ML20196E349

Informs That No Changes to SALP Board Rept 50-293/87-99 Warranted Based on Review of Util 880919 Comments.Ack Improvement Efforts Util Outlined in Functional Areas of Radiological Controls & Training Effectiveness

ML20196E349
Person / Time
Site:	Pilgrim
Issue date:	12/01/1988
From:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Bird R BOSTON EDISON CO.
References
NUDOCS 8812090321
Download: ML20196E349 (3)

See also: IR 05000293/1987099

Text

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DEC 011988

Docket No. 50-293

Boston Edison Company

ATTN: Mr. Ralph G. Bird

Senior Vice President - Nuclear

Pilgrim Nuclear Power Station

RF0 #1 Rocky Hill Road

Plymouth, Massachusetts 02360

Gentlemen:

Subject: Systematic Assessment of Licensee Performance (SALP) Board Report

No. 50-293/87-99 and Reply Letter Boston Edison Company (BECo)88-137

dated September 19, 1988

This letter refers to the Systematic Assessment of Licensee Performance (SALP)

of the Pilgrim Nuclear Power Station for the period February 1,1947 through

May 15, 1988, initially forwarded to you by our July 27, IL., letter

(Enclosure 1). This SALP evaluation was discussed with you and your staff at a

meeting held in Plymouth, Massachusetts, on August 25,1988 (See Enclosure 3

for attendees). M

We have reviewed your September 19, 1988 com.entsm (Enclosure 4) and acknowledge

the improvement efforts you outlined in the functional areas of Radiological

Controls and Training and Qualification Effectiveness. I encourage you to con-

tinue your efforts in these areas. After reviewing your response, I have con-

cluded that no changes to the original SRp Board Report (Enclosure 2) are

warranted.

In accordance with 10 CFR 2.790(a), a copy of this letter and its enclosures

will be placed in the NRC Public Document Room. No reply to this letter is

required.

Your cooperation with us is appreciated.

Sincerely,

OM at-M Cigned By

Lild C T. L,,CS;LL

William T. Russell

Regional Administrator

OfflCIAL RECORD COPY BLOUGH 393 11/23/S8 - 0001.0.0

11/23/88

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Boston Edison Company 2 DEC 011988

Enclosures:

1. NRC Letter, W. Russell to R. Bird, dated July 27, 1988

2. NRC Region I Systematic Assessment of Licensee Performance (SALP)

Report No. 50-293/87-99

3. SALP Management Meeting Attendees dated August 25, 1988

4. BEco Letter, R. Bird to NRC, September 19, 1988

cc w/encis: /

K. Highfill, Station Directoff

R. Anderson, Plant Manager v

J. Keyes, Licensing Division Manager j

E. Robinson, Nuclear Information Manager 7

De

R. Swanson, Nuclear Engineering / partment Manager /

TheHonorableEdwardJ.Markey/

The Honorable Edward P. Kirby /

The Honorable Peter V. Forman/

B. McIntyre, Chairman, Department of Put3 11 c Utilities /

Chairman, Plymouth Board of SelectmenV

Chairman, Duxbury Board of Selectmen /

Plymouth Civil Defense Director /

P. Agnes, Assistant Secretary of Public Safety, Commonwealth of Massachusetts

tt

S. Pollard, Massachuse/s

R. Shimshak, MASSPIRG Secretary of Energy Resources /

f

Public Document Room (POR)/ /

Local Public Document Room (LPOR)/

NuclearSafetyInformationCenter(NSIC)j

NRCResidentInspector/ '

Commonwealth of Massachusetts (2) /

Chairman Zech /

Commtssioner Roberts /

Commissioner Carrs

CommissionerRogersQ

Commissioner Curtiss /

K. Abraham, PAO-RI (19)/

OFFICIAL RECORD COPY BLOUGH 393 11/23/SS - 0002.0.0

11/23/S8

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Region I Docket Room (with concurrences) /

ManagementAssistant,ORMA(w/oencis) [

J. Taylor, OEDO / i

J. Lieberman, OE / l

W. Russell, RA / '

J. Allan, ORA / I

D. Holody, E0 / l

T. Martin, DRS // * l

S. Ebneter ORS $ v i

W. Kane, ORP/ /

S. Collins, ORP /  :

J. Wiggins, ORP '

R. Blough, DRP

L. Doerflein, ORP v /

M. Kohl, DRP/

B. Boger, NRR  !

R. Wessman, NRR !

D. Mcdonald, NRR f

'

C. Warren, SRI -/ Pilgrim (with concurrences)

R. Bores, DRSS/ /

Management Meeting t'tendees (Sey' Enclosure 2) 7

DRP

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NUCLEAR REGULATORY COMMISSION

RE010Nl

ENCLOSURE 1

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,, . KING OF PAueSI A. PeNNBYLVANIA tedse

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VUL 271988

Docket No. 50-293

Boston Edison Company

ATTN: Mr. Ralph G. Bird

Senior Vice President - Nuclear

Pilgrim Huclear Power Station

RFD #1 Rocky Hill Road

Plymouth, Massachusetts 02 3

Gentlemen:

Subject: Systematic Assessment of Licensee Performance ($ ALP)

Board Report No. 50-293/87-99

Enclosed for your review, prior to our scheduled meeting of August 25, 1988,

is the SAlp Board Report for Pilgrim Nuclear Power Station covering the period

February 1, 1987 through May 15, 1988.

In accordance with NRC policy, I have reviewed the SALP Board Report and

concur with the assigned ratings. Highlights of the report are set forth below:

1. Category 1 performance rating was assigned to Engineering and

Technical Support which continued strong performance through the

assessment period.

2. Category 2 ratings were given in the functional areas of Surveillance,

Fire Protection, Security and Safeguards and Assurance of Quality

acknowledging Boston Edison Company's extensive efforts to upgrade

performance from the previously assigned Category 3 ratings.

3. Category 3 Improving rating was assigned to the Radiological

Controls functional area.

The assignment of the Category 3 improving rating indicates that improvement in

the organization, programs and performance were noted in the Radiological

Controls functional area. However, in our view, the results of these

initiatives were coming to fruition at the close of the assessment period, and

had not yet demonstrated the ability to sustain improved performance.

Additionally, on July 8, 1988, Region I advised you that Pilgrim remains

categorized by NRC Senior Management as a plant that requires continued close

monitoring and demonstration of programs which estabitsh and implement

performance improvements. This was done in conjuction with a letter from the

NRC's Executive Director for Operations to your Chief Executive Officer. We

, recognize the progress demonstrated to date as a result of your extensive

efforts, however, continuec' rig 11ance on your part is necessary to achieve and

sustain overall results. NRC will also continue its increased attention to

your facility. In this regard, we will conduct an assessment team inspection

to further measure the effectiveness and readiness of your management controls,

programs and personnel to support safe restart of the freility. Further, I

plan to shorten the current SALP assessment period to permit an additional

opportunity to measure the results of your programs.

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Boston Edison Company 2

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At the SALP management meeting, please be prepared to discuss your evaluation

of our as sessrnent and the status of your performance improvement programs.

Additionally, we solicit written comments within 30 days after the meeting to

enable. us to thoroughly evaluate your response and to provide you with our

conclusions relative to them. Specifically, you are requested to respond

addressing actions planned to continue to improve performance in the

Radiological Controls area.

Your cooperation with us is appreciated. Should you have any questions

concerning the SALP report, we would be pleased to discuss them with you.

Sincerely,

William T. Russell

Regional Administrator

Enclosure:

As stated

cc w/ enc 1:

K. Highfill, Station Director

R. Anderson, Plant Manager

J. Keyes, Licensing Division Manager

E. Robinson, Nuclear Information Manager

R. Swanson, Nuclear Engirieering Department Manager

The Honorable Edward J. Markey

The Honorable Edward P. Kirby

The Honorable Peter V. Forman

B. McIntyre, Chairman, Department of Public Utilities

Chairman, Plymouth Board of Selectmen

Chairman, Duxbury Board of Selectmen

Plymouth Civil Defense Director

P. Agnes, Assistant Secretary of Public Safety, Commonwealth of

Massachusetts

5. Pollard, Massachusetts Secretary of Energy Resources

R. Shinshak, MASSPIRG

Public Document Room (POR)

Local Pubite Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

Commonwealth of Massachusetts (2)

Chairman Zech

Commissioner Roberts

Commissioner Carr

Commissioner Rogers

K. Abraham, RI (18 copies)

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EtiCLOSURE 2

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ENCLOSURE

SALP BOARD REPORT

U. 5. NUCLEAR REGULATORY COMMIS$10N

REGION I

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

INSPECTION REPORT 50-293/87-99

BOSTON EDISON COMPANY

PILGRIM NUCLEAR POWER STATION

ASSESSMENT PERIOD: FEBRUARY 1, 1987 - MAY 15, 1988

BOARD MEETING DATE: JULY 5 and 6, 1988

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TABLE OF CONTENTS

Page

1.0 INTRODUCTION ............................................. 1

1,1 Purpose and Overview ................................ 1

1.2 SALP Board Members .................................. I

1.3 Background .......................................... 2

2.0 CRITERIA ................................................. 7

3.0 S UMMA RY O F R E S U LT S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

3.1 Overall Facility Evaluation . . . . . . . . . . . . . . . . . . . . . . . . 10

3.2 Facility Performance ............................... 12

4.0 PERFORKANCE ANALYSIS .................................... 13

4.1 Plant Operations ................................... 13

4.2 Radiological Controls .............................. 18

4.3 Maintenance and Modifications ...................... 24

4.4 Surveillance ....................................... 29

4.5 Fire Protection .................................... 33

4.6 Emergency Preparedness ............................. 36

4.7 Security and Safeguards ............................ 38

4.8 Engineering and Technical Support .................. 43

4.9 Licensing Activities ............................... 47

4.10 Training and Qualification Effectiveness ........... 50

4.11 Assurance of Quality ............................... 53

5.0 $UPPORTING DATA AND SUMMARIES ........................... 57

5.1 Investigation and Allegations Review ............... 57

5.2 Escalated Enforcement Actions ...................... 57

5.3 Management Conferences ............................. 58

5.4 Licensing Actions .................................. 59

5.5 Licensee Event Reports ............................. 63

.T.A8LE S

Table 1 - Tabular Listing of Licensee Event Reports by Functional Areas

Table 2 - Inspection Hours Summary

Table 3 - Enforcement Summary

Table 4 - P11gris SALP History Tabulation

Table 5 - Management Meeting and Plant Tour Summary

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1.0 INTRODUCTION

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1.1 Purpose and Overview

The Systematic Assessment of Licensee Performance (SALP) is an inte-

grated NRC staff effort to collect observations and data on a per-

iodic basis and to evaluate licensee performance. The SALP process

is supplemental to the normal regulatory processes used to ensure

compliance to NRC rules and regulations. It is intended to be suf-

ficiently diagnostic to provide a rational basis for allocating NRC

resources and to provide meaningful guidance to licensee management

in order to improve the quality and safety of plant operations.

An NRC SALP Board, composed of the Staff members listed in Section

1.2 below, met on July 5 and 6,1988 to review the collection of

performance observations and data in order to assess the Boston

l Ecison Cee:any's (BECo) performance at the Pilgrim Nuclear Power

Station. This assessment was conducted in accordance with the

guidarce in NRC Manual Chapter 0516 "Systematic Assessment of

Licensee Perforrance". A summary of the guidance and evaluation

criteria is provided in Section 2.0 of this report,

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This report is the SALP Board's assessment of the licensee's safety

performance at the Pilgrim Nuclear Power Station for the period

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February 1,1987 - May 15,1988 . The summary findings and totals

reflect a 15 month assessment period.

1.2 SALP Board Members

' Chairman

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S. J. Collins, Deputy Director, Division of Reactor Prcjects (ORP)

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Members

W. F. Kane, Director, ORP

J. T. Wiggins, Chief, Reactor Projects Branch 3, DRP

A. R. Blough, Chief, Reactor Projects Section 38, ORP

J. P. Durr, Chief Engineering Branch, Division of Reactor Safety (ORS)

Sjoblom, Acting Director, Division of Radiation Safety and

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Safeguards (DR55)

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R. R. Bellamy Chief, Facilities Radiological Safety and Safeguards

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Branch, DR55

D. H. Wessman, Director, Project Directorate I-3, Of fice of Nuclear

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ReactorRegulation(NRR)

D. G. Mcdonald, Licensing Project Manager, NRR

' C. C. Warren Senior Resident Inspector, Pilgris Nuclear Power

Station (PNPS), DRP

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Other Attendeet

J. J. Lyash, Resident Inspector, Pilgrim NPS, DRP

T. K. Kim, Resident Inspector, Pilgrim NPS, DRP i

T. F. Dragoun, Senior Radiation Specialist, DRSS

G. C. Smith, Safeguards Specialist, DRSS

R. M. Gallo, Chief, Operations Branch. ORS

A. G. Krasopoulis, Reactor Engineer, DRS

T. Koshy, Reactor Engineer, DRS l

1.3 Background

A. Licensee Activities

The plant has been shut down since April 12, 1986 for mainten-

ance and to make program irnprovements and remained shut down

throughout this assessment period, The reactor was defueled on

February 13, 1987, to facilitate extensive maintenance and

rnodi fication of plant equipment. The licensee completed fuel

reload on October 14, 1957. The reactor vessel hydrostatic test

and the containment integrated leak rate test were also com-

pleted successfully.

Since the end of the last SALP period there have continued to

be extensive management changes at Boston Edison that affect

Pilgrim. The licensee has aggressively recruited experienced

personnel from outside sources. A new Senior Vice President

assumed responsibility for the nuclear organization at the  ;

beginning of the period. The licensee's organizational struc-

ture was also significantly altered several times. Recent

changes have more clearly defined the permanent onsite organiza-

tional structure. Essentially all key sanagement positions had

been filled with permanent employees by the close of the period.

The licensee developed several integrated action and testing

plans to evaluate the readiness of plant management, staff and (

hardware to support restart. These include the Restart Plan,

Material Condition Improvement Action Plan, Radiological Action t

Plan and Power Ascension Test Program. In addition, the licen- l

see performed a self assessment near the end of the SALP period i

to identify plant issues and evaluate the effectiveness of  !

implemented improvement actions.

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During the assessment period the licensee completed extensive

plant hardware and procedure modifications. The licensee's

Safety Enhancement Program included addition of a third emerg-

ency diesel generator, containment spray header nozzle changes,

installation of a backup nitrogen supply system, and additional

protection features for anticipated transient without scram.

Steps were also taken toward installation of a direct torus vent

system and installation of a diesel driven fire pump tied to the

residual heat removal system. License exemptions and modi-

fications to the fire protection program and equipment to bring

the plant into full compliance with 10 CFR 50 Appendix R, and to

improve reactor level instrunntation were completed. The

facility Emergency Operating Procedures were also upgraded to

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incorporate Revision 4 of the Boiling Water Reactor Owners Group

Emergency Procedures Guidelines.

On March 31, 1957, the station experienced a loss of offsite

power during a storm when a static line broke and fell onto the

conductors at a location several miles from the site. Offsite

power was restored within 45 minutes. A second loss of offsite

power event occurred on November 12, 1987 due to excessive ice

and snow accumulation on the transmission system during a severe

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winter storm. This event was complicated by a lockout of the

' plant startup transformer, the removal of one of the

emergency diesel generators from service due to maintenance

concerns and the limited availability of instrument air. A

source of of f site power was reestablished about 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> af ter

the initial loss. An NRC Augmented Inspection Team was

dispatched to the site in response to this event.

On November 9, 1987, the licensee as a conservative measure

halted ongoing mat'ntenance and modification work at the ststion

af ter determining that several incidents which occurred during

the weekend of November 7 and 8, 1987, raised concerns regarding

the control of ongoing work activities. The licensee's Senior

Vice President-Nuclear directed that ongoing maintenance and

modification work onsite be suspended, and contractor craft

personnel were instructed to leave the site and were directed

not to report for work until November 12, 1987. The licensee  !

subsequently formed eight teams of engineering and management

personnel to perform detailed evaluations of each incident prior

to resuming station work activities.

On February 11, 1988, the control r:oa received a report of a

fire in a contaminated area of the machine shop. The licensee

conservatively declared an unusual Event. The fire was confined

to a small area and was identified as burning insulation from a

heat-treating nachine which was being used in the machine shop.

The fire was extinguished by the plant fire brigade with no

plant damage noted, and the Unusual Event was secured.

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Operator licensing examinations were conducted on two occasions

during the period. A total of two senior reactor operators and

14 reactor operator candidates were examined with all candidates

successfully completing the examinations.

In December 1986, the Secretary of Public !.afety for the Common-

wealth of Massachusetts (Charles V. Barry) 56bmitted a report to

Governor Dukakis assessing the status of offsite emergency pre-

paredness for the Pilgrim station. The report identified

several problems with the existing response program. FEMA per-

formed a self-initiated review of the Pilgrim emergency response

plan and on August 5,1987, provided its report to the Commen-

wealth. FEMA identified six deficient areas and withdrew its

1iterim finding that Massachusetti of f site emergency planning

ind preparedness were adequate to protect the public health and

safety in the event of an accident at Pilgrim. The NRC reques-

ted the licensee to provide its plans and schedule for working

with state and local organi:atiens to resolve the deficiencies.

