IR 05000293/1991099

SALP Rept 50-293/91-99 for 910929-930313

ML20056G775
Person / Time
Site:	Pilgrim
Issue date:	04/28/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20056G758	List: IR 05000293/1991099 ML20056G757
References
50-293-91-99-01, 50-293-91-99-1, NUDOCS 9309070147
Download: ML20056G775 (29)

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i ENCLOSURE 1

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! U.S. NUCLEAR REGULATORY

COMMISSION

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i l REGION I

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l SYSTEMATIC ASSESSMENT OF l LICENSEE PERFORMANCE (SALP)

! FINAL SALP REPORT 50-293/91-99 !

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PILGRIM NUCLEAR POWER STATION i

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MARCH 13,1993 l '

I BOARD MEETING DATE:

APRIL 28,1993

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SUMMARY OF RESULTS II. A. Overview r i The SALP Board assessment noted continued overall improvement in the management and operation of the Pilgrim Nuclear Power Station. Integrated station performance was indicative of a competent staff and management involvement that was comprehensive and appropriately oriented towani nuclear safety. Previonc n of strong performance were sustained and improvement initiatives were effectively .m,iemented in all functional areas.

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Technical expenise and effective management oversight were most notable in plant ]

operations, radiological controls, emergency preparedness, and security. '

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Several strengths were noted this assessment period. Continued improvement in plant operations was evident throughout the assessment period and resulted in an improved category rating. A highly experienced and knowledgeable operations section management team effectively improved interdepanmental communications and support of operations, increased operator awareness of degraded plant conditions, and contributed to extensive refuel floor upgrades, while maintaining previous strengths that included excellent operator plant transient response capabilities, excellent control room professionalism and communications, outstanding licensed operator training program performance, and sound safety perspectives. Additionally, radiological controls programs were amended to better

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focus on the conduct, control, and accountability of activities performed in radiological control areas. Significant reductions in radwaste generation and liquid effluent discharge volumes have been realized as a result of management and staff commitments to these initiatives.

Reorganization of mainterance functions, increased first line supervisory training and field preemce, and implementation of the maintenance team approach have resulted in improving m sntenance performance. Notwithstanding overall functional area improvement, several plant transients, including engineered safety features actuations and an automatic reactor trip were caused by personnel error during the conduct of maintenance or surveillance activities.

Emergency preparedness and security, which were previous licensee strengths, continued to demonstrate excellent performance. Engineering support to plant operations was improved during the assessment period through department reorganizations and the adoption of a client manager relationship with station disciplines. Design change packages were typically of high quality and well supponed. Work backlogs were effectively prioritized and significant reduction progress had been accomplished. Technical support to emergent plant issues t including the reactor vessel water level indication inaccuracies was excellent. Engineering  !

suppon calculations were typically accurate, with appropriate assumptions applied. ,

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However, several weaknesses were identified in calculations associated with the motor l operated valve performance testing program. Additionally, early in the assessment period other MOV performance testing program weaknesses were not promptly addressed by management responsible for program implementation.

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The SALP Board noted that the improved and continued strong performance in the functional areas above was the result of similar improvement in the safety assessment and quality (

verification area. Excellent safety perspectives were evident in the planning and execution of .

outage activities. The system window approach ensured maximum fluid and electrical system !

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availability and flexibility. Quality audits and surveillances were comprehensive and l L typically performance based. A significant initiative to consolidate the multiple problem j identification processes into a single problem report process was effectively implemented. l The process has ensured prompt identification and evaluation of plant issues. However, the !

i l process has not yet developed sufficient accountability and responsibility to ensure timely l resolution of issues on a consistent basis. Safety review committees were effectively utilized ;

throughout the assessment period. [

i i 'II.B. Facility Perfonnance Rating Summary  ;

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, Last Period * This Period ** l

! Functional Area Ratine/ Trend Ratine/ Trend i

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2 Improving 1

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Radiological Controls 1 1 Maintenance / Surveillance 2 2 Improving  ;

Emergency Preparedness 1 1 l

Security 1 1 ,

! Engineering /rechnical Support 2 2 Improving  !

! Safety Assessment / Quality Verification 2 2 Improvmg '

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. August 16,1990 to September 30,1991 l

• • September 30,1991 to March 13, 1993  ;

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III. PERFORMANCE ANALYSIS III.A. Plant Operations III. A.1 Analysis Plant operations was previously rated as Category 2, with an improving trend. The report concluded that the licensee demonstrated effective management controls that ensured safe facility operation. Continued improvements in operator attention to detail and adherence to procedures were observed. Operator knowledge of systems and response to plant transients were noteworthy. The licensed operator training program maintained excellent support to operations. However, operators on several instances did not sufficiently question anomalous

- or limiting operational observations that were symptomatic of component or system degradation.

. Dudng this assessment period, management controls and oversight of plant operations i remained strong. Operations section management possessed extensive plant experience, with l

licensed senior reactor operator expertise (beyond requirements) in key positions such as the Section Manager, Operations Support, and the Day Watch Engineer. Management involvement in daily activities was evident in frequent control room pres:nce and facility tours. Expectations and standards of performance were clearly established and reinforced through weekly meetings with the offshift operating crew. Operational insights were clearly aniculated during Onsite Review Committee meetings.

Operations management demonstrated a strong safety orientation during all modes of plant operation, with attention focused on the plant response to various transient events and other important safety issues. Sound plant safety perspectives were demonstrated during several severe storms experienced during this assessment period by the establishmeri of more stable control rod configurations below the 80% rod pattern line, alignment of safety-related busses to onsite safety-related power supplies, and precautionary staffing of ponions of the emergency response organization. Elimination of operational " work arounds" (i.e., degraded conditions causing difficulty for operations) was evident in several power reductions to repair leaks in components of the condensate and feedwater systems before these situations had an adverse impact upon operations. Similarly strong safety perspectives were demonstrated during outage conditions. when, as an example, a reactor restart was delayed to repair a faulty intermediate range neutron monitor not required to be availe 3 by technical specifications. A 30-day, mid-cycle outage was successfully planned and coordinated. It was completed on-schedule.

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A formal and professional atmosphere was evident in the control room. Personnel respected l observation and control area demarkations and routinely requested entry authorization.

l- Control room distractions were neither allowed nor observed so that operators were cognizant of plant activities and equipment configuration, especially on the status of safety-related systems. A designated operator dress code effectively reinforced control room

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professionalism. Effective oral communications within the Operations Section continued. ,

l Routine dialogue was clear and succinct, with repeat-back verifications typical. Pre- i evolution briefings were comprehensive, with participation by all support disciplines. Shift j i turnovers were thorough and accurately communicated plant status. A split shift rotation j i (twelve hours for senior reactor operators and eight hours for reactor and non-licensed l operators) was effectively implemented, without loss of either teamwork or turnover i

effectiveness. The twelve hour senior reactor operator shift improved the quality and

- continuity of shift supervisory oversight of on-going work activities and scheduling of j

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training. Weekly meetings between sectional management enhanced support to plant I operations by other disciplines. Radiological support of these meetings resulted in dose !

a savings and equipment monitoring benefits from the use of closed circuit television and i robotic tours of high dose rate areas.

I i Operators exhibited excellent knowledge of plant systems and responded effectively to plant I transient events. For example, the plant was promptly stabilized following three

recirculation pump trips, with good awareness of power-to-flow regions of potential core

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instability. Nuclear watch engineers exhibited sound command and control in response to

two automatic reactor trips and one manual reactor trip involving three loss of offsite power

events (two partial and one full loss) during severe storms. Immediate actions ensured plant

} and personnel safety, and emphasized prompt restoration of power. Operators responded l l well to quickly energize a non-safety related 4 kV bus and two safety related 120 V busses

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that had unexpectedly tripped during the March 13,1993 reactor trip. However, during the subsequent reactor cooldown, operators were not sufficiently cognizant of applicable limiting

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operating conditions such that the reactor vessel bottom head pressure and temperature limits j were exceeded. Event critiques and post-trip reports typically demonstrated very good causal j analysis and corrective action recommendations. Notwithstanding, weaknesses in the post

trip report process were evidenced by the failure of the process to identify that the bottom j head pressure and temperature limits had been exceeded during the March 13-14, 1993

reactor shutdown and in conjunction with the event critique process did not ensure proper

main steam line radiation monitor instrument setpoint configuration following the December

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20,1992 reactor trip.

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Plant operators displayed improved questioning attitudes toward anomalous equipment

, conditions, a previous SALP concern. Operators promptly initiated investigat ions this period l

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into reactor core isolation cooling system governor grounds, the functionality of diesel

generator air start check valves, degradation of an auxiliary bay watertight door, missing 3 motor operated valve limit switch cover bolts, and reactor water cleanup system leakage.

