ML20155D063

Notice of Issuance of Final Director'S Decision Re Request to Have Plant Remain Shut or License Suspended

ML20155D063
Person / Time
Site:	Pilgrim
Issue date:	10/06/1988
From:	Wessman R Office of Nuclear Reactor Regulation
To:
Shared Package
ML20155D072	List: ML20155D063
References
2.206, DD-87-14, DD-88-16, NUDOCS 8810110070
Download: ML20155D063 (2)

Text

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7590-01 UNITED STATES NUCLEAR RC'i;LATORY COMMISSION BOSTON EDISON COMPANY PILGPIM NUCLEAR POWER STATION COCKET NO. 50-?93 NOTICE OF ISSUAhCE OF FINAL DIPECTOR'S DECISION Notice is hereby given that the Director, Office of Nuclear Reactor Regulation, has issued a final decision concerning a request filed pursuant to 10 CFR 2.206 by the Ponorable William R. Golden which requested that the Pilgrim Nuclear Power Station remain shut down or have its license suspended because of (1) deficiencies in the licensee ranagement (2) inadequacies in the emergency radiological plan, and (3) inherent deficiencies in the contairment structure.

The Director of the Office of huclear Reactor Regulation issued an Interim Director's Cecision on the Petition dated August 21, 1987. The Interim Decision ccncluded that the Petition with the exception of the licensee management issue, should be denied. The reasons for the Cecision were explained in the "Interim Director's Decision Under 10 CFR 2.206."

DD-87-14, which is available for public inspection in the Comission's Public Document Roem, Gelman Building Lower-Level, 2120 L Street, N.V., Washington, CC 20555 and at the 1.ocal Public Document Decm at the Plymouth Public Library,11 North Street, Plymouth, Massachusetts 02360.

The Director af the Office of Nuclear P.eactor Regulation has determined that the remaining issue, deficiencies in the licensee maragement, shculd be denied. The reasons for this cecisicn are explained in the "Final Director's l Decision Under 10 CFR 2.?" " 00-88-16 , which is available for public l

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< s Public Cocurent Decn, in the Gelman Buildirg, Lower-Level, 2120 L St., N.W. Washington, CC 20555 and at the Local Public Docurent Rcom at the Plymouth Public Library,11 North Street Plyncuth, Massachusetts 0??f0.

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4 A copy of the Decision will be filed with the Secretary for the Comission's review in accordance with 10 CFR 2.206(c). As provided in this

! regulation, the Decision will constitute the final action of the Comission twenty-five (75) days after issuance, unless the Comission, on its own

motion, institutes review of the Decision withip that time period.

3 Dated at Rockville, Maryland, this I

h d ay of October 1988.

.j 'P FOR THE NUCLEAR REGULATORY COMMISSION

! TN A l Richard H. Wessman, Director Project Directorate 1-3 4 Divisice of Reactor Projects I/II i

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,[ UNITED STATES Q 2.4

\~* NUCLEAR REGULATORY COMMISSION 7

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}e REGION I 47s ALLENoALE ROAD YO!

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oNo or PRussi A. PsNNSYLVANIA 19400 JUL E71988 Occket No. 50-293 Boston Edison Company ATTN: Mr. Ralph G. Bird Senior Vice President - Nuclear Pilgrim Nuclear Power Station RFD #1 Rocky Hill Road Plymouth, Massachusetts 02360 Gentlemen:

Subject:

Systematic Assessment of Licensee Performance (SALP)

Board Report No. 50-293/87-99 Enclosed for your review, prior to our scheduled meeting of August 25, 1988, is the SALP Board Report for Pilgrim Nuclear Power Station covering the period February 1,1987 through May 15, 1988.

In accordance with NRC policy, I have reviewed the SALP Board Report and concur with the assigned ratings. Highlights of the report are set forth below:

1. Category 1 performance rating was assigned to Engineering and Technical Support which continued strong performance through the assessment period.

2. Category 2 ratings were given in the functional areas of Surveillance, Fire Protection, Security and Safeguards and Assurance of Quality acknowledging Boston Edison Company's extensive ef forts to upgrade performance from the previously assigned Category 3 ratings.

3. Category 3 Improving rating was assigned to the Radiological Controls functional area.

Tne ass $ ment of the Category 3 improving rating indicates that improvement in the organization, programs and performance were noted in the Radiological Controls functional area. However, in our view the results of these initiatives were coming to fruition at the close of tne assessment period, and had not yet demonstrated the ability to sustain improved per'ormance.

Additionally, on July 8, 1988, Region I acvised you that Pilgrim remains categorized by NRC Senior Management as a plant that requires continued close

! monitoring and demonstration of programs which establish and implement performance improvements. This was done in conjuction with a letter from the NRC's Executive Director for Operations to your Chief Executive Officer. We recognize the progress demonstratect to date as a result of your extensive efforts, however, continued vigilance on your part is necessary to achieve and

sustain overall results. NRC will also continue its increased attention to your facility. In .this regard, we will conduct an assessment team inspection

! to further measure the effectiveness and readiness of your management controls, programs and personnel to support safe restart of the f acility. Further, I {

plan to shorten the current SALP assessment period to permit an additional asure the results of your programs.

g [ portunit{to

s Boston Edison Company 2 At the SALP man @einent meeting, please be prepared to discuss your evaluation

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of our assessment and the status of your performance improvement programs.

Additionally, we solicit written comments within 30 days af ter th meeting to wnable us to thorcoghly evaluate your response and to provide you with our conclusions relative to them. S per.i fi c a t 'y , you are requested to respond addressing actions planned to continue to improve performance in the Radiological Controls area.

Your cooperation with us is appreciated. Should you have any questions concerning the SALP report, we would be pleased to discuss them with you.

Sincerely, -

William T. Russell Regional Administrator

Enclosure:

As stated cc w/ enc 1:

K. Highf111, Station Director R. Anderson, Plant Manager J. Keyes, Licensing Division Manager E. Robinson, Nuclear Information Manager R. Swanson, Nuclear Engineering Department Manager The Honorable Edward J. Markey The Honorable Edward P. Kirby The Honorable Peter V. Forman B. McIntyre, Chairman, Department of Public Utilities Chairman, Plymouth Board of Selectmen Chairman, Duxbury Board of Selectmen Plymouth Civil Defense Director P. Agnes Assistant Secretary of Public Safety, Co verwealth of Massachusetts S. Pollard, Massachusetts Secretary of Energy Resources R. Shimshak, MASSPIRG Public Document Room (POR)

Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Hassachusetts (2)

Chairman Zech Commissioner Roberts Commissioner Carr Commissioner Rogers K. Abraham, RI (18 copies) 4

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Boston Edisor Company 3 J[JL g 7 g g bec w/ enc 1: -

Region I Docket % m (with concurrences)

M. Perkins, RI (w/o encl)

W. Russell, RI J. Allan, RI

0. Holody, RI W. Kane, RI S. Collins, RI J. Wiggins, RI R. Blough, RI L. Doerflein, RI M. Kohl, RI W. Johnston, RI J. Curr, RI R. Gallo RI W. Oliveira, RI S. Etneter, RI G. Sjoblom, RI R. Bellamy, RI R. Bores, R!

J. Taylor, OEDO B. Boger, NRR R. Wessman, NRR

0. Mcdonald, NRR F. Akstulewicz, NRR Board Members

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ENCLOSURE SALP BOARD REPORT ,

U. S. NUCLEAR REGULATORY COMMIS$10N '

REGION !

SYSTEMATIC ASS!$5 MENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-293/87-99 BOSTON E0!$0N COMPANY PILGRIM NUCLEAR POWER STATION ASSESSMENT PERIOD: FEBRUARY 1, 1987 - MAY 15, 1988 l BOARD MEETING DATE: JULY 5 and 6, 1988 .

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1.0 INTRODUCTION

............................................. 1 1.1 Purpose and Overview ................................ l' 1.2 SALP Board Members .................................. I 1.3 Background .......................................... 2 2.0 CRITERIA ................................................. 7 3.0 S U MMA R Y O F R E S U LT S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 3.1 Overall Facility Evaluation ........................ 10 ,

3.2 Facility Performance ............................ .. 12 89 4.0 P E R FO RMAN C E AN A LY S I S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 4.1 P l a n t O p e ra t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 4.2 Radiological Controls .............................. 18 4.3 Maintenance and Modi fication s . . . . . . . . . . . . . . . . . . . . . . 24 4.4 Surveillance ....................................... 29 4.5 Fire Protection .................................... 33 4.6 Emergency Preparedness ............................. 36 l

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

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4.8 Engineering and Technical Support .................. 43 4.9 Licensing Activities ............................... 47

! 4.10 Training and Qualification Effectiveness ........... 50 4.11 Assurance of Quality ............................... 53 l .

5.0 SUPPORTING DATA AND SUMMARIES ........................... 57 5.1 Investigation and Allegations Review ............... 57 5.2 Escalated Enforcement Actions ...................... 57 5.3 Management Conferences ............................. 58 5.4 Licensing Actions .................................. 59

> 5.5 Licensee Event Reports ............................. 63 i

i TABLES Tabir 1 - Tabular Listing of Licensee Event Reports by Functional Areas l Tab

• a 2 - Inspection Hours Summary 3

Ta'le 3 - Enforcement Summary

'\ 7, ole 4 - Pilgrim SALP History Tabulation rable 5 - Management Meeting and Plant Tour Summary ,

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1.0 INTRODUCTION

1.1 Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an inte-grated NRC staff ef fort to collect observations and data on a per-iodic basis and to evaluate licensee performance. The SALP process is supplemental to the normal regulatory processes used to ensure compliance to NRC rules and regulations. It is intended to be suf-ficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to Itcensee management in order to improve the quality and safety of plant operations. ,

An NRC SALP Board, composed of the Staff members listed in Section 1.2 below, met on July 5 and 6.,1988 to review the collection of performance observations and data in order to assess the Boston Edison Company's (BEco) performance at the Pilgrim Nuclear Power Station. This assessment was conducted 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 2.0 of this report.

This report is the SALP Board's assessment of the licensee's safety performance at the Pilgrim Nuclear Power Station for the period February 1,1987 - May 15,1988 . The summary findings and totals reflect a 15 month assessment period.

1.2 SALP Board Members Chairman S. J. Collins, Deputy Director, Division of Reactor Projects (DRP) i Members

'; W, F. Kane, Director, ORP J. T. Wiggins, Chief, Reactor Projects Branch 3, ORP A. R. Blough, Chief, Reactor Projects Section 3B, DRP J. P. Ourr, Chief. Engineering Branch, Division of Reactor Safety (ORS)

G. L. Sjoblom, Acting 01rictor, Division of Radiation Safety and Safeguards (ORSS)

R. R. Bellamy, Chief, Facilities Radiological Safety and Safeguards Branch, DRSS D. H. Wessman, Director, Project Directorate I-3, Of fice of Nuclear 4 Reactor Regulation (NRR)

O. G. Mcdonald, Licensing Project Manager, NRR C. C. Warren, Senior Resident Inspector, Pilgrim Nuclear Power l

Station (PNPS), ORP l

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

T. K. Kim, Resident Inspector, 911 grim NPS, DRP T. F. Dragoun, Senior Radiation Specialist, DRSS G. C. Smith, Safeguards Specialist, DRS5 R. M. Gallo, Chief, Operations Branch, ORS A. G. Krasopoulis, Reactor Engineer, ORS T. Koshy, Reactor Engineer, DRS ,

1.3 Background

A. Licensee Activities The plant has been shut down since April 12, 1986 for mainten-ance and to make program improvements and remained shut down throughout this assessment period. The reactor was defueled on February 13, 1987, to facilitate extensive maintenance and modification of plant equipment. The licensee completed fuel reload on October 14, 1987. The reactor vessel hydrostatic test and the containment integrated leak rate test were also com-pleted successfully.

Since the end of the last SALP period there have continued to be extensive management changes at Boston Edison that affect Pilgrim. The licensee has aggressively recruited experienced personnel from outside sources. A new Senior Vice President .

assumed responsibility for the nuclear organization at the beginning of the period. The licensee's organizational struc-ture was also significantly altered several times. Recent changes have more clearly defined the permanent onsite organiza-tional structure. Essentially all key management positions had been filled with permanent employees by the close of the period.

The licensee developed several integrated action and testing plans to evaluate the readiness of plant management, staf f and hardware to support restart. These include the Restart Plan, Material Condition Improvement Action Plan, Radiological Action Plan and Power Ascension Test Pryram. In addition, the licen-see performed a self assessment near the end of the SALP period to identify plant issues and evaluate the effectiveness of implemented improvement actions.

3 Dveing the assessment period the licensee completed extensive plTat' hardw.re and procedure modifications. The licensee's Safety Enh.ncement program included addition of a third emerg-ency dies 91 generator, containment spray header nozzle changes, installnion of a ba ;kup nitrogen supply system, and additional p rotec*,1 on features for anticipated transient without scram.

Steps were also taken toward installation of a direct torus vent system and installation of a diesel driven fire pump tied to the

. residual heat removal system. License exemptions and modi-fications to the fire protection program and equipment to bring the plant into full compliance with 10 CFR 50 Appendix R, and to improve reactor level instrumentation were completed. The facility Emergency Operating Procedures were also upgraded to ,

incorporate Revision 4 of the Boiling Water Reactor Owners Group Emergency Procedures Guidelines.

. On March 31, 1987, the station experienced a loss of offsite power during a storm when a static line broke and fell onto the conductors at a location several miles from the site. Offsite power was restored within 45 minutes. A second loss of offsite power event occurred on November 12, 1987 due to excessive ice and snow accumulation on the transmission system during a severe winter storm. This event was complicated by a lockout of the plant startup transformer, the removal of one of the emergency diesel generators from service due to maintenance concerns and the limited availability of instrument air. A

. source of off site power was reestablished about 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> after the initial loss. An NRC Augmented. Inspection Team was dispatched to the site in response to this event.

On November 9, 1937, the licensee as a conservative measure halted ongoing maintenance and modification work at the station af ter determining that several incidents which occurred during the weekend of November 7 and 8, 1987, raised concerns regarding the control of ongoing work activities. The licensee's $snior Vice president-Nuclear directed that ongoing maintenance and modification work onsite be suspended, and contractor craft personnel were instructed to leave the site and were directed not to report for work until November 12, 1987. The Itcensee subsequently formed eight teams of engineering and management personnel to perform detailed evaluations of each incident prior to resuming station work activities.

On February 11, 1988, the control room received a report of a fire in a contaminated area of the machine shop. The licensee conservatively declared an unusual Event. The fire was confined to a small area and was identified as burning insulation from a heat-treating machine which was being used in the machine shop.

The fire was extinguished by the plant fire brigade with no plant damage noted, and the Unusual Event was secured.

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4 Op(Eator licensing examinations were conducted on two occasions during the period. A total of two senior reactor operators and 14 reactor operator candidates were examined with all candidates successfully completing the examinations.

In December 1986, the Secretary of Public Safety for the Common-wealth of Massachusetts (Charles V. Barry) submitted a report to Governor Dukakis assessing the status of of fsite emergency pre-paredness for the Pilgrim station. The report identified several problems with the existing response program. FEMA per-formed a self-initiated review of the Pilgrim emergency response plan and on August 5,1987, provided its report to the Common-wealth. FEHA identified six deficient areas and withdrew its interim finding that Massachusetts of fsite emergency planning and preparedness were adequate to protect the public health and safety in the event of an accident at Pilgrim. The NRC reques-ted the licensee to provide its plans and schedule for working with state and local organizations to resolve the deficiencies.

The licensee submitted an action plan to address the deficien-cies on September 17, 1987. A progress report issued October 15, 1987 by Charles V. Barry notes that, while substan-tial progress had been made in some areas, adequate plans for response to an accident at Pilgrim did not exist and substantial work remained to be done. At the close of the assessment period, the licensee was actively working with the Commonwealth and local agencies to address the deficiencies and upgrade the emergency plans.

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5 B. I b ection Activities Co5firmatoryActionLetter(CAL)86-10wasissuedinApril,1986 in response to a series of cperational events. The CAL initially required that the licensee address these ever.ts, and was subsequently extended in August, 1986 to include resolution of programmatic and management concerns. In addition the CAL stated that the NRC Regional Administrator's approval would be required prior to restart. The CAL remained in effect through-out this assessment period.

Considerable inspection resources were expended at Pilgrim dur-ing this assessment period. The resident staff has been main-tained at three inspectors. During the fifteen month assessment period, over 9698 hours0.112 days <br />2.694 hours <br />0.016 weeks <br />0.00369 months <br /> of direct NRC inspection were performed t (7758 hours0.0898 days <br />2.155 hours <br />0.0128 weeks <br />0.00295 months <br /> on an annual bat.is). This represents a 43 percent .

. increase above the previous assessment period, and is signifi-cantly in excess of that normally allocated to a single unit site. A detailed breakdown of the total inspection hours into SALP functional areas is included in Table 2.

Senior NRC management involvement was substantial during the period. Early in the assessment period, a Pilgrim Restart ,

Assessment Panel was formed which consists of senior management from the NRC Of fice of Nuclear Reactor Regulation (NRR) and Region I. The panel generally meets biweekly to coordinate the planning and execution of NRC activities, and to assess the results of these activities to provide an independent judgement of the plants readiness for operation. A series of management meetings to discuss the licensee's progress and proposed pro-grams were also held. Frequent site tours by NRC Commissioners, the Director of Nuclear Reactor Regulation and the Regional Administrator were conducted. NRC senior management partici-paced in numerous public meetings and interacted extensively with local, state and federal officials. The NRC conducted public meetings in Plymouth to receive public comments on the plan. The staff's assessment of the comments and concerns received on the Restart Plan was presented to the public during a followup public meeting. A chronological listing of manage-ment meetings and tours is included as Table 5.

On July 15, 1986, Massachusetts State Senator William B. Golden and others filed a 10 CFR 2.206 petition regarding Pilgrim.

After review by the NRC, the contentions raised in the petition regarding containment deficiencies and inadequacies in the radiological emergency response plan were denied. A decision regarding the management deficiencies was deferred to a subse-quent response. This information was transmitted to the pett-tieners by letter dated August 21, 1987. Three of the petitioners filed an appeal in federal court on October 1, 1987.

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On- October 15, 1987, Massachusetts Attorney' General JimisM.Shannonfileda10CFR2.206 petition,onbehalfofhis office and Governor Michael S. Dukakis, requesting an order to show cause why Pilgrim should not remain shutdown until a full

, adjudicatory hearing resolves the issues raised in the petition.

The petition cites evidence of continuing managerial, Mark I containment, and emergency planning deficiencies and requests that the licensee also be required to perform a probabilistic risk assessment (PRA). In a response dated May 27, 1988, the NRC denied the petitioners re' quest that a PRA regarding the Mark  !

I containment be required and deferred decisions regarding emergency planning and management issues.

I During the assessment period nine NRC team inspections were  !

conducted:

1. Appendix R Fire Protection Program Review  !

2. Plant Modification Program Review [

3. Plant Ef fluent snd Environmental Monitoring Program Review i Augmented Inspection Team (AIT) Review of the loss of off-l 4. i l site power event on November 12, 1987 ,

s 5. Annual Emergency Plan Exercise Observation l

6. Onsite Electrical D.istribution Adequacy Review l

) 7. Emergency Operating Procedures Review

] 8. Maintenance Program Review

9. In-plant Radiological Controls Review .

i An NRC Order issued in 1984 requiring the licensee to implement l i

1 a Radiation Improvement Program was closed during the period l based on the results of a special inspection and other program d

inspections which indicated that all terms of the Order had been satisfactorily completed. Two operator licensing examinations were also conducted. An enforcement conference was held on September 9, 1987 to discuss security related matters. Enforce-ment action on these issues is still pending, i

Tabulations of inspection activities and associated enforcement i

! actions are contained in Tables 2 and 3.

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2.0 CRITERIA

! Licensee performance is assessed in selected functioral areas, depe1 ding upon whether the f acility is in a construction, preoperational, or opera-  ;

i ting phase. Functional areas normally represent areas significant to nuclear safety and the environment. Some functional areas may not be

assessed because of little or no licensee activities, or lack of meaning-ful observations. Special areas may be added to highlight significant .

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i This report also discusses "Training and Qualification Ef fectiveness",  ;

"Assurance of Quality" and "Engineering and Technical Support" as separate ,

1 functional areas. Although these topics, in themselves, are assessed in '

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

provide a synopsis. For example, assurance of qual',ty ef fecti'ieness has l been assessed on a day-to-day basis by resident inspect

• ors and is an  !

i integral aspect of specialist inspections. Major factors that influence  !

i quality, such as involvement of first line supervision, safety committees, quality assurance, and worker attitudes, are discussed in each ares. .

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! One or more of the following evaluation criteria were used to assess each functional area. ,

t l 1. Management involvement and control in assuring quality i

2. Approach to the resolution of technical issues from a safety stand-l 4 point '

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3. Responsiveness to NRC initiatives i 4 Enforcement history

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S. Operational events (including response to, analyses of, and correc- l l tive actions for) j i

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6. Staffing (including management) t 7. Training and Qualification Effectiveness i

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Based upon the SALP Board assessment, each functional area evaluated is 4

i classified into one of three performance categories. The definitions of j these performance categories are: ,

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8 Category 1. Licensee management attention and involvement are readily evident and place emphasis on superior' performance of nuclear safety'or safeguards activities, with the resulting performance sub-stantially exceeding regulatory requirements. Licensee resources c e ample and ef fectively used so that a high level of plant and persor.-

nel performance is being achieved. Reduced NRC attention may be appropriate.

Category 2. Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are good. The licensee has attained a level of performance above that needed to meet regulatory requirements. Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved. NRC attention may be maintained at normal levels.

Category 3. Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not suf-ficient. The licensee's performance does not significantly exceed that needed to meet minimal regul atory requirements. Licensee resources appear to be strained or not effectively used. NRC atten-tion should be increased above normal levels.

The SALP Board also assesses a functional area to compare the licen-see's performanci during the last quarter of the assessment period to that during the sntire period in order to determine the recent trend for each functio 1 area. The SALP trend categories are as follows:

Improving: Licens6s performance was determined to be improving near the close of ttI asstssment period.

DecHng: Licensee pei formance was determined to be declining near the c,ose of the assessment period and the licensee had not taken meaningful steps to address this pattern.

A trend is assigned only when, in the opinion of the SALP Board, the trend is significant enough to be considered indicative of a likely change in the performance category in the near future. For example, a classification of "Category 2, Improving" indicates the clear potential for "Category 1" performance in the next SALP period.

It should be noted that Category 3 performance, the lowest Category, represents acceptable, although minimally adequate, safety perform-ance. If at any time, the NRC concluded that a licensee was not achieving an adequate level of safety performance, it would then be incumbent upon NRC to promptly take appropriate action in the interest of public health and safety. Such matters would be dealt with independently from, and on a more urgent schedule than, the SALP process.

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d It should also be noted that the industry continues to be subject to rising 3erformance expectations. For example, NRC expects licensees j to actively use industry-wide and plant-specific operating experience 1 to effect performance improvement. Thus, a licensee's safety per-

, formance would be expected to show improvement over the years in order to maintain consistent SALP rat'ings. j 1

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3.0

SUMMARY

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, 3.1 Oveaall Faqility Evaluation j l a The 1985 SALP determined that programmatic and performance weaknesses existed in several functional areas and that improvements were in-  !

hibited by the lack of resolution of factors which in turn depended l heavily on management attitudes and aggressiveness of followup.

9 The 1986 SALP acknowledged that, although some improvements were t made, the lack of a clear organizational structure, recurring management changes, and chronic staffing vacancies delayed the establishment of a stable licensee management team at the plant and  !

4 inhibited progress during the period. These problems manifested  ;

! themrelves as Category 3 performance ratings in the Radiological' .

j Controls, Surveillance, Fire Protection, Security and Assurance of ~

Quality functional areas.

1 1 Throughout this 1987-1988 SALP period the facility was maintained by J BECO in an outage condition to make major plant facility modifica- [

' tions and complete a major equipment refurbishment program.  ;

At the beginning of the assessment period the licensee made the most significant of numerous personnel changes when a new Senior Vice  ;

i President-Nuclear was hired and his presence established on site, i

! Additional personnel and organizational changes continued throughout i

the assessment period with the most substantial reorganization being  !

completed in February, 1982.' Although the organization in its f present form did not formally emerge until late in the assessment j

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

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

I levels in the new organization are significantly higher than in the [

past and the licensee has been generally successful in recruiting [

l efforts. As a result of these transitions some individuals are i i re l., ti v ely new to their positions and in some cases do not have i j extensive operating Boiling Water Reactor expertise, i 4 The licensee has been aggressive in addressing most areas of known program weakness. However, implementation of certain program and

, organizational improvements was delayed due to the high priority

! placed on proceeding with outage work. Surveillance program  ;

responsiblitties have been consolidated in the Systems Engineering  ;

I Group and program weaknesses have been addressed. Hardware issues in t i

both the fire protection and security areas have been corrected and j j performance in these areas has improved. Health Physics program I problems identified in the previous SALP report continued to exist l during the first half of this assessment period, however recent

significant management attention and resource commitment to this area  ;

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

! period. Maintenance program improvements were implemented only (

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recentlCand their effectiveness remains under review. Licensee developwit of the Material Condition Improvement Action Plan,

- Restart Plan and performance of an extensive self assessment in j response to the NRC August 1986 Confirmatory Action letter are l

evidence of the licensee's ability to self-identify and understand facility performance and material condition. The action plans to implement these necessary improvements and management's ability to effect lasting performance change remained under review at the close of the assessment period.

In summary, licensee ef forts have been extensive including corporate ,

i and site reorganizations and a new management team which has 1 undertaken numerous projects and programs to improve plant material

! condition and enhance programmatic performance. Management 1

initiatives have been generally successful in correcting staffing,

organization and material deffetencies. Programmatic performance

. improvements have been evident in areas of previously identified significant weakness and the lic'ensee's self assessment process has

.! identified areas where further management attention is warranted.

1 In light of the past inability to implement lasting programs which j result in long term improvements, a continued licensee management i

comitment is needed to confirm tha+, past weakness have been icentified and sustain the overall improving trend in performance, i

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3.2 Fa cili trheforma nce

Functional Category Category Recent  !

1 Area last Peried* This Period ** Tread  :

1. Plant Operations 2 2 ,'

2. Radiological 3 3 Improving Controls r

3. Maintenance and 2 2 Modifications s ,

4. Surveillance 3 2 i p

, 5. Fire Protection 3 2

6. Emergency 2 2 Improving i Preparedness

7. Security and 3 2 Safeguards  !

8. Engineering and 1 1 Technical Support

9. Licensing 2 2  !

Activities  !

10. Training and 2 2  !

Qualification  !

Effectiveness [

j 11. Assurance of 3 2  ;

) Quality l 1

I Outage Management 1 i and Modifications l

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November 1, 1985 to January 31, 1987  !

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" February 1,1987 to May 15,1988 i j *" Not evaluated as a separate functionti area; findings relative to outage  ;

, activities are integrated into "Engineering and Technical Support", l l

"Maintenance and Modifications", and other functional areas as appropriate i l

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4.0 pfRFORMANCEAXALYS!$ (

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

(1) Analysis This functional area is intended to assess the Itcensee's per- r formance of plant operations. Throughout this assessment period  :

the plant was in an extended maintenance and refuvling outage. '

NRC observations of licensee performance during major plant  ;

activities included reactor core defuel and reload, the reactor  ;

vessel hydrostatic test, and the primary containment integrated ,

leak rate test.

i During the previous SALP period plant operations was assessed as a Category 2. Weaknesses identified included a shortage of licensed reactor operators and lack of professional support for the Operations Department. Although the licensee had taken actions to recruit new operators and improve the licensed oper-ator training program, the shortage of licensed reactor opera-tors (R0s) remained a significant problem. The effectiveness in professional staff support for the Operations Department was also not demonstrated due to delays in transferring personnel into the department, and their continuing collateral duties outside the department.

i During the current assessment period, the licensee's planning '

and evaluation of their readiness for refueling, the reactor vessel hydrostatic test, and the primary containment integrated leak rate test were well managed. Strong Operations Department involvement was ev$ dent. Plant management and the Operations Review Committee (ORC) exhibited a conservative, safety con- ,

scious approar.h to these milestones. ORC review of refueling '

readiness was conducted in a thorough and deliberate manner i including line item verification of the reload checklist. One exception was the licensee's use of Appendix G to the Final i Safety Analysis Report to justify conditional operability of equipment needed for refueling. In this case plant management proposed to begin fuel movement with a Standby Gas Treatment >

System design deficiency uncorrected, by preparing an analysis -

supporting operability of the system under restricted condi-tions. Licensee management however, reconsidered this practice ,

when concerns were raised by the NRC. Licensee senior manage- [

ment support for ORC decistens was visible throughout, these major activities. Senior management's presence and direct involvement in activities also demonstrated their cofmitment to ,

safety and expectations of high standards to the plant staff.

1

=

t a 14 Thr-licensee

~

has taken aggressive actions to resolve the short-age of licensed operators. Improvements in recruiting and oper-ator training programs have resulted in a significant increase in the size of the operations staf f. The number of licensed reactor operators (R0s) increased by 14 during the period to the present total of 23. This contributed to a reduction in routine operator overtime, which had been a chronic past problem. The addition of new licenses to the operations staff is positive.

However, additional operating experience will be required before these newly licensed personnel are fully qualified. The high RO attrition rate was a major factor in the RO shortage during the last assessment period. Increased management attention, reduced overtime, and higher morale have contributed to maintaining a stable operations organization during this period. The licensee currently maintains a staff of 20 equipment operators and eight of the 20 are scheduled to enter a reactor operator license training class later this year. Continued management support in maintaining a sound and aggressive recruiting and training pro-gram is required to prevent the recurrence of the operator shortage.

Despite the improvements in the staffing level, weaknesses con-tinued to exist in attention to detail and in communications.

Several procedural and personnel errors occurred during the refueling, the reactor vessel hydrostatic test, and the contain-ment integrated leak rate test. Immediate actions taken by the operations staff in response to incidents were not always con-servative. For example, operators continued refueling without stopping to assess a pendant light which was inadvertently dropped onto the reactor core. Problems in the operations area that contributed to the licensee's work stoppage on November 9, 1987 included inadequate sysLem turnover, valve lineup problems, and poor radwaste system operation practices. Some weakness in coordination and communications between the operations staff and other groups was noted during the loss of offsite power (LOOP) event on November 11, 1987. The lack of clear management directions both in and out of the control room, a somewhat frag-mented recovery effort, and poor communications may have delayed the full recovery from the LOOP and resulted in inadvertent manual shutdown of one of the emergency diesel generators. As a further example, operator communication during a dry run of the remote shutdown test was also informal and not completely effective.

15 OuZirtg previous assessments, informality and poor attitude had been identified as a weakness among the control room staff. The discovery by the licensee of non-job related reading material and a card playing machine in the control room in October, 1987 was a further example of the lack of professionalism and implied inattentiveness to duty. As a result of management attention to this issue, positive trends in the control room atmosphere and conduct were noted during the last quarter of the assessment period. The significant increase in the size of the operations staff, strict control of operator overtime, and intensive com-munication training also aided licensee management's successful effort to improve operator professionalism. As an example, effective use of the simulator for training and implementation .

of control room hardware improveeents have enhanced the control roem atmosphere. .

. Significant effort has been made by the licensee to provide adequate support staff in the Operations Department. The cepartment was reorganized and the Operations Support Group was cret.ted to strengthen effectiveness in identifying end resolving technical issues affecting Operations. The Operat. ions Support Group consists of three staff engineers and six shift technical advisor (STA) positions. The licensee has filled the grcup manager and senior staff engineer positions and is actively recruiting to fill the other staff engineer positions. Three additional STAS were hired and trained during this period which increased the total number of qualified STAS to six. This represents an increase of six in the allocated operations sup-

- port staff with four of the positions filled. The reorganiza-tion allowed the Chief Operating Engineer added opportunity to directly oversee operator performance. Operations staff involvement in developing and implementing 'the Emergency Opera-ting Procedures was strong. The licensee s ongoing ef fort to develop a jumper and Itfted lead log and a limiting condition of operation log are additional indications of improving staff support in the Operations Department.

The licensee's approach to problem investitlation and root cause analysis improved significantly during th9 Latter portion of the pe riod. Event critiques led by the Operations Section Manager and root cause analyses performed by the onsite Systems Engi-neering Group were thorough and aggressive. The critique pro-cess also instilled a leadership role for the Operations Department and promoted better communication among interdepart-mental groups.

16 1

Th$ operator training program continued to improve during this assTssment period. NRC operator license examinations on May 25, 1987 and December 7,1987 had a 100 percent pass rate.

Utilization of the plant specific simulator in requalification training and the new Emergency Operating Procedure training significantly enhanced the effectiveness of the training pro-gram. Th) licensee's effort to develop and implement the new Emergency Operating Procedures demonstrated high levels of senior management attention.

Reportable events were generally handled acceptably by the con-trol room staff. The levels of detail, technical accuracy, and the overall quality of licensee event reports have improved during the period.

Monitoring and maintenance of plant chemistry is the responsi-

bility of the Operations Department. The licensee's chemistry l department is responsible for plant chemistry, radiochemistry, and the facility radiological effluents control program. The

> chemistry organization was clearly defined, adequately staffed, and appeared to interface well with other plant groups including the radwaste organization. Chemistry representatives are included in shiftly turnovers with the control room staff.

! Importent plant chemistry parameters are discussed with station

! management daily at a morning planning meeting. Surveillance

! requirements were clearly established and performed on schedule.

l The licensee is meeting Technical Specification requirements for

! radiological ef fleunt sampling and analysis. Effluent control

! instrumentation was maintained and calibrations performed in I accordance with regulatory requirements. All release records were complete and well maintained. QA audits of this area were comprehensive and technically thorough.

The results comparison of NRC radioactivity standards submitted l to the licensee for analyses indicated excellent performance by the licensee with all results in agreement. During t.he analysis of the NRC radioactivity standards, the lit.ensee's chemistry staff demonstrated a clear understanding of the technical

' i s stle s . In addition, the Itcensee was responsive to NRC sugs gested practices for program improvements. The licensee chemical measurement capability was also evaluated twice during the assessment period. The results of the NRC chemical stand-ards indicated good performance with only four of 54 measure-i ments in disagreement. The licensee was responsive to NRC sug-gestions for program improvements in this area and also in the

! area of post accident sample analyses. Licenset management l

appears cemitted to providing adequate capital resources to the l

l i

t .

o .

17 ,

Chnistry Department. The licensee possesses state -of the art -

cheeical and radiochemical laboratory instrumentation, and also maintains a state of the art chemistry computer data base for eaintaining and trendin2 laboratory data. The licensee's chem-istry training program was also reviewed this assessment period.

Both the training and retraining programs appear to be adequate as indicated by the results of the NRC standards analyses.

In summary, the licensee's aggressive recruiting and training program has resulted in a significant increase in the size and effectiveness of the Operations Department staff, the staffing

. im'p roveme nt , strict control of operator overtime, appropriate I management attention, and intensive communications training all have contributed to a recent trend in positive attitude and professional atmosphere in the control room. However, some i weakness in attention to detail and procedural compliance were noted and require continued attention. The licensee's approach

- to problem investigation and root cause analyses has improved, and is generally prompt and positive. Overall performance in i

this functional area has improved, particularly during the last

( quarter of the assessment period.

(2) Conclusion -

Rating: 2 Trej: None Assigned I

j .

l i

I I

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1 - - -

18 4.2 RadioloE4 cal controls (1064 hours0.0123 days <br />0.296 hours <br />0.00176 weeks <br />4.04852e-4 months <br /> /12 perctnt)  !

(1) Analysis The radiological controls functional area is an assessment of ,

licensee performance in implementing the occupational radiation l Safety, chemistry, radiological environmental monitoring and I transportation programs. In November 1984, the NRC issued a i

confirmatory order requiring broad scope improvements in the r licensee's Radiological Controls Program. During the previous '

assessment period this area was rated Category 3. The NRC review found that some improvement had been made in the l

radiation safety program. However, significant weaknesses were identified which inhibited further performance improvement.

These weaknesses included poor communications, antagonistic l 1

working relationships, lack of personnel accountability, poor i ALARA performance, inef fective corrective actions, and vacancies

in key radiological safety supervisory and management positions.

As a result of these weaknesses the NRC confirmatory order was i not closed out. Weaknesses were also identified in implementa- ,

tion of Radiological Effluent Technical Specification sur- l veillance requirements and the licensee's environmental TLD program. During the previous assessment period, the licensee's i transportation program exhibited a decline in performance with s three violations being identified.

l During the current assessment period there were nine inspections J in this area of the occupational radiation safety program. The l inspections focused on oversight of outage work, establishment ,

of effective management controls for this area and efforts to '

close out the NRC Confirmatory Order and associated Radiological '

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

performed in the chemistry, transportation, and radwaste systems l

areas.

l Radiation Protection l

'. The weaknesses noted during the previous assessment period per-  ;

) sisted through the first half of this assessment period. How-j ever, in November,1987 an taspection found that performance had T improved to the point that the November 1984 NRC Confirmatory Order was closed out but, at the same time, acknowledged that ,

j additional improvements and continued management attention to -

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

' licensee to continue to improve performance such as improved radiological awareness and increased staffing are documented in [

the licensee's Radiological Action Plan (RAP).

Toward the end of this period, the Radiation Protection program

organization and staf fing levels, a weakness during most of the

! assessment, improved. 'he organization, staffing levels, re-i i

19 spbibilities, accountabilities, and interfaces are now well de fTned . Station management attention to the areas of communi-cations, accountability, morale and the corrective action pro-cess over the last half of the period has improved working re-lationships and communications between other departments and radiation protection.

. The recently revised Radiation Protection organization is approximately 90t, filled by permanent personnel. Although the organization and staffing are adequate to support the program, the position of Chief Radiological Engineer (Radiation Protec-tion Manager) was recently restaf fed with a contractor, several .

managers have limited commercial nuclear power experience, and many personnal are new to th?ir positions. Performance of this 4 new organtration will continue to be assessed in the future, l A well defined training and qualification program has been ,

established. The program contributes to an adequate understand-  ;

ing of program requirements with few personnel errors. Training

resources are adequate. The radiation protection traini'ng pecgram is INPO certified, ;4ew training initiatives are in progress to sensitize management, workers and radiation pro-  :

tection personnel to assure they are awIre of the need to l minimi:e all occupational radiation exposure. Examples include .

l training of tranagement on ALARA for plant design changes and l providing radiation awareness training to maintenance and '

operations personnel.

Licensee audits and assessments of program implementation and adequacy have improved. The audits and asstssments, augmented by supervisory and management tours, have been generally ade- ,

i

quate in following program implementation ano identifying weak-i nesses, particularly toward the end of the period Technical r specialists are used to augment the QA avdit teams. Additional i

QC surveillance of problem areas (e.g., High Radiation Area key control) has been implemented. However the scope of Itcensea j

audits have been principally ecmpliance oriented. There is j little enterrsl review of program adequacy ard performance  ;

relative to the industry.

In the area of Internal Esposure Controls, no significant indi-vidual exposure of parsonnel during the period was identified.

Also, during the major plant decontamingtion operation, exposure of workers '.o airborne radioactive material was well controlled. i Approximately 90% of the station is now accessible in street .

clothes. Licensee quant.ficatioit of radionuclides cont,ained in [

]

the NRC whole body counting phantes was good. The use of r sensitive whole body counting equipment combined with a capability to analyze the data reflect.s .an adequate bicassay

{ capability. Although performance in the area of Internal

)

l

20 Exhkisure Controls has improved. NRC review identified instances whe7e about 1000 individuals had terminated from the Site during ,

! the period without receiving confirmatory whole body counts.

l These termination cody counts are not required by the NRC but  ;

4 are a normal good practice at most reactor sites and are recommended by Pilgrim site procedures. When brought to the licensee's attention they were unaware of the magnitude of these

exceptions to the recommended practice, reflecting some weaknesses in oversight of this area.

During the assessment period three violations occurred which  !

involved improper control of High Radiation Areas. Although no l unplanned exposures resulted, when examined individually, these i violations clearly reflect one or more of the previous i

assessment period concerns. In response, the licensee made i certain short term corrective actions and established a task '

l force to review the concerns and develop long term corrective actions. The licensee corrective actions for the most recent  :

Hign Radiation Area access control concerns were appropriate. [

however, these corrective actions were prescribed by remorandum. )'

The NRC has previously expressed concern regarding imple-mentation of regulatory requirements by memoranda rather than by  !

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

assessment period, procedures were not yet revised to include

, these corrective actions. An additional weakness involved j licensee attempts to resolve a concern with exposure reports in that, early in the period, NRC identified that the licensee had  ;

not sent a number of termination reports to individuals. The -

licensee instituted a corrective action program, but this matter ,

is still under NRC review,  :

Ouring the latter part of the assessment period, control, over-  ;

sight and coordination of in-plant activities by the radiation  !

protection department had significantly improved. The number of  !

i licensee technicians and first line supervisors was increased. ,

) Coincident with this staffing increase. licensee management  !

selectively reduced contractor work force, keeping the most l competent performers. The augmentation of first line super- L visors combined with the elimination of a large number of con- ,

tract technicians resulted in improved management control and l I

accountability within the department. -

In the area of radiation exposure, Pilgrim Station collective I worker doses, calculated as 5 year rolling averages, have his-

! torically been among the highest in the nation. Some improve- l 3

ment was noted in the previous assessment period af ter a well ,

documented ALARA program was instituted accompanied by a high l l visibility exposure goals program. Licensee activities during i this period resulted in a collective worter dose (1580 person- t rem) which was the highest of all domestic power reactors in  !

< l i

I L

i

. 1 e .

21 i

19W . Analysi s . by station management attributes the exposures to7a.n'expandedworkscopeduringtheprolongedoutagewithabout 20% due to unplanned rework, poor contamination controls, and poor planning. Also, the large number of workers (about 2000) on site during the outage coupled with the high radiation source terms and poor work habits in the plant contributed to the high annual dose. During the initial part of this assessment period, [

NRC concerns included lack of understanding of day-to-day work activities due to poor maintenance planning and inaccurate description (- work provided to radiation protection personnel which is incorporated into RWPs. Also, RWPs continued to be requested for work that was not performed. Improve-ments in this area were noted during the latter half of this - I assessment period. .

5 Mana .ement efforts instituted to control exposure included hir-ing 4 large contractor staff to implement ALARA on the job, assigning six HP/ALARA coordinators to work groups, and imple-mentation of dose saving techniques recommended by . the ALARA i Committee. The effectiveness of the six coordinators was par-ticularly evident in the areas of maintenance and operations.

For example, the use of glove bags to contain contamination dur-ing maintenance hac been expanded. Conto..ination "spill drills" t

are routinely conducted to prepare o;erations personnel for dealing with future incidents so that the spread of contamina-tion can be minimized.

NRC review of the selected ALARA goals indicated that they ap-paared to not be challenging and there was no formal mechanism to incorporate ALARA principles during the d0 sign of plant modifications. For example, during the outage the licensee was noted to have rebuilt a number of large valves (e.g. , RHR System) without considerlag the need to reduce stellite, a major source af cobalt. During the latter part of the assessment period, the licensee was attempting to formalize a program to conduct ALARA reviews of plant design modifications during the conceptual design phase. A goal of 600 person-rem was initially planned for 1988 even though most of the outage work ended in  ;

l February and a lower gori appeared achievable based upon i anticipated radiological work. In addition, there was no long range planning evident to reduce the high general area dose .

rates at the station. .

Radioloaictl Environmental Monitorina Program Midway through this assessment perted an inspec4 3 of the

licensee's radiological environmental monitoring program (REMP) was conducted. The REMP i s administered by the corporate '

j Radiological Engineering Group. The licensee's REMP conforms to Technical Specification requirements. The licensee has made plans for improvement of the annual REMP report.s, and improve-n y ,. . , - . w-r-- > , .- , . -m -,-p.--w-,4 --

.,,v,m,--vy.w,-,--,.,,1 -,--.,-.._,.-.-tw--

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, r we, , , - wev-,--- = + -

22 meb to the meteorological monitoring program even though the 11cThsee's Technical Specifications contain no requirements in this area. In response to a program weaknesses identified by the NRC during the last assessment period, the licensee has eliminated the environmental thermoluminescent dosimeters TLD

.ystem which was in use during the previous assessment period and is now using TL0s supplied by the Yankee Atomic Environ-mental Laboratory. Planned personnel expansion in this area is indicative of the licensee's commitment to continued improvement of the REMP.

l l Transportation l

l One inspection of the licensee's transportation program was conducted midway through this assessment period. Two Severity Level IV violations were identified. Both violations related to shipments made during the previous assessment period. These t violations suggested inattention to technical detail and quality control in the preparation of radioactive shipment records.

However, during this assessment period the licensee increased quality control involvement in processing, preparation, pack-aging and shipping of solid radioactive waste. This indicated the licensee's clear understanding of issues relating to causes of the problems and, in addition, the implementation of cor-rective action. The licensee is meeting all commitments to the NRC with regard to training in this area. The licensee has implemented procedures which clearly define the roles of the departments involved in solid radwaste and transportation.

Procedures for processing, preparation, packaging, and shipping solid radwaste were adequate.

Summary In summary, there was an overall improvement in licensee Radia-tion Protection Program adequacy and performance, particularly during the last quarter of the assessment period. However man-agement attention is still required to exceed minimum regulatory requirements in the in plant radiation protection program. Com-munications and working relationships have improved. Facilities and equipment have been upgraded. Limited success in 1) upgrading the ALARA Program performanca, 2) staff qualifications and stability, and 3) aggressive long term corrective actions for High Radiation Area access control were noted.

In contrast, licensee performeco in the areas of REMP and transportation reflects substantial improvement. These areas, if rated separately, would receive the highest performance rating category. Previous weaknesses regarding radiological offluent technical specification surveillance and the environ-mental TLD program nave been corrected and plans made for ad-ditional program improvements. The station has substantially upgraded quality control activities in the transportation area.

23

. (2) CoIelusion

% Rating: 3.

Trend: Improving.

(3) Recommendations Lictnsee: 1. Continue strong senior management involvement in the in plant radiation protection program.

2. Strengthen the ALARA program and complete training on program implementation.

NRC:

1. Conduct a management. meeting with the licensee

' to review radiological program status and LALARA program progress. .

S

24 4.3 Mainte ce and Modifications (2347 Hours /24 percent)

. (1) Analysis This functional area is intended to assess the licensee's per-formance in planning and implementing t'1e station maintenance program, and in implementing and testing plant modifications.

The adequacy of modification design is evaluated under the Engineering and Technical Support functional area. This SALP period includes the results of the April 25 - May 5,1988 NRC Maintenance Team Inspection. It does not include evaluation of the licensee's Restart Readiness Self Assessment, nor does it evaluate the licensee's response to the Maintenance Team Inspec-tion findings.

l During the preyious SALP period, plant maintenance performance 1 was assessed as a Category 2 . Maintenance staffing was weak  ;

, due to first line supervisory vacancies and lack of direct pro-fessional support, hampering programmatic improvementf- The scheduling of "A" priority maintenance was good, however lower ,

priority maintenance scheduling was weak as demonstrated by the large maintenance backlog. This was particularly evident in the areas of fire protection and security, resulting in equipment unavailability. The maintenance planning group was effective in validating maintenance requests (MR), but was only marginally effective in planning daily maintenance activities. Maintenance 4

program procedures were considered weak and contained only minimal information. No administrative guidance for the newly formed planning and procurement groups was in place, hampering 4 their integration into the process.

During the current SALP period maintenance and modification activities were routinely monitored. Also seven special inspec-tions were conducted to evaluate the licensee's maintenance and modification control programs. An Augmented Inspection Team and

a special electrical system team inspection also evaluated as-pects of maintenance program effectiveness. Near the close of the SALP period a special maintenance team inspection evaluated the licensee's effectiveness in implementing the program.

Licensee efforts to improve facility material condition during this assessment period have been highly evident. Overhauls of i major plant equipment such as the Residual Heat Removal pumps, High Pressure Coolant Injection pump, and feedwater pumps were successfully completed. Commitment by senior licenses manage-oent to perform these and numerous other equipment overhauls is 1 a positive indication that material improvement has been a licensee priority.

1 E

9

25 ThC_ maintenance section also provided strong support during the November, 1987, extended loss of' of f site power recovery ef fort.

The Maintenance Section Manager held meetings to ensure directed and coordinated efforts of the work force and developed plans for an organized approach. Inspector observation of maintenance task performance in the field indicates that workers are ade-quately trained in that they are generally kneuledgeable of assigned activities and their impact on the plant.

Senior licensee management has acted to increase allocated main-tenance staffing, however staffing levels remained a weakness during much of the period. The significant burden of outage ,

activity combincd with this weakness continued to delay the progress of program enhancements. Early in the period, first line supervisory vacancies resulted in a reduction in oversight of field activities. Qualified licensee personnel did not apply for the positions. The licensee aggressively recruited indi-viduals from outside the organization and filled the vacancies.

Three maintenance staff engineer positions were created and

• filled in an effort to provide maintenance department technical support.

These individuals concentrated largely on completi'on of outage tasks and therefore were not available to develop longer range maintenance program improvements. Late in the period the Main-tenance Section Manager and both th~e Electrical and Mechanical Division Manager positions became vacant. The licensee filled these three vacancies immediately af ter the close of the SAlp period. Turnover and difficulty in recruitment of in-house personnel continues to be a significant problem at the mainten-ance rupervisor l e'v e l . The licensee compensated for two of these vacancies by using contractors. These continuing super-visory staffing vacancies combined with maintenance management ,

turnover resulted in a lack of stability and consistent direc-tion in the maintenance organization.

Communications between the maintenance department and other organizational entities has improved significantly. Early in the SALP period poor communication between the maintenance, radiation protection and operations departments resulted in a large number of radiation work permits requested but not uti-lized, and processing of equipment isolations for maintenance activities which were subsequently delayed. Maintenance prior-ities were not always consistent with operational needs. To address these issues, licensee management assigned two experi-enced radiation protection technicians to maintenance to assist in Job planning and to improve maintenance personnel apprecia-tion of radiological considerations. Two senior reactor opera-tors were assigned 50 provide direct input to the planning pro-cess, and to act as liason between operations and maintenance.

I 26 Th b e actions resulted in substantial communications improve-ment, and more efficient processing of maintenance and modifica-tions tasks during the latter part of the assessment period.

During the period the licensee continued to devote resources to the improvement of the planning and scheduling function. Staff-ing of the maintenance planning group was augmented by the ad-dition of significant contractor support. At the close of the SALP period all maintenance planning staff positions had been filled, with five positions filled by contractor personnel.

This group actively collected existing MRs and verified spare parts availability but was not effective in developing inte-grated maintenance schedules or ensuring consistent high tech-nical quality in maintenance packages. Licensee management also created the temporary Planning and Restart Group to assist in establishing outage scope and schedules. The functions of this group were later incorporated into the permanent line organiza-tion under the Planning and Outage Manager. The Planning and Outage Group appeared to be increasingly involved in developing and tracking longer term work schedules by the close of the SALP period. Continued attention to developing and implementing effective maintenance schedules, and to improving the detail and quality of maintenance work packages is neaded.

In the previous SALP period, a large backlog of low priority maintenance had resulted in. inoperable fire protection and security equipment, and reductions in operational flexibility due to equipment unavailability. During this assessment period, the licensee has ef fectively focused attention ci defining and processing this large backlog of work. Recent conpietion of the major outage activities allowed further reductions. Late,in the period the licensee directed increased effort at improving general equipment condition. Management frequently toured the

station, evaluating the effectiveness of these efforts. How-ever, because of a lack of sensitivity caused in part by con-

' centration on backlog reduction, loss significant maintenance deficiencies and poor maintenance practices were not always promptly addressed. An example of this is the poor condition of station batteries identified during a NRC team inspection.

i Several routine inspections and a maintenance team inspection near the end of the SALP period found that maintenance program procedures and work instructions continued to be a significant weakness. Work control and implementation practices were not clearly delineated in approved procedures or other directives as

• evidenced by the excessive delay in issuing the Maintenance i Manual. Maintenance requests contained little detail of the I as-found condition, repairs ef fected and post-maintenance test-

. ing performed.- This hindered subsequent root cause evaluations and reviews. Instructions provided to maintenance technicians i

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27 I

ofGn.were not sufficiently detailed to ensure proper perform-  ;

ancr Of the task, and to document activities such as placement of jumpers or lif ted leads. For example, a series of engineered safety feature (E5F) actuations were caused by lack of adequate instructions and planning of electrical relay replacements.

There was also no ef fective process for management review of completed maintenance packages. A number of improvements had been implemented such as maintenance package checklists, worker prejob briefings and use of a temporary procedure to document lifted leads, but appropriate maintenance process procedures were not revised to reflect the changes. For much of the SALP period, actions taken in response to NRC concerns were directed at correcting problem symptoms and were vt suf ficiently com- -

prehensive in nature. The licensee deferred the formal ad-dressing of program weaknesses in this area and the application of interim improvements has been inconsistent and not wholly effective. Shortly af ter the assessment period, licensee at-tention to this areas intensified and major program improvements

. were initiated.

The licensee's post-maintenance test program was not . clearly defined. No clear guidance for establishment of post-mainten-ance testing requirements existed. in one case MRs for exten-sive repair and retermination of electrical cables were desig-nated as not requiring retest, even though the repairs disturbed numerous circuits upon which logic testing. had previously been completed. Late in the period the licensee took action to strengthen the post-maintenance testing process and to create a matrix of testing requirements.

The licensee implemented several aggressive maintenance initia-tives directed at improvement of component performance. Pre-ventive maintenance on all safety-related motor operated valves (MOV) and AC circuit breakers was completed. However MOV pro-cedures were found to be weak in some areas. Circuit breaker /

maintenance was not extended to include any safety-related DC circuit breakers until prompted by the NRC, even though none had beer, performed during the life of the plant. While management commitment is evident, follow through on initiatives was occas-ionally incomplete. The increasing involvement of the Systems Engineer Group has had a positive impact on maintenance perform-ance, particularly the quality and promptness of . maintenance problem root cause analysis. The licensee also significantly increased staffing, training and management direction of the

, Station Services Group resulting in improvements in the station

! decontaminat <oo and housekeeping programs.

[ The licensee has implemented a Material Condition Improvement l

Action Plan (MCIAP) which identifies many of the weaknesses-I described above. An independent monitoring group was estab-l

28 lished by the licensee to monitor -its effectiveness. This plan i s J n' tended to result in significant maintenance program im-provements over the long term. The hardware . aspects of the MCIAP were efiectively addressed, however, program and proced-ural enhancements were deferred. The licensee also implemented a maintenance performance indicators program. This program has assisted licensee maintenance management in better focusing on adverse trends and department performai....

As a result of good working relationships between the Site Engineer Group and the Modification Management Group, licensee control of modification implementation and turnover was strong.

A large number of complex modifications were completed during the oeriod without significant problens. The program for con-trolling post-modification testing was generally effective.

However, technical review of post-modification test procedures was occasionally inadequate. Examples of this included the failure of testing to identify the incorrect installation of reactor water level instruments, and the approval of several tests which either caused or would have caused unanticipated ESF actuations. ,

In summary, the licensee continues to give high priority to improvement of plant material condition, although program weaknesses in several areas were evident. The licensee im-plemented informal process enhancements which resulted in more rapid improvement during the last months of the SALP period. A long range plan, the MCIAP, has been established to promote program improvements in the areas of identified weakness.

Licensee senior management attention to full and timely imple-mentation of this plan is necessary to assure that permanent improvements are achieved. Staffing problems and management turnover however, need to be resolved so that these problems do not continue to hamper licensee efforts.

(2) Conclusion On313: 2 Trend: "$ _ Assigned (3) Recommendations Licensee:

- Complete implementation of program inprovements and con-tinue staffing efforts.

- Provide for staff continuity and ' development.

E: None.

29 4.4 Survei13ance (1386 hours0.016 days <br />0.385 hours <br />0.00229 weeks <br />5.27373e-4 months <br /> /14 percent)

(1) An'a l y s i s The surveillance functional area is intended to assess the ef-fectiveness of licensee management in assuring the development and implementation of a comprehensive surveillance testing program.

During the previous SALP period, surveillance was assessed as a Category 3. Testing was generally conducted in a careful, safety conscious manner, however no centralized management of the surveillance test program existed. Responsibility for pro-gram management was not clearly established. The system for control of surveillance scheduling was weak, principally because the key individual involved with this activity was not a tech-nical staff member. The technical adequacy of surveillance procedures and the control of measuring and test equipment (M&TE) were also found to be inadequate. The licensee's sur-veillance test program had not received adequate ma'nagement attention.

During this SALP period surveillance testing was routinely ob-served and procedure technical adequacy was etaluated. One management meeting and several inspections were conducted to assess licensee efforts to correct the previcusly identified problems. An Augmented Inspection Team dispatched in response to a loss of of fsite power also evaluated aspects of surveil-lance program effectiveness.

During the previous assessment period, the absence of strong centralized control and responsibility for surveillance program oversight contributed to continuing weaknesses. Early in this SALP period the licensee assigned responsibility for program maintenance and upgrade to the Technical Section Manager. The Systems Engineering Group within the Technical Section has become increasingly involved with development of program improvements. A Surveillance Coordinator position was estab-11shed and staf fed by a senior systems engineer to help provide needed focus. In addition, a coordinator was assigned in each department responsible for surveillance test performance. Al-location of these resources has resulted in acceleration of program improvements and is an indication of management commitment.

i

30 I

Thblicensee has taken action to improve the technical adequacy of "surveillance test procedures. Technically inadequate test procedures were a recurring proble e identified during previous SALP periods, requiring repeated NRC initiatives to obtain licensee corrective action. During the current assessment per-iod however, the licensee implemented an extensive effort to evaluate and upgrade surveillance procedures. A team composed of licensee Nuclear Engineering Department, Technical Section

, and Maintenance Section representatives was formed to address the problem. Initially the effort was intended to assure com-pliance with technical specifications. Licensee management expanded the upgrades however, to include testing of additional system design features beyond technical specification require-ments. This is an indication of the licensee's desire to estab-lish a more comprehensive program that goes beyond regulatory -

requirements. Implementation of the improved testing allowed the licensee to identify and correct several system performance problems. Another example of the licensee's intent to thor-oughly test major systems was the use of a temporary boiler to perform extensive testing of the High Pressure Coolant Injection and Reactor Core Isolation Cooling systems with non-nuclear steam. While substantial progress has been made, and existing procedures have been upgraded sufficiently to assure compliance with the Technical Specifications, some procedural weaknesses

continue to be noted. For example, the inoperability of an emergency diesel generator during a loss of offsite power could ,

have been prevented if surveillance procedures had recorded and evaluated more than the required minimum instrument readings. I Additionally, inadequate test procedures have caused unnecessary engineered safety features actuations. ,

The 1tewee began development of a new computer-based Master l Surveillance Tracking Progran (MSTP) in an attempt to resolve previously identified scheduling problems. Considerable licen-see ef fort was expended on development of the new program. How-ever, late in the SALP period the licensee concluded that it was not viable due to problems with vendor-supplied computer soft-ware. The licensee's Systems Engineering Group has initiated an  :

interim manual tracking system, and is revising the previously  !

