ML20154C279
| ML20154C279 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/07/1988 |
| From: | Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20154C278 | List: |
| References | |
| 50-293-88-21, NUDOCS 8809140304 | |
| Download: ML20154C279 (161) | |
See also: IR 05000293/1988021
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No.:
50-293
Report No.:
50-293/88-21
Licensee:
Boston Edison Company
Pilgrim Nuclear Power Station
RF0 #1, Rocky Hill Road
Plymouth, Massachusetts 02360
Facility:
Pilgrim Nuclear Power Station
Location:
Plymouth, Massachusetts
Dates of Inspection:
August 8-24, 1988
Inspectors:
(See Attachment E)
_ _ ' 7/89
i whc e T.
Approved By:
'
nn
Dw
-
A. Rt.ndy Blough, Ch'ief
~f
Dath
Reactor Projects Section No. 3B
Division of Reactor Projects
Inspection Summary:
Areas Inspected:
Integrated Assessment Team In:,pection to assess the degree
of readiness of licensee management controls, programs, and personnel to sup-
port safe restart and operation of the plant.
The scope of the inspection is
further detailed in Section 2.2.
Results:
The team concluded that licensee management controls, programs, and personnel
are generally ready and performing at a level to support safe startup and
operation of the facility.
Results are further summarized in Sections 1.0
(Executive Summary) and 2.3 (Summary of Findings).
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TABLE OF CONTENTS
Page
ACR0NYMS.......................................................
iv
1.0 EXECUTIVE SUMMARY.........................................
1
2.0
INTRODUCTION..............................................
2
2.1
Background...........................................
2
2.2 Scope of Inspection..................................
3
2.3 S u mm a ry o f I AT I R e s u l t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4
2.3.1
Overall
Summary............................
A
2.3.2
Summary of Results by Functional Areas.....
5
2.4 Licensee Commitments.................................
9
2.4.1
Procedure Validation and Training..........
9
2.4.2
Identifying Procedure Changes Requiring
Training.................................
9
2.4.3
Temporary Modifications....................
9
2.4.4
Operations Review Committee................
10
2.4.5
Maintenin
10
e.
.........................
2.4.6
Survei,ionce..
10
.
.....................
2.4.7
Formalizing Personnel Qualification
Reviews..................................
11
2.4.8
Mission, Organization and Policy Manual....
11
2.4.9
Familiarizing Workers with t'xpected
Radiological
Conditions..................
11
2.4.10
Control Room Human
Factors.................
11
3.0 DE TAI LS O F I N S P EC T ION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
12
3.1 Management 0versight.................................
12
3.1.1
Scope of Review............................
42
3.1.2
Organization...............................
12
3.1.3
Staffing...................................
15
3.1.4
Qualifications..... . .....................
16
3.1.5
Administrative Policy and Procedures.......
18
3.1.6
Communications and Observations............
19
3.1.7
Conclusions.......................
.
20
......
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Table of Contents (Continued)
Page
3.2
Operations...........................................
21
3.2.1
Scope of Review............................
21
3.2.2
Conduct of Operations......................
21
3.2.3
Shift Staffing and Overtime Controls.......
23
3.2.4
Procedure Va11dation.......................
24
3.2 5
Temporary Modification Controls............
25
3.2.6
Required Reading Books.....................
28
3.2.7
Logs.......................................
29
3.2.8
Timely Update of Lif ted Lead / Jumper Log. . . .
29
3.2.9
Tagouts and Operator Aids..................
31
3.2.10
Plant Tours and System Walkdowns...........
31
3.2.11
Conclusions................................
34
3.3
Maintenance..........................................
36
3.3.1
Scope of Review............................
36
3.3.2
Observations and Findings..................
36
3.3.3
Conclusions................................
50
'
3.4 Surveillance Testing and Calibration Control.........
52
3.4.1
Scope of
Review.........................
52
..
3.4.2
Observations and Findings..................
52
3.4.3
Conclusions................................
61
3.5 Radiation
Protection.................................
63
3.5.1
Scope of Review............................
63
3.5.2
Observations and Findings..................
63
3.5.3
Conclusions................................
73
3.6 Security and Safeguards...... .......................
75
3.6.1
Scope of Review............................
/%
3.6.2
Observations and Findings..................
75
3.6.3
Conclusions................................
82
11
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Table of Contents (Continued)
Page
3.7
Training.............................................
83
3.7.1
Scope of Review............................
8'.
3.7.2
Observations and Findings..................
83
3.7.3
Conclusions................................
88
3.8 Fire Protection......................................
89
3.8.1
Scope of Review............................
89
3.8.2
Observations and
Findings..................
89
3.8.3
Conclusions................................
90
3.9 Engineering Support..................................
91
3.9.1
Scope of Review............................
91
3.9.2
Observations and Findings..................
91
3.9.3
Conclusions................................
93
3.10 Safety Assessment / Quality Verification...............
94
3.10.1
Scope of Review............................
94
3.10.2
Nuclear Safety Review and Audit Committee..
94
3.10.3
Operations Review Committee................
97
3.10.4
Quality Assurance Audit and Surveillance
Programs.................................
102
3.10.5
Corrective Action Process and Programs.....
104
3.10.6
Conclusions................................
115
4.0 UNRESOLVED ITEMS..........................................
117
5.0 MANAGEMENT MEETINGS.......................................
118
Appendix A - Entrance Interview Attendees......................
A-1
Appendix B - Exit Interview
Attendees..........................
B-1
Appendix C - Persons Contacted.................................
C-1
Appendix 0 - Documents Reviewed................................
D-1
Appendix E - IATI Composition and Structure................
E-1
...
.
Appendix F - Resumes...........................................
F-1
Appendix G - September 1, 1988 Letter from NRC to Commonwealth
of Massachusetts................................
G-1
Appendix H - September 6, 1988 Letter from Commonwealth of
Massachusetts to NRC...........................
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H-1
111
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As Low As Reasonably Achievable
-
ANSI
American National Standards Institute
-
American Society for Mechanical Engineers
-
BECo
Boston Edison Company
-
BEQAM
Boston Edison Quality Assurance Manual
-
Central Alarm Station
-
CQI
Commercial Quality Item
-
Core Spray (System)
-
Condensate Storage Tank
-
Direct Current
-
i.
Detaiied Control Room Design Review
DCRDR
-
Diesel Generator
-
DR
Deficiency Reports
-
E0P
Emergency Operating Procedures
-
E0
Equipment Operator
-
Electric Power Research Institute
-
Environmental Qualification
-
Engineered Safety Feature
-
r
Engineering Service Roquest
-
'
Failure and Malfunction Reports
F6MR
-
For Your Information
FYI
-
General Employee Training
-
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Health Physics
-
HPES
Human Performance Evaluation System
-
HSA
Housekeeping Service Assistance
-
IATI
Integrated Assessment Team Inspection
-
Instrumentation and Control
-
Immediate Corrective Actions
-
Institute of Nuclear Power Operations
-
In-Service Testing
-
LCO
Limiting Condition for Operations
-
LL/J
Lifted Lead / Jumper
-
Logic System Functional Test
-
Measuring and Test Equipment
-
MCAR
Management Cnrrective Action Requests
-
MCIAP
Material Condition Improvement Action Plan
-
MO&AT
Management Oversight and Assessment Team
-
MOP
Mission, Organization and Policy Manual
-
Maximum Permitted Concentration
-
Maintenance Request
-
Maintenance Summary and Control
-
MSTP
Master Surveillance Tracking Program
-
MWP
Maintenance Work Plan
-
Nonconformance Report
-
NED
Nuclear Engineering Department
-
h0P
Nuclear Organization Procedures
-
y
.
.
NRC
Nuclear Regulatory Commission
-
Office of Nuclear Reactor Regulation
-
NSRAC
Nuclear Safety Review and Audit Committee
-
NWE
Nuclear Watch Engineer
-
OMG
Outage Management Group
-
ORC
Operations Review Committee
-
Piping and Instrument Diagram
-
PCAQ
Potential Condition Adverse to quality
-
Plant Design Change
-
Pressere Indicator
-
Preventive Maintenance
-
Pilgrim Nuclear Power Station
-
Primary Containment Isolation System
-
Quality Assurance Department
QAD
-
-
Reactor Core Isolation Cooling
Radiological Environmental Technical Specifications
-
Residual Heat Removal (System)
-
Reactor Operator
-
ROR
Radiological Occurrence Report
-
Radiation Protection
-
'
Radiation Work Permits
-
Simulated Automatic Actuation
-
Secondary Alarm Station
-
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SBLC
Standby Liquid Control (System)
-
Security Deficiency Reports
-
Safety Evaluations
-
SEG
Systems Engineering Group
-
SES
Senior Executive Service
-
SFR
Supplier Finder Reports
-
Safeguards Information
-
Station Instruction
-
Senior Reactor Operator
-
-
SVP-N
Senior Vice President - Nuclear
-
TM
-
TS
Technical Specifications
-
VP-NE
Vice president - Nuclear Engineering
-
WIP
Workforce Information Program
-
WPRT
Work Prioritization Review Team
-
vii
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1.0 EXECUTIVE SUMMARY
In response to NRC concerns ever longstanding issues regarding the manage-
ment effectiveness of the Boston Edison Company (BECo) in the operation of
the Pilgrim facility, the licensee agreed to maintain the plant in a
shutdown
condition
following
operational
events which occurred on
April 11-12, 1986.
The NRC conf trmed the licensee's agreement in Con-
firmatory Action Letter (CAL) 86 10.
The CAL, as supplemented in an
August 27, 1986 letter, also confirmed that the licensee would develop a
comprehensive plan to address those concerns and perfonn an in-depth self-
assessment of the effectiveness of that Plan.
On June 25, 1988, the
licensee reported it had completed these activities to the extent that an
NRC review was appropriate. In order to assess the status and results of
BECo's corrective actions, the NRC performed an independent review of the
effectiveness of the licensee's management controls, programs and person-
nel during an Integrated Assessment Team Inspection (IATI) conducted
August 8-24, 1988.
The Team consisted of an SES-level manager, a Team leader, and members of
the NRC Region I
and Headquarters staff.
The inspection team also
included two obseners representing and appointed by the Commonwealth of
i;assachusetts.
These observers had access and input to all aspects of the
inspection as provided by the established protocol.
The areas reviewed
during the
inspection included operations, maintenance, surveillance,
radiation protection, security, training, fire protection and assurance of
quality.
The Team reported directly to the Regional Administrator of
Region I.
Overall, the Team concluded with high confidence that BECo management
controls, programs, and personnel were generally ready and performing at a
level to support safe startup and operation of the Pilgrim Nuclear Power
Station.
Further,
although the Team identified certain items which
require licensee actions or evaluations, there were no fundamental flaws
found in the licensee's management structure, management performance,
programs, or program lmplementation that would inhibit its ability to
assure reactor or public safety during plant operation.
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2.0 INTRODUCTION
This report details the findings, conclusions and observations of NRC's
Integrated Assessment Team Inspection conducted at the Pilgrim Nuclear
Power Station (PNPS) on August 8-24, 1988. The results of this inspection
are to be considered during NRC staff's deliberations as it reaches its
decisior. regarding a restart recommendation to the NRC Commissioners.
2.1 Background
The NRC's 1985 Systematic Assessment of Licensee Performance (SALP)
found programmatic weaknesses in several functional areas at the
Pilgrim Nuclear Power Station and noted that, historically, the
licensee could not sustain performance improvements once achieved. A
'
special NRC Region I diagnostic team inspection was subsequently per-
formed in February and March 1986 to evaluate facility performance.
This inspection, which included monitoring plant activities on a
24-hour basis, confirmed the 1985 SALP and concluded that poor
management control and incomplete staffing contributed to the poor
performance.
Following several operational events, Boston Edison Company (BECo)
shutdown PNPS on April 11-12, 1986.
The NRC subsequently issued a
Confirmatory Action Letter (CAL) on April 12, 1986, and a supplement
on August 27, 1986, maintaining the ple.nt shutdown and requiring that
the licensee obtain NRC approval prior to restert.
The central
issues in the CAL, as supplemented, involved the effectiveness of
licensee management of the facility and technical concerns.
SALP evaluations continued during the shutdown, and improvements were
noted during the 1986 SALP period, although the rate of change was
slow.
Several factors inhibited progress, including continued man-
agement changes and prolonged staf fing vacancies.
Good performance
was noted in four areas:
emergency planning, outage management,
corporate engineering support and licensed operator training.
The
success in these areas reflected a high level of corporate management
attention and substantial resource commitments.
The licensee also
had made signi'icant plant hardware improvements, including Mark I
Containment performance enhancements.
,
!
Consistent with the CAL and its supplement, BECo has addressed the
specific technical
issues, developed and submitted the Pilgrim
Nuclear Power Station Restart Plan and performed a detailed self-
assessment of readiness for restart.
The NRC staff reviews of these
items are complete.
The licensee has also submitted a Power Ascen-
sion Test Program, for which the staff review is ongoing.
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NRC subsequently completed a SALP evaluation for Pilgrim covering the
period February 1,1987 to May 15,1988.
It concluded that licensee
managenient initiatives are generally successful in correcting staff-
ing, organization, and material deficiencies. Programmatic perform-
ance improvements were evident in areas previously identified as
having significant weakness and in areas that the licensee's self-
assessment process
identified
as
warranting
further management
attention.
The NRC Confirmatory Action Letter (CAL) of April 1986 required the
NRC to perform a review to assess BECo's corrective actions. In con-
junction with an augmented inspection program and as part of a con-
tinuing effort to monitor BECo's program improvements, the NRC
planned this IATI to independently measure the effectiveness and
readinass of the licensee's management controls, programs and per-
sonnel to support safe restart of the facility. A Restart Readiness
Assessment Report that includes staff assessment results will be
prepared by the NRC in conjunction with development of an NRC staff
recommendation regarding plant restart.
2.2 Scope of Inspection
The IAT inspection was performed to provide an indepenuent, in-depth
assessment of the degree of readiness of licensee management con-
trols, programs, and personnel to support safe restart and operation
of the Pilgrim Nuclear Power Station (PNPS).
The inspection covered
a variety of functional areas, including operations, maintenance,
surveillance, radiation protection, security, training, fire protec-
tion, and assurance of quality.
Particular emphasis was placed on
management ef fectiveness and on the status of the licensee's recent
program improvements in maintenance.
The inspection consisted of
interviews with licensee personnel, plant tours, observations of
plart activities, and selective examinations of procedures, records,
and documents.
The Team also directly observed ongoing
plant
activities on ali shifts from August 10-13, 1988.
The 15-member Team consisted of a senior manager, inspection team
leader, five shift inspectors, and several specialist inspectors from
both NRC Region I and the NRC Of fice of Nuclear Reactor Regulation
(NRR).
Two representatives from the Commonwealth of Massachusetts
were also on the Team as observers throughout the inspection.
The
team roster and member resumes are attached as Appendices E and F to
this report.
Onsite IATI preparation, which included site familiarization and
plant tours, was conducted during the week of July 18, 1988. The Team
was onsite full-time from August 8 through 19, 1938. Some IATI mem-
bers were on site during the documentation period of August 20-24,
1988.
Attendees at the entrance and exit interviess are listed in
Appendices A and 8, respectively. Senior licensee managers contacted
during the course of the inspection are listed in Appendix C.
Many
other persons at all levels of the organization were also contacted
or interviewed.
.
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The licensee was not p/esented with any written material by the NRC
during this inspection. The licensee indicated that no proprietary
material was presented for review during this inspection.
2.3 Summary of IATI Results
2.3.1
Overall Summary
The T2am concluded, with high confidence, that licensee
management controls, programs, and personnel are generally
ready and performing at a level to support safe startup and
operation of the facility. Technical items requiring reso-
lution or completion prior to restart are being addressed
and tracked by the licensee.
The Team identified a rela-
tively small number of additional items for which licensee
actions or evaluations appear appropriate; during the
inspection, the licensee made acceptable commitments in
these areas.
There are currently no fundamental flaws in
the licensee's management structure, management perform-
ance, programs,
or program
implementation
that would
inhibit its ability to assure reactor or public safety dur-
ing plant operation.
The inspection generally confirmed the results of the SALP
report for February 1,1987 through May 15, 1988, as well
as validating the general SALP conclusion that performance
was improving at the end of the SALP period.
Further,
licensee performance appeared to be consistent or improving
in all functional areas examined during the IATI, with the
current level of achievement for overall safety performance
equal to or better than that described in the SALP.
For
maintenance and radiation protection, the performance is
noticeably improved.
The inspection generally confirmed the effectiveness of
various licensee self-improvement programs and of the
licensee's self-assessment process.
The Team identified
relatively few issues that had not been previously identi-
fied by the licensee.
In the interest of continually
improving its self-assessment process, the licensee should
evaluate those cases where NRC either identified new issues
or assigned a higher sense of prior;ty than identified by
the licensee.
The inspection confirmed that important organization and
attitudinal changes had occurred since 1986. Of particular
concern to NRC during the diagnostic inspection in 1986
were several f actors inhibiting progress.
These included:
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1)
Incomplete staffing, especially of operators and key
mid-level supervisory personnel;
2)
The prevailing licensee view that improvements to date
had corrected the problems identified;
3)
Reluctance by Itcensee management to acknowledge some
problems identified by NRC; and
4)
Dependence on third parties to identify problems
rather than implementing an offective licensee program
to identify weaknesses.
The Team found these inhibitors to be substantially re-
moved, and noted that a significantly improved nuclear
safety ethic exists at management levels and is developing
successfully at the worker level.
Based on a review of the management structure, staffing,
goals, policies and administrative controls, the Team con-
cluded that the licensee has an acceptable organization and
administrative process, with adequate management and tech-
nical resources to assure that the plant can be operated in
a safe and reliable manner during normal and abnormal con-
ditions.
Further, this performance-based inspection pro-
vided an integrated look at overall management effective-
ness in ensuring high
' andards of nuclear safety.
The
overall conclusions o#
is inspection confirm facility
management effectivene
especially its ability to perform
self-assessment functh
to improve performance, and to
3,
raise nuclear safety awareness and attitudes throughout the
organization.
2.3.2
Summary of Results by Functional Area
Within each functional
area,
conclusions were reached
including the identification of various strengths and weak-
nesses. Those are summarized below.
The basis for these
items, as well as the many significant observations made by
the Team, are explained in Section 3 of this report.
2.3.2.1
Operations
Strengths
Experienced and knowledgeable senior licen-
--
sed operators
,
O
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Effective shift turnover
--
Excellent plant housekeeping
--
Weakness
Lauk of thoroughness and attention to detail
--
in validation and training of Emergency
Operating satellite procedures
2.3.2.2
Fire Protection
Strengths
Effective program staffing and supervision
--
Effective
prioritization,
control,
and
--
tracking
of
fire
protection
equipment
maintenance
Weaknesses
None
2.3.2.3
Maintenance
Strengths
Good organization and structure
--
Thorough program procedures
--
Clear maintenance section internal communi-
--
cations and interactions
Good control and support of field activities
--
Weaknesses
Examples of poor implementation of planning
--
.
for post-work testing
Poorly controlled storage of Q-listed items
--
at
two
locations
outside
the warehouse
_ _ _ _ _ _
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.
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2.3.2.4
Radiological Controls
Strengths
Effective
use
of
a
maintenance
health
--
physics (HP) advisor
A well-organized training program
--
Weaknesses
Examples of a lack of continuity and pro-
--
ficiency in certain highly specialized jobs
because
of
frequent
technician
rotation
Indications of weak vertical communications
--
within the HP group
2.3.2.5
Surveillance
Strength
_
Management commitment to improve an already
--
satisfactory program
Weakness
Incomplete resolution of proper frequency
--
and scheduling of once per-refueling outage
tests 2.3.2.6
Security
Strength
Overall management attention
--
Weaknesses
None
.
2.3.2.7
Training
.
Strengths
Excellent management support for operator
--
training programs
-
,-
.
.
8
Strong relations between the plant opera-
--
tions and training departments
Weakness
Lack of a defined process to assure timely
--
identification and implementation of train-
ing needs resulting from newly approved or
revised procedures
2.3.2.8
Engineering Support
Not directly reviewed. No specific strengths
--
or weaknesses identified
2.3.2.9
Safety Assessment / Quality Verification
Strengths
Nuclear Safety Review and Audit Committee
--
(NSRAC) composition,
plant tour program,
frequency and location of meetings, open
forum, and focus of reviews
Attitude and performance toward identifying
--
problems
Effective, meaningful communications between
--
the Quality Assurance and plant Operations
departments
Weaknesses
Operations Review Committee does not perform
--
an effective independent group review of
operations
and
Technical
Specification
violations
Multiplicity of corrective action programs
--
without centralized tracking
Poor tracking of Potential Condition Adverse
--
to Quality (pCAQ) reports
_ _ _ _ _ _ _ _
,
.
9
2.3.2.10 Management Oversight
Strengths
Well-defined
organization,
incorporating
--
appropriate span-of-control
and including
highly qualifted, experienced managers in
key positions
Well-defined and well-conceived corporate
--
goals
Weaknesses
None
2.4 Licensee Commitments
During the IAT inspection, the licensee made certain commitments to
the inspection feam. These commitments relate to licensee corrective
or enhancer.ent actions planned in response to Team findtegs or con-
cerns.
These commitments, summarized below, are discussed in more
detail in subsequent sections of this report, shown in parentheses.
Commitments were confirmed during the exit interview. The status of
these issues will be reviewed by the NRC prior to any restart of the
plant (83-21-01).
2.4.1
Procedure Validation and Training (Section 3.2.4)
isy restart, the licensee will confirm effective implementa-
tion of all of f-normal and E0P satellite procedures that
have been substantively revised during this outage.
2.4.2
Identifying Procedure Changes Requiring Training (Section
3.7.2.1)
Before restart, the licensee will implement a process to
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allow more timely identification of new procedures and
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procedure changes which require training.
.
2.4.3
Temporary Modifications (Section 3.2.5)
By restart, the licensee will either prepare a justifica-
tion for operation for each active temporary modification
or apply the temporary modification extension request
process to all temporary modifications, including those
with outstanding engineering seevice requests.
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2.4.4
Operations Review Committee (ORC) (Section 3.10.3)
Prior to restart, in order to strengthen its operational
focus, the ORC will begin to:
(1) review plant incident
critiquas; (2) review licensee event reports before their
issuance to NRC; (3) review failure and malfunction reports
on a regular basis; and, (4) provide for a monthly presen-
tation and discussion of plant operations as a specific
agenda item.
2.4.5
Maintenance
Before restart, the licensee will re-evaluate all
--
priority 3 maintenance requests to ensure that they
have
been
properly
scheduled.
(Section
3.3.2.4)
The licensee will complete training addressing the
--
revised post-work testing program by September 9, 1988.
'
(Section 3.3.2.6)
The licensee will resolve the inability to align
--
valves in the Torus Water Makeup Line in accordance
with current operating procedures and drawings prior
to restart.
(Section 3.3.2.4)
The licensee will issue a procedure to provide appro-
--
priate controls for the
"Q"
oil storage facility by
September 7, 1988, and perform an evaluation of the
possible addition of "non-Q" oil to
"Q" equipment and
its potential effect.
(Section 3.3.2.3)
The licensee will complete, before restart, the dis-
--
position of a Potential Condition Adverse to Quality
(PCAQ) identifying the need for a review of Commercial
Quality Item procurement documents for consistency
with approved engineering specific 3tions.
(Section
3.3.2.3)
2.4.6
Surveillance
.
Before restart, the licensee will review and evaluate
--
the once per-refueling-outage surveillance tests to
determine if they should be repeated to enhance the
assurance of system operability and document the basis
for its decision.
(Section 3.4.2.1)
Before restart, the licensee will provide the tech-
--
nical basis for the current test frequency of the
Reactor Core Isolation Cooling (RCIC) System logic
System Functional Test (LSFT) on the initiation logic.
(Section 3.4.2.2)
. _ _ _ _ _ _ _ _ _ .
e
0
11
2.4.7
Formalizing Personnel Qualification Reviews
The licensee will verify before restart the qualifications
of all personnel within the organization required to meet
ANSI 18.1-1971; and, prior to completion of the power
,
ascension program, will have a formalized process in place
to ensure future auditability.
(Section 3.1.4)
2.4.8
Mission, Organization and Policy (MOP) Manual
The licensee will issue MOP policy instructions prior to
restart and the organizational position descriptiens prior
to completion of power ascension.
(Section 3.1.5)
,
2.4.9
Familiarizing Workers with Expected Radiological Conditions
Before restart, the licensee will provide training and
briefings to the appropriate plant staff regarding expected
radiological conditions resulting from plant operation and
hydrogen addition.
(Section 3.5.2.14)
2.4.10
Control Room Human Factors
The licensee will evaluate control room human factors dur-
ing the power ascension program and include an update
regarding the schedule and scope of "Paint, Label and Tape"
items in their report to the NRC at the completion of the
l
Power Ascension Program.
(Section 3.9.2)
1
i
i
,
1
!
.
-.-
_ _ - _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _
. _ _ _ _
.
.
12
-
3.0 DETAIL 3 0F INSPECTION
The following sections contain the scope of inspection, the detailed
i
findings, and the conclusions for each functional area the Team assessed.
3.1 Management Oversight
3.1.1
Scope of Review
The IATI assessed the organizational structure currently in
place at the Pilgrim Nuclear Power Station (PNPS).
The
assessment also included the administrative processes in
place to control and coordinate the activities and actions
'
affecting safe and reliable operation of the PNPS. Other
areas inspected included the adequacy of staffing, qualifi-
cations of personnel, and mechanisms to enhance and promote
stability in the organization's technical and managerial
staff.
Several management meettags were observed by Team members
to assess the interactions of managers and the effective-
ness of the policies and procedures being implemented.
Continual observations were made and shared by Team members
to augment findings and conclusions in the effectiveness of
.
the organization, management controls, and communications
I
throughout the functional areas.
The Team members inter-
'
viewed a cross-section of personnel at all levels of the
'
organization to determine if the overall attitude towerd
performance of safety-related activities has
improved.
These obrervations and interviews also provided the Team
with insight into the worker perception of management
policies,
involvement, effectiveness and its resulting
impact on safety,
j
i
3.1.2
Organization
The NRC staff noted in the most recent SALP report No.
,
50-293/87-99
for February 1, 1987 through May 15, 1983,
'
that an organizational transition had taken place.
The
report also noted tnat several temporary changes, including
i
.
numerous changes in personnel, had been made to strengthen
planning, control and performance at PNpS. Many of these
'
temporary changes were incorporated into a permanent reor-
ganization in February 1988. The licensee continued to re-
fine the new organziation and control
process through
!
t
,
, , _ _ - , . . - - - - _ . _ - - - . ,
- .
- . - - ,
n-
, - - , ,
.
_ _ ____________ -.
_ _ _ _ _ _
,
.
,
,
13
.
July 1988, notified NRC of the reorganization, and subse-
quently requested an amendment in August 1988 to the admin-
istrative section of its Technical Specifications (TS) to
reflect the new organization. The notification and request
were
in accordance with the PNPS TS, Section 6.2.C.
"Changes to the Organization," which allows organizational
a
changes to be implemented without prior NRC approval, pro-
"
vided notification is made and a subsequent license amend-
ment request is submitted for NRC review and approval.
I
he organization assessed during this inspection is the
j
subject
of
the
licensee's
amendment
request
dated
August 1, 1988, and approved by the Senior Vice President -
s
Nuclear (SVP-N) on August 4, 1988.
The discussion that
follows does not describe in complete detail the entire
,
i
organization, focusing instead on that portion that affects
j
the functional areas being evaluated during this inspection
(See Figure 1).
The results of this inspection will be
,
considered in NRC's review of the licensee's amendment
'
request.
4
I
The Team noted that the licensee has incorporated a balance
]
between the number of management levels from the first-line
supervisors to the SVP-N and the span of control for each
,
i
functional unit. The SVP-N has the Station Director, Vice
l
President
Nuclear Engineering (VP-NE), Emergency Pre-
-
paredness Department manager and Quality Assurance Depart-
t
}
mert manager reporting directly to him. The two department
managers report directly to the SVP-N to assure that inde-
pendence and appropriate management attention are provided
based on their functional requirements and responsibilities.
The committee charged with offsite satety, the Nuclear
i
Safety Review and Audit Committee (NSRAC), reports directly
}
to the SVP-N. The committee for onsite safety review, the
!
Operations Review Committee (ORC), reports directly to the
Station Director.
The reporting of the of fsite committee
!
to the SVP-N and the onsite committee to the Station
Director are appropriate based on their responsibilities.
'
Details on these standirg committees, their functional
requirements, responsibilities and accountabilities, are
contained in Section 3.10 of this report.
,
!
!.
The VP-NE has two department-level managers reporting
Jirectly to him.
These departments are the Nuclear Engi-
i
neering Department av the Manatement Services Department
i
both of which are located offsite.
The Station Director
1
has four department-level managers reporting directly to
l
him:
the Plant Support Department, Plant Manager (Opera-
tions), Planning and Outage Department, and the Nuclear
1
!
Training Department.
1
.,
,.
- , _ . - - , - -
r
_ - _ . . _ _
_.
__
_
_ _ _ _
_ _ _ _
.-
_.
.
q
.
.
I
<
-l
Chairsdn, Board of Directcr5
and CEO
Senior Vice President -
Nuclear
1
Director - Spec 141 Projects
14uclear Safety Review and Audit Coasnittee
I
i
W
4
l
Wice President -
Quality Assurance
Erergency Planning
Station Direc ar
rauclear Engineering
Department flanager
Departinent m nager
i
I
1
,
l
Nuclear Engineering
14uclear Management
Operations fteview
Plant Department
Plannirs &
Department stanager
Services Department
Consmittee
(Plant N nager)
Outage
Department
,
'
Manager
.
tianager
I
,
l
'
Plant Support
Wuclear Training
,
i
J Department
-l
Departs,aent
-
"*"*9'#
.
9"
Manager
Plant Operations
l
'
1
Sc tion Manager
Figure 1.
BOST0i1 E0150ri C0ftPAf4Y - PILGRIF. ORGAf41ZAT104
'
l-
- - _ ~ , . - -
.
.-.
,.
-
.-
-
.- -
_
, -
_.
,
n
15
The senior manager of the functional areas is at the
department level, which is then subdivided into section
levels and division levels. The first-line supervisors, in
some cases senior supervisors, report to the division
managers.
The station organization, now under a Station Director who
has no direct corporate (i.e., off-site) responsibilities,
represents a substantial change frcm previous organiza-
tions.
The current structure was instituted to strengthen
management attention to plant activities. The narrowing of
the span of direct control and responsibility of the Plant
Manager allows a more focused management and control of
operational activities, which should result in the enhance-
ment of safe and reliable operation.
The
martments
reportir.g to the VP-NE have been restructured r ., 1 more
even distribution of responsibilities.
The Team concluded that the current organizational struc-
ture provides for an appropriate distribution (span) of
responsibilities and accountabilities for the activities
being performed by the functional units within it.
The
depth (number) of managers in the functional areas should
contribute
to
improved performance and organizational
stability by providing managers with increased opportun-
ities to participate in professio.tal technical and manage-
ment development programs and by increasing the framework
for career growth.
The Team also concluded that the redistribution of func-
tional responsibilities and increased depth in management
provides the framework necessary to enhance stability and
support safe and reliable operation at PNPS.
The evidence
for these changes thus far has been management's effective-
ness in creating a much-improved nuclear safety ethic and
in improving the functional areas described in the subse-
quent sections of this report.
3.1.3
Staffing
The most recent SALP Report (No. 50-293/87-99) indicated
that the allocated staffing levels were significantly
higher than in the past.
The Nuclear Organization is cur-
,'
rently authorized a staffing level of 985. Approximately
90'. of the autho-ized positions are filled, of which 86*4
are licensee personnel; the remaining 4*4 cc.mprise contract
,
personnel. Licensee personnel fill all Key positions from
'
Section Managers and above, with less than
15*. of the
remaining managers and first-line supervisor positions
filled by contractors or licensee personnel in acting
,
capacities.
I
_ - -__ - - -- -_.