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' Additionally, previous weaknesses in refueling evolutions were similarly addressed. The refuel bridge mast-mounted camera was rnodified to eliminate interferences at the core periphery, and software upgrades were procured to minimize fuel shuffling and to maintain bundle accountability. Additionally, although not required by technical specifications, a

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designated crew of trained licensed operators supervised and performed all fuel handling

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l manipulations. Operations also assumed responsibility for work scheduling, which allowed l for more timely completion of high priority repair work, and better focus by the maintenance organization on planning and staffing jobs.

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! Emergency operating procedures (EOPs) were well written and properly formatted. The

! review and ease of use of engineering calculations that support the EOPs was a strength.

l Iesson plans were well written, and operating crews demonstrated very good ability to I

implement the EOPs. Independent quality assurance (QA) audits of the EOP program were effective, although one instance occurred wherein interim compensatory measures were not established in response to a QA audit-identified deficiency. Additionally, weaknesses existed i in verification and validation processes for revised support procedures, and the type and

delineation of jumpers needed to support EOP implementation. In response to these NRC l identified issues, the licensee performed good causal analysis and effective initial corrective i actions.

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l Operator training programs continued to be accomplished in an outstanding fashion, as i reflected by eighteen of nineteen candidates passing initial NRC-administered examinations.

l Operator performance during simulator scenarios continued to be outstanding. Operations Section management actively participated in training department curriculum development, and were well aware of candidat'e progress. Nuclear watch engineers provided valuable feedback

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during simulator scenario critiques.-

The increased availability of licensed operator resources allowed the licensee to intersperse l operational expertise throughout the station organization, which enabled the licensee to accomplish initiatives that contributed to safe reactor operation and provided improved organizational flexibility. The licensee maintained a six-shift rotation, with each shift staffed in excess of technical specification requirements. Overtime was well controlled and within administrative limits. Licensed operators also assumed various outage-related responsibilities including: refuel floor supervision and dedicated shift fuel handling; schedule review and electrical work coordination; and, membership on the outage task force to l evaluate emergent issues. Additionally, licensed operators were also dedicated to portions of ;

long-term projects including the control room design review program, the annunciator upgrade program, and electrolytic hydrogen water chemistry system startup testing.

In summary, a strong regard for safe facility operation was evident. Operations Section management maintained excellent plant experience and expertise, and established and implemented high standards of conduct. Operators were knowledgeable, exhibited questioning attitudes and performed professionally. Strong communications, and supervisory command and control during plant transient events were evident. Licensed operator training programs continued to provide excellent results and support to operations.

III.A.2 Performance Rating: Category 1 i

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III.B. Radiological Controls III.B.1 Analysis Radiological controls was previously rated as SALP Category 1. Strengths included excellent management involvement during outage periods, well developed and generally good compliance with radiation control procedures, a highly qualified staff, and an excellent i radiation protection program. Excellent ability to resolve technical issues was demonstrated

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during a dropped fuel bundle event with excellent follow-up to audit findings. Many excellent ALARA efforts continued to drive station exposures to lower levels. The radwaste and transportation programs demonstrated excellent performance. The environmental

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monitoring and effluent control programs were of high quality and included coordination of

! the station's environmental monitoring program with the Commonwealth of Massachusetts.

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! Radiolocical Protection i

! The areas of strength noted during the previous assessment period continued to be areas of strength during this period. Frequent and evident management presence in the plant and at job locations provided meaningful feedback to planners and craft personnel. The quality  !

assurance oversight of the radiological controls program was provided by previous Health l Physics (HP) management personnel and was extensive and of excellent depth. Management initiated several efforts designed to improve the focus and quality of radiological controls, by l continuing to automate and improve access control to the radiological area and by focusing l more attention on personnel exposure monitoring. This resulted in fewer and more focused l radiological problem reports. These efforts by management to improve the quality of the ( program have resulted in substantial improvements in the control and safety of radiological l work, and overall performance in this assessment area was considered excellent.

! Staff resolution of technical issues was usually very effective during this assessment period.

The implementation of programmatic improvements was generally thorough and produced excellent results. For example, implementation of water and lead shield packages in the drywell and the broad use of closed circuit television monitors and wireless communications l in the drywell and other plant locations have resulted in marked lowering of personnel i exposures in these work areas. However, the split responsibilities between the HP ALARA group and the maintenance planning ALARA group have resulted in occasional missed

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targets in exposure reduction efforts due to communication and coordination difficulties.

l For example, the review of the reactor water clean-up heat exchangers job indicated

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insufficient communications between the ALARA group and maintenance, and lack of a post l work shielding effectiveness review.

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The licensee's training programs continued to be a strength during this period. The training ,

programs were effective, based on few events attributable to poor or inadequate traim,ng. I

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The systematic approach to training, which incorporates cyclic feedt>ack from management and students into the training program, worked well for this licensee in keeping up to date  ;

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with industry lessons learned and with current plant practices.

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The radiation controls organization was well developed and experienced a low tumover rate during this assessment period. This organization, which is composed of very experienced i HP operations personnel and a very technically experienced HP management group, has j

continued to produce program improvements, as evidenced by the new approach to a single access control point and a new more limited dosimetry badging policy. A strong and conservative approach to controlling radiological work has also been maintained. A very low j

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! level of operational events was reflective of a well seasoned operational HP group and dedicated HP management. Notwithstanding the exception of the ALARA group split of l

l responsibilities issue, the licensee's radiation control organization was a strength.  ;

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! Performance in the area of ALARA has remained steady over this SALP period. There has I been a significant drop in the number of personnel contamination incidents during the i assessment period. Efforts to achieve these results included good planning and ALARA

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measures; aggressive efforts to decontaminate floor surfaces; use of temporary shielding; and  !

the use of audio / video equipment to minimize the need to enter high radiation fields and l contaminated areas.

Radiolocical Environmental Monitoring Procram (REMPL Radioactive Effluent Controls Program (RECPL and Confirmatory Measurements The licensee implemented an excellent radiological effluent controls program (RECP).

Licensee personnel exhibited excellent knowledge of the effluent radiation monitoring systems (RMS) including calibration and testing of radioactive effluent and process monitors, and in quantifying the total amount ofliquid and gaseous releases using the RMS. The l

Offsite Dose Calculation Manual (ODCM) requirements were satisfied on a consistent basis j by licensee personnel. The air cleaning systems were tested and maintained in accordance l with the Technical Specification requirements. The licensee had in place effective programs for measuring radioactivity in process and effluent samples, and for measuring chemical ,

parameters in plant systems.  !

Excellent performance in the radiological environmental monitoring program (REMP)

continued during this assessment period. The licensee implemented a very good Quality ,

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Assurance / Quality Control program to assure the validity of the analytical measurements for the REMP samples. The licensee continued to maintain an excellent meteorological monitoring program to ensure that the meteorological instrumentation and equipment were operable, calibrated and well maintained. The licensee's initiative to conduct a technical study of the levels of radioactivity in Blue Mussels at the site was excellent.

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l implementation of the REMP and RECP. The QA audits of the above programs were j thorough and of sufficient technical depth to assess the programmatic performance. An i effective system was in place to ensure follow-up of any findings requiring resolution.  :

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The radwaste and transportation program maintained the high level of performance observed l during the previous assessment period. Several radwaste program initiatives resulted in ,

significant reductions in the generation and discharge of radioactive wastes from the station.  ;

This program area was fully staffed with well qualified and well trained personnel, and the program was well managed. However, the quality audit oversight of this program area was i

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limited during the assessment period as individual surveillances were substituted for the  ;

!- required biennial audits. The licensee indicated that a collection of surveillances over a three l year period was intended to replace a biennial audit of this subject area due to the regular i strong performance in.the radwaste and transportation programs. The licensee committed to '

l reviewing the resources devoted to this area to ensure the long term strength of the radwaste transportation program.

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l l Improvements were observed in many aspects of the radiological controls program during I l this assessment period that resulted in a continued high level of performance in this area.

L Station personnel exposures continued to decrease due to the level of management l- commitment. The radioactive effluents and environmental monitoring programs exhibited l - excellent program implementation. A high level of performance was also observed in the radwaste area with relatively limited quality audit oversight of this program area. The radiation protection programs demonstrated very good results throughout the assessment period.

III.B.2 Performance Rating: Category I

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III.C. Maintenance and Surveillance

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III.C.1 Analysis

!= Maintenance and Surveillance was previously rated as Category 2. The board concluded that safety-related _ system reliability .had improved and material condition, with the exception of components located within the intake structure, was good. Participation in Multi-Disciplined y Analysis Teams had resulted in effective root cause evaluations for several equipment failures and malfunctions. Initiatives to improve the work planning process, task readiness, and first line supervisor effectiveness showed initial progress, but had not fully resolved existing

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performance weaknesses. Overall procedure quality was acceptable, although some l weaknesses had contributed to safety system actuations and improper drywell head reassembly while the plant was shutdown. The surveillance program was very good.

