IR 05000293/1997007
| ML20198H729 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/15/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20198H714 | List: |
| References | |
| 50-293-97-07, 50-293-97-7, NUDOCS 9709220156 | |
| Download: ML20198H729 (24) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION 1 -
License' No. - DPR 35 Report No.-- 97 07-Docket N Licensee: Boston Edison Company 800 Boylston Street -
Boston,' Massachusetts - 02199 Facility: Pilgrim Nuclear Power Station Inspection Period:- June 25 - August 16,1997 inspectors: Richard A. Laura, Senior Resident inspector Beth E. Korona, Resident inspector Greg Smith, Security Specialist inspector
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- Russell J. Arrighi, Resident inspector :
Approved by:- Richard J. Conte, Chief, Projects Branch 8 Division of Reactor Projects 9709220156 970915 PDR ADOCK 05000293 G PDR
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EXECUTIVE SUMMARY Pilgrim Nuclear Power Station NRC Inspection Report 50 293/97 07 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers an 8 week period of resident inspection; in addition, it includes the results of announced inspections by a regional security specialist inspector.-
Operations s-Operators properly utilized alarm response procedures when responding to control room
- alarms. Nuclear operating supervisors (NOS) routinely held detailed discussions at shift turnover briefings with nuclear plant reactor operators. (Section 01.1)
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.Two loose fasteners were identified on a high pressure coolant injection (HPCI) system pipe support which were reported to operations personnel for corrective actions. (Section 01.1)-
Positive operator performance was evident during the planned downpower including the
~ conduct of scram timing testing and during the condenser thermal backwash evolutions ;
The use of the "just-in-time" training contributed to this positive operator performanc (Section 04.1)
Maintenance =
The pre-job brief for the installation of jumper ports in panel C-7 and C-194 covered all salient points of the work and contributed to effective work performance. Qualified and competent mechanics welded a metal patch repair to temporarily correct through wall-
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leakage on a spool piece in a SSW pipe for the "B" RBCCW heat exchanger. A detailed mock-up was utilized to ensure the internal rubber lining was not damaged during the welding activities. (Section M1.1)
The installation of-a new split sealinto the "A" RBCCW pump failed the post work test and damaged the new seal due to an overall degraded pump in need of overhaul. An untimely
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response to refurbish the pump caused the RBCCW system to be considered A.1 system per the maintenance rule criterla~and resulted primarily from the slow resolution of a
- SWOPl (circa 1995) issue by the engineering department involving the need to design and fabricate a dummy RBCCW pump to support the suction and discharge header piping during pump removal for overhaul. The work control department work plan guidance for the work was sparse and simply referenced the vendor manual rather than clearly specifying.which sections needed to be' performed. Limited ' system engineering involvement was evident. (Section M2.1)
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The MSTP revalidation effort was comprehensive and identified several problems which were reported to the NRC pursuant to 10 CFR 50.73 requirements. IFl 95 21-01, LER 96-10, LER 95 09 and LER 95 07 were reviewed and are considered closed. (Section M3.1)
An experienced E-lab worker did not adhere to the procedure during the conduct of routine surveillance testing on emergency bus 5. The E-lab engineer did not use good self-checking. Additionally, the pre evolutionary briefing was identified by licensee personnel as a contributing cause since operators knew the "C" RHR pump was running in the torus cooling mode but were generally unaware of the plant impact of the surveillance tes (Section M4.1)
Enaineerina The engineering staff properly utilized NRC GL 90 05 to develop a repair plan for the degraded section of SSW spool piece, develop an inspection plan for possible similar degraded areas and obtain NRC review and approval. The temporary repair method of installing a welded metal patch was more rigorous than other potential alternatives such as
. the installation of a sof t rubber patch. (Section E2.1)
Plant Suncort An effective security program; however, an inspector follow-up item related to marginally effective assessment aids will remain open pending installation of new closed circuit television cameras. Management support was evident by upgrades in the self assessment program, the tactical firearms training course, and the photo badge processing syste The alarm station operators were knowledgeable of their duties and responsibilities and weie not engaged in activities that would interfere with their response functions. Security training was being performed in accordance with the NRC approved training and qualification plan. Protected area detection equipment satisfied the NRC-approved Physical Security Plan (the Plan) commitments and security equipment testing was being performed as required in the Plan. (Sections S1 and S6)
Maintenance of security equipment was being performed in a timely mai.'ar e , evidenced by minimal compensatory posting associated with security equipment repairs. Based on observations and discussions with security officers, the inspector determined that they possessed the requisite knowledge to carry out their assigned duties and that the training program was effective. A review of the vehicle barrier system determined that the system was installed and was being maintained in accordance with applicable regulatory guidance and requirements. (Sections S2, SS, and S8)
The lessons learned at Haddam Neck 1 on August 7,1997, when an automated fire suppression system inadvertently initiated were not directly applicable to PNPS since the control room has no automatically initiated fire suppression systems. Positive control of the five PNPS control room self-contained breathing apparatus (SCBA) was eviden (Section F2.1)
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TABLE OF CONTENTS
