IR 05000293/1984034

Revised SALP Rept 50-293/84-34 for Jul-Sept 1984

ML20127E360
Person / Time
Site:	Pilgrim
Issue date:	06/19/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
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ML20127E351	List: IR 05000293/1984034 ML20127E347
References
50-293-84-34, NUDOCS 8506240529
Download: ML20127E360 (53)

Text

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ENCLOSURE 1 i

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-293/84-34 BOSTON EDISON COMPANY j PILGRIM NUCLEAR POWER STATION ASSESSMENT PERIOD: JULY 1, 1983 - SEPTEMBER 30, 1984 BOARD MEETING DATE, NOVEMBER 13, 1984 i

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SUMMARY............................... 37 TABLE 2 - VIOLATION SUMMARY...................................... 38 TABLE 3 - INSPECTION REPORT ACTIVITIES........................... 42 TABLE 4 - TABULAR LISTING OF LERS BY FUNCTIONAL AREA............. 45 TABLE 5 - LER SYN 0PSIS........................................... 46 TABLE 6 - SELECTED LICENSING ACTIVITIES.......................... 49 L

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I. INTRODUCTION A. Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect the available observations and data on a periodic basis and to evaluate licensee performance based upon this in-formation. SALP is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's man-agement to promote quality and safety of plant construction and opera-tion.

A NRC SALP Board, composed of the staff members listed below, met on November 13, 1984 to review the collection of performance observations and data to assess the licensee performance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this report.

This report is the SALP Board's assessment of the licensee's safety per-formance at the Pilgrim Nuclear Power Station for the period July 1,1983 to September 30, 1984.

B. SALP Board Members

'R. W. Starostecki, Director, Division of Project and Resident Programs (DPRP)

J. H. Joyner, Acting Director, Division of Engineering and Technical Programs,(DETP)

E. Wenzinger, Chief, Projects Brancl, No. 3, DPRP L. E. Tripp, Chief, Projects Section No. 3A, DPRP J. R. Johnson, Senior Resident Inspection, Pilgrim W. Minners, Chief, Safety Program Evaluation Branch, NRR P. Leech, Licensing Project Manager, ORB No. 2, Office of Nuclear Reactor Regulation (NRR)

L. H. Bettenhausen, Acting Chief Engineering Programs Branch, (DETP)

W. J. Pasciak, Acting Chief, Radiological Protection Branch, DETP Other Attendees l

'G. Meyer, Project Engineer, RPS 3A, DPRP l M. H. McBride, Resident Inspector, Pilgrim l

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C. Background 1. Licensee Activities The facility operated from July 1, 1983 to December 10, 1983. Fuel burnup limited power during this period. Two unplanned shutdowns and three scrams occurred during the period, causing outages which lasted from one to four days. The unplanned shutdowns were caused by excessive reactor coolant system leakage inside the drywell and the failure of a reactor core isolation cooling valve to close.

Two of the scrams were caused by false low water level indications during surveillance tests. The third scram was caused by a mal-function in the steam pressure regulation system during a planned shutdown.

On December 10, 1983, the plant shut down to inspect primary system piping for indications of intergranular stress corrosion cracking (IGSCC). These indications were detected and the plant remained shut down until the end of the assessment period for a piping re-placement and refueling outage. Significant activities during the outage included: 1) a chemical decontamination of the recirculation system and portions of other primary coolant systems; 2) inspection and replacement of recirculation system piping and portions of residual heat removal system, core spray system, and reactor water cleanup system piping; 3) installation of post accident sampling systems; 4) control rod drive inspections and repair; 5) torus modifications; 6) an extensive valve inspection and maintenance program; 7) replacement of three feedwater heaters; 8) replacement of most HFA electrical relays; 9) overhaul of both emergency diesel generators, and 10) scram discharge volume modifications.

The licensee conducted an annual emergency exercise on August 15, 1984.

2. Inspection Activities Two NRC resident inspectors were assigned to the site during the assessment period. A total of 4,960 inspection hours were spent reviewing the licensed program. The distribution of inspection hours is shown in Table 1. Listings of violations and NRC inspec-tion activities are shown in Tables 2 and 3, respectively.

A significant portion of the inspection effort during the assessment period involved reviews of outage activities, including an indepen-dent verification of nondestructive test results by personnel using the NRC NDE van on July 30 to August 10, 1984. Welding activities were reviewed during the outage in two routine specialist inspec-

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tions.

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a team of specialist and resident inspectors. A remedial exercise was required and was scheduled after the assessment period.

Special inspections of licensee radiological controls over work in the control rod drive repair room were conducted on January 20 to l 27, 1984, August 6 to 10 and 24, 1984 and on September 26 to 27,

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II. CRITERIA Licensee performance is assessed in selected functional areas, depending on whether the facility is in a construction, preoperational, or operating phase. Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas. Special areas may be added to highlight significant observations.

One or more of the 1,110 wing evaluation criteria were used to assess each functional area.

1. Management involvement and control in assuring quality 2. Approach to resolution of technical issues from a safety standpoint 3. Responsiveness to NRC initiatives 4. Enforcement history 5. Reporting and analysis of reportable events 6. Staffing (including management)

7. Training effectiveness and qualification However, the SALP Board is not limited to these criteria and others may have been used where appropriate.

Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categories. The definitions of these performance categories are:

Category 1. Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of

~ performance with respect to operational safety or construction is being achieved.

Category 2. NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and are concerned with nuc-lear safety; licensee resources are adequate and reasonably effective so that satisfactory performance with respect to operational safety or construction is being achieved.

Category 3. Both NRC and licensee attention should be increased. Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with re-t spect to operational safety or construction is being achieved.

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The SALP Board has also categorized the performance trend over the course of the SALP assessment period. The categorization describes the general or prevailing tendency (the performance gradient) during the SALP period. The performance trends are defined as follows:

Improving: Licensee performance has generally improved over the course of the SALP assessment period.

Consistent: Li:ensee performance has remained essentially constant over the course of the SALP assessment period.

Declining: Licensee performance has generally declined over the course of the SALP assessment period.

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i III. SUMMARY OF RESULTS

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A. Overall Facility Evaluation During the current assessment period, weak performance was noted in radiological and contamination controls and emergency preparedness func-tions. Health physics activities during the piping replacement outage were generally adequate; however, the licensee had significant difficulty controlling the dismantling of control rod drives, and disseminating information to technicians. Although overall improvements continued in .

the operations area, a continuing problem is an inadequate number of I licensed operators.

l The licensee was observed to exhibit a strong corporate commitment to '

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improving the condition of plant equipment and providing much needed training, maintenance, office and warehousing facilities. Another note-worthy strength continued throughout this assessment period, n mely, effective communications between supporting departments and the station as well as direct involvement by senior corporate personnel.  ;

The licensee's management has demonstrated their aggressive attention to problem areas can result in radical improvements. However, declining performance occurred in functional areas which were severely stressed by the nature and magnitude of the on going activities or which did not receive adequate management attention.

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ORIGINAL PAGE

Facility Performance Category Category Function ( Area Last Period This Period Trend (July 1, 1982- (July 1, 1983 -

June 30, 1983) Sept. 30, 1984)

1. Plant Operations 2 2 Improving 2. Radiological Controls 2 3 Declining 3. Maintenance 2 1 Improving 4. Surveillance 1 1 Consistent 5. Fire Protection / 1 2 Declining Housekeeping 6. Emergency Preparedness 1 3 Declining 7. Security and Safeguards 2 2

1. Consistent 8. Refueling and Outage Insufficient 1

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Management Basis 4 Consistent 0p 9. Licensing Activities 2 1 oving

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B. Facility Performance l Category Category Functional Area Last Period This Period Trend i (July 1, 1982- (July 1, 1983 -

j June 30, 1983) Sept. 30, 1984)

l 1. Plant Operations 2 2 Improving

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2. Radiological Controls 2 3 Declining 3. Maintenance 2 1 Improving i

! 4. Surveillance 1 1 Consistent

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5. Fire Protection / Housekeeping 1 2 Consistent (

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6. Emergency Preparedness 1 3 Declining 7. Security and Safeguards 2 2 Consistent i 8. Refueling and Outage Insufficient 1 Consistent Management Basis

, 9. Licensing Activities 2 1 Improving

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IV. PERFORMANCE ANALYSIS A. PlantOperations(24%),

1. Analysis During the previous assessment period, problems were identified in the areas of notification and reporting, receipt inspection, Q-List updating, FSAR updating, tagging procedure implementation, and

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documentation of operator qualification. Licensee corrective ac-tions were effective in preventing recurrence of problems in these areas during this assessment period.

During the current assessment period, this functional area was under

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routine review by the resident inspectors. Region-based specialist inspectors reviewed the quality assurance program and other man-agement controls. Routine plant system operations were only con-ducted for the first third of this assessment period because of a lengthy outage beginning in December, 1983, a. Staffing and Training The licensee has maintained adequate station staffing with few vacancies, but has not implemented six operating shifts due to a shortage of licensed operators. Operators are often assigned self-study courses to make up for training classes that are missed due to work assignments. The licensee scheduled twelve-hour shifts in order to compensate for staff vacations. The licensee plans to increase the nunber of licensed personnel in the Operations Depart-ment from the current level of 15 reactor operators and 10 senior operators to 29 reactor operators and 16 senior operators. This increase is substantial, but may be very difficult to achieve based upon past experience. Additional management attention is required to recruit and train operators.

The licensee recently identified problems in the licensed reactor operator training program and cancelled a scheduled NRC license exam. Specifically, a contractor audit performed at the request of the licensee indicated weak prepration, in part, due to self-study. The postponement of the NRC exam indicates a desire on the part of the licensee for high quality performance and will slow the attainment of shift staffing goals. Senior licensee management is evaluating the training problems and plans to revise the program.

