ML20206H343

Responds to NRC Ltr Re Violations Noted in Insp Rept 50-293/87-04.Corrective Actions:Instrumentation & Control Measuring & Test Equipment Evaluation Completed on 870327. Response to Violation B Will Be Provided at 870422 Meeting

ML20206H343
Person / Time
Site:	Pilgrim
Issue date:	04/09/1987
From:	Bird R BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
87-56, NUDOCS 8704150332
Download: ML20206H343 (6)

Text

. e aosnmasm Executive Offices 800 Boylston street Boston, Massachusetts 02199 Ralph G. Bird senior Vice President - Nuclear April 9, 1987 BECo Ltr. #87-56 U.S. Nuclear Regulatory Commission Attn: NRC Document Control Desk Washington, D.C. 20555 License No. OPR-35 Docket No. 50-293

Subject:

NRC Inspection Report 50-293/87-04

Dear Sir:

Attached is Boston Edison Company's response to the Notice of Violation set forth in the subject inspection report. The response to violation B is not included in this letter and, at our request, will be discussed between Boston' Edison and NRC personnel on April 22, 1987. This was agreed to on April 8, 1987 in a telephone conversation between Boston Edison and NRC Region I management.

In response to the concerns identified in the cover letter which transmitted the subject inspection report, the Pilgrim Nuclear Operations Manager (NOM),

contacted the Chief-Reactor Projects Section 18, and the lead inspector for Inspection 87-04 to obtain a clear understanding of the issues. With respect to the concern that plant personnel recognized procedural problems but took no corrective action, our investigations confirmed company policy was violated in this instance. The individuals involved have been reprimanded.

During further discussion with your staff we determined that the other concerns in your cover letter involved the previously identified problems in our surveillance test procedures and surveillance tracking program. Our planned actions in response to these concerns were discussed on 2/2/87 at a meeting between NRC and Boston Edison managers, in subsequent telephone conversations between the NOM and Region I managers, and in the Boston Edison response to Inspection 86-41.

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8704150332 870409 PDR ADOCK 05000293 'O G PDR '

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. Page 2 NRC Inspection Report 50-293/87-04 Please do not hesitate to contact me directly if you have any questions.

EM/la Attachment cc: Regional Administrator U.S. Nuclear Regulatory Commission 631 Park Avenue - Region.I '

King of Prussia, PA 19406 Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Senior Resident Inspector 4 -

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ATTACHMENT 1 Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 Notice of Violation A 10CFR50, Appendix B, Criterion XII, requires that measuring and test equipment ,

be properly controlled. Boston Edison Company (BECO) Quality Assurance Manual, Volume II, Section 2, Quality. states that the QA program conforms to ANSI N18.7-1976. ANSI N18.7-1976, Paragraph 5.2.16 states in part "...Hhen calibration, testing, or other measuring devices are found to be out of calibration, an evaluation shall be made and documented concerning the validity of previous tests and the acceptability of devices previously tested from the time of the previous calibration..." Station procedure 1.3.36, Measuring and Test Equipment, further implements the above requirement.

Contrary to the above, measurina and test equipment (M&TE) was improperly controlled, in that, on January 14, 1987, eighteen instances dating back to March 1986, were observed in which M&TE were found to be out of calibration and no evaluation was made to determine and document the validity of previous test and the acceptability of devices which were previously tested using this M&TE.

This is a Severity Level IV violation (Supplement I) applicable to DPR-35.

Response

This violation involved the M&TE programs of both the Instrumentation and Control (I&C) and Station Services groups of the plant Maintenance Section.

1. Corrective Steps Taken and Results Achieved An evaluation of I&C M&TE usage was completed on March 27, 1987, correcting the items identified in the Inspection Report. The results of these evaluations did not identify any tests which required re-performance.

Corrective action for the Station Services Group has been initiated through the research of existing records to determine which evaluations have not been completed. This review and re-evaluation is forecast to be completed by April 30, 1987.

2. Corrective Steps Taken to Avoid Further Violations Investigation revealed that the contributing factors to this violation were an inadequate M&TE procedure and the need for increasing the M&TE staff. Boston Edison management had previously identified and was in the process of training an M&TE staff individual during the inspection period.

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ATTACHMENT 1 (Cont.)

The M&TE procedure is being revised to specify the responsibility for conduct of evaluations. Although the procedure has not yet been formalized, Boston Edison management has made it clear to the appropriate individuals exactly who is responsible and accountable for M&TE evaluations.

