IR 05000293/1987038

Insp Rept 50-293/87-38 on 870831-0904.No Violations or Deviations Noted.Major Areas Inspected:Licensee Efforts to Improve QA Program Re Qa/Qc Overview & Corrective Action Process as Discussed in Restart Plan & Previous Items

ML20236B396
Person / Time
Site:	Pilgrim
Issue date:	10/19/1987
From:	Blumberg N, Hunter J, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236B386	List: IR 05000293/1987038 ML20236B382
References
50-293-87-38, NUDOCS 8710260159
Download: ML20236B396 (9)

Text

_ _ _ _ . _ . _ _ --

, _ ,

'

'

. , 1 .

7 i-

[4 hh .;

,

,

L7 - 1:

g

U.S.' NUCLEAR REGULATORY, COMMISSION-REG {0N' '

~ Report'. N /87-38-Docket'N . Li cen s.e L N DPR-35-

Licensee: Boston Edison Company M/C Nuclear ) l 800 Boylston Street Boston, Massachusetts 021I19 q

'

Facility'Name: Plymouth Nuclear Power Station Inspect. ion At: Plymouth and Braint'ree, Massachusetts i

Inspection Conducted: August 31 - September 4, 1987 '

i

!

Inspectors) . A" /0f/Th7 G.Napuda,pniorReact ineer . da te '

W4A J. G. Hunter, III, Rea tor ngineer e "

lo/te//17 date J

,

Approved.by: -'

/Y N. Blumberg, Chief,. ./ date i

' Operational Programs- Section, i Operations Branch, DRS Inspection' Summary: Ro'utine unannounced inspection on August 31 -

. September 4, 1987 (Report No. 50-293/87-38).

' Areas Inspected: - Licensee efforts.to improve thy QA Program with respect to-QA/QC overview and the corrective action process as discussed in the Pilgrim RestartLPlan and, previously identified iten:.s, The inspection was conducted by two region based ^ engineer .Results: No violations or deviations +ere identifie r

.

s B710260159 PDR ADOCK h %93ppg

' '

G  !

_ _ _ _ _ _ _ = _ _ _ - _- .

_ __ _ _

.

. _ _ _ .

.

.

DETAILS 1.0' Persons Contacted Boston Edison Company (BECO)

• S. Bibo, QA Audit Group Leader

• H. Brannan, QA Manager

• M. Brosee, Outage Manage *F. Famulari, OQC Group Leader

• Grazio, Field Engineering Section Manager P. Hamilton, Compliance Group Leader

• S. Hudson, Operations Section Manager

• B. Lunn, Compliance

• J. Mattia, QA Surveillance Group Leader

• K. Roberts, Nuclear Operations Manager F. Schellenger, QA Engineering Group Leader

• J. Seery, Technical Section Manager United Statas Nuclear Regulatory Commission (USNRC)

• T. Kim, Resilent Inspector J. Lyash, Re;ident Inspector

• Denotes those present at the exit meeting held on September 4, 198 During the. course of the inspection, other licensee technical, operations, QA/QC and administrative personnel were also contacte . Previously Identified Items (0 pen) Unresolved Item -_ 50-293/83-03-05. On February 8, 1983, the resident inspector provided the licensee with a list of 73 questions concerning inconsistencies between various documents (Final Safety Analysis Report (FSAR), Technical Specifications (TS), procedures and station memoranda) for Primary Containment Isolation Valves (PCIVA). The Licensee, in Office Memorandum RA&P 86-016, dated January 31, 1986, responded to 71 of the 73 concerns and indicated that the two remaining questions were still under review The inspector discussed the status of this item with the licensee and reviewed their responses in Office Memorandum RA&P 86-016. The inspector

. verified that the required changes relating to the 71 responses were made to achieve consistency between the station memoranda and procedure During the course of the review, the inspector also identified 8 more inconsistencies between the licensee's responses, the station memoranda and procedures, and a need for additional updates to the FSAR. These concerns were discussed with the licensee who acknowledged them and stated that they would be addresse The inspector also determined that

_ _ _ _ _ _ i

7 c

..

• , .

w y .^.. '

u * '~

J lV) b [m $g l M

. .

w

.

y '

.

v; W,p

.

~

'

'

,

,#

t h Qf .g l

, r g.- 3 s

} .,

- 't

.the required: revisions to the FSAR a'nci TS discussed in the licensee's l responses have not been~ completed. This' item <remainsiop # pending NRC'.

review of.the resolutions of the two open questions'and p o newly ,

ldentified-discrepancies and review of the updated applicable FSAR a rd TS ,

sections.- A r,

'

' s' ,,. . ///,

(Closed)'IFI 59-2a3/84-02 LO Large MaintenancqRequest (:iR) backlog.0, The-'1".censeeedahlisheda'PlanningandSchedulingSection'(P&SS)in early 1986:tc ;sde'dule' and track maintenance activities. Their efforts were.dirqcted towards alleviating.the large backlog of MRs. The

?licensapMs progress in-dispositioning the large backlog of MRs has previo'usly been? reviewed in NRC Inspection Reports 50-293/86-27, 86-29 and G7 o, p 7+

b-The in's,f .

