ML20215C352

Suppls Response to Violations Noted in Insp Repts 50-293/86-14 & 50-293/86-21,per 861106 Request.Corrective Actions:Dept Managers Required to Submit Weekly Repts Re QA Issues & Escalation Requirement Revised

ML20215C352
Person / Time
Site:	Pilgrim
Issue date:	12/05/1986
From:	Lydon J BOSTON EDISON CO.
To:	Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
86-185, NUDOCS 8612150110
Download: ML20215C352 (15)

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Executive Offices 800 Boylston Street Boston, Massachusetts 02199 James M. Lydon Chief Operating Officer December 5,1986 BECo Ltr. #86-185 Mr. William 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:

Supplemental Response to NRC Inspection Reports No. 50-293/86-14 and 50-293/86-21

Dear Mr. Kane:

The attached provides Boston Edison Company's response on the subject as required by your letter dated November 6,1986. Attachment 1 provides supplemental information with regard to Inspection 50-293/86-14. Attachment 2 provides additional information with regard to Inspection 50-293/86-21.

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

Very truly yours, daMO D mes M. Lydon PJH/la Attachments: 1. Response to Concerns Regarding Initial Boston Edison Response to Inspection Report 50-293/86-14

2. Response to Concerns Regarding Initial Boston Edison Response to Inspection Report 50-293/86-21 8612150110 861205 PDR ADOCK 05000293 G PDR t\

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ATTACHMENT 1 RESPONSE TO CONCERNS REGARDING INITIAL BOSTON EDISON RESPONSE TO INSPECTION REPORT 50-293/86-14 Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35

1. NRC Concern Reaarding Senior Management Response to Quality Assurance Issues Actions taken to promote effective communication and prompt action on QA findings at the station level are adequately addressed in your response to 1

inspection report 86-14. However, the cover letter of inspection report 86-14 expressed concern about the apparent lack of senior corporate management initiative in resolving Quality Assurance (QA) identified issues.

Specifically, reports of delinquent QA responses had been routinely provided at the Vice-President level prior to our inspection, but little senior management action was evident.

Measures to ensure that senior managers are active in resolving quality assurance issues were not clearly described in your response. Please provide an explanation of steps taken to resolve this concern.

Boston Edison Response It is the intent of our Quality Assurance (QA) Program to hold individual Department Managers responsible for resolving QA identified deficiencies within a 90 day period. If a deficiency can not be resolved to the satisfaction of the QA Manager within 90 days, then the program requires that the issue be brought to the Vice President (VP) level for action. The QA program requirements for VP level involvement can be summarized as follows:

1) The VP level must become involved at the time a corrective action plan is submitted to QA if:

a) the schedule provided by the responsible Department Manager will exceed the requirement for resolution within 90 days or b) the action plan content provided by the responsible Department Manager is not acceptable to QA.

2) The VP level must become involved after a Department has implemented its correction action plan if:

a) Department implementation is not completed within the approved schedule or b) QA can not verify satisfactory implementation by the Department of the approved corrective action plan content.

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Attachment 1 (cent)

RESPONSE TO CONCFRNS REGARDING INITIAL BOSTON EDISON RESPONSE TO INSPECTION REPORT 50-293/Lb-14 The intent of these requirements is tc provide an appropriate process that delegates responsibility for resolving QA concerns to the Department Manager level with prompt intervention by the Vice President level if differences arise between two Departments or if a Department Manager fails to implement his responsibilities in accordance with the approved corrective action plan.

Reports on DR status have been previously provided to senior management by QA which show the approved schedules for all open DR's as well as the actual schedules on which DR's are resolved. QA also regularly reports on overdue DR's.

Additional reports are now required to be submitted weekly by each Department Manager to the VP level reporting on the implementation status of corrective actions for all open DR's assigned to the Department. This will provide for more effective oversight by senior management of the effectiveness of each Department's implementation activities.

