ML20128A129

Responds to NRC Re Violations Noted in Insp Rept 50-293/85-03.Corrective Actions:On 850113,scram Trips Performed as Part of Procedure 8.M.1-3.Violation B Denied Re Testing of APRM Downscale Rod Block Trips

ML20128A129
Person / Time
Site:	Pilgrim
Issue date:	05/17/1985
From:	Harrington W BOSTON EDISON CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
85-091, 85-91, NUDOCS 8505240130
Download: ML20128A129 (10)

Text

BasTON EntsDN COMPANY 800 BOYLSTCN STREET BDSTON, MASSACHUSETTS 02199 WILLIAM D. HARRINGTON samson visa resessen?

8eMstsAN May 17, 1985 BEco Ltr. #85- 091 Mr. Richard W. Starostecki, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Commission Region I - 631 park Avenue King of prussia, PA 19406 License No. DPR-35 Docket No. 50-293

Subject:

Response to Violations and Concerns as Contained in NRC Inspection Report No. 85-03

Reference:

NRC Letter to Boston Edison, dated April 11, 1985

Dear Mr. Starostecki:

This letter is in response to the violations and concerns identified during an inspection conducted by Mr. J. Johnson, M. McBride, and G. Meyer of your offico during the period February 1,1985 through March 4, 1985 and communicated to Boston Edison Company in Appendix A of the reference.

We would also like to refer to our May 10, 1985 telephone conver,ation to Mr. Lowell Tripp of your office during which we requested a seven-day extension of the response due date. Mr. Tripp agreed to the extension due to the complexity of certain issues addressed within the subject report. This response is hereby submitted within the extended time constraint agreed upon.

Notice of Violation "A" Technical Specification Table 4.1.1 requires the following:

1. The average power range monitor (APRM) inoperative scram trips be functionally tested prior to declaring them operable while the reactor is in the startup mode,

2. The APRM high flux scram trips be functionally tested as soon as practicable after entering the run mode if the functional test has not been performed within one week,

3. The APRM downscale scram trips be functionally tested prior to declaring them operable while the reactor is in the run mode, and

4. The main turbine stop valvo closure alarm be functionally tested prior to declaring the turbine stop valve closure scram instrumentation operable in the run mode with turbine first stage pressure greater than 305 psig.

8505240130 850517 PDR ADOCK 05000293 G PDR

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3 IBOSTON EDISON COMPANY Mr. Richard W. Starostecki U.S.~ Nuclear Regulatory Commission

- May 17, 1985 Page Two

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Contrary to the~above:

1. - On' December 24, 1984 and January 7, 1985, the APRM inoperative scram trips were not functionally tested prior to declaring them operable while the reactor was in the startup mode. The functional test was eventually performed on January ~13, 1985.

2. On December 29, 1984, the APRM high flux scram trips were not tested

-as soon as practicable after entering the run mode and the last test

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was not within one week.' The functional-' test was eventually performed on January 4, 1985.

< 3'. On December 29, 1984 and-January 9, 1985,-the APRM downscale scram trips were not functionally tested prior to declaring them operable while the reactor was in the'run mode. The functional test was eventually performed on January 13, 1985.

' .4 . On January 12, 1985, the stop valve closure alarm was not functionally 6 tested prior to declaring the turbine stop' valve closure instrumentation operable while the reactor was in the run mode and

~ turbine first stage pressure was greater than 305 psig. On February.9, 1985, the reactor mode was changed,,and this requirement

.no longer applied. The test was performed subsequently.

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Response

" Item 1: The corrective action to correct the condition was that the subject scram trips were performed as part of Procedure 8.M.1-3, "APRM

. Functional," on January 13, 1985, as stated in this report.

As interim corrective action to preclude recurrence, the procedure used in conducting the subject' scram trip tests was revised to require performance of the tests as' required by Boston Edison Company's current Technical

-Specifications.

As long-term corrective action, we will be evaluating other test procedures to ensure other Technical Specifications requirements are met.

