ML20150E814
| ML20150E814 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/30/1988 |
| From: | Blough A, Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20150E809 | List: |
| References | |
| 50-293-88-26-MM, NUDOCS 8807150306 | |
| Download: ML20150E814 (4) | |
See also: IR 05000293/1988026
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U. S. NUCLEAR REGULATORY COMMISSION
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Region I
Meeting No.:
50-293/88-26
Docket No.:
50-293
License No.:
Licensee:
Boston Edison Company
800 Boylston Street
Boston, Massachusetts 02199
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Facility Name:
Pilgrim Nuclear Power Station
Meeting At:
USNRC, Region I, King of Prassia, Pennsylvania
Meeting Conducted: June 27, 1988
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Reviewed By:
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Lawrence T. Doerfleiri,"Proj
t Engineer
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Approved By:
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A.' Randygrough, Chief
Date
Reactor Projects Section No. 3B
Division of Reactor Projects
Meeting Summary:
A management meeting was held at NRC Region I on June 27, 1988, to discuss the
following issues:
(1) Boston Edison Company's (BECo's) response to NRC Main-
tenance Team Inspection 50-293/88-17, (2) the status of BECo's evaluation of
RHR valve yoke cracking, and (3) the status of BECo actions in followup of its
Self-Assessment of Readiness for Restart.
The meeting lasted about two hours.
The Massachusetts Office of Public Safety, the Massachusetts Civil Defense
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Agency, and Massachusetts Attorney General's Office observed the meeting.
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9807150306 880630
ADOCK 05000293
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DETAILS
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.1.0
Purpose
The management meeting was held at the request of the Boston Edison
Company (BECo) to discuss the following issues:
(1) BECo's response to
NRC Maintenance Team Inspection 50-293/88-17, (2) the status of BECo's
evaluation of RHR Valve Yoke Cracking, and (3) the status of BECo actions
in followup of its Self-Assessment of Readiness for Restart.
2.0 Meeting Summary
The meeting was attended by those persons listed in Attachment I.
The meeting was opened with brief comments by NRC Region I Acting
Director, Division of Reactor Projects, Mr. Samuel J. Collins Mr. R. Bird
opened BECo's presentation and stated that BECo had finalized and was
delivering the following pertinent letters.
NRC Inspection Report 50-293/88-17 (Response), dated June 25, 1988;
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and,
Pilgrim Nuclear Power Station Request for Commencement of NRC
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Integrated Assessment Team Inspection and Transmittal of Schedules
for Actions Prior to Restart, dated June 25, 1988.
These letters are enclosed as Attachments II and III, respectively.
Mr. Bird indicated that the licensee was requesting the team inspection
to commence on July 11, 1988.
Mr. R. Anderson, Plant Manager, outlined
BECo's actions in response to the NRC Maintenance Team Inspection.
He
indicated that the selection of maintenance program upgrades to be com-
pleted before restart was based on licensee evaluation of self-assessment
results, Material Condition Improvement Action Flan feedback, INP0 find-
ings, and NRC inspection findings.
Relative to maintenance staffing,
Mr. Anderson indicated that full staffing had been achieved and current
efforts were focusing on hiring to permanently fill those positions cur-
rently staffed by contractors.
Mr. Anderson discussed the licensee's ongoing evaluations of cracking
identified on June 7,1988, in two motor-operated valves in the Residual
Heat Removal System.
Mr. Anderson indicated that BECo would notify the
industry of the problem, as well as keeping NRC informed of the progress
of evaluations and repairs.
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Mr. Ledgett provided an overview of the self-assessment process and stated
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that the June 25, 1988
letter (Attachment III)
provides
status and
schedule for those self-assessment followup actions to be performed before
restart. Mr. Anderson outlined additional work, including extensive test-
ing, to be conducted before restart.
He also stated that NRC Bulletin 88-05 response was an emergent issue under licensee evaluation.
3.0 Concluding Statement
Af ter a private caucus with the NRC participants, Mr. William T. Russell,
NRC Region I Administrator, summarized the meeting, thanked the licensee
for the information provided, and indictted that NRC would complete its
review of the information and inform the licensee of the results within
two weeks.
Attachments:
1.
Meeting Attendees
2.
GECo Letter to NRC dated June 25, 1938, NRC Inspection Report 50-293/88-17
(Response)
3.