. . .

pector'determin9d'that presented to management;oneekly a w,various MR performance buis to ensure awarenessindicators Jf are developirig ircrids The variab's beihg trended' include' total open K%

MRs requiredi for restart, overdue preventive maintenance (PM an;f '

-

maintenance 1 organization running e4 pair MRs (capabli of;beidg), / #

f

/ .

accomplished during normal plant'onerations). .,.

' "k

-

vt o ./l

.MRs and those assigned to the main There [tenance are organ approximately.3100 total MRs of which approximately 1675 are in the ,

working, testing or c1gseouO phase. TheA9ciffM1Rs related to the 4

,

Construction Managemhnt' Group include apprsimat'eTy 80lf MRs with approximately350inthe) working,-testing'orclosecutphas ~

The ,

maintenance organization,is responsible;for approximately 2200 MRs of 1 which approximately 12?S are,in the work 1pg, testing 7or closecut phase.,

',

j

/ i Theilicensee has categorized backlog mair,tenance organization MRs os / 1 those which are corrective maintenance riraning repaWF. The inspestor y '

determined from licensee trends, that the maintenance' organization has  %

dispositioned a significant number of the backlog'MRs and reduced their, number from approximately 1200 in October of'M86 to approximately 525 as of August 28, 198 ,

, ;

The inspector also discussed.PM activities with the licensee and c determined that approximately 65 electrical, 8 mechanical and 35 instrument and co, col PMs were. overdue. The majority of these can be ,

attributed to the outage work'and the fact that many of the systems are ,

inoperable. Those types of- PFs will be performed at the completion of the ,l K outage when the systems are returned to service. The PMs are integrated ' '

( into the maintenance schedulew on a routine basis by the planner '

!

, e

-  ;

>

/ 1 u

,

'

i

'

I i

',

J l '. h  :( ' I

' '

L t i _-__._--____D

_ _ - _ _ _ _ _ _ _ _ ,

'

.

,

l

,

The licensee, through establishment of.the P&SS and development of l tracking and scheduling programs, has considerably reduced the number of backlog MRs.~ The maintenance organization's established goal of 500 backlog MRs has almost been achieved .and once achieved the backlog should

'

be maintained below the goal. Based on the aforementioned discussion and the conclusion drawn in NRC inspection report 50-293/87-36, this item is close )

{0 pen)IFI 50-293/85-26-0 Provide specific guidance on the use of  !

Maintenance Summary and Control (MSC) attachments to Maintenance Requests  !

'

(MRs).

!

The inspector reviewed Revision 21 of Procedure No. 1.5.3, Maintenance i Request The licensee, in this latest revision, added procedural guidance stating, "... The MSC is not to be used to make revisions to the MR that change the original intent of the work. The MSC shall be I numbered sequentially with a numerical suffix relating it to the MR..."

The changes that were made to the procedure were too general in scope and did not adequately resolve the open item. The inspector informed the  ;

licensee that instructions on the use of the MSC, including the '

responsibilities for initiation, review, approval and control, were not provided in the MR procedur The licensee, subsequent to discussions l with the inspector, indicated that the MR procedure will be revised to '

. include specific guidance on the use of the MSC form. This item will remain open, pending issuance of the revised MR procedure and NRC review of selected MRs to determine that the MSC system is not being abuse '

(Closed) IFI 50-293/85-16-01. Review implementation of licensee policy i on controlling contractor work at the station by QA overview. The  !

monitoring of contracted onsite work activities was reviewed in-depth i and is discussed in paragraph 4. Based on the results of that review this item is close (Closed) IFI 50-293/86-14-07. Failure to take corrective action in response to QA findings. The improvement of the corrective action process is addressed in the Pilgrim Nuclear Power Station Restart Plan and includes the area of. concern expressed in this item. An in-depth review of corrective action is discussed in paragraph 5 and this area will receive continuing review by the NR Based on the above and the results of the review discussed in paragraph 5 this item is administrative 1y  !

close (Closed)_ Unresolved 50-293/87-20-01 Licensee must evaluate the adequacy of the INPO criteria versus the BEQAM significance criteria and develop consistency between the BEQAM and implementing procedures to accurately reflect the method utilized to determine significance, i

e v-

___

- - _ - _ _ - _ _ . -.

-

.