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EX EC UTIVE S U M M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Summ ary of Plant St atus . . . . . . . . . . . . . . . . . . . - . . . . . . . . . . . . . . . . . . . . . . . . . 1
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l . O PE R AT I O N S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . - 1 01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 G eneral Comme nts - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 04 Operator Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . . , 3 04.1 Control of Downpower and Condenser Backwash Activities .... 3 11. M AI NT E N A N C E . . . . . . . . . -. . . . . . . . . . . . . . . . . . . . . . . . . . . . , , . . . . . . . . 4 M1 Conduct of Maintenance ..................................-4 M t .1 General Comments ................................. 4 M2 Maintenance and Material Condition of Facilities and Equipment ...... 5 M2.1 " A" RBCCW Pump Overhaul . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 M3- Maintenance Procedures and Documentation . . . . . . . . . . . . . . . . . . , , . 6 M3.1 (Closed) Inspector Follow item (50 293/95 21-01): Master Surveillance Tracking Program (MSTP); and related LERs 96 10,95-09,95-07 .................................. 6 M4 Maintenance Staff Knowledge and Performance . . . . . . . . . . . . . . . . . . 7 M4.1 Unexpected Residual Heat Removal (RHR) Pump Trip . . . . . . . . . .7 111. E N G I N E E RI N G . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 E2- Engineering Support of Facilities and Equipment . .". . . . . . . - . . . .'. . . 9 E2.1 Non-ASME Code Repair on salt service water (SSW) Piping . . . . . 9 I V. PL A N T S U PP O RT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _ . . . . . 10
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S1 Conduct of Security and Safeguards Activities ...... ,,, ...... 10 S2 Status of Security Facilities and Equipment .................... -11 S2.1 Protected Area Detection Aids , . . . . . .-.............. 11
. S2.2 Alarm Stations and Communications .. . . . . . . . . . . . . . . .- 11
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S2.3 Testing, Maintenance and Compensatory casures .. ...... 12 SS Security and Safeguards Staff Training and Qua .. sation . . . . . . . . . . 13 S6 Security Organization and Administration -. . . . . . . . . . . . . . . . . . . . . . 13 S8 Miscellaneous Security and Safety issues ..................... 14 S8.1 Vehicle Barrier System (VBS) ......................... 14
' S8.2 Vehicle Barrier System (VBS) . . . . . . . . . . . . . . . . . . . . . . . . . . 14
' S8.3 Bomb Blast Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 S8.4 Procedural Controls . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . 15 F2 Status of Fire Protection Facilities and Equipment . . . . . . . . . . , , . . , 16 F2.1 ~ Operating Experience Review . . . . . . . . . . . . . . . . . . . . . . . . . 16 V. MANAGEMENT MEETINGS ....................................... 16 X1 Exit Me eting Summ ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 ,
X4 Review of UFS AR Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 IV
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- INSPECTION PROCEDURES USED . . t . . . . . . . . . . . . . . . . . ., ..,......
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. lTEMS OPENED, CLOSED, AND UPDATED :. . . . . . . . . . =. . . . . . . . . . . . . . , . . . . 191
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LI ST O F A C R O N Y M S U S E D ': . . . . . . . . . . . _ . . . . . . . . . . . . . . . . . . . . . . . . . . .- , . . 20_
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BJPORT DETAILS Summary of Plant Statyg At the beginning of this inspection period, the Pilgrim Nuclear Power Station (PNPS)
operated at or near 100% power until a planned downpower to 50% power was performad on July 26,1997, to backwash the condenser and conduct various maintenance and surveillance activities. Operators returned the unit to full power where it remained through the remainder of this inspection period. Further details of the downpower are discussed below in Section 04.1 of this repor BECO Staff Effectively July 1,1097, BECo implemented a rotation plan for several group and department manager positions. Mr. John Garrety, previously the engineering services group manager, replaced Mr. William Kline as the nuclear engineering services group manager. Mr. William Kline had previously announced his resignation with his intent to work in a comparable position at the Beaver Valley nuclear power plants. Mr. Clair Goddard, previously the nuclear services group manager, replaced Mr. Theodore Sullivan as the plant group manager. Mr. Sullivan replaced Mr. Jack Alex< 3 der as the nuclear training and services group manager. Mr. Jack Alexander replaced Mr. Trichur Venkataraman as the quality assurance group manager who was assigned to work special assignments under the senior vice president. The new nuclear services group manager was Mr. William Riggs
~who was the deputy plant group manager. Mr. Thomas Trepanier was assigned as the - 4 new deputy plant group manager who was temporarily replaced by Mr. Michael Jacob Mr. Stewart Minnehan tendered his resignation for work at another power plant and was replaced by Mr. Paul Gallant as the work control department manager. Ms. Laurie-Weatherall was selected as the new deputy group nuclear engineering services manage NRC Staff On July 20,1997, Mr. Russell Arrighi, formerly assigned as an NRC Resident inspector at the Millstone nuclear power plants, replaced Ms. Both Korona as the NRC Resident inspector assigned at PNPS.
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l. OPERATIONS 01 Conduct of Operations'
01.1 General Comments (71707)
Using Inspection Procedure 71707, the inspectors conducted frequent reviews of ongoing plant operations. The inspectors observed that proper control room staffing was l maintained, access to the control room was properly controlled, and operator behavior was commensurate with the plant configuration and plant activities in progres Topical headings such as o1, M8, etc., are used in accordance with the NRC standardized reactor inspection report outline. Individual reports are not expected to address all outhne topic . .- ..
