ML20236G407

Vol 1 to Pilgrim Nuclear Power Station Restart Plan. Rev 0 to Vol 2,appendices,encl

ML20236G407
Person / Time
Site:	Pilgrim
Issue date:	07/30/1987
From:	BOSTON EDISON CO.
To:
Shared Package
ML20236G395	List: ML20236G392 ML20236G407
References
PROC-870730, NUDOCS 8708040246
Download: ML20236G407 (133)

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{{#Wiki_filter:1 1 6'N i O i i PILGRIM NUCLEAR POWER STATION RESTART PLAN 1 VOLUME 1 [D %./ I 1 1 l APPROVED: T!80/h7 Date: R.G. Bird Senior Vice President - Nuclear l l l l k 870B040246 070730 PDR ADOCK 05000293 ^ p PDR w__-________

TABLE OF CONTENTS g J i Pace Executive Summarv............,...................,...... ES-1 j I. Introduct. ion....................................... I-l II. Manacement......................................... II-l A. Corporate Commitment.......................... II-2 B. Organizational and Personnel Changes.......... II-6 1 III. Operational Performance............................ III-l A. Specific Staffing and Experience Increases.... III-2 B. Training...................................... II.I-13 C. Procedures.................................... III-16 D. Performance Assessment Techniques............. III-17 E. Review of Restart Regulatory Responses........ III-20 F. Work Control.................................. III-26 G. Corrective Action Programs / Assurance of Quality.................................. III-32 IV. Plant And Ecuinment Performance.................... IV-1 (3 imd A. Maintenance Backlog Reduction................. IV-2 B. Radiological Controls......................... IV-7 C. Radiological Action Plan...................... IV-ll D. Fire Protection............................... IV-ll E. Security...................................... IV-14 F. Surveillance.................................. IV-17 G. Plant Operational Condition Change Checklists. IV-21 H. Systems Group................................. IV-24 I. Confirmatory Action Letter No. 86-10 Items Closure............................... IV-28 J. Power Ascension Program....................... IV-29 V. Bayes for Readiness Assessment.............. V-1 List of Accendices...................................... A-1 l \\ () t-i . - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _.. _ _ _ -. - ~ _... ._...-.__]

/~% LIST OF ACRONYMS V As Low As Is Reasonably Achievable ALARA American Nuclear Insurers ANI BEQAM Boston Edison Quality Assurance Manual BWR Boiling Water Reactor CAL Confirmatory Action Letter Chief Executive Officer CEO Chief Operating Engineer COE DR Deficiency Report Emergency Core Cooling System ECCS EOP Emergency Operating Procedure EPG Emergency Procedure Guideline Engineering Support Request ESR Failure and Malfunction Report F&MR Federal Emergency Management Agency FEMA Final Safety Analysis Report FSAR GET General Employee Training HPES Human Performance Evaluation System ISC Instrumentation and Control Inspection and Enforcement I&E Institute of Nuclear Power Operations INPO Independent Radiation Protection Oversight IROC Comaittee In-Service Inspection ISI I LCO Limiting Condition for Operations MCIAP Material Condition Improvement Action Plan \\q Maintenance Request MR i I

Non-Conformance. Report . i NCR' O. NCT Nuclear Control Technician Nuclear Engineering Department NED Nuclear Operations Department NOD NRC Nuclear Regulatory. Commission Nuclear Safety Review and Audit Committee NSRAC OE-Operations Engineer Operations Review Committee ORC Plant Design Change PDC PET Performance Excellence Team Pilgrim Nuclear Power Station PNPS Quality Assurance QA Quality Control j QC i Radiological Action Plan RAP ' Refueling Outage No. 7 RFO-7 Reactor Operator RO ROR Radiological Occurrence Report Radiological Work Permit RWP Systematic Assessment of Licensee Performance SALP SEP Safety Enhancement Program Scope Justification Approval SJA Senior Reactor Operator SRO Safety System Functional Inspection SSFI Tech Spec - Technical Specification Work Authorization.and. Control Branch WACB WSRC. . Work Scope: Review Committee O b _-_._----__._-.--__-------___-...L..__-

l l l l 1 O v1 ton 1a noctzia rowca srar1on RESTART PROGRAM PLAN EXECU1IVE

SUMMARY

This report describes the programs, plans, and actions considered necessary by Boston Edison Company (Boston Edison) management for safe and reliable restart and continued operation of Pilgrim Nuclear Power Station (PNPS). This report focuses upon the programs, plans, and actions to upgrade performance in the areas of management, operations, and plant and equipment. The report concentrates on the specific activities that are either in progress or planned to_ correct and prevent recurrence of weaknesses previously identified by Boston Edison, the U.S. Nuclear Regulatory l Commission (NRC), and the Institute of Nuclear Power l Operations (INPO). The repor' does not, therefore, address the full range of actions that have been and vill be taken throughout the course of the outage relating to the design, construction, testing, and operation to assure safe and reliable operation. While not considered as NRC prerequisites for restart, nor g (j specifically addressed in this report, continued safe and reliable PNPS operation will also be supported by the performance of the following programs and activities: o The Safety Enhancement Program. Offsite emergency planning actions addressed in o Boston Edison's interactions with local, state, Federal Emergency Management Agency (FEMA), and NRC emergency planning personnel. The programs, plans, and actions described herein extend beyond the original circumstances that led to shutdown of PNPS or that were encompassed within NRC's Confirmatory Action Letter (CAL) No. 86-10, dated April 12, 1986. The decision to extend the current outage was made by Boston Edison management and demonstrates its commitment to increased management involvement and control at PNPS. While the NRC has never found PNPS to have been unsafe, enhanced NRC confidence in future PNPS operation is required. The decision to request restart will be made by Boston Edison management only after first assuring itself that the level of Boston Edison management involvement and control, coupled r) with the implementation of the programs, plans, and actions (.J ES-1

described in this report, is sufficient to assure safe and reliable operation, and to restore and maintain NRC q, confidence. Future success in restoring and maintaining NRC confidence will ultimately be measured by improved NRC Systematic Assessment of Licensee Performance (SALP) ratings. As shown throughout this report, the programs, plans, and actions being undertaken by Boston Edison will specifically and systematically respond to and resolve the concerns previously identified by NRC inspections in certain fundamen-tal areas at PNPS, including: o Staffing o Work backlog o Responsiveness to regulatory concerns o Timeliness and effectiveness of corrective actions. l The Restart Plan includes both actions conside. red necessary for restart and longer term actions that will assure contin-ued improvement and safe operation. While the latter actions are less urgent, they are equally important to the achieve-ment of Boston Edison's objectives. This report is organized to describe Boston Edison's Restart Plan in the following sequence: o Introduction - Chapter I (~S (_/ o Management - Chapter II o Operational Performance - Chapter III o Plant and Equipment Performance - Chapter IV o Bases for Readiness Assessment - Chapter V o Appendices (Volume 2). The contents of Chapters II - V of the report are summarized below. CHAPTER II MANAGEMENT Boston Edison's self-assessments of management have confirmed that two basic factors are essential to bring about sustained management improvements: o a strong corporate commitment to improvement; and o a stronger Nuclear Organization. Boston Edison's senior management is committed to providing i the financial and manpower resources to assure safe and reliable restart and continued operation. The Chairman and rm Chief Executive Officer (CEO) has participated directly in Q) l I ES-2

e management of the restart effort, and a special Nuclear () Operations Review Committee of the Board of Directors-is involved in review and oversight of the restart activities. Boston Edison's corporate commitment to. excellence at PNPS has been passed down and implemented.in both the Nuclear Organization's mission statement and a set of challenging performance goals for each major component of the Nuclear Organization. Boston Edison's approach to strengthening the Nuclear ] Organization takes into account the strengths and weaknesses a that have been evident at PNPS. The existence of fundamen-i tally sound operators and engineering suggests that an infusion of experienced management talent and additional I technical personnel into areas noted to have been weak will best address current needs. This measured approach to organization is expected to pay dividends in terms of the timeliness, effectiveness, and permanency of Boston Edison's recovery efforts. The. Nuclear Organization has been strengthened by the addi- ^N tion of new management personnel with successful track l records in nuclear power activities. A new Senior Vice President - Nuclear was hired to report directly to the Chairman and CEO. He is stationed at the site and has also assumed the duties of the Vice President . Nuclear Operations to maintain close contact with and direction over operational (3 matters at the site. Two experienced senior managers, g) reporting directly to the Senior Vice President - Nuclear, have assumed oversight of line organization activities and direction of planning and restart: activities. Additional experienced managers have been placed in charge at PNPS in the areas of Fire Protection, Security, Radiological Controls, Emergency Planning, Systems, and Operations. Dedicated planners have been assigned to each PNPS Section and the organization has been realigned to elevate Fire Protection, Security, Emergency Plunning, and Nuclear Training to report directly to the Vice President - Nuclear i Operations. Additional engineering support has been placed directly at the site. A' Systems Group that provides dedi-cated engineering specialists for major plant systems is also being established. Boston Edison is committed to a plan for transition to a longer term organization. This plan will build upon the strong corporate commitment and the actions already taken to strengthen the Nuclear Organization and, through close monitor %i g, will assure that the balance between personnel resources and work bai,xlog will be established at restart and remain under management control. O ES-3

/~T CHAPTER III (-) OPERATIONAL PERFORMANCE 1 Boston Edison's programs, plans, and actions are designed to { bring about sustained improvements in operational performance l by emphasizing the need to upgrade human performance and by l providing Boston Edison personnel with the capabilities and j tools to meet that need. The specific areas in which staffing improvements have been made include Maintenance, Operations, Radiological Controls, Fire Protection, Security, and Quality Assurance (QA), as follows: 1. Maintenance: Boston Edison has increased both the number and experience levels of production and supervisory personnel in the Maintenance Section, and is developing an apprenticeship program to further enhance expertise. In addition, Boston Edison has assigned full time planners and on site procurement support staff to assist in planning and coordinating maintenance work. 2. Operations: Boston Edison has increased the authorized complement of operators and will have suffi-cient operators available to support four shifts during !^T startup and power ascension, and six shifts in the K/ longer term. Boston Edison has also made improvements in training and technical support for the Operations I Section and has appoin_ed a new, experienced Section Manager. To better manage operator overtime, Boston Edison has established a 60 working hour per week guideline, and has improved the tracking and monitoring of operator overtime. 3. Radiological Controls: Boston Edison has hired a new Section Manager and appointed a Chief Radiological Scientist, a Radiological Assessor, a Chief l Radiological Engineer, and a 20-person Radiological l Technical Support Group. Boston Edison has also estab-lished a new Independent Radiation Protection Oversight Committee (IROC) to assess the effectiveness of its j radiological program. 4. Fire Protection: Boston Edison has expanded l the staffing of the PNPS Fire Protection Group from one to six, including a new Group Leader, and its visibil-ity has been increased by having the Group Leader report directly to the Vice President - Nuclear Operations. A new position to support fire brigade training has also l l ES-4 9

l been filled. In addition, Boston Edison is completing d i (]) modifications to achieve compliance with the fire protection requirements of 10.CFR PartH50, Appendix R. 5. Fecurity: Boston Edison has established a new Nuclear Security Group reporting directly to the Vice President -- Nuclear Operationb, and appointed a new, experienced Group Leader. Staffing at both the line and supervisory levels has been increased in the Group, and the contractor security force has also been strengthened through staff increases and a decrease in the supervisor-to guard ratio. 6. QA: Boston Edison's QA Department has been expanded to include a new Surveillance Group to conduct surveillance of daily operating activities. QA staff 1 have also-been dedicated to provide continuous oversight' I in the areas of procurement and'radwaste shipment control. As a complement to these staffing enhancements, Boston Edison has also conducted a review of the staff training function and initiated actions to improve the quality of training in the Nuclear Organization. A-new Training Section has been established by moving the training function out of the Management Services Section. _The Section Manager reports directly to the Vice President - Nuclear Operations, and an () internal reorganization has been completed to clarify respon-sibilities and strengthen management control. Four of the ten Boston Edison. training programs have been formally accredited by the National Nuclear Accrediting Board and the other six programs have been submitted for accreditation this year. Numerous programmatic improvements are also being made, including revision of the Training Manual, improved fire protection and general employee training, and introduc-tion of new technical courses for site personnel, including courses on contamination control and specialized respiratory protection. To further strengthen operational performance at PNPS, Boston Edison management is-placing increased emphasis on develop-ment of procedures'for the plant. Boston Edison i upgrading its Emergency Operating Procedures (EOPs) in conjuu ton with j the Safety Enhancement Program (SEP). In addition, 4e "nn Edison is developing a plan for reviewing and upgrading PNPS procedures to improve technical content and consistency, as well as to simplify format. Boston Edison management-has introduced a variety of perform-ance as sessment t.echniques to monitor and improve operational performance at PNPS, with particular emphasis on restart activities. These techniques include a new Performance ES-5 J

Excellence Team.(PET), a management group that works to identify and resolve problems that could hinder the restart effort. A weekly Performance Excellence Indicators report is produced to' track progress on key restart work, and a monthly Performance Monitoring Report is also used by management to monitor trends in a variety of performance areas. Boston Edison is.also developing a program under which management personnel will perform systematic observations of plant operations to identify potential improvements, and is planning to implement the Human Performance Evaluation System (HPES) after restart. HPES is a program developed by INPO to ' identify and correct underlying causes of human error in plant operations. In developing this Restart Plan, Boston Edison undertook an extensive effort to review and document its regulatory restart commitments. Initially, a team comprised of Boston Edison supervisory and technical personnel and technical consultants reviewed numerous documents, including NRC inspection reports and meeting minutes, to identify Boston Edison's restart regulatory commitments. A second team took the identified items, sorted them by discipline, and reviewed the list for completeness and appropriateness of the disci-1 pline categorization. For the identified items, acceptance criteria were defined according to guidelines requiring that the items be specifically addressed according to objective (] standards and amenable to audit. Finally, a closure process was defined for the identified itemse To assure timely and effective completion of the work required during RFO-7, Boston Edison has organized a Planning and Restart Group to oversee and coordinate-restart activities. This Group is divided into four functional areas: (1) work authorization and control, including prior-itization of outage work according to defined' criteria; (2) planning and scheduling of work according to priority; (3) assurance of material readiness; and (4) monitoring of work progress. Bgston. Edison will incorporate these improve-ments as appropriate in the permanent Nuclear Organization after completion of RFO-7. A final area of operational performance receiving increased attention by Boston Edison management is the overall assur-ance of quality, which is not limited to.a strong QA Department but includes all operational areas at PNPS. Towards this end, Boston Edison has undertaken initiatives to improve the corrective action process, upgrade workload management, and provide increased tracking and reporting of p identified deficiencies.- In addition, Boston Edison has also taken corrective actions in several specific disciplines, including Radiation Control, Maintenance, Fire Protection, ({} and Security, as well as in the area of' surveillance testing. ES-6