Maintenance Successful equipment modifications during the assessment period corrected problems which i had previously necessitated entry into Technical Specification action statements, and resulted in improved safety system reliability. Maintenance supervision during construction,

! installation, and testing of safety system modifications was excellent. Management attention towards safety system performance and reliability improvements was evidenced by station i enhancements including: 125 V DC battery charger replacement, salt service water pipe replacement, new electrical connectors for primary containment temperature isolation sensors, and upgraded electrical inverters for the reactor cort. isolation cooling (RCIC) and

- high pressure coolant injection (HPCI) systems. The material condition of the intake structure (a previous SALP concern) was improved with new traveling screens, a rebuilt

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floor, upgraded hypochlorination, more reliable salt service water system check valves, and a l new electric fire pump controller. Licensee management was aggressive in replacing l emergency diesel generator (EDG) air system relief valves based on information provided in an NRC Information Notice; however, the licensee did not perform an effective root cause evaluation for recurring EDG engine driven fuel oil pump belt failures.

A major reorganization combined with improved first line supervisor performance enhanced maintenance productivity this period. Early in this assessment period, communications and job performance within the Maintenance Section were strengthened by the implementation of several organizational changes. Soon thereafter, the section was restructured to strengthen the planning and scheduling process. Additionally, three experienced maintenance supervisors were assigned as planners, resulting in improved work package quality, and an increase in the availability of task ready work packages and rate of maintenance completion.

Increased quality control involvement in the work package development process resulted in

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an approximately 50 percent reduction in the work package rejection rate. In conjunction

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with improved planning performance, several individuals from elsewhere in the crganization, who had demonstrated strong leadership capabilities, were selected to become maintenance supervisors. First line supervisory oversight and critical insights provided by craft feedback were positively influenced by the implementation of the maintenance team concept, in which maintenance disciplines were subdivided into small teams for work production as well as !

technical training. These additions, combined with team maintenance training and weekly l supervisory skill seminars, have improved first line supervisors' effectiveness in the field.

Supervisory and craft staffing levels assured timely completion of safety-related maintenance i activities.

Coordination between the maintenance and operations sections to schedule and accomplish work activities was excellent. Representatives from both sections participated in daily, weekly, and three-week scheduling meetings. All maintenance disciplines were represented l

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and well prepared for the meetings, which resulted in better daily work coordinati:n and more efficient planning of outage maintenance. The maintenance .snd quality control organizations responded promptly to safety system malfunctions (e.g., HPCI/RCIC flow controller and temperature sensors) to perform corrective repairs and thereby maximize safety system availability. Excellent coordination among maintenance, operations, materials and component engineering, and system engineering allowed for timely (on-schedule)

completion of repairs during several forced outages and the midcycle maintenance outage.

Typically, adequate post-maintenance test requirements were developed; however, on one occasion, required valve stroke time testing was not performed following a packing adjustment. Implementation of the In-Service Test (IST) Program was good, and significant improvements have been made to the IST procedures; however, on one occasion during performance of a quarterly IST surveillance, an improperly ranged gage was used to determine system operability.

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Better tool and spare parts inventories permitted work packages to be implemented in a more timely manner. An aggressive decontamination program by the tool management division, in addition to the upgrade of a tool issue facility located within the radiological centrolled area,

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significantly improved the availability of tools. Reconciliation of warehouse inventory and material tracking by the material and component engineering section improved parts availability and reduced tia backlog of work packages for which material was not available.

Preventive maintenance (PM) program implementation continued to be good. The scope and i compreheniveness of the program were expanded during this period. Examples included j automation of PM work package preparation, an expanded rotating equipment vibration  ;

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monitoring program, and the establishment of a reliability centered maintenance group to reevaluate PM scope on a system by system basis in preparation for implementation of the NRC maintenance rule. The overall rate of PM completion increased, and the PM backlog i decreased. One exception was an increase in the backlog of electrical repairs that resulted I from failure to reschedule in advance a large number of breaker PMs with a five year periodicity. These repairs were last performed in 1987, when a large contract maintenance force was onsite. Resources and management attention have been properly redirected to i reduce the electrical PM backlog.

Surveillance The surveillance program was properly implemented and confirmed the operability of safety- l related equipment. The master surveillance tracking program was effectively used for l scheduling and tracking of all surveillances. All Technical Specification surveillances, with l one isolated exception, were completed within required periodicities. Personnel demonstrated a good level of knowledge during performance of surveillances throughout the period. Communications and coordination between technicians and control room operators were outstanding. Technicians were attentive, technically competent, complied with procedures, and displayed an appropriate questioning attitude. Inattention to detail during three evolutions resulted in significant plant transients and engineered safety system i

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actnations. Causal analysis indicated these personnel error initiated events were not indicative of a common programmatic weakness. These evolutions included recirculation pump motor generator set brush replacement, high p rssure coolant injection logic circuitry testing, and main steam line high radiation level setpoint adjustment. Corrective actions to address these events including procedure revisions and training were effective.

In summary, the corrective and preventive maintenance programs were typically effective and resulted in improved material readiness and system reliability. Maintenance was characterized by improvements in work productivity, a reduced corrective maintenance work backlog, improved work package quality and decreasing instances requiring rework. Several factors including work package quality, maintenance team concepts, supervisor training, schedule coordination, tool availability, and material availaM1ity contributed to the overall improvement in material condition and safety system availability. Some weaknesses were evident with respect to post-maintenance testing practices and root causal analyses of equipment failures. The surveillance program was effectively implemented.

j III.C.2 Performance Rating: Category 2 Improving III.D. Emergency Preparedness III.D.1 Analysis l

l Emergency Preparedness was previously rated as Category 1. The report concluded that there was a strong and effective EP program, including training. The EP department and

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Emergency Response Orgatization (ERO) were fully staffed and well-qualified.

Management involvemerd ar,d effective resolution of technical issues were evident.

Responses to events were geod.

During this SALP period, one emergency declaration was made, an Unusual Event upon loss of off-site power during the severe northeastern storm of October 30,1991. Senior plant management personnel were present in the control room throughout the event, which occurred after the reactor had been shutdown, to investigate the cause of a recirculation ( pump low lubricating oil alarm. Notification to the Commonwealth of Massachusetts, local officials, and the NRC was informative and prompt. Local officials were kept well informed. The Station Off-Normal Notification System (SONS) was effectively used to j recall personnel to support plant response and recovery. Licensee actions during this storm

! were timely and appropriate. Throughout the assessment period, the licensee appropriately j assessed plant parameters and external weather-related events that posed potential emergency action level entry conditions.

[ Two emergency exercises were observed this SALP period. One was a full-participation exercise: no weaknesses were found; however, Health Physics Technician adherence to procedures was identified as an area for improvement. The other observed exercise was a

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partial-participation, simulator-driven exercise. Supervision and briefing of

, staff by the Shift Supervisor was an exercise strength. An incorrect annotr Emergency Operations Facility (EOF) Emergency Director to the EOF r .,

which included Commonwealth of Massachusetts representatives, of fr

,rt to j fission product release in progress was an exercise weakness. Howe keep Commonwealth responders apprised of event progress and m ations was also evident. Overall, exercise performance was assessed r Besides the two exercises, there were eight major licensee d 4 such as first aid, post-accident sampling, site staff augmentation, and F i

.:as for improvement were identified in licensee critiques, and t j on in a licensee EP database. The licensee goal of 100% ERO participat i a j year was about 80%

achieved; that was assessed as excellent participatic j j

. sing, conducted J walk-through drills, throughout the year, was assessed as very good. ],

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three shift crews demonstrated the on-shift abiF asify events, make appropriate and timely notifications, and pro' .tive Action Recommendations I Jent.

(PARS). Overall, licensee EP training war J

The licensee maintained three to four e .n each ERO position. Further, they were proactive in identifying potenti 4 4. Imsses identified were compensated

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for by appropriate ERO assignmer @ ihe EP function was well staffed with

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appropriately qualified personne'[4 temporary). Seven of these positions assachusetts and the ten-mile Emergency were assigned to assist the Ce p Planning Zone (EPZ) comrr g ency plan changes and with resolving

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emergency planning issue 4 d EP staffing was assessed as excellent.

To better integrate ite t Public Information Center (JPIC) was consolidated

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from two floors to reviewed multiple procedure changes addressing these

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arios. Also, a comprehensive and detailed checklist was effectively use/ aergency plan and implementing procedure changes did not

. decrease pro- 3. These aspects of coordination and oversight of EP were assessed ar Extene' .nvolvement in EP continued during reo ganization of the Boston Edir .e station organizational restructuring included the redesignation of the Er m a department that reported to the Senior Vice President of Nuclear

.ibdepartment reporting to the manager of the newly formed Regulatory

.ergency Preparedness Department. The restructuring to date has been

.splemented, with organizational responsibilities well defined and programmatic

.ory requirements maintained. Managers maintained their ERO qualifications, J selection and qualification of the ERO staff, reviewed and approved emergency ad implementing procedure changes, participated in drills, and resolved audit issues.

