and implemented -through QA procedures and . instructions by the onsite QA Surveillance.. Monitoring.
Division. .This division is staffed. with eight engineers of diverse expertise including two qualified reactor operators.
Each engineer is certified: as a lead audit. per ANSI N45.2.23.
The QA . surveillance are performed in all functional areas.
The staff. interviewed the line managers responsible for imple-menting the QA surveillance monitoring program and reviewed the various records and reports generated to evaluate the . scope and ef festiveness ' of the~ program. Surveillance schedules are pre-pared monthly. The staff not i that the scheduled surveillance.
cover all functional areas end are specified by. implementing procedures. Additional surveillance are - added at management discretion based' on observed . trends, industry ' experience feed-back, etc. Checklists are prepared and completed for each sur-veillance. Discrepancies noted during the surveillar'ce monitor-ing are recorded on a Deficiency Report (DR) in accordance with the BEQAM. Responsible line managers. are required to .dispo-sition the DR'and QA then verifies the completion and effective-ness of the corrective actions. Monthly status reports are also issued which lists the surveillance performed the previous
- month and summarizes the findings which includes DRs issued, recommendations, and the Immediate' Corrective Actions (ICA) taken. In addition', a quarterly' report is issued which, using a years worth of data, trends positive and negative findings. All the reports associated with the QA surveillance monitoring report are distributed to line management, including MO&AT.
1 MO&AT used the QA surveillance findings to identify or confirm potential problem areas. In addition, an overview presentation of the QA surveillance monitoring program was given to MO&AT.
As a result, MO&AT raised the issue that the program, because it was basically looking at regulatory compliance, was too narrow.
This resulted in the initiation of a program upgrade. The improvements will include revising procedures to ensure other areas, such as housekeeping and material condition, are observed during the surveillance . and providing the QA inspectors with peer evaluator and INPO observer training.
Enclosure 10 Based on the staff review, it appears the QA surveillance mon-itoring program was a useful tool in BECo's self-assessment pro-cess. The program emphasizes monitoring ongoing, in plant activities rather than record audits and as such provided an additional, independent source of information for assessing per-sonnel and program performance. The program identified signifi-cant issues such as the environmental qualificatiore program and drawing update control implementation problems. Finally, of all the processes used by MO&AT, the QA surveillance monitoring pro-gram is the most formalized, with well defined procedures for implementation and resolution of deficiencies.
C. Management Oversight and Assessment Team Results In the sections above, the staff described the various programs used by the licensee as sources of information for use in performing the self-assessment for restart readiness at the Pilgrim Station. The following is a discussion of the process which led to the generation of the action items required for restart as currently identified in Section II.A of the RRSA.
The restart readiness self-assessment process occurred from April 19 through May 2, 1988. As noted above, MO&AT served as the central or screening committee for the overall self-assessment effort. As part of this process, MO&AT reviewed individual MO&AT member observations or concerns, conducted interviews with line managers, and received presentations on the status of issues raised during the peer review process, management reviews and quality assurance i .9ections. Dur- !
ing the line managers interviews and presentations, any individual observation or a series of similar observations considered signifi-cant by at least one member of MO&AT was identified by MO&AT as a self-assessment item requiring additional followup action. This list i of "MO&AT issues" in general contained specific issues such as instrument valve lineup control and labelling problems or a noted training deficiency. However, the staff noted that during the course of the self-assessment, the MO&AT members may have identified several examples of the problem for any given MO&AT issue. This collective list of individual findings or examples of prehlems identified by MO&AT is termed the "MO&AT field notes."
After developing the list of issues, MO&AT prioritized them into four categories. These categories were:
(1) Action required in order to support publication of the RRSA.
(2) Action required in order to support the restart of the plant.
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E (3) Action required prior to completion of Lthe? power' ascension L1 program.
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(4) Long-term actions following plant restart.
Each '~of the. self-assessment issues identified by = MO&AT . during. the- L screening process was placed into one of the categories listed above.
The staff- reviewed the categorization of each -issue identified.- by MO&AT to assure it was ' properly prioritized. The staff also reviewed the status of the Category 2'issuesLto assure that planned corrective actions were scheduled and would be ' completed prior to restart. The-
- l. Category 2 issues- appear in ' the . BECo. Self-Assessment Report as
! Section II. A' " Matters Relating to Plant and Equipment Performance,.
I Operational Performance, and Management and Organization-that Require Specific Action Before Restart." The licensee indicated MO&AT would verify closure of the Category 1 and 2 issues.
