ML20210T819
| ML20210T819 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/24/1986 |
| From: | Lydon J BOSTON EDISON CO. |
| To: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 86-147, GL-83-28, NUDOCS 8610090215 | |
| Download: ML20210T819 (9) | |
Text
,e BOSTONEDtSON Executive offices 800 Boylston street Boston, Massachusetts 02199 James M. Lydon Chief Operating officer September 24, 1986 BECO Ltr. #86-147 Mr. Hilliam F. Kane Director, Division of Reactor Projects USNRC - Region 1 631 Park Avenue King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293
Subject:
NRC Inspection Report No. 50-293/86-21
Dear Mr. Kane:
This letter is in response to your letter dated August 25, 1986 transmitting NRC Inspection Report No. 50-293/86-21. Attachment I contains Boston Edison Company's response to the Notice of Violation included with the subject I1spection report. Attachment 2 responds to the five concerns identified in your cover letter to which a specific-response was requested. Attachment 3 is unrelated to Inspection 86-21, but has been included at the request of our Senior Resident Inspector.
This attachment discusses testing of backup scram valves. Attachment 4 15 a summary schedule of the major corrective actions included in this response.
Please do not hesitate to contact me directly should there be any questions regarding these matters.
Very truly yours, i
'@ N b
es M. Lydon PJH/la Attachments:
1.
Response to Notice of Violation 2.
Response to Concerns Identified in Cover Letter Transmitting Inspection Report No. 86-21 3.
Revised Response to NRC Generic Letter 83-28, Item 4.5.3 4.
Summary Schedule of Corrective Action 8610090215 860924 PDR ADOCK 05000293 G
ATTACHMEi1T 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 No. 86-21, Appendix A Technical Specification 6.8.A requires that written procedures be establish and implemented that meet or exceed the requirements of ANSI N18.7-1972.
ANSI N18.7-1972, Section 5.3.1 states that procedures shall be sufficiently detailed for a qualified individual to perform the required function without direct supervision. Section 5.3.5 states that special attention shall be given to restoration of normal conditions.
Contrary to the above on July 1, 1986, PNPS Procedure 8.9.8, revision 8, Battery Rated Load Discharge Test, was performed and was not sufficiently detailed for a qualified individual to perform the test without direct supervision.
It did not include steps addressing required system alterations and restoration.
Specifically, procedural steps addressing lifted cables needed for installation of test equipment, placement of temporary jumpers, and the required isolation of certain battery loads were not included in the test procedure.
Boston Edison Response to Violation Boston Edison has reviewed the subject violation and agrees that Procedure 8.9.8, revision 8, should contain additional detail to better enable a qualified individual to perform the Battery Rated Load Discharge test.
In response Procedure 8.9.8 was revised to include specific procedural steps for lifting of cables for installation of test equipment and for placement of temporary jumpers.
In addition,a reference to Nuclear Engineering Department (NED) memorandum 86-495 was added to the procedure to provide additional guidance on the required isolation of certain battery loads-during testing.
This reference combined with the specific procedural guidance to contact the Watch Engineer or Electrical Engineer for other required isolations was believed adequate to address this portion of the violation.
The revised Procedure 8.9.8 (revision 9) was issued for use on July 3, 1986.
As revised Procedure 8.9.8 provides qualified Maintenance personnel with the instructions necessary to perform a battery rated load discharge test on station batteries. Attachments to the Procedure address the specific battery being tested.
To preclude recurrence each of the applicable attachments were also revised to provide the same specific procedural steps required during testing.
Full compliance was achieved on July 3, 1986 when the revised procedure was issued.
-During preparation of this response it was determined that Procedure 8.9.8 should be revised to incorporate the key elements of NED memorandum 86-495 into the applicable attachments.
This revision is expected to be issued in October 1986 and is expected to provide even more specific instruction on the required isolation of certain battery loads during testing.
Page 1 of 2
1 ATTACHMENT 1 (Cont.)
RESPONSE TO NOTICE OF VIOLATION Although not part of the violation a second discrepancy in Procedure 8.9.8 was also noted in the Inspection Report.
That discrepancy involved monitoring of unitano durinn the diccharna toet in roennnen tn the Conine Decident
- Inspeciorsc5ncern[ProcedbrE'i.'9.8was'als5'revisedt5'Yequirec$nsEant
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rather than hourly monitoring of voltage during the discharge test.