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Over the course of this inspection, the inspectors witnessed several operational activities and noted the following:
e On July 7,1997, operators responded swiftly to a generator field ground alarm by lowering reactor power, following the abnormal procedure and isolating one generator rectifier bank which had water leakage from a mechanical joint lea * During shift turnovers, the nuclear operating supervisor took the initiative and questioned the equipment operators on their assigned round e During plant tours the inspector identified that two of four fasteners on a high pressure coolant injection (HPCI) system drain line pipe hanger (M243 B6) were found loose and unthreaded approximately one inch. The inspector questioned the effect of the loose fasteners on the operability of the HPCI system. Subsequently, operators initiated problem report (PR) 97.9498 to document the loose fasteners and obtain corrective action. An operability evaluation determined that the HPCI system was still operable since the degraded hanger was the second one from the class break. Hence, the HPCI system piping retained seismic and structural integrity. A maintenance request was initiated to tighten the two f asteners. Also, an apparent cause was initiated as part of the PR process. The inspector identified this equipment deficiency by the rattling sound of the loose pipe hanger bolt * The inspector observed a local and current newspaper in a contaminated trash barrelinside the auxiliary bay. At that time, a security watch was posted nearby as a compensatory measure watch and station services workers were working in the general area. The inspector expressed concern to the plant group manager that the current newspaper in the auxiliary bay potentially indicated plant personnel coud have been distracted during normal duties and that the newspaper generated unnecessary low level waste. The plant manager informed the inspector that reading a newspaper in plant areas did not meet his expectations. Operations personnel initiated a PR to document, evaluate and then obtain corrective action, as neede * Additional problems identified by the inspectors on plant tours were discussed with the nuclear watch engineer for potential corrective action. These included: an unsecured dry chemical fire extinguisher and blown light bulbs in the "A" RHR quadrant rooms. The inspector considered these two items to be relatively minor; these issues were promptly corrected by BECo personne The inspector reviewed an industry auditing group (INPO) report for a two week INPO inspection performed at PNPS the weeks of June 9 and June 16,1997. The focus of the inspector's review was to determine whether or not any safety significant issues were identified by INPO that warranted immediate NRC attention. Additionally, a general comparison of the NRC assessments verses INPOs assessments was considered. The various strengths and weaknesses in each of the functional areas were reviewed and no safety significant issues were noted. The INPO assessments were consistent with NRC assessments except in the chemistry area where INPO identified several management
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-effectiveness and technical training performance issues. Since no safety significant issued were identified, no further NRC inspection followup is planne Operator Knowledge and Performance 04.1- Control of Downoower and Condenspr Backwash Activities jnsoection Scope (71707)
The inspectors observed portions of the downpower, condenser backwash, and scram timing test evolutions during deep back shift inspection on July 26,199 Observations and Findinas On July 26,1997, operators lowered reactor power to approximately 45 percent to >
perform scram timing test and cor. denser backwash evolutions. The inspector noted that the Plant Group Manager and the Operations Department Manager (ODM) were in over the weekend monitoring these activities. A review of the scram timing test data revealed that it met the technical specification acceptance criteria. No human performance errors were noted during the performance of either of the evolutions. Discussions with the ODM
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downpower and backwash evolutions. Since the backwash procedure had been changed, ato allow operators to leave one of the condenser salt water pumps secured until-divers
- could pump out the bay, and due to the infrequent performance of these evolutions, th ODM requested that the training department provide simulator training to the individuals-who were scheduled to be on watch during the evolution The "just in time" training was held on July 24,1997 to support the activity. The "just-in-time" training initiative has been implemented by the licensee for a number of years, it is utilized for such things as plant evolutions that require a higher degree of coordination between the Operations Department and plant support groups, or where new methodologies or procedures are being employed. The just-in time training is provided to operators just prior to the performance of scheduled evolutions. The inspector verified that the crews performing these evolutions had attended the training secessio Conclusions Positive operator performance was evident during the planned downpower including the conduct of scram timing testing and during the condenser thermal backwash evolution The use of the "just in-time" training contributed to this positive operator performanc __ _ _ - ____ _
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11. MAINTENANCE M1 Conduct of Maintenance M1.1 General Comments inspection Scoce (61726,62707)
- Using inspection procedures 61726 and 62707, the inspector observed / reviewed portions of selected maintenance and surveillance activities to verify proper calibration of test instrumentation, use of approved procedures, performance of the work by qualified personnel, conformance to limiting conditions for operation, and correct system restoration following maintenance and/or testing. Some activities observed included the following:
- MR 19502725 Install jumper ports in panels C 7 and C-194
- 8.5.3.14 Salt Service Water Flo Rate Operability Test
- MR 19701832 Welded Patch Repair on "B" loop reactor building closed cooling water (RBCCW) System Piping
