IR 05000293/1988019
| ML20150C979 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/28/1988 |
| From: | Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20150C972 | List: |
| References | |
| 50-293-88-19, NUDOCS 8807130243 | |
| Download: ML20150C979 (39) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No.: -50-29 Report No.: 50-293/88-19 Licensee: Boston Edison Company 800 Boylston Street Boston, Massachusetts' 02199
' Facility: Pilgrim Nuclear Power Station location:- Plymouth, Massachusetts ~ Dates: April 18, 1988 - May 31, 1988 -
Inspectors: C. Warren, Senior Resident Inspector J. Lyash, Resident Inspector T. Kim, Resident Inspector M. Evans, Reactor Engineer R. Freudenberger, Resident Inspector (Maine Yankee Facility) J. Stair, Resident Inspector (Susquehanna Facility) D. Notley, Technical Reviewer, NRR R. Wescott, Technical Reviewer, NRR Approved By: -., A. Randy BlougfE(Chief bN Date
. Reactor Projects.Section No. 3B Division of Reactor Projects Inspection Summary:
Areas Inspected: - Routine resident inspection of plant operations, radiation protection, physical security, plant events, maintenance, surveillance, outage activities, and reports to the NR Principal licensee management represen-tatives contacted are listed in Attachment I to this report. Attachment II contains a copy of handouts presented to Commissioner Rogers during a licensee presentation on May 6,'198 Results: Concerns.
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. Initial licensee response to a previous violation concerning failure to perform periodic testing of safety-related DC circuit breakers was inade-quat The proposed short-term corrective actions were not based on con-servative engineering judgemen Licensee management was not appropri-ately involved in reviewing the proposed corrective actions (Section 2.0, VIO 88-08-02).
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Inspection. Summary (Continued) -2 s . < Weaknesses in--the area of. control of maintenance continue to be identi-
:fied. A Quality Assurance (QA) Department Stop Work Order in the area of maintenance on environmentally qualified equipment was issued during . the period (Section 3.b). An engineered safety feature actuation occurred due .to ' recurring problems with planning and control of maintenance (Section 4.d).
Strengths: The conduct of operations in the control room and the control room atmos-phere ha:: improved (Section 3.a).
- Licensee management and the licensee QA department have recently taken strong action to resolve long-standing maintenance program weaknesses (Section 3.b).
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TABLE OF CONTENTS Page Summary of Facility' Activities ............................... 1 Followup on Previous Inspection. Findings . . . . . . . . . . . . . . . . . . . . . 1 Rcutine Periodic Inspections ................................. 10 Control Room Observations Plant Maintenance and Outage Activities
- Surveillance Testing Radiation Protection and Chemistry Review of Plant Events ....................................... 14 Inadvertent Manual Start of the "B" Emergency Diesel Generator Reactor Water Cleanup Isolation Due to a Failed Electrical Relay Reactor Building Closed Cooling Water Pump Coupling Failure Secondary Containment Isolation and Standby Gas Treatment System Actuations During-Haintenance Allegation Reviews ........................................... 17 Management Meetings .......................................... 18 Attachment I - Persons Contacted Attachment II - Material Provided by the Licensee to Commissioner Rogers During a May 6, 1988 Plant Tour i
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DETAILS 1.0 Summary of Facility Activities
- The plant was shutdown on April 12, 1986 for unscheduled maintenance. On July 25,1986, Boston Edison announcer that the outage would be extended to include refueling and completion er certain modifications. The recctor core was defueled on February 13, 1987. The licensee completed fuel re-load on October 14, 1987. Reinsta11ation .of the reactor vessel internal
> components and the vessel head was followed by completion of the reactor vessel hydrostatic tes The primary containment integrated leak rate test was also completed during the week of December 21, 1987. During this-period, the licensee continued to perform routine maintenance and surveil-lance tests including the . local leak rate testing of selected containment isolation valve NRC inspection activities during the report period included: 1) a special team inspection conducted during the weeks of April 25 and May 2,1988, to evaluate the licensee's maintenance program, 2) an evaluation lof the licentee's security management effectiveness conducted during the week of April 25, 1988, 3) a review of the licensee's program undur materials license No. 20-07626-02 to control contaminated equipment during mainten-ance and testing at offsite facilities, 4) an evaluation of the licensee's fire protection program effectiveness conducted during the week of
.Muy 16, 1988, and 5) a review of the licensee's radiation protection program conducted during the week of May 23, 198 On May 6, 1988, NRC Commissionar Kenneth Rogers toured the station. The NRC conducted a public meeting on May 11, 1988 at Memorial Hall in Plymouth, Massachusett The meeting was held to discuss the NRC disposition of public comments and concerns expressed during the February 18, 1988 public meeting on the Boston Edison Company's Pilgri Restart Pla .0 Followup on Previous Inspection Findings (Modules: 92701 and 92702)
Violations (Closed) Violation (86-37-01), Safety-Related Modifications not Performed in a Manner to Assure Quality and Ineffective Post Work Inspections. Dur-ing inspection 50-293/86-37 the inspector identified that electrical leads associated with the tie-in of a new plant process computer had been ter-minated on incorrect terminal strip point Licensee post-work inspec-tions did not identify these improper tie-ins. As a reruit, the final
- configuration was not in accordanie with approved design drawings and the prescribed post-work testing was invali __
