IR 05000293/1979004

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IE Insp Rept 50-293/79-04.Noncompliance Noted:Failure to Conduct Surveillance Test Per Tech Specs Re Reactor Power Limitation
ML19225A861
Person / Time
Site: Pilgrim
Issue date: 04/25/1979
From: Kister H, Zimmerman R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19225A852 List:
References
50-293-79-04, 50-293-79-4, NUDOCS 7907200469
Download: ML19225A861 (8)


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U.S. NUCLEAR REGULATORY COMM OSION OFFICE OF INSPECTION AND ENF' RCEMENT J

Region I Report No. 50-203/70-04 Docket No.10-293 License No. DPR-35 Priority

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Category C

Licensee:

Boston Edison temoany M/C Nuclear 800 Bovlston Street Boston, Massachusetts 02199 Facility Name:

Pilarim Nuclear Power Station, Unit 1 Inspection at:

Plymouth, Massachusetts Inspection conducted:

March 20-23, 1979 I'is pectors :

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L+ / M I 79 R. P. Zimmerman, Reactor Inspector date signed

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date signed date signed

Approved by:

b M/79 H'. B. Kisteh Chief, Nuclear Support Section cate fignsd No. 2, RO&NS Branch Inspection Summary:

Insoection on March 20-23, 1979 (Report No. 50-293/79-04)

Areas Inspected:

Routine, unannounced inspection by a regional based inspector of licensee action on previous inspection findings; licensee event report review; administrative controls for surveillance procedures; surveillance resting; inspector witnessing of surveillance tests; technical qualification; and, review of control room operations.

The inspection involved 27 inspector-hours onsite by one NRC regional based inspector.

Results:

Of the seven areas inspected, no items of noncompliance were identified in six areas; one apparent item of noncompliance was found in one area (Deficiency - surveillance test not conducted in accordance with Technical Specifications - Paragraph 5.c(1)).

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7907200 6 Region I Form 12 (Rev. April 77)

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DETAILS 1.

Persons Contacted E. Cobb, Chief Operating Engineer

  • J. Fulton, Senior Plant Engineer
  • P. McGuire, Station Manager J. Nicholson, As;istant to Station Manager
  • C. Vantrease, unief Technical Engineer The inspector also interviewed other licensee employees including members of the technical and engineering staff and reactor operators.
  • denotes those present at the exit interview.

2.

Licensee Action on Previous Insoection Findinos (0 pen) Infraction (293/77-22-05):

Failure to retrieve Ouality Assurance documentatinn od inietrative Procedure (AP) 1.5.3, Maintenance Requests, has been rav;3ed to incorporate the commit-ments of the licensee response letter, dated October 13, 1977, with the exception that AP 1.5.3 has not been updated to include the Maintenance Staff Engineer's responsibility to note on the concleted checkoff sheet the applicable maintenance request form (MRF) number.

The licensee representative stated that Revision 11 to AP 1.5.3 will include the above commitment and will be issued within one month.

This item remains open pending NRC:RI review of Revision 11 to AP 1.5.3.

(Closed) Deficiency (293/77-22-06):

Failure to properly complete the Maintenance Request Form (MRF).

Operations Review Committee responses to Deficiency Reports 399 through 403, and s 5 through 412 from the licensee's OA Department Audit 78-3, were reviewed with respect to corrective action and measures to prevent recur-rence, and were found acceptable.

(Closed) Unresolved Item (293/78-18-05): Selected maintenance procedures fail to comply with ANSI 18.7.

Operations Review Committee responses to internal Deficiency Reports 392 and 397 were reviewed with respect to corrective action and measures to prevent recurrence, and were found acceptable.

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3.

Review of Licensee Event Report (LER)

The inspector reviewed the below listed LER to verify that details of the events were clearly reported, including the accuracy of the description of cause and adequacy of corrective action.

The inspec-tor determined whether further information was required from the licensee and whether the event had generic implications.

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LER 79-007/03L, dated February 23, 1979; Failure of oxygen analyzer valves to give proper position indication when cycled.

Failure was found not to be due to an alignment problem.

Proper indication was verified as each valve was subsequently cycled.

The licensee has increased the surveillance frequency from quarterly to monthly.

