ML20214X228
| ML20214X228 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/08/1987 |
| From: | Bird R BOSTON EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 87-98, NUDOCS 8706160386 | |
| Download: ML20214X228 (5) | |
Text
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8057tWEDiSON Executive Offices 800 Boylston Street Boston, Massachusetts 02199 Ralph G. Bird June 8, 1987 Senior Vice President - Nuclear BECo Ltr. #87-98 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docket No.' 50-293 License No. DPR-35
Subject:
NRC Inspection Report 50-293/87-04
Reference:
Boston Edison Company Letter Number 87-56
Dear Sir:
Attached is Boston Edison Company's response to Notice of Violation B contained in the subject inspection report.
On May 1, 1987, Boston Edison Company management representatives met with NRC management to obtain clarification of the Notice of Violation. As a result of meeting discussions, our conclusion is that the Notice of Violation was issued because we did not effectively communicate our programs for test control to the inspector. The need for effectiveness of communication and diligence in resolving inspector concerns in a timely manner has been re-emphasi:'ed to the appropriate members of our staff.
He continue to believe that our test program elements meet the applicable ANSI and BEQAM requirements and based upon the information presented in the
. attachment to this letter, request that Notice of Violation B be withdrawn.
Please do not hesitate to contact me directly if you have any questions.
8706160386 870608 h
PDR ADOCK 05000293
.G. Bird G
PDR EM/la Attachment cc: Regional Administrator, Region 1 Director, Office of Inspection U.S. Nuclear Regulatory Commission and Enforcement 631 Park Avenue U.S. Nuclear Regulatory Commission King of Prussia, PA 19406 Washington, DC 20555 Igol Senior Resident Inspector e
t ATTACHMENT l-Notice of Violation B
. 10CFR50, 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 test 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.... surveillance tests and tests which demonstrate satisfactory performance following plant maintenance and modifications.
In addition, the BECo 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, approved 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 N00 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 performance 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 satisfied.
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)
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Response
Boston Edison's program for the implementation of the " test program" as described in ANSI N18.7-1976/ANS3.2 consists of administrative procedures, implementing procedures,.and personnel selection and training processes.
The various elements of the ANSI _N18.7 1976/ANS3.2 " test program" and the BECo QAM, section 11. " Test Control" have been incorporated in the procedures.
-associated with the work activity rather than a separate test control procedure.
For example, post maintenance test specification, performance and approval are. contained in Nuclear Operations Department Procedure 1.5.3
" Maintenance Requests" while the format and content of procedures is specified in Nuclear Operations Department Procedure 1.3.4 " Procedures".
Boston Edison has reviewed the concerns of the above Notice of Violation and the requirements of ANSI N18.7-1976/ANS3.2 section 5.2.19 " Test Control" and BECo QAM section 11, " Test Control" as implemented by currently existing procedures and policies.
Boston Edison believes the test program, as it currently exists, is in compliance with the aforementioned ANSI and BECo QAM requirements.
A point by point comparison of the specific concerns expressed in the Notice of Violation with the methods currently in use to satisfy the concerns is presented below.
-- Overall mechanisms for control of specific test programs such as periodic surveillance tests, post maintenance tests, and post modification tests.
Nuclear Operations Department Procedure 1.8 " Master Surveillance Tracking Program" controls the performance of periodic surveillance tests.
The associated computer program provides the mechanism for scheduling performance of periodic surveillance tests.
Nuclear Operations Department Procedure 1.5.3 " Maintenance Requests" controls the performance of post maintenance testing.
Provisions for designation of both maintenance related and Technical Specification operability related tests are contained in this procedure.
Nuclear Operations Procedure 83El " Control of Modifications to Pilgrim Station", Nuclear Operations Procedure 83A6 " Modification Management", and Nuclear Engineering Department Procedure 3.02 " Preparation, Review, Verification, Approval and Revision of Design Documents for Plant Design Changes" control. post modification tests.
Definition of personnel qualified to perform the subject tests.
Personnel qualified to perform surveillance and post maintenance tests are determined through the detailed evaluation of previous job experience and specific job training which is performed by the Nuclear Training Department.
This information is posted in the maintenance shop areas for use by the supervisors in charge of the work activity to assist in the assignment of individuals to the particular maintenance task.
Technical
~ Specification surveillance and operability testing is also performed by Nuclear Plant Operators and Reactor Operators who, by virtue of the training associated with their job descriptions, are qualified to perform these tests.