The licensee has shown initiative in training shift technical ad-visors and the Chief Technical Engineer for senior reactor operator licenses. However, more management attention is needed to additional watch engineers (SR0s) for control room manning. provide

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Management support for other Training Department programs was l demonstrated by the completion of a new training facility during

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in the facility. This support was also evidenced by new labs and l equipment, I&C simulator on order, and a significantly increased

training staff. The licensee intends to seek INP0 accreditation I for the site training program in 1985 and has formalized a training l program for engineers, b. Control of Operations Control over station activities has been improved by the implemen-

! tation of an extensive component labeling program in the station

and by the installation of a new tag status board in the control room. However, several problems were observed regarding safety

, system procedure preparation and implementation. Examples include

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improper operation of core spray system vent valves and repetitive errors in the position specified in procedures for a containment block valve. This indicates a need for additional supervisory de-tail in monitoring safety system valve positions.

The licensee has been slow to implement TMI Task Action Plan item I.C.6 concerning procedures fur verifying correct performance of operating activities. While the licensee is currently incorporating

, independent verification into portions of the operations program, l the length of time taken to implement the verifications and the incompleteness in committed scope indicates inadequate management <

support to this area. Repeated requests for clarification of lic-l ensee plans for improvement in this area have been made by the NRC without resolution. Increased station management attention is con-sidered necessary to ensure that safety related activities (proce-l dures) such as valve alignments, maintenance, and testing are in- :

dependently verified.

Safety Review Committees (both onsite and off-site) meet frequently and have been observed to conduct comprehensive and probing discus-l

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sions of plant events. The members of the onsite committee are also key station management personnel and on some occasions, seem to be spending an inordinate amount of time in these meetings. Actions have recently been taken to streamline the committee review process, reduce the backlog of procedures and event reports to review, and l to propose changes in membership. The licensee is encouraged to I continue these initiatives in order to ensure that the time spent in these meetings does not detract from the other responsibilities l in the plant.

c. Reporting and Followup The licensee was more effective in tracking and resolving NRC in-spection findings during this SALP period than in the past. The compliance group staff (which tracks NRC inspection findings and

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licensee commitments and reviews items for reportability to the NRC)

was increased in size during the period. The licensee also improved their system for tracking and monitoring progress towards resolving INP0 findings, significant event reports, and other industry opbr- l ating experience.

The licensee event reports (LER's) submitted were adequate in each important respect with few exceptions. The LER's provided clear descriptions of cause and nature of the events as well as adequate explanations of the effects on both system function and public safety. Some of the LER's provided supplemental information in attachments to the LER forms. This enabled the LER reviewer to better understand the nature of the events encountered, greatly facilitating evaluation of the safety significance of the event.

The described corrective actions taken or planned by the licensee were considered to be commensurate with the nature, seriousness, and frequency of the problems found. A tabular listing and synopsis of LERs are in Tables 4 and 5, respectively, d. Management Involvement and Review A new administration and warehouse facility was placed into opera-tion during tte assessment period. This provides much needed space and equipment for office and clerical support, a new machine shop, an I&C calibration laboratory, and a state of the art warehouse.

This resource commitment, along with the comprehensive plant repairs during the outage and the procurement of a plant simulator, is in-dicative of management support for improving quality of equipment and facilities and increased morale.

Senior corporate management continued to work closely with station personnel during the current assessment period with weekly, monthly, and semi-annual meetings held between department and senior corpor-ate managers. In addition, at least one quarterly meeting of the Nuclear Oversight Committee of the Board of Directors is held at the station each year. Senior management have been observed touring the station several times during the piping replacement outage.

Continued corporate management support for full implementation of the Performance Improvement Program (PIP) has been evident. Close monitoring of site activities by corporate officials and improved communications within the organization resulted in the NRC termin-ating a requirement of the January 18, 1982 Order for a daily audit of plant operations by a corporate representative. Although im-provements in plant operations which are directly a result of the PIP have not yet been readily visible, it is expected that the completion of the two remaining milestones (design document and procedure update programs) will improve the accuracy of operating documents. The continued retention of Management Analysis Corpor-

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ation as an independent advisor and regular meetings of the Nuclear !

Oversight Review Committee of the Board of Directors demonstrate j the licensee's support for this oversight role. ,

e. QA for Operations l

Considerable improvement was evident in the control and effective- ;

ness of the design change program in response to NRC findings in s l

early 1982. Management attention in this area has brought the '

i program into full compliance with the requirements of ANSI N45.2.11. i Additional quality assurance involvement in the program was also 3 noted.  !

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! The previous SALP report stated that the quality assurance program l l did not aggressively seek correction of previously identified QA ~

l audit deficiencies and that the scope of routine QA surveillances i

! should be expanded. Licensee management attention has strengthened ,

j both of these areas. The backlog of open QA audit deficiency re- l ports has been greatly reduced due to corporate management attention :

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and initiatives. J Quality assurance audits and inspections were generally well in-plemented and thorough, although a problem was identified during the assessment period involving a lack of scheduling of audits of ;

contractor work. Procedures for the quality assurance program were i i

well written and explicit. Corrective actions for audits and non- !

l conformance reports were slow, but improving. Relations between l quality assurance personnel and the plant staff have improved due i to senior management attention. The quality controls staff Level -

, II and Level III inspectors were knowledgeable and qualified in accordance with ANSI 45.2.6.

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In January 1984, the licensee expanded the routine quality assur-ancesurve}11anceprogramtoincludeactivitiessuchasoperations, i routine surveillance testing, chemistry, and health physics. How- !

ever, a backlog of uncorrected surveillance findings has accumulated l since that time with corrective actions as much as six months over- l due. Senior corporate management is aware of the problem and has L given priority to reducing the backlog. Continued management at-l tention is needed to ensure that QA surveillance findings are re-i solved in a timely manner and that a bac V an does not continue as t happened in the past with Deficiency Report %%i ktion Items.

l 2. Conclusion

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f 3. Board Recommendation Licensee - Increase managet..ent attention to improve the quality of reactor operator training, ensure implementation of TMI Task Action Plan item I.C.6, and reduce the backlog of quality assurance sur-veillance reports.

NRC - Meet with licensee to discuss how Safety Review Committee (s)

work load can be decreased.

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l B. Radiological Controls (13%)

1. Analysis Seven inspections conducted by region-based radiation specialists, including two special inspections to review the circumstances sur-i rounding Itcensee corrective actions for unplanned extremity expo-

! sures, plus resident inspector review of ongoing radiological con-trols activities form the basis for this assessment. Program areas examined included the licensee's radiation protection, radioactive waste management', effluent controls and monitoring and radioactive

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waste transportation. Twelve violations and two deviations were identified, a Civil Penalty was assessed and a Confirmatory Action

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Letter was issued. The number and nature of these identified prob-lems are indicative of programmatic problems in the Radiological Controls Program.

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a. Radiation Protection l

The licensee's radiation protection organization for routine oper-ations was defined, responsibilities and authorities for all post-tions in the organization were established, and staffing was ade-

quate to support routine activities. In planning for the extended

! outage, the licensee hired about 100 senior level contractor radi-l ation protection technicians to augment the organization, and ex-panded the ALARA Group from 1 to 12 positions. However, authorities and responsibilities for the augmented organization were not well defined. This lack of defined responsibilities and authorities contributed in part to several breakdowns in radiological controls

, discussed later in this assessment.

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l The licensee has initiated action to upgrade the radiation protec-l tion organization. The licensee is separating the currently com-bined Chemistry and Radiation Protection Organization into two i separate organizations and has hired a contractor to evaluate, i

among other items, the adequacy of-the Radiation Protection Organi-

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zation. The contractor evaluation was initiated in September 1984 l and is expected to last three months. The licensee's action in this l area should help improve control of rcdlological tasks.

A defined initial selection, qualification and training program is l

in place for licensee and contractor radiation protection personnel.

l Personnel hired to augment the organization during the extended l outage were adequately trained and qualified. However, the licen-

! see's retraining program for training radiation protection techni-I cians in new procedures, procedure changes, and memoranda was in-

! formal, not well defined, and not effective. No criteria had been established to define which personnel were to be trained in various procedure changes and no effective program was in place to ensure all appropriate personnel were cognizant of the changes. Also, no i

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N effectivs , controls were in place to; ensure that new radiation pro-tection suphrvisors-(upgraded from technicians) would be trained *

in all guidance previously issued by management. ,

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The licensae; subsequently initiated a sign-6ff type system to as-surethatappropriatepersonnelwereproperlpreviewingapplicable material.! Howeveh,' sign'-offs were often not'being completed due l to a shift'of responsible personnel to oth'er tasks and a general lack.of supervisory oversight of the process. As a result, there was little assurance'that-all appropriate radiation protection

. personnel, . including iTupervisors, were c6gnizant of procedure j changes ^and important memoranda issued following a January 1984 unplanned personnel extremity exposure. This condition existed untir NRC identification in August 1984. The licensee ' subsequently y re-issued the changes and memoranda and upgraded oversight of this

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area. T hese" events indicate a lack of attention by station manage-

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The?ewerea:numberofdeficienciesidentifiedwiththelicensee's internal: exposure control program. These included poorly stated-proceduresforcontr4ofactivities,andthelackoftimely, thorough or technic 311y sound reviews. Although the licensee had a limited alpha radioactWity sampling and analysis program in place, the licensee' failed'to detect the presence of alpha emitters at the stationin a timeli manner, failed td evaluate the extent of the p6)blem~, and failed to initiate appropriate radiological controls to limit personnel exposure to alpha airborne-radioacti-i vity. The liceniee also had not established a program to include -

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L- reports. This is evidence of inadequately maintained and incom '

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plete' personnel exposure re6ords. When brought to their attention the licensee implemented a timely evaluation of the, alpha emitters?,, Y,"

andtookappropriateaction'tolimitpersonnelexjssurethereto.,

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The licensee's external exposure ' control was inadequate in that for the unplanned occupational extremity exposure in January 1984, as of five days after the event, thedicensee had~ failed to identify L that other workers could havereceived signif.icant extremity expo-sure. Tht licensee's initial evaluation of t.ne unplanned extremity exposure failed to exami k allscontributing factors to the exposure (e.g. prdper labeling o.f radioaci.ive material g ccQSnications, f adequacy of radiation surveysy.. A Confirmatbry AcT. ion Lette6 was -

issued to' doc.ueent licensee corrective action' commitments for this and other matters associated with the unplanned exposure. Subsc-quent NRC 9eview of licensee implementation of the commitments found that the commitments were implemented. ..

