IR 05000293/1986024

Insp Rept 50-293/86-24 on 860804-08.No Violations Noted. Major Areas Inspected:Actions to Address Generic Ltr 83-28 Re Equipment Classification,Vendor interface,post-maint Testing,Plant Surveillances & Qa/Qc Overview

ML20215E623
Person / Time
Site:	Pilgrim
Issue date:	09/18/1986
From:	Beckman D, Eapen P, Harris D, Hunter J, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20215E619	List: IR 05000293/1986024 ML20215E617
References
50-293-86-24, GL-83-28, NUDOCS 8610150409
Download: ML20215E623 (25)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-24 Docket No. 50-293 License No. DPR-35 Category Licensee: Boston Edison Company M/C Nuclear

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800 Boylston Street Boston, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station Inspection At: Plymouth and Braintree, Massachusetts  ;

Inspection Conducted: August 4-8, 1986 I'ispectors: he- v)

G. #apuda, Lead Reactor Engineer fcM

' date fiYk u h< $h '

J . @. Hunter III, Reactor Engineer ' dan dhae Art D. E Harris,Jr., NRC Consultant YA/$6

/dat4 d[parcf-u e &1 YM/ff D. A(./ Beckman, NRC Consultant /datt Approved by: - - # /7 6 Dr. P. K. Eapen, Chief, Quality Assurance ' date Section, OB, DRS Inspection Summary: Special announced inspection on August 4-8, 1986 (Report No. 50-293/86-24)

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Areas Inspected: Licersee's actions to address the conccrns identified in NRC Generic Letter 83-28 in the areas of Equipment Classification, Vendor Interface, Post Maintenance Testing, Plant Surveillances, and QA/QC Overvie Results: No violations were identifie PDR ADOCK 05000293 O PDR

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DETAILS 1.0 Persons Contacted

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-Soston Edison Company (BECO)

• H. Brannan QA Manager

• M. Brosee Maintenance Section Manager

, *J. Clifford Stores Supervisor M. Dorman Consultant

• F. Famulari 0QC Group Leader G. Fiedler Nuclear Watch Engineer

• J. Gerety Operations Engineer

• P. Hamilton Senior Compliance Engineer

• S. Hudson Operations Section Manager G. Lafond I&C Maintenance Sr. Engineer

• J. Lepore Stores Supervisor

• J. Lydon President, Chief Operating Officer, BECO

• L. MacDonald NMSD Group Leader M. Maguire Electrical Maintenance Sr. Engineer

• J. Mattia QA Audit Group Leader

• A. Morisi Assistant Director Outage Management

• J . See ry Technical Section Manager

• R. Sherry Chief Maintenance Engineer

• R. Swanson Nuclear Engineering Manger J. Vendor Mechanical Maintenance Sr. Engineer

• B. Tucker Audit Coordinator R. Williams Senior Systems & Safety Analysis Engineer

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E. Ziemanski Nuclear Operations Support Department Manager United States Nuclear Regulatory Commission

• Dr. L. Bettenhausen Chief, Operations Branch, DRS

• Dr. M. McBride, Senior Resident Inspector J. Lyash, Resident Inspector The inspectors also contacted other administrative and technical licensee personnel during the course of the inspectio *Present at the August 8, 1986 Exit Meeting

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2.0 Inspection Summary 2.1 Background The reactor trip system, as part of the reactor protection system, is fundamental to reactor safety for all nuclear power reactor design Transient and accident analyses are predicated on the assumption that the reactor trip system will automatically initiate reactivity control systems on demand to assure that fuel design limits are not exceeded, t

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The design and regulatory philosophies for attaining the high reli-ability required of the reactor trip system have primarily relied on the use of redundancy, periodic testing, and quality assuranc In February 1983 the Salem Nuclear Power Station experienced two failures of the r1 actor trip system on deman Regulatory and industry task forces were formed to determine the safety significance and generic implications of the events. Based on these findings, certain actions were required of all licensee These actions, transmitted in Generic Letter 83-28, fell into four area (1) Post-Trip review, (2) equipment classification and vendor interface, (3) post-maintenance testing, and (4) reactor trip system reliability improvement BECO submitted their response to Gereric Letter 83-28 in letters listed in Attachmer.t A. This inspection included the areas of equipment classification, vendor interface, post-maintenance testing, and QA/QC interfac .2 Inspection Results No violations were identified. One unresolved item is discussed in paragraph 5.2.c and further examples of weaknesses previously identi-fied in the Safety System Functional Inspection Report 50-293/85-30 were noted as detailed in paragraphs 4.2 and Except for the weaknesses, the licensee's actions were found to ade-quately address the concerns of the Generic Letter 83-23 and were consistent with their commitments provided in the letters listed in Attachment A. The licensee acknowledged the findings and agreed to take the necessary corrective action concerning the weaknesse .0 Equipment Classification 3.1 Program Review The inspectors reviewed the applicable documents listed in Attach-ment A and determined that the Equipment Classification Program addressed the following:

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Safety related components are identified as such in written procedures for procurement, maintenance, and modificatio Management oversight of source documentation for the designation of safety related systems and component Corporate level procedures for safety related component procure-ment, maintenance, and modificatio ,

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Periodic Quality Assurance audits of activities impacting safety related equipmen Corrective action program for safety related equipmen .2 Program Implementation The licensee uses the PNPS Q-List to identify safety related items at the " system" level. The Q-List,Section II, defines the safety related portions of each system by reference to the system drawings (P&ID, elementary diagram, etc.). Further definition is currently provided by Sections III and IV of the Q-List including a partial listing of components for each system and application guideline The BECO Systems and Safety Analysis Group acts as the station's point of contact for questions from other staff departments regarding application of the list to specific equipment classification prob-lem ~

The licensee is currently updating the Q-List to improve its utility at the component level. The revised Q-List will be on a computerized data base and is intended to include all safety related components but will not specifically include pieces / parts of those component The Systems and Safety Analysis Group expects to complete this update during September 198 The licensee has further adopted as part of the Q-List procedures a

" Commercial Quality Control Item" program for dedicating commercial grade items as safety relate A field comparison of system mechanical drawings and electrical elementary diagrams versus installed equipment was performed. From this components were selected for verification of the implementation of the licensee's Equipment Classification Program. For each com-ponent selected, the inspectors reviewed the adequacy of safety classification, procurement, receipt, storage and handling activities as discussed in the following sections of this report.