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- - i In response to this finding the licensee suspended all similar ongoing work = pending evaluation of the discrepancie The ovaluation identified that individuals involved in performing the terminations had not correctly-interpreted the applicable electrical connection drawings. Technicians believed that the diagrams represented actual component physical locations and orientations. This misinterpretation contributed to the errors. The licensee revised the design change package to clarify that internal and external wiring depicted on connection diagrams is presented diagrammat-ically. A caution was added to all connection diagrams stating that ter-minal block internal and external wi.aing may be physically opposite to that shown. The licensee also counselled the individuals involved. The-inspector sampled several connection diagrams to verify that the licensee in fact incorporated these changes. The incorrect tie-ins were evaluated and found to be functionally equivalent to the intended design and remained as installed, with design documents revised to reflect the chang The licensee's corrective actions appear adequate to address the specifics of this item. The inspector expressed concern however, that this incident may indicate a weakness in the licensee's safety-related modification and post work inspection program. The licensee's response did not appear to assess the potential impact of this weakness on the program as a whol Similar concern regarding the modification and post-work testing program is the subject of existing violation 88-12-02 regarding the incorrect installation of two reactor water level instruments. Licensee evaluation and response to violation 88-12-02 will be reviewed during a future inspection. Based on the specific corrective actions described above, and the existence of current open item 88-12-02, this item is considered close (Update) Violation (88-08-02), Failure to Perform Periodic Calibration and Testing of Safety-Related DC Circuit Breakers. During a special electri-cal team inspection it was identified that no calibration or testing of safety-related DC circuit breakers had been performed during the life of the plant. Subsequent to the formal exit interview for inspection 50-293/
88-08 a supp12 mental exit was conducted via telecon on February 10, 198 The supplemental exit was held to discuss licensee corrective actions requiring implementation prior to plant restart. During the telecon the licensee stated that 10 of 39 safety-related DC breakers would be tested prior to restart to provide assurance that components would function as designed. It was understood by NRC management that this testing would constitute a representative sample of installed breaker The licensee also proposed that a long-term program for periodic testing be established and implemented, with all remaining breaker testing completed after restar The licensee subsequently provided as-found test data on the sample of 10 breakers to the inspector for revie .
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The inspector then met with the licensee Maintenance Section Manager and others to discuss the results, and.to request further information on the basis for sample selection and test criteri Based on the information provided it was apparent that the total population of DC breakers was well in excess of 39, and that the testing conducted by the licensee did not constitute a representative sample. The primary criterion used for sample selection had been the onsite availability of replacement part The inspector expressed concern to licensee management that the short-term testing program proposed did not provide adequate assurance that the DC distribution system would perform as designed. In. addition, the inspector questioned the thoroughness of the management review process applied by the licensee prior to proposing these corrective actions to the NR On May 13, 1988, a conference call between licensee and NRC regional management was held to discuss these coricerns. The licensee stated that additional testing would be performed prior to restart so that the result-ing ' compilation of test data would be representative. It is of concern that the initially proposed actions were based primarily on practicability factors and not on conservative engineering judgement. Licensee manage-ment's involvement in reaching the initial testing position also appeared less than effective. It was also noted that the licensee has excluded a certain subset of components from their proposed prerestart test program, specifically the DC distribution panel breaker The- NRC requested to review the licensee's basis for excluding these breakers. This item will remain open pending more detailed review of the licensee's test proced-ures, results and basis for exclusion of the DC distribution panel breakers from testing prior to restar Unresolved Items ' _(C.osed) Unresolved Item (83-03-05), Inconsistencies Associated with the Tr.chnical Specifications, FSAR and Procedure 2.2.125. A 1983 review of Ticensee documents relating to Primary Containment Isolation (PCIS) Valves by the resident inspector identified 73 inconsistencies between the FSAR, the Technical Specifications and procedures. Additionally, this item was updated in 1987 as discussed in NRC inspection report 50-293/87-38. Dur-ing that inspection, it was verified that the licensee had made all but 2 of the 1983 identified changes to station procedure However, the inspector identified 8 more inconsistencies which were discussed with the license The inspector noted that since inspection 50-293/37-38, the Technical Specifications have been revised. The licensee also plans to complete updating of the FSAR in July, 1988. It appears that the licensee has addressed all of the inconsistencies identified by the inspector In addition, a study was performed to assure that Technical Specification requirements are accurately covered by station procedures, and that no additional FSAR discrepancies exist in this are The inspector noted however, that the licensee's responsiveness to NRC concerns was poor
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in .611s case, as indicated by the fact that the 1983 identified inconsis-tencies were not substantially resolved until 1986, and documentation will not be fully updated until July,1988. This concern was discussed with licensee managemen All the identified inconsistencies have been resolved, and are being tracked for revision. Based on the cbove this item is close (Update) Unresolved Item (86-21-03), Licensee to Review Adequacy of Technical Specification Surveillance Procedures for Logic System Functional Testing (LSFT). This item was last updated in inspection report 50-293/87-42. The inspector discussed the status of the LSFT review program with a licensee representative. The final report regarding the LSFT review efforts, based upon the pre-refueling plant configuration, has been issued. (RECo Technical Report TR SSA 88-01, January,1988). A supplemental report will be issued shortly, which documents the resolution of each technical discrepancy discove,ed during the LSFT review, and up-dates the documentation to reflect the post-refueling plant configuratio At the time of this inspection, all Plant Design Changes (PDC), updated drawings captured by document control as of October 1,1987, and plant procedures issued through March 1, 1988, have been reviewed for LSFT impact. The inspector reviewed the final report and the draft supplemen-tal report and identified several administrative items which require addi-tional action by the licensee and further NRC inspector followup. These include:
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Review of licensee plans to implement long-term recommendations iden-tified in the final repor Licensee disposition of FSAR commitments not presently tested, as identified in Table 4 of the final repor Verification of surveillance testing frequency on the Master Surveil-lance Tracking Program (MSTP).