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The licensee's. selection, establishment, and implementation of cor-rective actioris for the unplanned extremity exposure were inadequate in,that a second, similar, unplanned extremity exposure occurred

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seven. months later (August 1984). Following the second unplanned

'm; occupation extremity exposure, the license suspended all work in

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the area where the exposure occurred and initiated, within one hour of the exposure, a management review of the incident. The licen-see's corrective actions to resolve this matter included revision

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of procedures for performing Control Rod Drive disassembly and

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establishment of a mock up training program for this task. The

corrective action and attention to the second event were timely and

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appropriate.

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The-ALARA program had a number of deficiencies. Program improve-

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ments were identified as being necessary by NRC in February, 1984

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estimation of anticipated man-rem expenditures in that work super-

visors were performing their-own ALARA reviews for jobs with esti-p V i , mated exposures of less than 10 man-rem. Review found some actual A

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exposures were considerably higher than pre-job estimates. -This

- # can be attributed in part to a lack of guidance for performing on-going job-reviews. The licensee's ALARA program did not have any f+, f . provision for detecting, evaluating and correcting (as necessary)

.g# ,- situations in which personnel exposure exceed initial exposure P,- .U -

estimates in order to effect increased exposures saving or' gain an LM *

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understanding of the causes of the increased exposure. A subsequent-review in August 1984 found that little improvement had been made N in these areas. The licensee subsequently established criteria with

, which to use to determine if jobs will exceed man-rem goals while L the jobs are on going. There was also a general lack of licensee

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oversight of on going activities with respect to ALARA. For ex-f ample, essentially no ALARA controls' were established for work in C. the CRD repair room. As a result, radiological conditions in the

'c room degraded to the point where the. risk to workers was increased

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in that increased background radiation levels made identification a of localized radiation sources (e.g. chips) difficult. ~In addition,

~7 tools used by workers exhibited significant radiation dose rates

- which caused unnecessary exposure to workers. Such problems are indicative of a less than adequate ALARA program.

The licensee did, however, conduct several initiatives during the

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s recirculation piping replacement outage which substantially reduced-worker radiation exposure. As an example, most drywell work was

. not started until after the reacter coolant system had been chemi-

, - u - cally decontaminated and jet pump instrument lines had been removed.

A' . These actions reduced drywell area radiation levels by as much as

-- .e a factor of three. Later in the outage, portions of the reactor

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water cleanup system outside the drywell were also chemically de-contaminated, substantially reducing area radiation levels during

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maintenance. An estimated 1,000 person-rem were saved by hydro-1azing and extensive manual decontamination of the drywell interior.

The removal of respirator requirements enabled many drywell tasks to be completed more quickly, minimizing personnel radiation expo-

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sures, and.probably improved supervisory oversight of drywell work.

Extensive mockup training was conducted during the recirculation pipe replacement project, which minimized delays and unnecessary radiation exposure in the drywell.

A computer-based radiation exposure tracking system was developed for the outage ALARA program which enabled accumulated exposures to be tracked for major outage tasks. Senior licensee management received frequent reports on accumulated radiation exposure throughout the outage. These reports compared the actual. exposures to preplanned goals and discussed discrepancies and goal revisions.

Regarding the licensee's enforcement history, during this assessment period, there were several major violations and a number of minor.

violations. These violations are attributed to a general lack of the establishment of effective radiological controls for on going work. In January 1984, a special inspection to review an unplanned extremity exposure identified three violations. A Confirmatory Action Letter was' issued following the inspection. Also, a civil

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penalty was assessed. Three additional apparent violations, and a deviation were identified following a review of a second unplanned

. extremity exposure that occurred in August, 1984. These additional violations could have been prevented if more effective corrective actions had occurred following the first incident.

1- b. Radioactive Waste Management and Effluent Controls and

Monitoring Administrative controls in this area, licensee organizations and staffing, procedures, radiochemical analyses capabilities, process and effluent monitor surveillance and calibration, overall manage-ment involvement and control in these areas was acceptable.. The licensee is implementing an effective Radioactive Waste Management and Effluent Controls and Monitoring Program.

c. Radioactive Waste Transportation Although there was only one on-site inspection by a radiation specialist in this area, three violations and one deviation were identified. The violations involved: failure to approve procedures for dewatering and use of high integrity containers (three ex-amples), failure to perform evaluations to ensure compliance with shipping cask certificate of compliance requirement (two examples)

'and failure to include radioactive waste transport casks as an item to be covered by the' quality assurance program. The deviation in-volved a failure to meet a commitment regarding implemention of a training program for all personnel involved in radioactive waste activities, such as packaging, handling and shipping, made in re-

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sponse to an IE Bulletin (79-19). The licensee implemented accept-able corrective action for the deviation; responses to the viola-tions are currently under NRC review.

The licensee's quality assurance audit program for transportation aackages was reviewed and found acceptable.

The problems in this area indicate that the licensee should increase his attention to detail in assuring that approved procedures are used to control Radioactive Waste Transportation activities and that all applicable conditions of the certificates of compliance for transport packages are adhered to.

2. Conclusion Category 3, declining.

3. Board Recommendations Licensee - The on going contractor evaluation of the overall lic-ensee radiation protection program is expected to result in numerous recommendations for improvements. The licensee should vigorously implement initiatives and/or recommendations to improve areas that are identified as weak or deficient.

NRC - Increase inspection effort in this area during the next assessment period. Hold two management meetings during the next year to discuss the status of the licensee's ongoing Radiological Improvement Program.

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C. Maintenance (12%)

1. Analysis During the previous assessment period, extensive out of service times for safety related equipment and unfavorable environmental conditions for safety related components were identified as weak-nesses. The licensee has strengthened these areas by ov.erhauling and replacing many safety related valves and by installing envir-onmentally qualified equipment during the 1984 piping replacement outage.

During the current assessment period, this functional area was routinely reviewed by the resident inspectors. Regional inspections were also conducted in this area, including general maintenance and modifications reviews and a review of the safety related valve betterment program.

The licensee used the 1984 outage to inspect and repair or replace a large number of safety related components, including: ninety-four control rod drives, several cooling water pumps and heat exchangers, 4160 and 480 volt electrical circuit breakers, and most 120 volt HFA relays. The licensee demonstrated initiative in conducting a major valve inspection, repair, and replacement program (the valve betterment program) during the outage. The licensee has taken strong action to assess and correct the cause of sticking safety relief valves during the outage. Valve materials were metallo-graphically analyzed and subsequently changed. Old insulation was removed and a new style insulation was installed on drywell piping to reduce drywell temperatures and reduce radiation exposure during future piping inspection and component maintenance. The licensee l also completed substantial maintunance on non-safety systems during the outage, including the replacement of condensate pumps and three

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feedwater heaters. These activities reflect strong management commitments to improve plant equipment and facilities. They should result in increased system availability and reliability during the next operating cycle.

Licensee procedural controls over maintenance activities were ade-

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quate. Maintenance activities twice caused the accidental activa-l tion of the reactor protection system during electrical bus trans-fers during the outage. The licensee should strengthen procedural guidance to avoid recurrence of these actuations.

Training for maintenance activities was adequate resulting in few personnel errors. The licensee has placed a high priority on fill-ing vacancies in this functional area. The staff was recently ex-panded, with a Maintenance Technical Assistant and three technical writers authorized. This indicates strong licensee commitment to the maintenance program.

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A special NRC review of equipment failures during 1983 was conducted during the SALP period. Four repetitive maintenance activities were identified: 1) multiple electrical grounds in the 125 volt d.c.

power system, 2) failures of diesel generator oil pump belts, 3) loose motor operator cap screws on a core spray valve, and 4) recurring steam leaks in the HPCI and RCIC systems. In each case, licensee management was aware of problems and had taken or had planned appropriate corrective actions. This indicates good feedback regarding repetitive maintenance problems.

The licensee tracks equipment problems by major component to iden-tify trends and assess previous corrective actions. High priority maintenance problems are also identified and tracked. This tracking system is actively used by the licensee's maintenance group and assists management in identifying repetitive equipment failures and in determining root causes.

Substantial management attention was given to the procurement area during the assessment period. However, weaknesses persisted in the areas of preventative maintenance for spare parts and shelf life control for items in storage. The licensee was responsive to NRC findings in this area and instituted adequate corrective action.

Storage facilities were substantially upgraded in a new warehouse and control of items was strengthened by a computer based inventory system.

A site engineering office was established to monitor and support subcontracted modification activities. This helped to ensure that field changes were adequately controlled. Corporate support for site activities is also evident by the consideration being given to moving the entire Braintree offices to the site.

2. Conclusion Category 1, improving.

3. Board Recommendation Licensee - Continue initiatives in maintenance trending and

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tracking system.

NRC - Reduce routine inspection effort.

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D. SURVEILLANCE (7%)

1. Analysis ~

The previous assessment evaluation did not identify major defic-iencies in the surveillance program.

During the current assessment period, the resident inspectors rou-tinely reviewed this functional area. Specialist inspections were also conducted in this area, including reviews of the reactor cool-ant leakage surveillance program, inservice testing of pumps and valves, and inservice inspection of snubbers.

-During the operational phase of the current-SALP period, surveil-lance activities continued to be conducted in accordance with es-tablished procedures by experienced individuals. Most routine sur-veillance activities were not required during the last nine months of the current assessment period because the vessel was defueled for the piping replacement outage.

Few surveillance-related incidents were reported during the. current period, indicating continued management control over the program.

Although five surveillance-related events were reported to be caused by personnel errors, only two events involved errors by individuals conducting surveillance activities.