BEco letter to NRC dated June 25, 1988, Pilgrim Nuclear Power Station
Request for Commencement of Integrated Assessment Team Inspection and
Transmittal of Schedules for Actions Prior to Restart
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ATTACHMENT 1
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Meeting Attendees
U.S. Nuclear Regulatory Commission
W. Russell, Regional Administrator (Summary Only)
S. Collins, Deputy Director, Division of Peactor Projects (DRP)
R. Gallo, Chief, Operations Branch, Division of Reactor Safety (DRS)
J. Wiggins, Chief, Reactor Projects Branch No. 3, DRP
A. Blough, Chief, Reactor Projects Section No. 3B, DRP
L. Doerflein, Project Engineer, RPS 3B, DRP
B. Boger, Assistant Director for Region I Reactor, Office of Nuclear
Reactor Regulation (NRR)
D. Haverkamp, Chief, Reactor Projects Section No. 3C, DRP
N. Blumberg, Chief, Operational Programs Section, DRS
C. Warren, Senior Resident Inspector
Boston Edison Comnany
R. Bird, Senior Vice President - Nuclear
K. Highfill, Pilgrim Station Director
R. Anderson, Plant Manager
R. Swanson, Nuclear Engineering Manager
P. Hamilton, Compliance Division Manager
R. Ledgett, Director, Special Projects
E. Robinson, Manager, Nuclear Information
Commonwealth of Massachusetts
P. Agnes, Assistant Secretary of Public Safety
J. Hausner, Director, Nuclear Safety Energency Preparedness Program
G. Dean, Assistant Attorney General
Other Attendees
S. Sholly, MHB Associates
F. Jan, ASTA Engineering, Inc.
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ATTACHMENT 2
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Pdgrim Nuclear Pcwer station
Rocky Hdi Road
Plymouth, Massachusetts 02360
June 25, 1988
se hV$ce'PrNident--Nuclear
BECo Ltr. #88-98
U.S. Nuclear Regulatory Commission
Attn: Document Control Desk
Hashington, D.C. 205S5
Docket No. 50-293
License No. OPR-35
Subject: BRC Insoection Reoort 50-293/88-17 (Resoonse)
Dear Sir:
Attached is Boston Edison Company's response to the NRC Region I Haintenance
Assessment Team Inspection conducted from April 25 through May 5, 1988, at the
Pilgrim Nuclear Power Station (PNPS), Plymouth, Massachusetts and at the
Braintree, Massachusetts engineering office.
Boston Edison Company concurs with the NRC Assessment Team conclusions that:
1.
No violations of regelatory requirements were identified during the
inspection.
2.
Several program and performance strengths were identified.
3.
Certain concerns, including some that were considered significant,
were identified.
These conclusions are consistent with the actions mandated by our Material
Condition Improvement Action Plan (MCIAP) and the independent conclusions of
our Restart Readiness Self-Assessment (RRSA) conducted between April 18, 1988
and May 2, 1988. Boston Edison Company has accelerated the actions necessary
to implement those MCIAP and RRSA items which will resolve the significant NRC
Assessment Team concerns.
Boston Edison Company will address prior to restart, concerns identified in
the areas of (1) maintenance program, (2) staffing, and (3) program
performance.
The details and status of our corrective actions are discussed
in Attachment A.
R. Ledgett and R. Blough agreed on 6/23/88 that submittal of
this letter by 6/27/88 is acceptable.
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Docket No. 50-293
License No. DPR-35
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,P ease do not hesitate to contact mb if there are questions or comments
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regarding the attached response.
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Attachment
cc: Mr. Hilliam Russell
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Regional Administrator, Region I
U.S. Nuclear Regulatory Commission
475 Allendale Rd.
King of Prussia, PA 19406
Sr. Resident Inspector - Pilgrim Station
Standard BECo Distribution
ATTACHMENT 'A'
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Boston Edison Company
BECo Ltr: 88-98
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Pilgrim Nuclear Power Station
Docket No. 50-293
License No. DPR-35
Insoettion Reoort 88-17 Resoonse
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Boston Edison has reviewed the concerns discussed in Section 1.2 of the NRC
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Maintenance Assessment Team Report and concurs with the NRC Assessment Team
conclusions. .These conclusions are consistent with the independent actions
and conclusions of our Material Condition Improvement Action Plan (HCIAP) and
our Restart Readiness Self-Assessment (RRSA) conducted during the period of
April 18, 1988 to May 2, 1988.
Boston Edison has accelerated the
implementation of those HCIAP and RRSA actions necessary to resolve the
significant NRC Assessment Team concerns. The areas of concern are:
Maintenance Program
Maintenance Staffing
Program Performance
I.
Maintenance Proaram
The following is a summary of the actions taken in the area of the Maintenance
Program:
Boston Edison has taken action to more clearly define work control
practices in approved plant and department procedures as well as to
formalize the current plant work control practices for Haintenance.
To accomplish this, the ongoing comprehensive rewrite of the PNPS
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Maintenance Section Manual was completed to more clearly describe its
purpose, intent, structure, and its relationship to other sthtion
directives and procedures.
This rewrite incorporates INP0 Guidelines85-038, "Conduct of Haintenance at Nuclear Power Station", to enhance
maintenance practices at Pilgrim Station. Additionally, Boston
Edison performed a major rewrite of PHPS Procedure 1.5.3,
"Haintenance Requests", to incorporate improved administrative
controls. A new procedure, PNPS Procedure 1.5.3.1, "Haintenance Hork
Plan", was developed to be utilized in conjunction with the
Maintenance Request (HR) as an administrative tool to provide a Hork
Plan which further defines (details) the maintenance activity to be
performed.
Boston Edison has taken action to provide improved specifications for
unique and routine maintenance previously covered by Procedure 3.H.1-11,
"Routine Haintenance", to ensure adequate preparation of work packages for
such tasks.