1 used MSTP to compensate for the identified weaknesses. Substan- '

tial time was expended in the unsuccessful attempt to implement the new MSTP, ard therefore final resolution of tho' scheduling problems has not been reached. However, it is evident that '

licensee management is committed to improving the system, responsibility for implementation has been established and <

progress is being made. .

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31 The licensee's program for control of Measuring and Test Equip-meg '(M&TE) has improved significantly. The licensee dedicated four full-time individuals to the upgrade of the M&TE control program. Instruments were collected, assigned unique identifi-cation numbers and data was input to a computer-based tracking system. Control and implementation of ther local leak rate test program hav also improved since the last assessment period.

The significant improvement in these areas is a clear result of management involvement.

Licensee personnel generally conducted testing in a careful, safety conscious manner. Major testing evolutions such as the .

reactor vessel hydrostatic test and the containment integrated leak rate test were well coordinated and executed. Occasional personel performance lapses in the quality of testing were noted, however. For example, instrument and controls tech-nicians failed to enable equipment sump level switches after calibration, causing sump overflow in the high pressure coolant injection pump room. During a similar drain system overflow incident operators did not perform' required shiftly plant tours.

As a result contaminated water was allowed to accumulate. These instances mayindicate some , weakness in personnel training.

The inservice inspection (ISI) program was effectively imple-mented. The licensee's ISI staff demonstrated a good under-standing of technical issues. Management support of the ISI For example, prompt action was taken to

~

program is evident.

evaluate piping errosion and drywell liner corrosion in response to industry events.

In summary, the Itcensee has established appropriate responsi-bilities for management of the surveillance program. Sufficient senior management and technical resources have been allocated to affect the needed program improvements. Program responsibil-ities have been defined and assigned to the System Engineering Group. Test procedure technical adequacy and control of M&TE were substantially improved in response to reent-ing NRC con-cerns. While strengthening of surveillance scheduling has been slowed due to computer program problems, progress is currently being made. Continued licensee management attention is neces-sary to assure imples,entation of ongoing improvements, aggres-sive evaluation and correction of remaining weaknesses and reinforcement of newly established work standards.

r

32 (2) Coglusion RatTno: 2

, Trend: None Assigned (3) Recommendations Licensee: Continue positive initiatives to upgrade surveillance procedures and impliment improved surveillance track-ing programs.

t 6

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l 33 4.5 Fire prttection (493 hours0.00571 days <br />0.137 hours <br />8.151455e-4 weeks <br />1.875865e-4 months <br /> /5 percent)

(1) Anilysis This functional area is intended to assess the effectiveness of the licensee's station fire protection program, and th: :Jequacy of modifications and procedures established to ensure compliance with 10 CFR 50 Appendix R. During the last period this area was rated as a Category 3. The fire protection progrcm suffered from a chronic lack of management attention. The licensee was not aggressive in maintaining the operability of station fire protection equipment, resulting in heavy reliance on compensa-tory measures. Fire barrier surveillance procedures were un-clear and incomplete. Personnel performing fire watches and serving on the fire brigade were poorly trained. Licensee senior management had taken steps at the end of the period to strengthen the program.

During this assessment period routine inspections monitored the progress of . licensee improvement efforts, additionally two inspections were conducted te assess the status of the station fire protection program. In addition, a team inspection was performed to evaluate licensee compliance with 10 CFR 50, Appendix R. A management meeting was also held to discuss fire protection and Appendix R concerns.

The licensee demonstrated a high level of management involvement in ensuring fire protection and Aopendix R program improvements.

A fire protection group was established near the end of the last SALP period. During this period, staffing for the group was increased from one fire protection engineer to six permanent fire protection specialists. Frequent meetings with the fire

• protection group leader, and periodic status reports assisted senior licensee management in monitoring the group's progress.

In the area of Appendix R the licensed established a temporary project management organization. A senior project engineer was dedicated to provide focused oversight and support. The Appen-dix R project organization and the fire protection group worted closely together to coordinate activities.

The licensee has been successful in reducing the backlog of fire protection equipment maintenance, which had contributed to a heavy reliance on compensatory measures. Fire protection group and maintenance managers worked effectively together to reduce the outstanding maintenance backlog, and to maintain it at a manageable level. Total outstanding fire protection maintenance was reduced from over 300 items to less than 50 items, and is currently tracked by licensee management as a performance indicator.

34 The control and quality of fire brigade training ~have improved.

The71re protection group, with the assistance of the training department, developed and implemented a more comprehensive training program. A state certified instructor was hired to conduct the brigade training. The number of fire brigade drills conducted has substantially increased, and it appears that their effectiveness has improved. Through these actions the licensee has succeeded in developing a large core of trained personnel to serve as fire brigade members. Effective interaction and coor-dination between the fire brigade, the operations staff and local fire fighting companies was evident during several minor fire incidents occuring during the period, including a fire in the machine shop which prompted declaration of an unusual Event.

The licensee initiated, and the NRC has approved several fire protection licensing actions during the assessment period. In response to past instances of problems with fire barrier ade.-

quacy, the licensee's Appendix R project organization imple-mented a well conceived program to identify, inspect and repair plant fire barriers. These inspections resulted in the identi-fication of a significant number of deficient barrier seals.

Licensee management exhibited a conservative philosophy, estab-11shing compensatory fire watches for all plant barriers pending completion of inspections.

The licensee's approach to maintaining safe shutdown capability was found to assure redundant safe shutdown system train separa-tion, and to provide sufficient operational flexibility. To assure adequate separation the licensee performed a well docu-mented and thorough. analysis, although procedures for use of the safe shutdown equipment, and operator training in this area were found to be weak. The licensee has taken action to resolve these weaknesses and has committed to demonstrate safe shutdown capability by performing a test during the power ascension program.

In summary, licensee management has taken strong action to establish and staff an effective station fire protection organ-12ation. Significant improvement in fire protection equipment material condition and fire brigade training has resulted.

Licensee response during this SAlP period to Appendix R issues, particularly fire barrier seal problems, was prompt and effec-tive. Continued management attention is needed to assure prompt completion of fire barrier seal repairs, to achieve further reduction of outstanding compensatory fire watches and to pro-vide a stable effective fire protection program.

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35 (2) CoTw:1usion Rating: 2 Trend: None Assigned l

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36 4.6 EmergenSh- preparedness (176 hours0.00204 days <br />0.0489 hours <br />2.910053e-4 weeks <br />6.6968e-5 months <br /> /2 percent) -

r (1) Analysis During the previous assessment period, licensee performance in this area was rated Category 2. This was based upon a renewed commitment by management for emergency prepa*edness and a sig-nificant improvement in performance.

During the current assessment period, one partial participation exercise was observed, two routine safety inspections were con-ducted, one special safety inspection specifically related to emergency classification was conducted, and changes to emergency plans and implementing procedures were reviewed.

Two routine safety inspections were conducted in November,1987 and January, 1988. These inspections examined all major areas within the licensee's emergency preparedness program. During the November, 1987 inspection, significant changes were examined regarding the normal emergency preparedness organizaticn. These changes resulted in essentially a completely new organization with the Emergency Preparedness Manager reporting to the Senior Vice President. Functional responsibilities are divided into on-site and off-site areas with coordinators for each. The licensee has filled the managerial positions, as well as other working positions, with personnel experienced in emergency pre-paredness. In addition, the licensee has contracted with several consultants to help the permanent staff.

During the January, 1988 inspection significant changes were examined regarding the Emergency Response Organization (ERO) and Emergency Action Levels (EAL's). The licensee das committed to

! a complete restructuring of the ERO with a three-team duty rota-tion. the licensee is revising the EAL's to be Additionally, symptomatic, address~ uman factors,'and has integrated them with the Emergency Operating Procedures. Significant facility changes made include the addition of a Computerized Automated Notification System to notify the ERO.

A partial participation exercise was conducted on December 9, 1987. The licensee demonstrated a satisfactory emergency response capabi)ity. Actions by plant operators were prompt and effective. Event classification, and subsequent Protective Action Recommendations, were accurate and timely.

Personnel were generally well trained and qualified for their

! positions. No significant deficiencies were identified.

Several minor weaknesses were noted including insufficient depth in some positions to support prolonged operations, dose projec-l tion discrepancies, delays in fielding onsite repair teams, and weak initial notification forms.

37 Dur+ngr the response to a loss of offsite power event in Novaber,1987, some weakness in coordint. tion and communication between licensee groups was noted. While not required by the site emergency plan, the licensee eventually chose. to partially activate the Technical Support Center (TSC) to aid in recovery efforts. The difficulties experienced by the licensee during  :

the initial response and subsequent efforts to utilize the TSC -

. indicate that licensee attention to preplanning response options l to non-emergency events, such as discretionary acti>ation of.the TSC, may be appropriate.

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

response to a declaration of an Unusual Event were examined.

The licensee's classification was conservative and prompt. Mit-igation activities were effective. The licenste identified several problems associated with their actions including: fail-

. ure to completely folle' procedures; untimely notification of event termination; and ontrol room distractions due to the large volume of outside communications. The licensee promptly identified these issues and instituted appropriate short-ters and long-term actions to prevent their recurrence.

The licensee is continuing to work closoly with local and '

Commonwealth of Massachusetts officials to upgrade off-site emergency preparedness. The licensee has a large organization working on plan and procedure development, in conjunction with the appropriate local and Commonwealth agencies. -

l Ouring this period, the licensee was granted exemptions for the 1987 full participation exercise and a deferral of the submittal of public information. These were based on the Commor. wealth of Massachusetts requests to complete the local and Commonwealth emergency plans, implementing procedures and associated training '

r prior to issuance of public information or demonstration of j

capabilities.

1 In summary, the licensee has demonstrated a commitment to emerg-

, ency preparedness. Management involvement is evidenced by the major on- site program changes being supported, commitment to j

I the offsite level of emergency preparedness, and by timely '

, recognition of problems and subsequent corrective actions. The licensee has been responsive to NRC concerns and is continuing ,

to make progress in these areas.

(2) Conclusion l

Rattna

2 Trend: Improving i

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38 4.7 Security and Safecuards (641 hours0.00742 days <br />0.178 hours <br />0.00106 weeks <br />2.439005e-4 months <br /> /7 percent)

(1) Analysis This functional area was rated as a Category 3 during the pre-vious assessment period. NRC identified serious concerns regarding the implementation and management support of the security program. The licensee's proprietary security staff r consisted of one full time and one part time member, resulting  ;

in weak oversight of the contractor. In addition, inoperable equipment contributed to a heavy reliance on long term compen-satory measures. Contractor security force overtime was also poorly controlled. Toward the end of the assessment period, the licensee initiated actions to correct the problems. However, at the conclusion of the rating period the hardware upgrades were .

not complete and the expanded proprietary security staff organ-ization had not been in place for an adequate time for NRC to evaluate its effectiveness. ,

Four routine, unannounced security inspections, one special security inspection, and one routine unannounced material con-trol and accounting inspection were performed during this assessment period by region-based inspectors. Routine observa-1 tions were also conducted throughout the assessment period.

During this assessment period, the licensee aggressively pursued a planned and comprehensive course of action to identify and correct the root causes of the previously identified program-matic weaknesses in the area of physical security. To improve the overall performance of the security organization and the i security program the licensee implemented several significant actions, including a commitment by senior management to support and implement an effective security program; establishment of a licensee security management organization on-site to direct and .

oversee program implementation; upgrading unreliable systems and equipment to eliminate the previous heavy reliance on compens.-

tory measures that were manpower intensive; and revising the t i Security, Contingency and Training and Qualifications plans, and  !

their respective implementing procedures, to make them current and clearer, i

The licensee's security management organization is now headed by l

a section manager who reports to the Plant Support Manager,

under the Station Director. Assisting the Security Section

! Manager are five supervisors with specific functional areas of j responsibility (operations, administration, technical, compli-l ance and access authorization) and a staf f assistant. Addt-tionally, there are seven licensee shif t supervisors who are I

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39 restpn,sible to monitor the performance of the contract security force around-the-clock. This represents an overall increase of seven supervisors over those which were in place at the end of the last assessment period, and thirteen over that which was in place when the plant was shut down in April, 1986. (At that time there was one supervisor who reported to a group leader with other, concurrent duties.) The licensee also established a full-time corporate security position onsite. The incumbent is responsible to audit the security program on a continual basis and to provide another perspective on its implementation. In addition, the licensee established, as supervisory personnel, the alarm station operators employed by the security force con-tractor, and significantly improved the supervisor-to guard ratio. This expansion of the licensee's security organization represents a significant allocation in terms of resources and provides evidence of senior management's commitment to the program.

I In addition to the organizational expansion, considerable capital resources were expended throughout the assessment period to upgrade, by modification or replacement, security systems and equipment. The entire protected area barrier, assessment sys-tem, intrusion detection system and protected area lighting were significantly improved. These improvements began early in the assessment period and were, for the most part, complete at the end of the period with only minor fine tuning of the new systems and equipment still required. Additiopal upgrades in access control equipment and the security computer are scheduled. The improvements have already resulted in a sizable reduction in the number of compensatory posts and, therefore, a reduction in the contract guard force. The above mentioned upgrades permitted the guard force to go on a 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> work week rather than the 60 hour6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> work week required during the major portion of the assess-ment period. In addition to the improved systems and equipment, the licensee has taken action to strengthen the security equip-ment corrective maintenance program and has initiated action to establish a preventive maintenance program to further ensure the continued reliability of security systems and equipment. Open maintenance requests for security equipment are also now tracked as a performance indicator by plant management. Thesq actions and initiatives are further evidence of senior management's commitment to the program.

l 40 l

DurTog the assessment period, the licensee submitted six changes to the Security Plan under the provisions of 10 CFR 50.54(p).  !

One of these changes was a complete revision to upgrade the Security Plan and to revise the format to be consistent witn NUREG 0908. In conjunction with the Security Plan upgrade, the licensee also submitted revisions to the Safeguards Contingency Plan and the Security Force Training and Qualification Plan (complete revisions of these plans were submitted during March, 1988). The complete plan revisions were comprehensive, more -

consistent with current NRC regulations, and provided clearer documents from which to develop and modify implementing proced-ures. The plan changes were adequately summarized and appro-priately marked to facilitate review. Further, the licensee, prior to submitting the changes, communicated with the NRC by telephone and requested meetings in Region I and onsite to ensure that the changes were appropriate, clearly understood, and in compliance with NRC regulations.

• Audits of the Security program conducted by Corporate Security personnel and the onsite QA group during the assessment period were found to be very comprehensive and corrective actions were found to be prompt and generally effective, indicating a much improved understanding of program objectives. Because of the security program weaknesses identified toward the end of the l previous SALP period, the licensee assigned to the site, on a '

full-time basis, a member of the corporate security staff with responsibility for conducting continued surveillance and audit of the program. That initiative was reviewed and found to be a very effective management tool to provide an independent assess-ment of the day-to-day implementation of the security program and another input to the overall security program upgrade project.

The security force training program appears to be adequate to address the activities of the security organization. The lican-see has taken actions to assure the training program remains

!. current and reflects the changes and upgrades to the security program. For example, to ensure more comprehensive management oversight by licensee security shift supervisors, each received plant operational technical training in addition to security i program and other training. This training enables these super-visors to be more effective in interfacing with other plant technical functions.

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41 The) were three apparent viohtions identified b the NRC dur-ingIthi s assessment period. All of the violations were the result of degraded vital area barriers. The licensee was noti-fied of the apparent violations and an enforcement conference and a subsequent management meeting were held. These apparent violations resulted from weak communications between the secur-ity and maintenance organizations, and a poor appreciation by maintenance personnel of security requirements. Corrective actions were implemented by the licensee and they appear to be effective.

A total of six security event reports required by 10 CFR 73.71(c) were submitted to the NRC during this assessment per-iod. Three event reports were necessitated by the licensee's findings of degraded vital area barriers. Similar degradations were also reported in the previous assessment period. Two of the degradations reported during this period were the result of maintenance work being performed on plant systems that pene-trated the barriers. The other resulted from a degraded vital area door. Another event report was necessitated by the re-classification of an area of the plant as vital. The need for reclassification was identified as a result of the licensee's Vital Area Analysis and Barrier study. Another event report involved a guard leaving his weapon unattended The sixth event report involved the loss of a set of security keys by a member of the guard force. With the exception of the vital barrier degradations earlier in the assessment period, no adverse trend was indicated by the events whien occurred during this assess-ment period. The licensee eventually implemented appropriate measures to prevent recurrence of the vital area barrier degra-dation problems. The quality of the event reports was C 'ifi-l cantly improved over the previous assessment period ind. Ing &

better understanding of program objectives and more care in i

their preparation. They were clear, concise and contained suf-ficient information to permit NRC evaluations without the need for additional information.

The licensee's program and procedures for the control and ac-t counting of special nuclear material were also reviewed during this assessment period and were found to be adequate and gen-erally well implemented.

In summary, the licensee has demonstrated a commitment to imple-ment an effective security program that goes beyond minimum compitance with NRC requirecents. As a result of this commit ,

ment, the licensee security organization. has been expanded, significant capital resources have been expended to upgrade security hardware, and equipment and program plans have been improved. Continued senior management support and involvement in the security program is necessary to ensure that the momenturs demonstrated during thid assessment period is continued.

42 (2) ConD usion Ratino: 2 Trend: None Assigned

a ,

43 4.8 EngineehnsandTechnicalSupport-(1215 Hours /13 percent)

(1) Analysis This functional area is intended to assess the adequacy of the licensee's technical and engineering support in the areas of plant design changes, routine operations and maintenance activ-

. ities. Engineering and Technical Support was assessed as a Category 1 during the previous SALP period. Good engineering support to the site was noted in the Envirer. mental Qualification program and the design of several significant plant hardware modifications. Technical evaluations were typically thorough .

and demonstrated an adequate regard for safety. The engineering approach to the Safety Enhancement Pregram (SEP) demonstrated an excellent appreciation for underlying safety issues. A weakness in the lack of detailed design basis documents for plant equip-ment was also noted during the last period.

During this assessment period, five special inspections includ-ing an Augmented Inspection Team focusing on a loss of offsite power event, an electrical system team inspection, and a main-tenance team inspection were conducted and, in part, evaluated

. the licensee's performance in this area. The effectiveness of the onsite Systems Engineering Group, and the Nuclear Engineer-ing Department's (NED) interactions with the site organization were routinely mor"tored.

Significant plant modifications were installed during this assessment period, including the reactor water level instrumen-tation modification, a hydrogen water chemistry system, an analog trip system, and a naw plant process computer. Few prob-lems were identified with these projects, demonstrating the

! strength of the engineering work. Safety evaluations required by 10 CFR 50.59 for design changes and modifications were generally thorough and conservative. Safety evaluations for SEP 3

modifications demonstrated sufficient analysis and supporting facts to conclude that there were no unreviewed cafety Ques-tions. Highly qualified engineering staff and NED management focus on safety have contributed to the licensee's performance

, in this area.

Of f site technical and engineering support was generally good as indicated by the successful design and implementation of signif-  ;

icant plant hardware modifications. Continued effective use of i the N sign Review Board was evident Aring this SALP period.

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l 44 Th$ was demonstrated by high quality initial design reviews, and' routine evaluations of completed modifications for syner-gystic effects. The expanded Field Engineering Section, the design implementation oversight arm of NED, played a vital role in coordinating activities between the site organization and the NED. Engineering management was actively involved in implemen-tation of modifications and addressing problems. The Safety Enhancement Program, including extensive Mark I containment and station blackout modifications, were planned and implemented during this period. The engineering approach to the Mark I issues went considerably beyond NRC requirements and demon- .

strated a good appreciation of containment reliability issues.

• The NED's involvement in the development of the new Emergency Oper ting Procedures (EOP) demonstrated significant management attention in this area. The licensee's communications with the NRC regarding the planning and implementation of the SEP and E0P projects were generally good. In addition to these modifica-tions, the licensee is preparing an extensive Individual Plant Evaluation (IPE) as part of the (SEP) using probabilistic and deterministic analyses. In support of these efforts, the licensee effectively managed contract engineering expertise to produce quality design changes and analyses. Throughout the development and implementation of the SEP senior management's ,

involvement and commitment to safety was apparent.

i A team inspection was conducted during this assessment period tt.

review the licensee's implementation of a fire protection pro-i gram to meet the requirements of 10 CFR 50 Appendix R. The i licensee's approach to maintaining safe shutdown capability was found to assure adequate redundant safe shutdown system train

! separation, and to provide sufficient operational flexibility.

l The licensee's analyses were found to be well documented and l thorough. NE0's Appendix R project organization and the onsite 4 fire protection group worked. closely together to coordinate activities, i Sore weaknesses in the engineering design change process were noted. In one instance inadequate technical review of a design I change by NED resulted in incorrect installation of reactor l water level gauges. Additionally, the plant design change docu-

ment for the Standby Gas Treatment System did not specify ade-l quate post work testing requirements. Further, as indicated in

the previous SALP, the lack of detailed design basis documents l was a continuing problem this assessment period. Examples l included lack of seismic qualification documents for the reactor l

45 butiding. auxiliary bay and for the hydraulic control units.

Al E engineering failed to correctly translate containment accident temperature profiles into environmental qualification documents. However, the licensee has taken initiatives to further understand the design bases of the plant electrical distribution system as evidenced by the use of a new computer

1 code to analyse electrical distribution equipment performance.

At times, corporate engineering support for plant maintenance activities was limited. The NRC special electrical system inspection identified that the DC battery and electrical breaker maintenance activities were not supported by NED. The licen-see's initial response to the NRC's concern regarding the sur-veillance testing of the DC breakers was limited in scope and 4

lacked engineering justifications on the sample size and the acceptance criteria.

The increasing involvement of the onsite Systems Engineering Group (SEG) has had a positive -impact on the quality of opera l tions event analysis, the surveillance test program, and oh j maintenance performance, particularly the quality of maintenar-problem root cause analysis. At the beginning of the assessms.'

period the licensee established the. SEG under the Technir,,

4 Section within the Nuclear Operations Department. The SEG was

! staffed largely with experienced contractors, but the licensee

gradually expanded the group and replaced the contractors with permanent Boston Edison employees. At the end of this period, l

the SEG had a total technical staff of 26 including 15 senior systems engineers. The increasing involvement by the SEG has

, promoted better intergroup interactions as the operations and

maintenance departments have begun to value and rely on the SEG's contributions.

l i In summary, overall strong engineering support continued j throughout this period. Major plant modifications were com-1 pleted with only a few minor problems, demonstrating the quality l

of engineering work. The increasing involvement of the SEG has 1 contributed significantly to the qualif./ of root cause analyses l

and in maintenance performance. However, overall performance

(

in the areas of corporate engineering responsiveness and support

to site maintenance initiatives appears to need further licensee l evaluation and improvement. Additional management attention is needed in developing long-term programs to provide better i operational and maintenance support to the site, i

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46 (2) CorElusion Rating: 1 Trend: None Assigned

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47 4.9 LicensinM Activities 1 (1) Analysis The licensing functional area is intended to assess the licen-see's effectiveness in assuring a technically accurate and up-to-date licensing basis, and the licensee's responsiveness to NRC and industry concerns. During the previous assessment period licensing was evaluated as a Category 2.

During this period, the basis for this. appraisal was the licen-see's performance in support of licensing actions that were either completed or had a significant level of activity. These actions consisted of amendment requests, exemption requests, responses to generic letters, TMI items, and other actions.

The licensee has exhibited a high level of management involve- ,

ment in major licensing initiatives; however more routine licensing actions did not always receive substantive management action. An example of a high level of manageme.it involvement (

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

• containment and implement other plant safety improvements i intended to cope with severe accidents as part of' its Safety  !

Enharcement Program (SEP). This program includes improvements to emergency operating procedures,' modifications to containment spray nozzles, enhancements to water supplies that would be i available in the event of a severe accident, the installation of <

a direct torus vent and the installation of a third smergency diesel generator. A number of the SEP modifications, such as  ;

the Station Blackout Olesel Generator are also useful in dealing .

with less significa*nt transients and events as opposed to seyere accidents.

i The licensee is in the forefront of the iridustry in the effort to deal with severe accidents and has expended substantial resources on the SEP. The licensee has been very active in ,

industry owner's groups involved in severe accident initiativb. i Although much of the SEP effort did not involve direct licen' sing actions, the staff did assess the safety significance of the 7 licensee's modifications and inspected portions of the modifica- t tions. The licensee is commended fer its leadership on the SEP ,

program. It should be noted that the staff is still continuing its assessment of some of the details of the SEP modifications. j l

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48 Th D.echnic:1 quality of more routine licensing actions (such as some-Technical Specification amendments and exempti?n requests) has been sporadic. Several fire protection licensing actions have required numerous submittals and frequent interchanges with the staff. For example, the licensee revised its technical position twice in the determination of the appropriate basis for '

an exemption request involving the lack of 3-hour fire proofing for structural steel in the Reactor Building Torus Compartment.

Several submittals were .>equired, and the staf f had to request  ;

detailed calculations to support the licensee's basis. In a technical specification change involving 10 CFR 50 Appendix J requirements (Amendment 113), the licensee had to make numerous submittals in response to staff concerns and was recuired to correct errors in previous submittals identified by both the staf f and BECo. The staff identified inconsistencies in pro- ,

posed changes to the technical specif tcations for the Standby Gas Treatment System and Control Room High Efficiency Air Fil-tration System ( Amendment 112) and revised submittals by the licensee were required. The extensive activities and resources ,

required to correct problems identified in Con'irmatory Action i Letter 86-10 and subsequent management meetings has apparently i impacted the licensee's overall performance in the licensing area. These problema, suggest a weakness in corporate manage-ment at the level that establishes priorities and coordinates engineering and licensing activities for the utility.

The licensee has, however, submitted, and the staff has ap-proved, a number of technical specification changes or exemption requests that demonstrated a high level of technical quality and management involvement. Examples include the schedular ex-emotion for conduct- of the emergency preparedness exercise, Core Reload (Amendment 105), Control Rod Block Actuation (Amendment 110), and LPCI Subsystem Surveillance (Amendment 111). Where NRC staff requests for additional information were made, the licensee responses have been prompt and comprehensive.

The licensee has usually been responsive to NRC initiatives.

The licenses has been responsive to staff requests to track and control actions of mutual interest between NRR and the utility, i For example, the licensee has developed a tracking system to .

assist in the management of licensing actions and has provided i

extensive resources to support NRC effort in updating the Safety  ;

Information Management System ($1MS) data base. Particularly noteworthy was the high quality of technical support provided for the staff's review of Emergency Operating Procedures.

1 I

I

,---7 -, ---,---,.-y-+-

y. , - - ~ - , - . . -r ,--..,y

49 Thele .vas evidence of improvement during the latter portion of the -SALp period in the approach to the resolution of technical issues and responsiveness to NRC initiatives in the licensing area. This is in part due to recent organizational changes which have resulted in a closer relationship of the licensing and engineering groups. The overall staffing to support 16 n-sing activities is adequate and its effectiveness shoulc be

. improved by the recent organizational changes. Recently a reductio.i has been evident in the number of cases of technical errors, lack of clerity, and incomplete information.

In summary, the licensee has exhibited strong management ,

involvement in several major liunsing actions, but attention to more routine licensing actions has been inconsistent. The licensee has shown some improvrennt in the licensing area during the 1st'er portion of the 5 ALP period. The involvement of managemer. in routine, as well as major licensing activities, is nece s sa ry. The continued strengthening of mid-level management and i nc ret. sed technical capability of licensing staff are necessary.

(2) Conclusion Rating.: 2 Trend: None Assigned l

1

e 50 4.10 Trainin7 and Qualification Effectiveness (1) An'a l y s i s Technical training and qualification effectiveness is being con-sidered as a separate functional area. The various aspects of this functional area were discussed and used as one evaluation criterion within the other functional areas. The respective inspection hours have been included in each one. Consequently, this discussion is a synopsis of those assessments. Training effectiveness has been measured primarily by the observed per-formance of licensee personnel and, to a lesser degree, as a review of program adequacy. -

This area was rated as a Category 2 during the previous assess-ment period. The Jicensed operator training and requalification programs were found to be significantly improved. Assignment of knowledgeable staff had resulted in higher quality training materials, and more plant-oriented operator training. Mainten-ance, contractor and radiation protection personnel training were also .sdequate. Fire brigade and fire watch training had been significantly weak and contributed to poor personnel per-formance in the plant. Four of ten licensee training programs had received accreditation from the Institute of Nuclear power Operations (INPO).

During this assessment period, inspectors routinely reviewed ongoing training activities and their effectiveness in assuring quality personnel performance. Two sets of reactor operator and senior reactor operator license examinations were administered.

An inspection to evaluate the adequacy of the nonlicensed per-sonnel training program was also complcted. Various other inspections reviewed training provided in the areas of emergency preparedness, radiation protection, security, maintenance, fire protection and modifications.

Licensed operator training effectiveness continued to improve throughout the period. Two sets of licensed operator examina-tions werr. idsinistered to a total of two senior reactor opera-tors and f ourteen reactor operators, with all candidates suc-cessfully completing the licensing process. Newly licensed 4

operator familiarity with plant equipment and procedures was considered a strength. Challenges facing licensee management include completion of training for the large number of new, relatively inexperienced operators. Site management is intent on assuring that time spent by newly licensed operators in the control room during startup and initial operations, is used as effectively as possible to provide the maximum training benefit.

51 The mayerial developed for operator training and submitted for NRC.ceview was generally good. However, for the first examina-tion early in the assessment period, it was noted that some materials previded to the NRC did not reflect recent station r.adi fica tion s . This was because the modifications had recently been completed and previous training had focused on the original systems. It was also noted during exams and by direct discuss-ions with licensed operators, that training conducted on recently implemented modifications, such as on the reactor water level and automatic depressurization systems, had not been fully effective. Operators were unfamiliar with the modifications, primarily because only on-watch training had been performed and because the training had been conducted prior to completion of the modifications. Licensee management tonk prompt action to restructure the modifications training and committed to repeat the training prior to plant restart.

The licensee completed installation of a plant specific simu-later during this assessment period, and used it extensively to enhance operater training, particularly in the area of emergency operating procedures (EOP). The licensee implemented a compre-hensive E0P training program including a combination of simula-tor and classroom instruction. Licensee management assured the e f f ecti*;ene s s of this training by performing post-training evaluation of the operating crews en the simulator. The de-velopment of special criteria by which acceptable performance is judged was a strong point of the E0P training program. Operator performance weaknesses were identified by the licensee, and sup-plement:1 training was performed to resolve the problems.

Licenset management also initiated a communications training program for operations personnel. This communications training was implemented along with the E0P training and appeared to substantially improve operator performance.

Licensed operator performance during plant events such as a loss of of fsite power, and an Unusual Event due to a fire in the machine shop generally demonstrated a good command of plant equipment and procedures. However, some apparent weaknesses in operator training were evident. For example, several opera-tional errors were made during reactor refueling despite inde-pendent verification requirements. On several occasions oper-ators failed to properly perform routine surveillances,

0 52 ThT- nonlicensed and contractor personnel training program appeared effective. The training staff dedicated to this func-tion has been supplemented by the addition of contractors. Tha licensee initiated maintenance and radiological technician apprentice programs to assist in development of qualified lower level personnel. New training initiatives are in progress to sensitize management, workers and radiation protection personnel to the need to minimize all occupational exposure. For example, management training in ALARA for plant design changes and radia-tion awareness training for operations and maintenance personnel have been initiated. In addition, a Training Program. Evaluation Committee was established to assure plant management involvement in ongoing development of nonlicensed training.

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

. has been significantly improved. The station fire protection group and the licensee's training department have coordinated to expand the scope and enhance the quality of brigade training. A

~

large core of qualified fire brigade members has been estabitsbed.

Security force, emergency response and maintenance training

- appeared to be ef fective. No performance deficiencies directly attributable to training were identi' led in these areas during the period. INPO accredidation of all remaining training pro-

, grams was received during the current assessment period.

In summary, licensee management has been active in improving the overall quality of the training program and has been responsive to NRC concerns. Licensed and nonlicensed training programs are i effectively implemented. Of particular value is the use of the simulator, and other initiatives such as formal communications training and establishment of an apprentice program. Efforts I should be continued to strengthen operator training in the area of modifications and to ensure effective completion of training for newly licensed personnel.

(2) Conclusion i Ratino: 2

Trend: None Assigned I

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53 4.11 Assuranr7a of Quality -

r (1) Analysis During this assessment period. Assurance of Quality is being considered as a separate functional area. Management involve-ment in assuring quality continues to be discussed and assessed as an evaluation criterion in each of the other SALP functional areas. The respective inspection hours are included in each one. Consequently, this discussion is a synopsis of the assess-ments relating to assurance of quality in other areas. Since this is an evaluation of management's overall performance it conveys a broader scope than simply Quality Assurance (QA) department performance.

During the previous assessment period this functional area was Ivaluated as a category 3. Licensee management had not been ,

effective in addressing recurring SALP concerns. Organization and staffing were considered weak. Licensee management correc-tive actions in response to Quality Assurance (QA) findings and NRC issues had not been timely or comprehensive. QA department performance and engineering initiatives were considered a strength.

• Quality Assurance effectiveness has been assessed on a day-to-day basis. Three inspections focusing on the Quality Assurance and Quality Control (QC) programs were conducted during this period. In addition, the large number of management meetings held during tne period provided an opportunity for NRC manage-ment to assess licensee management's approach to resolution of issues.

• During much of the period licensee senior management continued to assess and correct organizational weaknesses through restruc-turing and recruitment of experienced personnel, many from out-side sources. A new Senior Vice Pre sider.t assumed responsi-bility for the nuclear organization at the beginr.ing of the period. In June, 1987 the Vice President-Nuclear Operations resigned. That position remained vacant until January, 1988 when the Site Director position was created and filled. Station management was reorganized several times, and significant personnel changes were made. Four individuals served as plant manager during the fifteen month assessment period. In addition to modifying the line organization a temporary Planning and Restart Group was created, working in parallel with the per-manent plant staff to provide outage planning oversight. This group was sub Mquently disbanded, incorporating its functions into the permanent organization. The licensee also replaced several mid-level managers during this assessment period in-cluding the Operations Section Man ger, Maintenance Section

c_ _ . ._ _ _ . _

54

, Manage r, Radiological Section Manager and- the Security Group-  !

Leger. In addition to changes in the line organization several staff assistant positions reporting to the Senior Vice President were established to enhance senior management oversight of or-ganization progress. Although actions in this area were imple-  !

mented slowly, it was evident that senior licensee management took a careful and deliberate approach to establishing the permanent organization and staff. Licensee management displayed i 4

the intent to fill open positions in the organization with the t i most highly qualified individuals available. This approach may  ;

have delayed staffing efforts and initially slowed licensee  !

progress in areas such as maintenance and radiological controls. l a e Management policies ai_ performance standards were strengthened and are clearly understood through mid-level management. How-  ;

ever, the new standards were not concurrently communicated or adopted at the working level in some cases. As a result ex-tensive management involvement in routine activities is still required to assure acceptable performance.

A high level of management involvement and commitment was effec-tive in promoting improvement in several SALP functional areas which had previously been identified as significantly weak.

l This is particularly evident in the areas of fire protection and  ;

security where management acted to establish, staff and support expanded oversight groups. This strong commitment is also evi- ,

i denced by the organization-wide increases in permanent staff,  !

! and the general reduction in reliance on contractors for augmen- l l

tation of line functions. One exception to this is in the area 1 j of maintenance where vacancies and reliance on contractors  !

i continues. -

[

j 1 Licensee response to new NRC concerns raised during the period - '

was sometimes narrowly focused, and did not target resolution of

) root causes. For example, a hiah level of NRC management ,

l involvement was required to assure development of a comprehen- I

, sive Power Ascension Test Program, and to resolve overtime con-trol deficiencies. Needed programmatic improvements in the area i

of maintenance were only implementeri after prompting by the NRC, j This may reflect that available licensee resources were focused i on areas of previously identified weak performance and on outage  :

completion schedules. In some instances the licensee's written l replies to NRC concerns have been vague, incomplete, and did not l l reflect the full extent of actions which had been taken at the l acility.

i i l \

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I I

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

55 TheElicensee initiated several programs designed to upgrade per-sonnel and plant performance. The plant Emergency Operating Procedures (EOP) were upgraded, and extensive E0P and communica-tion training was conducted to enhance operator response caca-bilities during abnormal and emergency conditions. A fitness-for-duty program was also instituted and applied to all licensee and contractor personnel. In addition, implementation of the

. Safety Enhancement Program and the station decontamination pro-gram improved the plant physical design and condition. The decontamination effort was particularly successful, .*esulting in increased accessability to plant areas and a general positive impact on personnel morale. .

Licensee management took an active role in es:ablishing long term plans to addr,ss identified weaknesses. The Restart Plan, the Material Condi .lon Improvement Action Plan (MCIAP), and the Radiological Action Plan (RAP) are examples. In the case of the MCIAP a team of contractors was created to provide ongoing independent assessment of the plan's effectiveness in improving plant material condition and maintenance practices. In the area of radiological improvements the liceasee reinstituted the Independent Radiological Oversight Committee to provide senior management with feedback on RAf- effectiveness. The licensee also implemented a self assessment process near the close of the peried. This self assessment was intended to provide a struc-tured method by which liceiste management could evaluate the progress made, and identify remaining weaknesses.

The licensee's Quality Assurance (QA) and Quality Control (QC) department continued to become more involved in station activ-ities. The onsite QA surveillance group was increased in size, and appeared to be actively involved in evaluating field activ-ities. QA audit methodology was revised to enhance its effec-tiveness, and an aggressive audit schedule was established. The licensee made good use of technical experts during audits to supplement available departmental resources. QA department management took prompt action to focus attention on significant concerns. For example, a stop work order was issued in response to adverse trends and findings in the area of maintenance on environmentally qualified equipment. Corporate and site manage-ment response to OA findings has also improved. Both the pro-gram controls and their application were strengthened to ensure timely response to QA ide.,tified deficiencies. Overdue response to these QA deficiencies are currently tracked as a perfcriance indicator.

56 i

Throughout most of the assessment period, the licensee's correc-  !

1 t&ve action process was not always effective'. A large number of ,

pf5blem reporting devices exist, each with a unique origination,  !

review and disposition process. This makes use of the correc-tive action system cumbersome, and weakens accountability for followup and closecut. Lack of clear problem descriptions, and I

delays between origination and followup, hampers establishment of root cause and implementation of corrective actions. The licensee has reviewed the process and recommendations to facil- -

itate improvemer.ts have been made. However, the recommendations  !

were not isolemented during this period. '

l In s umma ry ,' licensee senior management has taken strong action -

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

. ity personnel have been recruited to fill key management posit- '

ions. The reorganization and staffing process was not completed

uqtil late in the SALP period. As a result, progress in some functional areas, and in forcing management philosopy changes i

j down to the worker and first line supervisor level has been hampered. The continuing need for a high level of management

~

participation in routine activities occasionally prevents

, managsrs from focusing on other needed program improvements.

' Overall, the licensee has been successfull in effecting signifi-cant performance improvements in many areas. A high level of 1 management involvement is required to ensure that the initiated l 4

improvements cor.tinue and are sustained.  !

I (2) Conclusion >

r Ratino: 2 Trend: None Assigned j i .

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5.0 SUPPORTING DATA AND SUMMARIES 5.1 Investig7 tion and Alleoations Review Twenty allegations were received during this SALP period. Eleven of '

the allegations were investigated and found either to be unsubstan- <

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

allegations were investigated and substantiated, however the licensee had either already instituted appropriate corrective actions or such actions were promptly initiated in each case. Four allegations are currently under review. One of these four concerns the licensee's ,

program for control of overtime which is the subject of ongoing reviews.  !

I One investigation was initiated during the assessment period as a  !

i result of an allegation regarding a plant security vital area bar-rier. This investigation is continuing. -

s 5.2 Escalated Enforcement Action l Confirmatory Action Latter (CAL 86-10) was issued in response to a series of operational events in April, 1986. CAL 86-10 requested submittal of technical evaluations of these events and stated. that i l NRC Regional Administrator a.pproval would be required prior to j restart. The technical issues identified in CAL 86-10 have been i resolved. The CAL however was extended in August, 1986 and remains

open pending resolution of broader management concerns identified in l

the previous SALPs and subsequent inspection reports.

} Three violations were identified during the period for failure of the '

l ticensee to ensure the integrity of security vital area barriers.

These three violattens have yet to be characterized by severity '

level, and are currently being considered for escalated enforcement action. This action is pending conclusion of the O! investigation

described in Section 5.1 above.

l An NRC Order issued in 1984 requiring the licensee to implement a i l Radiation Improvement Program was closed during the period based on i the results of a special inspection and other program inspections f which indicated that all terms of the Order had been satisfactorily [

completed. ,

( Ruavest for Action Under 10. CFR 2.206 [

i l

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

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

July 15,1986, 2.206 petition filed by Massachusetts State Senator William B. Golden and others. The contentions raised in ths petition f I

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\ .

58 regarding . containment deficiencies and inadequacies in the radio-logicalnmergency response plan were denied. A decision regarding the management deficiencies was deferred to a subsequent response.

Three of the petitioners filed an appeal in federal court .on October 1, 1987.

On October 15, 1987, Massachusetts Attorney General James M. Shannon filed a 2.206 petition, on behalf of his office and Governor Michael S. Dukakis, requested an order to show cause why Pilgrim l should not remain shutdown until a full adjudicatory hearing resolves

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

) continuing managerial, Mark I containment, and emergency planning deficiencies. An interim NRC response was issued on May 27, 1988, i just after the end of the SALP period.

I

5.3 Management Conferences ,

Periodic management conferences and plant tours were conducted throughout the SALP period. NRC Commissioners toured the plant and 1 met with licensee management on six occasions during the period. A

• total of nine senior management conferences were held onsite or at

Region I. In addition to plant tours held in conjunction with onsite management conferences, senior NRC managers performed two plant inspections during the assessment period. NRC management partici-I pated in four public meetings in the vicinity of the plant. Two of

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

! communities. Five meetings with state officials and legislative l committees were attended by NRC managers. The NRC also testified i before the United States Senate Labor and Human Resources Committee

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

January, 1988. A chronological list of NRC management meetings and i plant tours conducted during the assessment period is contained in i

Table 5. In addition, a ' summary of licensing meetings has been included in section 5.4(1).

To coordinate the planning and execution o/ NRC activities and to assess the results of these activities a special Pilgrim Restart

Assessment Panel was formed. Tlie panel is composed of senior members l of the Region I and Headquarters staffs. This panel met bimnthly, with alternate meetings on site, i

~

59 5.4 LicensidE. Actions -

r (1) NRR/ Licensing Meetings and Site Visits Date Subject May 21, 1987 Licensing Issues, Bethesda, MD August 4, 1987 Emergency Operating Procedure and Direct Torus Vent September 24, 1987 Status of Pilgrim Restart / Schedule August 19-20, 1987 Multi-Plant Action Items August 24, 1987 Ongoing Fire Protection Reviews December 10, 1987 Emergency Operating Procedures Upgrade Janua ry 14, 1988 Discussion in Bethesda, MD of the in-service test program development (2) Commission Briefings Date Subject February 12, 1987 Regional Administrators' Meeting (Pilgrim Included)

December 17, 1987 Briefing on Status of Operating Reac-fuel facilities (Pilgrim tors and Included) t I

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60 (3) Schtdular Extensions Granted Sub}e:t Date Emergency Preparedness (EP) Exercise 12/09/87 Emergency Preparedness (EP) Exercise 05/11/88 (4) Reliefs Granted Subject Date Inservice Inspection Relief 03/26/87 (5) Exemptions Granted Subject -

Date Duplicate Yard Lighting 10/06/87 10 LFR 50 Appendix R-Operator Action O4/14/88 (6) License Amendments Issued Amendment No. Subject Date 98 New Design-Reactor 02/27/87 Control Rod Blades 99 Analog Trip System 03/03/87

. Surveillance Requirements 100 Maximum Average Flanar 04/09/87 Linear Heat Generation Rate 101 Control Room Ventilation 06/23/87 System 102 Standby Liquid Control 08/05/87 System 10 CFR 50.62 Rule 103 Administrative Changes 08/05/87 per 10 CFR 50.4 104 Nuclear Safety Review and 08/25/87 Audit Committee changes 105 Cycle 8. Core Reload 08/31/87

o ,

61 (6) LiEense Amendments issued 7

Amendment No. Subj ec_t Date 106 Automatic Depressurization 09/04/87 System Timer 107 Analog Trip System - 10/28/87 Calibration Frequency 108 Undervoltage Relay Require- 10/29/87 ments ,

109 High Pressure Coolant 10/29/87 Injection and Reactor Core Isolation Cooling

- Requirements 1

110 Rod Block and Average 11/30/87 Power Range Monitors Trip Functions l

111 Low Pressure Coolant 11/30/87 Injection Requirements 112 Standby Gas Treatment 01/20/88

& Control Room Air Filter Systems

. 113 Primary Containment 01/21/88 Isolation Values 10 CFR 50 Appendix J Requirements 114 Fire Protection - 03/08/88 Appendix R to 10 CFR 50 Requirements 115 Security Requirements - 03/28/88 10 CFR 73.55 116 Modification of Reporting 05/10/88 Schedule Supplements 1 Dose Assessment & Meterological Summary

a .

62 (7) OtEer Licensino Actions Action Date Containment Leak Rate Monitor 02/19/87 10 CFR 50 Appendix J Review 02/19/87 (Penetration X-21)  ;

Generic Letter 83-08, Mark I 02/27/87 Orywell vacuum Breakers Recirculation Flow Anomaly 02/28/87 -

Process Control Program (PCP) 03/03/88 Review Inservice Inspection Plan - 1986 03/16/87 Refueling Outage .

Control Room Floor-Fire Seals 03/24/88 3moke Seals - Conduit 03/24/88  :

Defects Westinghouse DC 04/13/88 Circuit Breakers Steam Binding - Pumps 04/15/88 Pilgrim SALP Activity 05/15/87 10 CFR 50 Appendix R Review 05/15/87 l

NUREG-0737 Item II.K.3.18 09/04/87 ADS Actuation Study l Offsite Dose Calculation Manual 10/28/87 f Correct Performance of Operating 11/16/87 [

Activities P

Intergranular Stress Corrosion 11/25/87 -

Cracking Augmented Inspection Program Refueling Interlocks 12/17/87 l

.r-.------_--------

o t

63 5.5 Licensee-Event Reports (1) Ove7'all Evaluation Licensee Event Reports (LER) submitted during the period ade-quately described all the major aspects of the event, including all component or system failures that contributed to the event and the significant corrective actions taken or planned to pre-vent recurrence. The reports were thorough, detailed, generally well written and easy to understand. The narrative sections typically included specific details of the event such as valve identification numbers, model numbers, number of operable redun-dant systems, the date of completion of repairs, etc., to pro-vide a good understanding of the event. The root cause of the event was clearly identified in most cases. Event inforeation was presented in an organized pattern with separate headings and specific information in each section that led to a clear under-standing of the event information. Previous similar occurrences were properly referenced in LERs as applicable.

The licensee updated two LERs during the reporting period. The updated LERs provided new information and the portion of the report that was revised was clearly denoted by a vertical line in the right hand margin, so the new information could be easily determined by the reactor.

However, in the past the licensee's threshold for reporting required monitoring. 4 LERs (87-021,87-022, 87-023, and 87-024) were submitted only after an audit by Region I. One of these LERs,87-021, was submitted 10 months af ter the event.

{2) Causal Analysis A review of the LERs indicates a number of problems, some recur-l ring. In particular, loss of offsite power has been a continu-ing problem at Pilgrim. In addition, Pilgrim has experienced repetitive events associated with inadequate procedures; admin-

)

istrative control problems associated with failure to conduct adequate reviews prior to maintenance and required surveillances and inadequate guidance and cautions for to:hnicians.

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Exemples of unclear procedures included LER-87-015 which de-scfTbes two events where RHR shutdown cooling was terminated by spurious isolation. One isolation was attributed to a precedure with inadequate instructions and cautions on installing jumpers; l the other isolation was due to inadequate procedures which failed to describe the right number of jumpers. LER 87-016 describes an unplanned actuation of primary and secondary con-tainment due to inadequate administrative controls for the planned replacement of a relay coil, specifically lack of appro-priate precautions and guidance. Furthermore the event was compounded by supervisory error in researching drawings, wiring i arrangements and assigning maintenance priorities.

Similarly, repeat problems can be illustrated by the following two LERs. LER-87-018 described a failed coil in a logic relay which caused a Reactor Water Cleanup System isolation. The  :

licensee conducted a technical evaluation of similar coils, identifying those requiring replacement. LER-88-005 describes an actu> tion of the Primary Containment Isolation Control System and Reactor Building Isolation Control System due to a failure of a similar coil in another relay.

Our assessment of the 39 events in this reporting period indicates:

16 involved either administrative control deficiencies, inade-Quate instructions, or inadequate procedures.

7 involved errors by non-licensed personnel.

As many as 8 may have involved design defects, t

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

at Pilgrim. '-

(Note: ovents may be assigned multiple causes)

In conclusion, the large number of events involving deficiencies in administrative controls, inadequate procedures and repeats of earlier, similar events points to the need for close monitoring of the effectiveness of licensee management in these areas.

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e o .

TABLE 1 .

dBULAR LISTING OF LERs BY FUNCTIONAL AREA PILGRIM NUCLEAR POWER STATION AREA CAUSE CODE

.A B C D E x TOTAL

1. Plant Operations 1 1

2 4

2. Radiological Controls - - - - - -

0

3. Maintenance and Modifications 4 -

1 7 6 1 19 4 Surveillance 4 - -

4 1 1 10

5. Fire Protection - - - - - -

0

6. Emergency Preparedness - - - - - -

0

. 7. Security and Safeguards 1 - - - -

1 2

8. Engineering and - 4 - - - -

4 Technical Support

9. Licensing Activities - - - - - -

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

0 j Effectiveness

11. Assurance of Quality - - - - - -

0 i,

TOTALS 10 4 2 11 7 5 39 l

J 1 Cause Codes: A - Personnel Error

! 8 - Design, Manufacturing, Construction, or Installation Error i C - External Cause 0 - Defective Procedure E - Cemponent Failure l X - Other l LERs Reviewed: 67-001-00 to 88-015-00 including 88-008-01 and 87-014-01 l

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.- TABLE 2 INTDECTION HOURS

SUMMARY

(02/01/87 - 05/15/88)

PILGRIM NUCLEAR POWER STATION Hours  % of Time

1. Plant Operations 2178 22

2. Radiological Controls 1262 13

3. Maintenance and Modifications 2347 24 4 Surveillance 1386 14 l

5. Fire Protection 493 5 1

Emergency Preparedness 176 2 6,.

7. Security and Safeguards 641 7

8. Engineering and 1215- 13 .

Ter.hnical Support i 9. Licensing Activities -

10. Training and Qualification -

Effectiveness i

11. Assurance of Quality .

Totals 9698

• Hours expended in facility license activities and operator license activities are not included with direct inspection effort statistics.

4 ** Hours expended in the areas of Training and Assurance of Quality are

! included in the other functional areas.

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

f I

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. TABLE 3 ENFORCEMENT

SUMMARY

(02/01/87 - 05/15/88)

PILGRIM NUCLEAR POWER STATION A. Number and Severity Level of Violations -

Severity Level I O r Severity Level !! 0 l' s Severity Level !!! O '

Severity Level IV 21 ,

Severity Level V 2 ,

Deviation 0 [

Total 26* ,

B. Violations Ys. Function Area .

Severity Levels ,

Functional Areas  ! II I!! IV V Oev Tot t 1_

1. Plant Operations - - -

2 - -

2

2. Radiological Controls - - -

8 -

8

3. Maintenance and Modification - - -

6 1

4 Surveillance

• 1 1

5. Fire Protection - -

1 1

6. Emergency Preparedness -

1 1

7. Security Safeguards - - - - - -

3*

- - - i

8. Engineering and - -

1 1

"- Technical Support i i

9. Licensing Activities - - - - - -

0

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

0

Effectiveness

11. Assurance of Quality - - -

1 2 -

3 l Totals 26*

j

' 'Three security violations are being considered for escalated enforcement  ;

action and have Hot yet been categorized for severity.

i i.

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1 TABLE 4 l Ptigrim SALP History .

i Assessment Period ,, ,

1/80- 9/80- 9/81- 7/82- 7/83- 10/84- 11/85- 2/87 i Functional Area 12/80 8/81 6/82 6/83 9/84 10/85 1/87 5/88 1

Operations 2 3 3 2 2 3 2 2

Radiological ,

Controls 3 2 2 2 3 3 3 3 Surveillance 2 2 2 1 1 2 3 2 Maintenance 2 3 2 2 1 2 2 2 Emergency .

Planning 3 1 1 1 3 3 2 2 I Fire Protection 2 2 3 1 2 -

3 2-Security

) 2 2 2 2 2 2 3 2 Engineering and J Technical j Support - - - - - -

1 1 1

4 l Licensing - -

2 1 1 1 2 2

! Training Effectiveness - - - - - -

2 2 i Assurance of Quality /QA 3 3 - - - -

3 2 l

Outage Management 3 2 2 -

1 1 1 -

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21 . TABLE 5 MANAGEMENT MEETING AND PLANT YOUR

SUMMARY

DATE SPONSOR TOPIC 02/02/87 NRC Management meeting at Plymouth, MA to discuss the status of licensee improvement programs (IR 87-08) 02/03/87 Massachusetts NRC Region ! Administrator and other Region !

Secretary of managers met in Bolton, MA with several Energy Commonwealth administrators to discuss NRC activities regarding Pilgrim 03/09/87 Massachusetts NRC Region I Administrator and other members of Legislature the staff appeared in Boston, MA before the Massachusetts Joint Committee on the Investigation af.d itudy of the Ptigrim Station at Plymouth (!R 87-14) 03/10/87 NRC NRC Chairman Zech toured Pilgrim accompanied by the Regional Administrator and attended a licensee presentation (IR 87-16) 04/27/87 Massachusetts NRC Region ! Administrator and other members of Legislature the staff appeared in Boston before the Mass-chusetts Joint Committee on the Investigation and Study of the Pilgrim Station in Plymouth (IR 87-18) 05/01/87 NRC Management meeting at NRC Region ! to discuss a surveillance program violation and program weaknesses (!R 87-23) 05/07/87 NRC 1987 SALP management meeting at Plymouth, MA 05/22/87 NRC NRC Commissioner Carr toured the plant and attended a licensee presentation 05/27/87 Plymouth Four NRC Region I management representatives Board of participated in a public meeting in Selectmen Plymouth, MA 06/24/87 NRC NRC Commissioner Asselstine toured the plant and attended a licensee presentation

• .e Table 5 2 0 ATE SPr.NSOR TOPIC 06/29/87 NRC Management meeting at NRC Region I to discuss the outage status, program improvements and licenwee preparations for restart (IR 87-28) 07/23/87 Commonwealth The NRC Section Chief, Licensing Project Manager of Mass, and Resident Inspectors for Pilgrim met onsite with representatives of the Commonwealth to discuss the NRC inspection process (IR 87-27) 09/09/87 NRC Enforcement conference at NRC Region I to discuss several security violations (IR 87-30) 09/24/87 NRC NRC Director of the Office of Nuclear Reactor

. Regulation, the Region ! Administrator and other senior NRC managers met with the licensee in Bethesda, M3 to discuss licensee activities and restart readiness (NRR meeting transcript) 09/30/87 NRC Enforcement conference at NRC Region I to discuss several security violations (IR 97-30) 10/05/87 NRC NRC Commissioner Bernthal toured the plant and attended a licensee presentation 10/08/87 Commonwealth NRC Region ! Administrator and other senior NRC

- of Mass, managers met at Region I with representatives of the Commonwealth of Mass, and two private citizeas to answer questions regarding the NRC inspection process (IR 87-45) 10/29/37 Ouzbury Board Four NRC Region ! and NRR management of Selectmen representatives participated in a public meeting sponsored by the Ouxbury Board of Selectmen, Duxbury Emergency Response Plan Committee and the Dumbury Citizens' Committee on Nuclear Matters in Duxbury, MA 12/08/87 NRC NRC Region ! Administrator toured the plant and met briefly with licensee management to discuss tour observations (IR 87-57)

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Table 5 3

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DATE SECNSOR TOPIC r-r 01/07/88 United NRC Director of the Office of Nuclear Reactor States Regulation and the Region I Administrator Senator appeared before the Senate Labor and Human Kennedy Resources Committee regarding Pilgrim. The public hearing was held in Plymouth, Ma, 02/18/88 NRC NRC Region I and NRR managers conducted a public meeting in Plymouth. MA to solicit public comments on the licensee's Restart Plan 02/24/88 NRC Management meeting at NRC Region I to discuss the licensee's self assessment process to be used for determining restart readiness (IR 88-10) 03/10/88 NRC The NRC Director of the Office of NRR and the Region I Administrator toured the plant and interviewed licensee staff regarding the design basis for the direct torus vent modification (IR 88-07) 04/08/83 NRC Management meeting at NRC Region I to discuss the licensee's proposed power ascension test program (Meeting Minutes 88-43) 04/22/88 NRC NRC Commissioner Carr toured the plant and atte,nded a licensee presentation (IR 88-12) 05/06/88 NRC NRC Commissioner Rogers toured the plant and attended a licensee presentation (IR 88-19) 05/11/88 NRC NRC Region I and NRR managers conducted a public meeting in Plymouth MA to provide responses to comments and concerns on the licensee's Restart Plan raised during the 2/18/88 public meeting (Meeting transcript)

1 ust Tso STATES

[% f\a NUCLEAR REGULATORY COMMl8810N a s a n em o ni.e n o as mee op poussaa commenvama teens .