Item 2:. Boston Edison denies this part of the violation. Although functional testing of the APRM high flux scram trips did not occur until January 4, 1985, it should be noted that this occurred due to the i, unusually extended length of startup following RF0 6. Although partial APRM testing. occurred after two attempted.startups and one shutdown per se, the functional tests'were performed well within the constraints of the

. PNPS Start-Up Checklist, OPER-1, which is keyed to Station power levels.

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.g SOSTORI EDIS001 COMPAIIY-Mr.' Richard bl. Starostocki' U.S. IIuclear Regulatory Commission

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May 17,1985 v Page'Three .

Specifically, the checklists require that APRM functional testing be completed prior to exceeding 605 power. The' January 13, 1985 test was ,

[. performed'at SOE power immediately after the 505 " plateau" testing was -l

!- completed. The 60E power level was not exceeded before this point.  !

Therefore, the intent of our Technical-Specifications, as implemented by our

' Station procedures, was met in that the APRM high flux scram trips were

. functionally tested as soon as practicable after entering the run mode.

Item'3: Boston Edison Company denies this part of the violationi The APRM downscale scram trips were functionally tested on December 18, 1994 and January 4, February 12, and February 17, 1985 as part of Procedure 8.M.1-3.1. .

r Item 4: As stated in LER 85-002-00, cause was determined to be a management t- deficiency which allowed inadequate Tech. Spec.-implementing procedures. ,

As'also' stated on the LER, our corrective action was to revise the

' Tech. Spec.-implementing Procedures 8.M.1-14 and 8.M.1-11, which are the MSIV ,

and. Turbine Stop Valve closure functional test procedures, to include f l . provisions for functional testing of the valve closure alarms. In addition,  !

a Temporary Modification (#85-11) was implemented to allow functional testing i of the alarms.:.The MSIV and Turbine Stop Valve functional alarm tests were successfully completed on 2/14/85 and 2/19/05, respectively. These L procedures, which now include the alarm functional test, will be' performed in accordance with the Technical Specifications as part of the Master Surveillance Tracking Program.

To preclude recurrence, BECo will continue with this increased effort, such as the QA audit which identified this problem, to improve the quality of the PAIPS procedures that implement the Technical Specifications.

Full compliance was achieved on 2/19/05,'the date upon which the last of the functional alarm tests was completed, llotice of Violation "B" {

Technical Specification 1.0.V and Table 4.2.C require the following: i f

-1. The APRM downscale rod block trips be functionally tested prior to *

!~ declaring them operable in the.run mode, i

i 2. The portion of the rod block' logic system which is used in the run mode

! be functionally tested prior to declaring the rod block logic system l operable in the run. mode, and i 3. ..The upscale and downscale trips for the rod block monitors be

( functionally tested and calibrated prior to declaring the monitors

. operable in the 'run mode with reactor power greater than 30 percent.

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00STON EDISON CORpANY u ,

W.-- Richard W. Starostocki o "U.S.--Nuclear Regulatory Commissson

. May 17, 1985 -

page Four i

Contrary to the above:

[

1. On December 29, 1984 and January 9,.1985, the APNM downscale rod block trips were not functionally-tested prior to declaring them operable in the  !

run mode. The test was eventually performed on January 13,'1985. i 1

L2. . On December. 29, 1984 and January 9, 1995, the portion'of the rod block i

' logic system used in the run mode was not functionally tested prior to 'l declaring the rod block logic system operable _in the run mode. j

3. On January 10, 1985, the upscale and downscale trips for the rod block' i monitors were not functionally tested or calibrated prior to declaring the  !

monitors operable in the run mode with reactor power greater than 30 percent. On February 9,1905, the requirement no longer applied. The test and calibration were performed subsequently.

Ressonse i

Item 1: Boston Edison Company denies this part of the violation. The APRM [

.downscale rod block trips were functionally tested on December le, 1984 and l January 4, February 12, and February 17, 1905 as part of Procedure 8.M 1-3.1. f i

Item 2: Corrective action was that the portion of the rod block logic system j used in the "Run" mode was functionally' tested on March 1, 1985 as part of i

. Procedures 8.M.2-3.4.1 and 8.M.2-3.6.2, " Control Rod Block System Logic Checks." -The procedures used in conducting the rod block tests are being r revised to allow for testing of the rod block logic in applicable modes of .

