IR 05000293/1988002

Insp Rept 50-293/88-02 on 880125-0204.No Violations Noted. Major Areas Inspected:Matl Condition Improvement Action Program

ML20151V017
Person / Time
Site:	Pilgrim
Issue date:	04/14/1988
From:	Blumberg N, Rebelowski T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151V003	List: IR 05000293/1988002 ML20151U999
References
50-293-88-02, 50-293-88-2, NUDOCS 8805020243
Download: ML20151V017 (23)

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U.S. NUCLEAR REGULATORY COMMISSION REGION I'

Report N /88-02 Docket N License No. DPR-35

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Licensee: Boston Edison Company >

800 Boylesten Street Boston, Massachusetts

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Facility Name: Pilgrim Nuclear Power Station Inscection At: Plymouth, Massachusetts Inspection Conducted: January 25 - February 4, 1988 Inspectors: 8 *

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T. Rebelowski, Senior Reactor Engineer, DRS Tate Approved by:r_ -

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N. Bluinberg, Cfief Operational grams ' dat%

Section, Operations Branch, OR ,

i Inspection Summary: Unannounceo Inspection on January 25 February 4, 1988

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LReportNo. 50-293/88-02)

Areas Inspected: The Boston Edison Company has committed to establish and implement its Material Condition Improvement Action Program (MCIAP). Administration, managerial and hardware changes

addressed in this report have been classified into thirteen issues which include eighty-nine sections that are to be addressed prior to restar Forty-three sections were reviewed during this inspection to determine the licensee's progress in the establishment of groundwork that will

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formulate progress, goals and policies that demonstrate

management's control of the plant.

I Results: This review of these MCIAP sections determined that the strengths of program include:

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The "Communication" issue, where stepping stones are

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now in place for Managers and First-line Supervisors

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to understand and implement Boston Edison goals.

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Housekeeping has shown dramatic improvements in area cleanup with a marked reduction in contaminated areas ( % of areas below 1000 DPM).

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The Measurement and Test Equipment Control Program that includes a new computer program that will monitor instrument statu Staffing where additional permanent personnel have been added to address plant planning functions thus relieving first line supervision of this tas The areas where additional management attention appears to be necessary are:

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Plans and schedules for performing post maintenance and post modification testing during system recovery and startup are not complete. Testing controls, including the determination of test requirements, scope of the testing program, test status tracking, documentation of test results and verification of data, are neede This concern is addressed in MCIAP Issue 03-017, Post Maintenance Testing, which is discussed in paragraph 2.8 of this repor In addition, the completion of Maintenance Requests (MR)

prior to restart is of concern due to the number that remain open. The outstanding 14Rs need additional licensee attention to allow an orderly approach to plant startu (Paragraph 2.9)

Overall, the MCIAP was determincd to be a viable program that will encompass programmatic improvements and it is being effectively implemente l

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AN L DETAILS 1.0 Persons Contacted Boston Edison Company Mr. R. Bird, Senior Vice President-Nuclear

• Hr. K. Highfill, Statinn Director Mr. M. Brosee, Maintenance Manager

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• Mr. J. Flanningan, MCIAP Review Staff Leader Mr. R. Sherry, Chief Haintenance Engineer Mr. P. Moraites Assistant Chief Maintenance Engineer

• Mr. B. Lunn, Sr., Compliance Engineer Mr. J. Mattia, QA Surveillance Eroup Leader

• Mr. R. Ledgett, Director Special Programs and Executive Assistant to Senior Vice President Mr. D. Sukanch, Station Facility Manager l Mr. B. Deacon, Assistant to Senior Vice President Nuclear

• Mr. P. Hamilton, Compliance Engineer  !

• Mr. L. Dooly Technical' Training

• Mr. J. Quinn, Sr., QA Engineer

• Mr. E. Ziemianski, Nuclear Training Manager

• Mr. K. Barrett, Plant Manager

• Hr. E. Kraft, Plant Support Manager

• Mr. R. Anderson, Outage Manager ,

US Nuclear Regulatory Comission

• Mr. N. Blumberg, Chief, Operational Programs Section, DRS '

• Mr. C. Warren, Senior Resident Engineer

• In attendance at exit meeting The inspector a' iso held discussion with other licensee personnel during the course of the inspection 2.0 Material Condition Improvement Action Program (MCIAP)

The licensee has developed a Material Condition Improvernent Action !

