IR 05000293/1998001

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Insp Rept 50-293/98-01 on 980107-0224.Violations Noted.Major Areas Inspected:Licensee Operations,Engineering,Maint & Plant Support
ML20217F014
Person / Time
Site: Pilgrim
Issue date: 03/24/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20217E986 List:
References
50-293-98-01, 50-293-98-1, NUDOCS 9803310240
Download: ML20217F014 (32)
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Enclosure U.S. NUCLEAR REGULATORY COMMISSION

REGION I

License No.: DPR-35 Report No.: 98-01 Docket N Licensee: Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199 Facility: Pilgrim Nuclear Power Station i Inspection Period: January 7,1998 - February 24,1998 l

Inspectors: R. Laura, Senior Resident inspector R. Arrighi, Resident inspector S. Dennis, DRS Operations Examiner J. Jang, DRS Radiation Specialist Approved by: Curtis J. Cowgill, Ill, Chief ;

Reactor Projects Branch No. 5 Division of Reactor Projects i i

9803310240 900324 PDR ADOCK 05000293 G PDR

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O l EXECUTIVE SUMMARY Pilgrim Nuclear Power Station NRC Inspection Report 50-293/98-01 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers resident inspection from January 7, 1998 through February 24,1998;in addition, it includes the results of announced inspections by a regional effluent specialist and also an operations examine Ooeratiorls

  • During two power reductions to support work in the condenser bay, good use of self-checking and procedure adherence was evident. Also, an operations self assessment was determined to be self critical with the identification of areas for improvement and the use of industry peers. (Section 01.1)
  • A mechanical joint leak in the Standby Liquid Control (SBLC) system was identified and discussed with the Nuclear Watch Engineer (NWE) for resolution. (Section 01.1)
  • The control room high efficiency air filtration system was properly configured to support system operability. No substantive concerns were noted during the walkdown of the system. Technical specification surveillance requirements were properly captured in BECo surveillance procedures. (Section O2.1)
  • Procedures for cold weather were properly implemented. The cold weather program at BECo was determined to be weak in that not all instrumentation for cold weather protection gets periodically calibrated / tested and is thereby subject to potential f ailure. (Section O2.2)
  • A comprehensive BECo review was performed to resolve an internal nuclear safety concern involving an operator log issue from 1989. (Section 04.1)
  • The Nuclear Safety Review and Audit Committee (NSRAC) was effective in the evaluation of potential safety significant issues. Meaningful discussions occurred that focused on reactor safety. (Section 07.1)
  • Corrective actions to resolve a broad procedure adherence problem were determined to be adequate to close two previous procedurs adherence violations. The initial corrective actions were not entirely effective, but additional corrective measures were developed and either implemented or are planned to be implemented this yea (Section 08.1)

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I Maintenance

Work activities were performed within the Technical Specifications (TS) allowed time and performed ahead of schedule. A good questioning attitude was demonstrated by the maintenance craft and good communications between j maintenance and engineering was noted in resolving the torque value for the "C" ,

Residual Heat Removal (RHR) terminal box. Good procedural adherence was I observed for all activities observed. (Section M1.1)

resolved with the assistance of the system engineer and I&C technicians. (Section !

M1.1)

Review of a past significant maintenance performance issue involving valve, AO-l 7011B, determined that the correct parts were not available during work when the system engineer ordered the incorrect parts and did not follow the prescribed procedure. (Section M8.1)

l Enaineerina

A violation of 50.72 reporting requirements resulted when engineering personnel initiated an engineering evaluation for a newly discovered problem with the Emergency Diesel Generator (EDG) fuel oil system but failed to follow the l

, established problem report process by initiating a problem report in a timely manner.

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  • A past programmatic problem with updating the Updated Final Safety Analysis l

Report (UFSAR) was closed out as a violation. (Section E8.1)

  • Improvements in the control and oversight of vendor services addressed previous problems in this area (Section E8.2)

Plant Sucoort

  • Effective radioactive liquid and gaseous effluent control programs were maintained l

and implemented. (Section R1.1)

l * An adequate calibration program was maintained and implemented. (Section R2.1)

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  • An adequate air cleaning surveillance program existed. (Section R2.2)
  • The plant air balance was maintained in accordance with established design specifications and the UFSAR. (Section R2.3)

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The inspector concluded: (1) effluent control procedures were sufficiently detailed to f acilitate performance of all necessary steps; (2) the licensee effectively implemented the TS and Offsite Dose Calculation Manual (ODCM) requirements for reporting effluent releases and projected doses to the public; and, (3) the licensee's t ODCM contained sufficient specification, information, and instruction to acceptably implement and maintain the radioactive liquid and gaseous effluent control j programs. (Section R3.1)

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QA audits were sufficient to effectively assess the radioactive liquid and gaseous effluent control programs. The licensee implemented a good OA/QC program to validate measurement results for effluent samples. (Section R7.1)

The minimum number of compensatory measures in place and the prompt response

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to repair identified degraded conditions indicates good management of security equipment. (Section S1.1)

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TABLE OF CONTENTS

EX EC UTIV E S U M M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii Summary of Plant Status ............................................1 l 1. O PE R AT I O N S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

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01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Comments (71707) ........................... 1 02 Operational Status of Facilities and Equipment ................... 2 i O2.1 Safety System Walkdown - Control Room High Efficiency Air Filtration System..........................................2 O2.2 Cold Weather Preparations . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 04.1 (Closed) NCV 98-01-01 andIFl 50-293/97-11-02: Operator Log Issue l Fr o m 1 9 8 9 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 '

07 Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 l 07.1 Offsite Review Committee Meeting . . . . . . . . . . . . . . . . . . . . . . 4 j 08 Miscellaneous Operations issues (90712,92700,92901) ........... 5 l 08.1 (Closed) VIO 50-293/97-06-01: Reactivity Manipulations ...... 5

! 08.2 (Closed) VIOs 50-293/96-06-02and 50-293/97-80-01: Procedure i

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Adequacy and Usage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

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08.3 (Closed) LER 50-293/96-09: Group 3 Isolation due to False High Reactor Vessel Pressure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 L 08.4 (Closed) LER 50 293/96-08: Reactor Shutdown Due to a Leak in the 1 l

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Reactor Building Closed Cooling Water (RBCCW) System . . . . . . . 6 08.5 (Closed) LER 5 0-2 9 3 /9 7-004 . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 j 08.6 (Closed) NCV 98-01-02 and LER 50-293/97-016: Recirculation l

System loop "B" Pump Trip . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 4 l 08.7 (Closed) NCV 98-01-03 and URI 50-293/97-02-01: Equipment issues I

...............................................7 ll . M AI NT EN AN C E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8  !

M 1.1 General Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8  !