One of the actions described in Section II'.A.1'of the licensee's RRSA-is the creation of. a " corrective action clearinghouse." ' During the -
review of the licensee's self-assessment process; the staff reviewed
'the licensee's plans- and implementation of the clearinghouse. The-staff did encounter some difficulty in understanding the program because the clearinghouse concept, purpose, and responsibilities were' not defined in writing at the time of our review. As a result, the following discussion is based primarily on.information obtained from discussions with the clearinghouse coordinator.
The clearinghouse is a licensee program which will be implemented to assure that all deficiencies described in the MO&AT field notes or in peer evaluator reports have been resolved or have been assigned to a responsible group for resolution. .It is also the intent of . the clearinghouse to maintain a record of the completion of each defici-ency. In particular, the staff understands the clearinghouse respen-sibilities to be: j
- 1. The review of deficiencies contained in the MO&AT field notes and peer evaluator reports to determine if the necessary main-tenance requests, deficiency report, nonconformance report, etc.
had been prepared for resolution of the specific item. .
- 2. The preparation of the necessary paperwork to assure resolution of a particular item if the appropriate paperwork had not been previously prepared.
- 3. The establishment of a tracking system for the resolution of identified items which may not conform to any of the existing plant tracking systems.
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- 4. The establishment of reporting requirements for resolution of identified items.
- 5. The maintenance of records or references of the completion or resolution of each identified item.
The clearinghouse coordinator stated that meetings had been scheduled with each of the plant system engineers to begin in early July as a primary effort to resolve a number of the specific items.
During the staff review, June 20-24, the clearinghouse licensee's program was only in the beginning stages of implementation and all specific details of the program had not yet been completely established. As a result, the staff was not able to reach any conclusions concerning the completeness or implementation of the licensee's corrective action clearinghouse program.
Based or the staffs review, it appears BECo's self-assessment process was effe:tive - and thorough. MO&AT identified a list of issues re-quiring f L11owup actions based on information from several sources and from line manager assessments. The staf f concluded that ;MO&AT properly classified the issues into the four categories discussed above. The staff also concluded that the MO&AT field notes and peer evaluator reports need to be reviewed to ensure all deficiencies are properly resolved; however, no conclusions could be reached on the adequacy on the " clearinghouse" in accomplishing this task given the early stage of prugram definition and implementation.
D, Confirmatory Action Letter (CAL) No. 86-10 The August 27, 1986 update to CAL 86-10 requiring the formal assess-ment of readiness for restart operation also requested that the assessment include a detailed check list for assuring that all out-standing items were satisfactorily resolved and that plant systems I have been restored and prepared for operation.
As noted above, the Restart Plan concentrated on activities to cor-rect and prevent recurrence of previously identified weaknesses.
Specifically, the Restart Plan, Volume 2, Appendix 10 " Restart Regulatory Commitments", identifies the action items developed to address NRC concerns. Initially, Appendix 10, submitted with the Restart Plan, Volume 2, Revision 1, on October 26, 1987, contained 450 items, the majority of which addressed Systematic Assessment of Licensee Performance (SALP) 86-99, CAL 86-10, and management meeting 86-41 issues. Commitments from NRC inspections or other NRC-BECo correspondence made after October 26, 1986 were added to Appendix 10, such that the May 26, 1988 revision contained 524 items. Of these, 498 are restart issues of which 412 have been completed and closed.
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The.' staff reviewed the action item closure process and found it to be-
. formal and rigorous. Specific acceptance criteria were developed for each item. Responsible managers verified completion of the item
. which then was reviewed by two _ additional levels of management for acceptance and closure. An independent third party, in this case members _ of the compliance group, was used to verify adequacy and completion of the item. The MCIAP and RAP issues followed a similar closure process. Finally, MO&AT _ received _ line manager presentations on the restart plan action item status during the RRSA.
As stated in the Restart Plan, ~one of the bases for BECo's self-assessment of PNPS readiness for restart was that system group reviews would be completed and restart actions identified _ by those reviews would be closed or specifically scheduled in the approach to startup.. The May 26, 1988 update to Appendix 12,, " System Summary Status Report," of the Restart Plan provides' the results of these-
- reviews 1 and information on system status. The report provides an overview and addresses major work or significant' issues affecting the-system. A : similar report is issued approximately monthly to BECo management. This practice is expected to be formalized and continued.