Program (MCIAP) that addresses maintenance planning, schedule preparation, work assignments, work progress, workforce supervision and discipline, workmanship practices, material condition and management '

control. The action plan consists of thirteen (13) issues with eighty ,

nine (89) individual items to be addressed and corpleted prior to restar i 1 The initial NRC inspection of MCIAP program is docurrented in NRC ;

Inspection Report 50-293/87 42. The program was found to address many of the areas of irprovement necessary to conduct the activities of

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maintenance managenent. A review of the restart items follow ,

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4 Issue 03-001 - Organization and Staffing (Restart Items)

This a ea of organization and staffing is addressed in the following subsections:

2.1.1 Section 03-001-01 - Promulgate Organization Licensee Action: Distribute the current nuclear organization structur Licensee Closure Requirements: Memorandum distributing copies of nuclear organizatio Inspector Review: On November 16, 1987, Document NOM 87-315 distributed a number of figures that depicted the BECo Nuclear organization. Recent revisions to BECo organization were addressed in a January 7,1988, BECo letter to USNRC identifying changes instituted, including a new position of Station Director, and the replacement of the Plant Support Manager and Planning and Outage Manage These changes have been promulgated to first line management personne This item is complet .1.2 Section 03-001-02 - Brief Managers and Supervisors Licensee Action: Section Managers to brief all management and senior supervisory personnel on current organization structure and the assignment of responsibilitie Licensee Closure Requirement: Completion of briefings with documentation of participant Inspector Review: The licensee has briefed managers as to the organization and responsibilities of individuals in the nuclear organization. The lectures and the distributed position charts were revised and updated and pertinent portions were discussed with supervisors. The licensee closed this item on August 24, 1987. A recent letter (January 7,1988) from the Senior Vice President-Nuclear to NRC, documented ongoing changes of positions. The inspector's discussions with first line

supervision indicated a satisfactory level of knowledge of the i present nuclear organization. This item is complet I

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2.1.3 Section 03-001-03 Managemar.t Naintenance Organization Licensee Action: Conduct a comprehensive review of the functions, responsibilities, processes and procedures of the NUORG organizational structure which should be in place to effectively maintain the station at the required level of material condition and to plan for and manage scheduled and unscheduled outages. This review is to encompass planed improvements in processes and procedures and focus on strengthening control and discipline. The above action was to be started at full power and 90 day Licensee Closure Reouirements: The following tasks are to be addressed: Report describing proposed realignment of major functions and responsibilities of NUORG organizational unit . Proposed NUORG organizational char . Matrix showing assignment of functions and responsibilities in the current organization and the proposed organizatio . Matrix showing assignment of similar functions and responsibilities in at least thre) other operating nuclear power station . Discussion of changes to existing processes and procedures necessary to implement the proposed organizational changes with advantages and disadvantages clearly state . Proposed implementation plan with schedul . Formal Senior VP Nuclear disposition of recommendation Inspector Review: The licensee has addressed items 1, 2, 3 and 5. This early start on the establishment of the orge.nization goals for the management of licensee plant, indicates a determined effort to bring about meaningful staff changes with a comprehensive program of self assessment. Although not complete, the changes are the early steps in the establishment of managements control of the self identified existing problem .2 Issue 03-004 - Administrative Demands This area of "Administrative Demands" is addressed as a MCIAP restart item in the following subsection . Section 03-004-01 - Assign Contractor Authority Licensen Action: Issue administrative authority to contractors filling BECo supervisory position ,-Q >- .

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Licensee Closure Requirements: Issue documentation for requisition validatio Inspector Review: The authority for requisition and procurement has been issued and items closed on July 31, 1987. Based on a reduction of maintenance contractor supervision this item has a reduced impact. This item is complet .2.2 Section 03-004-02 - Identify Inaporopriate Activities Licensee Action: Interview and observe first line supervision to identify adninistrative functions and other inappropriate activities which divert supervision from the primary responsibilities on job site of directing workforc Licensee Clorure Requirements: Complete evaluatior and list functions that deter first line supervision from direct work supervisio Inspector Review: The licensee has surveyed first line supervisors and determined the areas where additional administrative aid could bring forth on-site workforce direct supervision in the field. Areas identified that should be ramoved from first line supervision involvement includes procurement support, material expediting, the need for additional planners with the responsibilities in areas of maintenance request support, the maintaining of workers timesheets to specific modules of work and the required attendance of supervision at meetings. Actions have been taken by licensee to address these identified problem areas. This item is complet . Section 03~004-03 - Reduce Supervisors Activities Licensee Actions: Transfer the major inappropriate supervision activities to a different individual or organization element to enable supervisors to fulfill their primary responsibilitie Licensee Closure Requirements: Identify the major inappropriate activities transferred and how each activity will be performed in the futur Inspector Review: The licensee has performed a work study of first line supervisors daily activitie The conclusions reached were that over 50% of the time of the first line supervisor was utilized in a search for proper paperwork and l

lack of support from other organizations (obtaining work packages, parts, operational review, etc). Additional staff engineers in maintenance have been added for planning.

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Relocation of outage managers office to supply direct support to supervisors has been accomplished. Contractors have been added to relieve first line supervisors of the administration functions of overtime management and to expedite material Permanent staff increases have been requested for the 1988 budget, so as to secure a permanent staff to replace Contractor Il The inspector interviewed several first line supervisors to  !