Only four surveillance tests were not conducted as required by the technical specifications during the current period. Three of the tests had not been incorporated into the licensee's surveillance program and were identified during a licensee comparison of sur-veillance program requirements with technical specification re-quirements. The fourth test was missed because of an improperly worded schedule. The small number of missed surveillances and the licensee's self identification of missed surveillances are indica-tive of a basically sound program. The licensee's corrective ac-tions for these deficiencies were prompt and effective.

The licensee's surveillance procedures include conservative accept-

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ance criteria. The program could be strengthened by clearly relat-ing the administrative criteria (e.g. the test input for the two thirds core coverage permissive for containment spray) to technical specification requirements.

An inspection in May 1984 of corrective actions outlined in a Janu-ary 1984 BECo response letter concerning inservice testing (IST),

found the licensee's overall corrective actions to be incomplete.

This NRC inspection and a licensee's audit identified similar IST procedural and testing inadequacies. These audits point out a need to strengthen the program for complying with requirements of the ASME Code,Section XI, Subsections IWP and IWV. The licensee's-

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October 1984 response has been positive regarding IST improvements.

Further NRC evaluation of the licensee's compliance with ASME Sec-tion XI will be made.

The licensee's inservice inspection program for snubbers was carried out by well qualified personnel and showed evidence of adequate quality assurance involvement.

A special inspection of the reactor coolant leakage program was conducted in response to NRC concerns over possible intergranular stress corrosion cracking problems. Licensee management's commit-ment to safety was demonstrated by the establishment of an admini-strative limit on unidentified reactor coolant leakage inside the drywell which was more restrictive than the Technical Specification limit.

2. Conclusions Category 1, consistent.

3. Board Recommendations Licensee - Management attention is required to assure proper implementation of the IST program.

NRC - Conduct a followup inspection of IST program content and implementation. Assure that surveillance program is satisfactorily implemented for restart and subsequent operations.

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E. Fire Protection / Housekeeping (4%)

1. Analysis

, The previous SALP report discussed concerns regarding the use of Watch Engineers as fire brigade leaders, lack of resolution of fire protection Technical Specification issues, and the status of fire protection equipment in the cable spreading room. These concerns were resolved during the current period, indicating management re-sponsiveness to NRC concerns.

This area was reviewed during the current assessment period by the resident inspectors and by regional specialist inspectors. No major problems were identified.

Licensee management continued to exhibit aggressiveness and concern regarding fire protection and prevention issues during the assess-ment period. Fire watch personnel were aware of their duties and responsibilities during the outage and assisted in the detection and control of minor fires. Fire brigade training was adequate to perform required duties. The licensee's fire safety procedures were reviewed and found to be adequate.

Management attention to fire protection was strong during the out-age. Fire events and precautions were routinely discussed during daily outage meetings between plant and corporate managers. Con-tractor fire protection inspectors were used on all shifts during the outage and aggressively inspected work activities for fire pro-tection problems. No significant fires occurred during the piping replacement outage, despite the large amount of welding and torch cutting that was conducted. After a number of minor fires occurred at the station; the licensee took aggressive actions to prevent re-currence of such fires. Feedback of fire protection problems, cate-gorized by type and responsible group, was routinely provided to management personnel for review and followup. Fire protection data were also plotted to identify trends. Summary reports of each fire event with corrective actions were prepared.

Two causal chains involving potential problems with fire doors and penetrations were identified during the assessment period. The licensee took adequate compensatory measures and is currently evaluating the problems. However, at the end of this assessment period, the cause of problems with 38 penetration seals identified during May,1984 (LER No. 84-07) had not yet been completely evalu-ated by responsible licensee management and an updated LER issued.

The large number of potentially degraded barriers and doors indi-cates that management attention must be increased to ensure that the scope and root cause of the problems are identified and that comprehensive corrective actions are taken.

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licensee has had difficulty in staffing a key position in the fir safety program, the station fire prevention and protection offic (FPP0). The FPP0 position became vacant early in the as-sessmen period, was filled briefly, but became vacant again. Con-tinued ma gement attention should be given to filling this key program vac cy.

Licensee manage nt has given attention to housekeeping practices during the outage The station was kept relatively organized, de-spite the large amo t of work conducted. Senior licensee manage-ment toured the faci 'ty several times during the outage and initi-ated station cleanup p rams. Attention was given to lowering radioactive contaminatio in many plant areas and systems to enhance access during the outage a reduce personnel radiation exposure.

While the decontamination ef rts show strong management commitment in this area, the high level o radioactive contamination in the plant will require continued eff t in the future.

2. Conclusion Category 2, declining.

3. Board Recommendations Licensee - Take adequate corrective actions for ported potential fire door and barrier problems, continue efforts t locate a quali-fied fire protection officer and clean (decontaminat those areas which impede operator access to plant systems and caus unnecessary radiation exposure to station personnel.

NRC - Maintain routine inspection program. Review licensee valu-ations and corrective actions for reported potential fire doo and barrier problems. Schedule Appendix R inspection during the ne assessment period.

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The licensee has had difficulty in staffing a key position in the fire safety program, the station fire prevention and protection officer (FPP0). The FPP0 position became vacant early in the as-sessment period, was filled briefly, but became vacant again. Con-tinued management attention should be given to filling this key program vacancy.

Licensee management has given attention to housekeeping practices during the outage. The station was kept relatively organized, de-spite the large amount of work conducted. Senior licensee manage-ment toured the facility several times during the outage and initi-ated station cleanup programs. Attention was given to lowering radioactive contamination in many plant areas and systems to enhance access during the outage and reduce personnel radiation exposure.

While the decontamination efforts show strong management commitment in this area, the high level of radioactive contamination in the plant will require continued effort in the future.

2. Conclusion Category 2, consistent.

3. Board Recommendations Licensee - Take adequate corrective actions for reported potential fire door and barrier problems, continue efforts to locate a quali-fied fire protection officer and clean (decontaminate) those areas which impede operator access to plant systems and cause unnecessary radiation exposure to station personnel.

NRC - Maintain routine in.pection program. Review licensee evalu-ations and corrective actions for reported potential fire door and barrier problems. Schedule Appendix R inspection during the next assessment period.

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F. Emergency Preparedness (4%)

1. Analysis During the previous assessment period, no significant weakness was identified and this area was assessed as Category 1.

During this assessment period there were two routine inspections

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of emergency preparedness activities.

In the first inspection, most licensee actions in correcting Emer-gency Plan deficiencies first identified in June, 1982 by NRC were found to be acceptable; however, further plan revisions were iden-tified as being necessary during this inspection and have since been proposed by the licensee.

InthesecondinspectiononAugust 14-16, 1984, routine observation and inspection of the licensee s emergency preparedness exercise was performed. Exercise observation indicated that the decision making process for protective action recommendations to offsite authorities lacked structure and required additional licensee man-agement review before communication to State officials. Documen-tatior, and recordkeeping of scenario events in the Control Room, Emergency Operations Facility, and Operations Support Center were found to be incomplete and not well maintained. The exercise iden-tified nineteen (19) improvement items which related to a potential degradation in overall licensee response. Eight (8) items identi-fled for corrective action from previous exercises and assessments were found to recur.

Specific areas in need of improvement related to the licensee's training program and emergency response facilities. The training program has not been effective since emergency plan implementing procedures for recordkeeping, communications, and radiological as-sessment were not used or were inadequately followed during the exercise. The Emergency Operations Facility (EOF) is inefficient in fulfilling its function due to space limitation, unsatisfactory habitability conditions, excessive noise, and crowding. The licen-see recognizes the need to improve working conditions in the EOF and has taken steps to negotiate a new permanent facility with Ply-mouth County government officials. Another area of concern is the inability of licensee management to independently evaluate their emergency plan program deficiencies and take appropriate corrective actior.s following the exercise. For example, the licensee's self-critique did not identify several of the major problem areas.

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The licensee's overall emergency response actions for the exercise were adequate to provide protective measures for the health and safety of the public, but a remedial drill was required in order

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r 25 to adequately demonstrate emergency response actions in five defi-cient areas. The licensee conducted the remedial exercise on November 8, 1984 after the end of this assessment period.

l l 2. Conclusion Category 3, declining.

3. Board Recommendation Licensee - Additional management attention to emergency preparedness activities is needed to ensure that current performance deficiencies are corrected. Consideration should be given to (1) changing the frequency of periodic drills in order to develop and maintain key skills and (2) expanding the amount of training in performing emer-gency response procedures.

NRC - Increase inspection effort during the next assessment period

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to cover all areas of the emergency planning program. Resident l inspectors should observe periodic drills.

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G. Security and Safeguards (5%)

1. Analysis During the previous assessment period, weaknesses were identified in the areas of handling safeguards information, assigning priority to equipment repairs, and performing preventive surveillance.

Two routine and one special physical security inspections were con-ducted during the assessment period. Routine resident inspections continued throughout the assessment period. Six severity level IV violations were identified during the last physical security in-spection in the assessment period including one recurrent item.

While one routine and one special inspection early in the period identified no weaknesses, the nLmber and nature of problems identi-fied during the last inspection raised questions regarding manage-ment's commitment to an effective physical security program and, particularly, oversight and interface with the contracted security force. Several of these problems, especially defaced security force photo identification badges, reflect adversely on the contractor's supervision of personnel. The licensee has taken steps to improve this area by performing random surveillances and requiring regular plant tours by shift supervisors. Continuing management attention is needed in the area of field supervision and direction.

Records were well maintained and available for inspection at the site. Maintenance of security systems and hardware appeared to be adequate during the assessment period. This indicates responsive-ness to NRC concerns regarding the assignment of priority to secur-ity equipment repairs.

Contract security (Globe Security Services) personnel appeared generally knowledgeable of their duties. However, lapses in per-formance identified during the last inspection indicate the need for more definition in security procedures.