- Evaluation of procedural controls implemented to assure a LSFT review for procedure changes impacting LSFT surveillance Evaluation of procedural controls implemented to assure review of plant modifications to ensure that compliance with surveillance requirements for LSFT is maintaine The inspecto. conducted a detailed technical review of several Technical Specification LSFT requirements for the following systems: Emergency Diesel Generators, Standby Gas Treatment, Intermediate Range Monitor and Core Spra For all systems one or more sensing devices were chose Using the system elementary drawings and surveillance procedures a review was conducted to determine if all relays and contacts of the logic circuit from sensor to activated device were tested. No discrepancies were note No additional NRC technical review of surveillance procedures is required under this item. However, this item will remain open pending additional licensee action and further NRC inspection of the administrative actions identified above, ws -- _ _ _ , , - -w -
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. (Update) Unresolved Item (86-36-02), fire Barrier Operability Evaluations to be Performed by the License In inspection report 50-293/86-36, the inspector concluded that seven recent Licensee Event Reports (LER) regard-ing fire protection were related to fire barriers being declared inoper-able. The primary reasons for the barriers being declared inoperable were the following:
, Penetration seal documentation either does not exist or is unclear, Barrier components appear degraded, or , Uncertainty exists as to whether the degraded fire barrier is require In order to resolve this' problem, the licensee established a program to . evaluate the barriers and restore degraded barriers to operable statu This program consisted of surveying the penetrations in all of the plant barriers (approximately 300). Sketches were made showiag the location of all penetrations (about 5200). During the survey .it was determined that about 3900 seals did not meet the acceptance criteria. These seals have either been repaired, replaced, or reevaluated as to acceptabilit The inspector reviewed the licensee's procedures for inspection and con- i trol of fire barrier seals. The licensee also demonstrated the capabil- . ities of a computerized penetration seal tracking program called PENTRA PENTRAC enables the licensee to rapidly determine the identities, types and locations of all seals on a specified wall. By determining the seal , type, the seal can also be linked to specific qualification tests verify- ; ing its fire resistance ratin Based on a sampling review the inspector concluded that the licensee's procedures are adequate to document the acceptability of all existing fire barrier penetration seals in regard to Appendix A of Branch Technical , Position 9.5-1 and Section III(M) of Appendix R to 10 CFR 5 In addition, the inspectors also audited evaluations performed for minor penetrations in the rated fire barrier It was the inspectors' conclus-ion that these analysis were performed under the supervision of qualified fire protection engineers and were technically adequat From a technical standpoint, this item is resolve However, it will remain open pending further NRC review to determine if any enforcement is appropriate in light of the previous fire barrier deficiencie (Update) Unresolved Item (87-22-01), Licensee to Clarify the 10 CFR 50 Appendix R Analysi The licensee committed to develop a document that clearly describes the detailed basis for Appendix R compliance, so that continued compliance will be assure The licensee has begun this development proces The inspectors reviewed several of the separate ' items that will comprise the documentation and concluded that the licensee is proceeding in a proper manner. Among the items reviewed were:
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Memo with attachments from PNPS Fire Protection Group to the Nuclear Engineering Department dated October 30, 1987, which provided the framework and recommendations for format, technical content and administrative controls to be included in the documentation packag Engineering Department scoping document (undated) which included man-hour estimate and projected completica schedule. for the documentation packag This scoping document also included a draft table of con-tents for the "Consolidated Safe Shutdown / Fire Hazard Analysis".
- A time-line graph titled "NFPG Long Term Plan and Schedule" showing estimate of work completed on 13 separate items that will constitute the above documentation packag The licenseo currently estimates that the documentation package describing the basis for Appendix R compliance will be completed by October 1,198 Until this documentation package has been completed and reviewed this unresolved item remains ope (Closed) Unresolved Item (87-22-02). Licensee to Complete Procedures and Operator Training for the Safe Shutdown from Outside Control Room Tes The inspector reviewed operating procedure 2.4.143, Revision 7, and Power Ascension Test Procedure TP 87-147, Revision 0, for "Shutdown from Outside the Control Room". The inspector also reviewed and walked through with a licensee representative operating procedures 2.4.143.1, Revision 0, and 2.4.143.2, Revision 0, for "Shutdown with a Fire in Reactor Building East and West." All procedures were found to be adequat The inspector discussed operator training regarding thesc procedures with a licensee representative. The inspector verified that training has been conducted for operating procedure 2.4.143 and that training is scheduled during Requalification Training Session XI for proceoures 2.4.143.1 and 2.4.143.2. The representative stated that prior to conduct of TP 87-147, the operating crews who will participate in the test will conduct dry runs of the procedur In addition, the inspector questioned the licensee regarding the adequacy of the alternate shutdown communications equipmen The licensee stated that modification PDC 87-29 had installed transmitters, receivers and handheld radios to be used during a shutdown from outside the control roo However, the PDC as currently written has precautions which pro-hibit use of the radios anywhere in the plant during operation The Nuclear Engineering Department is currently working on a radio frequency interference survey to support use of the radios in all areas of the plant except the cable spreading room and back panel area of the control roo Engineering Service Request (ESR) No. 88-159 tracks licensee resolution of this issue. NRC observation of the licensee's remote shutdown test and ! evaluation. of communications effectiveness will be conducted during the , power ascension test program. Based on the above, this item is closed, t
