ML20151L815

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/88-08

ML20151L815
Person / Time
Site:	Pilgrim
Issue date:	07/21/1988
From:	Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Bird R BOSTON EDISON CO.
References
NUDOCS 8808040149
Download: ML20151L815 (3)

See also: IR 05000293/1988008

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21 JUL 1988

ket No. 50-293 l

n Edison Company

Mr. Ralph G. Bird

Senior Vice President - Nuclear '

Boylston Street l

voston, Massachusetts 02199

Gentlemen:

Subject: Inspection No. 50-293/88-08

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This refers to your letter dated May 26, 1988, in response to our letter

dated April 27, 1988.

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.

Your cooperation with us is appreciated.

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Sincerely,

cr$ ginal signed ByI

,. quo *

Jacque P. Durr, Chief

Engineering Branch

Division of Reactor Safety

8808040149 880721

PDR ADOCK 05000293

G PNV

0FFICIAL RECORD COPY RL PILGRIM 88-08 - 0001.0.0 -\ \

06/17/88

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Boston Edison Company 2

cc:

K. Highfill, Station Director

R. Anderson, Plant Manager

J. Keyes, Licensing Division Manager

E. Robinson, Nuclear InformationManager

R. Swanson, Nuclear Engineering Department Manager

The Honorable Edward J. Markey

The Honorable Edward P. Kirby

The Honorable Peter V. Forman

B. McIntyre, Chairman, Department of Public Utilities

Chairman, Plymouth Board of Selectmen

Chairman, Duxbury Board of Selectmen

Plymouth Civil Defense Director

P. Agnes, Assistant Secretary of Public Safety, Commonwealth of

Massachusetts

S. Pollard, Massachusetts Secretary of Energy Resources

R. Shimshak, MASSPIRG

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

Commonwealth of Massachusetts (2)

bcc:

Region I Docht Room (with concurrences)

M. Perkins, Management Assistant, DRMA (w/o encl)

S. Collins, DRP

R. Blough, DRP

L. Doerflein, DRP

R. Bores, DRSS

D. Mcdonald, PM, NRR

PA0 (15) SALP Reports and All Inspection Reports

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RI:DRS

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RI: RS

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RI:DRS

Koshy/gcb Anderson Durr

6/ 6/88 6/4 Y88 f//7/88

0FFICIAL RECORD COPY RL PILGRIM 88-08 - 0001.1.0

06/17/88

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Executive Offices

800 Boylston Street

Boston, Massachusetts o2199

Ralph G. Bird

Senior Vice President - Nuclear May 26, 1988

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BECo Ltr. #88 085

ll.S. Nuclear Regulatory Commission

Attn: Document Control Desk

Hashington, DC 20555

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{ Docket Nc. 50-293

l License No. DPR-35

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Subject: NRC Inspection Report 50-293/88-08

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Dear Sir:

Attached is Boston Edison Company's response to the Notice of Violation

contained in the subject inspection report.

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The physical corrective actions for the battery maintenance issue have been

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completed

response. and the procedures will be completed as described in the attached

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Thecomplete.

yet corrective actions for the D.C. breakers issue are progressing but are not

The corrective actions will be completed prior to plant restart.

Please do not hesitate to contact me directly if you have any questions.

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R.G. ird i

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RH/bl

Attachment: Resnonse to Violation

CC:

Mr.HilliamRussell!

Regional Administrator, Region 1

U.S. Nuclear Regulatory Commission )

475 Allendale Rd. '

King of Prussia, PA 19405 )

Sr. Resident Inspector - Pilgrim Station l

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Attachment

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Boston Edison Company Docket No. 50-293

. Pilgrim Nuclear Power Station License No. DPR-35

Notice of Violation

As a result of the inspection conducted on February 1-5, 1988, and in

accordance with the "General Statement of Policy and Procedure for NRC

Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement Policy), the

following violations were identified:

1. 10 CFR 50 Appendix B Criterion V requires that activities affecting

quality shall be prescribed by documented procedures which include

appropriate quantitative or qualitative acceptance criteria for

determining that important activities have been satisfactorily

accomplished.

The Pilgrim Nuclear Power Station safety related battery manufacturer's

instruction manual 12-800 "C&D Power Systems stationary battery

Installation and Operatina instructions manual" section 9.3 requires all

corrosion by-products be removed and to check torque values to be 125 inch

pound at battery connections and section 3.2.3 requires seismic support

side rails be very close to the battery with a gap just enough to permit

an index card to be inserted.

Contrary to the above, on February 2,1988, the licensee Procedures 8.C.14

Revisica 20, September 16, 1987 "Heekly Pilot Cell And Overall Battery

Check" and C.C16 Revision 14, October 5,1987 "Quarterly Battery Cell

Surveillance" did not include the appropriate qualitative and quantitative

criteria for removing corrosion by-products, specifying torque values at

the battery connections, and establishing the gap between seismic support

rails and the battery jars, and it was observed that the battery terminals

were corroded at cells 31 through 60 and cell 3 at Battery D2, cell 43 on

Batter,v D1, cell 40 on Battery D3, and there was an excessive gap between l

the seismic support rail and the battery cell at cell 91 on Battery D3.

Resoonse To Violation #1 l

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Discussion:

Pilgrim Nuclear Power Station (PNPS) Technical Specification sections 4.9.A.2.a and 4.9.A.2.b require that every week the specific gravity, the

voltage and temperature of the pilot cell and overall battery voltage shall be

measured and logged and that every three (3) montns the measurements shall be

made of voltage of each cell to the nearest 0.1 volt, specific gravity of each

cell, and temperature of every fifth cell shall be logged respectively. PNPS

Procedures 8.C.14 and 8.C.16 are used to comply with these Technical

Specification requirements and to provide instructions for performing each

surveillance.

