ML20203M452

Responds to Violations Noted in Insp Rept 50-293/86-14. Corrective Actions:Manual Revised to Require Appropriate Dept Manager & Vice President Be Notified When 90-day Limit for Deficiency Rept Exceeded

ML20203M452
Person / Time
Site:	Pilgrim
Issue date:	08/25/1986
From:	Lydon J BOSTON EDISON CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
86-120, NUDOCS 8609030464
Download: ML20203M452 (10)

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Executive Offees 800 Boylston Street Boston, Massachusetts 02199 James M. Lydon chief Operatmg Officer August 25, 1986 BECo Ltr. #86- 120 Mr. Richard W. Starosteckt, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission 631 Park Avenue - Region i King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293

Subject:

Response to Violations and Concerns Identified in NRC Inspection Report No. 86-14

Dear Mr. Starosteckt:

Attached please find our response to the two violations described in NRC Inspection Report No. 86-14. As requested in the inspection report, our response addresses the specific violations cited as well as the concerns identified in the cover letter.

Please do not hesitate to contact me directly should there be any further questions regarding these matters.

Very truly yours,

&m e Ja es M. Lydon PJH/ko Attachments: 1. Response to Violations

2. Response to Cover Letter Concerns 8609030464 860G25 PDR ADOCK 00000293 G PDR _

ATTACHMENT 1 RESPONSE TO NOTICE OF VIOLATION Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 Violation as described in NRC Inspection Report 86-14, Appendix A. Page 1 10CFR50 Appendix'B, criterion XVI requires in part that measures be established to assure that conditions adverse to quality are promptly corrected. These measures included the following requirements from the Boston Edison Quality Assurance Manual (BEQAM):

-- Section 18.4.5 of the Boston Edison Quality Assurance Manual (BEQAM) requires that Deficiency Reports (OR) be either dispositioned within 90 days from the date of issuance or have a DR extension authorized by the appropriate Vice President.

-- Sections 16.2.6 and 16.2.9 require that a DR identifying conditions reportable to the NRC under 10CFR50.72 be classified as a significant DR. Section 18.4.2 of the BEQAM further requires that ccrrective action for significant DR's be initiated promptly and that a response to the DR's be sent to QA within one week.

-- Section 18.4.6 of the BEQAM requires that a written request for a second response for a disputed DR be forwarded to and approved by the appropriate Vice President.

Contrary to the above, as of May 9, 1986, measures were not established to assure i that conditions adverse to quality were promptly corrected. Specifically, licensee DR 1466 (issued November 8, 1985) identified a condition adverse to i

quality, i.e., inadequate surveillance testing of the high pressure coolant injection system. However, this condition was not corrected for six months. The following violations of EEQAM requirements contributed to the problem:

-- No Vice President extension was requested either before or after DR 1466 exceeded its 90-day completion date.

j -- The surveillance test problem identified by OR 1466 was subsequently reported to the NRC under the requirements of 10CFR50.72. However, the OR was not classified as significant.

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-- The QA request, dated December 31, 1985, for a second response to DR 1466 was not forwarded to the appropriate Vice President after the initial DR finding was disputed.

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ATTACHMENT 1 (Cont.)

RESPONSE TO NOTICE OF VIOLATION Boston Edison Response to Violation (86-14-07)

In addition to corrective action listed in the Inspection Report, the following corrective action was taken or will be taken in response to the specific items in the violation; Item - No VP Extension Request

Response

i A VP extension was not requested because plant personnel did not agree with the QA finding that the current HPCI test program did not meet Tech Specs.

It was their belief that an engineering evaluation, being conducted at that time, would confirm this. The engineering evaluation, however, confirmed the QA finding.

To prevent the occurrence of a similar incident, the Quality Assurance Manual will be revised by 9/30/86, to require that the Quality Assurance Department (QAD) notify the appropriate department manager and Vice President when the 90 day time limit has been exceeded for each DR; the department manager is advised that unless QAD receives an extension in 15 days, the DR will be escalated to the VP for resolution.

The VP of Nuclear Operations also requires that weekly status reports be submitted for all open DR's; this provides an increased level of executive overview. In addition, thrice weekly meetings are scheduled between QAD and plant personnel; one of the purposes of these meetings is to foster prompt resolution of disagreements such as the one associated with DR 1466.