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I j

SEP 071883 Docket No. 50-293 Boston Edison Company

l ATTN

Mr. Ralph G. Bird Senior Vice President - Nuclear Ptigria Nuclear Power Station i RFD #1, Rocky Hill Road j Plymouth, Massachusetts 02360 i Gentlemen:

i

Subject:

NRC Region ! Inspection Report No. 50-291/88-21, Integrated

- Assessment Team Inspection .

l This refers to the Integrated Assessment Team Inspection (IATI) led by l

Mr. A. Randy 81ous5 of this office on August 8-24, 1988, at the Pilgrim l

Nuclear Power Station (pnp 5), Plymouth, Massachusetts. The results of the i inspection are documented in the enclosed inspec*. ion report. At the conclusion i of .the inspection, an exit interview was held with you and members of your j staff to discuss the scope and the findings of the inspection.

s i The purpose of this inspection was to perform an independent, in-depth assess-l ment of the readiness of management controls, programs, and personnel to sup-l port safe restart and operation of the facility. ihe inspection Team performed i an integrated evaluation of various functional areas, including operations,

! maintenance, surveillance, radiation protection, security, training, fire pro-

! taction, and assurance of quality. Within these areas, the inspection con-

! sisted of interviews with personnel, observations of plant activities, and i selective examinations of procedures, records, and documents by the inspectors, i

i Within the scope of its review, the Team concluded with high confidence that I Boston Edison Company (8Eco) management controls, programs, and personnel are I generally ready and performing at a level to support safe startup and operation 2

of the facility. Those technical items nquiring resolution or completion prior to restart are being addressed and tracked by BEco. The Team identified a relatively small number of additional items for which actions or evaluations appear appropriate; BEco has made commitments in those areas, as detailed in section 2.4 of the enclosed report. As a result of this inspection, the Team concluded that then are curnntly no fundamental flaws in BEco's I

management structure, management performance, programs, or program i implementation that would inhibit its ability to assun reactor or public safety during plant operation.

l f O^

b c_~ --

• ff I__ _ . _ . __

Boston Edison Company 2 'SEP 071988 If your understanding of any item detailed in Section 2.4 of the enclosed report differs from that stated, please contact Mr. Blough or me promp*.ly. The NRC will review the status of these issues prior to any restart of PNPS.

The results of this inspection will be considered during the NRC staff's deliberations as it reaches its decision regarding a PNPS restart recommenda-tion to the NRC Commission.

No written reply to this letter is required. Your cooperation with us is appreciated.

Sincerely, ue s, o ns, Deputy Director Division of Reactor Projects

Enclosure:

NRC Region I Inspection Report No. 50-293/88-21 cc w/ encl:

K. Highfill, Station Director R. Anderson, Plant Manager J. Keyes, Licensing Division Manager E. Robinson, Nuclear Information Manager

! R. Swanson, Nuclear Engineering Department Manager i

The Honorable Edward J. Markey The Honorable Edward P. Kirby The Honorable Peter V. Forman B. McIntyre, Chairman, Department of Public Utilities i Chairman, Plymouth Board of Selectmen Chairman, Ouxbury Board of Selectmen Plymouth Civil Defense Director P. Agnes, Assistant Secretary of Public Safety, Commenwealth of Massachusetts S. Pollard, Massachusetts Secretary of Energy Resources R. Shinshak, MASSPIRG Public Occument Room (POR) local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

! NRC Resident Inspector l Cossoonwealth of Massc husetts (2)

P. Chan, Commonwealth of Massachusetts S. Sholly, MHB Technical Associates t

U.S. NUCLEAR REGULATORY C0Kv,ISSION REGION I Oceket No.: 50-293 Report No.: SP293/88-21 .

Licensee: Boston Edtson Company Pilgrim Nuclear Power Station RF0 #1, Rocky Hill Road Plymouth, Massachusetts 02360 ,

Facility: Pi1 grim Nuclear Power Station location: Plyrouth, Massachusetts Cates of Inspection: August 8-24, 1933 Inspectors: (See Attachment E)

Approved By: n h us 1 'm ~

u 97!S6 A.' Rancy Blougn, Cnief '0 ate Reactor Projects Section No. 33 -

Division of Reactor Projects Inseection Sumary:

Areas Insoected: Integrated Assessment Team Inspection to assess the degree of readiness of licensee management controls, programs, and personnel to sup-port safe restart and operation of the plant. T' . scope of the inspection is further detailed in Section 2.2.

Results:

The team concluded that licensee manager.ent controls, programs, and personnel are generally reacy and performing at a level to support safe startup and operation of the facility. Results are further sumarized in Sections 1.0 (Executive Sumary) and 2.3 (Summary of Findings).

If

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TABLE OF CONTENTS

?a.gg ACR0NYMS....................................................... iv 1.0 EXECUTIVE

SUMMARY

..'....................................... 1 2.0 INTR 000CTION.............................................. 2 4

2.1 Background................................ .......... 2 2.2 Scope of Inspection.............:.................... 3 2.3 S umm a ry o f I AT I R e s u l t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.3.1 Ov e r a i l S umm a ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.3.2 Summary of Results by Functional Areas..... 5 2.4 Licensee Commitments................................. 9 2.4.1 Procedure Validation and Training.......... 9

2.4.2 Identifying Proc 7 dure Changes Requiring Training................................. 9 2.4.3 Tempo ra ry Modi ficat ion s. . . . . . . . . . . . . . . . . . . . 9 2.4.4 Opera

• ions Review Committee................- 10 l 2.4.5 Maintenance................................ 10 2.4.6 S u rv e t 1 1 a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 2.4.7 Formalizing Personnel Qualification Reviews.................................. 11

l 2.4.8 Mission. Organization and Policy Manual.... 11 2.4.9 Fastitarizing Workers with Expected 4

Radio'ogical Conditions.................. 11 2.4.10 Control Room Human Factors. . . . . . . . . . . . . . . . . 11 3.0 O ETAI LS OF IN 5 P ECTICN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 3.1 Managemeat 0versight................................. 12 3.1.1 Scope of Rev1ew............................ . 12 3.1.2 Organization............................... 12 i

3.1.3 5taffing................................... 15 i 3.1.4 Qualifications............................. 15 i 3.1.5 Administrative Policy and Procedures....... 18 3.1.6 Communications and Observations............ 19 1 3.1.7 Conclusions................................ 20 I

i

TableofContents(Continued)

Pace 3.2 Operations........................................... 21 3.2.1 Scope of Review............................ 21 l 3.2.2 Conduct cf Operations...................... 21 3.2.3 Shift Staffing and Overtime Controls....... 23 3 . .t . 4 Procedure Va11dation....................... 24 3.2.5 Temporary Modification Controls .......... 25 3.2.6 Required Reading 3coks..................... 28 3.2.7 Logs.......l............................... 29 A.2.8 Tirely Update of Lif ted Lead / Jumper Log.... 29 3.2.9 Tagouts and Operator Aids.................. 31 3.2.10 Plant Tours and System Waikdowns........... 31 '

3.2.11 Conclusions................................ 34 3.3 M a .' n t e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 3.3.1 Scope of Review............................ 36 3.3.2 Observations and Finding s . . . . . . . . . . . . . . . . . . 36 3.3.3 Conclusions................'................ 50 3.4 Surveillance Testing and Calibration Control......... 52 3.4.1 Scope of Rey 1ew............................ 52 3.4.2 Ob se rvati on s and Fi ndi ng s. . . . . . . . . . . . . . . . . . 52 3.4.3 Conclusions................................ 61 3.5 Radiation Protection................................. 63 3.5.1 Scope of Review............................ 63

3.5.2 Cbservations and Findings.................. 63 3.5.3 Conclusions................................ 73 3.6 S ecuri ty a nd Sa fegu a rd s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75

3.6.1 $ cope of Review............................ 75

! 3.6.2 tb servati ons and Fi ndi ng s ; . . . . . . . . . . . . . . . . . 75 3.6.3 Conclusions................................ 82 i

t 4

P 11

Table of Contents (Continued) ,

b .

) Page 3.7 Training......................................... 83 3.7.1 Scope of Review.......................... 83 1

3.7.2 Observations and Findings............... 83 3.7.3 Conclusions................................ 88

{

3.8 Fire Protectiot ..................................... 89

. 3 .'8 .1 S c o p e o f R e v i ew . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89 3.8.2 Observations and Findings.................. 89 3.8.3 Conclusions................................ 90 l 3.9 Engineering Suppert.................................. 91 3.9.1 Scope of Rr.'iew............................ 91 3.9.2 Observations and Findings.................. 91 3.9.3 Conclusions................................ 93 3.10 Safety Assessment / Quality Verification............... 94 3.10.1 Scope of Review.................... ....... 94 3.10.2 Nuclear Safety Review and Audit Committee.. 94 3.10.3 Operations Review Committee................ 97 3.10.4 Quality Assurance Audit and Surveillance Programs................................. 102

? '.1.5 Corrective Action Process and Programs..... 104

. 3.10.6 Conclusions................................ 115 4.0 U N R E S O LV E D I T EM S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 117 5.0 MANAGEMENT MEETINGS....................................... 118 Appendix A - Entrance Interview Attendees...................... A-1 Appendir B - Exit Interview Attendees.......................... B-1 Appendix C - Persons Contacted................................. C-1 Appendix 0 - Documents Reviewed................................ 0-1 Appendix E - IATI Composition and Structure.................... E-1 Appendix F - Resumes........................................... F-1 Appendix G September 1, 1988 Letter from NRC to Commorwealth of Massachusetts................................ G-1 Appendix H - September 6, 1988 Letter from Commonwealth of Massachusetts to NRC............................. H-1 l

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ACRONYMS ALARA -

As Low As Reasonably Achievable ANSI -

American National Standards Institute ASME -

American Society for Mechanical Engineers BECo - Boston Edison Company BEQAM - Boston Edison Quality Assurar.ce Manual CAS -

Central Alarm Station CQI Commercial Quality Item CS -

Core Spray (System)

CST -

Condensate Storage Tank OC Direct Current DCROR -

Detailed Control Room Design Review DG -

Diesc1 Generator DR -

Deficiency Reports E0P -

Emergency Operating Procedures EO -

Equipment Operator EPRI -

Electric Power Research Institute EQ Environmental Qualification ESF -

Engineered Safety Feature -

ESR -

Engineering Service Request FLMR - Failure and Malfunction Reports FYI -

For Your Information ,

GET - General Employee Training iv i

l

Acronyms HP -

Health Physics HPES -

Human Performance Evaluation System HSA -

Housekeeping Service Assistance IATI -

Integrated Assessment Team Inspection .

I&C -

Instrumentation and Control ICA -

Immediate Corrective Actions INPO -

Institute of Nuclear Power Operations IST -

In-Service Testing ,

LCO -

Limiting Condition for Operations

~

Lifted Lead / Jumper LL/J -

LS FT -

Logic System Functional Test M&TE -

Measuring and Test Equipment MCAR -

Management Corrective Action Requests MCIAP -

Matarial Condition Improvement, Action Plan MC&AT -

Mr.tagement Oversight and Assessment Team NOP -

Mission, Organization and Policy Manual MPC -

Maximum Permitted Concentration MR - Maintenance Request MSC - Maintenance Summary and Control MSTP -

Master Surveillance Tracking Program l

MWP -

Maintenance Work Plan 1

NCR - Nonconformance Report l

l NED -

Nuclear Engineering Department l NOP -

Nuclear Organization Procedures y

Acronyms NRC -

Nuclear Regulatory Commission NRR - Office of Nuclea'r Reactor Regulation NSRAC - Nuclear Safety Review and Audit Committee NWE - Nuclear Watch Engineer OMG - Outage Management Group ORC -

Operations Review Committee P&ID -

Piping and Instrument Diagram PCAQ

- Potential Condition Adverse to Quality POC -

Plant Design Change PI -

Pressure Indicator PM . -

Preventive Maintenance PHPS - Pilgrim Nuclear Power Station PCIS - Primary Containment Isolation System QA0

- Quality Assurance Department RCIC - Reactor Core Isolation Cooling ,

RETS - Radiological Environmental Technical Specifications RHR - Residual Heat Removal (System)

RO - Reactor Operator ROR - Radiological Occurrence Report RP Radiatier. Protection RWP -

Radiation Work Permits SAA -

Simulated Automatic Actuation SAS

- Secondary Alarm Station vi

~

A ronyms '

SBLC -

Standby Liquid Control (System)

SDR -

Security Deficiency Reports SE - Safety Evaluations SEG -

Systems Engineering Group SES -

Senior Executive Service SFR -

Supplier Finder Reports SGI -

Safeguards Information Station Instruction SI -

SRO -

Senior Reactor Operator STA -

Shift Technical Advisor SVP-N -

Senior Vice President - Nuclear TM -

Temporary Modification TS -

Technical Specifications VP-NE -

Vi;e President - Nuclear Engineering WIP -

Workforce Information Program WPRT -

Work Prioritization Review Team 6

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1.0 EXECUTIVE

SUMMARY

In response to NRC concerns over longstanding issues regarding the manage-ment effectiveness of the Boston Edison Company (BEco) in the operation of the Pilgrim facility, the Itcensee agreed to maintain the plant in a shutdown condition following operational events which occurred on April 11-12, 1986. The NRC confirmed the licensee's agreement in Con-firmatory Action Letter (CAL) 86-10. The CAL, as supplemented in an August 27, 1986 letter, also confirmed that the licensee would develop a comprehensive plan to address those concerns and perform an in-depth self-assessment of the effectiveness of that Plan. On June 25, 1988, the licensee reported it had completed these activities to the extent that an NRC review was appropriate. In order to assess the status and results of BECo's corrective actions, the NRC performed an independent review of the ef fectiveness of the licensee's management controls, programs and person-nel during an Integrated Assessment Team Inspection (IATI) conducted August 8-2.4, 1988.

The Team consisted of an SES-level manager, a Team leader, and members of the NRC Region I and Headquarters staff. The inspection team also included two observers representing and appointed by the Commonwealt'. of Massachusetts. These observers had access and input to all aspects 9f the inspection as provided by the established protocol. The areas reviewed during the inspection included operations, maintenance, surseallance, radiation protection, security, training, fire protection and asst rance of quality. The Team reported directly to the Regional Administ ator of Region I.

Overall, the Team concluded with high confidence the.t 8Eco management controls, programs, and personnel were generally ready and performing 't a level to support safe startup and operation of the Pilgrim Nuclear Powe Station. Further, althuugh the Team identified certain items which '

require licensee actions or evaluations, there were no fundamental flaws found in the licensee's management structure, management performance, programs, or program implementation that would inhibit its ability to assure reactor or pubite safety during plant operation.

e 9

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l 2

2.0 INTRODUCTION

f This report details the findings, conclusions and observations of NRC's Integrated Assessment Team Inspection conducted at thm Pilgrim Nuclear Power Station (PNPS) on August 8-24, 1988. The results of this inspection are to be considered during NRC staff's deliberations as it reaches its decision regarding a restart recommendation to the NRC Commissioners.

2.1 Background

The NRC's 1985 Systematic Assessment of Licensee Performance (SALP) found progrcmmatic weaknesses in several functional areas at the

.oilgrim Nuclear Power Station and noted that, historically, the licensee could not sustain performance improvements once achieved. A special NRC Region I diagnostic team inspection was subsequently per-formed in February and March 1986 to evaluate facility performance.

This i n spec t.i on , which included monitoring plant activities on a 24-hour basis, confirmed the 1985 SALP and concluded that poor management control and incomplete staffing contributed to the poor performance.

Following several operational events, Boston Edison Company (BEco) shutdown PNPS on April 11-12, 1986. The NRC subsequenti;- issued a Confirmatory Action Letter (CAL) on April 12, 1986, and a supplement on August 27, 1986, maintaining the plant shutdown and requiring that the licensee obtain NRC approval prior to restart. The central issues in the CAL, as supplemented, involved the effectiveness of licensee management of the faellity and technical concerns. .

SALP evaluations continued during the shutdown, and improvements were noted during the 1986 SALP period, although the rate of change was  ;

slow. Several factors ichibited progress, including continued man-agement changes and prolonged staffing vacancies. Good performance was noted in four areas: emergency planning, outage management, corporate engineering support and licensed operator training. The success in these areas reflected a high level of corporate management attention and substantial resource commitments. The licensee also j

had made significant plant hardsare improvements, including Mark I Containment performance enhancements.

l Consistent with the CAL and its supplement, BEco has addressed the specific technical issues, developed and submitted the Pilgrim r

Nuclear Power Station Restart Plan and performed a detailed self-assessment of readiness for restart. The NRC staff reviews of these items are complete. The licensee has t.lso submitted a Power Ascen-sion Test Program, for which the staff review is ongoing.

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

4

)

3 .

l NRC subsequently completed a $ ALP uvaluation for Pilgrim covering the period February 1,1987 to May 15,1988. It concluded that licensee management initiatives are generally successful in correcting staff-ing, organization, and caterial deficiencies. Programmatic perform-ance improvements were evident in areas previously identified as having significant weakness :. .d in areas that the licensee's self-assessment process identified as warranting further management 2 attention.

The NRC Confirmatory Action Letter (CAL) of April 1986 required the i NRC to perform a review to assess BEco's corrective actions. In con-junction with an augmented inspection program and as part of a con-i tinuing effort to monitor BEco's program improvements, the NRC .

- planned this IATI to independently measure the effectiveness and readiness of the licensee's managwment controls, programs and per-sonnel te support safe restart of the fLility. A Restart Readiness Assessment Report that includes staff assessment results will be prepared by the NRC in conjunction with development of an NRC staff recommendation regarding plant restart.

2.2 Scooe of Inspection The IAT inspection was performed to provide an independent, in-depth assessment of the degree of readiness of licensee management con-trols, pro ~ grams, and personnel to support safe restart and operation of the Pilgrim Nuclear Power Station (PNPS). The inspection covered a variety of functie.941 areas, including operations, maintenance, i surveillance, radiation ,9rotection, security, training, fire protec-tien, and assurance of qudity. Parti:ular emphasis was placed on

management effectiveness and oti the ~ status of the licensee's recent L program improvements in maintenance. The inspection censisted of ,

l interviews with licensee personnel, plant tours, observations of '

plant activities, and selective examinations of procedures, records, i and documents. The Team also directly observed ongoing plant activities on all shif ts from August 10-13, 1988.

The 15-member Team consisted of a senior manager, insp;ction team leader, five shift inspectors, and several specialist inspectors from both NRC Region I and the NRC Office of Nuclear Reactor Regulation -

(NRR). Two representatives from the Commonwealth of Massachusetts were also on the Team as observers throughout the inspection. The team roster and member resumes are attached as Appendices E and F to this report.

l Onsite IATI preparation, which included site familiart:ation and plant tours, was conducted during the week of July 18, 1988. The Team l was onsite full-time from August 8 through 19, 1988. Some IATI mem- ,

l bers were on site during the documentation period of August 20 24, 1988. Attencess at tne entrance and exit interviews are listec in (

Appendices A and 8, respectively. Senior licensee managers contacted during the course of the inspection are listed in Accendix C. Many other persons at all levels of the organization were also contacted or interviewed.

l ._ _ _ _ _ _ . _ _ _ _ _ _ . .______

n 4

The licensee was not presented with any written material by the NRC during this inspection. The licensee indicated that no proprietary material was presented for review during this inspection.

2.3 Summary of IATI Results 2.3.1 Overall Summary The Team concluded, with high confidence, thet licensee management controls, programs, and personnel are generally ready and performing at a level to support safe startuo and '

operation of the facility. Technical items requiring reso-lution or completion prior to restart era betag addressed and tracked by the licensee. The Team identified a rela-tively small number of additional items for which licensee actions' or evaluations appear appropriate; during the inspection, the licensee made acceptable commitments in these areas. There are currently no fundamental flaws in the licensee's management structure, management perform-ance, programs, or program implementation that would inhibit its ability to assure reactor or public safety dur-ing plant operation.

The inspection generally confirmed the, results of the SALP report for February 1,1987 through May 15, 1988, as well as validating the general SALP conclusion that performance was improving at the end of the SALP period. Further, licensee performance appeared to be consistent or improving in all functional areas examined during the IATI, with the current level of achievement for overall safety performance equal to or better than that described in the SALP. For

.aaintenance and radiation protection, the performance is noticeably improved.

The inspection generally confirmed the effectiveness ef various licensee self-improvement programs and of the licensee's self-assessment process. The Team identiffed

relatively few issues that had not been previcesly identi-i fled by the licensee. In the interest of continually

'. improving its self-assessment process, the licensee should evaluate those cases where NRC either identified new issues or assigned a higher sense of priority than identified by the licensee.

The inspection confirmed that important organization and attitudinal changes had occurred since 1986. Of particular concern to NRC during the diagnostic inspection in 1986 were several factors inhibiting progress. These included:

5

1) Incomplete staffing, especially of operators and key mid-level supervisory personnel;

2) The prevailing licensee view that improvements to date had corrected the problems identified;

3) Reluctance by Itcensee management to acknowledge some problems identified by NRC; and

4) Dependence on third parties to identi fy problems rather than implementing an effective licensee program to identify weaknesses. ,

The Team found these inhibitors to be substantially re-moved, and noted that a significantly improved nuclear safety ethic exists at management levels and is developing successfully at the worker level.

Based on a review of the management structure, staffing, goals, policies and administrative controls, the Team con-cluded that the licensee has an acceptable organization and administrative process, with adequate management and tech-nical resources to assure that the plant can be operated in a safe and reliable manner during normal and abnormal con-ditions. Further, this performance-based inspection pro-vided an integrated look at overall management effective-ness in ensuring high standards of nuclear safety. The overall conclusions of this inspection confi rm facility management effectiveness, especially its ability to perform self-assessment functions, to improve performance, and to raise nuclear safety awareness and attitudes throughout the organization.

2.3.2 Summary of Results by Functional Area Within each functional area, conclusions were reached including the identification of various strengths and weak-nesses. These are summarized below. The basis for these I items, as well as the many significant observations made by the Team, are explained in Section 3 of this report.

l 2.3.2.1 Operations Strengths

-- Experienced and knowledgeable senior lican-sed operators

1 6

Effective shift turnover Excellent plant housekeeping Weakness Lack of thoroughrisss and attention to detail in validation and training of Emergency Operating satellite procedures 2.3.2.2 Fire Protection Strengths Effective program staffing and supervision Effective prioritization, control, and tracking of fire protection equipment maintenance Weaknesses None 2.3.2.3 Maintenance Strengths Good organization and structure Thorough program procedures Clear maintenance section internal communi-cations and interactions

- -- Good control and support of field activities Weaknesses

-- Examples of poor implementation of planning for post-work testing

-- Poorly controlled storage of Q-listed items at two locations outside the warehouse

1 7

l 2.3.2.4 Radiological Controls Stranoths Effective use of a maintenance health physics (HP) advisor

~

-- A well-organized training program Weaknesses

-- Examples of a lack of continuity and pro-ficiency in certain highly speciali .ed jobs because of frequent technician rotation Indications of weak vertical communications within the Hp group 2.3.2.5 Surveillance Strength Management commitment to improve an already satisfactory program Weakness

-- Incomplete resolution of proper frequency and scheduling of once-per-refueling outage tests 2.3.2.6 Security Strenath ,

Overall management attention Weaknesses None 2.3.2.7 Training

$_trenoths

-- Excellent management support for operator training programs

1 8

Strong relations between the plant oper '

tions and training departments We,akness Lack of a defined process to assure timely

. identification and implementation of train-ing needs resulting from newly approved or revised procedures 2.3.2.8 Engineering Support Not directly reviewed. No specific strengths or weaknesses identified 2.3.2.9 Safety Assessment / Quality Verification Strengths Nuclear Safety Review and Audit Committee (NSRAC) composition, plant tour- program, frequency and location of meetings, open forum, and focus of reviews

-- Attitude and performance toward identifying problems Effective, meaningful communications between the Quality Assurance and plant Operations departments Wtaknesses

-- Operations . Review Comaittee does not perform an effective independent group review of operations and Technical Specification violatio,ns

-- Multipiteity of corrective action programs without centralized tracking

-- Poor tracking of potential Condition Adverse i to Quality (PCA0) reports

9 l l

2.3.2.10 Hanagement Oversight Strencths Well-defined organization, incorporating appropriate span-of-control and including

- highly qualified, experienced managers in key positions

-- Well-defined and well-conceived corporate goals Waaknesses None ,

2.4 Licensee Commitments During the IAT inspection, the licensee made certain commitments to the inspection Team. These commitments relate to licensee corrective or enhancement actions planned in response to Team findings or con-cerns. These commitments, summarized below, are discussed in more 1 detail in subsequent sections of this report, shown in parentheses.

Commitments were confirmed during the exit interview. The status of these issues will be reviewed by the NRC prior to any restart cf the plant (88-21-01).

2.4.1 Procedure Validation and Tr'aining (Section 3.2.4)

By restart, the licensee will confirm effective implementa-tion of all off-normal and E0P satellite procedures that have been substantively revised during this outage.

2.4.2 Identifying Procedure Changes Requiring Training (Section 3.7.2.1) ,

Before restart, the licensee will implement a process to allow more timely identification of new procedures and procedure changes which require training.

2.4.3 Temporary Modifications (Section 3.2.5)

• By restart, the licensee will either prepare a justifica-tion for operation for each active temporary modification i or apply the temporary modification extension request process to all temporary modifications, including those with outstanding engineering service requests.

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10 2.4.4 Operations Review Committee (ORC) (Section 3.10.3)

Prior to restart, in order to strengthan its operational focus, the ORC will begin to: (1) review plant incident critiques; (2) review iicensee event reports before their issuance to NRC; (3) review failure and malfunction reports on a regular basis; and, (4) provide for a monthly presen-tation and discussion of plant operations as a specific agenda item.

2.4.5 Mainsenance

-- Before restart, the licensee will re-evaluate all priority 3 maintenance requests to ensure that they have been properly scheduled. (Section 3.3.2.4)

-- The licensee will complete training addressing the revised post-work testing program by September 9, 1988.

(Sectien 3.3.2.6)

-- The . licensee will resolve the inability to align valves in the Torus Water Makeup Line in accordance with current operating procedures and drawings prior to restart. (Section 3.3.2.4)

-- The licensee will issue a procedure to provide appro- '

priate controls for the "Q" oil storage facility by September 7,1988, and perform an evaluation of the possible addition of "non-0" oil to "Q" equipment and its potential effect. (Section 3.3.2.3)

-- The licensee will complete, before restart, the dis-position of a Potential Condition Adverse to Quality (PCAQ) identifying the need for a review of Commercial Quality Item procurement . documents for consistency with approved engineering specifications. (Section

. 3.3.2.3) .

2.4.6 Surveillance Before restart, the licensee will review and evaluate the once-per-refueling-outage surveillance tests to determine if they, should be repeated to enhance the assurance of system operability and document the basis for its decision. (Section 3.4.2.1)

-- Before restart, the licensee will provide the tech-nical casts for the current test frequency of the Reactor Core Isolation Cooling (RCIC) System Logic System Functional Test (LSFT) on the initiation logic.

(Section 3.4.2.2)

l 11 2.4.7 Formalizing Personnel Qualification Reviews -

The licensee will verify before restart the qualifications of all personnel within the organization required to meet ANSI 18.1-1971; and, prior to completion of the power ascension program, will have a formalized process in place to ensure future auditability. (Section3.1.4) 2.4.8 Hission, Organization and Policy (MOP) Manual The licensee will issue MOP policy instructions prior to restart and the organizational position descriptions prior to completion of power ascension. (Section 3.1.5) 2.4.9 Familiarizing Workers with Expected Radiological Conditions -

Before restart, the licensee will provide training and briefings to the appropriate plant staff regarding expected .

radiological conditions resulting from plant operation anc hydrogen addition. (Section 3.5.2.14) 2.4.10 Control Room Human Factors The licensee will evaluate control room human factors dur-ing the power ascension program and include an update pegarding the schedule and scope of "Paint, Label and Tape" items in ,their report to the NRC at the completion of the Power Ascension Program. (Section 3.9.2)

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12 3.0 DETAIt.S OF INSPECTION The fol1 ewing sections contain the scope of inspection, the detailed findings, and the conclusions for each functional area the Team assessed.

3.1 Management oversteht 3.1.1 Scope of Review The IATI assessed the organizational structure currently in place at the Pilgrim Nuclear Power Station (PNPS). The assessment also included the administrative processes in place to control and coordinate the activities and actions affecting safe and reliable operation of the PNPS. Other arets inspected included the adequacy of staffing, qualif t-cations of personnel, and mechanisat to enhance and promote stability in the organization's :hnical and managerial staff.

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Several management meetings were observed by Team members to assess the interactions of managers and the ef fective-ness of the policies and procedures being implemented.

Continual observations were made and shared by Team members to augment findings and conclusions in the effectiveness of the organization, management controls, and communications throughout the functional, arec i. The Team members inter-viewed a cross-section of personnel at all levels of the organization to determine if the overall attitude toward performance of safety-related activities has improved.

These observations and interviews also provided the Team with insight into the worker perception of management policies, involvement, effectiveness and its resulting impact on safety.

3.1.2 Organization i

The NRC staff noted in the most recent SALP report N'o .

50-293/87-99 for February 1, 1987 through May 15, 1988, that an organizational transition had taken place. The report also noted that several temporary changes, including

, numerous changes in personnel, had been made to strengthen planning, control and performance at pNpS. Many of these

• temporary changes were incorporated into a permanent reor-ganization in February 1988. The licensee continued to re-fine the new ergantiation and control process through 1

13 1

I July 1988, notified NRC of the reorganizi. . ion, and subse-quently requested an amendment in August 1988 to the admin-istrative section of its Technical Specifications (TS) to reflect the new organization. The notification and request were in accordance with the PNPS TS, Section 6.2.C, L "Changes to the Organization," which allows organizational changes to be implemented without prior NRC approval, pro-vided notification is made and a subsequent license amend-ment request is submitted for NRC review and approval.

The organization assessed during this inspection is the subject of the licensee's sendment request dated August 1, 1988, and approved by the Senior Vice President -

Nuclear (SVP-N) on August 4, 1938. The discussion that follows does not describe in complete detail the entire organization, focusing instead on that portion that affects the functional areas being evaluated during this inspection (See Figure 1). The results of this inspection will be considered in NRC's review of the licensee's amerdment request.

The Team noted that the licensee has incorporated a balance between the number of management levels from the first-line supervisors ter the SVP-N and the span of control for each functional unit. The SVP-N has the Station Director, Vice President - Nuclear Engineering (VP-NE), Emergency Pre-paredness Department manager and Quality Assurance Depart-

. ment manager repo: ting directly to him. The two department managers report directly to the SVP-N to assure that inde-pendence and appropriate management attention are provided based on their functional requirements and responsibilities.

The committee charged with offsite safety, the Nuclear Safety Review and Audit Committee (NSRAC), reports directly to the SVP-N. The committee for onsite safety review, the Operations Review Committee (ORC), reports directly to the Station Director. The reporting of the offsite committee to the SVP-N a1d the onsite committee to the Station Director are appropriate based on their responsibilities.

Details on these standing comittees, their functional requirements, responsibilities and accountaoilities, are contained in Section 3.10 of this esport.

The VP-NE has two department-level managers reporting directly to him. These departments are the Nuclear Engi-neering Capartment and the Management Services Department both of which are located offsite. The Station Director has four department-level managers reporting directly to him: the Plant Support Department, Plant Manager (Opera-tiens), Planning and Outage Department, and the Nuclear Training Department.

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Chairman Board of Directors

, -j and CEO j

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l Senior Vice Pre:Ident -

ktlear I

!' Nclear Safety Review and Audit Casselttee I

' Director - Speclgt Projects j .

e Energency Pleanlag Station Dirc: tor Quality Assurance Vice President - Departament flanager Departuent Manager h isar tagineering I

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Plant Department Plaan:ng &

nuclear Management Operations Review Outage Actear Engineering Cosmelttee (Plant Manager)

J Departmentalanager Services Departaient .

Department 2

m aager flanager i

1 touclear Training Plant Support l - a)epartment

, l Depertuent - ""W "

Plant Operatlocs I

- 5 Manager '

Settles haager I figure 1. 8051011 E015081 C0l1PAI4Y - PILCAlt! ORCANilATI0li 1

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15 8

The senior manager of the functional areas is at the department level, which is then subdivided into section levels and division levels. The first-line supervisors, in some cases senior supervisors, report to the division managers.

The station organization, now under a Station Director who has no direct corporate (i.e., off-site) responsibilities, represents a substantial change from previous organiza-tions. .The current structure was instituted to strengthen management attention to plant activities. The narrowing of the span of direct control and responsibility of the Plant Manager allows a more focused management Lnd control of

' operational activities, which should result in the enhance-ment of safo and reliable operation. The departments 4 reporting to the VP-NE have been restructured for a more even distribution of responsibilities.

The Team concluded that the current organizational struc-ture provides for an appropriate distribution (span) of

' responsibilities and accountabilities for the activities the functional units within it. The being depth (performed bynumber) of managers in the functional areas sho contribute to improved performance and organizational stability by providing managers with increased opportun-ities to participate in professional technical and manage-ment development programs and by increasing the framework

for career growth.

The Team also concluded that the redistribution of func-l tional responsibilities and increased depth in management i provides the framework necessary to enhance stability and support safe and reliable operation at PNPS. The evidence .

for these changes thus far has been management's effective-ness in creating a much-improved nuclear safety ethic and in improving the functional areas described in the subse-quent sections of this report.

3.1.3 Staffing The most recent SALP Report (No. 50-293/87-99) indicated that the allocated staffing levels were significantly higher than in the past. The Nuclear Organization is cur-i rently authorized a staffing level of 985. Approximately l 90% of the authorized positions are filled, of which 46%

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' are licensee personnel; the remaining 4% comprise contract personnel. Licensee personnel fill all key positions frem Section Managers and above, with less than 15*. of the remaining managers and first-line sucervisor positions filled by contractors or licensee personnel in acting capacities.

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16 Increased v.affing in all levels of the Radiological and Maintenance Sections are examples of how the licensee has provided thts necessary management attention and resources to areas that need them. The increased staffing, specif-feally at the craft and technician level, appears suffic-ient to allow for a planned and controlled preventive main-tenance program that should result in overall safety en-hancement. The increased staffing levels also allow for training on a routine schedule.

The Team concluded that the authorized staffing has been filled to a level acceptable for the licensee to perform all the necessary functions for all plant conditions,

. including operations. This finding is reinforced by the evidence of improvements in the functional areas described in the subsequent portions of this report. (

3.1.4 Qualifications The PNPS TS, Section 6.3, "Facility Staf f Qualifications," i requires that PNPS personnel meet the requirements of the American National Standards Institute (ANSI) N18.1-1971, "Selection and Training of Personnel for Nuclear Power Plants." The TS also requires that the Radiation Protec-  !

l .tf on Manager shall meet or exceed the qualifications of

Regulatory Guide 1.8, "Qualification and Training for i Personnel at Nuclear Power Plants," September 1975.

The Team audited resumes and position descriptions of key managers and other selected personnel throughout the organ-ization. Their educational and experience backgrounds were l

compared with the requirements delineated in ANSI N18.1-  !

1971, with special attention on the management experience of key personnel. No deficiencies were identified relating l  ;

to the qualification requirements of the ANSI standard.

More significantly, the Team noted the staffing of key management positions with personnel having extensive and

! successful management experience.

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During its review, the Team found tMt some resumes needed i updating, and that no formal, detailed instructions or

! guidance in establishing qualifications were available. The i Team reviewed a Quality Assurance Department (QAD) audit i

report of the organization's administrative controls which was conducted June 22 through July 22, 1988 and which

resulted in similar findings. The report, Audit Report i 83-25 "Administrative Controls," dated August 18, 1988, I

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j 17 indicated that personnel qualifications were audited by the QA0 to determine compliance with the ANSI N18.1 require-r.ents for the organizational positions held. No defici-d eles were identified as the result of the QA0 audit. The report did, however, provide a recommendation consistent with the NRC inspector s finding. Specifically, Recommen-dation No. 88-25-03, notes the need to update resumes, develop guidelines and procedures for documenting qualif t-catien status, and maintain retrievable files.

The licensee has committed to the Team to reverify the

. qualifications of all personnel within the organization to confirm they comply with ANSI N18.1-1971 prior to restart and to have a process zin place prior to completion of the Power Ascension Program to ensure future auditability of personnel qualifications.

Within the scope of the NRC review, the Team deter-mined that the licensee's personnel are generally well qualified for the positions hold within the organization.

The licensee's commitment to reverification of all per-sonnel qualifications prior to restart will provide addi-tional assurance of full compliance relating to personnel qualifications. .

The results of the IATI effort in assessing the adequacy of the staf fing and qualifications of the PNPS organization is consistent with the overall facility evaluation in the most recent SALP report (No. 50-293/87-99). It noted the addi-tion of management personnel who lack extensive commercial nuclear power plant operating experience. However, as l

l noted above, recent changes have resulted in the addition ,

? cf per:onnel in key management positions with extensive and ,

succassful management experience, much of which is in nuclear areas. Also, many mid-level management positions are held by individuals whc, have extensive Pilgrim NPS (or other boiling water reactor) experience. The Team con-cluded that the combination of commercial nuclear power

! plant operating experience in the organization with the increased management capability provides the qualifications

! necessary to support safe and reliable operation at PNpS.

In the event of a restart authorization, licensee safety i performance will be closely monitored by the NRC during the

Power Ascension Program.

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3.1.5 Administrative Policy and Procedures The licensee has a variety of procedures to provide policy, control and coordination of organization activities. Cor-porate policy is provided in the form of company Bullstins maintained in a Boston Edison Company Organizational Manual. The manual includes information about the *corpor-ate crganization, its policy stetements, corporate instruc-tions, and committees which affect the entire company, including the Nuclear Organization. The corporate level policy specifically affecting the Nuclear Organization is contained in a Mission, Organization and Policy (MOP) manual.

The Nuclear Organization Procedures (Sa0Ps) provide guidance for the control and coordination of the Nuclear Organiza- '

tion. They include administrative entire organization, as well as ;y/cedures rocedures affecting affecting func- the tional purtions of the organization. Each department also has . procedures in place specifically for its functional areas. The Team reviewed several NOPs to assure that the guidance provided was curre'nt, reflected the organization in place, and acdressed coordinating activities within the organization. The Team also reviewed department-level procedures to assure they included the current organiza-tion, goals, department function, position descriptions, qualifications required, responsibilities, and accounta-bilities.

The Team concluded that the procedures are, for the most part, current. They adequately identify corporate policy, org hization, coordination, functional requirements, responsibilities, Ecountabilities, and , qualifications necessary for the control and coordination of actions within the organization.

The Mission, Organization and Policy Manual (MOP) is not fully up to date; however, and is currently being revised j to accurately reflect current policy and to include all the

' position descriptions within the organization. The lican-i see has identified additional refinements in the organiza-

- tional position descriptions to assure consistency and to provide accurate definitions of responsibilities necessary to assure accountability. The licenset was previously aware of this and has been working to finalize the updates.

The licens6e comitted to issue the revised MOP which I

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includes updated policy prior to restart and to complete the organizational position description refinements before the end of the Pawn Ascension Program. This commitment is acceptable, based on the status of the other procedures previously discussed which assure adequate administrative controls.

3.1.6 Ccmmunications and Observations Corporate policy for the Nuclear Organization in the MOP manual includes, among its goals, the need to strive to raise standards of performance, for dedication to protec-ting the environment and public, and for rigorous adherence The Team, through its observations and

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to procedures.

interviews, noted a positive change in the attitude toward nuclear safety throughout PNPS. This change is evident in improved performance of safety-related activities. These improvements are indicated in the most recent SALP Report (No. 50-293/87-99), and progress in the other functional areas is addressed in this inspection report. The Team also noted during interviews that the corporate goal of adherence to procedures has been conveyed to all levels of the organization. These observations attest to manage-ment's effectiveness in communicating corporate ' pals and management's oversight in assuring that the goals are being pursued.

The Team noted that the licensee established seural mech-anisms to assure adequate communications within the organ-ization. Meetings at all levels of the organization are held on a routine basis. Plant meetings are held every morning to discuss plant status and to coordinate daily activities. Several of these meetings were observed by the Team to assess the interaction of the managers and the resulting effectiveness. 'The Team concluded that the meet-t ings were effective and that safety-related activities are l

being planned, scheduled, and prioritized in accordance with their safety significance and plant status. These and l other observations by the Team indicate that teamwork at the site is evident. There are programs in place, such as the Workforce Information Program (WIP), For Your Informa-tion (FYI), and Management Oversight and Assessment Team

('40&AT) to enhance management involvement, overall communi-

ations, and management visibility in the plant.

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,20 Tiw licensee has also established a set of performance indicators to track performance issues, restart issues, plant condition reports, and activity status. These per-formance indicators are used as a management tool to seasure the effectiveness and results of established programs.

The Team concluded, based on its evaluation of programs in place, that communications throughout the organization have improved, that teamwork is evident, and that corporate goals are being conveyed to all levels of the organization.

3.1.7 Conclusions The Team concluded that the licensee has an acceptable or-ganization and administrative process in place with ade-quate management and technical resourets to assure that PNpS can operate in a safe and reliable manner during normal and abnormal conditions. This conclusion is based on the details discusssd above, th'e performance-based inspection in the functional areas covered by the IATI, the overall consistency in the findings of this inspection with the most recent SALP (No. 50-293/87-99), and the plan for a structured and controlled power ascension program prier to operation.

This performance-b d inspection of a wide range of func-tional areas provic. an integrated look at everall. manage-ment effectiveness in ensuring high standards of nuclear safety. The overall conclusions of this inspection confirm facility management effectiveness, especially with respect to management's ability to perform self-assessment func-tions, to make performance improvements, and to raise nuclear safety awareness and attitudes within the organization.

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3.2 ' Operations 3.2.1 Scope of Review The Team evaluated operations by observing how supervisors, operators and staff performed in the control room and throughout the plant. The Team observed plant operations during backshifts from August 10 through August 13, 1988, and reviewed staffing levels to determine if they were sufficient to support restart with minimal reliance on overtime. The ability to implement recently written E0P satellite procedures and the quality of these procedures were evaluated through a field walkdown of a procedure.

The implementation of administrative controls for opera-tions was evaluated through inspections .of overtime con-trols, temporary modification controls, operator-required ,

reading, logkeeping, tagouts, and operator aids. The line-up of two safety systems was independently verified by the

• inspectors. Housekeeping was observed during frequent plant tours. i 3.2.2 Conduct of Operations The Team observed control room operations un all shifts.

They were conducted in a formal manner, with effective communications between the operators and ' supervisors, including repJat backs for certain functions. There was no unneesssary traffic in the control room. Supervisors briefed shift personnel on significant functions before <

they occurred. Prior to energizing the recirculating pump i 4

heaters, which could have produced smoke in the drywell, the watch engineer thoroughly briefed to the reactor oper-ator, equipment operator, and fire brigade leader.

The watch engineers, shift supervisors, and reactor opera-toes were knowledgeable about plant conditions and ongoing

> work in the plant. Shift turnover briefings were thorough '

and were followed by control room panel walkdowns. Attend-ance at these briefings wa3 inconsistent in that not all ,

watch engineers include other shift personnel, such as health physics shift workers in the pre-shift briefing.

The Team observed that the health physics shift workers i receive separate br16fings. The Team discussed this prac-tice with plant management, which stated that it was their intent to include non-operations shif t workers in the pre-shif t briefing and that they would review its implementa-l tion.

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. 22 Control room operators received good support from the shift technical advisors (STA), administrative assistants, and other departtents. The STA's were used in developing fail-ure and malfunction reportr, (FER), and in the initial followup of an E0P satellit.e procedure issue. The admin-istrative assistants do much of the administrative paper-work and help to lessen traffic in the control room. There was very good support of operations from other departments in understanding and deciding the proper course of action in response to FM R avents.

The Team accompanied several non-licensed equipment oper-

. ators (E0's) on their tours. The E0's performed their pisnt tours in accordance with Procedure 2.1.16, "Nuclear Power Operator Tour." Readings were taken and recorded, as required. The operators also checked for abnormal condi-tions, such as vibrations, noise, leakage, odors, and inadequate ventilation. The E0's commented that they now have more time to check general plant conditions on their rounds .because the rounds are assigned to two E0's per shift. .Previously, only one E0 made the plant tour. The E0's showed good regard for radiological protection and ALARA practices. The operators were very familiar with the plant, systems, and components, and were knowledgeable about their duties and responsibilities. The performance by these operators demonstrated the effectiveness of the non-Itcensed training program. .

Watch engineers or operating supervisors accompany E0's on plant tours at least once per week. Operations management, including the chief operating engineer and operations manager, were observed touring the control room frequently and discussing plant status and evolutions with the watch engineer.

The Team discussed' the licensee's use of NRC's NUREG-1275, "Operating Experience Feedback Report-New Pb "i v e r-ified that licensee management had rath e 'NS a1275 recommendations for applicability. BEco ha,: sw dently initiated a number of improvements related to O G-1275 recommendations before they reviewed the report. This action was considered by the Team as a positive example of the quality of BEco self-improvement efforts. Some self-identified improvement items include operator communica-tions training, seminars to improve attention to detail, splitting tours and revising tour sheets to improve equip-ment operator performance, and doing dry run training on

23 i

the power ascension and alternate safe shutdown evolutions.

Some improvement items resulting from the NUREG review include seeking a more positive method of performing on-shift instructions, repeating all logic system functional tests, and performing a comprehensive review of inadvertent emergency safety feature (ESF) actuations. The ESF actua-tion review has resulted in several corrective actions.

In summary, the licensee conducted operations in a profess-ional mar.n e r. Operators are knowledgeable about their duties and plant conditions and management keeps an active and effective oversight of operations.

3.2.3 Shift Staffing and overtime Controls The licensee's Senior Reactor Operators (SRO) are very experienced and strengthen the operations organization.

To take advantage of this experience, an extra SRO will be 4

assigned to each shift during the Power Ascension Test Program. Only 8 Reactor Operators (RO) have unrestricted licenses because the 14 newly license 1 RO's are limited pending on watch training and reactivity manipulations dur-ing' the - Power Ascension Program. Therefore, the licensee will initially staff a' four-shif t rotation during plant.

restart. At an appropriate point after restart, the lican-see will go to a six-shif t rotation of two SRO's and two RO's per shif t. There are also sufficient non-licensed equipment operators to staff six shifts. STA's will work a five-shift rotation for at least the next year. These staffing levels are considered adequate.

I It should not be necessary to work operators in excess of the overtime guidelines of NRC Generic Letter 82-12. Senior plant managament has been active in restricting overtime.

! P Melure 1.3.6.7 "Use and Control of Overtime at PNPS,"

w :s ' NRC guidelines, provides procedural controls for 1

. e n hours, and requires advance approval of overtime.

.'s .aspector reviewed Operations Department overtime rec.ords for the period of July 6,1988 to August 16, 1988.

During this period, there were only three occasions when staff worked greater than 56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> in a 7-day period. Dur- '

ing this period, there was one instance of overtime in excess of NRC guidelines. This occurred August 1 and 2 whwn a radwaste worker worked 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> in a 48-hour period, This worker had approval to work up to 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> that week i

but did not have approval to exceed the 48-hour guideline. -

This worker is not a licensed operator and was not doing  ;

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safety-related work. The licensee identified this incicant and counseled the individual on overtime redirements.

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24 3.2.4 Procedure Validation ,

The Team walked down Procedure 5.3.25, "Reactor Pressure Vessel Injection During Emergencies," with a non-licensed equipment operator whc had been trained in the procedure.

The protedure involved connecting a fire water crosstie to the residual heat removal (RHR) system. Minor procedura errors were found. A drain valve labeled 1-0R-122 in the s field is referred to as 1-OR-121 and the fire water storage tank low level alarm is referred to as annunciator B-7, whereas it is actually 0-3. Also, the procedure instri..:ts the operator to "connect the local flow meter" without specifying the instrument number. The procedure was actually referring to a strainer differential pressure indicator, instrument number 33-FIO-4610, The operator did not simulate connecting this instrument and when questioned by the Team, he stated that the step referred to flow meter FI 4609 which was already connected. Of more significance

<eu confusion caused by step IV.B.2.b, which instructs the sperator to install jumpers to defeat LPCI initiation and PCIS isolation signals and operate LPCI injection v.alves 28 and 29. The equipment operator requested the assistance of the watch engineer and the STA. These watchstar.ders initially felt the jumper was not needed. The jumper is not directly related to LPCI valves 28 and 29, but is needed to provide a flow path for a fire pump and to pre-pare for contingencies in the E0Ps.

Procedure 5.3.26 was one of eight new procedures written by contractors and validated by contractors. All eight of these prt,cedures are therefore suspect and will be revali-dated by licensee operations staff before restart. A *.1 other ECP satellite procedures and other abnormal cperating procedures substantially changed during this outage will also be revalidated before restart.

The licensee did r.ot perform any QA audits or surveillances on the writing of procedures by contractors. However, the licensee has performed surveillances of the procedure

, validation process used on procedures other than the E0P satellite procedures. Surve111ances #87-9.3-9 and #88-1, 1-56 found that half sf the procedures be'*: revised and b implemented in April and May 1988 were not bs. g validated, fYN As a result of this finding, procedure *. 3.4-4, ' Procedure Valida' ion," was issuee. August 15, 1988.

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25 There were also some training aspects to this procedure Issue. The equipment operator was trained on Rev. O of ,

5.3.26 which did not include the instruction to connect the local flow meter, whereas the inspector used Rev.1. Licen-sed operators were trained on the control room portion of the E0P satellite procedures and equipment operators were trained in the procedural steps outside the control room.

The problem with the jumpers occurred at the interface betwesn these operators. Following the procedures revali-dation discussed above, the licensee will provide addi-tional training as needed. t l During a N5RAC meeting conducted on August 2,1988, the l committee discussed an open concern on the validation and upgrade of plant procedures. NSRAC concluded that they were concerned that all of the routine operating procedures had not been validated by one of the validation processes.

Following the meeting, the committee forwarded a concern to the SVP-N concerning the operating procedures necessary for long-term operation of the plant. The plant staff is scheduled to respond to NSRAC .on September 14, 1988. The NRC will review this respons9 during a sub?equent inspec-  :

tion. '

3.2.5 Temporary Modification Controls The Team observed that cu' rent logs show that about 15 tem-parary modifications (TMs) are in effect, some of which date back tn 1983. Fifteen is not an unusual or unmanage-able number of TM's, and represents a significant reduction l 3

from previous conditions, t

The Team reviewed nine TM's initiated 1987 and prior years

. and noted (1) only three of the nine modifications affected ,

safety-related systems; '(2) licensee safety evaluations i

(SE) were filed in the TM package, which demonstrated the '

, interim configurations created were acceptable; and, (3) Itcensee actions to address the TM's by conversion to .

l permanent modifications were apparently based on engineer- l

'. ing service requests and plant oesign changes referenced in the TM packages. Teac review of the SE's on a sampling

basis did not identify any inadequacies. Further, the Team noted that reduction of the TM backlog has been a licensee ,

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26 Plant Procedure 1.5.9, "Temporary Modifications," allows temporary modifications to be open for six months and pro-

vides a mechanism for active TM's to be extended. However, this mechanism is typically not used. Procedure 1.5.9 does

not require a review of the TM for extension of the expira-tion date if an engineering service request (ESR) for a '

permanent design change is in effect for the TM. Of seven TM's reviewed, six had ESR's and therefore did not have a  :

current approved extension date. The irispector indicated 4

l that good engineering practice would dictate continuance of l the periodic reviews for all TM's, and licensee management agreed. The licensee committed to either prepare a justi-fication for operation for every TM that is still open ,

prior to startup or.to revise the procedure to apply the TM extension .equest proce3s to all TM's, including those with

' outstanding ESR's.

TM 34-77 was selected for detailed followup review to assess the technical adequacy of the change on & temporary i basis and to evaluate the extent and timeliness of licensee i

followup actions to either remove the temporary modifica- -

tiott or convert it to a permanent change to the f acility. '

I The modification involved the replacement of an FCR-type  ;

i relay in cubical 72-754 of the DC motor control center for

• the RCIC 1301-22 valve. The valve is in the suction path from the condensate storaga tank (CST), is normally open -l for RCIC standby and initial operation, and will cycle ,

1 closed on low level in the CST. After failure of the existing FCR relay (an open circuit coil), an HFA-type .

relay was installed on December 17, 1984 and made elec-trically equivalent to the original circuit. An HFA was i

used because an FCR rklay was not available onsite. The ,

I change did not affect the normal function of the valve. , {

Engineerin; Service Request (ESR)85-368, dated July 22, 1985, requested engineering to convert the change t l to a permanent modification, with a completion date of November 22, 1985. ESR response memorandum NED 86-1275, dated December 31, 1986, rejected the ESR request to make

• j the change ',ermanent because of two concerns involving the need to keep the wiring in the 72-754 cubical consistent  ;

l j with other DC motor control centers (MCC) and the assumed differences in the inrush and coil holding currents between i

the two types of relays. In rejecting the request, engi-

! neering found that the change was accaptable on a temporary basis, but recommended restoration of the original design. ,

?

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

27

- A Potential Condition Adverse to Quality (PCAQ) Report (No.

NED 66-110) was issued to assess the deviations. Further engineering evaluation was requested by ESR 88-080, dated January 27, 1988, with action requested by May 1, 1988.

Further engineering review determined that the change would b: . acceptable as a permanent modification, which was made by' FRN 87-80-52 to PDC 87-80 dated June 14, 1988.

The plant design change (PDC) modified the drawing to per-manently document the change and addressed the seismic ade-avacy of the HFA relay installation. The HFA relay was not certified to be environmentally qualified since the 1301-22 valve is not on the EQ matter list and environmental qual-ification (EQ) is not required. The PDC also addressed the

! - adequacy of the inrush and holding current characteristics of the HFA relay. The second engineering review found the HFA current characteristics to be better than those of the

! FCR relay. -

The Team discussed the bases for the original and final

- engineering determinations via telephone on August 17, 1988 with engineering (NED) . The Team noted that engineering initially rejected tne proposed design change based on information indicating larger power consumption by the HFA relays, and based on a concern that, if replacement of the FCRs with HFAs became a general practice, a problem could result in the increase in DC loads. Those concerns were I

not realized since the FCR failure was a random one, and the operating current characteristics of the HFAs are

better than initially assumed.

i Based on the aboy?, the Team identified no technical con-

! cerns with the 11ce. 'see's dispositioning of the adequacy of the modification.

ll l The Team noted that licensee action on the original 1985 ESR was not timely in either the preparation of the original ESR or the followup actions by NED in response to the site request. However, the actions to respond to ESR 88-80 and disposition tne issue in 1988 were greatly imp roved.

l The Team audited the six tag outs for TM 84-22 and found that MCC B25 was missing two TM tags. Since this is a non safety-related modification which is about to be withdrawn, this was not considered by the Team to be of safety signif-j icance. It does indicate; however, the need to period-ically recheck TM tagouts.

i l

l

28 An additional concern is that in the following example tfie licensee performed a TM without implementing the formal review and approval process. During a tour of the reactor building on August 8,1988, the Team noted that reactor pressure boundary leak detiction system monitors C-19A and C-108 had their doors propped open, and each monitor had a large fan tied to the opening. Investigation id6ntified that no temporary modification had been processed to evaluate and authorize this alteration. The Itcensee stated that elevated temperatures in the cabinets result in failure of the monitor electronics and have been a long-standing problem. Engineering response to Engineering .

Service Request (ESR)85-462 implemented a reduction in system heat-tracing temperature. This alteration did not resolve the problem, and on August 6,1988, the ' licensee initiated ESR 88-558 requesting further engineering review, Monitors C-19A and C-19B are required to be ops.able by Technical Specifications during power operations so that some short-term action and long-term resolution are needed.

Since the monitors are not currently required to be oper-able, the licensee has de-energized them and removed the fans pending evaluation.

In summary, even thouch the licensee has been aggressive in reducing the number of TM's, there have been some lapses in their control of temporary modificationc. This indicates a need for continued licensee managemeni, attention to this area.

3.2.6 Required Reading Books The Team reviewed the "Required Reading" books in the con-trol room. The books consist of three large binders that contain procedure changes. They provide a method for promptly updating operators on plant and procedure changes.

Each piece of information in the book had a sign-off sheet to ensure that all operations personnel read the material.

The Team noted that information in the books dated back to April 1988 and many of the procedure changes had not been signed off am read by all personnel. This appears to indi-case that the program is not being monitored routinely by operations management. Material remaining in the book for l long periods defeats the purpose of providing timely infor-mation on changes to the operators. Conversely, if the changes are not important to operations personnel, it may not be necessary to put them in the books. ,

i The Team discussed these observations with the plant Opera-tions Section Manager. Some improvement was noted later  !

during the IAT inspection, as a result.

l

]

29 3.2.7 Logs The Team reviewed the implementation of the Technical Spec-ification Limiting Condition for Operations (LCO) log, the Disabled Annunciator Alarm Log, and the operations super-visor log procedures. The LCO log was implemented August 18, 1988, by Procedure SI-OP.0008, "Limiting Conditions for Operations Log," dated July 25,1988, and was being used on a trial bests from August 8 to August 18, 1988. The only LCO entered after the log was implemented, LC0 A-88-002, was properly entered, tracked, and cleared. Procedure SI-0P.008 is being revised to incorporate lessons learned in its initial implementation.

l The Disabled Annunciators Alarm Log is controlled by Pro-cedure 2.3.1, General Action Alarm Procedures, Item VII.

1 The inspector observed eight disabled annunciator tags on control room annunciators. All eight were property logged.

However, only two of the eight annunciators had a mainten-ance request (MR) issued. The shift supervisor informed the Team that disabled annunciators without MRs occurred due to p1rnt conditions and will be returned to service before startup. The licensee audits disabled annunciators monthly under preventive maintenance (pM) Procedure 8.A.24, "Audit of Control Poem Annunciators and Instruments," which should assure that these annunciators are returned to ser-vice bt fore startup.

