ML20213E939

Responds to NRC Re Violations Noted in Insp Rept 50-293/86-25 & Deviation Noted in Insp Rept 50-293/86-21. Corrective Actions:Two Fire Drills Per Brigade Member Will Be Conducted in 1986

ML20213E939
Person / Time
Site:	Pilgrim
Issue date:	10/30/1986
From:	Lydon J BOSTON EDISON CO.
To:	Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
86-169, NUDOCS 8611130382
Download: ML20213E939 (7)

Text

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,oamm Executive Offices 800 Boylston street Boston, Massachusetts 02199 James M. Lydon Chief Operating officer October 30, 1986 BECO Ltr #86-169 Mr. William F. Kane Director, Olvision of Reactor Projects USNRC - Region 1 631 Park Avenue King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293

Subject:

Response to NRC Inspection Report No. 50-293/86-25

Dear Mr. Kane:

This letter is in response to your letter dated September 25, 1986 transmitting NRC Inspection Report No. 50-293/86-25. Attachment I contains Boston Edison Company's response to the Notice of Violation included in the subject Inspection Report. In addition, we have reviewed the Notice of Deviation concerning fire brigade training and have supplemented our response on this issue as set forth in Inspection Report No. 50-293/86-21 in Attachment 2.

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

Very truly yours, James M. Lydon PJH/meb Attachments: 1. Response to Notice of Violation

2. Response to Notice of Deviation 8611130302 e61030 3 PDR ADOCK 0500 G

_. ____b

ATTACHMENT 1, RESPONSE TO NOTICE OF VIOLATION Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 Violation "A" as described in NRC Inspection Report No. 86-25, Appendix A 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, states that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.

Boston Edison Company Quality Assurance Manual, Sections 15 and 16, establishes the corrective action program. In particular, section 15 states that nonconforming materials, parts or components identified during operation are documented and reported via a Failure and Malfunction Report (F&MR).

Pilgrim Nuclear Power Station Procedure (PNPS) 1.3.24, Revision 12, Failure and Malfunction Reports, states that a F&MR shall be initiated whenever any abnormal plant condition is identified that has the potential to adversely affect safe operations. The procedure states that the F&MR is used to inform plant management of important plant conditions, insure that initial reviews and safety assessments are made, determine if events are reportable to the NRC, and document that corrective actions are initiated.

Contrary to the above, during 1985, F&MR's were not completed by licensee engineering personnel after they identified deficient station fire barriers.

An F&MR was also not promptly initiated on July 2, 1986, after an engineering memo outlining the deficient barriers was sent to the station. As a result the licensee did not promptly review the barrier deficiencies and could not determire in a timely manner whether corrective actions, as required by Section 3.12.F of the Technical Specifications, were initiated in 1985 and 1986. In addition, the deficiencies were not reviewed at the time, for reportability to the NRC.

Boston Edison Response to Violation A We have reviewed the history of the subject issue and have concluded the following:

Fire barrier deviations were in fact identified in March of 1935 (Ref. Ltr.

10394 GLBE 85/200 dated 4/5/85) and were expeditiously reported by engineering to station personnel via telecon rather than using the F&MR Process.

The existence of the deviations potentially affected fire barrier operability. The alternative compensatory measures required by the Technical Specifications were verbally requested by engineering personnel.

The impact of the above described situation on plant safety was negligible since general area fire watches provided adequate protection until plant design changes or engineering justifications could be completed to resolve the deviation. Fire watch coverage has been provided since the deviations were identified in early 1985.

Page 1 of 4 a

The fire ratch postings tere not tied to resolution of these specific deviations. H: wever, our review of each case revealed that protection

. equivalent to technical specification required compensatory measures was in place throughout this period.

Had a F&MR been issued, continuation of the fire watch until the barrier

' deviation was resolved would have been better assured and a review of the events for reportability would have been more timely.

A total of thirty-four fire barrier deviations are involved. To date:

-- 10 have been resolved

- 19 others are scheduled to be resolved in November, 1986 upon completion of fire hazard analyses.

- The remaining 5 are expected to be resolved by December 30, 1986 via plant design changes (reference Plant Design Change 86-31).