Several changes have been made in the management of the OA g-) process to further improve Boston Edison's responsiveness to ( identified problems, including escalation of overdue responses to progressively higher levels of management, improved reporting, tighter control over the disposition of audit recommendations, and increased interaction between OA and operational staff through regularly scheduled meetings. CHAPTER IV PLANT AND EOUIPMENT PERFORMANCE Boston Edison's programs, plans, and actions in the area of plant and equipment performance are designed to upgrade the plant material condition and establish and maintain manage-ment control over the operating lifetime of PNPS. The programs, plans, and actions to improve plant and equip-ment performance at PNPS have been designed to address specific plant conditions that have been identified at PNPS both by the NRC in past inspections and by Boston Edison management through its self-assessments. They will address the following areas: A. Maintenance Backloa Reduction. Boston Edison has fs applied sound management techniques to reduce the maintenance (_) backlog to acceptable levels by the time of restart. These include prioritization of Maintenance Requests (MRs) based on specified criteria, and more effective planning and sched-uling of maintenance work. Boston Edison management has developed a Material Condition Improvement Action Plan (MCIAP) to identify specific goals, actions, and closure criteria that will guide Boston Edison's maintenance program ) and assure that PNPS is maintained in top material condition. B. Radiological Controls. Boston Edison has taken a number of steps to upgrade the ef fectiver.ess of its radiological controls program. These include: the staffing and organiza-tional improvements discussed in Chapter III; improved communications between Radiological Controls and other disciplines; improved radiological protection and control practices; decontamination of identified areas of the plant; and better responsiveness to radiological occurrences. C. Radiological Action Plan. In addition to the above initiatives, Bostoa Edison is currently developing a Radiological Action Plan (RAP) that will capture the results of Boston Edison's further examination in this area and provide a basis for sustained, longer term improvements. The RAP will further reduce and control individual exposure at (~g PNPS. V ES-7

D. Fire Protection. Boston Edison has undertaken a correc-() tive action plan to improve its fire protection program. The actions taken include strengthened management and control of this function, improved availability of the PNPS fire protec-tion systems, reduced reliance on compensatory measures, improved fire barrier surveillance procedures, and improved fire brigade training. E. Eeeprity. Boston Edison has strengthened its security program through the organizational and staffing improvements described in Chapter III, and by identifying and carrying out improvements in security systems, hardware, and equipment. i The security procedures have been revised accordingly. Boston Edison management has also taken steps to reduce the use of compensatory measures and improve the quality of '3 training in the security area. F. Surveillance. Boston Edison has undertaken a program to upgrade its surveillance performance. Specific actions have been or will be taken to improve: control of the Sur-veillance Test Prcgram; surveillance procedures; the Master Surveillance Tracking Program (MSTP); local leak rate test-ing (LIRT) ; In-Service Inspections (ISIS) ; calibration and testing; control of measuring and test equipment (M&TE); Emergency Core Cooling System (ECCS) Logic System functional testing; and, in the longer term, fire protection surveil-lance. G. Plant Operational Condition Chance Checklists. Boston Edison has improved its system of detailed checklists to guide the restart process. These checklists correspond to eight major defined plant milestones that occur during the outage. They provide a means for Boston Edison management to monitor progress towards, and completion of, the definkd milestones. H. Systems Group. Boston Edison has established a new Systems Group patterned on INPO Good Practice TS-413, "Use of Systems Engineers." The Systems Group will provide greater depth and continuity in the oversight of major plant oper-3 ating systems at PNPS by assigning " ownership" of each system ] to a qualified individual. These personnel are also assisting in the restart effort by reviewing and verifying work completion in their respective areas of responsibility. I. Confirmatory Action Letter No. 86-10 Items Closure. Boston Edison has committed to close or have scheduled for completion during power ascension the items identified by the NRC in its Confirmatory Action Letter (CAL) No. 86-10, dated j April 12, 1986, as supplemented by the NRC's letter of August 27, 1986. es ES-8

i /~T J. Powgr Ascension Procram. Boston Edison has developed a (/ power ascension logic plan and schedule as requested by the NRC. The power ascension program defines the sequence of power ascension steps and associated tests and checks neces-sary to bring PNPS to criticality and progress to 100% power. The power ascension program includes appropriate hold points for NRC evaluation and approval of subsequent power ascension. CHAPTER V j BASES FOR READINESS ASSESSMENT As part of Boston Edison's self-assessment of PNPS per;;rm-ance, a Nuclear Organization senior management review defined and articulated a set of bases for assessing restart-readiness. These represent tl'e yardsticks for measuring the results of Boston Edison's Restart Program. The bases encompass those factors that N!1C inspections have previously identified as fundamental to PMPS performance, namely: (1) staffing; (2) work backlog l (3) responsiveness to regu-latory issues; and (4) effectiveness and timeliness of corrective action. Boston EdiE on recommends that the NRC consider adopting these bases f or assessment for the NRC's diagnostic review and readiness assessment, so that the /~ commission will have a consiste nt presentation of informa-(T tion on which to base its restart decision. / The bases that Boston Edison has selected for its restart readiness assessment are as fc11ows: AT THE TIME OF RESTART: Management will have ex3cuted its plans for Refueling o Outage No. 7 (RFO-7) wcirk. Staffing levels will be adequate to support safe and o reliable restart and c.ontinued operation, and a plan for orderly transition from the restart organization to a j long term organization will be established. o Positive trends in pertinent performance indicators for RFO-7 work, including backlog work, will show that management control has been established. o Self-assessments will have been performed and action plans established, including comprehensive action plans addressing material condition (including. maintenance) and radiological controls, to. assure that management (~T control will continue. \\-) ES-9

Regulatory issues will have been addressed. o Om Systems Group reviews will have been completed and i o restart actions identified in those reviews will have been closed or specifically scheduled in the approach to startup. o The RPO-7 Power Ascension Program, including NRC hold points, will have been established. The results of Boston Edison's readiness assessment are, or will be, submitted as follows: o Preliminary Results j } Chapter II, III and IV of Volume 1 of this edition of this report Volume 2, Revision 0 of this report { o Interim Results Submitted at restart minus six weeks f i Volume 2, Revision 1 o Final Results Submitted at restart minus three weeks 1 Volume 2, Revision 2. Boston Edison submits that, when the programs, plans, and actions described in this report are implemented, safe and reliable restart and continued operation will be assured. O 1 ES-10

f 1:. O > Loa'" "oc'=^a "o"=a st^*'o" RESTART PLAN I. INTRODUCTION j i This report describes the programs, plans, and actions .l considered necessary by Boston Edison Company (Boston Edison) management for the safe and reliable restart and continued operation of Pilgrim Nuclear Power Station (PNPS). 1 This report focuses on the programs, plans,.and actions to ] upgrade performance in the areas of management, operations, and plant and equipment. The report concentrates on the specific activities that are either in progress or planned to ccrrect and prevent recurrence of weaknesses previously O identified by Boston E-dison, the.U.S. Nuclear Regulatory j Commission (NRC), and the Institute of Nuclear Power Operations (INPO). The report does not, therefore, addrcss the full r&nge of actions that have been and will be taken l throughout the course of the outage relating to the design, construction,. testing, and operation to assure safe and J reliable operation. Nor does the report emphasize areas that have been identified as strengths at PNPS, such as quality of licensed operators and design / engineering and configuration control. O i I-l - l

Boston Edison's approach to effective recovery takes into O, account both the weaknesses and strengths that have been i evident at PNPS. The exis9ence of~ fundamentally sound operators and engineering suggests that an infusion of experienced outside management talent and additional techni-cal personnel into other areas that were considered to be weak will best address the current ne,eds. This measured approach to organization is expected to pay dividends in terms of the timeliness, effectiveness, and permanency of Boston Edison's recovery efforts. 1 l While not considered as NRC prerequisites for restart, nor specifically addressed in this report, continued safe and i reliable PNPS operation will also be supported by the ,f g V performance of the following programs and activities: 1. The Safety Enhancement Program (SEP), as described in Boston Edison's submittal to the NRC, dated July i 8, 1987; and 2. Off site emergency planning actions described in separate submittals to NRC, Region I, dated June 4 and 12, 1987, and to the Commonwealth of j Massachusetts, dated June 30, 1987, and addressed 4 in Boston Edison's interactions with local, state, Federal Emergency Management Agency (FEMA), and NRC l emergency planning personnel. The programs, plans, and actions described herein extend beyond the original circumstances that led to shutdown of PNPS or that were encompassed within the NRC's Confirmatory Action Letter (CAL) No. 86-10, dated April 12, 1986. The r" Y)3 l l - I _ _ _ _ _ _

4 decision to extend the current outage was made by Boston Edison management and demonstrates its commitment to increased management involvement and control at PNPS. While the NRC has never found PNPS to have been unsafe, enhanced NRC confidence in future PNPS operation is required. The' decision to request restart will be made by Boston Edison management only after first assuring itself that the level of Boston Edison management involvement and control, coupled 1 with the implementation of the programs, plans., and actions described in this report, is sufficient to assure safe and reliable operation of PNPS, as well as to restore and main-tain NRC confidence in Boston Edison's ability to do so. Future success in restoring and maintaining NRC confidence O will ultimately be measured by improved NRC Systematic Assessment of Licensee Performance (SALP) ratings. 1 Boston Edison's programs, plans, and actions to Gupport safe and reliable restart and continued operation are buttressed by an explicit corporate commitment to achieving excellence j i in all phases of PNPS operations. Senior corporate manage-ment has underwritten this commitment by authorizing the expanded financial and personnel resources necessary to meet this challenge, and by providing a continuing level of direct management involvement in, and control over, PNPS activities i and operations. O - I !

fy This report is organized to describe Boston Edison's' Restart U Plan in the following sequence: o Management (Chapter II) o Operational Performance (Chapter-III) Plant and Equipment Performance (Chapter,IV) o o Bases for Readiness. Assessment-(Chapter V) o Appendices (Volume 2). The report will play a central role in Boston Edison's restart logic, which is depicted on the Restart Plan Flow Chart contained in Appendix 1 to this report. Boston Edison believes that its bases for assessment of PNPS restart readiness, as presented in Chapter V, should be reviewed and [} adopted by the NRC as the corresponding bases.for the NRC's independent diagnostic inspection and. readiness assessment. As depicted on the flowchart, the report will be submitted in. three editions: (1) this version, which focuses primarily on program. content; (2) an interim version, to be submitted six i i weeks before restart, which will consist of an updated ] version of the Appendices showing the results of the various-R programs, plans, and actions up to that dater end (3) a final version, which will present an additional pdate of the results three weeks before restart, at the midpoint of the NRC's diagnostic inspection. O - I l When viewed collectively, the programs, plans, and actions i O described herein specifically and systematically respond to. i and resolve the problems underlying the concerns previously identified by NRC inspections for certain fundamental areas at PNPS, including: 1 o Staffing o Work backlog I Responsiveness to regulatory concerns o Timeliness and effectiveness of corrective actions. o The programs, plans, and actions include those considered necessary for restart and longer term actions that will assure continued improvement and safe operation. While those i I actions are less urgent, they are equally important to achievement of Boston Edison's objectives. Boston Edison submits that, when the programs, plans, and actions described herein are effectively implemented, safe and reliable restart and continued operttion of PNPS will be { assured. l l 1 0 - I :

') l l i II. MANAGEMENT In this-Chapter, Boston Edison's top level plans and actions to improve management at PNPS are addressed. Boston Edison's self-assessments of management have confirmed that, in order to bring about sustained management improve-ment, Boston Edison's plans and actions must incorporate ~the i following basic elements: 1. A strong corporate commitment to improvement, as indicated by: l Adequate resource (financial and manpower) l a. commitments; b. The continued involvement and support of senior corporate management; c. A well-defined mission for the Nuclear O Oreenization, end d. Challenging but achievable goals for each' major component of the Nuclear Organization; and 2. A stronger Muclear Organization, as indicated by: a. An increase in nuclear management experience with a proven track record; b. An improved capability for planning, sched-uling, and work control; Realignment of organizational functions; c. d. Improved technical and administrative support; j and e. A plan for orderly transition to a sound, long term organization, q O l 1 - II-l - s

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(~T When the above elements are viewed as a composite, they \\-) directly address the fundamental need for improvements in i staffing previously identified by the NRC. As a logical result of the strong corporate commitment to improvement and ] the stronger Nuclear Organization Boston Edison will also e improve its responsiveness to areas of regulatory concern and enhance its ability to take timely and effective corrective actions. 1 In the discussion immediately following, Boston Edison's corporate commitment to excellent performance and the organi-zational and personnel improvements which are being under-taken to achieve such performance are summarized. A. Corporate Commitment The 670 MWe PNPS is the largest baseload unit on the Boston Edison system and represents more than one-fourth of the installed generating capacity of that system. The successful restart and continued operation of PNPS is an integral part of Boston Edison's,short term and long term strategy for l meeting the electrical energy needs of the region. Boston ) Edison is therefore committed to devote whatever management time, attention, and resources are required to accomplish this objective. In light of the significance of PNPS to ) Boston Edison and the importance of the restart effort, Boston Edison has made a further commitment to excellence in ( - II i L 1

(^} the performance of activities related to the Restart Plan and ] L-the continued operation and maintenance of PNPS in a safe, j I reliable, and efficient manner thereafter. i The depth and breadth of this commitment is evident through-l out Boston Edison. The Board of Directors has been briefed I on the Restart Plan and has authorized Boston Edison manage-ment to make the capital and operating expenditures necessary to restart PNPS. In 1986, the Board directed that the [ position of Senior Vice President - Nuclear be filled, and participated in the selection of the individual who filled the position. /~N The Senior Vice President - Nuclear reports directly to the O Chairman and Chief Executive Officer (CEO) and is also responsible for the development and implementation of the Restart Plan. The Senior Vice President - Nuclear has undertaken a measured restructuring and restaffing of the Nuclear Organization which is designed to enhance the capabilities, responsiveness, and overall performance of the entire organization. The basic elements of this restruc-turing and restaffing are summarized in Chapters II.B. and III.A. i O - II _ _ _ _ _ _ _ - _ _ _ _ - _ - _ _ -

j i j l In addition to the support which it has'provided.in the form. of funding and staffing approvals, senior management is.also involved in overviewing plans, functions, and activities, and 1 providing guidance to the Nuclear Organization in connection with the development and implementation of the Restart Plan ~ itself. The Chairman and CEO rectives regular briefings from ( the Senior Vice President -' Nuclear, during which'they review the status of restart-related activities. The Chairman and_- CEO has maintained an active role through regular visits to the site and periodic status meetings with senior Nuclear Organization management. The Board of Directors also provides a broad overview of PNPS activities through its j I Nuclear Operations Review Committee, comprised of senior 1 executives with years of experience a.d expertise in nuclear ) power or technology-related matters. In addition to the support of senior management, Boston Edison's recovery efforts have been directed toward harnessing the support and participation of the Boston Edison Nuclear Organization. The Nuclear Organization Mission, as recently adopted and ratifien by each Department, Section, and Group within the organization, states as follows: " Consistent with the Company mission, the Nuclear Organization's Mission is to operate Pilgrim Nuclear Power Station-1 safely to produce reliable and economic electrical power for customers, with careful regard to impact on the environ-ment, public health and safety, and the welfare of employees. O - II, m