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. (Closed) Unresolved Item (88-11-01_), Licensee to Review Acceptability of a Deviation from the Plant Specific Technical Guidelines (PSTG) in the Sequencing of Steps for Emergency Operating Procedure (E0P) -3, "Primary Containment Control". .The licensee evaluated the E0P-PSTG discrepancy and - determined that it is not safety significan The licensee determined that the probability of occurrence of an event which may be affected by the E0P discrepancy was so small that correction of the discrepancy in the near-term was not warranted. However, since the item is a technical inac-curacy the licensee will correct the discrepancy as part of the next major revision to the E0Ps. The inspector reviewed the licensee's evaluation (NED-88-290) including the basis for the above conclusions and f,ound the licensee's corrective actions to be acceptable. The inspectormverified that correction of the discrepancy is being formally tracked as verifica-tion discrepancy number 3-7-2 for E0P-0 This item is close (Update) Unresolved Item (88-11-02), Evaluation of the Adequacy of E0P Satellite Procedures Following Completion of Licensee Walkthrough of the Procedures. The inspector discussed this item with a licensee representa-tive. -He_ stated that the walkthrough of satellite procedures has been complete As of May 25, 1988 all but two of the procedures had been revised and approved. Additionally, the inspector discussed the defici-encies identified in Attachment C of NRC inspection report 50-293/88-11 and verified that the licensee has taken appropriate correct:<e action for each deficiency. This item will remain open pending inspector walkthrough of a sample of satellite procedures to evaluate their adequac (Closed) Unresolved Item (88-11-03), Licensee to Resolve NRC Concerns Regarding Procedures and Training Associated with Containment Ventin The inspector discussed the revisions made to Procedure No. 5.4.6, "Pri-mary Containment Venting and _ Purging Under Emergency Conditions" with a licensee representative and verified that the concerns identified in NRC inspection report 50-293/88-11 were appropriately addressed. In addition the inspector discussed operator training on when to initiate and when to terminate venting of the containment with a licensee training representa-tive and reviewed the appropriate instructional training module (87-0-RQ-05A-01-07). Operators have been instructed to vent only as required to remain below the Primary Containment Pressure Limi Operators received this training during Session VII of the Requalification Training Progra The representative informed the inspector that th operators will receive additional E0P training during each Requalification Training Sessio *
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(Closed) Unresolved Item (88-11-04), Licensee to Revise the Quality Assurance Internal Audit Schedule to Include an Annual Audit of the E0P Progra The inspector reviewed QAD-88-327, "Revision to 1988 QA0 Audit Schedule" and QAD-88-508 "QAD 1988 Audit Schedule (Revised)" and verified that an . audit of the E0P program is scheduled for November, 198 In addition, the inspector reviewed QA Departme..t Procedure No. 18.01, Revision 17, and verified that the procedure was revised to include requirements for ccaduct of an annual E0P Program Audi This item is close _I_nspector Follow Items
{ Closed)InspectorFollowupItem(86-29-01), Implementation of Surveil-lance Testing Requirement for Determining Containment N2 makeu This item was opened as a result of the licensee's self-identification of the extended inoperability of the containment nitrogen makeup flow mete Monitoring for gross containment leakage by review of inerting system makeup volume is required by the Technical Specifications. This monitor-ing had not been performed due to the flow meter unavailabilit The
' licensee has established a primary, and plans to develop a backup method of determining containment makeup. The inspector verified that the licen-see has incorporated these measures into Station Instruction SI-0P.3-001 and Daily Surveillance Log Procedure No. 2.1.1 The inspector also verified that instruments to be used for logging the daily readings appeared operable. While no time limic is specified in the Technical Specifications, the inspector questioned the licensee regarding the need to impose an administrative limit on out-of-service time for the monitor-ing instrumentation to assure compliance with the intent of the specifi-cations. Licensee management stned that the need for establishment of a limit would be evaluated. This item is close (Closed) Intpector Follow Item (86-34-01), Review the Licensee's Repair Program for Salt Service Water Piping Corrosio In October, 1986, salt service water (SSW) piping inspections conducted by'the licensee revealed delaminated and missing pipe lining, and below minimum wall corrosion wastage on portions of the SSW piping. The licensee's root cause analysis indicated that erosion and delamination of the pipe lining material occur-red, followed by galvanic attack from the corrosive salt water environ-men The licensee's inspection included ultrasonic (UT) examination of accessible portions of the piping, hydrostatic pressure testing and visual remote camera inspection of the underground piping. A plant design change (PDC 86-22) was issued to replace and repair degraded portions of the SSW piping. This PDC was completed in 1987. The results of the licensee's inspection and subsequent corrective actions are documented in NRC inspec-tion reports 50-293/87-26 and 50-293/87-27. The licensee is tracking this item in Appendix 9 to the Restart Plan, "NRC Management Meeting 86-41 Issues". As a preventive measure, the licensee committed to inspect at least one loop of the SSW system piping during each outage. Also, the licensee engineering department was tasked with identi fying improved piping and lining materials for future replacement. Licensee actions in response to this problem appear adequat This item is closed,
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.. . - . (Closed) Inspector Followup Item (87-25-01), Evaluate Training Provided to Operation! Personnel on Modific ations Implemented During this Outag This item was last opdated in NRC inspection report 50-293/88-0 The inspector discussed modification training with a licensee training repre-sentative. A one-day formal review of previously presented modification training is currently being conducted during operator Requalification Training Session XIII. This training includes both a classroom and simu-lator presentatio In addition, the new modification _ training for approximately ten modifications is tentatively scheduled for Requalifica-tion Training Session XVI, prior to restart. Depending on the completion status of the modifications, this training could include the Diesel Fire Pump (PDC 86-520), Third Diesel Generator (PDC 86-568) and the Torus Vent (PDC 86-51).