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determine if they have been able to utilize this freedom from administrative functions and all believed they have been able to spend more time in the field, monitoring work activitie This item is complet .3 Issue 03-005 - Work Performance Standards

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The licensee has identified areas that require additional emphasis regarding station and contractor maintenance personnel lack of adhering to good industry practices. The specific topics addressed ,

include the standard for high quality work performance, personnel safety, equipment and system protection and plant safety and reliability. Eight subissues are to be addressed prior to restar The following issues were reviewe . Section 03-005-01 - prepare Briefing Materials Licensee Action: Prepare briefing materials and handouts which set forth the responsibilities of first line supervisors for enforcing performance standard Licensee Closure Requirements: Issue copy of briefing material Inspector Review: No formal briefing material was prepared. A  ;

General Maintenance Checklist addressing personnel responsibilities was used to train personnel on some of the  :

required attributes, This item is under licensee's review to provide additional material to aid in briefing maintenance management in supervisory skills. This iteht is not yet complete .3.2 Section 03-005-02 - Brief Supervisors Licensee Action: Formally brief all first line supervisors in BECo's maintenance organization and emphasize to each what management expects from them, including how much time of each l day they should spend at the worksit Licensee Closure Requirements: Certify completion of these i briefings and include a listing of personnel briefed and their position L

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Inspector Review: The licensee has briefed the first line supervisors of BECo and Contractor personnel on their duties of using a maintenance check list. In addition, surveys were taken during a one month interval that concluded that more than 50% of supervisors time per day was spent on administration of timekeeping, material iequisition and procurement. Recent charges to management assures that additional attention has been placed on the recognition of the lines of authority and the need to monitor field performance. Observations made during tours on January 27, 1988 of the plant identified a first line supervisor engaged in direct supervision of a wori task on an air operated valve. Discussions with the supervisor found him to be knowledgable of the task being performed, and the required documentation was at the worksite. This item is complet .3.3 Section 03-005-03 - Manager Worksite Tours Licensee Action: Establish the practice of having cognizant maintenance managers tour worksites with first line supervisor on a periodic but random schedul Licensee Closure Requirements: Maintenance managers required to tour worksites with first line supervisor on a periodic but random schedul Inspector Review: The licensee has developed and instituted a policy of Station Inspection Tour Plans. The plan designates supervisors to tour the plant during certain interval Review of the documentation indicates that the tours have varied in their results. One third of scheduled tours were not performe The licensee is presently revising the tour plan. The licensee is taking additional action. This item is not complet .3.4 Section 03-005-04 - Senior Manager Worksite Tour Licensee Action: Establish the practice of having senior managers in the nuclear organization tour accessible worksites in the plant on a regular but random basi Licensee Closure Requirements: Licensee to issue memorandum on specific senior management tour Inspector Review: The licensee has issued the required memorandum designating tours (9/8/87). The licensee's monthly check of implementation of senior management tours for the periods of 9/14/87, 9/28 to 10/2 and 11/2 to 11/5 documented no senior management tours. As of 1/88 a new management staff has been assigned to site. A new memorandum has not been issued to implement the required tours. The inspector's review of entries l

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into worksites by the present station director, plant manager, planning'and outage manager and plant support manager noted numerous entries had been made into the power block during tne month of January. Based on present management's regular but random tours of worksites, this item is complet .3.5 Section 03-005-05 - Contractor Worksite Tours t.icensee Action: Establish the policy of having RECo managers tour contractor worksites on a regular basi Licensee Closure Requirements: Memorandum to be issued to BEco managers and onsite contractor representatives on conducting tours of worksites, in addition to maintaining a log of such tour Inspector Review: This section is similar to Section 03-005-0 No memorandum was issued requiring contractor accompaniment with BECo management, due to reduction of contractor supervision on site (80 to 39) and an incomplete secticn (03-005-03) that will address this section's requirements. Thi item is complet .3.6 3ection 03-005-06 - INPO Observation Training Licensee Action: Complete INPO observation training for first line supervisors to improve their skills in identification of unsatisfactory worksite practic Licensee Closure Requirements: Completion of INPO obsarvation training and document the attendance of the supervisce Inspector Review: The licensee has presented the observation training to eighty (80) first line supervisors. Tie training has been incorporated in the BECo training lesson plan TDC-01-01. The inspector reviewed the instructor's guide and student presentation documents and found them satisfactor During tours of the reactor building the licensee's observer accompanying the inspector did identify a number of minor discrepancies. Interviews with several of +.he first-line supervisors indicated that the training did aid in identifying the housekeeping problem Based on training documentation, the contents of the training materials and observations in field, this item is complet . Section 03-005-07 - Assign Maintenance Coach Licensee Action: Assign an experienced, maintenance oriented individual, to tour worksites to observe work practices and worksite condition s

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Licensee Closure Requirements: An individual is to be designated, responsibilities outlined and tna individual relieved of all other responsibilities (intended to be full time position).