In support of this mission, management O will provide a continuing focus on achieving excellent performance by: 1. Continuously striving to achieve rising standards of performance. 2. Clearly articulating individual responsibility and ensuring account-abilitf for results. 3. Selecting, assessing and continuing training of skilled personnel cognizant of the requirements for working in the nuclear power indus-try and dedicated to rising stand-ards of performance ^ 4. Anticipating and planning ahead for routine work and improvements, proper assignment of resources, and close monitoring of progress. 5. Regularly self-assessing perfor-mance, identifying and reporting problems, and correcting the methods and practices which underlie O problems." Each Department and Section has ueveloped, and submitted-for management review and approval, its own set of internal goals designed to enable the Nuclear Organization to accomplish its overall mission and support the restart effort. The i Departments and Sections are also developing action plans and ) i schedules to monitor progress against the' achievement of ) these goals. Upon approval of the Restart Plan by the Senior Vice President - Nuclear, each Section Manager will be required to brief responsible supervisors on its contents. Supervisors () l - II ___-____- _ _ _

will be directed to read and understand the contents.of the {)' Plan, brief those reporting to them on Plan contents, and direct them to read and understand the contents of the Plan. I B. Organizational and Personnel Chances 1. Overall ADDroach Boston Edison has restructured and revitalized the Nuclear Organization based upon two fundamental principles: (1) identify the organization's existing strengths and then l augment these strengths with an infusion of qualified manag-erial and technical personnel with prior nuclear power experience; and (2) establish an organizational and reporting structure based upon functional responsibilities that util-izes thece enhanced capabilities not only to facilitate the development and implementation of the restart effort, but also to strengthen the basic line organization to support ongoing operations. 2. Senior Vice President - Nucleat The Senior Vice President - Nuclear is responsible.for the overall management and control of activities at PNPS, including operations, engineering, maintenance, and quality assurance,, The Vice Presadent - Nuclear Operations and the Vice President - Nuclear Engineering and Quality Assurance report to the Senior Vice President - Nuclear. Ralph G. Bird, a retired Rear Admiral, United States Navy, with extensive experience in the supervision ad management of ( - II L R l l A

naval nuclear power matters, assumed the responsibilities of Senior Vice President - Nuclear on February 20, 1987. Mr. Bird previously served as Deputy Chief of Naval Material for Logistics and Fleet Operations, and Chief of Staff of the' U.S. Pacific Submarine Force. i In order to maintain effective " hands-on" control of the day-to-day activities at PNPS, Mr. Bird has also assumed the duties and responsibilities of the Vice President - Nuclear Operations. Boston Edison has also retained an Executive Assistant to the Senior Vice President - Nuclear and assigned that individual oversight responsibilities with respect to restaffing and outage and restart activities. The Executive Assistant has over 25 years of nuclear experience, including 7 years as senior shipyard advisor to the Director of the Naval Nuclear Propulsion Program in connection with the l management of the repair and refueling of. nuclear powered-ships and submarines. 1 3. Special Plannino and Restart Group i Several other organizational changes were made in order to facilitate.the development and implementation of restart efforts. Foremost among these changes was'the establishment of a Planning and Restart Group in May 1987. This Group coordinates the overall restart effort and cuts across normal organizational lines, to ensure that appropriate resources O - II are applied and utilized to complete outage-related work. The Director of Planning and Restart reports directly to the Senior Vice President - Nuclear. The individual hired to assume that position has over 20 years of naval and commer-cial nuclear experience, including 7 years with INPO in a ] ) variety of management assignments involving performance ) \\ 1 assessments of commercial nuclear power plant and program management. i The Planning and Restart Group is staffed with a nucleus of experienced managers from throughout the nuclear power industry. The senior individuals in the Group collectively have over 400 years of prior nuclear experience. These managers are working closely with various Sections in the Nuclear Operations and Nuclear Engineering Departments involved in outage-related work, and draw upon tne resources of these Sections to augment the capabilities of the Group. The Planning and Restart Group managers are also providing assistance and input in connection with the restaffing effort, the training and development of the existing PNPS staff, and the overall effort to upgrade the capabilities of the line organization. ) i O - II ;

The four branches in the Planning and Restart Group, with a brief description of their functions and the experience of their managers, are as follows: Work Authorization & Control Branch - to screen and prioritize outage-related work requests and obtain necessary authorizations and approvals; manager has over 16 years of nuclear plant management, operations, and maintenance experience. Work Plannina & Estimatino Branch - to develop budget estimates, schedules, and detailed work plans for j outage-related work; manager has over 16 years of nuclear project controls experience at operating and i under-construction nuclear facilities. j i Material Readiness Branch - to coordinate acquisition and staging of materials for outage-related work; manager has over 25 years of experience in engineering and power plant operations. Work Prooress Branch - to coordinate performance and completion of outage-related work; manager has oc.er 19 years of nuclear plant experience, including 14 years in j managerial positions. l () 4. Other Organization Chances The other changes that were made in the Nuclear Organization in order to either place additional emphasis on the comple-tion of' restart-related tasks or provide higher level manage-ment visibility and control over specific functions are as f follows: The Outage Management function was transferred a. to Nuclear Operations and now reports to the Nuclear Operations Manager. This change resolved the problem expressed by the NRC with respect to lack of clear lines of authority between Nuclear Operations and Outage Management. () I - II l i l 1

I b. The Management Services Section of Nuclear (~)T Opera' ions was eliminated and a new c ( Administrative Section with an Administration and Proce;dures Group and a Procurement Support Group was established. The reporting lines of the Fire Protection c. Group and the Nuclear Security Group were elevnted from the Management Services Section to report directly to the Vice President - Nuclear Operations. d. The Nuclear Training function formerly reporting within the Management Services Section was elevated to report directly to the Vice President - Nuclear Operations as a Section. The Emergency Planning Group was elevated to e. report directly to the Vice President - Nuclear Operations. f. The Technical Section was expanded to include a new Systems Group. g. The Shift Technical Advisor function was i transferred from the Technical Section to the

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Operations Section. 5. Increased Staffina and Assianment Chances As a necessary part of its restructuring, Boston Edison has undertaken a restaffing effort to identify the additional management, engineering, and technical positions accompany-ing the new organizational structure, and to fill these positions with either reassigned Boston Edison employees, new Boston Edison employees, or contractor personnel. Boston Edison also has made a number of important changes in personnel assignments. O - II I l jq Some of the key positions that have recently been filled by L/ hiring or reassignment within Boston Edison, and the relevant i background information of the individuals filling those positions, are as follows: j 1. Operations Section Manacer - Former NRC Senior Resident Inspector at Nine Mile Point Plant and Shift Supervisor at the J.A. Fitzpatrick Plant; Graduate of the U.S. Naval Academy and Navy Nuclear Power School; 16 years of nuclear power experience. ] 2. Deouty Manaaer of Nuclear Enoineerino Department (NED) - Formerly Program Manager at INPO and Electrical Group Supervisor at Pennsylvania Power &~ Light Company's Susquehanna Plant; B.S. and M.S. in Mechanical Engineering from Rensselaer Polytechnic Institute; graduate of Navy Nuclear Power School; over 19 years of experience in the nuclear industry. 3. Emeroency Plannina Assistant to Senior Vice President - Emergency Preparedness Manager at the Davis-Besse Nuclear Power Station; Nuclear Support ('T Division Director for RPS Corporation; Project (_/ Engineer for the LILCO Project with Impell Corporation; Senior Project Coordinator on the Beaver Valley Project for Energy Consultants, Inc.; graduate of the Navy Nuclear Power School; emer-gency preparedness site coordinator for the Fast Flux Test Facility in Richland, Washington. 4. Nuclear Security Group Leader - Former military officer with more than 24 years of experience in physical security, security systems and govern-l mental and industrial security programs; graduate of Boston University; Masters Degree in Criminal Justice from Northeastern University; graduate of the U.S. Army Command and General Staff College; American Society for Industrial Security Certified Protection Professional. 5. Fire Protection Group Leader - 15 years of experi-ence in design engineering and project management involving fire protection barriers and nuclear power plant requirements; B.S.C.E. from Worcester Polytechnic Institute and M.S.C.E. from Northeastern University; registered professional J (~N 1 \\-) l 1 l l 11 - j i

() engineer in Massachusetts, Connecticut, and Alaska; \\/ Certified Member of Society of Fire Protection Engineers. 6. Radiological Section Manaaer - 18 years of nuclear power experience, including 5 years as Project Engineer responsible for radiological controls at U.S. Naval Shipyard in Bremerton, Washington during overhaul of 25 reactor plants and deactivation of 5 plants; B.S. from Southern Illinois University. 7. Systems Group Leader - Former Licensed Senior Reactor Operator and Assistant Plant Superintendent at the MIT research reactor; Corrective Action Engineer with Combustion Engineering; Qualified Engineering Officer and Shift Supervisor at the SlC naval prototype; Health Physics Technician at Lowell Technological Institute; B.S. in nuclear engineering from Lowell Technology Institute; Master's Degree in management from Rensselaer Polytechnic Institute; graduate of the Navy Nuclear Power School; former Boston Edison Fluid Systems and Mechanical Components Group Leader. (]) Contractor personnel are now used to augment the expertise and experience levels in the Boston Edison organization. For example, the Planning and Restart Group, which consists for the most part of contractor personnel, provided an immediate source of senior personnel to give additional impetus to the completion of the current outage and the restart of PNPS. Boston Edison plans to continue to utilize contractor person-nel to assist in the training of Boston Edison personnel as j potential replacements. Boston Edison will also recruit from this contractor work force and throughout the industry to catisfy its permanent organizational needs. Boston Edison has adopted the ultimate goal of minimizing its use of contractor personnel. - II [ -__--_____-__---_______--__D

Boston Edison has also undertaken a series of additicnal steps to upgrade the technical and management capabilities, responsiveness, and general problem-solving abilities of the Nuclear Organization,'particularly at the site itself. Many of these steps will alco 2.e.ance the ability of the vr.rious disciplines within the organization to perform their func-tions in a more proactive, rather than reactive, mode. For example, a Work Planning & Estimating Branch has been established. This Brancl. provides each Section with the services of a full time planner, which is designed to enable the Section to improve planning and scheduling of its own i work in an efficient manner and coord' 7te and integrate its work plans and schedules with those C other Sections and disciplines. A new Systems Group has also been established within the Technical Section. This Group provides direct and dedicated systems. support and services to the Nuclear Operations and Maintenance organizations in accordance with INPO recommen-dations contained in INPO Good Practice TS-413, "Use of Systems Engineers." The Field Engineering Section has increased its presence on i site in order to promote a closer working relationship between site personnel and the Engineering Department. Finally, Boston Edison is reviewing the effectiveness of the O - II 1

support services.being provided to PNPS by other Boston Edison Departments and organizations to assess whether the 5 relocation of the services to the site will materially improve the performance of the Nuclear Organization or the quality or availability of such services. 6. Transition to the Permanent Organization Boston Edison intends to establish a long range plan for the ongoing development and improvement of the Nuclear i Organization, the reduction of the level of contractor j l participation as the organization matures, and the orderly transition to the permanent organization which will operate i l and maintain the plant over the long term. The principles that will govern implementation of this transition plan are established in Chapter V.B.3. 1 1 1 l i O - II ) a 1

a III. OPERATIONAL PERFORMANCE In this Chapter, Boston Edison's programs, plans, and actions to improve operational performance at PNPS are addressed. Boston Edison's self-assessments have confirmed that, in order to bring about sustained operational performance improvements, Boston Edison's plans and actions must incor-porate the following basic elements: 1. Increased staffing and experience levels in key components of the Nuclear Organization. 2. Improved training in key Nuclear Organization components. 3. Upgraded Emergency Operating Procedures (EOPs) and, over the longer term, initiatives to improve other. PNPS procedures. U 4. Enhanced performance assessment techniques. 5. Review of the PNPS regulatory documentation to assure that restart commitments are properly identified and dispositioned. 6. Improved systems for management of outage work and site work control. 7. Improved programs, plans, and actions for assuring the quality of site work and corrective actions. When the above elements are viewed as a composite, they directly address the fundamental need for improvements in i i staffing, reduction of work backlog, and timely and effective crtrective actions that the NRC has identified. As a logical l result of addressing those three needs, there will be an O - III-l - 4 i

~ - - - In improvement in responsiveness to regulatory concerns. 3 kJ ) addition, the review of regulatory documentation will assure that Boston Edison's Restart Plan is responsive to identified regulatory concerns. The discussion that follows summarizes Boston Edison's programs, plans, and actions that address: (A) Specific Staffing and Experience Increases; (B) Training; (C) Procedures; (D) Performance Assessment Techniques; (E) Review of Restart Regulatory Responses; (F) Work Control; and (G) Corrective Action Programs / Assurance of Quality. A. Soecific Staffino and Experience Increases Boston Edison management has made progress during the current () outage (RFO-7) in addressing staffing requirements at PNPS. Staffing has been increased both for areas that had been experiencing shortages and for areas where greater emphasis was required. The areas of improvement have included: (1) Maintenance; (2) Operations; (3) Radiological Controls; (4) Fire Protection; (5) Security; and (6) Quality Assurance (QA). 1. Maintenance A key objective in the Maintenance Section, as reflected in the Boston Edison Material Condition Improvement Action Plan j (MCIAP), is to assure adequate staffing in terms of experi-ence level and numbers of personnel. As described in the O - III MCIAP under Issue No. 03-001, over the long term Boston O Edison management is committed to developing and implementing a revised organizational structure and staffing plan. However, Boston Edison has taken a number of steps to address staffing needs in the context of RFO-7. Staffing in each of the three maintenance areas - Electrical, j Mechanical, and Instrumentation and Control (I&C) - was j increased in January 1986. The number of first-line super-visors in each area has also been increased and the positions filled with experienced personnel. l l In addition, effective August 3, 1987, the Maintenance Nuclear Apprentice Program will go into effect. Trainees / ,f s NJ apprentices will include three electricians, four NCTs and five mechanics who will be enrolled in a structured, formal training and qualification program to elevate these individ-i i uals to the journeyman level of skill. In addition, these individuals will perform work and supplement the existing work force while in training. Of the 18 Maintenance supervisory positions, 16 are presently l filled by Boston Edison employees and the other 2 are filled by contractors. These are the senior Mechanical Engineer and I&C Supervisor. They will Le replaced by qualified permanent Boston Edison employees in August 1987. O l - III l l l

(]} Boston Edison has also created an on site Procurement Support Group in the Administrative Section that provides direct support to the Maintenance Section work. Staffing for this Group currently includes 24 Boston Edison and contractor personnel. Besides supporting more efficient and effective processing of procurement documents, this Group is relieving the Maintenance Supervisors of the administrative burden associated with procurement. Three full time planners have been hired and assigned to the Maintenance Section to provide support for supervisors in planning and coordinating work schedules. This has further eased the administrative burden on the supervisors and led to (]) a more efficient allocation of Maintenance staff resources. The Maintenance Section has been further strengthened by the l assignment of two full time Radiological Control specialists to the production organization. These personnel will l instruct and coach Maintenance staff on how to build effec-l I tive radiological control practices into the production work process. Staffing levels in the area of decontamination and 1 housekeeping have been increased by the addition of four supervisors and thirty production personnel. () - III - - _ _ _ _ - _ _ _ _ _ - - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _

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Operations O Boston Edison has undertaken a series of programs:to increase l the number of licensed Reactor Operators (ROs), increase the level of professional support for the Operations'Section, and improve control of operator overtime.. I In response to shortages of ROs, Boston Edison has increased j j the total authorized complement of operators (both equipment l operators and reactor operators)-from 29.in the last quarter of 1985 to 45 as of February 1987. The actual number of licensed ROs was 16 as of July 1987 (8 are limited to cold shutdown and refueling conditions pending-completion of time-on-shift requirements). Boston-Edison's goal is'to have a sufficient number of operators to man four shifts during O startup and power ascension, and, in the longer term, six shifts. Boston Edison has improved technical and administrative l support for the Operations Section. In connection with the operator recr.uiting and training program, an experienced Watch Engineer w'ao is a licensed Senior Reactor Operator (SRO) has been assigned to the Training Section to perform ( the function of assisting the operator training program. l l l l l O - III _ _ _ - _ _ - - _ _ _ _ - _ _ - -