M8 Miscellaneous Maintenance issues (92902) .................... 10 i M8.1 (Closed) NCV 98-01-04 and URI 50-293/96-03-02: Human Performance issues Related to Working on the Wrong Valve ... 10 lli . ENGIN EERI NG . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1 E4 Engineering Staff Knowledge and Performance . . . . . . . . . . . . . . . . . . 11 l E (Closed) NCV 98-01-05 and URI 50-293/96-10-02:FFWTR Safety Eva l u a tio n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1 E4.2 (Open) VIO 50-293/98-01-07: Late 50.72 Notification; and (Closed)

NCV 98-01-06 and LER 50-293/98-01: Single Failure Vulnerability of l the Emergency Diesel Generator (EDG) Fuel Oil Supply System . . 11 E8 Miscellaneous Engineering issues (92700,92903) . . . . . . . . . . . . . . . . 13 E8.1 (Open) VIO 50-293/98-01-08:UFSAR Update Process; (Closed) URI 50-293/96-10-03:UFSAR Update Process . . . . . . . . . . . . . . . . 13 v

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l E8.2 (Closed) IFl 50-293/95-22-02: Vendor Services . . . . . . . . . . . . . 14 E8.3 (Closed) IFl 50-293/96-02 02: Spent Fuel Pool Licensing Basis . . 15 l E8.4 (Closed) LER 50-293/96-03:RCIC System inoperable Due to i Anomalies During Testing . . . . . .. . . . . . . . . . . . . . . . . . . . . . . 15 E8.5 (Closed) LER 50-293/96-04-01: Low Voltage Power Primary Containment . . . . . . . . . ...........................15 E8.6 (Closed) LER 50-293/97-08: Setpoint of Target Rock Relief Valve Pilot Assembly Found Out of Tolerance During Testing . . . . . . . . 16 IV. PLA NT S U PPO RT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 i R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . 16 l R1.1 Implementation of the Radioactive Liquid and Gaseous Effluent

! ControI Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 -

R2 Status of RP&C Facilities and Equipment ......................17 R2.1 Calibration of Effluent / Process / Area Radiation Monitoring Systems (RMS)..........................................17 R2.2 Air Cleaning Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 R2.3 Plant Air Balance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 R3 RP&C Procedures and Documentation . ...................... 19 R3.1 Effluent control programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

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R6 RP&C Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . . 20 l R7 Quality Assurance (QA) in RP&C Activities . . . . . . . . . . . . . . . . . . . . . 20 l l R7.1 Quality control programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 l R8 Miscellaneous RP&C lssues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 l R (Closed) VIO 50-293/96-08-02: Implementation of radioactive effluent ,

control program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 l Conduct of Security and Safeguards Activities . . . . . . . . . . . . . . . . . . 21

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S1 S1.1 Compensatory Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 V. M AN AG EM ENT MEETING S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2 l X1 Exit Meeting Sum m ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2

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X4 Review of UFSAR Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 l  !

I INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 l

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ITEMS OPENED, CLOSED, AND UPDATED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 l i

LI ST O F AC R O N Y M S U S E D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 6 l

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Enclosure 2 REPORT DETAILS Summarv of Plant Status

, Pilgrim Nuclear Power Station (PNPS) began the period at 100 percent reactor power.

l Power was reduced to approximately 50 percent on January 16,1998, and again on January 22,1998, to make temporary repairs to a steam leak from an isolation valve for the zine injection skid. Since the leaking valve was located inside the condenser bay, plant l management chose to lower power to reduce radiation levels and personnel exposure. At the completion of the maintenance to the valve, operators returned the unit to 100 percent l power, where it remained through the end of the period.

l 1. OPERATIONS l l

01 Conduct of Operations l

01.1 General Comments (71707)

Using Inspection Procedure 71707,the inspector conducted frequent reviews of ongoing plant operations. In general, the conduct of operations was professional and safety conscious. The inspector observed that proper control room staffing was maintained, continued use of self-checking and effective pre-evolution briefings, and plant behavior was commensurate with the plant configuration and ,

plant activities in progress. Anomalies noted during plant tours were discussed with the nuclear watch engineer. For example, mechanical joint leakage downstream of standby liquid control (SBLC) system valve 1101-49 was evident by boron residu ;

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After informing the NWE, the boron residue was removed and the joint was monitored to determine whether an active leak existed. The inspector had no further concern in this regar The inspector reviewed the operations department fourth quarter self-assessment, dated February 25,1998, which was performed by industry peers to benchmark operations performance. The assessment noted both strengths and areas for improvement. For example, one opportunity for improvement involved the reformatting of abnormal procedures. Discussions with the Assistant Operations Department Manager revealed that plans are in place or being developed to address those areas noted in need of improvement. The inspector found the assessment to be self-critical, and the use of industry peers during the review was considered to be a strength.

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l Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized reactor inspection report outline. Individual reports are not expected to address all outline topic *

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O2 Operational Status of Facilities and Equipment O2.1 Safety System Walkdown - Control Room Hioh Efficiency Air Filtration System (CRHEAFS) Inspection Scoce (71707)

Accessible portions of the CRH AFS were walked down to verify proper system configuration to assure system operability. Also, the applicable surveillance procedures were reviewed to ensure the procedures met the intent of technical specification (TS) surveillance requirement Observations and Findinos Based on review of the piping and instrumentation diagram (P&lD) and of the normal and abnormal operating procedures for the CRHEAFS, the inspector determined that the system was properly aligned and 9perated as described in the Updated Final Safety Analysis Report. Review of BECo surveillance procedures for the CRHEAFS revealed that the surveillances accurately captured TS requirements. Equipment operability, material condition, and housekeeping were determined to be acceptabl No discrepancies were note Conclusions The CRHEAFS was found to be properly configured to support system operability during a safety system walkdown. No substantive concerns were noted during the walkdown of the systern. Technical specification surveillance requirements were properly captured in BECo surveillance procedure .2 Cold Weather Preparations Insoection Scope (71714)

The inspector reviewed BECo's program to protect safety-related systems against cold temperatures that could lead to freezing concerns during the winter month Observations and Findinos Procedure 8.C.40, " Cold Weather Surveillance," provides an outline of actions to due in preparation for winter to ensure support equipment for certain weather affected systems is operational. Systems / components include the station heating system, condensate storage tank heat exchanger, and station blackout diesel generator space heaters. The procedure is performed in the fall of each year.

l Another section of the procedure is performed whenever the outside air temperature l falls below 20*F. This requires walking down selected areas including the screen l house, emergency diesel generator and station blackout diesel rooms, and the stack sample line to ensure the areas are maintained above 32 * F, check the condition of f

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The inspector also reviewed the implementing procedure and verified that the cold weather surveillance was satisfactorily performed in October 1997. A review of

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outside temperature data for the month of January 1998 revealed that the

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temperature dropped below 20*F on two occasions and the applicable portions of procedure 8.C.4-0 were performed as required. A walkdown of the outside areas, the intake structure, the emergency diesel generator and station blackout diesel generator area revealed that all exposed piping was insulated, heat tracing installed, indoor temperatures were above 32 * F, and area heaters in the station blackout diesel room were operationa Discussions with the l&C Manager regarding calibration, testing and preventive maintenance for instrumentation associated with heat tracing, space heaters, and thermostats revealed that not all cold weather instruments are periodically calibrated / tested. Procedures exist for the heating, ventilation, and air-conditioning instruments; however, there are no requirements to test other cold weather instrumentation. After the inspection period ended, the licensee initiated a problem report to evaluate this conditio Conclusions Procedures for cold weather were properly implemented. The cold weather program at BECo was determined to be weak in that not all instrumentation for cold weather 1 protection gets calibrated / tested periodically and is thereby subject to potential failur Operator Knowledge and Performance 04.1 (Closed) NCV 98-01-01 andIFl 50-293/97-11-02:Ooerator Loa Issue From 1989 BECo previously informed the NRC of an internal nuclear safety concern (NSC)

dealing with an operator log entry made in 1989 as documented in section 08.1 of NRC Inspection Report No. 50-293/97-11. BECo had an independent investigation performed to review the circumstances of the log entry in question. BECo made a formal NRC notification pursuant to 10 CFR 50.72 and issued a local press releas During this inspection period, BECo issued letter 2.98.009 to the NRC, dated January 29,1998, which provided the results of the investigation. Specifically, the internal NSC was not substantiated; however, an error was identified for a control room log entry made in September 198 During this inspection period, the inspector reviewed the report issued by the independent investigative service. Additionally, the inspector reviewed the control room log entry made at 8:40 a.m. on September 2,1989, while the plant was shutdown. The log entry stated " Inserted full reactor scram for replacement of IRM bypass switches...... Placed mode switch in Shutdown." BECo determined that the scram was actually inserted by taking an IRM out of bypass in the "B" channel of i RPS in conjunction with an existing half scram on the "A" channel of the RPS. The control room alarm type output showed that the mode switch was not moved to the shutdown position until 14 minutes later. The licensee's investigation determined