Inspector Review: The licensee designated an individual on 7/3/87 for the position of maintenance coach. This individual is pr9sently supervising 80 maintenance / cleaning type personne His assistant has been delegated to observe work sites during his normal tours of the plant (daily). The inspector toured the Reactor Building with the "maintenance coach" and found him to be knowledgeable of methods to maintain cleanliness of areas duringperformanceofmaintenance. The present maintenance coach s assistant tours all areas and is in the containment and the reactor building enclosures several times a day (approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> a day). The contamination levels have been significantly reduced. Areas are clean and well organize 61, e.g. cleaning tents were in place. This item is complet .3.8 Section 03-005-08 - Prepare Visual Displays Licensee Action: Prepare a visual display which illustrates the

. quality standards expected as well as examples of conditions which are not acceptabl Licensee Closure Requirements: To install a photographic display illustrating current and desired housekeepin Inspector Review: The licensee has installed a display cabinet with photograohs illustrating unacceptable standards v acceptable standards. In addition, observations of good working practice exhibiting contamination control is on display in the lobby of the administration annex exhibiting contamination control. During a tour of the reactor building the inspector noted the use of a glove box similar to one displayed. The photo display is changed on approximately a monthly basi The licensee has met the action item closure requirements. This item is complet .3.9 Section 03-005-12 - Revisit Closed Items Licensee Action: Establish a method to revisit MCIAP items that have been closed. The pa pose of this revisit is to ensure continuance of the implementation of MCIAP section Licensee Closecut Requirements: Prepare and implement methods used for selection of MCIAP items to be reviewed, determine interval and reporting mechanism.

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Inspector Review: The licensee has established an acceptable method for documentating his revisits to the previously completed MICAP items. A monthly check on MCIAP items has been i instituted by by the licensee. Several previous completed MCIAP items were revisited and found to be acceptable, or where they were unacceptable followup was implemented with the cognizant department managers. This item is complet .4 Issue 03-008 - Material Condition The licensee has recognized that the station material condition and

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housekeeping need improvement. The desired standards have not been l defined, established or communicated to station persunne Four subissues are to be addressed prior to restart. The following l issues were reviewed: ,

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2. Section 03-008-01 - Material Condition and Housekeeping l

l Licensee Action: prepare a schedule, which considers other i

ongoing outage work, to systematically remove loose surface i contamination from all reasonably accessible plant areas including ventilation lines, :ableways, overhead framing, grating, et The schedule is to list specific areas to be cleaned, room by room and provide dates for cleaning each area.

l The priority shall be on those areas not routinely accessible during plant operation and areas where loose contamination is l easily spread to other area Licensee Closure Requirements: A copy of the area decontamination schedule and memorandum from the outage manager reporting that the decontamination plan has been included in the Plan of the Da "

Inspector Review: A routine plant decontamination and support schedule was reviewed on 1/20/8 The priorities assigned for the areas to be cleaned is first the nonroutine accessible spaces and than those areas of loose contamination that can be easily spread; a frequency of cleaning (Daily, Weekly, etc.) is noted in schedule. A walk through of plant areas indicates that the areas viewed were acceptabl This item is coroplete,

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2. Section 03-008-02 - Decontamination Priority Areas Licensee Action: Complete the cleaning anti decontamination of l priority areas, prior to the completion of refueling outage-7 Licensee Closure Requirements: Memorandum reporting completion  !

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of cleaning and decontamination of designated priority areas.

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Inspector Review: The licensee's commitment of bringing 90%

of the targeted areas to a level of less than 1000 DPM has not been completed. Results of the scheduled cleaning indicates 81%

of the areas targeted were completsd out of the 90% require The licensee has expended a major committment in resources to ,

attain this high level of (81%) of the areas decontaminate Areas requiring protective clothing measures have been reduce The licensee is to take further action. This item is incomplet .4.3 Section 03-008-03,- Leak Repair and Decontamination Policy

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Licensee Action: Issue a policy directive requiring that the repair of all leaks be accomplished on a priority basis and that loose surface contamination is to be removed immediately after i

the repair of leaks and prior to closure of the work ite Licensee Closure Requirements: Copy of issued policy directive.