The licensee submitted an action plan to address the deficien-

cies on September 17, 1957. A progress report issued

October 15, 1957 by Charles V. Barry notes that, while substan-

tial progress had been made in some areas, adequate plans for

response to an accident at Pilgrim did not exist and substantial

work remained to be done. At the close of the assessment

period, the licensee was actively working with the Commonwealth

and local agencies to address the deficiencies and upgrade the

emergency plans.

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B. Inspection Activities

Confirmatory Action Letter (CAL) 86-10 was issued in April,1986 '

in response to a series of operational events. The CAL

initially required that the licensee address these events, and

was subsequently extended in August, 1986 to include resolution i

of programmatic and management concerns. In addition the CAL

stated that the NRC Regional Administrator's approval would be l

required prior to restart. The CAL remained in ef fect through- ,

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out this assessment period.

Considerable inspection resources were expends 1 at Pilgrim dur-  !

ing this assessment period. The resident staff has been main-

tained at three inspectors. During the fif teen month assessment ,

period, over 9698 hours0.112 days <br />2.694 hours <br />0.016 weeks <br />0.00369 months <br /> of direct NRC inspection were performed

(7758 hours0.0898 days <br />2.155 hours <br />0.0128 weeks <br />0.00295 months <br /> on an annual basis). This vepresents a 43 percent

increase above the previous assessment period, and is signifi- ,

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cantly in excess of that normally allocated to a single unit i

site. A detailed breakdown of the total inspection hours into

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SALP functional areas is included in Table 2.

Senior NRC management involvement was substantial during the

period. Early in the assessment period, a Ptigrim Restart

Assessment Panel was formed which consists of senior management

from the NRC Office of Nuclear Reactor Regulation (NRR) and

Region I. The panel generally meets biweekly to coordinate the  ;

planning and execution of NRC activities, and to assess the

results of these activities to provide an independent judgement ,

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of the plants readiness for operation. A Series of management

' meetings to discuss the licensee's progress and proposed pro-

4 grams were also held. Frequent site tours by NRC Commissioners, ,

the Director of Nuclear Reactor Regulation and the Regional l

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Administrator were conducted. NRC senior management partici-  !

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pated in numerous public meetings and interacted extensively [

with local, state and federal officials. The NRC conducted

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public meetings in Plymouth to receive public comments on the

plan. The staff's assessment of the coseents and concerns ,

received on the Restart Plan was presented to the public during l

a followup public meeting. A chronological listing of manage-

ment meetings and tours is included as Table 5. f

On July 15, 1986, Massachusetts 5 tate Senator Williaa 5. Golden f

and others filed a 10 CFR 2.206 petition regarding Ptigrim.  ;

Af ter review by the NRC, the contentions raised in the petition l

regarding containment deficiencies and inadequacies in the

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radiological emergency response plan were denied. A decision i

i regarding the management deficiencies was deferred to a subse- ,

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quent response. This information was transmitted to the peti-

tioners by letter dated August 21, 1987. Three of the ;

petitioners filed an appeal in federal court on October 1, 1987. ;

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On October 15, 1987 Massachusetts Attorney General

James M. Shanr.on filed a 10 CFR 2.206 petition, on behalf of his

of fice and Governor Michael S. Dukakis, requesting an order to

show cause why Pilgrim should not remain shutdown untti a full

adjudicatory hearing resolves the issues raised in the petition.

The petition cites evidence of continuing managertal, Mark I

containment, and emergency planning deficiencies and requests

that the licensee also be required to perform a probabilistic

risk assessment (PRA). In a response dated May 27, 1988, the

NRC denied the petitioners request that a PRA regarding the Mark

I containment be required and deferred decisions regarding

emergency planning and management issues.

During the assessment period nine NRC team inspections were

conducted:

1. Appendix R Fire Protection Program Review

2. Plant Modification Program Review

3. Plant Effluent and Environmental Monitoring Program Review

4. Augmented Inspection Team (AIT) Review of the loss of of f-

site power event on November 12, 1987

5. Annual Emergency Plan Exercise Observation

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Onsite Electrical Distribution Adequacy Review

7. Emergency Operating Procedures Review

8. Maintenance Program Review

9. In plant Radiological Controls Review

An NRC Order issued in 1984 requiring the licensee to implement

a Radiation Improvement Program was closed during the period

based on the results of a special inspection and other program

inspections which indicated that all terms of the Order h.d been

satisf actorily r.oepleted. Two operator licensing examinations

were also conducted. An enforcement conference was held on

September 9, 1987 to discuss security related matters. Enforce-

ment action on these issues is still pending.

Tabulations of inspection activities and associated enforcement

actions are contained in Tables 2 and 3.

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2.0 CRITERIA l

Licensee performance is assessed in selected functional areas, depending

upon whether the f acility is in a construction, preoperational, or opera-

ting phase. Functional areas normally represent areas significant to

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nuclear safety and the environment. Some functional areas may not be

assessed because of little or no licensee activities, or lack of meaning-

ful observations. Special areas may be added to highlight significant

observations. t

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This report also discusses "Training and Qualification Effectiveness",

"Assurance of Quality" and "Engineer:ng and Technical Support" as separate  ;

functional areas. Although these topics, in themselves, are assessed in i

the other functional areas through their use as criteria, the three areas  ;

provide a synopsis. For example, assurance of quality effectiveness has  ;

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been assessed on a day-to-day basis by res' dent inspectors and is an  ;

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integral aspect of specialist inspections. M, ',o r factors that influence  ;

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quality, such as involverent of first line /up, rvision, safety committees, t

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Quality assurance, and worker attitudes, are discussed in each area. l

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4 One or more of the following eva$uation critiria were used to assess each  !

functional area. 2

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j 1. Management involvement and control in anuring quality l

2. Approach to the eenh*.1on of tecimical issues from a safety stand- i

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4. Enforcement history

) 5. Operational events (including response to, analyses of, and corree- ,

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tive actions for)

6. Staffing (includingmanagement) (

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7. Training and Qualification Effectiveness i

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Based upon the SALP Board assessment, each functional area evaluated is

1 classified into one of three performance categories. The definitiont f

these performance categories are:

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Category 1. Licensee msna gement u n t i ;a ' a.id involvement are

readily evident and place on hasis .m up  :,r performance of nuclear

safety or safeguards activ 'ies, wis' .h, resulting performance sub-

stantially exceeding regulatiry requirements. Licensee resources are

ample and ef fectively used so +. hat a high level of plant and person- ,

r.el performance is being achioed. Reduced NRC attention may be i

appropriate, (

Category 2. Licensee management attent i on to and involvement in the

performance of nuclear safety or safeguards activities are good. The

licensee has attained a level of performaree above that needed to

meet regulatory requirements. Licensee rescui es are adequate and '

reasonably allocated so that good plant and personi *) performance is

being achieved. NRC attention may be maintained at normal levels.

Category 3. Licensee rnaragement attention to and involveme,9 in the  !

performance of nuclear safety or safeguards activities are no; suf-

ficient. The licensee's performance does not significantly exued

that needed to eeet minimal regulatory requirements. Licenses [

resources appear to be strained or not effectively used. NRC atten-

i tion should be increased above normal levels,

l The SALP Board also assesses a functional area to compare the licen-

see's performance during the last quarter of the assessment period to

that during the entire period in order to determine the recent trend

for each functional area. The 3 ALP trend categories are as follows:

Improving: Licensee performance was determined to be improving near  !

1 the close of the assessment period.

,

Declining: Licensee perforrnance was determined to be declining near

tne close of the assessment period and the licensee had not taken  ;

meaningful steps to address this pattern. ,

A trend is assigned only when, in the opinion of the SALP Board, the ,

trend is significant enough to be considered indicative of a likely l

change in the performance category in the near future. For example, [

,

a classification of "Category 2, Improving" indicates the clear t

potential for "Ca tegory 1" performance in the next 5 ALP period.  !

, It should be noted that Category 3 perforvance, the lowsst Category, [

t

represents acceptable, although minimally adequate, safety perform-

ance. If at any time, the NRC concluded that a licensee was not '

achieving an adequate level of safety performance, it would then be

'

incumbent upon NRC to promptly take appropriate action in the l

interest of public health and safety. Such ,satters would be dealt i

'

with independently from, and on a more urgent schedule than, the $ ALP ,

,

process. l

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__

__ ___

_ . _ _ _

_ _ _ _ _ _ _ _ _ __ . _ _ _ ____

,

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It should also be noted that the industry continues to be subject to

rising performance expectations. For example NRC expects licensees

to actively use industry-wide and plant-specific operating experience

' to ef fect performance improvement. Thus, a licensee's safety per-

formance would be expected to show improvement over the years in

order to maintain consistent 5A1.P ratings.

!

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- _ _ _ _ . _ _ - . _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ . _ _ . . _ _ _ .

_ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . -

.

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3,0 $UWARY

!

3.1 Overall Facility Evaluation l

The 1985 SALP determined that programmatic and performance weaknesses  !

existed in several functional areas and that improvements were in-  !

hibited by the lack of resolution of factors which in turn depended  ;

heavily on management attitudes and aggrei,siveness of followup.

,

The 1986 $ ALP acknowledged that, although some improvements were ,

made, the lack of a clear organizational structure, recurring  !

management changes, and chronic staffing vacancies delayed the  !

establishment of a stable licensee management team at the plant and

inhibited progress during the period. These problems manifested

themselves 45 Category 3 performance ratings in the Radiological r

Controls, Surveillance, Fire Protection, Security and Assurance of *

Cwality furctioral areas.  !

l

Throughout this 1987-1988 $l 5 period the facility was mair.tained by

i i

EECO in an outage condition to make marr plant f acility modifica-

tions and complete a major equipment refurbishment program.

At the beginning of the assessment period the licensee made the most

significant of numerous personnel changes when a new Senior Vice

president-Nuclear was hired and his presence established on site.

Additional personnel and organizational changes continued throughout

the assessment period with the most substantial reorganization being  ;

completed in February, 1988. Although the organization in its  ;

present form did not formally emerge until late in the assessment

period, many of the functional reporting chains have been in place [

for some time and appear to be functioning well. Allocated staffing

levels in the new organization are significantly higher than in the  ;

past and the licensee has been generally successful in recruiting

efforts. As a result of these transitions some individuals are

relatively new to their positions and in some cases do not have L

extensive operating Boiling Water Reactor espertise, i

The licensee has been aggressive in addressing most areas of known

program weakness. However, implemntation of certain program and i

organizational improveMnts was delayed due to the high priority  ;

placed on proceeding with outage work. Surveillance program  ;

responsibilities have been consolidated in the Systems Engineering l

Group and program weaknesses have been addressed. Hardware issues in l

both the fire protection and security areas have been corrected and  ;

performance in these areas has .eproved. Health Physics program  ;

problems identified in the preytcus $ Alp report continued to entst L

during the first half of this assessment period, however recent j

significant management attention and resource commitment to this area ,

led to improved performance over the last part of the assessment  ;

period. Maintenance program 1sprovements were implemented only l

!

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- , . , - _ - , . - - - - - . _ _ _ - ~ _ . , - . . -

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

.- 11

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recently and their effectiveness remains under review, Licensee

development of the Material Condition Improvement Action Plan,

Restart plan and performance of an extensive self assessment in

response to the NRC August 1986 Confirmatory Action letter are

evidence of the licensee s ability to self-identify and understand

facility performance and material condition. The action plans to

implement these necessary improvements and management's ability to

effect lasting performance change remained under review at the close

of the assessment period.

In sumary, licensee efforts have been extensive including corporate

and site reorganizations and a new management team which has

undertaken numerous projects and programs to improve plant material ,

condition and enhance programmatic performance, Management

initiatives have been generally successful in correcting staffing,

organization and material ceficiencies. Programmatic performance

irceove ents have been evident in areas of previously identified

sigetficant weakness and the licensee's self assessrent process has

icentifisc areas where further management attention is warranted.

In light of the past ina'oility to implement lasting programs which

result in long term improvements, a continued licensee management

ecmmit ert is needec to confirm that past weakness have been

icentified and sustain the overall improving trend in performance,

_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _

.

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3.2 F,cility

a Performance

'

Functional Category Category Recent

Area Last Period * This Period ** Trend

i

1. Plar.t '1perations 2 2

2. Radiological 3 3 Improving

Controls  ;

'

3. Maintenance and 2 2

Modifications

4. Surveillance 3 2

,

5. Fire Protection 3 2

6. Emergency 2 2 Improving !

Preparedness  !

>

7. Security and 3 2

Safeguards ,

8. Engineering and 1 1 l

Technical Support  ;

9. Licensing 2 2 l

Activities r

10. Training and 2 2 I

Qualification

j Effectiveness  ;

I

11. Assurance of 3 2 [

l Quality

'"  :

Outage Management 1

!

and Modifications

Activities

• Noveeber 1,1945 to January 31, 1987

" February 1, 1987 to May 15, 1968 t

'" Not evaluated as a separate functional area; findings relative to outage ,

activities are integrated into "Engineering and Technical support , l

' Maintenance and Modifications", and other functional areas as appropriatt ,

f

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4.0 PERFOR m CE A ulYSIS

4.1 Plant Operations (2178 hours0.0252 days <br />0.605 hours <br />0.0036 weeks <br />8.28729e-4 months <br /> /22 percent)

(1) Analysis

This functional aren -

tended to assess the licensee's per-

formance of plant op, ' iu , Throughout this assessment period i

the plant was in an exteno.d eatntenance and refueling outage.

NRC observations of licensee performance during major plant

activities included reactor core defuel an1 reload, the reactor

vessel hydrostatic test, and the primary containment integrated

leak rate test.

During the previous 5 ALP ;eriod plant operations was assessed as

a Categcry 2. Weaknesses identified included a shortage of

licenste reactor crerators and lack of professional support for

tne Operations Department. Although the licensee had taken

actions to recruit new operators and improve the licensed oper- ,

ator training program, the shortage of licensed reactor neera-

tors (Ros) remained a significant problem. The effectiveness in

professional staff support for the Operations Department sas

also not demonstrated due to delays in transferring personnel

into the depsrtment, and their continuing collateral duties

outside the d0partment.

'

Ouring the current assement period, the Itcensee's plan taj g

and evaluation of their readiness for refueling, the ructor

l ,

vessel hydrostatic test, and the primary containment integrated I

l

1eak rate test were well managed. Strong Operations Department

involvement was evident. Plant management and the Operations

Review Comit, tee (ORC) exhibited a r.onservative, Safety con- <

,

scious approach to these milestones. ORC review of refueling

readiness was conducted in a thorough and deliberate manner

including line item verification of the reload checklist. One

exception was the licensae's use of Appendix G to the Final

Safety Analysis Report to justify conditional operabtitty of

equipeent needed for refueling. In this case plant management

,

proposed to begin fuel movement with a 5tandby Gas Treatment

i System design deficiency uncorrected, by preparing an analysis

supporting f perability of the system under restricted condi-

tions. Licensee meegement however, reconsidered this practice

what. oncerns werf. tised by the NRC. Licensee senior manage-

ment support for ORC decisions was visible throughout these

major activities. 5entor manageout's presence and di rect

involvecent in actsvities also demonstrr.ted their ccanitment to

safety and expectations of high standards to the plant staff.

1

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The licensee has taken aggressive actions to resolve the short-

age of licensed operators. Improvements in recruiting and oper-

ator training programs have resulted in a significant increase

in the size of the operations staff. The number of licensed

reactor operators (R0s) increased by 14 during the period to the

present total af 23. This contributed to a reduction in routine

operator overtime, which had been a chronic past problem. The

addition of new licenses to the operations staff is positive.

Hc 9r, additional operating experience will be required before

tb newly licensed personnel are fully qualified. The high RO

attrition rate was a major f actor in the RO shortage during the

last assessment teriod. Increased management attention, reduced

overtime, and higher morale have contributed to maintaining a

stable operations organization during this period. The licensee

cu.rently maintains a staff of 20 equipment operators and eight

of the 20 are schedu'.ed to enter a reactor operator license

training class later this year. Continued management support in

maintaining a sound and aggressive recruiting and training pro-

gram is required to prevent the recurrence of the operator

shortage.

Despite the improvements in the staffing level, weaknesses con-

tinued to exist in attention to detail and in communications.

Several procedural and personnel errors occurred during the

refueling, the reactor vessel hydrostatic test, and the contain-

ment integrated leak rate test. Immediate actions taken by the

operations staf f in response to incidents were not always con-

servative. For example, operators continued refueling without

stopping to assess a pendant light which was inadvertently

dropped onto the reactor core. Problems in the operations area

that contributed to the licensee's work stoppage on November 9,

1987 included inadequate system turnover, valve lineup problems,

and poet radwaste system operation practices. Some weakness in

coordination and communications between the operations staff and

other groups was noted during the loss of offsite power (LOOP)

event on November 11, 1987. The lack of clear management

directions both in and out of the control room, a somewhat frag-

mented recovery effort, and poor communications may have d9 layed

the full recovery from the LOOP and resulted in inadvertent

manual shutdown of one of the estrgency diesel generators. As a

further example, operato' comeunication during a dry run of the

!

remote shutdown test wo also informal and not completely

effective.