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5 Reactor Protection System (RPS)

A walk down of the Anticipated Transient Without Scram (ATWS)

panel confirmed correct equipment classification with the Q-List. Components were labeled and in agreement with plant drawings. Cables were tagged and separation of redundant cir-cuits maintained for the power and control wirin The Recirculation Pump B MG set field breaker was also inspec-ted, Standing water was noted inside the control wiring cubicl Nuts and terminal lugs were found lying on the floor of the cubicle and a wire protruded from a cable bundle exposing a bare terminal lug. Most of the field cable tags had deteriorated to the point where the tags are illegibl The inspector noted significant corrosion on the inside of the cubicle frame and on three relays mounted inside the cabine Relays noted were for Low Feedwater Flow Auxiliary, Pump A-1 and B The MG Set field breaker is used to trip the recirculation pump motors as an ATWS protection functio Failures of the MG Set A breaker and other similar breakers are further discussed in Section 5.2.a of this report. A Failure and Malfunction Report (F&MR) was written on MG Set A, and it identified I" to 2" of standing water. This F&MR was open at the time of inspection, waiting for Operations Review Committee (ORC) review. The licensee stated that corrective action was in process but provided no specifics, b. 4160 V Safety Related Switchgear Under voltage and degraded voltage relays were reviewed for proper safety classification. The relays and timers were identi-fied during a walkdown with the Electrical Maintenance Enginee All components were correctly labeled and in accordance with plant drawing C. Emergency Core Cooling Systems Mechanical Portions of the High Pressure Coolant Injection (HPCI), the Residual Heat Removal (RHR), and Control Rod Drive Hydrau-lic (CRDHS) systems were visually inspected and the follow-ing components selected for verification of safety classi-ficatio r

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MO 1001 28A & B LPCI INJECTION VALVES MO 1001 23A & B LPCI INJECTION VALVES A0 8000 & 8001 TORUS MAKEUP VALVES MO 1001 23A & B DRYWELL SPRAY VALVES M0 2301 8 & 9 HPCI INJECTION VALVES M0 2301 6 HPCI SUCTION - CONDENSATE STORAGE TANK M0 2301 35 & 36 HPCI SUCTION - TORUS M0 2301 4 HPCI TURBINE STEAM SUPPLY HPCI PUMP SO 117/118 CRDHS SCRAM SOLEN 0ID VALVES CV 126/127 CRDHS SCRAM PILOT VALVES SV 302 19A & B BACKUP SCRAM S0LEN0ID VALVES Review of the Q-List determined that the above components were correctly classified in Maintenance Requests (MRs) and proce-dures (listed in Attachment A).

During the field walkdowns, the inspectors noted that the general cleanliness level of the plant was adequate but the housekeeping efforts were deficient in some area Specifically, bags of rags were stuffed on top of conduit in the RHR "B" Quadrant, the HPCI turbine / pump pedestal was littered with rolls of tape and accumulated oil and water leakage. In the TIP room, insulation was peeling away from cable trays located overhead and was falling onto other equipment and the floo The manual handwheel for LPCI valve MO 1001 37A motor operator was found removed and lying beneath the valve. No reason for its removal could be identified by the licensee. A maintenance request was issued and the handwheel was reinstalle The inspectors reviewed MRs (listed in Attachment A) for proper safety classification, QC coverage, post maintenance test requirements, maintenance and test equipment used, spare parts used and appropriate supervisory reviews and approvals. No discrepancies were identified.

l d. Instruments and Controls Instrumentation and controls associated with the Reactor Protection, Emergency Core Cooling, and Control Rod Drive Hydraulic systems were visually inspected and the following components selected for verification of safety classificatio PS 2390A & B HPCI LOW LEVEL SUCTION TRANSMITTER FOR CST TO TORUS X0VER PI 131 CRDHS ACCUMULATOR PRESSURE INDICATOR t

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PS 131 CRDHS ACCUMULATOR PRESSURE SWITCH 23A K31 HPCI INITIATION LOGIC CIRCUITRY 23A K13 HPCI INITIATION LOGIC CIRCUITRY 23A K9 HPCI INITIATION LOGIC CIRCUITRY 10A K10A LPCI INITIATION LOGIC CIRCUITRY 10A K100A LPCI INITIATION LOGIC CIRCUITRY 13A K33 LPCI LOGIC AGASTAT TIMER 10A K81 LPCI LOGIC AGASTAT TIMER LT 263 73B ANALOG TRIP SYSTEM L0 RX LEVEL PT 263 498 ANALOG TRIP SYSTEM RX PRESSURE The field walk down verified that the above components identified were properly and clearly marked in the field and corresponded to the current revfSion of system diagram The licensee's Q-List properly designated both the systems and components reviewe Maintenance Requests (MR's) were examined for selected components of the RPS, HPCI, LPCI (RHR), and CRDHS to verify proper safety classification of repairs and spare parts used. The MRs reviewed are listed in Attachment A. In all cases, safety classification of work and spare parts used was in agreement with the licensee's Q-List and supplementary instrument indice Purchasing and Storage The licensee's purchasing and storage activities were reviewed using the components selected. The purchase documents were complete and they contained;

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Proper safety classification

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Environmental requirements

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Seismic category

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National codes criteria (e.g. IEEE, ASME)

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10 CFR 21 requirements

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Shelf life provisions

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Documentation (e.g. Certificates of Conformance, Test Reports) requirements

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Vendor technical information (e.g. manuals, storage ,

conditions) requirements

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The main warehouse was toure Cleanliness, storage environ-ment, item identification, traceability, access restrictions, and shelf life controls were adequate for reviewed Purchase Orders (P0s).