In order to further emphasize the importance which senior management intends be given to achieving timely and effective resolution of QA identified deficiencies, the Vice President level has also initiated a practice of holding and documenting formal corrective interviews with any Department Manager who fails to implement his responsibilities for DR resolution in accordance with the approved corrective action plan. Further actions will then be taken as appropriate by Senior Management to achieve the intended result.

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Attachment 1 (c@nt)

RESPONSE TO CONCERNS REGARDING INITIAL BOSTON EDIS0N RESPONSE-T0 INSPECTION REPORT 50-293/86-14

2. NRC Concern Regardina Response to Notice of Violation. Item A (1). (2).'(3)

- A (1) NOV item: The Boston Edison Quality Assurance Manual (BEQAM) required that Deficiency Reports (DR) be either dispositioned within 90 days or have a DR extension authorized by the appropriate Vice President. However, no Vice President extension was requested either before or-after DR 1466 exceeded its 90-day completion date.

Boston Edison-Initial Response: The Quality Assurance Manual will be revised to require that the Quality Assurance Department (QAD) notify the appropriate department manager and Vice President when the 90 day time limit has been exceeded for each DR. The department manager is 4 advised that unless QAD receives an extension in 15 days, the DR will be escalated to the VP for resolution. Boston Edison also stated.

that the VP of Nuclear Operations now requires that weekly status reports be submitted for all open DR's and that this provides an

, increased level of executive overview.

t NRC Concern: Actions planned in the event of overdue DR's appear less restrictive than previous requirements, i.e., an additional 15 day period is allowed prior to escalation to the VP level. Also, DR status reports were previously provided to senior management. Why is the previous 90-day resolution requirement being relaxed and how will i senior management become more actively involved?

Boston Edison Supplemental Response to NRC Item A (1)

It was not our intent to be less restrictive than previous requirements. The prior escalation requirement (BEQAM para.18.4.5, previously 18.4.6) was that:

...The Quality Assurance Manager mav. if he deems it appropriate, implement the requirements of Paragraph 2.5.6 of this manual."

In light of the NRC In.pector's concern expressed at the exit meeting and in Inspection Report 86-14, it was deemed appropriate to replace this permissive statement with reauired escalation.

Although escalation af ter the due dates required by BEQAM paras.18.4.2, .3, and .4 appears to provide conflicting requirements, our intent was to allow the responsible department manager to meet his responsibility within the established time limit before escalation to the vice president level. We then i intended that 15 days be provided for active involvement at the vice president level to resolve QAD concerns.

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Attachment 1 (c@nt)

RESPONSE TO CONCERNS REGARDING INITIAL BOSTON EDISON RESPONSE TO INSPECTION REPORT 50-293/86-14 Boston Edison Supplemental Response to NRC Item A (1) (cont)

In addition, paragraph 18.4.5 implicitly requires that the appropriate vice president actively pursue resolution of any concerns and completion of corrective action with the responsible department manager and QAD within the 15 days (7 days for significant DR's).

We believe we have fulfilled the responsibilities described above since the time the current BEQAM revisions were made. To make our intent clear, we will further revise Section 18 to make the above responsibilities and intent more explicit.

The proposed revision to BEQAM, Section 18, are expected to be in place in January 1987.

A (2) NOV item: The BEQAM requires that a DR identifying conditions reportable to the NRC be classified as significant. However, the reportable surveillance test problem identified by DR 1466 was not classified as significant.

Boston Edison Initial Response: The BEQAM will be revised to state that all Technical Specifications or FSAR deviations and all potentially reportable 10 CFR Part 21,10 CFR 50.72 and 10 CFR 50.73 ,

items found during an audit or surveillance will be issued as a significant Deficiency Report.

NRC Concern: The BEQAM previously required that the above items, with the exception of FSAR deviations, be classified as significant.

What action has been taken to ensure significant findings are properly identified?

Boston Edison Supplemental Response to NRC Item A (2)

The previous BEQAM requirements (Rev.17) were as follows:

Pa ra . 16. 2. 6 :

The term "significant" applies to a condition adverse to quality whira merits further evaluation for cause(s) and requires management attention / action to preclude recurrence.