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' 15

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During previous assessments, informality and poor attitude had

been identified as a weakness among the control room staff. The

discovery by the licensee of non-job related reading materitl

and a card playing machine in the control room in October, 1987

was a further exarople of the lack of professionalism and implied

inattentiveness to duty. As a result of management attention to

this issue, positive trends in the control room atmosphere and

conduct were noted during the last quarter of the assessment

period. The significant increase in the size of the operations

staf f, strict control of operator nyertime, and intensive com-

munication training also aided licensee management's successful

effort to improve operator professionalism. As an example,

ef factive use of the simulator for training and implementation

- of control room hardware improvements have enhanced the control

room atmosphere.

Significant effort has been made by the licensen to provide

adequate support staff in the Operations Department. The

department was reorganized and the Operations Support Group was

created to strengthen effectiveness in identifying and resolving

technical issues affecting Operations. The Operations Support

Group consists of three staff engineers and six shift technical

j advisor (STA) positions. The licensee has filled the group

manager and senior staff engineer positions and is actively

recruiting to fill the other staff engineer positions. Three

additional STAS were hired and trained during this period which

increased the total number of qualified STAS to six. This

represents an increase of six in the allocated operations sup-

port staff with four of the positions filled. The reorganiza-

tion allowed the Chief Operating Engineer added opportunity to

directly oversee operator performance. Operations staff

involvement in developing and implementing the Emergency Opera-

ting Procedures was strong. The licensee's ongoing effort to

develop a jumper and lifted lead log and a limiting cordition of

I operation log are additional indications of improving sta'f

support in tFe Operations Department.

l

The licensee's approach to problem investigation and root cause

analysis improved significantly during the latter portion of the

j

-

period. Event critiques led by the Operations Section Manager

ar j root cause analyses performed by the onsite Systems Engi-

neering Group were thorough and aggressive. The critique pro-

cess also instilled a leadership role for the Operations

i

Department and promoted better communication among interdepart-

l

mental groups.

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.

The operator training program continued to improve during this '

assessment period. NRC operator license exan.! nation s on

May 25, 1987 and December 7,1987 had a 100 percent pass rate.  !

Utilization of the plant specific simulator in requalification

training and the new Emergency Operating Procedure training

significantly enhanced the effectiveness of the training pro-

gram. The licensee's effort to develop and implement the new

Emergency Operating Procedures demonstrated high levels of

senior management attention.

Reportable events were generally handled acceptably by the con-

trol room staff. The levels of detail, technical accuracy, and

the overall quality of liceasee event reports have improved

during the period.

Monitoring and maintenance of plant chemistry is the responsi-

bility of the Operations Department. The licensee's chemistry

department is responsible for plant chemistry, radiochemistry,

and the facility radiological effluents control program. The

chemistry organization was clearly defined, adequately staffed,

and appeared to interface well with other plant groups including

the radwaste organization. Chemistry representatives are

included in shiftly turnovers with the control room staff.

Importent plant chemistry parameters are discussed with station

management daily at a morning planning meeting. Surveillance

requirements were clearly established and performed on schedule.

The licensee is meeting Technical Specification requirements for

radiological effleunt sampling and analysis. Effluent control

instrumentation was maintained and calibrations performed in

accordance with regulatory requirements. All release records

were complete and well maintained. QA audits of this area were

comprehensive and technically thorough.

The results comparison of NRC radioactivity standards submitted

to the licensee for analyses irdicated excellent performance by

the licensee with all results in agreement. During the analysis

of the NRC radioactivity standards, the licensee's chemistry

staff demonstrated a clear understanding of the technical

issues. In addition, the licensee was responsive to NRL sups

gested practices for program improvements. The licensee

chemical measurement capability was also evaluated twice during

the assessment period. The results of the NRC chemical stand-

ards indicated good performance with only four of 54 measure-

ments in disagreement. The licensee was responsive to NRC sug-

gestions for program improvements in this area and also in the

area of post accident sample analyses. Licensee management

appears comitted to providing adequate capital resources to the

.

." 17

.

Chemistry Department. The licensee possesses state of the art

chemical and radiochemical laboratory instrumentation, and also

maintains a state of the art chemistry computer data base for

maintaining and trending laboratory data. The licensee's chem-

istry training program was also reviewed this assessment period.

Both the training and retraining programs appear to be adequate

as indicated by the results of the NRC standards analyses.

In summary, the licensee's aggressive recruiting and training

program has resulted in a significant increase in the size and

effectiveness of the Operations Department staff, the staffing

improvement, strict control of operator overtime, appropriate

management attention, and intensive communications training all

have costributed to a recent trend in positive attitude and -

professional atmosphere in the control room. However, some

weakness in attention to detail and procedural compliance were

noted and require continued attention. The licensee's approach

to problem investigation and root cause analyses has improved,

and is generally prompt and positive. Overall performance in

this functional area has improved, particularly during the last

quarter of the assessment period.

(2) Conclusion

Rating: 2

Trend: None Assigned

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4.2 Radiological Controls (1064 hours0.0123 days <br />0.296 hours <br />0.00176 weeks <br />4.04852e-4 months <br /> /12 percent)

(1) Analysis

The radiological controls functional area is an assessment of

licensee performance in implementing the occupational radiation

safety, chemistry, radiological environmental monitoring and

transportation programs. In November 1984, the NRC issued a

confirmatory order requiring broad scope improveidents in the

licensee's Radiological Controls Program. During the previous

assessment period this area was rated Category 3. The NRC

review found that some improvement had been made in the

radiation safety program. However, significant weaknesses were

identified which inhibited further performance improvement.

These weaknesses included poor communications, antagonistic

working relationships, lack of personnel accountability, poor

ALARA performance, ineffective corrective actions, and vacancies

in key radiological safety supervisory and management positions.

As a result of these weaknesses the NRC confirmatory order was

not closed out. Weaknesses were also identified in implementa-

tion of Radiological Effluent Technical Specification sur-

ve111ance requirements and the licensee's environmental TLD

program. During the previous assessment period, the licensee's

transportation program exhibited a decline in performance with

three violations being identified.

During the current essessment period there were nine inspections

in this area of the occupational radiation safety program. The

inspections focused on oversight of outage work, establishment

of effective management controls for this area and efforts to ,

close out the NRC Confirmatory Order and associated Radiological

Improvement Plan (RIP). In addition, three inspections were

performed in the chemistry, transportation, and radwaste systems

areas.

Radiation Protection .

The weaknesses noted during the previous assessment period per-

sisted through the first half of this assessment period. How-

ever, in November, 1987 an inspection found that performance had ,

improved to the point that the November 1984 NRC Confirmatory

I Order was closed out but, at the same time, acknowledged that

adGtional improvements and continued management attention to

l these areas were needed. Actions that are planned by the

licensee to continue to improve performance such as improved l

radiological awareness and increased staffing are documented in

the licensee's Radiological Action Plan (RAP).  ;

Toward the end of this period, the Radiation Protection program

organization and staffing levels, a weakness during most of the

assessment, improved. The organization, staf fing levels, re-

, i

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l

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sponsibilities, accountabilities, and interfaces are now well

defined. Station management attention to the areas of communi-

cations, accountability, morale and the corrective action pro-

cess over the last half of the period has improved working re-

lationships and communications between other departments and l

radiation protection.

recently revised Radiation Protection organization is

<

The

approximately 90% filled by permanent personnel. Although the

organization and staffing are adequate to support the program,

the position of Chief Radiological Engineer (Radiation Protec-

tion Manager) was recently restaffed with a contractor, several l

managers have limited commercial nuclear power experience, and  !

many personnel are new to their positions. Performance of this

'

new organization will continue to be assessed in the future.

A well defined training and qualification program has been

-

established. The program contributes to an adequate understand-

ing of program requirements with few personnel errors. Training

resources are adequate. The radiation protection training

program is INPO certified. New training initiatives are in

progress to sensitize management, workers and radiation pro-

tection personnel to assure they are aware of the need to

minimize ali occupational radiation exposure. Examples include

' training of management on ALARA for plant design changes and

providing radiation awareness training to maintenance and

operations personnel.

Licensee audits and assessments of program implementation and

-

adequacy havs improved. The audits and assessments, augmented

'

by supervisory and management tours, have been generally ade-

quate in followinq program implementation and identifying weak-

nesses, particularly toward the end of the period. Technical

-

specialiats are used to augment the QA audit teams. Additional

! QC surveillance of problem areas (e.g., High Radiation Area key

control) W been impioented. However the scope of licensee

audits have been principally compliance oriented. There is

little external review of program adequacy and performance

i relative to the industry.

i

l

In the area of Internal Exposure Controls, no significant indi-

l

vidual exposure of personnel during the period was identified.

Also, during the major plant decontamination operation, exposure

of workers to airborne radioactive material was well controlled.

Approximately 90% of the station is now access.ible in street

clothes. Licensee quantification of radionuclides contained in

.

1

the NRC whole body counting phantom was good. The use of

,

!

sensitive whole body counting equipment combined with a

capability to analyze the data reflects an adequate bioassay

capability. Although performance in the area of Internal

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Exposure Controls b=. improved, NRC review identified instances

where about 1000 individuals had terminated from the site during

the period without receiving confirmatory whole body counts.

These termination body counts are not required by the NRC but

are a normal good practice at most reactor sites and are

recommended by Pilgrim site procedures. When brought to the

licensee's attention they were unaware of the magnitude of these

exceptions to the recomme "d practice, reflecting ,some

weaknesses in oversight of th area.

During the assessment period three violations occurred which

involved improper control of High Radiation Areas. Although no

unplanned exposures resulted, when examined individually, these

violations clearly reflect one or more of the previous

assessment period concerns. In response. the licensee made

certain short term corrective actions and established a task

force to review the concerns and develop long term corrective

actions. The licensee corrective actions for the most recent

High Radiation Area access control concerns were a pp rop ri ate ',

however, these corrective actions were prescribed by memorandum.

The NRC has previously expressed conctrn regarding imple-

mentation of regulatory requirements by memoranda rather than by

the use of formal, approved plant procedures. At the end of the

assessment period, procedures were not yet revised to include

these corrective actions. An additional weakness involved

licensee attempts to resolve a concern with exposure reports in

that, early in the period, NRC identified that the licensee had

not sent a number of termination reports to individuals. The

licensee instituted a corrective action program, but this matter

is still under NRC review.

During the latter part of the assessment period, control, over-

sight and coordination of in-plant activities by the radiation

protection department had significantly improved. The number of

licensee technicians and first line supervisors was increased.

Coincident with this staffing increase, licensee management

selectively reduced contractor work force, keeping the most

competent performers. The augmentation of first line super-

visors combined with the elimination of a large number of con-

tract technicians resulted in improved management control and

accountability within the department.

In the area of radiation exposure, Pilgrim Station collective

l worker doses, calculated as 5 year rolling averages, have his-

! torically been among the highest in the nation. Some improve-

ment was noted in the previots assessment period after a well

l documented Al. ARA program was instituted Accompanied by a high

visibility exp7sure goals program, l.icensee activities during

i

' this period resulted in a collective worker dose (1580 person-

rem) which was the highest of all domestic power reactors in

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1987. Analysis by station management attributes the exposures

to an expanded work scope during the prolon.ged outage with about

20% due to unplanned rework, poor contamination controls, and

poor planning. Also, the large number of workers (about 2000)

on site during the outage coupled with the high radiation source

terms and poor work habits in th,* plant contributed to the high

annual dose. During the initial part of this assessment period,

'

NRC concerns included lack of understanding of day-tc-day work

activities due to poor maintenance planning and inac: urate

description of work provided to radiation protection personnel

which is incorporated into RWPs. Al so, RWP s continued to be

requested for work that was not pe rformed. Improve-

ments in this area were noted during the latter half of this

. assessment period.

Management efforts instituted to control exposure included hir-

ing a large contractor staff to implement ALARA on the job,

assigning six HP/ AURA coordinators to work groups, and imple-

mentation of dose saving techniques recommended by the ALARA

Committee. The effectiveness of the six coordinators was par-

ticularly evident in the areas of maintenance and operations.

For example, the use of glove bags to contain contamination dur-

ing maintenance has been expanded. Contamination "spill drills"

are routinely conducted to prepare operations personnel for

dealing with future incidents so that the spread of contamina-

tion can be minimized.

NRC review of the selected ALARA goals indicated that they ap-

peared to not be challenging and there was no formal mechanism

to incorporate ALARA pHnciples during the design of plant

modifications. For examp.1, during the outage the licensee was

noted to have rebuilt a number of large valves (e.g. , RHR

System) without considering the need to reduce stellite, a major

source of cobalt. During the latter part of the assessment

period, the licensee was attempting to formalize a program to

,

l

conduct ALARA reviews of plant design modifications during the

l conceptual design phase. A goal of 600 person-rem was initially .

'

'

planned for 1988 even though most of the outage work ended in

February and a lower goal appeared achievable based upon

, anticipated radiological work. In addition, there was no long  ;

!

' ' range planning evident to reduce the high general area dose l

rates at the station.

l Radiological Environmental Monitoring Program

Midway through this assessment period an inspection of the

,

licensee's radiological environmental monitoring program (REMP)

was conducted. The REMP is administered by the corporate

Radiological Engineering Group. The licensee's REMP conforms ,

-

l to Technical Specification requirements. The licensee has made

plans for improvement of the annual REMP reports, and improve-

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ments to the meteorological monitoring program even though the ,

licensee's Technical Specifications contain no requirements in I

this area. In response to a program weaknesses identified by

the NRC during the last assessment period, the licensee has

eliminated the environmental thermoluminescent dosimeters TLD

system which was in use during tha previous assessment period

and is now using TLDs supplied by the Yankee Atomic Environ-

mental Laboratory. Planned personnel expansion in this area is

indicative of the licensee's commitment to continued improvement

of the REMP.

Transportation

One inspection of the licensee's transportation program was

conducted midway through this assessment period. Two Severity

Level IV violations were identified. Both violations related

to shipments made during the previous assessment period. These

violations suggested inattention to technical detail and quality

control in the preparation of radioactive shipment records.

However, during this assessment pJriod the licensee increased

quality control involvement in processing, preparation, pack-

aging and shipping of solid radioactive waste. This indicated

the licensee's clear understanding of issues relating to causes

of the problems and, in addition, the implementation of cor-

rective action. The licensee is meeting all commitments to the

NRC with regard to training in this area. The licensee has

implemented procedures which clearly define the roles of the

departments involved in solid radwaste and transportation.

Procedures for processing, preparation, packaging, and shipping

solid radwaste were adequate.

Summary

,

in summary, there was an overall improvement in licensee Radia-

. von Protection Program adequacy and performance, particularly l

during the last quarter of the assessment period. However man-

agement attention is still required to exceed minimum regulatory

requirements in the in plant radiation protection program. Com-

munications and working relationships have improved. Facilities

and equipment have been upgraded. Limited success in 1)

upgrading the ALARA Program performance, 2) staff qualifications

i and stability, and 3) aggressive long term corrective actions

for High Radiation Area access control were noted.

'

In contrast, licensee performance in the areas of REMP and

transportation reflects substantial improvement. These areas,

,

'

if rated separately, would receive the highest performance

rating category. Previous weaknesses regarding radiological

i

effluent technical specification surveillance and the environ-

cental TLD program have been corrected and plans made for ad-

ditional program improvements. The station has substantially

upgraded quality control activities in the transportation area.

. _ . _ _ _ _ _____ - -- _-

. _ - - - _ _ _ _ .

.

-* 23

-

.

(2) Conclusion

Rating: 3.

Trend: Improving.

(3) Recommendations

Licensee: 1. Continue strong senior management involvement in

the in plant radiation protection program.

,

2. Strengthen the ALARA program and complete

training on program implementation. -

!

NRC: 1. Conduct a management meeting with the licensee [

-

to review radiological program status and ALARA i

program progress.

I

I

f

!

'

l

l

!

t

l

. _ _ _ _ . , _ _ _ . . _ , , . _ _ _ _ . _ , _ . . _ _ _ _ . _ _ _ _ _ _ . . _ __ _ _ ,

. _ - - . , _ . . . . _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _

. _. ___ __ _ . -

,

,

,

24

.-

4.3 Maintenance and Modifications (2347 Hours /24 percent) ,

,

(1) Analysis

,

This functional area is intended to assess the licensee's per-

formance in planning and implementing the station maintenance

program, and in implementing and testing plant modifications.

The adequacy of modification design is evaluated under the

Engineering and Technical Support functional area. This SALP i

'

period includes the results of the April 25 - May 5,1988 NRC

Maintenance Team Inspection. It does not include evaluation of

the licensee's Restart Readiness Self Assessment, nor does it -

evaluate the licensee's response to the Maintenance Team Inspec-

tion findings.  ;

During the previous SALP period, plant maintenance performance

was assessed as a Category 2. Maintenance staffing was weak -

'

due to first line supervisory vacancies and lack of direct pro-

fessional support, hampering programmatic improvements. The

scheduling of "A" priority maintenance was ecod, however lower

priority maintenance scheduling was weak as demonstrated by the

large maintenance backlog. This was particularly evident in the

areas of fire protection and security, resulting in equipment

unavailability. The maintenance planning group was effective in

validating maintenance requests (MR), but was only marginally

effective in planning daily maintenance activities. Maintenance

program procedures were considered weak and contained only

minimal information. No administrative guidance for the newly

formed planning and procurement groups was in place, hampering

their integration into the process.

