IR 05000293/1987033
| ML20238A790 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/20/1987 |
| From: | Briggs L, Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20238A760 | List: |
| References | |
| 50-293-87-33, NUDOCS 8708310211 | |
| Download: ML20238A790 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
l Report.No.
50-293/87-33
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. Docket No.
50-293 License No.
DPR-35 Licensee:
Boston Edison Company M/C Nuclear 800 Boylston Street-Boston, Massachusetts 02199 Facility Name:
Pilgrim Nuclear Power Station Inspection At:
Plymouth, Massachusetts
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. Inspection Conducted: August-3-7, 1987
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Inspectorsi ~
4M 8 /.s70 / # 7 L. Briggs, laid Reactor Engineer, DRS date Approved by:
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P.'Eselgr ', Chief, Test Programs Section
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ddte 08, DRS j
Inspection Summary:
Inspection on August 3-7, 1987 (Inspection Report i
No. 50-293/87-33)
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Areas Inspected:
Routine unannounced inspection of the licensee's post I
modification test program preoperational test procedure review, QA/QC interface with post modification testing, independent verification and plant tours.
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Results: One violation was identified for failure to adequetely review a design package and its associated post maintenance preoperational test, l
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Paragraph 2.2.
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Note:
For acronyms not defined refer to NUREG-0544 " Handbook of Acronyms and l
Initialisms".
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8708310211 870821 PDR ADOCK 05000293 G
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DETAILS A"
'1.'0PersonsContactfdc
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- M.'Akhtar,< Modifications Management Group Leader
- T. Beneduci, Senior Engineer, Modifications Management
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- N. Brosee, Outage Manager-
- R.,Grazio, FieM Engineering Sectinn Manager
- P. Hamilton, Cortpliance Group Leader
' * S, Hudson," Operations'Section Manager-
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' B. Lunn, Compliance Engineer
" J..Mattia, QA, Group Leader
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' * A. Morisi,- @ pt and Turnover Section Mantger
> l * K. Roberts, Station Nnager i
- .R. Schifone, QA k
NRC
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- fN. Blumburg, Chief, Operational Programs'Section
- J. Lyash, Resident Inspector The inspector also contacted other memebers of the licensee'4 QA/QC and-technical statf.
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- Denotes those present at the August 7, 1987, exit meeting.
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2.0' Post Modification Preoperational Testing (PMPT). Procedure Review l
2.1 Scooe
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The PMPT's and Plant Design Changes (PDC's) listed below were
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reviewed in preparation for test witnessing.
The PMPT's were j
' reviewed for, technical and administrative adequacy and for
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verification that testing is planned to adequately satisfy a
regulatory svidance and licensee commitments.
They were also reviewed to vsrify licensee review and approval, proper format, test
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' objectives, prerequisites, initial conditions, test data recording requirements and system return to normal. The PDC's were reviewed to determine what changes were made to the associated system and to provide a bases for the determination of PMPT scope necessary to verify the system's modified design.
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'f PDC 86-70, Standby Gas Treatment System Modification; j
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PDC 82-25, 011 and Vibration Alarms Modification on
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Recirculation Pump Motors;
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PDC 85-59, HPCI Exhaust Vacuum Breaker; TP 87-128, Pre-Operational Test of Standby Gas Treatment System
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Modification Per PDC 86-70, Revision 1, dated July 20, 1987; r
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TP 86-95, Pre-Operational Test.of Oil Level and Vibration
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System on the Recirculation Pumps, Revision ~1, dated June 11, 1987;'and, TP.87-88, HPCI. Vacuum Breaker Pre-Operational Test, Revision 0
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1, (draft).
2.2. Discussion During the review of TP 87-128 the inspector noted several areas of the. test procedure that were either in error or. did not' appear. to verify the design of the modified system. These items were discussed with one of the licensee's senior Modifications Management Group (MMG) engineers.
The' engineer and licensee management agreed with the inspector that the following errors / omissions should tave been identified.
a.
Paragraphs 7.'2.5, 7.3.5 and 7.4.5 required 5 damper control switches-to be in the. auto position and their associated dampers in the open position. The associated dampers would be in the closed position with'the specified switch position and no initiation signal present, b.
Section 7.3.8.and 7.3.8.9-did' not require verification tha't.
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valve A0N-112 closed when the
'B'. Standby' Gas Treatment System-
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(SBGTS)-fan tripped (per procedure).
Inlet valve A0N-106 was verified as closing.
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Paragraph 7.3.8.6 required the differential pressure across the calibrated orifice plate'(DPI-AA-32) in the
'B' SBGTS train to be recorded with the 'B' SBGTS fan in standby (off).
This reading was being taken to measure 'B'
train bypass flow so it could be combined with 'A' train to determine system flow.