_ _ _ _ _ _ _ _ _ _ _ _ _ _____
_ _ _ _ _ _ _ _ _ _ _ _
______ _
,
16
Increased staffing in all levels of the Radiologica', and
Maintenance Sections are examples of how the licensee has
provided the necessary management attention and resources
to areas that need them.
The increased staffing, specif-
ically at the craf t and technician level, appears f.uffic-
ient to allow for a planned and controlled preventiv, main-
tenance program that should result in overall saf2ty en-
hancement.
The increased staffing levels also allow for
training on a routine schedule.
The Team concluded that the authorized staffing has been
filled to a level acceptable for the licensee to perform
all the necessary functions for all
plant canditions,
including operations.
This finding is reinforced by the
evidence of improvements in the functional areas, described
in the subsequent portions of this report.
3.1.4
Qualifications
The PNPS TS, Sectirn 6.4, "Facility Staff Qualifications,"
requires that PNPS personnel meet tSe requirements of the
American National Standards Institute (ANSI) N18.1-1971,
"Selection and Training of Personiel for Nuclear Power
Plants."
The TS also requires that the Radiation Protec-
tion Manager shall meet or exceed the qualifications of
"Quali fica tion and Training for
Personnel at Nuclear Power P1'.nts," September 1975.
The Team audited resumes and position descriptions of key
managers and other selec.ed pe c.onnel throughout the organ-
ization. Their educational ana experience backgrounds were
compared with the requiremerts delineated in ANSI N18.1-
1971Property "ANSI code" (as page type) with input value "ANSI N18.1-</br></br>1971" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., with special attention on t.he management experience
of key personnel. No deficiencief, were identified relating
to the qualification requirements of the ANSI standard.
More significantly, the Team noted the staffing of key
management positions with persornel having extensive and
successful management experience.
During its review, the Team fouid that some resumes needed
updating, and that no formal, detailed instructions or
guidance in establishing qualifications were available. The
Team reviewed a Quality Assurance Department (QAD) audit
report of the organization's administrative controls which
was conducted June 22 througn July 22, 1988 and which
resulted in similar findings.
The report, Audit Report
8S-25, "Administrative Controls," dated August 18, 1938,
,
e
.
17
indicated that personnel qualifications were audited by the
QA0 to determine compliance with the ANSI N18.1 require-
ments for the organizational positions held.
No defici-
encies were identified as the result of the QA0 audit.
The
report did, howeser, provide a recommendation consistent
with the NRC inspector's finding. Specifically, Reccmmen-
dation No. 88-25-03, notes the need to update resumes,
develop guidelines and procedures for documenting qualifi-
.
cation status, and maintain retrievable files.
The licensee has committed to the Team to reverify the
qualifications of all personnel within the. organization to
.
confirm they comply with ANSI N18.1-1971 prior to restart
and to have a process in place prior to completion of the
Power Ascension Program to ensure future auditability of
personnel qualifications.
Within the scope of the NRC review, the Team deter-
mined that the licensee's personnel are generally well
qualified for the positions hsid within the organization.
The licansee's commitment to reverification of all per-
tonnel qualifications prio: to restart will provide addi-
tional assurance of full compliance relating to personnel
qualifications.
The results of the IATI effort in assessing the adequacy of
the staffing and qualifications of the PNPS organization is
consistent with the overall facility evaluation in the most
recent SALP report (No. 50-293/87-99).
It noted the addi"
tion of management personnel who lack extensive commercial
nuclear power plant operating experience.
However, as
acted above, recent changes have resulted in the addition
of personnel in key management positions with extensive and
successful management experience, much of which is in
nuclear areas.
Also, many mid-level management positions
are held by individuals who have extensive Pilgrim NPS (or
other boiling water reactor) experience.
The Team con-
cluded that the combination of commercial nuclear power
plant operating experience in the organization with the
increased management capebility provides the qualifications
necessary to support safe and reliable operation at PNPS.
In the event of a restart authorization, licensee safety
performance will be closely monitored by the NRC during the
Power Ascension Program.
_ _ _ _ _ _ _ _ _ - __ _ _ _ _
. _ _ _ _
,
,
18
3.1.5
Administrative Policy and Procedures
The licensee has a variety of procedures to provide policy,
control and coordination of organization activities. Cor-
porate policy is provided in the form of company Bulletins
maintained
in
a
Boston
Edison
Company Organizational
Manual. The manual includes information about the corpor-
ate organization, its policy statements, corporate instruc-
tions, and committees which affect the entire company,
including the Nuclear Organization.
The corporate level
policy specifically affecting the Nuclear Organization is
contained in a Mission, Organization and Policy (MOP)
manual.
The Nuclear Organization Procedures (NOPs) provide guidance
for the control and coordination of the Nuclear Organiza-
tion. They include administrative pro edures affecting the
entire organization, as well as proceduret affecting func-
tional portions of the organization.
Each department also
has procedures in place specifier 11y for its functional
areas.
The Team reviewed several :0Ps to assure that the
guidance provided was current, reflected the organization
in place, and addressed coordinating activities within the
organization.
The Team also reviewed department-level
procedures to assure they included the current organiza-
tion, toals, department function, position descriptions,
qualti, cations required, responsibilities, and accounta-
bilities.
The Team concluded that the proceoures are, for the most
part, current.
They adequately identify corporate policy,
organization,
coordination,
functional
requirements,
i
responsibilities,
accountabilities,
and
qualifications
nacessary for the control and coordination of actions
within the organization.
The Mission, Organization and Policy Manual (MOP) is not
fully up to date; however, and is currently being revised
to accurately reflect current policy and to include all the
-
position descriptions within the organization.
The licen-
see has identified additional refin1ments in the organi a-
t
tional position descriptions to assure consistancy and to
provide accurate definitions of responsibilitias necessary
to assure accountability.
The licensee was previously
aware of this and has been working to finalize the updates.
The licensee committed to issue the revised MOP which
L
v
a
e
h
F
19
includes updated policy prior to restart and to complete
the organizational position description refinements before
,
the end of the Power Ascension Program. This commitment is
acceptable, based on the status of the other procedures
previously discussed which assure adequate administrative
controls.
3.1.6
Communications and Observations
Corporate policy for the Nuclear Organization 1.4 the MOP
manual includes, among its goals, the nced to strive to
raise standards of performance, for dedication to protec-
ting the environment and public, and for rigorous adherence
to procedures.
The Team, through its observations and
interviews, noted a positive change in the attitude toward
nuclear safety throughout PNPS.
This change is evident in
improved performance of safety-related activities.
These
improvements are indicated in the most recent SALP Report
(No. 50-293/87-99), and progress in the other functional
areas is addressed in this inspection report.
The Team
also noted during interviews that the corporate goal of
adherence to procedures has been conveyed to all levels of
the organization.
These c'sservations attest to manage-
ment's ef fectiveness in communicating corporate goals and
management's oversight in assuring that the goals are being
pursued.
The Team noted that the licensee established several mech-
anisms to assure adequate communications within the organ-
ization.
Meetings at all levels of the organization are
held on a routine basis.
Plant meetings are held every
morning to discuss plant status and to coordinate daily
,
activities. Several of tiase meetings were observed by the
4
Team to assess the interaction of the managers and the
resulting effectiveness. The Team concluded that the meet-
ings were effective and that safety-related activities are
being planned, scheduled, and prioritized in accordance
'
with their safety significance and plant status. These and
other observations by the Team indicate that teamwork at
the site is evident.
There are programs in place, such as
the Workforce Information Program (WIP), For Your Informa-
tion (FYI), and Management Oversight and Assessment Team
(MO&AT) to enhance management involvement, overall communi-
cations, and management visibility in the plant.
!
l
t
f
I
___ _ _ _ _ _
_
__
_ _ _ _ _ _
0
20
The licensee has also established a set of performance
indicators to track performance issues, restart issues,
plant condition reports, and activity status.
These per-
formance indicators are used as a management tool
to
measure
the
effectiveness
and
results
of established
programs.
The Team concluded, based on its evaluation of programs
in place, that communications throughout the organization
have improved, that teamwork is evident, and that corporate
goals are being conveyed to all levels of the organization.
3.1.7
Conclusions
The Team concluded that the licensee has an acceptable or-
ganization and administrative process in place with ade-
quate management and technical resources to assure that
pNPS can operate in a safo and reliable manner during
normal and abnormal conditions.
This conclusion is based
on the details discussed above,
th'e performance-based
inspection in the functional areas covered by the IATI, the
overall consistency in the findings of this inspection with
the most recent SALP (No. 50-293/87-99), and the plan for a
structured and controlled power ascension program prior to
operation.
This performance-bc
-d inspection of a wide range of func-
tional areas provic.c an integrated look at overall manage-
.
ment effectiveness in ensuring high standards of nuclear
safety. The overall conclusions of this inspection confirm
f acility management ef fectiveness, especially with respect
to management's ability to perform self-assessment func-
tions,
to make performance improvements, and to raise
nuclear
safety
awareness
and
attitudes
within
the
organization.
- _ _ _ __
.. .
_ _ _ _ _ _
__
_ _ _ _ _ _ _ _ _ _ _ _ _
- - - _ _ _ _ _ _ _ _ _ _ _
.____________
__
.
.
21
3.2 Operations
3.2.1
Scope of Reviev
i
The Team evaluated operations by observing how supervisors,
operators and staff performed in the control room and
throughout the plant.
The Team observed plant operations
during backshifts from August 10 through August 13, 1988,
and reviewed staffing levels to determine if they were
sufficient to support restart with minimal reliance on
overtime.
The ability to implement recently written E0P
satellite procedures and the quality of thesce procedures
were evaluated through a field walkdown of a procedure.
The implementation of administrative controls for opera-
tions was evaluated through inspections of overtime con-
trols, temporary modification controls, operator-required
reading, logkeeping, tagouts, and operator aids. The line-
up of two safety systems was independently verified by the
.
!
inspectors.
Housekeeping was observed during frequent
plant tours.
{
3.2.2
Conduct of Operations
The Team observed control reor,. operations en all shifts.
They were conducted in a formal manner, with effective
l
,
communications between
the operators
and
supervisors,
including repeat backs for certain functions. There was no
'
unnecessary traffic in the control
room.
Supervisors
briefed shift personnel on significant functions before
they occurred.
prior to energizing the recirculating pump
heaters, which could have produced smoke in the drywell,
'
the watch engineer thoroughly briefed to the reactor oper-
,
ator, equipment operator, and fire brigade leader,
t
The watch engineers, shif t supervisors, and reactor opera-
tors were knowledgeable about plant conditions and ongoing
work in the plant.
Shif t turnover briefings were thorough
i
and were followed by control room panel walkdowns. Attend-
i
ance at these briefings was inconsistent in that not all
wa:ch enginaars include other shift personnel, och as
health phytics shift workers in the pre-shift briefing.
The Teata observed that the health physics shift workers
receive separate briefings.
.ae Team discussed this prac-
t
tice with plant management, which stated that it was their
[
intent to include non-operations shif t workers in the pre-
!
t
!
shift briefing and that they would review its implementa-
t i o r, .
l
J
t
l
I
'
,
<
- - _ . _ - - _ _ .
--,
- _ -
__ _
_
.-
_
_ _ _ _ _ _ _ _ _ _
.
.
22
Control room operators received good support from the shift
technical advisors (STA), administrative assistants, and
other departments. The STA's were used in developing fail-
ure and malfunction reports (F&MR), and in the initial
followup of an EOD satellite procedure issue.
The admin-
istrative assistants do much of the administrative paper-
work and help to lessen traffic in the control room. There
was very good support of operations from other departments
in understanding and deciding che proper course of action
in response to F&MR events.
The Team accompanied several non-licensed equipment oper-
ators (E0's) on their tours.
The E0's performed their
plant tours in accordance with Procedure 2.1.16, "Nuclear
Power Operator Tour." Readings were taken and recorded, as
required. The operators also checked for abnormal condi-
tions,
such as vibrations, noise, leakage, odors, and
inadequate ventilation.
The E0's commented that they now
have more time to check general piant conditions on their
rounds beer.use the rounds are assigned to two E0's per
shift.
Previously, only one E0 made the plant tour.
The
E0's showed good regard for radiological protection and
ALARA practices. The operators were very familiar with the
plant, systems, and components, and were knowledgeable
about their duties and responsibilities.
The performance
by these operators demonstrated the effectiveness of the
non-licensed training program.
Watch engineers or operating supervisors accompany E0's on
plant tours at least once per week. Operations management,
including the chief ope atug engincar and operations
manager, were observed totring the control room frequently
and discussing plant status and evolutions with the watch
engineer.
i
The Team discussed the licentee's use of NRC's NUREG-1275,
"Operati.ig Ex9erience Feedback Report-New Plants" and ver-
iftad that licensee managemett had reviewed NUREG-1275
recommendations for applicabili'y,
BECo had independently
Initiated a number of improvemeats related to NUREG-1275
.
recommendations before they reviewed the ruort.
This
action was considered by the Team as a positiva example of
the quality of BEco self-improvement ef forts.
Some self-
identified improvement items include operator communica-
tions training, seminars to improve attention to detail,
splitting tours and revising tour sheets to improve equip-
ment operator performarce, and doing dry run training on
.
_ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ .
_ _ _ _ _ _ _ _
_ _ _ _ _ _
._.
._ __ __ _
. - _________.-____ _-_______-____
. _ _ _
O
O
23
the pcwer ascension and alternate safe shutdown evolutions.
Some improvement items resulting from the NUREG review
include seeking a more positive method of performing on-
shift instructions, repeating all logic system functional
tests, and performing a comprehensive review of inadvertent
emergency safety feature (ESF) actuations.
The ESF actua-
tion review has resulted in several corrective actions.
In summary, the licensee conducted operations in a profess-
ional manner.
Operators are knowledgeable about
their
duties and plant conditions and management keeps an active
and effective oversight of operations.
3.2.3
Shift Staffing and Overtime Controls
The licensee's Ser.ior Reactor Operators (SRO) are ver/
experienced and strengthen the operations organization.
To take advantage of this experience, an extra SRO will be
t
assigned to each shift during the Power Ascension Test
Program. Only 8 Reactor Operators (RO) have unrestricted
licenses because the 14 newly licensed RO's are limited
pending on-watch training and reactivity manipulations dur-
'
ing the Power Ascension Program.
Therefore, the licensee
will initially staff a four-shift rotation during plant
restart. At an appropriate point after restart, the licen-
see will go to a six-shif t rotation of two SRO's and two
RO'S per shift.
There are also sufficient non-licensed
equipment operators to staff six shifts. STA's will work a
five-shift rotation for at least the not year.
These
staffing levels are considered adequate.
It should not be necessary to work ope ators in excess of
the overtime guidelines of NRC Generic Letter 82-12. Senior
i
plant management has been active in restricting overtime.
Procedure 1.3.6.7, "Use and Control of Overtime at PNPS,"
adopts NRC guidelines, provides procedural controls for
overtime hours, and requires advance approval of overtime.
The
inspector reviewed Operations Department overtime
records for the period of July 6,1988 to August 16, 1988.
l
During this period, there were only three occasions when
!
.
staff worked greater than 56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> in a 7-day period. Dur-
ing this period, there was one instance of overtime in
,
excess of NRC guidelines.
This occurred August 1 and 2
when a radwaste worker worked 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> in a 48-hour period.
This worker had approval to work up to 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> that week
but did not have approval to exceed the 48-hour guideline.
This worker is not a licensed operator and was not doing
'
safety-related work. The licensee identitied this incident
and counseled the individual on overtime requirements.
_ _ _ _ _
o
24
l
3.2.4
Procedure Validation
The Team walked down Procedure 5.3.26, "Reactor Pressure
Vessel Injection During Emergencies," with a non-licensed
equipment operator who had been trained in the procedure,
i
The procedure involved connecting a fire water crosstie to
the residual heat ro;noval (RHR) system.
Minor procedure
(
errors were found. A drain valve labeled 1-DR-122 in the
l
field is referred to as 1-DR-121 and the fire water storage
'
tank low level alarm is referred to as annunciator B-7,
whereas it is actually 0-3.
Also, the procedure instructs
the operator to "connect the locel flow meter" without
specifying
the
instrument
number.
The
procedure was
actually referring to a st ra t r.e r differential pressure
indicator, instrument number 33-PID-4610. The operator did
not simulate connecting this instrument and when questioned
by the Team, he stated that the step referred to flow n)eter
FI 4609 which was already connected. Of more significance
was confusion caused by step IV.B.2.b, which instructs the
operator to install jumpers to defeat LPCI initiation and
PCIS isolation signals and operate LPCI injection valves 28
and 29. The equipment operator requested the assistance of
the watch engineer and the STA.
These watchstanders
initially felt the jumper was not needed,
iha jumper is
not directly ' elated to LPCI valves 28 and 29, but is
needed to provide a flow path for a fire pump and to pre-
pare for contingencies in the E0Ps.
Procedure 5.3.26 was one of eight new procedures written by
contractors and validated by contractors.
All eight of
these procedures are therefore suspect and will be revali-
dated by licensee operations staff before restart.
All
other E0P satellite procedures and other abnormal operating
procedures substantially changed daring this outage will
also be revalidated before restart.
The licensee did not perform any QA audits or surveillances
on the writing of procedures by contractors. However, the
licensee has performed surveillances of the procedure
validation process used on procedures other than the E0P
satellite procedures.
Surve111ances #87-9.3-9 and #88-1.
1-56 found that half of the procedures being revised and
implemented in April and May 1988 were not being validated.
As a result of this finding, procedure 1.3.4-4, "Procedure
Validation," was issued August 15, 1983.
- _ _____
__
_ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. _ _ . _
_ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _
___ _______ _ __.
.
.
25
There were also somt, training aspects to this procedure
issue.
The equipment operator was trained on Rev. O of
5.3.26 which did not include the instruction to connect the
local flow meter, whereas the inspector used Rev. 1. Licen-
,
sed operators were trained on the control room portion of
the E0P satellite procedures and equipment operators were
trained in the procedural steps outside the control room.
The problem with the jumpers occurred at the interface
between these operators.
Following the procedures revali-
dation discussed above, the licensee will provide addt-
tional training as needed.
During a NSRAC meeting conducted ' on August 2,1988, the
committee discussed an open concern on the validation and
upgrade of plant procedures.
NSRAC concluded that they
were concerned that all of tne routine operating procedures
had not been validated by one o' the validation processes.
Following the meeting, the committee forwarded a concern to
the SVP-N concerning the operating procedures necessary for
long-term operation of the plant.
The plant staff is
scheduled to respond to NSRAC on September 14, 1988.
The
NRC will review this response during a subsequent inspec-
tion.
3.2.5
Temporary Modification Controls
The Team observed that current logs show that about 15 tem-
porary modifications (TMs) are in effect, some of which
date back to 1983. Fif teen is not an unusual or unmanage-
able number of TM's, and represents a significant reduction
from previous conditions.
The Team reviewed nine TM's initiated 1987 and prior years
and noted (1) only three of the nine modifications affected
safety-related systems; (2) licensee safety evaluations
(SE) were filed in the TM package, which demonstrated the
interio
configurations
created
were
acceptable;
and,
(3) licensee actions to address the TM's by conversion to
permanent modifications were apparently based on engineer-
ing service requests and plant design changes referenced in
.
the TM packages.
Team review of the SE's on a sampling
basis did not identify any inadequacies. Further, the Team
noted that reduction of the TM backlog has been a licensee
priority.
I
t
!
L
~
.
_ _ _
_
_ __
_
26
Plant Procedure 1.5.9,
"Temporary Modi fications," allows
temporary modifications to be open for six months and pro-
vides a mechanism for active TM's to be extended. However,
this mechanism is typically not used. Procedure 1.5.9 does
not require a review of the TM for extension of the expira-
tion date if an engineering service request (ESR) for a
permanent design change is in effect for the TM. Of seven
TM's reviewed, six had ESR's and therefore did not have a
current approved extension date.
The inspector indicated
that good engineering practice would dictate continuance of
the periodic reviews for all TM's, and licensee management
agreed. The licensee committed to either prepare a justi-
fication for operation for every TM that is still open
prior to startup or to revise the procedure to apply the TM
extension request process to all TM's, including those with
outstanding ESR's.
TM 84-77 was selected for detailed followup review to
assess the technical adequacy of the change on a temporary
basis and to evaluate the extent and timeliness of licensee
followup actions to either remove the temporary modifica-
tion or convert it to a permanent change to the facility.
The modification involved the replacement of an FCR-type
relay in cubical 72-754 of the DC motor control center for
the RCIC 1301-22 valve.
The valve is in the suction path
from the condensate storage tank (CST), is normally open
for RCIC standby and initial operation, and will cycle
closed on low level in the CST.
After failure of the
existing TCR relay (an open circuit coil), an HFA-type
relay was installed on December 17, 1934 and made elec-
trically equivalent to the original circuit.
An HFA was
used because an FCR relay was not available onsite.
The
change did not affect the normal function of the valve.
Engineering
Service
Request
dated
July 22, 1985, requested engineering to convert the change
to a permanent modification, with a completion date of
November 22, 1985.
ESR response memorandum NED 86-1275,
dated December 31, 1986, rejected the ESR request to make
the change permanent because of two concerns involving the
need to keep the wiring in the 72-754 cubical consistent
with other DC motor control centers (MCC) and the assumed
differences in the inrush and coil holding currents between
the two types of relays.
In rejecting the request, engi-
neering found that the change was acceptable on a temporJry
basis, but recom. mended restoration of the original design.
.
.
27
A Potential Condition Adverse to Quality (PCAQ) Report (No.
NED 86-110) was issued to assess the deviations.
Further
l
engineering evaluation was requested by ESR 88-080, dated
January 27, 1988, with action requested by May 1, 1988.
Further engineering review determined that the change would
be acceptable as a permanent modification, which was made
by FRN 87-80-52 to PDC 87-80 dated June 14, 1988.
The plant design change (PDC) modified the drawing to per-
manently document the change and addressed the scismic ade-
quacy of the HFA relay installation. The HFA relay was not
certified to be environmentally qualified since the 1301-22
valve is not nn the EQ master list and environmental qual-
ification (EQ) is not required. The PDC also addressed the
adequacy of the inrush and holding current characteristics
of the HFA reley.
The second engineering review found the
HFA current characteristics to be better than those of the
FCR relay.
The Team discussed the bases for the original and final
engineering determinations via telephone on August 17, 1988
with engineering (NED)
The Team noted that engineering
.
initially rejected the proposed design change based on
l
!
information indicating larger power consumption by the HFA
relays, and based on a concern that, if replacement of the
FCRs with HFAs became a general practice, a problem could
result in the increase in DC loads.
Those concerns were
.
not realized since the FCR failure was a random one, and
l
the operating current characteristics of the HFAs are
l
better than initially assumed.
Based on the above, the Team identified no technical con-
cerns with the licensee's dispositioning of the adequacy of
>
the modification.
The Team noted that licensee action on the original 1985
ESR was not timely in either the preparation of the
original ESR or the followup actions by NED in response to
the site request. However, the actions to respond to ESR
88-80 and disposition the issue in 1988 were greatly
improved.
The Team audited the six tag outs for TM 84-22 and found
that MCC R25 was missing two TM tags. Since this is a non
safety-related modification which is about to be withdrawn,
this was not considered by the Team to be of safety signif-
icance.
It does indicate; however, the need to period-
ically recheck TM tagouts.
._ _____ _ _ _ _ _ _ _ _ _
.
.
28
An additional concern is that in the following example the
licensee performed a TM without implementing the formal
review and approval process. During a tour of the reactor
building on August 8,1988, the Team noted that reactor
'
pressure boundary leak detection system monitors C-19A and
C-19B had their doors propped open, and each monitor had a
large fan tied to the opening.
Investigation identified
that no temporary modification had been processed to
evaluate and authorize this alteration.
The
licensee
stated that elevated temperatures in the cabinets result in
failure of the monitor electronics and have been a long-
standing
problem.
Engineering response to Engineering
Service Request (ESR)85-462 implemented a reduction in
system heat-tracing temperature.
This alteration did not
resolve the problem, and on August 6,1988, the licensee
initiated ESR 88-558 requesting further engineering review,
Monitors C-19A and C-19B are required to be operable by
Technical Specifications during power operations so that
some short-term action and long-term resolution are needed.
Since the monitors are not currently required to be oper-
able, the licensee has de-energized them and removed the
fans pending evaluation.
In sumary, even though the licensee has been aggressive in
4
reducing the number of TM's, there have been some lapses in
their control of temporary modifications. This indicates a
need for continued licensee management attention to this
area,
3.2.6
Required Reading Books
The Team reviewed the "Required Reading" books in the con-
trol room.
The books consist of three large binders that
contain procedure changes.
They provide a method for
promptly updating operators on plant and procedure changes.
Each piece of information in the book had a sign-off sheet
to ensure that all operations personnel read the material.
The Team noted that information in the books dated back to
April 1983 and many of the procedure changes had not been
signed of f as read by all personnel. This appears to indi-
cate that the program is not being monitored routinely by
operations management. Material remaining in the book for
long periods defeats the purpose of providing timely infor-
mation on changes to the operators.
Conversely, if the
changes are not important to operations personnel, it may
not be necessary to put them in the books.
The Team discussed these observations with the Plant Opera-
tions Section Manager.
Some improvement was noted later
during the IAT inspection, as a result,
,
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
.
.
29
3.2.7
Logs
The Team reviewed the implementation of the Technical Spec-
ification Limiting Condition for Operations (LCO) log, the
Otsabled Annunciator Alarm Log, and the operations super-
visor
log
procedures.
The
LCO
log was
implemented
August 18, 1988,
by
Procedure
SI-OP.0008,
"Limiting
Conditions for Operations Log," dated July 25,1988, and
was
being
used
on
a
trial
basis
from August 8
to
August 18, 1988.
The only LCO entered after the log was
implemented, LC0 A-88-002, was properly entered, tracked,
and cleared.
Procedure SI-OP.008 is being revised to
incorporate lessons learned in its initial implementation.
The Disabled Annunciators Alarm Log is controlled by Pro-
cedure 2.3.1, General Action Alarm Procedures, Item VII.
The inspector observed eight disabled annunciator tags on
control room annunciators. All eight were properly logged.
However, only two of the eight annunciators had a mainten-
ance request (MR) issued.
The shift supervisor informed
the Team that disabled annunciators without MRs occurred
due to plant conditions and will be returned to service
before startup.
The licensee aud'ts disabled annunciators
monthly under preventive maintenance (FM) Procedure S. A.24
"Audit of Control Room Annunciators and Instruments," which
should assure that these annunciators are returned to ser-
vice before startup.
There was little activity in the control room during this
inspection, but the Team did observe the following items
properly logged in the operations supervisor's log: LCO's,
Failure and Malfunction Reports, a fire drill, and spent
fuel pool temperatures while the fuel pool pumps were
out of service for maintenance.
However, as discussed in
Section 3.I .8 below, changes in jumpers or lif ted leads
were not logp i in the operations supervisor's log.
The Team concluded that log keeping practices are generally
adequate.
3.2.8
Timely Update of Lif ted Lead / Jumper Log
During a review of the Lif ted Lead / Jumper (LL/J) procedure
and program implementation on August 16, 1988, the Team
identified that the log was not being n;aintained comoletely
up-to-date. Eight entries in the LL/J log involved lif ted
leads or jumpers installed on July 14, 1988, to perform
main station battery werk anc testing per Maintenance Work
Plan (MdP) S7-46-173.
All eight requests were associated
with the same M4P. All log entries showed the LL/J request
_ _ _ _ _ _ .
._.
_ _______ -_ ___ - _ _ _ _ _ _ _ _ _
_ _ - _ _ _
.
.
30
was still active on August 16, 1988. The Team found that
,
the batteries had been returned to normal and LL/J request
was closed out on July 29,1988, and that Maintenance
Request 87-46-173 was completed on August 1,1988, inclu-
sive of the post-work testing.
Step 5.3.1.5 of Station
Procedure 1.5.9.1, "Lif ted Leads and Jumpers," states that
the person performing the LL/J request is to notify the
Watch Engineer when the system is returned to normal by
removing the jumpers or landing the lif ted leads.. The
Watch Engineer is responsible for updatino the LL/J log.
The findings were referred to operations personnel on
August 16, 1988 for followup.
Licensee followup review confirmed that the work had been
completed and the log should have been updated.
The log
was updated to show the correct status on August 16, 1988.
In response to the inspector's findings, the licensee co..-
ducted an audit of the log.
The licensee's audit identi-
fied (1) two instances where the log had not been updated,
and (2) that operations personnel were not making entries
in the Operation's Supervisor log when LL/J log entries
were made.
These matters were referred to the Operations
!
Section for followup and corrective action.
QA followup
and trending will be covered by QA Surveillance Report
,
88-94-61.
4
The licensee reported that the cause of the discrepancy was
the failure of m61ntenance personnel to inform operations
j
that the jumpers and lif ted leads were cleared when the
i
systems were returned tb normal. Inspector interviews with
j.
the Maintenance Supervisor responsible for MR 87-46-173
noted that he failed to discuss the closecut action on the
4
LL/J request as a result of a misunderstanding on the
status of the work package closeout during shift turnover
with another maintenance supervisor.
Team review concluded the inaccurate LL/J log had minimal
significance and no impact on safe plant eperations for
these cases.
There was no loss of control of the physical
plant configuration.
Plant operators would have reviewed
the LL/J log as a prerequisite to plant restoration and
startup.
This review would have identified the open log
entries and
the completed closecut actions.
Further,
licensee followup to the discrepancies identified by the
Teara were prompt and appropriate.
Based on the above, and
in recognition that the jumper and lifted lead log is a new
tracking system, no further NRC action is warranted at this
time.
This
area will
receive
further
review during
subsequent routine NRC inspections.
_ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - -
.
.
31
3.2.9
Tagouts and Operator Aids
The Team reviewed the licensee's administrative controls
for use of protective tagging at PNPS.
The Team reviewed
Procedure No.1.4.5, "PNPS Tagging Procedure," Revision 23,
which is to be implemented September 1,1938, and noted
that this procedure was revised to address concerns with
tag controls identified during the licensee's self-assess-
L
ment.
Specifically, the procedure limits the use of Nu-
clear Watch Engineer (NWE) tags; prohibits the use of dan-
ger (red) tags for identification purposes on lifted leads;
and requires documented monthly reviews, including field
verification, of NWE, Caution and Master Danger tags and
tagout sheets.
The Team reviewed the NWE and caution tag
logs and independently verified that several NWE, caution,
danger, and master danger tags were properly filled out,
properly hung, and positioned as required on the compon-
ents.
No discrepancies were identified.
Based on this
review, the Team concluded that the licensce's control of
protective tagging was adequate and properly implemented.
The Team also reviewed the licensee's control of operator
1
aids as established by Procedure No. 1.3.34, "Conduct of
Operations." An operator aid is information in the form of
sketches, notes, graphs, instructions, or drawings used by
personnel authorized to operate plant equipment. The Team
reviewed the operations and chemistry operator aid log and
determined that it was maintained in accordance with the
i
procedure. The Team noted that periodic licensee reviews
1
and verification of the need for and placement of operator
aids were documented.
The Team independently verified
proper posting of selected operator aids, and no unauthor-
ized aids were identified during the Team's plant tours.
Based on this review, the Team concluded that the licen-
-
see's control of operator aids was adequate.
3.2.10
Plant Tours and System Walkdowns
3.2.10.1 Miscellaneous Tour Observations
!
The IATI Team made frequent plant tours.
The
overall material condition of rooms and equip.
I
ment was excellent.
Particularly notable was
cleanliness, fresh paint, and obvious decontam-
,
ination efforts to make major portions of plant
and equipment accessible. Comnonent labeling and
tagging was very good,
j
i
l
l
l
l
[
l
_ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
O
8
32
The Team observed activities in progress.
Per-
sons interviewed on tour (HP, security, opera-
tions
contractor)
had
experience
in
their
positions and were knowledgeable about their work
and duties.
HPs were cognizant of work activ-
ities in progress.
Housekeeping controls were
being maintained during work in progress.
The Team reviewed the status of indicators and
controls on selected local panels.
Controls and
indications were operable and no deficiencies
were noted. Operating procedures required to be
posted at the local panels were available and
adequate, based on Team review.
The Team observed loose cable tray covers includ-
ing one that was laying on top of an in place
cover.
