IR 05000293/1987031

Insp Rept 50-293/87-31 on 870720-24.No Violations Noted. Major Areas Inspected:Licensee post-mod Test Program,Qa/Qc Interface w/post-mod Testing,Independent Verification & Plant Tours

ML20237H733
Person / Time
Site:	Pilgrim
Issue date:	08/12/1987
From:	Briggs L, Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20237H725	List: IR 05000293/1987031 ML20237H723
References
50-293-87-31, NUDOCS 8708250128
Download: ML20237H733 (6)

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,h b U.S. NUCLEAR REGULATORY COMMISS10d R5GION I

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Report N /87-31

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Docket N Licensa No. D6R-35 Licensee: Boston Edison Company M/ ~

Nuclear 800 Coylston Street Boston, Massachusetts 02199 Facility Name: Pilgrim Nuclea* Power Station Inspection At: Plymouth, Massachusetts Inspection Conducted: July 20 - 24,1987 Inspectors: Mk/#/8 7 L. Briggs, _ eactor Engineer, DRS date Approved by: ~

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P.EseTgroJt, Chief,TestProgramsSection date 08, DRSV Inspection Summary: Inspection on July 20 - 24, 1987 (Inspection Report N /87-31 Areas Inspected: Routine unannounced inspection of the licensee's post modification test program, QA/QC interface with post modification testing, independent verification and plant tour Results: No violations were identifie Note: For acronyms not defined refer to NUREG-0544 " Handbook of Acronyms and Initialisms".

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Detail

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1.0 Persons Contacted

• M. Akhtar, Modification Management Group Leader j T. Beneduci, Senior Modification Engineer

• M. Brosee, Outage Manager f' J. Gwyer, Senior QC Engineer

• R. Grazio, Field Engineering Section Manager

, E. Larssow, Senior QA Engineer (Surveillance)

• B. Lunn, Compliance Group Leader (acting)

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• J. Mattia, QA Group Leader

• A. ilorisi, Test and Turnover Manager

• K. '4oberts, Nuclear Operations Manager RC_ Personnel

• T. him, Resident Inspector

• J Lyash, Resident Inspector

• J. Wiggins, Chief, Reactor Projects Section 18, DRP, RI The inspector also contacted other members of the licensee's QA/QC and engineering staf * Denotes those present at the July 7,1987 exit meetin .0 Post Modification Testing 2.1 Program Review Scope 1 The inspector reviewed the licensee's post modification testing program to verify that the following aspects were administratively controlled through an established and documented progra Preoperational test program description l

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Means to identify necessary testing

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Test procedure format and content requirements

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Test organization and personnel qualification requirements and training .

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Formal system turnover and jurisdictional control requirements

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Formal administrative control of test procedure review, approval and issuance including changes to procedures

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Formal controls for temporary modification jumpers and bypasses

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Formal control of measuring and test equipment

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Discussion The inspector reviewed the procedures listed in Attachment A to determine the scope and depth of established controls of the pcst modification testing program. The inspector also discussed test director training with a new test director to further verify training content and scop Findings The inspector found the licensee's program as written in Modifications Management Work Instruction Manual to be acceptabl Minor administrative comments were discussed with the Modifications Management Group (MMG) Leader. These comments will be incorporated into the next revision of the Work Instructio No violations were identified in the above revie .2 Post Modification Preorerational Test (PMPT) Procedure Review S_ cope The PMPT's listed below were reviewed to verify compliance with the licensee's administrative controls for scope, content, licensee review and approval. They were also reviewed for format, test objectives, prerequisites, initial conditions, test data recording requirements and system restoratio Procedure No. TP 87-88, HPCI Vacuum Breaker Pre-Operational Test, Revision 0 (Draft);

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TP 87-55, Post Testing of NA-300 LPRM's and Under Vessel Cabling, Revision 1, approved June 17, 1987; and,

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TP 86-183, Pre-Operational Test after Fuel Pool Filter Replacement, Revision 1, Results approved by the licensee on January 30, 198 Discussion During review of TP 87-88, the inspector had two comment The acceptance criteria for stroke times of valves MO-2301-33 and M0-2301-34 were not specified in Section VII (performance portion of the procedure) but were identified in Section II. The generic state-ment concerning sequence of performance of procedural steps within the procedure appeared to ' eave too much to test director discretion since this procedure was not written in discrete sections which could be tested individuall The MMG Leader noted that the procedure would receive a final review prior to approval and the inspectors comments would be incorporate _

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Findings The inspector found the procedures contained considerable detail and conformed to the licensee's program administrative requirement Reviews for detailed technical content of PMPT's will be reviewed during a future routine inspectio No violations nere identified within the scope of the above revie .0 QA/QC Interface with Post Modification Testing The inspector discussed QC involvement with post modification testing (PMT) with seve-al QC representatives and requested copies of QC inspection reports covering PMT performed under TP 86-183. The licensee provided QC Inspection Reports as follows:

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IRS 87-51, Surveillance of TP 86-183, performed January 18, 198 M&TE calibration was checked and portions of the test was witnesse No problems were observe IRS 87-61, Surveillance of TP 86-183, performed January.21, 198 Activities were similar to IRS 87-51 but testing was being conducted under a different test director. No problems were identifie IR 85-19-1, Surveillance of Maintenance Request 85-19-1 activities review and closecut, performed February 2,1987. QC engineer (Bechtel) noted that no open NCR's exist, no outstanding or "at risk" FRN's exist and that all work and inspection activities were completed and signed of No unacceptable conditions were identified during the above revie .0 Independent Verification The inspector performed an independent review and verification of the licensee's in place post modification testing progra No violations were identifie .0 Plant Tours The inspector toured various areas of the facility to assess plant and equipment conditions including cleanliness, fire hazards and work in progres No unacceptable conditions were observed.

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6.0 Exit Interview

'At the conclusion o'f the site inspection, on July 24, 1987, an exit interview was conducted with the licensee's senior site representatives (denoted in Section 1). The findings were identified and inspection items were discusse At no time during this inspection was written material provided to the licensee by the inspector. Based on the NRC Region I review of this report and discussions held with licensee representatives during this inspection, it was determined that this report does not contain information subject to 10 CFR 2.790 restriction ,

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Attachment A Procedures Reviewed to Assess Post Modification Preoperational Testing Program

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Modification Management Work Instruction Manual, January 12, 1987

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Procedure 1.3.4, Procedures, Revision 30

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1.3.13, Plant Design Changes, Revision 15

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1.3.23, 10 CFR 50.59 Safety Evaluations, Revision 10

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1.4.5, PNPS Tagging Procedure, Revision 19

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1.5.3, Maintenance Requests, Revision 19

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1.5.9, Temporary Modification, Revision 9

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Nuclear Operations Procedure (NDP) 83A2, Station Configuration and its Control, Dated March 21, 1983

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NOP 83A6, Modification Management, August 31, 1984

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NOP 83A12, Outage Management, October 19, 1985

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NOP 83E1, Control of Modification to Pilgrim Station, June 14, 1987

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NOP 85E5, 10 CFR 50.59 Safety Evaluations, August 16, 1986 l

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