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ATTACHMENT 'A'
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Insoection Reoort 88-17 Resoonse
(cont'd)
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To accomplish this, Boston Edison prepared, approved, and implemented
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Procedure 1.5.3.1, "Maintenance Hork Plan".
This procedure, used in
conjunction with the revised Procedure 1.5.3, "Maintenance Requests",
provides an effective means to specify unique instructions for
routine maintenance tasks formerly covered by Procedure 3.M.1-11.
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Maintenance Hork Plans are now required to centain specifically
defined steps for the performance and documentation of maintenance
activities. MRs written prior to the implementation of the revised
maintenance program, and which referenced Procedure 3.M.1-11, are
reviewed and approved by the Plant Maintenance Section Manager prior
to implementation to ensure that the intent of the revised
maintenance procedures is met.
II. Maintenance Staffing
Boston Edison conducted a review in the last quarter of 1987 of the authorized
staffing level. An integral part of this review included an estimate of
manpower resources required to meet and maintain the established performance
goals of the Maintenance Section.
Based on this review, the permanent full-time Maintenance complement has been
increased.
Ten of these positions are supervisory positions.
Revisedjob
descriptions have been developed for this expanded organization and hiring
efforts are aggressively underway.
Attention to the plant's material condition has been increased by the
expansion of the permanent complement of maintenance personnel, Attention has
been further enhanced by assignment of the Systems Engineering Division (SED)
to provide increased support to individual maintenance activities thereby
reducing the burden on maintenance personnel. The SED conducts in-depth
research for the majority of individual Failure and Malfunction Reports
(F&MRs).
The overall knowledge, experience, and performance levels of the Maintenance
staff is being improved.
This is being accomplished by:
Recruitment of personnel with greater experience levels to fill
'Jacant and new positions.
Improved training.
Development of well-defined job descriptions.
Improved Maintenance management and supervision.
The experience level of the Maintenance staff has been further enhanced by
creating the position of Deputy to the Maintenance Section Manager.
This
position has been filled by an individual with approximately 25 years of
experience in production aid planning for nuclear repair, overhaul, and
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refueling work,
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ATTACHHENT 'A'
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Ins;ection Reoort 88-17 Resoonse
(cont'd)
III. Maintenance Performance
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Boston Edison, through programmatic changes, is implementing actions which
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elements of the work control process. The improvement in the maintenance
program described in Set. tion I above, in conjunction with the staffing
increase and upgrades, is designed to result in improved maintenance
performance.
The following is a summary of the actions taken to improve performance:
Boston Edison has taken action to ensure that MRs are both complete and
correct.
The revision of Procedure 1.5.3 incorporated additional guidance and
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requirements regarding the preparation, review, and approval of MRs
to ensure correctness and completeness.
The Maintenance Summary
Control (MSC) form has been deleted.
The function of the MSC has
been integrated into the new Maintenance Hork Plan (Procedure
1.5.3.1).
Training has been conducted, with emphasis on the
appropriate method of processing a work plan and the need for the
documentation to be complete and accurate.
Boston Edison has taken action to control expansion or revision of the
originai work scope during maintenance in the field and to require
documentation of the actual work performed.
To accomplish this, Procedure 1.5.3.1 specifies the controls
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necessary to make revisions to the work package. Additionally, any
revision to the Work Plan must be reviewed and approved in the same
manner as the original document.
The work performed will be
documented and will become a part of the completed maintenance
package.
Boston Edison has taken ar. tion to ensure that complete work packages,
including necessary instructions, are available at the work site.
The revised maintenance program now provides the necessary guidance
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and program controls to ensure that work packages, including the
necessary instructions, are available at the applicable work site
when maintenance activities are being performed.
Boston Edison has taken action to ensure that Maintenance provides
documentation of material used, maintenance and test equipment
information, and work performed (including torque values).
The Hork Plan now requires this information to be documented by the
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maintenance personnel and becomes a part of the completed work
package.
The process develops a chronological history of the
individual activities.
Boston Edison has taken action to improve storage and retention of
maintenance records.
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Insoection Reoort 88-17 Resoonse
(cont'd)
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Upon completion of a maintenance task, the final work package is
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returned to the responsible Staffing / Planning Engineer for review and
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closure.
It is then processed by Document Control for retention as a
complate package,
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Boston Edison has taken action to ensure proper documentation of post work
testing.
The Work Plan now requires the maintenance post work testing to be
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identified, reviewed _ for adequacy, and results documented as part of
the completed work package.
These program improvements, coupled with the increased management focus and
direction, will ensure continued program improvement.
IV. Overview of the Revised Maintenance Proaram
The comprehensive rewrite of the Maintenance Section Manual for PNPS is
complete.
The changes and additions more clearly. describe its purpose,
intent, structure, and its relationship to other station directives and
procedures. This rewrite incorporates INPO Guidelines85-038, Conduct of
Maintenance at Nuclear Power Stations, to enhance maintenance practices at
Pilgrim Station.