1 i
l Page 2 of 2 i
m ATTACHMENT 2 RESPONSE TC (GNCERNS IDENTIFIED IN COVER LETTER TRANSMITlING INSPECTION REPORT NO. 86-21 Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 1.
"The recurring failure of the recirculation motor generator set field breaker used for anticipated transient without scram protection" Boston Edison Response This concern is detailed in Section 4.0.c of the Inspection Report. As indicated at the September 9, 1986 meeting with Dr. Murley and other senior regional managers in our Chiltonville office, this issue maintains very high priority with Boston Edison Company. A detailed root cause analysis effort on this issue has been developed with two distinct parts -
the General Electric Company is performine an evaluation of the failed AKF breaker (estimated completion December 1986), while a consultant is conducting an independent assessment of breaker reliability (estimated completion October 1986).
The recommendations resulting from these programs will be addressed in order to increase the reliability of this component.
Unless the root cause analysis and corrective actions resulting from that analysis can clearly demonstrate that the cause has been corrected, Boston Edison will test the recirculation motor generator (MG) set field breakers at 6-month intervals until an increased reliability has been demonstrated.
Included in the corrective action process will be a review of the available design options of replacing this specific breaker design application for tripping the Recirculation Pumps.
As stated in the 9/9/86 meeting resolution of the field breaker issue will be achieved prior to startup of the unit.
2.
"The apparent failure to properly schedule required surveillance tests" Boston Edi:on Response This concern is detailed in Section 7.0 of the Inspection Report and relates to surveillances whose test interval is once per operating cycle or once per refueling outage as defined by the Technical Specifications.
Boston Edison will perform an analysis of this problem with the aid of an outside consultant.
This analysis is expected to be complete by October 24, 1986, and an action plan to resolve the issue will be developed. An update to this response will be provided by November 21, 1986 based on the analysis.
Page 1 of 4
ATTACHMENT 2-(Cont.)
RESPONSE TO CONCERNS IDENTIFIED-IN COVER LETTER TRANSMITTING INSPECTION REPORT NO. 86-21
- 3.
"The completeness and technical adequacy of logic functional survelliance tests" V
Boston Edison Response As described in section 3.0.e.2 of the Inspection Report. concern #3 focuses on the completeness and technical adequacj of logic functional tests.
-A specific concern is the use of a series of overlapping surveillance tests to fulfill-logic system functional test. requirements.
Boston Edison is currently reviewing a recently con +1eted analysis, to
-determine completeness and technicD edequacy of logic functional surveillance tests.
The NRC will be informed of the results of this-review by November 21, 1986 in a letter updating our response to this
.. Con ce rn.
4.
" Excessive leakage past primary containment isolation valves in excess of established criteria" 1
Boston Edison Response This concern is detailed in section 8.0 of the Inspection Report and involves discrepancies identified by local leak rate test (LLRT)-results being performed under 10CFR50 Appendix "J".
To date 98 of 101 Type B tests and 124 of 133 Type C tests have been
]
completed.
There have been 16 failures, a summary of which is included as
~.
As in previous outages, problem valves will be addressed.
Boston Edison has had and will continue to have an aggre;sive LLRT corrective action program.
Such a program was evident *n the previous refuel outage when approximately 15 containment isolation valves were-overhauled and 13 additional containment isolation valves were replaced.
As corrective action on this concern, an LLRT Failure Analysis Team is being designated.
The Team is multi-disciplined and is comprised of members from both the Nuclear Engineering Department and Nuclear Operations Department.
The LLRT Failure Analysis Team will be responsible i
to determine root cause and recommend corrective actions for each valve that has failed to pass the Local Leak Rate Tests. Corrective action will include a repair, change, or modification that addresses the root cause of 4
' excessive leakage, an assessment of the impact of root cause on valves of similar design, and a review of the testing program for adequacy and frequency to detect valve failures. A schedule has been established to complete these tasks for the 16 failed valves as follows:
[
Designate LLRT Failure Analysis Team.... September, 1986 i
l Determine root cause................... 0ecember, 1986 i
Page 2 of 4 i
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ATTACHMENT 2 (Cont.)