- - Control Rod Scram Time Testing Observations and Findinas The inspector attended the pre-job brief for MR 19502725. Individuals involved in the brief included the I&C supervisor and technicians, quality assurance (QA) department personnel, and operation department personnel. The brief was conducted by the lead instrumentation and controls (l&C) technician, it was apparent from the discussion that all parties involved were familiar with the job and their responsibilities. Discussions with the lead I&C technician revealed that he had performed a pre-job walkdown; reviewed-electrical prints, and verified the torquing values specified in the work procedure were consistent with vendor recommendations. The inspector verified that proper isolation was established for the job and that the appropriate technical specification had been entered prior to the disabling of the equipment. No problems were noted during the installation of the jumper ports in panel C- The work to weld a metal patch on a spool piece in the salt service water (SSW) side of
- the "B" loop of the RBCCW system progressed smoothly. The maintenance department utilized a mock-up to ensure that the heat from welding would not adversely effect the internal pipe rubber lining. The inspector visually examined the welds which appeared to be of good quality. Also, the inspector observed QA personnel conduct ultrasonic examinations before and after the repair. Before the repair, water spraying from the through wallleakage and interference noise required the QA personnel to exercise judgement in collecting wall thickness data. The engineering aspects of this work are discussed later in Section E2.1 of this repor _ - _ _ _ _ _ _ _ _ _ - - . - _ _
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c.- Conclusions The pre job brief for the installation of jumper ports in panel C 7 and C-194 covered all salient points of the work and contributed to effective work performance. Qualified-mechanics welded a metal patch repair to temporarily correct through wallleakage on a spool piece in a SSW pipe for the "B" RBCCW heat exchanger. A detailed mock-up was utilized to ensure the internal rubber lining was not damaged during the welding activitie M2 Maintenance and Material Condition of Facilities and Equipment M "A" RBCCW Pumo Overhaul Inspection Scone (62707)
Portions of mechanical maintonance work on the "A" RBCCW system pump were observed ,
including a detailed review of the maintenance work package. The work was initiated to correct leakage from the pump mechanical seal which was leaking approximately 12 drops / minute. The pump had been operating well with normal vibration levels since the last overhaul completed in 1989. The inspector interviewed the planner, system engineer, maintenance work supervisor and maintenance department manager, Observations end Findinos Work to replace the "A" RBCCW pump mechanical seal began on July-23,>1997 using -
maintenance request (MR) No. 19700930. The mechanics installed a new split mechanical
' seal. .The new seal failed the post work test (PWT) as evidenced by water leakage through the scal.- The new mechanical seal was disassembled, inspected for damage and the seal preload tension was increased slightly. No problerns were identified. The mechanical seal was re-installed into the pump; however, the mechanical seal stillleaked water. At this point, the seal preload tension was increased to the maximum amount allowed by the vendor guidance. On July 25,1997, the pump was started and the new mechanical seal overheated and became damaged. Further investigation determined that the pump thrust was 0.026 inches which exceeded the vendor limit of 0.005 0.008 inches. The work package was placed on hold pending further guidance to overhaul the pump due to possible excessive thrust indicating bearing race wear. Up to this point, only limited system engineering involvement occurred with the decisions being made by maintenance department personnel. From July 25,1997, through the end of this inspection period on August 16,1997, no more physical work occurred and the "A" RBCCW pump remained unavailabl To remove the pump for overhaul, BECo had to design and fabricate a dummy support pump to be installec 'to support the suction and discharge piping to keep the loop operabl The need for temporary piping support during pump removal was identified by the BECo sponsored service water system operational performance inspection (SWOPI) conducted in early 1995. Engineering personnel were previously. aware of the need to construct a temporary support as evidenced in PR 95.9025 but this activity was deferred by engineering management personnel due to higher engineering department priority item Due to the increased unavailability time of the "A" RBCCW pump, the RBCCW system
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exceeded the maintenance rule limit of greater than 176 hours0.00204 days <br />0.0489 hours <br />2.910053e-4 weeks <br />6.6968e-5 months <br /> /2 years for any pump train; resulting in the HBCCW system be classified as an A.1 maintenance rule system. The inspector determhed that the RBCCW systvm became an A.1 system because of the unavailability of a t:mporary support structur The inspector observed that the work package instructions to replace the mechanical seal provided sparse guidance by simply referencing the vendor manual (i.e., VO309)
instructions. The vendor instructions did contain guidance to determine whether or not the pump was in generally good condition prior to installing the new mechanical split sea However, the work plan did not provide specific guidance on which sections of the vendor manual needed to be performed. The maintenance supervisor assumed the pump was in good condition based on f avorable vibration reading Several corrective actions were taken or planned. First, the inspector was informed that the pump coupling preventive maintenance (PM) procedure (l.c.,3.M.414), which has an annual periodicity and its repetitive task sheet will be changed to take thrust readings
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during the annual coupling PM. This will allow trcnding of pump thrust to better diagnose overall pump condition and need for overhaul. Secondly, the maintenance department mcnager informed the inspector that an I&C department review was planned to confirm