While Appendix 12 provides an overview, System Status Books are main-tained by system specialists who are assigned responsibility for tracking work on specific systems. The staff reviewed - the System Status Book for the Residual Heat Removal System and found it con-tained a detailed system status which included: a . listing of all priority 1-5 work items on the system; all surveillance testing status; the results of_ the weekly system walkdowns; current mainten-ance request listing; and, the startup checklist. As with other Restart Plan items, MO&AT received detailed line manager presenta-tions on system status.
In addition to Appendix 12, BECo uses a system of checklists to track the completion of designated milestones leading to restart and opera-tion of PNPS. Appendix 10, item 01-009-09, references the Operating Condition Checklist No. 6, " Pre-Critical Tests / Plant Startup", which identifies those items required to be resolved prior to restart. The checklist is maintained on an automated data base and is coordinated by a staff assistant to the Senior Vice President-Nuclear. Each item on the checklist has a responsible individual and manager assigned to
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complete the item. The staff reviewed checklist No. 6 and found it l
to be a detailed listing and included verification of items such as:
system operability (surveillance testing and valve lineups); mainten-ance requests; modification packages; QC deficiency reports; engi-neering support requests, and f#C commitments from inspections or bulletins. The staff ' also.noted that completion of the checklist is required to be reviewed and approved by the Operations Review Com-mittee prior to plant startup.
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O' Enclosure 14 ,
1 L Based on the abov' e , ' the staff cbncluded - that BECo had systems or j programs in place to ensure all outstanding ' items are resolved and that' systems would be properly restored prior.to restart..
p III. Conclusions-In conclusion, the staff. has reviewed the self-assessment process used by' the licensee.at the Pilgrim station. Based upon our own observations, our discussions ' with station personnel and our review of the self-assessment records, the staff:has concluded that:
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'1. 'The Management Oversight and Assessment Team. was the core of BECO's self-assessment. MO&AT -was ' effective..in screening a number - of diverse . inputs on plant - and program status to develop a list of issues requiring ' resolution. , These issues were- properly classified to identify those requiring resolution prior to plant restart. Over-
.all, the ' sel f-assessment process appeared thorough - and . rigorous.
- 2. The peer evaluator program, . management watch program, and . the QA.
surveillance monitoring program were all effective tools'in assessing plant and personnel performance and identifying deficiencies. Man-agement support for these programs is high and management-indicated these programs would continue.
- 3. The programs in place, including the Restart Plan (Appendices 10 and'
- 12) and the _0perating Condition Change Checklist,. appear to satisfy the CAL requirement that detailed checklists be developed to assure all . outstanding items were satisfactorily resobed and that plant systems are restored and prepared for' operation.
- 4. The corrective ' actions and schedules 'for those issues requiring specific action prior to restart appear adequate. 'There were no new issues identified during the NRC staff review which would negatively affect conducting the NRC Integrated Assessment Team Inspection.
Issues, including emergent issues such as NRC Bulletin 88-05,
" Potential Nonconforming Materials Supplied by Piping Supplies, Inc.
and West Jersey Manufacturing Company, are being actively tracked by Boston Edison Company.
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t ATTACHMENT
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Self-Assessment' Milestones L'
Date' Event April12, 1986 Pilgrim- shu'tdown; Confirmatory Action Letter (CAL)-. No.
86-10 issued August 27,.1986- NRC letter extending requirements of CAL' to include a for-mal assessment of' readiness for restart July 29, 1987. NRC-Boston Edison Company' (BECO) Management MeetingL(No.
50-293/87-28) to discuss licens'ee approach to restart assessment-July 30, 1987 BECo submits Restart Plan and Material Condition Improve-
. ment Action Plan (MCIAP)
October 15, 1987 'BEco submits Power Ascension Program October 26, 1987 BECo submits Volume 2, Revision 1.(updated resuits) for the Restart Plan December 30,~1987 BECo submits Radiological Action Plan (RAP)
- January 4, 1988 BECo submits Appendix 7 to Volume 2 of the Restart Plan,
" Summary Status of Restart Actions in RAP" February 24, 1988 NRC-BECo Management Meeting (No. _ 50-293/88-10) to discuss
, BECo's self-assessment process designed to determine read-iness for requesting restart permission February 22 - BEco's preliminary assessment March 11, 1988
. April 19 - BEco's Restart Readiness Self-Assessment Ma/ 2, 1988 May 26, 1988 BEco submits the Self-Assessment of Readiness for Restart Report and Volume 2, Revision 2 for the Restart Plan
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