During the current SALP period maintenance and modification

activities were routinely monitored. Also seven special inspec-

tions were conducted to evaluate the licensee's maintenance and

modification control programs. An Augmented Inspection Team and

a special electrical system team inspection also evaluated as-

pects of maintenance program effectiveness. Near the close of

the SALP period a special maintenance team inspection evaluated

the licensee's effectiveness in implem nting the program.

Licensee efforts to improve facility material conditir during

this assessment period have been highly evident. Ovet mis of

major plant equipment such as the Residual Heat Removal pumps,

High Pressure Coolant Injection pump, and feedwater pumps were

successfully completed. Commitment by senior licensee manage-

ment to perform these and numerous other equipment overhauls is

a positive indication that material improvement has been a

licensee priority.

.

.  %

-

.

The maintenance section also provided strong support during the

November, 1987, extended loss of offsite power recovery effort.

The Maintenance Section Manager held meetings to ensure directed

and coordinated efforts of the work force and developed plans

for an organized approach. Inspector observation of maintenance

task performance in the field indicates that workers are ade-

quately trained in that they are generally knowledgeable of

assigned activities and their impact on the plant.

Senior licensee management has acted to increase allocated main-

tenance staf fing, however staffing levels remained a weakness

during much of the period. The significant burden of outage

activity combined with this weakness continued to delay the

progress of program enhancements. Early in the period, first

line supervisory vacancies resulted in a reduction in oversight

of field activities. Qualified licensee personnel did not apply

for the positions. The licensee aggressively recruited indi-

- viduals from outside the organization and filled the vacancies.

Three maintenance staff engineer positions were created and

filled in an effort to provide maintenance department technical

support.

These individuals concentrated largely on completion of outage

tasks and therefore were not available to develop longer range

maintenance program improvements. Late in the period the Main-

tenance Section Manager and both the Electrical and Mechanical

Division Manager positions became vacant. The licensee filled

these three vacancies immediately af ter the close of the SALP

period. Turnover and difficulty in recruitment of in-house

'

personnel continues to be a significant problem at the mainten-

ance supervisor level. The licensee compensated for two of

these vacancies by using contractors. These continuing super-

visory staffing vacancies combined with maintenance management

turnover resulted in a lack of stability and consistent direc-

tion in the maintenance organization.

4

Communications between the maintenance department and other

organizational entities has improved significantly. Early in

the SALP period poor consnunication between the maintenance,

radiation protection and operations departments resulted in a

1 large number of radiation work permits requested but not uti-

lized, and processing of equipment isolations for maintenance

activities which were subsequently delayed. Maintenance prior-

ities were not always consistent with operational needs. To

address these issues, licensee management assigned two experi-

enced radiation protection technicians to maintenance to assist

in job planning and to improve maintenance personnel apprecia-

tion of radiological considerations. Two senior reactor opera-

tors were assigned to provide direct input to the planning pro-

cess, and to act as liason betweeh operations and maintenance.

,

L____

e

' 26

.'.

,-

These actions resulted in substantial communications improve-

ment, and more efficient processing of maintenance and modifica-

tions tasks during the latter part of the assessment period.

During the period the licensee continued to devote resources to

the improvement of the planning and scheduling function. Staff-

ing of the maintenance planning group was augmented by the ad-

dition of significant contractor support. At the close of the

SALP period all maintenance planning staff positions had been

filled, with five positions filled by contractor personnel.

This group actively collected existing MRs and verified spare

parts availability but was not effective in developing inte-

grated maintenance schedules or ensuring consistent high tech-

nical quality in maintenance packages. Licensee management also

created the temporary Planning and Restart Group to assist in

establishing outage scope and schedules. The functions of thit

group were later incorporated into the permanent line orgar.iza-

,

tion under the planning and Outage Manager. The Planning and

Outage Group appeared to be increasingly involved in driveloping

and tracking longer term work schedules by the close of the SALP

period. Continued attention to developing and implementing

effective maintenance schedules, and to improving the detcil and

quality of maintenarce work packages is needed.

In the previous SA.P period, a large backlog of low priority

maintenance had resulted in inoperable fire protection and

security equipment, and reductions in operational flexibility

due to equipment unavailability. During this assessment period,

the licensee has effectively focused attention on defining and

processing this large backlog of work. Recent completion of the

major outage activities allowed further reductions. Late in the

period the licensee directed increased effort at improving

general equipment condition. Man:gement frequently toured the

station, evaluating the effectiveness of these efforts. How-

ever, because of a lack of sensitivity caused in part by con-

centration on backlog reduction, less significant maintenance

deficiencies and poor maintenance practices were not always

promptly addressed. An example of this is the poor condition of

station batteries identified during a NRC team insper. tion.

Several routine inspections and a maintenance team inspection

near the end of the SALP period found that maintenance program

procedures and work instructions continued to be a significant

weakness. Work control and implementation practices were not

clearly delineated in approved procedures or other directives as

evidenced by the excessive delay in issuing the Maintenance

Manual. Maintenance requests contained little detail of the

as-found condition, repairs effected and ' post-maintenance test-

ing performed. This hindered subsequent root cause evaluattor.s

and reviews. Instructions provided to maintenance technicians

e

' 27

.~

..

of ten were not sufficiently detailed to ensura proper perform- l

ance of the task, and to document activities such as placement i

of jumpers or lif ted leads. For example, a series of engineered i

safety feature (ESF) actuations were caused by lack of adequate  ;

instructions and planning of electrical relay replacements. I

There was also no effective process for management review of l

completed maintenance packages. A number of improvements had

been implemented such as maintenance package checklists, worker

prejob briefings and use of a temporary procedure to document '

lifted leads, but appropriate maintenance process procedures

were not revised to reflect the changes. For much of the SALP ,

period, actions taken in response to NRC concerns were directed

at correcting problem symptoms and were not sufficiently com-

. prehensive in nature. The licensee deferred the formal ad-

dressing of program weaknesses in this area and the application

of interim improvements has been inconsistent and not wholly

effective. Ohortly af ter the assessment period, licensee at-

tention to thi: areas intensified and major program improvements

were initiated.

The licensee's post-maintenance test program was not clearly

defined. No clear guidance for establishment of post-mainten-

ance testing requirements existed. In one case MRs for exten-

sive repair and retermination of electrical cables were desig-

nated as not requiring retest, even though the repairs disturbed

numerous circuits upon which logic testing had previously been

completed. Late in the period the licensee took action to

strengthen the post-maintenance testing process and to create a

matrix of testing requirements.

The licensee implemented several aggressive maintenance initia-

tives directed at. improvement of component performance. Pre-

ventive maintenance on all safety-related motor operated valves

(MOV) and AC circuit breakers was completed. However MOV pro-

cedures were found to be weak in some areas. Circuit breaker

maintenance was not extended to include any safety-related DC

circuit breakers until prompted by the NRC, even though none had

been performed during the life of the plant. While management

commitment is evident, follow through on initiatives was occas-

iona11y incomplete. The increasing involvement of the Systems

Engineer Group has had a positive impact on maintenance perform-

ance, particularly the quality and promptness of maintenance

problem root cause analysis. The licensee also significantly

increased staffing, training and management direction of the

Station Services Group resulting in improvements in the station

dacontamination and housekeeping programs.

The licensee has implemented a Material Condition Improvement

Action Plan (MCIAP) which identifies many of the weaknesses

described above. An independent monitoring group was estab-

,

./ 28

,

lished by the licensee to monitor its effectiveness. This plan

is intended to result in significant maintenance program im-

provements over the long term. The hardware aspects of the

MCIAP were effectively addressed, however, program and proced-

ural enhancements were deferred. The licensee also implemented

,

a maintenance performance indicators program. This program has

assisted licensee maintenance management in better focusing on

adverse trends and department performance.

As a result of good working relationships between the Site

Engineer Group and the Modification Management Group, lice.see

control of modification implementation and turnover was strong.

A large number of complex modifications. vere completed during

the period without significant problemt The prcgram for con-

trolling post-modification testing was getierally effective.

However, technical review of post-modification test procedures

was occasionally inadequate. Examples of this included the

failure of testing to identify the incorrect installation of

reactor water level instruments, and the approval of several

tests which either caused or would have caused unanticipated ESF

actuations.

In summary, the licensee continues to give high priority to

improvement of plant material condition, although program

weaknesses in several areas were evident. The licensee im-

piemented informal process enhancements which resulted in more

rapid improvement during the last months of the SALP period. A

long range plan, the MCIAP, has been established to promote

program improvements in the areas of identified weakness.

Licensee senior management attention to full and timely imple-

mentation of this plan is necessary to assure that permanent

improvements are achieved. Staffing problems and management

turnover however, need to be resolved so that these problems do

not continue to hamper licensee efforts.

(2) Conclusion

Ratino: 2

Trend: None Assigned

(3) Recommendations

Licensee:

-

Complete implementation of program improvements and con-

tinue staffing efforts.

- Provide for staff continuity and development.

NRC: None.

1

- - _ _ .

.

.

."~ 29

.-

4.4 Surveillance (1386 hours0.016 days <br />0.385 hours <br />0.00229 weeks <br />5.27373e-4 months <br /> /14 percent)

(1) Analysis t

i

The surveillance functional area is intended to assess the ef-

fectiveness of licensee management in assuring the development

and implementation of a comprehensive surveillance testing

program.

-

During the previous SALP period, surveillance was assessed as a

Category 3. Testing was generally conducted in a careful,

safety conscious manner, however no centralized management of

the surveillance test program existed. Responsibility for pro-

gram management was not clearly established. The system for -

control of surveillance scheduiing was weak, principally because

the key individual involved wi'.h this activity was not a tech-

nical staf f member. The tectnical adequacy of surveillance

procedures and the control of measuring and test equipment

(M&TE) were also found to be 11 adequate. The licensee's sur-

veillance test program had not received adequate management

attention.

During this SALP period surveillance testing was routinely ob-

]

served and procedure techr.ical adequacy was evaluated. One

management meeting and several inspections were Sonducted to

1 assess licensee efforts to correct the previously identified

problem.. An Augmented Inspection Team dispatched in response

to a loss of offsite power also evaluated aspects of surveil-

lance program effectiveness.

I

,

During the previous assessment period, the absence of strong

centralized control and responsibility for surveillance program

oversight contributed to continuing weaknesses. Early in this

SAlp period the licensee assigned responsibility for program

maintenance and upgrade to the Technical Section Manager. The

Systems Engineering Group within the Technical Section has

, become increasingly involved with development of program

!

1mprovements. A Surveillance Coordinator position was estab-

lished and staffed by a senior systems engineer to help provide

needed focus. In addition, a coordinator was assigned in each

department responsible for surveillance test performance. Al-

location of these rasources has resulted in acceleration of

l program improvements and is an indication of management

commitment.

.

!

}

l

,

l

\

- _ _ - _ _ .

.

30

.O

.

.-

The licensee has taken action to improve the technical adequacy

of surveillance test procedures. Technically inadequate test

procedures were a recurring problem identified during previous

SALP periods, requiring repeated NRC initiatives to obtain t

'

licensee corrective action. During the current assessment per-

!

iod however, the licensee implemented an extensive effort to

evaluate and upgrade surveillance procedures. A team composed ,

of licensee Nuclear Engineering Department, Technical Section

and Maintenance Section representatives was formed to address

the problem. Initially the effort was intended to assure com-

pliance with technical specifications. Licensee management

expanded the upgrades however, to include testing of additional

system design features beyond technical specification require-

ments. This is an indication of the licensee's desire to estab-

lish a more comprehensive program that goes beyond regulatory

requirements. Implementation of the improved testing allowed

the licensee to identify and correct several system performance  :

3

problems. Another example of the licensee's intent to thor- l

4 oughly ?est major systems was the use of a temporary boiler to l

j perform extensive testing of the High Pressure Coolant Injection l

and Reactor Core Isolation Cooling systems with non-nuclear ,

.

steam. While substantial progress has been made, and existing

'

procedures have been upgraded sufficiently to assure compliance ,

- with the Technical Specifications, some procedural weaknesses -

continue to be noted. For example, the inoperability of an i

emergency diesel generator during a loss of offsite power could

have been prevented if surveillance procedures had recorded and l

evaluated more than the required minimum instrument readings. r

'

Additionally, inadequate test procedures have caused unnecessary ,

engineered safety features actuations.

.

The licensee began development of a new computer-based Master ,

Surveillane:e Tracking Program (MSTP) in an attempt to resolve ,

previously identified scheduling problems. Considerable licen-

'

see effort was expended on development of the new program. How- ,

ever, late in the SALP period the licensee concluded that it was

not viable due to problems with vendor-supplied computer soft-

ware. The licensee's Systems Engineering Group has initiated an *

interim manual tracking system, and is revising the previously

used MSTP to compensate for the identified weaknesses. Substan- ,

tial time was expended in the unsuccessful attempt to implement i

the new MSTP, and therefore final resolution of the scheduling l

problems has not been reached. However, it is avident that

i

licensee management is connitted to improving the system,

,

i

l

4 responsibility for implementation has been established and ,

t

j progress is being made,

!

!

! i

i i

!  !

i

.

l

i - - - _ _ - - - _ - - . - _ ._ -- - - . -

o l

.d 31

.- l

The licensee's program for control of Measuring and Test Equip-

ment (M&TE) has improved significantly. The licensee dedicated

four full-time individuals to the upgrade of the M&TE control

program. Instruments were collected, assigned unique identifi-

cation numbert ind data was input to a computer-based tracking

system. Control and implementation of the local leak rate test

program have also improved since the last assessment period.

The significant improvement in these areas is a clear result of

management involvement.

Licensee personnel generally conducted testing in a careful,

safety conscious manner. Major testing evolutions such as the

reactor vessel hydrostatic test and the containment integrated

leak rate test were well coordinated and executed. Occasional

personel performance lapses in the quality of testing were

noted, however. For example, instrument and controls tech-

nicians failed to enable equipment sump level switches after

calibration, causing sunp overflow in the high pressure coolant

During a similar drain system overflow

,

injection pump room.

incident operators did not perform required shif tly plant tours.

As a result contaminated water was allowed to accumulate. These

instances may indicate some weakness in personnel training.

The inservice inspection (ISI) program was effectively imple-

rented. The licensee's ISI staff demonstrated a good under-

standing of technical issues. Management support of the ISI

program is evident. For example, prompt action was taken to

evaluate piping errosion and drywell liner corrosion in response

to industry events.

.

In summary, the licensee has established appropriate responsi-

bilities for management of the surveillance program. Sufficient

senior management and technical resources have been allocated to .

affect the needed program improvements. Program responsibil-  !

ities have' been defined and assigned to the System Engineering

Group. Test procedure technical adequacy and control of M&'iE r

were substantially improved in response to recurring NRC con-

cerns. While strengthening of surveillance scheduling has been

slowed due to computer program problems, progress is currently

being made. Continued licensee management attention is neces-

,

sary to assure implementation of ongoing improvements, aggres-

sive evaluation and correction of remaining weaknesses and

reinforcement of newly established work standards.

!

,

.-.- - .- . _ - _ - _ - _ - _ _ , .__ - ._ . _ __ - -- _ _

= _ - - _._._-

4

,M 32

..

(2) Conclusion

Rating: 2

Trend: None Assigned

(3) Recommendations

Licensee: Continue positive initiatives to upgrade surveillance

procedures and impliment improved surveillance ~ track-

ing programs.

i

i

i

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l

~

!

!

l

4

l

I

}

i

,

- - - - - , , - . _ . _ _ _ _ _ _ _ _ _ , , _ _ __ , _ _ , _ _

.

33

.-

4.5 Fire protection (493 hours0.00571 days <br />0.137 hours <br />8.151455e-4 weeks <br />1.875865e-4 months <br /> /5 percent)

.

(1) Analysis

This functional area is intended to assess the effectiveness of

the licensee's station fire protection program, and the adequacy ,

of modifications and procedures established to ensure compliance >

with 10 CFR 50 Appendix R. During the last period this area was

rated as a Category 3. The fire protection program suffered

from a chronic lack of management attention. The licensee was

not aggressive in maintaining the operability of station fire

protection equipment, resulting in heavy relunce on compensa-

tory measures. Fire barrier surveillance procedures were un-

. clear and incomplete. Personnel performing fire watches and

serving on the fire brigade were poorly trained. Licensee

senior management had taken steps at the end of the perit i to

strengthen the program.

During this assessment period routine inspections monitored the

progress of licensee improvement efforts, additionally two

inspections were conducted to assess the status of the station

fire protection program. In addition, a team inspection was

performed to evaluate licensee compliance with 10 CFR 50,

Appendix R. A management meeting was also held to discuss fire

protection and Appendix R concerns.

The licensee demonstrated a high level of management involvement

in ensuring fire protection and Appendix R program improvements.

A fire protection group was established near the end of the last

l SALP period. During this period, staffing for the group was

increased from one fire protection engineer to six permanent

fire protection specialists. Frequent meetings with the fire

protection group leader, and periodic status reports assisted

senior licensee management in monitoring the group's progress.

In the area of Appendix R the licensee established a temporary

project management organization. A senior project engineer was ,

dedicated to provide focused oversight and support. The Appen- t

! dix R project organization and the fire protection group worked  ;

closely together to coordinate activities. '

1 The licensee has been successful in reducing the backlog of fire

protection equipment maintenance, which had contributed to a

heavy reliance on compensatory measures. Fire protection group

and maintenance managers worked effectively together to reduce l

l the outstanding maintenance backlog, and to maintain it at a

'

manageable level. Total outstanding fire protection maintenance  !

was reduced from over 300 items to less than 50 items, and is  :

f currently tracked by licensee management as a performance  !

indicator, i

t

I

!