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Boston Edison also performed a major rewrite (revision) of PNPS Procedure
1.5.3 "Maintenance Request" (MR) to incorporate stronger administrative
controls to identify problems, initiate, plan, track and accomplish station
maintenance with precise supervisory control on both safety-related and
nonsafety-related components, equipment, or structures. A new procedure, PNPS
Procedure 1.5.3.1 "Maintenance Work Plan" (MHP), was developed to be utilized
in conjunction with the Maintenance Request as an administrative tool to
provide a Work Plan which further defines (details) the work to be performed
including special tools, equipment, procedures, instructions, technical
documentation, expected exposure levels (if applicable) and to provide
feedback when work is completed. Revisions to MHPs will not change the intent
of the work scope originally approved.
Revisions to the Work Plan will be
reviewed and approved in the same manner as the original document. The Work
Plan and the parent MR are the controlling documents for installation of a
modification or performance of a maintenance work activity. The Work Plan
specifies the requirements for examination, and testing, and includes the
applicable instructions, procedures and drawings.
It also specifies
hold / witness points and provides for controlling the work in the event of a
nonconformance.
The highlights of these major revisions to PNPS Maintenance procedures are:
(1) the work documents are incorporated into a single work package for each
work activity, (2) the process of the Maintenance Hork Package provides
increased control in that the engineer who develops the package maintains
control during the process, (3) Management level review and approval of
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revisions, including Quality Control and Operations, are part of the process,
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and (4) the final package, along with copies of the required documentation is
returned to the engineer for review, closure, and processing to Document
Control.
These procedure revisions ha 9 been completed, reviewed, approved
and implemented.
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ATTACHMENT 'A'
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Insoection Recort 88-17 Resonlig
(cont'd)
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Boston Edison has conducted a series of formal training sessions for the
Haintenance Managers, Supervisors, Maintenance Craft and selected personnel
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from other sections that are directly or indirectly involved in the
processing, review, or examination of the new HR/HWP process. This training
was completed on June 17, 1988, with program implementation on June 20, 1988.
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To reduce the impact on production, and provide a smoother transition,
management oversight of the new HR process is being increased during the
implementation phase.
In addition, the Quality Assurance Surveillance
Division will be conducting surveillance on the revised Maintenance Program to
monitor implementation and performance.
This response focuses primarily on the corrective actions taken to resolve the
concerns described in Section 1.2 of the Team Report. Other corrective
actions and program improvements have also been identified and are being
addressed by Boston Edison Management. Although some items are not designated
as RESTART actions, these items are incorporated into long term programs such
as the "Haterial Condition Improvement Action Plan" (HCIAP).
Boston Edison is
continuing these actions / improvements with the goal of achieving and
sustaining the highest standards of maintenan:e performance.
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ATTACHMENT 3
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Pilgnm Nuclear Power State
Rocky Hill Road
Plymouth, Massachusetts 02360
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Ralph G. Bird
',enior vice President - Nuclear
BECo Letter #88-099
U.S. Nuclear Regulatory Commission
Attn:
Document Control Desk
20,555
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Docket No:
50-293
License No:
Pilgrim Nuclear Power Station Request for Commencement
of
NRC
Integrated
Assessment
Team
Inspection
and
. Transmittal of Schedules for Actions Prior to Restart
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Dear Sir:
Boston
Edison
Company
hereby
requests
that the Nuclear
Regulatory Commission
(NRC)
commence its Integrated Assessment
Team Inspection (IATI) of Pilgrim Nuclear Power Station on July
11, 1988.
Boston Edison provided the NRC with the results of its
Restart Readiness Self-Assessment (RRSA) on May 26, 1988.
This
letter provides the schedule for those matters identified in the
RRSA which require completion of specific, well defined actions
for restart.
Attachment I contains summaries of RRSA Chapter II. A items
and schedules for remaining actions to be done before restart.
Attachment II is an integrated summary-level schedule for the
remaining work and testing before restart.
This schedule is also
the Target Schedule to be inserted into the Restart Plan, Volume
2,
Rev. 2 as Appendix 2.
Attachment III is an errata sheet for the RRSA.
This sheet
should be inserted into each of the copics of the report in your
possession.
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June 24, 1988
Docket No:
~ 50-293
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BECo Letter #88-099
License No:
Page 2
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Please contac.t me or R. A.
Ledgett if you have any questions
about
the
schedules
and
status
information
provided
in
Attachments 1 and 2 or if yon need additional information in
preparation for commencing the IATI.
. G.
Bird
/ Attachments
cc:
Mr. William T. Russell
Regional Administrator
,
U.S.
Nuclear Regulatory Commission - Region I
475 Allendale Road
King of Prussia, PA
19406
Mr.
D. G. Mcdonald
Project Manager
Division of Reactor Projects I/II
U.S. Nuclear Regulatory Commission
Mail Stop #14D1
One White Flint North
11555 Rockville Pike
Rockville, MD
20852
Senior NRC Resident Inspector
Pilgrim Nuclear Power Station
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Attachment 1
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Matters that Require Specific Action Before Restart
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Identified in Chapter II.A of the
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Belf-Ascessment for Restart Report
The~ most
important
matters
identified
during
the
RRSA
relating -to
plant
and
equipment
performance,
operational
performance, management and ozganization that require specific
action before restart were described in Chapter II.A cf the Self-
Assessment for Restart Report.