The licensee reviewed this finding and
documented the review and corrective actions in
an engineering "white paper." This review deter-
mined that loose covers do not compromise the
design but that covers laying on top of in place
cable tray covers could be a seismic concern.
The misplaced cover found by the Team was deter-
mined to not be needed.
The licensee surveyed
cable trays throughout the process buildings and
found additional loose covers but no more that
were completely unfastened and laying on top of
other covers.
Corrective actions completed in-
clude refastening the loose covers, removing the
misplaced cover, revising procedure SI-SG.1010
"Systems Group System Walkdown Inspection Guide-
line," to use periodic walkdowns by the system
engineering division to identify seismic con-
cerns, such as misplaced tray covers, and prepar-
ing F&MR No.88-200, which will be used to deter-
mine how to keep future maintenance and modifica-
tion work
from creating
loose
or misplaced
covers.
The Team concluded that the licensee's
response to this issue was thorough and adequate.
The Team considers this issue resolved.
3.2.10.2 Diesel Generator Walkdown
A walkdown of the 'A' diesel generator (DG) was
completed on August 15, 1988, to verify opera-
bility and standby readiness of the emergency
power supply, and to observe the general condi-
tions in the 03 area.
The valve checkof f lists
of Procedure
2.2.8,
"Standby AC power System
(Diesel Generators) " were used as acceptable
criteria to establish the proper system valve
- _ _ _ _
.
s
33
positions.
The procedure checklists were also
reviewed for adequacy agatast Drawings M219 and
M224, and by comparison with the physical plant
during a walkdown of the diesel skid and room.
Proper valve lineup was verified for the DG fuel
oil and air start systems. This review confirmed
that the 'A' DG was operable in the standoy modo.
Cleanliness and the general condition of equip-
ment and components in the diesel rooms were
excellent.
Valve and component identification
(tags) and labeling were very good and showed
significant improvement in performance in com-
parison to past reviews. Several minor discrep-
ancies were noted, as follows:
(1)identifica-
tion tags were missing on valves 104C and 118,
and the tag was loose on valve 105C; (2) valve
118 was required to be locked in the closed
position and a chain and padlock were provided
for this purpose; however, the chain was suffic-
iently loose that the Team would have been able
to defeat the lock and thereby move the valve;
(3) the inner fire door granting access to the
'A'
DG skid had worn and damaged gaskets along
the closing surface and the door latching mech-
anisms (dogs) were misaligned with the position
indicators; (4) no permanent lighting was instal-
led in the ' A' and 'B'
diesel day tank rooms --
lighting, if installed, would aid operator re-
views during plant tours; and, (5) two isolation
valves for pressure switches 4555A and 4556A were
not labeled with an 10 tag in the plant and were
not identified on system drawings or procedures.
The valves were properly positioned.
Addition-
ally,
proper
valve
position
is demonstrated
indirectly during the monthly functional test of
the diesel air start system.
These discrepancies were noted by the Nuclear
Plant Operator accompanying the Team and were
discussed with the duty Watch Engineer. Actions
were taben to document and correct the discrep-
ancies, inclucing the issuance of Maintenance
Request 88-61-83 for the fire door.
Inspector
followup review on August 16, 1988 confirmed that
actions were in progress and had been completed
to correct the tag on valve 105C and to properly
lock valve 118.
Licensee response to the Team's
findings was appropriate and timely.
No other
inadequacies were noted.
__-______ __ ___
.
.
34
3.2.10.3 Standby liquid Control System Walkdown
'
The Team walked down the standby liquid control
(SBLC) system using the valve checklist in Pro-
cedure No. 2.2.?4, "Valve Lineup for Standby
Liquid Control System," and piping and instrument
diagram (P&ID) M-249. This review was performed
to verify the adequacy of the procedure checklist
and P&ID, evaluate the valve labeling, evaluate
the control of locked valves, verify the opera-
bility of instrument and support systems, and
assess the overall material Condition of the sys-
tem and general cleanliness of the area.
The
Team noted that the checklist control of vent and
drain capped connections differed from other
safety system procedures, such as those for the
residual heat removal (RHR) and core spray (CS)
systems. For example, an outboard vent valve on
the CS checklist would be "locked, closed and
espped." The SBLC procedure only checks "locked,
closed." No deficiencies with capped connections
were noted, however.
The Team also noted that
the vent valve for pressure indicator (PI) 1159
was not on the valve checklist.
The licensee
agreed to review these observations to determine
if the procedure needed to be revised.
No other
deficiencies or concerns were noted.
Overall, the Team found the valve labeling, mate-
rial condition, and general cleanliness to be
excellent.
3.2.11
Conclusions
The operations staff conducted their activities in a pro-
fessional manner. Operators were knowledgeable about their
duties and about plant status. The depth of experience and
knowledge of senior licensed operators is a strength and
will be a major asset du ri r.3 restart.
Shift turnover
.
briefings by individual operators and for the shift are
thorough; however, non-operations shift workers do not
routinely attend these briefings. Site management involve-
ment in operations was evident by their frequent presence
in the control room.
Shift staffing levels are adequate
and plant housekeeping was excellent
O
O
35
1
!
.
A weakness was noted in the validation and/or training of
E0P satellite procedures.
The licensee's commitment to
confirm effective implementation of E0P satellite and off-
normal procedures before restart is responsive to NRC con-
cerns.
Administrative controls and log-keeping practices
,
i
l
are generally adequate, although required reading materials
'
!
are not being reviewed by all personnel on a timely basis.
l
There are lapses in the licensee's control of temporary
4
modifications, particularly the absence of periodic reviews
and scheduled completion dates for temporary modifications
covered by an engineering services request,
i
!
l
l
l
I
I
i
r
l
L __
_ _ _ _ _ _ _ _ _ __ - _________ ____-__ _
..
__
_ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_
_ _ _ _
_ _ _ _ _ _ _ _ _ _ _
.
.
36
3.3 Maintenance
3.3.1
Scope of Review
The licensee's maintenance program has undergone signifi-
cant change during the past several months. Weaknesses had
been identified during the SALP period ending May 15, 1988,
,
,
and by Special NRC Maintenance Team Inspection 50-293/
~
88-17.
During the present inspection, the licensee's main-
'
tenance policies and program procedures were reviewed.
Maintenance activities were evaluated during the planning,
implementation, post work testing and closecut
stages.
Emphasis was placed on direct observation of ongoing werk
in the field.
Interviews were conducted with personnel at
each level within the maintenance department to determine
their depth of understanding of program goals.
The Team
'
,
also assessed the size and significance of the licensee's
l
maintenan'.e backlog, and reviewed established licensee
performance indicators.
1
3.3.2
Observations and Findings
3.3.2.1
Management Policies and Goals
'
The Team reviewed the licensee's Mission Organ -
tration and Policy Manual, Nuclear Operations
Procedures
Manual,
and
Maintenance
Section
Manual.
These documents describe the licensee's
'
policy and performance goals for the maintenance
l
l
program. The licensee has also established the
,
Material
Condition
Improvement
Action
Plan
!
,
(MCIAP).
The MCIAP, which is described in the
,
i
licensee's Restart Plan, is designed to achieve
!
long-term improvement in the maintenance program.
>
In addition, maintenance performance indicators
r
are being used by the licensee to evaluate the
success of recent program changes and the allo-
cated maintenance staff has been increased sig-
'
'
nificantly.
Interviews with maintenance person-
nel at various levels within the department indi-
, .
cate
that
the
organization
and
management
,
policies are generally well understood.
,
1
,
i
$
l
i
I
!
,
(
l
,
<
6
,
'
.
,
.
,
37
i
3.3.2.2
Organization and Staffing
The maintenance organization and staffing levels
were reviewed.
Interviews were conducted with
division
supervisors
and
staff personnel
to
determine whether organizational
relationships
were well
understood.
The
current
staffing
status was evaluated, particularly in the super-
visor, maintenance engineer, and planning post-
tions, to determine whether staffing levels were
adequate, responsibilities clearly defined, and
resources effectively used.
The maintenance section consists of three pro-
duction divisions (electrical,
instrumentation
and control and mechanical), plus a planning
,
division and an engineering group. All division
manager positions and all first-line supervisor
i
positions in the production divisions are filled
,
with licensee employees, except for two positions
in the equipment tool room, which are presently
filled by contractors.
Increased stiffing at the
craft level in the production divisions has been
i
authorized.
Instrumentation and Control (I&C)
will increase from 22 to 30 positions; Electrical
'
Maintenance will increase from 14 to 18 post-
tions; and Mechanical Maintenance will increase
from 27 to 33 positions.
Staffing of the plan-
ning division has not baen completed.
Twelve
contractor personnel are presently being used to
perform the planning function, with assistance
from the licensee's outage management group.
This arrangement is performing acceptably, as
described in Section 3.3.2.4
Team
interviews
with
supervisors
and
craft
'
empicyees showed that personnel clearly under-
stand the new program and their area of respon-
sibility. The interviews covered personnel with
a wide range of experience in their positions,
including those newly assigned.
The Team noted;
however, that the recently revised job descrip-
)
tions for the section have not been disseminated
to the staff.
The Maintenance Manager stated
that they would be issued in the near future.
!
!
!
. _ _ - - . __
e
O
38
Two positions in the new maintenance section
organization, the Deputy Manager and the Radio-
logical Advisor, are effectively being used. The
Radiological Advisor is a permanent staff post-
tion and provides a focus for interface with the
Radiological Protection Group. Team observations
indicated that the Deputy Manager was effective
in scheduling and coordinating activities through
his interface with other sections,
j
The Team's review indicated that licensee staff-
ing is ample to meet targeted production goals
without reliance on the use of excessive over-
time. While some variations occur, the percent
of overtime worked has been at or slightly above
the operatirg goal of 20*4, which equals a 48-hour
work week.
Work schedules for craf t and super-
.
visory personnel provide I day off in a 7-day
!
period.
The maintenance staff is working pri-
marily on the day shif t, with night shif t cover-
age provided for certain critical jobs in pro-
gress.
The licensee plans to provide around-
the-clock 8-hour shifts that will match the
Operations
Section
rotating
shift
schedule,
beginning with plant startup. Maintenance shift
coverage will continue through the power escala-
tion sequence and on a redaced scale afterwards.
Licensee staffing is sufficient to staff the
shift schedule without reliance on excessive
overtime.
New personnel assigned to the division manager
and production supervisor positions have adequate
prior experience in related assignments.
The
Team's observations of the first- and second-line
supervisors in conducting their daily activities
showed that the supervisory, oversight, and con-
trol functions were effectively performed. Based
on these observations, the Team concluded that
the newly hired supervisory staff does not have a
negttive impact on the quality of control over
maintenance activities.
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
,
.
39
In summary, identified strengths in the present
maintenance section organization include the use
of the Deputy Manager and
the
Radiological
Advisor.
The increase in supervisory positions
in the production divisions has been effective in
increasing oversight and control of work activ-
j
ities. While temporary staffing of the planning
division with contractors is sufficient and pro-
vides for an effective planning function (as
measured by the quantity and quality of mainten-
ance packages produced), plans to staff these
'
positions with permanent licensee employees by
October 1988 should remain a management priority
to assure timely integration of the planning and
i
scheduling functions. Management has controlled
overtime for the craf t and supervisory positions.
Plans to provide for maintenance staffing during
and after restart on an 8-hour rotating shift
basis should provide continued ef fective over-
time control.
3.3.2,3
Communications and Interfaces
Communication between the maintenance department
l
and other portions of the organization, particu-
[
larly operations and radiation protection, had
previously been a weakness.
The licensee has
,
taken successful steps towards improving communt-
cation, both internal to the maintenance depart-
,
ment and with other station groups.
The
Team attended a
variety of maintenance
department status and turnover meetings.
Based
,
on observation of the:S meetings and interviews
with maintenance personnel at each level of the
i
organization, the Team concluded that communica-
tions internal to the maintenance staff are ef-
[
fective.
Maintenance department managers vare
cognizant of the status of activities and of
f
emerging problems.
J
l
The
licensee
has
initiated
several
programs
directly
addressing
the
past
weaknesses
in
j
.
interdepartment communications.
In an effort to
,
l
improve the interface with radiation protection
!
and to raise worker sensitivity to health physics
,
issues, the licensee created and staffed the
!
l
nsintenance Radiological Advisor position. Inter-
l
views with a spectrum of individuals indicated
l
'
that this &ffort has had a positive impact on
f
.
h
.
.
.
. . .
.
.
. - __ _ _--
! .
.
,
6
!
l
40
day-to-day working relationships and performance.
The licensee also formed the Vork Prioritization
Review Team (WPRT), composed of representatives
,
l
of various station departments.
The WPRT pro-
I
vides a forum for discussion of the relative
I
importance of each maintenance item as it arises.
The WPRT has been effective in improving opera-
tion's departtent involvement with the mainten-
ance process. The maintenance department is also
involved in daily and weekly meetings intended to
l
ensure coordination between station groups. !!eet-
ings
attended
by
the
Team were
generally
effective.
l
The need for continued efforts to improve commur +
!
Ications and interfaces were noted in some arers.
The licensee's Stores Department practices .re
not alway: < >lly supportive of specific mainten-
ance department needs.
For example, lubricating
,
l
oil can only be withdrawn in bulk quantities,
l
such as a 55 gailon drum.
Typical maintenance
I
activities require use of only a fraction of this
amount.
Similar restrictions apply to materials
routinely used by the 1&C, electrical, and mech-
anical maintenance divisicns. This policy places
the burden for control and storage of unused
material on the individual requesting the with-
l
drawal. The Team noted that maintenance person-
'
nel were routinely using a cabinet in the main-
tenance shop to store uoused "Q" materials. No
prccedure existed to specify the appropriate con-
trols for the storage area.
The need for estab-
lishment of the storage cabinet had been dis-
cust.ed previously between the Quality Assurance
Department (QAD) and matntenar.ce.
QA0 believed
that the cabinet was nc,t currently in use, while
maintenance personnel believed that Q).O had con-
curred in its creation, demonstrating a lapse in
interdepartment
communications.
The
licensee
subsequently per ormed an inventory of the mate-
,
rials in the cal:1nct, and removed all non-Q ar.d
suspect materials.
Procedure 3.M 1-32, "Contrcl
of
- Q*
Hold A. ea ," wa s subsequently issued to
provide appropriate controls and surveillance of
the cabinet.
_____
_ _ _ _ .
____
- _ _ _
.
.
41
The Team also noted that partially used drums of
both Q and non-Q lubricatinq oil and grease were
being kept in a storage shed outside the process
building.
Several of the drums were not properly
sealed.
No procedure addressing this storage
arca existed.
Discussions with operations per-
sonnel indicated that the difference between Q
'
and non-Q drums of material was not clearly
understood. Routine withdrawals and their equip-
Mnt application were not A ecorded. In response,
a ..e
licensee removed all non-Q reaterials and
comitted to issue e procedu.*e to establish
aopropriate controls by Septecer 7,1988, in-
cluding provisions to ensure that, the lubricants
<
are traceable to their application in the field.
In addition, the liceasee committed to evaluate
the possible addition of non-Q oil to Q equipment
and its potential significance.
During followup to this issue, the Team reviewed
Engineering Specification M-547, which decuments
the procurement and receipt inspection re?vire-
ments for the purchase of lubricants as a Commer-
cial Quality Item (CQI).
The Team 70tsd that
l
M-547 requires sampling and testing of each b4tch
of material purcFased as a CQI.
At the Yeam%
request, the licensee reviewed records and iden-
I
tified two cases in which a CQI procurement order
had been issued which did not invoke thia samp-
!
ling
require. tent.
The
licensee
subsequently
issued a Potential Condition Adverse to Quality
(PCAQ) to initi.te a review of CQIs issuod for
i
consistency wit.h approved engireering specifica-
l
tions.
The licenste committed to disposition
!
this PCAQ prior to restart.
,
L
Overall ce:nunications between the maintenance
i
department and other groups within the organira-
l
tion are effective. However, the interface prob-
!
lems dis. usseo &bove, among the Stores Ospart-
'
,
men ,1AC, and the Maintenance Department. $ndi-
r
.
catt . hat continued at'.ention is needed.
T
,
i
l
i
P
i
i
f
-
-
'
'
.
.-
42
,
3.3.2.4
Maintunence Planning and Prioritization
' ensee has established a Mainte,a ce Plan-
r. . .
Ji . stor within the Maintenance Department.
The
!-
af the Planning Division is clearly
deline
in approved maintenance procedures and
the
.see's Maintensnce Section Manual .
The
. Planning
Division Manager position
has been
filled and the licensee is actively pursuing
candidates for the eight allccated staff post-
tions.
When staffing efforts are corolete, the
division will corsist of a work package planning
group and a scheduling group.
In the interim,
the licensee is utilizing twelve contractor per-
sonnel to perform the package planning function.
The licensee's Outage Management Group (OMG) is
currently providing scheduling guidance.
The
licensee expects to complete the staffing effort
by October 1988,
Team reviews indicate that the
present staff of contractors, in conjunction with
OMG assistance. is functioning well.
-
Implementation of the revised maintenance work
'.
process, particularly the need to generate de-
tailed job-specific maintenance work plans (K4P)
for each maintenance request (MR), has resulted
in a heavy emphasis on the planning function.
The Team reviewed a large sample of completed
KdP's, and KdP's in the field.
Interviews with
craf t personnel and first-line supervisors indi-
1
'
cated that these individuals were knowled;eable
about the new maintenance process requirements
and considered KdP's issued by Planning to be of
generally good quality.
One weakness was noted
i
in the area of post-work testing specification,
'
as discussed in Section 3.3.2.6.
The lum not"d that the completion of job plan-
ning,
ano approval of the F#P are typically
restraints to commencement of the activity.
This
results in the need to expedite the review pro-
cess, making scheduling difficult.
It appears
1
that this is primarily attributable to the new-
ness of both the program and the Planning staff.
Other factors also contribute.
For example, the
licensee's procedures currently do not provide a
simplified process for non-intert changes to the
M
e
-
m
o
-
43
MWP after issuance. MWP's require a complete re-
review to incorporate minor changes.
The licen-
see rtated that a revision to the program to
include provisions for non-intent changes
is
planned for the future. The licensee's engineer-
ing department is presently reviewing each MR/fiWP
and approving the use of any replacement mate-
rials.
This practice provides positive control
of all materials, but delays issuance of ;.he MWP
and
is
a
significant
drain
on
engineering
resources. While these factors inhibit efficient
planning, no instance of inadequate planning was
identified.
The licensee has created a WPRT to assist in the
assignment of the proper priority to each MR.
The WPRT meets daily and is composed of represen-
tatives of various station groups,
including
maintenance, operations, outage management, con-
struction management, and fire protection.
It
performs a multi-disciplined review of new main-
tenance items to identify potential plant impact.
The IATI Team attended a WPRT meetir.g and ob-
served that discussions were properly focused and
priorities weie assigned appro,-iately.
The Team also independertly reviewed outstanding
maintenance requests for the RHR system and the
electrical
distribution
system.
This
review
focused on MR's not designated for completion
before restart. The Team noted that MR 88-10-105
documented electrical ground and potential cable
insulation damage in the circuit for pressure
switch PS-1001-93A.
This switch is environmen-
tally qualified (EQ) and provides a
safety-
related interlock function for the automatic
depressurization system.
The MR had been sched-
uled for work af ter restart, leaving the switch
,
EQ in an indeterminate state. In response t
the
l
Team's question, the licensee rescheduled tne MR
for completion r~ior to restart.
!
l
,
i
l
_
.
-
~ -.
-
y
.-
-,
,
.
4
8
44
,
Tne -Team also noted that MR 88-10-26 documents
i
'
that valve A0-8901 is currently open and cannot
be closed using the ~ hand switch.
A0-8001 is
-
installed in series with a check. valve in the
tor'us fill line. The check valve satisfies the
,
primary containment isolation function for the
line. While A0-8001 is not rewired for contain-
ment isolation operability, h does serve as a
redundant isolation valve immediately adjacent to
the check valve. A0-8001 was originally designed
.
,
to receive an automatic open signal on sensed low-
t
torus level.
Because normal torus level is now
maintained below the instrument low level. set-
point, the valve continuously receives an open
signal, thus preventing manual closure.
This
condition has existed for at least several years.
The licensee has relied on closure of a maqual
block valve located in the turbine building to
compensate for the problem.
The Team expressed
concern that. the distance between the containment
!
isolation check valve and the redundant isolation
U
valve have been unnecessarily extended outside
the reactor building. In addition, a lineup that
'
is inconsistent with the design drawings and
operating procedures resulted.
The WPRT had
designated this MR as post-restart.
In response
to the Team's concerns, the licensee initiated an
Engineerirg Service Request (ESR) to identify an
acceptablo repair.
The licensee committed to
'
resolve tTis item prior to restart.
l
These tw o examples of misscheduled MR's were
discussed by licensee management with the WPRT.
In addition, the licensee committed to re-evalu-
i
i
ate all priority 3 MR's before restart.
The
licenser's process for review and prior tization
'
!
of MR's is thorough, and with the exuption of
the twc instances described above, appears well
l
implemented. The vffectiveness of the licensee's
plannirg and prioritization program is demon-
'
strated by the overall decrease in the number of
outsta1 ding maintenance tasks, their average age,
i
and their significance.
l
3
L
i
i
I
4
i
<
- .
- . -
- . . - .
- -
- - - . -
- -
- _ . _ _ - . . . -
.
~
-
.
>
45
The licensee tracks several maintenance perform-
ance indicators which are indicative of backlog
status.
Those performance indicators generally
display a favorable trend. The Performance Indi-
cator Report for August 9,1988, shows a total
backlog of 2177 open MR's, of which 746 are in a
test / turnover status.
Of these, 220 cannot be
tested until the plant system becomes operable
during startup. Of the 1431 remaining open MR's,
the
licensee has identified 652 required for
restart.
The physical work had yet to be done
for 145 of these 652 MR's.
Based on tho above,
and an average closeout rate of about 25 packages
per week, elimination of the restart backlog
with)n 6 to 7 weeks appears to be manageable
effort.
The licensee's goal, i r,
addition to
addressing the restart MR's, is to reduce the
total number of open MR's from 1431 to less than
1000 Dy plant restart.
The Team noted that this
would constitute an acceptable open MR backlog
for an opersting plant, and that the licen>ee's
goal was reasonable.
3.3.2.5
Control and Performance of Maintenance
Inspection in this area was performed to deter-
mine whether maintenance activities are being
properly controlled through
-tablished proced-
ures, and the use of approve
2chnical manuals,
drawings and job-specific instructions. Mainten-
ance activities were observed to determine how
well
the new prog am was being implemented.
The new maintenance program is nrimarily defined
in Procedures 1.5.3, "Maintenance Requests," and
1.5.3.1,
"Maintenance Work Plan," which were
implemented
on June 20, 1988.
The procedures
were reviewed and found to provide strong con-
trols for identification, planning, performance,
and closecut of maintenance tasks.
Issuance and
control of materials used for replacement / repair
assure that requisite quality requirements are
' maintained.
Super /isory oversight of work in
progress and the final review of work packages
for completeness is a strength.
Based on its
review of the above procedures and observations
of work in progress, the Tear concluded that the
r,swly defined program provides excellent control
and docu entation of activities.
.
,w
. .
n.
. -
..
..
.
.e-
0
4
46
,
!
'
.The new program and proced',ies formalize controls-
i
.
that were previously in place, but inconsistently.
t
applied and not . recognized by ' procedures.
The
procedures now require better documentation of
the initial
problem description,
the rcpairs
made, and the post-work test requirements. They
'
require detailed work instructions, which should
provide for consistent high quality in mainten-
ance work packages. An. additional improvement in
the maintenance procedures is that the mainton-
[
ance work plan now provides for detailed documen-
I
tation of installation and removal of lifted
I
leads and jumpers (LL/J).
This documentation
i
assures proper performance of the . task and is
i
supplemented by the tracking;provided in the LL/J
!
l
Log initiated by the Operations Department per
Procedure 1.5.9.1.
'
I
To eliminate a previously identified weakness,
.
the
licensee
has
stopped
using
Procedure
3.M.1-11, "Routine Maintenance," which was found
+
,
to be too general to adequately control work
i
activities.
Instead, detailed work instructions
are provided by the work plans prepared in ac-
l
cordance with Procedure 1.5.3.1.
Further, the
licensee has stopped using the Maintenance Sum a
i
i'
mary and Control (MSC) form.
The documentation
provided by the form has been replaced by the
detailed
work
plans,
maintenance
logs,
and
'
'
special process control sheets now required by
'
'
procedure. 1.5.3 and 1.5.3.1.
1
The maintenance activities and packages listed in
[
'
Appendix 0 of this report were reviewed to verify
,
proper implementation of program requirements.
'
t
The Team found that detailed work packages were
prepared and in use in the field with adequate
,
'
job specific instructions to accomplish the as-
!
scope were observed.
Pre-job briefings were
'
signed tasks.
No ad-hoc changes of the work
.
conducted and were appropriate to outline the
activities planned.
Coordination and in-process
!
communications with operations personnel were
[
proper
and
assured
good
control
of
plant
i
equipment.
I
f
t
i
,
.
h
?
-.- - - - -.-. -
_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. .
. .
47
Maintenance
personnel,
including
contractors,
have been trained in and were knowledgeable about
the new program and procedure requirements. Al-
though the new controls were deemed cumbersome by
'
some, overall worker attitudes about the new
procedures were positive.
There is a general
acceptance of the present progra:n and a desire to
"do the work right."
Personnel performing the
work wrre qualified, as verified by the training
and qualification status board maintained in the
maf-*.enance shop.
The licensee has made progress in filling vacan-
cies in the. first-line supervisor positions.with
personnel having the requisite experience and
expertise in the associated disciplines.
The
present supervisory staffing is adequate to cover
work production schedules and provides adeouate
oversight.
In an addition 21 program improvement,
supervisor review of work packages is now re-
quired by procedure to assure management review
of packages for completeness.
First-line super-
visors were ruutinely observed in the field di-
recting work in progress.
Supervisory involve-
')
ment was effective to assure completion of work
correctly, to help resolve technical problems,
and to coordinate engineering support, as re-
quired. The oversight function has been enhanced
by the larger number of first-line supervisors
who have been relieved of the excessive adminis-
trative burden associated with planning and pack-
age prepar' tion.
The effectiver.ess of maintenance staff engineers
and system engineers in supporting field activ-
ities was particularly noted in the repairs for
the fuel pool cooling pump and the repair of RHR
discharge valve 288. The engineers are also used
in the root cause analysis of component failures.
The repair of valves 28A and B involved the
.
fabrication of new valvo yokes, which resulted in
a large and complicated work control process that
was appropriately broken down into several work
packages.
Oversight and control of these jobs,
which spanned several weeks, were notable. The
quality of the final product was evident, as was
the welding of the yoke subparts. Good inprocess
t
. _ .
-,
-
i
. , -
,
t
,
48
,
controls resulted in an acceptable root weld on
the first attempt for valve 288.
Although a
'
problem was encountered in the fabrication of the
yokes (short by 3/8 inches), . this item, consid-
ered minor, was properly dispositioned by the
licensee
through Nonconformance
Report (NCR)
88-99.
3.'3.2.6
Post-Maintenance Testing Program
The licensee's program for identification and
implementation of post-maintenance testing was
considered weak during
previous
inspections.
During the current period, the Team revieweo the
licensee's post-maintenance testing program pro-
cedures and other approved test technical guid-
ance. A sample of maintenance tasks was reviewed
to determine if planned testing adequately demon-
strated correction of the cited deficiency. Test-
ing was observed in the field, and completed test
documentation was
reviewed
for
thoroughness.
The licensee recently implemented a major revis-
ion to Procedure
3.M.1-30,
"Post-Work Testing
Guidance."
The current revision establishes a
conservative philosophy designed to ensure that
prescribed testing verifies correction of the
original deficiency, as well as potential prob-
lems which could have resulted from performance
of
the
task.
Organizational
and
individual
responsibilities are clearly defined.
Procedure
3.M.1-30
incorporates
by
reference
Station
Instruction SI-MT.0501, "~os t-Work Test Matrices
and Guidelines."
SI-MT 0301 serves to further
define the method by which post work testing is
to be specified and documented.
It includes an
individual matrix for each type of component
describing the possible maintenance tasks and the
corresponding post-work test requirement.
Each
matrix references an appropriate data sheet which
,
provides more dctailed testing guidance. Proced-
ure 3.M.1-30, in conjunction with SI-MT 0501, is
to be used by the Maintenance Planning Division,
with needed technical input from other mainten-
ance department and systems engineering depart-
ment personnel, to establish comprehensive test-
ing requirements for each maintenance request.
The testing program as described in these docu-
ments is well conceived and is considered a
strength,
i
i
I
,
,
a.
_
49
c
The. Team reviewed a sample of ongoing maintenance
tasks and evaluated the technical adequacy of
prescribed testing. In three of the examples re-
viewed, the planned testing was not adequate to
ensure proper performance of the task. and com-
plete correction of the problem:
(1) Testing identified for the replacement of
i
the fuel pool cooling pump _ and _ motor under
MR 86-109, included only motor current and
vibration monitoring.
No pump head / flow
test was specified.
(2) The package for replacement of a safety 4
related 4160-VAC bus leekout relay under
MR-88-110
initiall/
contained
only
the
general guidance which should have been used
for development of detailed testing. Subse-
quently, suggested testing verified only a
portion
of the lockout relay functions.
(3) Post-maintenance testing following repair of
a motor operated valve limit switch under MR
88-10-179 was also not adequate to ensure
that
the
prcblem
had
been
completely
corrected.
In response to the Team's f_indings, the licensee
Maintenance Section Manager audited task-ready MR
packages and identified one additional case of
inadequately specified testing.
In each of the
above instances, the licensee subsequently de-
veloped and performed adequate post-work tests.
Discussion with the personnel involved and main-
tenance department management revealed that no
training on the newly developed post-work testing
procedures and guidance had been corducted. The
licensee immediately briefed appropriate super-
visors and workers on the program, and committed
to complete formal training in this area by
September 9, 1988.
A second potential contrib-
utor to the problem in planning post-work tests
is the press of business, particularly in the
planning area, in that the planners are currently
just able to keep pace with the schedule for
field activities.
Liensee management appeared
to be sensitive to this issue. The Team reviewed
an additional sample of in process and completed
MR's and did not identify any further problems.
_
__
_ _ _ _
' "
n
'-
50
Overall, the Team concluded that the licensee has
established a . thorough post-work testing program
demonstrating a sound safety perspective.
Al-
though sne program is generally well implen;ented,
some problems were noted.
The newness of the
program, the current press of business, and some
weakncss in personnel training appear to be af-
t
fecting its implementation. Therefore, this area
requires continued licensee attention.
3.3.3
Cor.clusions
1
The licensee has established a viable maintenance organiza-
tion.
Allocated staffing levels have been substantially
increased and are sufficient to support routine maintenance
,
activities. Of particular significance is the addition of
i
first-line supervisory positions, and the creation of an
'
expanded maintenance planning and scheduling division. The
licensee has been largely successful in filling previously
,
vacant positicas.
One exception is the staffing of the
l
maintenance planning division. While none of the permanent
staff in this area is in place, the licensee is effectively
i
utilizing contractors to perform tae function. Full staff-
,
ing and training of the planning division is important to
improving its overall ef fectiveness. Aggregate management
and supervisory qualifications were also found to be
,
adequate.
!
'
Newly revised maintenance and post - ek testing program
procedures provide significantly impre..d control and dccu-
mentation of field activities.
They also result in an
increased emphasis on detailed job planning. Observations
by the Team indicate that implementation of the program is
j
generally effective.
Some
implementation problems are
.
evident; however, the problems affect production and not
i
the ov.'ity of completed work.
Additional attention to
post-w rk test program applicrtion by the licensee
is
needed.
'
t
The licenseo appears to have identified and properly pri-
oritized outstandino maintenance tasks, with only minor
,
F
'
exceptions noted.
A process to ensure continued proper
[
prioritization has been established.
Both licensee senior
r
L
management and maintenance section management are using a
set of indicators to monitor performance.
i
!
,
!
L
t
!
..
.
51
In summary, the licensee's current maintenance staff and
program are adequate to suppo-t plant operations.