, plant operation as required by the Technical Specifications. This may involve v the installation of Temporary Modifications because of system design and is not our preferred method of corrective action. Therefore, as long-term corrective action, we will be evaluating our testing methods and considering various plant fdesign changes and/or Technical Specification revisions.

Full compilance was reached on March 1, 1905 when the subject functional tests

' were performed, t

. Item 3: Licensee Event Report #85-005-00, " Missed Surveillance Test," rekorted ,

this . situation and provided the root cause with corrective actions identified.  !

In summary, the LER noted that during a review of surveillance tracking

, reports, it was determined that the rod block monitor functional and calibration surveillance tests had not been performed as required by the Technical Specifications. Both tests were' performed immediately in order to

achieve full compliance. Corrective action to correct the condition included i an administrative review of the remaining overdue tests with no other i surveillances identified as " missed." 1 Additional investigation and research into this specific surveillance has generated an additional corrective measure. Since the involved startup test t program was a significant contribution in this situation, the physical method i of testing was thoroughly evaluated. On April 10, 1985, the rod block monitor  ;

functional surveillance was changed to allow for testing at any reactor power [

level . Previous to this procedural revir,lon, this surveillance test could only '

[

i be' performed above 305 reactor power.. i t

4 00STON EDISON COMPANY i

. Mr.' Richard W..Starostocki  !

U.S. leuclear Regulatory Commission i

May 17,1995 page Five i

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! Procedure 8.M.2-3.2,~" Rod Block Monitor Calibration," will be revised with the same operating philosophy prior to its next performance. This action will. satisfactorily preclude recurrence.

Full compliance was achieved on February 20, 1995, the date upon which the

l. subject surveillance test of the rod block monitor was performed. '

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- llotice of Violation "C" f 10 CFR 50, Appendix 8, Criterion XVI, Corrective Action, and the Soston Edison Company Quality Assurance Manual, Sections 16 (Corrective i Action) and le (Audits), require measures be established to assure that  !

l conditions adverse to quality are promptly identified and corrected. ,

Nuclear Operations Procedure N0pt4A1, Nuclear Operations Surveillance Monitoring Report (dated September 30, 1984), requires the Q.A. Manager to i be responsible to assore acceptable resolution of surveillance findings l- and the Department Managers and Group Leaders to be responsible to implement prompt corrective action. Section 6.2 of this procedure requires 1) the cognizant Group Leader to return the signed original Surveillance Finding Sheet to 94 within five (5) working days and, 2) the matter be referred to the Vice Presidents if a solution acceptable to the QA' Manager cannot be obtained within thirty days.  ;

i Contrary to the above, on February 6, 1905, conditions adverse to quality  ;

were not promptly corrected when' identified by the Nuclear. Operations i Surveillance Monitoring Program. Managers and Group Leaders did not i implement prompt corrective action as evidenced by the fact that initial l responses (signed Surveillance Finding Sheets) and corrective actions were routinely overdue. As of February 6, 1985, corrective actions for 29 surveillance findings were late; included were initial responses overdue  !

for up to 221 days and corrective actions overdue for up to 306 days. '

- Enamples are listed below {

i Corrective t

Initial r

Findine 100. Descristion Responsg Action i

04-1.4-2-3 Unapproved standby liquid 276 days control tank heater overdue  ;

setpoint r t

l 84-1,1-14-1 Improper selection of 149 days

! battery pilot cells overdue 04-4.2-1.1 Inadequate emergency 306 days diesel sprinkler test overdue '

e4-6.1-2-1 No verification of Ilconsed 221 days  !

operator education overdue {

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BOSTON EDISON COMPANY Mr. Richard W. Starostocki U.S. Nuclear Regulatory Commission Mey 17, 1985 Page Six .

Response

In order to ensure a more timely response to the subject findings, the following steps have been taken, or are planned to be taken, by the QA Department:

- Converted all open Surveillance Finding Sheets to Deficiency Reports.