Item - The DR Has Not Classified as Significant After 10CFR50.72 Report

Response

The BEQAM (Section 16) will be revised to state that all Technical Specifications or FSAR deviations found during an audit or surveillance shall be issued as a significant Deficiency Report. In addition, all potentially reportable 10CFR, Part 21, 10CFR50.72 and 10CFR50.73 ltems found during an audit or surveillance will be issued as a significant Deficiency Report.

Corresponding Procedures N0P83A9 and QAD16.03 will also be revised to reflect these changes. Estimated completion of the revisions to BEQAM, NOP83A9 and QADl6.03 is 9/30/86.

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ATTACHMENT i (Cont.)

RESPONSE TO NOTICE OF VIOLATI_ON Item - QA's Request For Second Respo'nse Not Sent to Vice President Response .

BEQAM Section 18, and NOP83A13 will be revised to require all requests for second responses be forwarded to the appropriate Vice President. Estimated completion of the revisions to BEQAM and NOP83A13 is 9/30/86. l Item - The primary concern of the violation is that a condition adverse to quality was not promptly corrected.

Response

The BEQAM (Section 18.4.6) was revised on 6/10/86, requiring that if QA does not concur with actual / proposed corrective action and prompt resolution cannot be obtained then the matter will be escalated every 15 days to the various levels of Corporate and Executive management up to an including the President.

l The above stated corrective actions combined with those actions listed under our broader response to the~ cover letter concerns relating to QA will sufficiently reduce the probability of recurrence. Full compilance was achieved on 7/14/86, when QA closed out OR 1466.

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ATTACHMENT 1 (Cont.)

RESPONSE TO NOTICE OF VIOLATION Violation as described in NRC Inspection Report 86-14, Appendix A, page 2 Technical Specification 6.8 requires that written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the requirements and recemmendations of Section 5.1 and 5.3 of i

ANSI N18.7-1972.

-- ANSI N18.7-1972 Section 5.3.6 requires that procedures be provided for proper control and periodic calibration of measuring and test equipment.

l -- Pilgrim Nuclear Power Station Procedure 1.3.36, " Measurement and Test J Equipment", states that ready to use (calibrated) measuring and test equipment will be separated from other equipment (rejected) to preclude j inadvertent use.

Contrary to the above, the licensee failed to properly control measuring and test equipment, in that, equipment which was overdue for calibration was not separated from calibrated equipment and was used on three occasions. Specifically, on May 23, 1986, Fluke multimeter No. S8600A was used during local leak rate testing, and

. on March 13 and May 15, 1986 Timer Counters Nos. 134 and 135, respectively, were

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used to calibrate process radiation monitors.

1 Boston Edison Response to Violation _(86-14-03)

In addition to the the immediate corrective action identified in the inspection i'

report the following corrective action was taken in response to the part of violation 86-14-03 pertaining to Timer Counters Nos. 134 & 135.

A person has been assigned to control the issuance of measurement and test equipment. The individual is assigned to the Instrumentation and Control (I&C) Group and is responsible to remove equipment from locked cabinets when calibration of equipment is due to check that equipment removed from the controlled area is signed out including a calibration due date, and finally to provide an independent verification that the equipment issued for use is within the calibration time frame.

An inspection of the measurement and test equipment area was made to determine corrective action effectiveness. During the inspection, the i following observations were made:

-- Timer Counter No. 134 was calibrated on 4/10/86, and is due for callbration on 10/10/86;

-- Timer Counter No. 135 was calibrated on 8/6/86, and is due for calibration on 2/6/87;

-- the calibration sheets for equipment issued for use in the field (on the day of the inspection) included sign outs with due dates;

-- the preventive maintenance data sheets used to determine when equipment calibration is due were reviewed and were up to date, j Page 4 of 6 1

ATTACHMENT 1 (Cont.)

RESPONSE TO NOTICE OF VIOLATION ,

A meeting was conducted on 6/24/86, by I&C supervisory personnel for I&C technicians (in::luding contractors) reiterating the importance of checking the calibration due dates of equipment prior to use. (Ref. Internal I&C memo dated 6/24/86 including attendance sheets and a copy of the Measurement and Test Equipment Control Guidelines).

