ML20151L815
| 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
n Edison Company
Mr. Ralph G. Bird
Senior Vice President - Nuclear
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Boylston Street
voston, Massachusetts 02199
Gentlemen:
Subject:
Inspection No. 50-293/88-08
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.
Sincerely,
cr$ ginal signed ByI
,. quo
Jacque P. Durr, Chief
Engineering Branch
Division of Reactor Safety
8808040149 880721
ADOCK 05000293
G
PNV
0FFICIAL RECORD COPY
RL PILGRIM 88-08 - 0001.0.0
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06/17/88
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Boston Edison Company
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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
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
PA0 (15) SALP Reports and All Inspection Reports
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RI:DRS
RI: RS
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
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ll.S. Nuclear Regulatory Commission
Attn: Document Control Desk
Hashington, DC 20555
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Docket Nc. 50-293
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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.
The physical corrective actions for the battery maintenance issue have been
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completed and the procedures will be completed as described in the attached
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response.
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The corrective actions for the D.C. breakers issue are progressing but are not
yet complete.
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
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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.
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King of Prussia, PA 19405
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Sr. Resident Inspector - Pilgrim Station
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Attachment
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Boston Edison Company
Docket No. 50-293
Pilgrim Nuclear Power Station
License No. DPR-35
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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
the seismic support rail and the battery cell at cell 91 on Battery D3.
Resoonse To Violation #1
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.
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.
Page 1 of 4
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ATTACHMENT (continued)
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Corrective Action Taken and Results Achieved:
Maintenance Requests were written and completed during the NRC inspection to
clean the batteries and battery compartments, to clean, grease, and check the
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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:
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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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ATTACHMENT (continued)
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IL@,e of Violation:
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Licensee Technical Specification Section 6.8A requires that kritten
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procedures be established, implemented, and maintained that meet or exceed
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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
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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ATTACHMENT (continued)
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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
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
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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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