In addition, a pilot computer program was instituted in February, 1987 for the I&C Group's M&TE tracking system. This program has been demonstrated as being very beneficial and is being expanded to incorporate the M&TE for the entire Maintenance Section. This pilot program was reviewed during Special NRC Inspection 87-12 in February, 1987 with positive results noted by the NRC Inspector. Implementation of this program is expected to be completed by July 31, 1987.

3. Date When Full Compliance Was Achieved The incomplete I&C evaluations identified during the inspection were completed on March 27, 1987. In addition, the system for completing evaluations within the I&C Group has been maintained current to within two weeks of the time M&TE is identified as being out of calibration or damaged. The review of outstanding evaluations for M&TE controlled by the Station Services group is more extensive and will be completed by April 30, 1987. The M&TE procedure changes are expected to be completed by April 30, 1987.

Notice of Violation C Technical Specification (T.S.) 4.7.B.l.a(4) requires that, at least once every 18 months, automatic initiation of each branch of the standby gas treatment system be demonstrated and that fans start and operate at 4000 CFM i 107..

Contrary to the above, as of January 16, 1987, surveillance test, conducted in accordance with procedures, 8.M.2-1.5.8.3 and 8.M.2-1.5.8.4, to demonstrate automatic initiation of the standby gas treatment system every 18 months, did not demonstrate that the fans start and operate at 4000 CFM i 107..

This is a Severity Level IV violation (Supplement 1).

Response

1. Corrective Steps Taken and Results Achieved A review was conducted of recent surveillance tests of the Standby Gas Treatment System (SGTS). The flow rates of the SGTS are recorded during the performance of procedure 8.7.3 Secondary Containment Leak Rate Test.

This test is performed during a refueling outage' to satisfy TS 4.7.C.l.c.

Recorded flow rates were verified to be within the acceptance criteria of TS 4.7.B.l.a(4).

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ATTACHMENT 1 (Cont.)

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2. Corrective Steps Taken to Avoid Future Violations '

Procedure 8.7.3, Secondary Containment Leak Rate Test, will be revised to incorporate the requirements of Technical Specification 4.7.B.1.a.(4).

The test is conducted every 18 months, consistent with the requirements of the Technical Specifications.

, 3. Date When Full Compliance Will Be Achieved The revision to procedure 8.7.3 is expected to be completed prior to April 30, 1987. Re-performance of the applicable portions of the procedure will be completed prior to returning nuclear fuel to the reactor vessel.

Notice of Violation D Technical Specification 6.8.A requires that written procedures be established, implemented and maintained that meet or exceed the requirements of ANSI N18.7-1972. ANSI N18.7-1972 requires the establishment of test procedures to demonstrate satisfactory performance following modification safety related structures.

Contrary to the above, On October 8, Temporary Procedure No.86-127, "Preoperational Test for Refueling Bridge", which tests satisfactory performances of a safety related structure following its modification, was improperly implemented and maintained in that the test was performed without making appropriate technical changes to correct procedural errors concerning refueling bridge position numbers and without obtaining the required approvals prior to implementation.

This is a Severity Level V violation (Supplement I).

Response

1. Corrective Steps Taken and Results Achieved The violation occurred due to the test director's failure to halt the test when he observed the two referenced inaccuracles in the procedure; the test procedure should have been revised per established station procedure prior to his proceeding with the test. The test director did use the correct values when he performed the test but Boston Edison does not permit such exceptions to be taken from test procedures as written.

Investigation indicates that this is not indicative of a trend for this individual.

As corrective action, the procedure was appropriately revised and approved on 1/16/87, and the test re-performed with the revised procedure on 1/19/87. The 1/19/87 test results indicated proper interlock functioning.

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ATTACHMENT 1 (Cont.)

2. Corrective Steps Being Taken to Avoid Future Violations The following actions have been taken to preclude recurrence of the violation:

The Director of Outage Management reprimanded the individual ~ test director regarding the unacceptability of his actions leading to the violation.

The Modifications Management Group Leader immediately reinforced to the other staff test directors that Boston Edison does not permit any exceptions from the test procedures and, if.a problem is encountered with a test procedure during its conduct, they are to stop the test and ensure that proper approval for changes are obtained per Station Procedure 1.3.4 before continuing.

3. Date Full Compliance Was Achieved Full compliance was achieved on January 19, 1987, when the test was successfully re-performed using the appropriately revised procedure.

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