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Inspector Review: The licensee issued a directive on the

removal of loose surface contamination and the MCIAP was close The follow up closure action check has identified the need to l

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rewrite the decontamination and leak identification procedur In addition the licensee identified on 9/9/87 the fact that no !

policy exists for requiring repair of all leaks on a priority basis. As of the fourth monthly check no action from the maintenance manager was provided and a memorandum has been directed to the plant manage The licensee addressed this concern with a preliminary procedure ,

developed to detail specific actions that will address immediate investigation of reported leaks, to isolate or prevent [

additional damage from occurring. Once a leak is identified the prioritization of repair will be performed and leak containment will be institute The mur.itoring group on MCIAP-CAC (Closure Action Check) has identified the lack of a polic This action indicates a lack of timely response to MCIAP followup from a department manage '

This item requires further licensee actio . Section 03-008-04 - Decontamination Process Indicator Licensee Actions: Establish a visual management indicator which displays progress towards achieving the plant decontamination '

goal for the current outage and for long term goal i

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Licensee Closure Requirements: Establish a progress indicator T with a specified update frequenc Inspector Review: The license has issued on a monthly basis the percent of areas that are considered clean. Criteria used ,

include a process indicator used for track!ng progress. This indicator has been observed on the bulletin boards. One of the maintenance department goals is to reduce and maintain 90% of 3 the plant's area inside process buildings to levels that would permit access in street clothes by the time the plant restart The percent completion of the controlled area decontaminated has reached 81%. The establishment of a visual management tool is complet .5 Issue 03-009 - Performance Goals i Boston Edison personnel and contractor management should have a clear understanding of the goals established for Pilgrim Station. These ;

goals should provide sufficient direction so that employee work efforts are focused and individual con sense accomplishment when goals are achieved. The following two subissues are to be addressed prior to restar .

2.5.1 Section 03-009-01 - Brief All Hands On Goal ,

Licensee Action: Formally issue the current Nuclear  ;

Organization Goal (NUORG)

Licensee Closure Requirements: Official copy of NUORG goals are distribute Inspector Review: The licensee NUORG as established by the !

Senior VP-Nuclear was distributed to a limited number of managers (9) of which several are no longer associated with the attainment of NUORG. The licensee's "All Hands Goals Information" is addressed in newsletters such as "Nuclear Newsbreak", and FYI "For Your Information" to inform station personnel of ongoing issues, Presantly the "FYI" is published on a twice a month schedule. A one day turnaround schedule will be implemented when important issues are to be addresse Discussions with newly appointed managers verified that they were cognizant of NUORG's. This item is cceplet .5.2 Section 03-009-02 - Goals Achievement Criteria Licensee Action: Provide an official means to periodically inform employees of management assessment of progress toward ;

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Licensee Closure Requirements: Memorandum outlining means to be used, topics covered, how assessment is to be made and how the information is to be disseminatec;.

Inspector Review: The licensee has developed and issued a l number of information letters including "For Your Information"

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newsletter and "Nuclear Newsbreak." General information on the EEco goals that each individual must set to achiese the Pilgrim Restart Schedule and a assessment of the progress has been addressed and has appeared in these publication The memorandure that was issued that included as a attachment the NUORG for 1987 and 1988 listed each nuclear department organizations specific goals. This memorandum which was issued on June 1987, instituted monthly meet rgs on e.chievement of d

goals. The Senior Vice President-Nuclear has met with the and a review of the audit packages indicated department mann ",,s'rogram to reeet goals was in force. This that an aggrest year's goals ha a w n discussed with a scheduled issuance to the various depai m....its in late February,1988. This item is complet .6 Issue 03-010 - Communications The licensee's self assessment recognized the need for both horizontal and vertical communication within the plan Effective communications are needed to facilitate teamwork and implementation of management guidance and feedbte Six subissues are to be addressed prior to restar The following issues were reviewed, s

2. Section 03-010-01 Issue Action Plans Licensee Action: Emph nize within the nuclear organization the three primary focal points for communication within the nuclear organization with respect to maintenance activitie Ltcensee Closure Requirement: Issue the restart plan and MCIA Inspector Review: The Senior VP- Nuclear has issued a memorandum that instituted the MCIAP with due dates for completion. In addition the estart program plan was distributed to managers with specific responsibilities delineated. This item is complet ,

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2.6.2 Section 03-010-02 - Short Range Maintenance Request (MR)

Schedule Licensee Action: Establish the practice of utilizir.g the Plan-cf-the-Day (P00) with short range schedules to coordinate and assign work to the first line superviso Licensee Closure Requirements: Provide short range schedule Inspector Review: The Plan of the Day combined with the four day look anead listing the "Maintenance Request Packages" by department designation, with the generated system schedule availability, allows planners to schedule work from the master schedule. Although a number of inputs are necessary to attain the final work assignments, based on review of the four day look ahead schedule and POD, the licensee has a process to assign work to first line superviso The inspector attended a Plan-of-the-Day Day meeting on 1/29/88 and discussions centered on schedules of MR's and additional nuclear systems statu This item is complet .6.3 Section 03-010-03 - Restart Progress Assessment Licensee Action: Issue a memorandum informing cognizant managers and supervisors of the method to be used for closure of Restart Plan action Licensee Closure Requirements: Issuance of memorandum deliniating the method to be used to effect closure of action item Inspector Review: A memorandum describing the method of closure of restart plan action items was issued on 8/7/8 The remorandum denotes responsibilities, review of the data base and management administrative guidelines. This item is complet . Section 03-010-04- Performance Excellence Team (PET)