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that vibration readings were taken in the correct locations since the "A" RBCCW pump vibration data did not indicate degraded pump conditions. Lastly, the work control-department manager held training with planners to emphasize the importance of providing batter quality work plan guidance such as specifying which sections of vendor manuals nded to be performed to aid maintenance personnel performing the wor Conclusions The Installation of a new split sealinto the "A" RBCCW pump failed the post work test and damaged the new seal due to an overall degraded pump in need of overhaul. An untimely response to refurbish the pump caused the RBCCW system to be considered an system per the maintenance rule criteria and resulted primarily from the slow resolution of a SWOPl (circa 1995) issue by the engineering department involving the need to design and f aoricate a dummy RBCCW pump to support the suction and discharge header piping during pump removal for overhaul. The work control department work plan guidance for the work was sparse and simply referenced the vendor manua! rather than clearly specifying which sections needed to be performed. Limited effective system engineering involvement was eviden M3 Maintenance ProWures and Documentation M3.1 (Closed) Insoector Follow item (50-293/95 21-01h Master Surveillance Trackina Pronrom (MSTPh and related LERs 96 10,95 09,95-07 insoection Scoon (61726)
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A review was performed of the corrective actions taken to address problems experienced with the MSTP As a result of the corrective actions, BECo identified several 10 CFR 50.73 reportable issues and submitted licensee event reports (LERs) to the NRC. Those
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LERs were also reviewed by the inspector to ensure compliance with the 10 CFR 50.73 requirements, Observation! Land Findinas A complete revalidatw of the MSTP ;.*ogram was completed per problem report 95.950 The review effort was extensive with one group loving 1200 individual task Enhancements were made to the MSTP and several MSTP problems were identified and corrected during the review. For example, LER 9610 reported that composite analysis samples of the waste neutralizing sump were not always taken. An NRC specialist inspector was involved with the identification of this neutralizing sump issue and Violation 90 08 02 was issued. LER 9610, dated #4ovember 4,1990, reported proper information to meet the requirements of 10 CFR 50.73 and is considered close For earlier events, LER 95 09, dated September 27,1995, reported a missed core spray surveillance test due to en operations personnel error. This error was documented in Section 3.3 of NRC Inspaction Report 50 293/95 21 where it was treated as an NCV. The content of LER 95 09 met the requirements of 10 CFR 50.73 and is considered close LCR 95 07, dated September 5,1995, reported a missed automatic depressurization system (ADS) surveillance test due to a personnel error. This missed ADS test was documented in NRC Inspection Report No. 9515, Section 3.3, and was treated as a NC The content of the LER met the requirements of 10 CFR 50.73 and is considered close Conclusions The MSTP revalidation effort was comprehensive and, therefore, effectively identified problems leading to appropriate corrective actions. The requirements of 10 CFR 50.73 were properly followed. IFl 95 2101, LER 9610, LER 95 09 and LER 95-07 were reviewed and are considered close M4 Maintenance Staff knoMedge and Performance M4.1 1)nexcocted Residual Heat Removal (RHR) Pumo Trio (URI 97 07 01 ard Undate VIO 90-06 02 Corrective Actions for Procedure Nonadherence) Insoection Scone (61726)
The inspector attended the July 18,1997, critique regarding the circumstances surrounding the inadvertently trip of the "C" RHR pump while operating in the torus cooling mode. At the time of the pump trip, E lab engineers were in the process of performing procedure 8.M 2 2.1.10, Attachment 1, for loss of voltage / degraded voltage routine testing of the 4160 volt emergency bus A5 relay 2. The inspector also reviewed the procedure in progress and questioned the E-lab worker involved with the pump tri _ _ _ .
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8 Observations and Findinas Appropriato personnel participated in the critique maeting whero it was determined that an E lab engineer incorrectly verified prerequisito stop 7.011)(b)(3) which specified to ensure that the "C" RHR pump was not running. The E lab engineer mentioned that he looked over on control room panel 903 and thought he verified the "C" RHR pump was not running by the evidence of a green pump status light. The worker felt that he could havo .
used better self verification techniques to complete the action. The worker had successfully completed the test numerous times before and was very experience Additionally at the critique, operations department management questioned the adequacy of the operations pre evolutionary briefing since operations personnel were aware that the
"C" RHR pump was running in the torus cooling mode. Hence, operations personnel were not fully cognizant of the plant impact details of the emergency bus undervoltage/ loss of voltage relay testin Problem report (PR) 97.9445 was initiated to document, evaluate and develop corrective actions in response to this event. The I&C department was tasked to conduct a probable cause evaluation which had not yet been completed at the end of this inspection perio The test was successfully reperformed with no problems. The inspector observed that the critique meeting and PR follow up actions were sufficient to develop lessons learned from this event. The inspector noted the involvement of a very experienced worker who became complacent during a routino evolution and admitted his mistak Based on review of the procedure, the lasporuct determined that the procedure worked as
- written and this event resulted from a procedural non adherence. BECo corrective actions
.for the procedure use problems are ongoing and NRC staff review of effectiveness for this and other problems are being further reviewed (VIO 96-06 02 Update). BECo corrective act%ns have not been fully completed and, to some extent, have not had a chance to fully assuage the organization. Accordingly, the inspector questioned the proper disposition of the violation (discretion or not). This is unresolved pending further NRC staff revie (URI 97 07 01) Conclusions A timely and thorough critique was completed. An experienced E lab worker admitted his mistake in not adhering to the procedure during the conduct of routine surveillance testing on emergency bus 5. The E-lab engineer did not use good self checking technique Additionally, the pre-evolutionary briefing was identified by licensee personnel as a contributing cause since operators knew the "C" RHR pump was running in the torus cooling mode but were generally unaware of the plant impact of the surveillance test.
