IR 05000293/1987042
| ML20236V921 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/20/1987 |
| From: | Bissett P, Blumberg N, Marilyn Evans, Finkel A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20236V916 | List: |
| References | |
| 50-293-87-42, NUDOCS 8712070176 | |
| Download: ML20236V921 (14) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-293/87-42 Docket No.
50-293 License No.
DPR-35 Licensee: Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station Inspection At:
Plymouth, Massachusetts Inspection Conducted:
September 28 - October 2, 1987
- !/N Inspectors:
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pN P. Dissett, Senior Operations Engineer d'a te 0-N A $?
E F16kel, Senior Reactor Engineer date
. (mv ll l0 $Y M. Evans, Operations-Engineer date Approved by:
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N N. Blumberg, Chief, Operf ional Programs
'date Section, Operations Br(nch, DRS Inspection Summary:
Routine, Unannounced Inspection on September 28 -
October 2, 1987 (Report No. 50-293/87-42)
Areas Inspected:
Routine, unannounced inspection of licensee actions on previous inspection findings, corrective action for confirmatory action letter
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concerning RHR System and the licensee's Material Condition Improvement Action Plan.
l Results:
No violations or deviations were identified.
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L DETAILS
'1.0 ' Persons' Contacted l
l Boston Edison' Company-k
- M.' Brosee, Outage Manager L
- R. Cannon, Compliance Engineer.
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.J. Flannigan, MCIAP. Review Staff Leader
- R. Grazio, Fie_1d Engineering Section Manager
- S. Hudson, Operations Section Manager P. Moraites,-Assistaat Chief Maintenance Engineer
- K. Roberts', Nuclear Operations Manager R. Sherry,' Chief. Maintenance Engineer
- J. Poorbaugh, Senior QA Engineer t The inspector also held' discussions with other licensee personnel during-
.the course of the inspection.
- Denotes those pres'ent at t'he exit meeting on October 2,1987.
2.0 Licensee Action on Previous Inspection Findings 2.1 (0 pen) Unresolved Item (293/86-21-03):
Licensee to review completeness and adequacy of-Technical Specification (TS)
surveillance procedures for logic system functional testing (LSFT).
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This item was last updated in Inspection Report 50-203/87-41.
The licensee is continuing its efforts in-reviewing TS surveillance procedures for LSFT.
Resolution of identified deficiencies. and discrepancies is presently' ongoing with priority being given to procedures required for the reactor coolant system hydrostatic tests.
During inspection 50-293/86-21, the inspector identified four LSFT'
deficiencies while reviewing High Pressure Coolant Injection (HPCI)
system surveillance. test procedures.
In this inspection,.the inspector reviewed a preliminary report summarizing.the review of HPCI system LSFT conducted by the licensee's contractor.
Identified deficiencies and highlighted HPCI system elementary drawings were reviewed.
The inspector noted that all deficiencies identified during inspection 50-293/86-21 were addressed. No unacceptable conditions were' identified.
This item will remain open pending further review of.the licensee's efforts regarding LSFT including review of revised surveillance procedures.
2.2- (Closed) Inspector followup Item (293/85-28-04):
Licensee to review the adequacy of the preventive maintenance (PM) tracking program.
Discussions were held with principle maintenance representatives to i
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ascertain what reviews and changes had been made to the PM program and associated tracking system. Two Assistant Maintenance Supervisors (AMS) have been delegated the responsibility for ensuring that periodic PMs are tracked, scheduled, completed and documented. One AMS is responsible for routine-type PMs, (i.e., oil changes, vibration measurements) and the other AMS is responsible for special project-type PMs (i.e., motor operated valves and circuit breakers).
The validity and accuracy of the " Preventive Maintenance Item List" has been reviewed and updated as necessary, and is now considered to be z useful working tool for tracking and scheduling PMs.
It is issued on a weekly basis and is also being updated as new PM requirements are identified.
The status of the PM backlog is also depicted on performance indicator charts issued on a weekly basis.
The overall trend has shown a decrease in the number of overdue PMs. The majority of overdue PMs will be completed once steam is available to operate the equipment.
Variance reports are being completed for those PMs that were unable to be completed.
