ML20207S771
| ML20207S771 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/10/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207S763 | List: |
| References | |
| 50-293-87-04, 50-293-87-4, NUDOCS 8703200257 | |
| Download: ML20207S771 (3) | |
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APPENDIX A NOTICE OF VIOLATION Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 As a result of the inspection conducted on January 12-16, 1987, and in accordance with the " General Statement of Policy for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C, the following violations were identified:
A.
10 CFR 50, 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 When calibration, testing, or other measuring devices are found te 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, measuring 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 deter-mine and document the validity of previous tests and the accept-ability of devices which were previously tested using this M&TE.
This is a Severity Level IV violation (Supplement I) applicable to DPR-35.
B.
10 CFR 50, Appendix B, Criterion XI, requires that test programs be established. BECO Quality Assurance Manual (QAM), Volume II, Section 2, Quality Assurance Program, states that the QA program conform to ANSI N18.7-1976.
ANSI N18.7-1976, paragraph 5.2.19, Test Control, states in part that "A srst program shall be established to assure that testing required to demonstrate that the item will perform satisfactorily in service is identified and documented, and that testing is performed in accordance with written test procedures which incorporate or reference the requirements and acceptance limits...
The test program shall cover all required tests including surveillances tests and tests which demonstrate sati sfactory performance following plant maintenance and modifications.
8703200257 B70310 PDR ADOCK 05000293 G
PDR i
2 In addition, the BEC0 QAM, Section 11, " Test Control", requires in part, that post work tests and periodic surveillance tests are performed by qualified personnel in accordance with
- written, approves test procedures, which identify all test prerequisites and environmental conditions which must be satisfied before performing these tests; that Watch Engineer or his designee, reviews and approves the post-work test data results; and that the N0D Manager is responsible to assure that surveillance tests are performed when required, test results are evaluated, and test requirements are satisfied.
Contrary to the above, as of January 16, 1987, programs for perfor-mance of periodic surveillance tests and tests following performance of plant modifications or maintenance had not been adequately established in that there were no station administrative control procedures which addressed the following:
Overall mechanisms for control of specific test programs such as periodic surveillance tests, post maintenance tests, and post modification tests.
Definition of personnel qualified to perform such tests.
Methods by which prerequisites and environmental conditions are to be determined and examples of such.
Specification of personnel who are designated to approve and evaluate test results and assure that test requirements are satisified.
Definitions of the kinds of instruments to be included in the instrument and control surveillance program.
Methods by which acceptance criteria are properly specified.
Format for post maintenance and post modification test procedures.
This is a Severity Level IV Violation.
(Supplement I)
C.
Technical Specification (T.S.) 4.7.8.1.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 10%.
Contrary to the above, as of January 16, 1987, surveillance test, conducted inaccordance 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
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ThisisaSeverityLevelIVviolation(53)plement1).
v D.
Technical Specification 6.8.A requires that written procedures be
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established, implemented and maintained that meet or exceed the requiiements of ANSI' N18.7-1972. ' ANSI N18.7-1972 requires the establishment of tett proceduresi. to"^ demonstrate satisfactory '
performape followitig 'niodification' safety related structures.
i, Contraiy to the above, on October,,8,1986, Test Procerure No.86-127, "Preoperational Test for Refuelins BrQdge", which tests satisfactory' '
perfor.mances of a safetyirelated,strdcture following 'its modifica - '
tion,.vas improperly impTemented and maintained in-1. hat the test was,
performed without making appropriate technical chdges to correct procedural errors concerning refueling bridgk position numbers and without obtaining the required approvals prior to ' implementation.
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s This is a Severity Level'V violation (Suppl sint'I).
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Pursuant to the provisions of 10 CFR 2.201, Boston Edison Company: is hereby i.
required to submit <co this office within thirty days of the date of the letter which transmitted this Notice, a writtu statement \\ or explanation' in reply,
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including: (1) the corrective steps which have been taken and the results 7
achieved; (2) correctivq steps which will be taken to avoid 'further violations; and (3) the date whep full compliance ki",1 be achieved.
Where good cause is
's shown, consideration will be given to ertending this response time, i
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