Specific plans or actions to be
implemented prior to restart are summarized below.
Actions already completed are designated "Complete." Dates
under "Complete" annotations indicate the date the action was
completed or the time frame in which the actions were taken.
Actions scheduled for completion between the date of this letter
and restart have the completion date designated.
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RRSA SECTION
II.A.1.a
"The first portion of the process (for
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reporting deficiencies and initiating
corrective action)
--a single reporting
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form and a corrective actio'n clearinghouse
-- will be initiated prior to restart.
In
the longer term, this activity will be
expanded and integrated with PNPS
information systems with the objectives of:
a) reducing the number of redunaant
corrective action tracking systems; and b)
providing more readily accessible and
usable management information tools."
DETAILED PI.AN or ACTION AND SCHEDULE DATE FOR II. A.1.a
1.
The PNPS Housekeeping Manual has been
Complete
issued and implemented.
Expanded
(May, 1988)
specific area owner assignments are
evntained in the manual.
2.
"Clearing house" was formed and began
complete
operation to screen personnel,
(Jun 13, 1988)
administrative and material deficien-
cies and to generate necessary
documentation to effect correction
(e.g. MR, PCAQ,'DR, NCR, etc.).
The
initial efforts of the clearing house
are being focused on dealing with the
backlog of items generated in the
cours9 of the self assessment as
delincated in a and b below,
a.
Document presently known material
Aug 01, 1988
deficiencies (Management
Oversight and Assessnent Team
Field Notes, Peer Evaluator
reports).
This is being
accomplished by the Systems
Engineering Division working with
c1 caring house personnel,
b.
Categorize and document non-
Aug 01, 1988
material deficiencies.
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DETAIIED PLAN or ACTION AND SCHEDUIE DATE FOR II. A.1.a
c.
Following the initial trial
period, thic organization will be
formally proceduralized.
The
first part of thi'proceduralizing
Aug E,
1988
process will be to create a
single reporting form based on
the experiences gained in
processing the work to date.
3.
QA Surveillance Upgrade program will
be implemented. ,The scope of this
upgrade program will extend beyond the
established Appendix B requirements.
a.
Draft QA Action plan to upgrade
Complete
the e.udit/ surveillance process.
b.
Train QA Division Manager in the
Complete
upgraded program.
(Jun 1988)
c.
Train remaining QA Department
Sep 1988
personnel in upgrade program.
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RRSA SECTION
II.A.1.b
"Priority actions are being directed to
filling 32 (29) newly authorized, permanent
Boston Edison positions within the
Maintenance Section that are now staffed on
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an interim basis by contractors.
Ten of
the positions are designated for
supervisors and work planners.
Management
has given advance approval and the highest
priority for hiring in order to more
effectively support team building within
the Maintenance Section.
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Additional items scheduled before restart
include:- (a) issuance of an
improved / updated Maintenance Control
(Section) Manual, which will formalize many
of the improvements presently in place, (b)
revising the troubleshooting procedure to
more clearly document work activities
during and subsequent to a troubleshooting
task; and (c) capturing remaining
improvements in appropriate formal PNPS
documents.
The Station Director and Plant Manager will
continue to exercise.close oversight of the
maintenance function through restart, power
ascension, and initial power operation to
assure that management control is
effectively maintained and improved.
In
this regard, particular emphasis will be
placed upon training and monitoring of
responsible organizational elements to
increase their familiarity with and
attention to the work control process."
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DETAILED PIAN or ACTION AND SCHEDULE DATE FOR II. A.1.b
A.
Initiate priority actions to fill
Boston Edison positions in the Main-
tenance Section.
As of June 23, 1988
eleven new employees hve been hired
a
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in this effort.
B.
Revise / Issue Maintenance Control
Procedures
1.
Procedure 1.5.3 (Maintenance Request
Procedure).
,
a.
Prepare draft
Complete
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b.
Formulate and conduct training
Complete
c.
Implement procedure
Complete
(Jun 20, 1988)
2.
Procedure 1.5.3.1 (Maintenance Work
Plan)
a.
Prepare draft
Complete
b.
Formulate and conduct training
Complete
c.
Implement procedure
Complete
(Jun 20, 1988)
3.
Rewrite
Maintenance Section Manual
a.
Prepare drafts
Complete
b.
Review drafts
Complete
c.
Develop training
Complete
d.
Conduct training
Jul 1,
1988
e.
Develop Plan of Action for
Complete
implementation
(Jun 24, 1988)
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DETAILED PLAN or ACTION AND SCIIEDULE DATE FOR II.A.I.b
4.
Implement Instrumentation and Control
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(I&C) valve lirse up procedure.
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Complete
a. Draft procedure
.
b. Install Phase I tags
complete
c. Develop and conduct training
Complete
d. Issue procedure
Complete
'
e. Develop plan of action for complete
Complete
tagging
(Jun 23, 1988)
5.