Shelf life expiration was annotated on the "QA Accept" tags attached to items inspected. Included in the control system were those components that had nonmetallic internal parts subject to aging deterioration. Safety related (i.e. Q) and non-Q items were physically segregated, smaller items were in cabinet drawers, and receiving inspection was done in a separate are Also, a Level "A" storage room had been established. It was noted that the many paddle fans that had been installed ade-quately maintained an even temperature distribution. Individual control and environmental conditions generally exceeded the QA Program storage requirement No violations were identifie .0 Vendor Interface 4.1 Program Review The licensee has identified approximately 500 vendor technical manuals in their possession. Procedures describing the review and control of these manuals have been established and implemented. A centralized library contains master copies of both validated and unvalidated manuals and the identifier / numbering system differen-tiates between the two. The plant Maintenance and Instrument and Control (I&C) groups each maintain libraries of their respective manuals.

The Maintenance Department has the prime responsibility for reviewing the manuals and supplementary information (e.g. vendor bulletins, letters, notices). The Co-ordinator of the Operating Experience Review Program is responsible for assuring that Vendor Technical Information (VTI) is captured and tracked by the control system. Each VTI review is assigned an Action Item Number, a reviewer is desig-nated, and the distribution of review results is controlled.

l The VTI review and control effort has been ongoing but remains incomplete. Deficiency Report (DR) 1011 was issued as result of QA

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l Audit 82-17 documenting inadequacies in control of vendor infor-mation. Corrective actions have been expanded and modified since the l audit and several extensions of action completion have been granted l

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by the cognizant Vice President. The current extension is until ,

September 30, 1986. A more current audit (86-34) identified addi-tional problems with VTI activities.

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The licensee was informed that this inspection's program review found that no definitive direction exists in procedures so as to assure that VTI would be properly forwarded for centralized incorporation into the master information files. This item remains unresolved pending revision of licensee procedures to provide required defini-tive directive (50-293/86-24-01)

No violations were identifie .2 Program Implementation Over 450 of the 500 manuals have undergone the initial evaluation process (i.e. validation program). The manuals listed in Attach-ment A were reviewed for conformance with the validation progra Other vendor technical manuals and information were also reviewed for proper incorporation into the licensee's other program The initial validation program above is intended to assure that each vendor manual is complete except for incorporation of "real time" supplemental information such as the vendor bulletins and letters, etc. A licensee representative stated that the supplemental informa-tion is being maintained on a departmental basis pending a longer term program for incorporation into the individual vendor's manual The licensee expects the incorporation of the "real time" information to be completed during the first biennial (1986-1988) manual review cycl Reactor Protection System *

A review of the General Electric vendor manual for AK type breakers used for the Recirculation Pump MG set field breakers determined that the manual does not include or reference pertin-ent vendor technical letters or service advisories as discussed above. However, the electrical maintenance engineer is ade-quately informed on such items and takes appropriate action to ensure integration of the information into maintenance activi-tie Mechanical Systems The inspectors reviewed preventive and corrective maintenance procedures, surveillance tests, and post maintenance test instructions listed in Attachment A for technical accuracy, and appropriate references to and incorporation of vendor technical information. The inspector determined that the documents reviewed appropriately incorporated such information.

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Motor Operators for Valves The Senior Electrical Maintenance Engineer informed the inspec-tor that, prior to the last outage (1984), preventive mainte-nance had not been performed on motor operators for valve Safety System Functional Inspection Report 50-293/85-30 had '

identified weakness in the licensee's program for conducting maintenance on this equipment, particularly the absence of a licensee issued procedure and heavy reliance an only the vendor technical manual maintenance instruction The lack of approved procedures for preventive and corrective maintenance of valve motor operators was identified for further NRC followup (Item 50-293/85-30-07) pending review of to-be-issued licensee procedure In response to the above finding, the licensee has issued a series of eight procedures (listed in Attachment A; 3.M.2-2 through 24.8) addressing valve operator removal, overhaul, electrical checkout and adjustment, installation, disassembly and reassembl A draft procedure, 8.Q.3-8, "Limitorque Type SB/SMB Valve Operator EQ Maintenance" has also been written but not yet issued to address routine preventive maintenance (lubrication, cleaning, etc.) required to maintain the environmental qualifi-cation of the operators. The procedure is also intended for use en valves not subject to environmental qualification require-ment The licensee has not yet established a formal preventive main-tenance schedule for the motor operators. Inspector followup item 50-293/85-30-07 remains ope NSSS Vendor Recommendations The licensee is currently addressing two NSSS vendor (General Electric Company (GE)) recomendations. First, GE Engineering expressed concern that the RHR pump impeller wear ring pins are not sufficiently retained by merely screwing into partially tapped holes in the impeller. The licensee has incorporated the GE recommended practice of staking each pin into its hole in Temporary Procedure 86-97 to provide additional assurance that the pins will not back ou Second, the licensee has initiated action for GE's Rapid Infor-mation Communication Services Information Letter (RICSIL) 008 and Services Information Letter (SIL) 441 concerning Control Rod Drive Scram Anomalie .. .