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111. ENGINEERIN_Q E2 Engineering Support of Facilities and Equipment E Non ASME Code Reoair on salt service water (SSW) Pinina Inspection Scooe (37551,92903)
On June 22,1997, an operator on tour observed leakage coming from an 18 inch diameter, carbon steel, SSW system piping spool piece (;.s., JF 29 8 2). The spool piece was located in the SSW system outlet piping from the "B" reactor building closed cooling water (RBCCW) system heat exchanger (i.e., E 200B1 which was directly downstream of butterfly valve MO 3806. After removal of piping insulation, the work it now team identified on June 23,1997 that through wallleakage existed in spool piece JF 29 8 The leakage consisted of five discreet perforations with three very smallin size and two larger perforations with an approximate diameter of 1/2 inch. The inspector reviewed the various engineering aspects of the evaluation, repair and root cause analysis related to the through wall SSW system piping leak Qhanty.ations and Findinas
- Problem reports (PR) 97. 9390,97.9414 and 97.9399 were initiated to document the leakage, initiate an operability evaluation and determine corrective actions. PR 97.9399 was assigned as a significant condition adverse to quality (SCAQ). The inspector reviewed NRC Generic Letter (GL) 90 05, "Guldance For Performing Temporary Non Code Repair of ASME Code Class 1,2 And 3 Piping." BECo engineers evaluated the merits of different types of temporary piping repairs as acceptable by GL 90-05. Given the nature of the perforations in the piping spool place which were allin the same general area, BECo opted to install a welded metal piping patch to add strength to the degraded spool piece are The inspector noted that the welded patch temporary repair was much more rigorous than simply covering and securing rubber sheets over the perforation The inspector verified that BECO inspected five other similar locations, in accordance with NRC GL 90 05, to determine the extent of the SSW piping degradation. Piping areas immediately downstream of butterfly valves, which were routinely throttled, were selected for inspection. No other similar problems were identified by quality assurance personnel who completed the pipe wall thickness measurements. Engineering personnel speculated that the perforations resulted from throttling butterfly valve MO 3806 which resulted in flow turbulence that wore through the internal rubber lining. This allowed the salt water to contact the carbon steel piping allowing accelerated erosion / corrosion. The inspector determined that BECo closely adhered to GL 90 05 by inspecting five other similar locations to properly determine the problem scop On July 7,1997, BECo submitted letter 2.97.072 to the NRC for review and approval of the non ASME code repair. A detailed 10 CFR 50.59 safety evaluation determined that an unroviewed safety question was not introduced by the ternporary pipe repair. Engineering personnel issued temporary modification 97-42 which provided the necessary instructions to install a 3/8 inch wolded pipe patch that was approximately 16 inches wide and 28
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inches long. The repair plan included a detailed monitoring plan to initially perform ultrasonic testing weekly and also have operators inspect the degraded area on a shiftily basis. The inspection schedule was intended to be reduced after the repair but not less than once/ month. BECo committed to perform a permanent ASME code repair during the next scheduled refueling outage (i.e., RF012) or next planned outage exceeding 30 day The NRC completed review of the repair plan and authorized BECo to install the pipe patch on July 10,1997. The inspector determined that engineering personnel took thorough corrective actions to provide the necessary engineering evaluations to develop and execute the repair pla A preliminary root cause analysis determined that engineering specification M591 for
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rubber lined, carbon steel piping in the SSW system did not provide sufficient guidance to account for augmented SSW pipe spool pieces to account for degradation due to age, configurations or operational characteristics which can considerably accelerate the rubber lining degradation leading to severe erosion / corrosion of the pipe wall. Two contributing causes included the failure to consider the wear effects of operational characteristics (i.e.,
-increased local water velocities created by throttling the but'.orfly valve) and the failure to recognize the predicted 15 year service life of the rubber lining. Quality assurance personnel informed the inspector that advanced methods of ultrasonic testing would be
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evaluated to try to detect SSW pipe wall thinning prior to the development of actual through wallleak Conclusionr, The engineering staff properly utilized NRC GL 90 05 to develop a repair plan for the degraded section of SSW spool piece, develop an inspection plan for possible similar degraded areas and obtain NRC review and approval. The temporary repair method of installing a welded metal patch was more rigorous than other potential alternatives such as the installation of a soft rubber patc IV. PLANT SUPPORT S1 Conduct of Security and Safeguards Activities (OpenIFl 96 04-01: Assessment Aid Weakness) Insoection Scoce The inspector reviewed the security program during the period of August 11 14,199 Areas inspected included: management support; protected area (PA) detection equipment; alarm stations and communication; testing, maintenance and compensatory measures; training and qualification, and the vehicle barrier system. The purpose of this inspection was to determine whether the licensee's security program, as implemented, met the licensee's commitments and NRC regulatory requirement _ _ _
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11 ~ Observations and Findinas Management suoport was evident by support for upgrades to the self assessment program, the tactical firtwrms training course, and the photo badge processing syste Alarm station operators were knowledgeable of their duties and responsibilities and security training was being performed in accordance with the NRC approved training and qualification (T&O) pla The PA detection equiprnent satisfied the NRC approved physical security plan (the Plan)
commitments and security equipment testing was being performed as required by the Pla Maintenance of security equipment was being performed in a timely manner as evidenced by minimal compensatory posting associated with non functioning security equipment. An inspector follow up item associated with degraded assessment capabilities will remain open pending installation of the new CCTV cameras ordered the week of the inspection, o (IFl 96 04 01) Conclusions The inspector determined that the licensee was conducting its security and safeguards activities in a manner that protected public health and safet Status of Security Facilities and Equipment S2.1 Protected Area Detection Al(g insoection Seece The inspector conducted a physical inspection of the PA intruslen detection systems (IDSs)
to verify that the systems were functional, effective, and met the licensee's Plan commitment Observations and Findingg On August 13,1997, the inspector determined by observation and selected testing that the IDSs were functional and effective, and were installed and maintained as described in the Plan, Conclusion The PA IDSs met the licensee's Plan commitment S?.2 Alarm Stations and Communicationg Insoection Scopa Determine whether the Central Alarm Station (CAS) and Secondary Alarm Station (SAS)
are: 1) equipped with appropriate alarm, surveillance and communication capability, 2)
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continuously manned by operators, and that 3) the systems are independent and diverse so ,