Based on the above, this item is closed.
2.3 (Closed) Inspector Followup Item (293/86-17-04):
The following evaluation is a status of the intersystem leakage througn the motor-operated injection valves of the residual heat removal (RMR)
system (hereinafter referred to as the "RHR Team") addressed in the NRC's Confirmatory Action Letter 86-10. The RHR Team items (IFI 293/86-17-04) consist of NRC identified problem areas to which the
. licensee addressed as 22 separate action items. The item numbers in this report are evaluations of the 22 licensee action items which collectively constitute IFI 293/86-17-04. All items have been reviewed, verified as complete and were closed during this inspection. Attachment I lists those documents reviewed by the inspector that support licensee actions in regard to the following RHR Team items.
2.3.1 Item No. RC 86-10-02.3 and RC 86-10-01.2 - Calibration of RHR pressure gages will be accomplished once per refueling outage.
Corrective Action:
Pressure gages for RHR 'A'
and 'B'
trains have been installed between motor operated valves (MOV) 1001-28A/B and (MOV) 1001-29A/B.
The gages are located in the vicinity of their respective equipment rooms near their system instrument racks. The maintenance request for the 'A' train (MR No. 86-10-37) was completed on June 11, 1986, and the 'B' train (MR No. 86-10-36)
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was completed on June 11, 1986.
Pressure gages PI-1001-30A/B, now scheduled for calibration once per cycle, were tested per Procedure No. 8.E.10, Revision 11, "LPCI System Instrumentation Calibration," on February 20, 1987. Test
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results for both instruments indicated that both gauges were within their required ranges. Based on the above, this item is closed.
-2.3.2 Item No. RC86-10-01.3 - System venting program, including adequate vent locations for local RHR high points, is to be developed.
Corrective Action: The licensee has prepared and issued
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procedure No. TP86-84, Revision 0, June 10,1986, titled
"RHR Discharge Piping Venting Procedure." This procedure i
provides directions for station personnel to vent air from
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the RHR discharge piping utilizing high point vents and is I
being used in conjunction with RHR system surveillance
procedures 8.5.2.2 and 8.5.3.3.
Based on the above, this i
item is closed, 2.3.3 Item No. RC 86-10-01.4 - Means are to be provided for measuring and monitoring RHR system temperature.
Corrective Action:
Temperature monitors have been installed on the RHR loops per maintenance request (MR) Nos. 86-10-36 and 86-10-37.
Pressure gages PI-1001-30A/B and pressure switches PS-1001-74A/B are calibrated per procedure 8E.10 at a frequency of once per refueling outage. Testing of the installed equipment was documented on test pages 8.A.16A-1, and data was found to be satisfactory. The above installation work associated with MR 86-10-36 has been documented in Quality Control Inspection Report No.
IR-86-10-36 "A" and "B".
Based on the above, this item is closed.
2.3.4 Item No. RC 86-10-01.6 - A'larm response procedure No. 2.3.2,1, will be revised to allow for control of repressurization and to provide additional assessment and corrective action. The revision will include requirements to log occurrence of alarm and require additional investigatory and evaluative actions.
Corrective Action: Alarm response procedure No. 2.3.2.1
" Panel Procedure Panel 903 Left" has been revised to incorporate additional operator actions and requires the operator to log times that alarms are received. Temporary
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procedure (TP) No. 86-85, "RHR Intersystem Leakage Assessment and Controlled Leakoff," discusses the RHR
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intersystem' leakage assessment and controlled leakoff L
concern. This procedure provides station personnel with a
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method and guidance for establishing a controlled leakoff of the RHR discharge piping to prevent increases in pressure due to leakage past the RHR injection isolation valves.
The following RHR Team items, as discussed within Section 2.3, were also completed to support this task:
RC 86-10-01.2 RC 86-10-01.4 Based on the above, this item is closed.
2.3.5 Item No. RC 86-10-02.1, RC 86-10-02.2 and RC 86-10-03.7 -
Test procedure acceptance criteria is required for testing pressure drop capability of 1001-68A/B check valves.
Corrective Action: Water testing is the preferred method being used to pressure test the 1001-68A and 1001-688 check valves.