Con-
tinued close licensee management monitoring of the newly
implemented program will be required until
additional
experience is gained. The long-term supaort programs, such
as preventive maintenance, will requir : licensee enhance-
ment to further strengthen performance.
l
l
I
l
)-
1
.
o
a
52
3.4 Surveillance Testing and Calibration Control
3.4.1
Scope of Review
The Team reviewed the licensee's administrative controls
and implementation of the surveillance testing and cali-
bration control program to assess its adequacy. As part of
this review, the Team examined the licensee's corrective
action to address past problems which included:
ef fec tive-
ness of test scheduling; the technical adequacy of proced-
ures; and lack of centralized control of the program.
The
inspection consisted of a review of various procedures,
drawings, and records; observations of testing in progress;
and personnel interviews.
3.4.2
Observations and Findings
3.4.2.1
Master Surveillar
Tracking Program
i
The Team reviewed the licensee's program for the
control and evaluation of surveillance testing
and calibration required by the Technical Specif-
ications (TS), inservice testing (IST) of pumps
and valves required by 10 CFR 50.55.a(g), ans
calibration of other safety related instrumenta-
tion not specified in TS.
The program is pre-
scribed by Procedure No.
1.8,
"Master Surveil-
lance Tracking Program." The Systems Engineering
Division Manager has overall adminsitrative re-
sponsibility for the Master Surveillance Tracking
Program (MSTP). A plant Surveillance Coordinator
has been assigned within the Systems Engineering
Division to implement the program, which includes
reviewing and approving the various lists, sched-
ules, and reports generated by the MSTP, and
maintaining the MSTP data base.
Each division
has appointed a Division Surveillance Coordinator
to interface with the plant Surveillarice Coor-
dinator.
The
plant
Surveillance
Coordinator
meets weekly with the Plar t Manager to review the
.
status of the surveillance program.
The purpose of the MSTP is to ensure the timely
perfnrmance of all surveillance testing.
The
MSTP data base contains information such as:
commitment reference (TS, preventive maintenance,
etc.);
the
applicable
procedure number and title; scheduler interval
and basis; the group responsible for performing
_
-
,-
,
53
the test / calibration; and the date last performed,
the next due date, and the last date by which the
surveillance test must be completed (plus 25%
date). Completed tests are rescheduled to ensure
the combined grace period for any three consecu-
tive tests does not exceed 3.25 times the spec-
ified surveillance interval'
The accuracy of the
data base was verified by a contractor during the
current outage. Procedure No. 1.8 contains spec-
ific controls on changing any of the data fields
in the MSTP data base to maintain its accuracy.
,
In addition, a second contractor verification of
the MSTP data base is scheduled to be performed
in the near future.
The Team selected several
TS-required surveillance tests to ensure that
they are in the MSTP data base, that' approved
procedures existed, and that the test frequency
was proper.
No discrepancies were identified
with the data base during the Team's review; how-
ever, the Team was concerned with a potential
problem involving the schedulir;g of once per-
operating-cycle versus once per-refueling-outage
tests, as discussed below.
As part of its review, the Team examined the pro-
cess established by Procedure No. 1.8 to deter-
mine its adequacy in ensuring that surveillance
tests were properly scheduled and performed with-
in the required time period.
A "Division List"
is issued to each division and to the Control
Room Annex each Friday which provides a schedule
of tests due for performance the following week.
A "Monthly Forecast" is also issued weekly to
assist the Section Managers in planning and
scheduling resources. When a surveillance test
is satisfactorily completed, the Control Room
Annex copy of the Division List is signed off.
Daily,
the
Planning and Scheduling Division
transcribes the completion dates and updates the
MSTP data base. A "Surveillance Day File Report"
is issued daily to identify all changes made to
the MSTP data base since the last time the report
was issued. This report is reviewed by the Plant
Surveillance Coordinator and used to verify pro-
per transcription and data entry.
"Variance
Reports" are issued weekly to Section Managers to
_
E.
.
x
a
54
identify those
surveillance
tests
that' were-
scheduled, but not performed. A written explana-
tion as to why the tests were not performed with-
~
in the required time and why it's act.eptable not
to perform the test is sent to the surveillance
coordinator within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of receipt of the
Variance Report.
A "Priority Notice" is issued
for any surveillance test that has reached its
deadline date (plus 25% date) and that has not
been performed by that date to assist in the pre-
vention of TS violations.
Failure to perform a
TS-required surveillance test on the deadline
date requires submission of a Failure and Mal-
function Report.. The Team reviewed samples of
each of the above reports, and their responses,
and concluded that the program was adequate and
contained sufficient checks to ensure that sur-
veillance
tests
were
completed
within
the
required time.
Although the Team found the administrative con-
trol and implementation of the MSTP to be ade-
quate, it noted a commitment by licensee manage-
ment to improve the program.
These improvements
include:
replacing the Division Lists with task
cards to reduce the potential for transcription
errors; adding an alert notice when a scheduled
test is not performed; improving the scheduling
of conditional surveillances; planning for the
addition of a full-time surveillance engineer;
and instituting an equipment history computer
program capable of trending surveillance /calibra-
tion results on individual components.
The Team identified one concern during its review
related to the scheduling of once per-operating-
cycle versus once per-refueling-outage surveil-
lance tests.
The Pilgrim Technical Specifica-
tinns define an operating cycle as the interval
between the end of one refueling outage and the
,
end of the next subsequent refueling outage.
A
refueling outage is the period of time between
the shutdown of the unit prior to refueling and
the startup of the plant after that refueling.
The TS contains some surveillance requirements
that are specified to be performed once per oper-
ating cycle, while there are others, such as
testing the drywell-to-suppression-chamber vacuum
breakers, which are to be performed during each
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _
,
.o
r
'55
refueling outage.
Also, all the safety-related
instruments not specified in the TS are cali-
brated once per refueling outage. As part of a
previously identified issue, the licensee has
defined once per-operating-cycle to be 18 months;
i
however, no clarification has been provided for
once per-refueling-outage.
As a result, there
are
several
once per-refueling-outage
tests /
l
calibrations which were performed in 1986 and
1987 which are currently scheduled on the MSTP
for
the
"next
refueling
outage," which
is.
projected for some time in 1991.
i
Therefore, by strictly interpreting the defini-
tions, the interval for some of the once per-
t
refueling outage surveillance tests could be as
long as four or five-years. The Team pointed out
that this appears to be beyond the intent of the
TS.
The Team also noted that a licensee task
force established to determine system operability
prior to restart had also identified this issue
and recommended that evaluations be performed on
the once per-refueling-outage surveillance tests
to determine if and when they should be reper-
formed.
The * 'censee committed to evaluate the
status
of
the
once-per-refueling-surveillance
tests and provide justification for those tests
not rescheduled, prior to restart.
3.4.2.2
Logic System Functional Test and Simulated
Automatic Actuation Procedures
The
Team reviewed
the
procedures
listed in
Appendix 0 of this report to determine the ade-
quacy of the licensee's performance of logic
system functional
tests (LSFT) and simulated
,
automatic actuations (SAA). The review consisted
of the indicated channel / train of the primary
containment
isolation
system (PCIS)
and
the
reactor core isolation cooling (RCIC) system LSFT
and SAA, and the diesel generator (DG) initiation
LSFT.
The procedures were reviewed against the
'
system drawings to ensure that they were tech-
!
nically adequate, that all relays and contacts
were tested, that the procedures were properly
,
approved, and that the tests were performed at
,
the required frequency.
The licensee uses a
series of overlapping tests to satisfy the LSFT
.
, -
c.
c
s
G
56
1
?
and SAA. The Team noted that the licensee had a
"
,
contractor review the adequacy of the LSFT and
SAA tests during this outage.
The contractor
identified several deficiencies, which were cor-
i
rected.
The Team found that each procedure re-
viewed was technically adequate and that the
testing sequence satisfied the Technical Specifi--
cation LSFT and SAA frequency and scope require-
ments.
The Team also noted that the format of
the procedures was adequate and included:
en-
vironmental' qualification quality control (QC)
witness
points
on
transmitter
calibrations;
i
<
double verification on lifting and landing leads;
!
fuse holder fit checks; and I&C management review
upon test completion prior to the NWE review.
i
Ouring the review of the RCIC isolation subsystem
LSFT, the Team questioned why there was no LSFT
on initiation logic. The Team acknowledged that
it was not required by TS Table 4.2.B
nor was
credit taken for it in the FSAR.
However, TS 3.5.0.1 re.Jires RCIC be operable (with reactor
pressure greater than 150 psig and coolant tem-
perature greater than 365 degrees F) and the TS
definition of system operability requires that
all subsystems also be operable.
This would
include the RCIC initiation logic.
Also, the~
guidance provided by the Standard Technical Spec-
ifications indicates that an LSFT on the RCIC
initiation logic should be performed every six
l
months. The Team noted that Procedure No. 8.M.2-
2.6.7,
"RCIC
Simulated Automatic
Actuation,"
actually performs an initiation logic LFST; how-
ever, it is scheduled at a once per-18-month fre-
!
quency, while TS-required LSFT's have a frequency
l
of once per 6 months.
This item is unresolved
,
i
pending a licensee evaluation of the adequacy of
i
the RCIC initiation logic LSFT frequency (88-21-
i
02).
The licensee committed to pcovide, before
i
restart, the technical basis for the surveillance
[
frequency.
3.4.2.3
Calibration Procedures
7
!
The Team noted that the licensee established a
!
series of procedures, known as the 6.E series, to
calibrate the safety-related instrumentation not
p
,
specified in the Technical Specifications.
This
,
_ _ _ _ _ _ _ _ - _
__ .
.
.
57
instrumentation is normally used to record data
necessary to complete TS required surveillance
i
tests or inservice testing of pumps and valves.
The 8.E procedures are scheduled on a once per-
refueling-outage interval.
The Team performed a detailed review of Proced-
ures No. 8.E.11, "Standby Liquid Control System
Instrument Calibration," and 8.E.13, "RCIC System
Instrument Calibration." Overall, the Tecm found
i
the technical content and format to be adequate;
'
however, two discrapancies were identified.
Pro-
cedure No. 8.E.11 does not calibrate pressure
indicator (PI) 1159.
This PI was installed dur-
.'
ing the current outage and is used in the per-
formance of Procedure No. 8.4.1, "Stendby Liquid
'
Control Pump Operability and Flow Rate Test."
The Team also noted that Procedure No. 8.E.13
does not calibrate PI 1340-2. This PI is used in
the performance' of Procedure No. 8.5.5.1, "RCIC
,
Pump Operability Flow Rate and Valve Test 9 1,000
psig."
PI 1340-2 was installed and last cali-
brated during the 1984 outage when pressure
i
transmitter 1360-19 was replaced with a Rosemount
Transmitter.
The licensee indicated that the
i
procedures .sould be
revised to correct the
l
deficiencies.
1
3.4.2.4
Survefilance Test Observations
'
,
.
On August 16, 1988, the Team observed a portion
'
of the performance of Procedure No. 8.M.2-2.10.
1-5,
"Core Spray System
'B'
Logic Functional
!
!
Test," Revision 13.
The test was performed as
!
j
part of the restoration of the
"B" Core Spray
l
j
System and as post work testing of relay 14A-
K208.
The test was observed to ensure it was
'
performed in accordance with a properly approved
'
and adequate procedure.
During the test, the
i
Team noted that the technicians' performance was
t
,
.
adequate. They conducted the test in a slow and
deliberate manner and stopped when questions
,
arose concerning mislabelled nameplates and the
'
identification of some relay coil leads.
In both
i
cases, the questions were resolved before they
proceeded.
The Team noted that the I&C first-
line supervisor monitored portions of the test.
.
The test was also monitored by QA personnel as
part of the surveillance monitoring program. QA
i
personnel indicated that they observe approxi-
j
mately one surveillance test a week.
~
'
.
.\\
l
t
l
1
. - - _ , - _ - - , - , -
. . , , , , , , . _ - , . - . _ , - _ , , , , . - . - , _ _ . , , , _ . - . , , _ , . ,_,
- . , _ ,
, . . , ,
. - - ,
--
..,,,e
. --
.
.
_
_
_
~4 f:
9
~
,
-58
i
The test was stopped at Step 25 when the test
results did not agree with the expected results
delineated in the procedure.
The step was sup-
posed to verify the instantaneous pickup of the
-
core spray pump start relay 14A-K128. Subsequent
,
licensee investigation revealed that the instan-
taneous pickup was removed as part c,f the de-
graded grid voltage modification (Plant Design
Change (PDC) 88-07).
The Team noted that PDC
.
88-07 had not yet been closed; however, an impact
!
review performed prior to installing the modifi-
cation failed to identify Procedure 8.M.2-2.10.
1-5 as being affected by the PDC.
The Team noted that one of the licensee's self-
assessment action items was to review the impact
of PDC's
(installed
since October
1987) on
"
L5FT's.
The
licensee's
review
began
on
October 1987 because this was the completion date
,
of the contractor review noted above which ver-
ified the adequacy of LSFT/SAA tests.
The Team
3'
noted that the contractor review produced an
i
LSFT/SAA data base which cross references the
'
safety-related components tested to the appli-
cable LSFT/SAA test.
This data was being used
during the licensee's review.
Four of the five
PDC's involved in the licensee's review of impact
on LSFT's have been completed. The remaining PDC
(88-07) was under review when the problem with
the core spray LSFT was noted.
Twenty-one pro-
i
cedures have been identified as possibly being
'
affected by the PDC and are currently under
review.
The CS functional te3t appears to be the
only affected test run prior to completion of the
!
PDC procedure review,
t
The licensee indicated that a possible future
'
improvement will be to use the LSFT/SAA data base
e
l
to determine the impact of a PDC on procedures
before implementing the modification.
j
.
3.4.2.5
Measuring and Test Equipment
The Tea;n reviewed records, interviewed personnel,
and toured storage areas to determine the ade-
quacy of the licensee's program for control of
measuring and test equipment (M&TE). Administra-
'
tive control of the program is established by
,
l
Procedure No.
1.3.36,
"Measurement
and Test
'
Equipment."
i
. - - _ _ _ _ - _ _ _ _ _-.
- _ - _ _ _
,
-.
59
,
!
,
The licensee has implemented a computerized sys-
.
tem to issue and track M&lE.
This system will
only allow issuance equipment to authorized per-
-
sonnel, will limit the checkout period to only 24
!
hours, and will not issue M&TE if the sticker
r
calibration date does not match the calibration
date in the computer. The system also issues a
PATE traveler form to the user to identify usage
on each plant device tested and each M&TE range
used.
This data is later entered into.the com-
-
puter to assist in evaluations if and when a
l
piece of M&TE is found to be out of calibration.
The Team reviewed two cases where M&TE was out of
calibratinn and noted that the evaluations per-
formed were documented in accordance with proced-
ures
and appeared thorough.
Thus far, only
electrical I&C and electrical PATE are on the new
computerized system; however, similar controls
are being manually implemented for mechanical
equipment until it is incorporated into the new
system.
,
The licensee currently has two storage areas for
l
M&TE:
ene for electrical /I&C and one for mech-
,
anical equipment.
The Team toured each area and
a
noted that the equipment was identified by a
unique number and indicated calibration status.
,
The Team found that the equipment was properly
stored and that P4TE out-of-calibration, on hold
i
for repairs, or new equipment not yet in the sys-
tem, were properly identified and segregated.
i
The licensee indicated plans to go to only one
storage arer and to increase the number of staff
!
issuing and controlling the P4TE.
'
i
!
The Team also reviewed the system for recalling
)
equipment for calibration.
The recall tracking
!
is performed in accordance with Procedure No,
t
1.8.2, "PM Tracking Program." The Team reviewed
l
,
severa' equipment calibration stickers during its
,
tour of the storage areas and during observations
I
of ongoing surveillance and maintenance activ-
t
ities.
No equipment past its calibration due
date was identified.
'
1
The Team found the licensee's control of measur-
ing and test equipment to be adequate.
L
{
r
!
l
L
!
I
1
.
.
.
. -
_ _ _ _ _ _ _ _ .
__
_ _ _ _ .
_____ ___
,
a
60
3.4.2.6
Inservice Testing of Pumps and Valves
The Team reviewed the status of the licensee's
program for inservice testing of pumps and valves
in accordance with the ASME Boiler and Pressure
Vessel Code,Section XI.
The licensee submitted Revision 1A to the inser-
vice test (IST) program on October 24, 1985.
A
meeting was held between BECo and the NRC on
January 14, 1988, to discuss the licensee's pro-
posed Revision 2 to the IST program. To minimize
impact on the NRC review cycle, the licensee sub-
niitted an interim IST program, Revision 18, on
March 14, 1988, to address concerns identified by
the NRC during review of Revision 1A. The licen-
see plans to subm!t Revision 2 af ter the Safety
Eva'.uation Report on Revision IB is issued. Pe-
vision 2 is to maintain the upgrades made to the
program in Revision 18 and increase the program
scope by adding more components
(e.g.,
relief
valves).
Control of the IST Program is established by Pro-
cedure No.
8.I.1,
"Administration of Inservice
Pump and Valve Testing."
The Team reviewed the
procedure and noted that while it defines the
,
methodology for compliance to the IST program for
pumps and valves, including analysis of test
data, direction on corrective action, and estab-
l
lishment of reference values (additional guidance
is contained in Procedure No. 8. I .3, "Inservice
Test Analysis and Documentation Methods"), the
organizational
responsibilities and referenced
IST program revision need to be updated.
For
example, the pump and valve testing is now sched-
uled through the MSTP instead
f.,f
the compliance
group, and a Senior ASME Test Engineer has been
hired to implement the program.
The licensee
acknowledged the Team's comments and showed it a
.
draf t revision to Procedure 8.I, which is sched-
uled to be implemented when Revision 2 is submit-
ted.
The Team reviewed the draf t procedure and
noted that
it provided additicnal detail on:
_ _ - _ _ _ _ - _ _ _ _ _ .. _ __-
,
.
61
responsibilities, definitions, test requirements,
compliance requirements, evaluation, disposition,
post-maintenance testing, and administration and
records maintenance.
The draft procedure also
provides a listing of the pumps and valves cur-
rently within the testing program and includes a
cross-reference for individual test requirements
to the approved PNPS procedure.
The Team noted that other improvements (planned
or in progress) to the IST program include revis-
ing all the implementing procedures to upgrade
them to Revision 2 and creating a position for a
second ASME test engineer.
The Team reviewed several pump and valve test
results for the standby liguid control, core
spray, salt service water and low pressure cool-
ant injection systems to verify that the accept-
ance criteria were met, that the results were
properly evaluated and trended, and that the fre-
quency of testing was increased when required.
The Team noted that Procedure No. 8.I contains
controls to change the MSTP data base test fre-
quency when the deviations fall within the alert
range. The Team reviewed changes to various pump
reference values to ensure that they were justi-
fied and documented.
The Team also checked the
reactor buildirg closed cooling water, salt ser-
vice water, and standby liquid control system
pumps to ensure that the IST vibration data point
was properly marud.
No deficiencies were iden-
tified during this review.
3.4.3
Conclusions
Based on observations, personnel intervieus, and the review
of procedures and records noted above, the Team concluded
that:
,
1.
The licensee has established and is implementing an
adequate and effective program to control all surveil-
lance activities at PNPS.
2.
Responsibility for implementing the MSTP has been
p! aced
in
a
centralized,
strong,
forward-looking
division.
_-
q
O
O
62
3.
The licensee was adequately implementing the IST pro-
gram for pumps and valves.
The Team noted that there
are several
planned
improvements
to
the
program
involving administrative and implementing procedures
and staffing to upgrade the IST program.
4.
Licensee management is committed to improve the sur-
veillance program,
as
evidenced by
the upgrades
planned or in progress in each area examined.
These
include:
contractor data base reviews; increasing the
scope of the IST program, increasing staffing; im-
proved control over issuing and tracking M&TE; estab-
lishing an equipment history computer program; replac-
ing the MSTP division lists with task i:ards; and
improving conditional test scheduling.
S.
With the exception of the few deficiencies noted
above,
the
procedures were
technically
adequate.
6.
The one concern identified was the licensee's need to
resolve
the
once per-refueling-outage
scheduling
deficiency.
i
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _
D
O
63
3.5 Radiation Protection (RP)
3.5.1
Scope of Review
The Team reviewed various aspects of the radiation protec-
tion program during the inspection, with emphasis on the
licensee's ability to safely support plant startup.
Per-
formance was determined from:
observation of work in
progress; periodic tours of plant areas; interviews with
managers,
supervisors,
and technicians; and review of
selected documents.
The areas reviewed are as follows:
1) Organization and staffing;
2) Training, qualification and continuing education of RP
technicians;
3) General employee training;
4) ALARA programs;
5) Control and oversight of work in radiological areas;
6) Control of locked high radiation areas;
7) Acequacy of laboratory (count room) equipment;
8) Availability and
adequacy of portable
RP survey
equipment;
9) Adequacy of gaseous and liquid release monitoring
systems;
'
10) Clarity and consistency of RP policies and procedures;
11) Audits.
3.5.2
Observations and Findings
'
3.5.2.1
Organization and Staffing
i
.
The organization of the radiation protection (RP)
department has remained stable since the signifi-
cant changes which were made early in 1983. The
i
staffing level has remained constant and is ade-
quate to support plant operations.
The RP soc-
tion
marager
described
various
enhancements
_ _ - _ _ - _ _ _ _ _ .
p
a
64
planned for the supervisory staff.
An outline
for qualification as Radiation Protection Man-
ager, per Regulatory Guide 1.8,
has been ap-
proved. One or two division managers within the
RP section will be expected to qualify as Radia-
tion Protection Manager to provide depth in the
organization.
Incentives have been approved for
achieving this qualification.
In addition, the
three division managers will rotate assignments
for cross-training purposes, and all will be
encouraged to pursue advanced scholastic degrees.
These efforts are expected to begin in the near
future.
The Team observed some indications of isolated
morale problems at the technician and first-line
supervisor level which were attributed to several
causes.
Contributors include personnel and as-
signment changes within the organization result-
ing from rotation of radiation protection shif t
supervisors, an influx of new technicians, im-
pending implementation of a new rotating work
.
schedule, and a perceived lack of management
presence in the field.
In addition, weaknesses
may exist in communications within the RP organ-
ization as evidenced by technician perceptions of
a lack of technician input or review during the
development or revision nf RP policies and pro-
cedures.
In summary, and in spite of these dif-
.
ficulties, the Team observed that the technicians
and supervisors were generally enthusiastic and
competent.
Another potential weakness results from the prac-
tice of rotating technicians through job assign-
ments each three to six months.
Although this
practice may have merit for familiarization and
job exposure purposes it may prevent or signifi-
cantly delay the development of a high profici-
ency
level
in certain
specialized
technical
areas, a concern particularly evident in the
instrument repair and calibration facility. Here
the RP technician is assigned to repair and cali-
brate a wide range of instrumentation, including
gas flow detector cells, sophisticated computer-
controlled automatic friskers, air pumps, and all
alpha, beta, gamma and neutron survey meters.
The area supervisor stated that he was attempting
to resolve this problem by requesting an exten-
sion of the rotation cycle.
1
i
--
, , _ _
__
__._._.--,_.c
.-_
- _ _ - _ _
__
i
d
.
65
~.
The RP section has 42 technicians, of whom 36 are
ANSI 18.1 qualified.
Only 21 have commercial
experience. The section manager provided a shift
staffing schedule for power ascension testing
that will ensure that the experience will be
adequately distributed among the individual shift
Crews.
3.5.2.2
RP Technician Training
The RP technician training and qualification pro-
gram is certified by the Institute of Nuclear
Plant Operations (INPO), uses INPO guidelines for
development of instructional material, and uses
the INPO exam question bank.
The training is
conducted in three phases over a period of two
years or less, depending on experience.
Upon
completion of Phase 2,
the technician .is con-
sidered to be ANSI qualified and can issue radia-
tion work permits.
The third phase includes
specialty tasks such as operation of the whole
body counter and respirator fit testing.
Classroom training is provided at the offsite
facility. The training facilities were adequate,
well lighted, comfortable and equipped with prac-
tice equipment.
The Team observed that most of
the basic survey instruments were available, but
laboratory-type gamma spectroscopy equipment, as
well as ALARA mock-ups, were not available. This
is typical of a single unit station.
Most pre-
sentations appeared to rely on lectures with
minimal use of audio-visual equipment. A review
of selected lesson plans showed adequate tech-
nical content.
Classroom training is followed by an in plant
phase where the technician receives on-the-job
training and demonstrates proficiency at various
tasks.
This is documented in a qualification
.
folder.
Qualified technicians will be provided
with ongoing training on a six-week schedule.
This will be contingent on implementation of a
new six-section rotating work schedule.
The
,
,
66
training department has begun drafting lesson
plans which will cover a broad range of topics,
including interpersonal
skills training.
The
instructors must also complete formal qualifica-
tions.
They were recently required to begin
spending a certain number of hours in plant be-
tween training cycles.
This keeps them abreast
of changes occurring in the plant.
The Team concluded that this program is well-
controlled and documented and is aided by a dy-
namic first-line supervisor.
The implementation
and effectiveness of cycle training will be eval-
uated in the future.
The licensee's current ef-
forts are directed at completing initial qual-
ification for the entire staff.
3.5.2.3
General Employee Training (GET)
All general employee training and in processing
is conducted at the on-site training center over
a three-day period.
Classrooms were spacious,
comfortable, and well equipped.
Ample training
aids, as well as audio-visual equipment, were in
evidence.
A comprehensive student manual
is
given to each trainee along with copies of appro-
priate regulations and regulatory guides.
Basic
training involves 20 contact hours, while radia-
tion workers receive an additional 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
Res-
pirator fit testing is also provided.
The two instructors associated with GET had com-
pleted the formal
Staff Development
program.
Both have extensive experience and are well qual-
ified. Although their teaching techniques could
not be observed since no classes were in session
during the week of this review, the Team con-
cluded that the training content provided ade-
quate direction to attendees.
Both instructors
spend time in the plant weekly to assess staff
training needs.
The GET training is INPO certified. In addition,
the training center offers five courses to all
new supervisors. A new industrial safety train-
ing program is under development. An instructor
has been hired and will begin providing training
in occupational safcty during the first quarter
of 1989.
- - .
.
.
67
The Team concluded that management support of GET
training was good, that the training was effec-
tively conducted, and that it made a positive
contribution to safety.
3.5.2.4
ALARA Programs
ALARA performance at this station had been a
persistent weakness over several past SALP report
periods.
The Team noted recent apparent improvement in
upper management support for ALARA programs.
Examples of this support are reflected in the
re-evaluatien of the 1988 ALARA goal from 600 to
390 manrem and formulation of 'iveral plans to
reduce exposures. Also, the licensee is assign-
ing an experienced manager to survey INPO, Elec-
tric Power Research Institute (EPRI), and several
other nuclear stations to make a list of cost-
effective exposure source term reduction tech-
niques.
The Station Director will then formulate
a long-term program based on the findings of this
survey.
Another plan is to begin removal of
abandoned in place systems in 1989 which should
remove unnecessary sources of exposure. A th'rd
project is underway to identify hot spotr in
plant piping and determine which of these could
[
be reduced by flushing.
The ALARA staff also has plans to attend a train-
ing course and visit other stations to observe
effective techniques.
This staff
i s in
the
process of filling its final vacancy.
,
'
,
ALARA performance at the working level remains
mixed. Licensing personnel developed a technique
for conducting remote inspections of fire barrier
penetrations using a flashlight mounted on a
telescope.
This concept may ta appiled in num-
,'
erous situations and has the potential for sig-
nificant dose savings.
On the other hand, in-
stances of f ailure to effectively use low-dose
waiting areas were observed during work.
The
ALARA divisicn manager is working to increase the
.
sensitivity of all workers and technicians to
l
ALARA practices.
(
!
!
l
,
l
..g
- _ _ - , - - -
gm
_ _ _ _ _ _ _ _
._ __
,
.
63
The Team concluded that licensee attention to
ALARA programs has significantly improved in
recent months.
The effectiveness and implemen-
tation of AL\\RA plans will be assessed in future
NRC inspections.
3.5.2.5
Control of Work
During closure of a Confirmatory Order in the
fall of D87, NRC noted some improvement in the
r91ations between the RP section and the other
sections performing work. However, poor planning
and lack of work control continued to be ob-
served.
During this assessment, further improve-
ment in resolving these weaknesses was observed.
One indicator of poor planning is the number of
radiation work permits (RWP) issued but not used.
A review found that only a small fraction of
RWP's issued are now unusad.
In addition, the
use of "A" priority maintenance work requests by
the Operations Department to expedite work has
decreased significantly.
The use of a Radiation Protection Advisor as-
signed to the Maintenance department continues to
be effective. This position was recently assumed
by an experienced RP technician.
He has intro-
duced innovations, including frequent work group
training sessions and installation of permanently
situated boxes in the plant for ccntaminated
tools.
The Planning Division is developing improved pro-
cedures for planning work.
This section is re-
sponsible for coordinating with the RP and ALARA
groups during the early phases of work planning.
This allows adequats time for RWP preparation and
re*
isponsible
section managers
stated tt
'N
- arly maintenance-HP contact
,
will be pr.u
s' ted ir. September 1988.
The Team observed that on-the-job cooperation
between workers and RP technicians was good.
A
minor problem ,vas noted in that RP technicians in
the controlled area appeared unprepared to deal
with a minor first-aid injury.
Technicians were
___
.-_
_ _ _ _ _ _ - . .
.
>
69
uncertain in dealing with a worker with abrasions
to his nose that caused bleeding.
This was at-
tributed by the Team to a lack of training snd
clear policies.
On the other hand, technicians
appeared well prepared to handle more serious
emergencies,
i
3.5.2.6
Control of Locked High Radia_ ion Areas
The
licensee has previously incurred several
violations for failure to properly control locked
high
radiation
areas.
This
issue has
been
tracked as a NRC outstanding item (87-57-01).
The licensee organized a task force to determine
which lasting corrective actions would prevent a
i
recurrence of these problems. Based on the find-
ings of th- task force, the control procedures
were revised to placa basic responsibility on the
RP technician who signs out the door key.
Fur-
i
ther controls are provided by shift tours of all
locked areas and by upgrading locking devices.
Gased on these actions, the Team concluded the
licensee had appropriately addressed concerns ir.
this area.
3.5.2.7
Laboratory Equipment
The adequacy and availability of RP laboratory
-
equipment to support plant startup was reviewed.
The
licensee
has
available
two multichannel
analyzers
(Nuclear Data
6700),
several
beta
counters (BC4), and several alpha counters (SAC
<
t
4).
The radiochemistry laboratory has redundant
,
equipment for backup. This equipment is required
to perform isotopic analysis of air samples for
maximum permitted concentration (MPC) calcula-
'
tions, detection of degraded fuel conditions, and
to support radwaste analysis. Procedures for the
use of the
equipment are available
in
the
laboratory.
The Team noted that, at the time of the inspec-
tion, several pieces of laboratory equipment wert
awaiting repair or calibration.
Only ;ne BC-4
i
and one SAC-4 were operational in the lab.
Both
nultichannel
analyzers
were
awaiting
repair
parts.
The supe tisor in charge attributed this
to the lack of proficiency of the technicians due
to the rotating work assignment policy.
This
issue was discussed in Section 3.5.2.1.
-
.
.
70
3.5.2.8
Survey Equipment
The svailability of properly calibrated survey
equipment was reviewed. Survey equipment is used
by RP techniciant, to measure dose rates, and sur-
face and airborne contamination levels.
Included
in the review were the automatic personnel con-
tamination detectors.
All equipment is calibrated and repaired in a
facility on site, eFCept for neutron survey
meters.
RP technicians are trained to perform
all
functions in the facility.
The facility
appeared to be adequately equipped to perforhi its
task,
s
Stocks of equipment ready for issuance appeared
ample and the calibration / repair backlog was
minimal.
This readiness may have been aided
somewhat by reduced outage activity.
The Team
noted an improvement in that the new manager of
the g"oup has recently implemented a computer
program that shows the status of each piece of
equi pme ri t , the data base for which is updated
each time an instrument is issued.
Information
that is captured includes users of the meter,
calibration due date, and failure mode if placed
out of service.