that no single act can remove the capability of detecting a threat and calling for assistance, or otherwise responding to the threat, as required by NRC regulation Observations and Findinos Observations of CAS and SAS operations verified that the alarm stations were equipped with the appropriate alarm, surveillance and communications capabilities. The inspector determined that aggressive maintenance of the system has substantially improved previously identified weakness in the assessment capability for the operators of the alarm stations using the fixed closed circuit television (CCTV) cameras. However, due to the age of the cameras, maintenance has not been totally effective in keeping the cameras operable, and a review of maintenance requests discloseri that the CCTV's were high maintenance items. Adequate compensatory measures were being implemented. During the inspection, the licensee made the decision to replace the aging CCTV cameras. As noted in Section S1, an inspector follow up item associated with marginally effective assessment aids will remain open pending the installation of the new cameras and will be reviewed during a subsequent inspectio Interviews with CAS and SAS operators found them knowledgeable of their duties and responsibilities. The inspector also verified through observations and interviews that the CAS and SAS operators were not required to engage in activities that would interfere with their assessment and response functions, and that the licensee had exercised communications methods with the locallaw enforcement agencies as committed to in the Plan, Conclusion The alarm stations and communications met the licensee's Plan commitments and NRC requirements. During the inspection BECo management informed the inspector of their decision to replace the high maintenance, aged closed circuit surveillance syste S2.3 Testino, Maintenance and Comoensatorv Measures IDap_pction Scone Determine whether programs were implemented that will ensure the reliability of security ,
related equipment, including proper installation, testing and maintenance to replace defective or marginally effective equipment. Additionally, determine that when security related equipment failed, the compensatory measures put in place were comparable to the effectiveness of the security system that existed prior to the failure, Observations and Findinas Review of testing and maintenance records for security-related equipment confirmed that the records were on file, and that the licensee was testing and maintaining systems and equipment as committed to in the Plan. A priority status was assigned to each work
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request and repairs were generally being completed in a timely manner for all work necassitating compensatory measures, Conclusions Security equipment repairs were timely. The use of compensatory measures was found to be appropriate and minima Security and Safeguards Staff Training and Qualification insoection S.q. gag Determine whether members of the security organization were trained and qualified to perform each assigned security related job task or duty in accordance with the T&Q plan, Observations and Findinas On August 12,1997, the inspector observed tactical firearms training and qualification on the firearms range and determined that the training was conducted in accordance with the T&Q plan and that the range was controlled in a safe manner. On August 13,1997, the inspector met with the security training staff and discussed the training requalification program and its effectiveness and reviewed the training records for 10 security officers.-
Additionally, the inspector interviewed a number of supervisors and officers to determine if
- they possessed the requisite knowledge and ability to carry out their assigned dutie Conclusions The inspector determined that training had been conducted in accordance with the T&O-plan. Based on the supervisors' and officers' responses to the inspector's questions, the training provided by the security training staff was considered effective. The tactical firearms training was challenging and well controlled. All records reviewed were complete-and well organized. Security training is considered a program strengt Security Organization and Administration Insoection Scooe Conduct a rt'siew of the level of management support for the licensee's physical security program, O
_ bservations and Findinas The inspector reviewed various program unhancements made since the last program inspection, which was conducted in Ja.nuary 1997, and discussed them with security management. These enhancements included upgrades to the self assessment programs, the tactical firearms training course, and the photo badge processing syste _ _ =
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SS Miscellaneous Security and Safety issues S8.1 Vehicle Barrier System (VBS)
L Gene al-On August 1,1994, the Commission amended 10 CFR Part 73, " Physical Protection of l Plants and Materials," to modify the design basis threat for radiological sabotage to include
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the use of a land vehicle by adversaries for transporting personnel and their hand carried equipment to the proximity of vital areas and to include the use of a land vehicle bom .
The amendments require reactor licensees to Install vehicle control measures, including- 4
.-vehicle barrier systems (VBSs), to protect against the malevolent use of a land vehicl Regulatory Guide 5.68 and NUREGICR-6190 were issued in August 1994 to provide guidance acceptable to the NRC by which the licensees could meet the requirements of the ;
amended regulation A May 3,1996, letter from the licenses to the NRC forwarded Revision 13 to its physical security plan. The letter stated, in part, that vehicle control measures meet the criteria of
+ 10 CFR 73.55(c)(7), (8) and (9) and the design goals of the " Design Basis Land Vehicle"a
and " Design Basis Land Vehicle Bomb." . A NRC June.24,1997, letter advised.the licensee that the changes submitted had been reviewed and were determined to be consistent with
- the pr'ovisions of 10 CFR 50.54(p) and were acceptable for inclusion in the NRC approved security pla This inspection, conducted in accordance with NRC Inspection Manual Temporary instruction 2515/132, " Malevolent Use of Vehicles at Nuclear Power Plants," dated January 18,1996, assessed the implementation of the licensee's vehicle control measures, ,
including vehicle barrier systems, to determine if they were commensurate with regulatory requirements and the licensee's physical security plan.-
S8.2_ Vehicle Barrier System (yEjl insoection Scone The inspector reviewed documentation that described the VBS and physically inspected the as built VBS to verify it was consistent with the licensee's summary description submitted
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to the NRC and was in accordance with the provisions of NUREG/CR 619 Observations and Findinas
- The inspector's walkdown of the VBS and review of the VBS summary description disclosed that the as built VBS was consistent with the summary description and met or exceeded the specifications in NUREG/CR 6190.- During the physical inspection of the
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VBS, the inspector noted that the VBS in one area was only marginally acceptable. After
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discussion between the licensee and the inspector, it was determined that the !
effectiveness of vehicle barriers could be significantly enhanced through a simple ;
modification. The modification was completed at this location prior to the conclusion of i the inspection, i
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- The inspector determined that these were no discrepancies in the as built VBS or the VBS summary description.
l S8.3 Bomb Blast Analysis
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The inspector reviewed the licensee's documentation of the bomb blast analysis and
.- verified actual standoff distances provided by the as built VB j Observations and Findinas
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The inspector's revlew of the licensee's documentation of the bomb blast analysis
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determined that it was consistent with the summary description submitted to the NRC.