The third of five operating crews received the review training during this inspection. The inspector attended a portion of the classroom training and all of the. simulator presentation. The simulator training was well conducted and appeared extremely useful to the op. rator In addition, the inspector interviewed several operators who hu previously received this review training and questioned them regarding the modification Based upon these interviews, the quality of the training observed and licensee schedules for continuing modifications training,- concerns regard-ing the effectiveness of the modification training program are resolve This item is close (Closed) Inspector Followup Item (87-27-06),- Emergency Diesel Generator (EDG) Room Cooling Design Deficienc This item was opened us a result of increasing EDG room temperature, water temperature and lube oil temper-ature during tests conducted coincident with high outside air tempera-ture The inspector reviewed the licensee's engineering evaluation, results of tests performed on October 31, 1987, and Plant Design Change 87-55. The inspector determined that the licensee's evaluation of temper-ature effects on diesel operability was generally adequate, but that it did not specifically account for the possible effect of temperature on the EDG control panel components. Information Notice 87-09 deals with effects of elevated temperatures on EDG control panel electrical and electronic components which could disable the EDG. Review by the licensee system engineer and the inspector of the FSAR design temperature and test runs performed during high outside temperatures, indicates that temperatures in the EDG rooms in excess of the design temperature are not likaly and therefore should not have an adverse impact on control panel component Based on the above, the inspector considers this item close e .
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3.0 Routine periodic Inspections (Modules: 71707, 71710,-62703, 61726, 71881, 37700, 71709, 92701 and 92703) The inspectors routinely toured the facility during normal and backshift hours to assess general plant and equipment conditions, housekeeping, and adherence to fire protection, security and radiological control measures, i
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Inspections were conducted between ten p.m. and six a.m. on May 4, 15, 16, 19, 23, 24, 26 and 31 for a total of 21 hours and on weekends and holidays on May 14, 15, 21, 22, 28, 29 and 30 for a total of 42 hours. Ongoing work activities were monitored to verify that they were being conducted in accordance with-approved-administrative and technical procedures, and that proper communications with the control room staff. had been establishe The inspector observed valve, instrument and electrical equipment lineups in the field to ensure that they were consistent with system operability-requirements and operating procedure During tours of ths control room the inspectors verified proper staffing, access control and operator attentiveness. Adherence . to procedures and limiting conditions for operations were evaluate The inspectors examined equipment lineup and operability, instrument traces and status of control room annunciators. Various control room logs and other avail-able licensee documentation were reviewe The inspector observed and reviewed outage, maintenance and problem inves-tigation activities to verify compliance with regulations, procedures, codes and standard Involvement of QA/QC, safety tag use, personnel qualifications, fire protection precautions, retest requirements, and reportability were assesse The inspector observed tests to verify performance in accordance with approved procedures and LCO's, collection of valid test results, removal and restoration of equipment, and deficiency review and resolutio Radiological controls were observed on a routine basis during the report-ing period. Standard industry radiological work practices, conformance to radiological control procedures and 10 CFR Part 20 requirements were observed. Independent surveys of radiological boundaries and random sur-veys of nonradiological points throughout the facility were taken by the
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inspecto Checks were made to determine whether security conditions met regulatory requirements, the physical security plan, and approved procedures. Those checks included security staffing, protected and vital area barriers, . ' personnel identification, access control, badging, and compensatory measures when require t
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a. -Control Room Observations During the period, the inspector performed NRC Region I Temporary Instruction RI-87-01, Control Room Environment. The objective of this instruction is to assess *.he work environment in the control
- room and its effect on conduct of duties by licensee personnel. The inspector observed control room activities on regular and backshifts, and.on weekends. Several previous changes and ongoing modifications have impacted the control room atmosphere positively. The licensee established a control room annex and staffed it with several adminis- -
trative assistants (AA). The annex is used to process paperwork such as maintenance and tagging requests, minimizing administrative activ-ities in the control roo A recently installed partition forces personnel to pass through the Watch Engineer's office prior to acces-sing the control room proper. A new elevated control room super-visor's console has been added. This console positions the super-visor slightly above and back from the main control panels, resulting in a broader view of activities. Installation of a new process com-puter with monitors on both the unit operator and supervisor consoles will also. enhance the control room staff's ability to monitor the plant. Overall the licensee has continued to upgrade control room hardware, enhancing the atmospher The control room staff is generally well aware of plant status and ongoing activitie Operators are knowledgeable of plant system characteristics and locations. The inspector noted significant improvements in operator attitude and professionalism in the control room. Shift turnover briefings were thorough and formal. Operator l interface with other plant personnel were generally conducted in a ' professional nianner and control of plant activities appeared to be adequate. The inspectors will continue to evaluate the control room ( environment during routine inspection Plant Maintenance and Outage Activities
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On May 19, 1988, the licensee's Quality Assurance (QA) Depart-
- ment issued a stop work order on certain maintenance activities