The Team concluded that an adequate supply of
calibrated instruments is on hand te <;pport
routine
operation.:
and
abnormal
c cm. '.i o n s .
3.5.2.9
Monitoring Environmental Releases
The operability of the environmental
release
monitors was verified.
The two paths for a gas-
eous release are the main stack and the reactor
butiding vent.
The monitors were fouiid to be
operational
and
properly
calibrated,
with
approvea procedures available. The eculpment is
ile the cal-
maintained by the Chemistry Group
'
culations of offsite doses require
oy the re-
<ised Radio
ical Environmental Technical Spec-
ifications
StTS)
are
performed
by
the
seation.
- .
-
-
_
x,
e
O
71
The s'ngle liquid release path monitor was oper-
ational.
Due to elevated background radiation
levels at the sodium iodida e.anitor, a new system
has been installed parallel to the old system.
The new system will offer increased sensitivity
and will be tnught on line in the near future.
3.5.2.10 Policies and Procedures-
-
A sampling of RP procedures indicates that they
ara generally clear.
The number of procedures
controlling
the RP department
activities
is
extensive. However, the format varies from step-
by-step instructions to a more general format.
The RWP procedure is currently being revised to
make the process less cumbersome and more useful.
In general, the RP technicians Md not feel ade-
quately consulted during the revi.ston of proced-
ures.
This
issue was discussed
in
Section
3.5.2.1.
The Team concluded that ;,he RP procedures were
adequate to support startup.
3.5.2.11 Audits
Previous inspections found the licensee's inter-
nal audits and asssessments of the RP program
-
were primarily compliance-oriented.
Currently,
these audits are completed in several ways. Sev-
eral peer evaluators were trained to make on the-
job observations.
A Radiological Assessor is
permanently assigned to the staff reporting to
the Senior Vice President.
The Management Over-
sight and Assessment Team (MO&AT) does monthly
plant tours.
Also, the QA Dr,artment recently
transferred in two expertene.
etP personnel.
In
addition to the above audits and reviews, the
Radiological Occurrence Report (ROR) system pro-
vides a method to capture input from workers and
RP technicians.
A review of these efforts shows that a moderate
level of success has been achieved in finding
program weaknesses.
However, the results i. ave
not been commensurate with the ef' ort involved.
The RP section manager stated that an ef fort is
. .
_ _ _ - _ _ _ _ _ _ _
,
72
,
underway to shift the emphasis of these audits to
performance rather than compliance.
The audit
performed by QA in November 1987 is being used
as a model.
Licensee efforts in this regard are
expected to be long term and are adaquate at this
time to support plant startup.
3.5.2.12 Control of Radiological Shielding
The Tear reviewed the licensee's program for the
,
installation, control, and removal uf radiation
'
shielding. This review concluded that the licen-
see's program for control of radiation shielding
is well documented and that implementation is
good.
The prograr.; guidelines are contained in PNPS Pro-
cedure 6.10-008, "Installation and Removal of
Shielding." Responsibility for implementation of
the procedural requirements fall under the aus-
pices
of
the
Radiological
Technical
Support
'
Division.
The procedural requirements for con-
'
trolling this process appear well defined and
comprehensive.
Licensee personnel
responsible
for implementation of the procedure were well
versed on procedural requirements and current
field installations.
l.icensee records of field
it.stallations were current, had been reviewed at
the required intervals, and were accurate.
3.5.2.13 Health Physics Training
The Team observed licensee personnel during a
i
contamination control
training exercise.
The
'
exercise simulated a spill of highly radioacLive
(3 Rem on contact) resin during transfer opera-
l
tions.
The scenerio document was well defined
-
and included detailed timelines and instructions
to the exercise controllers. The entire exercise
i
was videotaped and replayed during the debriefing
[
.
of participants.
The exercise was well control-
led and interviews with participants indicated
i
that the individuals involved considered it to be
'
an effective training device.
Lessons learned
and feedback frnm participants appeared to be
well disseminated.
,
,
4
i
t
._
-..
.
. . -
_ _ . _ - . _ , _
._
_
. _ .
_ _ _ _
,
.
73
l
3.5.2.14 Hydregen Water Chemistry System
The licensee has installed a system to inject
hydrogen gas into the fcedwater to reduce the
potential for corrosion of ieactor internal pip-
ing.
This process will result in increased radi-
ation levels onsite from increased radioactive
nitrogen isotope levels in the system. A review
of the impact analysis showed that a comprehen-
i
sive plan to control exposures has been developed.
A test run i.1935 resulted in the installation
of a 16-foot high 20-inch thick concrete shield
around the turbine.
Moreover, special controls
are programmed into the computer that controls
the hydrogen injection.
The cognizant engineer
stated that tFese controls are designed to pre-
vent increased exposure either onsite or of fsite.
Team review of these calculations showed that
J
doses may in fact be lowered.
The Training Department is developing a training
program for the RP technicians to review the
l
change in '.adiation levels that occur with opera-
tions. This program was developed to refresh the
RP technicians because of the extended shutdown
1
and the increased levels of radiation in the
shielded areas resulting from the addition of
'
The RP section manager stated that a
condensed revision of these presentations will
also be given to all maintenance and operations
personnel prior to startup.
3.5.3
Conclusions
The Team determined that progress has been made, that ade-
quate staff and management oversight is in place to achieve
further progress, and that performance is adequate to sup'
port plant startup.
ticenset
strengthr. include a well-controlled and well-
,
organized training program for general employees and RP
technicians.
The use of an RP Advisor in the Maintenance
Section, which had been effective in improving working
relationships, has led to further initiatives in training
and control of :ontaminated tools.
The addition of this
ocsition has also resulted in improved nianning and control
of work.
-
-
-
-
.
.
_ , _ _
- - -
.
.
74
Notable progress was observed regarding upper management
support and emphasis on ALARA.
This attention is expected
to result in improving levels of performance over the next
few years.
Staff development programs for all levels of
personnel, from technicians through managers, should con-
siderably improve their level of performance.
Control of
technical problems, such as the radiological impact of
hydrogen water chemistry and calibration status of survey
meters, has improved.
A weakness was observed as a result of the rotational as-
signment of RP technicians that may affect eheir profic-
1ency in performing certain highly specialized jobs.
An
additional weakness concerns the perception of poor ver-
tical communications between management and RP technicians
and workers. Although this issue has led to some incom-
plete understanding of policies and some morale problems,
it has not significantly affected safety
performance.
Additionally, vertical communications within the RP organ-
ization appeared somewhat weak.
The Team detected a per-
ception on the part of technicians that they have not been
adequately involved in the changes being made in the RP
Department policies and procedures.
This perception ap-
parently has resulted f rom RP management not effectively
communicating the b.ses for these changes to the staf f.
There is also a perception that RP management is remote and
not easily accessible. However, the Team determined that,
despite this weakness, the attitude and safety approach of
the RP Departmeat staff has significantly improved and is
adequate to support plant operations.
The licensee advised that a training program is being
developed to refresh RP technicians concerning the change
in radiological conditions on plant startup and the unique
conditions to be created by the addition of hydrogen. A
condensed version of this training will be provided to
other radiation workers. Cempletion of this effort will be
reviewed in a future NRC inspection.
.
O
..
.
- _ _ _ _ _ _ _ _ _ _ _
,
.
75
3.6 Security and Sateguards
3.6.1
Scope of Review
Prior to the plant shutdown in Anril 1986, NRC had identi-
fled serious concerns regarding the implementation and
management support of the security program at Pilgrim.
The
licensee has been aggressively pursuing a comprehensive
course of action to ider.tify and correct the root causes of
the programmatic weaknesses in physical security. The most
recent SALP (50-293/87-99) covering the period February 1,
1987 to May 15, 1988, determined that the licensee has
demonstrated a commitment to implement an effective secur-
ity program. The licensee's security organization has been
expanded with the addition of experienced personnel in key
positions, significant capital resources have been expend.:1
to upgrade security hardware, and equipment and progr m
plans base been improved.
During the IAT inspection, all phases of the security pro-
gram, including management support, staffing, organization,
and hardware maintenance, have been reviewed to assess the
eff ectiveness of the program implementation.
The results
of the review are described below in general terms to
exclude any safeguards infor.sation.
3.6.2
Observations and Findings
3.6.2.1
Review of Security Program Upgrades
The Team reviewed the progress made to date on
the security program improvements committed to by
the licensee as a result of previous NRC enforce-
ment action.
The Itcensee was advised by the
Team that progress on these improvements will
continue
to be monitored during
future NRC
inspections.
Those commitments and their status
are as follows.
.'roject
Status
.
Protected Area
The upgrades of tne perimeter
Perimeter
barrier, intrusion detection
system,
and assessment aid
system are complete.
- _ .
_
-
_ _ _ - _ _ _ _ _ _ _ . - . .-. _
__. _ . _. _ _ .
_ _
___
_ _ _ _ _ _ _
_ . _ _ _ .
.
.
76
Project
Status
Protected Area and Installation of upgraded
Perimeter Lighting
lighting is approximately 95%
complete.
Four light stan-
chions remain to be instal-
led.
The lighting system as
i
installed
meets
regulatory
requirements.
Main and Alternate The
designs
for
the
new
i.
Access Control
(upgraded)
access
control
Points
points are complete and new
package search equipment is
on site. Installation of new
package and personnel search
equipment
and
full
length
turnstiles is scheduled for
completion on
September 28,
1988, in the site's main ac-
cess point.
Installation of
new package search equipment
in the site's alternate et e-
cess point is also scheduled
for September 28, 1988.
Vital Area
The vital area analysis,
Analysis
including walkdown
of
all
vital areas to verify barrier
integrity,
and issuance of
.
'
the
report,
is
complete.
New Security
The selection of the new
Computer
computer has been made and a
purchase order for the com-
puter has been issued.
The
'
licensee is currently working
with the vendor on software
,
options.
The delivery of the
!
new computer is scheduled for
the first quarter of 1989,
l
with installation to follow.
,
,
I
L
_ _ _ _ _ _ _ _ _ -
.
.
77
3.6.2.2
Followup on Previously Unresolved Item
(Closed)
Unresolved
Item
(50-293/87-44-01):
Neighborhood checks for licensee employees being
assigned to the site were not being consistently
conducted as part of the access control program.
The neighborhood checks were not a regulatory
-
requirement
and
it
is
a
licensee-identified
issue. During this inspection, the Team verified
that the licensee has conducted a review and
identified all site personnel who had not been
subjected to neighborhood checks.
For those
employees with less than three years of service
with the licensee, neighborhood checks were s';b-
sequently conducted.
For employees with more
than three years with the company, a review of
the personnel file was conducted and a memorandum
was put into the file to indicate that the review
was being made in lieu of the netchborhood check.
The acceptability of this alternative to the
neighborhood checks was reviewed by NRC prior to
its implementation and was found satisfactory.
3.6.2.3
Security Plan and Implementing Procedures
The Team met with licensee representatives and
discussed the NRC-approved Security Plan (the
Plan).
As a result of these discussions, and a
review of the Plan and its implementing proced-
ures, the Team found that the implementing pro-
cedures adequately addressed the Plan's commit-
ments.
In addition,
all
security personnel
interviewed demonstrated familiarity with the
L
Plan, implementing procedures, an- NRC's security
program performance objectives.
1
3.6.2.4
Management Effectiveness - Security Programs
'
An in-depth review of the licensees management
ef fectiveness was conducted by NRC in April and
May 1988 and documented in Inspection Report No.
1
50-293/88-18.
During that inspection, the Team
concluded that the licensee has continued with
its initiatives at' taken significant actions to
further improve the effectiveness
1 security
organization.
It was also cor.
that the
i
existing organization should provive the capa-
bility to monitor the program properly.
<
t
P
-
.
.
.
_ _ _ _ _ _ _ _ _ _ _ _. _.
._
.
o
78
During its inspection, the Team independently
concluded that there is a strong management team
in place based on the experience of the expanded
proprietary security organization, the effective
interaction both between members of the security
organization and with other departments, and the
effective oversight of the contract security
organization.
3.6.2.5
Seci~ity Organization
On
ugust 16,1988, at 10:00 p.m.,
the security
con ractor
for PNPS was
changed
from Globe
Security Systems to the Wackenhut Corporation.
The Team reviewed the licensee's and the contrac-
tor's transition plans, and interviewed numerous
management and union security personnel prior to
the transition. Also, the Team was onsite during
the
transition for direct observations.
The
transition was somewhat simplified by the fact
that all Globe employees that applied for posi-
tions were retcined by Wackenhut.
The
Team
determined that, because of comprehensive transi-
tion planning, the change in the contract secur-
ity force was accomplished without any compromise
of security and with minimal disruption to secur-
ity operations.
!
3.6.2.6
Security Program Audit
The Team reviewed the monthly corporate audit
reports. These c
it reports were of gotd qual-
ity and were generated as a result of corporate
oversight of the site security program.
The
i
findings in these reports were minor and not
indicative of any major programmatic problems.
The corrective actions were appropriate for the
findings.
3.6.2.7
Records and Reports
.
The Team reviewed various :ecurity records, logs,
,
and reports, including patrol logs, central alarm
l
station (CAS) logs, visitor control logs, and
testing and maintenance records.
All records,
legs, and reports reviewed were complete and
maintained as committed to in the Plan.
!
l
l
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
o
79
3.6.2.8
Testing and Maintenance
The Team reviewed the testing and maintenance
records and procedures.
The review disclosed
that the preventive maintenance procedures were
comprehensive and that the licensee now has in-
place a program that provides for prioritization
of security maintenance by the security depart-
ment.
The maintenance support to the security
department has improved as a result of the secur-
ity department assigning priority to the mainten-
ance work.
The use of compensatory measures for
inoperative equipment is minimal.
3.6.2.9
Locks, Xeys and Combinations
The Team reviewed the installation, storage, ro-
ta ' ion and related records for all locks, keys
ano combinations and determined that the licensee
was meeting the commitments in the Plan and its
implementing procedures.
3.6.2.10 Physical Barriers - Protected Areas
The Team physically inspected the protected area
l
barriers. It was determined by observations that
the barriers were installed and maintained as
described in the Plan. Progress on upgrading the
barriers is addressed in Section 3.6.2.1 of this
section.
3.6.2.11 Physical Barriers - Vital Areas
The Team physically inspected the vital area bar-
riers and determined that the barriers were
installed and maintained as described in the
Plan.
3.6.2.12 Security System Power Supply
The Team reviewed the security system power sup-
,
ply system and determined that it was in accord-
t
ance with Plan requirements. The Team noted that
as a result of the approval of a recant Plan
!
revision, improvements for protecting the secur-
ity power supply are wnderway, with wo-k expected
i
to be completed by September 28, 1933.
!
I
>
f
i
. _ _ _ _ _
- . _ _ _ _ _ - _ _ _ - _ _ _ - _ _ _ _ _ _
_ _ _ _ _ _ _ -__
._ _
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _
,
.
80
3.6.2.13 Lighting
The Team observed lighting within the protected
area. All areas were lighted in accordance with
commitments in the Plan.
Progress on upgrading
the lighting is addressed in Section
3.6.2.1.
3.6.2.14 Compensatory Measures
,
The Team reviewed the licensee's compensatory
measures and determined that their use to be con-
i
sistent with the commitments in the Plan. As a
result of the security program upgrades addressed
in Section
3.6.2.1,
the need for compensatory
measures for degraded security equipment has been
dramatically reduced.
Further reductions in the
7
use of coripeasato 'v measures will occur as pro-
ject upgrades are t spleted.
!
3.6.2.15 Aasessment Aids
The Team reviewed the licensee's use of assess-
l
t
ment aids and Jetermined by observation that the
I
assessment aids are installed, functioning and
i
maintained as committed to in the Plan.
Progress
on upgrading the assessment aids is addressed in
Section 3.6.2.1.
3.6.2.16 Access Control - Personnel and Packages
The Team reviewed the access control procedures
for personnel and packages and determinti that
they are corisistent with commitments in the Plan.
This determination was made by observing person-
,
nel
access
processing
during
shift
changes,
visitor access processing, and by interviewing
l
security personnel about package access proced-
!
ures.
The status of upgrades in the access con-
(
trol points is addressed in Section
3.6.2.1.
'
[
'
.
3.6.2.17 Access Control - Vehicles
Tna Team reviewed vehicle access control proced-
ures and observed vehicle searches at the Main
i
Vehicle Gate.
It was d;t.>rmined that vehicle
[
searches were being conducted consistent with
i
commitments in the Plan.
I
i
I
I
i
i
!
t
-
-
-
- -
- - -
-
-
.
-
-
.
- -
-
-
-
-
-
,
.
81
3.6.2.18 Detection Aids - Protected Area
The Team observed penetration tests of approxi-
mately 25% of the licensee's intrusion detection
system on August 17, 1983. The remaining 75% was
not tested during this inspection; however, pre-
vious test records were reviewed and the records
indicated that the system was operating as de-
scribed in the Plan and implementing procedures.
3.6.2.19 Detection Aids - Vital Area
The Team observed the testing of intrusion detec-
tion aids in selected vital areas and determined
that they wer? installed and functioning as
committed to in the Plan.
3.6.2.20 Alarm Stations
The Team observed the operation of both the Cen-
l
tral Alarm Station (CAS) and the Secondary Alarm
l
Station (SAS) and found them to be in accordance
c
i
with Plan
commitments.
During
the
previous
inspection (50-293/88-16), a concern was identi-
fied that the licensee was diverting an alarm
station monitor f rom security duty to respond to
t
i
fire protection system and health physics alarms.
'
During
the
IAT
inspection,
the Team noted
improvements in that there is a marked decrease
in the number of nuisance alarms, as a result of
the removal of the fire door and health physics
doors from the security alarm system.
L
3.6.2.21 Communications
I
The Team observed tests of all communication
capabilities in both the CAS and the SAS.
The
Team also reviewed testing records for the vari-
ous means of communications available to security
force members and found them to be as committed
,
to in the Plan.
I
3.6.2 ;2 Training and Qualification - General Requirements
The Team reviewed the licensee's Training and
Qualification Plan and teplementing procedures
and determined that they we re be'.ng implemented
i
as committed to in the Plan,
t
t
,
_ _ _ _ _ _ _ - _ _ _ _ _ _ _
_.
.
o
82
3.6.2.23 Safeguards Contingency Plan Implementation Review
The Team reviewed the licensee's Contingency Plan
and implementing procedures and determined that
all exercises were being performed by the secur-
ity organization as committed to in the Plan.
3.6.2.24 Protection of Safeguards Information
The Team reviewed the protection and handling
procedures for Safeguards Information (SGI) and
determined that the licensee had completed an
inspection of each office onsite that handled and
stored SGI.
The inspection result, indicated
that the SGI assigned to each of fice was accoun-
ted for and was being stored in accordance with
established licensee procedures.
3.6.3
Conclusions
A comprehensive review of the licensee's security program
determined that the licensee has established and is imple-
menting a significantly improved seeJrity program over that
which existed when the station was shutdown in April 1986.
Upgrades to the security program include a greatly expanded
proprietary security organization, major installation of
state-of-the-art equipment, improved security maintenance
support, and upgrades to plans and procedures,
i
l
i
. _ _ _ _ _ _ _ _
- . _ _ _ _ _ _ _ _ _ _
__
_ _ _ _
.
.
83
3.7 Training
3.7.1
Scope of Review
The Team assessed the scope, quality, and effectiveness of
the licensee's training programs.
Included in this review
were the licensed and non-licensed operator training pro-
grams and the programs for technical and general training
of the plant staff.
3.7.2
Observations and Findings
3.7.2.1
Operations Training
Operations Training Programs are outlined in PNPS
Nuclear Training Manual, T-001, Part 3, and have
received
accreditation.
The Operations
Training Programs include initial and requalifi-
cation training for licensed operators, initial
and continuing training for non-licensed opera-
tors, Shif t Technical Advisor (STA) training, and
SRO certification training.
The Team reviewed
these programs and discussed various aspects of
the programs with members of the licensee's
training and operation's staff.
The Team re-
viewed eight Operator and Senior Reactor Operator
training records to verify compliance with Sec-
tion 3.5.5 of the Training Manual.
To evaluate
l
the effectiveness of the training programs, the
l
Team observed classroom and simulator training;
interviewed licensed operators and senior opera-
tors, non-licensed operators and STAS; reviewed
several training evaluation and feedback forms
from classroom and simulator training conducted
during the current requalification cycle; and
observed ongoing operations in the plant.
Overall, the Team determined that the Operations
Training Programs are adequate and effective.
Classroom and simulator training observed ap-
.
peared to be effective.
Instructor preparation
was good and the lesson plan content was com-
plete.
During cbservations of classroom training
for PDC 88-07 involving the degraded voltage
modification, the Team noted that the depth of
knowledge being presented was adeqaste and stu-
dant participation was encouraged. After obser-
ving the conduct of the annual simulator opera-
t.ng exam, the Team noted improved coraunications
_-
_ _ _ _ _ _
._
_
_ _ _ _
__
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ - _
_ _ _ .
.
.
84
s
between meners d the operating crew.
In addi-
tion, the Hm noted the simulator examination
was also bei. , observed by licensee upper manage-
ment.
Discussions with training and operations
personnel confirmed that strong upper tranagement
attention and support for all aspects of the
Itcensed training programs is evident.
Inter-
views with licensed operators indicated that
overall they a re very satisfied thi t training
programs are well-suited to their needs, and that
the programs are responsive to their feedback.
Operators indicated that the training program has
greatly improved over the past year with the
incorporation of simulator training
into the
requalification program.
Discussions with Operations Training staff 4.a-
cated sufficient staffing to conduct training
programs.
Thirteen instructors are
currently
receiving Senior Reactor Operator (SRO) certif t-
cation training and are expected to be fully cer-
tified by the end of 1988
The use of experi-
enced PNPS instructors instead of contractors for
the operations training programs should enhance
the quality of the licensee's programs as well as
contribute to the depth of in-house operational
expertise.
Recent additions to the licensed requalification
program include the incorporation of Emergency
Operating Procedure (EOP) proficiency training.
This includes at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> devoted to E0P
review ir, the classroom and/or simulator during
each 32-hour segment of the program. (Each oper-
ator normally receives one segment of requalifi-
cation training every five weeks. )
Also, the
exam structure at the end of each session has
been nodified to include written and simulator
operating exams, which will aid the training
staff in determining the effectiveness of the
programs on a more frequent basis.
In addition,
the training staf f appears to carefully track
attendance in req;alification training to assure
that everyone required to attend is trained in
each module
of
the
requalification
program.
,.
- _ - _ _ _ _ _
_.
,
e
85
4
The operation's training staff appears to have a
very effective working relationship with the
operations department.
They meet to discuss
training needs on a frequent caris.
Through
these meetings, the training department anpears
able to sufficiently track and schedule the
licensed training either required or requested to
be completed prior to restart.
In addition, the
operation's department often provided support
l
during simulator examinations.
'
The Team reviewed the licensee's special training
,
program for the sixteen licensed operators (14
RO's and 2 SRO's) who currently hold NRC licenses
which are limited pending on-watch training dur-
ing the Power Ascension Program. The Team dis-
cussed various aspects of the program with mem-
,
bees of the licensee's training and rperations
'
staff.
The Team noted that the licensee has
established a structured and supervised program
to assure completion of NRC requirements to allow
removal of the individuals' license limitations.
.
Following a discussion with the Team regarding
plans for ensuring that each operator performs a
sufficient number of reactivity manipulations,
the licensee representative stated that en at-
tachment to the special program would be added to
further clarify what constitutes an acceptable
manipulation.
The Team observed
the
operations department
staff on four days of consecutive shift rotation.
These observations verified the overall effec-
'
tiveness
of training.
For example, on-shift
.
'
communications, an area of emphasis in simulator
training, was formal and effective.
However,
during a walk-through with an equipment operator
(non-licensed) of E0P Satellite Procedure 5.3.26,
t
the Team noted several discrepancies in the pro-
,
cedurt.
It also noted that the E0 and an SRO
-
misunderstood a step in the procedure.
Upon
l
investigation of these problems, the licensee
determined that a decision to train only the E0's
and not the licensed operators on the field por-
tion of the ratellite procedures contributed to
the misunderstanding. These issues are discussed
in detail in Section 3.2.4
!
!
!
t
,
!
I
.
.
--
-
-
i
w
.
t
1
86
,
Additional Team followup of the problems found
during the above-mentioned procedure walk-through
identified a weakness in the licensee's method of
determining the need far additional training on
new procedures and procedure changes. The licen-
see's current method incorporates review of ORC
meeting minutes to determine newly approved pro-
cedures or procedure changes requiring training.
However, a delay of 30 to 45 days is not unusual
between the meeting and the distribution of for-
[
mal minutu.
Tor example, Procedure 5.3.26 had
been revised since equipment operator training
was conducted in March and April 1988. The ORC
meeting minutes which addressed this procedure
change had not been received by the training
department as of August M. 1938, 42 days af ter
the ORC meeting on July 6,1988.
The Team discussed the issue with a licensee
training department representative who stated
that the department recognized this concern and
was preparing to implement, in October 1988, a
more timely method for cetermining the needed
training.
During the inspection, the licensee committed to
accelerate implementation cf certain features of
the improved program, such that the training
,
department will become aware of procedure changes
l
within soproximately one day following the ORC
l
meeting.
This will allow the training staff the
opportunity to review the precedure changes end
determine the need for training prior to issuance
of the approved procedure.
If the
training
i
]
department determines that training is required
prior to issuance of the procedure, the depart-
i
ment will have the ability to delay the proced-
i
ure issuance. The licensee representative stated
that .o inta.ed as k iri.tiwtion detailing this
,
process was being written and would be approved
'
by ORC within about a week.
In additica, the
l
training staff will revis, their backlog of ORC
i
recting minutes to determ ne which procedure
,
changes have not been addressed and will take
j
appropriate action. These actions planned by the
'
licensee appeared very responsive to the Team's
concerns.
I
.
l
,
l
i
.
.
.
. .
.
. .
. .
.
.
. -
.
.
.
. .
.
1,
87
3.7.2.2
Technical and General Training
Nuclear Training Manual, T-001, Parts 4 and 5,
outline the licensee's technical and general
training programs.
Included are training 3ro-
grams in maintenance, health physics, chemistry,
fire brigade, emergency plan, supervision, and
technical training for staf f and managers,
ihe
Team reviewed these programs and discussed var-
ious aspects of them with members of the licen-
see's training, technical, and supervisory staff.
To evaluate the ef fectiveness of the training
1
programs, the Team observed classroom instruc-
tion;
interviewed
radiological
controls
and
radiological chemistry (radchem) technicians, QA
engineers and first-line supervision; reviewed
classroom training evaluation and feedback forms;
and observed ongoing work ir. the plant.
Overall, the licensee's training programs were
found to be adequate.
Classroom training ob-
served appeared to be effective and student
participation was strongly encouraged.
In-house
staffing for those training programs appeared
more than sufficient.
The following relatively
new training programs are indicative of licensee
!
initiatives to develop employee skills:
apprentice programs for maintenance, health
--
physics,
and rad chem technicians;
and,
technical
training
for
newly
assigned
--
supervisors.
Additional
training
programs
currently being
developed in industrial safety and safety aware-
ness, along with the licensee's CPR program, show
the licensee's positive attitude in those areas.
The Team's observations of work in the plant dur-
.
ing this inspection verified the averall training
effectiveness. However, inadequacies in mainten-
ance post-work testing appeared to be the result
of lack of training for the maintenance planning
group and first-line supervisors on the post-work
testing portion of the new maintenance program
(See Section 3.3.2.6).
i
. , _
s e
_
.
.
83
3.7.3
Conclusions
The 11:ensee's training programs appear to be very good.
Team findings in all functional areas indicated overall
'
effectiveness of the training implemented.
Examples of
areas where training may have needed to be conducted sooner
include E0P satellite procedures and the post-work testing
program.
A weakness was identified in the licensee's
method of determining training needed for new procedures
and procedure changes.
The licensee appears to have made a strong commitment in
the area of licensed operator training, as exemplified by
increased staffing, simulator use in requalification train-
ing, strong interface between training and operations man-
agement, and increased attention and support from upper
management.
In addition, the creation of new programs for
supervisors and apprentices reflects an effort by the
licensee
to effectively
promote
employee development.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
.
.
89
3.8 Fire Protection
3.8.1
Scope of Review
The Team's evaluation of the fire protection program
focused on the maintenance of fire protection equipment,
the reliance on compensatory measures for degraded equip-
ment, and the performance of personnel on the fire brigade
and standing fire watches.
3.8.2
Observations and Findings
.
Licensee senior management established a station goal of
reducing the number of open fire protection corrective
maintenance requests (MR's) to 40 from a high of 300. This
,.
goal was reached in June 1988.
This reduction is indica-
tive of the overall improvement of the material condition
of fire protection equipment and systems.
The number of
MR's began climbing two weeks before the IAT inspection,
and reached 63 during the second week of this inspection.
The increase was mainly for low priority MR's.
l
Fire protection MR's are tracked as a stction performance
r
indicator and this increasing trend received prompt senior
i
management attention.
Tha licensee is currently contract-
ing to bring in additional fire protection maintenance sup-
port by the end of August 1933.
The fire protectinn man-
ager meets daily with operations, maintenance and planning
,
sections to schedule MR's and develop the station's work
,
plan.
The Team concluded that the licensee is giving
proper management Attention to itre protection MR's.
l
There are over 5,000 fire barrier penetration seals at
PNPS.
The licensee's tagging system has been effective in
identifying these penetrations, with no untagged penetra-
i
tions or degraded penetration seals observed by the Team.
The number of fire watch postings has been reduced from 145
a year ago to 45 prior to this inspection.
Fifteen of
these remaining postings will be eliminated by changes to
the fire protection program which are currently being
i
reviewed by NRC.
Another twelve will be eliminated when
the licensee completes Engineering Services Request (ESR)
'88-339, "Alarm delays on non-vital CAS alarms."
This ESR
will provide a means to electronically monitor fire doors
,
without undue distractian of security personnel from their
'
'
primary function. The remaining 18 fire watch postings are
due to degraded (quipment for which repairs are currently
l
!
being planned.
I
l
l
l
_ _ _ _ _ _ _ _ _ _ _ _
__
_
.
.
t.
90
Because TS's allow one individual to rove and cover more
than one fire watch posting, the number of people on shif t
committed to fire watch activities is substantially lower
than 45.
Two personnel per shift are assigned to cover
these fire watchos. In discussions with the Team, the fire
watches appeared knowledgeable about their duties.
The
Team reviewed several fire watch postings in the plant and
identified no concerns.
All fire watch rounds were com-
pleted on schedule.
The Team observed the on-shif t fire brigade respond to an
unannounced fire drill. The drill scenario was a simulated
main transformer fire with a concurrent failure of the
deluge system.
The brigade leader developed a successful
fire fighting strategy.
The brigade members responded
promptly in full fire fighting gear.
Communications be-
,
tween the brigade and the control room appeared to be ade-
q t.a t e . The fire brigade's first-line supervisors observed
the deill on their own initiative.
The fire protection
training instructor was also found to be knowledgeable and
ent.husiastic about the training program.
"
3.8.3
Conclusions
Effective management by the fire protection manager and
support by senior management are shown by the attention
given to the material condition of fire protection equip-
ment and reduced reliance on compensatory measures for
degraded equipment. Completion of licensing actions and an
ESR will further reduce the number of fire watch postings.
There is good identification and control of fire barriers.
Personnel assigned fire watch and fire brigade duties are
knowledgeable about their duties and perform them properly.
The
f' re protection division is well
staffed to meet
program needs.
,
i
i
)
-
_ _ _ _ _ _ _ _ _
r
,
.
91
3.9 Engineering Support
3.9.1
Scope of Review
NRC found licensee engineering support to be strong in the
past two SALP reports.
Because of this history of good
i
performance, engineering support was not selected as a
specific area of focus for this inspection.
Instead,
observations relative to engineering support were made by
the Team while it inspected the other functional areas.
3.9.2
Observations and Findings
The Team found that engineering support to the facility is
generally very effective.
In particular,
the
Systems
Engineering Division functions well to meet plant needs.
Also, engineering support to maintenance has improved and
is eahanced by the improved maintenance work process and
the effective performance of the maintenance engineers.