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ATTACHMENT 1 (Cont.)
Personnel qualified to perform post modification tests are specified as Test Directors. Test Directors are individuals whose qualifications meet or exceed applicable ANSI requirements.
-- Methods by which prerequisites and environmental conditions are to be determined.
Surveillance and post maintenance test procedures are written per the requirements of Nuclear Operations Department Procedure 1.3.4
" Procedures".
Test procedures contain a section specifying prerequisites and environmental conditions, if applicable, which must be satisfied prior to initiation of the test.
Preoperational test procedures are written per the requirements of the Modification Management Work Instruction Manual, section 10.0
" Modifications Management Preoperational Test Procedure Development".
Test procedures contain a section specifying prerequisites and environmental conditions, if applicable, which must be satisfied prior to initiation of the test.
Specification of personnel who are designated to approve and evaluate test results and assure that test requirements are satisfied.
The individual survelliance test procedures specify the persons responsible for the evaluation and approval of test results.
For example, the Watch Engineer evaluates and approves Technical Specification surveillance test results.
The designation of personnel who evaluate and approve post maintenance test results is contained in Nuclear Operations Department Procedure 1.5.3
" Maintenance Requests" and in the individual test procedures.
For example, the Watch Engineer evaluates and approves Technical Specification operability test results.
The designation of personnel who evaluate and approve post modification test results is contained in Nuclear Operations Procedure 83A6
" Modification Management" and in the individual preoperational test procedures written in accordance with the Modification Management Work Instruction Manual, section 10.0 " Modification Management Preoperational Test Procedure Development".
-- Definitions of the kinds of instruments to be included in the instrument and control surveillance program.
As clarified in our meeting, the inspector's concern was calibration of non-safety related, installed instrumentation, used to measure system parameters during the performance of system tests.
The calibration of installed plant instrumentation required to support the performance of tests is either performed as a step in the individual test procedure or periodically as controlled by the Master Surveillance Tracking Program.
-- Methods by which acceptance criteria are properly specified.
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1 ATTACHMENT 1 (Cont.)
Surveillance and post maintenance test procedures are written and approved per the requirements of. Nuclear. Operations Department Procedure 1.3.4, a
'" Procedures". Test procedures contain a section.specifying test acceptance criteria.
Reference documents used in the generation of the
. test procedure (i.e. Technical Specifications, Final Safety Analysis Report,; Vendor Manuals, design documents, etc.) supply information on specific acceptance criteria.
' Post modification test procedures are written per the requirements of the Modification Management Work Instruction Manual, section 10.0
" Modification Management Preoperational Test Procedure Development".
Test procedures contain a section specifying test acceptance criteria..The specific acceptance criteria for inclusion in the test procedure are developed during the portion of the design process controlled by Nuclear Engineering Department Procedure 3.02 " Preparation, Review, Verification, Approval and Revision of Design Documents for Plant Design Changes".
Format for post maintenance and post modification test procedures.
Post maintenance test procedures are written per the requirements of Nuclear Operations Department Procedure 1.3.4 " Procedures" which specifies test procedure format.
Post modification test procedures are written per the requirements of the Modification Management Work Instruction Manual, section 10.0
" Modifications Management Preoperational Test Procedure Development" which specifies test procedure format.
Boston Edison is currently performing an extensive programmatic upgrade for the control of surveillance testing. This upgrade, scheduled for implementation and validation in June, 1987, will greatly increase the
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effectiveness of the current surveillance test program. The Master Sur.veillance Tracking Program (MSTP) is being refined to; 1) provide a complete cross reference between surveillance requirement and implementing surveillance test procedures, 2) provide for the scheduling of surveillance tests which correspond to the operating condition of the plant, 3) provide the ability to schedule surveillance tests based upon plant system availability,
- 4) track-the completion of' surveillance tests in which portions of the test are completed at different points.In time, and 5) provide for the designation of acceptance criteria. Most importantly, experienced technical personnel have been assigned to the administration and maintenance of the MSTP.
This
-will ensure the continuance of a high quality surveillance program under the cognizance of a single manager.
Boston Edison-will examine the elements of the post maintenance test program to determine which areas are in need of improvement.
The program for post modification testing, as it currently exists, is effective and adequate.
To ensure that the appropriate management personnel are aware of the implementing procedures for the various aspects of the test program, our "Index of Procedures Per Criteria of ANSI N18.7-1976" is being updated and will be distributed.
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