! involving environmentally qualified (EQ) equipment. A total of six QA deficiency reports (OR) had been issued by the licensee during the previous six months in the area of maintenance on EQ equipment. These previously issued DRs, combined with recent QA surveillance observations, prompted issuance of the stop work orde Weaknesses identified by the licensee included lack of control of the EQ Master List and EQ maintenance requirement documentation, poor replacement material traceability provis-ions, and weak training of maintenance personnel in EQ consider-ations and precautions. The stop work order remained in place during the remainder of the period. The licensee is addressing these concerns as part of the maintenance process restructuring discussed belo The resident inspectors will continue to monitor licensee actions in this are _ - - - _ _
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On May 27, 1988, Boston Edison management restricted performance of some maintenance tasks at Pilgrim. A licensee self-assess-ment completed on May 26, identified maintenance program weak-nesses. Concerns regarding the effectiveness of the licensee's program for control of routine and corrective maintenance had been raised by the resident inspectors during previous inspec-tion periods, and by the NRC during & recent maintenance team inspection completed un May 5, as documented in report 50-293/ 88-17. In addition, the licensee's Quality Assurance Department ~ recently identified concerns in the area of maintenance on environmentally qualified equipment as described abov Licen-see management concluded that changes to the station maintenance program are warranted, and is developing actions to address the problems. The restrictions imposed on May 27, 1988, involved those maintenance tasks which were not covered by job-specific, detailed, approved station procedures. Those jobs were restric-ted pending additional management review. Activities such as surveillance testing and maintenance tasks that are clearly delineated by detailed procedures were allowed to continu Restricted maintenance tasks were being reviewed on a case-by-case basis and then released to the field if either 1) appropri-ate job-specific procedures or instructions were written and applied, or 2) the additional reviews confirmed that existing controls were conservative for that job. All work released is to be raviewed and approved by the Maintenance Section Manage Licensee efforts to develop a strengthened _ maintenance co' trol pro-cess are currently underwa Licensee management expects to issue
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revised program procedures, implement personnel training . commence maintenance using the enhanced system within about one manth. These program enhancements are designed to address previously identified QA, NRC and licensee management concerns. While the licensee has previously been slow to implement corrective measures in this area, recent actions appear strong, and are clearly directed at resolving these concerns. Continued licensee management involvement is needed to assure . their effective implementatio The resident inspectors will contir.ae to monitor licensee actions in this are Surveillance Testing In response to NRC concerns the licensee committed to develop and implement a new tracking system for surveillance requirements. The licensee, in conjunction with ABZ Corporation, has been attempting to implement a surveillance scheduling program called MOSAIC to meet these commitments. Due to numerous problems with the MOSIAC program, its operating procedures, computer language (PROLOG) and design docu-mentation the licensee has decided not to complete implementation of MOSIA Instead the licensee has undertaken a program to upgrade its original surveillance scheduling system, the Master Surveillance Tracking Program (MSTP).
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The licensee assigned members of the Technical Section to identify weaknesses in the MSTP and develop corrective actions. The results of this evaluation are complete, and a number of weaknesses in the MSTP were identified. Corrective actions have been developed to address each area of weaknesse The evaluation concluded that the use of two different computer sys- l tems (IBM and Prime) to maintain the MSTP data base, and poor control of data base changes led to the discrepancies that were identifie , The data base has subsequently been verified and is now completely i stored on one computer syste Data base changes are being reviewed I and approved by the Technical Section, which should prevent future problems in this are In the past there was no responsibility at the user level for assuring the accuracy of MSTP scheduling and data input. Presently there is one individual from each user section who is assigned to interface with the Technical Section on the MSTP up-grade program. These Division Surveillance Coordinators have been individually trained by members of the Technical Section on the weak-nesses in the MSTP and the imprevements being made to overcome those weaknesse MSTP computer programming weaknesses that would have been overcome with the introriuction of the MOSAIC program have been identified. The program changes are currently being developed and will be fully implemented by August, 1988. The Technical Section is currently employing manual methods to compensate for these weaknesse The inspector has reviewed the licensee's actions to compensate for and correct the weaknesses in the MSTP and finds the short and long-term actions to be adequate. There are no further questions at thi t m i d. Radiation Protection and Chemistry During the conduct of a routine inspection of the contractor parking lot a Health Physics (HP) technician identified two concrete slabs with low levels of fixed contaminatio Health Physics management was informed of these findings and subsequently had HP personnel con-duct surveys of the slabs and the surrounding area for loose contam-i ination with negative result Radioanalysis of concrete taken from I the slab revealed the presence of low levels of Cobalt 60 and Cesium 134 and 137. Radioanalysis of soil samples taken from the area around the slab were negative.
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4 The licensee has determined that the slabs were placed in their pre-sent position during the latter part of 1982. At the time that the material was piaced _in the contractor parking lot the licensee's
- administrative criteria for releasing such materials were less ,
stringent and would have allowed this material to be released from
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the radiologically controlled area (RCA). _-The present administrative limits would not allow this material to be released to the general environs and the licensee has moved the material back into the RC The licensee conducted surveys of all bose ma*.erials outside the RCA on Boston Edison property to identify any other materials which may not meet the present release criteria and found no similar instance The licensee has instituted procedural requirements to routinely con-duct these surveys outside the RCA in the future. The inspector has reviewed the licensee's actions in addressing this occurrence and has ' no further questions.