Upgrade Environmental Qualification
(EQ) procedure.
a.
Approve draft procedure
Complete
b.
Develop training
Complete
c.
Conduct training
Complete
d.
Issue procedure
complete
Lift stop Nork order
Complete
e.
(Jun 20, 1988)
6.
Implement Lif ted Leads Procedure
(1.5.9.1)
Complete
a.
Approve draft procedure
Complete
b.
Develop training
Complete
c.
Conduct training
Complete
d.
Issue procedure
(Jun 1,
1988)
6
.
-
. _ _ _ , _ _ - _ - _ _ .
--
. - _
-.
. - _ ._______--_ ___
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
__
__
_ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _
.
..
DETATIED PLAN or ACTION AND SCliEDULE DATE FOR II. A.1.b
'
7.
Implement torquing procedure
a.
Determine scope a.nd receive
Complete
engineering inpat
,
b.
Prepare draft procedure
Complete
c.
Review draft procedure
Jun 27, 1988
d.
Develop and conduct training
Jul 8,
1988
e.
Issue procedure
Jul 15, 1988
8.
Imp' lament valve stem lubrication
procedure
a.
Determine scope
Complete
b.
Determine lube types
Jun 27, 1988
c.
Develop procedure
Jun 27, 1988
d.
Develop and conduct training
Jul 1988
e.
Issue procedure
Aug 1,
1988
f.
Revise PM dchedules
Aug 1988
9.
Revise the troubleshooting procedure
Aug 1,
1988
to more clearly document work
activities during and subsequent to
troubleshooting.
,
7
..
j
- _ _ -
,
-
DETAIIID PLAN or ACTION AND SCIIEDULE DATE FOR BOTH II. A.1.a & b
l
,
The Work Prioritization Team function has
Complete
been proceduralized in the recently
completed revision of PNPS 1.5.3,
-
,
Maintenance Requests (MRs).
In combination
with the Rotating Window concept, each
system's status is periodically reviewed
and station management focuses on the
'
system's deficiencies.
Thus MRs of all
priorities are evaluated and the items
scheduled are those that support system
performance and address plant reliability.
The Maintenance Section Manager has
Complete
addressed the issue of qualification to
perform maintenance with Division Managers
and S Jpervisors.
Maintenance tasks are
assigned based on the satisfactory
completion of the applicable training or
the previous experience of the individuals.
.
8
. _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _
0
.
a
BBSA'SECTION
II.A.1.c
"a.
Continue the process for hiring.
b.
Develop an integrated schedule for
remaining surveillance and testing to
meet restart using an inter-
.
disciplinary team.
c.
Continue addressing remaining
maintenance work required for restart
in the Plan-of-the-Day and assure that
resources are focused on meeting
scheduled dates.",
II.A.1.d
"Complete reviews, sequence, and schedule
any additional testing identified by these
reviews for completion prior to restart or
during power ascension testing."
DETAILED PIAN or ACTION AND SCHEDULE DATE FOR II. A.1.c & d
1.
A detailed schedule for accomplishment
Complete
of fire barrier surveillances has been
(May 26, 1988)
issued and has been incorporated into
the integrated schedule for work and
testing.
2.
NED periodically issucs a report to
Latest version
address "issues 'that could potentially
dated:
delay restart . "
Jun 20, 1988
3.
An integratect schedule for work and
Complete
testing has been issued in summary
(Jun 23, 1988)
schedule form and is included as a
separate attachment to the cover
letter for *:his document.
The
schedule incorporates vemaining
maintenance work, Logic system
Functional Tests [LSFTs), fire barrier
surveillances, and other surveillances
and controlling paths.
4.
The process for hiring of personnel
has been continued.
As of June 23,
1988 sixteen personnel have been hired
for this department.
9
,
- .
4 -
4
DETAILED PIAN or ACTION AND SCIIEDULE DATE FOR II. A.1.c & d
5.
Review of testing for plant equipment
and systems are being completed to
confirm their readiness.for reactor
operation.
'
-
a.
Reviews of Logic Systems
Aug 22, 1988
Functional Tests ( LS FT) ,
Simulated Automatic Actuation
Tests and Plant Design Change
post work test procedures for
adequacy.
,
b..
Review to verify the scope of
Jul 7,
1988
planned power ascension dynamic
testing.
The review process is
as follows:
Select relevant dynamic
-
events, (operating tran-
sients).
Define expected transient
-
response, (system component
and plant parameter).
Identify changes made,
-
(Plant Design changes, major
maintenance and emergent
problems) which could
potentially affect plant
transient response.
Predict and evaluate
-
potential impact on plant
response due to failures,
malfunctions or installation
errors.
Evaluate completeness and
-
adequacy of tests done or
planned during power
ascension to assure adverse
impact, if any, could be
detected.
10
. -
- -
, _ _ _ - _
G'
a
.-
DETAILED PIAN or ACTION AND SCliEDULE DATE FOR II. A.1.c & d
c.
Review to verify that plant
Jul 22, 1988
systems will be tested and are
operable before restart.