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In response to RICSIL 008, the licensee had placed scram sole-noid valve repair kits (ASCO Kit 204-139) on QC hold pending resolution of potential deficiencies in the parts identified by G During this inspection, the licensee received SIL 441 which advised that repair kits (above) shipped prior te July 17, 1986 could be defective and should be returned to GE for reinsnec-tion. GE also advised that facilities with such kits alitady installed should continue to use Technical Specification surveillance testing to demonstrate Control Rod Drive Hydraulic System (CRDHS) operabilit SIL 441 provided additional instructions for inspecting solenoid valve core springs and core assemblies to assure proper oper-ation. The licensee informed the inspector that all of the solenoid valves and backup solenoid valves would be rebuilt with repair kits from acceptable batches shipped after July 17, 1986 during the current outage and that the recommendations of SIL 441 would be incorporated into the station maintenance pro-cedur c. Instrumentation and Controls Instrument functional test and calibration procedures and data listed in Attachment A were reviewed to determine adequate incorporation of vendor information. The review included a sample of data from recently completed functional tests and calibration One discrepancy was identified. Surveillance Test 8.E.10, LPCI System Instrument Calibration, performed on June 30, 1986 included erroneous "as left" data entries for calibration of the

"B" RHR Header Discharge Flow Instrument. Two of ten data points appeared to have been incorrectly recorded. Further, the pro-cedure had been subjected to BEC0 supervisory review which had not identified the discrepant dat The inspector reviewed the data with the Senior I&C Maintenance Engineer and determined that the discrepancies apparently resulted from data recording errors and were not indicative of an improper calibration. All other data for the instrument displayed good linearity and distribution around the nominal desired setting Further review did not identify additional concerns. Based on this review the inspector concluded that the above discrepancy is an isolated instanc .

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5.0 Post Maintenance and Surveillance Testing 5.1 Program Review By reviewing the Procedures in Attachment A the inspectors determined that the following were addressed during the performance of mainten-ance:

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Written procedures provide for initiating requests for post mainten-ance testin Criteria and responsibilities for review and approval of' maintenanc Criteria and responsibilities for the basis of safety related/

non-safety related activity designate Criteria and responsibilities for inspection of post maintenance testin Methods for performing functional testing following maintenanc Administrative controls for documentation of maintenance activitie .2 Program Implementation Post maintenance testing is initiated and tracked in accordance with Procedure 1.5.3, Maintenance Requests and the Maintenance Request form. The inspectors reviewed maintenance activities as listed in Appendix A and compared the documentation for those activities with the requirements of the above procedure, the facility Technical Specifications, and available vendor supplied informatio Except as noted below, the licensee's program for assuring adequate post maintenance testing and surveillance testing appeared to be functioning acceptably. The existing practice includes retaining copies of the detailed records of such testing with the maintenance records, providing definitive confirmation of testing adequac Reactor Protection System The inspector reviewed those MR's listed in Attachment A for adequate Post Maintenance Testing, (RPS).

The Recirculation Pump MG Set Field Breakers are used to rapidly trip the pumps and stop reactor flow on an ATWS event. On June 26, 1986, the "A" MG Set Field Breaker failed to trip on demand with the plant in Cold Shutdown. A burned out trip coil was found after the event. This failure was administered under Failure and Malfunction Report (F&MR)86-157. Previous i

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similar reviewed failures were documented by F&MRs85-003 and 85-013. Three apparently unrelated events involving MG set failures due to generator and generator accessory failures were also identified (F&MRs85-028, 85-017, and 85-165).

F&MR 86-157 for the June, 1986 event remained open with cor-rective action still pending at the time of the inspection. The inspector reviewed Engineering Service Request (ESR)86-270, dated July 1,1986, which referred the matter to BECo Engineer-ing for root cause analysis and recommendations of corrective and preventive actions. The licensee stated that corrective action was in process but provided no definite status when requested by the inspector. These repeated failures suggest that the Licensee's corrective actions are ineffective in this regar Inspection =60-293/86-21 identified similar significant weak-

. nesses in the timeliness and effectiveness of the licensee's corrective action programs. The above. matter represents further example of such deficiencies and will be reviewed during future c inspections under existing unresolved item 50-293/86-21-0 Two Plant Design Change Requests (PDCR) 79-25 and 81-27 invol-ving ATWS and RPS were examined. As identified in Inspection Report 50-293/85-30 these PDCRs also did not contain adequate details to support the conclusion of the Safety Reviews required by 10 CFR 50.5 b. 4160 V Safety Related Switchgear Technical Specification Table 3.2.b and Table 4.2.b provide requirements for calibration and functional testing of the Class 1E busses undervoltage and degraded voltage protection relays. The inspector reviewed the licensee's procedures and test data which demonstrate compliance with the above Technical Specification The licensee does not maintain a matrix of TS requirements versus implementing procedures. The inspectors requested the licensee to identify the procedures that specifically addressed the Technical Specification requirement The procedures initially provided by the licensee did not address all of the TS requirements. Additional procedures were provided but the licensee was still unable to show that the collective procedures satisfied each of the TS requirement .

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During a meeting the licensee supervisory personnel responsible for technical specification required testing could not ade-quately identify (1) all procedures reouired to meet technical specification requirements (2) the specific steps executed during a test and (3) the relationship between procedure accept-ance criteria to the technical specification requiremen None of the procedures contained acceptance values for relay performance and did not provide for recording as-found or as-left trip value Relay Setting Sheets did record the as-left trip values but did not include acceptance criteria, although the as-left values appeared to meet the TS requirement Further, many of the procedures did not clearly identify the

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tested relays or components in a form which could be related to either the drawings or the TS, e.g. Procedure 8.M.3-1, Automatic ECCS Load Sequencing of Diesels and Shutdown Transformer with

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Simulated Loss of Offsite Power, listed forty-two (42) reference drawings but did not discretely identify the tested HEA relays by tag number nor the specific TS line item (s) to which the test applied. The procedure referred to the relay only by terminal board connection numbers. Although the test does not discuss testing of the UV relaying, it is used as one of several tests needed to meet the TS 3.2.B requirement The problem above appears to result from: 1) lack of clear identification of procedure scope ~or purpose, the specific TSs addressed, and the specific ^ equipment tested per the TS, 2) a testing philosophy which results in fragmentation of required test elements among several otherwise unrelated procedures, and 3) a testing philosophy which does not rely upon actuation of the relay logic in a comprehensive sequence which discretely tests each complete logic pat This is considered by the NRC as another example of the weaknesses in the Licensee's Surveillance test program identified existing unresolved item 50-293/85-30-06. Therefore a separate unresolved item or violation is generated. The licensee's actions in this regard will be reviewed in conjunction with the above ite A random sample of test equipment documents from the I&C shop were reviewed for out-of-calibration and usage of equipment. The documents were found to be in compliance with station proce-dure .