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- The inspector also verifled that the actual standoff distances provided by their.as built VBS !
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were consistent with the minimum standoff distances calculated using NUREG/CR 619 The standoff distances were verified by review of scaled drawings.
, Conclusion No discrepancies were noted in the documentation of bomb blast analysis or actual-standoff distances provided by the as built VB S8.4- Procedural Controls Insoection Scooe The inspector reviewed applicable procedures to ensure that they had been revised to !
include the VBS.
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I Observations and Findinas The inspector reviewed the licensee's procedures for VBS access control measures, )
surveillance and compensatory measures. _The procedures contained effective controls to !
provide passage through the VBS, provide adequate surveillance and inspection of the l
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16 Conclusion The inspector's review of the procedures applicable to the VBS disclosed no discrepancie F2 Status of Fire Protection Facilities and Equipment F Operatina Exoerlence Review Insoection Scope
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A review was performed of the applicability of the lessons learned through an event on August 7,1997 at the Haddam Neck 1 nuclear power plant which involved the inadvertent actuation of the control room automatic halon fire suppression system. Operators evacuated the control roo.n, made several entries as needed using self contained breathing apparatus (SCBAs) and declared an Unusual Event. The inadvertent actuation occurred
.- > when an individual took a photograph of the halon actuation panel. The inspector reviewed the details of this Haddam Neck 1 event in NRC Preliminary Notificatlan PNO l-97-04 Observations and Findinas Unlike Haddam Neck 1, the PNPS control room does not have an automatic fire suppression system. Hand held carbon dioxide and water fire extinguishers are stationed in the PNPS control room for fire suppression purposes. Hence, the inspector determined that the lessons learned at Haddam Neck 1 were not directly applicable to PNPS. Five
,SBCAs are mounted in the PNPS control room which are inspected and maintained through procedure 6.7.1 106, " Inspection and Testing of Respiratory Protection Equipment." The
- inspector did not locate any information in the UFSAR or technical specifications relating to the basis for the number (i.e.,5) of SCBAs located in the control room. BECo personnel speculated that the number of SBCAs in the control room was probably related to the size of the control room crew. The inspector had no further questions or concerns, Conclusions The lessons learned at Haddam Neck 1 on August 7,1997 when an automated fire suppression system inadvertently initiated were not directly applicable to PNPS since the control room has no automatically initiated fire suppression systems. Positive control of the five PNPS control room self contained breathing apparatus (SCBA) was eviden V. MANAGEMENT MEETINGS X1 Exit Meeting Summary The inspectors presented the inspection results to members of licenseo management at the conclusion of the inspection on September 11,1997. The licensee acknowledged the
. findings presented. Also, the security inspector met with the licensee representatives at the conclusion of the inspection on August 14,199 ___.__
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X4 Review of UFSAR Commitments A recent discovery of a licensee operating their f acility in a manner contrary
- to the UFSAR description highlighted the need for additional verification that licensees were complying with Updated Final Safety Analysis Report (UFSAR) commitments. For an indeterminate time period, all reactor inspections will provide additional attention to UFSAR commitments and their incorporation into plant practices and procedures. While performing inspections discussed in this report, inspectors reviewed the applicable portions of the UFSAR. No inconsistencies were note . .. .. -
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INSPECTION PROCEDURES USED Tl 2515/133: Implementation of Revised 49CFR Parts 100179 and 10 CFR Part 71 IP 37551: Onsite Engineering IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems IP 61726: Surveillance Observation IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support Activities
!P 82301: Evaluation of Exercises for Power Reactors IP 82701: Operational Status of the Emergency Preparedness Program IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive Materials IP 92700: Onsite Followup of Written Reports of Non routine Events at Power Reactor Facilities IP 92901: Followup Operations IP 92902: Followup Maintenance IP 92903: Followup Engineering IP 92904: Followup Plant Support _ _
IP 93702: Prompt Onsite Response to Events at Operating Power Reactors
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ITEMS OPENED, CLOSED, AND UPDATED CLOSEQ IFl 95 2101 MSTP/ TECH Spec Correlation inadequacy LER 9610- TS Required Composite Analysis LER 95 09 Surveillance Procedure for Core Spray Motor OP Valve LEH 95 07 Simulated Auto Actuation Test Not Performed Open/ Undated URI 97-07 01 Procedure Nonedherence (Section M4.'1)
VIO 96 06-02 Corrective Actions for Procedure Nonadherences System test replacement (Section M4.1)
IFl 96 04 01- Assessment Aid Weakness (Section S1) s
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LIST OF ACRONYMS USED PNPS Pilgrim Nuclear Power Station BECo- Boston Edison Company TS Technical Specifications EDG emergency diesel generator MSIV main steam isolation valve LER I.lconsee Event Report CFR Code of Federal Regulations EPIC Emergency and Plant information Computer ESF engineered safety feature IR inspection report NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation PR Problem Report UFSAR Updated Final Safety Analysis Report ECCS emergency core cooling system RHR residual heat removal EOP emergency operating procedure ALARA As Low As Reasonalty Achievable
- I&C Instrument & Control IFl Inspector Follow item NCV Non Cited Violation NOV Notice of Violation