.all, management involvement in EP was assessed as effective.

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13 a partial-participation, simulator-driven exercise. Supervision and briefing of the control room staff by the Shift Supervisor was an exercise strength. An incorrect announcement by the Emergency Operations Facility (EOF) Emergency Director to the EOF response personnel, i

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which included Commonwealth of Massachusetts representatives, of fuel damage and a fission product release in progress was an exercise weakness. However, a strong effort to keep Commonwealth responders apprised of event progress and meteorological conditions j l

was also evident during the second exercise. Overall, exercise performance was assessed as l Very good.

Besides the two exercises, there were eight major licensee drills covering areas such as first aid, post-accident sampling, site staff augmentation, and ERO call-out. Areas for improvement were identified in licensee critiques, and tracked to completion in a licensee EP database. The licensee goal of 100% ERO participation in a drill every year was about 80% )

achieved; that was assessed as excellent participation. Other EP training, conducted !

throughout the year, was assessed as very good. Also, during NRC walk-through drills, l three shift crews demonstrated the on-shift ability to properly classify events, make i appropriate and timely notifications, and provide correct Protective Action Recommendations (PARS). Overall, licensee EP training was assessed as excellent.

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The licensee maintained three to four persons qualified in each ERO position. Further, they were proactive in identifying potential ERO staff losses. lesses identified were compensated for by appropriate ERO assignments and training. The EP function was well staffed with appropriately qualified personnel (18 permanent, 6 temporary). Seven of these positions were assigned to assist the Commonwealth of Massachusetts and the ten-mile Emergency Planning Zone (EPZ) communities with emergency plan changes and with resolving emergency planning issues. Overall, ERO and EP staffing was assessed as excellent.

To better integrate its functions, the Joint Public Information Center (JPIC) was consolidated from two floors to one. The EP staff reviewed multiple procedure changes addressing these initiatives, including simulator scenarios. Also, a comprehensive and detailed checklist was effectively used to assure that emergency plan and implementing procedure changes did not i decrease program effectiveness. These aspects of coordination and oversight of EP were assessed as excellent.

Extensive management involvement in EP continued during reorganization of the Boston Edison Company. The station organizational restructuring included the redesignation of the EP organization from a department that reported to the Senior Vice President of Nuclear i Operations to a subdepartment reporting to the manager of the newly formed Regulatory Affairs and Emergency Preparedness Department. The restructuring to date has been effectively implemented, with organizational responsibilities well defined and programmatic and regulatory requirements maintained. Managers maintained their ERO qualifications, controlled selection and qualification of the ERO staff, reviewed and approved emergency plan and implementing procedure changes, participated in drills, and resolved audit issues.

Overall, management involvement in EP was assessed as effective.

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The licensee audit program observed off-site interfaces, surveillances, and drills, and evaluated the Emergency Plan and Implementing Procedures. Deficiencies and observations l were identified and reported to management for corrective action. Overall, audits were l assessed as being thorough and critical.

In summary, an effective licensee EP program was evident, with strengths in training, management, and auditing. Emergency exercise performance and actual event response were

. proficient. The EP depanment and the ERO were fully staffed and well qualified. The station reorganization which effected the EP division site reporting status was effectively !

j implemented, however as with the remainder of the organization, the long term effects of the i restructming initiative on performance in the Emergency Preparedness area remains to be l assessed.

III.D.2 Performance Rating: Category 1 l

l III.E. Security III.E.1 Analysis

! Security was previously rated as Category 1. The report noted an effective, performance-oriented security program with clear evidence of management attention. Systems and equipment, as well as the security force training program, were upgraded to strengthen plant security indicating the licensee's continued commitment to a quality program. j During this assessment period, the security program continued to be effective and performance-oriented. The licensee's continued use of self-assessments and appraisals were i effective in that personnel errors were rare, events were not repetitive, and correction of I identified deficiencies was time!y and technically sound.

Plant and security management attention to and involvement in the program were evident through the continuation of improvements and enhancements. These included the installation of state-of-the-an equipment to upgrade assessment capabilities, the upgrading of the perimeter intrusion detection system (IDS) to enhance system reliability and minimize maintenance, the issuance of new duty weapons, and the incorporation of a tactical weapons course in the training program.

Effective communications with other plant groups was maintained through security management's active participation in the daily plant staff meetings and by having a security representative on the outage work committee. This direct involvement in the work planning process enhanced rapport, coordination and support among plant groups and provided a vehicle for identifying and resolving potential problems. Security management remained active in industry groups dealing with nuclear security matters and maintained effective liaison with state and local law enforcement agencies through interface meetings and

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orientation sessions. Additionally, at the licensee's request two management meetings were held at the NRC's regional office to discuss several matters related to the physical security program. Such initiatives demonstrates the licensee's commitment to maintaining an effective program.

The NRC-required audits of the security program were comprehensive in scope and depth l and were performance-based. The licensee used a nuclear security consultant to provide l technical expertise to the Quality Assurance audit team. During the audits, no adverse

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findings were identified and recommendations, made to strengthen the program, were promptly and effectively implemented. The audit results were promptly reported to the appropriate levels of management.

The security force training program, administered by the security contractor, was well l developed and staffed by experienced and knowledgeable instructors. Training facilities and j

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training aids were appropriate and well maintained. During this assessment period, the licensee developed and implemented a tactical weapons familiarization course to enhance l response training. Additionally, all lesson plans were revised to be more performance-based j and a new tracking system was implemented to ensure all requalification requirements were l l met as required. Interviews of security officers indicated that their training was effective and l directed toward ensuring that security objectives were properly met. Security officers l displayed high morale and were knowledgeable of their post assignments and responsibihties. i Staffing of the security force remained stable during this assessment period with a turnover rate of less than two percent.

Corrective equipment maintenance was carried out in accordance with a prioritization schedule to reduce the impact of manned compensatory measures on the security program.

In addition, an effecdve preventive maintenance program continued to minimize equipment problems. The effectiveness of the licensee's maintenance efforts was reflected by minimal security department overtime.  ;

During this assessment period, a reactive inspection of the licensee's Fitness-for-Duty (FFD)

i program was conducted. It was determined that the program was very effective, proactive and directed towards assuring public health and safety. Corrective actions taken by the l licensee to resolve previously identified potential FFD program weaknesses were prompt and effective. Additionally, security management periodically participated in meetings held by i the local law enforcement agencies to remain abreast of the types of drugs that were

prevalent in the local area. The resultant information was forwarded to the responsible fitness-for-duty personnel to enhance the effectiveness of the program.

The licensee was responsive to adverse weather conditions experienced during this assessment period. A severe storm experienced early in the period, caused extensive damage to the protected area barrier and intrusion detection systems. The licensee anticipated well in i advance the need for increased staffing, resulting in compensatory measures that were

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thorough, timely, and effective. Additionally, repairs and restoration of security equipment and protected area barrier integrity was performed in an expeditious manner. Such actions further demonstrate the licensee's commitment to a quality program.

Event reporting procedures were clear and consistent with NRC requirements. The reporting procedures were well understood and carried out by the security supervisors. The licensee's security event logs indicated that all events were properly categorized and were appropriately analyzed, and tracked, with timely corrective actions, as necessary. No prompt reportable security events occurred during the period. A FFD event that involved an NRC-licensed operator who tested positive for alcohol was reported in accordance with the NRC requirements.

During this assessment period, the licensee submitted two revisions to the Physical Security Plan. The revisions were technically sound and reflected well-developed policies and procedures, indicating appropriate management oversight and attention to quality.

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The licensee continued to maintain a very effective and performance-oriented program.

Notable program strengths included excellent management suppon for improvements, high quality maintenance, performance-based training, and active participation in industry groups and liaison with law enforcement agencies. The staff was very professional and knowledgeable, provided effective program oversight, and continued to maintain a very good These attributes rapport among licensee, contractor management and the security force.

demonstrated the licensee's commitment to a high quality security program.

III.E.2 Performance Rating: Category 1 III.F. Engineering and Technical Support III.F.1 Analysis Engineering and technical support was previously rated as Category 2. The report noted positive factors in the following areas: highly qualified staff, effective modification process, and strong support for the station. However, the Board noted ineffective root cause analysis to prevent recurrence of high pressure coolant injection and reactor core isolation cooling (HPCI/RCIC) inverter trips and several weak' technical calculations were identified during the NRC Electrical Distribution System Functional Inspection (EDSFI). Overall, the engineering and technical support organizations were determined to provide high quality station support.

The Nuclear Engineering Department (NED) continued to maintain a stable and highly qualified staff of engineers. Over half of the NED engineers hold advanced college degrees and nearly half are professional engineers. The NED has provided a number of training

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l courses for the technical staff including a root-cause/ failure analysis course, the Institute of l

Nuclear Power Operations Technical Staff and Managers Training Course, and Senior l Reactor Operator Certification Training. The NED has also developd an annual refresher l

training course en NED procedures. In the aggregate, these courses ha re been effective in l improving NED performance and were considered a positive initiative. The NED management has maintained a highly qualified staff and has effectively focused staff traming in the appropriate areas.