Engineering Calculation (EC 86-278) established an acceptance criteria of a maximum leakage rate of 5 gpm at a test pressure of 1030 50 psig.
The licensee has prepared procedure No. 8.5.2.7, " Hydrodynamic Test for Measuring Leakage Thru RHR System" which contains acceptance criteria and provides test instructions to station personnel for performing hydrodynamic testing for the RHR 18" Loop LPCI Injection Valves No. 1001-29A/B, as well as the 1001-68A/B check valves.
The Test Block and Valve Lineup conditions for the 1001-68A/B check valve test is attached to the procedure No. 8.5.2.7.
The testing of these valves was performed on August 14, 1987, and September 20, 1987.
The valves passed the required tests and are scheduled to be retested during the next refueling outage. Based on the above, this item is closed.
2.3.6 Item No. RC 86-10-02.4 - Temperature markers will be checked once per week for any change in temperature.
Corrective Action: Temporary Procedure No. 86-85, "RHR Intersystem Leakage Assessment Method," provides
instructions on the method that the licensee will use in
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testing and measuring controlled leakage of the RHR pump discharge piping to the torus via the 2" RHF pump discharge check bypass valve H0-1001-1000, after pressurization by leakage past the RHR injection valves. Attachment B of TP 86-85 identifies the temperature marker locations for the l
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RHR Loop A and B piping in their respective valve room locations. A temperature survey data sheet is also part of this attachment. A RHR temperature marker surveillance was performed per TP 86-85 on September 11, 1987.
Based on the above, this item is closed.
2.3.7 Item No. RC 86-10-02.8 - Training of the operating staff on the RHR intersystem leakage issue will be conducted.
Corrective Action: As described in Item No. RC 86-10-02.4, the assessment of RHR intersystem leakage was performed in accordance with TP 86-85. A training session for operating personnel was conducted on the RHR intersystem leakage issue and documented in training records, dated June and July 1986.
The training course material was reviewed by tne inspector and found to be adequate.
Based on the above, this item is closed.
2.3.8 Item No. RC 86-10.02.10 - Pressure switches (PS) 1001-74A/B will be placed on a once per cycle calibration schedule.
Corrective Action:
RHR high pressure alarm switches 1001-74A/B have been placed on a once per cycle calibration schedule per procedure No. 8.E.10, "LPCI System Instrument Calibration."
During the most recent calibration, the actuation setpoint of the switches was found to be set at 360 psig.
Steps 49 and 50 of Procedure No.8.E.10 list the setpoint of 400 psig for PSH 1001-74A/B (adjustment limits are 388 to 412 psig.) The actuation setpoint was subsequently adjusted to approximately 400 psig.
The inspector has verified that item No. RC 86-10-02.10 has been complied with. A copy of the revised alarm procedure was submitted to Region I on June 16, 1986 in BECO Letter No.86-079 (item C.5.a.).
Based on the above, this item is closed.
2.3.9 Item No. RC 86-10-02.12 - Motor Operated Valve (MOV)
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1001-28B valve disk will be removed and evaluated or
restored during Refueling Outage No. 7 to confirm the wear
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rate.
Corrective Action:
The disc, stem nut pressure seal ring i
i and packing were replaced on both MOV's 1001-28A/B.
Engineering evaluation ERM 87-20 July 10, 1987 changed the i
valve disc material from ASTM A217 WC6 to ASTM A105.
The maintenance work was performed per MR 86-10-55 for MOV 1001-28A and MR 86-10-56 for MOV 1001-288.
Inspection of
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the valve maintenance work is documented in Quality Control Inspection Report Nos. IR-86-10-55A through F for the 28A valve and IR-86-10 and IR 86-10-56A through K for the 28B valve. Testing of the 28A and B valves has been documented on data sheets of Temporary Procedure No. TP87-135 (untitled).
Based on the above, this item is closed.
2.3.10 Items No. RC 86-10-02.13, RC 86-10-03.1 and RC 86-10-02.14 -
The feasibility of replacing or redesigning RHR check valves'to provide positive position indication will be evaluated.