The Team noted that a number of technical issues, including
some NRC open items, as well as licensee-identified items,
require NED resolution before plant restart.
They are
being tracked and pursued for resolution by NED.
During tours of the control room, the Team noted the mini-
mal use of certain human engineering features, such as
color-codes, meter "banding"
(e.g.,
marking of normal,
alert, and fail positions on meter and gauge faces), and
system lineup memory aids.
Based on discussions with NED
personnel, the Team determined that the licensee performed
a detailed control room design review (DCRDR) and received
comments on it from the NRC Office of Nuclear Reactor
Regulation.
A
supplemental
licensee D0RDR
report
is
required four months af ter the end of the current outage.
Currently, the licensee's DCRDR project has identified
about 140 proposed human engineering improvements which are
being evaluated and prioritized.
A few were incorporated
into design changes this outage.
The Team noted that some
,
of the remaining improvements were relatively simple, from
an engineering perspective, but could significantly enhance
control room human factors.
The Team asked whether'imple-
mentation of some of these items could be accelerated rela-
tive to the other, more complex items which may require
more detailed engineering and a plant outage to install.
.
l
-
-
.
___
_--
a
. _ _ _ _ _ _ _ _ _ . _ _ _ - _
.
o
92
The
licensee fndicated that these simple improvements,
categorized by the licensee as "Paint-Label-Tape," are
included in the current 1989 budget.
The licensee also
committed to evaluate control room human factors during the
Power Ascension Program and to include an update regarding
the schedule and scope of these "Paint-Label-Tape" items in
their report to NRC at the completion of the Power Ascen-
sfon Program.
The licensee was very responsive on this
issue.
The Team noted that (1) licensee personnel have
performed well in the simulator under NRC observation, and
(2) there has not been any pattern of performance problems
traceable to control room human factors.
Thus, the T:am
cancluded that the licensee's approach to this issue is
acceptable.
The Team reviewed the licensee's program for the control of
transient materials.
This review included the licensee's
methods for identifying, tracking and removing non perman-
ent equipment such as tools, gas bottles, and scaffolding
located in plant treas where safety-related equipment is
housed. The licensee currently assigns responsibility in
this area to the Systems Engineering Group (SEG). Station
Instruction SI-SG.1010 "Systems Group Systems Walkdown and
Area Inspection Guidelines," details the licensee's program
for controlling transient materials. Materials so identi-
fied during weekly walkdowns by system engineers are docu-
mented and are either removed or their presence justified
in writing.
If the material is allowed to remain in the
process building, a seismic missile hazard analysis is per-
formed under Station Instruction SI-SG.1015
"Dotential
Seismic Missile Hazard," and appropriate measures are
implemented to ensure that the materials are properly
secured.
The licensee is compiling a data base which
identifies transient eaterials which must be removed prior
to startup.
The program appears to be comprehensive and
,
adequate.
l
During plant tours, the Team questioned the licensee con-
cerning the installation of splash shields and personnel
barriers in the areas of safety-related instrumentation.
.
Specifically, the Team questioned the seismic response nf
ti,e structures and the effect they may have on safety-
related structures.
l
l
l
I
_.
-..
- --
--__,, -
-
_ _-_
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
93
The fire water spray shield was installed during the cur-
rent outage.
This plant design change was processed under
current
licensee
procedures
which
require
a
seismic
response analysis prior to modification approval.
nel barriers installed during the mid-1970's recently had
seismic analyses performed on their current configurations.
These analyses found them satisfactory.
Based on this information and on a review of licensee docu-
reentation, the Team had no further questions.
3.9.3
Conclusions
'the Team concluded that engineering support continues to be
effective and identified no weaknesses.
The Itcensee has
committed to evaluate potential near-term improverrents in
control
room human engineering during power ascension
testing.
l
l
i
h
4
- - , --
-
, . , , - _ , - , - . , , _ , . _ _ , , _ , _ _ . , _ . - _ - . , , _
,,..,,._,------_,-,,_n
e-
.,
, -- ,
y
g. :,g
, _ _ _ - - - - - - - _ - - _ - -
_
--
. - - - - - - - - -
-- _ ---- ------- --- -- - - . _ -
- - - _ - - _ --
- - - ---- --- ------
o
.
94
3.10 Safety AssessmentfQuality Verj,fication
3.10.1
Scope of Review
The objective of this irspection was to evaluate the ef fec-
i
tivenass of the licensee's t
assessment programs.
The
inspection focused on determining whether these programs
contribute to the prevention of problems by stonitoring and
evaluating plant performance, providing assessments and
findings, and communicating and following up en corrective
action recommendations.
The inspection consisted of a
documentation review, personnel interviews, and observa-
tions of meeting and work.
3.10.2
Nuclear Salety Review and Audit Committee
The Nuclear Safety Review and Audit Committee (NSRAC) is an
independent body responsible for performing senior-manage-
ment-directed
reviews
of activities
affecting
nuclear
safety. The NSRAC reports to the Senior Vfce President
-
Nu: lear (SVP-N).
Membership on the committee is composed
of senior
licensee management
personnel
augmented by
consultants.
The Team reviewed the NSRAC procedures manual, Technical Specification 6.5.B
meeting minutes, audit reports, and
associated NSRAC reports and correspondence. The Team also
attended
a
full
NSRAC
trueting
at
the
station
on
August 2, 1988.
A review of the committee meeting minutes for the period
between January 1987 and June 1988 verified that Technical
Specification requirements have been met with respect to
the composition, duties, meeting frequencies, and responsi-
bilities of the committee.
The composition and charter of
the committee was significantly revised in February 1938.
The selection process for members was designed to assure a
broad-based, independent review of facility activities and
to minimize the potential for cost and schedule pressures
to influence the committee's reviews and findings.
The
current committee is made up of ten eenbers appointed by
the SVP-N
Of the ten members, five are consultants, in-
cluding the Committee Chairman.
Only two members of the
committee hold line responsibility for operation of the
plant. Only one member, also a consultant, belonged a year
ago. To enhance the perspective of the new members, the
licensee implemented an annual training program. The Team
was provided with a t strix indicating the ev.cerience of
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ .
O'
0
,
,
95
i
current committce members relative to Technical Specifica-
tion requirements and verified the committee collectively
possesses a broad based level of experience and competence.
The committee charter, as detailed in NSRAC Procedure
101-1, also does not. allow the use of alternate members,
although these are allowed by the Technical Specifications.
Af ter a review of recent membership changes, and discuss-
ions with the NSRAC Ceordinator, the Team r ified that the
collective competence of the committee monborship has been
maintained as changes were made.
NSRAC currently conducts meetings approximately once a
~
month.
Since the beginning of 1988, seven meetings have
been conducted, six of which were held at the site.
This
is significantly more than the once per-six-months minimum
required by the Technical Specifications. Three additional
meetings are scheduled for 1988.
In addition, individual
subcommittees may hold additional meetings at the site.
NSRAC also intends to meet at the site in September with
several key members of station management to review restart
preparations and plans to provide its own independent
recommendations for restart readiness.
NSRAC uses subcommittees ef fectively to review specific
areas of interest. Currently, six subcommittees are estab-
lished:
(1) safety evaluations;
(2) operations /mainten-
ance; (3) training / security / fire protection; (4) radiation
control / chemistry / emergency preparedness; (5) quality over-
view; and, (6) engineering / technical. Each subcommittee is
chaired by a NSRAC member, and is composed of additional
personnel appointed by the committee.
The subcommittees
provide reports to the full committee during their ;ched-
uled meetings.
The subcommittees are especially usef ul in
performing documentation review to allow more time for open
discussions at the meetings.
A stronger NSRAC involvement in station accivities is evi-
dent not only in the recent site meetings and effective use
of subcommittees, but also in scheduled site tours and
audit participation.
The NSRAC has established a schedule
for individual committee members to perform station tours
and report the results to the full committee.
NSRAC has
also designated
individual
members
to participate in
selected QA audits throughout the year.
The Team reviewed selected audits conducted under the
cognizance of NSRAC, which are required by Technical
Specifications. The audits reviemed were thorough, timely,
and the noted deficiencies have been corrected or are being
tracked. The audit reports reviewed included a third party
assessment of the adequacy of the QA program, and QA audits
.
o
o
i
96
of
Technical
Specifications,
administrative
controls,
operations, chemistry, radiation protection, and inservice
testing.
In addition, special audits were recently con-
ducted concerning shutdown from outside the control room,
the salt service water system, and NSRAC activities.
The current committee has an effective formal tracking
system for all "concerns" forwarded to management and com-
'
mittee
followup
items.
The
"concerns"
reviewed were
clearly transmitted to the SVP-N.
However, review of
,
recent meeting minutes by NRC revealed that a number of
"recommendations" had been forwarded to the SVP-N, but a
formal response had not been received.
The committee also
di.d not formally track resolution of these recommendations.
Further investigation by the NSRAC Coordinator determined
that although the items had not been tracked, the specific
recommendations had been implemented, or were incorporated
into another corrective action process.
,
Ouring NSRAC Meeting 88-04, conducted on May 24, 1983, the
Operations and Maintenance Subcommittee presented a report
on the conduct of the Operations Review Committee (ORC).
,
NSRAC raised concerns over whether the ORC was fully meet-
'
ing the intent of its duties required in the Technical
Specifications. The report identified four specific find-
ings of deficiency. They included:
'
Inadequate method of reviewing changes to safety-
'
-
related procedures;
i
Lack of ORC prepared reports resulting from ORC inves-
-
tigation of a Technical Specifications violations;
,
Lack of specific review and reports of facility oper-
I
-
ations by ORC; and,
!
Lack of formality in the conduct of ORC meetings.
-
Af ter the discussion, NSRAC concurred that the ORC perform-
ance issues should be formally raised as a concern to the
,
SVP-N. Tha NSRAC concern (88-04-01) was transmitted to the
SVP-N on May 27,1938.
The concern stated that NSRAC's
'
.
overall assessment was that ORC's conduct and administra-
tion needed substantial improvement.
Specifically, the
!
concern stated that the established process did not appear
j
to foster adequate depth and discipline for substantive
indepandent reviews. In addition, NSRAC noted that of the
[
40 meetings cenducted in 1933 prior to the review, neither
l
the Station Director nor the Plant Manager had attended,
l
based on its review of the meeting minutes.
'
I
!
I
!
(
- -
- -
_ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _
,
97
The NSRAC concern was responded to on June 22, 1988.
In
response, the Station Director initiated revisions to the
ORC Charter and Procedure 1.3.4, "Procedures," to accur-
ately describe the specific methods by which ORC met the
procedure and operations review requirements.
In addition,
the
Station
Director
attended
an
ORC
meeting
on
June 22, 1988, and is considering additional initiatives to
improve the conduct and administration of ORC activities.
N5RAC closed the concern at the August 2, 1988 meeting, but
initiated a followup item to continue to monitor ORC per-
formance.
In addition, NSRAC members were encouraged to
attend ORC meetings as observers. NRC's review of ORC per-
formance 'Jentified similar deficiencies and concluded that
additior.1 actions to strengthen some ORC functions were
warranted (See Section 3.10.3).
Based on meeting attendance and review of recent meeting
minutes, the Team noted that the NSRAC reviews have been
thorough and focused on improving performance in areas
important to safety. During the August 2, 1988 NSRAC meet-
ing, the Team noted that the discussions were frank and
open, with the reviews concentrated on recurring and emerg-
ing issues.
The areas of emphasis have included 50.59
reviews, ORC performance, corrective action programs, pro-
cedure adequacy, and management depth.
Due to the limited number of "concerns" issued by NSRAC
since revision of the committee in February 1988, the Team
could not reach a conclusion on the responsiveness of the
station organization to NSRAC.
It appears at least in one
case pertaining to ORC performance, that the response was
not comprehensive.
However, all other "concerns" reviewed
were responded to adequately.
3.10.3
Operations Review Committee
The function, composition, and responsibilities of the
i
Operations Review Committee (ORC) are described in PNPS
L
Technical Specification 6.5.A.
In addition, PNPS Procedure
1.2.1, "Operations Review Committee," describes in greater
detail the authority and responsibility of the ORC at the
Pilgrim Station.
For this inspection, the Team reviewed
the
minutes
of
ORC
meetir,g s
88-40
through
88-63
(April 1,1988 through July 5,1988) and observed the con-
duct of three regularly scheduled and two special ORC meet-
ings (ORC Meetings 80-80, 81, 82, 83 and 86). In addi+1on,
the Team interviewed various ORC members and alternates.
_ _ _ _ _ _ _ _ _ _ _ _ _
. _ _ _ _ _ _ _
a
.
93
The inspection focused on whether ORC operations satisfied
current Technical Specification requirenents; whether the
ORC was meeting its responsibilities identified in PNPS
Procedure
1.2.1,
and whether the CRC was responsive to
recommendations for improvements icentified during NSRAC
and QA audits of its operations.
3.10.3.1 Compliance with Technical Specifications and
Procedures
'
By reviewing existing documentation, and through
direct observation of ORC meetings, the Team has
determined
that
the
Technical
Specification
requirements for the ORC composition, quorum,
meeting frequency, authority, and records are
being satisfied. During the period reviewed, the
Team noted that the ORC reviewed plant proced-
ure changes, plant design changes (PDCs), Field
Revision Notices
(FRNs),
and
Licensea
Event
Reports (LERs), as well as proposed revisions to
the security plan, to the inservice inspection
program, to the emergency plan and to fire pro-
tection program implementing procedures. The ORC
members and alternates are appointed by memur-
andum from the Station Director and cannot serve
on the committee until they have successfully
completed the station ORC training course.
There
is also a required reading review program used by
the Training Department as a retraining program
for ORC members and alternates.
The Team re-
viewed the training course material and deter-
mined that it bad an appropriate emphasis on
assuring safe operation as well as on regulatory
requirements.
The ORC at Pilgrim Station has been reeting
regularly every Wednesday and has a scheduled
"special" meeting every Friday on an as-needed
basis.
The ORC met an average of about twice a
week, which is well above Technical Specification
,
requirements.
While there was evidence in the minutes of dis-
cussions about LERs, PDCs or FRNs, the prepond-
'
erence of the ninutes described changes to pro-
cedures.
The Team saw no reference of ORC
reviews of Failure and Malfunction Reports.
The
ORC has a system for following issues identified
during
discussions
which
requires
a
formal
response to the ORC and a review of the response
by ihe ORC to assure that the response resolved
'
the initial concerns.
-_.
O
99
The Team reviewed the closeout process for ORC
followup items and determined that, in one case,
an item (88-58-01) may have been clo'.ed prema-
turely. During a discussien among the Team, the
ORC Chairman, the Design Section Manager, and the
Construction Division Manager, the ORC Chairman
agreed that the item should be reopened for addi-
tional review.
During ORC Meeting 88-82, the
item was reopened.
By observing the ORC, the Team concluded that the
committee members and alternates are concerned
with assuring the safe operation of the facility.
Discussions focused on the impact of items on
safety systems, as well as whether the items
being discussed met regulatory requirements or
constituted unreviewed safety questions.
The
Station Director also attended one of the regu-
larly scheduled ORC meetings during the inspec-
tion period.
During its review, the Team identified two weak-
.
nesses in the operation of the ORC. They are the
Technical Specification (TS) review of plant
operations (T.S. 6.5 A.6.e) and the TS require-
ment to investigate violations and prepare i
report covering the evaluation and recommenda-
tions to prevent a recurrence (T.S. 6.5.A.6.1).
TS 6.5. A.6 e states that the ORC ds responsible
for the review of facility operations to detect
po te;.',i a l
safety hazards while
TS 6.5.A.6.1
states that the ORC is responsible for investiga-
ting all TS violations and for preparing a report
covering the evaluation and recommendations to
prevent a recurrence.
The Team noted that ORC routinely uses the review
of LERs and Failure and Malfunction Reports
(F&MRs) to satisfy the TS required review of
plant operations and TS violations.
The Team
also noted that the ORC has appointed the Compli-
ance Division as a subcommittee to the ORC and
assigned it the responsibility et presenting
selected Failure and Malfunction Reports as weil
as the preparation of all LERs, including any
, _ _ _ _ _
O
O
l
100
involving TS violations. Copies of all LERs are
provided to the ORC as a means of satisfying
the TS requirements.
Further, PNPS Procedure
1.2.1 permits the ORC Chairman to set the time-
liness of subcommittee reports to the full ORC.
While the use of subcommittees te support ORC
!
activities is acceptable, the Team believes that
the method used by ORC in fulfilling its respon-
sib 111 ties as defined by TS 6.5.A.6.e and i needs
improvement.
In
particular,
the
Compliance
-
Division has been issuing all LERs, including
those discussing TS violations, prior to any ORC
review of the product prepared. A review of 10
LERs disclosed that ORC review of the LER occurs
usually a week to two weeks after the LER was
formally sent to the NRC. While this may satisfy
'
the timeliness requirements of PNPS Procedure
i
1. 2.1, i t does not appear that the corrective
l
actions proposed to prevent recurrence receives
the full benefit of a timely multi-disciplinary
review, as is intended by the composition and
responsibilities of the ORC.
The formal release
!
of the LER involving a TS violation by the ORC
'
subcommittee without a formal review by the com-
'
plete ORC is a weakness in meeting the require-
!
ments of TS 6.5.A.6.1.
j
'
During a review of F&MRs, which had not yet been
reviewed by ORC, the Team noted that F&MR 86-266,
'
which discussed a TS violation, had not yet been
reviewed by ORC.
f
In this case, the violation was against an admin-
istrative requirement in TS Section 6.8, and was
I
not reportable as an LER.
Therefore, the F&MR
did not result in an LER or a special report.
I
The event occurred in September 1986, and no
reports have yet been
submitted
to ORC as
required by the TS. The licensee stated that the
F&MR was still open punding completion of the
remaining corrective action, and that then a
report would be issued.
Both of these findings indicate that the ORC is
not actively participating in the timely review
of plant orerations and does not appear to pro-
vide reaningful input into the process.
____
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
.
O
O
101
3.10.3.2 Responsiveness to /udit Recommendations
The Team reviewed both quality assurance (QA)
audit
findings
and HSRAC
recommendations
to
determine ORC responsiveness to recommendations
for improvements to its operations.
In QA Audit
Report
87-37,
listed
two
recommendations
accepted by the ORC.
PNPS Procedure 1.2.1 was
reviewed and the Team determined that PNPS Pro-
cedure
1.2.1,
Revision 21, contained the QA
recommendations.
The ORC was also audited by QA
i rem May 22 through June 22, 1988.
The audit
generated
one
recommendation
concerning
the
cross-referencing of ORC meetings with document
references.
Based upon discussions between the
QA auditor and the Team, ORC has also accepted
this recommendation.
In May 1988, the ORC received a list of four
concerns from NSRAC based upon an audit review of
the ORC.
While the nature of the specific con-
cerns are discussed in detail in Section 3.10.3
above, they are summarized here.
Specifically,
the NSRAC expressed concerns about the following
areas:
(1) the ORC review of changes to safety-
related procedures, (2) ORC investigation of TS
violations, (3) ORC review of facility opera-
tfons, and (4) conduct of ORC meetings.
The concerns related to the ORC's investigation
of TS violations and its review of plant opera-
tions are paralleled by the Team's findings dis-
cussed in Section 3.10.3.1 above.
The NSRAC concern with ORC procedure reviews is
being evaluated for long-term improvements but no
definitive action is currently planned by the
licensee. As for NSRAC concern #4, the meetings
observed by the Team, were conducted in a manner
permitting formal and informal discussions of
specific issues.
A meeting agenda for regular
ORC meetings was prepared and followed. The Team
concluded
that
the
meetings
were
conducted
acceptably.
Based on the above, the Team has determined that,
in general, the ORC has been receptive to recom-
nendations for improvement.
However, the fact
that the NSRAC concerns remain unresolved sug-
gests that the ORC may have difficulty addressing
more complex recomendations.
_ __
O
O
,
102
The Team also observed that the quality of the
'
>
meeting minutes could be improved by providing
more discussion of the issues by the various ORC
members as opposed to providing abstracts of the
documents discussed.
Based upon a review of the ORC activities, the
,
Team determined that there are weaknesses in the
implementation of responsibilities assigned to
the DRC. In particular, the Team determined that
weaknesses exist in the review of plant opera-
tions and tne investigation of TS violations.
The Team has concluded that improvements in these
two specific areas would result in a more effec-
tive ORC.
In response to the Team's concerns,
the licensee agreed to take certain actions prior
to restart to strengthen the operational focus of
ORC.
These actions are:
(1) to review plant
,
incident critiques; (2) to review LER's prior to
[
their submittal to NRC; (3) to review F&MR's on a
-
regular basis; and, (4) to provide for a monthly
l
presentation and discussion of plant operations
'
as a specific agenda item. The Team found these
licensee commitments responsive to its concerns.
,
I
3.10.4
Quality Assurance Audit and Surveillance Programs
!
1
The Team reviewed selected QA audit and surveillance
i
reports, selecting specific findings, discrepancies, and
i
observations for followup of the licensee's corrective
t
action process. QA personnel, including the QA Department
!
(QAD) manager, and other station nanagers and engineers,
'
were interviewed regarding the audit and surveillance pro-
!
gram objectives and overall conclusions which can be drawn
l
f rom the audit and surveillance findings.
The Team also
i
reviewed the quarterly QA0 Trend Analysis report, and at-
tended several QA interface meetings.
Portions of the
Boston Edison Company Quality Assurance Manual (BEQAM) and
applicable station procedures were also reviewed.
4-
,
The technical content and quality of the issues raised in
'
the selected audit reports were excellent.
The conduct of
.
a performance-based radiological controls audit by outside
i
consultants was noteworthy.
Specificolly, the Team re-
-
viewed audits required under the cognizance of NSRAC, i r.
accordance with the TS, and found that they are being per-
formed as required.
The Team determined that all defici-
i
encies identified in the audits were either closed or ade-
quately tracked by a for al system,
j
t
I
n,-.-.
. - - -
. - - - - _ - _ . - - - - - - - , . - -
-
.- . _ .
,
.-
o
l
l
!
103
During the conduct of audits and surveillances, deficiency
'
reports (OR) are issued by QA for conditions contrary to
management policies and procedures, regJlatory require-
ments, or licensee commitments.
A DR which reports a
,
deficiency identified during a QA audi+, is issued at the
,
time of the audit exit interview.
The licensee has an
t
effective system of re, quiring a written response to the OR
within a specified period, dependent on its significance,
and for subsequent followup of corrective action. A system
also edists for granting extensions through an escalation
process to upper management.
QA prepares a monthly status report, including OR status,
which is forwarded to senior management for appropriate
,
actions.
Review of the most recent QA trend report indi-
cated a decline in the OR backlog, an increase in the num-
ber of OR's completed on time, and few extensions needed
.
L
for OR closeout. The number of deficiencies reported by QA
!
remained fairly constant.
These are all indicators that
,
licensee management attention to the corrective action
l
process has had a positive impact.
'
The licensee also effectively trends Immediate Corrective
'
Actiens (ICA), which are identified in audit and surveil-
,
lance reports. These report conditions which could lead to
a DR, but which are corrected prior to the end of the audit
,
or surveillance.
They also are tracked along with the
,
OR's.
The Team also found the tracking of recommendations
.
from the audits and surveillances to be effective.
l
Approximately 45 QA surveillance reports concerning obser-
i
vations of surveillance testing were reviewed. The reports
I
were well planned, well documented, and thorough.
Again,
,
the tracking and followup of identified deficiencies were
l
adequate. A minor concern of the Team involved QA followup
to identified procedural inadequacies during surveillances,
i
In ten of the surveillance activites reviewed by NRC,
!
technical piocedure deficiencies were identified by QA, but
I
since the technicians being observed halted the test and
(
pursued a procedure change, no deficiency reports were
l
issued. Furt.her review ' snd that the majority of the pro-
!
cedure deficiencies were identified prior to implementation
,
of new procedure validation program, and that QAD has an
i
open DR on the procedure validation process.
QA0 is con-
l
tinuing to monitor the process.
The Team had no further
cor.ce rn s .
l
!
I
,
b
,
-
r .- -
_ _ _ _ _ _
-
__
_____ _
, ,,
,
104
Two QA Interface meetings were attended during the inspec-
tion. The mee*.ing attendees include representatives from
QA, plant staff, and engineering.
They meet weekly to
review the status of various corrective action items,
including OR's,
Management Corrective Action
Requests
(MCARs) and Potenti:1 Conditions Adverse to Quality Reprts
(PCAQ's).
The meetings have improved communications among
the organizations and have contributed to the more timely
resolution of corrective action items.
3.10.5
Corrective Action Process and Programa
The Team reviewed the licensee's programs curr6ntly in
place to identify, follow, and correct safety-related prob-
lems. A newly formulated Corrective Action Program "Clear-
inghouse," and proposed revisions to corrective action pro-
cess procedures were also evaluated with respect to the
current objectives and planned initiatives to improve cor-
rective action program effectiveness.
Samples were chosen
from each of the programmatic areas where problem identift-
cation is routine and implementation of corrective measures
is required.
Each of these programs is discussed below.
The Tean interviewed licensee personnel responsible for
individual program management and implementation, as well
as the technical personnel accountable for problem dis-
position and corrective action adequacy.
For all of the areas evaluated, the Team sought to deter-
mine the effectiveness of the licensee's process for root
cause analysis of problems, investigation of problems and
causes for their generic applicability, and trending of
findings to prevent their recurrence. Selectad issues were
analyzed % understand the technical problems, check how
they were
programmatically hsndled,
and
to determine
whether the corrective measures were appropriate to the
specific cases.
The examples are cited in the following
subparagraphs not only to illustrate the scope of licensee
activities inspected, but also to support the conclusions
reached
regarding
the
corrective
action
program
effectiveness.
3.10.5.1
Failure and Malfunction Reports
The Failure and Malfunction Report (F&MR) is a
process by which failures, malfunctions, and
abnormal operating events are reported, evaluated
and corrected to preclude repetition.
The pro-
cess
is
described
in:
Nuclear
Organization
-
_. ___ __ __ ______
.
.
105
Procedure (NOP) 8305, the "Failure and Malfunc-
tion
Report Process;"
PNPS Procedure Number
i
1.3.24, "Failure and Malfunction Reports;" and
PNPS Work Instruction NS-3.2.12
"F&MR Trend
Analytis."
Team review of licensee precedures verified that
responsibilities are established for the F&MR
process; reports are prioritized by safety sig-
nificance; underlyin
root causes are evaluated;
reports are tracked for completion of corrective
,
action; and, trending for repctitive proble.ns is
performed.
A report may be initiated by any
licensee staff member for failures, malfunctions,
and abnormal operating events identified during
station operation.
The Nuclear Watch Engineer
ensures that adequate compensatoi,, measures are
implemented and the required notifications are
!
performed.
The Compliance Division Manager then
>
recomnends a lead group to perform the investiga-
'
'
tion and performs a reportability review.
The
appropriate department manager is responsible to
ensure that the identified deviations are prc-
perly resolved and that corrective actions are
planned and effectively iniplemented in a timely
manner. The department manager is a'.so responsi-
'
ble for the revi- and approval of the reporta-
bility, root caase analysis, corrective action
!
a
plans, disposition, and final closeout.
A root
cause analysis is performed for those F&MR's
i
determined to be significant. The term "signifi-
'
cant" applies to a condition adverse to quality
which merits further evaluation for cause and
>
requires management attention to preclude recur-
I
!
rence.
The nonsignificant deviations are evalu-
l
ated in a periodic trend analysis.
l
[
The Team identified several discrepancies in the
}
,
3
ddministration of the F&MR process.
Procedure
,
1.3.24
states
that
the
Complianc
Division
'
.
Manager is responsi51e to present F&MR's that are
!
designated significant or important to ORC. As
'
.
discussed in Section 3.10.2, the Team noted that
'
the ORC meeting minutes for the previous six
months did not record the review of any F&MR's.
.
Further Team review found that a backlog of over
j
'
,
t
,
i:
l
l
- - - - - - - - -
1
a
,
106
eristed, and that no F&MRs had been submitted to
ORC since February 3, 1988, except for those
associated with an LER.
Some of the F&MR's
involved events which occurred in 1986.
The
,
licensee stated this was caused by personnel
'
resource constraints.
The Team also found two
i
closed F&MR's which appeared to meet the criteria
established in Proendure 1.3.24 for being submit-
ted to ORC, but which had not been submitted
prior to closure.
F&MR's88-127 and 88-76 were
!
cot reviewed by ORC, but invefived recurring con-
ditions, which is a criterion for ORC review.
Ir. addition, many of the closed safety-related
!
F&MRs were denoted not safety-related by the
,
Watch Engineer during the initial review process.
'
This .nts-clat *fication; however, did not affect
,
the processing and evaluation of the associated
events for those F&MR's inspected.
The Team reviewed a listing of open and closed
F&MR's and evaluated a sampling of closed reports
to determine the completeness and effectiveness
r
of the corrective actions.
The total number of
F&MR's initiated has been increasing over the
!
last few years. The licensee has attributed this
increase to a heightened sensitivity of personnel
i
to critical self-assessment and to the identif f-
l
cation of potentially reportable or significant
events to management.
The total number of open
F&MR's has significantly decreased over the last
year.
l
The root cause analyses performed for the F&MR's
i
'
reviewed were found to be of excellent quality.
l
!
Each analysis included an event description,
probable cause, actions completed, recommended
actions, and safety significance.
The Systems
!
Engineering Group's impact on this important
process has been positive.
1
I
.
The Team revf ewed the latest F&MR Trend Analysis
e
Report, which covered the period July through
December 1987, anti the applicable procedures.
The Team noted that the station's Technical Sec-
l
tions did not specifically assign responsibility
for the report's proposed recommendations.
Fur-
i
ther review found that this program deficiency
i
had been previously identified by the licensee
!
and the NRC and that the licensee had initiated
j
corrective action. Specifically, a review of all
previous trend report rec w endations was per-
forced by the licensee to determine their status.
l
>
_ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
__ _
_
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
__________
- __
_
_
.
o
107
The review was completed in July 1983, and 74% of
the recommendations were corrected.
The remain-
ing items are currently being dispositioned by
the licensee to ensure effective long-term cor-
rective action.
In addition, the licensee has
revised the F&MR procedures to include use of the
Management Corrective Action Report (MCAR) as a
vehicle for the Technical Section to report and
correct negative trends identified in the re-
ports. The most recent trend report resulted in
the issuance of two MCAR's, which the Team
reviewed.
The Team also noted that the trend report focused
its discussions primarily on individual problems
rather than trend patterns and recurring fail-
ures. The Team observed that the Technical Sec-
tion would be more effective if it thoroughly
evaluated trends and patterns, since the indi-
vidual F&MR itself is adequate to evaluate iso-
lated problems.
In addition, the report did not
provide any detailed discussion of personnel
errors or procedural failures, although there
were a large number in the report.
3.10.5.2 Potential Conditions Adverse to Quality
As described by PNPS Nuclear Organization Proced-
ure (NOP) 83A9, "Management Corrective Action
Process," the potential conditions adverse to
-
quality (PCAQ) report can be used by any licensee
member tc document and report any actual or sus-
pected conditions adverse to quality not reported
by other report forms such as NCRs, ors, and
F&MRs.
In short, it is a process for anyone to
elevate a concern to management to assure that
the concern will be evaluated and
resolved.
As
implemented.
PCAQs
are written
from one
'
department to another or from one section to
another within a department.
For example, Oper-
ations (N00) could send a FCAQ to Engineering
(NED) asking for an evaluation of a specific
plant condition.
In each case, the originating
department is responsible for tracking each item
to resolution. According to NOP 83A9, a PCAQ is
not formally closed until the originating depart-
eent is satisfied with the proposed corrective
action
and
the
corrective
action
has
been
implemented.
<
O
103
The Team reviewed a listing of open and closed
PCAQ's and also reviewed a sampling of individual
PCAQ's to determine the completeness and effec-
tiveness
of
corrective
actions.
As
of
August 19, 1988,
there were about
250 PCAQs
awaiting resolution.
There is currently no cen-
tral tracking system for all PCAQs, although
licensee management has begun initiatives in that
area. In June 1988, the licensee began an effort
to reduce the number of open PCAQ's and to estab-
lish a central tracking system for PCAQ's with
the QAO. As part of this effort, each department
is reviewing unresolved PCAQ's to evaluate each
one's significance and its potential impact on
restart.