In May 1986,. Boston Edison hired a new Operations Section 4 ) Manager with substantial experience in nuclear power opera-tions, as described in Chapter II.B.S. 1 i A number of actions have also been taken to increase the ] technical staff support for the Operations Section. Two Operations Engineers (OEs) have been assigned to the Chief Operating Engineer (COE) as technical staff assistants. These OEs have assumed some of the workload from the COE to provide him with more time to directly oversee operator performance. In addition, a full time planner has been assigned to the Operations Section to provide planning and i scheduling capability within the Section. This will help in relieving administration burdens from the Operations Section (~i) 4 Manager. Boston Edison's administrative control of operator overtime has received significant management attention, resulting in fundamental policy changes in this area. A new organiza-tional policy as of May 1986 established a 60 working hour per week guideline for plant personnel, including licensed operators. Administrative tracking and management control of i the actual operator overtime worked has been improved through the following measures: 1. the use of on-shift administrative aides to track the operator hours worked; O E - III 2. _the establishment of a weekly overtime report sent to_ top management to monitor adherence to overtime-policy. guidelines; and 3. the establishment of a computer-based system to perform real time monitoring of operator overtime, including a seven day rolling average of work hours. 3. Radiological Controls Changes in supervisory level staffing in the Radiological Section have upgraded the level of personnel experience and provided improved technical support for plant radiological control programs. The new Section Manager has 18 years of' nuclear experience, including management and radiological controls engineering positions. A new Chief Radiological Scientist position has been created and'is filled by the former Section Manager, who is able to apply his experience {) at PNPS to the solution of radiological control technical problems and radiological health matters. In addition, the Radiological Assessor position is now filled by a new Boston Edison employee with 20 years of nuclear power experience. Additional technical support for the Radiological Section is provided by the new Chief Radiological Engineer, and the new Radiological Technical Support Group. The Chief Radiological l Engineer has 13 years of nuclear power experience and is a i certified Health Physicist. The new Radiological Technical O - III l Support Group consolidates the on site operational radiologi-O cal engineering functions and is staffed by approximately 20 engineers and technicians. Boston Edison has established the Independent Radiation Protection Oversight Committee (IROC) to bring broad, industry-recognized experience, and increased independence and objectivity to the assessment of radiological activities j at PNPS. The IROC, which reports to the Senior Vice President - Nuclear, is comprised of four independent members, each of whom has extensive radiological and nuclear power experience, and one experienced Boston Edison employee who acts as secretary. The experience base of the IROC members includes service in positions such as Director of the g-Nuclear Technology Division in the Naval Sea Systems Command, Manager of Radiological Engineering for the Electric Boat Division of General Dynamics Corporation, Head of Safety and Environmental Protection at Brookhaven National Laboratory, and Chief Licensing Engineer for General Physics Corporation. IROC will overview Boston Edison's efforts to achieve excel-lence in its radiological control activities. As implementa-j tion of the Radiological Action Plan (RAP) described in Chapter IV.C proceeds and necessary improvements are achieved, the scope of IROC activities will diminish accordingly. O - III i i The Radiological Occurrence Report (ROR) Coordinator position l f, I k-) is now filled permanently in lieu of having technicians rotate through that position. This change is designed to ensure a consistently high level of ROR identification, trac!;ing, and documentation. l 4. Fire Protection The PNPS Fire Protection organizatiott has grown from a staffing level of one in 1986 to a current level of six, consisting of a Fire Protection Group Leader, three engi- ~ neers, a fire protection technician, and an administrative assistant. The Group Leader is responsible for providing management direction and control for all fire protection operations at the site, including monitoring fire protection j () equipment readiness, prioritizing fire protection maintenance I work, overseeing implementation of fire protection modifica-tions, and enforcing fire protection requirements. The Group Leader has 15 years of nuclear power plant experience in engineering supervisory positions, including management of nuclear plant projects, fire barrier upgrades, and fire protection systems. The visibility of the Fire Protection Group has been increased by having the Group Leader report directly to the Vice President - Nuclear Operations. k - III A new position to support fire brigade training and drill 7g s.g instruction has been established and filled. The improve-ments in PNPS Fire Protection training are described in Chapters III.B.3 and IV.D.5. Boston Edison has established a project organization f comprised of contractor personnel under the direction of a Boston Edison project manager, with more than 16 years of j I previous experience in nuclear plant design, construction, and operation, to design and construct modifications to I l achieve compliance with 10 CFR Part 50, Appendix R. The Project Manager was previously responsible for the successful PNPS program on environmental qualification of electrical equipment under 10 CFR 50.49. Within the project structure, the contractor force consists of 18 engineers and technicians in design and 150 people in construction and supervision. 1 1 5. Security Boston Edison has established a Nuclear Security Group l reporting directly to the Vice President - Nuclear Operations to provide oversight of the contract security force and to identify and correct any security problems in a timelt manner. Three Nuclear Security Specialists have been added in the areas of administration, compliance, and technical - III systems, and one Boston Edison Security Supervisor is now on every shift to provide a continuous security management on site. The new Nuclear Security Group Leader has 25 years of law enforcement and security experience, including experience at over 20 nuclear power plants. The addition of this experi-ence to the security organization significantly strengthens l the security program and enables the organization to respond _ j 1 more effectively to security problems at both the programma-tic and specific level. In connection with the establishment of the Boston Edison Nuclear Security Group, the contractor security force has been reorganized into a Security Operations organization. Three new positions have been established in the plant areas of main gate access, central alarm station, and secondary alarm station. In addition, the total contractor security force has been increased in size and the individual guards have been elevated to a higher level in the organization. The supervisor-to-guard ratio has been reduced from 1-20 to i 1-10 or less to provide more direct supervision of the f guards. k I l 0 - III ; I I

i 6. Quality Assurance The QA Department has established a permanent, ten-member, on site Surveillance Group to conduct surveillance.of daily l operating activities, including backshift activities. Formerly, only two staff members, assigned to the Audit I Group, carried out'this function. Eight members of the Group have been hired under employment guidelines specifying a Bachelor's degree in engineering, and two additional vacan-cies are expected to be filled in the near future. Each member of the Surveillance Group has expertise in at least one area of plant operations. The activities of this group should provide an early warning system to management and thus contribute to improved management oversight and {) awareness of quality. In addition, the QA Department has dedicated two engineers on-site whose sole function is to review procurement documents for spare parts and equipment for plant modifications. These quality engineers ensure that QA requirements are properly specified for procurement actions. Finally, Boston Edison management recently authorized three new personnel slots in the Quality Assurance (QA) Department. One of these slots is for an auditor with health physics O - III _ _ _ _ _ _ _ _ _ _. J

expertise. The two remaining slots are for Quality Control (QC) inspectors who will perform inspections of radwaste shipments. B. Trainino Boston Edison recently completed a review of its nuclear training program to determine where additional improvements could be implemented. Although it was determined that the training programs are adequate, a long range plan is under development to bring about further enhancements. Boston Edison has already taken a series of steps designed to place additional emphasis on the training function and to improve the quality and frequency of the training currently () being provided. One of the first steps was to take the l l nuclear training function out of the Management Services l Section and elevate it to Section status with the Manager of_ ] the Training Section reporting directly to the Vice l President - Nuclear Operations. Further, the Training Section recently completed an internal reorganization to clarify responsibilities and strengthen management controls. The PNPS Training Manual is currently being revised to update, clarify, and ensure consistency among the program 1 descriptions. A number of new courses are being offered and implemented while some of the existing courses are-offered at a greater frequency. O - III.

l Highlights of achievements to date and ongoing developments O in the area of training are summarized below: 4 1. Accreditation Boston Edison became a. Branch of the National. Academy for. 1 Nuclear Training in June 1986 when the Reactor Operator, Senior Reactor Operator, Non-Licensed Nuclear Plant Operator, and Health Physics Training Programs were formally accredited by the National Nuclear Accrediting Board. Boston Ediron l will become a Member of the National Academy for Nuclear Training when the remaining six programs (Mechanical Maintenance, Electrical Maintenance, Instrumentation and ) Control, Chemistry, Shift Technical Advisor, and Technical Training for Staff and Managers) are formally accredited. ({) Final arrangements for a National Nuclear Accreditation Board meeting (tentatively scheduled for August 1987) are currently being made. 2. Operator Trainina A training coordinator and an experienced Watch Engineer who is a licensed SRO were assigned in early 1986 to manage the operator training program. The results of their efforts were manifested recently when eight out of eight candidates successfully passed the NRC examinations and received their reactor operator licenses, effective June 1987. j I O - III _ _ - _ _ _ _ _ _ _ _ _ _

1 O PNPS licensed operators successfully completed the written portion of the annual requalification examination. In ad-dition, Boston Edison is providing on-shift training on modifications installed during RFO-7, including the Safety Er.hancement Program (SEP) modifications. In anticipation of plant restart,-refresher training was implemented for shift personnel on the PNPS plant-specific simulator at CAE Electronics, Ltd., in Montreal, Quebec during April 1987. Shortly thereafter, the simulator was shipped to the Chiltonville Training Center (located about three miles from PNPS). Currently the simulator is under-going further software enhancements to improve its capability for use in the validation of the improved Emergency Operating Procedures (EOPs). A supplement to Boston Edicon's July 8, 1987 submittal to the NRC on SEP modifications will describe Boston Edison's activities in the areas of EOPs and associ- ~ ated training. 3. Fire Bricade Trainino The Training Section has worked closely with the Fire Protection Group on site to effect substantial improvements e in the area of fire brigade training. Chapter IV.D.5 summar-izes these activities. 4 - III '

) 4. General Employee Trainina (GET) .O The GET Program was certified by INPO in December 1985 and is continually updated to reflect current plant policies and-practices. Examples of recent changes include the addition of standards for proper frisking and for donning / removing protective clothing, the Chemical Control Program, and multi-image media on Quality' Assurance, Biological Effects of Ionizing Radiation, and Respiratory Protection. 5. Technical Trainina A number of new courses have been offered and implemented. Courses in contamination control have been developed'for site workers including but not limited to operators, maintenance and radiological supervisors, and technicians. Additional () course offerings include specialized respiratory protection traininn, training for craft supervisors in practices and procedures for maintaining personnel radiation exposures as low as is reasonably achievable (ALARA), housekeeping and observation training, decontamination training, and safety evaluation training. C. Procedures Boston Edison is upgrading the Emergency Operating Procedures (EOPs) based on the Emergency Procedure Guidelines, Revision 4, developed by the Boiling Water Reactor (BWR) Owners' Group. A description of Boston Edison's actions concerning O 1 - III _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ l

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O EOPs and associated training will be addressed in a future supplement to Boston Edison's July 8, 1987 Safety Enhance-ment Program (SEP) submittal to the NRC. A Procedures Group, consisting of technical writers, will be assembled to review PNPS procedures. These writers will receive technical input from the line organizations and re-. vise the procedures in accordance with a writer's guide. The efforts of this Group will initially be applied to revi-sion of procedures necessary for restart. The revisions to the procedure format wit? make the procedures easier to follow. D. Performance Assessment Techniaues Boston Edison is utilizing performance assessment techniques to enable senior management to monitor the p : ogress of restart-related activities and improve the overall performance and. productivity of the Nuclear Organization. These techniques include tracking mechanisms designed to l provide senior management with status reports on key performance indicators. () - III-17 4 i

f l () In addition, there are regularly scheduled meetings at various management levels te :cordinate' restart-related activities, discuss near term work plans, and confirm the progress on critical path items. Collectively, these performance assessment techniques provide senior management with the necessary tools to monitor the progress of the work and identify and correct potential obstacles to suc-cessful and timely completion of restart activities, while simultaneously upgrading the overall capabilities and performance of the Nuclear Organization. The principal performance assessment techniques that Boston (} Edison is or will be employing are summarized below: ) 1. Performance Excellence Team (PET) j l The Performance Excellence Team (PET) is a special purpose ] management team that reports directly to the Director of the Planning and Restart Group. The Team is specifically tasked with monitoring and improving the restart effort by working closely with the line organization and the Planning and Restart Group to improve communications between the two organizations and identifying and solving problems that could hinder the restart effort. Actions undertaken by the PET to date in the latter category include the identification of short term solutions to RFO-7 tool supply and material - III shortages, productivity surveys of work performed by the -~ k-) various crafts, and assessment of the need to participate in j the INPO Human Performance Evaluation System (HPES). ,eekly PET Indicators Report W 2. A weekly Performance Excellence Indicators Report is prepared by the Planning and Restart Group and distributed to Nuclear i Organization managers. This report tracks a total of nine performance indicators (i.e._, Radiological Occurrence Reports (RORs), Deficiency Reports (DRs), Non-Conformance Reports (NCRs), Reload System Schedule, Plant Decontamination, and four categories of MRs (total open MRs, open fire protection and security MRs, open power-block-related MRs, and MRs required for restart)), all of which were selected for ,~(,) inclusion in the report based on their importance to the restart effort. 3. Monthly Performance Monitorina Reports The Nuclear Organization produces a monthly Performance Monitoring Report for distribution to Nuclear Organization managers. This report contains selected PNPS performance information in graphic format to permit ready identification of trends. It provides a means for management to track progress in areas such as personnel / human resources, nuclear safety, operations, radiation protection, and QA. Ov - III 1

4. Manaaement Monitorina Procram Boston Edison is developing _a program to encourage managers to stay involved in the day-to-day operations of PNPS at the orking level through systematic observations of the perform-ce of station personnel and plant evolutions across organi-zational lines and from the bottom of.the organization up.' This program will broader. managerial perspectives, strengthen l the overall capabilities of the organization, and promote cross-fertilization of managerial and technical expertise and ideas among the various disciplines, particularly with respect to productivity improvements and problem identifica-tion and resolution. 5. Human Performance Evaluation System () Boston Edison plans to implement a program known as the Human Performance Evaluation System (HPES). This program was-developed by INPO as a means of identifying"and evaluating situations that involve human performance errors. The goal of the' program, which is based on a highly successful program used in the aviation industry, is to prevent recurrence of human error events by identifying and correcting the under-lying causes of human error. 4 E. Review of Restart Reculatory Responses Boston Edison reviewed regulatory responses and other docu-mentation to identify regulatory restart commitments. These 1 commitments were reviewed in detail, specific actions neces-O - III sary to address commitments were identified, acceptance 7-) 4 criteria for completion of actions were defined, the Boston Edison closure process for completion of actions was defined, and a proposed NRC closure process was identified. Each of these steps is described in additional detail below. 1. Team Composition The regulatory response review process was conducted by two i teams. The first team, which was comprised of Boston Edison j supervisory and technical personnel from Licer. sing, Compli-i l i ance, and Quality Assurance, in addition to saveral techni-I cal consultants, undertook the activities described in Chapter III.E.2, below. The second team, which was broken into three working groups, each consisting of a Boston () Edison manager, an experienced Boston Edison employee, and a l consultant, undertook the activities described in Chap-ter III.E.3-5, below. In addition, a management oversight group including the Vice President - Nuclear Engineering and Quality Assurance, the Executive Assistant to the Senior Vice President - Nuclear, the Director of Planning and Restart, the Nuclear Engineering Manager, and the Plant Manager provided management guidance to the working teams. l 2. Documents / Sources Reviewed The following documents and document compilations were reviewed to identify regulatory commitments for restart: i I - III. 1 ~ 1