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Attachment 1 (cent)

RESPONSE TO CONCERNS REGARDING INITIAL BOSTON EDISON RESPONSE TO INSPECTION REPORT 50-293/86-14 Boston Edison Supplemental Response to NRC Item A (2) (cont)

Conditions adverse to quality which are significant include the following:

Conditions which indicate lack of, or reduction of, management's ability to control activities affecting quality.

Recurring conditions Pa ra . 16. 2. 9 :

Other conditions adverse to quality that warrant management attention and actions to preclude recurrence are those determined to be reportable to the NRC via 10CFR Part 21 and 10CFR50.72 and 50.73. Reportable conditions are significant conditions. However, because reportable conditions are resolved using a process that includes a root cause analysis and identification of preventative actions, it is not necessary to include reportable conditions in the process to resolve other significant conditions.

Paragraph 16.2.9 allowed DR 1466 to be classified as not sianificant and has been deleted from the BEQAM. Under revised paragraph 16.2.6, a potentially reportable DR, such as 1466 is required to be classified as significant.

Therefore, we believe the changes since made to the BEQAM, and identified in our initial response on this issue, clearly resolve these problems by expanding the formal definition of "significant" and removing our reliance on processes other than the DR.

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Attachment 1 (cont)

RESPONSE TO CONCERNS REGARDING INITIAL BOSTON EDISON RESPONSE TO INSPECTION REPORT 50-293/86-14 A (3) NOV item: The BEQAM required that a written request for a second i response for a disputed DR be forwarded to and approved by the appropriate Vice President. However, the QA request for a second response to DR 1466 was not forwarded to the appropriate Vice y President after the initial DR finding was disputed.

Boston Edison initial response: The BEQAM and N0P83A13 will'be revised to require all requests for second responses be forwarded to

, the appropriate Vice President.

NRC concern: Since this requirement previously existed it is again unclear what action has been taken.

Boston Edison Supplemental ResDonse to NRC Item A (3)

The previous requirement (118.4.6, Rev.15) was stated as follows:

"Should Quality Assurance not concur with actual / proposed corrective action, and be unable to obtain satisfactory resolution directiv with the responsible manaaer, a formal request for a second response shall

, be forwarded to the appropriate Vice President...."

The QAD interpreted this requirement to allow them to attempt to obtain satisfactory resolution without intervention by the Vice President.

Again, our intent was to allow the department manager to meet his responsibility before escalation. The current requirements (Rev. 18) clearly do not allow such interpretation by QAD; if actual / proposed corrective action is not acceptable, the matter must be immediately referred to the appropriate VP including requests for a second response (paras, 18.4.3 and 18.4.5).

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ATTACHMENT 2 RESPONSE TO CONCERNS REGARDING INITIAL BOSTON EDISON RESPONSE TO INSPECTION REPORT 50-293/86-21 Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. OPR-35 NRC Concern A. Your response stated that if no clear cause for the recurring failure of the recirculation motor generator set field breaker failures can be established, more frequent surveillance testing will be implemented. It is our position that an increase in surveillance frequency cannot compensate for unreliable equipment. If a definite failure cause is not identified, the ability of this equipment to function will remain in question. We expect your final response to Region 1 on the AKF breaker issue to address this concern. We understand that the AKF response will be submitted at least 45 days before startup.

Boston Edison Response The failure mode analysis that is in progress on the AKF Breaker consists of two major and independent phases.

1.) A root cause analysis is being performed to assess the failure mechanism. This study will include not only plant specific details, but also the industry's experience with the AKF-2-25 field breakers.

2.) The Original Equipment Manufacturer (General Electric) is physically evaluating the failed breaker.

The results of these investigations will be utilized to develop a corrective action plan to improve the reliability of this component. This program will address the following areas:

- Instruction Manuals and Procedures

- Personnel Training

- Preventive Maintenance Program

- Testing The previous reference to increased surveillance testing was not to be considered the solution to this problem, but rather the proof of the adequacy of the corrective actions that were accomplished as a result of the root cause analysis. As previously stated our final response on this issue will be submitted at least 45 days before startup.