There was little activity in the control room during this ,

4 inspection, but the Team did observe the following itemt '

l properly logged in the operations superviser's log: LCO's, Failure and Malfunction Reports, a fire drill, and spent I fuel pool temperatures while the fuel pool pumps were '

out of service for maintenance. However, as discussed in

Section 3.2.8 below, changes in jumpers or lif ted leads were not logged in the operations supervisor's log.

t i The Team concluded that log keeping practices are generally adequate, Timely '.!odate of Lif ted Lead / Jumper Log i 3.2.8 I

. During a review of the Lifted Lead / Jumper (LL/J) procedure  ;

and proe m implementation on August 16, 1988, the Team identif;  : Sat the log was r.ot being maintained completely

' up-to-da -. Eight entries in the LL/J log involved lifted r leads or jumoers installed on July 14, 1988, to perform  ;

main station battery work and testing per Maintenance Work l

! Plan (WP) 87-46-173. All eight recuests were associated

' with the same WP. All log entries showed the LL/J request

30 1

l was stt11 active on August lb.1988. The Team found that the batteries had been returned to normal and LUJ request was closed out on July 29,1988, and that Maintenance ,

Request 87-46-173 was completed on August 1,1988, inclu- '

i sive of the post-work testing. Step 5.3.1.5 of Station Procedure 1.5.9.1, "Lifted Leads and Jumpers," states that i the person performing the LUJ request is to notify the Watch Engineer when the system is returned to normal by removing the jumpers or landing the lifted leads. The l Watch Engineer is responsible for updating the LUJ log. 1 The findtngs were referred to operations personnel on  !

] August 16, 1968 for followup.

4 Licensee followup review confirmed that the work had been i completed and the log should have been updsted. The lop  ;

was updated to show the correct status on August 16, 1986.

In response to the inspector's finuings, the licensee con- '

ducted an audit of the log. The Itcensee's audit identi- .

fled (1) two instances where the log had not been updated, i and (2) that operations personnel were not making entries i in the Operation's Supervisor log when LUJ log entrits [

were n.ade. These matters were referred to the Operations t Section for followup and corrective action. QA follo'wup and trending will be covered by QA Surveillance Report 88-94-61. ,

j f The licensee reported that the cause of the discrepancy was l

the failure cf maintenance personnel to inform aperations 4 that tne jumpers and lifted leads were cleared when the systems were re.;rned to normal. Inspector interviews with j the Maintenance Supervisor responsible for MR 87-46-173 ,

noted that he failed to discuss the closecut action on the  !

{

LUJ request as a result of a misunderstand 1ng on the status of the work package :losecut during, shift turnover .

with another maintenance supervisor. -

i Team review concluded the inaccurate LUJ lo; had minimal significance and no impact on safe plant operations for these cases. There was no loss of control of the physics) 1 , plant configuration. Plant operators would have reviewed t the LUJ log as a prerequisite to plant restoration and startup. This review would have identified the open log [

} entries and the completed closecut actions. Further, t

! licensee followup to the discrepancies identified by the .

1 Team were prompt and appropriate. Based on the above, and l l in recognition that the jumper and lifted lead log is a new j tracking system, no further NRC action is warranted at this  !

i time. This area will receive further review during l subseouent routine NRC inspections, j l

! l i

! [

d i - - - - - .

31 k 3.2.9 Tagouts and Operator Aids The Team reviewed the licensee's administrative controls for use of protective tagging at PNPS. The Team reviewed Procedure No.1.4.5, "PNPS Tagging Procedure," Revision 23, which is to be implemented September 1,1988, and noted that this procedure was revised to address concerns with tag controls identified during the licensu's self-assess-ment. Specifically, the procedure limits the use of Nu-clear Watch Enginser (NWE) cags; prohibits the use of dan-ger (red) tags for identification purposes on lifted leads;

. and requires documented monthly reviews, including field verification, of NWE, Caution and Master Danger tag: and tagout sheets. .The Team reviewed the NWE and caution tag logs and independently verified that several NWE, caution, danger, and master danger tags were properly filled out, properly hung, and positioned as required on the compon-ents. No ciscrepancies were identified. Based on this review, the Team concluded that the licensee's control of protective tagging was adequate and properly in pluented.

The Team also reviewed the licensee's control of operator aids as established by procedure No. 1.3.34, "Conduct of Operations." An operator aid is information in the form of sketchps, notes, graphs, instructions, or drawings used by personnel authorized to operate plant equipment. The Team reviewed the operations and chemistry operator aid log and determined that i+. was maintained in accordance with the procedure. The Team noted that periodic licensee reviews and verification of the need for and placement of operator aids were documented. The Team independently verified proper posting of selected operator aids, and no unauthor-ited aids were identified during the Team's plant tours.

Based on this review, the Team concluded that the lican-see's control of operator' aids was adequate.

3.2.10 Plant Tours and System Walkdowns 3.2.10.1 Miscel.laneous Tour Observations The IATI Team made frequent plant tours. The overall material condition of rooms and equip-i sent was excellent. Particularly notable was i

cleanliness, fresh paint, and obvious decontam-

ination ef forts to make major portions of plant and equipment accessible. Component labeling and tagging was very good.

1 1

32 The Tea.m observed activities in progress. Per-sons interviewed on tour (HP, security, opera-tions contractor) had experierce in their positions and were knowledgeable about their work '

and duties. HPs were cognizant of work activ-ittes in progress. Housekeeping controls were

. being maintained during work in progress.

The Team reviewed the status of indicators and controls on selected local panels. Controls and indications were operable and no deficiencies were noted. Operating procedures required to be posted at the local panels were available and adequate, based on Team review. .

The Team coserved loose cable tray covers inr.lud-ing one that was laying on top of an in-place cover. The licensee reviewed this finding and documented the review and corrective ~ actions in an engineering "white paper." This review deter-mintd that loose covers do not compromise the design but that covers laying on top of in place cable tray covers could be a seismic concern.

The mi'splaced cover found by the Team was deter-mined to not be needed. The licensee surveyed i

cable trays throughout the process buildings and ,

found additional loose covers but no more that '

were completely unfastened and laying or dop of otner covers. Corrective actions completed in-4 clude refastening the loose covers, removing the misplaced cover, revising procedure SI-SG.1010, t "Systems Group System Walkdown Inspection Guide-line," to use periodic walkdowns by the :ystem engineering division to identify seismic con- -

carns, such as misplaced tray covers, and prepar-

. ing F&MR No. B8-200, which will be used to deter-j mine how to keep future maintenance and modifica- l'

! tion work from creating loose or misplaced covers. The Team concluded that the licensee's response to this issue was thorough and adequate.

The Team considers this issue resolved.

3.2.10.2 Diesel Generator Walkdown A walkdown of the ' A' diesel generator (OG) was completed on August 15, 1988, to verify opera-bility and stancby readiness of the emergency power stoply, and to oeserve the general condi-tions in the OG area. The valve checkoff lists of Procedure 2.2.8, "Standby AC power System (Diesel Generators) " were used as acceptable .

criteria to estabitsh the proper system valve (

33 .

positions. The procedure checklists were also reviewed for adequacy against Orawings M219 and M224, and by comparison with the physical plant  :

during a walkdown of the diesel skid and room. l

, Proper valve lineup was verified 'or the DG fuel oil and air start systems. This review confirmed that the 'A' DG was operable in the standby mode.  ;

Cleanliness and the general condition of equip-1 sent and components in the diesel rooms were  !

excellent. Valve and component identification i j (tags) and labeling were very good and showed  !

significant improvement in performance in com- t i

parison to past reviews. Several minor discrep-ancies were noted, as follows: (1)identifica- .

tion tags were missing on valves 104C and 118, i i and the tag was loose on valyc 105C; (2) valve .

118 was required to be locked in ,the closed l position and a chain and pidlock were provided i for this purpose; however, the chain was suffic-tently loose that the Tean would have been able l

. to defeat the lock and thereby move the valve;  ;

3) the inner fire door granting access to the l

{A' DG skid had worn and damaged gaskets along  ;

the closing surface and the door latching mech- .

anisms (dogr) were misaligned with the pcsition  !

indicators; (4) no permanent Itphting was instal- l led in the 'A' and 'B' diesel day tank roon.s -- i lighting, if installed, would aid operator re- l views during plant tours; and, (5) two isolation  !

valves for pressure switches 4555A and 4556A were '

not labeled with an 10 tag in the plant and were f not identified on system drawings or procedures.

l (he valves were properly positioned. Addition-  :

I

. ally, proper valve position i s, demonstrated indirectly during the monthly functional test of j the diesel air start system., .

These discrepancies were noted by the Nuclear l Plant Operator accompanying the Team and were '

discussed with the duty Watch Engineer. Actions i were taken to document and correct the discrep- f anctes, including the issuance of' Maintenance i Requ6st 88-61-83 for the fire door. Inspector  !

followup review on August 16, 1988 confirmed that  !

actions were in progress and had been completed  :

to correct the tag on valve 105C and to properly f lock valve 118. 1.tcensoe response to the Team's findings was appropriate and timely. No other inadequacies were noted.

I

34 3.2.10.3 Standby Liquid Control System Walkdown The Team walked down tha standby lit cd control (SBLC) system using the valve checklist in Pro-cedure No. 2.2.24, "Valve Lineup for Standby Liquid Control System," and piping and instrument 4 diagram (P&IO) M-249. This review was performed to verify the adequacy of the procedure checklist  :

and P&IO, evaluate the valve labeling, evaluate the control of locked valves, verify the opera-bility of instrument and support systems, and assess the overall satorial condition of the sys-tem and general cleanliness of the area. The Team noted that the checklist control of vent and drain capped connections differed from other safety system procedures, such as those for the residual heat removal (RHR) and core spray (CS) systems. For example, an outboard ver}t valve on the CS checklist would ce "locked, closed and capped." The SSLC procedure only checks "locked, closed." No deficiencies with capped connections i were noted, however. The Team also noted that the vent valve for pressure indicator (P!) 1159 was not on the valve checklist. The Itcensee agreed to review these observations to determine

~

if the procedure needed to be revised. No other deficiencies or concerns were noted.

Overall, the Team found the valve labeling, mate-rial condition, and general cleanliness to be excellent.

3.2.11 Conclusions The operations staff conducted their activities in a pro-fossional manner. Operators were knowledgeable about their duties and about plant status. The depth of experience and knowledge of senior licensed operators 15 a strength and 1

stil be a major asset during restart. Shift turnover briefings by individual operators and for the shift 2"1 thorough; however, non-operations shift workers do not routinely attend these briefings. Site management involve-ment in operations was evident by their frequent prosence in the control room. Shift staffing levels are adequate and plant housekeeping was excellent

_m-

35 A weakness was noted in the validation and/or training of E0P sate 111te procedures. The licensee's comitment to confirm effective implementation of E0p satellite and off-4 normal procedures before restart is responsive to NRC con-cerns. Administrative controls and log-keeping practices are generally adequate, although required reading materials are not being reviewed by all personnel on a timely basis.

There are lapses in the licensee's control of temporary scdifications, particularly the absence of periodic reviews and scheduled completion dates for temporary modifications covered by an engineering services request.

l 1 .

i f

e r

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+ - - --- .2.___

36 3.3 Maintenance 3.3.1 Scope cf Review The licensee's maintenance program has undergone signifi-cant change during the past several months. Weaknesses had been identified during the SALP period ending May 15, 1988, and by Special NRC Maintenance Team Inspection 50-293/  !

88-17. During the present inspection, the ifcensee's main- i tenance policies and program procedures were reviewed.

Maintenance activities were evaluated during the planning, implementation, post work testing and closecut stages.

Emphasis was placed on direct observation of ongoing work in the field. Interviews were conducted with personnel at each level within the maintenance department to determine .

their depth of understanding of program goals. The Team also assessed the size and significance of the Ifeensee's maintenance backlog, and reviewed established licensee

performance indict. tors.

3.3.2 Observations and Findings r 3.3.2.1 Management Policies and Goals j

! The Team reviewed the lic'ensee's Mission Organ-4 ization and Policy Manual, Nuclear Operations Procedures Manual, and Maintenance Section  !

Manual. These documents describe the licensee's policy and performance goals for the maintenance

. program. The licensee has also established the ,

Material Condition Improvement Action Plan i i

(MCIAP). The MCIAP, which is described in the licensee's Restart Plan, is designed to achieve j long-term improvement in the maintenance program, t i

In addition, maintenance performance indicators  !

are being used by the Itcensee to evaluate the j success of recent program changes and the allo- t

'- cated maintenance staff hat been increased sig-  !

nificantly. Interviews with maintenance person-  ;

nel at various levels within the department indi- <

cate that the organization and management poltetes are generally well understood, j I

t i

t L

i i

37 3.3.2.2 organization and Staffing ,

The maintenance organization and staffing levels were reviewed. Interviews were conducted with ,

division supervisors and staff personnel to  :

determine whether organizational relationships i were well understood. The current staffing .

status was evaluated, particularly in the super-i visor, maintenance engineer, and planning post- L tions, to determine whether staffing levels were j

adequate, responsibilities clearly defined, and resources effectively used.

The maintenance section consists of three pro- i duction divisions (electrical, instrumentation and ccatrol and mechanical), plus a planning division and an engineering group. All division

, manager positions and all first-line supervisor

positions in the production divisions are filled i with Itcensee employees, except for two positions i in the equipment tool room, which are presently .

l filled by contractors. Increased staffiag at the

, craft level in the production divisions has been I

authorized. Instrumentation and Control (I&C)

, will increase'from 22 to 30 positions; Electrical Maintenance will increase from 14 to 18 rost-I tions; and Mechanical Maintenance will i n e'.*e a s e .'

from 27 to 33 positions. Staffing of the plan-ning division has not been completed. Twelve i contractor personnel are presently being used to l perform the planning function, with ass', stance l from the Itcensee's mutage management group. ,

This arrangement is performing . acceptably, as  ;

described n iaction 3.3.2.4 r

! Team interviews with supervi sors and craft r employees showed that personnel clearly under-

l. stand the new program and their area of respon-sibility. The interviews covered personnel with a wide range of experience in their positions, I including those newly assigned. The Team noted; l j however, that the recently revised job descrip- i

. tions for the section have not been disseminated '

to the staff. The Maintenance Manager stated ,

that they would be issued in the near future, j l

38 Two positions in the new maintenance section organization, the Deputy Manager and the Radio-logical Advisor, are effectively being used. The Radiological Advisor is a permanent staff post-tion and provides a focus for interface with the Radiological Protection Group. Team observations indicated that the Deputy Manager was effective in scheduling and coordinating activities through his interface with other sections.

The Team's review indicated that licusee staff-i ing is ample to meet targeted production goals without reliance on the use of excessive over-time. While some variations occur, thc percent of overtime worked has been at or slightly above the operating goal of 20*i, which equals a 48-hour work week. Work $ hedules for craft and super-visory personnel provide 1 day off in a 7-day period. The maintenance staff is working pri-marily on the day shif t, with night shift cover-age provided for certain critical jobs 1.n pro-gress. The licensee plans to provide areund-the-clock 8-hour shifts that will match the Operations Section rotating shift schedule, beginning with plant startup. Maintenance shift coverage will continue through the power escala-tien sequence and on a reduced scale afterwards.

Licensee staffing is sufficient to staff the shift schedule without reliance on excessive overtime.

New personnel assigned to the division manager and production supervisor positions have adequate prior experience in related assignments. The Team's observations of the first- and second-line supervisors in conducting their daily ac'ivities shewed that the supervisory, oversight, .nd con-teol functions were effectively performed. 8tased on these observations, the Team concluded that the newly hired supervisory staff does not have a negative impact on the quality of control over maintenance activities.

l

39 In summary, identif t td strengths in the present maintenance section t *ganization include the use of the Deputy Manaier and the Radiological Advisor. The increa a in supervisory positions in the production div sions has been effective in increasing oversight and control of work activ-ities. While temporary staffing of the planning division with contractors is sufficient and pro-vides for an effective planning function (as measured by the quantity aid quality of mainten-ance packages produced), plans to staff these positions with permanent licensee employees by l October 1988 should remain a management priority to assure timely integration of the planning and scheduling functions. Management has controlled overtime f ar the craf t and supervisory positions.

! Plans to provide for maintenance staffing during and after restart on an 8-hour rota. ting shif t basis should provide continued effective over- f time control.

. 3.3.2.3 Communications and Interfaces Communication between the maintenance department and other portions of the organization, particu-i larly operations and radiation protection, had i previously been a weakness. The licensee has taken successful steps tow &rds improving communi-I cation, both internal to the maintenance depart-ment and with other station groups.

l ,

j The Team attended a variety of maintenance l department status and turnovtr meetings. Based

• on observation of these meetings and interviews L l with maintenance personnel at each level of the '

organization, the Team concluded that communica- i tions internal to the maintenance staff are ef- l l fective. Maintenance department managers were cognizant of the status of activities and of emerging problems. l The licenses has initiated several programs directly addressing the past weaknesses in interdepartment communications. In an ef fort to

! improve the interf ace with radiation protection and to raise worker sensitivity to health physics issues, the licensee created and staffed the

maintenance Radiological Advisor position. Inter- ,

i views with a spectrum of individuals indicated  :

that this effort has had a positive impact on l

4 i

! 40 i

! day-to-day working relationships and performance. ,

i The licensee also formed the Work Prioritization 4 Review Team (WPRT), composed of representatives '

of various station departments. The WPRT pro-

]

vides a forum for discussion of the relative j importance of each maintenance ites as it arises. i 1 The WPRT has been effective in improving opera-tion's department involvement with the mainten- i

' ance process. The maintenance department is also  !

involved in daily and weekly meetings intended to l ensure coordination between station groups. Meet- .  !

ings attenced by the Te m were generally .

effective. [

I .

The need for cortinued efforts to improve commun- I ications and ir.serfaces were noted in some areas.

l The licensee's Stores Ospartment practices are  ;

l r.ot always fully supportive of specific mainten- ,

ance department needs. For example, lubricating oil can only be withdrawn in bulk quantities, '

such as a 55 gallon drum. Typical maintenance activities require use of only a fraction of this  :

amount. Steilar restrictions apply to materials routinely used by the II.C. electrical, and mech-l anical maintenance ciivisions. This policy places I the burden for control and storage of unused .

material on the individual requesting the with- l i drawal. The Team noted that maintenance person- ,,

I nel were routinely using a cabinet in the main-tenance shop to store unused "0" materials. No  !

procedure existed to specify the appropriate con- ,

i trols for the storage area. The need for estab- l 11shment of the storage cabinet had been dis-cussed previously between the Quality Assurance  :

Department (QAD) and maintenance. QAD. believed l J

that the cabinet was not currently in use, while  !

j maintenance personnel believed that QA0 had con-  !

f curred in its creation, demonstrating a lapse in i instrdepartment communications. The Itcensee .

. subsequently performed an inventory of the mate- l l

rials in the cabinet, and removed all non-Q and ,

suspect materials. Procedure 3.M.1-32, "Control  !'

of 'Q' Wold Area," was subsequently issued to provide appropriate controls and surveillance of  :

i the cabinet. [

l i

l t

4 '

41 The Team also noted that partially used drums of both Q and non-Q lubricating oil and grease were being kept in a storage shed outside the process building. Several of the drums were not properly sealed. No procedure addressing this storage  ;

area existed. Discussions with operations per-sonnel indicated that the difference between Q and non-Q drums of material was not clearly understood. Routine withdrawals and their equip- ,

ment application were not recorded. In response, the licensee ramoved all non-Q materiais and

! committed to issue a precedure t'o establish appropriate controls by September 7,1988, i r,-

, cluding provisions to ensure that the lubricants are traceable to their application in the field, i In addition, the licensee cor.mitted to evalu;te the possible addition of non-Q oil to Q equipment and its potential significance.

During f'ellowup to this issue, the To:m reviewed Engineering Specification M-547, which documents the procurement and receipt inspection require-ments for the purchase of lubricants as a Commer-cial Quality Item (CQI). The Team noted that K 547 requires sampling and testing of each batch of material purchased as a CQI. At the Team's re,uest, the licensee reviewed records and iden-tified two ". eses in which a CQI procurement order hAd been issued which did not invoke this samp-ling requirement. The licensee subsequently issued a Pete.itial Condition Adverse to Quality (PCAQ) to ine. tate a review of CQIs issued for consistency witi: approved engineering soecifica-tions. The Itcensee committed to disposition

this PCAQ prior to. restart.

Overall communications between the maintenance l

department and other groups within the organiza-tion are effective. However, the interface prob- ,

l.

less discussed above, among the Stores Depart-ment, QAD, and the Maintepance Department, indi-i cate that continued attention is needed. ,

1 1

i

?

42 -

e 3.3.2.4 Maintenance Planning and Prioritization The licensee has estabitsbed a Maintenance Plan-ning Division within the Msintenance Department. ,

The role of the Planning Division is clearly '

delineated in approved maintenance procedures and <

the Itcensee's Maintenance Sectici Manual. The Planning Division Manager position has been filled and the licensee is actively pursuing candidates for the eight allocated staff posi-  ;

sions. When staffing efforts are complete, the division will consist of a work package planning group and a scheduling group. In the interim, the licensee is utilizing twelve contractor per- ,

! sonnel to perform the package planning function.

The licensee's Outage Management Group (CPG) is  ;

currently providing scheduling guidance. The licensee expects to complete the se.af fing effort '

by October 1988. Team reviews indicate that the 1

present staff of contractors, in conjunction with i OMG assistance, is functioning well, i j Implerentation of the revised maintenance work .,

process, particularly the need to generate de-  !

tatted job-specific maintenant? work plans (WP) i fer each maintenance request (MR), has resulted l in a heavy emphasis on the planning function. l The Team reviewed a large sample of completad l WP's, and WP's in the field. Interviews with  !

- craft personnel and first-line supervisors indi- l cated that these individuals were knowledgeable  ;

about the new maintenance process requirements f and considered Wp's issued by Planning to be of l generally good quality. One weakness was noted I in the area of post-work testing specification, l as discussed in Section 3.3.2.6. l The Team noted that the completion of job plan- (

l l

ning, and approval of the WP are typically i restraints to commencement of the activity. This  !

l results in the need to expedite the review pro-cess, making scheduling difficult. It appears [

that this is primarily attributable to the new-l ness of both the program and the Planning staff.

) Other facters also contribute. For e;. ample, the licensee's procedures currently do not provide a simplified process for non-intent changes to the l

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. l MWP after issuance. MWP's require a complete re-  ;

review to incorporate minor changes. The 11cen-

' see stated that a revision to the program to ,

l include provisions for non-intent changes is

" planned for the future. The Itcensee's engineer- ,

ing department is presently reviewing each MR/MWP

. and approving the use of any replacement mate-rials. This practice provides positive control of all materials, but delays issuance of the We  ;

and is a significant drain on engineering ,

resources.. While these factors inhibit efficient t i silanning, no instance of inadequate planning was -

identified. l The licensee has created a WPRT to assist in the  ;

i assignment of the proper priority to each MR. i The WPRT meets daily and is composed of represen- ,

1 tatives of various station groups, including ,

maintenance, operations, outage management, c.o n- i struction management, and fire protection. It performs a multi-disciplined review of new main-4 i tenance items to identify potential plant impact.

l The IATI Team attended a WPRT meeting and ob-served that discussions were properly focused and I priorities were assigned appropriately, i .

The Team also independently reviewed outstanding l

i maintenance requests for the RHR system and the i electrical distribution system. This review focused on MR's not designated for completion l before restart. The Team noted that MR 88-10-105 documented electrical ground and potential cable i

1 insulation damage in the circuit for pressure I switch PS-1001-93A. This switch is environmen-tally qualified (EQ) and provides a safety-

) related interlock function for the automatic depressurization system. The MR had been sched- ,

1 uled for work af ter restart, leaving the switch l EQ in an indeterminate st' ate. In response to the Team's question, the licensee rescheduled the MR i .

for completion prior to restart.

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. l The Teas also noted that MR 88-10-26 documents that valve A0-8001 is currently open and cannot be closed using the hand switch. A0-8001 is installed in series with a check valve in the torus fill line. The check valve satisfies the primary containment isolation function for the

. line. While A0-8001 is not required for contain-ment isolation operability, it does serve as a i redundant isolation valve immediately adjacent to the check valve. A0-8001 was originally designed to receive an automatic open signal on sensec low torus level. Because normal torus level is now maintained below the instrument low level set-point, the valve continuously receives an open signal, thus preventing manual . closure. Thts condition has existed for at least several years.

The licensee has relied on closure of a manual block valve located in the turbine building to compensate for the problem. The Team' expressed concern that the distance between the containment isolation check valve and the redundant isolation valve have been unnecessarily extended outside the reactor building. In addition, a lineup that is inconsistent with the design drawings and operating procedures resulted. The WPRT had designated this NR as post-restart. In response to the Team's coricerns, the licensee initiated an Engineering Service Request (ESR) to identify an acceptable repair. The Itcensee committed to resolve this item prior to restart.

l These two examples of misscheduled MR's were discussed by Itcenset management with the WPRT.

In addition, the licensee ecmmitted to re-evalu-

- ate all priority 3 MR's before restart. The <

. Itcensee's process for review and prioritization of MR's is thorough, and with the exception of the two instances described above, appears well i implemented. The effectiveness of the licensee's planning and prioritization program is demon-strated by the overall decrease in the number of

, outstanding maintenance tasks, their average age, and their significance.

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45 The licensee tracks several maintenance perform-ance indicators which are indicative of backlog status. Those performance indicators generally -

display a favorable trend. The Performance Indi-cator Report for August 9,1988, shows a total backlog of 2177 open MR's, of which 746 are in a test / turnover status. Of these, 220 cannot be tested until the plant system becomes operable during startup. Of the 1431 remaining open MA's, the Licensee has identified 652 required for restart. The physical work had yet to be done for 145 of these 652 MR's. Baseo on the above, and an average closecut rate of about 25 packages

. . per week, elimination of the restart backlog within 6 to 7 weeks appears to be manageable effort. Taa licensee's goal, in ' addition to addressing the restart MR s, is to reduce the total number of open MR's from 1431 to less than 1000 by plant restart. The Team noted that this would constitute an receptable open MR backlo for an operating plant, and that the licensee'gs goal was reasonable.

3.3.2.5 Control and Performance of Maintenance Inspection t'n this area was performed to deter-

- eine whether maintenance activities are being properly controlled through established proced-ures, and the use of approved technical manuals, j drawings and job-specific instructions. Mainton-l ance activities were observed to deterr.ine how j well the n w program was being imp *i emonted.

4l The new maintenance progre.m is primarily defined in procedures 1.5.3, "Maintenance Regaests," and

) ! 1.5.3.1, "Maintenance Work Plan," which were j implemented on June 20, 1984. The procedures were reviewed and found to provide strong con-J j

trels for identification, planning, performance,

l. e and closecut of maintenance tasks. Issuance and

' control of materials used for replacement / repair assure that requisite cuality requirements are j

maintained. Supervisory oversight of work in progress and the final review of work packages for completenoss is a strength. Based on its review of the above procedures and observations of work in progress, the Team concluded that the newly defined program provides excellent control and documentation of activities.

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46 The new program and procedures formalize centrols that were previously in place, but inconsistently applied and not recognized by procedures. The procedures now require better documentation of the initial problem description, the repairs made, and the post-work test requirements. They require detailed work instructions, which should provide for consistent high quality in mainten-ance work packages. An additional improvement in the stintenance procedures is that the mainten-ance work plan n:w provides for detailed documen-tation of installation and removal of lifted leads and jumpers (LL/J) . This documentation assures proper performanca of the task and is supplemented by the tracking provided in the LL/J Log initiated by the Operations Department per Procedure 1.5.9.1.

To eliminate a previously identified weakness, the licensee has stopped using Procedure 3.M.1-11. "Routine Maintenance," which was found to be too general to adequately control work activities. Instead, detailed work instructions are provided by the work plans prepared in ac-I cordance with Procedure 1.5.3.1. Further, the Itcensee has stopped using the Maintenance Sum-mary and Control (MSC) form. The documentation provided by the form has been replaced by the detailed work plans, maintenance legs, and special process control sheets now required by Procedures 1.5.3 and 1.5.3.1.

The maintenance activities and packages listed in Appendix 0 of this report were reviewed to verify proper implementation of program requirements.

The Team found that detailed work packages were prepared and in use in the field with adequate job specific instructions to accomplish the as-signed tasks. No ad-hoc changes of the work

. scope were observed, pre-job briefings were conducted and were appropriate to outline the m activities planned. Coordination and in-process coassunications with operations personnel were proper and assured good control of plant equipaent.

47

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. Maintenance personnel, including contractors, have been trained in and were knowledgeable about

• the new program and procedure requirements. Al-though the new controls were deemed cumbersome by

some, overall worker attitudes about the new procedures were positive. There is a general acceptance of the present program and a desire to "do the work right." Personnel performing the work were qualified, as verified by the training and qualification status board maintained in the maintenance shop.

The licensee has made progress in filling vacan-ctes in the first-line supervisor positient, with personnel having the requisite experieace and -

expertise in the associated disciplines. The l present supervisory staffing is adequate to cover work production schedules and provides adequate oversight. In an additional program improvement, supervisor review of work packages is now re-

- quired by procedure to assure management review of packages for completeness. First-line super-

visors were routinely observed in the field di-recting work in progress. Supervisory involve-ment was effective to assure completion of work

. correctly, to help resolve technical problems, and .) coordinate engineering support, as re-quired. The oversight function has been e.hanced by the larger number of first-line supervisors who have been relieved of the excessive adminis-l trative burden associated wi*.h planning and pack-age preparation.

! The effectiveness of maintenance staff engineers i

and system engineers in supporting field activ-ities was particularly notes in the repairs for the fuel pool cooling pump and the repair of RHR

' discharge valve 288. The engineers are also used I in the root cause analysis of component failures, l

The repair of valves 28A and B involved the fat,rication of new valve yokes, which resulted in a large and complicated werk control process that was appropriately broken down into several work I packages. Oversight and control of these jobs,

! which spanned several weeks, were notable. The j

quality of the final product was evident, as was the welding of the yokt subparts. Good incrocess l

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48 controls resulted in an acceptablt root weld on the first attempt for valve 288. Although 4 problera was encountered in the fabrication of the yokes -(short by 3/8 inches), this item, consid-ered minor, was properly dispositioned by the licensee througn' Nonconformance Report (NCR) 88-99.

3.3.2.6 Post-Maintenance Testing Program The licensee's pro:1 ram for identification and implementation of nost-maintenance testing was considered weak during previous inspections. >

During the current period, .the Team reviewed the licensee's post-maintenance testing program pro-cedures and other approved test technical guid-ance. A sample of riaintenance tasks was reviewed i to determine if planned testing adequately demon-strated correction of the cited deficiency. Test-ing was observed in the field, and completed test documentation was reviewed for thoroughness.

The licensee recently implemented a major revis-ion to Procedure 3.M.1-30, "Post-Work Testing Guidance." The current revision establishes a conservative philosophy designed to ensure that t

prescribed testing verifies correction of the original deficiency, as well as potential prob-lems which could have resulted from performance of the task. Organizattenti and individual responsibilities are clearly defined. Procedure i

3.M.1-30 incorporates by reference Station l Instruction SI-MT.0501, "Post-Work Test Matrices

! and Guidelines." $1-MT.0501 serves to further I define the method by which post-worn testing is to be specified and documented. It includes an i individual matrix for each type of component  :

describing the possible maintenance tasks and the corresponc'ing post-work test requirement. Each i matrix references an appropriate data sheet which provides more detailed testing guidance. Proced-ure 3.M 1-30, in conjunction with 5!-MT.0501, is  :

to be used by the Maintenance Planning Division, r with needed technical input from other mainten-a'ce department and systems engineering depart-ment personnel, to establish comprehensive test-ing requirements for each maintenance request.

The testing program as descrioed in snese docu-  ;

ments is well conceived and 15 consicered a strength.

49 The Team reviewed a sample of ongoing mair enance tasks and evaluated the technical ader. ,,a cy of prescribed testing. In three of the examples re-viewed, the planned testing was not adequate to ensure proper performance of the task and com-plete correction of the problem:

(1) Testing identified for the replacement of the fuel pool cooling pump and motor under MR 86-109, included only motor current and vibration monitoring. No pump head / flow test was specified.

(2) The package for replacement of a safety-

! related 4160-VAC bus lockout relay under MR-88-110 initially contained only the

. general guidance which should have been used for development of detailed testing. Subse-quently, suggested testing verified only a portion of the lockout reley functions.

(3) post-maintenance testing following repair of t a motor operated valve limit switch under MR 88-10-179 was also not adequate to ensure that the problem had been completely corrected.

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• In response to the Team's findings, the licensee Maintenance Section Manager audited task-ready MR packages and identified one additional case of inadequately specified testing. In each of the j

above instances, tne licensee subsequently de-veloped and performed adequate post-work tests.

Discussion with the personnel involved and main-tenance department management revealed that no l

training on the newly developed post-work testing 1

procedures and guidance had been conducted. The licensee immediately briefed appropriate super-visors and workers on the program, and committed '

to complete formal training in this area by September 9, 1988. A second potential contrib-

" utor to the problem in planning post-work tests j is the press of business, particularly in the i

planning area, in that the planners are currently i

)

just able to keep pace with the schedule for 7 field activities. Licensee management appeared  ;

1 j to be sensitive to this issue. The Team reviewed 1

an additional sample of in-process and completed MR's and did not icentify any further problems.

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\ . Overall, the Team concluded that the licensee has - -

established a thorough post work testing program demonstrating a sound safety perspective. Al-though'the program is generally well implemented, some problems were notec. The newness of the program, the current press of business, and some '

weakness in personnel training appear to be af-fecting its implementation. Therefore, this area requires continued licensee attention.

3.3.3 Conclusions The Itcensee has established a viable maintenance organiza-tion. Allocated staffing levels have been substantially .

- increased and are sufficient to support r.outine maintenance' activities. Of particular significance is the addition of j first-line supervisory positions, and the creation of an expanded maintenance planning and scheduling division. The Itcensee has been largely successful in filling previously vac4nt positions. One exception is the staffing of the i maintenance planning division. Wnile none of the permanent 'l staff in this area is in place, the licensee is effectively utilizing contractors to perform the function. Full staff-ing and training of the planning division is important to improving its overall effectiveness. Aggregate management and supervi sory qualifications were also found to be '

adequate.

Newly revised maintenance and post-work testing program i procedures provide significantly improved control and docu- ,

! mentation of field activities. They also result in an l increased emphasis on detailed job planning. Observations ,

I by the Team indicate that implementation of the program is (

generally effective. .Some implementation problems are j i evident; however, the problems affect production and not .

the quality of completed work. Additional attention to i

post-work test program application by the licensee is '

l needed.

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i The Itcensee appears to have identified and properly pri- ,

critized outstanding maintenance tasks, with only minor [

l exceptions noted. A process to ensure continued proper  ;

prioritization has been established. Both licensee senior f 1 management and maintenance section management are using a [

set of indicators to monitor performance. -

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. t In summary, the licensee's current maintenance staff and program are adequate to support plant operations. Con-2 tinued close licensee management monitoring of the newly implemented program will be required until additional experience is gained. The long-term support programs, such as preventive r.aintenance, will require licensee enhance-

. ment to further strengthen performance.  !

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3.4 Surve,111ance Testing and Calibration Control 3.4.1 Scope of Review The Team reviewed the licensee's administrative controls

- and implementation of the surveillance testing and cali-bration control program to assess its adequacy. As part of this review, 4he Team examined the licensee's corrective action to addrass past problems which included: effective-4 ness of test scheduling; the technical adequacy of proced-ures: and lack of centralized control of the program. The inspection consisted of a review of various procedures, drawings, and records; ob!ervations of testing in progress; and personnel interviews.

3.4.2 Obswrvations and Findings 3.4.2.1 Master Surveillance Tracking Program The Team reviewed the Itcensee's program for the control and evaluation of surveillance testing and calibration required by the Technical Specif-ications (TS), inservice testing (IST) of pumps and valves required by 10 CFR 50.55.a(g), and calibration of other safety related instrumenta-

. tien not specified in TS. The program is pre-scribed by Procedure No. 1.8, "Master Surveil-lance Tracking Program." The Systems Engineering Division Manager has overall adminsitrative re-sponsibility for the Master Surveillance Tracking Prog-am (MSTP). A plant Surveillance Coordinator has been assigned within the Systems Engineering Division to imple9ent the program, which includes reviewing and approving the various lists, sched-ules, and reports generated by the MSTP, and maintaining the MSTP data base. Each division has appointed a Division Surveillance Coordinator to interf ace with the plant Surveill?nce Coor-dinator. The plant Surveillance Coordinator meets weekly with the Plant Manager to review the status of the surveillance program.

The purpose of the MSTP is to ensure the timely performance of all surveillance testing. The MSTP data base contains information such as:

commitment reference (TS, preventive maintenance,

. regulatory commitment, etc.); the applicable procedure numoer and title; scheduler interval and basis; tne group responsible for performing m

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the test / calibration; anc the date last performed, the next due date, and the last date by which the surveillance test must be completed (plus 25%

date). Completed tests are rescheduled to ensure the combined grace period for any three consecu-tive tests does not exceed 3.25 times the spec-ified surveillance interval. The accuracy of the data base was verified by a contractor during the current outace. Procedure No.1.2 contains spec-ific controls on changing any of the data fields in the MSTP data base to maintain its accuracy.

In addition, a second contractor verification of the MSTP data base is scheduled to be performed in the near future. The Team selected several

. TS-required surveillance tests to ensure that they are in the MSTP data base, that approved procedures existed, and that the test frequency was proper. No discrepancies were identified with the data base during tne Team's review; how-ever, the Team was concerned with a potential 1 problem involving the scheduling of once per-operating-cycle versus once per-refueling-outage

, tests, as discussed below.

l As part of its review, the Team examined the pro; l cess established by Procedure No.1.8 to deter-mine its adequacy in ensuring that surveillance tests were properly scheduled and performed with-in the required time period. A "Division List" 4 is issued to each divisten and to the Control j Room Annex each Friday which provides a schedale l

cf tests due for performance the following week.

A "Monthly Forecast" is also issued weekly to

assist th .Section Managers in planning and i scheduling resources. When a surveillance test

is satisfactorily completed, the Control Room Annex copy of the Division List is signed off.

Daily, the Planning and Scheduling Division transcribes the completion dates and updates the l MSTP data base. A "Surveillance Day File Report" is issued daily to identify all changes made to the MSTP data base since the last time the report was issued. This report is reviewed'by the Plant l

Surveillance Coordinator and used to verify pro-per transcription and data entry. "Variance i Reports" are issued weekly to Section Managers to i

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e identify those surveillance tests that were scheduled, but not performed. A written explana-tion as to why the tests were not performed with-in the required time and why it's acceptable not to perform the test is sent to the surveillance coordinator within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of receipt of the Variance Report. A "Priority Notice" is issued for any surveillance test that has reached its deadline date (p'us 25% date) and that has not been performed by that date to assist in the pre-vention of T5 violations. Failure to' perform a

. TS-reguired surveillance test on the deadline date requires submissien of a Failure and Mal-function Report. The Team reviewed samples of each of the above reports, and their responses.

- and concluded that the program was adequate and contained suf ficient checks to ensure that sur-veillance tests were completed within the required time.

Although the Team f.ound the administrative con-trol and implementation of the MSTP to be ade-quate, it noted a commitment by iicensee manage-i ment e improve the program. These improvements include: replacing the Division Lists with task cards to reduce the potential for transcription errors; adding an alert notice when a scheduled i

test is not performed; improving the scheduling of conditicnal surveillances; planning for the l addition of a full-time surveillance engineer; i

and instituting an equipment history computer program capable of trending surveillance /calibra-

{

tion results on individual components.

The Team identified one concern during its review i

related to the scheduling of once-per-operating-cycle versus once-per-refueling-outage surveil-lance tests. The P11 grin Technical Specifica-tions define an operaticq cycle as the interval

'. be'. ween the end of one refueling outage and the end of the next subsequent refueling outage. A

' refueling outage is the period of time between the shutdowr. of the unit prior to refueling and the startup of the plant af ter that refueling.

The TS contains some surveillance requirements J

that are specified to be performed once per oper-

ating cycle, while there are others, such as testing tne drywell-to-suporession-charcer vacuum breakers, which are to be performed curing each

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55 refueling outage. Also, all the safety-related instruments not specified in the TS are cali-brated once per refueling outage. As part of a previously identified issue, the licensee has defined once-per-operating-cycle to be 18 months; however, no clarification has been provided for once-per-refueling-outage. As a result, thers are several once-per-refueling-outage tests /

calibrations which were performed in 1986 and 1987 which are currently scheduled on the MSTP for the "next refueling outage," which is projected for some time in 1991.

Therefore, by strictly interpreting the defini- '

tions, the interval for some of the once-per-refueling-outage surveillance tests could be as ,

long as four or five years. The Team pointed out that this appears to be beyond the intant of the TS. The Team also noted that a licensee task force estabitsbed to deter:ntne system opacability prior to restart had also identified this issue ,

and recomended that evaluations be performed on l the once-per-refueling-outage surveillance tests l to determine if and when they should be reper-formed. The licensee committed to evaluate the I status of the once-per-refueling-surveillance tests and provide justification for those tests not rescheduled, prior to restart.

3.4.2.2 Logic System Functional Test and $1mulated Automatic Actuation Procedures

> The Team reviewed the procedures listed in Appsndix 0 of this report to determine the ade-quacy of the licensee's perforsance of logic system functional tests (LSFT) and simulated automatic actuations (SAA). The review consisted of the indicated channel / train of the primary containment isolation system (PCIS) and the reactor core isolation cooling (RCIC) system LSFT and SAA, and the diesel generator (DG) initiation i

LSFT. The procedures were reviewed against the r l

systes drawings to ensure that they were tech-nically adequate, that all relays and contacts l

were tested, that the procedures were properly l approved, and that the tests were performed at ,

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the required frequency. The licensee uses a series of overlapping tests to satisfy the LSFT I

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ar.d SAA. The Team noted that the Itcensee had a contractor review the adequacy of the LSFT and SAA tests during this outage. The contractor ,

identified several deficiencies, which were cor-rected. The Team found that each procedure re-viewed was technically adequate and that the testing sequence satisfied the Technical Specif1- .

cation LSFT t.ed SAA frequency and scope require- l ments. The Team also noted that the format of l the procedures was adequate and included: en-vironmental qualification quality contes 1 (QC) witness points on . transmitter calibrations; i double verification on lifting and landing leads; '

i fuse holder fit checks; and I&C management review l

.upon test completion prior to the NWE review. j Ouring the review of the RCIC isolation subsystem  ;

LSFT, the Team questioned why there was no LSFT .

on initiation logic. The Team acknowledged that i j it was not required by TS Table 4.2.8, nor was "

credit taken for it in the FSAR. Hewever, TS i

3.,5.0.1 requires RCIC be operable (with reactor l pressure greater than 150 psig and escitat tem- I perature greater than 365 degrees F) and the TS 4

i deHnition of system operability requires that I all subsystems also be operable. This would l

include the RCIC initiation logic. Also, the j i guidance provided by the Standard Technical Spec-ifications indicates that an LSFT on the RCIC 1 initiation logic should be performed every six  ;

I r.onths. The Team noted that Procedure No. 8.M.2- l 2.6.7, "RCIC Simulated Automatic Actuation," l i actually performs an initiation logic LFST; how- l i over, it is scheduled at a once-per-18-month fre- l

' quency, while TS-required LSFT's have a frequency  ;

! of' once per 6 months. This ites is unresolved  !

! pending a licensee evaluation of the adequacy of '

T

! the RCIC initiation logic L$Fr frequency (88 -

! 02). The licensee committed to provide, before l

restart, the technical basis for the surveillance l frequency. l l

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! 3.4.2.3 Calibration procedures [

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l The Team noted that the licensee established a I series of procedures, known as the 8.E series, to  !

calibrate the safety-related instrumentation not .

specified in the Technical Specifications. This (

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instrumentation is normally used to record data necessary to complete TS-required sumleillance l tests or inservice testing of pumps and valves. l The 8.E procedures are scheduled on a once-per-refueling-outage interval, i 9

The Team performed a detailed review of Proced-  !

ures No. 8.E.11. "Standby Liquid Control System Instrument Calibration," and 8 E.13. "RCIC Systes  ;

Instrument Calibration." Overall, the Team found the technical content and format to be adequate; '

however, two discrepancies were identified. Pro-cedure No. 8.E.11 does not calibrate pressure indicator (PI) 1159. This PI was installed dur-

' . ing the current outage and is used in the per- ,

formance of Procedure No. 8.4.1, "Standby Liquid '

4 l

Control Pump Operability and Flow Rate Test." ,

j The Team also noted that Procedure No. 8.5.13 l does not calibrate PI 1340-2. This PI'is used in .i' the performance of Procedure No. 8.5.5.1, "RCIC 1 Pump Operability Flow Rate and Valve Test 91,000 I psig." PI 1340-2 was installed and last cali-

.' brated during the 1984 outage when pressure i i

transmitter 1360-19 was replaced with a Rosemount l

Transmitter. The Itcensee indicated that the i procedures would be revised to . correct the I deficiencies.

! 3.4.2.4 Surveillance Test Cbservations j

} On August 16, 1988, the Team observed a portion l

of the performance of Procedure No. 8.M.2-2.10.  ;

• 1-5, "Core Spray System 'B' Logic Functional -

[

l Test," Revision 13. The test was performed as (

part of the restoration of the "$" Core Spray  !

l System and as post work testing of relay 14A- l The test was observed to ensure it was l K208. i

! performed in accordance with a properly approved i and adequate procedure. During the test, the

• Team noted that the technicians' performance was >

adequate. They conducted the test in a slow and f

' deliberate manner and stopped when questions t arose concerning mislabelled naseplates and the i identification af some relay coil leads. In both -

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cases, the questions were resolved before they j proceeded. The Team noted that the I&C first-line supervisor monitored portions of the test. i t

1 The test was also monitored by CA personnel as I part of the surveillance monitoring program. QA personnel indicated that they observe approxi-mately one surveillance test a week. l l

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The test was stopped at Step 25 when the test results did not agree with the expected results delineated in the procedure.' The step was sup-posed to verify the instantaneous pickup of the core spray pump start relay 14A-K128. Subsequent i

licensee investigation revealed that the instan-taneoua pickup was removed as part of the de-graded grid voltage modification (Plant Ouf gn Change (POC) 88-07). The Team noted that PDC 88-07 had not yet been closed; however, an impact review performed prior to installing the modif t-cation f ailed to identify Procedure 8.M.2-2.10.

1-5 as being affected by the POC.

The Team noted that one of the licensee's self- +

assessment action items was to review the impact i of PDC's (installed since October 1987) on j LS FT's . The licensee's review began on

October 1957 because thf was the completion date of the contractor review noted above which ver-ified the adequacy of LSFT/SM tests. The Team  !

noted that the contractor review produced an

. . LSFT/SM data base which cross references the safety-related components tested to the appli-cable LSFT/SM test. This data, was being used during the licensee's review. Four of the five PCC's involved in the licensee's review of impact  :

on LSFT's have been completed. The remaining PDC t l (88-07) was under review when the problem with I the core spray LSFT was noted. Twenty-one pro- )

cedures have been identified as possibly being i 1 affected by the POC and are currently under review. The CS functional test appears to be the <

! only affected test run prior to completion of the PDC-procedure review.

l I The licensee indicated that a possible future i l

l improvement will be to use the LSFT/SM data base j

! to determine the impact of a PDC on procedures before implementing the modification. i 3.4.2.5 Measuring and Test Equipment The Team reviewed records, interviewed personnel, l and toured storage areas to determine the ade- i

quacy of the licensee's program for control of l measuring and test equipment (M&TE). Acministra-l

'tive control of the program is established by Procedure No. 1.3.36 "Measurement and Test j a '

Equipment."

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59 The licensee has implemented a computerized sys' ,

tem to issue and track MTE. This system will only allow issuance equipment to authorized per-sonnel, will limit the checkout period to only 24 '

hours, and will not issue MTE if the sticker calibration date does not match the calibration date in the computer. The system also issues a MTE traveler form to the user to identify usage on each plant device tested and each MTE range used. This data is later entered into the com-puter to assist in evaluations if and when a '

piece of MTE is found to be out of calibration.

The Team reviewed two cases where MTE was out of calibration and noted that the evaluations per- l formed were documented in accordance with proced-  !

ures and appeared thorough. Thus far, only  !

electrical !&C and electrical MTE are on the new .

computerized system; however, similar controls '

are be'ing manually implemented for mechanical equipment until it is incorporated into the new system.

The licensee currently has two storage areas for MTE: one for electrical /I&C and one for mech-anical equipment. The Team toured each area and - i noted that the equipment was identified by a  ;

unique number and indicated calibration stati:s, ,

The Team found that the equipment was properly <

, stored and that MTE.out-of-calibration, on hold ,

for repairs, or new equipment not yet in the sys- ,

tem, were properly identified and segregated. -

The licensee indicated plans to go to only one '

storage area and to increase the number of staf f issuing and controlling the M TE.

The Team alt , reviewed the system for recalling  :

equipment for calibration. The recall tracking

- is performed in accordance with Procedure No. ,

1.8.2, "PM Tracking Program." The Team reviewed

. several equipment calibration stickers during its tour of the storage areas and during observations of ongoing surveillance and maintenance activ-  :

ities. No equipment past its calibration due l date was identified. -

• t The Team found the licensee's control of measur-ing and test equipment to be adequate. [

i 60 i

\

. i 3.4.2.6 Inservice Testing of Pumps and Vaive,s  :

The Team reviewed the status of the licensee's program for inservice testing of pumps and valves j in accordance with the ASME Boiler and Pressure  :

Vessel Code,Section XI.

The licensee submitted Revision 1A to the inser- '

vice test (15T) prograra on October 24, 1985. A '

meeting was held between BEco and the NRC on January 14, 1988, to discuss the licensee's pro- .

posed Revision 2 to the !$T program. To minimize impact on the NRC review cycle, the licensee sub-  ;

mitted an interim IST program. Revision 18, on March 14, 1988, to address concerns identified by .

the NRC during review of Revision 1A. The lican-see plans to submit Revision 2 af ter the Safety Evaluation Report on Revision IB is issued. Re- <

. vision 2 is to maintain the upgrades made to the program in Revision 18 and increase the program ,

scope by adding more components (e.g., relief

• l valves).

Control of the IST Program is established by Pro-  !

cedurs No. 8 I.1, "Administration of Insenice  !

- Pump and Valve Testing." The Team reviewed the i procedure and noted that while it defines the methodology for compliance to the IST program for pumps and valves, including analysis of tes [

data, direction on corrective action, and estab- i lishment of reference values (additional guidance is contained in Procedure No. 8.I.3, "Inservice  :

(est Analysis and Cocumentation Methods"), the '

organizational responsibilities and referenced i 15" program revision need to be updated. For example, the pump and valve testing is now sched-uled through the M5TP instead of the compliance group, and a Senior ASME Test Engineer has been hired to implement the program. The Itcensee acknowledged the Team's comments and showed it a draf t revision to Procedure 8.!, which is sched-uled to be implemented when Revision 2 is submit-ted. The Team reviewed the draf t procedure and noted that it provided additional detail on:

i 6) s  !

I responsibilities, definitions, test requirements, compliance requirements, evaluation, disposition, post-maintenance testin0, and administration and records maintenance. "he draft procedure also

provides a Itsting of the pumps and valves cur-rently within the testing program and includes a cross-reference for individual test requirements to the approved PNP 5 procedure, a

l The Team noted that other improvements (planned i or in progress) to the !$T p.*ogram include revis-  !

ing all the implementing procedures to upgrade

'them to Revision 2 and creating a position for a

• second ASME test engineer.

The Team reviewed several pump and valve test results for the standby liquid control, core.

spray, salt service water and low pressure cool-ant injection systems to verify that the accept-

' ance criteria were met, that the results were i properly evaluated and trended, and that the fre-l quency of f.esting was increased when required. i 1

i The Team noted that Procedure No. 8.! contains ,

l controls to change the MSTP data base test fre-quency when the deviations f all within the alert 1

range. The Team reviewed changes to various gump i

• reference values to ensure that they were justi-fied and documented. The Ter: also checked the 4

l reactor building closed' cooling water, salt ser-  :

vice water, and standby Itquid control system pumps to ensure that the !$T vibration data point ,

{

i was properly marked. No deficiencies were iden- )

tified during this review.  ;

I

! . 3.4.3 Conclusions '

I Based on observations, personnel interviews, and the review , l of procedures and records noted above, the Team concluded  !

that: I 4

J 1. The Itcensee has established and ti implementing an l j

• adequate and effective program to control all surveil- l j

l lance activities at PNPS. <

l 2. Responsibility for implementing the MST7 has been placed in a centralized, strong, forward-lookirg

)

I division. >

i

! f i

i

62

3. The If eensee was adequately implementitig the IST pro-gram for pumps and valves. The Team noted that there are several planned improvements to the program involving administrative and implacenting procedures and staffing to upgrade the IST program.

4. Licensee management is committed to improve the sur-  !

veillance program, as evidenced by the upgrades  ;

planned or in progress in each area examined. These i include: contractor data base reviews; increasing the i scope of the !$T program, increasing staffing: in-proved control over issuing and tracking M&TE; estab-lishing an equipment htstory computer program; replac-ing the HSTP division lists with task cards; and j improving conditional test scheduling. ,

5. With the exception of the few deficiencies noted i above, the procedures were technically adequate.

6. The one cencern identified was the licensee's need to resolve the once-per-refueling-outage scheduling deficiency.

I I

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33 3.5 Radiation Protection (RP) 3.5.1 Scope of Review The Team reviewed various aspects of the radiation protec-tion progree during the inspection, with emphasis on the licensee's ability to safely support plant startup, Per- ,

formance was determined front observation of work in progress; periodic tours of plant areas; interviews with t i sanagers, supervisors, and technicians; and review of l selected documents. The areas reviewed are as follows:

l l 1) Organization and staffing;

2) Training, qualification and continuing education of RP ,

to:hnicians;

3) General e:picyte training; -

i

4) ALARA programs;

5) Control and oversight of work in radio'iogical areas;

6) Control of locked high radiation areas;

7) Adequacy of laboratory (count room) equipment;

4) Availability and adequacy of portable RP survey equipment;

9) Adequacy of gaseous and liquid release monitoring systems;

10) Clarity and consistency of RP policies and procedures;

11) Audit s.

3.5.2 Observations and Findings

. 3.5.2.1 Organization and Staffing The organization of the radiation protection (RP) department has remained stable since the signift-cant changes which were made early in 1984. The staffing level has remained constant and is ade-quate to support plant operations. The RP sec-tion manager described various enhancements

64 s

planned for the supervisory staff. An outline for qualification as Radiation Protection Man-ager, per Regulatory Guide 1.8, has been ap-proved. One or two division managers within the RP section will be espected to qualify as Radia-tion Protection Manager to provide depth in the ergenization. Incentives have been approved for achieving this qualification. In addition, the thru division managers will rotate assignments for cross-training purposes, and all will be encouraged to pursue advanced scholastic degrees. '

These efforts are espected to begin in the near.

. future.

The Team observed some indications of isolated morale problems at the technician and first-1tne supervisor level which were attributed to several causes. Contributors include personnel and as-signment changes within the organization result-ing free rotation of radiation protection shift

- supervisors, an influx of new technicians, in-

. pendteg implementation of a new rotating work schedule, and a perceived lack of management presence in the ' field. In addition, weaknesses may exist in communications within the AP organ-ization as evidenced by technician perceptions of a lack of technician input or review during the ,

development er rey,Jion of AP policies and pro-cedures. In summary, and in spite of these dif-ficulties, the Team observed that the technicians and supervisors were generally enthusiastic and competent.

Another potential weakness results from the prac-tice of rotating technicians through job assign-monts each three to six aenths. Although this practice may have merit for fant11erization and job exposure purposes it may prevent or signifi-cantly delay the development of a high profict-ency level in certain specialized technical areas, a concern particularly evident in the instrument repair and calibration f acility. Here the RP technician is assigned O repair and cali-brate a wide range of instrumentation, including gas flow detectar cells, sophisticated computer-controlled automatic friskers, air pumps, and all alpha, beta, gassa and neutron survey meters.

The area sucervisor stated that he was attempting to resolve this problest by requesting an exten-sten of the rotation cycle.

c o . .

65 s

The RP section has 42 technicians, of whom 36 are ANSI 18.1 qualified. Only 21 have commercial experience. The section manager provided a shift staffing schedule for power ascension testing that will ensure that the experience will be adequately distributed among the individual shift crews.

3.5.2.2 AP Techalcian Training The RP technician training ar.d qualification pro-gram is certified by the institute of Nuclear Plant Operations (INPO), uses INPO guidelines for development of instructional material, and uses '

the INPO exas question bank. The training is conducted in three phases over a period of two years or less, depending on experfence. Upon completion of Phase 2. the technician is con-sidered to be ANSI qualified and can issue radia-tion work permits. The third phase includes soecialty tasks such as operation of the whole body counter and respirator fit testing.

Classroom training is provided at the offsite facility. The training factitties were adequate, we'll lighted, comfortable and equipped with prac-tice equipment. The Team observed that most of the basic survey instruments were available, but laboratory-type gama spectroscopy equipment, as well as AL. ARA mock-ups, were not available. This is typical of a single unit station. Most pre-sentations appeared to rely on lectures with minimal use of audio-visual equipment. A review of selected lesson plans showed adequate tech-nical content.

Classroom training is followed by an in-plant phase where the technician receives on-the-job training and demonstrates proficiency at various tasks, This is documented in a qualification folder. Qualified technicians will be provided with ongoing training on a sis-wee k schedule.

This will be contingent on implementation of a new six-section rotating work schedule. The

66 s

training department has begun drafting lesson plans which will cover a broad range of topics, in:1uding interpersonal sk,ill s training. The instructors must also complete formal qualifica-  :

tions. They were recently required to begin  !

spending a certain number of hours in plant be-  :

tween training ' cycles. This keeps them abreast ,

of changes occurring in the plant.

The Team concluded that this program is well- l 4 . controlled and documented and is aided by a dy- .

• nemic first-line supervisor. The implementation j

and effectiveness of cycle training'will be eval-usted in the future. The Itcensee s current of-  !

forts are directed at completing initial qual-

] ification for the entire staff.  !

I 3.5.2.3 General Employee Training (GET) 1 All general employee training and in-processing is conducted at the on-si*.e training center over  !

'l a three-day period. Classrooms were spacious, comfortable, and well equipped. Ample training i

. aids, as well as audio-visual equipment, were in evidence. A comprehensive student manual is given to each trainee along with copies of appro-priate regulations and regulatory guides. Basic training involves 20 contact hours, while radia-tion workers receive an additional 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Res-pirator fit toesting is also provided.

The two instructors associated with GET had com-plet,ed the formal Staff Cevelopment program.