Licensee Action: Establish a PET representing each functional area of the Nuclear Organization to identify and remove obstacles that hinder performance and to improve the flow of information within the NUOR Licensee Closure Requirement: Copy of memorandum establishing PET, its purpose, areas of responsibility and requirement for periodic assessmen Inspector Review: The PET team was established on 5/14/87 and had met on a weekly basis. Review of minutes in closecut package exhibits determined that a wide range of topics were discussed. There was no method of periodic assessment other

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than weekly reports onl PET accomplishments. The PET presently

has.not continued-to meet on any specific frequency. Discussion with managen,ent indicated that only limited results were obtained from PET and that it would be dissolved. This item is currently under licensee evaluatio . System 03-010-05 - Shift Coordinators Licensee Action: Designate a single individual as the point contact on each shift to coordinate communications and resolve problems affecting maintenance and/or construction wor '

Distribute the namcs and telephone numbers of these personnel to all supervisor Licensee Closure Requirements: Document the assignments of the coordinators. to the management personnel on all shifts. Inform individuals of their duties and responsibilities. Brief BECo and ,

contractors of these ind1viduals to resolve holdups and have management evaluate effectiveness of the role of shift coordinato Inspector Review: Documentation indicated successful performance of the shif t coordinator in resolving inter-trade l and inter-departmental problems. The inspector inspected logs and interviewed the AD00MS (Assistant Director of Outage Management) shift coordinato His responsiblities for coordinating the production schedule and resolving immediate problems or conflicts in the implementation of the Plan of the Day (P00) was understoo Interviews wits personnel were conducted and logs were found to reflect solutions to numerous interface problems. This item is complet .6.6, Section 03-010-06 - Daily Reviews of Maintenance Requests (MRs)

Licensee Action: Establish a daily routine for the Chief Operating Engineer and the Chief Maintenance Engineer to review all Maintenance Requests (MR) originated during the previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> The purpose of this review is to classify and establish the relati.e priority of each MR, and help ensure that second and third priority work is planned and schedule Licensee Closure Requirement: Issue directive initiating the daily reutines; change MR procedure to reflect daily require-ments; and establish criteria for prioritizing MRs and evaluating effectivenes !

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Inspector Review: The licensee has incorporated the MR daily review process in Revision 21 to the Maintenance Request Procedure which established the method of prioritization. This routine has resulted in a marked decrease in priority one item The overall MR's still remain numerically high and additional management attention to lower the backlog of MR's is necessar This item is complet .7 Issue 03-013 Maintenance Requests The licensee's maintenance requests have not identified the type of work, tagging procedure prior to diagnosis of components; nor the specific problems requiring maintenance. In addition the work control system could not readily identify redundant MR's. A revision to work control should be instituted that will accurately identify the plant deficiencies and the work to be accomplished. Two subissues were revi wed during this inspectio . Section 03-013-02 Maintenance Planning Licensee Action: 1ssue a revision to Procedure Number 1 5.3,

"Maintenance Request," to improve classification, priorit',' zing, tracking and managing deficiency items and maintenance action Licensee Closure Requirements: Revise Procedure Number 1.5.3, Maintenance Requests Inspector Review: Prior to the outage the licensee did revise Procedure 1.5.3 (Revision 21) that did address immediate concerns of classification, prioritization and trackin Additional areas of retest of systems, reviews of retests were addressed in a subsequent revision to the procedure (present Revision 24) and additional management review is continuing to improve system control. This item is complet . Section 03-013-03 Maintenance Request Process Training Licensee Action: Reindoctrinate personnel in the changes made to the MR process for the current outage as well as existing requirements which are incorrectly interpreted or not followe Licensee Closure Requirements: A copy of briefing materials and handouts and certification that personnel have been briefe Inspector Review: The briefing paper inciuded the procedure

"Maintenance Work Request 1.5.3, Rev. 21." Sections that were changed were identified and discussed during the briefing Documentation of the training conducted was acceptable. The licensee issued Revision 24 to procedure 1.5.3 during this s

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inspection. No documented formal training or the need for

training existe Interviews indicated that maintenance

., personnel were informally indoctrinated thru supervisors'

./ meetings. Continuing. training appears warranted in this are This section is complet .8 Issu'e 03-017 Post Maintenance Testing

, The licensee has recognized that plans.and. schedules for performing post maintenance and-post modification testing during system recovery and start up are not complete. Post maintenance testing controls, including the determination of test requirements, scope of testing program, status tracking, documentation of results and verification of data, are neede Five subissues were reviewed by the' inspecto . Section 03-017-01 - Review Testing Program Licensee Action: Commission an independent review team to ,

determine the extent nf problems in the existing condition of Issue 03-017 and establi<,h short term and long term actions '

required to put in place ar, effective post maintenance post modification testing progra Licensee Closure Requirement: Establish a review team and report disposition of review team recommendation Inspector Review: The licensee established two teams, a Post ;