Based on discussions with respons!ble
managers, the Team learned that QA0 has completed
its review and concluded that r.one of the unre-
solved
PCAQ's
concern
equipment
operability
issues or are of a significance level that re-
quires action before restart.
N00 has not com-
pleted its evaluation but expects to be finished
within two weeks.
NED has been implementing a
routine review of each unresolved PCAQ and has
been maintaining a list of PCAQ's needed to be
resolved prior to restart.
The review of out-
standing PCAQ's is an iten on the restart check-
list maintained by the plai t.
Subsequent check-
list review by ORC also provides a decision point
in the process to assure that all necessary
evaluations have been completed.
Based on the above, the Team has concluded that
the licensee is assuring that each PCAQ is being
evaluated for its nuclear safety and equipment
operability
impact
relative
to
the
planned
restart of the plant and that all PCAQ'; noeded
for resolution before restart will be identified.
The ORC review of the PCAQ's on the restart
checklist will provide another check to assure
)
that resolution n' PCAQ's needed for restart has
I
occurred.
_ _ - - _ _ - _
.
.
109
i
The Team selected several closed PCAQ's to deter-
mine whether the proposed corrective action had
satisfied the originating department's concerns
and whether the corrective action was completed
as required by station procedures.
In general,
all identified corrective actions described on
the PCAQ's were completed; however, the docume -
tation of the completed activity was, in many
cases, limited and specific references were not
provided.
The Team stated that additional guid-
ance on the level of documentation to be provided
on the closecut portion of the PCAQ form could
enhance clarity and auditability of the closure
process. The Team also noted that the PCAQ sys-
J
tem can allow ambiguity of PCAQ status in cases
where a proposed action has been rejected by the
-
originating office.
For example, NED rejected
'
)
the response prepared by N00 to PCAQ NED-SS-087.
A review of the N00 log showed the issue resolved
(July 22, 1933), but further investigation with
parsens af fected indicated that the response was
being rewritten and further corrective action was
to be performed. The fornal closecut process and
I
status tracking for the PCAQ's needs improvement,
i
This finding parallels a similar finding of the
!
QA Department contained in QA0 88-609, dated
May 23, 1988.
l
3.10.5.3 Managenent Corrective Action Request
The GEQAM and NOP 83A9, "Management Corrective
Action Process," describe the purpose of the
Management Corrective Action Request (MCAR).
The
MCAR is a two part corrective action document
]
used to:
(1) perform a root cause analysis of
significant conditions adverse to quality and
'
develop preventive action plans; and (2) request
management to implement selected action plans to
prevent recurrence of a problem.
In lieu of a
,
Deficiency Report, an MCAR may be used to report
,.
and resolve deficiencies involving process or
i
1
policy issues which af fect more than one depart-
'
ment and for which management attention and
direction is required. An MCAR eay also be used
for tracking long-term corrective actions related
i
to nonconformance reports (NCRs) and PCAQ's nr
for identification of adverse trends identified
'
i
threugh trend analysis programs.
i
!
!
_.
_ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
110
l
QA0 is assigned adiinistrative control for the
MCAR process.
QAD logs the status, distributes
copies, reports on delinquent MCAR's, and per-
forms the closecut. QAD also reviews each MCAR
where the responsible department is different
j
from the issu.ing department to verify that the
assignment of
the
responsible department
is
-
appropriate.
The Team reviewed the current status of open
l
MCAR's and the administrative controls in place
to track and promptly resolve MCAR's. The latest
monthly status report, issued to the SVP-N on
August 1,1988, from the QA0 Manager listed 30
l
'
open MCAR's. This list included two 1985 MCAR's
and eight 1936 MCAR's. Approximately 40% of the
MCAR's initiated since 1984 remain open,
i
The licensee has previously observed that in-
l
creased management attention is required to close
!
cut MCAR's in a timely manner.
For example, the
I
most recent QAD trend analysis report, issued on
May 23, 1988, recommended that the SVP-N initi-
ate action to closecut MCAR's QA0 85-2 and QA0
87-2, which address the large number of quality
problem reports issued for "f ailure to follow
procedures" and "inadequate procedures."
Team attendance at several QA Interface meetings
also noted
that
there
is
clearly
increased
management attention being directed to c'ostout
the longstanding MCAR's.
The Team reviewed two open M;AR's to evaluate the
effectiveness of the process. MCAR 86-06, issued
in November 1936, involved recurring failures of
the salt service water (SSW) pumps. The MCAR was
issued as a result of an F&MR trend repert find-
ing.
The MCAR resulted in a detailed root cause
.
analysis by a consultant and the development of a
l
long-term corrective action plan, which is not
yet complete.
MCAR 8S-02, issued in June 1938,
concerned programmatic inefficiencies in the PCAQ
process.
The licensee is actively working on
developing an integrated list of the approxi-
mately 250 open PCAQ's with a curre it status (see
Section 3.10.4.2).
This list is to be utilized
to increase emphasis on closecuts.
Review of
these M;AR's did not identify any discrepancies
in the process.
_ . _ _ _ _ _ _ . . _ _ _ _ _ . __
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
-
_ _ _ _ _ _ - _ _ .
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
__
D
,
'
111
,
3.10.5.4 Clearinghouse Process
I
The current procedure describing the corrective
i
action process is NOP 83A9, "Management Correc-
[
tive Action Process."
This prccedure discusses
l
the responsibilities of the station depart-cents
t
t
in resolving identified deficiencies and report-
ing the trends observed
The procedure also
describes the various types of reports or docu*
t
ments available to station personnel and specifi-
cally defines their use.
r
As a result of the self-assessment evaluations
and performance improvement plans, the licensee
determined that the existing corrective action
t
processes were
very compliccted and
that a
i
streamlined process was needed that would provide
I
,
an easy means of raising any concerns to manage-
,
'
ment for resolution. A need was also identified
!
for a specific entity which could monitor the
performance of the station organization in imple-
,
menting self-improvement recommendations, as well
!
as provide the focal point for identified issues
to be placed into the appropriate plant correc-
,
tive actin 6 process,
j
.
P
In June 1933, the "Clearinghouse" was established
l
3
to serve a number of needs.
It was developed to
l
'
assure that the licensee's restart assessment
(
team observations had been entered into the
!
,
regular corrective
action
process
and,
when
j
necessary, that all necessary .Nperwork. was pre-
-
pared for the resolution of any outstanding
[
ttems.
As of this inspection, 69 assessment
items remain unresolved but have schedules iden-
e
tified
for
their completion.
Responses
for
!
approximately 69 additional items have not been
!
received
from the station organization.
The
balance of the original 449 items have been
f
listed as closed. The Team cid not evaluate the
l
.
closecut process for any completed or closed
j
,
items.
j
j
A second responsibility of the Clearinghouse was
!
,
to streamline the corrective action process. As
{
of this inspection period, revisions to the sta-
i
i
tion procedures for improvements in corrective
!
!
action processes have not been made. The current
,
i
estirate for cenpletion of the necessary proced-
l
l
ure revist" s was the end of Augus..
j
i
.
,
i
!
4
_.
-
.
.
_ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. _ _ _ _ _
O
4
i
112
While subject to revision during the required
station procedure review process, the following
i
is a discussion of the current licensee philos-
ophy concerning potential modification of the
I
corrective action processes.
The Team did not
evaluate the effectiveness of these proposed
changes
in
the
overall
corrective
action
,
programs.
!
The Clea ringhoui,e is currently revising three
i
existing NOPs, creating a new NOP, and revisirg
l
the BEQAM. The new NOP would define the role and
responsibilities of the Clearinghouse, establish
a new form for identifying real or potential
'
plant
problems,
as
well
as
for
reporting
employee-identified concerns or self-assessment
!
recommendations for plant improvements. The new
,
form would provide a uimple method for raising
issues, concerns, or recommendations to station
,
,
'
management.
Upon receipt of this form,
the
'
Clearinghouse would review the issue described
i
t
and integrate the issue into the regular plant
j
corrective
action
proc 2sses
for
resolution.
l
Another proposed change is a categorization of
l
all
the existing corrective action processes
'
.
identified in NOP B3A9 into three groups.
One
i
group, identified as corrective action processes.
l
would include deficiency reports (OR), non-con-
,
,
formance reports (NCR), management corrective
}
action requests (MCAR), failure and malfunction
!
reports (F&MR), radiological eccurrence reports
,
(ROR), security deficiency reports (50R), and
l
supplier finder reports (SFR).
These processes
i
are used to identify and document plant deficia
'
encies and to provide a neans of tracking the
e
resolution of identified problems.
(
t
j
A second group of controls would be categorized
as normal work control processes.
This group
would potentially include maintenance requests
!
(MR),
housekeeping services assistance (H5A),
!
procedure change notices (PC), and engineering
i
I
services requests (ESR).
t
i
,
!
I
1
i
j
i
-
- -
_ _ _ - _ _ _
.
o
,
f
113
The last group currently being proposed includes
all recommendations or findings from the existing
self-assessment programs.
The information to be
'
,
tracked in this group are recommendations for
improving performance and would not be used to
identify programatic deficiencies.
Any identi-
1
fication of deficiencies would be tracked using
'
I
one of the processes described in the first group
above.
Examples of the types of recommendations
1
to be tracked would be quality assurance audit
findings and peer evaluator reports,
j
Changes would also be required for NOP 84E1,
!
"Engineering Service Request (ESR) Proe-ss," and
NOP 84A7, "Drawing Control," as well as the
'
quality assurance manual,
in order to fully
implement the revised program,
j
The
licensee anticipates
that all
necessary
I
changes to station procedures would be completed
l
by the end of August, with formal implementation
of the program changes within an additional 30
days.
t
3.10.5.5 Management 0.ersight and Assessment Team (MO&AT)
In addition to the plant operations oversight
i
provided by the ORC, the MC&AT also provides an
!
oversight review of plant operations by the
nature of its responsibilities for overview of
restart activities.
The MO&AT is corrposed of
eight sentor managers, which includes the Station
Director. Director of Special Projects and Vice
i
President Nuclear Engineering. The SVP-N acts as
the Chairman of the team.
Further, three M01AT
,
merbers had been licensee managers prior to the
I
arrival of the SVP-N, while the remaining ran-
(
agers joined the licensee subsequent to February
l
1987.
l
The M01AT maintains its oversight of restart-
related activities and associated plant opera-
'
I
tio'is through several self-assessment programs.
These programs include but are not limited to the
,
peer evaluator and management ronttoring pro-
l
grams.
The Team noted that these programs were
ef'ective in evaluating plant activities.
l
l
(
i
!
!
,
I
!
,
- ---
. - - -
- - - _ _ _ - _ _ _ . - _ . - -
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
'
O
114
The Team determined that, in some ways, the
responsibilities of the MO&AT parallels some of
the responsibilities to review plant operations
assigned to the ORC.
In addition,
the Team
determined that the curreret role of the MO&AT is
not credited by the ORC as a means of fulfilling
its responsibilities to review plant operations,
but it does provide a second, independent look
at plant operations.
3.10.5.6 Engineering Service Requests (ESR's)
ESRs are tracking forms used by any licensee
department to request engireering assistance from
the Nuclear Engineering Department (NED). Stand-
ard practice within NEO is to attach an ESR to
all requests for assistance which may be already
tracked under another corrective action tracking
system, such as DR's, PCAQ's, etc. This is done
to provide a means for the NED to track and
monitor the progress of its work. When ai ESR is
opened or received. NED is to review the concern,
determir.e a plan for resolution of the item,
which wculd include an evaluation relative to
plans for plant restart. Unless the issue can be
resolved within 30 days, a response to the origi-
nating department is to be provided within 30
days which describes the above.
In discussions
'
l
with the Team, a management representative of NED
l
indicated that this practice has not always
worked as planned and that additional emphasis is
being placed on assuring that the 30-day re-
sponses are being sent in a timely fashion.
NED tracks all existing E5R's, determines what
actions are required prior to restart, and rou-
tinely evaluates the potential impacts of out-
standing ESR's on the plansed restart of the
plant.
In each case where NED determines that
resolution of an ESR is not required to support
restart. NED prepares docu entation to support
that
position.
This
documentation
undergoes
several levels of review, including the Section
Manager, Department Manager and the Vice Presi-
dent - Nuclear Engineering.
Any open ESR asso-
ciated with unresolved pCAQ's or MCAR's is also
revie=ed by the CRC as part of its assigned
restart checklist revie.'.
____-_ __-____-_
.
,
!
i
l
'
i
115
!
i
Based upon discussions with NED personnel, the
I
Team concluded that ESR's are adequa0ely tracked
j
and that upper management is routinely informed
!
of potential problems in a timely fashion.
}
i
3.10.5.7 Human Performance Evaluation System
'
The Team inquired as to the licensee's intentions
!
in participating in the Institute for Nuclear
Power Operations (!NPO) Human Performance Evalua-
tion Systvm (HPES) program.
The program
is
r
intended to assist licensees in the reduction of
[
human error by encouraging pe*sonnel to report
!
actual or potential situations which keep a per-
t
son from outstanding performance.
The licensee
I
has designated an HPES coordinator, who is in the
!
Training Department.
The coordinator has been
i
I
trained by INPO and is currently preparing to
implement
the
program.
The
coordinator
has
!
'
already become involved in the Incident Investi-
l
gation and Critique process, and has reviewed the
i
recent findings frc:n the licensee's ESF Actuation
.
!
Task Fo
i report,
This p rog ra.. . ence fully
implete'.' o l,
should provide additional valuable
input int- the corrective action process.
f
3.10.6
Conclusions
Overall, the Team determined the licensee's programs for
!
safety assessment / quality verification to be adequate and
I
improving.
Based upon the areas inspected and examples
'
L
raised, the Team concluded that'
t
1.
The Nuclear Safety Review and Audit Committee is
actively involved in ;.he oversight of facility opera-
'
tions.
The con:11ttee is composed of experienced man-
agers with diverse experience and provides clear and
valid input to the SVP-N on safety-related activities.
2.
Plant problems and deficiencies are being ident'f ted
f
and entered into the appropriate corrective action
system,
t
-- - ---
o
.
.
.
116
3.
There are effective, meaningful communications between
the QA and plant operations departments, as well as
good systems engineering involvement in evaluation and
resolution of problems.
4.
The weekly QA interface meeting has enhanced communt-
cations at the station and improved the process of
resolving open issues.
5.
The Operations Review Committee (ORC) has not been
reviewing plant operat'.ons ef fectively so that mean-
ingful input to Itcensee manag cent is being consist-
ently provided,
Recently, heavy emphasis has been
placed on administrative reviews of procedure changes
and modifications, rather than reviewing plant opera-
tions. Also, ORC review of plant failure and malfunc-
cion reports has neither been timely nor included all
appropriate reports.
6.
Multiple corrective action processes and multiple
tracking systems detract from efficient functioning of
the system. This has been identified by the licensee
and programs ar
being established to correct the
known deficiencie;.
7.
The tracking and ;1osecut of PCAQ's and MCAR's have
not been effective in the pest.
Also, a relatively
large number of open PCAQ's exists.
The licensee is
taking action to resolve these problem.
. . _ .
_ _ _ _ _ _ _ _
,
'
117
4.0 UNRESOLVED ITEMS
An unresolved item is an item for which additional information is required
in order to determine whether the item is acceptable, a violation, or a
deviation.
An unresolved item is discussed in section 3.4.2.2 of this
report.
I
o
i
118
!
5.0 MANAGEMENT MEETINGS
l
At periodic intervals during the inspection period, the Team Leader held
[
meetings with senior facility management tu discuss the inspection scope
and preliminary findings.
A final exit interview vas conducted on
l
August 24, 1938.
Attendees are listed in Appendix 8.
At the exit meet-
i
ing, the Team Leader described the preliminary insoection findings,
!
including both the preliminary overall conclusions and the preliminary
findings and observations in each functional area.
The Team Leader also
!
confirmed licensee comm.itments at the exit meeting, Then the Team Manager
I-
discussed how the Team findings will be used in NRC Restart Assessment
Panel activities. Also, the Regional Administrator outlined the remaining
.
step in the NRC staff process of evaluating Pilgrim restart readiness and
[
developing staff recommendation.
l
l
l
[
t
I
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i
L
i
i
!
.
I
i
!
!
I
I
.
I
!
--
_ _ _ _ _ _
_ - _ _ . -
l
,
APPEN0!X A
Entrance Interview Attende_es
August 8, 1988
Boston Edison Company
J. Alexander, Plant Operations $ection Hanager
R. Anderson, Plant Manager
H. Balfour, Iraining Section Manager
R. Bird, 5entor Vice President - Nuclear
F. Famulari, Quality Assurance Department Manager
0. Gillispie, Nuclear Training Department Manager
R. Grazio, Regulatory Section Manager
P. Hamilton, Compitance Division Manager
K. Highfill, Station Director
J. Jens, Radiological Section Manager
E. Kraft, Plant Support Department Manager
R, ledgett, Otrector Special Projects
0. Long, Security Section Manager
A. Morist, Planning tad Outage Department Manager
E. Robinson, Corporate Comunication Information Division Head
L. Schmeling, Program V.anager
J. Seery. Technical Section Manager
R. Sherry, Plant Maintehance Section Manager
R. Swanson, Nuclear Engineering Department Manager
E. Wagner, Asr*stant to Senior Vice President - Nuclear
F. Wozniak, Fire Protection Olvision Manager
l
United States Nuclear Regulatory _Comission
l
F. Alstulewicz, Senter Technical Assistant, Policy Development and
!
Technical Support Branch, Office of Nuclear React,or Regulation (NRR)
,
R. Blough, Chief, Reactor Projects Section No. 3B, Otvision of Reactor
l
Projects (DRP), Region 1 (RI)
S. Collins Deputy Director, ORP, RI
L. Doerflein, Project Engineer, ORP, R!
T. Cragoun, Senior Radiation Specialist, Division of Radiation $afety
and Safeguards (CRSS)
M. Evans, Operations Engineer, Olvision of React,or Safety (ORS), R!
J. tyash, Resident Inspector, Ptigrim Nuclear Power Statten, ORP, R1
0. Mcdonald, Project Manager, Project Directorate 1 3, NRR
L. Pitsco, 5tntor Operations Engineer, Otvision of License Performance
and Quality Evaluatien, NRR
W. Raymond, Senior Resident Inspector, Mi11 store Point, ORP, RI
L. Rossbach, Senior Resident Inspector, Indian Point Unit 2, CRP, RI
G. $sith, Safeguards $recia115t, OR55. RI
C. Warren, Senior Resident Inspector, Pilgrim huclear Fe.er Station, ORP, RI
%
_ _ _ _ _ _ _
- _ _ _ _ _ _
_ _
_ _
.
I
I
Appendix A - Entrance Interview
A-2
'
Attendees
r
!
Com.monwealth of_ Massachusetts
l
i
'
P. Agnes, Assistant Secretary of Department of Public Safety
i
P. Chan, Observer
S. Sho11y (MHS Technical Associates, Inc.), observer
i
t
i
I
t
\\
!
!
t
!
l
.
I
!
l
'
l'
i
.
1
4
a
'
1
I
.
s
i
!
,
.I
t
l
.
t
J
f
i
!
'
!
l
i
1
i
1
P
I
'
'
l
,
e
-
- - .
-
- --- --
- ~ ~ ~ ~ - - * - ' ' ^ - ~ '
_ _____________ _ ___ _ _
_ _ _ _ _
,
j
.
e
'
1
!
1
-
l
I
1
'
APPENDIX B
i
Exit Interview Attenden
August _24.193,]
[
j
Boston Edtson Company
>
!
J. Alexander, Plant Operations Section Manager
R. Bird, Senior Vice President - Nuclear
F. Famulari Quality Assurance Department Manager
,
l
0. G1111spie, Nuclear Training Department Manager
i
-
R. Gramont, Deputy Maintenance Section Manager
R. Grazio, Regulatory Section Manager
i
P. Hamtiton, Compliance Divtston Manager
l
K, Highfill, $tation Ofrector
l
J. Jens, Radiological Section Manager
!
E. Kraft, Plant support Department Manager
R. Ledjett, Director $pecial Projects
l
0. Long, Security Section Manager
!
l
E Robinson, Corporate Comunication Irformation Disiston Head
L. Schmeling, Program Manager
J. Seery, Technical Secsion Manager
i
R. Sherry, Plant Maintenance Section Manager
j
R. Swanson, Nuclear Engineering Department Manager
5. Sweeney, Chief Executivc Officer ard Chairman ef the e n d
i
E. Wagner, Assistant to Senior Vice President - Nuclear
,
,
l
F. Wozniak, Fire Protection Otvisten Manager
,
United States Nuclear Regulatory Cemmisslo)
f
f
F. Akstulewicz, Senior Technical Assistant, Policy Development and
T*,:hnical support Branch, Off.ce of Nuclear Raactor Regulation (NRR)
-
R. Blough, Chief, Reactor Projects Section No. 3B, Olvision of Reactor
!
Projects (ORP), Region I (RI)
t
B. Boger, Assistant Director for Region ! Reactors, NRR
l
5. Collins, Deputy Otrector, ORP, R!
l
L. Doerfietn, Project Engineer, DRP. RI
j
W. Little Office of Special Projects, R!!
i
J. Lyash, Resident Inspector, Pileetm Nuclear Power Station, CRP, R!
!
0. Mcdonald, Project Manager, Prc et Directort te (PD) !-3, 'lRR
l
W. Naymond, Senior Resident Inspector, Pills +.ane Point, ORP, RI
L. Rossbach, Senior Resident Inspector, Indian Point Unit 2. ORP, R!
V. Russell, Regional Maintstrator, R!
C. Warren, Senior Resident Inspector, Ptigrim Nucicar Power Station. ORF, RI
R. Vesssan, Director, PO I-3, NRR
i
,
-
,
.
Appendix B - Exit Interview
B-2
Attendees
Commonwealth of Massachusetts
P. Agnes, Assistant Secretary of Department of Public Safety
P. Chan, Observer
G. Minor (MHB Technical Associates, Inc.), Observer
!
I
i
-
__
_
'
.0
APPENDIX C
Persons Contacted
R. Anderson, Plant Manager
R. Bird, Senior Vice President - Nuclear
F. Famulari, Quality Assurance Department Manager
K. Pi-hfill, Station Director
E. ! ,tard, Vice President - Nuclear Engineering
E. Kraft, Plant Support Services Manager
A. Morisi, Planning and Outage Manager
R. Swanson, Nuclear Engineering Department Manager
S. Sweeney, Chairman of the Board and Chief Executive Officer
In addition, the Team interviewed a large number of managers (including
virtually all section and division managers), engineers, supervisors, and
craft personnel in each inspection area.
.
9
O
O
APPENDIX 0
Documents Reviewed
PNPS, Nuclear Training Manual, T-001, Parts 3, 4 and 5
PNPS,
Special
Post-Startup Training Program, Approved August 9, 1988
PNPS Technical Specifications
Boston Edison Company Nuclear Mission, Organization and Policy Manual
Nuclear Organization Procedures
Material Condition Improvement Action Plan
Boston Edison Quality Assurance Manual
Audit Reports -- Sampling review it.cluding the following:
87-40, 88-02,
87-63, 88-10, 88-20, 87-37, 87-49, 8b-04, and 88-11
Potential Conditions Adverse to Quality (PCAQ) Reports -- Sampling review
including N00 87-88, NED 86-71, GE0 87-255, S0 88-57, SO 88-58, 50 88-48,
N00 87-02, N00 87-28, NED 88-087,
50 88-59,
SO 88-12, N00 88-120,
NED 88-90, 50 88-55, and S0 88-22
Management Corrective Action Requests (MCAR's) -- Sampling review includ-
a
ing QA0 85-2, QA0 87-2, 86-06, and 88-02
Licensee Event Reports (LER's) -- Sampling review including 87-21,88-008
thru 88-014,88-016, and 88-017
Maintenance Requests (MR's) -- Sarrpling review including 88-11-6,88-110,
88-10-179, 88-46-300, 88-14-16, 88-45-183, 88-45-181, 88-46-194, 88-10-26,
88-10-105,
88-10-69,
88-10-71,
88-10-141,
87-10-282,
and
87-10-283
Maintenance Activities / Packages
Sampl i r.g review including 88-3-26,
--
63-19-109, 88-46-213, 88-10-86, 87-46-173, 88-13-20, 88-46-438, 88-2-12,
86-20-47, 88-45-157, 88-45-176, 88-3-62, 88-63-276, 88-45-190, 88-1-31,
88-14-16, 88-46-194, and 88-10-114
Meeting Minutes for ORC Meetings 88-40 through 88-63
Failure and Malfunction Report 86-266
NEO Procedure 16.03, "Corrective Action Program"
_.
.
.
Appendix 0 - Documents Revir.wed
0-2
QAD Trend Analysis Report for the First Quarter of 1988 - QAD 88-609
PNPS Work Instruction NS-3.2.12, F&MR Trend Analysis
Memo from J. Seery to R. Grazio, Appointment of Compliince Division as ORC
Subcommittee, June 23, 1988
Memo from R. G. Bird to K. L. Highfill, NSRAC Concern from May 24, 1988
NSRAC Meeting - May 27, 1988
Memo from
K. L. Highfill to R. G. Bird, Response to NSRAC Action Item
88-04-01 - June 22, 1988
Memo from J. A. Seery to
R. Flannery, OkC Mee*.ing Minutes Distrioution
List
dated May 6, 1988
Procedure 1.2.1, Operation Review Committee
Procedure 1.3.24, Failure and Malfunction Reports
Procedure 1.3.2.6, Response to Deficiency Reports
Procedure 1.3.4, Procedures
Procedure 1.3.33, Operating Experience Review
Procedure 1.3.37, Post Trip Reviews
Procedure 1.3.33, Plant Performance Monitoring Program
Procedure 1.3.63, Conduct of Critique 5 and Incident Investigations
Procedure NOP 83A9, Management Corre
ive Action Process
Procedure NOP 83A13, Deficiency Repo.t Process
Procedure NOP 83A14, Nonconformance Report Process
Procedure NOP 84A1, Surveillance Monitoring Program
I
Procedure NOP 84A11, Annual Independent Review of BECo's Quality Assurance
Program
Procedure N0P 85A1, Nuclear Organization Performance Monitoring and
Management Information Program
Procedure NOP 88A1, Performance Standards and Evaluation Guidelines for
.
Pilgrim Station
i
a
.
Appendix 0 - Docurents Reviewed
0-3
Procedure NOP 8305, The Failure and Malfunction Report Process
Procedure NOP 8401, Operating Experience Review Program
Procedure 1.4.5, PNPS Tagging
Procedure 1.5.3, Maintenance Requests
Procedure 1.5,3.1, Maintenance Work Plan
Procedure 1.5.7, Energency Maintenance
Procedure 3.M.1-30, Post-Work Testing Guidance
Procedure SI-MT.1000, Maintenance Section Manual
Procedure SI-MT.0501, Post-Work Test Matrices and Guidelines
Procedura 3.M.1-11.1, E0 Maintenance Process:
Repair / Replacement
Procedure 3.M.3-1, A5/A6 Buses 4KV Protective Relay Calibration / Functional
Test and Annunciator Verification
Procedure 3.M.3-8, Inspection / Troubleshooting Electrical Circuits
Procedure TP 88-40, 480 VAC Contactor Testing
Procedure TP 88-22, Pre-Operational Test of the New Degraded Voltage
Relays and Motilfied Load Shedding Logic
Procedure PW TMI-1, Post Work Test Matrix and Guidelines, Revision A
Procedure
3.M.4-14,
Rotating Equipment inspection, Asambly and Dis-
j
assembly, Revision 6, dated April 4, 1988
i
l
Procedure 8.Q.3.4, 125/250V DC Motor Control Center Testing and Mainten-
ance
Procedure 2.2.85, Fuel Pool Cooling System
Procedure 3.M.1-15, Vibration Monitoring for Preventive Maintenance and
.
Balancing, Revision 5, dated June 12, 1938
Procedure 2.2.8, standby AC Power System (Diesel Generators), Revision 20,
,
l
dated January 13, 1988
Procedure ARP, Panel C39, Fuel Pool Cooling System, Revision 0, dated
l
January 30, 1988
l
!
Procedure 2.2.83, Reactor Cleanup System, Revision 22, dated June 20, 1988
l
l
-
-
.
Appendix 0 - Documents Reviewed
D-4
Fire Watch Computer Listing, dated August 4, 1988
Fire Protection Maintenance Request Computer Listing, dated August 9, 1988
Pilgrim
Station
Performance
Indicators,
dated
August 10, 1988
and
August 17, 1988
Procedure 8.8.29, "Inspection of Fire Barriers," Revision 1
Temporary Modification Status Report to R. Anderson f rom P. Mastrangelo,
dated August 4, 1988
Procedure 1.5.9, "Temporary Modifications," Revi' ion 12
Procedure 1.5.9.1, "Lif ted Leads and Jumpers," Revision 0
Procedure 1.3.34, "Conduct of Operations"
Procedure 2.1.16, "Nuclear Power Plant Operator Tour," Revision 54
Overtime Book
Procedure 1.3.67, "Use and Control of Overtime at PNPS"
Advance Overtime Requests for Week Ending August 6,1988
PNPS 1-ERHS-VIII.8-4-0, Turbine Building Shield Wall Design
Confidential
Memo
- 13,
to
J. P. Jens
from
K. L. Highfill,
dated
July 19, 1938, "Training Program for Radiation Protection Manager"
Procedure 6.1-209, "Radiological Occurrence Reports"
Radiological Work Plan for A and B Recirculation Pump Seal Welds
Procedure 6.1-012, "Access Control to High Radiation Areas"
Selected RP Techrician Training and Qualification Folders, lesson Plan,
Quizzes and Training Guides
Selected Radiation Work Pernits from March 1988 to August 19S8
Maintendnce Request 87-20-84
_ _ _ _ _ _ _ _ _ _ _ _ _ _
_
.
Appendix 0 - Documents Reviewed
0-5
Procedure 8.M.2-1.5.3.4, "Primary Containment Isolation Logic Channel Test
- Channel 82," Revision 8, dated September 24, 1987
Procedure 8.M.2-1.5.7, "Group I Primary Containment Isolation Valve Test-
ing," Revision 5, dated November 7, 1987
Procedure 8.M.2-8.2, "Calibration of ATS Transmitters Rack C2206," Revis-
ion 2, dated June 30, 1988
Procedure 8.M.1-32.4, "Analog Trip System - frip Unit Calibration - Cabi-
net C2229-82," Revision 5, dated April 4, 1938
Procedure 8.M.2-2.10.8.5, "Diesel Generator 'A'
Initiation By Loss of Off-
Site Power Logic," Revision 8, dated November 6, 1987
Procedure 8 M.2-2.10.8. 3,
"Diesel Generator 'A'
Initiation By Core Spray
logic," Revision 12, dated April 9, 1988
Procedure
3.M.3-1,
"AUA6
Buses 4KV Protective
Relay Calibration /
Functional
Test
and
Verification,"
Revision 23,
dated
August 13, 1988
Procedure 8.M.2-2.6.7, "RCIC Simulated Automatic Actuation," Revision 6,
dated February 5, 1988
Procedure 8.5.5.1,
"RCIC Pump Operability and Flow Rate Test at 1000
psig," Revision 24, dated June 4, 1988
Procedure 8.M.2-2.10.7, "RCIC Automatic Isolation System Logic," Revi s-
ion 11, dated November 7, 1987
Procedure
8.M.2-2.6.1,
"RCIC Steam Line Hi Flow," Revision 13, dated
June 9, 1988
Procedure
8.M.2-2.6.3,
"RCIC Steam Line Hi Temperature," Revision 12,
dated July 17, 1987
Procedure 8.M.2-2.64, "RCIC Steam Line Low Pressure," Revision 16 dated
June 20, 1988
Procedure 8.M.1-32.5, "Analog Trip System - Trip Unit Calibration Cabinet
C2233A, Section A," Revision 2, dated December 7, 1987
Procedure 8.E.11. "Standby Liquid Control System Instrument Calibration,"
Revision 9, dated September 2, 1987
Procedure 8.E.13, "RCIC System Instrument Calibration," Revision 14, dated
June 26, 1988
_ _ _ _ _ _ _ _ _ _ _
.