Both have estensise experience and are well qual-ified. Although their teaching techniques could not be observed since no classes were in session during the week of this review, the Team con-cluded that the training content provided ade-qu' ate direction to attendees, loth instructors spend time in the plant weekly to assess staff training needs.

The GET training is !NPQ certified. In addition, the training center offers five courses to all new supervisors. A new industrial safety train-ing program is under development. An instructor has been hired and will begin providing training in occupational safety during the first quarter of 1989.

67 ,

The Team concluded that man 1gement support of GET training was good, that the training was effec-tively conducted, and that it made a positive contribution to safety.

3.5.2.4 ALARA Prograas

! ALARA performance at this station had been a i

persistent weakness over several past SALP report periods.

i .

The Team noted recent apparent improvement in l

upper management support for ALARA programs.

1 Examples of this support are ref1seted in the re-evaluation of the 1988 *LARA goal from 600 to i 390 sanres and formulation of several plans to reduce exposures. Also, the licensee is assign-ing an esperienced manager to survey INPO, Elec-l trte Power Research Institute (EPRI), and several other nuclear stations to make a list of cost-1 ef fective exposure source term reduction tech-i niques. The Station Director will then formulate

! a long-term program based on the fi.edings of this survey. Another plan is to begin removal of j abandoned in place systems in 1989 which should s remove unnecessary sources of exposure. A third project is undcrway to identify hot spots in plant piping and determine which of these could be reduced by flushing.

The ALARA staff also has plans to attend a train-ing course and visit other stations to observe effective techniques. This staff is in the process of filling its final vacancy.

ALARA performance at the worting level remains mixed. Licensing personnel developed a technique for conducting remote inspections of fire barrier penetra,tions using a flashlight mounted on a telescope. This concept may be appited in num-erous situations and has the potential for sig-nificant dose savings. On the other hand, in-stances of f ailure to effectively use low-dose waiting areas were observed during work. The ALARA division manager is working to increase the sen.itivity of all workers and technicians to ALARA oractices.

68 The Team concluded that licensee attention to ALARA programs has significantly improved in recent months. The effectiveness and implemen-tation of ALARA plans will be assessed in future 4

NRC inspections.

'3.5.2.5 Controi of Work During closure of a Confirmatory Order in the fall of 1987, NRC noted some improvement in the -

! relations between the RP section and the other sections performing work. However, poor planning and lack of work control continued to be ob-se rved. During 'this assessment, further improve-  !

ment in resolving these weaknesses was observed. - L i

One indicator of poor planning is the number of ,

! radiation work permits (RWP) issued but not used.

l A review found that only a small fraction of RWP's issued are now unused. In addition, the use of "A" priority maintenance work requests by j the Operations. Department to expedite work has

! decreased significantly, i i The use of a Radiation Protection Advisor as- l signed to the Maintenance department continues to ,

1 be effective. This position was recently assumed j

by an experienced RP technician. He has intro- i i duced innovations, including frequent work group  !

i training sessions and installation of permanently situated bones in the plant for contaminated t I tools. (

j The Planning Division is developing improved pro-cedures for planning work. This section is re-sponsible for coordinating wit 3 the RP and ALARA ,

g' roups during the early phases of work planning. '

his allows adequate time for RWP preparation and Respersible section managers ALARA revievs. [

stated that this early maintenance-HP contact  !

l. will be proceduralized in September 1988.

The Team observed that on-the-job cooperation i

' between workers and RP technicians was good. A l minor problem was noted in that RP technicians in i

l the controlled area appeared unprepared to deal i with a minor first aid injury. Technicians were f i  !

l I

r

- - _ _ - - - - _ - - . , _ , _ _ _ _ , _ _ . . _ . , _ _ - _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . - ~ , _ _ - . ___m.-..m.__.__,__m, _ , , - - - - - - - - - - _ . ~ .

69 uncertain in dealing with a worker with abrasions to his nose that caused bleeding. This was at- '

tributed by the Team to a lack of training and clear policies. On the other hand, technicians appeared well prspared to handle more sericas emergencies.

3.1.2.6 Control of Locked High Radiation Areas The licensee has previously incurred several violations for failure to properly control *ocked high radiation areas. This issue has been -

tracked as a NRC cutstanding ites (87-57-01).

, The licensee organized a task force to determine i which lasting corrective actions would prevent a recurrence of these problems. Based on the find-ings of the task force, the cortrol procedures were revised to place basic responsibility on the RP technician who signs out the door ' key. Fur-ther controls are provided by shift tours of all Iceked areas and by upgrading locking cevices.

Based on these actions, the Team concluced the Itcensee had ~ appropriately addressed concerns in this area.

3.5.2.7 Laboratory Equipment The adequacy and availability of RP laboratory

< equipment to support plant startup was reviewed.

The licensee has available two multichannel analyzers (Nuclear Data 6700), several beta counters (BC4), and several alpha counters (!AC 4). '*he i radiochemistry laboratory has redundant

! equipment for backuo. This equipment is required l to perform isotopic analysis of air samples for

maximum permitted concentration (MPC) calcula-tions, detection of degraded fuel conditions, and to suppert .radwaste analysis. Procedures for the

! use of the equipment are available in the i laboratory.

The Team noted that, at the time of the inspec-tion, several pieces of laboratory equipment were awaiting repair or calibration. Caly one BC-4 and one SAC-4 were coerational in the lab. Both multichannel analyzers were awaiting recair l

parts. The sucervisor in charge attributed this j to the lack of proficiency of the f.ecnnicians due to the rotating work assignment policy. This issue w&S discussed in Sect. ion 3.5.2.1.

L

f 70 I

. 3.5.2.8 Survey Equipment l The availability of properly calibrated survey equipment was reviewed. Survey equipment is used by RP technicians to measure dose rates, and sur-  !

, face and airborne contamination levels. Included  ;

in the review were the automatic personnel con- -

l tamination detectors.

All equipment is calibrated and repaired in a l facility on site, except for neutron survey  ;

meters. AP technicians are trained to perform .

all functions in the factitty. The facility

'j' sppeared to be adequately equipped to perform its  ;

task. . ,

i

. t l - $tocks of equipment ready for issuance appeared t

! ample and the calibration / repair backlog was '

{ minimal. Tht readiness may have been aided i j somewhat by reduced outage activity. The Team .

noted an improvement in that the new manager of l the group has recently implemented a computer l program that shows the status of each piece of i

! equLpment, the data base for which ts upcated j each time an instrument i, issued. Infcvation i that is captured includes users of sne meter,  !

calibration due date, and failure mode if placed l

out of service. -

i The Teas concluded that an adequate supply of L

! calibrated instr 9ments is on hand to support

routine operations and abnormal conditions.

3.5.2.9 Nonttoring Environmental Releases l The operability of the environmental release monitors was verified. The two paths for a gas-eeus release are the main stack and the reactor butiding vent. The monitors were found to be operational and properly cattbrated, with approved procecures available. The equipment is maintained by the Chemistry Group while the cal-cu14tions of of f stte doses required b.v the re-vised Radiological Environmental Technical Spec-ifications (RETS) are parformed by the RP section.

. . i 71  :

l The single Itquid release path monitor was oper-ational. Due to elevated background radiation l

levels'at the sodium todide monitor, a new system L has been installed parallel to the old system, t The new system will offer increased sensitivity and will be brought on line in the near future. .

3.5.2.10 Policies and Procedures i A sampling of RP procedures indicates that they  ;

are generally clear. The number of procedures controlling the RP department activities is extensive. However, the format varies from step-  ;

i by-step instructions to a more general format. l

, The RWP procedure is currently being revised to  !

make the process less cumberseme and more useful.

In general, the AP technicians did not feel ade- t quately consulted during the revision of proced-  !

4 ures. This issue was discussed in Section

3.5.2.1.

l Tha Team concluded that the RP procedures were  !

adequate to support start,up. '

3.5.2.11 Audits I i  !

Prcvious inspections foend the licensee's inter- '

nal audits and isssessments of the RP program a were primarily como11ance-oriented. Currently.

l these audits are completed in several ways. Seva 1 i

eral peer evaluators were trained to make on-the- l job observations. A Radiological Assessor is permanently assigned to the staff reportinc to the Senior Vice President. The Management Over-sight and Assessment Team (MC&AT) does monthly  ;

plant tours. Also, the QA Cesartment recently i transferred in two experienced RP personnel. In i addition to the above audits and reviews, the  !

Radiological Occurrence Report ( AOR) systes pro-wides a method to capture input from workers and l RP techniciar.s.

A review of these efforts shows that a moderate l level of success has been achieved in finding program weaknesses. However, the results have  !

not been commensurate with the effort involved.  !

The RP section sanager stated that an effort is i i

72 s

underway to shift the empr.asts of these audits to performance rather than ccmpitance. The audit performed by QA in November 1987 is being used as a model. Licensee efforts in this regard are expected to De long term and are adequate at this time to support plant startup.

3.5.2.12 Control of Radio 1cgical Shielding The Team reviewed the iteensee's program for the installation, control, and removal of radiation l shielding. This review concluded that the licen-see's program for control of radiation shielding is well documented and that implementation is

• good.

The program guidelines are contained in PNPS Pro-cedure 6.10-008, "Installation and Removal of Shielding." Responsiblitty for implementation of j the procedural requirements fall vader the aus-J pices of the Radiological Technical Support 4 Division. The procedural requirements for con-

trolling this process appear well defined and

) comprehensive. Licensee personnel responsible a for implementation of the procedure were well l

versed on procedural requirements and current field installations. Licensee records of held

, installations were current, had been revieud at the required intervals, and were areu P a.

3.5.2.13 Health Phystes Training The Team observed Itcensee personnel during a contamination control training exercise. The exertise simulated a spill of highly radioact've (3 Rem on contact) resin during transfer opera-

. tions. The scenerto document was well defined and included detailed timelines and instructions to the esercise controllers. The entire exercise

i. was videotaped and replayed during t,ne doortefing

of participants. The exercise was well control-led and interviews with participant; indicated

that the individuals involved considered it to be

. an effective training device. Lessons learned and feedback from participants appared to be i

well disseminated.

1 73 s

3.5.2.14 Hydrogen Water,Cheststry System  :

The licensee has installed a system to inject 1 hydrogen gas into the feedwater to reduce the potential for corrosion of reactor internal pip- (

ing. This process will result in increased radi-ation levels onsite from increased radioactive nitrogen isotope levels in the system. A review i of the ispect analysis showed that a comprehen- l sive plan to control exposures has been developed.

2 A test run in 1985 resulted in the installation i of a 16-foot high 20-inch thick concrete shield i 1

around the turbine. Moreover, special controls

, are programmed into the computer that controls  !

! the hydrogen injection. The cognizaht, engineer r

. stated that these controls are designet; to pre-  ;

4 vent increased exposure either ensite or i,ffsite.  !

l

. Team review of these calculations showed that l l

doses may in fact be lowered.

1 The Training Departgent is developing a training

program for the RP technicia:is to review the l

! change in radiation levels tha'. occur with operaa i tions. This program was developed to refrest the  !

i .

RP technicians breause of the extended shutdown i i

and the increased levels of r diation in tne  !

shielded areas resulting from the addition of  !

I hydrogen. The AP section manager stated that a i conde9 sed revision of these presentations will l I also be given to all maintenance and operations personnel prior to startup, a 3.5.3 Conclusions The Team determined that progress has been made, that ade-quote staff and senegement oversight is in-place to achieve i further progress, and that performance is adequate to sup-

, port plant startup.

. , l.icensee strengths include a well-controlled and well-i organized training program for general esployees and RP l technicians. The use of an Rp Advisor in the Maintenance

! 5ection, which had teen effective in improdng working j relationships, has led to further initiatives in trainta.g and control of co ttaminated tools. The addition of this jl position has also resulted in improved planning and control of work.

]

1

1 74 s

4 Notable progr9ss was observed regarding upper management support and orphasit on Al. ARA. This attention is espected to result in ta;,r%ing levels of performance over the next few years. Staff development programs for all levels of personnel, from technicians through managers, should con-siderably improve their level of performance. Control of tec'nnical problems, such as the radiclogical intpact of hydrogen water chemistry and calibration status of survey l meters, has improved, t A weakness was observed as a result of the rotational as-signment of RP technfetans that may af fect their profic-

, tency in performing certain highly specialized jobs. An additional weakness concerns the perception of poor ver-tical communications between management and RP technicians and workers Although this issue has led to so.ae incom-ple'.e understanding of policies and some morale problems, it has not significantly affected safety performance.

Addittenally, vertical communications within the RP organ-tzation appeared somewhat weak. The Team detected a per-ception on the part of technicians that they have not been adequately involved in the changes being made in the RP Department policies and procedures. This perception an-parently has 'resulted from RP management not effectively communicating the bases for these changes to the staff.

There is aise a perception that RP management is remote and not easily accessible. However, the Team determined that, despite this weakness, the attitude and safety approach of the RP Department staft has significantly improved and is adequate to support plant operations.

The licensee advised that a trainino program is being developed to refresh RP technicians concerning t.he change in radiological conditions on plant startup and the unique

, conditions to be created by the addition of hydrogen. A condensed version of this training will be provided to other radiation workers. Completion of this effort will be reviewed in a future NRC inspection.

9

1 1 75  :

) . $ -

4 .

3.4 Security and Safeauard1 3.6.1 Scope of Review 2

Prior to the plant shutdown in April 1985, NRC had identi-fled serious concerns r1garding the implementation and management support of the security program at Pilgrim. The

! Itcensee has been aggressively pursuing a comprehensive

course of action to identify and correct the root causes of

the programatic weaknesses in physical security. The most  !

i recent SALP (50-793/87-99) covering the period February 1. ,

1 1987 to May 15, 1988, determined that the Itcensee has  !

demonstrated a commitment to implement an effective secur-  ;

j . ity program. The licensee's security organization has been l 1 espanded with the addition of esperienced personnel in key i 3 positions, significant capital resources have been expended  :

( to upgrade security hardware, and equipment and program l 1

plans have been taproved. .

r 1

Ouring the IAT inspect. ion, all phases of the sscurity pro-i gru, including management support, staffing, organicotton, j and hardware maintenance, have been reviewed to assess tne 1 effectiveness of the program implementation. The results P of the reviev are described eelow in general terms to l exclude any safeguards information. ,

i j 3.6.2 Observations and Findings j 3.6.2.1 Revie*4 of Security P*ogram tJpgrades

! The Tear. reviewed the progress made to date on the security program improvements committed t.o by the licensee as a result of previous NRC enforce-ment action. The licensee was ' advised by the 4

Team that progress on these improvements will

) continue to be monitored during future NRC inspections. These commitments and their status

! are as follows.

1 Project ling},

Protected Area The upgrades of the perimeter I perimeter barrier, intrution detection system, and assessment aid j system are complete.

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L _ - - - _. - - - . - . . - _ - _ - - . . . . - . .

^

76 Projecc Status Protected Area and Installation of upgraded Perimeter Lighting lighting is approximately 95%

complete. Four light stan-chions remain to be instal-led. The lighting system as installed meets regulatory requirements.

Main and Alternate The designs for the new Access Control (upgraded) access control Points points are complete and new package search equipment is on site. Installation of new package and personnel search equipment and full length turnstiles is scheduled for

• completion on September 28, 1988, in the site's main ac-cess point. Installation of new package search equipment in the site's alternate ac-cess point is also scheduled for September 28, 1988.

Vital Area The vital area analysis, Analysis including walkdown of all vital areas to verify barrier integrity, and issuance of the report, is complete.

New Security The selection of the new Computer computer has been made and a purchase order for the com-puter has been issued. The licensee is currently working with the vendor on software options. The del'.very of the new computer is scheduled for the first quarter of 1989, with installation to follow.

77 3.6.2.2 Followup on Previously Unresolved Item (Closed) Unresolved Item (50-293/87-44-01):

Neighborhood checks for licensee employees being assigned to the site were not being consistently conducted as part of the access control program.

The neighborhood checks were not a regulatory requirement and it is a licensee-identified issue. During this inspection, the Team verified that the licensee has conducted a review and identified all site personnel who had not been .

subjected to neighborhood checks.. For those employees with less than three years of service <

with the licensee, neighborhood checks were sub- '

sequently conducted. For employees with more  :

than three years with the company, a review of the personnel file was conducted and a memorandum -

was put into the file to indicate that the review was being made in lieu of the neighborhood check.

The acceptability of this alternative to the neighborhood checks was reviewed by NRC prior to '

its implementation and was found satisfactory. .

3.5.2.3 Security Pian and Implementing Procedures  ;

The Team met with licensee representatives and discussed the NRC-approved Security Plan (the Plan). As a result of these discussions, and a review of the Plan and its implementing proced-ures, the Team found that the implementing pro-cedures adequately addressed the Plan's commit-ments. In addition, all security personnel interviewed demonstrated familiarity with the Plan, implementing procedures, and NRC's security program performance objectives.

3.6.2.4 Management Effectiveness - Security Programs -

An in-depth review of the licensees management effectiveness was conducted by NRC in April and -

~

May 1988 and documented in Inspection Report No.

50-293/88-18. During that inspection, the Team concluded that the licensee has continued with .

its initiatives and taken significant actions to further improve the effectiveness of the security organization. It was also concluded that the existing organization should provide the capa-bility to monitor the program properly.

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78 During its inspection, the Team independently concluded that there is a strong management team in place based on the experience of the expanded proprietary security organization, the effective interaction both between members of the sa:urity organization and with other departments, and the effective oversight of the contract security organization.

3.6.2.5 Security Organizstion On August 16,1988, at 10*:00 p.m., the security contractor for PNPS was changed from Globe Security Systems to the Wackenhut Corporation. .

The Team reviewed the licensec's and the contrac-tor's transition plans, and interviewed numerous management and union security personnel prior to the transition. Also, the Team was onsite during the transition for direct observations. The transition was somewhat simplified by the fact tnat all Globe employees that applied for posi-tions were retained by Wackenhut. The Team determined that, because of comprehensive transi-tion planning, the change in the contract secur-ity force was accomplished without any compromise

. of security and with minimal disruption to secur-ity operations.

3.6.2.6 Security Program Audit The Team reviewed the monthly corporate audit reports. These audit reports were of good qual-ity and were generated as a result of corporate oversight of the site security program. The findings in these reports were minor and not indicative of any major programmatic problems.

The corrective actions were appropriate for the findings. .

, . 3.6.2.7 Records and Reports The Team reviewed various security records, logs, l

and reports, including patrol Ings, central alarm l station (CAS) logs, visitor control logs, and

, testing and maintenance records. All ree rds, i

logs, and reports reviewed were complete and maintained as committed to in the Plan.

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3.6.2.8 Testing and Maintenance The Team reviewed the testing and maintenance records and procedures. The review disclosed that the preventive maintenance procedures were comprehensive and that the licensee now has in-place a program that provides for prioritization of security maintenance by the security depart-ment. The maintenance support to the sacurity department has improvad as a result of the secur-ity. department assigning priority to the mainten-ance work. The use of compensatory measures for inoperative equipment is minimal.

3.6.2.9 Locks, Keys and Combinations The Team reviewed the installation, storage, ro-tation and related records for all locks, keys and combinations and determined that the licensee was meeting the commitments in the Plan and its implementing procedures.

3.6.2.10 Physical Barriers - Protteted Areas The Team physically inspected the protected area barriers. It was determined by observations that the barriers were installed and maintained as described in the Plan. Progress on upgrading the barriers is addressed in Section 3.6.2.1 of this section.

3.6.2.11 Physical Barriers - Vital Areas The Team physically inspected the' vital area bar-riers and determined that the barriers were installed and maintained as described in the Plan.

3.6.2.12 Security System Power,$upply The Team reviewed the security system power sup-ply system and determined that it was in accord-ance with plan requirements. The Team noted that as a result of the approval of a recent plan revision, improvements for protecting the secur-ity power supply are underway, w.th work expected to be completed by September 28, 1:88.

80 3.6.2.13 Lighting The Team observed lighting within the protectsd area. All areas were lighted in accordance with commitments .in the Plan. Progress on upgrading the lighting is addressed in Sectier. 3.6.2.1.

3.6.2.14 Compensatory Measures The Team reviewed the ifcensve's compensatory measures and determined that their use to be con-sistent with the commitments in the Plan. As a result of the security program upgrades addressed in Section 3.6.2.1, the need for compensatory measures for degraded security equipment has been dramatically reduced. Further reductions in the use of compensatory measures will occur as pao-ject upgrades are completed.

J.6.2.15 Assessment Aids Tne Team reviewed the Itcensee's use of assess-ment aids and determined by observation that the assessment aids are installed, functioning and maintained as committed to in the Plan. Progress

• on upgrading the assessment aids is addressed in Section 3.6.2.1.

3.6.2.16 Access Control - Personnel and Packages The Team reviewed the access control procedures for personnel and packages and determined that they are consistent with commitments in the Plan.

This determination was made by observing person-nel access processing daring shift changes,

. visitor access processing, and by interviewing security personnel about package access proced-ures. The status of upgrades in the access con-trol points is addressed in Section 3.6.2.1.

3.6.2.17 Access Control - Vehicles The Team reviewed vehicle access control proced-ures and observed vehicle searches at the Main

Vehicle Gate. It was determined that vehicle 1

searches were being conducted consistent with commitments in the Plan.

81 3.6.2.18 Detection Aids - Protected Area The Team observed penetration tests of approxi-mately 25% of the licensee's intrusion de:ection system on August 17, 1988. The remaining 75% was not tested during this inspection; however, pre-vious test records were reviewed and the records indicated that the system was operating as de-scribed in the Plan and implementing procedures.

3.6.2.19 Oetection Aids - Vital Area The Team observed the testing of intrusion detec-tion aids in selected vital areas and determined that they were installed and furetioning as committed to in the Plan.

3.6.2.20 Alarm Stations .

The Team observed the operation of both the Cen-tral Alarm Station (CAS) and the Secondary Alarm Station (SAS) and found them to be in accordance with Plan commitments. During tihe previous inspection (50-293/88-16), a concern was identi-fied thrt the licensee was diverting an alarm station monitor from security duty to respond to fire protection system and health physics alarms.

During the IAT inspection, the Team noted improvements in that there is a marked decrease in the number of nuisance alarms, as a result of the removal of the fire door and health physics doors from the security alarm system.

3.6.2.21 Communications The Team observed tests of all communication capabilities in both the CAS and the SAS. The

Team also reviewed testing records for the vari-

! ous means of communications available to security

!. force members and found them to be as committed to in the Plan.

I 3.6.2.22 Training and Qualification - Genera 1' Requirements The Team reviewed the licensee's Training and Qualification Plan and implementing procedures and determined that they were being implemented as committed to in sae Plan.

82 3.6.2.23 Safeguards Contingency Plan Implementation Review The Team reviewed thr, licensee's Contingency Plan and implementing procedures and determined that all exercises were being performed by the secur-ity organization as committed to in the Plan.

3.6.2.24 Protection of Safeguards Information The Team reviewed the protection and handling procedures for Safeguards Information (SGI) and determined that che licensee had completed an inspection of each office onsite that handled and stored $GI. The inspection results indicated that the SGI assigned to each office was accoun-ted for and was being stored in accordance with established licensee procedures.

3.6.3 Conclusions A comprehensive review of the ifcensee's security program determined that the licensee has established and is imple-menting a significantly improved security program ever that which existed when the station was shutdown in April 1986.

Upgrades'to the security program include.a greatly expanded proprietary security organization, major installation of state-of-the-art equipment, improved security maintenance support, and upgrades to plans and procedures. ,

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83 3.7 Trainino .

3.7.1 Scope of Review The Team assessed the scope, quality, and effectiveness of the licensee's training programs. Included in this review were the licensed and non-licensed operator training pro-grams and the programs for technical and general training of the plant staff.

3.7.2 Observations and Findings 3.7.2.1 Operations Training Operations Training Programs are outlined in PNPS .

Nuclear Training Manual, T-001, Part 3, and have '

received INPO accreditation. The Operations Training Programs include initial and requalif t-cation training

• for licensed operators, initial i and continuing training for non-iicensed opera-tors, Shift Technical Advisor (STA) training, and SRO certification training. The Team reviewed these programs and discussed various aspects of the programs with members of the licensee's training and operation's staff. The Team re-

,I viewed eight Operator and Senior Reactor Operator

, training records to verify compliance with Sec-tien 3.5.5 of the Training Manual. To evaluate the effectiveness of the training programs, the Team observed classroom and simulator training; interviewed licensed operators and senior opera-

tors, non-licensed operators and STAS; reviewed several training evaluation and feedback forms from classroom and simulator training conducted during the current requalification cycle; and .

observed ongoing operations in the plant.

! Overall, the Team determined that the Operations l

Training Programs are adequate and effective.

Classroom and simulator training observed ap-peared to be effective. Instructor preparation was good and the lesson plan content was com-plate. During observations of classroom training for PDC 88-07 involving the degraded voltage modification, the Team noted that the depth of knowledge being presented was adequate and stu-dont participation was encouraged. After obser-f ving the conduct of the annual simulator opera-l ting eram, the Team noted improved communications l

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84 between members of the operating crew. In addi-

. tion, the Team noted -t simulator examination was also being cbserved oy licensee upper manage-ment. Discussions with training and operations personnel confirmed that strong upper management attention and support for all aspects of the licensed training programs is evident. Inter-views with licensed operators indicated that i overall they are very satisfied that training programs are well-suited to their needs, and that the programs ar" responsive to their feedback.

Operators indicated that the training program has greatly improved over the past year with the i incorporation of simulator training into the

. requalification program.

Discussions with Operations Training staff indi-cated sufficient staffing to cunduct training programs. Thirteen instructors are currently receiving Senior Reactor Operator (SRO) certifi-

' cation training and are expected to be fully cer-tified by the end of 1988. The use of experi-enced pNpS instructors instead of contractors for the operations training programs should enhance the quality of the licensee's programs as well as  ;

contribute to the depth of in-house operational  !

expertise.

Recent additions to the licensed requalification program include the incorporation of Emergency Operating Procedure (EOP) proficiency training.

This includes at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> devoted to E0P review in the classroem and/or simulator during each 32-hour segment of the program. (Each oper-ator normally receives one segment of. requalifi-cation training every five weeks.) Also, the

exam structure at the end of each session has i been modified to include written and simulator l operating exams, which will aid the training -

staff in determining the effectiveness of the programs an a more frequent basis. In addition, the training staff appears to carefv11y track attendance in requalification training to assure that everyone required to attend is trained in each module of the requalification program.

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85 The operation's training staff appears to have a very effective working relationship with the operations department. They meet *o discuss training needs on a frequent basis. Through these meetings, the training department appears able to sufficiently track and schedule the licensed training either required or requested to be completed prior to restart. In addition, the operation's department often provided support during simulator examinations.

The Team reviewed the licensee's special training program for the sixteen licensed operators (14 RO's and 2 SRO's) who currently hold NRC licenses which are limited pending on-watch training dur-ing the Power Ascension Program.. The Team dis-cussed various aspects of the program with mem-bers of the licensee's training and operations staff. The Team noted that the licensee has established a structured and supervised program to assure completion of NRC requirements to allow

. removal of the individuals' license limitations.

Following a discussion with the Team regarding plant for ensuring that each operator performs a

' sufficient number of reactivity manipulations, the licensee representative stated that an at-tachment to the special program would be added'to

• further clarify what constitutes an . acceptable manipulation.

The Team observed the operations department staff on four days of consecutive shift rotation.

These observatiens verified the overall effec-tiveness of training. For example, on-shift communications, an area of emphasis in simulator training, was forfral and effective. However, during a walk-through with an equipment operator (non-licensed) of E0P Satellite Procedure 5.3.26, the Team noted several discrepancies in the pro-cedure. It also noted that the E0 and aa SR0 misunderstood a step in the procedure. Upon investigation of ihese problems, the licensee determined that a decisien to train only the E0's and no: the licensed operators on the field por-tion of the satellite procedures contributed to the misunderstanding. These issues are discussed in detail in Section 3.2.4.

86

. Additional Team followup of the problems found -

during the above-mentioned procedure walk-through identified a weakness in the licensee's method of determining the need for additional training on new procedures and procedure changes. The lican-see's current method incorporates review of ORC meeting minutes to determine newly approved pro-cedures or procedure changes requiring training.

However, a delay of 30 to 45 days is not unusual between the meeting and the distribution of for-sal minutes. For example, Procedure 5.3.26 had been revised since equipment operator training was conducted in March and April 1988. The ORC meeting minutes which addressed this procedure

. . change had not been received by the trajning

- department as of August la, 1988, 42 days after the ORC meeting on July 6,1988.

The Team discussed the issue with a licensee training department representative who stated

.that the department recogni:ed this concern and was preparing to implement, in October 1988, a more timely method for determining the needed training.

During the insoection, the licensee committed to accelerate implementation of certain features of the improved program, such that the training department will become aware of procedure changes within approximately one day following the ORC meeting. This will allow the training staff the opportunity to review the procedure changes and determine the need for training prior to issuance of the approved procedure. If the training

- department determines that training is required I

prior to issuance of the procedure, the depart-ment will have the ability to delay the proced-ure issuance. The licensee representative stated that an internal work instruction detailing this process was being written and would be approved by ORC within about a week. In addition, the

' training staff will review their backlog of ORC meeting minutes to determine which procedure changes have not been addressed and will take appropriate action. These actions planned by the licensee appeared very responsive to the Team's concerns.

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87 3.7.2.2 Technical and General Training Nuclear Training Manual, T-001, Parts 4 and 5, outline the licensee's technical and general training programs. Included are training pro-grams in maintenance, health physics, chemistry, fire brigade, emergency plan, suoervision, and technt:al training for staff and managers. The Team reviewed these programs and discussed var-ious aspects of them with members of the licen-see's training, technical, and supervisory staf f.

To evaluate the effectiveness of the training programs, the Team observed classroom instruc-tion; interviewed radiological controls and radiological chemistry (radchem) technicians, QA engineers and first-line supervision; reviewed classroom training evaluation and feedback forms; and' observed ongoing work in the plant Overall, the licensee's training programs were found to be adequate. Classroom training ob-served appeared to be effective and student participatiori was strongly encouraged. In-house staffing for those training programs appeared more than sufficient. The following relatively naw training programs are indicative of licensee initiatives to develop employee ski,lls:

apprentice programs for maintenance, health physics, and rad chem technicians; and, technical training for n6wly assigned supervisors.

. Additional training programs currently being developed in industrial safety and safety aware-

' ness, along with the licensee's CPR pro; ram, show the licensee's positive attitude in those areas.

The Team's observations of work in the plant dur-ing this inspection verified the overall training

• effectiveness. However, inadequacies in mainten-ance post-work testing appeared to be the result of lack of training for the maintenance planning group and first-line supervisors on the post-work testing portion of the new maintenance program (See Section 3.3.2.6).

88 3.'7.3 Conclusions The licensee's training programs appear to be very good.

Team findings in all functional areas indicated overall effectiveness of the training implemented. Examples of ,

areas where training may have needed to be conducted sooner include E0P satellite procedures and the post-work testing program. A weakness was identified in the licensee's method of determining training needed for new procedures and procedure changes. ,

The licensee appears to have made a strong commitment in the area of licensed operator training, as exemplified by increased staffing, simulator use in requalification train-ing, strong interface between training and operations man-i agement, and increased attention and support from upper management. In addition, the creation of new programs fer supervisors and apprentices reflects an effort by the licensee to effectively promote employee development.

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a I 89 3.8 Fire Protection 3.8.1 Scope of Review .

The Team's evaluation of the fire protection program i

focused on the saintenance of fire protection equipment, J the reliance on ecmpensatory measures for degraded equip-sent, and the performance of personnel on the fire brigade

and standing fire watches.  ;

3.8.2 Observations and Findings Licensee senior management estabitshed a station goal of

. reducing the number of open fire protection corrective I maintenance requests (MR's) to 40 from a high of 300. This i goal was reached in June 1988. This reduction is indica-

! tive of the overall improvement of the material condition of fire protection equipment and systems. The number of i MR's began climbing two weeks before the IAT inspection, i and reached 63 during the second weak of this inspecticn.

The increase was mainly for low-priority MR's.

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i Fire protection MR's are tracked as a station performance j indicator and this increasing trend received prompt senior ,

management attention. The licensea is currently contract , <

. ing to bring in additional fire protection maintenance sup- -

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- port by the end of August 1988. The fire protection man-

! ager meets daily with operations, maintenance and planning sections to schedule MR's and develop the station's work plan. The Team concluded that the licensee is giving j proper management attention to fire protection MR's.

(

There are over 5,000 fire barrier penetration seals at i PNPS. The licensee's tagging system has been effeutive in .

identifying these penetrations, with no untagged penetra-

• fons or degraded penetration seals observed by the Team, i t The number of fire watch postings has been reduced from 145

. a year ago to 45 prior to this inspection. Fifteen of ,

these remaining postings will be eliminated by changes to

the fire protection program which are currently being j i reviewed by HRC. Another twelve will be eliminated when  ;

i the Itcensee completes Engineering Services Request (ESR) ,88-339, "Alarm delays on non-vital CAS alarms." This ESR will provide a means to electronically monitor fire doors t

' without undue distraction of security personnel from their ,

l primary function. The remaining 18 fire watch postings are  :

due to degraded equipment for which repsirs are currently  ;

being planned.

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90 Because TS's allow one individual to rove and cover more than one fire watch posting, the number of people on shift conuitted to fire watch activities is substsntially lower than 45. Two personnel per shift are assigned to cover ,

these fire watches. In discussions with the Team, the fire watches appeared knowledgeable about their duties. The Team reviewed several fire watch postings in the plant and identified no cor.cerns. All fire watch rounds were com-pleted on schedule.

The Team observed the on-shift fire brigade respond to an unannounced fire drill. .The drill scenario was a simulated main transformer fire with a concurrent failure of the deluge system. The brigade leader developed a successful fire fighting strategy. The brigade members responded promptly in full fire fighting gear. Communications be-tween the brigade and the control room appeared to be ade-cuate. The fire brigade's first-litie supervisors observed the drill on their own irittative. The fire protection training instructor was also found to be knowledgeable and enthusiastic about the training program.

3.8.3 Conclusions Effective management by the fire protection manager and support by senior management are shown by the attention given to the material condition of fire protection equip-ment and reduced reliance on compensatory measures for degraded equipment. Comple>. ton of licensing actions and an ESR will further reduce the number of fire watch postings.

There is good identification and e.ontrol of fire barriers.

Personnel assigned fire watch and fire brigade duties are knowledgeable about their duties and perform them properly. '

The fire protection division is well staffed to meet program needs.

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91 3.9 Engineerino support i 3.9.1 Scope of Review .

NRC found licensee engineering support to be strong in the past two SALP reports. Because of this history of good performance, engineering support was not selected as a specific area of focus for this inspection. Instead, observations relative to engineering support were made by the Team while it inspected the other functional areas.

3.9.2 Observations and Findings

. The Team found that engineering support to the' facility is generally very effective. In particular, the Systems Engineering Division functions well to meet plant needs.

Also, engineering support to maintenance has imoreved and is enhanced by the improved maintenance work process and the effective performance of the maintenance engineers.

The Team noted that a number of technical issues, including some NRC open items, as well as licensee-identified items,- '

- require NED resolution before plant , restart. .They are being tracked and pursued for resolution by NED.

During tours of the control room, the Team noted the mini-mal use of certain human engineering features, such as color-codes, meter "banding" (e.g., marking of normal, alert, and fail positions on meter and gauge faces), and i system lineup memory aids. Based on discussions with NED personnel, the Team determined that the licensee performed  !

a detailed control room design review (OCROR) and received l l cocaents on it from the NRC Office of Nuclear Reactor Regulation. A supplemental Itcensco CCROR report is i

required four months after the end of the current outage.  !

Currently, the Itcensee's CCROR project has identified about 140 proposed human engineering improvements which are being evaluated and prioritized. A few were incorporated into design changes this outage. The Team noted that some of the remaining improvements were relatively simple, from an engineering perspective, but could significantly enhance control room human factors. The Team asked whether imple-mentation of some of these items could be accelerated rela-tive to the other, more complex items which may require more detailed engineering and a plant outage to install. j i

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The licensee inc'icated that these simple improvements, categorized by the licensee as "Paint-Label-Tape," are included in the current 1989 budget. The licensee also ,

committed to evaluate control room human factors during the Power Ascension Program ar.d to include an update regarding the schedule and scope of these "Paint-Label-Tape" items in their report to NRC at the completion of the Power Ascen-ston Program. The Itcensee was very responsive on this issue. The Team noted that (1) licensee personnel have ,

performed well in the simulator under NRC observation, and '

(2) there has not been any pattern of performance problems traceable to control room huWan factors. Thus, the Team

concluded that the licensee's approach to this issue is acceptable.

f i The Team reviewed the licensee's program for the control of transient materials. This review included the licensee's methods for identifying, tracking and removing non-perman-ent equipment such as tools, gas bottles, and scaffolding  !

located in plant areas where safety-rela *ed equipment is housed. The licensee currently assigns responsibility in this area to~the Systems Engineering Group (SEG). Station i

Instruction SI-5G.1010. "Systems Group Systems Walkdown and Area Inspection Guidelines," details the licensee's. program for controlling transient materials. Materials so identi-fied during weekly walkdowns by system engineers are docu- i mented and are either removed or their presence justified in writing. If the material is allowed to remain in the process building, a seismic missile hazard analysis is per- '

formed under Station Instructic, 51-5G.1015, "Potential Seismic Missile Hazard," and appropriate measures are

implemented to ensure that the materials are properly secured. The licensee is compiling a data base which i

, identifies transient materials which must be removed prior r l to startup. The program appears to be comprehensive and l j adequate. *

! Ouring plant tours, the Team questioned th'e licensee , con-1 corning the installation of splash shields and personnel barr: Us in the areas of safety-related instrumentation.

Specifically, the Team questioned the seismic response of the structures and the effect they may have on safety-related structures. ,;

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The fire water spray shield was installed during the cur-rint outage. This plant design change was processed under current licensee procedures which require a seismic response analysis prior to modification approval. Person-nel barriers installed during the mid-1970's recently had seismic analyses performed on their current configurations.

These analyses found them satisfactory.

Based on this information and on a review of licensee docu-mentation, the Team had no further questions.

3.9.3 Conclusions The Team concluded that engineering support continues to be effective and identified no weaknesses. The licensee has committed to evaluate potential near-term improvements in control room human engineering during power ascension testing.

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3.10 Safety Assessment /Ouality verification 3.10.1 Scope of Review. r i

The objective of this inspection was to evaluate the effec- l tiveness of the licensee's self-assessment programs. The inspection focused on determining whether these programs l contribute to the preventien of problems by monitoring and evaluating plant performance, providing assessments and findings, and comunicating and following up on corrective action recomendations. The inspection consisted of a documentation review, personnel interviews, and observa-tions of meetings and work.

3.10.2 Nuclear Safety Review and Audit Committee i

The Nuclear Safety Review and Audit Committee (NSRAC) is an l

independent body responsible for performing senior-manage-ment-directed reviews of activities affecting nuclear ,

l safety. The NSRAC reports to the Senior Vice President -  !

i Nuclear (SVP-N). Membership on the committee is composed 4

of senior licensee management personnel augmented by consultants. '

The Team reviewed the NSRAC procedures manual, Technical Specification 6.5.3, meeting minutes, audit reports, and associated NSRAC reports and correscondence. The Team also attended a full NSRAC meeting at the station on August 2, 1988.

A review of the committee meeting minutes for the period i

between Janu.ary 1987 and June 1988 verified that Technical Specification requirements have been met with respect to the composition, duties, meeting frequencies, and responsi-bilities of the committee. The compositiM and chartne of the committee was significantly revised u February 1988, i

The selection process for members was designed to assure a broad-based, independent review of facility activities and to minimize the potential for cost and schedule pressures to influence the committee's reviews and findings. The current committee is made up of ten members appointed oy the SVP-N. Of the ten members, five are consultants, in-cluding the Committee Chairman. Only two members of the 1

committee hold line responsibility for operation of the plant. Only one member, also a consultant, belonged a year ago. To enhance the perspective of the new membert. the licensee implement.e1 an annual training program. Tne Team was provided with a matrix indicating the experience of

95 current comittee members relative to Technical Specifica-tion requirements and verified the committee collectively possesses a broad based level of experience and competence.

The committee charter, as detailed in NSRAC Procedure 101-1, also does not allow the use of alternate members, although these are allowed by the Technical Specifications.

Af ter a review of recent membership changes, and discuss-tons with the NSRAC Coordinator, the Team verif ted that the collective competence of the committee membership has been maintained as changes were made.

NSMC currently conducts meetings approximately once a month. Since the beginning of 1988, seven meetings have bean conducted, six of which were held at the site. This is significantly more than the once per-six-months minimum required by the Technical Specifications. Three additional mer. tings are scheduled for 1988. In addition, individual succomittees may hold additional meetings at the site.

NSMC also intends to meet at the site in September with

'everal key members of station management to review restart preparations and plans to provide its own independent recomendations for restart readiness.

NSMC uses sub:cmittees effect;vely to review speci fic -

areas of interest. . Currently, six subcomittees are estab-lined: (1) safety evaluations; (2) operations /mainten-ance, (3) training / security / fire protection; (4) radiation control / chemistry / emergency preparedness; (5) quality over-view; and, (6) engineering / technical. Each subcomittee is chaired by a NSMC member, and is composed of additional personnel appointed by the committee. The subcommittees provide reports to the full comittee during their sched-uled meetings. The subcommittees are especially useful in performing documentation review to allow more time for open discussions at the meetings.

A stronger NSMC involvement in station activities is evi-dent net only in the recent site meetings and effective use of subcommittees, but also in scheduled site tours and audit participation. The NSRAC has established a schedule for individual comittee members to perform station tours and report the results to the full comittee. NSMC has also designated individual members to participate in se1ected QA audits throughout the year.

The Team reviewed selected audits conducted under the cognizance of NSMC, which are required by Technical Spe:tftcations. The audits reviewed were thorough, timely,

'and the noted deficiencief have been corrected or are being tracked. The audit reports reviewed included a third party assessment of the adequacy of the QA program, and QA sudits

. 96 of Technical Specifications, administrative controls, operations, chemistry, radiation protection, and inservice testing. In addition, special audits were recently con-ducted concerning shutdown from outside the control room, the salt service water system, and NSRAC activities.

The current committee has an effective formal tracking system for all "concerns" forwarded to management and com-sittee followup items. The "concerns" reviewed were clearly transmitted to the SVP-N. However, review of recent meeting minutes by NRC revealed that a number of "recommendations" had been forwarded to the SVP-N, but a formal response had not been received. The concittee also did not formally track resolution of these recommendations.

Further investigation by the NSRAC Coordinator determined that although the items had not been tracked, the specific recommendations had been implemented, or were incorporated

- into another corrective action process.

During NSRAC Meeting 88-04, conducted on May 24, 1983, the Operations anc Maintenance Subcommittee presented a. report on the conduct of the Operations Review Committee (CRC).

NSRAC raised concerns over whether the CRC was fully meet-ing the intent of its duties required in the Technical Specifications. The report identified four specific find-ings of deficiency. They included:

- Inadequate method of reviewing changes to safety-related procedures;

- Lack of ORC-prepared reports resulting from ORC inves-tigation of a Technical Specifications violations;

- Lack of specific review and reports of facility oper-ations by ORC; and,

- Lack of formality in tha conduct of ORC meetings.

After the discussion, NSRAC concurred that the ORC perform-ance issues should be formally raised as a concern to the SVP-N. The NSRAC concern (88-04-01) was transmitted to ths, SVP-N on May 27, 1988. The concern stated that NSRAC's overall assessment was that ORC's conduct and administra-tion needed substantial improvement. Specifically, the concern stated that the established process did not appear to foster acequate depth and discipline for substantive independent reviews. In addition, NSRAC noted that of the 40 meetings conducted in 1988 crior to che review, neither the Station Director nor the Plant Manager had attended, based on its review of the meeting minutes.

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

97 The NSRAC concern was responded to on June 22, 1988. In

- response, the Station Director initiated revisions to the ORC Charter and Procedure 1.3.4, "Procedures," to accur-ately describe the specific methods by which ORC met the procedure and operations review requirements. In addition, the Station Director attended an ORC meeting on June 22, 1988, and is considering additional initiatives to improve the conduct and administration of ORC activities.

NSRAC closed the concern at the August 2, 1988 meeting, but initiated a followup item to continue to monitor ORC per-formance. In addition, NSRAC members were encouraged to attend ORC meetings as observers. NRC's review of ORC per-formance identified similar deficiencies and concluded that additional actions to strengthen some ORC functions were warranted (See Section 3.10.3).

Based on meeting attendance and review of recent meeting minutes, the Team noted that the NSRAC reviews have been thorough and focused on improving performance in areas important to safety. During the August 2, 1988 NSRAC meet-ing, the Team noted that the discussions were frank and open, with the reviews concentrated on recurring and emerg-ing issues. The areas of emphasis have included 50.59 reviews, ORC performance, corrective action programs, pro-cedure adequacy, and management depth.

l Oue to the limited number of "concerns" issued by' NSRAC since revision of the committee in February 1988, the Team could not reach a conclusion on 'the responsiveness of the station organization to NSRAC. It appears at least in one case pertainina to ORC performance, that the response was not comprehensive. However, all other "concerns" reviewed ,

were responded to adequately.

3.10.3 Operations Review Committee The function, composition, and responsibilities of the Opercions Review Committee (ORC) are described in PNPS Technical 3pecification 6.5.A. In addition, PNPS Procedure 1.2.1, "Operations Review Committee," describes in greater detail the authority and responsibility of the CRC at the Pilgris Station. For this inspection, the Team reviewed o

the minutes of ORC meetings 88-40 through 88-63 (April 1,1988 through July 5,1988) and observed the con-duct of three regularly scheduled and two special ORC meet-ings (ORC Meetings 88-80, 81, 8,

. 83 and 86). In addition, the Team interviewed various CRC members and alternates.

98 The inspection focused on whether ORC operations satisfied current Technical Specification requirements; whether the ORC was meeting its responsibilities identified in PNPS Procedure 1.2.1, and whether the ORC was responsive to recommendations for isprovements identified during NSRAC and QA audits of its operations.

3.10.3.1 Compliance with Technical Specifications and Procedures By reviawing existing documentation, snd through direct observation of ORC meetings, the Team has determined that the Technical Specification requi r.ements for the ORC composition, quorum, -

. meeting frequency, authority, and reco-ds are being satisfied. During the period reviewed, the Team noted that the ORC reviewed plant proced-ure changes, plant design changes (pCCs), Field Revision Notices (FRNs), and Licensee Event Reports (LERs), as well as proposed revisions to 1 the security plan, to the inservice inspection

program, to the emergency plan and to fire pro-taction program implementing procedures. The ORC i

members and alternates are appointed by memor- '

andum from the Station Director and cannot serve on the committee until they have successfully  !

completed the station ORC training course. There i is also a required reading review program used by '

the Training Department a: a retraining program for ORC members and alternates. The Team re-viewed the training course material and deter-mined that it had an appropriate emphasis on assuring safe operation as well as on regulatory requirements. .

i The ORC at Ptigrim Station has been meeting  !

4 regularly every Wednesday and has a scheduled l "special" meeting every Friday on an as-needed j basis. The ORC met an average of about twice a week, which is well above Technical Specification requirements.

i

! While there was evidence in the minutes of dis-

> cussions about LERs, PDCs or FRNs, the prepond-erence of the minutes described changes to pro-

, cedures. The Team saw no reference of ORC reviews of Failure and Malfunction Reports. The t ORC has a system for following issues identified i during discussions which requires a formal response to the CRC and a review of the response by the CRC to assure snat the response resolved the initial concerns, l

i

1 99

- The Team reviewed the closecut process for ORC followup items and determined that, in one case, an item (88-58-01) may have been closed prema-turely. During a discussion among the Team, the ORC Chairman, the Design Section Manager, and the l Construction Division Manager, the ORC Chairman  :

agreed that the item should be reopened for addi-tional review. During ORC Meeting 88-82, the item was reopened.

By observing the ORC, the Team concluded that the committee members and alternates are concerned with assuring the safe operation of the facility. i Discussions focused on the impact of items on

- safety systems, as, well as whether the items. l being discussad met regulatory requirements or l constit'Jted unreviewed safety questions. The

$tation Director also attended one of, the regu-larly scheduled ORC meetings during the inspec- i tion period. '

. During its review, the Team identified two weak-nesses in the operation of the ORC. They are the Technical Specification (TS) review of plant  !

operations (T.S. 6.5 A.6.e) and the T$ require-ment to investigate violations and prepare a report covering the evaluation and recommenda-tions to prevent a recurrence (T.S. 6.5 A.6.1).

TS 6.5. A.6.e states that the ORC is responsible for the review of facility operations to detect potential safety ha:ards while TS 6.5 A.6.1 states that the ORC is responsible for investiga- r ting all TS violations and for preparing a report t covering the evaluation and recommendations to prevent a recurrence.

The Team noted that ORC routinely uses the review of LERs and Fatture and Malfunction Reports (F&MRs) to satisfy the TS required review of L plant operations and TS violations. The Team  ;

also noted that tha ORC has appointed the Compli- ,

ance Division as a subcommittee to.the ORC and (

assignea it the responsibility of presenting t selected Failure and Malfunction Reports as wel' as the preparation of all LERs, including any ,

I i

I

100 involving TS violations. Copies of all LERs are.

provided to the ORC as a means of satisfying the TS requirements. Further, PNPS Procedure 1.2.1 permits the ORC Chairman to set the time-liness of subcommittee reports to the full ORC.

While the use of subcommittees to support ORC activities is acceptable, the Team believes that the method used by ORC in fulfilling its respen-sibilities as defined by TS 6.5.A.6.e and i needs improvement. In particular, the Compliance

• Division has been issuing all LERs, including those discussing TS violations, prior to any ORC review of the product prepared. A review of 10 LERs disclosed that ORC review of the LER occurs usually a week to two weeks after the LER was formally sent to the NRC. While this may satisfy the timeliness requirements of PNPS Procedure

1. 2.1, i t does not appear that the corrective actions proposed to prevent recurrence receives

- the full benefit of a timely multi-disciplinary review, as is intended by the composition and responsibilities of the ORC. The formal release of the LER involving a TS violation by the. ORC subcommittee without a formal review by the com-plete ORC is a weakness in meeting the require-ments of T? f.5.A.C.1. .

Owing a review of FMRs, which had not yet been reviewed by ORC, the Team noted that FMR 86-266, which discussed a TS violation, had not yet been reviewed by ORC.

In this case, the violation was against an admin-1strative requirement in TS Section 6.8, and was not reportable as an LER. Therefore, the FMR did not result in an LER or a special report.

The event occurred in $sptember 1986, and no reports have yet been submitted to ORC as required by the TS. The licensee stated that the-FMR was still open pending completion of the remaining corrective action, and that then a

~

report would be issued.

Both of these findings indicate that the ORC is not actively participating in the timely review of plant operations and does not appear to pro-vide meaningful input into the process.

101 3.10.3.2 Responsiveness to Audit Recommendations The Team reviewed both quality assurance (QA) audit findings and NSRAC recommendaticas to deterstne ORC responsiveness to recommendations for improvement; to its operations. In QA Audit Repcrt 87-37, QA listed two recommendations accepted by the ORC. PNPS Procedure 1.2.1 was reviewed and the Team determined that PNPS Pro-cedure 1.2.1, Revision 21, contained the QA recommendations. The ORC was also audited by QA from May 22 through June 22, 1988. The audit generated one recommendation concerning the cross-referencing of ORC meetings with document references. Based upon discussions between the QA auditor and the Team, ORC has also accepted this recommendation.

In May 1988, the ORC received a li'st of four concerns from NSRAC based upon an audit review of the C?.C. While the nature of the specific con-cerns are. discussed in detail in Section 3.10.3

'above, they are summart:ed here. Specifically, the NSRAC expressed concerns about the following areas: (1) the ORC review of changes to safety-related procedures, (2) ORC investigation of TS violations, (3) ORC review of factitty opera-tions, and (4) conduct of ORC meetings.

The concerns related to the ORC's investigation of TS violations and its review of plant opera-tions are paralleled by the Team's findings dis-cussed in Section 3.10.3.1 above. .

The NSRAC concern with GRC procedure reviews is being evaluated for long-term improvements but no definitive action is currently planned by the licensee. As for NSRAC concern #4, the meetings observed by the Team, were conducted in a manner permitting formal and informal discussions of specific issues. A meeting agenda for regular ORC meetings was prepared and followed. The Team concluded that the meetings were conducted acceptably.

Based on the above, the Team has determined that, in general, the ORC has been receptive to recem-

' mendations for improvement. However, the fact that the NSRAC concerns remain unresolved sug-gests that the ORC may have difficulty addressing more complex recommendations.

1 102  ;

The Team also observed that the quality of the meeting minutes could be improved by providing more discussion of the issues by the various ORC members as opposed to providing abstracts of the l documents discussed, i Based upon 'a review of the ORC ar.tivities, the Team determined that thera are weaknesses in the implementation of responsibilities assigned to the ORC. In particular, the Team determined that

- weaknesses exist in the review of plant opera-tions and the investigation of T5 violations.

The Team has concluded that imprevenents in these two specific areas would result in a more effec-tive ORC. In resperise to the Team's concerns,  ;

the licensee agreed to take certain actions prior '

to restart to strengthen the operational focus of i ORC. These actions are: ' (1) to review plant incident critiques; (2) to review LER(s prior to their submittal to NRC; (3) to review FLMR's on a regular basts; and, (4) to provide for a monthly presentation and discusstori of plant operations 1 as a specific agenda item. The Team found these j . Itcensee commitments responsive to its concerns.

3.10.4 Quality Assurance Audit and Surveillance Programs The Team reviewed selected QA audit and surveillance reports, selecting specific findings, discrepancies, and i observations for followup of the licensee's corrective action process. QA personnel, including the CA Department (QAD) manager, and other station managers and engineers, were interviewed regarding the audit and surveillance pro-gram objectives and overall conclusions which can be drawn f rom the . audit and surveillance findings. The Team also reviewed the quarterly QA0 Trend Analysis report, and at-i tended several QA interface meetings. Po nions of the Boston Edison Conpany Quality Assurance Manual (BEQ41) and applicable station procedures were also reviewed, t The technical content and quality of the issues rai sd in the selected audit reports were excel 1Gn. The conduct of ,

a performance-based radiological controls suttit by outside 1

consultants was noteworthy. Specifically, the Team rc-viewed audits require under the cognirance of H5RAC, in accordance with the T5, and found that the i are being per-formed as required. The Team deteratied that all defici-ent.ies identified in the audits wera either closed or ade-Quately tracked by a formal system.

i

103 -

During the conduct of audits and surveillances, deficiency reports (DR) are issued by QA for conditions contrary to management policies and procedures, regulatory require-ments, or licensee commitments. A OR which reports a deficiency identified during a QA audit is issued at the time of the audit exit interview. The Itcensee has an effective system of requiring'a written response to the OR within a specified period, dependent on its significance, and for subsequent followup of corrective action. A system also exists for granting extensions through an escalation process to upper management.

QA prepares a monthly status report, including OR status, which is forwarded to senior management for appropriate actions. Review of the most recent QA trend report indi-cated a decline in the OR backlog, an increase in the num-ber of OR's completed on time, and few extensions needed for OR closecut. The number of deficiencies reported by QA remained fairly constant. These are all indicators that 1 licensee management attention to the corrective action process has had a positive impact.

The licensee also ef'ectively trends Immediate Corrective Actions (ICA), which are identified in audit and surveil-

. lance reports. These report conditions which could lead to a DR, but which are e.orrected prior to the end of the audit or surveillance. They alt.o are tracked along with the OR's. The Team also found the tracking of recommendations from the audits and surveillances to be effective.

Approximately 45 QA surveillance reports concerning obser-vations of surveillance testing were reviewed. The reports were well planned, well documented, and thorough. Again, the tracking and followup of identified deficiencies were adequate. A minor concern of the Team involved QA followup to identified procedural inadequacies during surveillances.

In ten of the surveillance activites reviewed by NRC, technical procedure deficiencies were identified by QA, but since the technicians being observed halted the test and pursued a procedure change, no deficiency reports were issued. Further review found that the majority of the pro-cedure deficiencies were identified prior to implementation of new procedure validation program, and that QA0 has an open OR on the procedure validation process. QA0 is con-tinuing to monitor the process. The Team had no further Concerns.

, . . l 104 Two QA Interface meetings were attende'd during the inspec-tion. The meeting attendees include representatives from

~

QA, plant staff, and engineering. They meet weekly to review the status of various corrective action items, including DR's, Management Ccrrective Action Requests MCARs) and Potential Conditions Adverse to Quality Reports. ,

PCAQ's). The meetings have improved communications among the organizations and have contributed to the more timely resolution of corrective action items.

3.10.5 Corrective Action Process and Programs The Team reviewed the licensee's programs currently in l place to identify, follow, and correct safety-related prob-l~ less. A newly formulated Corrective Action Program "Clear- ,

inghouse," and proposed revisions to corrective action pro-i cess procedures were also evaluated with respect to the i current objectives and planned initiatives to improve cor-  :

l rective action program effectiveness. Samples were chosen  !

from each of the programmatic areas where probles identift- i cation is routine and implementation of corrective measures

. is required. Each of these programs is discussed below.

The Team interviewed licenses personnel responsible for ,

individual program management and implementation, 'as well .

as the technical personnel accountable for problem dis- ,

position and corrective action adequacy. l l For all of the areas evaluated, the Team sought to deter-

! mine the effectiveness of the licensee's process for trot 6 cause analysis of problems, investigetton of problems nd j causes for their generic applicability, and trending of  :

i findings to prevent their cecurrence. Selected issues were  ;

l analyzed to understand the technical problems, check how  !

they were programmatically handled, and to determine ,

I whether the corrective measures were appropriate to the i i specific cases. The examples are cited ir the following [

! subparagraphs not chly to illustrate the scope of licensee l l activities inspected, but also to support the conclusions reached eega rdi'.g the corrective action program  ;

! effectiveness, t 3.10.5.1 Failure and Msifunction Reports i I

The Failure and Malfunction Report (F&MR) is a process by which failures, malfunctions, and i

! abnormal operating events are reported, evaluated  :

and corrected to preclude repetition. The pro- .