Cause:

The cause of this violation was inadequate procedures for the conduct of

maintenance on station batteries. Specifically, procedures did not include

acceptance criteria for removal of corrosion by-products, torquing of battery

connections and spacing between the battery cells and the seismic support

rails.

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ATTACHMENT (continued)

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Corrective Action Taken and Results Achieved:

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Maintenance Requests were written and completed during the NRC inspection to

clean the batteries and battery compartments, to clean, grease, and check the

torque of the battery connections and to perform a battery discharge test to

verify operability. The results of the discharge test revealed 2 faulty cells

numbers 47 and 49, in the 125 volt 'A' battery. HR's were written to replace

the cells and the discharge test was successfully completed.

Corrective Actions Taken to Prevent Recurrence: .

In a joint effort, PNPS Plant Operations and Maintenance personnel are

revising Procedures 8.C.14, 8.C.16 and developing a new r'ocedure

3.H.3-25.1. The revisions incorporate the Technical Specification

requirements and acceptance criteria into Procedures 8.C.14 and 8.C.16 (owned

by Plant Operations) and the manufacturer's requirements and acceptance

criteria into Procedure 3.H.3-25.1 (owned by Plant Maintenance). The new

requirements set forth in the two procedure revisions and the new procedure

will be incorporated into the Haster Surveillance Tracking Program.

Safety Conseauences:

The safety consequences of this event were minimal. A review concluded, that

based on HR's and the existing, planned and scheduled Maintenance activities

the station battery operability would have been verified prior to restart.

Date of Full Comoliance:

The HR's to clean the batteries and battery compartments, to clean, torque and

lubricate the battery connections and to perform the discharge test were

completed in February of 1988. The procedure revisions are expected to be

completed and approved by June 1, 1968.

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IL@,e of Violation:

I 2'. Licensee Technical Specification Section 6.8A requires that kritten

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procedures be established, implemented, and maintained that meet or exceed

the requirements of ANSI N18.7-1972 and Appendix A of USNRC Regulatory

Guide 1.33, Paragraph 5.3.6 of ANSI N18.7-1972 which requires that

procedures be provided for the periodic calibration and testing of safety

related protective circuits. RG 1.33 Appendix A Section 8(2)(q) requires

calibration for emergency power tests.

Contrary to the above on February 2, 1988, the safety related 125 and 250

Volt DC safety related circuit breakers utilized in DC Motor control

Centers DS, D6, 08, D9, DIO, D17 and D37 did not have written test

procedures for calibration and testing of safety related protective

circuits and were not tested or calibrated to demonstrate their safety

related function.

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B soonse Violation #2:

Discussion:

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Pilgrim Nuclear Power Station (PNPS) FSAR section 8.6.5 Inspection and

Testing, states, "Periodic tests of the equipment and the system are conducted

to detect the deterioration of equipment in the system toward an unacceptable

condition." PNPS Technical Specification 3.8.A.5 states "The reactor shall

not be made critical unless all of the following conditions are

satisfied:...."The Station and switch yard 125 and 250 volt batteries are

operable. Each battery shall have an operable battery charger."

Cause:

Inadequate procedures was the cause of this violation.

Corrective Action Taken and Results Achieved:

Immediate corrective action was taken by the Nuclear Engineering and

Maintenance Departments to test 10 of the 39 DC breakers at DC Motor Control

Centers. PNPS Procedure 8.Q.3-4, "125/250 V DC Motor Control Center Testing

and Haintenance," was revised to include the acceptance criteria established

by Nuclear Engineering Department for the 10 DC breakers tested. The 10 DC

breakers tested satisfactorily.

Effort to establish additional testing of safety related DC breakers prior to

restart from RFO-7 is in progress. The testing plan for the DC breakers and

test results will be provided to the Senior NRC Resident Inspector and Region

I office prior to restart.

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, Corrective A-tions Taken to Prevent Recurrence:

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A coordinated effort between PNPS Nuclear Engineering and Maintenance is under

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way to develop a periodic testing program for DC breakers. The existing PNPS

Procedure 8.Q.3-4 will be revised to include acceptance criteria established

by Nuclear Engineering Department for the remaining DC breakers and will be

included in the automated Preventive Maintenance Schedule program. This

action will ensure that the DC breakers will be inspected and tested

periodically to satisfy the requirements of PNPS Technical Specification 6.8.A.

Safety Conseauences:

The Safety Design Basis for the 125V and 250V DC power Systems is that no

single component failure will prevent the systems from providing power to a

sufficient number of vital DC loads necessary for safe shutdown. A single l

line to ground fault is the most common type of fault. Since the DC system is  !

ungrounded, this type of fault would not cause overcurrent and undervoltage.

Faults to ground are detected and annunciated for operator action. Multiple

DC grounds are unlikely because a single ground is promptly located and i

removed as soon as possible after alarming in the Main Control Room. The type

of fault that would cause excessive overcurrent and undervoltage is a

line-to-line fault. If this highly improbable single failure occurs anywhere

in the DC system it will cause a trip and isolation of DC equipment downstream

of the closest isolation device and, in the worse cause, would result in the

loss of an entire train of the DC system. It will not result in losing both

redundant trains because of design basis separation. Loss of either train

will not cause loss of its redundant train.

Date of Full Como11ance:

The initial testing of DC breakers will be completed prior to restart from

RF0-7. The long-term periodic surveillance testing program for the DC

breakers will be in place after restart from RFO-7 but prior to RFO-8.

RW/b1

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