Work Testing Team and a "Tioer Team" tu determine policies to

. pursue in addressing Post Work' Testing (PWT). The teams provided policies and other benefits. A PWT review with various attributes was developed to assure that proper testing was being .;

performed an'd with the ability to track and audit testing. A PWT Short Term Program that instituted a "ready to test Maintenance Request (MR) file" with review teams that classified and reduced the total inventory of MR's. An additional problem area identified was the lack of guidance to identify testing requirements. The (INP MA-3055) matrix of generic test activities was used as guidance and required that responsibilities be clearly defined, addressed the assignment of

, qualified personnel and the updating of testing requirement The guidance satisfies the section. This item is complet .8.2 Section 03-017-02 Prepare Testing Schedule Licensee Action: Develop an integrated test schedule to complete all testing evolutions sufficiently in advance of the scheduled restart date to allow for minor deficiency correction and system certificatio This schedule shall be worked backward from the restart date.

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Licensee Closure Requirements': Copy of current schedule that intergrates all post maintenance and surveillance testin ~

Inspector Review: A Maintenance Request (MR) Test Schedul Plant. Design' Change / Test _ Procedure and MR data base exis Recently (January 1988) the licensee's MRs were reviewed .to determine the need to complete items prior to the system turnover and/or power ascension. Present data systems require individual rev!ew of each data system output to ascertain status of MR items to be tested. A power ascension testing schedule is presently being develope The schedules are not totally integrated. Discussions with management indicate that increased attention has beer given to -

scheduling the completion of MRs thus increasing the need for retesting with proper scheduling to equalize man-hours over the period prior to plant startu Licensee continued review of the scheduling and completion of MRs with a marked reduction in total uncompleted items is needed. This item'is incomplet .8.3 Section 03-017-03 Revise Testing Procedure Licensees Action: Revise Station Procedure 1.53, "Maintenance Request," to include specific guidance for post work testin Licensee Closure Action: Copy of Approved Procedur Inspector's Review: Revision 22 to the Station Procedure 1. "Maintenance Request" addresses Post Work Testing (PWT) and referenced Nuclear Operation Department Procedure No. 3.M.1-30, Post Work Testing Guidance. The PWT guidance is a generic procedure that guides the staff thru a matrix of component repair versus test requirements. This procedure can be used as the minimum test requirements where no Technical Specification (T.S.) or regulatory requirements are to be addresse Revisions to Post Work Testing and continued development of this matrix are being pursued by maintenance managers. This item is incomplet ,

2. Section 03-017-04 Establish "Tiger Team" Licensee Action: Establish a "Tiger Team" of personnel from Maintenance, Operations and the Technical Section to review all active MR's for testing ac'equacy and consistenc Licensee closure Requirement: Establish the team listing individuals assigned, their responsibilities and reporting structure.

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Inspector Review: A "Tiger Team" was estabiished to review Po:t Work Testing (PWT) of Maintenance Requests in the present test-fil Initial review of the test ffle by the team determined that there were initially 400 MR's required for core reload. A Post Work Testing review sheet was formulated with testing parameters for required review. The "Tiger Team" concept was a short term program which was dissolved after reload. The need for a long term program is under management review. No "Tiger Team" exists today. This items is complet .8.5 Section 03-017-05 Ettablish Testing Requirements Licensee Action: Review active MR's to ensure that post refueling work and technical specification (TS) requirements are identified and rescheduled for accomplishmen Licensee Closure Requirements: Verification that active MR's have been reviewed and post work testing and required TS testing has been identified and placed in the "MR Testing and Outage Schedule."

Inspection Review: Initial action has been taken. The completion and integration of a program that will monitor MRs with inputs from failed MR tests has not been complete The licenseo is to take further action on this ite .9 Issue 03-019 Centralize Planning The Maintenance Department Planning Group is not assigned the responsibilities for all planning. Many planning activities are performed by the staff engineer and operations personne Maintenance planning should be assigned to centralized planning group. Twenty restart sections were formulated to address the above issue. One issue was reviewe Section 03-019-15 - Resolve Restart Items Licensee Action: Review all open items in the below listed tracking systems for issues which have the potential of affecting construction and/or maintenance work on systems supporting plant restart. The following tracking systems were reviewe MCARs - Management Corrective Action Request Deficiency Reports DRs - Deficiency Reports MRs - Maintenance Requests ESRs - Emergency Service Requests PDCs - Plant Design Changes PCA0 - Potential Condition Adverse to Quality NRCC - NRC Commitments s

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Operational Experience Review Program ,

r F&MR - Failure and Malfunction Report

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License Closure Requirements: Review tracking system .