- i

i

i

- - - ,-_ __, - - - - -

- - _ - . _ - . - - . - . - - . - _ _ . _ . .

.

,

< 34

,

~

The control and quality of fire brigade training have improved.

The fire protection group, with the assistance of the training

department, developed and implemented a more comprehensive

training program. A state certified instructor was hired to

conduct the brigade training. The number of fire brigade drills

conducted has substantially increased, and it appears that their

effectiveness has improved. Through these actions the licensee

has succeeded in developing a large core of trained personnel to

serve as fire brigade members. E'fective interaction and coor-

dination between the fire brigace, the operations staff and

local fire fighting companies was evident during several minor

fire incidents occuring during the period, including a fire in .

'

the machine shop which prompted declaration of an Unusual Event.

The licensee initiated, and the NRC has approved several fire

protection licensing actions during the assessment period. In

response to past instances of problems with fire barrier ade-

Quacy, the licensee's Appendix R project organization imple-

mented a well conceived program to identify, inspect and repair

plant fire barriers. These inspections resulted in the identi-

fication of a significant number of deficient barrier seals. '

Licensee management exhibited a conservative philosophy, estab-

lishing compensatory fire watches for all plant barriers pending ,

completion of inspections.

The licensee's approach to maintaining safe shutdowr capability

was found to assure redundant safe shutdown system train separa-

tion, and to provide sufficient operational flexibility. To

assure adequate separation the licensee performed a well docu-

mented and thorough analysis, although procedures for use of the

safe shutdown equipment, and operator training in this area were

i found to be weak. The licensee has taken action to resolve

these weaknesses and has committed to demonstrate safe shutdown

capability by performing a test during the power ascension

program.

! In summary, licensee management has taken strong action to

establish and staff an effective station fire protection organ-

itation. Significant improvement in fire protection equipment

material condition and fire brigade training has resulted.

Licensee response during this SALP period to Appendix R issues,

,

particularly fire barrier seal problems, was prompt and effec-

tive. Continued management attention is needed to assure prompt

completion of fire barrier seal repairs, to achiev, further

reduction of outstanding compensatory fire watchet and to pro-

vide a stable effective fire protection program.

,

l

I

r

--

o

,e 35

..

(2) Conclusion

Rating: 2

Trend: None Assigned

.

4

4

s

36

.Y

• • 4.6 Emeraency Preparedness (176 hours0.00204 days <br />0.0489 hours <br />2.910053e-4 weeks <br />6.6968e-5 months <br /> /2 percent)

(1) Analysis

During the previous assessment period, licensee performance in l

this area was rated Category 2. This was based upon a renewed

commitment by management for emergency preparedness and a sig-

nificant improvement in performance.

During the current assessment period, one partial participation

exercise was observed, two routine safety inspections were con-

ducted, one special safety inspection specifically related to

emergency classification was conducted, and changes to emergency

plans and implementing procedures were reviewed.

Two routine safety inspections were conducted in November,1987 ,

and January, 1988. These inspections examined all major areas 1

i

within the licensee's emergency preparedness program. During ,

'

the November, 1987 inspection, significant changes were examined

regarding the normal emergency preparedness organization. These [

changes resulted in essentially a completely new organization  ;

'

with the Emergency Preparedness Manager reporting to the Senior

Vice President. Functional responsibilities are divided i r.to  !

on-site and off-site areas with coordinators for each. The  !

4

licensee has filled the managerial positions, as well as other j

working positions, with personnel experienced in emergency pre- f

i paredness. In addition, the licensee has contracted with I

i

several consultants to help the permanent staff.

During the January, 1988 inspection significant changes were (

l examined regarding the Emergency Response Organization (ERO) and

!

Emergency Action Levels (EAL's). The licensee has committed to  !

i l

a complete restructuring of the ERO with a three-team duty rota-

Additionally, the licensee is revising the EAL's to be

tion.

symptomatic, address human f actors, and has integrated them with l

the Emergency Operating Procedures. Significant facility

l

changes made include the addition of a Computerized Automated

l Notification System to notify the ERO. l

j l

t

A partial participation exercise was conducted on i

i

satisfactory

l

December 9, 1987. The licensee demonstrated a

emergency response capability. Actions by plant operators were

prompt and effective. Event classification, and subsequent

l

'

l

Protective Action Recommendations, wre accurate and timely.  ;

j

Personnel wre generally well trained and qualified for their l-

significant deficiencies were identified.

i

I positions. No *

I 5everal minor waknesses wre noted including insufficient depth

l

in some positions to support prolonged operations, dose projec- [

tion discrepancies, delays in fielding onsite repair teams, and (

l

weak initial notification forms. ,

'

!

L

i

I

!

!

. i

./ 37

'~

During the response to a loss of offsite power event in

November,1987, some weakness in coordination and communication

between licensee groups was noted. While not required by the

site emergency plan, the licensee eventually chose to partially

activate the Technical Support Center (TSC) to aid in recovery

efforts. The difficulties experienced by the licensee during

the initial response and subsequent efforts to utilize the TSC

<

indicate that licensee attention to preplanning response options

to non-emergency events, such as discretionary activation of the

TSC, may be appropriate.

During the February,1988 inspection the licensee's actions in

response to a declaration of an Unusual Event were examined.

The licensee's classification was conservative and prompt. Mit-

igation activities were effective. The licensee identified

several problems associated with their actions including: fail- 1

ure to completely follow procedures; untimely notification of

- event termination; and control room distractions due to the

large volume of outside communications. The licensee promptly

identified these issues and instituted appropriate short-term

and long-term actions to prevent their recurrence.

The licensee is continuing to work closely with local and

Commonwealth of Massachusetts officials to upgrade off-site

emergency preparedness. The licensee has a large organization

working on plan and procedure development, in conjunction with

the appropriate local and Commonwealth agencies.

During this period, the licensee was granted exemptions for the

-

1987 full participation exarcise and a deferral of the submittal

of public information. These were based on the Commonwealth of

Massachusetts requests to complete the local and Commonwealth

emergency plans, implementing procedures and associated training

prior to issuance of public information or demonstration of

capabilities.

In summar/, the licensee has demonstrated a commitment to emerg-

ency preparedness. Management involvement is evidenced by the

major on- site program changes being supported, commitment to

the offsite level of emergency preparedness, and by timely

recognition of problems and subsequent corrective actions. The

licensee has been responsive to NRC concerns and is , continuing

to make progress in these areas.

j

(2) Conclusion

.Ra tino: 2 ,

,

Trend: Improving

r

,

. __ _

.

.

( 38

.

4.7 Security and Safeguards (641 hours0.00742 days <br />0.178 hours <br />0.00106 weeks <br />2.439005e-4 months <br /> /7 percent)

(1) Analysis

This functional area was rated as a Category 3 during the pre-

vious assessment period. NRC identified serious concerns

regarding the implementation and management support of the

security program. The licensee's proprietary security staff

consisted of one full time and one part time member, resulting

in weak oversight of the contractor. In addition, inoperable

equipment contributed to a heavy reliance on long term compen~

satory measures. Contractor security force overtime was also

poorly controlled. Toward the end of the assessment period, the

licensee initiated actions to correct the problems. However, at

the conclusion of the rating period the hardware upgrades were

not complete and the expanded proprietary security staff organ-

ization had not been in place for an adequate time for NRC to

evaluate its effectiveness.

Four routine, unannounced security inspections, one special

security inspection, and one routine unannounced material con-

trol and accounting inspection were performed during this

assessment period by region-based inspectors. Routine observa-

tions were also conducted throughout the assessment period.

During this assessment period, the licensee aggressively pursued

a planned and comprehensive course of action to identify and

correct the root causes of the previously identified program-

matic weaknesses in the area of physical security. To improve

the overall performance of the se urity organization and the

security program the licensee implemented several significant

actions, including a commitment by senior management to support

and implement an ef fective security program; establishment of a

licensee security management organization on-site to direct and

oversee program implementatian: upgrading unreliable systems and

equipment to eliminate the previous heavy reliance on compensa-

tory measures that were manpower intensive; and revising the

Security, Contingency and Training and Qualifications plans, and

their respective implementing procedures, to atk.e them current

and clearer.

4

The licensee's security management organization is now headed by

a section manager who reports to the Plant Support Manager,

under the Station Director. Assisting the Security Sect. ion

Manager are five supervisors with specific functional areas of

responsibility (operations, administration, technical, compli-

ance and access authorization) and a staf f assistant. Addi-

'

tionally, there are seven licensee shif t supervisors who are

.

._ _ _ . _ _ _ _ _ , _ _ _ _

. ___________ ____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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responsible to monitor the performance of the contract security

force around-the-clock. This represents an overall increase of

seven supervisors over these which were in place at the end of

the last assessment period, and thirteen over that which was in

place when the plant was shut down in April,1986. (At that

time there was one supervisor who reported to a group leader

H e ather, concurrent duties.) The licensee also established a

f ull-tier .orporate security position onsitt. The incumbent is

responsible to audit the security program on a continual basis

and to provide another perspective on its implementation. In

addition, the licensee established, as supervisory personnel,

the alarm station operators employed by the security force con-

tractor, and significantly improved the supervisor-to guard

-

ratio. This expansion of the licensee's security organization

represents a significant allocation in terms of resources and

provides evidence of senior management's commitment to the

program.

In addition to the organizational expansion, considerable

capital resources were expended throughout the assessment period

to upgrade, by modification or replacement, security systems and

equipment. The entire protected area barrier, assessment sys-

tem, intrusion detection system and protected area lighting were

significantly improved. These improvements began early in the

assessment period and were, for the most part, complete at the

end of the period with only minor fine tuning of the new systems

and equipment still required. Additional upgrades in access

control equipment and the security computer are scheduled. The

improvements have already resulted in a sizable reduction in the

number of compensatory posts and, therefore, a reduction in the

contract guard force. The above mentioned upgrades permitted

the guard force to go on a 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> work week rather than the 60

hour work week required during the major portion of the assess-

ment period. In addition to the improved systems and equipment,

the licensee has taken action to strengthen the security equip-

ment corrective maintenance program and has initiated action to

establish a preventive maintenance program to further ensure the

continued reliability of security systems and equipment. Open

j

maintenance requests for security equipment are also now tracked

as a performance indicator by plant management. These actions

and initiatives are further evidence of senior management's

~

commitment to the program.

4

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During the assessment period, the licensee submitted six changes

to the Security Plan under the provisions of 10 CFR 50.54(p).

One of these changes was a complete revision to upgrade the

.

Security Plan and to revise the format to be consistent with

NUP.EG 0908. In conjunction with the Security Plan upgrade, the

licensee also submitted revisions to the Safeguards Contingency

Plan and the Security Force Training and Qualification Plan

(complete revisions of these plans were submitted during March,

1988). The complete plan revisions were comprehensive, more

consistent with current NRC regulations, and provided clearer "

documents from which to develop and modify implementing proced-

ures. The plan changes were adequately summarized and appro-

priately marked to facilitate review. Further, the Itcensee,

prior to submitting the changes, communicated with the NRC by

telephone and requested meetings in Region I and onsite to

ensure that the changes were appropriate, clearly understood,

and in compliance with NRC regulations.

Audits of the Security program conducted by Corporate Security

personnel and the ., .ite QA group during the asset ment period

were found to be - ry comprehensive and corrective actions were

found to be prompt and generally effective, indicating a much

improved understanding of program objectives. Because of the

security program weaknesses identified toward the end of the

previous SALP period, the licensee assigned to the site, on a

f ull-time basis. 6 member of the corporate security staff with

responsibility for conducting continued surveillance and audit

of the program. That initiative was reviewed and found to be a

very effective management tool to provide an independent assess-

ment of the day-to-day implementation of the security program

and another input to the overall security program upgrade

project.

The security force training program appears to be adequate to

address the activities of the sacurity organization. The licen-

see has taken actions to assure the training program remains

current and reflects the changas and upgrades to the security

program. For example, to ensure more comprehensive management

oversight by licensee security shift supervisors, each received

plant operational technical training' in addition to security

program and other training. This training enables these super-

visors to be more ef fective in interfacing with other plant

technical functions.

. -

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There were three apparent violations identified by the NRC dur- '

ing this assessment period. All of the violations were the

result of degraded vital area barriers. The licensee was noti-

fied of the apparent violations and an enforcement conference

and a subsequent management meeting were held. These apparent

violations resulted from weak communications between the secur-

ity and maintenance organizations, and a poor appreciation by

maintenan:;e personnel of security requiremants. Corrective

actions were implemented by the licensee and they appear to be  ;

effective.

,

A total of six security event reports required by 10 CFR '

'

73.71(c) were submitted to the NRC during this assessment per- .

iod. Three event reports were necessitated by the licensee's

findings of degraded vital area barriers. Similar degradations

were also reported in the orevious assesserent period. Two of

the degradations reported curing this period were the result of

maintenance work being performed en plant ? #mt that pene-

trated the barriers. The other resulted fron. cegraded vital

area door. Another ever,t report was necessitated by the re-

classification of an area of the plant as vital. The need for

reclassification was identified as a result of the '.icensee's

Vital Area Analysis and Barrier study. Another event report

involved a gJard leaving his weapon unattended The sixth event

report involved the loss of a set of security keys by a member

of the guard forre. With the exception of the vital barrier

degradations ear'ier in the assessment period no adverse trend

was indicated by the events which occurred during this assess-

ment period. The licensee eventually implemented appropriate

measures to prevent recurrence of the vital area barrier degra-

i

dation problems. The quality of the event reports was signifi-

cantly improved over the previous assessment perioct indicating a

' better uncerstanding of program objectives and more care in

their preparation. They were clear, concise and contained suf-

ficient information to permit NRC evaluations without the need

'

for additional inforwatton.

The licensee's program and procedures for the control and ac-

counting of special nuclear saterial were also reviewed during

this assessment period and were found to be adequate and gen-

c 'ly well implemented.

l .

i

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In sumary, the licensee has demonstrated a commitment to imple-

i

ment an effective security program that goes beyond minimum

!

compliance with NRC requiremants. As a result of this comunit- ,

ment, the Itcensee security organization has been expanded,  ;

significant capital resources have been expended to upgrade

security hardware, and equipment and program plans have been

improved. Continued senior management support and involvement

in the security program is necessary to ensure that the momentum

demonstrated during this assessment period is continued. ,

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(2) Conclusion

Rating: 2

Trend: None Assigned

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4.8 Engineering and Technical Support (1215 Hours /13 percent) ,

(1) Analysis

This functional area is intended to assess the adequacy of the

licensee's technical and engineering support in the areas of ,

plant design changes, routine operations and maintenance activ- f

ities. Engineering and Dehnical Support was assessed as a i

Category 1 during the previous SALP period. Good engineering t

'

support to the site was noted in the Environmental Qualification

program and the design of several significant plant hardwa e

modifications. Technical evaluations were typically thorough

and demonstrated an adequate regard for safety. The engineering

approach to the Safety Enhancement Program (SEP) demonstrated an

excellent appreciation for underlying safety issues. A weakness

in the lack of detailed design basis documents for plant equip-

ment was also noted during the last period.

. .

During this assessment period, five special inspections includ-

ing an Augmented Inspection Team focusing on a loss of of(site

power event, an electrical system team inspection, and a main-

tenance tegm inspection were conducted and, in part, evaluated i

the licenste's performance in this area. The effectiveness of

the onsite Systems Engineering Group, and the Nuclear Engineer-

ing Department's (NED) interactions with the site organization

were routinely monitored.

Significant plant modifications were installed during this

assessment period, including the reactor water level instrumen-

tation modification, a hydrogen water chemistry system, an

analog trip system, and a new plant process computer. Few prob-

lems were identified with these projects, demonstrating the

strength of the engineering work. Safety evaluations required

by 10 CFR 50.59 for design changes and modifications were

generally thorough and conservative. Safety evaluations for SEP

modifications demonstrated sufficient analysis and supporting

facts to conclude that there were no unreviewed stfety ques-

tions. Highly qualified engineering staff and NED mant.gement

focus o.1 safety have contributed to the licensee's performance

in this area,

Of fsite technical and engineering support was generally good as

indicated by the successful design and implementation of signif-

icant plant hardware modifications. Continued effective use of

the Design Review Boani was evident during t 's ! ALP period.

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This was demonstrated by high quality initial design reviews,

and routine evaluations of completed modifications for syner-

gystic ef fects. The expanded Field Engineering section, the

design implementation oversight arm of NED, played a vital role

in coordinating activities between the site organization and the

NED. Engineering management was actively involved in implemen-

tation of modifications and addressing problems. The Safety

Enhancement Program, including extensive Mark I containment and

station blackout modifications, were planned and implemented

during this period. The engineering approach to the Mark I

issues went considerably beyond NRC requirements and demon-

strated a good appreciation of containment reliability issues.

The NED's involvement in the development of the new Emergency

Operating Procedures (EOP) demonstrated significant management

attention in this area. The licensee's communications with the

NRC regarding the planning and implementation of the SEP and E0P

projects were gencrally good. In addition to these modifica-

tions, the licer.see is preparing an extensive Individual Plant

Evaluation (IPE) as part of the (SEP) using probabilistic and

deterministic analyses. In support of these efforts, the

licensee effectively managed contract engineering expertise to

produce quality design changes and analyses. Throughout the

development and implementation of the SEP senior management's

involvement and commitment to safety was apparent.