A contractor with previous experience in the Control of Measurement'and Test Equipment has been hired to enhance the issuance and control process. That individual is also involved in planning long-term modifications to further improve the facility and logistics associated with issuing and controlling measurement and test equipment.

The fluke multimeter No. S8600A cited in the report as being outside its calibration time frame was not being controlled in the I&C equipment lockers at the time of the violation. Instead the multimeter was being controlled by the On Site Safety and Performance Group (OSS&PG) to expedite local leak rate testing.

In response to the part of NRC Violation #86-14-03 pertaining to the Fluke Multimeter, the following corrective actions have been or will be taken:

The Fluke Multimeter No. S8600A has been removed from the OSS&PG " Measurement and Test Equipment System". This multimeter has been sent off site for calibration and a "For Information Only - Not in M&TE System" sticker will be placed on the face area when it returns from being calibrated. Local leak rate testing calibrations requiring a Fluke Multimeter are now being i performed utilizing I&C multimeters which are tracked and calibrated under the I&C system.

1 A complete review of the OSS&PG M&TE System was performed to ensure compliance with Procedure 1.3.36.

1 In addition, OSS&PG personnel will attend a training seminar to further clarify their M&TE Systen and the associated requirements of Procedure 1.3.36. Any personnel that have not completed the above training will not i have access to the locked OSS&PG M&TE storage chests. OSS&PG personnel are

! expected to successfully complete this training by 9/19/86.

To address the Senior Resident Inspector's concern that the serial number and calibration due date were not required to be recorded on LLRT test data sheets, a procedure revision was made (8.7.1.5) to require this information on the LLRT data sheet.

As a result of the previously stated corrective actions, the following results have been achieved.

established a higher degree of confidence that test equipment with expired calibration dates will be separated from other equipmenti Page 5 of 6

ATTACHMENT I (Cont.)

RESPONSE TO NOTICE OF VIOLATION established an independent verification to ensure that equipment issued from the I&C area is within its calibration time frame and is signed out t

using an instrument issuance sheet with calibration due dates properly recorded; determined via a quality check that the corrective actions have been effective; determined that the corrective actions taken will s!gnificantly reduce the likelihood of future violations in this area.

Full compliance was achieved on May 23, 1986, when the fluke multimeter in question was replaced by one within the calibration window and the local leak rate test cart check was satisfactorily completed. Full compliance with regard to the timer, counters was achieved on May 15, 1986, when immediate corrective action war taken to address the inspector's concerns.

The body of Inspection 86-14 referred back to a previous citation (Inspection 85-03 Notice of Violation E) in this area. We have reviewed that citation and believe that corrective actions stated in response to violation 86-14-03 are more thorough and evtensive and will significantly reduce the possibility of a recurrence.

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ATTACHMENT 2 RESPONSE TO COVER LETTER CONCERN Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. OPR-35 NRC Cover Letter Concern Regarding Inadequacles in the Preparation of Safety Evaluations A concern stated in the cover letter (paragraph four) involves inadequacles in the preparation of safety evaluations and a lack of communication between Boston Edison staff. The specific item referred to involves utilization of non-seismic Diesel Generator Lockout Relays and is listed in the body'of the inspection report as unresolved Item 86-14-01.

Boston _ Edison Response to Safety Evaluation Concern In response to the Senior Resident Inspector's concern, Boston Edison

! initiated an investigation into the 41 story, cause and corrective actions to prevent recurrence of this event. The results of that investigation are detailed in a ten page memorandum (NED 86-583 dtd. 8/4/86) from the Nuclear l Engineering Manager to the Vice President of Nuclear Engineering and Quality Assurance. A copy of that memo was given to our Senior Resident Inspector.

In summary, failure of Boston Edison to utilize one of the existing corrective action programs to dispositten the relay issue resulted in a lack of documented operator notification that the relays were susceptible to failure during a seismic event. Specifically, the investigation determined that there were several points during the history of this event that the corrective action process could have been uttilzed:

1. upon original determination by Station personnel that GE type CFD relays were installed;

2. Upon determination by Engineering that these relays were in a circuit configuration which made our EDG's susceptible to seismic lock-out;

3. Upon release of the Engineering Service Request Response memo by Engineering;

4. upon acceptance of the Engineering Service Request Response by the Station.