Based on our review of this situation the following corrective actions have been completed:

Failure and Malfunction Report 86-164 was issued on 7/8/86 documenting the existence of the remaining fire barrier deviations (as noted in the Inspection Report). Fire watches have been confirmed to be in place for the remaining deviations with continued coverage now tied to the F&MR.

Fire watches and patrols currently in place have been researched by the fire watch project manager. The project manager is responsible to ensure that no coverage is removed without first resolving the subject deviations.

Additional corrective action to prevent recurrence is not necessary because of the existing controls in place under the Fire Protection Officer.

In order to resolve the programmatic weakness involving the failure to utilize the F&MR process, specialized training of Engineering personnel in the existing Corrective Action Program including the use of F&MR's was conducted on August 4, 5 and 21. Similar training of site personnel including the individual who had received the engineering memo on July 2, 1986 without promptly initiating an F&MR, was completed on October 2, 1986.

Engineering Support Request responses for the past year have been reviewed for similar problems where the corrective action program should have been used but was not. Forty-two Potential Conditions Adverse to Quality (PCAQs) were identified and documented based on this review; however, no operability or reportability concerns were identified.

We believe that the above stated corrective actions, especially the Corrective Action Program Training, have achieved the desired result of eliminating the programmatic weakness cited in the Notice of Violation. Full compliance was achieved on October 2, 1986 when the Corrective Action Program Training was completed.

Violation "B" as described in NRC Inspection Report No. 86-25. Appendix A Technical Specification 6.8.A states that written procedures shall be established and implemented that meet or exceed the requirements of section 5.1 of ANSI N18.7-1972.

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kNSIN18.7-1972, Administrative Controls for Nuclear Power Plants, Section 5.1 requires that surveillance test procedures be established and followed for

. tasks in which operations must be performed in a specified sequence. It further states that if documentation of an action is required, the procedure should be present and followed step by step, and necessary data should be recorded as the task is performed.

Contrary to the above, on the dates indicated below, the following surveillance test procedures were performed and steps implementing verification and independent verification of system response and system restoration were not completed:

1. PNPS Procedure 8.M.2-1.5.8.4, Logic System Functional Test of System "B" Standby Gas Treatment Inttiation, Reactor Building Isolation and Outboard Drywell Isolation Valves on June 26, 1986.

2. PNPS Procedure 8.M.2-1.4.1, Revision 12, v ain Steam High Temperature Sensors Functional Test, on April 5, 1986, and May 7, 1986.

Boston Edison Response to Violation B Procedure 8.M.2-1.5.8.4 Boston Edison concurs with the inspector's findings regarding the subject surveillance test. Our review of this event indicates the subject surveillance test was stopped on 6/26/86 when secondary containment damper A0N/90 malfunctioned. After the test was stopped restoration of the system to normal was not documented by the person performing the test.

The operator's reason for not documenting restoration was that the system was not required to be operable due to plant condition and that a new test would be run after damper A0N/90 was repaired.

After the test was stopped independent verification of restoration was not performed. The above mentioned operator's logic again applied. Prior to stopping the test previous procedure steps had not been fully documented (e.g. Attachment A, page 2, was not fully completed).

In addition, the Inspector noted that the operating supervisor and watch engineer review of the test results were not completed with abnormal test results properly documented. Instead the watch engineer documented the discrepancies by initiating Failure and Malfunction Report (F&MR) 86-151-dated 6/26/86. Although the discrepancies were not documented in accordance with the procedure, initiation of the F&MR allowed for prompt resolution of the noted discrepancy.

In response to the Inspector's findings regarding conduct of the subject surveillance test the Chief Operating Engineer issued a memorandum to Operations personnel entitled, Conduct of. Surveillance Testing. The memorandum (CR 86-162 dated 7/28/86) references the above mentioned inspector's findings and conveys to the reader that in cases where surveillances require independent verification the Nuclear Watch Engineer / Nuclear Operations Supervisor (NHE/NOS) will ensure that the specified items are independantly verified and signed where required, even I

in cases where the surveillance is not completed and the system is returned to normal lineup.