Operations Review Connittee neeting 79-11 discussed the details of the event.

No items of noncompliance were identified.

4.

Administrative Controls for Surveillance Procedures The inspector performed an audit af the licensee's administrative controls by conducting a samplin9 eview of the below listed admin-istrative procedures with respect to the requirements of the Technical Specifications, Section 6, " Administrative Controls,"

ANSI N18.7 " Administrative Controls for Nuclear Power Plants" and Regulatory Guide 1.33 " quality Assurance Program Requirements."

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Procedure No.1.3.4, Procedures, Revision 19, December 27, 1978.

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Procedure No. l. 5.3, Maintenance Requests, Revision 10, September 13, 1978.

No items of noncompliance were identified.

5.

Surveillance Testing a.

The inspector reviewed surveillance tests on a sampling basu to verify the following.

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Tests reqcired by Technical Soecifications are available and covered by properly approved procedures.

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Test fermat and technical content are adequate and provide satisfactory testing of related systems or components.

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Test results of selec+ed tests are in conformance with Technical Specifications and procedure recuirements have been reviewed by someone other than the tester or indi-vidual directing ;"e test.

b.

The following surveillance tests were reviewed to verify the items identified above:

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Procedure No. (PN) 8.M.2-2.10.4-2, High Pressure Coolant injection saitiation Logic Test, Revision 3, November 5, 1976.

Data was reviewed for test perforned November 1, 1978.

PN 8.M.3-1, Simulated Auto Initiation of Diesel Generators,

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Revision 3, May 17, 1978.

Data was reviewed for test performed October 27, 1978.

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PN 8.5.1.1, Core Spray Pump Operability and Flow Rate Test, Revision 5, February 21, 1979.

Data was reviewed for fourteen tests performed Sectember 7,1978 through March 6, 1979.

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PN 8.5.2.1, Low Pressure Coolant Injection Subsystem Operability Surveillance Test, Revision 7, October 7, 1977.

Data was reviewed for test performed January 17, 1979.

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Operations Form-09, P.N.P.S. Operating Daily Surveillance Log, Revision 15.

Data was reviewed for the dates March 9, 1979 and March 16-18, 1979.

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PN 8.4.2, Standby Liquid Control Pump Operability Flow Rate and Relief Valve Test, Revision 6, March 7,1979.

Data was reviewed for tests performed April 4-5, 1977.

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PN 8.5.5.1, Reactor Core Isolation Coolina Pump Operability and Flow Rate Test at 1000 psig, Revision 6, November, 1976.

Data was reviewed for nine tests performed December 12, 1978 through March 9, 1979.

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PN 8.5.4.1, High Pressure Coolant Injection Pump

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Operability and Flow Rate Test at 1000 psig, Revision 8, February 7, 1979.

Data was reviewed for tests performed February 12, 1979, March 8, 1979, and March 14, 1979.

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PN 8.5.6.1, Automatic Depressurization System Subsystem:

Manual Opening of Relief Valves (Preferred Method), Revision 3, May ll, 1977.

Data was reviewed for four tests performed November 15, 1977 through October 27, 1978.

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PN 8.B.1, Fire Pump Test, Revision 9, March 7, 1979.

Data was reviewed for five tests performed February 19, 1979 through March 19, 1979.

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PN 8.7.4.4, Main Steam Isolation Valve Trip, Revision 4, September 27, 1978.

Data was reviewed for seven tests performed May 28, 1978 through March 4, 1979.

c.

The following items were identified as a result of the above review:

(1)

Surveillance Procedure 8.7.4.4, Main Steam Isolation Valve Trip, written to satisfy Technical Specification 4.7.D.1.b.(2), requires verifying closure time of the main steam isolation valves when tripped individually.

Procedure 8.7.4.4 contained acceptance criteria allowing the test to be performed at less than 60%

reactor power whereas Technical Specification 4.7.D.1.b.(2) requires that the surveillance test be performed at less than 50% reactor power.

Surveillance tests performed May 28, 1978 and February 18, 1978 were conducted at reactor power levels of 55% and 52.5%, respectively.

The above condition represents an item of noncompliance (deficiency) with TS 4.7.D.1.b.(2).