Use of the corrective action program (Fallure and Halfunction Report Procedure 1.3.24 or NED Procedure 16.03) would have provided the following:

1. Immediate notification of the Watch Engineer that the installed relays were susceptible to failure during a seismic event.

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ATTACHMENT 2 (Cont.)

RESPONSE TO COVER LETTER CONCERN

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2. Review of the issue for reportability (10CFR50.77/50.73) to the NRC. (LER 86-013 entitled "Use of Non-Seismic Ceneral Electric Type CFD Relays" was submitted on 6/30/86).

3. Formal engineering review of the issue and its implications.

4. Identification and tracking of short and long term corrective actions.

5. Operations Review Comalttee review of the problem.

In specific response to the relay issue, new seismically quallfled relays were installed (completed 8/14/86). Prior to installation of the new relays, on watch Ilcensed operations personnel were trained by the Nuclear Training Department with regard to the relay prcblem (completed 6/23/86).

In response to the broader issue of inadequacies in the preparation of safety evaluations and the lack of staff communication we revisited what was determined to be the underlying cause of the problem (i.e., Boston Edison did not utilize one of the corrective action programs to disposition the relay issue). Corrective action was directed at the underlying cause and included the following:

- An Engineering review of ESR's generated by Station personnel during the past year to determine the extent to which ESR's were used in place of the Corrective Action Program. The review of actual ESR's was completed on 8/15/86. Potential Coiidition Adverse to Quality (PCAQ) forms were initiated for each item discovered and are currently under pursuit through the Corrective Action Program.

- Plant management will evaluate the adequacy of Corrective Action Program (Procedure 1.3.24) training completed by Station personnel in February 1986 based upon the results of the Engineering review of ESR's. The evaluation will determine if the training, completed for unrelated reasons, addressed the type of issue discussed herein. Expected completion of the evaluation is September 1986.

- Initiated training of Engineering Department personnel in the existing Cerrective Action Program which is 90% complete. Full completion is expected by September 1986.

- A review of NED procedures which implement the Corrective Action Program has been initiated to determine adequacy. This is expected to be completed in September 1986.

- Training of appropriate Engineering Department personnel on the preparation of safety evaluations is scheduled for completion in September 1986.

He believe that these corrective actions, especially the Corrective Action Program training, will significantly reduce the probability of a recurrence.

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ATTACHMENT 2 (Cont.)

RESPONSE TO COVER LETTER CONCERN NRC Cover letter Concern Regarding the Role of the Quality Assurance Department i A concern stated in the cover letter (paragraph 3) involves a lack of management initiative in the timely resolution of QA identified issues and that there may be a lack of appreciation on the part of some elements of the organization as to the role of the QA staff.

Boston Edison Response to Quality Assurance Concern j The Boston Edison Company including Vice President and Executive Vice President levels have recognized the need to improve the entire Organization's attitude toward the Quality Assurance Program. This recognized need has been communicated to Regional Management during our last three progress update meetings held at your offices in King of Prussia and our Chiltonv111e facility. Specific actions that have already been taken or planned to improve our performance in this area include:

Daily, (now thrice weekly) meetings, are scheduled between the Station Manager, Section Heads and QA representatives to address overdue, current and new Deficiency Reports. These meetings have resulted in the significant reduction of overdue DR's and timely resolution of current and i ncw Dr's. These meetings will include discussion and resolution of QA l DR's and recommendations and demonstrate improved communication, i

The QA Department hrs revised the DR response procedure to mandate rapid escalation of problem DR's up through the Manager, Vice President and Executive Office level. This change will ensure that problem DR's do not become inactive at one level of management and also demonstrates increased QA aggressiveaess in resolving open issues.

Selected managers in the Nuclear Organization are planning to evaluate a

" Quality Improvement Program" utilized by a sister utt11ty. A presentation of that program is scheduled for September 24, 1986.

During the exit meetings QA personnel will make every effort to ensure that the cited department understands and concurs with the deficiency.

DR's are assigned by the Station Manager to Section Managers who are held accountable to complete corrective actions within the required time frame.

We believe that these specific actions address the concerns regarding the role of the Quality Assurance Department at Pilgrim Station and demonstrate that management and staff of the nuclear organization clearly understand the important role of our Quality Assurance Department.

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