Technical calculations reviewed this assessment period, an area of previous SALP concern, were typically accurate, with appropriate technical assumptions and bases established.

Notwithstanding, improper valve factors were applied to several motor operated valve performance calculations and the bases for certain salt service water system instrumentation setpoints were not readily accessible. Actions to correct these issues were promptly implemented.

The NED continued to provide high quality plant design changes (PDCs). The plant design changes reviewed used sound technical approaches and were in accordance with established design control measures. To enhance the quality of PDCs, a multi-disciplinary Design Review Board provided an independent review of plant design changes prior to releasing the PDC to the station. Safety evaluations of PDCs were of excellent quality and a small number of field revisions were required during installation. The post modification testing procedures specified the appropriate test requirements and were typically of high quality. An example of an excellent plant design change was the replacement of the salt sewice water piping. All aspects of this design change and implementation of this project were well managed, technically sound and of high quality. Other examples of thorough modifications j

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were the replacement of the emergency diesel generator day tank level switches and the replacement of the HPCI/RCIC inverters. Notwithstanding, adequate design controls were i not established to ensure the proper trip setpoints for the input breakers for recently installed I voltage regulating transformers were maintained. This resulted in the unanticipated deenergization of two 120 V safety related busses during the March 13,1993 reactor scram.

This event was a noteworthy departure from an otherwise strong design change program.

A number of NED initiatives have been implemented to enhance the effectiveness of support to station activities and to improve the interdepartmental interaction between engineering and station organizations, both areas of previous SALP concern. The daily plant meeting was attended by NED management in the Braintree office via a tele-conferencing link. The

. reactive support for discrepancies, such as the American Society of Mechanical Engineers ASME Code Case N-411 deviations, were routinely technically sound and thorough. To enhance interfaces between NED and the site, rotational assignments between engineering l and plant organizations have been encouraged. For example, the Deputy Manager of the NED was previously the Operations Section Manager. Similarly, a number of organizational changes were made to increase the permanent engineering presence at the station. Engineers from the Braintree office were permanently assigned to the site in the Field Engineering, Project and Construction, and the Materials and Component Engineering Sections. The

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incorporation of engineers into the line organizations enhanced the technical capability at the site. The NED developed a Client Manager Program to enhance support for the site organizations. Key section managers at the site interfaced with a NED client manager who acted as a focal point for the clients' support requests. The initiatives to enhance communication were strong. Overall, the NED provided timely support for plant issues.

The NED backlog of outstanding work activities was primarily tracked via engineering service requests (ESRs). The number of outstanding ESRs has been reduced from the last assessment period and was within the goal established by the licensee. The NED has also been aggressive in completing scheduled modification PDC packages in advance of planned outages, with scheduled PDC packages completed nearly one outage in advance. The long term project to update plant drawings was also progressing well. The program effectively developed update prioritization consistent with drawing significance to safe station operations. Nearly 90% of the drawings requiring updating were completed.

The effectiveness of root cause analysis of equipment failures and system anomalies has improved. Specific examples included analysis of a reactor core isolation cooling system steam supply valve failure that caused an unplanned plant shutdown, identification and resolution of emergency diesel generator (EDG) prelube pump cavitation, and design and material upgrades to the EDG air starting systems. The investigation and trouble shooting of the reactor vessel level instrumentation spiking has been very well controlled with the exception of an inadequate temporary test procedure that when performed resulted in an unplanned partial emergency core cooling system actuation. A root cause analysis team, consisting of cognizant Boston Edison Company and contractor personnel was developed to investigate the instrumentation spiking. The team was focused on safety and effectively l initiated positive actions to determine the root cause for the level spiking. Station management strongly supported the team, was routinely involved in key issue development decisions, and demonstrated appropriate safety perspective with respect to this phenomenon.

Actions to identify the root causes of this generic issue were continuing at the end of the assessment period.

Initially during this assessment period, NED management of the NRC Generic Ixtter (GL) I 89-10, " Safety-Related Motor-Operated Valve (MOV) Testing and Surveillance" program was weak. Technical issues were not being addressed. Program inadequacies identified by internal licensee audits were not corrected in a timely manner. Improper assumptions and valve factors were used in the performance calculations for several valves in the original program. Milestones were not achieved. Subsequent to NRC identified problems in this area, an aggressive effort was initiated to improve the MOV program. A revised program schedule was developed with ambitious milestones established. Calculation assumptions were verified, the calculations reperformed, and necessary resultant actions were completed. i Significant MOV inspection, testing, and maintenance activities were accomplished during the 1992 mid cycle outage. At the conclusion of the assessment period, NED had effectively

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l addressed the MOV program weaknesses. However, continued licensee management l

involvement is required to assure successful implementatian of the GL 89-10 program, including the design basis testing.  !

l Other programs reviewed, such as the NRC Regulatory Guide 1.97, " Instrumentation for i Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During l and Following an Accident," NRC Generic letter 89-08, " Erosion / Corrosion Induced Pipe l Wall Thinning," and NRC Generic Letter 88-20, "IPE for Severe Accident Vulnerabilities," l'

indicated a sound approach to the resolution of technical issues from a safety standpoint.

The Regulatory Guide 1.97 implementing engineering calculations, drawings, and procedures ;

were all technically accurate and thoroughly documented. Strong management suppon for i this program was noted in the detail taken to physically verify and document separation. The ,

actions taken in response to NRC Generic Letter 89-08 were effective in detecting pipe wall thinning. The erosion / corrosion program clearly defined responsibilities and provided

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detailed inspection methodology and acceptance criteria. The erosion / corrosion program plan !

and the implementation of the program were excellent. Similarly, NRC Team Inspection  !

reviews of the HPCI system, the EDGs, and the salt service water system indicated the systems were being maintained, tested, operated, and modified consistent with the respective l safety functions described in design bases specifications. BECo submitted an Individual Plant ,

Examination (IPE) for severe accident vulnerabilities, in accordance with Generic Letter 88- !

20. The licensee has effectively used aspects of the IPE results to place priority on NED l activities and support engineering dispositions of system modifications.

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Plant technical suppon activities were effective in dealing with routine, reactive and major programmatic issues. System engineers were knowledgeable and were provided with sufficient authority to act upon identified problem areas. In particular, the corrective action process has been strengthened since the previous SALP period. This conclusion is supported not only by the effective plant response to individual events such as the inadvertent reactor building isolations experienced during surveillance testing, but also by the support provided to planned system enhancements such as the recirculation pump motor-generator set brush holder redesign and replacement. Additionally, programmatic activities such as the Rosemount transmitter monitoring and trending program have been effectively implemented

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by site technical staff. Plant management has initiated a " Plant Manager's Top Ten List" l that has successfully focused technical resources. The effectiveness of plant technical suppon I has been noted for major modifications such as the salt service water piping replacement.

The increased emphasis upon an integrated team approach for both problem resolution and planning of engineering changes has been e.ffective.

A switchyard betterment program was initiated to address the three occurrences during this assessment period in which severe weather conditions caused switchyard faults that resulted in a loss of offsite power and two partial loss of offsite power events. The program

- identified several good short term actions and longer term capital proposals to reduce

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switchyard vulnerability during severe weather. At the conclusion of the assessment period, the program proposals were being evaluated for potential reliability improvements and implementation feasibility.

In summary, the engineering staff has a strong technical background and was routinely provided training. The NED process for making design changes to plant safety-related systems remained effective and resulted in high quality plant design changes. The management attention to the backlog of outstanding engineering work continued throughout the assessment period and the backlog at the end of the assessment period was within established goals. The efforts taken to support the plant on a day-to-day basis were excellent. A weakness in engineering calculations for motor-operated valves was identified.

The weakness in engineering calculations was identified during the last SALP assessment and was an area which required additional attention. The system engineers and the technical support organizations were effective in addressing routine and reactive issues.

III.F.2 Performance Rating: Category 2 Improving

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III.F.3 Board Recommendation:

In light of the recent weather related switchyard faults, the switchyard betterment program proposals should be formalized, and be expeditiously evaluated and implemented to reduce switchyard vulnerability during severe weather conditions.

III.G. Safety Assessment and Quality Verification III.G.1 Analysis Safety Assessment and Quality Verification (SAQV) was previously rated as Category 2.

The report noted improving self assessment capabilities and excellent safety system controls during outages. The ability to comprehensively analyze operational events and implement l effective actions was usually demonstrated. However, resolution of several recurrent l operational anomalies was ineffective such that system operability had been impacted. !

