ML20151G587
| ML20151G587 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/13/1987 |
| From: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bird R BOSTON EDISON CO. |
| Shared Package | |
| ML20151G582 | List: |
| References | |
| NUDOCS 8804200059 | |
| Download: ML20151G587 (1) | |
See also: IR 05000293/1987036
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Docket No. 50-293
License No. DDR-35
Boston Edison Company
ATTN:
Ralph G. Bird
Senior Vice President - Nuclear
800 Boylston Street
Boston, Massachusetts 02199
Gentlemen:
Subject:
Inspection No. 50-293/87-36
This refers to your letter dated October 26, 1987, in response to our letter
dated September 24, 1987.
Thank you for informing us of the corrective and preventive actions documented
in your letter.
These actions will be examined during a future inspection of
your licensed program.
Also, as a result of our review and evaluation of paragraph 2 of your response
to the Notice of Violation, as noted above, we have changed the Severity Level
from IV to V.
Your cooperation with us is appreciated.
Sincerely,
William V. Johnston, Acting Director
Division of Reactor Safety
cc:
Public Document Room (PDR)
Nuclear Safety Information Cenier (NSIC)
Commonwealth of Massachusetts (2 copies)
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Region I Docket Room (w/ concurrences)
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Executive Offices
800 Boylston Street
Boston, Massachusetts 02199
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Ralph G. Bird
Senior Vice President - Nuclear
October
26, 1987
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BECo Ltr. #87 167
U.S. Nuclear Regulatory Commission
Attn: Document Control Desk
Washington, DC 20555
License No. DPR-35
Docket No. 50-293
Subject: NRC Inspection Report No. 50-293/87-36
Dear Sir:
Attached is Boston Edison Company's response to the Notice of Violation
contained in the subject inspection report.
Please contact me directly if you have any questions on this response.
Attachment
cc: Regional Administrator
U.S. Nuclear Regulatory Commission
Region I
631 Park Avenue
King of Prussia, PA 19406
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Sr. Resident Inspector
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ATTACHMENT I
Boston Edison Company
Docket No. 50-293
Pilgrim Nuclear Power Station
License No. DPR-35
Notice of Violation:
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10CFR50, Appendix B, Criterion XI, states in part, "Test results shall
be... evaluated to assure that test requirenants have been satisfied."
10CFR50, Appendix B, Criterion XVI, states in part, "measures shall be
established to assure that...nonconformances are promptly identified and
corrected."
Contrary to the above, as of August 27, 1987, post maintenance test results
that failed to meet acceptance criteria had not been adequately evaluated. As
a result of the inadequate evaluations, these unsatisfactory test results were
not identified and subsequently corrected.
Two instances were noted where
completed test results of 480 volts (MR No.86-273) and 520 volts (MR No.
86-14-25) had exceeded the acceptance criteria of 460 volts specified in
Procedure No. 3.H.4-10, Attachment C Revision 6.
Both test results had been
accepted as satisfactorily completed following a supervisory and a Quality
Control review on April 10, 1986 and August 15, 1987, respectively.
This is a
Severity Level IV violation (Supplement I) applicable to DPR-35.
Response:
1.
Summary:
Boston Edison concurs with the facts stated in the Notice of Violation.
The fundamental violation was personnel failing to identify discrepancies
between acceptance criteria and recorded test results as required by
Procedure 3.H.4-10.
Corrective action has been taken to resolve that
problem as described in Section 4 of this letter.
Based on a review of the facts of the violation Boston Edison requests the
Severity Level be changed from IV to V.
10CFR Part 2 Appendix C states
that Severity Level V violations, "have minor safety or environmental
significance". He consider this. violation to meet that criterion since an
evaluation has concluded that the motors would not be adversely affected
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by the observed elevated voltages.
A discussion of the pertinent technical details is provided below to
support our position.
Page 1 of 3
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ATTACHHENT I (Centd
2.
Discussion:
Elevated AC voltages have negligible effect on motor RPM and therefore
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will not significantly affect valve stroke time.
Elevated voltages (i.e.
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approximately 520 volts) increase motor heating but do not exceed the
motor's temperature rise capability /reting due to the short operating time.
During a previous outage, prior to the subject work being pr'ormed, an
informal assessment of the discrepancy between nameplate voltage (460V)
and actual bus voltage had been performed on a generic basis.
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informal assessment was performed by a senior Boston Edison electrical
engineer and recently was confirmed by the Nuclear Engineering Department
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by memo dated October 21, 1987.
The subject Procedure, No. 3.M.4-10 "Valve Maintenance" was not being used
to demonstrate valve operability, therefore valve operability was not
comoromised by this error. A separate operating procedure was used to
confirm valve operability.
This violation therefore meets the criterion for severity Level V.
3.
Cause:
Personnel failed to identify a discrepancy between the stated "Acceptance
Criteria" and the recorded test results. This violation was caused by
personnel 1) failing to follow procedures and 2) relying upon a previous
informai evaluation which concluded that voltages up to 520 volts were
acceptable.
In retrospect, the procedure should have either been revised to delete
voltage as an acceptance criteria or the discrepancy evaluated each time
Procedure 3.M.4-10 was used.
4.
Corrective Actions Taken to Avoid Future Violations and Results Achieved:
The Quality Control and Maintenance personnel involved in the violation
were counseled on the importance of procedural adherence.
The Operations QC Group Leader conducted a training session of QC
personnel on August 28, 1987 and reinforced their responsibility to
question and document discrepancies between identified "Acceptance
Criteria" and recorded test data.
The QC Group Leader also issued a
change to the "Quality Control Inspection" procedure to include the
attachment of the acceptance criteria to the quality control inspection
report to facilitate independent review. Additionally, previous uses of
Procedure 3.M.4-10 from January 1987 to the present have been reviewed.
Olscrepancies have been documented and resolved.
The Cnief Maintenance Engineer took prompt action to revise procedure
3.M.4-10 (Rev. 8 issued August 21, 1987) to address the immediate concern
of the voltage data and its intended use.
This change deleted voltage as
an acceptance criteria but retained .ua requirement to record voltage at
the MCC.
Page 2 of 3
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ATTACHMENT I (Cont.)
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On August 28, 1987, the Senior Vice Presidaat, Nuclear empha- %ed to site
personnel at an "All Hands" meeting the importance of prc:erural
adherence. He also noted that if a procedure cannot be followed as
written then work should be stopped and the pr.cedure corrected. On
September 9,1987, a brief summary of the "All Hands ineeting was posted
on the bulletin boards throughout the site.
This recent emphasi;, as well
as continuing training and implementation of the formal Plant Management
Monitoring Program are expected to lessen the likelihood of future
violations.
5.
Date of Full Compliance:
Full compliance was achieved on August 21, 1987 when procedure 3.M.4-10
was revised. Additionally, the QC effort to review previous uses of
Procedure 3.M.4-10, from January 1987 to the present, was concluded on
October 21, 1987,
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Page 3 of 3
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