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- Mechanical Systems The inspector reviewed MRs listed in Attachment A for adequate post maintenance testing. Surveillance test procedures and completed surveillance tests performed as post maintenance tests, listed in Attachment A, were also reviewed for technical adequacy, completeness, acceptance criteria, maintenance and test eouipment tracking, corrective action and appropriate supervisory review and approva In a letter to NRC in response to GL 83-28, Item 4.5.1, on June 28, 1984, BECO provided a justification for not performing on line functional testing of backup scram valves and included a description of an alternative method for demonstrating backup scram valve operabilit That letter stated that backup scram valve operability would be demonstrated during performance of Procedure 2.1.5, Controlled Shutdown from Power, by scramming the plant, and verifying the receipt of an CRDHS air header low pressure alarm and subsequent alarm rese The procedure's steps did not specifically highlight any aspect of verifying backup scram valve operability but were merely the functional followup steps required to stabilize and restore plant systems after a scram from low or zero powe Further, discussions with the BECO Operations Section Manager established that current station operating practice is directed at avoiding scrams during routine shutdowns and that the above provisions of Procedure 2.1.5 would not be routinely use Several telephone conversations, were held with licensee management subsequent to this inspection about testing these backup scram valve Licensee management confirmed a commitment to perform testing on backup scram valves each refueling outage in telephone conversations on September 10 and 11, 1986. This item is unresolved pending verification of licensee action (50-293/86-24-02).

d. Instrumentation and Control Maintenance Orders for RPS and Safety Injection sys. ems were reviewed to verify adequacy of post maintenance testing. In all cases reviewed, post maintenance testing was found to be thor-ough, adequate, and complete. Those maintenance orders reviewed are listed in Attachment A.

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16 , Trending and Corrective Action

'The inspector reviewed various aspects of the licensee's trend-ing programs. The BECO Compliance Group trends Failure and Malfunction Reports semiannually for proper corrective action and repetitive failure The QA Department trends Deficiency Reports for closecut. The Maintenance Section trends equipment vibration and oil sampling dat The major contributor to the equipment performance trending pro-gram is the Inservice Testing (IST) Group. The IST Group moni-tors data for pumps and valves and informs maintenance of any degradation in performance to allow scheduling of overhauls and rebuilding. The licensee informed the inspector that there is no formal program of trending component failures except as noted abov The inspectors reviewed outputs from the various licensee cor-rective action programs for evidence of sensitivity to vendor interfaces and vendor supplied information. Failure and Mal-function Reports and Nonconformance Reports listed in Attachment A were reviewed in detai Failure and Malfunction Report (F&MR)85-188 addressed appar-ently defective manufacture or maintenance of the motor oper-ators for LPCI Injection Valves MO 1001 28 A & B wherein the torque sleeve 0-ring groove and 0-ring specified by the manu-facturer were found missing during overhau In consultation with the equipment vendor, the licensee elected to reassemble the operator with temporary packing (vice the 0-ring installation) pending receipt of permanent repair part The licensee administered the activity as a Temporary Modiff-cation and processed Safety Evaluation No. 1862 per 10 CFR

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50.5 Safety Evaluation No. 1862 relied extensively upon the " engine-ering judgement" of the licensee's engineering staff and vendor technical representative to substantiate its conclusions. The licensee was unable to provide additional calculationai or other analytical base Additionally, neither the Safety Evaluation nor the F&MR addres-sed the licensee's actions for review of potentially generic implications of the problem. While nearly all similarly de-signed valve operators were overhauled during the same outage, no documented followup appeared to exist which would demonstrate that the licensee systematically evaluated the generic impli-cations, particularly with regard to potential manufacturing breakdowns.

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This observation is similar to those made during Inspection 50-293/85-30 regarding weaknesses in the licensee's programs for conducting safety evaluations. Further licensee action to improve performance in this area will be reviewed during future NRC inspections under an existing unresolved item (85-30-07).

Except for the above the inspector identified no further con-cern . ]A/QC Interface The Nuclear Quality Assurance Department is headed by the Quality Assur-ance manager (QAM) who reports to the Vice President Nuclear Engineering and Quality Assurance. An Audit Group Leader and seven engineers, a Quality Engineering Group Leader and seven engineers, and an Operational Control Group Leader and thirteen engineers report to the QA The Audit Group is responsible for conducting audits required by Technical Specifications (TS) and the QA Program except those associated with vendor control. Also, QA surveillances of in plant TS related activities are con-ducted by two engineers dedicated to this effort. The 1985-86 audit sche-dule listed 55 audits which were being conducted at an even pace. An audit matrix of 10CFR50 Appendix B Criteria vs. ten functional areas noted what was addressed in each 1986 audit. This matrix is developed for each calendar year. Another matrix lists each TS line item and notes the audit that addressed a given item. Each line item will be sampled at least once during a four year cycle. The TS activities schedule for QA surveillance of in plant TS activities lists 20 functional areas, fifteen of which have already been monitored. These surveillances included equipment tagging, Non-Q MR's vs. the Q-List, system alignments (e.g. valve lineups of Stand-by Liquid Control Systems, and Fire Systems), Health Physics, and instru-ment calibrations (e.g. ATWS sensors).