Under the system conditions specified this reading would be zero
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(0) since one of the SBGTS modifications moved the upstream i
bypass flow connection such that the connection between the A
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and B SBGTS trains is now downstream (bypassing) of the l
calibrated orifice plate.
The flow recorded on the 'A'
calibrated orifice plant would represent full system flow ter
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the specified lineup.
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Train 'B' logic requires A0N-106 damper (inlet) to open and
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pick up a position limit switch which allows the 'B'
SBGTS fan to start and outlet damper A0N 112 to open.
This logic sequence would occur during any start of the 'B' SBGTS train and was not-
checked in TP 87-128.
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The procedure did'not verify that per design the 'B'
SBGTS i
train would remain running after 20 minutes if the
'A'
train
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p h-l had. insufficient flow or.was tripped with the 'B'. train in standby, The system is designed to trip the 'B'
train after 20 minutes if sufficient flow exists.
The inspector discussed the above items with the licensee and reviewed the other TPs and PDCs identified in Paragraph 2.1 above.
It_was. observed that the other PDCs provided a more defined level of testing requirements.
PDC 86-70 did not specify any electrical or logic checks while PDC 85-59 and 82-25 did.
The inspector noted that the Boston Edison Quality Assurance Manual-(BEQAM) Paragraph 3.3.2.7 and 3.3.2.8 specifically requires the cognizant design organization, in this case Boston Edison Nuclear Engineering Department (NED), to specify acceptance criteria and methods for verifying' design changes,
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such as qualification testing.
It was also noted that the Modifications Management Work Instruction Manual (MMWIM), dated January 12, 1987, in Section 10 requires the Maintenance Modification Group (MMG) to determine preoperational
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testing (POT) requirements and to prepare POTS to satisfy all
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aspects of required testing.
The inspector also observed that throughout the. entire review chain for this' PDC and TP that these deficiencies (lack of specified testing required to verify design and PMPT errors) were not identified and corrected. The licensee as part of their immediate correc+ive action statect that an independent, 3 man review group will be established, with no concurrent duties, to review PMPT's initiated for implementation during this outage.
The review of the remaining PMPT's did not'ider.tify any procedural deviations from the system design as described in the PDC.
2.3 Findings The above examples relative to PDC 86-70 and TP 87-128 constitute a violation of the requirements of 10 CFR 50 Appendix B, Criterion VI and BEQAM, Section 6, Document Control, for failure to perform an adequate review (293/87-33-01).
3.0 QA/QC Interface with Post Modification Testing 3.1 Scope The inspector requested all QC inspection reports (QCIR) associated with PDC 86-70 (SBGTS) and 82-25 (Recirculation Pump) which were implemented under maintenance requests 87-48-12 (SBGTS) and 86-2-49 j
and 86-2-50 (Recirculation Pump).
The following QCIR's were j
provided the inspector.
They primarily deal with the installation of i
the modifications since testing of the modifications were in the l
very early stages during this inspection, i
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i 3.2 Discussion
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QCIR 87-048-12A, Instrument Calibration (SBGTS) performed July 22, 1987 The QC inspector witnessed calibration of 2 separate
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instrument loops being performed in accordance with an approved
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procedure and also verified calibration status of all test equipment being used.
No deficiencies were noted by the QC inspector.
QCIR 87-980, verification of correct installation of switch
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42.1426-CS (SBGTS B train fan) performed August 2,1987. The QC inspector observed that the switch was installed in accordance with the PDC.
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QCIR 87-14, Surveillance of the drilling of anchor bolt holes for hangers on the 41 foot 6 inch elevation of the reactor building, performed on January 6, 1987.
No discrepancies were observed by the QC inspector.
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QCIR's 87-75 and 87-81 concerned the witnessing of cables being pulled into the cable spreading room and into the control room.
They were performed on January 27 and 28, 1987. No discrepancies were observed by the QC inspector.
3.3 Findings No violations were identified in the above review.
4.0 Independent Verification During the review discussed in Paragraph 2.2 the inspector independently calculated the various voltages required to give the desired vibration readings during the recirculation pump vibration monitor calibration check in TP 86-95.
The inspectors calculations agreed with those contained in the procedure.
5.0 Plant Tours The inspector toured various areas of the facility to assess plant and equipment conditions including cleanliness, fire hazards and work in progress.
No unacceptable conditions were observed.
6.0 Exit Interview At the conclusion of the site inspection, on August 7, 1987, an exit interview was conducted with the licensee's senior site representatives (denoted iri Section 1).
The findings were identified and inspection items were discussed.
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- 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 licensae representatives during this inspection, it was determined that this report does not contain information subject to 10 CFR 2.790 restrictions.
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