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Attachment 2 (cont)

RESPONSE TO CONCERNS REGARDING INITIAL BOSTON EDIS0N RESPONSE TO INSPECTION REPORT 50-293/86-21 NRC Concern

. B. Regarding the apparent failure to properly schedule surveillance tests, Boston Edison committed to perform an analysis and submit an updated response to Region 1 by November 21, 1986. This issue was identified approximately six months prior to your analysis completion date.

Considering that surveillance tests could be required for current plant modes, please explain the cause for the delay in your analysis.

Boston Edison Response This response includes the information we had planned to submit on November 21, 1986 as well information explaining the cause for delay in our analysis.

Extension of the November 21, 1986 submittal date for response to this question and a second question regarding logic system functional testing was discussed with our Resident Inspector at approximately 1730 hours0.02 days <br />0.481 hours <br />0.00286 weeks <br />6.58265e-4 months <br /> on 11/21/86 by Boston Edison staff personnel. As requested by the Resident, the delayed submittal was also discussed with you by Boston Edison staff personnel directly following our meeting in Chiltonville on 11/24/86.

On 11/25/86 a meeting was held between the Station Manager, Boston Edison staff personnel and our Senior Resident and Resident Inspectors to discuss the delayed submittal. At that meeting it was conveyed to the Residents that our response had been prepared for submittal on 11/21/86 but that in order to be complete and thorough the letter required more effort. Rather than sacrifice quality for timeliness a decision was made to hold back the letter. A major factor contributing to our delay was the late receipt of a consultants report on the issue. The report was originally scheduled to be received on 10/24/86 but the draft report was actually received on 11/20/86. The new date for submittal was proposed to be 12/6/86 and subsequently confirmed as acceptable by the Residents af ter their discussion with Region 1 management.

The original NRC concern is detailed in Section 7.0 of Inspection Report 86-21 and identifies three specific instances where surveillance tests may have been improperly scheduled. The first event was identified on June 13, 1986 and involved local leak rate tests. The second instance involved a manual initiation test of the standby liquid control system and the third event was identified on June 21, 1986 and involved the calibration of undervoltage relays. Our analysis of these events revealed that one of the contributing causes of these three issues is that two different definitions of operating cycle are contained in the Pilgrim Technical Specifications.

Background information and associated corrective action for these 3 specific events includes the following:

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Attachment 2 (cont)

RESPONSE TO CONCERNS REGARDING INITIAL BOSTON EDISON RESPONSE TO INSPECTION REPORT 50-293/86-21

1. Local Leak Rate Testina -

On 6/13/86, with the plant in the cold shutdown condition, an independent Boston Edison management review of individual local leak rate test (LLRT) completion dates was conducted. The review showed that greater than two years had elapsed since 69 of 101 Type B tests and 39 of 133 Type C tests had been successfully performed. This condition was initially interpreted as exceeding the two year maximum interval between LLRTs as specified in 10CFR50 Appendix J.

The following 3 contributing causes have been identified thus far:

i two definitions of operating cycle in the PNPS Technical Specifications and listed below caused confusion in determining the test due date (e.g. application of one definition resulted in the LLRT Program being overdue while application of the other definition resulted in the LLRT Program being on schedule).

definition 0 - interval between the end of one refueling cycle

and the end of the subsequent refueling cycle definition U - the operating cycle is considered to be 18 months

, an extended operating cycle which put BECo out of compliance with the most conservative definition of operating cycle (definition U).

a question as to whether the two year interval for LLRT's as set i

forth in 10CFR50 Appendix J applied to local leak rate testing of individual components every two years or whether the two year rule applied to the interval between the final completion date of all LLRT

tests during one refueling outage and the start of the next LLRT program during the next refueling outage.