The Quality Engineering Group is responsible for the evaluation and approval of vendors, maintenance and control of the approved supplier list, and audits /surveillances of active vendor The group also reviews purchase requisitions prior to their issuanc Each vendor is evaluated annually and audited on at least a tri-ennial cycle with certain vendors being audited annually. The CASE Register System, a form of utility vendor audit system is also used. This group also does the trending of quality elements and issues an annual Trend Analysis Report. The 1985 report was issued April 1986 and received wide distribution. The analysis considered organizational responsibilities, cause codes including personal error, functional areas, severity grading (i.e. weight factor), and internal and external sources of problem documentation (e.g. NRC). Tables and graphs were used liberally in the report detail sections and corrective actions escalated to or initiated by management were treated separately. Disci-

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pline engineers are used as audit specialists on occasio . ..

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The Operational Control Group is responsible for reviewing Maintenance Requests (MR's), performing installation inspections and conducting surveillances of onsite contractors. Inspection checklists are developed for the MR's reviewed each month. No hold / witness points have been waived

.this calendar year. Two engineers are dedicated to the QA surveillance effort and another has primary responsibility for receiving inspection of purchased items. The Group Leader stated that approximately 50 additional contracted personnel will be added to his permanent staff by mid-September to provide adequate coverage during the outag No violations were identifie .0 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, deviations or violation Unresolved items are discussed in Paragraphs 4.1 and 5. .0 Management Meetings Licensee management was informed of the scope and purpose of the inspec-tion at an entrance meeting conducted August 4, 1986. The findings of the inspection were discussed with licensee representatives during the course of the inspection. An exit meeting was conducted August 8, 1986 at the conclusion of the inspection (see Paragraph I for attendees) at which time the licensee management was informed of the inspection results. At no time

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during this inspection was written material provided to the licensee.

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ATTACHMENT A 1.0 References / Requirements NRC Generic Letter 83-28, " Generic Implications of Salem ATWS Events" 10 CFR 50, Appendix B PNPS Technical Specifications FSAR Quality Assurance Program ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plant ANSI N45.2.2-1972, Packing, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plant ANSI N45.2.12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plant ASME Boiler and Pressure Vessel Code Section XI,1974 edition with addend NRC Safety System Functional Inspection Report 50-293/85-30, 1/28/86 NRC Safety Evaluation for Pilgrim Nuclear Power Station Regarding Generic Letter 83-28, Items 3.1.1, 3.1.2, 3.2.1, 3.2.2, and 4.5.1, 7/14/86 NRC Generic Safety Evaluation Regarding Generic Letter 83-28, Item 4.5, On Line Testing of Backup Scram, GE Plants, 11/16/8 BEC0 letter 84-168 of 11/4/84, Subject: Revised Response to Item 2.2.1.4 of Generic Letter 83-2 BECO letter 84-093 of 6/28/84, Subject: Generic Letter 83--28, Section BECO letter 84-308 of 12/30/83, Subject: Incorporation of Vendor Manual Validation into a Nuclear Operation Procedur BECO letter 86-051 of 4/25/86, Subject: Generic Letter 83-28, Items 3.1.1, 3.1.2, 3.2.1, and 4.5.1, supplemental respons _ _ .

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BEC0 letter 83-275 of 11/7/83, Subject: Response to Generic Letter 83-2 GE RICSIL No. 008, Control Rod Drive Scram Anomaly, 6/27/86 GE SIL No. 441, Contro Rod Drive Scram Anomaly, 7/17/86 2.0 Documents Reviewed 2.1 Procedures / Tests 3.M.1-11 Routine Maintenance, Revision 3 1. Maintenance Requests, Revision 16 1. Maintenance Requests, Revision 17 N0 5.01 Quality Control Review of PNPS Maintenance Requests, Revision 6 3.M.4-10 Valve Maintenance, Revision 5 (Performed 9/20/84, 10/4/84, 10/16/84, 11/29/84, 12/9/84, 12/16/84, 12/23/84, 1/4/84, 1/9/85, 7/23/85, 7/26/85, 7/27/85)

2.2.21 HPCI System Operation, Revisin 26 8.5. HPCI Pump Operability Flow Rate and Valve Test At 1000 psig, Revision 28 (Performed 12/3/84, 12/31/84,7/27/85)

8.5. HPCI Valve Operability Test, Revisions 15 & 16 (Performed 1/23/86, 7/24/85)

3.M.1-15 Vibration Monitoring for Preventive Maintenance, Revision 1 3.M.2-16 Scram Pilot Valve Maintenance, Revision 3, (Performed 4/9/85)

TP 85-29 Pre 0perational Test for Logic Limit Switches on HPCI Torus Suction Valves, 5/8/86 (Performed 7/25/85,7/27/85)

PDC 84-60-00 Post Work Testing paquirements (Performed 7/23/85, 7/25,85)

PDC 84-160 Post Work Testing Re; irements (Performed 7/25/85)

8.Q.3-8 Limitorque Type SM/SMB Valve Operator EQ Maintenance, Draft TP 86-97 RHR Motor / Pump Removal, Inspection, Refubishment and Reinstallation, Revision 1 3.M.3-2 Limitorque Type SMB Valve Operator Removal, Revision 1 3.M.3-2 Limitorque icpe SMB-000/00 Motor Operator Overhaul, Revision 0 3.M.3-2 Limitorque Type SMB-0 through SMB-4 Motor Operator Overhaul, Revision 0 3.M.3-2 ,Limitorque Type SMB-5 Motor Operator Overhaul, Revision 0 3.M.3-2 Limitorque Type SB/SMB Electrical Checkout and Adjustment, Revision 1