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Licensee performance in the SAQV functional area remained good during this S ALP period. l Previous areas of strength were maintained and initiatives to address previous concerns were instituted. However, inadequate disposition of several known, documented deficiencies was a noted during several NRC inspections.

l Previously, the licensee documented and evaluated discrepant conditions via one of several corrective action documents, including potential conditions adverse to quality (PCAQ)

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reports. 'These repoits were adequate for thc documentation / evaluation. However, the

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disposition of corrective action was not timely in at least four areas identified during NRC inspections. As a result of these findings, the licensee consolidated their various corrective action processes into a single problem report process.

The consolidated problem report process effectively ensured that concerns were promptly reviewed for operability and reportability determinations by the problem assessment committee (PAC). While the problem report has ensured consistent identification and operability and reportability reviews of plant concerns, the process has not yet established sufficient responsibility and accountability to ensure consistent timely closure of issues. As a result, a fairly large backlog of open problem reports developed. Near the end of the

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assessment period, the licensee initiated a broad review throughout the organization to identify and resolve any outstanding discrepancies which had been identified prior to implementation of the problem report process.

The system window approach to outage management was very effective in assuring maximum decay heat removal capability, reactor coolant system inventory control, electrical distribution system availability, and primary and secondary control during mid-cycle outage maintenance and testing. The approach clearly established system configurations which met or exceeded Technical Specification requirements. The outage safety perspectives were further refined by the independent outage safety review committee that recommended additional vessel inventory controls as well as contingencies to address potential system misalignments. A recently established emergent issue team effectively coordinated the response to outage issues on a real time basis, which minimized ovemil outage management impact. The licensee demonstrated a marked improvement in the planning, scheduling and implementation of short notice, forced outage work schedules.

Plant organizations were responsive to QAD findings. The Quality Assurance Department (QAD) suneillance and audits were comprehensive and generally performance based. For example, the QAD demonstrated sound awareness of industry issues as evidenced by their detailed audit of operator rounds and by continuing periodic verification of plant records. :

i Excellent surveillance criteria were established and management for the operations section was responsive to QAD fmdings.

Licensee event reports (LERs) continue to be complete and of high quality. A consen'ative perspective in reporting practice was maintained as evidenced by the submittal of a voluntary LER on seismic damping ratios. During the assessment period, the backlog of supplemental LER submittals was eliminated.

Station management was actively involved in modification activities that upgraded component performance and improved long term reliability of safety-related systems. The preparations and controls employed in the five phases leading up to the replacement of the rubber lined, carbon steel salt service water (SSW) system piping with titanium piping were examples of excellent modification management. Additionally, station management provided excellent

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l safety and regulatory perspectives during evaluation of the reactor core isolation cooling system inverter operability issue. Installation of upgraded battery chargers and inverters :

l I demonstrated commitment to improving long-term station safety system reliability. l

Station management has been responsibly dealing aggressively dealt with reactor vessel water :

j level instrumentadon spiking. The issue is being addressed in a sound and deliberate i L manner. Potential contributing factors have been systematically addressed in a logical ,

technical sequence. Evaluations and issue reports have identified appropriate potential impact

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! on instrumentation safety. functions. Additionally, the licensee has actively supported !

l industry's generic investigation, through meeting participation, and information and  !

l experience exchanges. The training department also developed a program to ensure that the l operators were properly instructed and drilled on simulator scenarios that familiarized and tested their response to reactor vessel water level indications of spiking / notching.

l Additionally, on several occasions, licensed operators demonstrated the capability to mitigate ;

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l the effects of reactor vessel water level events during NRC developed simulator scenario

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exercises.

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A major restructuring of the nuclear organization, including management personnel changes ranging from Senior Vice President - Nuclear to various deptment level positions was well controlled. It is a three phase process that should be complued at the end of RFO No. 9.

No degradation of plant or personnel safety has been noted i The on-site operations review committee (ORC) has shown increased involvement in plant issues during the assessment period. This is especially evident on the issue of reactor vessel level instrumentation operability which received close ORC scrutiny as the issue further evolved through the SALP period. New members have improved the overall technical expertise of the offsite Nuclear Safety Review and Audit Committee (NSRAC), thereby l contributing greater insight to safety reviews. NSRAC continues to meet bimonthly and makes good use of subcommittees. NSRAC attention to performance issues in the area of j Engineering and Technical support and to industry events such as the generic analyses of i recent BWR power oscillations has been outstanding. I l

The material condition of the intake structure, a previous SALP concern, has been partially ;

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addressed during this assessment period. In addition to the previously discussed Salt Service Water (SSW) system piping replacement project, the electric fire pump and motor and control cabinet were replaced,' SSW pump discharge check valves were upgraded, a new chlorination control system was installed, significant traveling screen overhauls were )

completed, and a new flooring surface was put down. Nonetheless, the harsh marine L environment that the intake structure is subjected to presents an on-going challenge to .

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In summary, licensee performance in SAQV continues to show a safety conscious attitude

~ during power operations and outage management. Self assessment, problem identification, evaluation and documentation continue to be a notable strength. However, the problem report promss which effectively consolidated issue identification mechanisms and ensured prompt issue operability and reportability evaluations, has not yet developed the accountability and responsibility necessary to ensure consistent and timely issue closure.

III.G.2 ' Performance Rating: Category 2 Improving o

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(- 24 IV. SUPPORTING DATA AND SUMMARIES IV.A. Licensee Activities '

l Pilgrim Nuclear Power Station operated in a safe manner throughout this assessment period.

l The plant was shutdown on October 30,1991, during a severe storm, to investigate a l

recirculation pump low lube oil level alarm. Subsequent to the shutdown, a weather related l - loss of offsite power was experienced and a Notification of Unusual Event was declared. On March 26,1992, the plant was shutdown to repair a reactor core isolation cooling system motor operated isolation valve that was located inside the drywell. On October 24,1992, a planned shutdown was conducted to enter the midcycle maintenance and surveillance outage.

l The plant experienced three automatic reactor trips when at power operations during this l assessment period: (1) December 13,1992, a turbine generator load reject during a severe storm resulted in a plant trip from 50 percent power; (2) December 20,1992, during plant l restart improperly established main steamline radiation monitor trip setpoints resulted in a

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plant trip from 70 percent power; and (3) on March 13,1993, a turbine generator load reject during a severe storm resulted in a plant trip from 100 percent power.

- IV.B. NRC Inspection and Review Activities Three NRC Resident Inspectors were assigned to Pilgrim Nuclear Power Station throughout this assessment period. The following significant NRC inspections were conducted during l this assessment period. l l

e Emergency Operating Procedures Inspection: January Il-14,1993. NRC Inspection ,

Report 50-293/93-01. i l

e BWR Reactor Vessel Water Level Instrumentation Inspection: August 4-14,1992. l NRC Inspection Report 50-293/92-17.

• Systems-Based Instrumentation and Controls Team Inspection: November 4-8 and 18-22,1992. - NRC Inspection Report 50-293/91-201.

e Motor Operated Valve Team Inspection: March 9-13,1992. NRC Inspection Report i I-50-293/92-80.

e Probabilistic Risk Assessment Based Team Inspection: November 30 - December 18, 1992.- NRC Inspection Report 50-293/92-81.

• _ Operator Requalification Examination Inspection: May 4 and 11,1992. NRC Inspection Report 50-293/92-05.

o Operator Initial Qualification Examination Inspections: December 2,1991 and November 16,1992. NRC Inspection Report Nos. 50-293/91-25 and 92-22. j

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The NRC conducted the following significant public meetings during this assessment period. j J

• On August 29,1992, the NRC conducted a public meeting in Plymouth, l Massachusetts, to discuss current events and experience regarding Rosemount i transmitters, Thermo-lag fire retardant material, and reactor vessel water level i

- instrumentation inaccuracies.  !

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• ,On February 3,1993, the NRC conducted a public meeting in Plymouth,  ;

I Massachusetts, to discuss and update the status of the reactor vessel water level j instrumentation inaccuracies issue. l

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ATTACIIMENT SALP EVALUATION CRITERIA Licensee performance is assessed in selected functional 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 meaningful observations. Special areas may be added to highlight significant observations.

The following evaluation criteria were used, as applicable, to assess each functional area:

1. Assurance of quality, including management involvement and control; 2. Approach to the resolution of technical issues from a safety standpoint; 3. Enforcement history; 4. Operational events (including response, analyses, reporting and corrective actions);

5. Staffing (including management);

6. Training and qualification.

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

Category 1. Licensee management attention and involvenient in nuclear safety or safeguards activities resulted in superior performance. The NRC will consider reduced levels of discretionary inspection.

Cateeorv 2. Licensee management attention and involvement in nuclear safety or safeguards activities resulted in good performance. The NRC will consider maintaining normal levels of discretionary inspection.

Category 3. Licensee management attention and involvement in nuclear safety or safeguards activities resulted in acceptable performance. Performance at this level is of concern to the NRC because a decrease in performance will approach or reach ) unacceptable level. The NRC will consider increased levels of discretionary inspection. (ff the NRC was to conclude i that there was not an adequate level of safety performance, prompt and appropriate action would be taken separately from, and on a more urgent schedule than, the SALP process.)