A team inspection was conducted during this assessment p4riod to

review the licensee's implementation of a fire protection pro-

gram to meet the requirements of 10 CFR 50 Appendix R. The

licensee's approach to maintaining safe shutdown capability was

found to assure adequate redundant safe shutdown system train

separation, and to provide sufficient operational flexibility.

The licensee's analyses were found to be well documented and

thorough. NED's Appendix R project organization and the onsite

fire protection group worked closely together to coordinate

activities.

Some weaknesses in the engineering design change process were

noted. In one instance inadequate technical review of a design

change by NED resulted in incorrect installation of reactor

water level gauges. Additionally, the plant design change docu-

ment for the $tandby Gas Treatment System did not speCify ade-

quate post-work testing requirements. Further, as indicated in

the previous SALP, the lack of detailed design basis documents

was a continuing problem this assessment period. Examples

included lack of seismic qualification documents for the reactor

1

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building auxiliary bay and for the hydraulic control units.

Also, engineering failed to correctly translate containment ,

accident temperature profiles into environmental qualification  ;

documents. However, the licensee has taken initiatives to

further understand che design bases of the plant electrical

distribution system as evidenced by the use of a new computer

code to analyse electrical distribution equipment performance.

At times, corporate engineering support for plant maintenance

activities was limited. The NRC special electrical system

inspection identified that the DC battery and electrical breaker

maintenance activities were not supported by NED. The licen-

see's initial response to the NRC's concern regarding the sur- >

-

veillance testing of the DC breakers was limited in scope and

lacked engineering justifications on the sample size and the

acceptance criteria.

The increasing involvement of the onsite Systems Engineering

-

Group (SEG) has had a positive impact on the quality of opera-

tiens event analysis, the surveillance test program, tnd on

maintenance performance, particularly the quality of maintenance

problem root cause analysis. At the beginning of the assessment

period the licensee established the SEG under the Technical

Section within the Nuclear Operations Department. The SEG was

staffed largely with experienced contractors, but the licensee

gradually expanded the group and replaced the contractvrs with

j permanent Boston Edison employees. At the end of this period,

the SEG had a total technical staff of 26 including 15 senior

systems engineers. The increasing involvement by the SEG has

j

promoted better intergroup interactions as the operations and

,

'

maintenance departments have begun to value and rely on the

SEG's contributions.

In summary, overall strong engineering support continued

throughout this period. Major plant modifications were com-

l

pleted with only a few minor problems, demonstrating the quality

of engineering work. The increasing involvement of the SEG has

l

contributed significantly to the quality of root cause analyses

' and in maintenance performance. However, overall performance

in the areas of corporate engineering responsiveness and support

to site maintenance initiatives appears to need further Heensee

evaluation and improvement. Additional management attention is

needed in developing long-ters programs to provide better

operational and maintenance support to the site.

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(2) Conclusion

Rating: 1

Trend: None Assigned

e

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4.9 Licensing Activities

(1) Analysis

The licensing functional area is intended to essess the licen-

see's effectiveness in assuring a technically accurate and up-

to-date licensing basis, and the licensee's responsiveness to

NRC and industry concerns. During the previous assessment

period licensing was evaluated as a Category 2.

During this period, the basis for this appraisal was the licen-

see's performance in support of licensing actions that were

either completed or had a significant level of activity. These .

actions consisted of aniendment requests, exemption requests, ,

responses to generic letters, TMI items, and other actions.

The licensee has exhibited a high level of management involve-

ment in major licensing initiatives; however more routine

licensing actions did not always receive substantive management

action. An example of a high level of management involvement r

and initiative is the licensee's actions to improve the Mark I

containment and implement other plant safety improvements

intended to cope with severe accidents as part of its Safety

Enhancement Program (SEP). This program includes improvements

' to emergency operating procedures, modifications to containment

spray nozzles, enhancements to water supplies that would be

available in the event of a severe accident, the installation of

a direct torus vent and the installation of a third emergency

diesel generator. A number of the SEP modifications, such as

the Station Blackout Diesel Generator are also useful in dealing

with less significant transients and events as opposed to severe

accidents.

The licensee is in the forefront of the industry in the effort

to deal with severe accidents and has expended substantial

resources on the SEP. The licensee has been very active in

industry owner's groups involved in severe accident initiatives.

Although much of the SEP effort did not involve direct licensing

actions, the staff did assess the safety significance of the

licensee's modifications and inspected portions of the modifica-

tions. The licensee is commended for its leadership on the SEP

i

program. It should be noted that the staff is still continuing

its assessment of some of the details of the SEP modifications.

,

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The technical quality of more routine licensing actions (such as

some Technical Specification amendments and exemption requests)

has been sporadic. Several fire protection licensing actions

have reo.uired numerous submittals and frequent interchanges with

the staff. For example, the licensee revised its technical

position twice in the determination of the appropriate basis for

an exemption request involving the lack of 3-hour fire proofing

for structural steel in the Reactor Building Torus Compartment.

Several submittals were required, and the staff h.id to request

detailed calculations to support the licensee's basis. In a

technical specifit:ation change involving 10 CFR 50 Appendix J

requirements (Amendment 113), the licensee had to make numerous

submittals in response to staf f concerns and was required to

correct errors in previous submittals identified by both the

staf f and BEco. The :taff identified inconsistencies in pro-

posed changes to the technical specifications for the Standby

Gas Treatment System and Control Room High Efficiency Air Fil-

tration System (hendment 112) and revised submittals by the

licensee were required. The extensive activities and resources

required to correct problems 'dentified in Confirmatory Action

Letter 86-10 and subsequent management meetings has apparently

impacted the licensee's overali performance in the licensing

area. These problems suggest a weakness in corporate manage-

ment at the level that establistes priorities and coordinates

enginearing and licensing activities for the utility.

The licensee has, however, submitted, and the staf f has ap-

proved, a number of technical specification changes or exemption

requests that demonstrated a high level of technical quality and

..anagement involvement. Examples include the schedular ex-

emption for conduct of the emergency preparedness exercise, Core

Reload ( Amendment 105), Control Rod Block Actuation ( Amendment

110), and LPCI Subsystem Surveillance (bendment 111). Where

NRC staff requests for additivnal information were made, the

licensee responses have been prompt and comprehensive.

The licensee has usually been responsive to NRC initiatives.

The licensee has been responsive to staff requests to track and

control actions of mutual interest between NRR and the utility.

For example, the licensee has developed a tracking system to

assist in the management of licensing actions and has provided

extensive resourcas to support NRC effort in updating the Safety

Information Management System ($1MS) data base. Particularly

noteworthy was the high quality of technical support provided

for the staff's review of Emergency Operating Procedures.

,

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There was evidence of improvement during the latter portion of

the SALP period in the approach to the resolution of technical

issues and responsiveness to NRC initiatives in the licensing

area. This is in part due to recent organizational changes

which have resulted in a closer relationship of the licensing

and engineering groups. The overall staffing to support licen-

sing activities is adequate and its effectiveness should be

'

improved by the recent organizational changes. Recently a

reduction has been evident in the number of cases of technical

errors, lack of clarity, and incomplete information.

In summary, the licensee has exhibited strong management

involvement in several major licensing actions, but attention to

more routine licensing actions has been inconsistent. The

licensee has shown some improvement in the licensing area during

the latter portion of the SALP period. The involvement of

manage ent in routine, as well as eajor licensing activities, is

necessary, The continued strengthening of mid-level management

and increased technical capability of licensing staff are

ne c e s s a ry.

(2) Cen:1usion

Rating: 2

Trend: None Assigned

.

<

k

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- - - -

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_ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _

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..

4.10 Training and Qualification Effectiveness

(1) Analysis

Technical training and qualification effectiveness is being con-

sidered as a separate functional area. The various aspects of

this functional area were discussed and used as one evaluation

criterion within the other functional areas. The respective

inspection hours have been included in each one. Consequently,

this discussion is a synopsis of those assessments. Training

effectiveness has been measured primarily by the observed per-

formance of licensee personnel and, to a lesser degree, as a

review of program adequacy.

This area was ated as a Category 2 during the previous assess-

ment period. The licensed operator training and requalification

programs were found to be significantly improved. Assignment of

knowledgeable staff had resulted in higher quality training

materials, and more plant-oriented operator training. Mainten-

ance, contractor and radiation protection personnel training

were also adequate. Fire brigade and fire watch training had

been significantly weak and contributed to poor personnel per-

formance in the plant. Four of ten licensee training programs

had received accreditation from the Institute of Nuclear Power

Operations (INPO).

During this assessment period, inspectors routinely reviewed

ongoing training activities and their effectiveness in assuring

quality personnel performance. Two sets of reactor operator and

senior reactor operator license examinations were administered.

An inspection to evaluate the adequacy of the nonlicensed per-

sonnel training program was also completed. Various other

inspections reviewed training provided in the areas of emergency

preparedness, radiation protection, security, maintenance, fire

protection and modifications.

Licensed operator training ef fectiveness continued to improve

throughout the period. Two sets of licensed operator examina-

tions were administered to a total of two senior reactor opera-

tors and fourteen reactor operators, with all candidates suc-

cessfully completing the licensing process. Newly licensed

operator familiarity with plant equipment and procedures was

considered a strength. Challenges facing Itcensee management

include completion of training for the large number of new,

relatively inexperienced operators. Site management is intent

on assuring that time spent by newly licensed operators in the

control room during startup and initial operations, is used as

effectively as possible to provide the maximum training benefit.

_ _ _ _ _ _ _ _ _ _ _ - _ _

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,f . 51 l

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The material developed for operator training and submitted for

NRC review was generally good. However, for the first examina-

tion early in the assessment period, it was noted that some

materials provided to the NRC did not reflect recent station

modifications. This was because the modifications had recently

been completed and previous training had focused on the original

systems. It was also noted during exams and by direct discuss-

ions with licensed operators, that training conducted on

recently implemented modifications, such as on the reactor water

level and automatic depressurization systems, had not been fully '

effective. Operators were unfamiliar with the modifications, 1

"

primarily because only on-watch training had been performed and

because the training had been conducted prior to completion of

the modifications. Licensee management took prompt action to

restructure the modifications training and committed to repeat

the training prior to plant restart.

The licensee completed installation of a plant specific simu-  ;

later during this assessment period, and used it extensively to

enhance operator training, particularly in the area of emergency

operating procedures (EOP). The licensee implemented a compre-

hensive E0P training program including a ecmbination of simula- ,

ter and classroom instruction. Licensee management assured the i

effectiveness of this training by performing post-training

evaluation of the operating crews on the simulator. The de-  ;

velopment of special criteria by which acceptable performance is

'

,

judged was a strong point of the E0P training program. Operator

performance weaknesses were identified by the licensee, and sup-

4 plemental training was performed to resolve the problems.

Licensee management also initiated a communications training

program for operations personnel. This communications training

j was implemented . along with the E0P training and appeared to  ;

substantially improve operator performance.

Licensed operator performance during plant events such as a loss

of of f site power, and an Unusual Event due to a fire in the

machine shop generally demonstrated a good command of plant

equipment and procedures. However, some apparent weaknesses in

i operator training were evident. For example, several opera-

>

tional errors were made during reactor refueling despite inde- .

pendent verification requirements. On several occasions oper- l

4

ators failed to properly perform routine surveillances.  ;

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The nonlicensed and contractor personnel training program

appeared effective. The training staff dedicated to this func-

tion has been supplemented by the addition of contractors. The

licensee initiated maintenance and radiological technician

apprentice programs to assist in development of qualified lower

level personnel. New training initiatives are in progress to

sensitize management, workers and radiation protection personnel

to the need to minimize all occupational exposure. For example,

management training in ALARA for plant design changes and radia-

tion awareness training for operations and maintenance personnel

have been initiated. In addition, a Training Program Evaluation

Committee was established to assure plant management involvement

in ongoing development of nonlicensed training.

The licensee's program for fire brigade and fire watch training

has been significantly improved. The station fire protection

group and the licensee's training department have coordinated to

expano the scope and enhance the quality of brigade training. A

large core of qualified fire brigade members has been

established.

Security force, emergency response and maintenance training

appeared to be effective. No performance deficiencies directly

attributable to training were identified in these areas during

the period. INPO accredidation of all remaining training pro-

grams was received during the current assessment period.

In summary, licensee management has been active in improving the

overall quality of the training program and has been responsive

to NRC concerns. Licensed and nonlicensed training programs are

effectively implemented. Of particular value is the use of the

simulator, and other initiatives such as formal communications

training and establishment of an apprentice program. Efforts

should be continued to strengthen operator training in the area

of modifications and to ensure ef fective completion of training

for newly licensed personnel.

(2) Conclusion

Ratino: 2

Trend: None Assigned

^

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4.11 Assurance of Quality  ;

(1) Analysis

During this assessment period, Assurance of Quality is being

considered as a separate functional area. Management involve-

ment in assuring quality continues to be discussed and assessed

as an evaluation criterion in each of the other SALP functional

areas. The respective inspection hours are included in each

one. Consequently, this discussion is a synopsis of the assess-

l

ments relating to assurance of quality in other areas. Since

this is an evaluation of management's overall performance it

ennveys a broader scope than simply Quality Assurance (QA) -

department performance.

During the previous assessment period this functional area was

evaluated as a category 3. Licensea management had not been

ef fective in addressing recurring SALP concerns. Organization

and staffing were considered weak. Licensee management correc-

tive actions in response to Quality Assurance (QA) findings and

NRC issues had not been timely or comprehensive. QA department

'

performance and engineering initiatives were considered a

strength.

Quality Assurance effectiveness has been assessed on a day-to-

day basis. Three inspections focusing on the Quality Assurance

and Quality Control (QC) programs were conducted during this

l

period. In addition, the large number of management meetings

held during the period provided an opportunity for NRC manage-

ment to assess licensee management's approach to resolution of

I issues.

4

During much of the period licensee senior management continued

to assess and correct organizational weaknesses through restruc-

turing and recruitment of experienced personnel, many from out-

side sources. A new Senior Vice President assumed responsi-

bility for the nuclear organization at the beginning of the

period. In June, 1987 the Vice President-Nuclear Operations

resigned. That position remained vacant until January, 1988

when the Site Director position was created and filled. Station

management was reorganized several times, and significant

personnel changes were made. Four individuals served as plant

manager during the fifteen month assessment period. In addition

to modifying the line organization a temporary Planning and

Restart Group was created, working in parallel with the per-

manent plant staff to provide outage planning oversight. This

group was subsequently disbanded, incorporating its functions

into the permanent organization. The licensee also replaced

several mid-level managers during this assessment period in-

cluding the Operations Section Manager, Maintenance Section

.

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Manager, Radiological Section Manager and the Security Group j

Leader. In addition to changes in the line organization several

staf f assistant positions reporting to the Senior Vice President

were established to enhance senior management oversight of or-

ganization progress. Although actions in this area were imple-

mented slowly, it was evident that senior licensee management

took a careful and deliberate approach to establishing the

permanent organization and staff. Licensee management displayed

the intent to fill open positions in the organization with the

most highly qualified individuals available. This approach may

have delayed staffing efforts and initially slowed licensee

progress in areas such as maintenance and radiological controls.

Management policies and performance standards were strengthened

and are clearly understood through mid-level management. How-

ever, the new standards were not concurrently communicated or

adopted at the working level in some cases. As a result ex-

tensive management h olvement in routine activities is still

required to assure acceptable performance.

A high level of management involvement and commiteent was effec-

tive in promoting improvement in several SALP functional areas

which had previously been identified as significantly weak.

This is particularly evident in the areas of fire protection and

security where management acted to establish, staff and support

expanded oversight groups. This strong commitment is also evi-

denced by the organization-wide increases in permanent staff,

and the general reduction in reliance on contractors for augmen-

tation of line functions. One exception to this is in the area

of maintenance where vacancies and reliance on contractors

continues.

Licensee response to new NRC concerns raised during the period

was sometimes narrowly focused, and did not target resolution of ,

'

root causes. For example, a high level of NRC management

involvement was required to assure development of a comprehen-

sive Power Ascension Test Program, and to resolve overtime con-

trol deficiencies. Needed programmatic improvements in the area l

of maintenance were only implemented af ter prompting by the NRC. ;

This may reflect that available licensee resources were focused

on areas of previously identified weak performance and on outage

completion schedules. In some instances the licensee's written

replies to NRC concerns have been vague, incomplete, and did not ,

reflect the full extent of actions which had been taken at the

acility.

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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ . _ - _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

-

. 55

.-

The licensee initiated several programs designed,to upgrade per-

sonnel and plant performance. The plant Emergency Operating

Procedures (EOP) were upgraded, and evtensive E0P and communica-

tion training was conducted to enhar :e operator response capa-

bilities during abnormal and emergei y conditions. A fitness-

for-duty program was also instituted .nd applied to all licensee

and contractor personnel. In addi* lon, implementation of the

Safety Enhancement Program and the nation decontamination pro-

gram improved the plant physical design and candition. The

decontamination effort was particularly successful, resulting in

increased accessability to plant areas and a general positive

impact on personnel morale.

