IR 05000293/1982013
| ML20053A689 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/06/1982 |
| From: | Caphton D, Eapen P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20053A678 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM 50-293-82-13, NUDOCS 8205270132 | |
| Download: ML20053A689 (7) | |
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U. S. NUCLEAR REGULATORY COMMISSION Region I Report No. 50-293/82-13 Docket No. 50-293 License No. DPR-35
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Priori ty
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Category C
Licensee:
Boston Edison Company 800 Bovlston Street Boston. Massachusetts 02199 Facility Name:
Pilarin Nuclear Power Station Inspection At:
PilcJrim Nuclear Power Station and Corporate Offices Inspection Conducted:
April 12-16, 1932 Inspectors:
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i P. K. Eapen, Ph
., Reactor Inspector date signed
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date signed Approved By:
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h dN D. L. 'Capo o, Chief, Management Programs d'ee signed Section, EPB f.nspection Summary:
In_spection on April 12-16, 19S2 (Regort No. 50-293/82-13}
i Routine, unannounced inspection of facility modifications.
The inspection involved 36 inspection hours onsite and 8 inspection hours at the corporate offices by one regien based inspector.
Results: One violation was observed in the inspected area, inadequate design controls for design interface and design verification.
(See paragraph 2.e)
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DETAILS 1.
Persons Contacted
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J. Ashkar, Deputy Engineering Manager E. Cobb, Startup Test Engineer
- J. Coughlin, Site Engineering Representative
- W. Decon, Nuclear Operations Supports (Acting)
R. Fairbank, TMI Project Manager
- N. Gabriel, Records Management Engineer
"E Graham, Senior Plant Engineer J. Howard, Vice Fresident - Nuclear
- C. Hulteen, Group Leader, Construction Management P. Kahler, Licensing Engineer
- R. Machon, Nuclear Operations Manager
- M. McLaughlin, Senior Compliance Engineer D. Mills, Project Manager, Torus Modifications A. Morisi, Startup Manager H. O'Connor, Group Leader, Fluid Systems and Mecnanical Components
- L. Oxen, Director of Nuclear Operations Review D. Richard, ILC Engineer L. Rucker, Group Leader, Systems and Safety Analysis T. Sowden, Group Leader, Env. and Rad. Health and Safety
- T. Thurston, TMI Project Engineer J. Voeixen, Project Engineer NRC
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- J. Johnson, Senior Resident Inspector
- H. Eichenholtz, Resident Inspector The inspector also held discussions with and_ interviewed other members of the Power Station and Boston Edison Corporate Technical and Administrative Staff.
- denotes those present at the exit interview conducted onsite, April 16, 1982.
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Design Change / Modification Control a.
References
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ANSI N 45.2-1977
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ANSI N 45.2.11-1974
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Regula Guide 1.64
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Boste Company Quality Assurance Manual Volume II, Sect
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Nuc ering Department Procedure No. 3.02, (Revision 7)
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Nuc ngineering Department Procedure No. 3.05, (Revision 4)
b.
Review
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The design change packages listed in c.,
below, were reviewed on a sampling basis to verify that the following requirenents have been ret, as applicable:
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Design Input Requirements, such as design bases, regulatory requirements, codes, and standards were identified, documented and their selection reviewed and approved.
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Design activities shall be prescribed and accomplished in accordance with procedures that would assure the applicable design inputs are correctly translated intc specifications, drawings, procedures, or instructions.
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Interface controls sere established to identify, control and maintain responsibilities, lines of cemmunications, and document-ation requirements for internal and external interfaces.
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Design verification was established to determine the adequacy of the design to meet the requirements specified in design inputs.
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Dccument control procedures were established to control the issuance of design documents and their changes.
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Design change control procedures were established to control design changes.
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Design documentation and records were maintained.
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Audits were conducted to verify ccmpliance with all aspects of OA programs for design and design changes.
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New or modified systems were installed in accordance with the approved design.
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New or revised procedures relating to the modified system were
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completed and appr, sed for technical specifications.
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As built drawings were revised to reflect modifications.
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The operators were trained to use the modified system.
c.
Document / Record Pac _kages The inspector reviewed the following Plant Design Change Requests (PDCR's):
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PDCR 79-59, Torus Water Level Indication
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PDCR 79-61, Containment High Range Radiation Monitor
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PDCR 77-78, Acoustical Monitors for Safety Relief Valve Position Indication
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PDCR 81-34, Inadequate Core Cooling Instrumentation
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PDCR 80-63, Modification of Break Detection Logic to P-event Spurious Isolation of HPCI/RCIC Systems
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PDCR 81-06, Torus Modifications
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PDCR 81-27, RPS Shutdown Scram Reset Interlock
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PDCR 79-62, Noble Gas Detectors t
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PDCR 81-66, Cut and Cap CRD Line d.
Detailed Interviews and Examination of Certain Documents The inspector interviewed cognizant Engineering personnel both at the plant site and at the Corporate headquarters to determine the effectiveness of the licensee's design control program as they related to the PDCP's listed in item c above.