) cess is described in: Nuclear Organi:atior I t

r

f r

105 Procedure (NOP) 8305, the "Failure and Malfunc-tion Report Process;" pnp 5 Procedure Number  !

1.3.24, "Failure and Malfunction Reports;" and '

PNPS Work Instruction N8-3.2.12 "FMR Trend Analysis."

Team review of licensee procedures verified that responsibilities are established for the FMR '

process; reports are prioritized by safety sig- '

nificance; underlying root causes are evaluated; reports are tracked for completion of corrective -

action; and, trending for repetitive prdblems is performed. A report may be initiated by any licensee staff member for failures, malfunctions, and abnormal operating events identified during station operation. The Nuclear Watch Engineer

• ensures that adequate compensatory measures are  ;

implemented and the required notifications are performed. The Compliance Division Manager then recommends a lead group to perform the investiga-tion and performs a reportability review. The  :

appropriate department manager is responsible to '

ensure that the identified deviations are pro-perly resolved and that corrective actions are 1 planned and effectively implemented in a timely -

sanner. The department manager is also responsi-ble for the review and approval of the reporta-  :

bility, root cause analysis, corrective action  ;

plans, disposition, and final closecut. A rout t cause analysis is performed for those FMR's determined to be significant. The term "signifi-  !

cant" applies to a condition adverse to quality I which merits further evaluation , for cause and requires management attantion to preclude recur- i rence. The nonsignificant deviations are evalu-ated in a periodic trend analysis., ,

The Team identified several discrepancies in the  :

admin!stration of the FMR process. Procedure l 1.3.24 states th-st the Ccapliance Division Manager is responsible to present FMR's that are designated significant or important. to ORC. As discussed in Section 3.10.2, the Teps noted that the ORC meeting minutes for the previous six months did not record the review of any FMR's.

Further Team review found that a backlog of over  ;

i l

s = < - - - - - - - 4, ~ . , _ - - - _ _ . _ _ . - , , , . _ _ _ _ _ _ _ _ _ _

106 existed, and that no FMRs had been submitted to ORC since February 3, 1988, except for those associated with an LER. Some of the F#iR's involved events which occurred in 1986. The

?

Itcensee stated this was caused by personnel resource constraints. The Team also found two closed FER's which appeared to meet the criteria established in Procedure 1.3.24 for being submit-i ted to ORC, but which had not been submitted prior to closure. FMR's88-127 and 88-76 were not reviewed by ORC, but involved recurring con-ditions, which is a criterion for ORC review.

l In addition, many of the closed safety-related FMRs were, denoted not safety-related by the

' Watch Engineer during the initial review process.

This mis-classification; however, did not affect -

the processing and evaluation of the associated events for those FMR's inspected. ,

1

- The Team reviewed a Itsting of open and closed FMR's and evaluated a sampling of closed reports to determine the completeness and effectiveness of the corrective actions. The total number of

{ FMR's initiated has been increasing over the last few years. ' i licensee has attributed this j

increase to a het ted sensitivity of personnel to critical self-a ,sment and to the identifi-cation of potentially reportable or significant i events to management. The total number of open i

' FMR's has significantly decreased over the last year.

l; The root cause analyses performed for the FMR's reviewed were found to be of excellent quality.

1 Each analysis included an event description, probable cause, actions completed, recommended

! actions, and safety significance. The Systems l Engineering Group's impact on this important i

process has been positive.

The Team myiewed the latest FMR Trend Analysis Report, wnich covered the period July through I December 1987, and the applicable procedures.

a The Team noted that the station's Technical see-l tions did not specifically assign responsibility

{ for the report's proposed recessendations. Fur-i ther review found that this program deficiency l had been previously identified by the licensee and the NRC anc tnat the licensee had initiated corrective action. Specifically, a review of all previous trend report recommencations was per-formed by the licensee to cetermine their status.

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

. I 107 l j

The revtew was completed in July 1988, and 74% of the recommendations were corrected. The remain-ing items are currently being dispositioned by the licensee to ensure effective long-term cor-

. rective action. In addition, the licensee has revised the FMR procedures to include use of the Management Corrective Action Report (MCAR) as a vehicle for the Technical Section to report and correct negative tren6 identified in the re-ports. The most recent trend report resulted in the issuance of two MCAR's, which the Team revia.4d.

The Team also noted that the trend report focused

'

• its discussions primarily on individual problems rather than trend patterns and recurring fail-ures. The Team observed that *.he Technical Sec-tien would be more effective if it thoroughly evaluated trends and patterns, since 'the indi-vidual FMR itself is adequate to evaluate iso-lated problems. In addition, the report did not provide any detailed discussion of personnel

• errors or procedural failures, although there were a large number in the report.

3.10.5.2 Potential Conditions Adverse to Quality As described by PNPS Nuclear Organization Proced-ure (NOP) 83A9, "Management Corrective Action Process," the potential conditions adve-se to quality (PCAQ) report can be used by 6ey licensee

' member to document and report any actual or sus-pected conditions adverse to quality not reported by other report forms such as NCRs, ors, and FERs. In short, it is a process for anyone to

elevate a concern to management to assure that i

the concern will be evaluated and resolved, i

As implemented, PCAQs are written from one department to another or from one section to another within a department. For example, Oper-ations (NCO) could send a PCAQ to Engineering

, (NED) asking for an evaluation of a specific plant concition. In each case, the originating department 15 responsible for tracking each item 4

' to resolution. According to NOP 83A9, a PCAQ is not formally closed until the orig!nating depart-l ment is satisfied with the proposed corrective the corrective action has been action and implemented.

I

108 The Team reviewed a listing of open and closed PCAQ's and also reviewed a sampling of individual PCAQ's to determine the completeness and effec-tiveness of corrective actions. As of August 19, 1988, there were about 250 PCAQs awaiting resolution. Thera is currently no cen-tral tracking system for all PCAQs, although licensee management has begun initiatives in that area. In June 1988, the licensee began an effort to reduce the number of open PCAQ's and ta estab-lish a central tracking system for PCAQ's with the QAD. As part of this effort, each department '

is reviewing unresolved PCAQ's to evaluate each one's significance and its potential impact on , i restart. Based on discussions with responsible managers, the Team learned that QAD has completed l

its review and concluded that none of the unre-solved PCAQ's concern equipment operability issues or are of a significance level that re-quires action before restart. NCO has not com-plated its evaluation but expects to be finished within two weeks. NED has been implementing a routine review of each unresolved PCAQ and has  ;

been maintaining a list of PCAQ's needed to be r: solved prior to restart. The review of out-standing PCAQ's is an item on the restart check-i list maintained by the plant. Subsequent check-list review by ORC also provides a decision point in the process to assure that all necessary evaluations have been completed.

Based on the above, the Team has concluded that

' the licensee is assuring that each PCAQ is being

' evaluated for its nuclear safety and equipment operability impact relative to the planned 4

) restart of the plant and that all PCAQ's needed for resolution before restart will be identified.

l The ORC review of the PCAQ's on the restart I

checklist will provide another check to assure l

that resolution of PCAQ's needed for restart has '

occurred.

i

\ .

i l

- - - - .,,u---- --

-t-**"-m _s --v-- -y_W --m-wwNm----------v-"wew- + - - - + ' - - * - - m 7-, 9----- r--N* e -- - - -

109 The Team selected several cle' sed PCAQ's to deter-mine whether the proposed corrective action had satisfied the originating department's concerns and whether the corrective action was completed as required by station procedures. In general, all identified corrective actions described on the PCAQ's were completed; however, the documen-tation of the completed activity was, in many cases, limited and specific references were not provided. The Team stated that additional guid-ance on the level of documentation to be provided on the closecut portion of the PCAQ form could enhance clarity and auditability of the closure process. The Team also noted that the PCAQ sys-tem can allow ambiguity of PCAQ status in cases where a proposed action has been rejected by the originating office. For example. NEO rejected the response prepared by N00 to PCAQ NED-88-087.

A review of the N00 log showed the issuo resolved (Jvly 22, 1988), but further investigation with persons affected indicated that the response was t

! being rewritten and further corrective action was

! to be performed. The formal closecut process and status tracking for the PCAQ's needs improvement.

This finding parallels a similar finding of the QA Department contained in QA0 88-609, dated

' May 23, 1988.

3.10.5.3 Management Corrective Action Request I

The BEQAM and NOP 83A9. "Management Corrective Action Process," describe the purpose of the

Management Corrective Action Request (MCAR). The i MCAR is a two-part corrective action document used to

(1) perform a root cause analysis of j

significant conditions adverse to quality and develop preventive action plans; and (2) request management to implement selected action plans to l prevent recurrence of a problem. In lieu of a Deficiency Report, an MCAR may be used to report i

and resolve deficiencies involving process or i

policy issues which affect more than one depart-ment and for which management attention and direction is required. An MCAR may also be used

! for tracking long-term corrective actions related r

' tn nonconformance reports (NCRs) and PCAQ's or for identification of adverse trends identified through trend analysis programs.

I I 110 i

QAU is assigned administrative control for the

! MCAR process. QA0 logs the status, distributes

, copies, reports on delinquent MCAR's, and per-i forms the closecut. QA0 also reviews each MCAR where the responsible department is different from the issuing department to verify that the j assignment of the responsible department is aprrepriate.

f The Team reviewed the current status of cpen MCAR's and the administrative controls in place to track and promptly resolve MCAR's. The latest

. monthly status report, issued to the SVP-N on August 1,1988, from the QA0 Manager listed 30 i

open MCAR's. This list included two 1985 MCAR's and eight 1986 MCAP.'s. Approximately 40% of the MCAR's initiated since 1984 remain open.

) The licensee has previously observed that in-creased management attention is required to close

out MCAR's in a timely manner. Ter e umple, the most recent QA0 trend analysis report, issued on

! May 23, 1984, recommended that the SVP-N , initi-i ate action to closecut MCAR's QA0 85-2 and CAD

47-2, which address the large number of quality j problem reports issued for "failure to follow procedures" and "inadequate procedures."

Team a;tendance at so .41 QA Interface meetings I also noted that tnere is clearly increased management attention being directed to closecut l

- the longstanding MCAR's.

I i

The Team reviewed two open MCAA's to evaluate the

effectiveness of the process. MCAR 46-06, issued

- a in November 1987 involved recurring failures of the salt servict water (55W) pumps. The MCAR was i

issued as a result of an F&MR trend report find-i ing. The MCAR resulted in a detailed root cause l

analysis by a consultant and the developeent of a

long-term corrective action plan, which is not i yet complete. MCAR 84-02, issued in Jur e 1988, i

concerned programmatic inefficiencies in f.he pCAQ process. The licensee is actively wor ting on l

J developing an integrated list of the approxi-i mately 250 open pCAQ's with a current status (see l Section 3.10.4.2). This list is to be utilized to increase emphasis on closecuts. Review of l

these MCAR's did not identify any discrepancies in the process.

4

c

?

1 b 111 l 3.10.5.4 Clearinghouse Process The current procedure describing the corrective I action process is NOP 83A9, "Management Correc- l tive Action Process." This procedure discusses the responsibilities of the station departments  :

in resolving identified def tetencies and report-ing the trends observed. The procedure also (

describes the various types of reports or docu- t monts available to station personnel and specift-4 cally defines their use.

As a result of the self-assessment evaluations  :

and performance improvement plans, the licensee l determined that the existing corrective action  !

processes were very complicated and that a l J

streamlined process was needed that would provide i

an easy means of raising any concerns to manage- ,

. ment for resolution. A need was also identified l for a specific entity which could monitor the performance of the station organization in imple- l menting self-improvement recommendations, as well i l

- as provide the focal point for identified issues  !

to be placed into the appropriate plant correc-  !

tive action process. t j ,

I In June 1988, the "Clearinghouse" was established j to serve a number of needs. It was developed to i

i assure that the licensee's restart assessment

! team observations had been entered into the i regular corrective action process and, when l

) necessary, that all necessary paperwork was pre-pared for the ' resolution of any outstanding l

i items. As of this inspection. 69 assessment ,

items remain unresolved but have schedules iden- l for their completion. Responses for 1

tified i l j j approximately 49 additional items have not been received from the station orgeaitation. The j balance of the original 449 tiens have been listed as closed. The Team did not evaluate the ,

]

closecut process for any completed or closed items. . j i

i A second responsibility of the Clearinghouse was l

} to streamline the corrective action process. As l l

of this inspection period, revisions to the sta-  !

i tion procedures for improvements in corrective l action processes have not been made. The current ,

estimate for completion of the necessary proced- ,

! ure revisions was the end of August. l l

l

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

i l

112 While subject to revision during the required l station procedure review process, the following j is a discussion of the current licensee philos-  ;

ophy 'concerning potential moditication of the corrective action processes. The Team did not evaluate the effectiveness of these preposed in the overall corrective action changes programs.

The Ciearinghouse is currently revising three

, existing NCPs, creating a new NCP, and revising the BEQAM. The new NOP would define the role and responsibilitiec of the Clearinghouse, establish

• a new form for identifying real or potential

. plant problems, as well as for reporting empio s ee-identified concerns or self-assessment recommendations for plant improvements. The new form would provide a simple method for raising  ;

issues, concerns, or recommendations to station management. U, ion receipt of this ferm, the  !

Clearinghouse wov1d review the issue des:ribed and integrate the issue into the regular plant corrective action processes for resolution.

Another proposed change is a categorization of f all the existing corrective action processes  ;

identified in NOP B3A9 into th-ee groups. One  !

i group, identified as corrective action processes,  !

would include deficieray reports (OR), non-con- . l formance reports (NCR), management corrective  ;

action requests (MCAR), f ailure and malfunction repor ts (F&MR), .adiological occurrence reports  !

(ROR), security deficiency reports (SCR), and  ;

supplier finder reports (SFR). These processes l are used to identify and document plant defici- ,

encier and to provide a means of tracking the  ;

j resolution of identified problems.

?

l A second group of controls would be categorized I as norms) work control processes. This group  !

would potentially include maintenance requests  !

(MR), housekeeping services assistance (HSA),' i procedure change notices (PC), and engineering  !

services requests (ESR). ,

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113 The last group currently being proposed includes all recommendations or findings from the existing self-assessment programs. The information to b1 tracked in this group are recommendations for improving performance and would not be used to identify programmatic deficiencies. Any identi-fication of deficiencies would be tracked using one of the processes described in the first group above. Examples of the types of recommendations 4

to be tracked would be quality assurance audit i finditrgs and peer evaluator reports l Changes would also be required for NOP 84E1, Survice Request (ESR) Process," and "Engineering"Drawing NOP 84A7, Control," as well as the quality as sura.nce manual, in order to fully implenent tne revised program.

The licensee anticipates that all' necassary f changins to station procedures would be completed by the end of August, with formal implementation of the program changes within an additional 30 days.

3.10.5.5 Management Oversight and Assessment Team (WEAT)

In addition to the plant operations oversight provided by the ORC, the MO&AT also provides an oversight review of plant operations by the  !

nature of its responsibilities for overview of i restart activities. The MO&AT is composed of

! eight senior managers, which includes the Station Director, Director of Special Projects and Vice President Nuclear Engineering. The SVP-N acts as I the Chairman of the team. Further, three MO&AT members had been licensee managers prior to the -

arrival of the SVP-N, while the remaining man-agers joined the licensee subsequent to February 4 1987. ,

The MO&AT maintains its ove,rsight of restart-related activities and associated plant opera,-

tions through several self-assessment programs.

4 These programs include but are not limited to the  ;

j peer evaluator and management monitoring pro-grams. The Team noted that these programs were

! effective in evaluating plant activities.

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The Team determined that, in some ways, the -

responsibilities of the MO&AT parallels some of the responsibilities to review plant operations

assigned to the ORC. In addition, the Team determined that the current role of the MO&AT is

not credited by the ORC as a means of fulfilling its responsibilities to review plant operations, but it does provide a setciid, independent look at plant operations.

3.10.5.6 Engineering Service Requests (ESR's)

ESRs are tracking forms used by any licensee denartment to request engineering cssistance from the Nuclear Engineering Depart. tent (NED). Stand-ard practice within NED is to attach an ESR to all requests for assistance which may be already tracked under another corrective action tracking sy stem, such as OR's, PCAQ's, etc. This is done to provide a means for the NED to track and

' monitor the progress of its work. When an ESR is opened or received NED is to review the concern,

- determine a plan for resolution of the item, which would include an evaluation relative to plans for plant restart. Unless the issue can be resolved within 30 days, a response to the origi-nating department is to be provided within 30 days which describes the above. In discussions with the Team, a management representative of NED i'

indicated that this practice has not always j

worked as planned and that additional emphasis is l

being placed on assuring that the 30-day re-sponses are being sent in a timely fashion, i NED tracks all existing ESR's, determines what actions are required prior to restart, and rou-tinely evaluates the potential impacts of out-l standing ESR's on the planned restart of the plant. In each case where NED determines that

resolution of an ESR is not required to support NED prepares documentation to support re sta rtpo,'s i ti on .

that This documentation undergoes several levels of review, including the Section Manager, Depart.sent Manager and the Vice Prost-dent - Nuclear Engineering. Any open ESR asso-ciated with unresobed PCAQ's or MCAR's is also reviewed by the ORC as part of its assigned restart checklist review.

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Based upon discussions with NED personnel, the Team concluded that ESR's are adequately tracked and that upper management is routinely informed of potential problems in a timely fashion.

3.10.5.7 Human Performance Evaluation System The Team inquired as to the licensee's intentions in participating in the Institute for Nuclear Power Operations (!NPO) Human Performance Evalua-tion System (HPES) program. The program is intended to assist licensees in the reduction of human error by encouraging personnel to report actual or potential situations which keep a per-son from outstanding performance. The licensee has designated an HPES coordi- .or, who is in the ,

Training Department. The coordinator has been trained by INp0 and is currently preparing to implement the program. The coordinator has j

already become involved in the Incident Investi- l gation and Critique process, and has reviewed the r

. recent findings from the'Itcensee's ESF Actuation Tast. Force report. This program, once fully imple.mented, should provide additional valuable input inte the corrective action process.

3.10.6 Conclusions Overall, the Team determined the licensee's programs for safety assessment / quality verification to be adequate and '

improving. Based upon the areas inspected and examples raised, the Team concluded that: l

1. The Nuclear Safety Reviaw and Audit Committee is l actively involved in the oversight of facility opera- j

' tions. The committee is composed of experienced man-agers with diverse experience and provides clear and J

valid input to the SVp-N en safety-related activities.

2. Plant problems and deficiencies are being identified

. and entered into the appropriate corrective action system.

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3. There are effective, meaningful communications between the QA and plant operations departments, as well as  !

good systems engineering involvement in evaluation and resolution of problems. [

4. The weekly QA interface meeting has enhanced communi- 1 cations at the station and improved the process of  !

resolving open issues.

5. The operations Review Committee (CRC) has not been I

. reviewing plant operations effectively so that mean-o ingful input to iteensee management is being consist-ently provided. Recently, heavy emphasis has been -

placed on administrative reviews of procedure changes and modifications, r.ther than reviewing plant opera-tions. Also, ORC review of plant failure and malfunc-  ;

tion reports has neither been timely nor included all ,

t appropriate reports,

6. Multiple corrective action processes and multiple tracking systems detract from efficient functioning of the systes. This has been identified by the licensee and programs are being established to correct the known deficiencies, t

7. The tracking and closecut of PCAQ's and MCAR's have .

not been effective in the past. Also, a relatively large number of open PCAQ's exists. The Itcensee is .

taking action to resolve these probles.  :

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117 4.0 UNRh50LVED ITEMS e An unresolved ites is an item for which additional information is required in order to determine whether the item is acceptable, a violation, or a deviation. An unresolved item is discussed in section 3.4.2.2 of this

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118 ,

5.0 MANAGEMENT MEETINGS At periodic intervals during the inspection period, the Team Leader held meetings with senior facility management to discuss the inspection scope and preliminary findings. A final exit interview was conducted on

August 24, 1984. Attendees are Itsted in Appendix B. At the exit meet-i ing, the Team Leader described the preliminary inspection findings,  :

) including both the preliminary overall conclusions and the preliminary l findings and observations in each functional area. The Team Leader also confirmed Itcensee commitments at the exit meeting, Then the Team Manager .

discussed how the Team findings will be used in NRC Restart Assessment Panel activities. Also, the Regional Administrator outlined th: reasining step in the NRC staff process of ' evaluating Pilgrim restart readinesi and

! developing staff recommendation.

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l APPEN0!X A .

Entrance Interview Attendees Avaust 8. 1988  !

loston Edison Comoany ,

J. Alexander, Plant operations Section Manager l R. Anderson, Plant Manager  ;

H. Balfour, Training Section Manager

• R. Bird, Senior Vice President - Nuclear i F. Fanulari . Quality Assurance Department Manager D. Gt111spie, Nuclear Training Department Manager *

. R. Grazio, Regulatory Section Manager . 6 P. Hamtiton, compliance Division Manager '  ;

K. Highfill, Station Director .

J. Jens, Radiological Section Manager

• I E. Kraft Plant Support Department Manager R. Ledgett, 01 rector Special Projects  ;

D. Long, Security Section Manager  !

. A. Mortsi, Planning and Outage Department Manager E. Robinson, Corporate Communication Information Division Head  :

L. Schmeling, Program Manager  !

J. Seery, Technical Section Manager R. Sherry, Plant Maintenance 9ection Manager '

R. Swanson, Nuclear Engineer' s Department Manager '

E. Wagner, Assistant to Sen Vice President - Nuclear F. Wozniak, Fire Protection Division Manager United States Nuclear Reculatory Comission  ;

l F. Akstulewicz, Senior Technical Assistant, Policy Development and  !

Technical Support tranch Office of Nuclear Reactor Regulation (NRR)

R. Blough, Chief, Reactor Projects Section No. 3B, Division of Reactor .

Projects (ORP), Region I (RI)

5. Collins, Deputy Director, ORP, RI L. Doorfietn, Project Engineer, ORP, RI T. Oragoun, Senior Radiation Specialist Division of Radiation Safety  ;

. and Safeguards (DR55) -

M. Evans, Operations Engineer, Division of Reactor Safety (OR$), RI ,

J. Lyash, Resident Inspector, Pilgrim Nuclear Power Station, ORP, RI (

0. Mcdonald, Project Manager, Project Directorate I-3, NRR L. Plisco, Senior Operations Engineer, Division of License Performance t and Quality Evaluation, NRR W. Raymond, Senior Resident Inspector, Millstone Point, ORP, RI i L. Rossbach, Senior Resident Inspector, Indian Point Unit 2, ORP, R! L G. Smitn, Safeguards Specialist, OR5!, R!  ;

C. 'sarren, Senior Aesicent Inspector, P11gris Nuclear Power Station ORP, R1  :

b

Appendix A - Entrance Interview A-2 A*.tendees .

Commonwealth of Massachusetts P. Agnes, Assistant Secretary of Depart.aent of Pubite Safety P. Chan, observer

5. Shelly (MH8 Technic'al Associates, Inc.), observer ,

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APPEN0!X B Exit Interview Attendees

' August 24, 1988 1 loston Edtson Company J. Alexander, Plant Operations Section Manager R. Bird, Senior Vice President - Nuclear ,

F. Famulari, Quality Assurance Department Manager ,

D. Gillispie, Nuclear Training Department Manager R. Grammont, Deputy Maintenance Section Manager .

R. Gratio, Regulatory Section Manager ,

P. Hamilton, Co-pliance Division Manager

) K. Highfill, Station Director J. Jens, Radiological Section Manager E. Kraft, Plant Support Department Manager

' R. !.edgett, Otrector Special Projects ,

0. Long, Security Section Manager E. Robinson, Corporate Conaunication Information Divistor Head

L. Schmeling, Program Manager.

J. Seery, Technical ~ 5ection Manager R. Sherry, Plant Maintenan:e Section Manager R. Swanson, Nucleae Engineering Department Manager

5. Sweeney, Chief Executive Officer and Chairman of the Board E. Vagner, Assistant to Senior Vice President - Nuclear F. Wozniak, Fire Protection Division Manager United States Nuclear Regulatory Commission F. Akstulewicz, Senior Technical Assistant, Policy Deve1coment and Technical Support Branch, Office of Nuclear Reactor Regulation (NRR)

R. Blough, Chief, Reactor Projects Section No. 3B, Division of Reactor Projects (ORP), Region I (R!)

B. Boger, Assistant Director for Region ! Reactors, NRR

5. Collins, Deputy Director, ORP, RI L. Doerflein, Project Engineer, DRP, RI i

V. Little, Office of Special Projects, RI!

l J. Lyash, Resident Inspector. Pilgrim Nuclear Power Station ORP, RI

0. Mcdonald, Project Manager, Project Otrectorate (PD) I-3, NRR W. Raymond, Senior Resident Inspector, Millstone Point, ORP, RI L. Rossbach, 5entor Resident Inspector, Indian Foint Unit 2. ORP, RI l W. Russell, Regional Administrator, R!

C. Varren, Senior Resident Inspector, Pilgria Nuclear Power Station, ORP, R!

R. Wessman, Director. PD I-3, NRR

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f Appendix B - Exis Interview 8-2 Attendees Commonwealth of Massachusetts -

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P. Agnes, Assistant Secretary of Department of Public Safety P. Chan, Observer j G. Minor (MHO Technical Associates, Inc.), observer l

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s APPEN0!X C Persons Contacted R. Anderson, Plant Manager R. Bird, Senior Vice President - Nuclear F. Famulari, Quality Assurance Department Manager K. Highfill, Station Director E. Howard, Vice President - Nuclear Engineering E. Kraft Plant Support Services Manager A. Morisi, Planning and Outage Manager R. Swanson, Nuclear Engineering Department Manager

5. Sweeney, Chairman of the Board and Chief Executive Officer In addition, the Team interviewed a large number of managers (in:1uding virtually all section and division mansgars), engineers, supervisors, and craft personnel in each inspe: tion area.

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" APPEN0!X 0 Documents Reviewed 4

-

• PNPS, Nuclear Training Manual, T-001, Parts 3, 4 and 5 i

• PNPS, Special Post-$tartup Training Program, Approved August 9, 1984 1

'

• PNPS Technical 5pecifications 3

• Soston Edison Company Nuclear Mission. . Organization and Policy Manual ,

l

• Nuclear Organization Procedures

!-

• Material Condition Improvement Action Plan J

l

• Soston Edison Quality Assurance Manual 87-40, 84 02, f !

Audit 87-63, Reports -- Samplinf, 88-10, 48-20, review 87-3 87-49, f acluding 88-04, and 88-17the following:

i

• Potential Conditions Adverse to' Quality (PCAQ) Reports -- Sampling review including N00 87-84. NED 86-71, SED 47-255, 50 88-57, 50 88-58, 50 88-44, N00 88-120,

' N00 87 02, NOO 87-28, NED 88 047, SQ 84-59, 50 88-12

! NED 84-90, 50 88-55, and 50 88-22 j

• Management Corrective Action Requests (MCAR's) -- Sampling. review includ-j int' QA0 45-2, QAD 87-2, 84-06, and 88-02

• Licensee Event Reports (LER's) -- Sampling review includtng 87-21,84-004 thru 88-014,84-016, and 88-017

• Maintenance Requests (MR's) -- Sampling. review c19 ding 88-11-6,44-110, 88-10-179, 88-46-300, 88-14-16, 84-45-183, 88-45-181, 88-46-194, 88-10-24, 87-10-282, and 88-10-105, 88-10-69, 88 10-71, 88-10-80, 88-10-141,

! 87-10-283

• Maintenance Activities / Packages -- Sampling review including 84-3-26, l

88-19-109, 84-46-213, 88-10-86, 87-46-173, 88-13-20, 88 46-438, 88 2-12, 86-20-47, 88-45-152, 88-45-176, 88-3-62, 84-43-276, 44 45-190, 88-1-31, 88-14-16, 88-46-194, and 88-10-114

• Meeting Minutes for ORC Meetings 44-40 through 84-63 Failure and Malfunction Report 86-266 l .

• NEO, Procedure 16.03, "Corrective Action Program" l

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. Appendix 0 - Documents Reviewed 0-2

)

• QAD Trend Analysis Report for the First Quarter of 1988 - QA0 88-609 l l

• PNPS Work Instruction N8-3.2.12, F&MR Trend Analysis y l 1

• Memo from J. Seery to R. Gratto, Appointment of Compliance Division as ORC.

Subcommittee, June 23, 1988 i 1( f

• Memo from R. G. Bird to K. L. Highfill, N5RAC Concern from May 24, 1984 i

NSRAC Meeting - May 27, 1988 {

• Memo from K. L. Highfill to R. G. Sted, Response to N$4AC Action Ites 44-04 June 22, 1988 i

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• Memo from J. A. Seery to R. Flannery, ORC Meeting Minutes Distribution j

) List - dated May 6, 1988 l I

!

• Procedure 1.2.1, Operation Review Comatstee .

? I

• Procedure 1.3.24, Failure and Malfunction Reports

/

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• Procedure 1.3.2.6, Response to Deficiency Reports 1 '

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• Procedure 1.3.4, Procedures ,

• Procedure 1.3.33, Operating Experience Review -

[

• Procedure 1.3.37 Post Trip Reviews

!

• Procedure 1.3.34, Plant Performance Monitoring Program l

• Procedure 1.3.63, Conduct of Critiques and incident Investigations j

• Procedure NOP 83A9, Management Corrective Action Process  :

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• Procedure NOP 83A13, Deficiency Report Process

• Procedure NCP 83A14, Nonconformance Report Process

• Procedure N0P 84A!, Surveillance Monitoring Program

• Procedure NOP 84A11, Annual Independent Review of IEco's Quality Assurance l Program j

• Procedure NOP 85A1, Nuclear Organization Performance Monitoring and  !

Managreent Information Program l t

• Proceture N0p $$A1, performance Standa*ds and Evaluation Suidelines for Pilgr\m Station i

l

Appendix 0 - Documents Reviewed 0-3

• Procedure NOP 8305, The Failure and Malfunction Report Process

• Procedure NOP 8401, Operating Experience Review Program

.

• Procedure 1.4.5, PNPS Tagging

• Procedure 1.5.3, Maintenance Requests -

• Procedure 1.5.3.1, Maintenance Work Plan

• Procedure 1.5.7, Emergency Maintenance,

• Procedure 3.M.1-30, Post-Work Testing Guidence

• Procedure $!-MT.1000, Maintenance Section Manual

• Procedure 5!-MT.0501, Post-Work Test Matrices and Guidelines j

• Procedure 3.M.1-11.1, EQ Maintenance Process: Repair / Replacement

• Procedure 3.M.3-1. AS/A6 Buses 4KV Protective Relay Calibration / Functional Test and Annunciator Verification ,

• Procedure 3.M.3-8, Inspection / Troubleshooting Electrical Circutts

• Procedure TP 88-40, 480 VAC Contactor Testing

• Procedure TP 88-22 Pre-Operational Test of the New Degraded Voltage Relays and Mocified Lead Shedding Logic

• Procedure PW TM!-1, Post Work Test Matrix and Guidelines, Revision A

• Procedure 3.M.4-14 Rotating Equipment Inspection. Assembly and 01s-assembly, Revision 4, dated April 4, 1988

• Procedure 8.Q 3.4,115/250V DC Motor hntrol Center Testing and Mainten- t ance

• Procedure 2.2.85, Fuel Pool Cooling Systes .

• Procedure 3.M.1-15. Vibration Monitoring for Preventive Maintenance and Balancing, Revision 5 dated June 12, 1988

• Procedure 2.2.8, Standby AC Power System (Diesel Generators), Revision 20, dated January 13, 1988  ;

t

• Procedure ARP, Panel C39, Fuel Pool Cooling $ystes, Revision 0, dated i January 30, 1988 l t

• Procedure 2.2.83 Reactor Clataup System. Revision 22, dated June 20, 1998

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

4 Appendix 0 - Documents Reviewed 0-4 .

'

• Fire Watch Computer Listing, dated August 4,1988

• Fire Prot =ction Maintenance Request Computer Listing,cfated August 9, 1988 i

• Pilg.ia Station Performance Indicators, dated August 10, 1984 and August 17, 1988 ,

• Procedure 8.8.29. "Inspection of Fire Barriers," Revision 1

]

• Temporary Modification Log

• Temporary Modification Status Report to R. Anderson from P. Mastrangelo,

.I dated August 4, 1988

• Procedure 1.5.9, "Temporary Modifications," Revision 12 i q t

• Procedure 1.5.9.1, "Lif ted Leads and Juspers " Revision 0 Procedure 1.3.34. "Conduct of Operations" t

• Procedure 2.1.16. "Nuclear Power Plant Operator Tour," Revision 54

• ' ertime Ov Book j

• Procedure 1.3.67, "Use and Control of Overtime at PNP 5" s

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• Advance Overtime Requests for Week Ending August 6, 1988 l u

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• PNPS 1-ERHS-V!!!.5-4-0. Turbine Building shield Wal) Design l l

Conffdential Memo #13, to J. P. Jens from K. L. Highti11, dated i July 19, 1938, "Training Program for Radiation Protection Manager" (

i

• Procedure 6.1-209, "Radiological Occurrence Reports"  ;

, J

• Ratitological Work Plan for A and B Recirculation Puer 3eal Welds l  !

! e Procedure 6.1~012. "Access Control to High Radiation Areas"

]

• Select.ed RP Technician Training and Qualification Folders, lesson Plan, ,

Qui::es and Training Guides

• Selected Ractation Work Perstts from March 1988 to August 1988 [

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• Maintenance Request 87-20-34 i j j r

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I Appendix 0 - Documents Reviewed 0-5 f t

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. i i

• Procedure 8.M.2-1.E.3.4, "Primary Containment Isolation Logic Channel Test  !

! - Charnel 82." Revision 8, dated September 24, 1987 i i

i

• Procedure 8.M.2-1.5,7, "Group I Priaary Containment Isolation Valve Test-

{ ing," Revision 5. dated November 7, 1987  !

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• Procedure 8 M.2-8.2, "Calibration of AT5 Transmitters Rack C220.8," Revis- 1

ton 2, dated June 30, 1988 l

• Procedure 8.M.1-32.4, "Analog Trip System - Trip Unit Calibration - Cabt-1 not C2229-82 " Revision 5, dated April 4, 1988 -

l j

• Procedure 8.M.2-2.10.8.5, "Otesel Generator ' A' Initiation Iy Loss of Of f-  ;

5tte Power Logic," Revision 8, dated November 6, 1987  ;

i j

• Procedure 8.M.2-2.10.6.3, "0tesel Generator ' A' !nittition By Core Spray -

1 Logic," Revision 12, dated April 9, 1988 ,

)

• Procedure 3.M.3-1, "A5/A6 Suses 4KV Protective Relay Calibration / l

Functional Test and Annunciator Vertftcation," Revision 23, dated August 13, 1988 ,.

• Procedure 8.M.2-2.6.7, "RCIC Simulated Automatic Actuation," Revision 6, dated February 5, 1988 -

• Procedure 8.5.5.1, "RCIC Pump Operability and Flow Rate Test at 1000 plig," Revision 24, dated June 4, 1988

>

• Procedure 8.M.2-2.10.7, "RCIC Automatte Isolation System Logic," Revis-l ton ll, dated N6vember 7,1987 l

• Procedure 8 M.2 2.6.1, "RCIC Steam Line Hi Flow," Revision 13 dated

{

June 9, 1988

• Procedure 8.M 2-2.6.3, "RCIC' Steam L.i ne Hi Temperature," Revtston 12,

, dated July 17, '987 '

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• Procedure 8.M.2-2.64, RCIC Steam Line Low Pressure," Reviston 16, . dated j June 20, 1988 l'

• Procedure 8.M.1-32.5, "Analog Trip System - Trip Unit Calibration Cabines C2233A, Section A," Revision 2. dated December 7,1987 l

• Procedure 8.E.11. "Standby Liquid Control System Instrument Calibration,"

Revision 9 dated September 2,1987

• Procedure 8.E.13. "RCIC Systes Instrument Calibration," Revisten 14, dated June 26, 1988 L_

! Appendix 0 - Occuments Reviewed 0-6 i

• Procedure 8.4.1, "Standby t.iquid Centrol Pump Operability and Flow Rate Test," Revision 19. dated April 9, 1988 ,

l

• Procedure 1.8, "Master Surveillance Tracking Program," Revision 9, dated r i

August 15, 1984 l

• Prdcedure 1.3.36, "Measurement and Test Equipment," Revision 4, dated l 1 March 9, 1988

• Procedure 8.I.1, "Administration of Inservice Pump and Valve Testing,"

Revisien 4, dated August 15, 1986

• Procedure 8.I.3, "Inservice Test Analysis and Docurrentation Methods,"

Revision 6, dated May 11, 1988 l j Ora.<m:s 1

• PNPS Elementa ry Diagram MIN 34-9 (Revision E1): Primary Containment 1 Isolation Systes I

j

• PNPS Elementary Diagram M1N 28-12 (Revision E14): Primary Containment )

1 Isolation Systes  ;

l.

• PNPS Elementary Diagram MIN 36-7 (Sh.10, Revision E7): Primary Contain- .

i

! ment Isolation Syste.a .

!

• PNPS Elementary Diagram M1N 36-7 ($h.11, Revision E5): Primary Contain-

ment Isolation System j

• PNPS Elementary Diagran MIN 41-10 (Revision E2): Primary Containment Isolation Systes

• PNPS Elementary Otagram MIN 38-11 (Revision E2): Primary Contairment

Isolation Systes

• PNP 5 Elementary Diagram MIN 35-7 (Revision E4): Primary Containment Isolation System 1

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• PNPS Elementary Diagram M1G 11-11 (Revision Ell): RCIC System i

• PNP 5 Elementary Otagram mig 12-12 (Revision E5): RCIC Systes j ,

• PNPS Elementary Diagram MIG 14-9 (Reviston E5): RCIC System f

• PNPS Elementary Diagras mig 15-9 (Revisten E8): RCIC Systes l

i

• PNPS Elesentsey Diagram MIG 16-7 (Revision E5): RCIC Systra

• PNPS Elementary Diagram MIK 4-11 (Revision E10): Core Spray

l j Appendix 0 - Documents Reviewed 0-7 I

i i

• PNPS Schematic Otagram E-548 (Revision EO): Containment Atmosphere Isola-i tion Control

• PNP 5 Schematic Diagran E-34 (Revision E6): 4160V System Breaksrs 152-504 l and 152-604

• PNPS Schematic Diagram E-15 (Revision E3): 4160V Auxiliary Relays and i

Miscellaneous Schemes

• PNP 5 Schematic Diagram E-27 (Revision E7): Olesel Generator i

• PNP 5 Schematic Diagram E-17 (Revision E7): Schematic Metar and Relay j . Diagram 4160 Volt Systea i

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• PNP 5 Schematic Diagram M6-22-14 (Sh.1; Revision Ell): Diesel Generator "A" X107A Engine Control I

• PNP 5 Relay Setting Drawing E5-200 (Sh.1. Revision E3): 4160 Volt Switch-gear Relay Settings

• PNP 5 Relay Setting Drawing E5-200 (Sh. 3, Reviston E2): 4160 Volt Switch-4 gear Reity 5ettings

) ,

• PNP 5 P&!D M245 (Revision E13): RCIC System, Sh. 1 ,

• PNP 5 P&!O M246 (Revision E10): RCIC System, Sh. 2

• PNP 5 P&!O M249 (Revision E12): Standby Liquid Contro, System i

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APPEN0!X E IAT! Compositten and Structure Team Manager Samuel J. Collins Team Leader A. Randy llough Technical Assistant Clay C. Warren Administrative Assistant Mary Jo OtDonato operations Lawrence W. Rossbach (Lead)

Shift Inspsetors Lawrence W. Rossbach W1111am J. Raymond Loren R. Pitsco Lawrence T. Doerflein Francis M. Akstulewicz Radiologi al Controls Thomas F. Dragoun Maintenance Jeffrey J. Lyash William J. Raymond surveillance Lawrence T. Doerfietn -

Security Gregory C. $sith Fire Protection Lawrence W. Rossbach Assurance of Quality Loren R. Pitsco Francis M. Akstultwict l Training and Management Daniel G. Mcdonald Effectiveness Michele G. Evans Report Coordinatoe, Tae X. Kim Coer.onwealth of Steven C. Shelly Massachusetts (Ctservers) Pamela M. Chan

a -- .

e APPENDIX F .

NRC Integrated Assessment Team Inspection (IATI)

Members Resumes This appendix shows IATI summary resumes of the team members and Common-wealth of Massachusetts observers. The resumes outline the nuclear experience of team members. .

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Appendix F F-2 ,

NAME: FRANCIS M. AKSTULEWICZ ORGANIZATION: United States Nuclear Regulatory Commissio, Office of Nuclear Reactor Regulation Policy Development and Technical Support Branch TITLE: Senior Technical Assistant EDUCATION: B.S., Nuclear Engineering ,

EXPERIENCE: Fourteen Years of Nuclear E4perience as Fo11cws:

Two and One-Half Ye4rs - Shielding Engineer - Bechtel Power Corporation One Year - Technical Analyst - Office of Material Safety and Safeguards (NRC)

Eight Years - Nuclear Engineer - Office of Nuclear Reactor Regulation (NRC)

Two Years - Project Ma,'ager - Haddam Neck Plant, Office of Nuclear Reactor Regulatian (NRC) 0,ne-:talf Year - Present Position SPECIAL QUALIFICATIONS: Completion of NRC Fundamental and Advanced BWR Systems Training Course and BWR Simulator Course SPECIAL ASSIGNMENTS: Member of Fire Protection, Health Physics and Diagnostic Team Inspection at Haddam Neck 4

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T Appendix F F-2 NAME: A. RANDOLPH BLOUGH ,'

ORGANIZATION: United States Nuclear Regulatory Commission, Region I Division of Reactor Projects TITLE: Chief, Reactor Projects Section No. 3B EDUCATION: B.S., U.S. Naval Academy. 1973 (Graduated with Honors)  :'

Navy Nuclear Engineer Jr Course, 1977 NRC Inspector Techt.:t (raining Program, 1980 Various technical and management courses in USN and USNRC, such as QA, Reactor Engineering, Reactor Safety, Supervis-ing Human Resources EEO,, Management Workshops EXPERIENCE: Fifteen Years Nuclear Experience as Follows:

1985-Present United States Nuclear' Regulatory Commission (USNRC) --

Reactor Projects Section Chief. Manage safety inspection programs for three commercial reactor facilities. Super-vise nine nuclear engineers. Provide formal assessments of '

utility management effectiveness and safety performanet.

1982-1985 USNRC -- Senior Resident Inspector at operations phase and preoperational phase nuclear power plants. Planned, super-vised, and performed inspections of management controls and

. activities important to nuclear safety. Coordinated specialist inspector efforts. Formally reported findings and recommended appropriate enforcement.

1972-1982 USNRC -- Resident Inspector. Planned, performed, and docu-mented inspections of all functional areas at a dual-unit operating reactor site. ,

1973-1979 U. S. Navy Nuclear Power Program. Duties included super-visory positions in nuclear plant operations, ' maintenance and training. Performed audits and coordinated plant self-assessment. Was responsible for a complex, in plant nuclear training program for up to 300 students. Shipboard duties included Main Propulsion Assistant: responsible for all reactor and main propulsion systems, all radiological controls and plant chemistry. Collateral duties included QA Of ficer, and Nuclear Weapons Safety / Security Of ficer.

SPECIAL QUALIFICATIONS: Qualified BWR Inspector, NRC Region I, 1980 Qualified Nuclear Engineer Officer, Naval Reactors,1977 SPECIAL ASSIGNMENTS: Team Leader, NRC Integrated Performance Assessnment Team Inspection Oyster Creek, 1987 Team Leader, NRC Team Inspection of Oyster Creek Contain-ment Vacuum Breakers Event, 1987 Participated in various other plant readiness inspections, 1984-1985

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Appendix F F-4 ,

i NAME: PAMELA M. CHAN ORGANIZATION: Massachusetts Energy Facilities Siting Council (Since 12/87)

TITLE: Engineer / Utility Analyst EDUCATION: B.S. M.E. Pennsylvania State University EXPERIENCE: Five Years Nuclear Experience as Follows:

1987 United States Nuclear Regulatory Commission, Region III, Reactor Inspector 1985-1987 Nuclear Power Services - Construction 1984-1935 Combustion Engineering - Nuclear Systems Services; Field Service Engineer -

1982-1984 Stone & Webster Engineering Corporation - Power Division System Engineer - Turbine Plant Systems SPECIAL QUALIFICATIONS: Background in Maintenance and Quality Assurance SPECIAL ASSIGNMENTS: Participated in several team inspections while at NRC Region III l

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Appendix F F-5  :

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NAME: SAMUEL J. COLLINS , l ORGANIZATION: United States Nuclear Regulatory Commission, Region I Division of Reactor Projects ,

4 TITLE: Deputy Director EDUCATION: Bachelor of Science, Maine Maritime Academy Business Program, Southern Vermont College EXPERIENCE: Seventeen Years Nuclear Experience in Design, Construction,

. Operations, Inspection and Management as Follows:

1987 - Present Deputy Of rector: division of Reactor Projects, USNRC, .  !

Region I  ;

1986 - 1987 Deputy Director (Detail): Division of Reactor Projects, USNRC, Region I As a member of the Senior Executive Service, responsible for division management; the conduct of inspections and evaluations of assigned NRC programs for all power and non power reactors within Region I.

1985 - 1986 Branch Chief: Reactor Projects Branch No. 2 USNRC, Region I Responsible for project management, staffing and budget considerations, including inspections, implementation of -

SALP, resident inspection and enforcement for eleven

. assigned power reactor sites in operation and under construction.

1984 - 1985 Section Chief: Reactor Projects Section No. 2C, USNRC,

, Region I Responsible for implementation of the routine and reactive inspection program at six assigned p6wer reactors during new construction, testing and operation.

1983 - 1984 Senior Resident Inspector: Operations, Yankee Nuclear Power Station, ORP, USNRC, Region I Supervised; inspection and event respo,nse program at opera-ting Westinghouse PWR power reactor facility.

1980 -1983 Resident Reactor Inspector: Operations, Vermont Yankee Nuclear Power Station, ORP, USNRC, Region I. Field inspector at operating General Electric BWR power reactor facility.

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1 Appendix F - Samuel J. Collins F-6 Private Industry: ,

1971 - 1980 Tenneco Corporation, Newport News Shipbuilding. Various

• positions as contrAci.or to U.S. Navy Nuclear Program including: .

1 Project Manager - S5W Steam Generator Chemical Cleaning  !

Project Chief Test Engineer - Chairman and NNS representative to Joint Test Group for S5W overhaul and construction Shift Test Engineer - Shift supervisor for reactor overhaul and refueling Shift Test Engineer - Shift supervisor for' reactor new construction Mechanical Test Engineer - Shift nochanical test for reac-tor new construction Reactor Design Engineer - Design support for reactor new construction SPECIAL QUALIFICATICNS: Senior Executive Service Candidate Development Program.

USNRC, 1986 - 1987 .

Qualified BWR Resident Inspector Qualified PWR Resident Inspector Qualified 55W Shift Test' Engineer Third Engineer License, USCG SPECIAL ASSIGNMENTS: 1968 - Team Manager, Pilgrim Integrated Assessment Restart Team Inspection 1987 - 1988 - Chairman, Pilgrim Restart Assessment Panel 1987 - 1988 - Region I Representative, NRC Training Ad-visory Group 1987 - Chairman, Differing Professional Opinion Peer Review Group 1987 - Chairman, Comanche Peak Task Usrce Review Group 1986 - Team Leader, Nine Mile Point 1 and 2 Diagnostic Team Inspection 1985 - Team Leader, Peach Bottsm 2 and 3 Diagnostic Team Inspection

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l Appendix F F-7 NAME: LAWRENCE T. DCERFLEIN ORGANIZATION: United States Nuclear Regulatory Commission, Region I Division of Reactor Projects TITLE: Project Engineer EDUCATION: BS Electrical Engineering US Naval Academy, 1973 EXPERIEN;E: Fifteen Years Nuclear Experience as Follows:

Aug. 1985-Present Project Engineer Oct. 1933-July 1985 Senior Resident Inspector, Fit: Patrick Nuclear Power Plant Nov. 1980-0ct. 1980 Resident Inspector, FitzPatrick Nuclear Power Plant June 1973-Oct. 1980 US Navy SPECIAL QUALIFICATIO.N"J : Certified NRC BWR Inspector

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Qualified Chief Naval Ntclaar ingineer-SPECIAL ASSIGNMENTS: Limerick Readiness Assessment Team Pilgrim Augmented Inspection Team l

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Appendix F F-8 NAME: THOMAS F. ORAGOUN ORGANIZATION: United States Nuclear Regulatory Commission, Region I division of Radiation Safety and Safeguards TITLE: Senior Radiation Specialist EDUCATION: Rensselaer Polytechnic Institute, and Union Co ege D00 , Staff College, Battle Creek, Michigan EXPERIENCE: Twenty-Three Years of Nuclear Experience as Follows:

1983-Present NRC - Senior Radiation Specialist 1933-1969 General Electric Company, which included the following:

- Qualified as Operations Engineer and E00W at Navy Prototype (3 Years)

- Senior Engineer on Trident Prototype Construction Project (5 Years)

- Health Physicist responsible for service work, both domestic and foreign by Large Steam Turbine Division (6 Years) 1965-1969 Cornell University - Taught Radiation Protection Subjects 9

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Appendix F F-9 NAME: MICHELE G. EVANS ORGANIZATION: United States Nuclear Regulatory Commission, Region I Division of Reactor Safety TITLE: Op~erations Engineer EDUCATION: B.S., Chemical. Engineering, University of Pennsyivania EXPERIENCE: Four Years of Nuclear Experience as Follows:

Aug 1987-Present Operations Engineer, Boiling Water Reactor Section - Con-du:t review and inspection of Power Ascension Programs at Pilgrim ana Nine Mile Point 2. Currently in training to qualify as BWR Operator Licensing Examiner July 1984-Aug .1987 Reactor Engineer,'lest Programs Section - Conducted review and inspection of preoperational test programs at Hope

• Creek and Nine Mile Point C, and Startup Testing Programs at Limerick 1. Sheriham, Hope Cieek and Nine Mile Point 2.

SPECIAL QUALIFICATICNS: USNRC Certified BWR Inspector Engineer in Training (State of Pennsylvania)

SPECIAL ASSIGNMENTS: Curer.ntly participating in the Women's Executive Leadership Program for Management Development O

Appendix F F-10 NAME: JEFFREY J. LYASH ORGANIZATION: United States Nuclear Regulatory Commission, Region I Division of Reactor Projects TITLE: Resident Inspector - Pilgrim Nuclear Power Station EDUCATION: B.S., Mechanical Engineering, Orexel University EXPERIENCE: Six Years Nuclear Experience as Follows: ,

Two and One-Half Years - NRC Resident Inspector - Pilgrim Nuclear Power Station One Year - NRC Resident Inspector - Hope Creek Generating Station One Year - NRC Reactor Engineer - Region I One and One-Half Years - Pennsylvania Power and Light Company - Test Engineer - Suscuehanna Steam Electric Station SPECIAL QUALIFICATIONS: Meritorious Service Award as NRC Resident Inspector cf the Year 1987-1988 b

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a Appendix F F-11 NAME: DANIEL G. MC00NALD, JR. ,

ORGANIZATION: United States Nuclear Regulatory Commission (USNRC) -

Office of Nuclear Reactor Regulation TITLE: Senior Project Manager EDUCATICN: B.S., Management, Shenendoah College A.A., Engineering, Solano College EXPERIENCE: Thirty-One Years Nuclear Experience as Follows:

1982-Present Senior Project Manager - Manage and coordinate all NRC licensing functions on assigned operating reactor facil-1 ties which have difficulties or complexities with manage-ment and operation. (NRC) 1982(3 Months) Reactor Ergineer (Instrumentation) - Technical evaluations of instrumentation and control systems or licensee appli- ,

cations and operating reactor modifications. Assist in developing regulatory requirements and establishing staff policy. (NRC) .

1980-1982 Staff Member - Conduct, direct and coordinate assessments of critical technologies in the context of national secur-ity. provide technical support to the Nuclear Regulatory Commission. (Los Alamos National Laboratory) 1979-1980 Reactor Inspector (Electr.ical) - Inspects reactors under construction and in operation. (NRC) 1978-1979 Senior Electrical Engineer - Technical evaluations of electrical, instrumentation and control systems. Assist in developing staff policy. (NRC) 1973-1978 Reactor Engineer (Instrumentation) - Technical evaluation for license applications and operating reactors. (NRC) 1966-1973 Senior Technical Associate'- Field engineer in nuclear weapons test programs. (Lawrence Livermore Laboratory (LLL))

1964-1966 Senior Electronte Engineering Coordinator - Design of con-trol, interlock and instrumentation systems for critical assembly machines, test reactors and containment vaults.

(LLL) 1960-1964 Electronics Designer - Design of communication, personnel warning, closed circuit TV and radiation monitoring >

systems. (LLL)

O Appendix F - Daniel G. M: Donald, Jr. F-12 1957-1960 Senior Electronic Technician - Fabricated and assisted in the design and development of prototype electrical and electronics equipment. (LLL)

I 1953-1957 Electrical Specialist - Four yeaa apprenticeship with Department of Navy. (Mare Island Shipyard) l l l

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Appendix F F-13 NAME: LOREN R. PLISCO ORGANIZATION: United States Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Licensee Performance and Quality Evaluation TITLE: Senior Operations Engineer EDUCATION: B.S., Systems Engineering, U.S. Naval Academy EXPERIENCE: Eleven Years Nuclear Experience as Follows:

1987-1988 Senior Operatiens Engineer, NRC:NRR 1986-1987 Senior Resident Inspector - Susquehanna Steam Electric Station

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1983-1986 Resident Inspector - Susquehanna steam Electric Station 1982-1983 Reactor Engineer, Region I 1977-1982 US Navy Nuclear Power Program SPECIAL QUALIFICATIONS: Certified NRC BWR Inspector Qualified Naval Nuclear Engineer Officer SPECIAL ASSIGNMENTS: Susquehanna 2 - Operational Readiness Assessment Team Inspection Limerick 1 - Operational Readiness Asssessment Team Inspec-tion

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Hope Creek - Operational Readiness Assessment Team Inspec-tion Salem - ATWS Inspection TMI Management Integrity Inspection l

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Appendix F F-14 NAME: WILLIAM J. RAYMOND ORGANIZATION: United States Nuclear Regulatory Commission, Region I Division of Reactor Projects TITLE: Senior Resident Inspector - Millstone Nuclear Power Station EDUCATION: B.S. Physics M.S. Nuclear Science and Engineering EXPERIENCE: Eighteen Years Nuclear Experience as Follows:

1975-1988 NRC Reactor Operations Inspector

- SU&T, Core Physics, Refueling, Pre & SU&T for BV, CC1, IP3, MP2 i

- Project Inspector - Boaver Valley, Ginna and Susque-

, hanna -

- TMI Recovery Team - Accident Response and Containment Entry

- Senior Resident Inspector - Vermont Yankee and Mill-stone 1972-1975 Startup Engineer, Babcock & Wilcox, Oconee 1 anc 2 and Three Mile Island, Unit 1

. 1970-1972 Reactor Operator, VPI Research Reactor l SPECIAL QUALIFICATIONS: VPI Reactor Operator License Certified NRC Licensed Operator Examir.er - 1986 SPECIAL ASSIGNMENTS: IAEA Assist Visit to Bra:11 CNEN - 1981 Team Leader Salem ATWS Event - NRC Fact Finding - 1983 Salem ATWS Generte Issue Review Team - 1983 NRC Response to Crystal River Event - 1981 Assist Visit to Region V - WNP2 Startup Readiness - 1982 Team Inspections - Shoreham 1982 and Pilgrim 1986 Operator Briefings of TMI Event - 1979

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1 Appendix F F-15 NAME: LAWRENCE ROSSBACH ORGANIZATION: United States Nuclear Regulatory Commission, Region I Division of Reactor Projects TITLE: Senior Resident Inspector - Indian Point Unit 2 EDUCATION: B.S., Nuclear Engineering EXPERIENCE: Sixteen Years of Nuclear Experience as Follows:

Six Years, NRC Resident Inspector and Senior Resident Inspector Two and One-Half Years, Program Manager for NRC's prepara-tion to review a high level waste repository license application Two and One-Half Years, NRC Proje:t Manager and Reviewer for Uranium Mills Five Years, Systems Design Engineer at Architecturat Engineering -(AE) Company 9

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Appendix F F-16 s l NAME: STEVEN C. SHOLLY ORGANIZATION: MHB Technical Associates (Observer for the Commonwealth of Massachusetts TITLE: Associate Consultant EDUCATION: B.S. in Education (1975); Graduate Course Work in Geo-environmental Studies (1976-1977)

EXPERIENCE: Seven and One-Half Years Nuclear Experience as Follows:

1985-Present NHS Technical Associates, San Jose, CA - Work in Risk Assessment, Quality Assurance, Operating Events Analysis, and Design and Construction Assessment 1931-1935 Union of Concerned Scientists, Washington, D.C. - Work in generic safety issues, risk assessment and emergency p'anning SPECIAL ASSIGNMENTS: - Member of NRC Peer Review Group, NUREG-1050 (1984)

- Participate'd in NRC Containment Performance Design Objective Workshop (1986) ,

- Participated in NRC/LLNL Workshop on Safety Goals Implementation, Presentation on Seismic Risk Assessment (1987) o

Appendix F F-17 NAME: GREGORY C. SMITH ORGANIZATION: United States Nuclear Regulatory Commission, Region I Division of Radiation Safety and Safeguards TITLE: Safeguards Specialist EDUCATION: B.S. Education, California State College Various additional courses including: Technical Writing, Quality Assurance Auditing, Statistics, Reactor Design and Layout, Radiological Accident Assessment, Radiological Emergency Response, BWR Technology, Transportation of Radioactive Materials, Advan'ced Neutron Nuclear Materials Assay, Safeguards Chemical Analysis of Nuclear Materials, Nondestructive Assay of Nucl-*, Materials, Nondestructive Assay of Fissionable M.cerial, Accident / Incident Investigation and Intrusion Detection Systems EXPERIENCE: Twenty-Two Years Nuclear Industry Experience as Follows:

1977-Pre:ent Safeguards S;ecialist, Physical Protection Inspector and Safeguards Auditor (USNRC) 1966-1977 Westinghouse Electric Corporation, Bettis Atomic Power Laboratory - Production Engineer, Nuclear Materials Aud-itor, Nuclear Materials Analyst, Reactor Development Technician l

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l Appendix F F-18 NAME: CLAY C. WARREN .