Licensee management took an active role in establishing long

term plans to address identified weaknesses. The Restart Plan,

the Material Condition Improvement Action Plan (MCIAP), and the

Radiological Action Plan (RAP) are examples. In the case of the

MIAP a team of contractors was created to provide ongoing

independent assessment of the plan's effectiveness in improving

plant material condition and maintenance practices. In the area

of radiological improvements the licensee reinstituted the

Independent Radiological Oversight Committee to provide senior

management with feedback on RAP effectiveness. The licensee

also implemented a self assessment process near the close of the

period. This self assessment was intended to provide a struc-

tured method by which licensee management could evaluate the

progress made, and identify remaining weaknesses.

The licensee's Quality Assurance (QA) and Quality Control (QC)

'

department continued to become more involved in station activ-

ities. The onsite QA surveillance group was increased in size,

,

l

and appeared to be actively involved in evaluating field activ-

ities. QA audit methodology was revised to enhance its effec-

tiveness, and an aggressive audit schedule was established. The

licensee made good use of technical experts during audits to

supplement available departmental resources. QA department ,

management took prompt action to focus attention on significant

concerns. For example, a stop work order was issued in response .

4

to adverse trends and findings in the area of saintenance on f

environmentally qual *fied equipment. Corporate and site manage-

ment response to QA findings has also improved. Both the pro-

gram controls and their application were strengthened to ensure

timely response to QA identified deficiencies. Overdue response

to these QA deficiencies are currently tracked as a performance

indicator,

i

f

- - _ - -

. . - . , . , - - - _ - - _ _ . _ _ _ _ _ . . , - - - - _ _ , _ . , ,

. - - - _ _ . _ _ _ , - _ .

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ ,

"

/

56

..

Throughout most of the assessment period, the licensee's corree-

tive action process was not always effective. A large number of

problem reporting devices exist, each with a unique origination,

review and disposition process. This makes use of the corree-

tive action system cumbersome, and weakens accountability for

followup and closecut. Lack of clear problem descriptions, and

delays between origination and followup, hampers establishment

of root cause and implementation of corrective actions. The

licensee has reviewed the process and recommendations to facil-

itate improvements have been made. However, the recommendations

were not implemented during this period.

In summary, licensee senior management has taken strong action

to develop and staff a viable station organization. High qual-

ity personnel have been recruited to fill key management posit-

ions. The reorganization and staffing process was not completed

until late in the SALP period. As a result, progress in some

functional areas, and in forcing management philosopy changes

down to the worker and first line supervisor level has been

hampered. The continuing need for a high level of management

participation in routine activities occasionally prevents

managers from focusing on other needed program improvements.

Overall, the licensee has been successfull in effecting signifi-

cant performance improve:eents in many areas. A high level of

management involvement is required to ensure that the initiated

improvements continue and are sustained.

.

(2) Conclusion

Rating: 2

Trend: None Assigned

.

'

.

.

? 57

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5.0 SUPPORTING OATA AND SUMMARIES

5.1 Investigation and Allegations Review

Twenty allegations were received during this SALP period. Eleven of

the allegations were investigated and found either to be unsubstan-

tiated or to be substantiated but of no safety significance. Five

allegations were investigated and substantiated, however the licensee

had either already instituted appropriate corrective actions or such

actions were promptly initiated in each case. Four allegations are

currently under review. One of these four concerns the licensee's

program for control of overtime which is the subject of ongoing

. reviews.

One investigation was initiated during the assessment period as a

result of an allegation regarcing a plant security vital area bar-

rier. This investigation is continuing.

5.2 Escalated Enforcement Action

Confirmatory Action Letter (CAL 86-10) was issued in response to a

series of operational events in April, 1986. CAL 86-10 requested

submittal of technical evaluations of these events and, stated that

NRC Regional Administrator approval would be required prior to

restart. The technical issues identified in CAL 86-10 have been

resolved. The CAL however was extended in August, 1986 and remains

open pending rese'eution of broader management concerns identified in

the previous SALPs and subsequent inspection reports.

Three violations were identified during the period for failure of the

licensee to ensure the integrity of security vital area barriers.

These three violations have yet to be characterized by severity

level, and are currently being considered for escalated enforcement

action. This action is pending conclusion of the OI investigation

described in Section 5.1 above.

An NRC Order issued in 1984 requiring the licensee to implement a

Radiation Improvement Program was closed during the period based on

the results of a special inspection and other program inspections

which indicated that all terms of the Order had been satisfactorily

completed.

Request for Action Under 10 CFR 2.206

On August 21, 1987, the Director of the NRC Office of Nuclear Reactor

Regulation signed an Interim Director's Decision in response to the

July 15,1986, 2.206 petition filed by Massachusetts State Senator

William B. Golden and others. The contentions raised in the petition

'

O

T.

58

..

regarding containment deficiencies and inadequacies in the radio-

logical emergency response plan were denied. A decision regarding

the management deficiencies was deferred to a subsequent response,

,

Three of the petitioners filed an appeal in federal court on

October 1, 1987.

On October 15, 1987, Massachusetts Attorney General James M. Shannen

filed a 2.206 petition, on behalf of his office and Governor

Michael S. Dukakis, requested an order to show cause why Pilgrim

should not remain shutdown until a full adjudicatory hearing resolves

the issues raised in the petition. The petition cites evidence of

continuing managerial, Mark I containmant, and emergency planning

deficiencies. An interim NRC response was issued on May 27, 1988,

just after the end of the SALP period.

5.3 Management conferences

Periodic management conferences and plant tours were conducted

throughout the SALP period. NRC Commissioners toured the plant and

met with licensee management on six occasions during the period. A

total of nine senior management conferences were held onsite or at

Region I. In addition to plant tours held in conjunction with onsite

management conferences, senior NRC managers performed two plant

inspections during the assessment period. NRC management partici-

pated in four public meetings in the vicinity of the plant. Two of

these public meetings were sponsored by the NRC and two by local

communities. Five meetings with state officials and legislative

committees were attended by NRC managers. The NRC also testified

before the United States Senate Labor and Human Resources Committee

regarding Pilgrim at a public hearing held in Plymouth, MA in

January, 1988. A chronological list of NRC management meetings and

plant tours conducted during the assessment period is contained in

Table 5. In addition, a summary of licensing meetings has been

included in section S.4(1).

To coordinate the planning and execution of NRC activities and to

assess the results of these activities a special Ptigrim Restart

Assessment Panel was formed. The panel is composed of senior members

of the Region I and Headquarters staffs. This panel met bimonthly,

with alternate meetinos na site.

_ _ - _ _ _ _ _ _ _ _ _ _ _

.$

59 1

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5.4 Licensing Actions

(1) NRR/ Licensing Meetinos and Site Visits

Date subject

May 21, 1987 Licensing Issues, Bethesda, MD

-

August 4, 1987 Emergency Operating Procedure and

Direct Torus Vent

'

,

September 24, 1987 Status of Pilgrim Restart / Schedule

August 19-20, 1987 Multi-Plant Action Items

August 24, 1957 Ongoing Fire Protection Reviews

December 10, 1987 Emergency Operating Procedures Upgrade

<

~

January 14, 1938 Discussion in Bethesda, MD of the in-

service test program development ,

,

'

(2) Commission Briefinos

Date Subject

i  !

'

February 12, 1987 Regional Administrators' Meeting  ;

(Ptigrim Included) l

December 17, 1987 Briefing on Status of Operating Reac- l

'

tors and fuel facilities (Pilgrim ,

Included)  !

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60 ,

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(3) Schedular Extensions Granted

Subject Date

Emergency Preparedness (EP) Exercise 12/09/87

Emergency Preparedness (EP) Exercise 05/11/88

(4) Reliefs Granted

Subject Date

Inservice Inspection Relief 03/26/87

(5) Exemptions Granted

_S_ubj ec t Date

'

Ouplicate Yard Lighting 10/06/87

10 CFR 50 Appendix R-Operator Action 04/14/88

(6) License Amendments Issued

Amendment No. Subject Date

98 New Design-Reactor 02/27/87

Control Rod Blades

99 Analog Trip System 03/03/87

Surveillance Requirements

-

100 Maximum Ait tge Planar 04/09/87

Linear Heat Generation Rate

101 Control Room Ventilation 06/23/87

System

'

102 Standby Liquid Control 08/05/87

System 10 CFR 50.62 Rule

103 Administrative Changes 08/05/87

per 10 CFR 50.4

104 Nuclear Safety Review and 08/25/87

Audit Committee changes

105 Cycle 8, Core Reload 08/31/87

o

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61

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(6) License Amendments Issued

Amendment No. Subject Date

106 Automatic Depressurization 09/04/87

System Timer

107 Analog Trip System - 10/28/87

Calibration Frequency

108 Undervoltage Relay Require- 10/29/87

ments

109 High Pressure Coolant 10/29/87

Injection and Reactor

Core Isolation Cooling

Requirements

. .

110 Rod Block and Average 11/30/87

Power Range Monitors

Trip Functions

111 Low Pressure Coolant 11/30/87

Injection Requirements

112 Standby Gas Treatment 01/20/88

& Control Room Air

Filter Systems

-

113 Primary Containment 01/21/88

Isolation Values 10 CFR 50

Appendix J Requirements

114 Fire Protection - 03/08/88

Appendix R to 10 CFR 50

Requirements

115 Security Requirements - 03/28/88

10 CFR 73.55

116 Modification of Reporting 05/10/88

Schedule Supplemental Dose

Assessment & Meterological

Summary

,, _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

,

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(7) Other Licensing Actions  ;

Action Date

Containment Leak Rate Monitor 02/19/87

10 CFR 50 Appendix J Review 02/19/87

(Penetration X-21)

Generic Letter 83-08, Mark 1 02/27/87

Orywell Vacuum Breakers ,

'

Recirculation Flow Anomaly 02/28/87

Process Control Program (PCp) 03/03/88

Review

Inservice Inspection Plan - 1956 03/16/87

Refueling Outage

Control Room Floor-Fire Seals 03/24/88

Smeke Seals - Conduit 03/24/88

I

Defects Westinghouse DC 04/13/88

Circuit Breakers

Steam Binding - Pumps 04/15/88 l

Pilgrim SALP Activity 05/15/87

10 CFR 50 Appendix R Review 05/15/87

NUREG-0737 Item !!.K.3.18 09/04/87

i

ADS Actuation Study

Offsite Dose Calculation Manual 10/28/87 [

Correct Performance of Operating 11/16/87 [

Activities

Intergranular Stress Corrosion 11/25/87 i

Cracking Augmented Inspection i

-

Program

Refueling Interlocks ,

12/17/h?

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63

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5.5 Licensee Event Reports

(1) Overall Evaluation

Licensee Event Reports (LER) submitted during the period ade-

quately described all the major aspects of the event, including

all corponent or system failures that contributed to the event

and the significant corrective actions taken or planned to pre-

vent recurrence. The reports were thorough, detailed, generally

well written and easy to understand. The narrative sections

typically included specific details of the event such as valve

identification numbers, model numbers, number of operable redun-

dant systems, the date of completion of repairs, etc., to pro-

vide a good understanding of the event. The root cause of the

event was clearly identified in most cases. Event information

was presented in an organized pattern with separ M headings and

specific inforeation in each section that led to a clear under-

standing of the event infortnation. Previons simila? occurrences

were properly referenced in LERs as applic..ble.

The licensee updated two LERs during the reporting period. The

updated LERs provided new information and the portion of the

report that was revised was clearly denoted by a vertical line

in the right hand margin, so the new information co01d be easily

determined by the reactor.

However, in the past the licensee's threshold for reporting

required monitoring. 4 LERs (87-021,87-022, 87-023, and

87-024) were submitted only af ter an audit by Region I. One of

these LERs,87-021, was submitted 10 months af ter the event. '

(2) Causal Analysis *

A review of the LERs indicates a number of problems, some recur-

ring. In particular, loss of offsite power has been a continu-

ing problem at Pilgrim. In addition, Pilgrim has experienced

repetitive events associated with inadequate procedures; admin- .

istrative control problems associated with failure to conduct l

adequate reviews prior to maintenance and required surveillances

and inadequate guidance and cautions for technicians.  ;

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - . - - - - - - - - - - _ - - - - - - - -

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Examples of unclear procedures included LER-87-015 which de-

scribes two events where RHR shutdown cooling was terminated by

spurious isolation. One isolation was attributed to a procedure

with inadequate instructions and cautions on installing jumpers;

the other isolaticn was due to inadequate procedures which

,

failed to describe the right number of jumpers. LER 87-016

describes an unplanned actuation of primary and f econdary con-

tainment due to inadequate administrative Con'.rol s for the

planned replacement of a relay coil, specifically lack of appro-

priate precautions and guidance. Furthermort the ever.t was

compounded by supervisory error in researching drawings, wiring

arrangements and assigning maintenance priorities.

Similarly, repeat problems can be illustrated by the followi.ig

two LERs. LER-87-018 described a failed coil in a logic relay

which caused a Reactor Vater Cleanup System isoittion. The

J licensee conducted a technical evaluation of similar coils,

<

identifying those requiring replacement. LER-SS-005 describes

an actuation of the Primary Containment Isolation Control System

and Reactor Building Isolation Control System due to a f ailure

of a simi)3r coil in another relay,

Our assessment of the 39 events in this reporting period

indicates:

- 16 involved either ap.inistrative control deficiencies, inade-

quate instructions, or inadequate procedures.

- 7 invc1ved errors by non-licensed personnel.

- As many as 8 may have involved design defects,

4 - As many as 19 may have been repeats of earlier or similar events

at Pilgrim.

(Note: events may be assigned cultiple causes)

In conclusion, the large number of events involving deficiencies in

L1ministrative controls, inadequate procedures and repeats of

earlier, similae events points to the need for close monitoring of

the effectiveness of licensee management in these areas.

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TABLE 1

TABULAR LISTING OF LERs BY FUNCTIONAL AREA

PILGRIM NUCLEAR POWER STATION

AREA CAUSE CODE

A B C D E X TOTAL

Plant Operations -

1

- -

2 4

1. 1

.

2. Radiological Controls - - - - - -

0

3. Maintenance and Modifications 4 -

1 7 6 1 19

4 Surveillance 4 - - 4 1 1 10

Fire Protectior. - - - - - - 0

5.

Emergency Preparedness - - - - - -

0

6.

-

7. Security and Safeguards 1

- - -

1 2

- - - - - 4

8. Engineering and 4

Technical Support

Licensing Activities - - - - - -

0

9.

10. Training and Qualification - - - - - -

0

Effectiveness

11. Assurance of Quality - - - - - -

0

.

""

TOTALS 10 4 2 11 7 5 39

Cause Codes: A - Personnel Error

5 - Design, Manuf acturing, Construction, or Installation Error

C - External Cause

D - Defective Procedure

E - Component Failure

X - Other

LERs Reviewed: 87-001-00 to 88-015-00 including 88-004-01 and 87-014-01

1

-.-.-----.- ._ ___

- __

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TABLE 2

INSPECTION HOURS SUMMARY (02/01/87 - 05/15/88)

PILGRIM NUCLEAR POWER STATION

Hours  % of Time

1. Plant Operations 2178 22

2. Radiological Controls 1262 13

3. Maintenance and Modifications 2347 24

4. Surveillance 1386 14 ,

5. Fire Protection 493 5

6. Emergency Preparedress 176 2

7. Security e.nd Safeguards 641 7

8. Ergineering and 1215 13

Technical Support

9. Licensing Activities * -

"

10. Training and Qualification -

Effectiveness  ;

11. Assurance of Quality " -

Totals 9698 I

,

• Hours expended in facility license activities and operator Itcense ,

activities are not included with direct inspection effort statistics. -

" Hoers expended la the areas of Training and Assurance of Quality are .

included in the other functional areas. l

c

Inspection Reports included: 50-293/87-06 to 50-293/88-22 i

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_ . _ _ , . _

____________ ________________ _ _ _ _ _ _ _ _ _ _ - _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

0 .

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TABLE 3

ENFORCEMENT $UWARY (02/01/87 - 05/15/88)

p!LGRIM NUOLEAR POWER STATION

t

A. Number and Severity Level of Violatfors

Severity Levet ! 0

Severity Level !! 0

Severity Level !!! 0

Severity Level IV 21

Severity Level V 2

Deviation 0

Total 26'

B '. Violations vs. Function Area

-

Severj_tyLevels

Functional Area 4  ! !!  !!! IV V Dev Total

- -

Plant Operations - - -

2 2

1.

Radiological C'ntrols - - -

8 - -

8

2. -

- - - 6 - 6

- 3. Maintenance and Modification - - -

- 1

4. Surveillance *

-

-

1

- -

1

'

5. Fire Protection - -

-

1

- -

- - 1

6. Emergency Preparedness 1

-

Security Safeguards - - - - - 3

7. - - -

- - 1

8. Engineering and 1

Technical $upport

- - - 0

9. Licensing Activities - - -

10. Training and Qualification - - - - - - 0

' Effectiveness -

11. Asturance of Quality - - -

1 2 3

a

26'

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Totals

.

• Three security violations are being considered for escalated enforcement

l

action and have not yet been categortred for severity.

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_ _ _ _ _ _ .

_ _ _ , _ _ _ . _ _

_ _ _ _ - _ _ _ _ _ _ _ _ _

.