Corrective Action: The licensee has issued Plant Design Change (PDC) 87-11 which authorized engineering to procure and install Namco proximity switches and brackets to-hold the position switches on the valves which will provide positive indication of check valve positions. Methods of installation, testing, inspection and design verification are part of the design documentation package. This task is scheduled for Refueling Outage No. 7 plus four months with a task ready date of December 1987. Based on the above, this item is closed.
2.3.11 Item No. RC-86-10-02.15 - Reduce the frequency of testing for MOV-1001-28A/B, and submit appropriate T.S. change.
Corrective Action: The licensee submitted to the NRC on April 30,1987 (BECo Letter 87-069) proposed change 87-02 to Technical Specification Section 3/4.5, which reduced the frequency of testing for MOV-1001-28A/B. This proposed change reference is made to Pilgrim Operating License No.
DPR-35, Sections 3/4.5.A, B, C, D, E, and F.
Based on the above, this item is closed.
2.3.12 Items No. RC 86-10-03.3 and RC 86-10-03.4 - Local venting of the RHR system, per TP 66-84 will be performed once a week for four weeks after maintenance is rompleted.
Corrective Action:
Local venting of the RHR system has been performed, per temporary procedure (TP) 86-84, which provides instructions to station personnel for venting air from the RHR discharge piping utilizing high point vents.
A final procedure is scheduled to be issued by the Opera-tions organization by October 10, 1987.
This procedure is to be performed once per week for four successive weeks, from the time the RHR work is completed.
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The-licensee will then evaluate the test results to determine appropriate frequency of testing.
Based on the above, this item is closed.
2.3.13 Item No. RC 86-10-03.5 - Alarm response procedure 2.3.2.1 will be clarified for action on any PNL C903-Left Annunciator B-7, "RHR High Pressure alarm."
Corrective Action: Alarm response procedure No. 2.3.2.1,
" Panel Procedures Panel 903 Left", has been revised to clarify and incorporate additional operator actions. Ad-ditional direction for operators, when annunicator panel (ANN) No. B-7 is lighted, is to log the time that alarm is receive 1, and if leakage is greater than 1 gpm, initiate a controlied shutdown and perform leakage assessment per TP 86-85.
TP 86-85 is the RHR Intersystem Leakage Assessment Method procedure that has been prepared for this specific test.
Based on the above, this item is closed.
2.3.14 Item No. RC 86-10-03.6 - A surveillance test for periodic data collection of RHR system pressure and temperature will be prepared.
Corrective Action: Temporary Procedure TP 86-85, "RHR Intersystem Leakage Assessment Method," has been issued.
Attachment "B" of TP 86-85 requires recording of RHR local pressures and temperatures during surveillance inspections.
Based on the above, this item is closed.
2.3.15 Item No. RC 86-10-03.8 - Safety evaluation No. 1959, for RHR system controlled leak path modification, Revision 1, will be revised to clarify intent and assumptions.
Corrective Action: Safety evaluation No. 1959, Revision 2, was completed and sent to the NRC in September 17, 1986 (BECo Ltr. No. 86-41). The safety evaluation describes the method and analysis to establish a controlled leak path in the RHR system per modification MR 86-20.
Based on the above, this item is closed.
2.3.16 Item No. RC 86-10-03.9 - Procedure changes will be made to establish RHR valve positions.
Valves (RHR) MOV 1001-29 A/B will be normally open and MOV 1001-28A/B will be normally closed.
If a pending safety evaluation determines that the positions of MOVs 1001-29 A/B and 28 A/B should be changed, the NRC resident inspector will be notified.
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Corrective Action: -The licensee issued operations-memorandum 87-03, dated January 5, 1987, which states that
- outboard valves M0V 1001-28A/B will be open, while inboard valves MOV 1001-29A/B will be closed. -As a result of these valve positions changes, the licensee subsequently notified the NRC resident.
Valve checklist 2.2.19A-10 and Print No. M241 " Piping and Instrumentation Diagram RHR System,"
have been changed to indicate the above valve positions.
Operating' procedures 2.2.19, 2.2.86 and 2.2.125 have been revised to reflect the above requirements while procedures 8.5.2.2, 8.5.2.3, 8.5.2.6 and 8.7.1.4.1 are in final management review (See Attachment 1 for listing of procedures).
Based on the above, this item is closed.