Security events were managed properly and no actual compromises of security occurred. However, no security event reports were sub-mitted to the NRC. The licensee stated that their interpretation was that only in the event of an actual penetration or event is there a need to report. This narrow interpretation is being re-evaluated by the licensee.

Upper corporate management responded to the last inspection by con-tacting NRC management and requesting a meeting with NRC personnel at Region I to discuss the improvements they were implementing to strengthen the program and to correct the deficiencies and preclude further reoccurrence. Their plans appeared to be very comprehensive

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and well thought out. This demonstrated licensee management's con-cern and reflects favorably on their attitude towards the physical protection program.

2. Conclusion Category 2, consistent.

3. Board Recommendations Licensee - Increase onsite management attention to supervision of the contractor security force.

NRC - Schedule a special inspection to review improvements initiated by the licensee.

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H. Refueling and Outage Management (30%)

1. Analysis The previous SALP period did not include a major outage and no con-clusion was reached on licensee performance in this area. The cur-rent SALP period includes the initial and intermediate phases of the recirculation piping replacement outage. Outage work has been reviewed by resident and region-based specialist inspectors. Non-destructive examinations of completed welds were conducted by NRC inspectors using the NRC NDE van. Few problems.were noted during the outage except in the radiation protection functional area.

The licensee shut down on December 10, 1983 to inspect recirculation system piping for intergranular stress corrosion cracking (IGSCC).

Licensee management showed a strong commitment to safety and a good understanding of the issues by deciding in advance to replace, rather than repair, the piping if tests indicated the presence of IGSCC. Initial piping examinations confirmed the presence of IGSCC in heat affected zones in the piping and the licensee subsequently decided to replac.e most of the primary system piping inside the drywell . The licensee management also responded favorably to an NRC request to test NRC sponsored experimental nondestructive equipment on the insitu pipe cracks.

Substantial licensee resources were committed to the chemical de-contamination of the primary system piping system and the reactor water cleanup heat exchangers. These decontamination efforts greatly reduced personnel radiation exposures during the outage.

The licensee established an ALARA group to monitor and limit per-sonnel radiation exposures during the outage in response to an NRC initiative.

Contractors supervised a large portion of outage work, including all of the recirculation piping replacement. Licensee management coordinated and controlled the contractor work through an outage management group. Individuals from this group were onsite on all shifts during the outage to coordinate outage activities. The director of this group reported to senior corporate management.

During the first part of the outage, the quality assurance program of the prime contractor was weak in that the contractor's quality assurance organization and lines of authority were not clearly de-fined. The licensee identified these problems prior to the outage, but did not actively seek to resolve them until after the problems were also identified by NRC inspectors, several months into the outage. The licensee quality assurance group was more active during the latter stages of the outage, identifying weaknesses in contrac-tor activities and seeking resolution of concerns.

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Licensee management implemented project QC surveillance over recir-culation pipe replacement and related tasks. This action was a favorable step toward insuring that contractor work and QC inspec-tion met or exceeded procedural and regulatory requirements. How-ever, this surveillance did not result in correcting problems with contractor inspectors in the areas of 1) locating piping welds, 2) eye examination certifications, and 3) procedures for testing control rod drive collet housings. Licensee response to these problems was adequate but was occasionally slow and geared to NRC initiatives.

Prior licensee planning and a desire for high standards was indi-cated trainingby/ qualification.the implementation This of nozzle was accomplished throughmockup training an a training sequence and a program for qualification of welders, meeting both ASME requirements and conditions unique to automatic GTAW pipe welding. The results were good. Completed welds were examined by NRC inspectors using nondestructive examination techniques and were acceptable.

A weaknesses in the licensee's program for reviewing industry ex-periences contributed to the dropping of a control rod blade into the reactor vessel following core offloading. The licensee had not, prior to the incident, had an effective system for reviewing indus-try experiences. As a result, licensee personnel moving control rods were not aware of previous incidents involving improperly latched and dropped control rods. Following the dropped blade in-cident, licensee corrective actions were incomplete in that vendor suggestions for preventing improper control rod latching were not fully implemented. The licensee subsequently agreed to revise its program for reviewing industry experiences and committed to fully implementing vendor recommendations on control rod blade handling.

Additional comments regarding improvements in feedback of industry operating experience are described in the Operations functional area.

Licensee corporate management was routinely involved with the sta-tion staff during the outage. Daily briefing meetings were held between the station and corporate staffs to coordinate activities.

A computerized task tracking system was used to schedule onsite work. Senior corporate management involvement was evident; such managers were observed touring the plant several times during the outage.

Licensee management responded well to unexpected problems during the outage, including: 1) delays in the start and completion of the chemical decontamination of primary system piping, 2) cracks in new recirculation piping, 3) cracks in the inconel butter layer on reactor vessel nozzles, 4) extensive cracking in old style collet housings on control rod drives, 5) safety relief valve test fail-

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of 1 inch sch 80 piping which had been rejected by a vendor's test lab. In each case, licensee management responded to the problems in a manner which demonstrated thoroughness and appropriate atten-tion to safety.

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' The licensee exhibited strong contingency planning and coordination skills in managing the outage. This enabled the licensee to react '

promptly to identified hardware problems in a controlled, technically acceptable manner without introduction of any new safety related Concerns.

1 2. Conclusion Category 1, consistent.

3. Board Recommendations ,

Licensee - Continue initiative to monitor industry refueling outage experiences and incorporate lessons learned.

NRC - Continue routine inspection program during outages.

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I. Licensing Activities (1%)

1. Analysis During the previous assessment period, weaknesses were identified in the areas of 1) thoroughness and timeliness of licensing submit-tals, and 2) the lack of initiative in resolving inaccurate and inappropriate Technical Specifications.

The basis for this appraisal was the licensee's performance in support of licensing actions that were either completed or had a significant level of activity during the current assessment period.

These actions, consisting of amendment requests, excmption requests, responses to generic letters, TMI items, and other actions, are described in Table 6.

Throughout the assessment period the licensee's management has demonstrated a high level of i.. erest in licensing by active par-ticipation in the important issues. This was particularly notice-able in the licensee's briefings of the NRC Staff concerning in-spection and replacement of recirculation system piping that might be affected by intergranular stress corrosion cracking (IGSCC).

The licensee's Long Term Plan (integrated schedules) for plant modifications was adopted during this period. The Plan provides assurance to NRC that commitments will be met and enables BECo's management to better control the use of its resources.

A senior executive signs all letters to the NRC, helping assure management involvement in licensing matters. Except for a couple of occasions near the end of refueling outage #6, Technical Speci-fication (TS) change requests have been transmitted to the NRC in time to provide for its normal review before the changes are needed.

An aid in doing so is the computerized Technical Specification change Log recently developed by the utility's licensing group to track the status of proposed TS changes. Those changes that may become startup issues are identified in the Log, so that special attention can be given to them.

The licensee's staff has technical understanding of the licensing issues and has demonstrated, through his submittals and comments, appropriate attention to safety. Engineering and licensing staffs appear to interact frequently with plant personnel in resolving current problems. The licensee also keeps abreast of the developing issues through participation in industry organizations and the BWR Owners Group.

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Management's decision to replace, rather than repair, the piping affected by IGSCC indicates its conservative approach to this

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problem. Considerable progress has also been made, through meet-ings and telephone conferences with the licensee, toward resolution l

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of issues relative to fire protection, masonry wall design, Mark I containment, equipment qualification, NUREG-0737 items, RETS and inservice testing. For example, the licensee has provided clarify-ing information concerning its requested exemptions from Appendix R fire protection requirements and the conclusions of the NRC's B-41 review with respect to Pilgrim is imminent. Boston Edison has also provided thorough submittals, with JCOs, relative to equipment qualification requirements and is diligently attempting to qualify all applicable equipment by March 1985, in accordance with 10 CFR i 50.49.

An example of the licensee's attention to safety is his voluntary identification of additional block walls that should be streng-thened and his initiatives to accomplish that objective.

The licensee has substantially increased its licensing staff as a result of the Performance Improvement Program. Upper management positions were increased and the organizational structure has been improved. However, personnel have not been readily available to complete revisions of the RETS and inservice inspection testing submittals to NRC due to the diversion of many individuals to re-start activities.

Corrections have been made or proposed to limiting conditions for operation in the plant Technical Specifications regarding the core power-to-flow map and the containment cooling loop (salt service water pump) performance. However, the licensee's efforts have been ineffective in proposing changes to the wording of the specifica-tions regarding primary containment inerting makeup requirer,:ents.

This indicates that the increased management attention paid to this area should continue.

Effective communications exist between the NRC and Boston Edison licensing staffs. The licensee is prompt in responding to NRC re-quests for information or gives logical reasons for delay and es-tablishes a new date. Conference calls are quickly arranged with appropriate engineering, plant or contractor personnel. The lic-ensee voluntarily developed an integrated schedule for plant modi-fications and became the second in the industry to do so. During this rating period, perhaps the most significant demonstration of the licensee's responsiveness to NRC initiatives has been its timely meetings with, and submittals to, NRC relative to IGSCC.

Review of 5 submittals regarding changes to the Security Contin-gency,andTrainingplansindicatesthatmoreattentionIsneeded to improve clarity and to ensure that the changes do not decrease effectiveness,

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2. Conclusion Category 1, improving.

3. Board Recommendations

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NRC - None.

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V. SUPPORTING DATA AND SUMMARIES A. Investigations and Allegations Review No investigations were conducted during the current assessment period.

Several events involved alleged poor practices in the radiological con-trols program, including: requiring individuals to stay in low-level rad;ation fields without assigned work, ordering workers to violate the instructions on a radiation work permit, refusing a request for a whole body count, and unnecessarily reducing respiratory protection require-ments in the drywell. These concerns were reviewed during specialist and resident inspections and by the licensee. The licensee's actions were prompt and generally effective in resolving the problems. The re-petitive concerns involving unnecessary low level radiation exposure indicate the need for additional licensee communications regarding con-tractor work in radiation areas.