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To ensure that stopped surveillances are properly filled out the memorandum also states that, "To alleviate any problems that may arise during the

- conduct of surveillances the NHE/NOS will ensure himself that the operator doing the surveillance has the completed surveillance, not just data sheets, and is familiar with the surveillance and required documentation."

The subject surveillance was successfully completed on 7/21/86 which is the date of full compliance.

Procedure 8.M.2-1.4.1 Boston Edison concurs with the inspector's findings that second verification of system restoration had not been performed by Instrumentation and Controi (I&C) personnel during conduct of the subject surveillance test on April 5, 1986 May 7, 1986 and again on July 10, 1986.

Our review of this event indicated that the controlled copy of the subject test in the I&C files, in the Control Room and in the files used by the Document Control Center as well as the working copy used by the I&C Technicians in the field, were poor reproductions of the original procedure in that the signature lines on the right-hand side of the page were not distinctly broken into two separate lines. This resulted in little, if any, distinction between steps requiring a check mark as indicated by a single line and steps requiring independent verification as indicated by two distinctly separate lines. The reproductica problem occurred only on Attachment A of the subject procedure (the functional test) and not on Attachn. ant B (the calibration test).

The Chief Maintenance Engineer, to whom the I&C personnel report, was notified of the condition on the afternoon of July 10, 1986. He informed the Document Control Supervisor in charge of reproductions within one working day of the situation. An improved reproduction of Attachment A of the procedure was subsequently issued to each of the controlled procedure sets. The surveillance was performed utilizing the improved Attachment A on August 4, 1986 with the second verifications performed as required and without any discrepancies.

A review of other I&C procedures identified one other surveillance test with a similar legibility problem. That procedure was corrected and reissued.

Several completed procedure results for that procedure were checked for compilance with second verification and no inadequacies were identified. Full compliance was achieved on August 4, 1986 when the surveillance was performed and second verifications of restoration were appropriately completed.

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.' ATTACHMENT 2 RESPONSE TO NOTICE OF DEVIATION Boston Edison Company Docket No. 50-293 Pilgrhn l'uclear Power Station License No. DPR-35 ptire of Deviation as Described in NRC Inspection Report No. 86-25, Appendtx B The licensee committed in a letter to the NRC, dated March 1, 1977, to conduct fire brigade training in accordance with item B.6.e.2 of NRC Branch Technical Position APCSB 9.5-1, Revision 1. Item B.6.e.2 states that training can only be accomplished by conducting drills several times a year (at least quarterly) so that all members of the fire brigade have had the chance to train as a team, testing itself in the major areas of the plant.

Contrary to the above, as of August 4, 1986 all members of the fire brigade team had not participated in brigade drills. During calendar year 1985 thirty of sixty-nine team members did not participate in any drill. Fourtea. team members had not participated in a drill during the nineteen month period preceding July 31, 1986.

Boston Edison Response to Deviation He are in full agreement with the concern that there be an adequate program of training and drills for fire brigade personnel and we agree that such a program should include additional controls respecting drill attendance for individual fire brigade members. Presently five fire brigade drills per quarter are conducted. This was believed sufficient to meet, what we understood, the requirement of performing quarterly drills for each shift fire brigade. Based on our review of appilcable NRC regulations, Station Technical Specifications and prior Boston Edison commitmer.ts, including those referenced in this Notice of Dev1aiton, we were previously unaware that Boston Edison was subject to specific numerical requirements regarding the number or frequency of drills for each individual fire brigade member.

It is now our understanding that in addition to performing at least 5 drills per quarter, each brigade member should receive at least 2 drills per year.

In response Boston Edison commits to conducting 2 drills per brigade member in 1986. At the end of 1986 any brigade member who has not been drilled at least twice will not be allowed to return to active fire brigade status until each member has participated in two drills. Enclosure 1 is a~ summary level schedule of the supplemental fire brigade drill effort.

Currently we have secured a contract fire brigade instructor to assist with conducting the additional drills. A second instructor is being sought to assist with that effort.

• As committed to in our response to NRC Inspection Report 50-293/86-21, beginning in 1987 the drill schedule will provide a minimum of 2 drills per year per individual fire brigade member. Applicable procedures will be revised accordingly by December 31, 1986 to reflect the revised drill schedule.

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