1. Confirmatory Action Letter (CAL) No. 86-10; (^} xs 2. NRC-Boston Edison Management Meeting minutes, including Management Meeting 86-41; i 3. Boston Edison Licensing Section computer printout of regulatory commitments; 4. Boston Edison Compliance Group computer printout of NRC Inspection and Enforcement (I&E) open items; and 1 5. Source documents for the items listed on the Licensing and Compliance computer printouts. The review will be continued to bring the restart regulatory - 1 commitments data up to date at the time of final results { d I submission. 3. Assessment of Issues and Actionq The regulatory commitment issues identified were sorted into ( the following categories: 1. Operations; Radiological Controls; Maintenance; i 4. Surveillance; 5. Fire I;rotection; 6. Security; 7. Quality Assurance; 8. Licensing; 9. Training; 10. Engineering; and 11. Miscellaneous. O - III _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _

l The programmatic maintenance issues and actions were broken O out of the team review effort and are being addressed in the Material Condition Improvement Action Plan (MCIAP); radiolog-ical control issues and actions are being addreused in the Radiological Action Plan (RAP); and off site emergency preparedness issues and actions are being addressed through separate interactions between Boston Edison, local, state, FEMA, and NRC emergency planning personnel. The other issues and their associated specific actions are being reviewed with_ line management in a series of meetings to assess the following: i 1. Completeness of issue list; 2. Completeness of actions list; 3. Categorization of issues; O 4. Ansignment of actions to each issue; 5. Adequacy / completeness of issue descriptions; 6. Adequacy / completeness of action descriptions; and 7. Adequacy of actions to address each issue. l The results of these reviews will be contained in Boston Edison's Regulatory Response Data Base (Appendix 10). This review of issues and actions has identified additional actions as necessary to address the restart issues. In addition, several issues and actions that were previously identified in the documents and sources of regulatory commit-ments will be modified or eliminated. In order to highlight O - III _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - - _ _ _ _.

these issues and actions in the Restart Plan, these changes b,s to prior regulatory commitments will be licted separately in Appendix 11. i l 4. Acceptance Criteria For the specific actions associated with the identified issues, acceptance criteria that define closure fer purposes 1 of restart will be developed. The following standards are I l being used for development of acceptance criteria: 1. Acceptance criteria must define precisely what is ) necessary to satisfy Boston Edison and the NRC that I the identified issue has been fully addressed and resolved to support restart. 2. Acceptance criteria must be objective standards or criteria against which progress can be measured. 3. Acceptance criteria must be amenable to audit by Boston Edison or the NRC. l f. The teams and line management will review the restart accept-I i ance criteria for their adequacy, specificity, functional l reasonableness, and compliance with the standards under which 1 they were developed. 5. Closure Process Boston Edison will close the items in accordance with the acceptance criteria. The process for closure will be identi-fied through a joint effort of the teams and the line management. The Boston Edison closure process descriptions will define who will.1pprove closure of the specific items and how closure will be accomplished. For example, closure DU - III - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

I may require documented evidence of completion of the action assembled into a closure package by the responsible disci-pline and approved by management. Following Boston Edison closure of an item, the NRC may \\ determine that NRC closure of the item is appropriate. l Accordingly, Boston Edison will identify one of the following five suggested NRC closure actions as being commensurate with the significance and technical subject matter of a given item: l 1. Resident Inspector verification; 2. Included in a Special Inspection by specialists from Region I; 3. Headquarters verification; ) 4. Diagnostic Team Inspection item; or 5. No NRC action needed. 6. Restart Reaulatorg,,Mesponse Data Base The product of the issue and action item identification, the acceptance criteria development, and the closure processes definition by the Boston Edison teams will be presented in i Appendix 10, Restart Regulatory Responseo, i n ') \\ - III.

F. Work Control 7-.V 1. Centralized Management Control over Plannina and Restart As described in Chapter II.B.3, Boston Edison has assembled a management team under the Director of Planning and Restart to oversee and coordinate the completion of RFO-7. The Planning and Restart Group is made up of experienced managers both I { from within Boston Edison and from other organizations [ throughout the nuclear industry and is organized along functional lines into four separate Branches. The mission of the Planning and Restart Group is to ensure that the tasks assigned to each of these Branches are accomplished in a timely and ef'fective manner. The Planning and Restart Branches and their respective tasks are as follows: O a. Work Authorization & Control Branch The most fundamental management task in the restart effort l l was to identify and prioritize outstanding work items. This 1 initial task of establishing priorities in turn permitted the development of a restart work schedule. Within the Planning and Restart Group, a Work Authorization and Control Branch l (WAC) was established to develop and assist in carrying out the prioritization and authorization process. l 0 - III -

Initially, WAC developed guidelines for inclusion of work in O RFO-7. These guidelines were designed to sort and prioritize 3 work items according to the impact of the specific work item on the safe operation of the plant. The guidelines are as follows: Plant Technical Impact Area 1. If the item fails: (a) Will plant safety degrade? (b) Will the plant be put in a limiting condition for operations (LCO)? (c) Will plant availability be severely impacted? 2. What is the probability of failure between outages? (Hi? Med? Lo?) 3. If the item was identified during operation, would the plant be shut down immediately to () work on it? 4. Can the work be done while the plant is in operation? 5. Can " Tie-Ins" be made in RFO-7 to facilitate work completion during operations? Manacement Commitment Area 1. Stated completion prior to startup? 2. Stated completion prior to a specified date? 3. Stated plant improvement objective? External Requirement or Commitment 1. Is the item an NRC requirement (Technical Specification (Tech Spec), Final Safety Analysis Report (FSAR))? - III 2. Is the item an NRC commitment (e.a., SALP 3 and 86-41)? 3. Is the item committed to INPO (per report j j review)? 4. Is the item an American Nuclear Insurers (ANI) requirement? ) 5. Is the item a public commitment? i i Using these questions, the specific work items were sorted i into the following five categories: 1. Required prior to startup, l 2. Should include if possible (not to impact schedule); 3. Want to include if possible (not to impact schedule); 4. Fill in work; and 5. Not to be included in RFO-7. Boston Edison has reviewed the above criteria against the criteria incorporated into the MCIAP, and, based upon that review, is of the opinion that those two sets of criteria are functionally equivalent. Effective June 12, 1987, the Director of Planning and Restart established a Work Scope Review Committee (WSRC). The WSRC was given responsibility for identifying and prioritizing RFO-7 work according to the above guidelines. The WSRC also assisted in developing a l detailed, integrated outage work schedule based on this prioritization. O - III _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _

b. Work Plannino & Estimatina Branch 4 (_) -s Another team of experienced managers within the Planning and j Restart Group was assigned responsibility for centralized planning and scheduling of outage-related work. The Work Planning & Estimating Branch assists line organizations by f 1 preparing, updating, and revising the work scope and work plans for outage work. In addition, the Planning & Estimating Branch developed, and continues to maintain, integrated outage planning and production schedules for PNPS. This Branch also provides early identification of critical path work items and assesses the schedule impact of work i scope changes and any program delays. The Plan of the Day j l schedule is maintained for work control and daily work I assignment. i l l The-Branch also includes a cost control team to develop budget estimates for outstanding work items, and to estimate and monitor project costs by work order. This will facili-tate the identification and evaluation of any cost variances based on costs incurred versus physical progress. c. Material Readiness Branch The Material Readiness Branch coordinates the identification of material required for completion of the outage and works closely with both on site and off site Boston Edison procure-ment personnel to expedite the acquisition and any required III - l L__________.

preparation of that material. This assures that material is available on site as needed to support the restart process. j The Material Readiness Branch expedites any material identi-fied by the Outage Manager as restraining production to reduce delays resulting from lack of materials. A process is being implemented to anticipate material needs and reduce recurrence of similar restraints. l t d. Work Proaress Monitorina Branch The Work Progress Monitoring Branch has responsibility for tracking the actual performance of outage-related work. The l l Branch keeps the appropriate line managers and higher level ) I management informed of the progress and status of outstanding work items. The ready availability of such information will () enable Boston Edison management to respond in a timely manner to problems that may develop in planning and carrying out the work necessary to ensure a successful completion of RFO-7. e. Work Scope Review Committee The Work Scope Review Committee (WSRC) was established to facilitate the identification, review, and approval of work to be included in the outage schedule. The Station Manager is Chairman of the WSRC. j l The WSRC initially undertook the task of classifying and prioritizing new RFO-7 work according to the guidelines described in Chapter III.F.1.a. Boston Edison has developed l - III. _.__-._____________b

1 and will continue to maintain an integrated RFO-7 schedule () based upon this prioritization. The WSRC also continues to assist the line organization in identifying, clarifying, and I prioritizing potential new work items for inclusion in the integrated RFO-7 schedule. 2. Data Manacement Support The Planning and Restart Group also includes individuals with considerable experience in designing and implementing auto-mated information management systems for use as management and control tools on complex nuclear power plant projects. This expertise has enabled the Planning and Restart Group to meet the needs of Boston Edison management for information on the outage work. In addition, the use of automated systems has provided an essential tool for sorting, prioritizing, and {) tracking work items, many of which require involvement by multiple components within the organization, such as Engineering, Maintenance, and QA. i 3. Activities Beyond RFO-7 Boston Edison management plans to integrate into the perma-nent organization new methods, systems, and procedures developed during RFO-7 that will contribute to the on-going effectiveness of operational performance. In addition, Boston Edison senior management will incorporate the func-tions of the Planning and Restart Group into the permanent organization. O - III _

) i i i G. Corrective Action Procrams/ Assurance of Ouality 1. Overall Commitment to Assurance of Ouality Boston Edison has instituted a series of new programs and actions to improve the level of senior management attention to prompt and effective resolution of problems identified through the QA process. The need for responsiveness to identified problems is an organization-wide challenge and ) i responsibility that goes beyond the effectiveness of the QA Department in identifying and tracking such problems. 1 l i Two factors - the lack of a stable management team and a split of authority between the Plant Manager and the Director of Outage Management - were identified in SALP No. 86-99 as sources of Boston Edison's slow response to identified problems. Actions that address these concerns are described a in Chapter II.B. In addition, Boston Edison has instituted a number of improvements in the tracking and closure of open QA items directed at improving the responsiveness of line management to deficiencies and recommendations identified by QA. Asserance of quality does not begin and end with a strong QA Department; it also requires that an emphasis on quality be manifest in the activities of each component in the Nuclear Organization and each individual in those components. O - III -____-__ - _ - _ _ _ _

Boston Edison has recognized the need to improve the correc-O tive action process. The QA Department has been assigned the lead role in these efforts. Representatives from each Nuclear Organization component are participating with the QA Department in a joint task force. The goals for improving the corrective action process include better reporting, processing, and dispositioning of quality-related problems. A Work Identification and Management Task Group comprised of representatives of Operations, Engineering, QA, and the Planning and Restart Group was recently established. The purpose of the Task Group is to streamline the process for identifying, screening, authorizing, and tracking MRs, as well as the actions taken to resolve them. The Task Group has recommended actions, both for restart and long term improvement, which are being incorporated into the first revision of the MCIAP. The QA Department has improved the tracking of Non-Conformance Reports (NCRs) and provides weekly reports on the status of open NCRs. This weekly report li'sts total NCRs and includes a complete, computer generated list of open NCRs showing, among other things, the date opened, disposition status, and the initiation source of the NCR. The report provides timely feedback to management on the disposition of NCRs. In addition, the QA Department produces a semi-annual I s i - III - _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ -

Trend Analysis Report which provides data and trends on NCRs \\/ and other deficiencies for use by senior management. The Trend Analysis Report was recently revamped to simplify and 1 improve the presentation of data. j l Further assurance of prompt and effective corrective action on identified problem areas will be provided by the various ) j improvements in work control described in this report. These ) improvements will eni.ance management's ability to identify and monitor work in progress and to ensure that the focus on first line quality of work is maintained throughout the Nuclear Organization. l l 2. Corrective Actions in Specific Disciplines () a. Radiological Controls In response to identified weaknesses in the control of on site radiological protection activities at PNPS, 'ston I ( Edison management has implemented a number of corrective actions. First, the new Radiological Assessor, who reports directly to the Senior Vice President - Nuclear, will conduct I assessments of radiological performance in each radiological functional area at least biennially. The functional assess-l 1 ment areas include the ALARA Program, Radiological Task Planning and Radiological Work Permits (RWPs), Radiation Protection Training, and Contamination Control. In addition, the Radiological Assessor will conduct regular assessments in i O - III I l l management areas such as Training and Qualification of O, s Personnel in Radiological Protection, Radiation Exposure Reduction, and Monitoring and Improving Radiological Protection Performance. Second, control of the Radiological Occurrence Report (ROR) process was enhanced by revising the ROR procedure to improve categorization of RORs by severity level, and a full time ROR coordinator position was established. Boston Edison also developed a computerized tracking system for RORs. RORs are now routed to management at the level of the Section Manager or higher, and responsi-bility for implementing disciplinary action for radiation protection violations was transferred to the line supervisors. Third, as described in Chapter III.A.3, Boston Edison's Radiological Oversight Committee has been restruc-tured and upgraded to provide a more independent perspective on the effectiveness of corrective actions in the area of radiation protection. Finally, a program for an annual internal review of radiological controls compliance is currently under development in connection with the Radiological Action Plan (RAP) described in Chapter IV.C. b. Maintenance The Material Condition Improvement Action Plan (MCIAP) was ] developed by Boston Edison in response to industry group and internal assessments. The MCIAP establishes a program to improve the overall quality of maintenance performance at j () - III PNPS. It institutes numerous changes in organization, I O staffing, administration, and procedures in the Maintenance Section, some directed towards the immediate, outage-related workload and others directed towards longer term performance. The short term aspects of the MCIAP are intended to bring the workload under more effective control by reducing the backlog j l of MRs and achieving greater coordination of personnel and 1 ) resources. These efforts will make the workload more manage-able and permit a more focused approach to the maintenance function. c. Fire Protection l In the area of fire protection, Boston Edison has implemented an integrated corrective action plan, as described in Chapter l () IV.D. The NRC's recent inspection in the 10 CFR Part 50, Appendix R fire protection area, as summarized in Inspection l Report No. 87-22, dated June 18, 1987, found no unacceptable l conditions. l d. Security Boston Edison has made a number of upgrades to its security operations to more effectively carry out corrective actions. Three new staff positions, a Security Administrative Coordinator, a Compliance Specialist, and a Senior Security Technical Specialist, were added. The Nuclear Security Group has been actively involved in prioritizing and tracking security-related MRs. O - III _ _ _ _ - _

The Boston Edison Nuclear Security Group also has undertaken ,O-efforts to identify and initiate action to implement design and hardware improvements to reduce the use of compensatory The Senior Security Technical Specialist continu-measures. ally reviews the use of-compensatory measures and prepares weekly program reports that are provided to management. These efforts, in conjunction with improved management of the l l MR process, can be expected to achieve a considerable reduc-tion in the use of compensatory measures in the area of

security, e.