- 4.0 Review of plant Events (Modules
- 71707, 62703, 61726, 93702, and 37700)
The inspectors followed up on events occurring during the period to deter-mine if licensee response was thorough and effective. Independent reviews , of the events were conducted to verify the accuracy and completeness of ! licensee informatio Inadvertent Manual Start of the "B" Emergency Diesel Generator On April 25, 1988, at 2:40 p.m., the licensee experienced an inad-vertent start of the "B" emergency diesel generator during calibra- i tion of a pressure switch for the qgine prelube pump. Investigation l by the licensee indicated that a technician inadvertently pushed the !
"local diesel start" button while attempting to clear an alarm on the '
local control panel generated by the ongoing test. Both the "reset" button and the "local diesel start" button are on the same panel approximately three inches apar The generator was returned to ; normal standby service following an investigation by the operating ) shift personne ' The licensee's investigation concluded that the cause of the actua-tion was non-licensed utility technician personnel error. A critique of the event and a technician workshop were conducted by the licensee to formulate corrective actions. The licensee engineering depart-ment, in response to an engineering service request (ESR 88-365), N ided to relocate the "reset" push buttons on both diesel generator control panels as a long-term corrective actio The licensee's ! ongoing control room design review of human factors does not include local panels and board The licensee however, reviewed safety-related local panels and boards in light of this incident and has F identified local relay panels C941 and C942 in the relay room as potentially error pron The licensee is formulating interim cor-rective actions which may include dispatching of an operator during surveillance testin l . h
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. Reactor Water Cleanup Isolation _Due to a Failed Electrical Relay On April 26, 1988, at about 2:05 p.m., the control room received an inadvertent automatic closure of the inboard containment isolation valves on -the reactor water cleanup _ system (RWCU) suction and return lines.- The licensee's investigation identified that a General Electric Type CR 120A relay in the Primary Containment Isolation-System (PCIS) logic had failed, creating a fault and de-energizing the logic circuit for the isolation valves. The licensee made an ENS notification at app.oximately 3:30 p.m. on April 26, 198 Ptigrim has observed a high failure rate in the population of about 220 relays of this type. The licensee believes the failures are the result of age, aggravated by elevated cabinet temperature Cur-rently, a program is underway to replace all CR 120A relays in safety-related applications. This area is the subject of previously established inspector follow item 50-293/86-37-0 ' Reactor Building Closed Cooling Water Pump Coupling Failure On April 26, 1988, at 3:22 a.m. , the "B" Reactor Building Closed Cooling Water (RBCCW) pump coupling failed during normal operatio Low RBCCW system pressure initiated an auto-start of the standby "A" ~
RBCCW pum The licensee's investigation indicated that the cause appeared to be accelerated wear induced failur The alignment of the pump and motor were measured and found to have an offset of 0.030 i to 0.033 inches. The vendor recommended offset value is 0.007 to 0.0010 inches. Accelerated wear of the coupling teeth would be , expected as the amount of offset approaches the maximum value. The licensee believes the offset was prnbably due to an error during previous maintenance on the pump in 1985. The licensee has replaced , the failed coupling and is formulating a preventive maintenance schedule for the other RBCCW pump The RBCCW pumps are Ingersol- , Rand cradle mounted, centrifugal type pumps rated for 1700 gallons ' i, per minute flow. The pump coupling is a Model "B", size 2-1/2, self aligning type coupling manufactured by the' Koppers Company, In Secondary Containment Isolation and Standby Gas Treatment System Actuations During Maintenance ;
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On May 5, 1988, at about 11:00 a.m., the licensee experienced an , inadvertent Group II isolation, including all outboard secondary '_
:
- containment dampers, an automatic start of the "B" standby gas ' treatment system (SGTS), and isolation of the outboard residual heat removal system (RHR) to Radwaste primary containment iso- r lation valve. The observed actuations occurred during a relay t
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coil replacement in the Group VI reactor water cleanup (RWCU) system primary containment isolation logic circui The licen-see's investigation determined the cause to be personnel erro The maintenance package identified the correct fuse for removal, however a licensee electrician failed to properly identify the prescribed fuse and mistakenly pulled a fuse from the Group II isolation logic circuit. Both Group II and Group VI isolation logic circuit fuses are on the same fuse bloc The fuse was reinserted and the actuations cleared a short time later. The licensee made an ENS notification at approximately 12:05 on May 5, 198 On May 17, 1988, at about 11:30 a.m., the licensee inadvertently initiated the "A" train of standby gas treatment and secondary containment isolation systems. Licensee maintenance technicians were preparing to replace three primary containment isolation system logic relay coil As part of the equipment isolation a logic power supply fuse was removed. The licensee failed to fully identify the effect of deenergizing this portion of the logic. When the fuse was removed the ESF actuation occurre The fuse was reinstalled and the isolation logic was reset a short time later. The NRC was notified of the actuation via ENS at 12:58 Initial planning for the relay replacement appeared good. In-structions regarding the sequence of activities, placement of critical jumpers and control of lifted leads had been estab-lished by the maintenance planning group. The systems engineer-ing group had performed an independent technical review of the I maintenance package prior to its release for implementation. As ! a first step technicians were to have installed a jumper to maintain certain relays energized during the activities, thereby preventing any inadvertent equipment action In the field the , technicians found it difficult to install the prescribed jumper.