The SALP repon may include an appraisal of the performance trend in a functional area for use as a predictive indicator. Licensee performance during the assessment period is examined to determine whether a trend exists. Normally, this performance trend would only be used if both a definite trend is discernable and continuation of the trend would result in a change in performance rating.

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Attachment 2 l

l The trend, if used, is defined as:

Imorovine: Licensee performance was determined to be improving during the assessment j period.

l l Declinine: Licensee performance was determined to be declining during the assessment l period and the licensee had not taken meaningful steps to address this pattern.

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• gp tic UNITED ST ATES ENCLOSURE 2 d 0 4 NUCLEAR REGULATORY COMMISSION

[ g REGION I g  ;

-y 475 ALLENDALE ROAD o, KING OF PRUSSIA, PENNSYLVANIA 19406 1415 h8

• • • • • MAY 2 1933 Docket No. 50-293 Mr. E. Thomas Boulette, PhD .

Senior Vice President-Nuclear Pilgrim Nuclear Power Station RFD #1 Rocky Hill Road-Plymouth, Mamchusetts 02360

Dear Mr. Boulette:

SUBJECT: INITIAL SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REPORT NO. 50-293/91-99 On April 28,1993, an NRC SALP Board conducted a review to evaluate the performanc activities associated with the Pilgrim Nuclear Power Station for the period of September 29, 1991 through March 13, 1993. The results of this assessment are documented in the enclosed Initial SALP Repod.

The SALP Board noted continued overallimprovement in the management and operation of the Pilgrim Nuclear Power Station. Technical expertise and effective management oversigh were most notable in plant operations, radiological controls, emergency preparedness, and security. The engineering and technical suppon and maintenance and surveillance areas were good, and improved during the assessment period. The SALP Board noted that the impro and continued strong performance in all functional areas was in pan the result of improvement in the safety assessment and quality verification area.

Upon completion of our discussion of this SALP repon on June 10,1993, we request that you provide written comments, including correction of factual information, within 20 da the date of the meeting. The enclosed report and your response will be placed in the NRC Public Document Room.

Your cooperation is appreciated.

Sincerely,

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ff Thomas T. Martin Regional Administrator

Enclosure:

NRC Region 1 Initial Systematic Assessment of Licensee Performance (SALP)

Report No. 50-293/91-99 c-w w e

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i Mr. E. Thomas Boulette, PhD 2 .

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REGION I

! E. T. BOULmE, SENIOR VICE PRESIDENT, BECO

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l SALP PROCESS J. MACDONALD l

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SENIOR RESIDENT INSPECTOR SALP REPORT PRESENTATION E. KELLY, CHIEF PROJECTS SECTION 3A CLOSING REMARKS W. KANE, DEPUTY REGIONAL ADMIh1STRATOR, NRC REGION I E. T. BOULmE, SENIOR VP, NUCLEAR, BECO Pilgrim SALP l

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SALP PROGRAM OBJECTIVES i

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• IDENTIFY TRENDS IN LICENSEE PERFORMANCE 1

• PROVIDE BASIS FOR NRC RESOURCE ALLOCATION  !

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• IMPROVE NRC REGULATORY PROGRAMS

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FUNCTIONAL AREAS

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e PLANT OPERATIONS

• RADIOLOGICAL CONTROLS l

• MAINTENANCE / SURVEILLANCE

• EhERGENCY PREPAREDNESS

l * SECURITY AND SAFEGUARDS

• ENGINEERING / TECHNICAL SUPPORT

• SAFETY ASSESSAENT/ QUALITY VERIFICATION

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Pilgrim SALP

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EVALUATION CRITERIA l

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• ASSURANCE OF QUALITY, INCLUDING MANAGEMENT INVOLVEMENT AhT CONTROL

• APPROACH TO THE RESOLUTION OF TECHNICAL ISSUES FROM A SAFETY STAhTPOINT l * ENFORCEMENT HISTORY ,

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• OPERATIONAL EVENTS INCLUDING RESPONSE, ANALYSIS, REPORTING, AND CORRECTIVE ACTION

• STAFFING (INCLUDING MANAGEMENT)

• EFFECTIVENESS OF TRAINING AND QUALIFICATION PROGRAMS l

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Pilgrim SALP

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PERFORMANCE RATINGS

CATEGORY 1 SUPERIOR PERFORMANCE CONSIDER REDUCED INSPECTION l CATEGORY 2 GOOD PERFORMANCE CONSIDER NORMAL INSPECTION

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i CATEGORY 3 ACCEITABLE PERFORMANCE CONSIDER INCREASED INSPECTION TRENDS IMPROVING PERFORMANCE IMPROVING

.DURING ASSESSMENT PERIOD I

DECLINING PERFORMANCE DECLINTNG  !

DURING ASSESShEST PERIOD AND TIE LICENSEE HAD NOT TAKEN AEANINGFUL STEPS TO ADDRESS TIUS PATIERN

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Pilgrim SALP l

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SALP BOARD  ;

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MEETING DATE: APRIL 28,1993

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l l CHADC'dN:

i J. WIGGINS, ACTING DIRECTOR,

! DIVISION OF REACTOR PROJECTS l

l MEMBERS:

L W. HODGES, DIRECTOR, DIVISION OF REACTOR SAFETY l R. COOPER, DIRECTOR, DIVISION OF RADIATION SAFETY l AND SAFEGUARDS  !

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W. BUTLER, DIRECTOR, PROJECT DIRECTORATE I-3, OFFICE OF NUCLEAR REACTOR REGULATION (hTR)

R. EATON, PROJECT MANAGER, NRR

J. MACDONALD, SENIOR RESIDENT INSPECTOR, PILGRIM

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Mignm SMP l

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-SYSTEMATIC ASSESSMENT OF LICENSEE l PERFORMANCE

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NRC REPORT No. 50-293/91-99 .

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l PILGRIM NUCLEAR POWER STATION l

ASSESSMENT PERIOD l

SEPTEMBER 29,1991 - MARCH 13,1993  !

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Pilgrim SALP

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PERFORMANCE RATING SUMMARY l

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l FUNCTIONAL AREA PREVIOUS CURRENT l

RATING RATING PLANT OPERATIONS 2, BIP 1 l

l RADIOLOGICAL CONTROLS 1 1 i

l MAINTENANCE /SURVm1ANCE 2 2, IMP EMERGENCY PREPAREDhTSS 1 1

l SECURITY AND SAFEGUARDS 1 1 .

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ENGINEERING /

TECHNICAL SUPPORT 2 2, BIP

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SAFETY ASSESSMENT /

QUALITY VERIFICATION 2 2, BIP

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Previous Assessment Period: 8/16/90 - 9/28/91 Current Assessment Period: 9/29/91 - 3/13/93 l

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PLANT OPERATIONS l l l * STRONG MANAGEMENT OVERSIGHT

• SOUND SAFETY PERSPECTIVES

• OPERATIONAL " WORK AROUNDS" ELIMINATED l

• SUCCESSFUL MID-CYCLE OUTAGE l

l * PROFESSIONAL CONTROL ROOM ATMOSPHERE I

• COMPREHENSIVE PRE-EVOLUTION BRIEFINGS

• SOUND COm1AND AND CONTROL l

• THOROUGH EVENT MITIQUES

• PREVIOUS WEAKNESSES CORRECTED e BROAD EXPERTISE ENABLED IhTTIATIVES

• WELL WRITTEN EMERGENCY PROCEDURES

• OUTSTANDING OPERATOR TRAINING PERFORMANCE RATING CATEGORYl Pilgrim SALP

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RADIOLOGICAL CONTROLS  !

• MANAGEMENT PRESENCE AT JOB LOCATIONS ,

• EXCELLENT QUALITY OVERSIGHT DEP'ITI

• AUTOMATED ACCESS CONTROL

• ALARA COORDINATION DIFFICULTIES l

• IMPROVEMENTS LOWERED EXPOSURE

• UP TO DATE, SYSTEMATIC TRAIhTNG l

• EXPERIENCED STAFF / PROGRAM IMPROVENENTS

• GOOD PLANNING AND ALARA MEASURES  !

• EFFECTIVE SAMPLING PROGRAMS l

• EXCELLENT ENVIRONMENTAL MOhTTORING

• GOOD QA

• RADWASTE INITIATIVES REDUCED WASTE l

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MAINTENANCE / SURVEILLANCE

• IMPROVED SAFETY SYSTEM RELIABILITY

• INEFFECTIVE DIESEL BELT FAILURE ANALYSIS

• ENHANCED PRODUCTIVITY / WORK PACKAGES ,

• STRENGTHENED PLANNING AND SCHEDULING

• IMPROVED SUPERVISORY EFFECTIVENESS IN FELD e EXCELLENT COORDINATION WITH OPERATIONS

• PROMIrr REPAIR OF SAFETY SYSTEMS

• BETTER TOOL AhT PARTS INVENTORIES

• EXPANDED PREVENTIVE MAINTENANCE SCOPE

• TESTING CONFIRAED OPERABILITY

• INATTENTION TO DETAIL CAUSED EVENTS !