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l that the error in the 8:40 a.m. operator log entry most likely resulted from

miscommunication between the reactor operator and the nuclear operating j l supervisor. During this inspection period, BECo made a late entry in the control lt

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room log which corrected the error made in the aforementioned log entry regarding the method of inserting a full reactor scram while shutdow .

This non-repetitive licensee-identified and corrected operator log violation is being

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treated as a Non-Cited Violation (NCV 50-293/98-01-01), consistent with Section Vll.B.I of the NRC Enforcement Policy. Since the scram in question was a planned initiation of an ESF actuation signal for maintenance purposes, BECo determined that the event was not reportable pursuant to the reporting criteria specified by 10 CFR 50.72/73. The inspector identified no new concerns and determined that BECo )

had performed a satisfactory review. IFl 97-11-02is considered close Quality Assurance in Operations 07.1 Offsite Review Committee Meetina Insoection Scope (71707)

The inspector attended the Nuclear Safety Review and Audit Committee (NSRAC)

meeting held on February 11 and 12,1998, to assess the committee performance .

and compliance with technical specifications (TS).

L Observations and Findinas The NSRAC is comprised of seven members; five of which are not members of the plant staff. Mr. William Metevia was appointed as a new member by the NSRAC chair. All members were present at the meeting. The VP Nuclear Operations and Station Director and the Technical Section General Manager also attended the meetin During the meeting, various safety related topics were discussed including current operating status, proposed TS changes, quality audits performed since the last meeting, and prior NSRAC concerns / issues. Each department also addressed NSRAC and discussed performance criteria and challenges to their organizatio Based on the observed discussions, the NRC determined that the members were prepared for the meeting. The NSRAC members exhibited a questioning attitude, and an effective exchange of information occurred between the plant staff and the NSRAC members. The discussions focused on reactor safety and opportunities for improved performanc !

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s 5 Conclusion The inspector con'cluded that the NSRAC effectively performed reviews of station j activities that met the TS requirement !

l l l 08 Miscellaneous Operations issues (90712,92700,92 901) l 08.1 (Closed) VIO 50-293/97-06-01: Reactivity Manioulation This violation was reviewed and documented in NRC Inspection Report No. 50-293/97-06. BECo acknowledged the violation in their response letter dated August

. 18,1997, and determined that they had incorrectly interpreted what is a significant

! reactivity manipulation. An additional review, including guidance in NRC Information Notice 97-67, was completed by the operations training departmen ;

The licensee's review resulted in development of a comprehensive list of acceptable J and unacceptable methods of counting significant reactivity manipulations. The inspector conducted an on-site review and determined that the newly developed reactivity manipulation list and the revised RO/SRO qualification cards were acceptable. The inspector also indepenifontly confirmed that the additional l commitment for training department review was met. The inspector determined the licensee's corrective actions were appropriate and that violation 97-06-01 is considered close .2 (Closed) VIOs 50-293/96-06-02and 50-293/97-80-01: Procedure Adeauacy and Usene Section 07.1 in NRC Inspection Report No. 50-293/96-06-02, dated October 30, 1996, cited a corrective action violation involving the failure of BECo to identify an overall procedure adequacy and usage problem at the station. Some of the specific examples noted involved several self disclosing events that occurred during RFO10 in 1995. BECo admitted to the violation and made various commitments contained ;

in BECo letters 2.97-009, dated January 31,1997, and supplemental BECo i response letter 2.97-026, dated February 28,199 A second violation in the area of procedure adequacy and usage was issued in section 4.3 of NRC Inspection Report No. 50-293/97-80, dated September 17, 1997. The examples cited were identified by the NRC and were administrative in '

nature. BECo admitted to the violation and made various commitments in the BECo reply letter 2.97-104, dated October 17,1997, and supplemental BECo response ,

letter 2.97.132, dated December 17,199 !

The inspector reviewed the BECo root cause analysis, dated December 15,1997, in the procedure adherence area. Two primary causes were identified. The first cause was related to the structure and content of procedures which often times had cumbersome requirements. The second cause was that manager and supervisor oversight to resolve procedure adherence issues have generally not worke Previous corrective action plans endorsed by senior site management were not effective nor were they validated. Plant personnel developed an acceptance toward

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procedure non-adherence. Several other ancillary or contributing causes were also identified. The inspector determined that the root cause analysis was detailed and sufficiently self critica In letter 2.9.132, dated December 17,1997, BECo made three additional commitments to the NRC regarding corrective actions to prevent recurrence of procedure use and quality problems at PNPS. Two of the three commitments were scheduled for completion by the end of the first quarter in 1998 with the remaining one scheduled for completion by the end of the second quarter in 199 BECo recently completed a formal root cause analysis and committed to implement additional corrective actions to improve procedure use and quality. Additionally, BECo continues to implement the 22 previously committed specific actions to improve procedure use and quality. Based on review of the corrective action completed, the commitments contained in the four BECo response letters and the recent BECo root cause analysis, violations 96-06-02 and 97-80-01 are considered close .3 (Closed) LER 50-293/96-09:Grouc 3 Isolation due to False Hiah Reactor Vessel Pressure LER 96-09 reported a group 3 isolation (while shut down) of the primary containment isolation control system (PCIS) due to a false high reactor vessel i pressure signal. The signal occurred while backfilling a reactor vessel pressure transmitter. Investigation revealed that the cause of the false high reactor pressure ;

signal was a deficiency in the procedure being used to backfill the pressure transmitter. The inspector conducted an on-site review and verified that the applicable procedures had been revised. This issue was previously categorized as a NCV in Section E2.2 of NRC Inspection Report 50-293/96-08. This LER is considered close .4 (Closed) LER 50-293/96-08: Reactor Shutdown Due to a Leak in the Reactor Buildino Closed Coolino Water (RBCCW) Syste The details of the event were reviewed and documented in section 01.3 of NRC Inspection Report 50-293/96-06. An in-office review of the LER revealed that this issue was tracked as an inspector follow item to review and evaluate the root cause of the RBCCW heat exchanger failure. The follow item was subsequently closed in NRC Inspection Report 50-293/96-08Section E2.1. No violations of NRC requirements were identified. This LER is considered close .5 (Closed) LER 50-293/97-004: Loss of Preferred Off-Site Power and Oil Soill Due to Main Transformer Fault While Shut Dow The details of the event were reviewed and documented in section 01.2 of NRC Inspection Report 50-293/97-02. The inspector conducted an on-site review and visually verified the modifications made for a berm installation in the isophase bus duct area of the turbine building and the oil drainage pathway installed on the

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isophase bus header. Additionally, the associated design modification documents l

were verified. The inspector also reviewed and found acceptable the updated fire hazard analysis report as well as the BECo evaluation of the modifications and compensatory measures taken for the station blackout diesel. This LER met the requirements of 10 CFR 50.73. No violation of NRC requirements were identified by the inspector. This LER is considered close !

08.6 (Closed) NCV 98-01-02 and LER 50-293/97-016: Recirculation System Looo "B" l

Pumo Tri The details of this event were previously reviewed and documented in Section 0 of NRC Inspection Report No. 50 293/97-11. BECo determined that the root cause of the event was a proceduralinadequacy in surveillance test procedure 8.M.2-2.10.8.2," Diesel Generator "B" initiation by RHR Logic." Corrective actions in progress include a review and revision of all l&C logic system functional test procedures to provide sufficient operator guidance in regard to logic circuitry rese BECo will also include a review of the event as part of operator requalification and i

, l&C technician training. The inspector conducted an on-site review of the l

developed procedure list and the progress made to revise the affected procedure The list was found to be comprehensive with sufficient progress made at this time to ensure revision of the affected procedures prior to their next scheduled us Additionally, the inspector verified that the event was included in training program documentation. This LER met the requirements of 10 CFR 50.73 and the inspector identified no new concerns.

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The inspector determined the procedural inadequacy was a violation of 10CFR50, Appendix B, Criterion V, " Procedures." This non-repetitive licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section.Vil.B.1 of the NRC Enforcement Policy. (NCV 50 293/98-01-02). This LER is close .7 (Closed) NCV 98-01-03 and URI 50-293/97-02-01:Eauioment issues Two equipment issues emerged during the April 1997 reactor startup which affected operational activities, item (1) involved sluggish performance of several control rods during initial movement, in addition, rod 22-03 actually inserted under a withdrawal signal from position 04 to 02. Item (2) involved feed water system regulating valve (FRV) performance. At low power levels with one pump in service, large swings of approximately 1.3 million pounds mass / hour in feed flow were observe Regarding item (1), BECo determined that the cause of the sluggish rod movement was inadequate venting of the control rod dr ve (CRD) system prior to reactor startup. The erratic movement of rod 22-03 was attributed to the insert directional control valve being too far open. The CRDs were not stroke time tested at the end of the cycle 10 or 11 refueling outages (RFO). Actions taken/ planned by BECo to address this issue included adjusting the needle valve for rod 22-03, stroke time testing the control rods at the next forced outage, and requiring that dynamic

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venting of the drives be required prior to startup from a RFO. The inspector verified that a node was created in the master surveillance tracking program to require dynamic venting and stroke time testing of all control rods prior to startup from a RFO. The inspector also noted that several control rods were vented and approximately 30 rods were stroke time tested during the November 1997 maintenance outage. In addition, based on discussions with the system engineer and Assistant Operations Department Manager, and a review of operationallogs revealed that stroke time tes;bg of control rods are being performed quarterly at power during the technical specification required control rod scram timing testin The inspector notes that initial rod movement was improved during the startup from the November 1997 maintenance outag Regarding item (2), the Plant Manger initiated an issue team to solve the problems associated with the feed water control system. Review of feed water system traces revealed a step change in the "A" FRV and sporadic oscillation on the "B

FRV. The team determined that the apparent cause was inadequate preventive maintenance of the FRVs. The failure to perforra adequate preventive maintenance is a violation of Regulatory Guide 1.33, Appendix A, step 9, " Procedures for Performing Maintenance." ,

To resolve FRV performance issues, BECo lowered the packing setting on the "A" FRV and adjusted the booster gain of the "B" FRV. During the November 1997 forced outage corrective maintenance was performed that included calibrating the ,

valva positioner, and replacing the diaphragm, actuator yoke, and the signal i conditioner for the FRV. The inspector reviewed traces for the feed water system and noted that feed water flow oscillation has improved. A review of preventive maintenance activities revealed that several now preventive maintenance requests have been generated for the FRV Based on the timely and comprehensive corrections actions taken to address this ,

issue: this non-repetitive, licensee identified and corrected violation is being treated I as a Non-Cited Violation (NCV 98-01-03), consistent with Section Vll.B.1 of the l

NRC Enforcement Policy. This unresolved item is close '

I 11. MAINTEN ANCE M1 Conduct of Maintenance

M 1.1 General Maintenance I Insoection Scope (62707/61720)

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l The inspector observed all or portions of selected LCO maintenance and surveillance activities. Portions of the following activities were observed:

  • 19701685- Washer installation on bolts securing terminal box to "C" RHR i

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pump motor casing

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  • P9600993- "C" RHR pump motor breaker magger

-* P9701031- "C" RHR pump motor bearing tube oil samples

  • 19701686- Washer installation on bolts securing terminal box to "A" RH j pump motor casing

8.5.4.6f "HPCI Pump and Valve Operability from Alternate Shutdown Panel" Observations and Findinas A planned maintenance outage was performed on the "C" RHR pump pursuant to Technical Specification (TS) 3.5.A.4. The inspector observed that the overall work progressed well. A problem was noted by the l&C technicians performing work task 19701685 as they began to retorque the bolts. They observed a slight deformation of the terminal box casing as the bolts were initially torqued. They appropriately stopped work and the problem was referred to engineering for resolutiori. The system engineer contacted the vendor who recommended a lower torque value. The licensee initiated a problem report to evaluate the torque valv Following independent review and concurrence by the department manager the work continued and was completed in a timely manner. The required documentation for the change was reviewed by the inspector and found to be acceptable. The LCO for the "C" RHR pump was exited on schedule after the successful completion of the operations quarterly operability surveillance test. The lessons learned from the torquing issue on the "C" RHR pump terminal box were applied to the "A" RHR pump and work was completed without additional problem The LCO for the "A" RHR pump was also exited as schedule During operation of the HPCI system turbine from the alternate shutdown panel, a controller problem prevented the start of the HPCI turbine. As a precautionary measure, operators verified that the local controller anomaly did not affect operability from the control room by starting the turbine from the control room. I&C !

technicians troubleshot and repaired the controller, and the surveillance test was j successfully completed, l&C technicians found that pieces inside the controller j became loose and needed to be tightened. The licensee initiated a problem report 1 to evaluated this condition and determined additional action was necessar The inspector observed the operator's use of self checking and procedure adherence at the alternate shutdown panel and considered this a human performance strengt The surveillance test was well supported by the system engineer, radiation

protection and also a manager on tour. The system engineer indicated that the controller problem did not result in an on demand failure in accordance with the maintenance rule since the turbine controls from the control room were operable at all times. The controller malfunction was considered to be a maintenance preventable functional failure and would be tracked as part of the HPCI system. In summary, the surveillance test was effectively performed by operators and a test anomaly was resolved with the assistance by engineering and l&C personne ;

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! Conclusions Work activities were performed within the LCO allowed time. A good questioning attitude was demonstrated by the maintenance craft and good communications between maintenance and engineering was noted in resolving the torque value for the "C" RHR terminal box. Good procedural adherence was observed for all activities observed. A HPCI surveillance test was properly performed by operators j and a test anomaly was effectively resolved by the system engineer and l&C personne M8 Miscellaneous Maintenance issues (92902)

M8.1 (Closed) NCV 98-01-04 and URI 50-293/96-03-02: Human Performance issues Related to Workina on the Wrona Valve Maintenance personnel worked on the wrong train air-operated valve, AO-7011 A vice AO-7011B, as documented in section M4.1 of NRC Inspection Report 50-293/96-03, dated June 27,1996. No PNPS technical specification requirements were violated. This problem was self-identified, a critique was immediately held, and a significance level 1 problem report was generated. The violation of the work i package instructions by working on the wrong valve was previously treated as a j non-cited violation. However, the detailed root cause analysis had not been completed and was classified as an unresolved item relating to the use of the wrong parts during the maintenance activit BECo performed a root cause analysis, dated August 1,1996, to determine why the correct parts (i.e.,0-rings) were not available during the actuator work on AO-70118. The root cause analysis for the procurement of the wrong seal kit was the failure of the system engineer to correctly identify the required part using a controlled document such as the vendor manual or drawing. Corrective actions were taken including a revision to procedure 1.7.2, " Request For Materials and Stock Authorizations," to require a second check to ensure that the requested materialis in accordance with the plant design. Additionally, all engineering .

personnel were retrained on the importance of using only controlled design basis documents to determine the installed configuration. The inspector independently confirmed these actions. This non-repetitive, licensee identified and corrected violation is being treated as a Non-Cited Violation (NCV 50-293/98-01-04),

consistent with the Section Vll.B.I of the NRC Enforcement Policy. Unresolved item (50 293/96-03-02)is closed based on review of the BECo root cause analyses and related corrective actions associated with working on an incorrect valve and also obtaining the incorrect replacement parts. BECo subsequently ordered the correct

, parts and successfully completed corrective maintenance on AO-7011B. The l inspector identified no new concerns during this review.

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111. ENGINEERING

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E4 Engineering Staff Knowledge and Performance j l

E (Closed) NCV 98-01-05 and URI 50-293/96-10-02:FFWTR Safetv Evaluation l l

Sections 04.1 and E2.1 of NRC Inspection Report No. 50-293/96-10, dated February 7,1997, documented two potential weaknesses associated with safety evaluation (SE) 3018. This SE reviewed and approved lowering feed water , j temperature (FFWTR) at the end of the operating cycle to add additional core '

reactivity for cycle optimization. The operational aspects of FFWTR were implemented by the operations staff on January 11,1997, with no problem During this period, the inspector reviewed the final engineering actions taken to resolve the two potential weaknesses identified by the inspector. Overall, SE 3018 was very detailed and properly concluded that an unreviewed safety question (USO) l did not exist. The potential weaknesses related to the possible affect FFWTR had on the UFSAR evaluations for ATWS and reactor internal pressure differences (RIPDs). Both of these evaluations used normal feed water temperature in the initial conditions. BECo subsequently reverified that the FFWTR did not adversely affect the ATWS and RIPDs evaluations. Hence, the inspector determined that the weaknesses in SE 3018 were of minor significance. The stated weaknesses in the SE were isolated in nature as other SEs were typically of very good quality. This failure constitutes a violation of minor significance and is being treated as a Non-Cited Violation (NCV 50-293/98-01-05), consistent with Section IV of the NRC Enforcement Policy. URI 96-10-02 is close E4.2 (Ocen) VIO 50-293/98-01-07: Late 50.72 Notification: and (Closed) NQ 98-01-06 and LER 50-293/98-01:Sinale Failure Vulnerability of the Emeroency Diesel l Generator (EDG) Fuel Oil Sunofv System Insoection Scoce (37551)

On January 27,1998, the nuclear watch engineer (NWE) made a formal NRC notification pursuant to 10 CFR 50.72(b)(1)(ii)(B)for a condition involving the emergency diesel generator (EDG) fuel oil storage system. The inspector reviewed the problem identification and corrective action aspects of this issu Observations and Findinas During review of an EDG fuel requirement calculation, a licensee engineer identified that a single EDG may consume more than the technical specification 3.9.A.3

, minimum (i.e.,19,800 gallons) amount of fuel during the first seven days following a design basis LOCA. Some incorrect assumptions in the calculation were discovered. BECo also identified a potential single failure vulnerability that affects I the fuel transfer from the fuel storage tank to either EDG.

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PNPS has two 25,000 gallon fuel oil storage tanks. Fuel oil can be transferred from one EDG fuel oil tank to the other. However, each storage tank has a foot check valve, 38-CK-101 A or B, in the suction line; which if were to fail, could render one EDG inoperable as well as the fuel oil cross connect. This scenario was considered to be a potential single failure problem which is contrary to UFSAR 8.5.1 that specifies the function of the EDGs is to provide single failure proof source of AC 5.ower adequate for safe shutdown following postulated design basis accident Engineering personnel wrote and reviewed engineering evaluation 98-011 that concluded that the EDGs remained operable because sufficient fuel existed in either fuel oil storage tank to supply either EDG for 7 days following a postulated LOC A problem report was issued and a 10 CFR 50.72 notification made on January 27, 199 During the review of this issue, the inspector identified that engineering evaluation 98-011 was written on January 21,1998, but not reported until January 27,199 This resulted in a violation (VIO 50-293/98-01-07)of the one hour non-emergency reporting requirement contained in 10 CFR 50.72. Additionally, the inspector i learned that engineering personnel did not inform plant and operations management i of the issue until January 27,1998. On January 27,1998, BECo initiated a J problem report to evaluate this proble After extensive research into the licensing and design bases, the onsite safety review committee subsequently determined that both fuel oil storage tanks were required under certain postulated accident conditions to support the continued operation of one EDG. The operations department manager initiated a standing order which provided interim corrective actions to cross connect the storage tanks, if neede l The inspector performed an in-office review of related LER 98-01, Single Failure Vulnerability of the EDG Fuel Oil Supply System. BECo committed to issue a supplement to the LER to include the final review and corrective actions. The apparent cause was the failure to correctly translate design basis assumptions into the licensing basis and to establish proper configuration control. A BECo review of the Pilgrim design basis determined that the original calculation credited the manual cross connect and availability of both storage tanks for consumption by either ED The need to cross connect the tanks was never integrated into system operation controls. This inadequate configuration control resulted in a violation of design control requirements contained in 10 CAR 50, Appendix B, Criterion Ill. This non-repetitive, licensee identified and corrected violation is being treated as a Non-Cited Violation (NCV 50-293/98-01-06), consistent with Section Vll.B.I of the NRC Enforcement Policy. LER 98-01 is considered close l

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13 Conclusion A violation of 50.72 reporting :equirements resulted when engineering personnel initiated an evaluation for a problem with the EDG fuel oil system but failed to follow the established' problem report process by initiating a problem report in a timely manne E8 Miscellaneous Engineering issues (92700,92903)

E (Ooen) VIO 50-293/98-01-08:UFSAR Uodate Process: (Closed) URI 50-293/96-10-03: UFSAR Update Process A BECo regulatory relations self assessment (96-4) identified that the PNPS UFSAR update process did not provide timely UFSAR updates which are used by the organization and was an opportunity to improve. Specifically, after a plant design change (PDC) was performed, an UFSAR change request was only submitted after final PDC close-out (i.e., exhibit 9). PDC final close-out occurred after all drawings and other paperwork were updated. This resulted in substantial delay in UFSAR update NRC Inspection Report No. 50-293/96-10, dated February 7,1997, documented the inspector's concern that the UFSAR change process weakness initially identified by BECo was actually a nonconformance with the requirements of 10 CFR 50.71(e).

This was a programmatic deficiency. In response, BECo initiated problem report (PR) 97.9133, dated February 21,1997, which was classified as a significant condition adverse to quality. The related BECo PR root cause analysis, dated September 22,1997, concluded that the licensee procedures for updating the UFSAR did not meet the intent of 10 CFR 50.71(e). BECo initially identified the issue as an enhancement during a self assessment, but did not issue a PR and treat this issue as a nonconformance with 50.71(e) until the inspector became involve Several corrective actions were subsequently developed and implemented as part of the resolution of the PR, including revising procedure, NOP 83A17,"10CFR50.71(e)

FSAR Update," to initiate UFSAR change requests at the same time r.1odifications were considered ready for operational turnover. Additionally, the inspector confirmed that the backlog of UFSAR change requests were submitted in revision 21 which was sent to the NRC in October 1997. The inspector determined that these corrective actions resolved the programmatic deficienc Based on review of the corrective actions during this inspection period, the inspector determined that a current regulatory concern does not exist. However, prior to October 1997, procedure NOP 83A17 was inadequate in that the procedure was in violation (VIO 50-293/98-01-08)of 10 CFR 50.71(e) requirements. The severity level of this violation was determined using Enforcement Guidance Memorandum (EGM) 96-05, Enforcement issues Associated With FSARs, dated October 21,1996. EGM 96-05 specifies that past programmatic issues can be treated as a Level IV violation where both the cause and the impact has been corrected. Also, EGM 97-12, Additional Guidance For Severity Level IV NCVs,

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!- dispositioned as a NCV, notwithstanding the licensee identification and correctio URI 96-10-03 is considered close E8.2 (Closed) IFl 50-293/95-22-02: Vendor Services I

The licensee's root cause analysis (RCA) of vendor-related problem reports was identified as a potential program weakness. It was noted that the corrective actions for identified concerns were adequate; however, all RCA's were not of a comprehensive nature that would reveal and address adquate " preventive" measures. In addition, ownership of the related correcave action items was identified as not being clear. No areas of technical concern or unresolved safet issues were identifie BECo made several changes to the correction action process. These include changing the corrective action process whereby only significant conditions adverse to quality undergo a RCA. The RCA's are reviewed by a group-level manager and a correction action review board to ensure the identified corrective actions adequately address the root causes. The specified corrective actions are individually assigned, entered, and tracked until completion in the licensee's integrated action data bas A review of BECo corrective action process, including adequacy of RCAs, was reviewed in NRC Inspection Report 50-293/97-80and determined overall to be goo Further problems with the interface / oversight of vendor activities were observed during the cycle 11 refueling outage (reference NRC Inspection Report 50-293/97- i 02). These included over-reliance on vendor communications which affecte selected maintenance and engineering activities. BECo improved the oversight of )

vendor activities by developing a matrix to flag extra measures or precautions to be

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taken when dealing with specialty vendor services. The completed matrix is scheduled to be completed in March 1998. Discussions with engineering department personnel revealed that Nuclear Engineering Service Group procedures i associated with the quality and expectations for calculations and designs are in the

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process of being revised to include these additional measures / precautions. These include the verification of parameters used, assumptions made, and completeness I of documentation records for calculstions. The maintenance work control procedure is also scheduled to be revised to include additional vendor oversight criteria. These include additional steps in work procedures (hold points) to verify the quality of vendor related work activitie The additional controls (matrix and procedure changes) being implemented to l oversee specialty vendor services should improve the oversight of vendor activitie ]'

Based on these changes, and the changes made to strengthen BECo corrective action process, including assigned owners of corrective action items, this item is closed, i

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- E8.3 (Closed) IFl 50-293/96-02-02:Soent Fuel Pool Licensina Basis The NRR project manager previously reviewed the PNPS licensing basis for the spent fuel pool as documented in NRC inspection report 50-293/96-02, dated May 8,1996. No implicit or explicit prohibitions existed in the licensing basis that prevented full reactor core fuel off loads. At the time of the review, BECo planned to update the spent fuel pool section of the UFSAR to include the limiting parameters for the current refueling off-load analyses. This update was intended to be done during the next scheduled UFSAR update pursuant to 10 CFR 50.71(e).

The current spent fuel pool licensing basis was the BECo submittal of record that supported License Amendment 155 which increased the authorized number of spent-fuel assemblie During this inspection period, the inspector reviewed revision 21 to the UFSAR which was issued in October 1997. UFSAR Section 10,4, " Fuel Pool Cooling and Cleanup System," was revised to include acceptance criteria for normal refueling conditions including a maximum fuel pool temperature of 142* and a minimum ,

time-to-boilin the spent fuel pool of 6.41 hours4.74537e-4 days <br />0.0114 hours <br />6.779101e-5 weeks <br />1.56005e-5 months <br />. Based on this acceptance criteria, i BECo conducts a cycle specific safety evaluation of fuel pool decay heat removal I methods and practices used during each refueling outage (RFO).- For example, the inspector reviewed BECo safety evaluation 3029, dated November 1996, which ;

was completed prior to the start of RFO11 in early 1997. The evaluation concluded !

that an unreviewed safety question did not exist and the refueling practices did not I result in a spent fuel pool heat load that exceeded the aforementioned acceptance criteri This inspector follow item (i.e., IFl 96-02-02)is closed based on the review of revision 21 to the Pilgrim UFSAR which included the acceptance criteria for refueling methods. No concerns or violations of NRC requirements were identifie E8.4 (Closed) LER 50-293/96-03:RCIC System inoperable Due to Anomalies Durina Testina LER 96-03 reported that during the performance of the reactor core isolation cooling (RCIC) system surveillance test, the RCIC pump exhibited pressure operational abnormalities while in automatic control. Upon identification, the applicable technical specification action was entered. Investigation revealed a malfunctioning speed control system hydraulic actuator. The actuator was replaced and the RCIC l pump satisfactorily tested. Tha inspector conducted an on-site review of the LER ;

which included past prs and discussed the problem with the system engineer; no j

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similar problems have been experienced since the replacement of the actuator. No violations of NRC requirements were identified. This LER is close E8.5 (Closed) LER 50-293/96-04-01: Low Voltaae Power Primarv Containment LER 96-04, Supplement 1, reported that the trip settings of magnetic trip circuit breakers associated with certain 480 VAC containment electrical penetrations were set too high to ensure containment integrity. Corrective actions included lowering l

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the trip settings and the subsequent replacement of the trip breakers. An in-office review of the LER revealed that this issue was discussed in section E2.2.7 of NRC Inspection Report 50-293/96-07and escalated enforcement action taken due to the failure to previously identify and correct the condition during the licensee's self

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assessment of the electrical distribution system A technical specification violation was also issued for primary containment integrity. The violation was subsequently closed out as a Severity Level til violation with no civil penalty in section E8.5 of NRC Inspection Report 50-293/97-04. This LER is close E8.6 (Closedi LER 50-293/97-08: Setooint of Taraet Rock Relief Valve Pilot Assembiv Found Out of Tolerance Durina Testina in this LER, BECo reported that safety relief valve (SRV) RV-203-3C had an initial popping pressure which exceeded the technical specification limit as discovered at the vendor test facility. The pressure setpoint drift was attributed to minor steam leakage exhibited during the initial and followup popping pressure tests. BECo noted that the valve exhibited no leakage during the previous operating cycle. The inspector conducted an on-site review of similar events and associated documentation, the most recent in 1991 (LER 91-014), and found that improvement in the area of setpoint drift had occurred since the installation of a different pilot disc materialin 1984. The inspector also verified that BECo had evaluated the factors described in NRC Information Notice 88-30, " Target Rock Two-Stage SRV Setpoint Drift Update," against the problem exhibited by this SRV pilot valve. The inspector interviewed the system engineer and evaluated the test and rework data provided by the vendor and found it to be acceptable. The pilot valve is currently awaiting certification tests and is not installed in the plant. This LER met the requirements of 10 CFR 50.73. No violations of NRC requirements or new concerns were identified by the inspector. This LER is close IV. PLANT SUPPORT R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Imolementation of the Radioactive Liauid and Gaseous Effluent Control Proarams Insoection Scooe (84750-01)

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The inspection consisted of: (1) tour of radioactive liquid and gaseous effluent pathways and its process facilities including effluent radiation monitors, radwaste control room, AOG facility, and the main control room; (2) review of radioactive liquid and gaseous effluent release permits; and, (3) review of unplanned or unmonitored release pathway Observations and Findinas The inspector toured: (1) the control room; (2) selected radioactive liquid and gas processing facilities and equipment; (3) effluent / process radiation monitoring systems (RMS); (4) turbine and reactor buildings for plant air balance; and, (5) air

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cleaning systems. All equipment was operable at the time of the tour. The  !

inspector also noted that the licensee maintained air balances for reactor and turbine buildings to assure conformance to Updated Final Safety Analysis Report (UFSAR)

specifications. The inspector noted that the licensee did not maintain a negative i

, pressure for the augmented off-gas (AOG) building, however, the licensee I i scheduled this system for repair during this inspection. The inspector verified that !

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there was no elevated radiation level in the AOG building. (See Section R2.3 of this inspection report for details.)

l During the review of selected radioactive gaseous effluent discharge permits, the I inspector determined that the discharge permits were complete and met the l Technical Specification /Offsite Dose Calculation Manual (TS/ODCM) requirements

!- for sampling and analyses at the frequencies and lower limits of detection l

established in the TS/ODC The inspector also noted that there was no unplanned /unmonitored radioactive l liquid or gas release since the previous inspection conducted in October 199 'i Conclusion '

i Based on the above reviews and observations, the inspector determined that the '

licenree maintain'ed and implemented an effective radioactive liquid and gaseous l effluent control programs.

j R2 Status of RP&C Facilities and Equipment j l R2.1 Calibration of Effluent / Process / Area Radiation Monitorina Systems (RMS)

i Insoection Scone (84750-01)

L l The inspector reviewed the most recent calibration results for the following selected l effluent / process RMS to determine the implementation of the TS requirements and i

UFSAR commitments:

l e Liquid Radwaste Effluent Monitor; e Main Steam Line Monitors; e Reactor Building Closed Component Cooling Monitors; e Main Stack Noble Gas Monitors (Normal and High Range);

e Reactor Building Vents Noble Gas Monitors (Normal and High Range);

e AOG Post Treatment Monitor (offgas); and e Air Ejector Monito Observations and Findinos The l&C, Chemistry, and Radiation Protection departments had the responsibility to perform electronic and radiological calibrations for the above radiation monitors. All reviewed calibration results were within the licensee's acceptance criteria. The licensee's calibration methods were in conformance with regulatory criteria.

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The inspector observed that the licensee installed two gaseous effluent monitors (GEM) to supplement the existing particulate / iodine / noble gas monitors for the turbine building effluent. The GEMS were installed to enhance the gaseous effluent monitoring capability which was a positive initiative. The licensee had efforts in progress to improve the reliability of the GEM Conclusions:

Based on the above reviews, the inspector determined that the licensee maintained and implemented an adequate calibration progra R2.2 Air Cleanina Systems Insoection Scooe (84750-01)

The inspection consisted of the licensee's most recent surveillance testing results (visual inspection, in-place HEPA and charcoal leak tests, air capacity tests, pressure drop tests, and laboratory tests for the iodine collection efficiencies) for the standby gas treatment system and the control room air cleaning system, which were required by the TS. The inspector also reviewed the most recent surveillance testing results for the Operation Support Center / Technical Support Center (OSC/TSC) air cleaning system, which were required by NUREG-0737 and the licensee's emergency operations procedure Observation and Findinas All surveillance results met the acceptance crite i . The responsible individual had good knowledge for the testing methodologies a, d acceptance criteri Conclusions Based on the above reviews, the inspector determined that the licensee maintained an adequate air cleaning surveillance progra R2.3 Plant Air Balance Insoection Scooe (84750-01)

The inspection consisted of the licensee's implementation of the Updated Final Safety Analysis Report (UFSAR), Sections 10.9.1 and 10.9.2, relative to the air movement from lesser to progressively greater areas of radioactive contamination potential prior to exhaust to the environment. To comply this requirement, the licensee installed several pressure gauges for the reactor and turbine buildings to demonstrate its negative pressure .

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19 Observations and Findinas The Operations staff monitored negative pressures, one reading at each shift, for l l the reactor and turbine buildings. The inspector reviewed pressure reading results I from October 1,1997, to January 13,1998, for the reactor and turbine building l l All readings indicated acceptable negative pressures. During the plant tour, the l Inspector verified that the reactor and turbine buildings were maintained at negative pressure Conclusions:

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Based on the above reviews, the inspector determined that the licensee maintained

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the plant air balance in accordance with established design specification and UFSA R3 RP&C Procedures and Documentation R3.1 Effluent control oroarams Inspection Scope (84570-01)

The inspection consisted of review of: (1) selected effluent chemistry procedures; (2) the 1995 and 1996 Semiannual Radioactive Effluent Reports; and, (3) the contents of the ODCM for performing the effluent control programs, including projected dose calculation to the publi Observations and Findinas l

The inspector noted that reviewed effluent control procedures were detailed, easy !

to follow, and ODCM requirements were incorporated into the appropriate procedure !

The inspector reviewed semiannual reports and annual dose report. These reports provided data indicating total released radioactivity for liquid and gaseous effluent The assessment of the projected maximum individual doses resulting from routine radioactive airborne and liquid effluents were listed as required. Projected doses to l the public wore well below the Technical Specification (TS) limits. The inspector determined that there were no anomalous measurements, omissions or adverse trends in the reports.

l The ODCM provided descriptions of the sampling and analysis programs, which were established for quantifying radioactive liquid and gaseous effluent '

concentrations, and for calculating projected doses to the public. All necessary i parameters, such as effluent radiation monitor setpoint calculation methodologies, I and site-specific dilution factors, were listed in the ODCM. The licensee adopted other necessary parameters (dose factors) from Regulatory Guide 1.10 !

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Based on the above reviews, the inspector concluded: (1) effluent control

procedures were sufficiently detailed to facilitate performance of all necessary_

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steps; (2) the licensee effectively implemented the TS/ODCM requirements for i reporting effluent releases and projected doses to the public; and, (3) the licensee's l ODCM contained sufficient specification, information, and instruction to acceptably l implement and maintain the radioactive liquid and gaseous effluent control

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i' The inspector reviewed the organization and administration of the radioactive liquid l and gaseous effluent control programs and discussed with the licensee changes made since the last inspection, conducted in October 1996. The inspector noted l that the Chemistry Department has primary responsibility for conducting the radioactive liquid and gaseous effluent control programs. The System Engineering, l Operations, Radiation Protection, and instrumentation and Controls (l&C) l l'

Departments also have responsibilities to support effluent control programs, such as plant air balance, radwaste discharges, and radiation monitoring system calibrations l (radiological and electronic calibrations). The inspector determined that there were l no changes since the previous inspection conducted in October 199 l l

R7 Quality Assurance (QA)in RP&C Activities i l

R7.1 Quality control oroarams 4 inspection Scooe (84570-01)

The inspection consisted of: (1) review of the 1996 and 1997 audits and its

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responses, if any; and, (2) review of the implementation of the measurement laboratory QC program for radioactive liquid and gaseous effluent samples, Observations and Find!nas i The inspector reviewed QA Audit Report No. 97-03, and Surveillance Nos.97-156, ,

L 97-214,~ and 96-025. The audit team did not identify any finding of safety '

L significance. The inspector noted that the scope and technical depth of the audit L were sufficient to assess the quality of the radioactive liquid and gaseous effluent L

control program The licensee maintained a good QA policy and implemented the policy throughout

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the chemistry department, including the analytical measurement laboratory. The inspector reviewed the QC data for intra /interlaboratory comparisons. When discrepancies were found, effective resolutions were determined and implemente ;

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21 Conclusions Based on the above reviews, the ircgynor determined that the licensee's QA audits were sufficient to effectively assess the radioactive liquid and gaseous effluent l

control programs. The licensee implemented a good QA/QC program to validate i measurement results for effluent sample R8 Miscellaneous RP&C lssues R (Closed) VIO 50-293/96-08-02:Imolementation of radioactive effluent control oroaram This violation involved the failure to sample and analyze monthly and quarterly composites of the neutralizing sump. The inspector determined that the licensee's actions were acceptable. The licensee updated associated procedures and implemented the non-gamma radioisotopes measurement program for the neutralizing sump samples on May 20,1997. This violation is close S1 Conduct of Security and Safeguards Activities

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S1.1 Compensatory Measures Inspection Scope (71750)

The inspector toured the Central Alarm Station (CAS) and Secondary Alarm Station (SAS) to ensure proper manning, and reviewed the security logs to identify any degraded equipment conditions and established compensatory measure Observations and Findinas The inspectors review of security logs from January 1998 to present revealed that for all degraded conditions identified aither the conditions had been corrected, compensatory measures established, or a work order generated to resolve the problem. Discussions with individuals stationed at the CAS and SAS revealed that the security force was aware of the degraded conditions and of the established compensatory measures. The inspector noted maintenance activities were in progress for those conditions that required compensatory measure Conclusion The minimum number of compensatory measures in place and the prompt response

to repair identified degraded conditions indicates good management of security equipment, l

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V. MANAGEMENT MEETINGS X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on March 13,1998. The licensee acknowledged the findings presente l l

X4 Review of UFSAR Commitments I A recent discovery of a licensee operating their facility in a manner contrary to the UFSAR description highlighted the need for a special focused review that compares plant practices, procedure and/or parameter to the UFSAR description While performing the inspections discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that related to the areas inspected. The inspector verified that the UFSAR wording was consistent with the observed plant practices, procedures, and/or parameter l l

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INSPECTION PROCEDURES USED 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 IP 82301: Evaluation of Exercises for Power Reactors IP 84750-01: Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power 4 Reactor Facilities IP 92901: Followup - Operations IP 92902: Followup - Maintenance IP 92903: Followup - Engineering i IP 92904: Followup - Plant Support I lP 93702: Prompt Onsite Response to Events at Operating Power Reactors I

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ITEMS OPENED, CLOSED, AND UPDATED l Pilgrim Nuclear Power Station i NRC Inspection Report 50-293/98-01

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> Ooened 98-01-07 VIO Late 50.72 Notification 98-01-08 VIO UFSAR Update Process Closed 95-22-02 IFl Vendor Services 96-02-02 IFl Spent Fuel Pool Licensing Basis 97-11-02 IFl Operator Log issue From 1989

,96-003 LER RCIC Inoperability 96-004-01 LER Low Voltage Power Primary Containment 96-008 LER Reactor Building Closed Cool Water System 96-009 LER Group 3 ISO Due to False High RV pressure Sig 97-004 LER Loss of Preferred Off-Site Power and Oil Spill Due to Main Transformer Fault While Shut Down 97-008 LER Set Point of Valve Out of Tolerance During Test l

97-016 LER Recirculation System Loop "B" Pump Trip 98-001 LER Single Failure Vulnerability of the Emergency Diesel Generator Fuel Supply System 98-01-01 NCV Operator Log issue from 1989-98-01-02 NCV Recirculation system Loop "B" Pump Trip 98-01-03 NCV FRV Preventative Maintenance i

f 98-01-04 NCV Wrong Parts j 98-01-05 NCV FFWTR Safety Evaluation j

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25 l 98-01-06 NCV EDG Single Failure Vulnerability 96-03-02 URI Human Performance issues Related to Working on the Wrong Valve 96-10-02 URI FFWTR Safety Evaluation 96 10-03 URI UFSAR Update issues 97-02-01 URI - Equipment issues

96-06-02 VIO Procedural Adherence and Adequacy Problems 96-08-02 VIO Implementation of Radioactive Effluent Control 97-06-01 VIO Reactivity Manipulations 97-80-01 VIO Procedure Adequacy and Usage l

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LIST OF ACRONYMS USED l ALARA As Low As is Reasonably Achievable APRMs Average Pcwer Range Monitors BECo Boston Edison Company CFR Code of Federal Regulations CRD Control Rod Drive CRHEAFS Safety System Walkdown-Control Room High Efficiency Air Filtration System .

CS Core Spray I EDG Emergency Diesel Generator EP Emergency Preparedness EPIC Emergency and Plant Information Computer l ESF Engineered Safety Feature gpm gallons per minute HEPA High Efficiency Particulate I HPCI High Pressure Coolant Injection I I&C Instrumentation and Controls IFl Inspection Follow-Up item j IR inspection Report '

LER Licensee Event Report MG Motor Generator MR Maintenance Request i NCV Non-Cited Violation  !

NOV Notice of Violation NRC Nuclear Regulatory Commission

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NRR Office of Nuclear Reactor Regulation NSRAC Nuclear Safety Review and Audit Committee  ;

NWE Nuclear Watch Engineer i ODCM Offsite Dose Calculation Manual 1 P&lD piping and instrumentation diagram PNPS Pilgrim Nuclear Power Station PR Problem Report l QA Quality Assurance OC Ouality Control RHR Residual Hea'. Removal RMS Radiation Monitoring System RP&C Radiological Protection and Chemistry RP Radiological Protection SALP Systematic Assessment of Licensee Performance SBLC Standby Liquid Control SRO Senior Reactor Operator TM Temporary Modification TS Technical Specification UFSAR Updated Final Safety Analysis Report URI Unresolved item UFSAR Updated Foal Safety Analysis Report VIO Violation l WWM Work Week Manager u__

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