The inspector reviewed Revision 16 of Procedure No. 1.3.2.4, Failure and'

Malfunction Reports (F&MR), which was reviewed.by the Onsite Review Committee.and is awaiting the Nuclear Operations Manager's approval and signature. The licensee, in revision 16, deleted the INP0 screening criteria and referenced the guidance for significance determination provided in section 16 of the BEQAM. This change made the F&MR criteria for determining significance consistent with the requirements of-procedures NOP 83A9 and N0P8305. The inspector also verified.that the

. licensee conducted training for the Sh4ft Technical Advisors (STAS), who are responsible for making the determination of significance of F&MR, to ensure their familiarity with the procedural changes. This item is close . Pilgrim Nuclear Power Station Restart Plan Items Volume-I,Section III.A.6(page III-12): Establish an interdisciplinary onsite QA Surveillance Group; dedicate two Quality Assurance Department '

,(QAD). Personnel onsite_to review procurement documents; and add one auditor and two inspectors to QAD staff. The assessment and status of

.this item is discussed in paragraph Volume I, Section'III.G(page III-32): Improve the corrective action process including the tracking of open QA items. .The assessment and status of this item is discussed in paragraph . QA/QC Interface and Overview An overall evaluation-of the Quality Assurance Department (QAD) was l performed during a previous NRC inspection and is discussed.in Report

<

No.'50-293/87-20. Boston Edison Company (BECO), the licensee, had transmitted a Pilgrim Nuclear Power Station Restart Plan (BEC0 Letter-87-130) to the NRC that described the programs, plans, and actions considered necessary by BECO management for safe and reliable restart and continued operation of the Pilgrim Nuclear Power Station (PNPS). 1 Volume I,Section III.A.6 addressed the changes and enhancements to

'the Quality Assurance Department. During this inspection an in-depth review of the onsite Surveillance Monitoring Group was conducted to determine the status of the enhancements and improvements implemented by the licensee in this area. Additionally, onsite contractor control by the offsite based Quality Engineering Group was reviewed. This group's responsibilities include overview of procurement related activitie The effectiveness of other licensee changes to the QA/QC overview effort were also reviewed and evaluated furthe .1 Surveillance Monitoring Group The Surveillance Monitoring Group currently consists of seven individuals and a supervisor. Recruitment efforts for an aiditional individual with Health Physics experience is ongoing. A review of j the staff's qualifications indicated that all held technical degrees, {

l

_ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ l

- - - - _ _ _ -

~

.

x v

a: broad _ spectrum of experience was represented and most individuals had extensive experience (e.g. licensed reactor operators, ' licensed marine engineer, Station Technical Assistant, U.S. Naval Reactor Program _ experience, 0perations QA Engineers).

A Master Surveillance Tracking System has been' developed and is used i for scheduling purposes. Approximately 42 functional areas are to be monitored during 1987 which include valve position verification ~, post maintenance testing, jumper / wire removal, core power distribution limits and determination of shut down margin Technical Specifications -J

.(TS). limits. Surveillance are scheduled. evenly throughout a month and an-individual.normally conducts two per week. It was noted that 46 surveillance were scheduled for August, 1987 and that seven and ten surveillance were ' conducted during backshift operations in July and August, 1987 respectivel Standard checklists have been developed when appropriate, such as for

. general tours of.the plant. :Also, QA. audit findings, NRC inspection findings, Licensee Event Reports (LERs), etc. are ' utilized to determine those. activities.to be surveilled. The plant Plan of.the Day is another source of infora tion used to plan surveillance. The supervisor stated that the daily olant meetings are attended during normal ope. rations as a further aid to plannin ;

4.2: Audit Group i

The Audit Group, located offsite at the corporate offices, currently consists of a supervisor and six auditor One vacant position has -;

been filled but not~ yet occupied and active recruitment is ongoing to !

fill the other two vacant positions. Arrangements have been completed with another utility to assign an auditor to the licensee on a

'

temporary. basis and.a contract has been executed with a vendor to provide auditing services on an as need basis until both vacant positions have been fille .3 Quality Engineering Group The corporate based Quality Engineering Group reviews Purchase Orders (PO) and this becomes one source of information that identifies that a given vendor could be or is working onsite. When a P0 is issued to a vendor who will perform work ons_ite the group develops a Contractor Surveillance Monitoring Plan for that specific contract that includes L hold _ points, areas to be surveilled and monitoring frequency.

l Examples of such overview are: eight surveillance of Bechtel during H the second calendar quarter that included welding, radiography, and procurement! and, 18 surveillance of Promatec during August.that included reviews of engineering drawings, observation of Magnetic Particle Testing and the installation of fire barrier Another indicator of this overview effort is the approximately 100

!

_- -

__ . _ _

. _

..