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3.M.3-2 Limitorque Type SMB Valve Operator Installation, Revision 1 3.M.3-2 Limitorque Type SB-00 through SB-3 Valve Operator Disassembly / Removal, Revision 0 3.M.3-2 Limitorque Type SB-00 through SB-3 Valve Operator Reassembly / Installation, Revision 0 Master Surveillance Tracking Program, Rev 4 8.M.2-2. Lower Pressure Permissive Opening LPCI Injection Valve, Rev 10 8.M.2-2. Rx. Drywell Pressure ADS, Rev 9 8.M.2-2. Low Pressure Permissive LPCI Loop Selection, Rev 6 8.M.2-2. Low Pressure Permissive Automatic Initiation, Rev 8 8.M.2-2.10.2- LPCI Break Detection Logic Functional Tests 16 Division A, Rev 8 8.M.2-2. Reactor Drywell High Pressure Automatic Initiation, Rev 10 8.M.2-2. ADS - Pump Discharge AC Interlock, Rev 10 8.M.2-2. Reactor Water Level Safeguard Systems, Rev 8 8.M.2- RHR System Pump P-203C Automatic Start Functional 2.10.11 Test, Rev 8 1.3.36 Measurement and Test Equipment, Rev 2 8.M.2-2.10.9.1 ADS Logic Rx Other than Shutdown, Rev 11 6.07 Maintaining the Q-List, Rev 5 1. PM Tracking Program, Rev 1 8.M.2- RHR System Pump P-203B Automatic Start Functional 2.10.2.12 Test, Rev 7 8.M.2- RHR System Pump P-203D Automatic Start Functional 2.10.2-13 Test, Rev 7 8.M.2- Automatic Start, RHR Pumps P-203B and P-203D 2.10.2-15 Function:1 Test, Rev 9 8.M.3-1 Automatic ECCS Load Sequencing of Diesels & Shutdown Transformer with Simulated Loss of Off-Site Power, Rev 6 8.M.2- Logic System Functional Test Automatic Start Core 2.10.1-7 Spray Pump 1401-B, Rev 8 8.M.2- Automatic Start, RHR Pumps P-203A and P-203C 2.10.2-14 Functional Test, Rev 9 8.M.2-2.1.11 Emergency Buses A5 & A6 4.16kV Start-Up Transformer

, Under Voltage and Degraded Voltage Relays, Rev 10 l 8.M.2-2.1 Depressurization System Actuation Logic When Reactor is Shutdown, Rev 7

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8.M.2- RHR System Pump 203A Automatic Start Functional 2.10.2-10 Test, Rev 8 8.M.2-2.1.10 Emergency Buses A5 and A6 Loss of Voltage and l Degraded Voltage Relays, Rev 11 l 3.M.3-1 AS/A6 Buses 4kV Protective Relay Calibration / Function Test i 2.2.126 ATWS (Operation), Rev 4 8.M.1-30 ATWS Calibration Test, Rev 5 8.M.2-2.10.2-5 Loop Selection Logic System A, Rev 6 l

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8.M.2-2. Recirculation System Differential Pressure, Rev 5 (Performed 7/31/86)

8.M.1-29 ATWS Function and Trip Unit Calibration, Rev 14 (Performed 6/28/86)

8.M.1-1. RHR Isolation Valve Control Test A Inboard, Rev 4 (Performed 7/16/86)

8.E.10 LPCI System Instrument Calibration, Rev 8 (Performed 2/20/86,6/30/86)

8.M.2-2.10.2-7 LPCI Loop Selection Logic System Test, Rev 6 8.5. LPCI MOV Operability Test, Rev 11 8.5.2.2-1 LPCI Pump Flow Rate - Test & MOV Timing, Rev 20 NOP 8305 Failure and Malfunction Report Process, 5/2/84 N0P 83A9 Management Corrective Action Program, 7/23/85 NOP 83A13 Deficiency Report Process, 7/23/85 '

NOP 83A14 Nonconformance Report Process, 7/23/85 8.M.2- ADS-Pump Discharge AC Interlock, Rev 9 TP 85-36 Preop. Test for DP15-1001-79A/B for EQ Upgrade, Rev 1 TP 85-34 Preop. Test for Logic Limit Switches on LPCI Inj. Valves MD-1001-28A'sB,-29 A/B, Rev 1 3.M.4-10 Valve Packing Rev 5, FNPS Q-List, Rev E14 NED6.07 Maintaining the Q-List, Rev 5

- Draft Rev 15, PNPS Q-List 3.M.4-100-1 Valve Actuator Test, Rev 5

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Temporary Modification No. 85-46, M0V1001-28B Actuator 0-Ring Repairs Including Safety Evaluation 8.M.2- Automatic Start, RHR Pumps 203A and 203C 2.10.2-14 Functional Test, Rev 9 NOP8401 Operating Experience Review Program, 5/15/85 2. Controlled Shutdown Fan Power, Rev. 29 2.2.86 Residual Heat Removal 1.2. Failure and Malfunction Reports, Rev 12 PDCR#81-27 Modification of RPS Shutdown SCRAM Reset PDCR#81-20 Reactor Protection System Power Supply Protection QAD 1.01; Organization, Rev 11 QAD 4.06, Procurement of Items and Services, Rev 4 QAD 7.01, Receipt Inspection, Rev 7 QAD 7.02, Onsite Contractor Monitoring, Rev 5 QAD 7.04, Evaluation of Suppliers, Rev 3 i QAD 10.02, Conduct and Reporting of Installation Inspections, Rev 9 QAD 16.02, Trend Analysic, Rev 9 QAD 18.04, Conduct and Reporting of Nuclear Operations Surveil-lance Monitoring Activities, Rev 8 l WI 1.0, Technical Specifications Audit Matrix, Rev 3 WI 2.0, Internal Audit Matrix, Rev 2