In response Boston Edison has taken the following action:

4 conducted meetings on 6/13/86 and 6/20/86 with appropriate plant personnel to review the MSTP and determine if any other scheduling problems were evident.

submitted a licensee event report on this issue (ref. LER 86-015-01).

4 completed the required LLRTs with the exception of approximately 9 j

components which cannot be tested due to operational constraints.

Those tests will be completed before unit restart.

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Attachment 2 (cont)

RESPONSE TO CONCERNS REGARDING INITIAL BOSTON EDISON RESPONSE TO INSPECTION REPORT 50-293/86-21 submitted a letter to the NRC General Counsel requesting clarification of the two year interval set forth in 10CFR50 Appendix J. (ref. BECo letter #86-153 dated 9/30/86) committed to perform local leak rate testing on a component to component basis utilizing the definition of operating cycle as "the interval between the end of one refueling cycle and the end of the next refueling cycle". In addition, a 2 year noximum interval will be established for each LLRT component to component test. The 2 year limit will ensure that the most conservative interpretation of the 2 year rule will be satisfied. This approach to testing will be maintained until clarification of the 2 year testing interval is obtained.

committed to revising the Master Surveillance Tracking Program (MSTP) to include the individual components required by the LLRT to ensure that the 2 year maximum interval of component to component testing is properly controlled. The MSTP. revision is expected to be complete prior to restart from the existing outage.

committed to submit a Technical Specification change to clarify the definition of once per operating cycle within 90 days af ter unit restart.

continue to monitor proposed NRC rule making on 10CFR50 Appendix J (ref Federal Register dated 10/29/86).

2. Manual Initiation Test of the Standby Liouid Control System Also on 6/13/86, while reviewing the Master Surveillance Tracking Program (MSTP) test schedule, a potential overdue test of the Standby Liquid Control System was identified. At that time an NRC notification was initiated via the ENS line as a conservative measure.

One of the contributing causes of the potentially overdue test was the two definitions of operating cycle contained in the Technical Specifications.

Application of the definition of operating cycle being "every eighteen months" resulted in the test appearing overdue while application of the second definition, " Interval between the end of one refueling cycle and the end of the subsequent refueling cycle", resulted in the test being on schedule and not overdue. A subsequent review of the Technical Specification bases by plant personnel indicated that the test was in fact not overdue.

In response to this issue Boston Edison commits to submitting a Technical Specification change to clarify the definition of operating cycle within 90 days after restart from the existing outage.

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Attachment 2 (cont)

RESPONSE TO CONCERNS REGARDING INITIAL BOSTON EDISON RESPONSE TO INSPECTION REPORT 50-293/86-21

3. Calibration of Undervoltage Relays On June 21, 1986, during follow-up corrective action prompted by the June 13 events, it was determined that the emergency 4.16KV bus A5 and bus A6 degraded voltage annunciation relays, and the startup transformer degraded voltage and under voltage relays had not been calibrated within the required frequency of once per operating cycle. The follow-up corrective action and analysis included a review, by responsible group, of tests on the MSTP having a once/ cycle surveillance interval. No additional problems were identified as a result of that review which was completed on 6/21/86.

Initial corrective action in response to the overdue tests identified was to log the voltage on bus A5 and bus A6 every one half hour until the required calibrations were completed. To prevent exceeding the calibration surveillance frequency in the future, calibrations of electrical components required by the Technical Specifications will be scheduled as due on specific dates (e.g. within the eighteen month +25%

time frame) rather than being scheduled with a due date of " Refueling Outage."

l' Again, the major contributing cause of this scheduling problem is that there are two definitions for operating cycle in the Technical Specifications. In this case the 18 month +25% interval applied. As previously discussed the submittal of a Technical Specification change to

! clarify the definition of operating cycle will address the root cause of i this particular problem. Additional detail of this event is contained in

LER 86-016-01.