RESPONSE TO CONCERNS IDENTIFIED IN COVER LETTER TRANSMITTING INSPECTION REPORT NO. 86-21 Provide recommended corrective actions... December, 1986 Implement corrective actions to address root cause...............................Feoruary, 1987 Review testing program to ensure methodology and frequency of testing adequately addresses recommended corrective actions to detect valve failures......... March, 1987 A second item noted in Section 8.0 of the Inspection Report discussed the lack of a caution statement in LLRT Procedure 8.7.1.5 on correcting packing leakage prior to taking "as found" data.
In response, caution statements were added to leak rate Procedures 8.7.1.5, 8.7.1.6 and 8.7.1.7 on July 17, 1986 to address this item.
5.
"The extent of fire brigade training at the station" Boston Edison Response This concern is detailed in section 2.0 on page 8 of the Inspection Report and discusses the fire brigade drill requirements set forth by 10CFR50 Appendix R.
Specifically Appendix R,Section I.3.b requires that each fire brigade member participate in at least two drills per year. A review, however, of 10CFR50.48 (b) indicates that 10CFR50 Appendix R. ~--
section I is not applicable to Pilgrim Station.
Instead, Branch Technical Position (BTP) APCSB 9.5-1, Appendix A is applicable at Pilgrim. Although it includes similar drill and training requirements, it does not include a specific drill attendance requirement for each brigade member.
Nevertheless, we believe the Inspector's concern is valid and in response plan to implement the following corrective action.
Presently there are 35 fire brigade members who have not participated in a drill in 1986. Our plan is to secure the necessary resources to perform additional drills commencing on or about October 1,1986 in order to ensure that each of these 35 brigade members will have participated in at least one drill by the end of 1986. At the end of 1986 any of the 35 brigade members who have not been drilled will not be allowed to return to active fire brigade status until they participate in a drill.
Beginning in 1987 the drill schedule will provide a minimum of 2 drills per man per year as recommended. Applicable procedures will be revised accordingly by December 31, 1986 to reflect the new drill schedule.
Page 3 of 4 i
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SUMMARY
OF LLRT FAILURES-be 1.,
Attachaent 2 As Found Leakage SLM System Date LLRT Penetration Component Tested Type Number Inboard Outboard Minimum-Path MSIV "A" 04-19-86 C
7A 70.31
- 04-19-86 C
7A 8.69
- 8.69 MSIV "B" 04-20-86 C
7B 36.66
- 04-20-86 C
7B 4.40 4.40 MSIV "D" 04-20-86 C
7D 52.93
- 04-20-86 C
7D 13.43
- 13.43 D/W Access 06-10-86 B
2 0.00 06-10-86 B
2 10.50
- 0.00 MS Drain 06-24-86 C
8 1.00 06-24-86 C.
8 15.75
- 1.00 FW Ck "A" 06-26-86 C
9A 177.88
- 07-01-86 C
9A 648.50
- 177.88 FW Ck "B" 06-27-86 C
9B 73.63*
06-30-86 C
9B 16.50
- 16.50 Recirc Sample 07-11-86 C
41 169.9
- 07-11-86 C
41 4.40 4.40 D/W Purge Exhaust 07-18-86 C
25 335.0
- 08-12-86 C
25 0.00 0.00 Gas Sample Return 07-23-86 C
228G 9.50*
07-23-86 C
228G 1.00 1.00 D/W Equip Drain 07-25-86 C
19 20.30*
07-25-86 C
19 4.40 4.40 RWCU Supply 07-07-86 C
14 4.00 4.00 07-07-86 C
14 23.00*
4.00 o
- Denotes Valve Failur Total Minimum Path Leakage - 235.7 SLM P e 4 of 4
ATTACHMENT 3 REVISED RESPONSE TO NRC GENERIC LETTER 83-28, ITEM 4.5.3 Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 1.
Testing on Back-up Scram Valves NRC Generic Letter 83-28, item 4.5.3 requested that the licensee evaluate the need for on line functional testing of the back-up scram valves.
Boston Edison Response This letter supplements the previous Boston Edison letter from W.D.
Harrington to D.B. Vassallo, U.S.NRC, dated August 23, 1985 on this topic. Although the need for on-line functional testing of the back-up scram valves is not warranted as explained in the above letter, additional assurance of their ability to function can be demonstrated by periodic testing with the plant shutdown.
Boston Edison, therefore, intends to perform testing during the current outage to demonstrate the ability of these valves to properly function.
This testing will be performed during each subsequent refueling outage.
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Page 1 of 1
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