I After discussion with an electrical maintencnce supervisor and l the on-duty Watch Engineer, the technicians decided not to l install the jumper but to remove an associated logic power fuse l instead. The effects of removing the fuse had not been fully evaluated and upon deenergizing the circuit tne actuations occurred. In this case the maintenance planning process was bypassed in the field when a significant change was made to the method of performing the activity without reconsidering the factors which led to development of the original instruction This indicates that while informal improvements to the mainten-ance process have been made, a complete and well-developed pro-gram has not been established, resulting in continued inconsis-tent performance. Licensee actions to strengthen the mainten-ance control program are underway as described in section 4.b of this repor _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
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The licensee conducted a post-event critique to assess the actu-ations. During this critique licensee engineering personnel noted that an-identical actuation caused by not fully . identify-ing the effects of removing this same fuse had occurred three months earlier. However, the report documenting that event critique and proposed corrective actions had not been issue The event critique process has had a very positive effect on licensee root cause identification and corrective action. How-ever, additional attent ion is needed to assure pro.npt dispo-sition of critique result .0 Allegation Review Allegation of Altered Health Physics Surveys (RI-88-A-0006) On January 21, 1988, the NRC resident office at Pilgrim received an alle-gation that Health Physics survey records were changed to preclude having to perform additional surveys. A contractor health physics technician allegedly reduced a contamination survey result to a value less than the threshold value for followup surveys to avoid performing the additional wor The onshift health physics supervisor was alleged to have been aware of the altered survey but did not take any actio Upon receipt of the allegation the NRC requested that the licensee perform an evaluation and provide the results for review. Based on the licensee's response and inspector review of licensee records, it was determined that the licensee had identified the problem and taken corrective actions. prior to being informed of the allegatio The onQift supervisor initially called the problem to the attention of health physics manaoement. There-fore, the portion of the allegation regarding inaction by the supervisor is unsubstantiated. Corrective actions included correcting the altered radiation protection survey, reprimands and reinstruction for the involved individuals, and the termination of the technician that altered the survey data. Based on the above this allegation is considered close Allegation of Contaminated Resins Improperly Disposed of Onsite (RI-88-A-0007) On January 21, 1988, the NRC resident office at Pilgrim received an alle-gation that radioactively contaminated resin had been buried under a large pile of soil located on licenste property, outside the protected are The resin was allegedly dumped in the pile after a January 1981 resin spill, More resin was alleged to have been added to the pile approxi-mately one year later and subsequently covered by additional soil. Upon receipt of the allegation the NRC requested that the licensee perform an evaluation and provide the results for revie ,
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, , , . - - . - - - . , , , - , - , , , ..-,-v. , ,- , - - . . . .- . , . , - g.-v.- , . - - - - - . , , - , - . , - ,
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NRC inspections and' radiation surveys have been performed by resident and specialist inspectors concerning the storage of the pile of dirt, asphalt and concrete generated during onsite excavation for plant modification These inspections are documented in the following - Region I Inspection Reports: 50-293/87-57, pages 14 and 15, 50-293/87-18, pages 15 and 16, and 50-293/88-01, page 5. Based on these NRC inspections and the licen-see's evaluation there is no indication that any significant amount of radioactive' resin was buried in the area. While extremely low levels of contamination are measurable in some soll _ samples, the materia 2 does not represent a health or safety concern. Based on the above, this allegation
-
is considered close .0 Management Meetings (Module: 30703) At periodic intervals during the course of the inspection period, meetings were held with senior facility management to discuss the inspection scope and preliminary findings of the resident inspector An exit interview was conducted after the close of the inspection, to discuss final inspec-tion results and conclusions. No written material was given to the licensee that was not previously available to the public. At no time dur-ing the inspection did the licensee identify any materials provided fcr review which contained proprietary informatio ' l On May 6,1988, NRC Commissioner Rogers toured the plant and attended a brief pretentation by the licensee. Written material used by the licensee during the presentation is included as Attachment II to this report. Af ter the tour the Commissioner briefly aodressed members of the press.
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m Attachment I to Inspection Report 50-293/88-19 -
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Persons Contacted
- * R. Bird, Senior Vice President - Nuclear K. Highfill, Site Director R. Anderson, Plant Manager
E. Kraft, Station. Services Manager A. Morisi, Acting Outage and Planning Manager D. Swanson, Nuclear Engineering Department Manager J. Alexander, Operations Section Manager , J. Jens, Radiological Section Manager , J. Seery, Technical Section Manager R. Sherry, Maintenance Section Manager P. Mastrangelo, Chief Operating Engineer D. Long, Security Group Leader W. Clancy, Systems Engineer Group Leader C. Higgins,-Security Group Leader F.- Wozniak, Fire Protection Group Leader
* Senior licensee representative present at the exit meeting.
1 i
* . ' .
PILGRIM NUCLEAR POWER STATION m,.. IPIE W IF 0 W ?S] W Yil(CJE IE B (C IEJ1J1JE 'iil(CJE il Fil WJI (CJJJ V 0 W E ( STATt*S AS OF MAY 2.1988 )
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MR'S REQUIRED FOR RESMRT LONGTERMBEND SHORT TERMEEND , 1200-1000-800- COW 1ETE 14 .
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OPEN DEFICIENCY REPORTS (DR'S) LONGTERMTREND SHORT TERM TREND 50-40- _
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LONGTERMTREND SHORTTERM TREND i 100-88.4 8 .4 88.4 88.4 l GOAL ' 80-l PERCENT l CLEAN 60-i j 40- ! l 20- ! !
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- frst qter figures E FRCST Q ACTUALS are a weekly average
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