,

surveillance that were conducted of onsite vendors during July that included Diesel Generator work, HFA Relay maintenance and cable meggerin Two vacancies currently exist in the group, one of them occupied temporarily by a contracted individual. In an effort to enhance the effectiveness of PO reviews two members of the group have been permanently relocated recently to onsite office .4 Findings This assessment of the status of enhancements to the QA/QC overview effort indicated expanded involvement in the verification of quality, conduct of activities in accordance with established procedures (see j Attachment I), and increased involvement and support by managemen These actions were consistent with the licensee statements and l schedules contained in the PNPS Restart Pla No violations or deviations were identifie i 5. PNPS Restart Plan Corrective Action Systems '

The programs, plans, and actions considered necessary by Boston Edison Company (BECO) management for safe and reliable restart and continued operation of Pilgrim Nuclear Power Station (PNPS) were described in i the PNPS Restart Plan that was transmitted to the NRC by BECO Letter 87-130. Volume I,Section III.G.1 describes the changes and enhancements to Corrective Action Programs. During this inspection  ;

the status of enhancements and improvements to corrective action ,

programs was reviewed in-dept A contracted consultant had completed an evaluation of BECOs five different corrective action systems and submitted a report to the licensee, whose management established a four person task force that included a Quality Assurance Department (QAD) representative. This task force was directed to analyze the report, conduct additional research and develop recommendations for improving the corrective action proces Since membership on the task force was a corollary assignment to other duties progress toward the objective was considered too slow by QAD. QA0 then dedicated one individual to summarize the work done by the task force. The original task was then assigned to this individual who completed the evaluation and submitted a report to the Senior Vice President-Nuclear on August 31, 1987. This report describes and discusses four different options to improve the corrective action proces Further progress in this area now requires direction from the executive levels of managemen Efforts have also been ongoing to improve the effectiveness of the current corrective action proces The Boston Edison Quality Assurance Manual (BEQAM) has been revised to require explicit escalation of overdue or problem corrective actions and applicable

.___-___-a

_

, . - _ _.

n." -

-

L l

'

8 i

L procedures (see Attachment I) have also been changed to reflect the-i, BEQAM requirement Evidence that these requirements are being

'

implemented and the-corrective action process is becoming more

.

effective included

the followin As of August 28,1987 the total number of' Deficiency Reports (DRs)-

,

beyond.their due dates was down to. six from. greater.than 10 A weekly status report on overdue DRs is being issued to a range

~of supervisors and. managers that includes the Senior Vice President-Nuclear (SVPN).

--

Memoranda from the' Mana'ger QAD to the SVPN is being issued escalating overdue DRs (QAD-87-868 on use of an unapproved vendor, QAD-87-717 on refueling' floor conditions and QAD-87-480 on radwaste solidification i are examples).

--

Revisions to.the BEQAM and applicable procedures more. clearly delineate the method .for determining the significance level of Nonconformance-Reports (NCRs), and all issued NCRs are being reviewed for'conformance to this new guidanc Memoranda.from the' Manager QAD are issued to cognizant managers, with a copy to the SVPN, listing those corrective actions that will be escalated in 15 day The licensee is holding weekly meetings between the QA Manager, Station Manager and the-Senior Vice President-Nuclear to review items placed on an agenda; established by the QA Manager. The inspector reviewed various meeting minutes and determined that the meetings were being utilized to ensure that both plant and senior management were aware of QA concerns, plant and.QA trend reports and other pertinent information concerning safe operation of the plant. The QA department also conducts weekly meetings with Nuclear Operations personnel to discuss QA identified problems or concerns 'and the status of Deficiency Reports (DRs) resolutions. All QA department personnel are aware of the scheduled time for the meetings, are encouraged to and do attend the meetings to discuss their concerns. These informal meetings have been beneficial in resolving QA concerns and DRs in a:more efficient manner since they have established a stronger account-ability of the personnel responsible for handling specific problem The assessment of this area indicated that corrective action effectiveness has improved, efforts are continuing to effect further improvements to the corrective action process, and continued management involvement and support is evident. The status of licensee actions in this area are consistent with the statements and schedules contained in the PNPS Restart Pla No violations or deviations were identified.

-__ -__:____--

_ _ _ _ _ _ _ _ _ - _

,.

.. j

)

9 3 I

i 6. Management Meetings l

Licensee management was informed of the scope and purpose of the l inspection at the entrance meeting conducted August 31, 1987. The findings of the inspection were discussed with licensee representatives during the course of the inspection. An exit meeting was conducted on September 4, 1987, at the conclusion of the inspection (see paragraph 1 for attendees) at which time the licensee management was informed of the inspection result At no time during this inspection was written material provided to the licensee. The licensee did not indicate that proprietary information was '

involved within the scope of this inspectio !

l

__ -________ ___ _- ___ _. - __ _ _-_ _ _