Inspector Review: L A computer generated listing of items necessary for restart is available. Meetings are presently held on a bi weekly basis to update these items. Individuals assigned to each computer input consist of operations &

maintenance management and start up staff members. Comparisons >

of deleted and entered items have been monitored by the senior resident inspector. The licensee's review meets the requirement of MCIAP. The present listing exceeds 1000. items. One area that was not initially addressed was the required preventive and

. corrective maintenance surveillances and was added to the reviewed documents later. " is item is complet .10 Issue 03-028 - Preventive Maintenance The existing preventive maintenance program is not based on a systematic review of station equipment that includes engineering and

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' economic consideration. Stand alone procedures <and the scheduling and distribution of work loads are necessary ingredients not '

presently found in the preventive maintenance program.

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2.10.1 Section 03-028-01 - Schedule Preventive Maintenance Licensee Action: Include equipment preventive maintenance work item in the outage schedule established by the Plan of the Da Licensee Closure Requirements: Practices have been established i to routinely include preventive maintenance work items in the [

short range outage schedul Inspector Review: The short outage schedule includes in the Plan of the Day a list of preventive maintentnce items and tests. Procedures, including No. 1.8.2, Preventive Maintenance

Tracking Program, identifies the preventive maintenance (PN)

item list for work performance. In addition group tests (electrial, niechnanical, & IC) are sorted by due date. If tests '

are not performed or missed a Variance Report (VR) is generated, that documents the cause of the failure of licensee to perform the tests. The licensee has 38 overdue surveillance tests as of end of the report perio The system to document reasons for failure to perform tests is acceptabl This item is complet .10.2 Section 03-028-02 Schedule Preventive Maintenance for Restart t

Licensee Action: Include scheduled P.M. items in the scope of work which is scheduled by the Planning and Restart I

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Licensee Closure: Requirements: Issue memorandum reporting that the practice has.been established to routinely include preventive maintenance work items.in the short range outage schedul In'spector Review: The precritical Test / Plant Startup (Checklist

1. 6) does not directly address the area of tracking maintenance tasks with the Preventive Maintenance Check List (PMCL). This contains 2788 items of which 38 PM items are overdue. The '

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present system will allow traceability of the status of preventive maintenance program. Additional attention is necessary in the areas of scheduling and planning for the performance of preventive maintenance tasks. This item is incomplet .11 Issue 03-029 Measuring and Test Equipment This issue addresses the need to assign clear accountability for the control, calibration and maintenance of measuring a..d test equipment ,

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2.11.1 Section 03-029-01 Maintenance Calibration Licensee Action: Conduct a complete inventory of M&TE in the i maintenance area and enter the basic information required for calibration recall into an automated data bas ;

Licensee Closure Requirement: Complete inventory and data entr Inspection Review: The licensee has completed the inventory of i instruments and has identified numerous out-of-calib' ration i

, instruments and a review of the use of these instruments is

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underway. A numoer of instruments are missing and were

' replaced. The use of hand logging is prevalant but with greater issuance control. Observations by the inspector did not identify any discrepancies in a sampling review of data. Data entry into a computer based system was ongoing but not complet Management's surveillance of instruments in use in the field is l

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ongoing by supervisor This item is complet :

i 2.11.2 Section 03-029-02 Temporary Staff

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Licensee Action: Establish a temporary staff to centrally

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control the issue and calibration of M&T ,

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Licensee Closure Requirements: Copy of organizational chart and a description of t.he function and responsibilities of the staf ,.

Inspection Review: The licensee has assigned four_ technicians on an. interim basis. Permanent positions have not been formulated. Present staff (contractors) were interviewed and observation of the methods of control determined them to be adequate. Management continuing review of the program is nece s sary. This item is incomplet .11.3 Section 03-029-03-Maintenance Management-Storage Area

Licensee' Action: Identify space convenient to the maintenance, operation, centralized storage and inventory control (issue and receipt) of M&T Licensee Closure Requirements: Memorandum reporting.that centralized storage and inventory control has been establishe . Inspection Review: Observation of present M&TE storage areas was performe Procedural controls and physical controls have '

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been established to preclude the previous uncontrolled issuance of equipment. A walkthrough of areas that have been designated as '

storage areas will be adequate when proper shelving a storage bins have been installed. The areas are to be renovated to accommodate issuance of equipment while maintaining preventive measures to preclude unauthorized withdrawal of equipment. This item is incomplet .0 Conclusion:

The individual reviews of the Material Condition Improvement Action

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Program has denoted where the licensee is to take further action. The l program requires completion of all issues with accompanying management controls over all phases of the planning, maintenance and operational aspects of the Pilgrim Nuclear Station.

' 4.0 Exit Meeting

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i The inspector met with licensee representatives on February 4, 1988, to ,

summarize the scope and findings of the inspection. The areas of concerns  ;

were discussed and licensee's responses are addressed under each secton of  ;

this report. At no time during the inspection was written material i provided to the licensee by the inspectors. Also the licensee did not indicate that any proprietary information was contained within the scope i

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