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TABLE 4

Ptigrim SALP H1 story

Assessment Period

1/80- 9/40- 9/81- 7/82- 7/83- 10/84- 11/85- 2/47

Furetional Area 12/80 8/81 6/82 6/83 9/84 10/85 1/87 541)

Operations 2 3 3 2 2 3 2 2

Radiological

Controls 3 2 2 2 3 3 3 3 ,

survetilance 2 2 2 1 1 2 3 2

Maintenanse 2 3 2 2 1 2 2 2

Erergency

Planning 3 1 1 1 3 3 2 2

-

Fire Protection 2 2 3 1 2 3 2

Seenrity 2 2 2 2 2 2 3 2

Engineering and

Technical

- - -

Support - - - 1 1

Licensing - -

2 1 1 1 2 2

Training

- - 2 2

Effectiveness - - - -

Assurance of

Ovality /0A 2. 3 - - - - 3 2

-

Outage Etnagement 3 2 2 -

1 1 1

.

A

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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TABLE 5

MANAGEMENT MEE*. m 'jp PLANT TOUR StMARY

DATE SPONSOR TOPIC

02/02/87 NRC Management meeting at Plymouth, M to discuss

the status of licensee improvennt programs

(!R 87-08)

02/,03/87 Massachusetts NRC Region ! Administrator and other Region !

Secretary of managers met in Boston, M with several

Energy Cormonwealth administrators to discuss NRC

activities regarding Pilgrim

03/09/87 Massachusetts NRC Region ! Administrator and other members of

Legislature the staff appeared in Boston, MA before the

Massachusetts Joint Committee on the

Inv9stigation and Study of the Pilgrim Station

at Plymouth (!R 87-16)

03/10/67 NRC NRC Chairman Zech toured Pilgrim at e mpanied by

the Regional Administrator and attended a  :

licensee presentation (lR 87-16)

i

,

04/27/87 Massachusetts NRC Region ! Administrator and other members of

legislature the staff appeared in Boston before the Mass-

chusetts Joint Committee on the Investigation

and Study of the Pilgrim Station in Plymouth  ;

(IR87-18)

05/01/87 NRC Management meeting at NRC Region ! *,o discuss a

surveillance program violation and program

weaknesses (!R 87-23) ,

,

05/07/87 NRC 1987 5 ALP management meeting at Plymouth, E  ;

05/22/3' NRC NRC Commissioner Carr toured the plant and f

attended a Itcensee presentation ,

05/27/87 Plymouth Four NRC Region I sanagement representatives

Soard of participated in a public meeting in

Selectmen Plymouth, M

06/24/87 NRC NRC Commissioner Anselstine toured the plant and

attended a l'. centre presintation

. - -

% ,

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Table 5 2 )

o

DATE SPONSOR TOPIC

06/29/87, NRC Management meeting at NRC Region I to discuss

the outage status, program improvements and

licensee preparations for restart (IR 87-28)

07/23/87 Commonwealth The NRC Section Chief, Licensing Project Manager

of Mass. and Resident Inspectors for Pilgrim met onsite

with representatives of the Commonwealth to

discuss the NRC inspection prneess (IR 87-27)

09/09/87 NRC Enforcement conference at NRC Region I to

discuss several security violations (IR 87-30)

>

09/24/87 NRC NRC Director of the Office of Nuclear Reactor

Regulation, the Region I Administrator and other

senior NRC managers met with the licensee in

Bethesda, MD to discuss licensee activities and

restart readiness (NRR meeting transcript)

b'

09/30/87 NRC Enforcement conference at NRC Region I to

discuss several security violations (IR 87-30)

10/05/87 NRC NRC Commissioner Bernthal toured the plant and

attended a licensee presentation

10/08/87 Commonwealth NRC Region I Administrator and other senior NRC

of hass. managers met at Region I with representatives of

the Commonwealth of Mass, and two private

citizens to answer questions regarding the NRC

inspection process (IR 87-45)

10/29/87 Duxbury Board Four NRC Region I and NRR management

of Selectmen representatives participated in a public meeting

sponsored by the Ouxbury Board of Selectmen,

Du>. bury Emergency Response Plan Committee and

the Duxbury Citizens' Committee on Nuclear

Matters in Duxbury, M

12/08/87 NRC NRC Region I Administrator toured

the plant and met briefly with licensee

management to discuss tour observations (IR

. 87-57)

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• Table 5

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0 ATE Sp0NSOR TOPIC

01/07/88 United NRC Director of the Office of Nuclear Reactor

States Regulation and the Region I Administrator

Senator appeared before the Senate Labor and Human

Kennedy Resources Committee regarding Pilgrim. The

public hearing was held in Plymouth, Ma.

.

02/18/88 NRC NRC Region I and NRR managers conducted a public

meeting in Plymouth, MA to solicit

public comments on the licensee's Restart Plan

.

02/24/88 NRC Management meeting at NRC Region I to discuss

the licensee's self assessment process to be

used for determining restart readiness (IR

88-10)

03/10/88 NRC The NRC Director of the Office of NRR and the

Region I Administrator toured the plant and

interviewed licensee staff regarding the design

basis for the direct torus vent modification (IR

88-07)

04/08/88 NRC Management meeting at NRC Region I to discuss

the IP,ensee's proposed power ascension test

program (Meeting Minutes 88 *'

04/22/88 NRC NRC Commissioner Carr toured t.4 plant and

attended a licensee presentation (IR 88-12)

NRC Commissioner Rogers toured the plant and

05/06/88 NRC

attended a licensee presentation (IR 88-19)

05/11/88 NRC NRC Region I and NRR managers conducted a public

meeting in Plymouth, MA to provide

responses to comments and concerns on the

licensee's Restart Plan raised during the

2/18/88 public meeting (Meeting transcript)

.

.a

5:

ENCLOSURE 3

SALP Management Meeting Attendees

U.S. Nuclear pegulatory Commission

W. Russell, Regional Administrator

S. Collins, Deputy Director, Division of Reactor Projects (ORP)

S. Ebneter, Director, Division of Radiation Safety and Safeguards (DRSS)

J. Wiggins, Chief, Reactor Projects Branch No. 3, DRP

R. Bellamy, Chief, Facilities Radiological Safety and Safeguards Branch, DRSS

A. Blough, Chief, Reactor Projects Section No. 3B, ORP

L. Doerflein, Project Engineer, DRP

C. Warren, Senior Resident Inspector

J. Lyash, Resident Inspector

B. Boger, Assistant Director for Region I Reactor, Office of Nuclear

Reactor Regulation (NRR)

R. Wessman, Director, Project Directorate I-3, NRR

0. Mcdonald, Project Manager, NRR

Boston Edison Company (BECo)

S. Sweeney, Chairman and Chief Executive Officer

R. Bird, Senior Vice President - Nuclear

R. Ledgett, Director, Spec 41 Projects

K. Highfill, Station Direct *

E. Kraft, Manager, Plant Support Department

J. Alexander, Manager, Plant Operations Section

J. Seery, Manager, Technical Section

R. Sherry, Manager (Acting), Plant Maintenance Section

J. Jens, Manager, Radiological Section

D. Long, Manager, Security Section

F. Wozniak, Manager, Fire Protection Division

D. Gillespie, Manager, Nuclear Training Department

F. Famulari, Manager, Quality Assurance Department

R. Grazio, Manager, Regulatory Section

R. Swanson, Manager, Nuclear Engineering Department

J. Howard, Vice President, Nuclear Engineer

E. Wagner, Staff Assistant to the Senior Vice President - Nuclear

L. Schmeling, Program Manager, Special Projects

O_ther Attendees

P. Agnes, Assistant Secretary of Public Safety, Commonwealth of

Massachusetts

P. Chan, Commonwealth of Massachusetts

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p E'iCLOSURE 4

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eosnwasm

, Pilgrim H.sclear Ptmer station

Rc:ky Hdi Road

Plymouth, Massachusetts 0236o

Ralph G. Bird

senior Vice President - Nuclear

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BECo Ltr. #88-137

U.S. Nuclear Regulatory Commission

Attn: Document Control Desk

Hashington, D.C. 20555

Docket No. 50-293

License No. DPR-35

Subject: Response to Systematic Assessment of Licensee

Performance Board Report No. 50-293/87-99

Dear Sir:

Attached is Boston Edison Company's response to the Systematic Assessment of

Licensee Performance (SALP) Board Report for Pilgrim Nuclear Power Station

(PNPS) covering the period February 1, 1987 through May 15, 1988.

Boston Edison Company's management review of the SALP Report concluded that

overall, the NRC has recognized our efforts and success in improving the

material condition, programs, and staffing at PNPS. He have proven our

ability to self-assess and to set and meet rising standards of excellence.

During the Power Ascension Program, we will demonstrate that we can sustain

this success.

He understand that the NRC will consider, as part of the SALP review process,

the information contained in Attachment i for the specific functional areas of

Radiological Controls, and Training and Qualification Effectiveness.

.

L

.G Bird

RLC/jmk

Attachment 1

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U.S. Nuclear Regulatory -2- Septe:ber 19, 1988

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Commissior. BECo Ltr. #88 137

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cc: Mr. William T. Russell

Regional Administrator

U. S. Nuclear Regulatory Commission

Region I

475 Allendale Road

King of Prussia, PA 19406

Mr. D. G. Mcdonald

Project Manager

Division of Reactor Projects I/II

U. S. Nuclear Regulatory Commission

Mail Stop #1401

One White Flint North

11555 Rockville Pike

Rockville, MD 20852

Senior NRC Resident Inspector

Pilgrim Nuclear Power Station

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ATTACHMENT 1

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Boston Edison Company BECO Ltr. #88 137

Pilgrio Nuclear Power Station Docket No. 50-293

, License No. DPR-35

RESPONSE TO SYSTEMATIC ASSESSMENT OF LICENSEE

PERFORMANCE BOARD REPORT NO. 50 293/87-99

A. Radioloaical Controls

Boston Edison's performance, management involvement, and commitment of

resources in the Radi0 logical Controls functional area indicate

substantially improved overall pet;formance in this area during the 87-99

SALP period, particularly during the latter portion of the period. The

NRC staff stated that Boston Edison's "performance in the areas of REMP

(Radiological Environmental Monitoring Program) and Transportation (of

radioactive waste) reflected substantial improvement" (and) "would

receive the highest performance category rating if rated separately"

(SALP 87-99, Page 22). Continued improvements above the levels

described in the 87-99 SALP Report for the Radiological Controls Program

were confirmed during the course of the Integrated Assessment Team

Inspection (IATI). NRC Region 1 Inspection Report 50-293/88-21 (IATI

Report Page 4).

Several factors indicated substantially improved performance in the

radiological ;ontrols area. The plant achieved 90 percent

decontamination during the assessment period. Substantial reductions in

the numbers, types, and levels of personnel contaminations were

obtained. Boston Edison also formed a task force and virtually

eliminated high radiation area violations.

Boston Edison improved its performance in the specific areas of

potential weakness that had been identified in the 86-99 SALP Report.

The exposure goals for the ALARA program were reduced to 390 person

tem in 1988 which is 20 percent below the industry average.

Personnel exposures are tracked daily to allow for early correction

of any undesirable trends. A source-term reduction program has

been implemented. The Plant Manager who has extensive experience

in ALARA programs was appointed as chairman of the ALARA Committee.

Several actions were taken to increase the experience and

qualifications of radiation protection personnel. An

INPO-certified training program was estabiished. Health Physics

(HP) technicians and supervisors who are currently on shift

continue to receive additional training. The radiation protection

organization staffing is virtually complete with over 90 percent

being permanent employees.

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Boston Edison has taken aggressive actions to correct identified

problems and reduced the number of outstanding radiological

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issues. The backlog of Radiological Occurrence Reports (RORs) has

been eliminated. The number of RORs generated has dramatically

decreased while the quality of the reports has improved. RORs are

resolved in a timely manner. Senior management mor.itors the ROR

program to ensure aggressive corrective action for identified

weaknesses.

In SALP 87-99 the NRC Staf f indicated that substantial progress had been

made in programs for control of radiation at Pilgrim Nuclear Power

Station (PNPS) during the last half of the assessment period. Boston

Edison implemented several programs to ensure that this trend

continues. These programs, which were implemented in the last half or

after the assessment period, include:

the Radiological Action Plan that is now approximately 75 percent

complete;

an ALARA Design Manual was issued and formal training on the manual

is approximately 50 percent complete;

Boston Edison embarked on programs to eliminate radioactive leaks

and reduce the number of people required to wear dosimetry;

spill kits and operator aids are now in place;

spill drills and associated training for H.P. technicians is

ongoing; and

contamination control and ALARA training for senior and middle

management as well as Radiation Awareness training for craft and

operations has been implemented.

The IATI Team concluded "with high confidence, that the management

controls programs and personnel are generally ready and performing at a

level to support safe start up and operation of the facility" (IATI

Report, Page 4). "The inspection confirmed the results of the (87-99)

SALP Report . . . and validated the general SALP conclusion that

performance was improving at the end of the SALP period. Further,

licensee performance appeared to be consistent or improving in all

functional areas examined during the IATI, with the current level of

achievement for overall safety performance equal to or better than that

described in the SALP. For . . . Radiation Protection the performance

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was notably improved" (IATI Report, Page 4).

Boston Edison recognizes that radiological controls are everyone's

responsibility, not just the Radiological Section's, and that message is

being widely disseminated and reinforced throughout our organization.

It is on the agerda of our weekly management meetings; we post data on

the program throughout the site and emphasize radiological safety in

work force information programs. A Senior Radiological Engineer has

been assigned to the Quality Assurance Department to improve oversight

in this area. Tht Planning Department now includes experienced

radiation control personnel in order to reduce personnel exposure.

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f. .'.

Boston Edison believes that the management involvement, program

development, and resources expended in the area of radiation protection

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have substantially increased the level of performance and will continue

to improve radiological performance in the future.

B. Trainina and Oualification Effectiveness

Boston Edisen agrees with the SALP Report assessment that Training and

Qualification Effectiveness has improved significantly. Boston Edison

believes that as a result of management involvement and licensee

resources committed to Training, suoerior oerformance was achieved.

Moreover, Boston Edison believes that its actions to improve in the area

of Training and Qualification Effectiveness have resulted in and will

continu' to result in a sustained trend of improvement. The results of

the NRC's IATI support this view (IATI Report, Page 4). In further

support, Boston Edison submits the following information for

consideration by the NRC in its SALP evaluation process.

SALP 87-99 evaluated 11 functional areas. Comparison of the 12 areas

, evaluated in SALP 86-99 to those in 87-99 shows the following:

i same (Category 2 ratings or better) in six areas;

increasing trends in two areas; and

increased ratings in four areas.

These results underscore the effectiveness of Boston Edison's training

programs. Boston Edison also received full INPO accreditation for all

major training programs. This shows that the training performance

substantially exceeds those necessary under regulatory standards and is

indicative of a high level of Boston Edison management attention and

involvement.

Boston Edison has made substantial resource commitments to the training

of plant operators. Boston Edison installed a site-specific simulator

at the Pilgrim Station training center and used it aggressively for

l training and procedural development and validation. This included

enhanced Operator training on the revised Emergency Operating Procedures

(EOP's). A component of the E0P training was formal communications

training for Operations personnel. In addition, full-time training

instructors are provided on every shift with Operator trainees. Boston

Edison achieved a 100 percent pass rate for two consecutive classes; 8

out of B candidates passed the NRC's Reactor and Senior Reactor Operator

{ licensing examinations for each class during the SALP period. Moreover,

the candidates in both classes passed with exceptionally high grades,

averaging over 90 percent. Boston Edison has also developed on-shift

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training programs for newly-licensed operators and will implement those

programs during the Power Ascension program.

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ATTACHIEFT 1

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As was indicated by the SALP Report, Boston Edison has made significant

, improvements in training for other disciplines. Additional improvements

that may not have been fully credited in the SALP Report include:

the development and implementation of the Nuclear Training

Improvement Action Plan;

the use of peer evaluators from the Training Department in

Maintenance, Operations, Chemistry, and Radiation Protection;

the Radiological Protection Management Personnel College Degree

Program (the college degrea program for plant operators will begin

in 1989);

spill drill and glove bag training for appropriate plant personnel

in order to reduce radioactive contamination;

Work Control Process training for the majority of the Nuclear

Organization;

INPO-type Observation tr.ining for selected Pilgrim Station

personnel; and

coordinated Human Performance Evaluation System training ftr

selected personnel.

Furthermore,, Boston Edison has taken several actions to ensure

. subsequent improvements in performance in this area. These actions

include:

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integration of the new procedures group to ensure that procedures

and training are complementary with a single point of

accountability;

development of a human performance evaluation program sponsored by

INP0 to ensure that lessons are learned from operating experience

and integrated into the training program and procedures where

appropriate;

strengthening operator training on plant modifications and

completing training for new licenses;

initiatives to sensitize personnel to ALARA concerns to aid in

minimizing personnel exposure; and

the extension of formal communications training to Health Physics,

Maintenance and Chemistry personnel.

The training program at PNPS is designed to bring about sustained

improvements and performance beyond regulatory requirements. A

sustained iniproving performance trend is evident for Operations and

other Station personnel and the results of the IATI confirm this trend.

Boston Edison has committed substantial resources and management

attention to the training and qualifications of personnel at PNPS,

thereby demonstrating to the Nuclear Organization the importance of

performance in accordance with documented standards for Pilgrim Station

and the Company's commitment to rising standards of excellence.

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