3.
Material Condition Improvement Action Plan In July, 1987, the licensee initiated the formalization of the Material Condition Improvement Action Plan (MCIAP).
The MCIAP was developed, per upper management's request, to improve upon the material condition of plant equipment and to further enhance the manner in which maintenance and maintenance-related activities were conducted at the site.
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An independent review team, comprised of experienced consultants from the nuclear industry, was formed to provide an unbiased assessment of present site maintenance practices, in order to identify areas in which improvements needed to be made. Areas reviewed included, but were not limited to, maintenance planning, scheduling, work practices, staffing, training and qualification, procurement, preventive maintenance, and measuring and test equipment.
Following this review, the Material Condition Improvement Action Plan was developed.
The MCIAP addressed those areas reviewed and identified specific areas of concern, which were categorized into numerous " restart" and "long term" corrective action items.
Each identified action item was assigned to various management personnel, who are responsible for ensuring the completion of specified corrective actions.
A review staff was also established to independently monitor and verify the satisfactory completion of all MCIAP action items. This review group is responsible for not only the MCIAP, but also the Restart Plan; Restart Plan, Appendix 10 (Restart Regulatory Response); and the Radiological Action Plan.
The review group is comprised of 15 individuals. As many as five individuals had been dedicated towards monitoring the progress of MCIAP items.
During this inspection, three individuals were following up on the MCIAP Restart items.
The specific responsibilities of the MCIAP review team include 1)
monitoring the progress of actions taken in satisfying MCIAP action items; 2) verifying the adequateness of corrective actions taken; 3) periodically reverifying items previously closed, and 4) assessing the effectiveness of corrective actions take _ _ _ - _ _ _
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The inspector held several discussions with the review staff manager and personnel in regard to the status of the MCIAP action items. These discussions and a review of the status of MCIAP Restart Actions indicated that, to date, 64 of the total 89 Restart Actions.have been closed and another five were ready for closure.
Examples of Restart Action items completed include the following:
Maintenance Planning Improvements
-Work scope review committee-Master work schedule-RFO-7 Approved Task List
Procedure Control
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Procurement Tracking i
Material Staging
Preventive Maintenance Scheduling
Staffing for Measuring and Test Equipment (M&TE) area
Housekeeping
The review staff manager stated that particular attention was being directed towards the remaining 20 items since they are considered to be the more comp'ex of the criginal 89 action items.
Examples of the remaining 20 Restart Action items include:
Post Maintenance Testing requirements
Decontamination of priority areas
Centralization of M&TE issuance / storage
Testing schedule for Restart
The inspector also questioned the manager as to why eighteen items were categorized as " Continuing" (long term) action items versus " Restart" action items.
The explanations presented were considered by the inspector to be reasonable and appropriate.
Also reviewed were six closecut packages for six Restart action items completed. These closecut packages also included subsequent reverifica-tion reviews. Once an item is closed, the same item is reviewed again on a monthly basis to ensure corrective action measures are still in place.
Also reviewed are whether or not the measures taken are effective and, if not, what other changes could be made.
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The process-for initial closure called.for.only a review of documented evidence submitted by the. individual responsible for'the designated item.
' However, monthly; reverification checks revealed-that some Restart items had been closed that'did not fully meet the original intent of the. item.
i Consequently, the review staff altered-their closure process such that'
they now, in addition to performing an inoffice document. review,'also verify that appropriate field changes have been made (similar to the monthly reverification process).
For those Restart items reviewed by the-
. inspector, it was noted that the review staff performed extensive,
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detailed reviews prior to closure, and that documentation supporting this effort was' included in-the review packages.
Conclusions The_MCIAP has addressed many important. aspects of the station's maintenance a::tivities that were historically viewed as less than adequate -
by licensee management, consultant reviews, and NRC inspections...These areas have been categorized as either " Restart" or'" Continuing' Action" items. xThe review staff, established to verify'.the progress and adequacy of licensee actions in regard to.the MCIAP Action items, is adequately'
overseeing this project'
Upper management is being kept apprised of the_
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review staff's' conclusions, following closure verification r'eviews, and the-status of all MCIAP action items.