B. Escalated Enforcement Actions 1. Civil Penalties A forty thousand dollar civil penalty was issued during the assess-ment period in connection with the uncontrolled presence of small, highly radioactive sources in the control rod drive repair room between January 14 and 18, 1984. A special review of the incident by resident and specialist inspectors identified problems with the labeling of containers, use of extremity dosimetry, and the adequacy of instructions given to individuals working in the repair room.

2. Orders Confirmatory Order dated August 26, 1983 addressed a commitment to shutdown by December 10, 1983 to inspect for indications of inter-granular stress corrosion cracking in reactor piping.

Confirmatory Order dated September 22, 1983 extended the completion date for torus modifications from the start of operating cycle No.

7 to the start of the mid-cycle 7 modification outage.

Confirmatory Order dated June 15, 1984 extended the completion date for NUREG-0737 Items II.B.3 (Post-Accident Sampling Capability) and II.F.1.(6) (Continuous Hydrogen Indication in Containment) from June 1, 1984 to the end of refueling outage No. 7.

3. Confirmatory Action Letters Confirmatory Action Letter No. 84-03, dated January 25, 1984, con-cerned licensee actions following the discovery of small, highly radioactive sources in the control rod drive repair room.

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C. Management Conferences Held During the Assessment Period 1. Management Meetings with Region I Staff Performance Improvement Program meeting at Region I on August 31, 1983 SALP management meeting at Boston Edison Co. corporate offices on September 23, 1983 Performance Improvement Program and refueling outage meeting at Region I on November 3, 1983 Enforcement conference at Region I on February 21, 1984 regarding the uncontrolled presence of small, highly radioactive sources in the control rod drive repair room Performance Improvement Program meeting at Region I on March 14, 1984 Management meeting at Region I on September 5, 1984 regarding a second instance of the uncontrolled presence of small, highly radioactive sources in the control rod drive repair room Performance Improvement Program and refueling outage meeting at Region I on September 18, 1984 2. Licensee Meetings with NRR Control room design review on November 15, 1983 Inspection and replacement of reactor piping on November 17, 1983 Replacement of drywell insulation on May 11, 1984 Environmental qualification of electrical equipment on May 22, 1984 Inservice testing on May 30 to 31, 1984 Radiological Technical Specifications on June 5 to 6, 1984 Replacement and repair of piping systems on June 15, 1984 Mark I containment long term program on August 23, 1984 l

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D. Licensee Event Report Tabular Listing

Type of Events

A. Personnel Error 10 i

B. Design /Manuf./Constr./ Install 5

C. External Cause 1 0. Defective Procedure 0

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E. Component Failure 19 I X. Other 5

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Licensee Event Reports Reviewed: Report Nos, 03-39 to 84-12

, Causal Analysis

a. LER's 83-47, 84-08, and 84-09 reported HFA relay failures, b. LER's 83-41, 83-56, and 84-06 reported problems with fire doors.

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c. LER's 83-42 and 84-07 reported problems with fire penetrations, d. LER's 84-05 and 84-06 reported set point drift of main steam line j safety and safety relief valves.

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e. LER's 83-57 and 84-03 reported missed surveillance tests.

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f. LER's 84-11 and 84-12 reported inadvertent diesel generator starts.

- t g. LER's 83-39, 83-52, and 83-65 reported problems with HPCI turbine valves, h. LER's 83-55 and 83-66 reported failures of fire pumps to start.

i. LER's 04-01 and 84 * reported scram signals during power transfer.

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! INSPECTION HOURS SUMMARY (7/1/83 - 9/30/84)  !

l PILGRIM NUCLEAR POWER STATION l

Hours % of Time A. Plant Operations....................................... 1179 24 t

i B. Radiological Controls................................... 650 13 i C. Maintenance............................................. 619 12 l  ;

D. Survel11ance............................................ 335.5 7 l E. Fire Protection / Housekeeping............................ 198.5 4 F. Emergency Preparedness.................................. 200 4

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G. Security and Safeguards................................. 236 5 l

l H. Refueling and Outage Management........................ 1492 30 I. Licensing Activities................................... 50* __1* !

Total 4960 100 ;

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• Direct inspection hours regarding correcting and implementing Technical Specifi-cation changes and implementation of IGSCC Order reporting requirements.

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. _ - - _ _ _ -

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

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TABLE 2 VIOLATION SUMMARY (7/1/83 - 9/30/84)

PjlGRIM NUCLEAR POWER STATION j A. Number and Severity Level of Violations l Severity Level I O Severity Level II O Severity Level III 1 Severity Level IV 18 Severity Level V 6 Deviation J l

Total 26*

8. Violations Vs. Functional Area l

Severity Level Functional Areas I II III IV V DEV A. Plant Operations 2 5 B. Radioloalcal Controls * _

1 7 1 1 C. Maintenance 2 D. Surveillance 1 E. Fire Protection and Housekeeping F. Emergency Preparedness G. Security and Safeguards 6 H. Refueling and Outage Management _

I. Licensing Activities Totals * 1 18 6 1

• Totals do not include three apparent violations and one apparent deviation in the area of radiological controls that were identified during inspection 84-25.

NRC enforcement action was under review at the end of the assessment period.

__

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O 39 t C. Summary Inspection Inspection Severity Functional Report No. Date level Area Violation

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83-19 8/16-10/3/83 V A Failure to review and up-date special orders V A Failure to vent piping from the high point in the core spray system 83-20 8/8-12/83 IV B Failure to follow a Radi-ation Work Permit 83-21 8/22-24/83 V A Failure to schedule exter-nal audits V A Failure to document defi- >

ciencies in deficiency i reports 83-23 10/4-11/7/83 IV D Failure to conduct an in-service test on a high pressurecoolantinjection ;

(liPCI) valve IV C Failure to review a proce-dure for procuring safety-related items.

83-24 11/8-12/31/83 IV A Failure to record reactor vessel cool down rate 84-03 1/20-27/84 III B Failure to label a container of licensed material, use extremity dosimetry, and instruct workers on radt-ation levels 84-04 2/7-3/12/84 IV A Failure to maintain a pro-cedure for the proper operation of the contain-ment atmospheric dilution system 84-06 2/13-17/84 IV B Failure to follow a radi-ation work permit

___ _ ___________ _ __

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40  :

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Inspection Inspection Severity Functional Report No. Date __ Level Area Violation

,

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84-11 4/23-27/84 IV C Failure to maintain a pro-cedure for controlling :

welding slag 84-13 4/24-27/84 IV B Failure to properly review and approve contractor pro- !

cedures involving transpor- '

tation of radioactive l materials j IV B Failure to comply with the requirements of a Certifi-cate of Compliance for a transport package ;

V B Failure to properly document a quality assurance program <

for transport packages ;

DEV B Failure to fulfill a trans-portation training commit- I ment 84-14 5/9-11/84 IV B Failure to instruct workers on the presence of radio-active materials IV B Failure to survey radiation !

hazards IV B Failure to implement pro-cedures consistent with 10 CFR 20 84-22 7/16-20/84 IV G Failure to control a i security key card IV C Failure to maintain photo :

ID badges  !

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IV G Failure to respond to two vital area alarms IV G Failure to maintain one !

guard radio and one offsite '

communications net operable i-

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G Failure to maintain effec-f tive compensatdry measures.

IV G Fa'ilure to laintain effec-

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84-25 8/6-10/84 ~* B Failure to perform radiation l s

surveys

..- B Failure'to instruct workers l

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on radiation hazards

• B Failure to properly approve procedures

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TABLE 3 INSPECTION REPORT ACTIVITIES (7/1/83-9/30/84)

PILGRIM NUCLEAR POWER STATION Inspection Inspection Areas Report No. Hours Inspected 83-17 166 Routine, resident

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83-18 22.5 Special, reactor boundary leakage sur-veillance program review

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83-19 306 Routine, resident

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83-20 95 Routine, radiological controls n-

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83-21. 36 Routine, quality assurance 83-22 59 Routine, quality assurance 83-23 143 Routine, resident 83-24 163 Routine, resident 83-25 72 Routine, security

'

83-26 108 Routine, pipe snubber and equipment sup-

'

ports review and review of licensee non-

.' destructive examinations of recirculation 4 pipes 83-27 60 Routine, radiological controls

[ 84-01 266 Routine, resident 84-02 96 Routine, recirculation pipe replacement

,

3 and maintenance programs

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84-03 102 Special, followup to an unanticipated extremity radiation exposure

..

84-04 324 Routine, resident

+ 84-05 28 Special, emergency preparedness 84-06 80 Routine, radiological controls

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Inspection Inspection Areas Report No. Hours Inspected 84-07 311 Routine, resident 84-08 46 Routine, recirculation pipe replacement and welder qualification programs 84-09 18 Special, security safeguards 84-10 N/A Cancelled - Inspection number not used 84-11 76 Routine, recirculation p;pe replacement and quality assurance programs 84-12 335 Routine, resident 84-13 38 Routine, radiological controls 84-14 59 Routine, radiological controls 84-15 68.5 Routine, fire protection prevention program 84-16 11 Routine, inservice testing program 84-17 222 Routine, resident 84-18 35 Routine, snubber surveillance, inservice inspections, and review of torus modifications 84-19 44 Routine, recirculation pipe replacement, welder qualification, and licensee non-destructive examination programs 84-20 162 Routine, emergency preparedness 84-21 542 Special, NDE van, review of piping welds and other components 84-22 56 Routine, security safeguards 84-23 254 Routine, resident 84-24 29 Routine, scram discharge volume modifi-cation

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Inspection Inspection Areas Report No. Hours Inspected 84-25 84 Routine, radiological controls and special review of an unanticipated extremity radiation exposure 84-26 261 Routine, resident 84-27 72 Routine modifications review 84-28 --- *

84-29 18 Special, radiological controls 84-30 38 Routine, preservice inspection of recir-culation pipe replacement and inservice inspection program 84-31 54 Routine, valve testing and maintenance

• Inspection conducted outside reporting period.

!