A list
of surveillance and test procedu-
.
res is being prepared for selec-
ted systems.
The list includes
Technical Specification surveil-
lances and non-Technical speci-
fication required procedures
which support operabilicy.
The
complete lis,t of procedures will
be reviewed to ascertain which
procedures should be performed
,
before restart.
Considerations
will include date last performed
and whether work has been
performed since the last test.
.
11
O.
n
.-
RRSA SECTION
II.A.2.a
"a.
Prior to restart, complete
reviews and any necescary changes
-
to provide improved control over
valve position and to enable
operators to more readily
,
determine valve position status.
b.
Prior to restart, revise the-
tagout procedure to limit the
types and clarify the uses of
specific tags.
c..
Prior to restart, develop a plan
to imple en* the INPO good prac-
tices f;;
,a'.ve lineups and labe-
111ng if
w .ird to instrument is-
olation
c',,es,
d.
Prior to startup, develop instru-
ment-specific valve lineup sheets
for all safety system and cr-
cal Balance of Plant systems."
DJD'AIIID PIAN or AC'f]ON AND SCHEDULE DATE FOR II. A.2.a
1.
Revision to PNP 5 Procedure 1.4.5,
Aug 1,
1988
Equipment Tagout, is in progress.
Some specific in.provements include:
a.
Elimination of the use of red
danger tags to mark lifted leads,
b.
Improved control over NWE and
test tagging.
c.
Requirements to perform lineups
following removal of equipment
clearance tags.
12
,
!
-
--
_.
_
_
.
.
o'
DETAILED PLAN or ACTIOd AND SCilEDULE DATE FOR II . A. 2
.4
2
,
)
2.
Operations has completed reviews of
Aug 15, 1988
-
the valve position control procedure.
Prior to startup, each operating
system will be given a complete valve
,
lineup as close as practical to the
actual startup date.
Subsequent to
that lineup, periodic lineups at
specified frequencies will be
performed on all accessible
components.
Additional improvements
will be considered and implemented
whenever necessary to improve operator
control over and knowledge of valve
positions.
3.
An instrument specific instrumentation
Complete-
and control (I&C) valve lineup
(Jun 22, 1988)
procedure has been issued for safety
systems and selected Balance of Plant
instruments. This procedure was based
on INPO good practices for valve
lineups.
,
,
e
13
m
== q
-#--
-w-
.-a+%.
--p
9
p
g
i+
wy-
=
, _ .
-O
n
,-
RRSA SECTION
II.A.2.b
"Complete the review of the ESF actuation
'
study and initiate positive actions to
+
.
reduce the occurrence of unplanned ESF
actuations."
'
,
DETAILED PIAN or ACTION AND SCHEDULE DATE FOR II . A. 2.b
1.
Complete a pre-restart test review to
Jul 1,
1988
identify those tests needed to
minimize problems most likely after
start-up from a long outage.
2.
Conduct the pre-restart tests
Aug 19, 1988
identified during the review of 1
above.
-
3.
Conduct a review of "Management
Comple'te
Lessons" in NUREG 1275 and evaluate
(May 23, 1988)
for applicability to PNPS.
4.
A review has been performed of
Aug 19, 1988
training conducted on industry
operating experience.
Training on
thermal binding of large gate valves
has now been included in the operator
training program to be completed
before restart.
.
5.
Inadvertent ESF Actuation Task Force
Aug 1,
1988
will complete analysis, and corrective
actions to disseminate lessons learned
and prevent recurrence will be
completed.
6.
Anti-spill Task Force will complete
analysis of spill events and
corrective actions will be
implemented.
a.
Complete analysis of all spills
Jun 27, 1988
in 1988.
b.
Convene task force to establish
Aug 1,
1988
corrective actions and develop
schedule to implement corrective
actions.
14
.
. _ _
,
__
^
,
r.
'
.
RRSA SECTION
II.A.2.c
"No additional actions (to improve the
formality of communications) are required
-
for restart, although Boston Edison will
initiate steps to apply appropriate
portions of the standards for Control Room
-
communication to I&C and other personnel
identified for improvement."
DETAILED PLAN or ACTION AND SCHEDULE DATE FOR II.A.2.c
1.
Communications training for licensed
Complete
operators is compKete.
(Apr 1988)
2.
Communications training for non-
Aug 19, 1980
licensed-operators is in progress.
3.
A Station Instruction (SI-nP.0006) has
Complete
been established for standards of
(Nov 4,
1987)
communications in the Control Room.
.
t
15
_
_
B
.
.'
RhJA SECTION
II.A.2.d
"Validate procedures revised during RFO-7.
-
Prior to restart, complete training on
procedures revised for modifications and
implement the writers guide,..
An upgrade of
Operations procedures by the Procedures
'
,
group is scheduled as a long-term ef fort. "
DETAILED PLAN or ACTION AND SCIIEDULE DATE FOR II. A.2.d
1.
Procedure validation is in progress.
Jul 15, 1988
As of 6/17/88, it is approximately 60%
complete for all, procedures revised
since April 1986.-
2.