ORGANIZATION: United States Nuclear Regulatory Commission, Region I Division of Reactor Projects TITLE: Senior Restoent Inspector - Pilgrim Nuclear Power Station EDUCATION: B.S., Natural Sciences,'Louisianna State University Industrial: 1986 - USNRC Inspector Qualification Program 1985 - Training Program on the General Electric BWR-6 pro-duct line and received NRC Senior Reactor Operator License 1982 - GE Boiling Water Reactor (BWR) Senior Reactor Oper-ator Certification training at the General Electric BWR Training Center 1980 - Shif t Test Engineer training program at General Dynamics Corporation. Electric Boat Division. Successfully completed the Naval Engineering Officer exam admi'ntstered by Naval Reactors.

Military: Navy Nuclear Prototype Training Navy Nuclear Power School Electronics Technicians School ,

EXPERIENCE: Fifteen Years Nuclear Experience as Follows:

Jan 1987-Present United States Nuclear Regulatory Commission, Senior Resident Inspector Jan 1986-Jan 1987 Resident Inspector June 1984-Jan 1986 Shift Supervisor, Gulf States Utilities Company, River Bend

• Nuclear Station Jan 1981-June 1984 Control Operating Foreman, Gulf Sta*.es Utilities Company, River Bend Nuclear Station June 1979-Oec 1980 Shift Test Engineer, General Dynamics Corporation, Electric .

Boat Division Jan 1971-June 1979 Electronics Technician - Reactor Operator, United States

• Navy SPECIAL QUALIFICATIONS: USNRC Senior Reactor Operators License

t Appendix F - Clay C. Warren F-19 SPECIAL ASSIGNMENTS: Nine Mile Point 2 Operational Readiness Assessment Team ,

Inspection Peach Bottom - Special Team Inspection March 1986 I

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UNitansTATES A "

y e

[ "*%\ NUCLEAR REGULATORY COMMIS$10N RtGION i I* 47s ALLEN 0ALs moAD KING of PmusslA.PeNNeYLVANIA todel ,

...* 0i SEF 1988 . .

The Commonwealth of Massachusetts Executive Office of Public Safety ATTN: Mr. Charles V. Barry One Ashburton Place Boston, Massachusetts 02108

Dear Mr. Bar y:

This refers to our letter of July 13, 1988, regarding the Conconwealth of Massachusetts' participation in the Integrated Assessment Team Inspection '

(IATI) conducted at the P,ilgris Nuclear Power Station.

As the NRC Senior Manager responsible for the inspection, I would like to ac-knowledge the conduct of the designated state representatives Ms. Pamela J. Chen and Mr. Steven C. Shelly as being professional and contributing to the perfor-mance of the inspection.

The established protocol (enclosed) provided to you on June 1,1988, clarified by our letter of July 13, 1988, and discussed directly by myself with Mr. Peter Agnes of your staff on August 9,1988, provides for collection and coordination of the concerns from the various interests within the Commonwealth.

As stated in our July 13, 1988 letter, the NRC placed the burden on the Comon-wealth's representative to present the many views, be they from the local governments or from the State's Attorney General's office, to the NRC for censitieration during development of the inspection scope. In this regard, we understand that Mr. Agnes conducted a public meeting on August 4, 1988, witn a designated state representativa to the IATI present.

On August 9,1988, having received no issues from the Comenwealth as an additional input to the existing inspection plan, I contacted the Assistant

Secretary of public Safety directly anc' was assured that

no formal input to the IATI inspection plan would be submitted by the Commonwealth, the Commonwealth would work through the desig.$ated representatives for any issues and that issues brought to the Comonwealth's attention were no different than those previously noted. Also, the team leader has notified me that at no time during the inspection did he receive immediate notification of any different state observation or conclusion as would be called for under Protocol ,

Guideline 3 if any such differences were identified during the inspection.

51nce the IAT! exit meeting conducted on August 24, 1988 which was attended by Mr. Agnes and Ms. Chen, the Cosmonwealth,has espressed on several occasions both to the media and at pubite meetings that technical issues and management 1

concerns continue to exist. These statements appear inconsistent with the 1

Cosmonwealth's response to repeated NRC requests for IAT! inspwetion scope

input and moreover inconsistent with the Commonwealth views expressed at the IATI exit meeting.

In order to better understand and address the areas of concern, the NRC requests that in accordance with the protocol agreement accepted by the i

Cosmonwealth, as provided for by Guideline 3, that the Comonwealth make

available in writing those conclusions or observations that are substantially different from those of the NRC inspectors in order that the NRC can take the necessary actions to meet its regulatory responsibilities.

__ _ _N l_I_2 ' 5 ~

S FP '

t G-2 Mr. Charles V. Barry 2 0i SEF G88 It is necessary that the Commonwealth's response be provided to the NRC Region I by September 6,1988, to be considered in conjunction with the documentation of the results of the recently :ompleted IATI. This request was discussed with Mr. P. Agnes of your staff on August 26 and August 31, 1988.

If you have any questions regarding the above matters, pleasa ecstact me at (215) 337-5126 or the State Liaison Officer for Region I, Ms. Marie Miller at (215) 337-5246.

Sincerely, M eputy Director

. Division of Reactor Projects

Enclosure:

As Stated cc w/ enc 1:

R. Bird, Senior Vice President - Nuclear K. Highfill, Station Director R. Anderson, Plant Manager J. Xeyes, Licensing Division Manager E. Robinson, Nuclear Information Manager R. Swanson, Nuclear Engineering Department Manager The Honorable Edward J. Markey The Honorable Edward P. Kirby The Honorable Peter V. Forman B. McIntyre, Chairman, Department of Public Utilities Chairman, Plymouth Board of Selectmen Chairman, Ouxbury Board of Selectmen Plymouth Civil Defense Director

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

, 5. Pollard, Massachusetts secretary of Energy' Resources R. Shinshak,, MAS $PIRG Public Document local Public Document RoomRoom (POR) (LPOR)

Nuclear Safety Information Center (N51C)

NRC Resident Inspector Commonwealth of Massachusetts (2) bec w/ enc 1:

Region ! Docket Room (with concurrences)

$. Callins, ORP J. Wiggins, ORP R. Blough, ORP i L. Doerficin, ORP i R. Bores, ORSS

0. Mcdonald, PM, NRR

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G-3 ENCLOSURE .

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Guidelines for Accompaniment on the Integrated Assessment Team Inspection i

The following are guidelines for accompaniment during NRC's Pilgria Integrated Assessment Team Inspection.

1. The observer is to make arrangements with the licenses for site access training and badging.

2. The observer snall be available throughout the inspection and will accom-pany NRC inspectors. Communication with the licensee will be through the appropriate NRC team member, preferably the team leader.

3. When the conclusions or observations made by the Consoonwealth of Massachusetts observer are substantially different from tho'se of the NRC inspectors, Commonwealth of Massachusetts will make its observations immediately known to the inspection team leader and available in writing to the NRC and the licenste, in order that NRC can take the necessary actions to meet its regulatory responsibilities. These communicatiens will be publicly available, similar to NRC inspection reports.

4. NRC inspectors are authorized to refuse to permit continued accompaniment by the Cosmonwealth' of Massachusetts observer if his conduct interferes with a fair and orderly inspection.

5. The Coassonwealth of Massachusetts observer in accompanying NRC inspectors will not normally be provided access to proprietary information. No license saterial may be removed from the site or licensee possession without NRC approval.

6. The Cosmonwealth of Massachusetts observer in accompanying the NRC inspectors pursuant to these guidelines does so at his own risk. The NRC will accept no responsiblitty for injuries and exposures to harmful substances which may occur to the accompanying individual during the inspection and will assume no liability for any incidents associated with the accompaniment.

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APPS DIX *i w ,. _

c e v.smy s,mm, Ok980/3M8G ordke

& afd u L et f $ $$c S k 13adsie/Xs Of/Od' GC MdCflJ September 6, 1988 Gamuel J. Collins, Deputy Director Divisi'on of Reactor Projects N.R.C. Region One 475 Allendale Road King of Prussis, Pa. 19406

Dear Mr. Collins:

This is in reply to your letter dated September 1, 1986, completed the regceding IATICommonwealth's inspection.at Pilgrim participation in the recently Station.

The Commonwealth's observers, Mr. Gholly and Ms. Chan, generally concur with the findings of the IATI team. The Commonwealth's observers followed the prescriptions of paragraph three of the *0uldelines For Accompaniment on The

. Integrated observations, Assessment concerns Team Inspection

• by communicating their and comments about matters considered during the inspection to appropriate N.R.C. personnel during the inspection. The only additional comment we wish to add about the IAT: at this time is a recommendation by Mr. Sho11y, that in view of the difficulty in one case with implementation of a satellite ECP, that there should be an effort to validate all new plant procedures before restart. Any specific reaction we may have to the written IATI report will, of course, have to await our review of the document. -

However, as I pointed out during the recent S.A.L.P.

meeting, the Commonwealth re.9erves the right to disagree with the conclusions drawn by the N.R.C. or the licensee aoout the IATI findings. Por example, notwithstanding what sight be considered un.nistakable evidence of progress by Soston Edison Company, the Commonwealth remains skeptical of the licensee's readiness to restart at this time. In addition to our concerns about offsite emergency peeparedness which have been outlined recently in letters to Mr. Henry Vickers of P.E.M. A., Regional Administrator William Russell, and to the A.C.R.$. Ad Hoc Subcommittee on the restart of Pilgrim, the Commonwealth is concerned that mediocre scoreo by the licensee during the last mw c o w l

H-2 sanuol Collino, N.R.R.

September 6, 1988 Page Two  ;

s.A.L.P. period coupled with a history of poor performance by the licensee have not been taken seriously enough in the staff's evaluation of readiness to restart. If the licensee is unable to achieve S.A.L.P. scores that even equal the national average for licensed commercial nuclear power plants in this country while Pilgrim remains shutdown, why should we believe that the plant is ready to restart?

Some of our other concerns, which transcend the scopo of the IATI, are outlined in our letter to the A.C.R.O., a copy of which will be forwarded to you tomorrow.

We appreciate your acknowledgment of the professionalism exhibited by Mr. Sholly and Ms. Chan during the IATI and the cooperation extended to them by the team members and the licensee. -

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.e. W. Agnes, Jr.

Asaistant Secretary of Public Safety hj PWA/cas k

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. 4 TABLE OF CCHTENTS JURI3 DICTION AND-1NTRODUCTION Jurisdiction 1 Description of the Petititioners 2 Intrduction 3 STATENENT OF THE FACTS

!. MANAGEMdNT

1. Licensee's Management of Pilgrim is Deficient 5

2. Licensee has Failed to Correct Management Deficiencies  ?

3. Deficiencies in the Area of Plant Operations 8

4. Deficiencies in the Area of Radiological Controls 9

5. Deficiencies in the Area of On-Site Preparedness 14

6. Deficiencies in the Area of Maintenance and Modifications 15

7. Deficiencies in the Area of Surveillance 16

8. Deficiencies in the Area of security and Safeguards 19

9. Deficiencies in the Area of Refueling and Outage Management 20

10. Deficiencies in the Area of Liciansing Activities 21

11. Deficiencies in the Area of Fire Protection 21

12. Deficiencies in Licensee Management Manifest in All its Endeavors 23

13. statement of Law as it Applies to standards of Management 23 II. IMERGENCY HESPONSE PLAN

14. Deficiencies in the Radiological Energency Response Plan 25

15. Deficiencies in Advance Information 26

16. Deficiencies in Notification During an Accident 27

17. Deficiencies in Evacuation Plans 27

18. Deficiencies in Medical Facilities 28

." 19. The Energency Planning Zone is Too Small 29

20. Lack of Coordination and Prioritization of the RERF 30

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!!!. CONTA!NMENT STRUCTURE

21. Inherent Design Flavs of Pilgrim's Containment Structure 32 i APPEND!XES Appendix A Table 5, Inforcement Data (SALP report 650-293/85-99) A-1 i . Appendix 3: Table 7, Plant shutdowns (SALP report $50-293/45-99) 8-1 i Appendix C Pilgria Station Regulatory Performance History C-1 l ',

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UNITED STATE 8 0F AMERICA

.,_ BEFORE THE NUCLEAR REGULATORY C0KMISSION PETITION FOR 290W CAUSE CONCERNING PILGRIM I NUCLEAR POWER STATION JURISDICTION AND INTRODUCT!0N Jg Jurisdiction This petition is flied pursuant to 10 CFR F2.206 and 10 CTR F2.202. The action

" requested is that an order be issued to the Boston Edison company to show cause as to why the Pilgrim ! Nuclear Power Station station (' Pilgrim') should not remain closed and or have its operating license suspended by NRC unless and t tti that time at which S the licensee demonstrates conclusively to the NRC and the publict (1) that its management is no longer hampered by the deficiencies noted by the petitioners heretn; (2) that the Radiological Emergene) Assporte Plan fully complies with 10 CFR 750.47 and 10 CFR 750.57, is given high organizational priority and sufficient funding by the licensee, the Federal Emergency Managecent Agency (FEdA), the Massachusetts Civil Defense Agency (MCDA) and local governments; and (3) that the inherent design flaws ,

. N noted by petitioners herein--._

which render Pilgrim I's containment strucM W 6 Fiem7e 7~ t

__f vulnerable in most accident scenarios have been overcome to the extent that the public health and safety will be assured.

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'1 The material which follows demonstrates that there is not reasonable assurance that Pilgrim ! can be safely operated due to numerous deficiencies in licensee

, management, the inadequacy of the existing Radiological Emergency Response Plan (RIRP),

and inherent deficiencies in the Facility's containment structure. The deficiencies

discussed in detail below cut a broad swath across the spectrum of safety requir e ments . It alght be argued that one or more of the deficiencies taken individually does not pose an intolerable risk. In the aggregate, however, they ,

thoroughly compro21se the reliability of the most important safety systems in the plant

- and destroy the fundamental principle of defense-in-depth espoused by the NRC.

Both the Pilgrim ! licensee, Boston Edison Company, and the NRC staf f have failed to resolve these safety issues which have arisen repeatedly throughout the plant's history.

This petition is !!1ed with the Director of Nuclear Reactor Regulation a*. the

. licensee is currently shut down. Therefore, it is vital that the Director addrea:s and resolve these safety issues before the licensee is granted a fira date for resusption ,

of iperations.

In the face of the information presented herein, failure to institute proceedings pursuant to 10 CFR 72.202 by the Director would violate its statutory undate to ensure

. the public health and safety.

.l e

Descriction of the Petitigng u Williaa 8. Colden is a Massachusetts State Senator repr,esenting Cohasset, veymouth, Duxbury, Hingham, Hull, Marshfield, and Scituate. Frank M..Hynes is a Massachusetts State S.Tw'WM'cepresenting Scituate and Marshfield. Barbara A. Hildt is a Massachusetts StateQiWMW representing Amesbury, Newburyport and Salisbury. These legislators have *xpressed their concern for their constituents within and around the Plymouth Emergency Planning Zone by involving themselves in the  :

1ssues surrounding nuclear power in the Commonwealth and particularly in their assistance in producinng this petition.

4 The Massachusetts Public Interest Research Orsup (MASSPIRG) is a non-profit l citizens group concerned with safe energy, environmental issues and consumer

! protection. MA33P!RG has over 96,000 citizen senbars and over 75,000 student members throughout Massachusetts. Approximately 2,000 citizen members live in the plume exposure Caerlency Plaaning tone for Pilgria and approximately 7,000 live on Cape Cod 4

for at least patt of the year. Because of its concern for the safety and health of the public and the environment, MASSPIRO has long been involved in the issues of nuclear power, especially with regards to the plymouth nuclear facillt/. In 1977, MASSP!RO '

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ublished a study of e=ergency responso plans in Massachusetts entitled "Nuclei /

l Evacuation ?lanning: Blueprint for Chaos" and in 1983 follcwed it with an updated study  ;

entitled "Blueprint for Chacs II: Pilgrin Disaster Plans Still a Disaster." Since then, MASSPIRG has represented the public interest in public hearings and debates en the issues of nuclear power.

i

, The Ply =outh County Nuclear Informatien Cc==ittee, Inc. (PCNIC) is a non-profit Massachusetts corporation with a principle place of business at 50 Congress St, Beston, MA 02109, care of William S. Abbott, Esq. PCIIC is composed of approxi=ately 300 se: bars who reside in and around Sly:cuth County. PCNIC was incorporated in 1974 for the purpose of educating the public with regards to the ha:ards, risks and operating characteristics of various applications of nuclear energy, to partici; ate in licensing hearings and other ad=inistr tive and legal proceedings involving the use of nuclear energy, end to encourage parties licensed by the Nuclear Regulatery Cc= issien to fulfill their obligatiens to the public. Proc 1974 to the present, PCNIC has participated in nu=erous regulatory and licensin3 pecceedings regarding the Pilgrim I statien, and the Pilgrim II statien (subsequently cancelled by 3esten Edicen).

The Ply =outh Alliance ic 2 citi: ens' crganizatica based in Ply cuth Mass achusett s. Motivated 'ty a concern fer the health aric welf tre er the cec unity, its goal iJ the establish:ent of safe energy alternatives. Ir order *o achieve this, the Alliance strives to promote public awareness through education and democratic action, r Jo Ann Shotwell and James M. 3hannen are both candidates for Massachusetts State t

L Attorney General.

The remaining signatories of this petitien are ;ublie efficials, organi:ations and t citicens of the Cocconwealth who are concerned with the issue cf centinuing operatien of the Pilgri: nuclear facility by the licensee and who endorse the relief requested by the ratitteners herein, s

intreductien The three =ain issues raised herein have to do with Besten Idis:n's sanage:ent cf plant ope =ations, the Radielegical Energency .: 'cnse Plan (RCRP), and the Pilgrim f acility's ;tysical etructure. 3, t

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Part I (sections i through 13) of the statement of the Facts refers to manifestations of the licensee's deficient plant management. The management-related technical and organizational problems listed therein by plant functional area are already known to the NRC, since they are largely culled from NRC inspection reports.

As such, they are not pesented as specific violations whose past or ongoing presence at Pilgrim in themselves should warrant a plant shutdown; indeed, some are being dealt with by the licensee under close NRC scrutiny. Rather, they are symptomatic of the long history of Boston Edison's incompetence as the manager of a nuclear facility. The +

most recent SALP report and the April 2, 1986 special inspection report demonstrate NRC's grave concern with the overall quality of Boston Edison's management. As the reports indicate, every year's round of NRC inspections, each of which covers only a fraction of the facility's mechanical and organi:aticnal functions, uncover a plethora of new management-related problems. The reports note that many of the specific problems are not resolved by the licensee in a timely fashion or, in some cases, not at  !

all. Recurring problems in such areas as staf fing, self-identification of problems, management oversight of operations and attitudes toward problems, equipment f maintenance, radiological controls, and sutvaillance testing, despite repeated promises by the licensee to resor1ve them, indicate a history of mismanagement and an incapability by Boston Edison to maintain the standards of safety that are required of a nuclear operator. Thus, its continuing operation of the Pilgrim plant poses an  !

extreme'ly serious and unacceptable health and safety threat to the citi: ens of the commonwealth. ,

f Part !! (sections 14 through 20) detail the failure of TEMA, MCDA and Boston '

Idison, to develop a Radiological Emergency Response Plan (RERP) that can be given ,

final approval by the NRC. By law, this in itself should be enough to warrant the f suspension of a nuclear faellity's operating license. However, given Pilgrim's .

s.anagement deficiencies and their threat to safe plant operations, this lack of an

?

acceptable emergency plan should be of even greater concern to the region'a public officials and citi:enry. The fact that the NRC has granted interim approval of ,

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~,-.-y.wr-,3mn.*----.---,--------t+----r---- -~v

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.1)grio'sRERPdoesnotprovideanyreassurancetothepublic'ssafetyandhealth.

Rather, the failure of the RERP to gain final approval by the NRC after many years of j plant operation on,1y underscores its unacceptability.

. Part III (section 21) deals with the basic deficiencies of the Pilgrim facility's t >

GE Mark I containment structure, which has a very high probability of failure early in the course of severe accident scenarios. This probability of failure is highly i 1'

significant in light of the facility's manageriel problems and the inadequacy of the RERP.

1

, STATEMENT OF THE TACT 5 I  !. MANAGEMENT f I

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! I i . 1). Licensee's Manaaement of Pilarlm in Defielet  ;

I l' NRC contends that competent management is cI1tical to ensure the safe operation of

.I any nuclear power facility:

I No level of technical safeguards can make a nuclear facility safe unless j it has good management (statement of NRC commissioners at hearing before i U.S. House Subcomalttee on Energy Conservation and Power, Boston Globe,

! May 23, 1986)....

i The common denominator at inferior plants is poor management (ibid.)....

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Manageannt is the single most important factor in assuring safe plant

{ operations.... There seems to be a history and pattern of poor j ,

management and leadership at this site (James Asselstine, telephone interview with the Boston Globe, ibid.).

i Management has been weak at the plant for some time and this has had a 1

negative influence on safety (James Asselstine, interview, Boston Globe, l, May 28, 1986).

The NRC commissioners, who had just ordered the Pilgrim facility to remain shut down I temporarily because of safety problems (Boston Globe, May 21, 1986), characterized it

!, as one of the worst run and least safe plants in the nation at the abovt Subcommittee i

! hearing (Boston Globe, May 28, 1936).

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4 Boston Edison (SECO) has falled %6 corrGct manage':141 dGilclQncles found ag fa'r back as 1982, despite NRC's order to do so through a comprehensive management itsprovement program; In that year NRC fined B5co a record 4550,000 for two safety

'. violations and a material false statement made by management about allegedly resolving one of the violations. NRC concluded that 'insuf ficient review is being given by BECo management to the operation of the Pilgrim facility (NRC 50-293/ EA $1-63, cover letter i from Richard C. DeYoung, Director, Office of Inspection and Inforcement). The 1982 l evei.*.s, as described by Mr. DeYoung, reveal substantial serious breakdowns in Boston Edison Company's management controls related to the Pilgrim facility. Continued operation of the Pilgrim facility requires significant changes in Boston Edison Company's control of licensed activities. Accordingly, I have determined that the actions set forth below are required by the public

,, health, safety, and interest, and therefore, should be imposed by an Immediately effective order (NRC 50-293/EA.81-63, Order Modifying License Ef fective tamediately,Section IV, p. 6).

The Order Hodifying License Ef fective immediately specifically demanded:

-a full evaluation by an independent organi:ation of BEco's .

organizational responsibilities, management controls, staffing levels i

and competence, training and retraining programs, communications, and j operating practices, with recommendations for improvement;

{ -a program for assuring that inform tion supplied by BECo to NRC on i items "important to safety' is "complete and accurate."

t

-an evaluation'and improvement of the program for plant modifications and design changes to ensure "compilance with the provisions of 10 CTR 450.59;'

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-an evaluation and modification of "r-fety-related procedures and the method used in the development and a m oval of these procedures

• and assurance that plant modifications vill be included in written procedures and drawings;

-an evaluation and modification of the program for training and

(,, retraining personnel involved in safety-related activities;

-an evaluation and modification of the program for assuring "responsible

corporate management oversight

• of safety-related activities;

,i

-development of a system of audits by management representatives to assure conformance to procedures and continued adherence to changes dictated by any of the rev!evs licted above (ibid.,Section V, pp. 7-9).

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i 2), r.icenn** hu riitad on emaco winuewne ceficiancian.

The recent, ongoing history of managerial deficiencies at the Pilgrim plant clearly demonstrates that the management improvement measures demanded by the Order described in section (2) of this petition were never effectively implemented. Special inspection report 50-293/86-06, released April 2, 1986, echoes a theme of managerial weaknesses recurrent since 1982. In this report, NRC found

$ ,' four principle factors that are inhibiting progress in these programs and in identifying and correcting other weaknesses. These are (1) incomplete staffing, in particular operators and key mid-level

' supervisory personnel, (2) a prevailing view in the organization that the improvements made to date have corrected the problems, (3) reluctance, by management, to acknowledge some problems identified by

the NRC, and (4) dependence on third parties to identify problems l ,, , rather than implementing an ef fective program for self-identification of weaknesses (Inspection Report 50-293/86-06, cover letter from Richard Starostecki, Director, Division of Reactor Projects).

The conclusions highlighted in the most recent SEP report (report no. 50-293/85-

~

99), issued February 18, 1986, similarly refer to the same general managerial problems that NRC identifled and demanded that Ecston Edison resolve in 1982. They also I' stressed the safety lup11 cations of those problems:

1 One of the significant outeemes noted during the SEP Board 1 deliberations was the recurrent issue of staffing. In the areas of operations, security, maintenance and radiological controls, the 1 adequacy of staffing supervisory, professional and crafts positions was l noted to be weak. In a sistlar vein, the oversight of BEco supervisors f of work in progress by either SEco staff or supervisors was noted to be l Insufficient. Whether this is due to a lack of supervisors or a lack of

! policy to foster such work by supervisors is not clear. However, review i of the enforcement history (Table 5) clearly highlights a number of I recurring problems attributable to either poor procedural adherence, 4

. poor administrative practices or failure on the part of managers and supervisors to ensurt proper planning, scheduling and performance of required tests or alintenance. Similarly, a review of plant shutdowns

• (Table 7) shows that some of the four automatic scrams and five plant r shutdowns can be attributed to similar causes.

Another observation relates to the lack of critical self-as sessment . During the assessment period, significant NRC interaction was required to identify problems and subsequently to get appropriate corrective action. in some cases, corrective actions tended to be

. i superficial in that they addressed only the symptoms but not the underlying reason for the problea. A corplicating factor in this regard is the management attitude toward perceived weaknesses; a defensive posture is frequently taken with respect to NRC as well as licensee self-identtiled weaknesses. This defensive posture lahibits a thorough and critical evaluation with subsequent delays in resolving the problem (s).

Consequently, problems tend to linger for long periods until drastic measures are taken.... Another lingering problem is the adequacy of licensed operator staffing (SALp Report 50-293/85-99, pp. 6-7).

3.) Deficiencies in the Area of Plant Oeerations The SALP reports covering 1981, 1982 and 1989 give Boston Edison the lowest possible rating in the area of plant operations. In 1985, despite four years of NRC concerns, SALP Report 50-293/85-99 concludes that Pilgrim continues to have serious problems in plant operations, specifically with regards to staf fing, operator performance, and response to quality assurance (QA) findings:

- A chronic shortage of licensed reactor operators grew worse during the assessment period due to promotions, job transfers, and the death of one

. Individual. At the end of the assessment period, only nine reactor operators and one senior operator (functioning as a reactor operator) were staffing five operating shifts. To compensate for the shortage, operators routinely exceeded the overtime guidelines in Generic Letter 82-12. Senior licensee management did not become aware of the full extent of operator overtime until after one individual's time card i indicated that he worked 97 hours0.00112 days <br />0.0269 hours <br />1.603836e-4 weeks <br />3.69085e-5 months <br /> in a seven day period. A continuing

"- weakness in the overtime approval process caused operators to repeatedly l I (thirty-five instances) exceed overtime guidelines without station i management's prior knavledge or approval.... NRC action in this area demonstrates inadequate long range planning and staf fing, weaknessee 'n .

policy implemeritation, and lack of effective corrective action for c recurring problem.

The lack of a sufficient number of licensed operators has been a

repeated NRC concern over the past four years.... Despite these concerns, senior licensee management did not act to ensure that an ,

, adequate number of individuals with appropriate backgrounds / capabilities I j entered the reactor operator training progra= pipeline.... Licensee '.

i management actions on personnel related issues as well as the failure to

! anticipate the shortage in licensed reactor operators indicates inadequate management sensitivity to the effect of personnel decisions

on plant operations (SALP Report 50-293/85-99, pp. 9-10).

According to the same SALP report, this long-term operator staf fing problem has

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. . led 90 serious lapses An operater pesformance and atBention in instances which j involved %he use of nuclear instrumentation during refueling operations

(bypassing one SRM and not continuously monitoring another SRM), the

assesspent of drif ting reactor protection system instrumentation (main

steam line radiation monitors), and an inadvertent reactor scram from low power due to inadequate reactor water level cont

ol. Additional operator attention could have prevented the loss of secondary containment integrity while the plant was at power. Circumstantial i evidence indicates that increased operatos attention might have i prevented refueling equipment from being damaged during fuel movement at [

, the end of the assessment period (ibid., p. 11), i

. r l Another aspect of the plant operations area which was of particular con:ern to NRC l was licensee response to QA findings. The SEp report determined that  !

I f licensee management was sometimes slow in responding to QA surveillance k and audit findings. This lack of responsiveness indicates that

! ., management is not taking full advantage of the quality assurance l program. Senior licenset management has not ensured that management

! support for the QA process is evident and that plant personnel have the i appropriate attitudes and resources to ef fectively respond to QA findings (ibid., p. 12).

The NRC concluded that safety would be eroded without significant attention to the ,

l managerial problems in the area of plant operations:

3 d ,' the board believes that these problems are significant and that future i plant performance and safety may be degraded without senior management  ;

action to strengthen this functional area (id.).

a

< 4), eef tetencies in the u.a e! RMielectemi centrois I

In the area of radiological controls, BEco has had a history of extremely poor l manage. ment performance and high worker exposure levels since the early 1980's. The i company has proven itself unable to address these problems without constant NRC  !

1 ,

! identification, oversight and direction. Despite demands for a specific improvement I

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i program, NRC is still finding fundamental weaknesses in r.anagement oversight in its I,

j, implementation. The latest SEP report still assigns the lowest possible rating to [

l t this functional area, i t

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operations at the P11grita facility have been characterized by unplanned radiation releases and occupational exposures that are among the highest in the nation. SALP teport 50-193/85-99 places those levels at 4,082 person-retas in 1964. NRC reports, occupational Radiation Exposure at Commercial Nuclear Power Reactors, NUREG-0713 and NUREG-0714, list the Pilgrim plant among all commercial plants nationwide as having the highest number of man-reas per reactor in the period 1975-1979 and the highest collective dose per reactor in the period 1980-1984. Although the licensee has sade ef forts to clean up contaminated areas, "recontamination of the clean areas is an ongoing problem' (SALP report 50-293/85-99 p.16).

In reference to ongoing problems with unplanned radiological releases, the SALP report concludes that -

The licensee continued to experience problems in the area of self identification of problem and initiation of prompt, ccmprehensive corrective actions to resolve identified problems and prevent recurrence.... Examples are:

-in December 1984, a contractor employee made an unauthorized entry to a tank to perform sludge lancing.

The licensee's oversight of this high radiation area work i

was less than adequate in that: established high

i. radiation area controls were not implemented, appropriate additional procedures were not established, nor was

supervisory oversight of this activity effective....

-A second ' example involved the licensee's oversight of spent fuel pool work. NRC review...found that unapproved contractor procedures were being used for the activity; discrepancies existed between unapproved contractor and licenset approved procedates for the work; and personnel were not trained or qualified in all appropriate procedures. Stallar problems were identified i during licensee and NRC review of two unplanned personnel exposures sustained by contractors during control rod

. drive work last assessment period. The licensee's corrective actions for fuel pool work were ' job specific"  ;

and not comprehensive. As a result, additional NRC effort '

was needed to obtain an acceptable resolution of problems i

associated with this work.

A third example involved failure to correct high radiation area surveillan:e deficiencies. The problem l i involved f ailure to clearly specify the Technical '

Specification required high radiation area surveillance l

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, . frequency on radiation work peroits. This probles was brought to the licensee's attention on a number of '

occasions....

Due to the number and nature of problems identified in the radiological control's' area last assessment period (tselve violations and two deviations in radiat:an protection, three violctions in radioactive waste transpectation, SEP report 50-293/84-34) an order Modifying License was issued. This Order required that a comprehensive review of the radiological controls program be performed by the licensee and that the findings of this review be addressed by a Radiological Improvement

Program (RIP) (ibid., pp. 14-15).

Despite the implementation of tha RIP, NRC has found that implementation and ef fectiveness are not closely monitored.... Problems i

were noted with the RIP failure to address high radiation area access key controls and some failures to generate acceptable procedures to meet RIP commitments....The licenset has considerable work yet to do in the area of EARA Program establishment; procedures; management oversight; and corrective action system (ibid., p. 15).

o Findings of radiological occurrence reports (ROR) were not always i handled in a timely, comprehensive manner. Corrective actions for ROR i l findings were sometimes late and superficial. These problems were '

apparent in the areas of radiation protection procedure adherence and high radiation area key control....The lack of timely corrective action indicates that mid-level management is either not prioritizing work 4

. effectively or does not have sufficient resources to respond to problems ,

(ibid., p.16).

1 l Other NRC inspection reportr. list problems during the RIP implementation. One example l 1s a routine radiological safety inspection carried out during the SEP evaluation period (from May 20 to May 24, 1985) which uncovered a violation of procedures for fuel ,

pool work:

We are :oncerned about the violation because it is similar to violations l l previously identified; and because it had existed for an extended period '

l of time (about a month) prior to being identified by the NRC (Inspection

! Report 50-293/85-13, cover letter from Thomas Martin, Director, Division of Radiation Safety and Safeguards).

. In summarizing the information in the Radiological Control functional area, the SEP report covering this period states that i

the licensee continues to experience problems in the area of oversight of radiological work and self identification and resolution of problems i (

to prevent their recurrence....These problems indicate that weaknessac

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were still present in the radiation protection progr e. weaknessos in the identification and correction of problems indicates that upper management initiatives in this area are not fully understood by mid-level managers or that human resources may not be sufficient (SALP .

report 50-293/85-99, p. 18).

Beside noting that staf fing problems still persisted in this functional area, the April 2, 198G Special Inspection report identifies additional organi:ational defic!sncies:

Some problems continue to exist between certain Watch Engineers and radiological controls technicians. The communications problems have

' resulted in some violation of radiological controls procedures, friction between the groups (e.g., maintenance, operations, and instrumentation and controls), and scrale problems. Recent examples include poor communications during a recent 041-Tronics problem, and poor communication during an entry into the A0G building to drain filters.

These problems appear to continue in part due to the failure to bring identified deficiencies in this area to the attention of appropriate management for resolution (Inspection Report No. 50-293/86-06, p. 21).

The licensee has not established and implemented an ef fective radiological controls technician retraining program. This is indicative of inadequate planning considering the number of new procedures which are bting established and implemented to meet Radiological Improvement

• Program (RIP) commitments. Also, the program does not ensure appropriate retraining of personnel being rotated through various jobs (id.).

. EARA group personnel do not receive outage planning schedules, are unaware of the work planning process, and in most instances are unaware of work to be performed more than a day in advance of the work.

The lack of adequate review time could compromise the adequacy and ef f ectiveness of EARA controls. . . . .

Regarding in-field EARA controls, observations of radiation protecticn technicians covering jobs found non-uniform implementation of ALARA controls during work. This is of concern because in some cases, the technicians provide the only EARA oversight for the job ( e.g. "A"

'. priority RWPs)....

An example of poor EARA planning was the repeated repairs to the clean radweste pump (Section 5.7). Here, unnecessary repeated repairs were

. made in areas with radiation levels of 140 ar/hr (ibid., p. 22).

j In discussing radiological occurrence reports (ROR), the April 2, 1986 report I asserts that

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the program was found to be less than adequate in 2 hat specific problems associated viBh radiologleal incidents w'ese not clearly s% abed and identified problems were no2 brought to the a%%ention of the appropriate level of station management for their review and resolution (e.g.

January _,1986 contaminated Watch Engineer ROR) (ibid., p. 22).

The licensee has identified significant problems in the area of use of HP personnel resources to support RWPs which are not used.... The licensee has not clearly identified the cause of this problem and initiated timely, lasting corrective action to address it. At one point up to 75% of daily RWPs were not being used. On a yearly basis, the licensee estimated that unused RWPs could cause up to 26 person-ress of needless radiation exposure to personnel performing radiation surveys (ibid., p. 23).

In the area of Chemistry /Radiocheatstry and Effluent Monitoring and Controls, radiological safety inspections have uncovered a number of problems during the RIP implementation period. The May, 1985 routine radiological safety inspection reported one 6eviation:

. This deviation involved failure to evaluate certain nonradioactive systems and estabitsh appropriate sampling and analysis programs for these systems in order to identify radioactive contamination in a timely manner to preclude ant unmonitored, undetected radioactive ef fluent i releases (ibid.).

Another radiological safety inspection conducted August 19-23, 1985 uncovered I

three unplanned releases. The first involved an "apparent unmonitored release path from the ' Hot' Machine Shop" that "may have existed for some period of time" (Inspection report 50-293/85-22, p.7). The second involved a backed-up drain in the i "Hot" Machine Shop:

The licensee's investigation indicated that liquid in the drain may be directed to the Main Sewage Pumping Station. Since the effluent from this pumping station is directed to an onsite leaching fleid and the pumping station ef fluent is periodically pumped out and sent to the Plymouth Sewage Disposal facility, the Main Pumping Station potentially j represented an unnonitored effluent release path.... It was determined that the licensee had failed to laplement a noncontaminated system sampling progran consistent with the requirements of II Sulletin 80-10,

!- ' Contamination of Nonradioactive Sy; tem and Resulting Potential for

Unmonitored/ Uncontrolled Release to the Environment (ibid., p.10).

The third instance was described as follows:

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On July 30, 1985, the licensee's sanitary sewage systec malfunctioned causing an estimated 100 gallons of untreated sewage to flow into stora

, drains. The drains discharge to Cape Cod Bay via the discharge canal.

The licensee investigated the cause and determined it to be inoperable level instru'nentation on the sewage tank at the main sewage pumping station (ibid., pp. 12-13).

Another routine radiological safety inspection conducted November 17-22, 1985 uncovered a violation involving "fallure to perform monthly tests on waste gas monitors' for the Reactor Building Vent and the Stack Vaste Gas Monitors, as required by Technical Specification 4.8 c.10. This resulted in issuance of a Notice of Violation (Inspection Report 50-293/85-32, cover letter from Thomas hartin, Director, Division of Radiation Safety and Safeguards, and Appendix A, Notice of Violation).

The problems that Pilgrim's management has had with monitoring and controlling

(

radiological exposures, ef fluents and wastes is further demonstrated by its inability or lack of desire to make accurate low level radioactive vaste projections. An April, 1985 report by Stone & Vebster predicted that the Pilgrim facility's vaste would contain about 1024 curies in that year; an updated survey by the Special Legislative Commission on Low Level Radioactive Waste on the vaste produced determined that the actual level was 1540 curies, or more than 50% greater than predicted.

.e 5). Deficiencies in the Aiea of on-site preearedness The deteriorating ratings in the area of Emergency Preparedness over the last two SALP ev.aluation periods are particularly critical to plant safety and could lead to potentially catastrophic consequences for the region's citizenry. The 1986 SALP report concluded that performance was only minimally acceptable in this functional area for the second year in a row. Portions of the annual exercise were unsatisfactory and had to be demonstrated in a supplementary drill. The lack of thorough exercise critique was a recurring problem. Perscnnel errors were evident during the exercise and may reflect weaknesses in program staffing and training (ibid., p. 27).

, During the December routine inspection, two problems were idtntified concerning implementation of provisions of the Emergency Plan. (Failure

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to nail information brochures to the general public and failure to perform an annual update to the Emergency Plan and procedures). During the review of the scenario package submitted for the 1985 exercise, it became~ apparent that the scenario package did not contain sufficient detail. It was recommended that the exercise be postponed in order to take time to clarify and complete the exercise scenario....

j During the exercise, two significant areas of concern were identified by the NRC. The first involved a lack of evaluation or control of i  : radiation exposure for re-entry teams sent into the plant for various

- tasks Serious overexposures would very likely have resulted from the

• actions taken if this had been an actual situation. The second concern .

involved the fact that there were no procedures in ef fect for relocation "

of the EOF to the alternate location, in spite of the fact that the trailers which presently function as the EOF are positioned near the

• stack with no shielding or ventilation filtering. (ibid., p. 26).

6). Deficianc!*n in the has of n intenanca and wodificatione Significant deterioration in performnce from the previous SALP evaluation period

. (07/01/83-09/30/84) to the period evaluated by SALP report 50-293/85-99 was noted in i the functional area of Maintenance and Modifications. Over time, this lack of l diligence in management oversight can lead to serious safety-related equipment deficiencies. The current SALP report cites the following problem:

A review of the licensee vendor interface program identified several weaknesses. The licensee program did not systematically address  ;

cotrespondence'from vendors other than General Electric. Additional

problems involving the scope of reviews of vendor infor .ation, the timeliness of the reviews, and the documentation of the reviews were l j identified (ibid., p. 20). L

! Two isolated instances of untimely corrective action (for maintenance l

!. findingr) wers identified during this period. In one case, the licensee

did not plan to complete corrective action to prevent the defeat of safety systems during component isolations until 1995. Mditional NRC i effort was required to obtain timely action in this case. The licensee has also been slow to repair the backup 125V and 250V station battery- ,

chargers. These chargers have been out of service since the 1984  ;

outage. This could be a problem if battery :harger reliability degrades.... The licensee occasionally has been slow to repair equipment  !

that was not required to be operable by the technical specifications, I

, e.g., post accident monitoring equipment. The lack of timely response l to out of service safety equipment (not covered by technical l I* specifications) may indicate a weakness in scheduling second and third l l.

priority maintenance (ibid., pp. 20-21). l e

e L 4 - - - , . . - .. _ ..- --

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- . , , _ _ _..,,.._...,-___,,-c -_ ,. m,. _ ___ ---,

~

Another probloo found in this functional area that is indicativa of weak I management was an 1 '

inter $~ceproblembetweenthecorporatestaffandthesite....

Contractote reporting to ofIsite licensee engineers improperly installed a test instrument on the high pressure coolant injection (HPCI) system, l vhich made the system inoperable (ibid., p. 21).

Also, NRC found that this functional area suf fered from a problem typical

throughout the facility, that of "staffing weakness" (id.).

7). Deficiencies in the Area of Surveillance As in the area of Maintenance and Modifications, SEco's performance rating in the j area of Surveillance has experienced significant slippage since the previous evaluation 4

period. In this area NRC found:

i weaknesses in the areas of startup test scheduling, test adequacy, compliance with procedural requirements, and response to abnormal test

., results.... (ibid., p. 23).

During a slow startup from a 1984 outage, eight surveillance tests required by the technical specifications were not conducted in a timely manner. The tests vere alssed due to scheduling omissions and procedural deficiencies. The scheduling omissions indicate a weakness in the licensee's computer scheduling l

, system, the Mas,ter Surveillance Tracking Program (MSTP)....

i Another problem with the startup tests involved the timeliness of follevup to quality assurance (QA) audit findings. A QA finding i identified two surveillance tests that did not meet technical -

specification requirements two months prior to the startup from the 1984 l outage. The licensee did not resolve the finding until after the i startup, which... demonstrated a lack of sensitivity to the finding.  ;

i subsequent NRC action could have been avolded if the finding was  :

resolved prior to the startup (ibid., p. 24).  !

i The startup period was marked by additional procedural deficiencies which

! involved the f ailure to completely test some safety system components.

Deficiencies were identified in testing neutron instrumentation and j* certain other reactor protection system instrumentation. An additional

, example of an incomplete surveillance test procedure was reported in LER ['

', No. 85-26. The licensee's staff had difficulty in some casts i

l l-J 4

I l'

l...

determining which one of several ovorlapping test procedures fulf1)1ed regulatory requirements (ibid., pp. 21-24).

The SALP report also described problems in carrying out surveillance tests:

Deficle'I1eieswereidentifiedduringtheassessmentperiodwhichinvolved a lack of attention to detail. In one case, operators failed to correct known deficiencies in a station battery surveillance test procedure, which subsequently caused a technical specification surveillance test to be missed. Lack of attention to detail was also evident in the inadvertent return to service of an uncalibrated local power range

, neutron monitor during surveillance tests. Arithmetic errors were noted in several salt service water systen surveillance tests and a computer 4

progran error was identified which falsely lowered vacuum breaker leak rates by a factor of sixty....

The licensee did not always react promptly to abnormal surveillance test findings. The lack of action was usually related to delays in reporting abnormal results to the control roca via the licensee's Failure and Malfunction Reporting System (F4MR). Delays in subattting FsHR's to the control room caused secondary containment integrity to be lost for a day while the reactor was at power and caused a delay in conducting i compensatory surveillance tests for an inoperable emergency diesel generator. A delay in submitting an F4MR on abnormal inservice

! Inspection results for safety systen pipe hangers delayed the licensee's

! response to those test results.... In one case, considerable NRC effort was needed to resolve O normal surveillance test results. In this case, the safety lap 11 cations of drif ting main steam line radiation monitors

> vere not recognized by the licensee. In addition, the licensee was slow to correct a potential weakness in the surveillance test program involving the uncontrolled removal of safety related instruments from 1

service for calibration and testing....

f. A new halon fire suppression systen for the cable spreading roca had not been declared operational at the end of the assessment period because of the lack of a surveillance test for several months (ibid., pp. 24-25).

l In summart:ing its evaluation of the surveillance functional area, the SALP report

{ clearly. Indicates that weak management oversight has led to lax performance:

l Veaknesses were noted in the response to abnormal surveillance test i results, in surveillance test procedural adequacy, and in startup test j scheduling. personnel performance errors contributed to most of these j weaknesses. Additional emphasis on attention to detail would taprove test timeliness and help minimize problems in this functional area l'**

(ibid., p. 25).

I since the 1916 SALP report was issued, many new revelations of surveillance l testing deficiencies have been uncovered. The April 2, 1986 Special Inspection Report notes the following problems:

I 1

l .n.

l l

(.-. . . .--

one particular obsGrvation that reflGc9ed both poor prior planning and control involved re:ently ins 21tuted Inservice Testina (857) of @he HPCZ system in procedure 8.5.4.1, HPCT Pump Operabillty and Flow Rate at 1000...,

The test procedure was not promptly changed after the February 21 test.

Therefore, the HPCI test could not be performed as required by procedure on March 1, 1986. A new test sequence will be developed to allow proper verification of the minimum flow valve while operating the system.

The deficient procedure in question was reviewed and approved by the ORC without their recognition that 1) the success of the minimum flow check valve test depended on the presence of the auto-initiation signal, and

2) that the 5 second timing valve was incompatible with system design 4

and safety analysis assumptions (!nspection Report, 50-293/86-06).

During the reviews of !aC surveillance procedures, it was noted that the licensee did not fully provide for independent verification requirements for lifted leads or installed jumpers. ANSI Standard 18 7-1976, Section 5.2.6, Equipment control, specifies that temporary modifications, such as electrical jumpers and lifted electrical leads require independent verification. The ANS! Standard also requires that independent verification of tagging of equipment be performed. During the return to

. service of the HPCI system on March 1,1986, it was observed by an inspector that there were tags removed from the system, with valves realigned, without a double verification of the position of the valves (ibid., p. 15).

A Quality Assurance surveillance, 85-1.2-1, dated January 25, 1985, resulted in issuance of Deficiency Report (DR) No. 1384. This DR was issued to resolve questions about independent verification practices used by 14C personnel during surveillance testing. The Nuclear operations Manager (NOM) subsequer.tly issued a July 1 , 1985 mezcrandum M85-137, Control and Verification of Operating Actit a, which discussed the method to be used to perform the verifications. The inspector determined that the management objectives of this document were not translated into the maintenance request and tagging procedure tibid., p.

16).

. The inspector expressed concern over an intermittent condition that leaves a residual flow indication of approximately 50 GPM following the reactor core isolation cooling (RCIC) pump operability test, precedure 8.5.5.1. During this test on February 28 and March 1, 1966, the anomalous condition was observed by the inspectors. It was not observed

, during the test performed on March 2, 1986. Based upon discussion with

. licensee personnel, it appears that this has been a long standing condition.... However, on March 1,1984, it was noted that procedure 3.M.3.8 was neither taplemented as required b/ station policy, nor was a second verification of the valving actions performed when returning the transmitter to service (ibid., p. 16).

"ovever, acceptance of a residual flow indication on the RCIC system

'"sing a surveillance test was an example of a poor attitude (ibid.,

F .

. ~ = -

. e-. *se

The NRC reviewed the licensee's evaluation of a potentially generic problea (subsequently detailed in !I information Notice N. 86-13 dated i February 21, 1986) involving explosive squib valves used in the Standby i Liquid.Sontrol System (SLC3) . . . . Bench test firing of a squib valve's explosive charge is and unacceptable test. However, the licensee determined that the squib charges were fired using a bench test, rather than the SLCS firing circuit in 1984. The licensee's failure to perform an in-circuit firing of an explosive charge that cime from the same s.anufactured batch as those installed on April 10, 1984 is contrary to the requirement specified in Technical Specification 4.4.A.2.c and is considered a violation (86-06-07) (ibid., pp. 17-18).

This last instance led to events in which the licensee declared both systems of the SCLS inoperable on February 20, 1986 and initiated a plant shut down. A Notice of Viola 21on was issued with the April 2 special Inspection Report.

A more recent example of BEco's failure to insure proper surveillance was reported 3

in the June 18, 1986 edition of the nesten olebe. In that instance, Edison failed to l perforn 90% of the required tests on valves designed to contain the spread of a i radioactive leah in case of an accident and 36% of the required tests on leak-detection I

devices.

Another recent example was reported in the June 24, 19i6, edition of the Besten

! Ghh:

An alara that warns operators when voltage levels are too lov to run j emergency systems was due,to be tested in January or February, but plant operators forgot, according to a report filed with the NRC on Saturday.

i 8). Deficiencies in the Aren of security and safeeuards j in the area of security and safeguards, as in other functional areas, staffing

! deficiencies and weak corrective actions were noted. These criticisms further reflect I

on the inadequate nature of 3Eco's management.

l Licensee corrective actions for reportable events were sometimes weak.

For example, six events were reported this year which involved the failure to promptly compensate for security equipment failures. The recurring probles demonstrates both a staffing deficiency and a lack of

, effective corrective action. Additional security program weaknesses were apparent during a review of openings in a security vital area

barrier. These weaknesses included inadequate control over contractor construcQ1on activities adjacent to the barrier and inconolete licensee evaluation of the barrier, and the use of materlal to repalr a barrier opening that did not meet requirements. Previous licensee evaluations of bartjer integrity were conducted in 1982 and were inadequate.

Considerable NRC attention, including escalated enforcement action, was taquired to obtain comprehensive corrective action. In both instances, the licensee failed to establish guidelines to implement security objectives. In the first case, the licensee did not establish criteria for timeliness of compensatory actions. In the second case, no

, guidelines were established for judging acceptable site openings in security barrier. Licensee management should be more aggressive in establishing guidelines and clarifying security program objectives (ibid., p. 28).

In addition to these complaints, inspection number 85-24 revealed a security 1svel

!!! violation for "failure te maintain an adequate vital area barrier" (ibid., Table 5).

a I,

9). Deficiencies in the Area 68 ,Sg82311ne and Outace Manacement j- The fact that NRC assigned the highest possible rating to the area of Refueling and outage Management, despite finding obvious and continuing examples of sloppiness and weak annagerial oversight, raises questions bout NRC's ability to critically access I. BEco's performance. The recent SALP report admits thritt i

A signtitcant lack of housekeeping control was indicated by the presence of articles of , protective clothing and masking tape in the main and test 1 tanks of the standby 1tguld control system (SLCS) early in the l assessment period. The deb:is likely fell into the tanks during the

1984 outage. A reactor shutdown in January 1985 was required wh!!e the

!- SLCS system was flushed and the debris removed. The presence of loose

! items on the floor of the reactor building (protective clothing, trash, j and loose tools) is a continuing intermittent problem at the station.

1 -

Kanagement should increase the emphasis on housekeeping to help prevent SLCS type problems from recurring (ibid., pp. 30-31).

,, Fur the r mo re, j Veaknesses in the turnover of modification from the construction to the preoperational test groups, vert 21 cation of system configusation

l. following precrerational testing, control over nonconforming material,

- and the lack of a station drawing for the air start system on the emergency diesel generators were noted (ibid., p. 31).

l T

i 4

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

, . .b0). Def tetenetes in the trea of Licensina ActiviQies The recent SALP reporQ highlights another example of management deficiencies in the area of Licensing Activities. Responses to concerns about technical specifications have been too slows currently, even ainor changes in technical specification wording require

, several months to prepare and subalt to NRR. Current technical specif! cation problems include vaguely worded action stataments and i

incomplete definitions. In some cases, the licensee uses standard -

technical specification requirements to interpret vaguely worded station i specifications. Also, the licensee could have shown more initiative in 1 ', requesting changes regarding surveillance technical specifications that require additional testing (as compared to standard Technical Specifications) when components are made inoperable. This change could have resulted in less equipment testing and wear when components were made inoperable during on-line IQ aedification work (ibid., p. 33).

• 11). Deficiencies in the i m of Fir + Protection l

The April 2,1986 special inspection report found BE00's perf ormance and i i

management in the area of fire protection to be ' weak". The summary states: "A lack of management initiative to reduce the number of station fire watches was evident. Fire watch personnel had minimal training. Several examples of degraded fire protection equipment were observed * (April 2,1986 Inspection report No. 50-293/86-06, p. 30). j j The excessive number of Maintenance Requests (MRs) and the presence of numerous fire ,

watches underscores the inability of Edison's manager.ent to address deficiencies in a timely manner, t l As of February 14, 1986, there were 72 plant locations requiring fire

watches (either continuous or hourly) resulting from 90 separate

reasons. The reasons for these watches vary from inoperable fire  ;

). protection suppression equipment and unsealed penetrations between fire  ;

i area boundaries to one alssing screv on a fire door.

j

• There is a significant backlog of fire protection MRs (over 250) which 4

were open from 1984 to the present. This backlog has contributed to the 1 1 number of fire watches needed. The TPE indicated that techtel was

. , recently tasked to reduce this backlog (ibid., p. 28). j I

j .

l

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- - - - _ - - + - --m_.,_- _-_g y -

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p,,

.

• A total of five plant areas have five suppression systea deficiencies.

These areas are recirculation theactor purp cable spreadingset generator roon, emergency roon, the M2 seal diesel oilgenerators,d systeo an the standby gas treatment systen.

ThehaTonsystemforthecablespreadingroomhasnotbeenweightterted as required by Technical Specifications. The halon system is connected and considered functional. It is difficult to weight tent because of the large size of the halon bottles, lack of sufficient clearance beneath cable trays, and fact that they are restrained by racks for seismic purposes. This condition has existed for about two years without correction. Engineering has been involved with attempting to determine halon quantity in place by a level detection system. An unofficial level was obtained which indicated that there had been no change in quantity in the bottles. It is not clear why this system was not taken out of service temporarily, disassembleh and tested. There appears to have been a lack of management attentic. to fix this probles

, and eliminate fire watch in this area.

Preaction sprinkler system for the energency diesel generators (t00) is inoperable due to a design problem (ibid., p. 28).

The deluge system for both tral.*s of the standby gas treatment system is inoperable due to the manual block valves being tagged shut. This condition stems f rom an incident in 1983 in which a leaking valve caused wetting of a charcoal filter bed, and the system has been inoperable since that time. This appears to be another case where a fire vatch has been used in lieu of achieving problem resolution.

The inspectors were also concerned with the level of training provided to the contractor fire watches, several fire watches were interviewed to determine their responsibilltles and level of training. With the exception of fire watches for hot work, most of the contractor fire watches have.little training in fire fighting including use of fire extinguishers. I.tcensees procedure for fire watches specifies that the it.te watches primary duties are to inform the control room in the event of a fire.... In addition, the fire door connecting the 'A' and 'B' 300 rooms is blocked open to allow one fire watch instead of two. howe ve r ,

two individuals who manned this position stated that they had received no instruction to shut this door to prevent fire spread. This is another example of lack of management initiative to correct a long standing problem (ibid., p. 29).

An example of particularly sloppy performance and oversight was the following:

On February 28, the inspector again examined the D/G fire pump conditions. A portable electric heater using an ungrounded plug was directed at the battery in an attempt to keep battery cell temperatures within normal range. The heater was connected to an extension cord and the connection was laying on the roca floor. If the D/0 fire pump had

. started, this area was likely to get very wet from the leaking relief valve. The inspector considered this to be a safety hazard, and brought it to the attention of the NWF (ibid., p. 30).

. The rooJ heating systen for the diesel generator (D/0) fire pump was found to be cut of service due to a frozen motor. As a consequence, the cell temperatures for the fire pump battery were below specification.

This condition had existed since December 1985 (!d.).

! 12). Deficiencies in Licensee wanagement Manifest in 111 its Endeavers l 1 Bosten Edison's company's deficient management was the subject of an extremely critical report issued by the Massachusetts Department of Public Utilities on June 26, 1986. This report indicates that these management problems are not restricted to the a -

, operation of the pilgrim facility but rather were manifested in all of the company's endeavors. It announced the refusal of a BEco request for $35 million rate increase '

1 .,

and lowered the licensee's allowable rate of return on common stock from 15.25% to 12%, i l

stating:

) We have grave concerns about the ability and desire of Boston Edison's

management to carry out its public service obligation. Based on the j evidence in the record of this case and other recent cases involving the company, we conclude that there is a pervasive attitude within the company's top management, that unless ratepayers underwrite the business 4

- risks associated with the company's operations, it is not required to  ;

' act in a manner consistent with its public service obligation....!! the i company continues to combine an abdication of its responsibility for I capacity expansion planning with an approach that undervalues the l 1

potential for C&LM programs, it will jeopardize the health and safety of

. Its custcaers and the economy of the region. The company's apparently

! cavalier attitude toward these impending consequences is a development

which we regard with extreme alarm (DPU Report, from excerpts prinh4 in

^

the seston olebe. June 27, 1986).

j Although the problems outlined in the report are not directly related to operations at

) the Pilgrim f acility, Paul F. Levy, DPU chairman, "said that in terms of management alone, the pilgrim problems 'nay be symptomatic' of Boston Edison's entire operation

• j (1 bid.). Loston Edtson's lack of social responsibility manifests itself at the pilgrim facill'ty in the kinds of managerial and organizational deficiencies that have been

! described herein to have been of great concern to the NRC for a number of years.

I

)'

l 13). Statement of Law as it leelns to Standards of Manacement i.'