Surveillance Testina i The major actions to improve corrective actions in surveil-lance testing are described in Chapter IV.F. O 3. Impr.oved Responsiveness to OA Findinos The Boston Edison Quality Assurance Manual (BEQAM) has been l revised to enhance the flow of information to-management and ensure a timely and effective management response to QA l findings. The corrective action process previously required responsible managers to provide problem dispositions and take corrective actions within specified time limits. The control provided by this process has been further. strengthened by the addition of a mandatory 15-day escalation period to senior management of any overdue or inadequate responses. Further escalation to the next higher level of corporate management O - III, l 1 a

1 1 I is required every 15 days until it reaches the CEO; this-O escalation period is reduced to 7 days for deficiencies } determined by QA to be significant, j l l The QA Department Manager issues a weekly report to senior ] 1 management documenting the status and due date of overdue DRs. This report also shows DRs that will become. overdue if not acted on before the next status report. The semi-annual QA Trend Analysis Report shows trends in the issuance and resolution of DRs over a six-month period. These reports ensure that senior management is kept continually informed as to the status of DRs and any problem areas in terms of responsiveness. Management is thus better able to identify and address slow or inadequate corrective action in response O to identified deficiencies. To further strengthen management's role in the corrective action process, the BEQAM has also been revised to require a response from the appropriate manager to audit recommenda-l l tions. Unlike DRs, recommendations in the past did not l require a specific response, and implementation was to some extent left to the discretion of the individual manager. 1 Finally, Boston Edison has established a weekly meeting I 1 between the'QA Department Manager, the Station Manager, and-l ti,e Senior Vice President - Nuclear. In addition, there is a 0 - III l )

l 1 weekly meeting between QA Department and Nuclear Operations ') Department personnel to address prompt disposition of quality related problems. These weekly meetings provide useful forums for identifying and addressing problems and concerns I in the QA and corrective action process and can be expected j i to contribute to improved management responsiveness in this important area of operational performance. Management is continuing to assess the effectiveness of these changes. O i 4 / 1 l l O l - III l l ________-____A

/~U IV. PLANT AND EOUIPMENT PERFORMANCE I In this Chapter, Boston Edison's programs, plans, and actions to improve plant and equipment performance at PNPS are addressed. Boston Edison's self-assessments have confirmed that, in order to bring about sustained plant and equipment perform-ance improvements, Boston Edison's programs, plans, and actions must incorporate the following basic elements: ~ 1. Prioritization of the maintenance work backlog and reduction to manageable levels; 2. An improved plan for maintenance activities to assure continued management control; 3. Effective implementation of radiological control {} improvements and a specific action plan; 4. An improvement in the conduct of fire protection activities, completion of Appendix R modifications, and reduced dependence upon compensatory measures; 5. An improvement in the material condition of the security system; 6. Improved conduct of surveillance testing; 7. A set of plant operational condition change check-lists for restart and power ascension; 8. Deployment of a systems group to conduct system-by-system walkdowns and readiness reviews for restart; 9. Closure of Confirmatory Action Letter (CAL) No. 86-10 items; and 10. Establishment of a power ascension program, including NRC hold points. O - IV -

("' When the above elements are viewed as a composite, they (s) directly address the fundamental need for improvements in the 1 J reduction of the work. backlog, and the timely and effective corrective actions that the NRC has identified. The develop-i ment and implementation of programs, plans, and actions incorporating these elements will also result in a marked improvement in responsiveness to regulatory concerns. l I The discussion immediately following summarizes Boston Edison's programs, plans, and actions to improve plant and equipment performance in the following areas: (A) Maintenance Backlog Reduction; (B) Radiological Controls; (C) Radiological Action Plan; (D) Fire Protection; () (E) Security; (F) Surveillance; (G) Plant Operational Condition Change Checklists; (H) Systems Group; (I) CAL No. 86-10 Items Closure; and (J) Power Ascension Program. A. Maintenance Backloa Reduction 1. Backloa Prioritization and Reduction One of the principal tasks confronting Boston Edison manage-ment in completing RFO-7 is the reduction of the current backlog of Maintenance Requests (MRs). This goal will be achieved by application of sound management practices in the areas of prioritization, documentation, and tracking of outstanding MRs. These management techniques.will facilitate a rational and effective allocation of resources to complete A - IV t's work on a substantial portion of outstanding MRs. Boston U Edison plans to reduce the overall backlog to within the range of.specified goals by restart. The initial step in addressing the MR backlog was to sort and prioritize outstanding MRs in order to distinguish those that must be closed during the current outage from those that do not need to be accomplished prior to restart. The criteria used to accomplish the prioritization of MRs are described in. Chapter III.F.1.a. ) After prioritizing the MRs using the criteria, the Maintenance planning and scheduling staff developed and is {]) maintaining a detailed maintenance work schedule by plant system for completion of the MRs in accordance with assigned i priorities. This schedule, in turn, is translated into ] actual daily work plans by means of the Plan of the Day, through which daily coordination of maintenance personnel and j material is achieved. The Maintenance planning and sched-uling staff also maintains a weekly maintenance schedule that is used in conjunction with the Plan of the Day to plan maintenance work. These efforts have resulted in a more rational and consistent allocation of resources in the area of maintenance. In addition, as described in Chapter III.D.2, the Director of - IV -

- 2 l [} Planning and Restart has developed a weekly Performance Excellence Indicators Report that reflects progressftowards Boston' Edison's goals for' reducing the MR backlog. The Director of-Planning and Restart:also monitors on a daily basis the production rate for.dispositioning MRs. These' efforts have improved management's ability to' spot trends'and trouble spots, and have increased the accountability of line supervisors to management for progress.in reducing the MR-backlog. They have also' facilitated effective coordination of the large contractor work. force currently on site to accomplish outage-related maintenance. 2. Material Condition Improvement Action Plan While the efforts described above are focused primarily on the short term reduction of the MR backlog, Boston' Edison also has undertaken significant new initiatives to achieve a long term improvement in maintenance at PNPS. Specifically, i based upon self-assessments and consultation with outside experts', Boston Edison management has adopted a Material Condition Improvement Action Plan-(MCIAP). A copy of the MCIAP will be provided to the NRC for information. The MCIAP was developed through a rigorous process of inspec-l tion and assessment that included the following: 1. A clear understandingfof current conditions was, established by thoroughly; inspecting and evaluating the overall maintenance program using; industry l () - IV. ._____.;_______________._____.__.___.___w

i = ~ (~} professional'ls with proven capability for managing maintenance and evaluating complex industrial N-(nuclear) operations. 2. The conditions which should exist at PNPS were established after careful evaluation with success-ful managers within the industry and by reviewing successful maintenance operations at other similar i plants. j 3. A plan with clear responsibility, accountability, and closure criteria for actions was established through extensive evaluation by Boston Edison managers and consultation with successful industry managers. 4. The plan was developed and is being implemented under the close direction of senior Boston Edison managers. Boston Edison's initial assessment of the maintenance func-tion focused on work identification and planning, schedule preparation, work assignment, work progress, workforce (,l \\ \\- supervision and discipline, workmanship practices, material condition, and management control. This involved: 1. Interviewing upper level managers to determine j applicable policies and management methods; j 2. Reviewing procedures established for implementing policies; j 3. Analyzing working documents, schedules, and other communications to evaluate the degree of adherence in following established procedures; 4. Observing work in progress and interviewing working level personnel to determine actual practice; and 5. Inspecting plant spaces and systems. O - IV _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _

i I (]J The initial assessment of existing conditions was verified by a independent reviews conducted by a Maintenance Review Team from the Institute of Nuclear Power Operations (INPO) and by two-teams of experienced consultants from'within the nuclear power industry. These reviews were mutually consistent and reinforced the resolve of Boston Edison senior managers-to l take decisive actions to improve performance. To enable appropriate selection of actions, desired condi-tions were identified during the maintenance review. These condition statements focus attention on the results to be achieved and, when compared to existing conditions, on the changes required to company and employee practices. O For each identified problem area, recommended restart and long term corrective actions were proposed by the teams identifying or verifying existing and desired conditions. In addition, cognizant Boston Edison managers evaluated the identified problems from their own perspectives and provided independent recommendations. From these various inputs, Boston Edison managers distilled a final plan of action with clear definition of the results to be achieved. 1 For each short term action, a responsible manager.is assigned and an action completion date established. For each long term action, a start date is established. - IV l ({} Specific criteria for closure of each action item are being l developed and will be included in the management plan estab-lished to oversee the improvement program. Implementation progress will be monitored by senior managers' weekly for restart actions and monthly for long term actions. i The MCIAP will help to fulfill Boston Edison's commitment to l achieving excellence in operation of PNPS by. upgrading the ]' l l material condition of the physical plant. It reflects high standards for maintaining the plant in top material condition and incorporates a detailed schedule of implementation through which adherence to these standards will be achieved. B. Radiological Controls O The actions taken by Boston Edison in the radiological controls program to address and resolve identified weaknesses l include: (1) Organizational and Staffing Improvements; J (2) Communications Within Nuclear Organization;-(3) Improved Radiological Protection and Control Practices; (4) Plant i Decontamination; and (5) Response to Radiological l Occurrences. 1. Organizational and Staffina Improvements As described in Chapter III.A.3, Boston Edison has recently. moved the former Radiological Section Manager to the Chief Radiological Scientist position, brought in a new experienced Manager for the Section, and hired a number of other experi-l ' '( ) i - IV l l l .___________--w

i 1 l /] enced radiological technical personnel. In addition, to (- provide better radiological control of maintenance work, Radiological Control Specialists have been assigned to the Maintenance Section for groups with work loads which require substantial numbers of Radiological Work Permits. 2. Communications within Nuclear Organization Each organizational section at PNPS developed radiological goals, including: (a) exposure budgets; and (b) requirements to build radiological controls into the routine work process and the work habits of the individuals performing the work. i This requires the production personnel to assume responsibil-ity for proper radiological control practices in their work. In connection with this change in philosophy, communications between the health physics staff and other station Sections l have been improved through inclusion of radiological protec-l tion discussions in nuclear organization daily and weekly meetings and close nanagement monitoring of the working ) relationship between Radiological Control and the other Sections. 3. Improved Radiological Protection and Control Practices Radiological protection and control practices have been i improved in a number of areas. The health physics counting laboratory practices have been upgraded through daily super-l ) - IV _ _ _ _ _ _ _ _ _ _ - _ _ _

I visor reviews of counting laboratory data and development of technical documentation or procedural guidance on radioactive source checks and background radioactivity calculations. I Procedures for radiological protection, such as those for i decontamination, storage and issuance of contaminated tools, in-vitro monitoring, and internal exposure monitoring, have been upgraded to incorporate more detailed instructions and appropriate guidance and standards. Another improvement in radiological practices is the comprehensive upgrading of the ALARA program. Program procedures have been developed and I radiation exposure goals have been established for tracking i and reporting. Boston Edison has initiated closer monitoring and reporting of ALARA program results, establishment of an ALARA employee of the month, and inclusion of ALARA perform-i ance in the employee performance evaluations. This increased 3 attention to proper radiological practicen at both the section and individual employee levels is designed to reduce personnel exposure, prevent unnecessary contamination of the plant, and improve the overall cleanliness of the work areas. 4. Plant Decontamination An extensive decontamination program is underway to reduce contamination levels throughout the plant and clean up certain previously contaminated areas such as the Reactor Building quadrant rooms so that they can be toured without O - IV protective clothing. Short and long range goals for the {) decontamination program have been established.and will be described in the' Radiological Action Plan (RAP). 5. Response to Radiological Occurrences ~ The system for identification'and resolution of Radiological Occurrence Reports (RORs) has been upgraded to identify priority-RORs for immediate resolution and improve plant responsiveness to RORs. The ROR procedure has been revised to require categorization of RORs by severity level so that priority RORs are identified and tracked appropriately. Where possible, RORs are assigned to a section manager or higher level manager for resolution to ensure prompt manage-ment attention to radiological problems. O Many of these actions represent continuation of actions undertaken in the Radiological Improt'. ment Program (RIP) that was developed in response to NRC and Boston Edison' concerns about the radiological control program at PNPS. Although the RIP has been compl,eted, Boston Edison is also developing a Radiological Action Plan (RAP) that will serve as an addi-tional basis for final closure of the NRC's radiological Order, and sustained long term improvement in the radiologi-cal controls area. O - IV i I ~ C. Radiological Action Plan Boston Edison is currently developing a Radiological Action Plan (RAP) designed to ensure reduction and control of personnel exposure. The RAP will reflect the new Radiological Sec'(on organization, the qualification require-ments and job descriptions for Section personnel, training requirements, and improved training programs in radiation protection and radiological control. The Plan will also describe the improved procedures and facilities for radiolog_ ical control, radiological control policies, and goals and measurement mechanisms to track radiological performance, and will ensure that PNPS Sections and personnel will be held accountable for their radiological performance. The annual rT internal programmatic review of radiological controls in the V RAP will provide a management tool for assessing the effec-tiveness of the radiological control program. D. Fire Protection Boston Edison has undertaken a corrective action plan to improve its fire protection program by: (1) strengthening the management and control of this function; (2) improving the availability of the PNPS fire protection systems; (3) reducing reliance on compensatory measures; (4) improving fire barrier surveillance procedures and ensuring compliance 1 l with Appendix R requirements; and (5) upgrading the quality - IV-ll -

and effectiveness of its fire brigade training. program. The' ) major steps that Boston Edison has taken to accomplish each of these objectives are summarized below. 1. Enhanced Manaaement Controls Boston Edison retained a new Nuclear Fire Protection Group Leader in December 1986 to assess the operational capabili-' ties and status of the PNPS fire protection organization and coordinate the restructuring and revitalization of the fire protection function. The new Group Leader has extensive ~ experience in project management, the design of fire l barriers, and other fire protection projects at nuclear 1 i facilities. The Fire Protection Group Leader is accountable ) for providing management direction and control for fire (} protection operations at the site. The size and scope of the i Group has been expanded, and the management controls described in the following portions of this report have been instituted to monitor and enhance the capabilities of the PNPS fire protection systems. 2. Imoroved System Availability A Fire Protection System status board.s now maintained in the control room and the fire protection office. The board reflects the operability status of each system (e.a., fully j operational, tagged out for maintenance, or tagged out for hot work). Initially, the Fire Protection Group participated in the daily and weekly maintenance. meetings to prioritize O L - IV l l l