There were no. further questions, however, the inspector stated that the MCIAP and the progress of " Restart" and " Continuing" action item closures would be subject to further review during subsequent NRC inspections.
4.0. Exit' Meeting The-inspector met with licensee representatives (denoted in paragraph 1)
on October 2,1987, to summarize the scope and findings of the. inspection.
At no time during the inspection was written material provided to.the licensee by the inspectors. Also the licensee did.not indicate that any proprietary information was contained within the scope of this inspection.
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ATTACHMENT 1
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Quality Control Inspection Reports No. IR 86-10-55-0 Disposal of M0-1001-28A Valve Disc No. IR 86-10-55-E Pre Operational Test for Logic Limit Switches on Mo-1001-28A No. IR 86-10-55-A Measurement of New Disc For MD-1001-28A Valve No. IR 86-10-56-A Megger Testing of M0-1001-28B No, IR 86-10-56-B Tack Welds of Stem Nut on MD-1001-28B
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No IR 86-10-56-C Cleanliness Inspection of MO-1001-28B No. IR 86-10-56-D Replacement Parts for M0-1001-28B No. IR 86-10-56E Remount Motor for MO-1001-28B No. IR 86-10-56F Termination of Field Cable to Motor Leads MO-1001-28B No. IR 86-10-56G Measure Thickness of Disc Edge MO-1001-28B No. IR 86-10-56H Disposal of M0-1001-288 Valve Disc No. IR 86-10-561 Pre-Ops Test for Logic Limit Switch on M0-1001-28B No. IR 86-10-56J Megger Test Valve MO-1001-28B No. IR 86-10-56K Maintenance Reauest Close Out of MD-1001-28B Documentation Mair.tenance Request Log Nos.
MR No. 86-10-55 Disassemble and Inspect MO-1001-28A Valve MR No. 86-10-56 Disassemble and Inspector MD-1001-28B Valve MR No. 86-10-36 Install Pressure Gages on RHR "B" Train MR No. 86-10-37 Install Pressure Gages on RHR "A" Train Procedures TP-86-85 RHR Intersystem Leakage Assessment and Controlled Leakoff TP-86-14 RHR Discharge Piping Venting-Procedure
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ATTACHMENT 1 (Continued)
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Procedure No. 8.5.2.7 Hydrodynamic Test for Measuring Leakage Thru RHR System Procedure No. 8.7.1.5 Local Leak Rate Testing of Primary Containment Penetrations and Isolation Valves Procedure No. 8.5.2.2 LPCI Pump Flow Rate Test and MOV Timing, Revision 21 Procedure No. 8.5.2.3 LPCI Motor Operated Valve Operability Test', Revision 11 Procedure No. 8.5.2.6 LPCI Motor Operated Valve Operability Form alternate Shutdown Panels, Revision 8 I
Procedure No. 8.7.1.4.1 Primary Containment Integrated Leak Rate Test Preparations, Revision 2 Test Data Reports Procedure No. 8.7.1.5 Local Leak Rate Testing of Primary Containment Penetrations and Isolation Valves.
Test data record on the following item per above procedure requirements:
MO-1001-28A - August 14, 1987 MD-1001-288 - August 11, 1987 MO-1001-29A - August 13, 1987 MO-1001-298 - August 12, 1987
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Procedure No. 8.5.2.7 Hydrodynamic Test for Measuring Leakage Thru RHR System.
Test data recorded on the following items per above procedure requirements.
Loop "A" LPCI Injection Check Valve No. 1001-68A -
August 14, 1987 Loop "B" LPCI Injection Check Valve No. 1001-688 -
September 20, 1987 Training Records Nuclear Training Participation Record, June - July,1986.
RHR intersystem leakage.
Misc. Documentation Procedure No. 2.2.19A-10, Revision 27, Valve Checklist Procedure No. 2.2.125A-13, Revision 5, Primary Containment Isolation Valve Checklist-2-L
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ATTACHMENT 1 (Continued)
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Procedure No.1.3.4F-1, Revision 32, Surveillance Test Schedule Form Procedure Nos. 8.5.2.2 and 8.5.3.3, RHR Surveillance Procedure Safety Evaluation Report No. 1959 RHR System Leakage
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