In addition to the corrective action addressing the 3 specific issues in

, Inspection Report 86-21, Boston Edison also has taken the following action with regard to the MSTP:

Conducted a detailed root cause analysis of this and other previous surveillance scheduling issues to obtain a fresh look at the surveillance scheduling problem and the recommendations for resolution. The results of that analysis confirmed the root causes

! of these 3 events and also provided recommendations on resolution of i

the surveillance scheduling inadequacies. Some of those 4

recommendations have been implemented including pursuit of an interpretation on the 10CFR 50 Appendix J two year interval and a commitment to perform component to component testing in the LLRT program. Other recommendations will be implemented including

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submittal of a Technical Specificatien change to clarify the definition of operating cycle. Additional corrective actions are being evaluated as discussed in the next section of our response.

Continue to periodically conduct Quality Assurance audits of the Technical Specifications to ensure implementing procedures are in place and adequate.

Additional Corrective Action Regarding Surveillance Schedulina y As committed in our original response to Inspection Report 86-21 Bostoi Edison commissioned an outside consultant to perform an in-depth root cause analysis of this issue. A comprehensive study of this type was considered necessary in ordr,r to gain a clear perspective of the extent and magnitude of this issue with'a goal to derive a complete and lasting set of corrective actions aimed at the "real" causes of the problem rather than the symptoms. The results of this analysis identified several root causes which are currently under review such that the above described approach can be utilized with the most optimized and effective utilization of resources.

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Attachment 2 (cont)

RESPONSE TO CONCERNS REGARDING INITIAL BOSTON EDISON RESPONSE TO INSPECTION REPORT 50-293/86-21 NRC Concern C. Inspection report 86-21 identified several concerns regarding the technical adequacy of surveillance testing. Boston Edison was requested to respond to a specific concern about the completeness of emergency core cooling system (ECCS) logic system functional tests. However, your response does not address the completeness and adequacy of the logic system functional tests. Instead, it discusses other surveillance concerns in our inspection report. Please describe your plans and positions on this specific issue.

Boston Edison ResDonse We have reviewed the items listed on page 14 of Inspection Report 86-21 regarding the HPCI system and we share your concerns on the completeness and technical adequacy of the logic system functional test procedures. We agree that our procedures do not fully test the features described in A,C,0 of the report. Accordingly we will revise our logic system functional test procedures prior to declaring the HPCI system operable. In addition our corrective action will include a review of other ECCS logic system functional test procedures for similar areas of concern prior to plant mode change requiring these systems to be operable. The plant is presently in the cold shutdown condition and there is no activity in progress with the potential to drain the reactor vessel. Therefore, the ECCS systems are not required to be operable.

With regard to item B in the inspection report we believe that PNPS procedures (8.M.2-2.5.1, 8.M.2-2.10.5 and 8.M.2-2.5.3) fully implement the requirements of the logic system functional test as defined in the Technical Specifications.

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Attachment 2 (cent)

RESPONSE TO CONCERNS REGARDING INITIAL BOSTON EDISON RESPONSE TO INSPECTION REPORT 50-293/86-21 NRC Concern D. Your response to our concern regarding fire brigade training stated that 35 brigade members have not participated in a drill in 1986. However, current plans would allow individuals to remain active members of the brigade without meeting minimum drill requirements until the end of 1986.

It is our position that you are committed to meet minimum drill requirements for all active brigade members and that only individuals who currently meet the minimum drill requirements are eligible for brigade duty. Please describe your plans to meet these criteria.

Boston Edison Response As stated in our response to the Notice of Deviation set forth in NRC Inspection Report 86-25 (ref. BECo letter #86-169, dated October 30, 1986) we 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. In the past, five fire brigade drills per quarter were 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 applicable NRC regulations, Station Technical Specifications and prior Boston Edison commitments, including those referenced in the Notice of Deviation, 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.

Currently, forty-nine (49) fire brigade members have received at least 2 drills in 1986. Nineteen (19) fire brigade members have had one drill to date, and are scheduled to receive an additional drill before the end of 1986. Fire brigade members who have not received any drills have been disqualified from active fire brigade status and will not be allowed to return to active fire brigade status until they have participated in two drills.

As committed to in our response to the previously mentioned Notice of Deviation, 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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