construction support and maintenance activities involving the (} upgrade or repair of fire protection systems. As communica-tions improved, prioritization of fire protection upgrade or l repair was initiated by routine submittals from the Fire Protection Group. These and other programs have enabled the Fire Protection Group to reduce the number of open MRs for { l fire control systems from over 260 in January 1987, to 69 as of July 30, 1987. 3. Reduced Reliance on Comot-nsatory Measures i A fire watch management system has been instituted which assures prompt evaluation and resolution of any conditions that require an assigned fire watch. The institution of this system, coupled with the concerted effort to reduce the (~) number of outstanding MRs relating to the fire protection systems, is reducing and will further reduce PNPS' reliance on the use of fire watches and compensatory measures in the I fire protection area. 4. Improved Fire Barrier Surveillance Procedures l The temporary surveillance procedures developed and imple-mented during RFO-7 served to support the requirements for surveillance during this cycle. They also provided a baseline for the fire barrier upgrade project. The existing fire barrier surveillance procedures will be revised to incorporate the results of the field walkdown and fire barrier upgrade project and reflect the current O l l l - IV (]) configuration. The existing Plant Design Change procedures will also be revised to provide a more detailed checklist for controlling the fire barrier design configuration. l 5. Enhanced Fire Bricade Trainina l The fire protection training program has been expanded and upgraded. A full time fire brigade training instructor has been brought on board and the course content and training materials have been improved to ensure that the fire drills are more realistic and involve greater use of the fire l I protection equipment. Procedures for critiquing the effec-tiveness of the drills have been improved. All fire brigade members are required to participate in at least two drills per year and in quarterly training sessions conducted by the g3 U Training Section. E. Security PNPS management has made compliance with NRC security program ) ) requirements and objectives a top priority. As a result, a l number of improvements have been made in the PNPS Security Program. The Security Group has been reorganized and expanded and an experienced manager has been brought in to direct the Security Program. The contractor security force has also been expanded and upgraded. Additional hardware and equipment has been added. The overall effectiveness of the security systems has been improved. Finally, the (O - Iv (']) administrative procer2ures and training relating to the Security Program are being revised and updated to improve the control of the security function. The principal improvements in each of these respects are summarized below. 1. Restructuring and Restaffina of the Security Group j The authorized complement for the Boston Edison on site Nuclear Security Group has been expanded to 20 personnel. The new position of Nuclear Security Group I.eader was created and filled by a security professional with over 25 years of law enforcement and nuclear security experience. The secur-ity function was also elevated to report directly to the Vice President - Nuclear Operations in order to provide direct access to senior management on security issues and upgrade management visibility and control of nuclear security matters. Three new nuclear security specialists with primary expertise in the areas of administration, regulatory compli-ance, and technical systems, respectively, were added to the Security Group to supervise these aspects of the Security 1 i 4 Program. One Boston Edison Security Shift Supervisor now works on each security shift to provide continual security management presence on site. The contractor security force was reorganized in March 1987 to include additional personnel and a reduction of the supervisor-to patrolman ratio from 1-to-20 to 1-to-10 or less - IV in order to ireduce the amount of overtime requirements. In -) us addition, an operations group within the contract security force reporting directly to the Chief of Security was estab-lished to obtain more direct supervision of the guard force. These changes have enhanced the ability of the Security Group to manage and control the Security Program and hhve improved i the overall quality and effectiveness of the nuclear security l function. 2. Additional Hardware and System Maintenance j The Nuclear Security Group conducted a system level require-I ments analysis to identify necessary modifications and improvements in the security systems, hardware, and equip-() ment, and prioritize the maintenance requirements associated with the existing security systems, hardware, and equipment. The new security staff technical systems specialist is working closely with the Engineering Department and the i Maintenance Section to implement design changes to the closed circuit TV system and the intrusion and detection systems, 1 track outstanding maintenance items, and develop and monitor l 1 preventive maintenance programs for the security systems. I The perimeter fencing and lighting have been upgraded and additional work is currently underway in this area. The MR backlog in the security area has also been reduced. Upon the completion of the planned modifications to the other security O - IV _ _ _ _ _ _ _ _ _ _ _ _. _ _ _

1 l I systems,, Boston Edison's need to rely on compensatory measures to comply with regulatory requirements and objec-l tives will be reduced. J 3. Imoroved Administration and Trainina { The Nuclear Security Group has updated and revised the PNPS Security procedures and instructions to reflect the new l organizational requirements and ensure consistency with the upgraded staffing and physical features of the Security Program. A mechanism has also been developed to identify the' causes for utilization of compensatory measures and keep senior management apprised of significant developments in this area. The Nuclear Security Group is also developing new training materials for the Security Program. } F. Surveillance 4 Boston Edison has undertaken a program to upgrade its 1 surveillance performance by improving: (1) Control of the Surveillance Test Program; (2) Surveillance Procedures; l (3) Master Surveillance Tracking Program; (4) Local Leak Rate Testing Administration and Surveillance; (5) In-Service Inspections; (6) Calibration and Testing; (7) Control of Measuring and Test Equipment; (8) Emergency Core Cooling System Logic System Functional Testing; and (9) Fire Protection Surveillance. Each of these areas is described in greater detail below. l O - IV i i v 1. Control of the Surveillance Test Procram The Technical Section has been assigned responsibility to 1 ' provide clear guidelines, centralized control, and a strong j technical focus for the Surveillance Test Program. This organization will conduct analyses of the causes of reporta- ) ble surveillance test events and initiate actions to address those identified causes. 2. Surveillance Procedures A review of PNPS surveillance procedures has been undertaken to determine whether those procedures encompass the require-ments of the Technical Specifications. Revisions will be incorporated as necessary to ensure compliance with the Technical Specifications. O 3. Master Surveillance Trackina Procram' j The Master Surveillance Tracking Program (MSTP) is in the j process of revision, based on INPO Good Practice TS-410, ) 1 " Surveillance and Periodic Task Scheduling Program," to improve tracking and scheduling of surveillance'and clarify potentially ambiguous descriptions of testing: frequency requirements. To demonstrate its reliability, the new MSTP will be operated in parallel with the existing MSTP ccamen-j cing in August 1987. PNPS plans to shift to the new MSTP in November 1987. The new MSTP will have the capability to identify surveillance tests required based on changed opera-O - IV,

tional conditions or plant events and to schedule multiple O component testing. The MSTP database is being improved and expanded in accordance with the revised program. 1 4. Local Leak Rate Testing Administration and j Surveillance ] l The program for local leak rate testing (LLRT) has been upgraded. Specific actions include bringing LLRTs up to date, providing better definition of LLRT frequency require-I ments, establishing a multidisciplinary LLRT failure analysis I team to conduct causal analysis and make recommendations to correct problems and prevent future failures, and updating the MSTP to include components requiring LLRT. 3 5. In-Service Inspections () Boston Edison has performed the In-Service Inspection (ISI) program scheduled for RFO-7. The examinations included ISI surface and/or volumetric examinations of safety-related piping and visual examinations of pipe supports. Other recent inspections related to the ISI program included ultrasonic examinations of selected stainless steel welds for intergranular stress corrosion cracking (IGSCC) in accordance with the requirements of Generic Letter 84-11 and examina-l tions of welds rescheduled in the final report of the RFO-6 ISI. l 0 - IV i (]) 6. Calibration and Testina i Procedural controls for calibration and testing have been j upgraded. Protective relay setting and test criteria have been evaluated, revised, and documented for use by the Maintenance Section. Protective relay / breaker setting and j testing requirements for safety related 4KV circuits and 480V i load centers and for 480V control centers and non-safety 4KV l circuits have been revised and documented. i 7. Control of Measurina and Test louitment Boston Edison's plans and actions for improvement in the area i of Measuring and Test Equipment (M&TE) are described in the MCIAP under Issue No. 03-029. () 8. ECCS Loaic System Functional Testinq l Emergency Core Cooling System (ECCS) Logic System functional l test procedures are being reviewed and revised for use during plant mode changes for RFO-7 and restart. Simulated automa-tic actuation testing is being factored into the Tevised ECCS l Logic System functional test where appropriate. 9. Fire Protection Surveillance Current fire protection surveillance are being performed primarily by plant operators. In the long term, Boston Edison will develop and implement a Fire Protection Improvement Action Plan. As part of this Plan, Boston Edison will implement a program to examine existing fire protection O - IV _ _ _ - _ _ _

surveillance and assign dedicated personnel for performance {} of those surveillance under the auspices of the Fire' J Protection Group. G. Plant Operational Condition Chanae Checklists Boston Edison has adopted a system of checklists to track the completion of designated milestones leading to restart of operations at PNPS. This management tool provides a ready means of assuring satisfaction of management, regulatory, and 1 operational requirements prior to changing plant operational condition as each of the milestones is achieved. 1 Checklists were first used at PNPS for the recirculation pipe replacement work-during RFO-6. Based on that successful O experience, the checklist program has been expanded and refined for use during RFO-7. The checklist program is intended to accomplish the following objectives: 1) Provide management with a. tool to aid in evaluating j outage progress. 2) Provide a means of breaking down the outage into distinct milestones. 3) Provide a tickler file for items to be accomplished prior to performing milestone activities. 4) Provide a final management check on required work prior to management authorizing performance of milestone activities. O - IV. f

l (] 5) Prevent running into an insurmountable number of l \\ items to be accomplished just prior to entering a l Plant Operational Condition Change. The process of selecting items for inclusion in the check-I lists was designed to identify the potential areas of impor-l l tance for successful completion of RFO-7. To assure the f inclusion of potentially relevant items, Boston Edison 4 i management developed broad guidelines for the selection of ) 1 checklist items, as follows-i 1) Any uncaptured items known or believed necessary to I " complete" prior to beginning a Plant Operational l Condition Change (Checklist Milestone). I 2) Any required and " tracked" items which, because of their substantial multidisciplinary review and approval process, require increased management attention to ensure completion. Usually an item of () this type will have multiple checklist entries that ccver the major events within the single work j package. 3) Any items that have caust_d problems or delays in reaching plant milestones. 4) Surveillance procedures required to be performed I prior to plant milestones, including MSTP scheduled I procedures. 5) Any item that the Checklist Team (Outage Management Group) wishes to follow due to potential for delaying a milestone. 6) Any item for which a party is responsible and wishes to be reminded. - IV _ _ _ _ _ _ _ - - _ _ _ _ _ - _ - _ _ _ _ _ _

1 (} There are eight checklists planned for use during RFO-7, which correspond to the major defined plant milestones l (Operational Condition Changes) that occur during the outage, i as follows: 1) Refuel Bridge Testing' Complete - Offload Core; ) l 2) Commence Reloading' Fuel; ) 3) Reload Complete - Assemble Vessel & Containment; 4) Plant Hydrostatic Testing; 5) Integrated Leak Rate Testing; 6) Pre-Critical Tests / Plant Startup; 7)< Plant Heatup & Testing; and 8) Power Escalation & Physics Testing. l' Information on the checklists is maintained on an automated O data base and is updated daily as work progresses toward the relevant milestone. The updated checklists are distributed weekly to managers and personnel with responsibility for completion of checklist items. As a milestone is approached, checklist items are statused more frequently to' ensure that each item on the checklist is properly dispositioned. There i are four possible dispositions: (1) complete, meaning field complete; (2) closed, meaning relevant paperwork has also been completed; (3) not required, meaning the item has'been-determined to be unnecessary for the present milestone and will be cascaded to the next milestone; and (4) deleted, a O - IV,

l -{ ) ~ category used only'in relatively few cases, such as. duplicate-items, in which it is found that.the item should not have been included on the checklist. Section Managers review the completion and disposition of their checklist items before the checklist is signed by the Outage Manager for presentation to the Plant Manager. Checklist completion is reviewed by the on1 site safety review committee - the Operations Review Committee (ORC) - prior to, a decision to authorize operation. It.should be noted that I ( the off site safety review committee - the Nuclear Safety' Review and Audit Committee (NSRAC) - will perform its normal role in regard to independent safety review. NSRAC will not {]) perform an independent restart readiness review that will' cover the spectrum of issues impacting startup. This is a change from earlier plans presented at the September 9, 1986 Management Meeting. This change has been made in recognition of the demands already placed on the NSRAC and the increase in senior management experience and involvement'in the oversight and self-assessment of readiness. ] l 1 H. Systems Grr2ME l i l 1. Basic Responsibilities In January 1987, Bostta Edison began the staffing of a Systems Group in the Nuclear Operations Technical Section. The Systems Group is patterned on INPO Good Practice TS-413, O - IV !

[} "Use of Systems Engineers." Its purpose is to provide . greater depth and continuity in the oversight of major ' operating systems at PNPS. l The Systems Group is responsible for remaining cognizant of the status of major plant systems, including condition, configuration, operation and maintenance, and modification activities. It is staffed by specialists who serve as contact points and resident experts on designated systems. The number of systems or areas assigned to each specialist is limited to ensure a depth of expertise. System and area assignments will be rotated periodically among the special-l ists to allow flexibility and permit personnel to gain (]) experience in several areas. Alternates are appointed for each area or system to ensure adequate coverage. The com-plexity of assignments is based on the experience level of 1 the individual specialist. The specialists conduct system I walkdowns and area inspections in order to identify and document potential safety hazards, material conditions, and overall cleanliness. Checklists are used to guide these walkdowns and inspections. The central concept behind the Systems Group is'that desig-nated individuals with the requisite credentials and experi-ence will have " ownership" of the major operating systems at 0 - IV __ _ _-_____________ ____________________ __ - _-_

i I PNPS. This will improve the quality of system performance {} over the long term. The specific duties of the Systems Group are as follows: 1) Accumulate, review, and disposition operational experience information related to plant systems received from industry sources both inside and ] outside the plant. 2) Assist in the investigation of reportable occur-rences or significant operating events. This will 1 l include ultimate corrective / preventive measures and root cause analysis and disposition.for selected Failure and Malfunction Reports (F&MRs) on cogni-l zant systems. Systems Group personnel will also j provide problem investigation support to Operations i personnel in determining system operability in the face of equipment failures (F&MRs) on an on-call (24 hour) basis as requested by Operations. l 3) Perform regular reviews of appropriate logs and instrumentation, observe system operation and I testing to identify procedural deficiencies or incipient failures, and conduct periodic inspec-l ({} tions of assigned areas to ensure that proper plant i cleanliness and material and radiological condi-1 tions are being maintained. Based on these activi-ties, identify problems with systems and initiate I prompt problem documentation, investigation, and corrective measures prior to occurrence of a forced system or unit outage. 4). Evaluate system performance to-improve efficiency and reliability, including reviewing data gathered and trended by the performance engineers. 5) Contribute to updating various applicable documents such as FSAR, Technical Manual, Technical Specifications, lesson plans, etc. 6) Participate in the preparation and review of Engineering Service Requests (ESRs), Scope Justification Approvals (SJAs) and Plant Design Changes (PDCs), proposed licensing submittals, operating procedures, and other~ pertinent documents l as appropriate. O - IV () 7) Remain cognizant of modifications, design, construction, installation, and associated test activities. Remain cognizant, advise, or assist with post-modification startup testing, and advise management regarding system readiness. 8) Administer the NPRDS Program and manage the MSTP program. l Long term responsibilities of the Systems Group are as follows: 1) Concurrent with maintenance planners, track MR burden in system, review mini-outage contingency l work lists and make recommendations for system l outages, if required to reduce MR/ outage burden, l and maintain top equipment condition. 2) Participate in and approve Post-Trip Reviews. 3) Trend MRs for repeated / generic failures, identify rcot cause, and implement corrective action. { \\ 4) Perform other assignments, and contribute to or j () manage special projects or studies as assigned by the Systems Group Leader and Technical Section l Manager. j l 2. Responsibilities for Restart In addition to the above responsibilities, the Systems Group also has responsibilities directed specifically toward the restart effort. Specialists in the Systems Group work closely with the Work Authorization and Control Branch (WAC) in the Planning and Restart Group in the review of outage-related work and selective verification of work completion. In the Systems Group, additional contractor personnel have been added to support this function. Ob - IV The Systems Group is performing a review of outstanding work items in the Nuclear Organization to identify for WAC the required refueling outage work scope. Work items are identi-fied in several separate work tracking systems and sorted according to functional system for prioritization and author-ization by WAC. Information generated by this process is fed into the milestones checklist data base for use in formu-lating the checklists, as described in Chapter IV.G. The i Systems Group is also monitoring work item closeout on a selective basis to ensure thorough closure. These responsibilities for identifying the scope of outage work and overseeing the closure process have made the Systems O Group an essential resource to management in controlling the U progress of outage work and in assuring that the systems are returned to service so that reliable operation will be i achieved. These outage-related responsibilities will carry l over to Systems Group responsibilities for continuing over-sight of plant systems. I. Confirmatory Action Letter No. 86-10 Items Closure l Confirmatory Action Letter (CAL) No. 86-10, as supplemented by the NRC's letter of August 27, 1986, established a set of requirements for response by Boston Edison. The closure status of CAL No. 86-10 items will be presented in Appendix ) l l l 0 - IV _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _

8. These items will be closed by Boston Edison or scheduled (} for completion in-connection with the Power Ascension Program depicted in Appendix 13. J. Power Ascension Procram Boston Edison has developed a power ascension logic plan and schedule in response to the August 27,.1986 NRC request. The i power ascension logic plan and schedule for restart from RFO-7 is based on PNPS power ascension logic plans developed i for restart from prior refueling outages, and specific j 1 testing requirements associated with specific plant hardware and technical issues for this outage. I The' power ascension program defines the sequence of power O ascension steps and associated tests and checks that will be used by the Nuclear Operations Department (NOD) to bring PNPS to criticality and progress through power ascension to 100% power. Prior to startup and several points during the power ascension have been identified as logical hold points for NRC evaluation of the operational performance of the plant based on results of tests and inspections associated with those natural plateaus in the power ascension. Logic diagrams for the power ascension program will be included as Appendix 13. The diagrams depict two alterna-tives: One set of diagrams will be predicated on completion O - IV -

of HPCI and RCIC testing at 150 psi prior to power ascension, j while the.other will be predicated on HPCI and RCIC testing .being performed during power ascension. Boston Edison Is continuing to evaluate the possibility of using a portable auxiliary boiler to perform HPCI and RCIC testing at 150 psi i prior to beginning power ascension. ) A procedure is being developed to describe the sequence of startup and restart tests to be conducted.following the RFO outage. The procedure will provide a brief description of each of the tests included in the power ascension program as ..I depicted in Appendix 13 and a brief statement of the purpose l 1 of each test. In addition, it will include a restart test O matrix of tests performed at identified points during the 4 power ascension, a suggested critical path schedule for the restart test program, and a checklist which will be used.to 4 document that a test has been completed by the responsible individual. There will be two hold points during actual power ascension and one hold point prior to restart, for a total of three hold points. In accordance with CAL No. 86-10, Boston Edison will not restart PNPS until the NRC Regional Administrator has authorized restart. Therefore, the first hold point is the NRC authorization for PNPS restart based on review of Boston Edison's readiness assessment and Restart Plan. - IV l

l The second hold point will be after recovery from reactor j A mode switch testing and with the plant conditions established (,j for commencing the test ~for. shutdown from outside the control The tests performed up to this hold point will have room. sufficient acceptance criteria and the results can therefore j be evaluated _for operational plant performance to form the basis for approval of continued power ascension. The third hold point will be prior to movement of the scram set point above 95% power. The tests performed up to this hold point will have sufficient acceptance criteria for use as a basis for the decision to continue power ascension. Senior management personnel will provide oversight of major-() evolutions during restart and power ascension. Seni'or. I management performing this function will include: o Senior Vice President - Nuclear; Vice President - Nuclear Engineering and Quality o Assurance; o Assistant to Senior Vice President - Nuclear; o Director of Planning and Restart; Nuclear Engineering Manager; and o o Quality Assurance Manager. Individuals with current or previous BWR Senior Reactor Operator licenses or certifications will be assigned on-shift 1 to support senior management, and to observe and evaluate performance during startup and power ascension. l () - IV l

q 1 (]) Operations staffing will be based upon a four shift rotation and there will be an additional senior licensed' individuals ~ reporting to the Nuclear Watch' Engineer on each' shift. Four' { senior' operations-experienced individuals will serve as shift-operations managers for each shift.. ~ R .i Shift _ operations management, with oversight by senior. manage-l I ment, will assess performance, provide real time feedback to operations personnel, and initiate corrective action as necessary. O L O - IV-32:- ..__._______.._m_

() V. Bases for Readiness Assessment As part of Boston Edison's self-assessment of PNPS perform-ance, a Nuclear Organization senior management review defined and articulated the bases that Boston Edison will use for conducting its self-assessment of PNPS readiness for restart. These bases deal directly with the problema that underlie concerns expressed by previous NRC inspections, including ] those in the areas of: (1) staffing; (2) work backlog; (3) responsiveness to regulatory issues; and (4) timeliness ~ and effectiveness of corrective actions. Boston Edison recommends that the NRC consider adopting these bases for the NRC's independent diagnostic review. If Boston () Edison's readiness assessment and the NRC's independent diagnostic inspection and readiness assessment utilize this approach, NRC senior. management and the Commissioners will have a consistent presentation of information on which to base the restart decision. 4 e As used throughout this report, the term " goal" is not intended as a go/no-go acceptance criterion. It is intended to have the dictionary meaning: "the end to which effort is directed." In this sense, Boston Edison's goals are intended to guide its efforts, and if performances falls reasonably O - V I a

i-within the' range of a goal, or if trends toward'the goal are {) positive, a positive management assessment of performance would be. indicated. This Chapter of the Restart Plan-contains a programmatic description'of the specific bases.that Boston Edison has selected for use in its readiness assessment. Some of the results of Boston Edison's readiness assessment are already presented in Chapters II, III and IV of this report. Most of the results to date will be presented in Volume 2 of this report, which is a separate volume of 1 Appendices. Updates to these appendices will be submitted in (]} two subsequent editions of Volume 2, namely: A. An interim report that will be submitted six weeks prior to restart; and, B. A final report-that will be submitted three weeks prior to restart (at about the midpoint of the NRC diagnostic inspection). I The seven bases that Boston Edison has selected for its self-assessment of PNPS readiness for restart are as follows: AT THE TIME OF RESTART: l A. Management will have executed its plans for RFO-7 work. I B. Staffing levels will be adequate to support safe and reliable restart and continued operation, and a plan for orderly transition from the restart organization to a. long term organization will be' established. O - V 1

(3 C. Pertinent performance indicator trends for RFO-7 work, (_) including backlog work, will show that management control has been established. D. Self assessments will have been performed and action plans established, including comprehensive action plans addressing material condition (including maintenance) and radiological controls, to assure that management control will continue. E. Regulatory issues will have been addressed. F. Systems group reviews will have been completed and i restart actions identified for those reviews will have been closed or specifically scheduled in the approach to startup. G. The RFO-7 Power Ascension Program, including NRC hold points, will have been established. A detailed description of each of these bases is set forth l below: A. Management will have executed its plans for RFO-7 work. O x./ This basis for assessment consists of the following elements: 1. Boston Edison's actions to improve management, as described in Chapter II, will have been implemented. 2. An improved planning and work (,)ntrol system will have been implemented as described in Chapter III.F. 3. Work specified for completion in the RFO-7 sched-ule, which includes modifications, preventive maintenance, and. corrective maintenance, will be I complete or scheduled for the power ascension l - V - _ _ _ - - - - - -

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.-_________j

i 1 ) phase. Appendix 2 presents the results of the O assessment of this element in the form of a Level I Schedule. B. Staffing levels will be adequate to support safe and reliable restart and continued operation, and a-plan for orderly transition from the restart organization to a ') long term organization will be established. This basis for assessment consists of the following elements: 1. Boston Edison will have implemented programs, plans, and actions to improve staffing levels, experience, effectiveness and support. Chapters II and III summarize these programs, plans, and i actions. 2. Staffing levels will be adequate to support safe { and reliable restart and continued operation, as follows. l a. A sufficient number of licensed operators j will be available to man four shifts during startup and power ascension. Over the longer I term, the goal of manning six shifts will be achieved. Appendix 3 in Volume 2 presents the results of Boston Edison's projections of licensed operator resources as of June 1987, for the period of time extending through December 1988. As discussed in Chapter IV.J, licensed operator resources during () startup and power ascension will be concen- - V l l

i i trated by providing an additional senior 7~ (, licensed operator and a management presence. b. In the areas of maintenance supervision, i security, fire protection, radiological controls, and technical, adequate complements ) i will be established and vacancies will be I minimized. The data will be presented in Appendix 4. 3. A plan for orderly transition from restart to a long term organization will be established. i a, Boston Edison has made the commitment of resources and continuing senior management involvement necessary to achieve and maintain (^) 1 an excellent organization over the long term. These commitments are presented in Chapter II of this report. b. Boston Edison has augmented its organization by bringing experienced managers into key Nuclear Organization positions. The augmented j structure and staff of the Nuclear Organization, as of July 30, 1987, are presented in Chapter II and III.A of this report. O - V _ - _ _ _ _ _ _ _ _ _ _ _ _

c. Boston Edison will establish a plan for continuing improvement in its organization and for orderly transition to a long term organization. This plan is committed to in Chapter II.B and the Material Condition Improvement Action Plan (MCIAP). d. Boston Edison will monitor the implementation of its long term organization by adherence to I the following principles: 1) overtime will be maintained within Company policy limits as described in Chapter III.A.2. l l 2) The use of contractors to fulfill the {} functions of permanent Boston Edison positions will be minimized as discussed in Chapter II.B. 3) The backlog of work, as measured by l Boston Edison's Performance Excellence Team (PET) program performance indica-l tors, will be maintained within the range of established goals. The PET Program is described in Chapter III.D and the results of the PET program performance I indicators are presented in Appendix 5. l l O v - V 1

f3 C. Positive trends in pertinent performance indicators for (_) RFO-7 work, including backlog work, will show that . management control has been established. Management control will be considered established when the results of the following performance indicators presented in Appendix 5 are within the range of respective goals for each indicator: i Indicator Goal ) Reload Systems Schedule 100% of milestones scheduled Total Open MRs 1000 MRs required for restart 0 Open power block related MRs 500 (INPO definition) I Open Fire Protectiot and 40 (FP)/20 (Sec.) Security MRs (corrective maintenance) i Open Deficiency Reports (DRs) 20 ) Overdue DRs 0 j 0 l Non-conformance Reports (NCRs) Power Block (~ Radiological Occurrence Reports 1/150 people on site (RORs) l Plant Decontamination 90% accessible floor area clean D. Self-assessments will have been performed and action plans established, including comprehensive action plans addressing material condition (including maintenance) and radiological controls, to assure that management control will continue. This basis consists of the following elements: 1. Self-assessments and other actions to assure management control will have been performed or will be ongoing. Chapter III contains a description of these management programs, plans, and actions, including those for management performance moni-toring, training, PET activities, planning and - V _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~

scheduling, and corrective actions. Upon submittal gs O of the final edition of Volume 2 and its request for restart, Boston Edison will.have completed its self-assessment. 2. Boston Edison's prcgrams, plans, and actions to l. improve plant and equipment performance will have been implemented as described in Chapter IV. 3. A Material Condition Improvement Action Plan-(MCIAP) will be developed and implemented in accordance with its provisions. The summary status of each action item in the MCIAP will be presented in Appendix 6. 4. A Radiological Action Plan (RAP) will be developed and implemented in accordance with its provisions. The summary status of each action item in the RAP will be presented in Appendix 7. 1 1 E. Regulatory issues will have been addressed. This basis consists of the following elements: 1. Confirmatory Action Letter (CAL) No. 86-10 open items will have been cloued by Boston Edison or l scheduled for completion. Appendix 8 presents the l closure status of CAL No. 86-10 items. - V _ _ - _ _ _ _ _ _ _ - - _ _ _ _ - _ _ _ - _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _. ___

2. Management Meeting 86-41 items will have been 'bg closed by Boston Edison or scheduled for comple-tion. Appendix 9 presents the closure status of Management Meeting 86-41 items. 3. The Boston Edison Restart Regulatory Responses described in Chapter III.E will have been closed by Boston Edison-prior to restart or scheduled for completion. Appendix 10 presents the status of all l Boston Edison' Restart Regulatory Responses, including a summary of each regulatory issue, the Boston Edison actions, the' acceptance criteria, the closure status, and the recommended closure process for each such issue. Previous commitments that Boston Edison proposes to change are separately [} summarized in Appendix 11. 1 F. Systems group reviews will have been completed and restart actions identified in those reviews will have been closed or specifically scheduled in the approach to startup. A summary report on the results of the systems group reviews for each system reviewed will be presented in Appendix 12. l The systems which will be reviewed will also be listed in Appendix 12. 1 G. The RFO-7 Power Ascension Program, including NRC hold points, will have been established. The power ascension program, including Boston Edison's proposed NRC hold points, is presented in Appendix 13. O - V ______

1 l 1 ) l O. LIST OF APPENDICES 1 i 1. Restart Plan Flow Chart J i 2. Level I RFO-7 Schedule j 3. Licensed Reactor Operator Complement. Projection 4. Staffing Levels in Key Areas 5. Performance Excellence Indicators 6. Summary Status of Restart Actions in MCIAP 7. Summary Status of Restart Actions in RAF 8. Status of CAL No. 86-10 Items 9. Status of Management Meeting 86-41 Items 10. Restart Regulatory Responses 11. Proposed Changes to Regulatory Commitments ) 12. Systems Group Review Summary Reports 13 '. Power Ascension Program - A.

s) LIST OF APPENDICES 1. Restart Plan Flow Chart 2. Level I RFO-7 Schedule 3. Licensed Reactor Operator Complement Projection 4. Staffing Levels in Key Areas 5. Performance Excellence Indicators 6. Sur. mary Status of Restart Actions in MCIAP 7. Summary Status of Restart Actions in RAP 8. Status of CAL No. 86-10 Items 9. Status of Management Meeting 86-41 Items 10. Restart Regulatory Responses 11. Proposed Changes to Regulatory Commitments (,,' \\ 12. Systems Group Review Summary Reports 13. Power Ascension Program I O

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O APPENDIX 2 LEVEL I RFO-7 SCHEDULE q t (To Be Provided With Future Revisions) 4 O

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1 ) -( APPENDIX 4 1 STAFFING LEVELS IN KEY AREAS BECo BECo BEco Contractors Positions complement Complement Employees in BECo Unmanned j Positions i 1/1/86 7/30/87 '7/30/87 7/30/87 7/30/87 j ' Maintenance Section (First Line 26 41 36 '4 1 Supervisors ) l and above) .j i ) Security 11 20 12 8 0 Group j Fire Protection 1 6 2 4 0 Group I 'l Radiological Protection 53 76 62 13 1 Section i i Technical 26 46 ~ 40 5' 1-Section j O 1 L 1

APPENDIX:5 PERFORMANCE EXCELLENCE INDICATORS (To Be Provided With Future Revisions). 'l 1 ) I O i i I l l 1 O q

I APPENDIX 6 BUMMARY BTATUS OF RESTART ACTIONS IN MCIAP j I (To Be Provided With Future Revisions) i I f l i l 'I 1 i I i l i i O I 1

O APPENDIX 7

SUMMARY

STATUS OF RESTART ACTIONS IN RAP (To Be Provided With Future Revisions) W O O

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LO 4 APPENDIX 9 STATUS OF M 86-41 ITEMS (To Be Provided With Future Revisions) i c O J O

O APPENDIX 10 RESTART REGULATORY RESPONSES (To Be Provided With Future Revisions) l l l O i 1 i

== 0

O APPENDIX ~11 PROMSED CHANGES TO REGULATORY COMMITMENTS l (To Be Provided With Future Revisions) l } O l 0

O APPENDIX 12 SYSTEMS GROUP REVIEW

SUMMARY

REPORTS (To Be Provided With Future Revisions) 1 ' n V 1 l i O l

I 10 V APPENDIX 13 POWER ASCENSION PROGRAM (To Be Provided With Future Revisions) O j i 4 i l 4 [' l V} ,}}