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TABLE 4 TABULAR LISTING 0F LERS BY FUNCTIONAL AREA PILGRIM NUCLEAR POWER STATION Area Number /Cause Code Total A. Plant Operations 1A 1C 7E 9 B. Radiological Controls 1E 1 C. Maintenance and Modifications 2A 3B 3E 3X 11 D. Surveillance SA 7E 12 E. Fire Protection /

Housekeeping 1A 2B IE 2X 6 F. Emergency Preparedness None 0 G. Security and Safeguards None 0 H. Refueling and Outage Management 1A 1 I. Licensing Activities None 0 Total 40 Cause Codes A - Personnel Error B - Design, Manufacturing, Construction, or Installation Error C - External Cause D - Defective Procedure E - Component Failure X - Other

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TABLE 5 LER SYN 0PSIS (7/1/83 - 9/30/84)

PILGRIM NUCLEAR POWER STATION LER Number M Summary Description 83-39 30 day HPCI turbine stop valve (MOV 2301-23) failed to open in required time 83-40 30 day Core spray injection valve (MOV 1400-25A) failed to close during a surveillance test 83-41 30 day Two fire door latches inoperable 83-42 30 day Fire penetrations defective 83-43 30 day' Off gas radiation monitor out of calibration in a non-conservative direction

, 83-44 30 day RCIC steam line isolation valve (MOV 1301-16) failed

!

to close during a surveillance test 83-45 30 day Loss of offsite power 83-46 30 day Inoperable control rod l 83-47 Prompt HFA relay failure l

83-48 Prompt HPCI feedwater overpressure

83-49 30 day Recirculation pump trip 83-50 30 day Fire patrol requirements not met 83-51 30 day Inoperable containment atmospheric monitor

I 83-52 30 day HPCI steam inlet valve (MOV 2301-3) failed to open during a surveillance test 83-53 30 day Main steam line drain isolation valve (MOV 220-2)

failed to open after an isolation 83-54 30 day Off gas monitor 1705-3A inoperable 83-55 30 day Diesel fire pump failed to start during a surveil-lance 83-56 30 day Sliding fire door defective

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47 4 LER Number Type Summary Description 83-57 Prompt Three missed surveillance tests 83-58 30 day Main stack sample pump out of service 83-59 30 day Torus temperature recorder downscale 83-60 30 day leaking control rod drive accumulator l 83-61 30 day Drywell to torus vacuum breaker alarm inoperable 83-62 30 day Two secondary containment dampers inoperable 83-63 Prompt Recirculation system pipe cracks i

83-64 Prompt Shield plugs not removed between dryer separator pit '

and refueling cavity during fuel movement 83-65 30 day HPCI exhaust check valve 2301-45 failed type C local leak rate test 83-66 30 day Electrical fire pump failure to start during surveillance 84-01 30 day Scram signal during power transfer 84-02 30 day HFA relay failure 84-03 30 day Missed surveillance on the diesel fire pump 84-04 30 day Both main steam line safety valve set points drifted below the specified pressure limit 84-05 30 day Two of four main steam line safety relief valves drifted above the specified pressure limits 84-06 30 day Thirty-seven fire doors potentially inoperable 84-07 30 day Thirty-eight fire penetration seals defective 84-08 30 day HFA relay failure 84-09 30 day HFA relay failure 84-10 30 day CRD collet tube weld defect

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LER Number , Type Summary Description

~84-11 30 day Inadvertent start of the "A" diesel generator during HFA relay replacement 84-12 30 day Inadvertent start of the "B" diesel generator during a core spray surveillance test

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TABLE 6 SELECTED LICENSING ACTIVITIES The following activities provided the basis for the analysis of the Licensing Functional Area.

14 Multi-Plant Actions (8 completed): selected items included in this category are:

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Appendix R Fire Protection (B-41)

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BWR Feedwater and Control Rod Drive Nozzle Cracking (B-25) - completed

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Implementation of NUREG-0313, Revision 1 (B-05) - complete

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Appendix J Exemption Requests (A-04) - complete

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Containment Vent and Purge (B-24) - complete

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Appendix I Technical Specifications (A-02)

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Control of Heavy Loads over Spent Fuel Pool (C-10)

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BWR Single-Loop Operation (E-40)

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Masonry Wall Design (B-59)

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Environmental Qualifications of Electric Equipment (B-60)

28 Plant-Specific Actions (20 completed): selected items included in this category are:

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Appendix R Fire Protection Alternative Safe Shutdown - completed

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Expansion of Power / Flow Map Operating Region - completed

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Procedural and Organizational Changes - completed

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Reload for Cycle 7 Operation - completed

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Scram Discharge Volume Modifications - completed

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Inservice Inspection and Testing Programs

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Operability of New 8-inch Isolation Valves - completed

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Integrated Schedule Plan - completed

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Responses to IGSCC Order and Generic Letters 84-07 and 11 19 NUREG-0737 (TMI) Actions (10 complete)

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. .g, ENCLOSURE 2

1. o UNITED STATES g

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REGION I-l

$ 631 PARK AVENUE

% ,o',c KING OF PRUSSIA. PENNSYLVANIA 19406 Docket No. 50-293 DEC 0 61984 Boston Edison Company M/C Nuclear ATTN: Mr. William D. Harrington Senior Vice President, Nuclear _ _

800 Boylston Street Boston, Massachusetts 02199 Gentlemen:

Subject: Systematic Assessment of Licensee Performance (SALP) Report No.

50-293/84-34 The NRC Region I SALP Board has reviewed and evaluated the performance of activi-ties at the Pilgrim Nuclear Power Station for the period of July 1,1983 through September 30, 1984. The results of this assessment are documented in the enclosed SALP Board Report dated November 13, 1984. A meeting to discuss the assessment will be scheduled at a later date.

At this SALP meeting, you should be prepared to discuss our assessment and your plans to improve performance. The meeting is intended to be a dialogue wherein any comments you may have regarding our report may be discussed. Additionally,

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you may provide written comments within 20 days after the meeting.

Your cooperation is appreciated.

Sin erely, *

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Ri ard W. tarostecki, SALP Board Chairman Director, Division of Project and Resident Programs Enclosure: SALP Report No. 50-293/84-34 cc w/ enc 1:

A. V. Morisi, Manager, Nuclear Management Services Department C. J. Mathis, Station Manager Joanne Shotwell, Assistant Attorney General Paul Levy, Chairman, Department of Public Utilities Plymouth Board of Selectmen '

Plymouth Civil Defense Director Senator Edward P. Kirby Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Massachusetts (2)

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ENCLOSURE 3 SALP MANAGEMENT MEETING ATTENDEES JANUARY 23, 1985 Boston Edison Company S. Sweeney, President and Chief Executive Officer W. Harrington, Senior Vice President, Nuclear A. Oxsen, Vice President, Nuclear Operations E. Howard, Vice President, Nuclear Engineering and QA C. Mathis, Nuclear Operations Manager E. Ziemianski, Nuclear Operation Support Manager J. Keyes, Regulatory Affairs and Programs Group Leader B. Nolan, Emergency Preparedness Coordinator R. Tis, District Manager, Public Information Nuclear Regulatory Commission T. Murley, Regional Administrator R. Starostecki, Director, Division of Reactor Projects (DRP)

T. Martin, Director, Division of Radiation Safety and Safeguards (DRSS)

E.- Wenzinger, Chief, Projects Branch 3, DRP W. Miners, Chief, Safety Program Evaluation Branch, NRR L. Tripp, Chief, Reactor Projects Section 3A, DRP P. Leech, Project Manager, NRR J. Johnson, Senior Resident Inspector M. McBride, Resident Inspector l

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ENCLOSURE 4

BDETON EDISDN COMPANY B00 SOYLETON STRErF BOSTON, M ASEACHusrns D2199 WILLIAM D. HARRINGTO N u ........ ....... ,

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February 12, 1985 BECo 85-031 Mr. Richard W. Starostecki SALP Board, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406 License DPR-35 Docket 50-293 Response to Systematic Assessment of Licensee Performance (SALP) Report No. 84-34

Dear Sir:

We have reviewed and evaluated your assessment report of our operation of Pilgrim Nuclear Power Station. As you know, the major portion of the assessment period encompassed an outage of exceptional scope and duration.

During this period management and operations were severely tested. We believe a fair assessment of our performance during the past evaluation needs to consider the extraordinary circumstances of that period. In that context, we suggested some areas of disagreement with your findings during the meeting of February 23, 1985. We request your consideration of those areas and their circumstances as you review the attached comments.

Very truly yours, ERM/ns Attachments t

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Attachment PLANT OPERATIONS Staffing NRC Assessment Additional management attention is required to recruit and train operators.

BECo Perspective Operations is currently authorized 16 management and 29 NPO positions. At present, only 5 positions remain to be filled as follows:

(1) Nuclear Watch Engineer (2) Nuclear Operating Supervisors (2) Nuclear Plant Operators One of the Nuclear Operating Supervisor vacancies is due to a recent resignation, and both NPO vacancies are due to recent losses in the group.

We believe that our efforts on recruitment have been exceptional.

Concerning our attention to training, we believe that management has shown considerable attention based on the fact that we did postpone our last licensing exam for 3 months and, as a result of increased attention, 6 out of 10 individuals were licensed and 3 of the remaining 4 were close to the passing grade. We have 5 NP0's in a Tour Qualification Program and have scheduled 7 NP0's for Reactor Operator training commencing 3 March 1985.

CONDUCT OF OPERATIONS

NRC Assessment Several problems were observed regarding safety system procedure preparation and implementation.

BEco Perspective The examples used for this assessment were improper operation of core spray system vent valves and repetitive errors in the position specified in one procedure (2.2.70) for a containment block valve. The CS drain valves in between 1400-24 & 25 were being used by Operations to ensure headers were full instead of the high point vent valves as required by procedure. This was being done because the vent valves were approximately 20 feet off the floor and considered a safety hazard, whereas the drains off the same section of pipe were at waist level. Once management was made aware of the problem, a modification was implemented to correct the problem.