- Revise various BEQAM sections and QAD procedures to eliminate the use of Surveillance Finding Sheets. This will be done by May 31, 1985.

- Revise the NOP 84A1 and BEQAM II, Sections 16 and 18, to eliminate Surveillance Finding Sheets as a method of documenting deficiencies and replace them with Deficiency Reports which are used for documenting deficiencies discovered during audits. This will be done by May 31, 1985.

- Revised QAD Procedure 18.04, " Conduct and Reporting of Nuclear Operations Surveillance (Monitoring) Activities," to delete Surveillance finding Sheets and replace with Deficiency Reports.

The above actions will satisfactorily correct the condition and w!!! preclude recurrence.

Full compliance will be achieved by May 31, 1995, the date by which the deficiencies' owners will have either satisfactorily closed out their respective items, or will have submitted an acceptable corrective action plan or response which meets the requirements of the Deficiency Report system.

Notice of Violation "D" 10 CFR 50, Appendix D, Criterion VI Document Control requires that measures be established to control the issuance of procedures to assure that they are used where the activity is performed.

Contrary to the above, on February 14, 1985, measures did not assure that procedures were used where the activity was performed in that Procedure 8.7.2.7, " Measure Flow and Pressure Drop Across Control Room Environment System," was performed utilizing Revision 4 instead of the correct Revision 5, approved on July 27, 1904.

Response

Upon questioning, the person observed using the outdated revision admitted that he had not obtained his copy of the procedure through the appropriate established channel, the Station Document Control Center. In order to preclude recurrence, he was immediately counseled as to the necessity of using controlled copies of procedures to ensure use of a document's most current revision and the appropriate procedure to be followed to obtain such controlled copies. We believe this incident represented an isolated case of an individual's failure to follow procedure.

o BOSTON EDISON COMPANY Mr. Richard W. Starostecki U.S. Nuclear Regulatory Commission May 17,1985 Page Seven As noted in your inspection report, Revision 5 differed from Revision 4 in that the later revision incorporated independent verification steps for returning the system to service. As the corrective action to correct this condition, the required independent verification was subsequently performed on February 22, 1985.

Therefore, based upon the above, full compliance was achieved upon counseling of the individual and subsequent completion of the independent verification on February 22, 1985.

Notice of Violation "E" Criterion XII of 10 CFR 50 Appendix D, requires that measures be established to assure that measuring and testing devices used in activities affecting quality are properly controlled.

Contrary to the above, on January 19, 1985, measures were not established to assure that measuring and testing devices used in activities affecting quality are properly controlled.

Contrary to the above, on January 19, 1905, measures were not established which assured that measuring and testing devices were properly controlled in that digital multimeter No. I-860C which was past due for calibration was used to check the rod block monitors during rod block monitor calibrations. In addition, on February 20, 1985, decade box No. IDC 6A and frequency counter No.

134 were past due for calibration but stored with calibrated equipment and available for use.

Response

We would first like to correct the date of the ina' dent reported by the NRC as Janusry 19. The actual date was February 19, 1985.

Upon learning that the digital multimeter used to calibrate the rod block monitors itself was past due for calibration, Doston Edison halted the rod block monitor procedure in progress. The entire procedure was then performed with a calibrated instrument.

Additionally, a physical inventory of I&C's test equipment was taken and an administrative review of its usage data performed. Only the three instruments already identified during the inspection were found to be out of calibration.

They were subsequently sent out for calibration. No adjustments to any of the three proved necessary.

Usage records for the decade box and frequency counter indicate that the last date each instrument was used proceded the calibration due date. The rod block monitor calibration discussed above was the only usage of the digital multimeter since its previous calibration due date elapsed.

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r-gn 00STON EDISON COMPANYi ',

, Mri Richer 1d W.; Starostocki *

. U.S. Nuclear Regslatory Commission '

May 17, 1985'

~Page Eight .