Appendix 0 - Documents Reviewed
0-6
l
Procedure 8.4.1,
"Standby Liquid Control Pump Operability and Flow Rate
Test," Revision 19, dated April 9, 1988
Procedure 1.8, "Master Surveillance Tracking Program," Revision 9, dated
August 15, 1988
Procedure
1.3.36, "Measurement and Test Equipment," Revision
4,
dated
March S',
1988
Procedure 8.I.1,
"Administration of Inservice Pump and Valve Testing,"
Revision 4, dated August 15, 1986
Procedure
8.I.3,
"Inservice Test Analysis and Documentatics Methods,"
Revision 6, dated May 11, 1988
Orawings
PNPS Elementary Diagram MIN 34-9 (Revision E1):
Isolation System
PNPS Elementary Diagram MIN 28-12 (Revision E14):
Isolation System
,NPS Elementary Diagram MIN 36-7 (Sh. 10, Revision E7): Primary Contain-
t
ment Isolation System
PNPS Elementary Diagram MIN 36-7 (Sh.11, Revision ES): Primary Contain-
ment Isolation System
PNPS Elementary Diagram MIN 41-10 (Revision E2):
Isolation System
PNPS Elementary Diagram MIN 38-11 (Revision E2):
P rima ry Containment
Isolation Sy', tem
PNPS Elementary Otagram MIN 35-7 (Revision E4):
Isolation System
PNPS Elementary Diagram mig 11-11 (Revision Ell):
RCIC System
PNPS Elementary Diagram MIG 12-12 (Revision ES):
RCIC System
PNPS Elementary Diagram mig 14-9 (Revision ES):
RCIC System
PNPS Elementary Diagram MIG 15-9 (Revision E8):
RCIC System
PNPS Elementary Diagram MIG 16-7 (Revision ES):
RCIC System
PNPS Elementary Diagram MIK 4-11 (Revision E10):
- - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
__ j
.
Appendix 0 - Dncuments Reviewed
D-7
PNPS Schematic Diagram E-548 (Revision E0): Containment Atmosphere Isola-
tion Control
PNPS Schematic Diagram E-38 (Revision E6):
4160V System Breakers 152-504
and 152-604
PNPS Schematic Diagram E-35 (Revision E3):
4160V Auxiliary Relays and
Miscellaneous Schemes
PNPS Schematic Diagram E-27 (Revision E7):
Diesel Generator
PNPS Schematic Diagram E-17 (Revision E7):
Schematic Meter and Relay
Diagram 4160 Volt System
PNPS Schematic Diagram M6-22-14 (Sh. 1, Revision Ell):
Diesc1 Generator
"A" X107A Engine Control
PNPS Relay Setting Drawing E5-200 (Sh. 1, Revision E3): 4160 Volt Switch-
gear Relay Settings
PNPS Relay Setting Drawing E5-200 (Sh. 3, Revision E2): 4160 Volt Switch-
gear Relay Settings
PNPS P&ID M245 (Revision E13):
RCIC System, Sh. 1
PNPS P&ID M246 (Revision E10):
RCIC System, Sh. 2
PNPS P&ID M249 (Revision E12):
Standby Liquid Control System
.
O
r
APPENDIX E
IATI Composition and Structure
Team Manager
Samuel J. Collins
Team Leader
A. Randy Blough
l
Technical Assistant
Clay C. Warren
Administrative Assistant
Mary Jo DiDonato
Jperations
Lawrence W. Rossbach (Lead)
Shift Inspectors
Lawrence W. Rossbach
William J. Raymond
Loren R. Plisco
Lawrence T. Doerflein
F,ancis M. Akstulewicz
I
Radiological Controls
Thomas F. Dragoun
Maintenance
Jeffrey J. Lyash
William J. Raymond
e
Surveillance
Lawrence T. Doerflein
Security
Gregory C. Smith
Fire Protection
Lawrence W. Roseh..n
Assurance of Quality
Loren R. P11sco
Francis M. Akstulewicz
Training and Management
Daniel G. Mcdonald
Effectiveness
Michele G. Evans
Report Coordinator
Tae K. Kim
Commonwealth of
Steven C. Sholly
Massachusetts (Observers)
Pamela M. Chan
- - _ _ - _ _ - _ _ - _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ .
.
APPENDIX F
NRC Integraced Assessment Team Inspection (IATI)
Members Resumes
This appendix shows IATI summary resumes of the team members and Common-
wealth of Massachusetts observers.
The resumes outline the nuclear
experience of team members.
.
9
.
.
Appendix F
F-2
NAME:
FPANCIS M. AKSTULEWICZ
ORGANIZATION:
United States Nuclear Regulatory Commission
Office of Nuclear Reactor Regulation
Policy Development and Technical Support Branch
TITLE:
Senior Technical Assistant
EDUCATION:
B.S., Nuclear Engineering
EXPERIENCE:
Fourteen Years of Nuclear Experience as Follows:
Two and Goe-Half Years - Shielding Engineer - Bechtel Power
Corporation
One Year - Technical Analyst - Office of Material Safety
and Safeguards (f.'RC)
Eight Years - Nuclear Engineer - Office of Nuclear Reactor
Regulation (NRC)
Two Years - Project Manager - Haddam Neck Plant, Office of
Nuclear Reactor Reg Jlation (NRC)
One-Half Year - Present Position
SPECIAL
QUALIFICATIONS:
Completion of NRC Fundamental and Advanced BWR Systems
Training Course and BWR Simulator Course
SPECIAL
ASSIGNMENTS:
Member of Fire Protection, Health Physics and Diagnostic
Team Inspection at Haddam Neck
I
!
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I
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o
.
Appendix F
F-3
NAME:
A. RANDOLPH BLOUGH
ORGANIZATION:
United States Nuclear Regulatory Commission, Region I
Division of Reactor Projects
TITLE:
Chief, Reactor Projects Section No. 3B
EDUCATION:
B.S.,
U.S.
Naval Academy, 1973 (Graduated with Honors)
Navy Nuclear Engineer Officer Course, 1977
NRC I,3pector Technical Training Program, 1980
Various technical and management courses in USN and USNRC,
such as QA, Reactor Engineering, Reactor Safety, Supervis-
ing Human Resources, EEO, Management Workshops
EXPERIENCE:
Fifteen Years Nuclear Experience as Follows:
1985-Present
United States Nuclear Regulatory Commission (USNRC)
--
Reactor Projects Section Chief.
Manage s <fety inspection
programs for three commercial reactor fac)'ities.
Super-
vise nine nuclear engineers. Provide formal assessments of
utility management effectiveness and safety performance.
1982-1985
USNRC -- Senior Resident Inspector at operations phase and
preoperational phase nuclear power plants. Planned, super-
vised, and performed inspections of management controls and
activities
important
to
nuclear
safety.
Coordinated
specialist inspector efforts.
Formally reported findings
and recommended appropriate enforcement.
1972-1982
USNRC -- Resident Inspector. Planned, performed, and docu-
mented inspections of all functional areas at a dual-unit
operating reactor site.
1973-1979
U.
S. Navy Nuclear Power Program.
Duties included super-
visory positions in nuclear plant operations, maintenance
and training. Performed audits and coordinated plant self-
assessment.
Was
responsible
for a
complex,
in-plant
nuclear training program for up to 300 students. Shipboard
duties included Main Propulsion Assistant: responsible for
all reactor and main propulsion systems, all radiological
controls and plant chemistry.
Collateral duties included
9A Of ficer, and Nuclear Weapons Safety / Security Officer.
SPECIAL
QUALIFICATIONS:
Qualified BWR Inspector, NRC Region I,1980
Qualified Nuclear Engineer Officer, Naval Reactors, 1977
SPECIAL
ASSIGNMENTS:
Team Lesder, NRC Integrated Performance Assessnment Team
Inspection, Oyster Creek, 1987
Team Leader, NRC Team Inspection of Oyster Creek Contain-
ment Vacuum Breakers Event, 1987
Participated in various other plant readiness inspections,
1984-1985
. - _
-_
{
.
Appendix F
F-4
NAME:
PAMELA M. CHAN
ORGANIZATION:
Massachusetts Energy Facilities Siting Council (Since 12/87)
TITLE:
Engineer / Utility Analyst
EDUCATION:
B.S. M.E. Pennsylvania State University
EXPERIENCE:
Five Years Nuclear Experience as Follows:
1987
United States Nuclear Regulatory Commission, Region III,
Reactor Inspector
1985-1987
Nuclear Power Services - Construction
1984-1985
Combustion Engineering
Nuclear Systems Services; Field
-
Service Engineer
1982-1984
Stone & Webster Engineering Corporation - Power Division
System Engineer - Turbine Plant Systems
SPECIAL
QUALIFICATIONS:
Background in Maintenance and Quality Assurance
SPECIAL
ASSIGNMENTS:
Participated in several team inspections while at NRC
Region III
l
1
.
.
Appendix F
F-5
NAME:
SAMUEL J. COLLINS
ORGANIZATION:
United States Nuclear Regulatory Commission Region I
bivision of Reactor Projects
TITLE:
Deputy Director
EDUCATION:
Bachelor of Science, Maine Maritime Academy
Business Program, Southern Vermont College
EXPERIENCE:
Seventeen Years Nuclear Experience in Design, Construction,
Operations, Inspection and Management as Follows:
1987 - Present
Deputy Director:
Division of Reactor Projects, USNRC,
Region I
1986 - 1987
Deputy Director (Detail):
Division of Reactor Projects,
USNRC, Region I
As a member of the Senior Executive Service, responsible
for division management; the conduct of inspections and
evaluations of assigned NRC programs for all power and
non power reactors within Region I.
1985 - 1986
Branch Chief:
Ret.ctor Projects Branch No. 2. USNRC,
Region I
Responsible for project management, staffing and budget
considerations, including irspectionr, implementation of
SAlp, resident inspection and enforcement for eleven
assigned power reactor sites in operation and under
construction.
1984 - 1985
Section Chief:
Reactor Projects Section No. 2C, USNRC,
Region I
Responsible for implementation of the routine and reactive
inspection program at six assigned power reactors during
new cunstruction, testing and cperation.
1983 - 1934
Senior Resident Inspector: Operations, Yankee Nuclear
Power Station, ORP, USNRC, Region I
Supervised; inspection and event response program at opera-
ting Wastinghouse PWR power reactor facility.
1930 -1933
Pesident Reactor Inspector: Operations, Vereont Yankee
Nuclear Power Station, DRP, USNRC, Region :.
Field
inspector at oper. ting Geners' Electric BWR power reactor
,
facility.
.
Appendix F - Samuel J. Collins
F-6
,
Private Industry:
1971 - 1980
Tenneco Corporation, Newport News Shipbuilding.
Various
positions as contractor to U.S. Navy Nuclear Program
including:
Project Manager - S5W Steam Generator Chemical Cleaning
Project
Chief Test Engineer - Chairman and NNS representative to
Joint Test Group for 55W overhaul and construction
Shif t Test Engineer - Shif t supervisor for reactor overhaul
and refueling
Shift Test Engineer - Shift supervisor for reactor new
construction
Mechanica
Test Engineer - Shift mechanical test for reac-
tor new construction
Reactor Design Engineer - Design support for reactor new
construction
SPECIAL
QUALIFICATIONS:
Senior Executive Service Candidate Development Program,
USNRC, 1986 - 1987
Qualified SWR Resident Inspector
Qualified PWR Resident Inspector
Qualified 55W Shif t Test tingineer
Third Engineer License, USCG
SPECIAL
ASSIGNMENTS:
1988 - Team Manager, Pilgrim Integrated Assessment Restart
Team Inspection
1987 - 1988 - Chairman, Pilgrim Restart Assessment Panel
1987 - 1988 - Region I Representative, NRC Training Ad-
visory Group
1937 - Chairman, Differing Professional Opinion Peer Review
Group
1987 - Chairman, Comanche Peak Task Force Review Group
1986 - Team Leader, Nine Mile Point 1 and 2 Diagnostic Team
Inspection
1985 - Team Leader, Pes:h Bottom 2 and ? 11 agnostic Team
Inspection
- _ - _ _ _ _ _ _ _ _ _
e
Appendix F
F-7
NAME:
LAWRENCE T. DOERFLEIN
ORGANIZATION:
United !tates Nuclear Regulatory Commission, Region I
Division of Reactor Projects
TITLE:
Project Engineer
EDUCATION:
BS Electrical Engineering
US Naval Academy, 1973
EXPERIENCE:
Fifteen Years Nuclear Experience as Follows:
Aug. 1985-Present
Project Engineer
Oct. 1993-July 1935 Senior Resident Inspector, FitzPatrick huclear Power Plant
Nov. 1980-0ct. 1980 Resident Inspector, FitzPatrick Nuclear Power Plant
June 1973-Oct. 1980 US Navy
SPECIAL
QUALIFICATIONS:
Certified NRC SWR Inspector
Qualified Chief Naval Nuclear Engineer
SPECIAL
ASSIGNMENTS:
Limerick Readiness Assessment Team
Pilgrim Augmented Inspection Team
I
t
-
.
l
l
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I
__ .
. _ __
_
- _ _ _ _ _ _ _
_
._ _____ _ __ .
..
_
.
Appendix F
F-8
NAME:
THOMAS F. DRAGOUN
ORGANIZATION:
United States Nuclear Regulatory Commission, Region I
Division of Radiation Safety and Safeguards
TITLE:
Senior Radiation Specialist
EDUCATION:
Rensselaer Polytechnic Institute, and Union College
000 Staf f College, Battle Creek, Michigan
EXPERIENCE:
Twenty-Three Years of Nuclear Experience as Follows:
1983-Present
NRC - Senior Radiation Specialist
1983-1969
General Electric Company, which included the following:
Qualified as Operations Engineer and E00W at Navy
-
Prototype (3 Years)
Senior Engineer on Trident Prototype Construction
-
Project (0 Years)
Health Physicist responsible for service work, both
-
domestic and foreign by Large Steam Turbine Division
(6 Years)
1955-1969
Cornell University - Taught Radiation Protection Subjects
i
4
_ _.
o
.
Appendix F
F-9
NAME:
MICHELE G. EVANS
ORGANIZAfl0'd:
United Sta#ies H<i.itar Regulatory Commission, Region I
Division of Reactor Safety
TITLE:
Operations Enciseor
EDUCATION:
B.S., Cr/mi as Eno'lecring, University Jf Pennsylvania
EXPERIENCE:
Four Years of Nuslear ;perieace as
r llows:
o
Aug 1987-Present
Operations Enginter, Eoiling Water Rasctor Section - Con-
duct review and inspection o# Power Ascension Programs at
Pilgrim and Nine Mile Point 2.
Currently in training tn
qualify as BWR Operator Licensing Examiner
July 1934-Aug 1937 Reactor Engineer, Test Programs Section - Conducted review
and ii:spection of preoperational test programs at Hope
Cre2k ar.d Nine Mile Point 2, and Startup Testing Programs
at Limerick 1, Shoreham, Pope Creek and Nine Mile Point 2.
SPECIAL
QUALIFICATICNS:
Engineer in Training (State of Pennsylvania)
SPECIAL
ASSIGNMENTS:
Currently participating in the Women's Executive Leadership
Program for Management Development
,
. _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _
.
Appendix F
F-10
NAME:
JEFFREY J. LYASH
ORGANIZATION:
United States Nuclear Regulatory Commission, Region I
Division of Reactor Projects
TITLE:
Resident Inspector - Pilgrim Nuclear Power Station
EDUCATION:
B.S. , Mechanical Engineering, Orexel University
EXPERIENCE:
Six Years Nuclear Experience as Follows:
Two and One-Half Years - NRC Resident Inspector - Pilgrim
Nuclear Power Station
One Year - NRC Resident Inspector - Hope Creek Generating
Station
One Year - NRC Reactor Engineer - Region I
One and One-Half Years - Pennsylvania Power and Light
Company - Test Engineer - Susquehanna Steam Electric
Station
SPECIAL
QUALIFICATIONS:
Meritorious Service Award as NRC Resident Inspector of the
Year 1987-1988
.
,
Appendix F
F-11
NAME:
DANIEL G. M 00NALD, JR.
ORGANIZATION:
United States Nuclear Regulatory Commission (USNRC)
Office of Nuclear Reactor Regulation
TITLE:
Senior Project Manager
EDUCATION:
B.S., Management, Shenandoah College
A.A., Engineering, Solano College
EXPERIENCE:
Thirty-One Years Nuclear Experience as Follows:
1982-Present
Senior Project Manager - Manage and coordinite all NRC
licensing functions on assigned operating reactor facil-
ities which have difficulties or complexities with manage-
ment and operation.
(NRC)
1982 (3 Months)
Reactor Engineer (Instrumentation) - Technical evaluations
of instrumentation and control systems or licensee appli-
cations and operating reactor modifications. Assist in
developing regulatory requirements and establishing staff
policy.
(NRC)
1980-1932
Staff Member - Conduct, direct and coordinate assessments
of critical technologies in the context of national secur-
ity.
Provide technical support to the Nuclear Regulatory
Commission.
(Los Alamos National Laboratory)
1979-1980
Reactor Inspector (Electrical) - Inspects reactors under
construction and in operation.
(NRC)
1978-1979
Senior Electrical Engineer - Technical evaluations of
electrical, instrumentation and control systems. Assist in
developing staff policy.
(NRC)
1973-1978
Reactor Engineer (Instrumentation) - Technical evaluation
for license applications and operating reactors.
(NRC)
1966-1973
Senior Technical Associate - Field engineer in nuclear
weapons test programs.
(Lawrence Livermore Laboratory
(LLL))
>
1964-1966
Senior Electronic Engineering Coordinator - Design of con-
trol, interlock and instrumentation systems for critical
assembly machines, test reactors and containment vaults.
(LLL)
1960-1964
Electronics Designer - Design of cormunication, personnel
warning, closed circu t TV and radiation monitoring
i
systems.
(LLL)
.
,
Appendix F - Daniel G. McDona'.d Jr.
F-12
1957-1960
Senior Electronic Technician - Fabricated and assisted in
the design and development of prototype electrical and
electronics equipment.
(LLL)
1953-1957
Electrical Specialist - Four year apprenticeship with
Department of Navy.
(Mare Island Shipyard)
1
l
1
. .
.
.
_ ______
_ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ .
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
s
.
Appendix F
F 13
NAME:
LOREN R. PLISCO
ORGANIZATION:
United States Nuclear Regulatory Commission
Office of Nuclear Reactor Regulation
Division of Licensee Performance and Quality Evaluation
TITLE:
Senior Operations Engineer
EDUCATION:
B.S., Systems Engineering, U.S. Naval Academy
EXPERIENCE:
Eleven Years Nuclear Experience as Follows:
1937-1988
Senior Operations Engineer, NRC:NRR
1936-1987
Senior Resident Inspector - Susq;ehanna Steam Electric
Station
-
1983-1986
Resident Inspector - Susquehanna Steam Electric Station
1932-1983
Reactor Engineer, Region I
197/-1982
'.'S Navy Nuclear Power Program
SPECIAL
QUALIFICATIONS:
Certified NRC BWR Inspector
'
Qualified Naval Nuclear Engineer Officer
SPECIAL
ASSIGNMENTS:
Susquehanna 2 - Operational Readiness Assessment Team
Inspection
Limerick 1 - Operational Readiness Asssessment Team Inspec-
tion
i
Hope Creek - Operational Readiness Assessment Team Inspec-
tion
i
1
Salt.m - ATWS Inspection
THI-1 - Management Integrity Inspection
i
I
{
I
,
1
i
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l
1
i
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(
!
l
,
4
. . .
- .
r -
,
Appendix F
F-14
NAME:
WILLIAM J. RAYMOND
ORGANIZATION:
United States Nuclear Regulatory Commission, Region I
Division of Reactor Projects
TITLE:
Senior Resident Inspector - Millstone Nuclear Power Station
EDUCATION:
B.S. Physics
M.S. Nuclear Science and Engineering
EXPERIENCE:
Eighteen Years Nuclear Experience as Follows:
1975-1988
NRC Reactor Operations Inspector
SU&T, Core Physics, Refueling, Pre & SU&T for BV, CC1,
-
IP3, MP2
Project Inspector - Beaver Valley, Ginna and Susque-
-
hanna
TMI Recovery Team - Accident Response and Containment
-
Entry
Senior Resident Inspector - Vermont Yankee and Mill-
-
stone
1972-1975
Startup Engineer, Babcock & Wilcox, Oconee 1 and 2 and
Three Mile Island, Unit 1
1970-1972
Reactor Operator, VP1 Research Reactor
SPECIAL
QUALIFICATIONS:
VPI Reactor Operator License
Certified NRC Licensed Operator Examiner - 1986
SPECIAL
ASSIGNMENTS:
IAEA Assist Visit to Brazil CNEN - 1981
Team Leadar Salem ATWS Event - NRC Fact Finding - 1983
Salem ATWS Generic Issue Review Team - 1983
NRC Response to Crystal River Event - 1981
Assist Visit to Region V - WNP2 Startup Readiness - 1982
Tean Inspections - Shoreham 1932 and Pilgrim 1986
Operator Briefings of TMI Event - 1979
-
_ _ _ _ _ _ _ _ _ _ _ _ _
o
,
t
Appendix F
F-15
NAME:
LAWRENCE ROSSBACH
ORGANIZATION:
United States Nuclear Reguletory Commission, Region I
Division of Reactor Projects
TITLE:
Senior Resident Inspector - Indian Point Unit 2
EDUCATION:
8.S., Nuclear Engineering
EXPERIENCE:
Sixteen Years of Nuclear Experience as Follows:
Six 7 ears, NRC Resident Inspector and Senior Resident
Inspector
Two and One-Half Years, Program Manager for NRC's prepara-
tion to review a high level waste repository li:ense
application
Two and One-Half Years, NRC Project Manager and Reviewer
for Uranium Mills
Five Years, Systems Design Engineer at Architectural
Engineering (AE) Company
l
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l
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.
j
.
App;ndix F
F-16
NAME:
STEVEN C. SHOLLY
ORGANIZATION:
MHB Technical Associates (Observer for the Commonwealth of
TITLE:
Associate Consultant
EDUCATION:
B.S. in Education (1975) Graduate Course Work in Geo-
environmental Studies (1976-1977)
EXPERIENCE:
Seven and One-Half Years Nuclear Experience as Follows:
1985-Present
MHB Technical Associates, San Jose, CA - Work in Risk
Assessment, Quality Assurance, Optrating Events Analysis,
and Design and Construction Assessment
1981-1935
Union of Concerned Scientists, Washington, D.C. - Work in
generic safety issues, risk assessment and emergency
planning
SPECIAL
ASSIGNMENTS:
Member of NRC Peer Review Group, NUREG-1050 (1984)
-
Participated in NRC Containment Performance Design
-
Objective Workshop (1986)
Participated in NRC/LLNL Workthop on Safety Goals
-
Implementation, Presentation on Seismic Risk
Assessment (1987)
l
.
r -
,
Appendix F
F-17
,
NAME:
GREGORY C. SMITH
ORGANIZATION:
United States Nuclear Regulatory Commission, Region I
Division of Radiation Safety and Safeguards
l
TITLE:
Safeguards Specialist
'
EDUCATION:
B.S. Education, California State College
Various additional courses including:
Technical
-
Writing, Quality Assurance Auditing, Statistics,
'
Reactor Design and Layout, Radiological Accident
Assessment, Rrdiological Emergency Response, BWR
Technology, Transportation of Radioactive Materials,
Advanced Neutron Nuclear Materials Assay, Safeguards
Chemical Analysis of Nuclear Materials, Nondestructive
Assay of Nuclear Materials, Nondestructive Assay of
Fissionable Material, Accident / Incident Investigation
and Intrusion Detection Systems
EXPERIENCE:
Twenty-Two Years Nuclear Incestry Experience as Follows:
1977-Present
Safeguards Specialist, Physical Protection Inspector and
Safeguards Auditor (USNRC)
1966-1977
Westinghouse Electric Corperation, Bettis Atomic Power
Laboratory - Production Engineer, Nuclear !'aterials Aud-
.
itor, Nuclear Materials Analyst, Reactor Development
l
Technician
!
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,
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.
Appendix F
F-18
4
NAME:
CLAY C. WARREN
ORGANIZATION:
United States Nuclear Regulatory Commission, Region I
Division of Reactor Projects
TITLE:
Senior Resident Inspector - Pilgrim Nuclear Power Station
EDUCATION:
B.S., Natural Sciences, Louisianna State University
Industrial:
1986 - USNRC Inspector Qualification Program
1985 - Training Program on the General Electric BWR-6 oro-
.
duct ifne and received NRC Senior Reactor Operator License
1982 - GE Boiling Water Reactor (BWR) Senior Reactor Oper-
stor Certification training at the General Electric BWR
l
. raining Center
1980 - Shif+ Test !
'neer training program at General
Dynamics Corporation, Electric Boat Division.
Successfully
completeo the Naval Engineering Officer exam administered
by Naval Reactors.
Military:
Navy Nuclear Prototype Training
Navy Nuclear Power School
Electronics Technicians School
EXPERIENCE:
Fif teen Years Nuclear Experience as Follows:
Jan 1987-Present
United States Nuclear Regulatory Commission, Senior
Resident Inspector
Jan 1986-Jan 1987
Resident Inspector
June 1934-Jan 1936 Shift Supervisor, Gulf States Utilities Company, River Bend
Nuclear Station
Jan 1931-June 1934 Control Operating Foreman, Gulf States Utilities Company,
River Bend Nuclear Station
June 1979-Dec l'J30 Shift Test Engineer, General Dynamics Corporation, Electric
Boat Olvisien
.
Jan 1971-June 1979 Electronics Technician - Reactor Operate., United States
Navy
SPECIAL
QUALIFICATIONS:
USNRC Senior Reactor Operators License
.
-
_
f
Appendix F - Clay C. Warren
F-19
SPECIAL
ASSIGNMDO S;
Nine Mile Point 2 Operational Readiness Assessment Team
Inspection
Peach Bottom - Special Team Inspection March 1986
1
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UNITED STATES
k
f
NUCLEAR REGULATCRY COMMi^^15N
I
.
REGION 1
,
475 ALLINoALE ROAD
KING oF PRUe41 A. PENNSYLVANIA 19406
.....
01 SEF 1988
The Commonwealth of Massachusetts
Executive Office of Public Safety
ATTN: Mr. Charles V. Barry
One Ashburton Place
Boston, Massachusetts 02108
Dear Mr. Barry:
This refers to our letter of July 13, 1988, regarding the Commonwealth of
Massachusetts' participation in the Integrated Assessment Team Inspection
(IATI) conducted at the Pilgrim Huclear Power Station.
As the NRC Senior Manager responsible for the inspection, I would like to ac-
knowledge the conduct of the designated state representatives Ms. Pamela J. Chen
and Mr. Steven C. Sho11y as being professional and contributing to the perfor-
mance of the inspection.
The established protocol (enclosed) provided to you on June 1,1988, clarified
by our letter of July 13, 1988, and discussed directly by myself with
Mr. Peter Agnes of your staff on August 9,1988, provides for collection and
coordination of the concerns from the various interests within the Commonwealth.
As stated in our July 13, 1988 letter, the NRC placed the burden on the Common-
wealth's representative to present the many views, be they from the local
governments or from the State's Attorney General's office, to the NRC for
consideration during development of tne inspection scope.
In this regard, we
understand that Mr. Agnes conducted a public meeting on August 4, 19:3, with a
designated state representative to the IATI present.
On August 9, 1988, having received no issues from the Commonwealth as an
additional input to the existing inspection plan, I contacted the Assistant
Secretary of Public Safety directly and was assured that: no formal input to
the IATI inspection plan would be submitted by the Commonwealth, the
Commonwealth would work through the designated representatives for any issues
and that issues brought to the Commonwealth's attention were no different than
those previously noted. Also, the team leader has not.ified me that at no time
during the inspection did he receive immediate notification of any different
state observation or conclusion as would be called for under Protocol
Guideline 3 if any such dif ferences were identified during the inspection.
Since the IATI exit meeting conducted on August 24, 1988 which was attended by
Mr. Agnes and Ms. Chen, the Commonwealth has expressed on several occasions
both to the tredia and #t public meetings that technical issues and management
concerns continue to exist. These statements appear inconsistent with the
Commonwealth's response to repeated NRC requests for IATI inspection scope
input and moreover inconsistent with the Comonwealth views expressed at the
IATI exit meeting.
In order to better understand and address the areas of concern, the NRC
requests that in accordance with the protocol agreement accepted by the
Comrinwealth, as provided f( ? by Guideline 3, that the Commonwealth make
available in writing those conclusions or observations that are substantially
,
different fro'n those of the NRC inspectors in order that the NRC can take the
necessary actions to meet its regulatory responsibilities.
? 0 T O ? ?!C-5
.?g
l_
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_-
.
.
G-2
-
Mr. Charles V. Barry
2
01 SF.F 1988
It is necessary that the Commonwealth's response be provided to the NRC Region
I by September 6, 1988, to be considered in conjunction with the documentation
of the results of the recently completed IATI.
This request was discussed
with Mr. P. Agnes of your staff on August 26 and August 31, 1988.
If you have any questions regarding the above matters, please contact me at
(215) 337-5126 or the State Liaison Officer for Region I, Ms. Marie Miller at
(215) 337-5246.
Sincerely,
we
o
ns, leputy Director
.
Division of Reactor Projects
Enclosure: As Stated
cc w/ enc 1:
'
R. Bird, Senior Vice President - Nuclear
K. Highfill, Station Director
'
R. Anderson, Plant Manager
J. Keyes, Licensing Division Manager
E. Robinson,. Nuclear Information Manager
R. Swanson, Nuclear Engineering Department Manager
The Honorable Edward J. Markey
i
The Honorable Edward P. Kirby
The Honorable Peter V. Forman
!
B. McIntyre, Chairman, Department of Public Utilities
1
Chairman, Plymouth Board of Selectmen
I
Chairman, Duxbury Board of Selectmen
Plymouth Civil Defense Director
P. Agnes, Assistant Secretary of Public Safety, Commonwealth of
S. Pollard,**sssachusetts Secretary of Energy Resources
,
R. Shieshak, ,s'.SSPIRG
!
Public Documet Room (POR)
Local Public Document Room (LPOR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
CommonwealthofMassachusetts(2)
,
bec w/ enc 1:
!
Region I Docket Room (with concurrences)
l
S. Co11tns, DRP
f
i
'
J. Wiggins, ORP
R. Blough, DRP
L. Doerflein, DRP
R. Bores, DR35
D. Mcdonald, FM, NRR
!
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I
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.
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. - - - - - - - - - - - - .
_ _ _ _ _
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G-3
EN,C_LOSURE
Guidelines for Accompaniment on the Integrated Assessment Team Inspection
The following are guidelines for accempaniment during NRC's Pilgrim Integrated
Assessment Team Inspection.
1.
The observer is to make arrangements with the licensee for site access
training and badging.
2.
The observer shall be available throughout the inspection and will accom-
pany NRC inspectors. Communication with the licensee will be through the
appropriate NRC team member, preferably the team leader.
3.
When
the conclusions
or observations made by the Comonwealth of
Massachusetts observer are substantially different from those of the NRC
inspectors, Comonwealth of Massachusetts will make its observations
-
imediately known to the inspection team leader and available in writing
to the NRC and the licensee, in order that NRC can take the necessary
actions to meet its regulatory responsibilities.
These communications
will be publicly available, similar to NRC inspection reports.
4.
NRC inspectors are authorized to refuse to permit continued accompaniment
by the Comonwealth of Massachusetts observer if his conduct interferes
,
l
with a fair and orderly inspection.
S.
The Comonwealth of Massachusetts observer in accompanying NRC inspectors
will not normally be provided access to proprietary information.
No
license material may be removed from the site or licensee possession
without NRC approval.
6.
The Comonwealth of Massachusetts observer in accompanying the NRC
,
inspectors pursuant to these guidelines does so at his (.vn risk. The NRC
i
l
will accept no responsibility for injuries and exposures to harmful
,
substances which may occur to the accompanying individual during the
l
inspection and will assume no liability for any incidents associated with
'
the accompaniment.
L
t
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