Prior to the conclusion of the inspection, the licensee issued a procedure change bringing Surveillance Procedure 8.7.4.4 into conformance with the 50%

reactor power limitation.

Further, the licensee representative stated that a TS change will be submitted to remove the power restriction requirement.

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(2)

During the review of Surveillance Procedure 8.7.4.4, Main Steam Isolation Valve Trip, the inspector noted that the acceptance criteria required a closure time of from 3.0 to 5.5 seconds, whereas Technical Scecification (TS)

Table 3.7.1 requires a closure time of from 3.0 to 5.0 seconds.

The additional half second is footnoted in the accertance criteria as being due to the lag time fron when the valve actually closes, to when indication of closure is received in the control room throuah position indicating lights.

Elsed on a sample review of closure time data, recorded f rom the control roon, the inspector founo no instances of closure time greater than 5.0 seconcs.

The acceptance criteria did not appear to take into consideration the half second response time for the minimum 3.0 closure time TS requirement as had been the case for the maximum 5.0 second TS requirement.

The licensee representative acknowledged the di crepancy in s

the acceptance criteria of Procedure 8.7.4.4, and issued a procedure change to require a minimum closure time of 3.5 seconds.

Further, data from the latest surveillance test, performed March 4,1979, contained closure times of 3.1 seconds and 3.0 seconds for nain steam isolation valves 203-lA and 203-1B, respectively.

Durina a sub-sequent telechone conversation with the licensee reoresentative, the inspector was notified that a surveillance test was performed March 28, 1979 and the valves above had closure times which met the acceptance criteria.

The inspector informed the licensee representative that documentation is required to substantiate the additional half second footnoted in the acceptance criteria.

The licensee representative acknowledged the inspector's comment.

This item is unresolved pendina NRC.RI review of the documentation associated with the accentance criteria of Procedure 8.7.4.4 (50-293/79-04-02).

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(3)

During the review o# Surveillance Procedure 8.5.1.1, Core Spray Pump Operability and Flow Rate Test, the inspector noted that the monthly surveillance, performed September 7,1978, contained pump flow and discharge pressure values for the 'A' Core Spray pump which did not appear to satisfy the acceptance criteria of the procedure.

The licensee representative had documented

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the fact + hat the results did not appear to satisfy the acceptance criteria and that further review was requit3d.

However, at the time of the inspection no documentation could be located to stbstantiate that a retest had been performed.

The inspector reviewed all surveillance tests performed after the September 7,1978 test, and found the results acceptable.

The above item is unresolved pending licensee retrieval of documentation supporting the performance of the retest, and suosequent NRC:RI review (50-293/79-04-03).

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6.

Insdector Witnessing of Surveillance Tests i

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a.

The inspector witnessed the performance of surveillance testing of selected components to verify the following.

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Surveillance test procedure was available end in use.

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Special test equipment required by procedure was cali-brated and in use.

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Test prerequisites were met.

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The procedure was adequately detailed to assure perform-ance of a satisfactory surveillance.

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b.

The inspector witnessed the performance of:

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PN 8.M.2-6.7, Suppression Chamber Water Temperature, Revision 3, May 11, 1977, performed March 21, 1979.

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PN 8.9.1, Manually Start and Load Each Die;.

.nerator Once Pe.' Month, Revision 9, August 9,1978, performed March 21, 1979.

No items of noncompliance were identified.

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7.

Technician Qualification The inspector reviewed the qualification records of selected tech-nicians having responsibility for calibrat;on and surveillance tests of safety related systems and components to verify that the individuals' experience level and training were in accordance with ANSI N18.1, Selecticn and Training of Nuclear Power Plant Personnel.

No items of noncompliance were identified.

8.

Control Room Operations The inspector observed control room operations on both day and evening shifts for proper control room manning, and facility operation in accordance with selected Administrative and Tech-nical Specification requirements.

No items of noncompliance were identified.

9.

Unresolved Items Unresolved items are findings about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviations.

Unresolved itens disclosed during the inspection are discussed in Paragraph 5.c.

10.

Exit Interview The inspector met with licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on March 23, 1979.

The scope and findings of the inspection were summarized.

The findings were also reviewed in subsequent telephone discussions between Mr. R. Zimmerman and Mr. J. Fulton on March 27 and 28, 1979.

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