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Therefore, based upon our investigation, we believe that use of L 1out-of-calibration-I4C equipment was-confined to this incident and'that.other-proceduree were.not, impacted <

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-To preclude recurrence of the violation, personnel specifically involved were

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' immediately counseled concerning proper methods- for control of measuring and ,

' ' test' equipment. Additionally,.thelsame' administrative direction was provided~

to the Maintenance staff and Nuclear Control Technicians.  ;

Additionally, a single individual has been assigned.the maintenance of the i equipments',Preventivo Maintenance Schedules until program surveillance ,

confirms an increased reliability of I&C test equipment calibration. ,

Based upon the above, we believe full compliance was achieved on February 20, 1985, the date by which the rod block monitor calibration was re-performed and .

the physical inventory was completed.

I.-d_ n-d_.t Verification Concerns i

l' We (NRC) are... concerned with your recently implemented program for .

i independently verifying system configurations following maintenance and testing-in response to TMI Action. Plan Item I.C.6. The enclosed inspection report t ' identifies specific programmatic concerns related to 1) the scope and systems to which the verification program applies, 2) the manner in which the

• i verifications are being parformed, and 3) the verification of maintenance work after which.no surveillance testing is performed.

Ressonse .

In July of 1984, Boston Edison described its position and programs relative to  !*

I.C.6 issues and has not yet received NRR's evaluation. We are anticipating NRR's concurrence with our Independent Verification Program, but,.in'the

. interim as part of our ongoing efforts to improve.the program so that it )

satisfies the concerns-of I.C.6 and provides us assurance that any given safety ,

system is in its prepar configuration following maintenance and testing, a i

-po!!cy memorandum is being drafted in order to clarify our methods.of  ;

performing Independent Verification. As far as clarifying the scope and i systems to which the verification program applies, Procedure'1.3.344 " Conduct .t of operations." will be revised to moro closely coincide with the PNPS FSAR's definition of safety systems. ,

Start-Un Surveillance Testina Concerns

.We (NRC) are concerned that Violations A and B indicate that potentially serious program weaknesses are present in your surveillance program. These ,

weaknesses include the failure to properly schedule and track a number of  ;

surveillance teste during the startup sequence in December 1984 and January 1995,. failure to take timely corrective actions to surveillance testing .

problems indicated during a'QA audit, and failure to conduct a thorough '

followup investigation on the missed surveillances.

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' BOSTON EDISON COMPANY

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?Mr. Richard W.EStarostecki JU.S. Nuclear Regulatory Commission 7 May 1[1985

Page Nine c

- Response'-

In regard to your comment that there was an alleged failure to properly

. schedule'and track a number of surveillance tests,'the surveillance tracking program was designed -to schedule required tests on 'a' calendar basis. Plant startup sequences, such as' the .one recently conducted at Pilgrim Station af ter

-<- RFO 6, specifically were not factored into the design' of our surveillance

-tracking program. .

Consequently, the Master Surveillance Tracking Program, which is Boston Edison Company's. method ofLscheduling, tracking, and ensuring performance.of all

- Technical Specification-required tests, is being evaluated for.further

' improvements. One of these considerations for improvement is'to modify the program such that during startup sequence te' sting, more sophisticated parameters such as mode . switch position and reactor -temperature, pressure, and power level-will be considered. This would specify a more exact time for the performance;of a test and would be more sensitive to unusual plant sequences (e.g., extended' periods of time at reduced power levels, etc.). We believe these program ' improvements will ensure improved manageeent controls in the area

= of surveillance . testing and will better ensure Technical Specification e

compliance for unusual plant startup. sequences encountered in the -future.

Regarding .your concern that we may not have taken timely corrective actions to surveillance testing problems indicated during a QA audit, we differ with your perception that our actions were not timely'. In view of the time'that was required-to perform schematic-level evaluations of each individual' test with

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respect' to the applicable Technical Specification requirement, we feel our Teorrective actions were done in a thorough and timely manner.

Regarding your . concern.that we may not have conducted a thorough followup

- investigation of the missed'survsillances, we disagree and would direct you to

.our responses' earlier in this letter.

If there'are any questions concerning these matters, please do not hesitate to contact me.

Respectfully submitted,

)

W. D.-HarringtoW s

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