The incident involving the error in the procedure on the position of a containment block valve occurred because of the way we used to process procedure changes (i.e., use of typing pool at Prudential). The valves involved were the subject of a 10CFR50.54 fine and, when the original m

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. pr:blem was identified by BECo, the procedure was revised on-site to correct the specified position; however, the change was not transmitted to the offsite typing pool to change the computerized data. A subsequent revision to add numbers to these valves was processed through nornal means and, when the procedure came out of the typing pocl, it reverted back to the wrong position.

Procedure revisions are now processed on-site with a computerized data base and immediate revisions are made to that data base and, with the completion of the Procedure Update Program, these kinds of problems should not recur.

NRC Assessment increased management attention is considered necessary to ensure that safety-related activities such as valve alignments, maintenance, and testing are independently verified.

BEco Perspective The Procedure Update Program is essentially complete. All system procedures and operations surveillance procedures have been revised, and the najority of the maintenance surveillance procedures have been revised to include independent verification. The remaining maintenance procedures have been revised, but not yet approved by ORC. Station management, however, is committed to approving each remaining procedure before the next required use of that procedure.

In addition, Procedure 1.3.34, " Conduct of Operations," was revised to specify what system categories must be independently verified, when, and by whom. The only remaining issue is to revise the Maintenance Request form to provide documented evidence of independent verification following maintenance activities.

TRAINING As discussed at the January 23 meeting, we performed a major re-assessment of our training methodologies and discovered areas we believe need improvement. Specifically, through our own self-evaluation and an independent evaluation by General Electric Company of our candidates, we acknowledged that although we have put together an excellent cadre and have a new dedicated training f acility, the training program itself couldn't turn out the desired product. As a result, immediate decisive action was taken to revamp the structure, faculty, and testing methods.

Essentially, we will utilize 1985 as an improvement year for our training program and staf f.

RADIOLOGICAL CONTROLS We concur with the assessment of the SALP Report and feel very strongly that our implementation of our Radiological Improvement Program will ensure positive results in f uture assessments.

MAINTENANCE We recognize the positive comments and acknowledge the Category 1 rating with pleasure. We will continue our improvement posture in program areas to sustain the current assessment.

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' SURVEILLANCE We acknowledge this Category 1 rating and concur with the NRC evaluation.

We intend to continue this high standard of performance for the present and future.

FIRE PROTECTION / HOUSEKEEPING As discussed during the SALP meeting on January 23, 1985, the NRC discussion of supporting information does not appear to substantiate the stated conclusion, i.e., Category 2, declining (during the SALP period).

With the exception of one negative paragraph dealing with the root cause of potential problems with fire doors and penetrations, the entire discussion of this category is positive and supportive of a Category 1 ranking.

Regarding the fire doors and penetration seals, although the doors were reported as non-functional in the LER, they were subsequently analyzed and determinid to be functional. Further testing and modification is planned to restore design margins. Of the approximate 6000 fire penetration seals inspected during the outage, 38 were declared as non-functional and reported in LER 84-07. A subsequent engineering evaluation determined that only 12 of these needed repairs to satisfy Technical Specification requirements.

Notwithstanding the above, management continued to exhibit aggressiveness, concern and attention to fire protection. An innovative approach of using dual-qualified Fire Inspector / Emergency Medical Technicians provided strict compliance to fire protection procedures; outstanding commitment was demonstrated by providing fire inspection coverage on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day basis during the outage; ef fective results were demonstrated because '

no significant fires occurred despite the extremely dif ficult construction conditions encountered during the recirculation piping replacement outage.

bs.s Similarly with housekeeping, strong management commitment and success were evident. In addition to the excellent fire protection results, good housekeeping contributed to an outstanding safety record, as no lost-time injuries were experienced by licensee employees for the duration of the outage.

Frequent visits from the corporate and executive office and positive results demonstrate continued strong management commitment, a strength which was noted in the 1983 SALP Report.

The plant cleanup (area decontamination) program is an aggressive licensee initiative which was begun during the SALP reporting period. Because of ,

the extensive maintenance and modification work throughout the plant, the identified work scope was not completed during the outage but is currently The required continued ef f ort

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reported to be approximately 70% complete.

for the future is recognized, with planning in progress. Management commitment and resource allocation remains strong.

Based on the results achieved during the reporting period, management attention and involvement has been aggressive and oriented to nuclear safety; resources are ample and effectively used so that a high level of performance is being achieved with respect to operational safety.

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,' SECURITY AND SAFEGUARDS The current organization dealing with this functional area was established in June 1983, and staf fed early in the SALP reporting period. During the settling-in period we had recognized the desire to af fect improved performance on the part of the contractor security force. Management oversight was increased in the form of unannounced, back-shift audits of the security force; security-related infractions were actively sought-out, reported, and the findings assessed and actions taken to provide improvement; efforts were initiated to increase the level of awareness of site personnel regarding security issues; a Nuclear Operations Procedure (NOP) was developed and issued to provide availability and use of a non-safeguard information security program document; a corporate security investigator provided full-time on-site support for a large portion of the recirculation piping replacement outage; and finally, significant pressure was initiated with the corporate management of the contractor security force as a result of minor problems discovered during the last security inspection.

Management attention was also manifested in other ways. Following the last security inspection, BECo management initiated prompt, thorough and effective corrective action on the identified violations; a corporate vice-president of the contractor security force was invited to a management conference to discuss actions to improve security force performance. The contractor agreed to provide internal audits utilizing off-site support; BEco requested and was granted a management conference at Region I to discuss actions taken and planned: Finally, BECo arranged to conduct the annual security audit earlier than originally scheduled, and to use an independent consultant to conduct the audit.

The actions described above demonstrate strong management attention and comitment to an ef fective physical security program.

EMERGENCY PREPAREDNESS Boston Edison recognizes that shortcomings in the 1984 exercise scenario, and in the mechanisms utilized to present scenario data to exercise participants, resulted in a dysfunction which prevented NRC observers from validating the continued effectiveness of the decision-making process for developing protective action recommendations and communicating these to off-site officials. Immediately subsequent to the 1984 exercise, Boston l I

Edison committed to the conduct of a remedial drill in November,1984, during which these key functions would be observed. This remedial drill l was held outside the assessment period, and Boston Edison has not received 1 the relevant inspection report, but recognizes the positive comments j offered by the NRC at our meeting of January 23, 1985, relative to i satisfying the principal concerns raised during the August,1984 exercise. I The problems encounte' red during the August, 1984 exercise also raised l concerns relative to Boston Edison's emergency preparedness training i program and the self-critique process. During our January 23, 1985 meeting, Boston Edison pointed out that a new eight unit training program had been implemented by the Training ~ Department during 1984, and that Boston Edison had committed in August, 1984, to expand this program by adding a unit on ef fective participant conduct during drills and exercises. This additional unit was developed and validated in anticipation of the November, 1984 drill. It will be administered to

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members of the emergency organization during 1985. Further, it is Boston

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Edison's intention to conduct " table-top" assessment and protective action recommendation development exercises in the context of future emergency preparedness training.

The 1984 SALP report also noted that the self-critique following the August 1984 exercise did not identify several minor problem areas. As noted during the January 23, 1985 meeting, we believe that this observation was also the result of the problems encountered during the August exercise, and that Boston Edison had demonstrated rigorous and effective critique capabilities in both 1982 and 1983. Boston Edison management will assure that the effectiveness of the processes to independently evaluate emergency preparedness capabilities are maintained, and that the 1985 post-exercise critique is both comprehensive and rigorous.

The 1984 SALP report also addresses habitability and space limitations of the existing Emergency Operations Facility (EOF) but notes that Boston Edison recognizes the need for a new EOF, and has taken steps to negotiate a new permanent facility with Plymouth County officials. (Boston Edison was notified in December, 1983, that the existing EOF was considered unsuitable because it did not meet the habitability criteria of NUREG 0737, and was asked to develop an alternative EOF concept.) During the January 23, 1985 meeting, an additional concern was raised relative to how the EOF would function in the context of interface with the considerable federal resources which could be brought to bear following implementation of the Federal Radiological Emergency Response Plan, as demonstrated during the federal / state / utility exercise at St. Lucie in 1984. This matter will be followed up between Boston Edison and Region 1.

Boston Edison has opted for a near-site (3 miles) EOF to assure rapid integration of the augmented emergency response team. We have committed to a 10,000 square foot facility, 5,000 square feet of which will be dedicated EOF space. In considering both size and location, Boston Edison considered both the size and location of the new St. Lucie EOF.

Representatives of Boston Edison and the architect / engineer for the new EOF will visit St. Lucie in early February. Boston Edison has also initiated a unique assistance program for the Commonwealth of Massachusetts, in cooperation with the Federal Emergency Management Agency and Yankee Atomic Electric Company which is intsnded, in part, to ensure smooth integration of federal response capabilities into the overall response effort.

Senior management appreciates the helpf ulness of NRC comments during the January 23 meeting, and will ensure that concerns expressed are effectively addressed.

REFUELING AND OUTAGE MANAGEMENT We are particularly pleased with the rating received in this area. The I concept of an Outage Management section dedicated to planning, scheduling I and managing all outage tasks worked extremely well for its first trial. l The experience gained through implementation of this innovative form of l task management will be applied during the current operating cycle. i Additionally, we will be fine tuning the programmatic aspects to enhance i the work flow process in areas we feel could be improved.

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LICENSING ACTIVITIES We acknowledge the Category I rating and concur that the NRC evaluation is accurate. Senior nenagement maintained an active involvement in this functional area with the specific objective of assuring that quality responses be provided in a timely f ashion. Overall, we believe we met that objective and appreciate the latitude afforded by the NRC to re-prioritize or postpone work when outage-related manpower constraints necessitated the shuffling of tasks to meet schedule demands elsewhere.

Those tasks which were postponed will be among our highest priorities as well as maintaining the high standard of performance reflective of this Category I rating.

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