Conduct training on operations
Aug 19, 1988
procedures revised for modifications
implemented during RFO-7.
3.
Issue the Procedure Writer's Guide.
Jun 29, 1988
4.
The validation process has been
Complete
defined in TP 88-07.
(Jan 30, 1988)
5.
Specific procedural deficiencies as
Aug 1,
1988
delineated in the MO&AT Field Notes
will be dispositioned.
6.
Improve human fa'ctors in EOPs and
Complete
satellite procedures.
7.
Human factors improvements in other
procedures is not a restart issue and
will be completed as
longer term
a
project.
16
.
.'
RRSA SECTION
II.A.2.e
"Resolve deficiency reports (on Priority A
drawings) prior to restart."
.
DETAILED PIAN or ACTION AND SCHEDULE DATE FOR II. A.2.e
,
1.
Independent review of Priority A
Complete
drawings was completed by the Surveil-
(May 20, 1988)
lance Monitoring Group.
Two DR's were
issued.
2.
Conduct a survey of all Priority A
Complete
drawings and associated messages in
"SEEK."
'
"
3.
NED review the accuracy and validity
Jul 22, 1988
of each message in "SEEK" for Priority
A drawings.
4.
Request removal of unnecessarv ' SEEK"
Jul 22, 1988
messages.
5.
Complete drawings update.
Aug 15, 1988
6.
The effectiveness of having Priority A
Aug 15, 1988
drawings updated and issued prior to
operational turnover of a modification
is the subject of a DR, (See Item #1
under II.A.2.e shove).
The resolution
of the DR, including completion of
corrective actions constitutes the
verification of adequacy of the
_ . _ ,.. .... _ . _ ... .. _ P.F.o c e s s .
. _ _ ,__,, _ , _
,,
, _ ___ _ , __, ,
,
,,,,_ , _ _ _ _
17
.-
.*
9
RRSA SECTIQH
.
II.A.3
"Prior to restart begin actions to
institutionalize practices involving:
.
a.
Planning,' scheduling, ~ assignment, pre-
job briefing, and control of
'
,
maintenance; and
b.
The event investigation and critique
process, including the process for
determination of underlying causes,
and assigning and accomplishing
identified actiops.
After power ascension, efforts will be
directed to institutionalizing the peer
evaluator process, and developing a long-
term, issue oriented data base."
DETATLED PLAN or ACTION AND SCHEDULE DATE FOR II.A.3
Good practices in use that will be formally
proceduralized:
1.
Specification of permissable or
Jun 27, 1988
required times to conduct post work
testing in Maintenance Requests.
2.
System Window C6ncept for maintenance.
Aug 30, 1988
3.
Describe work flow process.
Complete
(Jun 20, 1988)
~' '
~
'"
3.
Work Package Development Checklist.
Complete
(Jun 20, 1988)
5.
MR Data Base accessability via the
Jun 27, 1988
Prime computer at 12 terminal
locations.
6.
Define Work Prioritization Team
Complete
concept.
(Jun 20, 1988)
7.
ALARA aspects of development of
Jul 15, 1988
preoperational tests.
8.
System turnover process.
Jul 15, 1988
9.
New training material on NPA trash
Jul 1,
1988
compactor operations.
18
, _ - .
e
.
i
DETAILED PIAN or ACTION AND SCHEDULE DATE FOR IT. A.3
.
10.
Refresher academic training for
Jul 1,
1988
license candidates.
'
.
11.
The practice of giving 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> NRC
Jul
1,
1988
style written practice exams.
12.
Methodology to deal with testing of
Jul 15, 1988
special projects such as Hydrogen
Water Chemistry Control.
13.
The practice of p'roviding NTD
Jul 1,
1988
instructors on-shift for NRC license
candidates.
14.
The practice of giving NRC license
Jul 1,
1988
candidate NRC style walkthrough and
oral practice exams.
15.
Glove bag use.
Aug 15, 1988
16.
Excavation practices.
Aug 15, 1988
17.
Prevention of excavations in the
Aug 15, 1988
buffer zone.
18.
Pre-job briefing's (in excess of RWP
Complete
requirements) .
(Jun 20, 1988)
19.
Conduct of spill drills.
Jun 30, 1988
20.
The Fire Protection System status
Jul 22, 1988
boards.
21.
Requirements for medical attention
Aug 15, 1988
off-site.
22.
Inspections of work sites by super-
Aug 15, 1988
visors.
23.
Personal safety responsibilities.
Aug 15, 1988
24.
Station overtime policy.
Jul 15, 1988
25.
Event critique procedure.
Complete
l
(Jun 20, 1988)
I
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'
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'
- _ _ _ _ - _ _ _ _ _ .
,
4
. ?'
.
2
Attachment 3
-
.
Self-Assessment of Readiness foi- Restart ReDort Errata
'
.
Chances
Pace
Line
Report
Correction
I-13
16
32
29
,
II-4
21.
32
29
.
II-29
4
32
29
IV-9
21
32
29
l
IV-10
6
120
160
IV-12
19
32
29
V-13
13
32
29
V-15
2
120
160
V-18
16
23
27
l
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_ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _