ML20050C280
| ML20050C280 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/17/1982 |
| From: | Briggs L, Eichenholz H, Elsasser T, Jerrica Johnson, Raymond W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20050C274 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-***, TASK-TM 50-293-82-01, 50-293-82-1, IEB-80-15, NUDOCS 8204080367 | |
| Download: ML20050C280 (17) | |
See also: IR 05000293/1982001
Text
DCS 50293-820222
820122
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820129
811218
U.S. NUCLEAR REGULATORY COMMISSIOff
811110
0FFICE OF INSPECTION AND ENFORCEMENT
Region I
Report No.
50-293/ 82-01
Docket No.
50-293
License No.
Priority
Category
C
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Licensee:
Boston Edison Company
800 Boylston Street
Boston, Massachusetts 02199
Facility Name:
Pilgrim Nuclear Power Station
' Inspection at:
Plymouth, Massachusetts
Inspection conducted:
January 18, 1982 - February 28, 1982
Inspectors:
hh E hMW
J/'*/
J. Johnson Senior,R
date signed
8'9 4 djN,A A )* /esident Inspector
3//R/P,2
'
e
H. Eichenholz, Regident Inspector
'date'signeu
hthw
,for
3)ssist
' Briggs, Reactor Inspector (Feb. 3-5,1982)
date signeo
L.Am 2.debsw
doc-
D/ tales
W.~Raymond! Sr. Resident Inspector VY
date signed
(Febru
y3-26
1982)
.
J!/7!8k
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3
Approved by:
//
14
T. Elsasser dChfef, Reactor Projects,
date sicfned
Section No.(lB, Projects Branch No. 1
Inspection Summary:
Inspection on January 18, 1982 - February 28, 1982 (Report No. 50-293/82-01)
Areas Inspected:
Routine unannounced safety inspection of plant operations, including
followup on previous inspection findings, an operational safety verification during long
term shutdown, followup'of events occurring during the inspection and LER's, surveillance,
maintenance, and testing activities, I.E. Bulletin followup, fire protection program follow-
up, startup testing for modified systems, preparations for plant restart, and a review of
th2 TMI TAP. The inspection invloved 358 inspector-hours by three resident and one region-
based inspectors.
Results: Two items of noncompliance were identified in two areas.
(Failure to properly
instruct workers of the storage and transfer of radioactive resins, Paragraph 4.B; Failure
.
' to establish and implement station procedures to meet requirements of the Fire Protection
I
Plan, Paragraph 8.B).
B204080367 820323
PDR ADOCK 05000293
O
R:gion I Form 12
(R:v. April 77)
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DETAILS
1.
Persons Contacted
W. Armstrong, Deputy Nuclear Operations Manager
A. Caputo, Fire Prevention and Protection Officer
R. DeLoach, QC Group Leader
B. Eldredge, Sr. HP Supervisor
E. Graham, Sr. Plant Engineer
F. Giardiello, Sr. Compliance Engineer
M. Johnson, Raytheon Service Co.
E. Kearney, Assistant to QA Manager
F. Kruse, Supervisor, Raytheon Service Co.
R. Machon, Nuclear Operations Manager
C. Mathis, Deputy Nuclear Operations Manager
J. McCann, Watch Engineer
J. McEachern, Security Supervisor
T. McLaughlin, Sr. Compliance Engineer
A. Morisi, Startup Manager (Nuclear Operations ~ Support Manager)
L. Oliver, Watch Engineer
R. Reposa, QC Inspector
K. Roberts, Chief Maintenance Engineer
R. Smith, Sr. Chemical Engineer
K. Taylor Day Watch Engineer
A. Trudeau, Chief Radiological Engineer
G. Whitney, Plant Engineer
The inspectors also interviewed other members of the health physics,
operations, maintenance, security, technical, and administrative staffs.
2.
Followup on Previous Inspection Findings
(0 pen) Unresolved Item (50-293/81-19-04).
Reissue training and indoctrina-
tion procedure No.1.3.14, and revise Training Manual to include a list of
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effective pages.
Procedure No.1.3.14, Indoctrination and Training was
reissued as Rev. 12 on December 19, 1981, but with an expiration date of
January 15, 1982, imposed by the Q.A. Manager because of future anticipated
changes. The Training Manual was revised on December 15, 1981 and included
a table of contents and list of effective pages. The inspector reviewed
these two documents and provided comments to the licensee representatives.
Station management personnel informed the inspector that either procedure
No.1.3.14, or the instructions in the Training Manual (describing policy,
responsibility and methods of review and approval of manual . changes) would be
reviewed and approved by the Onsite Review Committee. Training department
personnel stated that a change would be made to the Training Manual clari-
fying the latest approved revision (No. 5).
This item remains open pending a review of the actions.
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3.
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(0 pen) Inspection Follow Item (50-293/81-13-01).
Discharge of the Waste
Neutralizing Sump. The inspector held discussions with licensee personnel
and reviewed the original discharge pemit documents relating to the dis-
4
charge of June 9,1981. The inspector determined that the original sample
data form CH-llB dated June 9,1981 had the gross beta count specified
(2.416.7 cpm /ml) as opposed to the gross gama count (5 i16.2 cpm /ml).
.
.The inspector verified that a chemistry log entry of June 9,1981 indicated
that the gross gama count was approximately 4.5 1 16.2 cpm /ml.
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This item remains open pending a review of the licensee's actions to propose
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- Technical Specification' changes as discussed in a letter from NRC: Region I
,
dated October 28, 1981.
3.
Operational Safety Verification During Long Term Shutdown
A.
Scope and Acceptance Criteria
The inspector observed control room operat' ..is, reviewed selected logs
and records and conducted discussions witn control room operators. The
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inspector reviewed the operability of selected emergency systems. Tours
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of the reactor building, switchgear rooms, cable spreading room, intake
structure, torus, torus room, battery room, auxilliary bay, station yard,
turbine building and the control room were conducted. The inspectors
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observations included a review of equipment conditions, control room
annunciators, potential fire hazards, physical security, housekeeping,
radiological controls, and equipment control. The inspector also re-
viewed the instrumentation associated with gaseous release rates from
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'the station.
These reviews and observations were perfomed in order to verify con-
formance with the Code of Federal Regulations, the facility Technical
Specifications, and the licensee's procedures.
B.
Findings
(1) Fire Brigade Ready Room
Following discussions with members of the station Fire Prigade,
the inspector toured the Fire: Brigade Ready Room (Secondary Alarm
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Station) on January 27, 1982 and noted that the fire fighting equip-
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ment required to be worn or used by members of the Fire Brigade was
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in a state of disarray because of the level of activity and congestion
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resulting from ongoing plant modifications.
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Following discussions with the station Fire Protection and Prevention
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Officer.(FPPO), all fire fighting equipment and protective clothing
was moved to the passageway between the Reactor Building and Tur-
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bine Building.
Instructions were also provided to all members of
the Fire Brigade concerning this change in location.
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The inspector'had no further questions at this time, however, the
inspector discussed the apparent lack of preplanning with respect
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to the modifications in the area and the detrimental effect on the
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readiness of the fire fighting equipment.
The licensee acknowledged
the inspector's comments and stated that plans existed to purchase
lockers for more positive control of this equipment in the future.
Further reviews of the implementation of the fire protection pro-
gram are discussed in Paragraph 8 below.
(2) On January 18, 1982, the inspector noted the temporary storage of
approximately 19 large wooden radioactive waste shipping boxes (empty)
near the protected area fence.
Following discussions with Station
Security Personnel, these boxes were immediately moved away from
the fence to a more appropriate location.
In addition, the licensee
replaced the existing signs (describing storage limitations) on the
fences with ones easier to read.
The inspector had no further questions.
(3) On January 21, 1982, the inspector noted that various radiation
areas throughout the station were posted as an a'.ea prescribed by
an " Extended Radiation Work Permit" (RWP), but did not, in all
cases, have posted the associated survey, dress requirements, or
sign-in sheets.
Following discussions with the licensee's Senior
Radirlogical Engineer, these discrepancies were corrected, and a
weekly audit initiated to insure completeness in the future.
,The inspector had no further questions.
(4) On January 20, 1982, the inspector observed several contractor
personnel in the Reactor Building 23' elevation who were apparently
not actively engaged in productive work in areas of about 2-10
mrem /hr. The inspector discussed this observation with the Chief
Radiological Engineer and other senior station management personnel
and expressed concerns regarding possible unnecessary radiation
exposure. Following this discussion the Nuclear Operations
Manager issued a policy directive on January 25, 1982, to all per-
sonnel at the station requiring that, if an individual is not en-
gaged in productive work, he must leave the process building
radiation areas.
The inspector I.oted during subsequent tours of the facility,
that improvements had been made in this area.
No violations were
identified.
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(5) On February 4,1982, the inspectors toured the inside of the torus
to note conditions present prior to refilling. Several discrepancies ~
noted were provided to the licensee's management. The inspector noted
than many items had already been identified during the licensee's own
inspections, including inspections by QC personnel. The additional
items noted by the inspector were incorporated into the licensee's
corrective action tracking systems.
The inspector subsequently verified the satisfactory resolution
of all concerns noted. No violations were identified.
(6) During various tours of the station, the inspector noted marked
improvements in cleanliness and housekeeping aspects in the
Turbine Building including the turbine operating floor, condenser
bay, and the condensate demineralizer valve corridor. The licensee
is tracking the cleanup of the station in preparation for plant
startup.
No inadequacies were identified. The inspector will follow the
licensee's efforts to cleanup other areas of th; plant.
4.
Followup on Events Occurring During the Inspection / Licensee Event Report
(LER) Followup
A.
Fire in 480v Switchgear 223.
On January 22, 1982, a minor fire developed
in the 480v panel B23. The inspector went to the scene of the fire (23'
elevationswitchgearroom)andobservedthelicensee'sactions. The fire
was out, and had been de-energized. The cause was determined to be a
failed control power transformer in breaker No. 2371 to the 'B' flatbed
filter drive motor. No damage to essential equipment was observed. The
inspector observed the preparations for repairs and had no further ques-
tions. No inadequacies were identified.
B.
Radioactive Resins in the Standby Gas Treatment (SBGT) System Room.
(1) Background. On January 29, 1982, at approximately 11:00 am, a
worker held discussions with the ir. pector relating to concerns
abcut the radiological conditions in the SBGT system filter room.
The inspector reviewed the circumstances surrounding this event,
held discussions with the licensee's management representatives
and reviewed the associated radiological documentation.
Findings
are separated into two areas:
radiological conditions; and
system operation.
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(2)
Radiological Conditions. Work had been ergoing in the SBGT system
room since early January,1982 under RWF 82-42 involving the fire
protection deluge system for the SBGT system filter traint.
On
September 27, 1982, an H.P. technician surveying the area opened the
door to the inlet plenum on the 'B' filter train to determine the
cause of a 200 mr/hr contact reading on the door and found a large
amount of dry radioactive resin on the floor.
The door was immediately
shut and further discussions with ser - H.P. management were conducted.
On January 28, 1982, while routine wo-K was ongoing under RWP 82-42,
inside the SBGT room (but outside of the filter trains), H.P. per-
sonnel were preparing to remove the resin.
On the cvening of
January 28, 1982, workers moved the resins from the 'B'
filter train
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and placed them in two 55 gallon drums standing inside the SBGT
room. This cleanup evolution was perfomed under RWP 82-273.
A
survey performed at 11:00 pm on January 28, 1982 of the SBGT room,
showed two barrels of resin reading about 400-600 mr/hr on contact
and general radiation levels near the barrels of about 50-125 mr/hr.
On January 29, 1982, at about 8:15 am, workers were briefed by an
H.P. representative for RWP 82-42 to continue routine work on the
fire protection modifications. The survey used to present radiolo-
gical conditions was perfomed at 9:00 am on January 28, 1982.
General area dose rates in the SBGT room were described as about
1-10 mr/hr. This survey did not indicate the presence of the two
barrels of radioactive resin.
Worker (s) entered the area at about 8:20 am on January 29, 1982
wearing plastic slipons and cotton gloves and upon noticing an
unusual increased dose on the pocket dosimeters, and the two barrels,
left the area.
Following subsequent discussions with the licensee representatives
and NRC: Region I personnel and a review of records, the inspector
determined that the worker (s) in question did not receive any signi-
ficant exposure (total exposure about 10 mrem), and were not externally
or internally contaminated.
Station Procedure No. 6.1-022, " Radiation Work Permit, Rev. 8",
requires the following actions:
The latest survey data be posted at the work area or with the
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When it becomes necessary to change dress requirements or instru-
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ctions, an RWP revision sheet shall be completed.
All persons who enter the area are to be briefed on the radiolo-
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Oical conditions in the area.
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The failure to keep workers informed of the storage and transfer
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of dry radioactive resin in the SBGT system room is considered a
violation (50-293/82-01-01).
(3) System Operation., Following discussions with licensee representa-
tives, the inspector determined that the most probable source of the
resins was from the condensate demineralizer system during past
station operations.
During this past outage, the demineralizer
vent valves were overhauled and it was identified that six out of
seven valves were defective and would not seal tight when closed.
These have been repaired.
It is thought that radioactive water /
resin passed by the condensate demineralizer vent valves into the
vent neader, through the gas scrubber, into the contaminated exhaust
ventilation system which ties into the SBGT system suction ducting.
The licensee is continuing to evaluate this problem and pursuing
additional radiological surveys of the ventilation systems, and
engineering requests for plant design changes.
The inspector will continue to review the system operation during
future routine inspection of the facility.
C.
Water in Bay 15 of the Torus Room.
On February 17, 1982, during a plant
tour, the inspector observed a cmall amount of water on the floor of the
torus room at the base of the vessel support structure on the inboard side
of ring girder No.15.
Following discussions with licensee personnel and
a review of records, the inspector determined that this water had been
identified by the licensee in Failure / Malfunction Report No.81-176
dated December 18, 1981. This event was reviewed by the ORC in meeting
No.81-121 on December 30, 1981.
No determination was made concerning
reportability or corrective actions since the source was unknown and
further information was requested.
The inspector determined that sample rEsults indicated the water was not
radioactive but was caustic and the source was thought to be in leakage
from ground water through a seam in the building structure. Engineering
Department memo NED 82-115, dated February 25, 1982, concluded that the
water seepage does not adversely affect or r.cmpromise the integrity
of the containment structure but that further analysis of the source is
needed, and that pressure grouting should be performed to seal the in-
leakage.
This item is uresolved pending further review to determine whether the
licensee complied with reporting requirements and a review of the
licensee's actions to correct the source of in-leakage (50-293/82-01-02).
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D.
Torus Gouges LER 81-61. The inspector reviewed the licensee's actions in
repairing Ine gouges identified on the inner surface of the torus shell,
Bay No. 11, reported in LER No. 81-61. The gouges were repaired using the
butter bead /temperbead technique using the requirements of ASME Code
Section XI and Code Case N-236. NDE was perfon ed by magnetic particle
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and radiography and a pressure tcst examination was performed during the
PCILRT. These repairs are also c'escribed in a letter to NRC:NRR dated
January 26, 1982.
On February 16, 1982, the inspector questioned the licensea concerning
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another indication in Bay No. 9, and reviewed the associated QC inspection
reports. The inspector determined that the licensee had properly identi-
fied this additional indication, reviewed the conditions with respect to
the acceptance criteria, and detennined that additional repairs were un-
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necessary.
The inspector had no further questions.
No inadequacies were identified.
E.
Type 'B' LLRT on Containment Flanges. On February 22, 1982, the licensee
discovered that several ficnges on the 20 inch containment vent and
purge valves were testable as type 'B' penetrations and had not been in-
cluded in the local leak rate test program.
The licensee reported this
discovery in LER No. 82-04 and initiated actions to perfonn the re-
quired tests.and review other similar components.
The inspector verified that local leak rate tests were performed on the
six flanges (inboard drywell and torus supply and exhaust lines, and
the two torus-to-reactor buildirg vacuum breakers) prior to the PCILRT.
The inspector determined that the licensee had properly reported this
event and taken appropriate' corrective actions.
No additional violations
were identified. This LER remians open pending completion of the licensee's
review of oth.c similar components and further testing if required.
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Surveillance Activities
The inspector reviewed the licensee's actions associated with surveillance
testing in order to verify that the testing was performed in accordance
with station procedures and met the Technical Specification limiting con-
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ditions for operation.
,
Portions of the following tests were observed / reviewed:
System Leakage and/or System Hydrostatic Test; Procedure No. 2.1.8.
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On February 12-13, 1982, the inspector witnessed portions of the
. test and observed control room operations-including use of approved
procedures. .The inspector verified that reactor coolant system tem-
peratures and pressures met the requirements of Technical Specifications 3.6.1 and 3.6.2 ~ for reactor vessel integrity protection. The in-
spector also verified that vessel metal temperatures were being logged
every 15 minutes as required..
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The inspector noted that no abnormal system degradation was identified
(otherthanpackingorflangeleakage).
The inspector noted that the licensee has proposed using the 1977,
Summer of 1978 Edition of Section XI ASME Code for system pressure tests
(letterdatedJuly 24,1979). NRC:NRR has tentatively approved this pro-
gram as described in letter dated August 15, 1979. Sections IWA 5000,
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and IWB 5220 of this Code specify the following:
a pressure test
c 110% of normal operating pressure
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that nonnally installed instrumentation is acceptable.
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.The inspector verified that these conditions were met during the test.
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No inadequacies were identified.
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Primary Containment Integrated Leak Rate Test. The inspector reviewed
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the licensee's actions involving preparations for, and actual conduct
of, the Type 'A' PCILRT. This review included discussions with licensee
personnel, a review of documents, and witnessing of the test. The in-
spectors coninents and findings were forwarded to the NRC: Region I inspector
,
reviewing the test and will be included in a s p arate NRC report.
No violations were identified during this review.
6.
Maintenance Activities and Operational Control of Maintenance and Testing
The inspector reviewed the following activities in order to verify that the
activities were conducted in accordance with the licensee's procedures, the
facility Technical Specifications and the Code of Federal Regulations. The
inspector verified for selected items that the activity was properly authorized,
and that the appropriate radiological controls, equipment control tagging, and
fire protection were being implemented.
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The items / documents reviewed were described below:
'TP 82-06, "X-ray of Core Spray Piping"; On January 26, 1982, at about
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9:15 am, the inspector noted that the 'B' Core Spray Pump was energized
and that the discharge injection valve (MO 1400-24B) was shut and de-
energized for radiographing the pipins. The inspector questioned the
control room operator concerning pump protection (discharge path)~upon
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inadvertent energization of the pump. The operator stated that there was
no discharge path, since the nonnally open recirculation valve (M01400-
13B) was shut due to the torus drain down.
Following discussions with the
' Watch Engineer, the licensee de-energized the pump and niade a temporary
change to the test procedure.
4
The inspector noted that although there were no concerns for T.S. opera-
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bility requirements of the core spray system at this time, FSAR Section
6.4.3, states that the bypass flow is required to prevent the pump from
overheating when pumping against a closed discharge valve.
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The inspector discussed this event with senior station management and
expressed concern for the apparent inadequate procedure review by the
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Onsite Review Committee and the lack of attention to detail by control
room operators.
The licensee acknowledged the inspector's comments and stated that this
matter would be discussed with the appropriate personnel.
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M.R. 82-61-02; 'A' Diesel Generator inoperable for inspection of air
tanks.
M.R. 81-45-205; ATWS System modifications per FRN 79-25-48.
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For these two M.R.'s, the inspector noted that no reference had been
made to the T.S. applicability and limiting conditions for operation
for the ATWS-Alternate Rod Insertion function. Although the inspector
did not identify a safety concern, reference should have been made to
the T.S. Section 4.2.6 for completeness.
Further discussion of this
area is described in Paragraph 9.
No violations were identified during this review.
7.
I.E. Bulletin Followup
The inspector reviewed the licensee's actions relating to IEB 80-15 (ENS
phone line uninterruptable power supply).
Inspection Report No.'s 80-25
and 80-27 describe the licensee's actions with the exception of the Tech-
nical Support Center (TSC) and the Emergency Operations Facility (EOF).
On January 19, 1982, the inspector held discus:,lons with licensee representa-
tives and verified that these two facilities had ENS phone extensions that
had been powered from uninterruptable power supplies.
This Bulletin is considered open pending a review of the additional modifica-
tions planned /in progress as initiated by the NRC.
8.
Fire Protection Program Implementation
A.
Modification Status
The inspector requested from the licensee a completion status of fira
protection program modifications which were required by Amendment No. 35
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to the facility operating license. The following table includes the in-
formation provided to the inspector on December 16, 1981.
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Item No.
Description
Date of Completion
3.1.1
Fire Detection
December 30, 1980
3.1.2
Water Suppression
June 1, 1980
3.1.3
Gas Suppression
August 1, 1979
3.1.4
Ventilation
May 31, 1979
3.1.5
Lighting
February 29, 1980
3.1.6
Cable Coating
February 29, 1980
3.1.7
Fire Doors
March 15,1980
3.1.8
Fire Dampers
February 29, 1980
3.1.9
October 3,1980
3.1.10
Control Room Kitchen
July 7, 1979
3.1.11
Control of Combustibles
September 17, 1979
3.1.12
Extinguishers
January 1,1979
3.1.13
Admin./Q.A.
September 1,1979
3.1.14
Exposed Steel (Design / mods)
March 14, 1979/ February 8, 1980
3.1.15
Detection / Actuator Circuits
February 1, 1979
3.1.16
Breathing Apparatus
January 16,1979/
(Design / mods)
December 1, 1978
3.1.17
Communications (Design / mods)
March 14, 1979/ March 20, 1980
3.1.18
Alternate Shutdown
October 5, 1979/May 15, 1980
(Design / mods)
3.1.19
Penetration Seals
September 30,1979/ Prior
(Testing / mods)
to end of current outage.
This status is included in this report for record purposes only. NRC
followup of these fire protection modifications will be described in a
separate report.
B.
Fire Brigade Emergency Equipment
(1) Scope
As a result of the inspector's observations of the fire brigade
ready room on January 27, 1982 (see Paragraph 3.B), the inspector
perfonned additional reviews of the administrative controls used
for inventory and testing of emergency equipment used by the station
fire brigade. The inspector also toured various locations where the
equipment was kept to ascertain its present condition. These reviews
were performed to detennine whether the equipment was being controlled
in accordance with the requirements of the facility operating license
DPR-35 (condition 3.F), the Technical Specifications, the station
Fire Protection Plan dated August 10, 1978, and the licensee's pro-
cedures.
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The following procedures were reviewed:
--- l.4.23, Fire Brigade Training Drill, Revision 1
5.5.1, General Fire Procedure, Revision 6
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5.5.2, Special Fire Procedures, Revision 5
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5.5.3.1, General Fire Procedure Discussion, Revision 3
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6.7-107, Operation and Maintenance of Scott Pressure-Pax 4.5,
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Revision 1
6.7-108, Operating Instructions for Breathing Air Charing
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System, Revision 0
The inspector toured the control room, fire brigade ready room, and
the breathing air charging system at the north end of the warehouse.
(2)
Findings
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The inspector noted the following inadequacies in station procedures:
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-- There are no surveillance procedure requirements for the inventory
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of fire ready equipment except for the Self Contained Breathing
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Apparatus (SCBA).
2
Procedure 1.4.23 does not require an inventory and operability
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check of fire ready equipment following a drill.
Procedure 5.5.1,Section III.A.4, specifies a requirement to
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inventory emergency equipment and restore the same to its
normal ready condition. No specific administrative control is
established to accomplish this check and document its comple-
tion.
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-- Procedure 6.7-108 does not include a requirement to assure that
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the Scott air bottles are examined for current hydrostatic test
as a prerequisite for recharging.
The inspector also identified inadequacies in the implementation of
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requirements to provide self-contained breathing' capability for fire
fighting personnel.
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The facility operating license DPR-35, condition 3.F, fire protec-
tion modification item No. 3.1.16, requires operable self-contained
breathing apparatus that will support 10 men for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. To meet
this requirement, Amendment 35 to DPR-35 dated December 21, 1978
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and procedure 6.7-108 requires in part,10 SCBA units with 20 spare
bottles of 30 minute capacity, filled and ready to use, and an air
compressor / cascade filling system which can refill four bottles in
abc,ut 5 minutes.
On January 28, 1982, the inspector examined the air charing system
located in the warehouse and later met with the Fire Prevention and
Protection Officer and other licensee representatives to determine
if site conditions satisfied the above requirements.
It was deter-
mined that 29 of the 30 required fully charged SCBA bottles were
on site, 19 in operational SCBA units and 10 spares.
However, only
7 of these had been hydrostatically tested within the past 3 years
as required by OSHA and manufacturers requirements and could have
been recharged. Therefore, due to having an inadequate inventory
of SCBA bottles meeting safety standards, the licensee failed to
meet license requirements.
On January 28, 1982, the licensee issued Failure and Malfunction
Report 82-21 indicating that a minimum of 20 spare bottles were not
charged as required because the bottles were beyond the 3 year
hydrostatic test date, and that current surveillance does not re,-
quire a hydrostatic date check. The licensee immediately trans-
'-
ported about 32 spare bottles to a vendor on January 28, 1982
and by February 3,1982 all 32 spare bottles had been returned
to the station following hydrostatic testing.
Failure to establish and implement written procedures to ensure
that an adequate inventory of fire fighting equipment is maintained
at all times, as required by T.S. 6.8.D and the PNPS Fire Protec-
tion Plan Section IV.6.C, is considered a violation (50-293/82-
>
01-03).
9.
Startup Testing of New/ Modified Systems
A. The inspector held discussions with licensee personnel and reviewed the admini-
strative control system being used this outage to plan, schedule, ano track
various aspects of plant modifications. The licensee has maintained a Start-
up Management group on site composed of personnel from the Nuclear Operations
Support Department and a consulting firm (Raytheon Service Co.) to assist
station management.
.
.
14.
The inspector reviewed the following administrative documents:
Refueling Outage Manual R0-6 (Postwork Testing Planning), Rev. 0
--
-- Startup Manual, October 12, 1981
These documents outline a plan for tracking (for each modification)
five key elements:
-- Revised operating and surveillance procedures
-- Marked up control room drawings
-- Training
-- Technical Specification revisions, and
Post work testing
--
The inspector also reviewed status reports which were provided
to station management on a periodic basis.
The inspector concluded that this overall effort was a marked improve-
ment in previous station practices and, if implemented thoroughly, should
assist in ensuring the station's readiness for startup from the outage.
A review of the implementation of this effort will be performed in a
future inspection.
No inadequacies were identified in the scope of this program.
B.
Technical Specification Requirements for ATWS (RPT and ARI)
On February 9,1982, the inspector reviewed two modifications in order to
determine whether Technical Specification (T.S.) changes were necessary.
The following items were reviewed:
FRN 79-25-47; changes ATWS/ARI auto reset
--
FRN 79-25-48; inverter installation, power supply changes, and time
--
delay change.
.
The inspector did not identify any changes needed to the T.S. as a result
of these modifications. However, the inspector identified several concerns
with respect to the existing T.S.
T.S. Section 3.2.G, Recirculation Pump Trip (RPT)/ Alternate Rod Insertion
(ARI) requires the ARI function be operable whenever in the RUN, STARTUP,
or SHUTDOWN modes. The inspector noted that previous maintenance and
modification activities may have made the ARI function inoperable while
in the Cold Shutdown mode. However, the inspector detennined that it would
not be appropriate to place the mode switch in the REFUEL position (as
required by T.S. Table 3.2.G action statement) because this would conflict
,
with other safety concerns and T.S. limiting conditions for operation
for CCS, reactor protection, and containment integrity equipment.
l
.
.
15.
The inspector further noted that the existing T.S. Table 3.2.G was in-
adequate in the following areas: minimum number of operable instrument
channels per trip system; the wording of "at least cold shutdown".
The
inspector also questioned the lack of a logic test in Table 4.2.G.
The inspector informed the licensee's management of these findings and
expressed concern with the apparent lack of knowledge by station personnel
of these T.S. requirements and the inconsistencies involved. The licensee
acknowledged the inspector's connents and stated that proposed T.S. changes
would be issued to NRC:NRR prior to plant startup.
This T.S. issue is being tracked by the NRC and BECo. licensing personnel
and is included in the Confirmatory Action Letter discussed below in
Paragraph 10.
No violations were identified.
10. Management Overview of Preparations for Plant Restart
Various activities over the past several months have indicated a need for
closely following the licensee's preparations for plant restart from the
current refueling outage. Some of these activities are as follows:
Commitments made during an Enforcement Meeting at NRC: Region I on
--
October 15, 1981
technical issues discussed during a meeting with NRC:NRR on December 18,
--
1981
-
-- modifications implemented during the outage and resulting licensing
issues
recent inspections by NRC: Region I personnel in the areas of Q.A. audits
--
and leak rate testing.
Following evaluation of these activities, discussions were held between senior
Boston Edison Co. and NRC: Region I personnel on February 16, 1982, regarding
items to be performed by the licensee prior to plant restart. These discussions
involved tM following areas:
Licensing Issues
--
Modified and/or newly installed systems
--
Verification of Plant Status
--
Audit deficiencies, and
--
Public notification system.
--
These commitments were subsequently described in a Confirmatory Action Letter
No. 82-05, from NRC: Region I to Boston Edison Co.
These commitsrents will be followed during future routine inspections of the
facility (50-293/82-01-04).
m
.
.
16.
4
11. Status of TMI Action Plan (TAP) Item
The TMI Action Plan items listed below were reviewed to determine the
scheduled completion date and status for each item. TAP items selected
for review were those with July 1, 1981 and January 1, 1982 due dates as
listed in NUREG 0737, Clarification of Post TMI Action Plan Requirements,
dated October 31, 1980. The licensee's commitments for implementation
and schedules were determined from BECo. submittals to NRC:NRR, as identi-
fled for each item.
BECO
ITEM
TITLE
LETTER
STATUS
IT.B.2.B
Shielding
82-24
Two of three mods done.
Modifications
1/25/82
Additional 6 mos. required
tocompletePASP(TAPII.B.3.)
II.B.3.2B
Post Accident Sample
82-24
Complete sample panel
Panel
1/25/82
installation by July, 1982.
II.E.4.1.2
Dedicated Hydrogen
81-199
Installation complete.
8/20/81
II.E.4.2.5B Containment Pressure
81-01
Item complete. No modifica-
Isolation Setpoint
1/ 5/81
tions required.
II.E.4.2.7
Purge Isolation on
81-199
No modifications planned.
High Radiation
8/20/81
Adopted BWROG position.
II.F.1.1.B2 Noble Gas Monitor -
82-24
Actions complete.
Long Term Mods
1/25/82
Procedure revised.
II.F.1.2.B1
Iodine / Particulate
82-24
Actions complete.
Sampling - Long Term
1/25/82
Procedures revised.
Mods
II.F.1.3
Containment High Range 82-24
Installation-in progress.
Radiation Monitors
1/25/82
Schedule relief may be re-
quired to complete after
plant startup.from RF0 #5.
I
II.F.1.4
Containment High Range 82-24
Complete installation
Pressure Monitors
'/25/82
prior to startup from
RF0 #5.
II.F.1.5
Torus Wide Range
82-24
Complete installution
Level Monitors
1/25/82
prior to startup from
RF0 #5.
II.F.1.6
Containment H2/02
82-24
Work in progress.
Addi-
,
Monitors
1/25/82
tional 6 mos. required to
complete modifications.
.
-.
-
.
.
17.
i
BECO
TTEM
TITLE
LETTER
STATUS
II.F.2.3.38 Instrumentation for
81-190
Actions complete,
no
8/14/81
modifications.
Adopted
BWROG position.
Evalua-
tions continue.
II.K.3.15
HPCI/RCIC - Break
82-24
Work in progress.
Com-
Detection Logic
1/25/82
plete prior to RF0 #5
startup.
II.K.3.228
RCIC Suction
81-44
Complete. No modifications
Switchover
2/27/81
planned.
II.K.3.24
HPCI/RCIC - Space
81-271
Actions complete. No
Coolers
12/3/81
modifications required.
II.K.3.25.B1 Power for Recirculation 81-199
Actions complete. No
Pump Seal Cooling
8/20/81
modifications required.
II.K.3.13.B Separate HPCI/RCIC
81-01
Adopted BWROG position.
Initiation levels
1/ 5/81
No modifications for
initiation levels.
82-24
Work in progress for RCIC
1/25/82
restart.
Complete prior
to RF0 #5 startup.
II.K.3.28
Qualification of
81-276
Actions complete. No
12/3/81
modifications required.
BECo. actions taken to implement NUREG 0737 requirements in accordance with
the above commitments will be the subject of subsequent NRC inspections in
this area.
No inadequacies were identified.
12. Unresolved Items
Areas for which more information is required to determine acceptability are
considered unresolved. An unresolved item _is discussed in Paragraph 4.
13.
Exit Interview
At periodic intervals during the course of the inspection, meetings were
held with senior facility management to discuss the inspection scope and
findings.
,
-.