. The Ato:1c Energy Act, 42 USC T2236(a), provides for the revocation, suspension or modification of a license if any information is disclosed froa ' report, record, inspection or other means which would warrant the commission to refuse to grant a license on an original application." Furthermore, the commission has held that "public safety is the first, last and a permanent consideration in any decision on the issuance of a construction permit or a license to operate a nuclear facility." Power Remeter i

Bavelemment core. v. Internatienal Union of Electrical Radio and Machine Workern. 367 U.S. 396, 402, 81 S.Ct. 1529 (1961). The Supreme Court, in that case, emphastred that even after a reactor is licensed for operation, the Commission will retain jurisdiction

'to ensure that the highest safety standards are maintained." Power Reactor, supra, 367 U.S. at 402, 81 S.Ct. at 1532.

However, since the NRC is able to overste or inspect only a fraction of the  !

organizational and technical functions of a nuclear facility, it must rely on the management of the utility to honestly, accurately and timely identify safety problems, to perform objective analyses, to propose solutions and to provide a great deal of data necersary for NRC to perfora its duties. Petition for Emercenev and Remedial letien.

CL!-18-6, 7 NRC 400, 418-419 (1.978). Unless the licensee demonstrates a full connitaant to safety, "It is beyond the power of regulators to put an appropriate program in place.' Metretelitan toisen cemeanv (Three Mile Island Nuclear Station, Unit No. 1), LEP-82-56, 16 NRC 281, 358 (1982). Thus, the NRC must rely heavily upon the licensee's competence to manage the facility's operations so as to ensure that the public safety standards are maintained. In the case of the Pilgria nuclear facility, the foregoing sections of this petition describe how the NRC tried in 1982 to get Boston Edison to 'put an appropriate program in place,' to improve managestent so as to ensure safe plant operation and how, in numerous reports and public statements issued within the last year, both the NRC and the Massachusetts Department of Public Utilities have expressed their determination that a high degree of management incompetence still teasins, despite those efforts by the NRC in 1982. The NRC ltself has stated that it

, andeed cannot rely upon the licensee to honestly, securate'ly and timely identify safety problems at the Pilgric facility. In fact, it reports that 11censee management suf fers fr0s a defensive g titude toward perceived weaknesses that ' inhibits a thorough and critical evaluation with subsequent delays in resolving the problem (s)" (section 2 herein). Because of management's inability or lack of commitment to prevent, identify and resolve organtrational and operational problems, NRC itself has recognized that safety standards are not being adequately maintained as required for the retention of an operating license. Although through its inspection reports and regulatory oversight 4

the NRC 5 encourages excellence in operations," Commissioner Asselstine admits,

'however, the commission too of ten accepts far less' (James Asselstint, The Patriot todaer. July 9, 1986).

I

!!. EMERGENCY RESPONSE Pt.AN 4

l' 14). Defieleneles in the Radioleoical fueroenev Reneense' plan fatap) 1 j Nuclear Regulatory Commission (NRC) regulations provide that no full power operating license shall be issued by the NRC unless the NRC finds "that there is 4

reasonable assurance that adequate protective measures can and will be taken in the

)' event of a radiological emergency' (10 CTR 550.47 (a)(11). The NRC lists sixteen

]

particular standards which must be att by the emergency response plans (10 CTR 450. 0 (b)). More detailed specifics for RRRP's are set out in "Energency Planning and l '

Preparedness Tor Production and Utilization Facilities' found at 10 CTR Part 50,

!, Appendix I. The NRC generally bases its finding of adequacy of RERP's upon a review by 1

• d the Federal Energency Management Agency (FEMA) of state and local emergency plans (10 CTR r50.47 (a)(2)). The NRC and TEMA have issued ' Criteria for Preparation and

'. Evaluation of Radiological Emergency Response Plans and Preparedness In Support of l- Nuclear Pever Plants,' NUREG-0654/TEMA-REP-1, Rev.1, November,1980 (hereinaf ter l

25

1

, , esvaluation criteria'). The evaluation criteria are relied upon by state and federal agencies to set up and evaluate RERPs. I Soth the NRCJ10 CFR i50.100, f 50.54 (e)) and FEMA (44 CFR T350.13) are empowred to withdraw their approval of plans that do not adequately protect the public. The NRC can revoke, suspend or modify a license to operate a nuclear powr plant (10 CFR

. V50.100).  !

serious deficiencies exist in the RERP for F11gria, warranting suspension of

.t Boston Edison's operating license by the NRC. The deficiencies are outlined below. l The combined effect of these deficiencies is to abrogate the ' reasonable assurance that l adequate protective measures can and will be taken in the event of a radiological energency,' the standard set by 10 CFR r50.41 (a) (1).

l 15). Baficiencien in advance inf ormation al. The only method being used for advance public education in the Pilgrin Baergency Planning tone (EP!) is the distribution of pamphlets by aall. A MASSP!RO telephone survey cond:cted in 1983 revealed serious inadequacies in the distribution, retention and understanding of the pamphlets by area residents. No improvements in the

. advance information procedures t ave been carried out since 1983. [

b). The current (september,19851 panphlets contain no information regarding  !

. public transportation for purposes of evacuation, despite the fact that the 7 Radiolo'gical Energency Response Plan (RERP) for the Town of Plymouth provides for i

thirteen ' staging areas

• where persons without transportation will be directed for ,

'possible' public transport.

9

(

c). The advance information system for tourists and other transients is 4

inadequate or nonexistent. Por example, no signs have been posted to provide appropriate information for transients, a measure suggested by the NRC in 10 CFR Part

, 50, Appendix I. IV. D. 2.

t

-2s- l

.- -,- . _ . . . _ ._ . . _ _ . ___ j

. . d). The inadequate advance information systen violates 10 CFR v50.47 (b) (7); 10 l

t CFR Part 50, Appendix 3. !Y. 0.2, and svaluation Criteria o.1, 0.2 and P. 10 of Nutso-  :

0654.

I i

16). Defielanelas in Matifiention Burina in leefdant I

The warning stren systen and back-up systems are inadequate to essentially

4 l complete the initi41 notification of the public within the plume exposure pathway of '

t .

- the Baergency Planning tone (371) within fifteen minutes, as required by 10 CFR Part l 50, Appendix 3., IV. D.3. For example, the stren systen has been plagued with false alatas. Rather than correct this probles, the r9sponse has been to disconnect the j ', siten systen during electrical storas. The strens are inaudible or barely audible (

i o within large areas of the EP! (Report on the Pilgria Nuclear Power Station Stren Test, f June 19, 1982, FEMA, January, 1983, p. 6). Furthermore, federal regulations require l#

• notification of 'all segments' of the population (Criteria J. 10. c, E.6; 10 CFR Part ,

)e 50, Appendix E, IV. D. 3). Clearly, the deficient stren system would fall to warn the I I

! hearing impaired; testimony at the June 18, 1986 hearing on the F11 grin RERP before  !

I i

! Massachusetts legislators provided no evidence of the existence of an alternate plan j l, for notification of this segment of the population, a direct violation of this f l-statutory mandate.

t l Further, in testimony before Massachusetts State legislators on June 18, 1986, '

i I

} 3dward 'A. Thomas, 01 vision Chief, Watural and Technological Hazards, FEMA, stated that

! loston Edison had failed repeatedly to deliver to FEMA necessary technical '

I f 1

specifications on the stren system. Mr. Thomas added that thase delays by Btco have I'-  !

]z forced repeated postponements of the full-scale system test required by FEMA. (

)'

);  !

l ',' 17.1 enfietencian in tvientien Plann ,

4). The evacuation time estlaates for the Pilgrin EPI are unrealistically low.

They fati to take into account the probability of some panic, traf fic disorder, traf fic r

!: obstacles outside the EP! and the fact that thousands of people outside designated I

j 27-l 1

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

. . evacuation zones will also evacuate. Accordi.ag to testimony before Massachusetts ,

legislators on June 18, 1986, by Edward A. Thomas, Division Chief, Natural and l ftChnologlC41 H41 Md$, FEMA, the ' reasonable assurance' adequacy of the current plan is based on the assumption that consunities outside of the ten alle EF3 have developed 4

plans to augment evacuation and sheltering efforts. When asked, Mr. I,ubering, Deputy ,

i

Director of the Massachusetts Civil Defense Agency (MCDA), stated that he had no 1

evidence that such plans exist. Furthermore, evacuation time estimates are not provided for various adverse weather scenarios.

b). There are no workable plans for evacuating the physically disabled, nursing

.., home residents, school children, hospital patients, campers, inmates of correctional  !

l l facilities, or people without autoncbiles. In light of the deficiency noted in c.)  !

l I i below (lack of contractual agreements vith transportation providers), general l l  !

]'

I statements in the plan to the effect that these groups will somehow be evacuated are meaningless and unrealistic.

l 3 c). Testimony by FEMA and MCDA officials at the June 18, 1986 hearing on the Pilgria RERP Indicated that there are no contractual af,*tements with bus compan!es or .

l bus drivers, ambulance companies, or any other transportation providers for thousands  !

l of people who cannot drive or any not have an automobile. No drivers have been trained '

in their supposed role in evacuation plans. In fact, no drivers have been informed j that they have a role in evacuation plans. Furthermore, the proposed route of such

(

j, evacuation (Routes 3 North and 44 Vest) are completely inadequate to effectively handle l

[

j the anticipated volume of traffic. This is particularly true dur!ng the sunser months 4

{. due to the heavy volume of tourists heading to and from cape Cod.

14). g g ancies in Medle11 Facilities I'

al. Various NRC and FEMA regulations require that arrangements be made for [

\ ,. t

], medical services for contaminated injured individuals (10 CFR 15 0 47 (b) (12); 10 CFR Part SC, Appendix 3. !!. E and tv. 3. 7; svaluation Criteria t. 1 and 1,.3). The plan t

makes inadequate provision for treatment of victlas of radioactive contaalnation. A l

(

MASSFIRO 1983 study of the two hospitals listed in the plan then in ef fect revealed

)

J,  ;

they have ,a total capacity to treat only eight or nine victims of radioactive f.onta:1 nation. One of these (Jordan Hospital, Plymouth) is Vithin four alles of the plant, so it may ated to be evacuated. The other (Norton Hospital, Tauntan) In 1983 had no str.ff trained for radiological accidents. No data suggests the situation has matettally improved since 1983.

b). The plan falls to pravide fr.: the distributton of radioprotective drugs for [

the prevention of thyroid tumors to the general public or to persons in institutions who may not be evacuated. The NRC and TEMA recommend distribution of such drugs at 1 east to such lastitutionalized persons (Evaluation Crlteria, J. 10. e, and J. 10. f.

1

19). The taaroency Plannina tone is Tee small al. The Invironmental Protection Agency reconsends protective measures by the public when radiation exposure is likely to exceed the IPA "protective action guide' of '

one tem (Manual of Protective Action Guide and Protective Actions for Nuclear Accidents, EPA-520/1-75-001, ETA,1975.

bl. NRC regulations require the exact size and configuration of each EP! to be

', ' deters!ned in relation to local energency response needs and capabilities as they are ,

af fected by such conditions as demography, topography, land characteristics, access l routes, and jurisdictional boundaries." Centrally, the NRC provides, the plume exposure EP3 should be about ten alles in radlus (10 CFR Part 50.47 (c) (2)). Boston Edison Company has adaltted that the only factor used to create the Pilgria EP! was jurisdictional boundarter (response of Boston Idtson Company to Consonwealth of f Massachusetts' Pirst Set of Interrogatories on taergency Planning, July 20, 1,81, p.2). {

- c). Cape Cod beginJ just eleven alles from P11gria and is connected to the I i

z mainland by only two bridges. There is no emergency rianning for Cape Cod, not public [

f education of protective measures, not warning strens. However, there are plans to  !

I close the Cape Cod bridges to prevent Lts evacuation, so as to give preference to  ;

evacuatees within the plant's lo-mile radius. This is totally unacceptable to the people on the Cape, who would be in the path of a radioactive plume if the the wind j j

33  !

~~ . -- - . - . .. __ .. ___

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

W re blowing toward the Cape, sven if they wcre 41& owed to evacuate the Cape over the connecting bridges, they would be doing se in the direction of the plant and the source of the radiation._the issue of evaeusting Cape Cod is extremely important in the light of the Chernobyl accident, since there the radioactive plume extended much further than 10 alles.

d). Basing his conclusion upon NRC data, the Attorney General of Massachusetts has concluded that the size of the Pilgrim IPt is inadequate teoaments of Attorney General Francis X. Bellott! Relative to Off-51te Emergency Planning for the Pilgria

, Nuclear Power Station, submitted to FEMA, August 1982).  ;

a 20). h of ceerdination nno Prieritiratien of the nrep The NRC should suspend the operating license of the Pilgria power plant until a realistic, detailed RERP is developed, showing an actual capability to educate, alert,

', treat and ef ficiently evacuate all people who may be at risk from a catastrophic accident at the plant. Federal, state and local government agencies, as well as Boston i Idtson, have all accorded a low priority to emergency planning. Instead of trying setto: sly to devise a plan that will protect all of the public, planners have sought to  ;

achieve only alnlaua compliance with NRC regulations; as sections 13 through 18 of this petition demonstrate, they have f ailed to do even that. This insuff!clent corattaent to public protection is evident in alssed deadlines, slow processing of paperwork, lack .

of atte'ntion to detall and inadequate budgets and staffing.

to date, FEMA has largely acquiesced in plans that f all to demonstrate a [

capability to adequately respond to an actual emergency, and T6MA's acquiescence has  !

L

been emulated by the NRC. Where FEMA has criticized peitts of the plan, the '

l.

Massachusetts Civil Defense Age N y (MCDA) has not responded in a timely fashion to f

FEMA's concerns. For example, according to testimony before Massachusetts state fr legislators on June 11, 1986, by tdvard A. Thomas of FEMA, the agency sent letters ,

out11ning persistent TEMA concerns to MCDA la October,1985 and January,1986, t!MA I

[

. . . , , -- L '

geceived no response to the october letter until June 6, 1986, and FEMA had not yet received a response to the January letter by the time of the hearing. Another example of the serious lack of coordination was the failure of MCDA to delissr to FEMA an up-to-date version of the state emergency plan. According to statements by FEMA and MCDA officials in the June 28, 1986 edition of the Patriot I. edger of Quincy, MA, the plan' was not delivered until 10 months after it was prepared. MCDA completed the updated plan in August, 1985 but did not deliver a copy of it untti June 25, 1986. FEMA had formally requested a copy of the plan in October, 1985, but did not follow up on that t

request. MCDA's failure to respond to F::MA's request and FEMA's evident lack of concern and unv1111ngness to demand more responsive action are symptomatic of an

,', emergency response regime that is uncoordinated and given low priority by its attendant

-J public agencies.

Further evidence of this lack of coordination and prioritization was revealed in Mr. Thomas ' June 18, 1986 testimony. Mr. Thomas stated that Boston Edison had failed repeatedly to deliver to FEMA necessary technical specif1 cations on the sirens that I would notify the public of a radiological emergency at the Pilgrim plant. Mr. Thomas stated that these delays by Boston Edison have forced repeated postponements of sy3 tem testing. Thus, the system has never been given the full-scale test required by FEMA.

The emergency response system's lack of prioritization is further demonstrated by the fact that local civil defense agencies in the communities within the Emergency Plannirig Zone have serious staffing and budgetary problems. Most local civil defense directors within the EPZ are unpaid or receive only stu11 stipends. Most have little e

or no paid staff. The reliance on volunteers, who often have minimal professional

. experience or trainir.g, reflects the unwillingness of state and local government to

. make a genuine commitment to eNrgency response planning. Major improvements in

\'

l staffing and budgets of state and local civil defense bodies must be implemented before public safety can be ensured. Moreover, lest the necessary measures taken constitute

• public subsidization of the financial requirements of a safe nuclear power syster, I

Boston Edison should be required to provide the financial means for them. I l

l i

III. CONTAINMENT STRUCTURE

. 21.) Inherent Desian riaws of Pilaria's containment structure l The General Electric Mark I pressure-suppression system employed by the pilgrim reactor contains inherent design flaws which raise serious questions about its ability to withstand a severe accident:

-; A pressure-suppression containment systen has some means of absorbing

? the heat of the steam in the fluid released to the containwnt volume.

In all three GE models, the steam is forced to bubl>1e through a pool of water and is condensed....If some unexpected evant should result in 3 steam generation or flow greater than the suppression capability, then the steam that is not condensed would add an increment of containment

.' pressure. Since the objective of pressure-suppression is to permit use

of smaller containment, rated at lower pressure than would be required

, without suppression, the incomplete suppression would lead to overpressurizing a pressure-suppression containment so designed (AEC internal report by Dr. Stephen Hanauer, September 20, 1972).

) The containment structure employed at the Pilgrim reactor is rated to withstand 62 pounds per square inch of pressure :om steam and other gases. In comparison, the containment structure employed at the Chernobyl reactor (also a pressure-suppression system) was rated to withstand 57 pounds per square inch of pressure (Boston Globe, May 26, 1986).

The AEC internal report by Dr. Hanauer goes on to state:

All pressure-suppression containments are divided into twc (or more) najor volumes, the steam flowing from one to the other through the i condensing water.... Any staan that flotts from one of these voluass to the other without being condensed is a potential source of unsuppresaed pressure. Neither the strength nor the leakage rate of the divider (between the volumes) is tested in the currently approved programs for-i initial or periodic inservice resting.... Because of the limited strength against collapse, the "receiving" volume has to be provided with vacuun relief. In all designs... this function is performed by a

,. group of valves. Such a valve stuck open is a large bypass of the condensation scheme; the amount of steam that thus escapes condensation can overpressurize the containment. Valves do not have a very good reliability record (AEC internal report by Dr. Hanauer, supra.).

1 y --.s .--

7 777

As to the probability of such overpressurization, the AEC has statedt -

GE claims two passive failures are required for trouble, but any malfunction of 12 vacuum relief valves, not easily inspected in the torus,*3ver 40 years will set up half the accident, ready for trouble if a steam leak occurs. The GE position that this is too improbable to worry about is rejected (Task Force Review, Bypass Effects in GE pressure Suppression Containments, November 9,1971 and December 1, 1971).

This situation is exacerbated by the inability to carry out proper tests of the pressure-suppre:sion system:

The smaller size of the pressure-suppression containment, plus the requirement for the primary system to be contained in one of the two volumes, has led to overcrowding and limitation of access to reactor and primary system components for surveillance and in-service testing.... A pipe break in one of these compartments creates a pressure dif ferential; each compartment must be designed to withstand this pressure. A method of testing such designs has not been developed ( AEC Internal report by l Dr. Hanauer, Supra.).

The implications of the problem with the pressure-suppression containment in the GE reactors was not lost to the AEC:

' The problem is germane to all past and present GE pressure-suppression containments . About 40 such are already approved.... GE vants us and ACRS not to mention the problem publicly. They are afraid of delaying hearings in progress.... In any event, this is potential trouble for the Vermont Yankee and pilgrim hearings; it will have to be faced ar.d a real solution found (Task Force Review, Supra.).

Given his concerns about the problem, Dr. Hanauer formulated his own solution, concluding his study by recommending the following:

Recent events have highlighted the safety disadvantages of pressure-suppression containments. While they also have some safety advantages, on balance I believe the disadvantages are preponderant. I recommend that the AEC adopt a policy of discouraging further use of pressure-suppression coctainments, and that such designs not be accepted for construction permits filed after a date to be decided (say two years after the policy is adopted) (iDid.).

i AEC official Joseph M. Hendrie found Dr. Hanauer's recommendation to ban pressure-suppression containments an "attractive one in some ways," but ultimately rejected it, 9

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

stating: .

However, the acceptance of pressure-suppression containment concepts by all elements of the nuclear field, including Regulatory and the ACRS, is firmly _jmbedded in the conventional visdom. Reversal of this hallowed policy, particularly at this time, could well be the end of nuclear powe r . It would throw into question the continued operation of licensed plants, would make unlicensable the CE and Westinghouse ice condenser plants now in review, and would generally create more turmoil than I can stand thinking about (memo from Joseph M. Hendrie to John F. O' Leary, September 25, 1972).

Clearly, this decision to disregard Dr. Hanauer's recommendation demonstrates that the AIC was much more interested in preserving the interests of the nuclear power industry than in assuring public health and safety. In fact, Dr. Hendrie's response

.'; was embarrassing enough to the AEC that it was withheld from the FO! A both prior to an af ter Dr. Hendrie's confirmation as Chairman of the NRC, despite FOIA's specific request for all responses to Dr. Hanauer's recommendation (Union af Concerned Scientists, "An Analysis of Chairman Hendrie's Response to Senator Hart's Letter of June 15, 1978," December, 1978, pp. 1-2) .

Dr. Hendrie has defended his September 25, 1972 reply to Dr. Hanauer's recommendation by stating that Dr. Hanauer offered his September 20, 1772 memo sir. ply as "an idea to kick around" and that its main conclusica was that it was more troub,le tnan Lt was worth to work out the review issues in

. :he GE containments, and the concept ought to be discouraged. I thought should not reject a containment system just because it was harder to lew and required more staf f ef f ort (Joseph M. Hendrie, letter to the eu. 7, New York Times. June 21, 1986).

. This representation of Dr. Hanauer's memo by Dr. Hendrie is is highly misleading.

Although Dr. Hanauer did complain about the inadequacy of testing components of the 4

pressure-suppression system, his conclusion, as quoted in full above, reads very clearly- he felt that sne safety disadvantages of the CE pressure-suppression containments warranted the end of their use in the industry.

t 34-

,.  % . . . . . . .. . -*, - - * = =

--7 --e.m - ------ p , --.y .,.-- - - _ , - - _

Dro Hanauer did assert la a June 20, 1978 meno to Dr. Hendrie that his current opinion was that there was adequate assurance of safety in the GE pressure-suppression containments, and,that that had been his opinion in 1972 as well. However, a memo that he wrote in early 1973 lists, among other problems:

, Bypass Paths on BVR Pressure Suppression Containments. I think this is a real problem. Please note my memorandum of September 20, 1972, copy enclosed (S. H. Hanauer, meno to E. J. Bloch, January 15, 1973).

It seems obvious that Dr. Hanauer believed on January 15, 1973 that his September 20, 1972 conclusion on the lack of safety ..: GE pressure-suppression containments was accurate. The very different tone of his 1978 meno "leaves the public to decide whether his 1978 memo which was prepared for public consumption or his 1972 memo which the NRC tried to withhold from the public represents the truth" (Union of Concerned Scientists, "An . Analysis of Chairman Hendrie's Response to Senator Hart's Letter of

, June 15, 1978," pp. 11-12).

The reason for the dif ficult position that Dr. Hendrie found himself in when responding to Dr. Hanauer's memo in 1972 is attributable to the fact that GE plants were being licensed and built before safety problems were solved. In order to justify licensing, the NRC "staf f makes 'judgements' in the absence of the proof of safety" and subsequent attempts to "solve the safety problems are portrayed to the public as

' confirmatory in nature'" (ibid., p.12) . As the Union of Concerned Scientists analyses indicate, NRC's confirmatory tests, such as those presented in NUREG-0474, of ten fall to produce expected results. The December,1978 analysis summarizes three such cases in NUREG-0474: pool swell hydrodynamics were larger than expected; flow rates into the wet well were not well simulated; and "tests of the ' magnitude and character of 4

'. hydrodynamics LOCA related air clearing loads on the Mark I containment system... have i

revealed that the articipated load reduction due to three dimensional ef fects may not be realized'" (NUREG-0474, from UCS, supra, p. 13).

l

. . As the 1978 UC3 analysis concludes, the practice of licensing plants before testing is completed and safety assured is that it is imp:ssible for the NRC to enforce c once plants are in operation, the pressures are enormous to its own regulations 2 allow them to continue in. operation" (ibid., p. 15). Thus, plants with GE pressure-suppression designs, such as the GE Mark I containment structure at the Pilgrim plant, have been allowed to operate despite safety design flaws that have been known to the

. AEC/NRC for a decade and a half.

A substantial part of the problem in using "judgements" in licensing plants with design flaws like pilgrim's Mark I containment has had to do with the probability risk assessments (PRAs) that the NRC has typically performed and the perception of risk that l they entall. According to a study released by the Union of Concerned Scientists earlier this year, pRAs do not take into account some very important factors, such as the aging of structures; technical specification violations and temporary exemptions T

from specifications; construction defects and weaknesses; partial system failure I sequences; and external factors such as earthquakes, fires, or sabotage (Steven Sholly and Dr. Gordon Thompson, "The source Term Debate," Union of Concerned scientists, January, 1986).

The Sho11y and Thompson depict various accident scenarios and containment failure modes which are not taken into account in PRAs. Some of these entall a situations in which the concerns raised in Dr. Hanauer's 1972 memo nay be realized. For instance, the safety / relief valves (SRVs) to limit reactor pressure by discharging to the suppression pool are located on the main steam lines inside the dryvell. If a discharge line passing through the air space above the suppression pool vere to break

. in the vet well space following a stuck-open SRV in that line, "steam would bypass the j suppression pool and rapidly pressurize the containment" (Sho11y and Thompson, supra,

p. 4-17). Another type of scenario involves the failure of the residual heat removal system and subsequent inability to circulate suppression pool water, which could lead

- . . - . . . . - - . - .- . - - . . . . . - . .A_.

, eto containment failure. A third type of scenario mentioned in the study involves station blackout sequences (sholly and Thompson, supra, Chapter 4).

Other scenarios not accounted for in PRAs include Interfacing loss of coolant accident (LOCA) sequences, Mark I/II sequences with exploding hydrogen in de-inerted

, containment, reactor vessel rupture, main steam isolation valve (MSIV) leakage, and steam explosions (ibid., pp. 4-18 to 4-22). As the study asserts, "the failure to m

include important sequences such as these means that the estimated nuclear risks will necessarily be underestimated" (ibid., p. 4-1).

- The tendency to underestimate the probability of various types of accidents, especially very serious ones, has had serious implications for nuclear f acility

, construction. Nuclear manufacturers tended toward the lighter GE Mark designs because h their lower pressure containment requirements and lighter designs were attractive economically. However, as stated recently by Commissioner Asselstine, 4

as is apparently the case with the Soviet reactors, our reactors were

not designed for large-scale core meltdown accidents. Because such accidents were assumed to be so unlikely as to be incredible, they were

.. Judged to be outside of the design basis for the plants. One consequence of this assumption is that U.S. reactor containments were designed to withstand the rupture of a large steam pipe but were not designed to withstand large-scale core meltdowns....There are accident sequences for U.S. plants that can lead to rupture or bypassing of the containment in U.S. reactors which would result in the of f-site release l

of fission products comparable to or verse than the releases estimated by the NRC staff to have taken place during the Chernobyl accident (James Asselstine, statement before the Subcommittee on Energy ,

Conservation and Power, May 22, 1986).

Similarl'y, in NUREG-0956, Reassessment of the Technient Bases for Estimatina Source Terms, the containment Loads Working Group obtained study results that "lead on to conclude that Mark I failure within the first few hours following core melt vould l .

appe,ars rather likely" (NUREG-0956, July, 1985).

,] In the sobering light of the Chernobyl disaster, the issue of the inadequacy of

the GE pressure-suppression containment has been raised again. The f act that the same i

problems still remain was underscored recently by the NRC's top safety of ficial, Harold l

n - . . .. ...... . . . - - . - .. .. . __

Denton, Director of NRC's Office of Nuclear Reactor Regulation, Who urged the nuclear industry to give top priority to resolving the containment structure problen:

I don't nave the same varm feeling about os containment that I do about the lafger dry containments. There has been a lot of work done on those containments, but Mark I containments, especially being smaller with lower design pressure- and in spite of the suppression pool- if you look

, (at the) VASH 1400 reg safety study, you'll find something like a 90%

probability of that containment falling (Harold Denton, quoted in Inside KRgj Vol. 8 No. 12, June 9, 1986).

The lesson of Chernelo' was not lost on Mr. Denton, who vent on to say to industry leaders, We can argue about the probability of severe core damage for a long time . I think the political climate is such that people are villing to concede that maybe they (severe accidents) will happen now and then at

, U.S. plants, despite the best efforts of everyone (ibid.).

Taken by itself, the high probability that pilgrim's GE Mark I containment structure vill not withstand various sev3re accident scenarios is a very serious factor 4

threatening public health and safety within the region. However, the additional factors of deficient plant management, which greatly increases the probability of a severe accident taking place, and an inadequate Radiological Emergency Response Plan, which vill fall to protect the public in case of a serious mishap, add up to an intolerable potential for dis' aster.

CONCLUSION The petitioners have demonstrated herein that the managerial and structural problems of the Pilgrim nuclear facility, as well as the inadequacy of its Radiological Emergency Response plan, combine to prevent any reasonable assurance whatsoever that "the highest safety standards are maintained,' as is deemed necessary by the NRC in the case of facilities with existing operating licenses. (Pover Reactor, surr3, 367 U.S. at 402, 81 S.Ct. at 1532). Since in fact the health and safety of the region's inhabitants are gravely threatened by each of the above factors working both

[

• independently and in conjunction with each other, the petitioners request that the NRC issue an order to the Boston Edison company to show cause as to why the Pilgrio facility should not remain closed,and initiate proceedings to suspeid Basten Edison's operating license (8DPR-35),unless and until that time at which the licensee demonstrates conclusively to the NRC and the public: (1) that its management 1.s no longer hampered by the deficiencies noted by the petitioners herein, which have brought the licensee under the criticism of the Massachusetts Department of Pubile Utilities

}

- and have resulted in the NRC commissioners identifying the Pilgrim plant as one of the

[

vorst run in the nation; (2) that the Radiological Emergency Response Plan is in full compliance with the provisions of 10 CFR 550.47 and 10 CFR #50.57, is given high organizational priority and suf ficient funding by the licensee, FEMA, MCDA, and local governments, and has practical application over a vide range of serious acciden'

- scenarios; and (3) that the deficiencies that render the facility's structure extremely

, vulnerable in most accident scenarios have been overcome to the extent that public

' health and safety will be assured even under severe accident scenarios. In the latter

~

case, the petitioners request that the NRC require Boston Edison to submit a feasibility study on all possible structural modifications prior to NRC approval of specific modification proposals. The petitioners also request that, subsequent to the operating license suspension, the NRC provide to the public full documentation of the factual basis for any determination it makes pursuant to the lifting or revision of the operating Ilcense suspension.

Furthermore, the petitioners request that the NRC, prior to making a decision

, pursuant to issuing an operating license suspension, schedule a comprehensive pubile hearing to address the issues raised by the petitioners herein. Such a hearing should address other related issues, including but not 11alted to Pilgrim's relationship to present and future regional energy needs.

PPDIDIX A"

- eme 4

7 2.

t. :. .

ENFORCEMENT CATA PILGRIM NUCLEAR EC'4I3 3 7AI

• C.4 Z.

-J Inso. InsD. Severit y Functional No. Cate level Area Violatici.

54-25 11/1-11/85 IV Plant- Failure to cercuct an ace:vate Ope ratic'n s shift turnover for centrei reem I persennel curing refusiing IV Plant Failure to continuously monitor Operations source range monite.s curing refueling

~

!?-33 11/21- IV ' Surveillance Failure to prom : y identify

12/31/84 concisions acverse :: c . a '. f t y (i.e. failure : i nitiate Failure and Malfunction Re;:r:5) 54-41 12/10-13/34 IV Emergency Failure to diseminate e e gency

. Precarecness planning informati:n IV Emergency Failure to u:date the e.mergency Preparecness plan and procacures 34-44 12/13-19/34 III Radiological Failure to follow raciation work Controls :e rmi t instructions arc fatlure

. to establisn a se:cecure f:r a

. remote reacing telecest.e:ry -

system , yy

!!-01 1/1-31/35 V Plant Failure to maintain ::strol-room ,

l Caerations staffing at levels re:vicec by 10 CFR 50.54 IV Surveillance Failure to tes :ne c:ntairment cooling subsysten *?mectately when :ne Icw pressure :: !an:

injection system was in:: era:1e

.' !5-03 2/1/55- IV Surveillance Failure to concuct surveillan:e 1 3/4/85 ,

tests for the rea::c ;r::ecst:n system (six exam les)

IV Surveillance Failure to conc.:: :c ::::(

surveillance tes:s (f tve tua. :les)

. A-1

• Reprinted from SALP report 50-293/95-99

'me w.. .

e mer a y.,e +==e. ee .e . -,w , .e e . .e ..g,,

Inso. Inss. Severi:y Fun::icnal '

No. Cate Level Area V4ela:1en

IV D ! ar.: Failure :: promptly corre:: ::n-Operations dittens acverse to quait ty (i .e.

,'. failure to take sfmely acti:n

,j on Quality Assurance surveillance findings) '

- V Survei l l a'nce Failure to use the mes; cu- ent

' revision of a surveillance tes:

, p.:cedure N V $weveillance Failure te calforate test ecuip-a ment within tne calibratec perice 85-05 3/5/35- V plant Failure to main:ain an uncali-4/1/35 0: era:1cns bra:ec local cower range m: niter

, in a bypassed state

, IV Maintenance Failure to condu:: a dicctyl phthalate test of HE.:A filters i following maintenance on :ne stancey gas trec; ment system i

35-13 5/20-24,'55 V Radiological Failure to have ne Opera:!cns Conte:ls Review Ccemittee (C80) review

' two raciolcgical PC0edures and failure to control wort in :ne fuel scol witn a maintenance recuest Ceviation Radiolegical Failure to c:n:v:t an ade:vate 7 i -

Conte:Is review sf systems :na: cevic .G Gy 3

generate an uncontrollec, un-m0nitored radicactive ef fluent release, as re::mmencec in IE

. Bulletin 50-10 25-17 6/13/35- IV Sveveillance Failure to concuct a surveillance

7/15/$5 surveillance tes of

ne 250 V batte*y system recuirec Oy the

,l

j technical sce

ification ar.c ::

' follce sta:10n crocacu es fo-accisional cattery test:

N IV Radiological Failure to 5:ecify n';n -sciati:n i

C ntrols area surveillance fre ;ec.:1es on raciation nors permits A-

, ,g,,,, . * ~ e * * * ' ' * *'

s . .

-ee

~

inSJ. 5;. everi.y Functional

• NJ. l i e Level, Area Violation

~

h'

.. Ceviation Surveillance Failura to c:nduct inservice tests as specifiec in an NRC l submit:a1

~s L 85-20 7 / '. 5 / 5 5 - IV Surveillance Failure to mainta'e the tri; 3/19/55 level setting for the "3" and

, "C" main steam line hign raji-ation m nitors within tecnnical

,- siecification limits

. 85-21 7/15/35- IV Surveillance Failure to maintain secondary.

4 7/30/35 contain.eent r.

.. IV Surveillance Failure to tes alternate safety system wnen an e?erger.cy diesel genera:Or was found to be inoperaele 5

. IV Surveillance Failure to initiate Failure and

.i Malfunc f en Repor:s as requirec

, by sta fon peccecures E5-24 3/5-3/35 III Security Failure :: maintain an acequate vital area carrier 85-25 3/20/35- . IV Plant Failure to cre:erly authori:e s'. .

9/23/35 Coerations excessive licensec :: era :r j)$I overtime as recuirec y station procedures (thir y-five instances)

~ 85-27 9/16/85- Deviation Radic1cgical Failure to install a ;re: active 9/20/35 Controls c:ncuit 4

6 4 9

i t

e e'

e A-3 4

4:

a

', ,, , . . . . . .. .e== - * ***e- * - * * * * * * ** * ~ * *

• I l

~

. l

/JPEND X 3'

. i 1

TABLC 7 PLANT SHUTOCWNS Snuteewn eri:e Descrietion Cause Dec. 11, 1933 :: Refueling anc recir:viation pipe ---

Cec. 24, 1934 replacement outage.

Oec. 24, 193: Startup frem the outage.

Dec. 25, 193 Shu:dewn frem low ewer due to Oesign (tra::ec air ::ssible erratic incication of reacter in instrument itnes) er water level instruments curing the pr::ecure weakness (verting

- startue. Tra::ec air in instru- ins;rument lines fuliewing i

ment reference legs is a long an extencec cutage no: ace-stancing Orcolem. quate). -

Jan. 1, 1935 : Shutd:wn cue t: :ne presence Of P:cr housekeeping (SLC3) tf

~I Jan, 7, 1935 cetris in SLCS anc for maintenance anc c:m:enen; malfunction on torus t crywell vacuum (vacuum breakers),

breakers.

Feb. 9-15, 1955 Shutd:wn :: re: lace failec recie- ::::enen; malfun::i:n and culation :um: :sa-ings. The : ear- r:cecure weakness (res::nse ing f ailure was caused by a less  := a ni/le Oil level a'. arm Of cum lubricating oil invent:ry, not acequate).

Ine oil 1:ss was caused by a leak in a.4 oil packing glanc :na sur-r:unds a :: ling water line.

Fe . 15-13, 1955 Shutdown te re: air a leaking . eld C:::enent malfun :1:n.

in ene reactor vessel drain lire.

Mar:n 15-20, 1935 5: ram fr:m 1000 ::wer on a f al se Cesign weakness (instr-. e":

hign reacter pressure signal valves rent :: sti:t) er caused by a sticking instrumert Oe 50nnel errer (valve valve. The shutd:wn was c:ntinvec vert'gnsent ).

to ccm:lete maintenance on the reactor water sa :le system and se ndary ::ntainmen Campers.

.i June 14, 1935 Scram frem less than IC% pcwer cue Personnel err:r.

a nign reacter water level

isolation curing lo, ewer maneuvers.

A:-fi 4-5, '.!35 5: ram fr m 35% :: er :ve to a esign weatress ( tu-:i e f alse tur:ine nt;n vi:ratt an  : i: icgic is 011 cus Of signal. n).

5-;

• Reprinted f cr,sALP repor 50-293/35-99

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

' o 4

19u: ownJ e-'a_ _esertotion Cause Se:t. 1-5, ;iS5 Scram from 32% pc er cue to high Cest;n eakness (;ortions

, reactor pressure following a

- generator lead rejectio.. The of switchyard must be washec lead rejection was caused when a live).

, ground fault occurred in the sta-tion switchyard curing _ washing ac-tivities. The fault was caused by a buildup.of ocean salt on switchyard insulators. A leakin g i recirculation ; ump seal was re .

y placec while the reactor was shut cown.

Sept. 5-7, 1955 Shutdown to re:1,c, ,n ,eg, ,

, leaking rectre.14 . jen gy,, ,,,{8,' ,

8slj,normaintenance 9

i

. l

. s I

. 1 1

i e

O e

s 1

5

• 4 4

B-2 1

_, ._ _ .. -.~. - -* ~ ~ ~ " ~ ~ '

---r-w,

7 . . . . . . . . . . -

~H Appendix C .

-=

PlLGRIM STATION i Oceket No. 50-399 MS REGULATORY PERFCRMANCE HISTORY A :abulation of significant milestones and enforceme.n t acticns em e 4 ,

1

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. o Issued operating license.

Tune 072 .

l ecemoer 1973 Shutdown Order issued to inspec: for and re-pair fuel onannel box damage.

December 1974 Fuel failure: Hydriding and pellet-clad

- interaction failures resulted in high i

gaseous activity. Oceration with the fuel q c1 N ding perforations resulted in high cose rates in locations requiring access for operation and maintenance. During 1975, 76 and 77, power was limi:ed between 60-80 to

, maintain offgas activity within regulat:ry

. requirements. The last of the defective fuel bundles was replaced during the 1977 refueling outage.

• May 1975 A civil penalty ($12,000) was assessed for violations concerning Inservice Inspection activities identifiec during an . ins:ection '

c:nducted Cecemoer 1974 - February 1975.

July 1976 Management meeting to discuss concerns related to the management and implementation of the Health Physics Pregram.

October 1976 Management r:eeting to discuss cencerns related to management and implemen:a 1en of- 4 the Health Physics Pr: gram.

$ November 1977 Management meeting to review licensee eff:r:3 to strengthen Radiation Protection Program.

March 1978 A civil penalty ($15,000) was assessec fer violations identified in ins:ection re: ort 50-293/77-31. The violations were: Over-exposure of cne individual; failure to in-struct personnel in accordance w1:n 10 CFR 19; failure to perfor9 recuired air sampling; and failure :o follow procacures.

I Sectember 1978 Management meeting to discuss c:ncerns en recent inspecticn findings (all areas).

September 1979 ,

Management mee:ing to discuss viola:icn of primary c:ntainment integrity.

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Oc: ber 1979 A civil :enalty (!!,000) was assessec f:r a violation icen:ifdec in ins:ection re:cet 50-293/79-15 involving a failure :: follcw

ne Security Plan.

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A civil pena'ty (55,000) was usessec for shipping radioactive materials witn external radiation levels in excess of regulatory l imi ts .-

March 1981 (SALP) Management meeting to discuss the results of the SN P for the period January 1,1980 to Decemt er 31, 1980.

April 1981 A ci. '1 penalty ($13,000) was assessed for events 'urrounding covement of irradiated fuel wit. ,ut secondary containment as identifier. in inspection report 50-293/80-0.'.

.  ! July 1981 A management meeting was held in July 1981 .to discuss concerns for TMI Action Plan Items involvingpostaccidentsamplingprocecures

, and equipment and an Imediate action Letter was issued regarding implementation of these items. Meeting was prempted by a' June 1981

, radiation protection inspection .

(50-293/81-14) found the ifcensee failed to conform with NRC criteria in connection with 4 of the 5 NUREG-0578 Category A items inspected.

June - September 1981 Inspections 50-293/81-18 and 81-22 identified six croblems; inoperable combustible gas J

control system; failure to perfom an adequate 50.59 review; failure to provide appropriate procedures and drawings; failure to make a recort required by Technical Specifications; failure to provica ac: urate information to NRC; and failure to satisfy an Limiting Ccndition for Operation (LCO) regarding primary centainment isolation valves. These inspections were su:secuently the subject of enfercement actions taxen in

. January 1982.

July - August 1981 A Perfomance Aporaisal Inscectien (50-293/

81-20) found 6 of 8 areas e.tamined belcw average. These were: cennittee activities; quality assurance audits; maintenance; corrective action systems; licensed and non-licensed training; and procurement. Plant operatiens and design changes and m:cifica-tions were fcund to te average; hewever, significant weaknesses were icentifiec in botn areas.

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.:cm ,H'. Inforcement conference :o discuss man'agement centrois of safety related activities in-ciuding the violations identified during inspections 50-293/81-18 and 81-22, :he Performance Appraisal Inspaction results, and an interim SALP review (period

Septemcer 1,1980 - August 31,1981).

January 1982 Civil penalty (5550,000) assessed for N failure to ecmoly with requirements o' 10 CFR 50.44; submittal of false infoma; ion to

, NRC and subsequent delay of notification to

, NRC of kncwn inaccurate infoma:icn; and

', failure to ecmply with LCO for RCIC centainment isolation valves.

.* (PIP) Order modifying license required licensee te st.bmit a comprehensive plan of action that would yield an inde:endent appraisal of site and corporate management, rec:m,endatiens for imorove.ments in management contrels and 4

oversignt, and a review of previcus ccm- ,

', pliance with NRC requirements.

, Management meeting to discuss implement ng i recui

e.ments of tne NOV/preposed civil

.' penalty and ceder -odifying license regarding the inde:enden acoraisal of i

Besten Edisen Ccmeany (SECc) management practices.

January 1982 Inscection recor 50-293/81-25 identi'ied a severi:y level !!! viola:1cn fcr trans:cria-tien of radicactive materials with licuid in r the containers. This vic13:icn was based en an inscecticn in Augus; 193* ty :ne 5:ste c'

• South Carolfr.a wnien resul:ed in issuance cf l a civil penal:y (31,0C0).

March 1982 !oston Edison Ccmeany (BECo) su:mitted :ne Der'omance Imceevement Program (FIP)

required by tne January 1982 Orcer.

NRC Managemen meetings to review sta:us cf ,

the Perfomance Imor:vemen: Pr: gram were held approximately every six weeu, un:11 f ,

testemcer 1984 i

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ne 1982 A 3

ecial insoection (50-293/92-iO) conducted of licensee actions after radioactive s

ent resin was found on roof tops and pavement within *.he protected area. No violations

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identit.ed. Confirmatory Action Letter issued concerning actions to be taken s regarding the spent resin.

$ July 1982 Enforcement Conference to discuss exceeding

an LCO associated with the Reactor Protection System water level

. instrumentation.

August 1982 Snforcement Conference to discuss exceeding an LCO associated with the Vacuum Breaker Alarm System. .

5 Septem0er 1982 (SALP) Management meeting to discuss the results of

, the SALP for the period September 1,.1981. to June 30, 1982.

August 1983 A shutdcwn order was issued requiring the ,

licensee to snutdewn in December 1983 and

s inspect the recirculation' system piping fer Intergranular Stress Corrosiun Cracking. It required then to remain in cold shu:dewn until authori:ed' to restar oy the Director of NRR. The licensee reolaced the ,

recirculation system piping and was authorized to restar: in December 1984

' September 1983 (SALP) Management meeting to discuss the results of the SALP for ne pericd July 1,1982 to June 30, 1983.

November 1983 Management mae:ing to discuss refueling /;ipe replacement prepara:1ons.

January 1984 Ccnfirmatory Acticn Letter issuee regarding

, licensee actiens relative to healta :nysics practices following :ne oiscovery of small, i

hign'y radioactive sources in :he centrol red drive repair reen.

February 1984 Enforcerent conference regarding the uncen.

trolled handling of small, hignly

, radioactive scurces in the c:n:rci red drive repair rocm.

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A iivil penalty (540,0CO) was assessed for y rcolems in c:nnection with t.9e unc:ntrolled handling of small, highly radicactive sources in the centrol rod drive repair reem

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between January 14 and 18, 1984 The violation involved identified problems with s the labeling of containers, the use of

, extremity dosimetry, and the adequacy of instructions given to individuals working in 3 the repair room.

September 1984 l'anagement meeting to discuss a sec nd instance of the uncentrolled presence :f

• small, highly racioactive sources in the control rod drive repair reem.

October 1984 Enforcement conference on the unplanned ex-tremity exposure (within regulatcry limits) connected with the small, highly radioactive sources in the control red drive repair -

4 rocm. (Follcw-up to September 1984 -

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management meeting en same subject) ,

.,, Confirmatory Action Letter issued in connection with recurring radiation .

protection program weaknesses. The letter cutlined licensee plans for evaluating and correcting taese weaknesses. .

Novemcer 1984 An order mcdifying the license was issued in ,

connection with recurring weaknesses in the radiation protection program. The ceder re-cuired the licensee to c:molete an

, indecendent contractor assessment of the i

. radiological controls program and to submit to NRC review and accroval a Radiolcgical Improvement Plan (RIF) fer upgrading the radiological controls program. Fo11cwup

, inspections cenducted in May, August, anc November 1985 and Acril 1986.

l A Severity Level III violatien (no civil penalty) was issued for failure to cerform

., radiation surveys; failure to instruct workers in acccedance with 10 CFR 19; and

.. failure to properly imolemen: a :recedure in

', . connection with the unplanned excesure noted above.

Enforcemen c:nference to discuss =eaknesses

.' in the control and menit: ring of neutr:n in-strumenta:icn during refueling :cerations.

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• Jar arv .15 5 .' 3. A'.0 ~ ) . Management meeting to discuss :he results' of the SALP for the :eriod July 1,1983 :o Septemcer 30, 1984

, Enforcement conference to discuss an unplanned occupational radiation excesure w within regulatory limits associated with sludge-lancing operations on a waste tank as

.. identified in inspection 30-293/84-44 August 1985 Enforcement conference to discuss licensee's action on abnormal surveillance tes results

] and a degraded vital area barrier.

0 October 1985 A civil penalty (550,000) was assessed f:r the degradation of a vital area barrier.

November 1985 A safety system functional team inspection (50-293/85-30) was c:ncucted by t'ne Office of Inspection and Enforcement to assess the

. operational readiness and function of

• selected safety systems. The inspecticn .

identified that the licensee had no:

effectively mitigated a water hamer problem associated witn the HPCI turbine exhaus:

line which had been occurring since the ~

.bagintiing o f_ ol a_rit q;e ra tion. Weaknesses were also icentified witn tha licensee's .

design cha~nge process; c ntrol of plant instrutren 3:f on; nandling of vender infor ra-tion; program for approving and validating

', emergency operating procecures; ca:acility to conduct a plant shutd:wn frem cu: side the cartrol reem; rnd maintenance program for motor operated valves.

February 1985 Inspection re:or: 50-293/ 36-C.: identified a severity level III viola:icn #:e failurt ::

meet packaging recuirements for Icw s;ecific

, activity radicactive materials. This viola-tien was based on an inspection in January

, 1986 by the Sta:a of Scu:n Car: lina wnien ,

, resulted in issuance of a civil :enalty

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a r : n '.25 5 ; 2A L ? ). Management meeting to discuss the results of 5e sat? for the perioc Octocer 1, 1984 -

October 31, 1985.

February - March 1986 A special diagnostic team inspection (50-293/  !

86-06) was conducted to determine the under-

lying reascns for the licensee's poor

,. performance described in the most recent

SALP and to ascertain whether they could have an adverse impact on the safety of plant operations.

April 1986 An Augmented Inspection Team (AIT) c nducted

. an inspection of recent cperational events which included 1) the spurious group one primary containment isolations (and associated reactor scrams) that occurred on Acril 4 and 12, 1986, 2) the failure of the main steam isolation valves to prcmotly reopen after the containment isolations, and L

3) the recurring pressuri:ations' of the -

residual heat removal system. The AIT found the licensee's evaluations following the second event to be carefully structured and thorough. A Confirmatory Action Letter concerning the events was issued which required the licensee to provide a written report prior to restart containing the ,

results of the evaluation and corrective actions. The CAL also recuired Regional

• 4 Administrator authorization for restart.

Ins;ection (50-293/86-10) reviewed implementation of the RIP. The inscection l

, found the licensee adecuately addressed 13 l of the 34 ftens reviewed.

May 1986 Management meeting to discuss evaluati:ns and 4

corrective actions concerning one oceratienal q events ef April 4 and 12, 1986.

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., June 1986 The first in a planned series of management  ;

meetings scheduled to review 3ECo management i

! eversignt of the imolementation of the licensee improvement pr: grams in progress.

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Cescriotion of Imorevemen: 3rocram -

I. Per<ormance Improvement Program (PIP) a) Required by Order in January 1982

' b) Areas for Improvement  !

1) Independent Review and Evaluation (MAC)

2) Organization Review / Revision

3) Management Control System Review / Revision L

, 4) Training on Changes f c) 125 milestones established '

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- examples - Procedure Update Program I (660 procedures)

Update Design Occuments Program '

(450 drawings) .

d) Status - C0mplete .

Licensee QA verification of final eecrnitment performed October 1985

i. II. Radio 1ccical Imorovement orocram 1.

i a) Required by Order in . November 1984 .

{ b) Areas for Improvemen, I

1) Indecendent Assessment of Program

2) Radiological Organi:ation Review / Revision

3) Radiological Controls Review / Revision

4) Management Oversight and Corrective Actions  :

5) Training on Changes c) 209 Milestenes Established

.l t As of Cecember 1985 ene item remains open (recenfigure access control) 7 t

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III. Continuous Imorover*ent Program 1

, a) Initiated by SEco in June 1985 j

! b) Actions . l

1) Visited plants with good SALP evaluations '

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2) Conducted internal survey to identify pr:blems/cause

!} 3) Issued recort of findings in Cecencer 1985 l

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2) Ac:cuntability

3) Weak Root Cause Analysis

4) Comunication .

5) Effectiveness Assessmen:

d) Status Implementation of sixteen of eighteen recomendations in pr:gress 4

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PETITIci PCR SHCW CAUSE CalCERNING PILORIM-I NUCLEAR PCdER ST ATIQi b SUBMITTED JULY 15, 1986

'A SIGN AT QJIS,3, Signed v

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Winias B. Golden Af filiation: Massachusetts State Senator Address: State House, Boston, MA 02133 A

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U Na:e: T ftAAA /% N fN!J Af fili ation: f7~d7( hlem Address: State House, Besten, MA 02133 Signed .

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Na=e: Barbara A. Hildt Affiliation: Massachusetts State Representative Address: State !!ouse, Boston, MA 02133 4

Signed -

Na et J. Rachel Shisshak Affiliation: Massachusetts Public Interest Research Group (.vaSSPIRG)

Address: 29 Temple Place, Boston, MA 0:111

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PETITIOl FCR SHW OAUSE CCNCERNING

-- PILGRIM-I NUCLEAR PGER STATIOl SUBMITTED Jt1Y 15,1986 -

.. SIGNATCPIES Siped: A'U 2 l - l

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Name: Joary' . Barry, Co-chairpersen Attillation: Pilgrim Alliance Address: 20 Alden St. Plymouth, MA 02360 -

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Name: Gail H. Raed

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Attiliation: Co-chairperson, Pilgrim Alliance  :

t Address: Pilgrim Alliance, 93 E111sv111e Rd, Ply =outh, MA 02360 ,

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. Atti11ation: Massachusetts Public Interest Research Group (MASSPIRG)

! Address: 29fespiePlace. Boston,MA 02111 l

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a 0 l PETITION FOR SHOW CAUSE CONCERNING PILGRIM I NUCLEAR POWER STATION SUEftITTED JULY 15, 1965 SIGNATORIES Signed: L b b. C Ellliam S. Abbott, President M/ I i

Plymouth County Nuclear Information Cor mittee, Inc.

50 Congress Street Boston, Massachusetts 02109 1

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. a FETITIT FOR SMN CAUSE CNCER"ING

, PILORIWI NUCLE AR PGER STATIM SUBMITTED JULY 15. 1086 11GNATCRIES Signed:  % V4 - --  %

Name:

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Attiliatien; Massachusetts citizen and candidate for Attorney General Address: 462 Boylston street Boston, Missachusetts 02116 Signed _..

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H PETITION FOR SHOW 0F CONCERN PILGRIM -I NULLEAR POWER STATION d

SUBMITTED JULY 15, 1986

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PE?2TIOl FCR 9HQd CAUSE COfCERNINf1 4

i PILCPIWI NUcttAP PGER STATICff ,

Sim!4I*TfD JULY 16. 1986 i

SIGNATC3IES Signed:

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, i PRTfTION fc1 SHOW FitfER CONC 1RM2Nd Pit 0RfM-f MUctr1R POWER STATf0N SUEMf??ID JULY 15, 1996 SIGNATORIES Signed: Michael Mariotte -

Names Michael Mariotte, Editor

.' Affiliation: Nuclear Information and Resource Service Address : 1616 P St NV, Suite 160, Washington, DC 20036 Signed: Richard Parrish Name Richard Parrish, Staff Attorney Affiliation: Environmental Task Force Address: 1012 14th St NW, Washington, DC 20005 Signed: Jane Parker Names fane Parker Affiliation: Lower Cape Citizens for Peaceful Alternatives Address : PO Box 573, Touro, MA 02666 Signed: stechen cook Name Stephen Cook, Spokesperson Affiliation: Mass. Safe Energy Alliance, Greater New Bedford Office Address: 106 Jenny Lind St, New Bedford, KA 02740

, e PR?f Tf 0N FOR EWow Eif fER CONERIMf MG , ,

pftCMfM-f MUEf.rin POWER ETATf0M SURMf?TED JULY 15. 1986 SIGNATORIES Signed:_ lob French '

Name : Bob French, Spokesperson Affiliation: Greater New Bedford Jobs for Peace Address: 83 Durfee St, New Bedford, MA 02740 Signed: Anna oracia Name : Anna Gracia, Publicity Chairperson Affiliation: Greater New Bedford Area lluclear Weapons Freeze Group 1

Address: Friends Meeting House, 83 Spring St, New Bedford, KA 02740 Signed: Ceraldine Camburd Name : detaldine Gamburd, Coordinator Affiliation: Human Ecology Center of South Eastern Massachusetts University

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Address: Old Westport Rd, North Dartmouth, KA 02747 d

Signed: Par cranahan

• Name : Pat Granahan, Chairperson l ,.

Affiliation: Responsible Energy Alternative Coalition of Hingham i Address: 36 Croyden Rd, K!ngham, MA 02043 1

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PETITIOf FCP SMcd CAU9E CCricrRNrto

_ PILORIM-I NUCL? A? PCJER STATIC *l SUEMITTES JULY 18 1086 SIGNATCRIES 1

Signed: Mary Louie  !

Name Mary I,ouie, Ch airpersen [

Affiliatient Boston Rainbcw Coa 11tien f Address: 431 Celirshus, 3eston, M A 02116  ;

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j Signed: Su s an re m ande-Name: Susan Fernandez, Spokespersen l

Affili ation: Keep Freetcwn Hazard Free Address: 35 County Rd, East. Freetcwn, MA 02717 Signed: Jack Cliver l Nace: Jack Cliver, President Affiliation: Coalition of Vietnam Veterans ,

j Address: 181 R111aan St, New Bedford, MA 02740 i  !

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SHOW CAUSC petition #ith the Nuclear Regulatory Commission concerning the Pilgrin nuclear plant in Plymouth, MA  :

int 'Show Cause petition will ask that the NRC suscend Gilgrim's license until Cdison and the NRC can demonstrate t.% the Tclicwing issues have been resolved. The areas are:

. a. Mismanagement

b. Structural problems wit;' centsinment

'. c. Radiological controls d Evacuation plans

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FETITIQI TCR SHOi CAUSE COICERNING

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PILORIM.I NUC!,, EAR PQlER STATIOl -

SUBMITTED JULY 15, 1986 1

SIGNATCRIES

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PET 2T201 FCR SHW CAUSE CCNCERNING

.. PILGRIM.I NUCLEAR PGER STAT!Q1 SUBMITTED JULY 15, 1986 SIGNA? CRIES Signed:

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Name: d?,Nahem.hge,gg hggg,q,g Affiltation: M.A.50, STA7s $ 5 WmTCA f Address: Reen; 408 ,S reTit ,tA3o.sc

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Nue: 359,47:n, n9tcpar.o A, kanus Affiliations iM A 33. OTATE OEMA7 Cit Address: bCSTON, M A. . C.Il3 3 Signed: -T -- - -

Name: 35tJM70lt, $Ai,vg7;gg R , 4,t p,,4 9 3 Affiliation: IM A 55, STATC S E MM70rt Address: .kOC.9 dl Y bT bC f 8csr , M^ O 13 Signed: M AM n m

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Affiliation: [*,i Ap.,r, , 3 7A M [9 d CJ E Address: CSTON, Ma, C2133

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PETITIOl PCR Shot CAUSE CalCERNING

~ PILORI!!-I NUCLEAR PGIER STATIOl SUBMIT ED JULY 15, 1986 i SIGN AT CPIES l

Signed: a cA & _Ed>n ear i

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. Address: OCM I3 O d7 ATE NCOsg BesTon , rta. 02133 1

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