• OUTSTANDING COORDINATION PERFORMANCE RATING CATEGORY 2, IMPROVING TREND Pilgrim SALP

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EMERGENCY PREPAREDNESS

• APPROPRIATE ACTIONS DURING OCT 91 STORM

• PROMPT AND INFORMATIVE NOTIFICATIONS

• GOOD OVERALL EXERCISE PERFORMANCE

- CONTROL ROOM BRIEFING STRENGTH l

1 - INCORRECT ANNOUNCEMENT WEAKhTSS l * CRITIQUES IDENTIFIED IMPROVEMENT AREAS l * EXCELLENT TRAINING & DRILL PARTICIPATION

• THREE PERSONS IN EACH ERO POSITION j i

• PROCEDURE CHANGES WELL COORDINATED ,

• EFFECTIVE MANAGEMENT INVOLVEMENT

• THOROUGH CRITICAL AUDITS PERFORMANCE RATING CATEGORYl Pilgrim SALP

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l- SECURITY l

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l * EFFECTIVE SELF-ASSESSMENTS

• CONTINUED BIPROVEMENTS IN EQUIPMENT

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• EFFECTIVE COHB 1UNICATIONS l * AUDIT FINDINGS PROMPTLY IMPLEMENTED l

l * STABLE STAFF, HIGH MORALE

• PERFORMANCE-BASED TRAINING

• MAINTENANCE MINIMIZED COMPENSATORY AEASURES

• PROACTIVE FITNESS-FOR-DUTY PROGRAM o RESTORATION FROM ADVERSE WEATIER

• CLEAR CONSISTENT REPORTING

• WELL-DEVELOPED POLICIES AND PROCEDURES PERFORMANCE RATING CATEGORY 1 Pilgrim SALP l

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ENGINEERING AND TECHNICAL SUPPORT  ;

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e HIGHLY QUALIFIED ENGINEERING STAFF e ATrENTION TO CALCULATIONAL BASES e HIGH QUALITY PLANT DESIGN CHANGES e ENHANCED SUPPORT TO STATION e REDUCED BACKLOG OF SERVICE REQUESTS l-e GOOD PROGRESS ON DRAWING UPDATES e ADVANCED PREPARATION OF MODIFICATIONS e IMPROVED ANALYSIS OF EQUIPMENT FAILURES e VALVE PROGRAM INADEQUACIES e STRONG PROGRAM SUPPORT

• KEY SAFETY SYSTEM FUNCTIONS MAINTAINED l

e TEAM APPROACH TO PROBLEM SOLVING PERFORMANCE RATING CATEGORY 2, IMPROVING TREND RECOMMENDATION SWITCHYARD Bent 1GIENT PROGRAM Pilgrim SALP i

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• INITIATIVES ADDRESSED PREVIOUS CONCERNS

• CONSOLIDATED CORRECTIVE ACTION PROCESS

• BACKLOG OF OPEN PROBLEM REPORTS

• EFFECTIVE OUTAGE MANAGEhEST

• COMPREIENSIVE PERFORMANCE BASED AUDITS

• HIGH QUALITY LICENSEE EVENT REPORTS

• COMMITMENT TO SAFETY SYSTEM RELIABILITY

• SOUND APPROACH TO LEVEL " NOTCHING"

• WELL CONTROLLED ORGANIZATIONAL CHANGES

• h1 PROVED SAFETY COMMITTEE EXPERTISE

• INTAKE STRUCTURE MATERIAL CHALLENGE PERFORMANCE RATING CATEGORY 2, h1 PROVING TREND Pilgrim SALP k., ~. -,. ..a.. ... . - .

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PERFORMANCE OVERVIEW

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l * CONTINUED OVERALL IMPROVEMENT

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• PREVIOUS STRENGTHS SUSTAINED  !

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j e FOCUS ON RADIOLOGICAL CONTROL AREA ACTIVITIES i (

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• SIGNIFICANT REDUCTION IN RADWASTE AND DISCHARGES i l

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• CONTINUED EXCELLENCE IN EP & SECURITY I

• ENGINEERING SUPPORT FOR EhERGENT ISSUES L * HIGH QUALITY DESIGN CHANGES l l

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• COMPREHENSIVE QUALITY AUDITS y

• EFFECTIVELY UTILIZED SAFETY COMAurmES !

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l I' l-ENCLOSURE 5

i SALP BOARD REPORT REVISION SIIEET PAGE LINE DID READ NOW READS

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13- 7 was also evident. - was also evident  :

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Basis: To clarify which exercise was being assessed.  !

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t* -1 / ENCLOSURE 6

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-- # ~g o UNITED STATES 8' n NUCLEAR REGUL.ATORY CCMMISSION g a wAsuswot oN,0, c. 20555-t E w f

' "*"* July 27, 1993 MEMORANDUM FOR: Charles W. Hehl, Director Division of Radiation Safety and Safeguards Region I .

FROM: Frank J. Congel, Director Division of Radiation Safety and' Safeguards Office of Nuclear Reactor Regulation SUBJECT: INDEPENDENT ASSESSMENT OF EMERGENCY PREPAREDNESS UCTinN nr DII. GRIM'S SALP REP 33T ,~0R THE PEitiuD OF SEPTEMBER 29, 1991, TO MARCH 13, 1993 As requested, the Emergency Preparedness Branch has completed its independent assessment of the emergency preparedness section of the initial Systematic Assessment c;-Licensee Performance (SALP) report for Pilgrim Nuclear Power Station over the period of' September 29, 1991 to March 13, 1993. The staff reviewed the following inspection reports for this independent assessment:

1. 50-293/91-24, December 4,1991, Routine safety inspection.

2. 50-293/91-28, Jaucary 23, 1992, Annual emergency preparedness exercise inspection.

3. 50-293/92-04, May 27, 1992, Routine safety inspection.

4. ' 50-293/92-07, July 2,1992, Annual emergency preparedness exercise inspection.

5. 50-293/92-21, November 6. 1992, Routine safety inspection.

6. . 50-293/92-23, December 29, 1992, Routine safety inspection.

7. 50-293/92-26, January 21, 1993, Annual emergency preparedness program inspection.

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8. 50-293/92-28, January 28, 1993, Routine safety inspection.

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A:: iresult of ou. review we founc that inspection findings were generally well integrated into the SALP report and conclusions were consistent with the findings. However, we have identified two inspection items which we believe the. Region should assure that the SALP board has considered in preparing the final report.

The first item was identified by the resident inspectors in Inspection Report No. 50-293/92-04. During the 1991 emergency exercise, the licensee's notification form documenting the exercise's General Emergency condition, as CONTACT:

Scott A. Boynton, NRR/PEPB 504-2926 nnso,,mn,s g,,...- . ,

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Charles W. Hehl -2- July 27,1993

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sent from the Emergency Operations Facility (EOF) to the State Emergency

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Operations Center (E00), noted that the meteorological tower was out of service. The back-up meteorological tower data (scenario wind speed and

direction) were available in the EOF, but were not included on the notification form transmitted to the EOC. NRC followup found no specific

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transmission of scenario weather information from the licensee to the State.

As a result of NRC discussion with the licensee, the licensee indicated that

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backup meteorological data would be included on the notification forms when primary meteorological tower data was not available, and that EOF staff would

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be made aware of other sources for information such as meteorological data.

The communication of weather data during emergency conditions was classified

, as' an emergency exercise area for improvement. It was noted in Inspection Report 50-293/92-04 that licensee actions would be-reviewed during routine inspection, and that the effectiveness of the lir.pncaA't ea>J9res would be j assessed during the next exercise.

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The second item, identified in Inspection Report 50-293/92-26, indicated a ,

weakness in protective action recommendation (PAR) procedure knowledge.

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Although no unacceptable PARS resulted from the table-top exercises during the inspection,' inconsistencies were noted in Emergency Director and Nuclear Watch

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Engineer understanding of the PAR Flow Chart of Attachment I to EP-IP-400. ,

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The inspectors concluded that there was an indicated need for PAR procedure ;

clarification and/or training for all emergency response organization f personnel who may participate in PAR development. This item was identified as

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an Inspection Followup Item (IFI 50-239/92-26-03) for further cxamination.

In conclusion, our independent assessment nf Pilgrim's emergency preparedness program for the SALP period from September 29, 1991 to March 13, 1993, based upon inspection findings for that period, agrees with the conclusions drawn in

the initial'SALP report. However, for completeness, the two items discussed above should be duly considered by the SALP board in the course of preparing its final SALP report.

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Frank J. Con el, Director i

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Division of Radiation Safety and Safeguards

, Office of Nuclear Reactor Regulation

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