The following documents in each of the PDCR's were reviewed to verify the adequacy of the licensee's engineering overview and administrative controls for design modifications:
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Design Requirements
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Design Drawings
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Design Verification
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Safety Review e.
Findings The inspector noted an apparent lack of interface control in the area of design modifications, as evidenced by the following:
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(1) PDCR 79-61 indicated that the installed high range containment radiation monitors did not meet the photon energy range, linearity requirements for detection, dose detection range and the physical separation requirements of Item II.F.1, Attachment 3 of NUREG 0737.
The licensee is using an alternate approach for this design.
Due to lack cf interface control the specific requirements of NUREG 0737 were not translated into the procurement document (Purchase Order No. 22250); the differences between the design and the NUREG 0737 requirements were not clearly identified; and, the deviations from NUREG 0737 were not reported to the NRC by July 1,1981, as specified in NUREG 0737.
The inspector informed the licensee's representatives that this is an example of the violation discussed below.
(2) PDCR 79-59 indicated that the differential pressure transmitters for the Torus Water Level indication would be qualified to IEEE-323-1971 requirements.
This is contrary to the requirements of NUREG 0737 Item II.F.1, Attachment 5.
The engineering staff was unable to procure the appropriately qualified transmitters due to the limited supply of qualified transmitters. A decision was then made to install transmitters that were qualified to IEEE-323-1971 for the interim.
The installed transmitters are to be replaced with qualified units as they become available.
The licensee representatives indicated that this problem would be followed under the activities required by NRC Rolletin 79-01.
The inspector told the licensee representatives that the above approach should have been presented to the NRC for relief.
Due to inadequate controls in the design modification program, engineering personnel failed to transmit this design difference to their licensing personnel for submittal to the NRC.
The inspector informed the licensee's representatives that this is also an example of the violation discussed below.
(3) The bases for Safety Evaluation Reports were not adequately documented in a number of PDCR's (e.g. PDCR 77-78, 79-62, and 80-63).
Due to the heavy work lead the Cognizant Engineer, (who is also the Safety Reviewer) does not always document the bases for the safety evaluation; perform detailed review of design documents furnished by other corporate groups and outside contractors; and assess the adequacy of the design to meet the design requirements.
A licensee representative informed the inspector that the seismic qualifications for NUREG 0737 mod-ifications were performed to the licensee's FSAR commitments and not to IEEE-344 1975 as required by NUREG 0737.
The inspector advised the licensee's reoresentatives that this difference should have been brought to the attention of the NRC under the provisions of Mr. Eisenhut's letter dated October 31, 1980.
The inspector informed the licensee's representatives that the above examples are contrary to 10 CFR 50, Appendix B, Criterion III and
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Regulatory Guide 1.64 (Rev. 1) (as endorsed by Boston Edison Quality Assurance Manual Volume II Section 3) and collectively constitutes a violation (50-293/82-13-01).
The inspector presented the findings to the Deputy Engineering Manager and informed him that the Design Control Program was weak and did not meet the intent of Regulatory Guide 1.64.
The Deputy Engineering Manager stated that a detailed review of the Design Control Program would be conducted; weaknesses would be identified; the program would be modified to conform fully with the requirements of ANSI N 45.2.11-1974 as endorsed by Regulatory Guide.1.64; Procedures would be written; and, the Engineering Groups would be staffed and trained to perform design modifications under the revised program.
Schedules and other details for this program will be provided to the NRC upon receipt of higher management approval.
At the conclusion of the inspection at the corporate offices on April 14, 1982 the inspector met with the Vice President - Nuclear and the TMI Project Manager to discuss the inspection findings and the commitments made by the engineering staff. The Vice President acknowledged the inspector's findings and stated that the design control program would be reviewed and revised along with the ongoing activities in response to the NRC order dated January 18, 19S2,
" Modi fying (the) License, Ef fective Immediately" 3.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, deviations or violations.
No unresolved items were identified during this inspection.
4.
Exit Interview The inspector net with the licensee's representatives denoted in Paragraph 1 at the conclusion of the inspection on April 16, 1982 to summarize the findings cf the inspection as detailed in this report.
The inspector informed the licensee's representatives that these findings should ba considered to be symptoms of an inadequate design control program.
The inspectcr further stated that the violation was cited against the design control program; +herefore, merely correcting inspector identified items would not constitute an acceptable corrective action; and the revised program should meet the requirements of ANSI N 45.2.11 -
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ndorsed by Regulatory Guide 1.64 (Revision 1).
The licensee representatives acknowledged the inspection findings and made the following commitments:
(1) A detailed review of all installed NUREG 0737 modifications would be conducted.
Differences between the as installed design and NUREG 0737 requirem.ents would be identified and submitted to the NRC by May 17, 1982 (IFI 50-293/82-13-02).
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(2) Schedule and other details for design modification program review would be provided in the response to the Notice of Violation.
The inspector acknowledged the licensee's commitments.
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