PNPS Operations Manual Procedure Change Notice, 8/7/86

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2.2 Vendor Manuals V0072 Mercold Control; Pressure, Level, Flow, D/P further etc., Rev 0 V0100 ASCO Air Operated Valves and Air Controls, Rev 0 Including GSCO Service Recommendations V0055 ITT Barton Instrument, Rev 0 V0047 Foxboro Instruments, Rev 0 V0119 GE Meters & Aux. Relays, Rev 0 V0390 Limitorque Motor Operators 2.3 Prints / Drawings M250 Control Rod Drive Hydraulic System, Sheet 1, Rev E13 M243 HPCI System Sheet 1, Rev E8 M244 HPCI System Sheet 2, Rev E8 M1Y1 Elementary diagram ATWS System M1Y2 Elementary diagram ATWS System M1Y3 Elementary diagram ATWS System M1Y4 Elementary diagram ATWS System M1YS Elementary diagram ATWS System M1Y6 Elementary diagram ATWS System M1Y7 Elementary diagram ATWS System M1Y8 Elementary diagram ATWS System M1Y9 Elementary diagram ATWS System M1Y10 Elementary diagram ATWS System MIH9-12 RHR Elementary Diagram SHS Rev E6 MIH12-8-13 RHR Elementary Diagram SH8 Rev E4 MIH10-10 RHR Elementary Diagram SH6 Rev E6 MIH16-5 RHR Elementary Diagram SH12 Rev ES MIH20-4 RHR Elementary Diagram SH16 Rev E2 E239 RHR Wiring Block Diagram SH3 Rev E3 MIH6-9 RHR Elementary Diagram SH2 Rev E5 MIH5-1-15 RHR Elementary Diagram SH1 Rev E7 MIY1 ATWS System Elementary SH1 Rev E0 Diagram MIY2 ATWS System Elementary SH2 Rev El Diagram MIY3 ATWS System Elementary SH3 Rev E0 Diagram MIY4-10 ATWS System Elementary SH1/10 Rev El E7 Class 1E 4.16kV Switchgear one-line diagram E35 Elementary Undervoltage Diagram and Undervoltage Relays for 4.16kV Swgr E38 Elementary Degraded Relays for Undervoltage Relays for 4.16kV Swgr Retax Setting Sheets for under voltage and degraded voltage relays L ___

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2.4 Maintenance Requests 83-23-51 M02301-6 Preventive Maintenance 83-23-58 M02301-8 Preventive Maintenance 83-23-59 M02301-9 Preventive Maintenance 83-23-53 M02301-35 Preventive Maintenance 83-23-54 M02301-36 Preventive Maintenance 83-10-34 N01001-37A Preventive Maintenance 83-10-55 M01001-373 Preventive Maintenance 84-23-95 M02301-35 EQ Inspect & Repair Motor Actuator 85-23-7 M02301-35 EQ Motor Replacement 85-23-5 M02031-8 EQ Motor Replacement 84-23-102 M02301-8 EQ Inspect & Repair Motor Actuator 85-426 M02301-6 Valve not moving 84-23-99 M02301-6 EQ Inspect & Repair Motor Actuator 85-23-10 M02301-6 EQ Motor Replacement 84-23-138 X-203 Reinstall HPCI Turbine Coupling 84-23-39 M02301-35 Valve Repacking 84-23-38 M02301-6 Valve Repacking 85-393 X-203 Control Oil Modification 85-361 X-203 Stop Valve Adjustment 85-23-30 X-203 Stop Valve Adjustment 85-249 X-203 Borderling Vibration Readings 83-23-76 X-203 Annual PM on HPCI Turbine 85-23-4 M02301-9 EQ Motor Replacement 84-23-98 M02301-9 EQ Inspect & Repair Motor Actuator 84-23-42 M02301-36 Valve Repacking 84-614 X-203 Overspeed Trip Adjustment 84-23-36 M02301-9 Valve Repacking 84-23-4 M02301-? Cable Connection Verification 84-23-15 M02301-8 Valve Repacking 85-23-6 M02301-36 EQ Motor Replacement 85-462 M02301-36 Motor Replacement 84-23-94 M02301-36 EQ Inspect & Repair Motor Actuator 85-3-4 HCU 46-15 Limit Switch Realignment 85-381 SV-122 Solenoid doesn't Pickup 85-217 Various Solenoid Retaining Clip Replacement 83-3-14 Rebuild Scram Pilots 85-3-3 Check Tightness of Scram Solenoid Actuators85-686 Replaced SV120 and SV122 l

l 2.5 Purchase Orders and Material Receipt Inspection Reports (MRIR)

i 24223 Relays (MRIR 84-285))

20228 Gages (MRIRs 80-1139 and 81-371)

25073 Grofoil Packing (MRIRs84-307)

l 25092 Solenoid Valves (MRIR 85-211)

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56540A Motors (MRIR 83-444)

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, 86-5302 Fuse Links

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2.6 Failure & Malfunction Reports85-190 Failure of M01001-28B Motor (See MR 85-578)85-264 Setpoint Draft DP15-261-37A, Recirc System DP 85-188 Missing 0-Ring in M01001-28B Actuators (See MR 85-10-254)75-107 HPCI Isolation Due to Steam Line Hi DPIS Failure 85-104 HPCI Isolation Due to Steam Line Hig D/P; Air in System 85-077 MOV 1001-25B Parts Not properly procured 85-077 PS2389A (HPCI Low Stm Press (SOL) Failed Surveillance 86-041 A029 Failed Stroke Time Test 86-040 HPCI Turbine Step & Control Valves Stroke Times 0. RHR Isolation Due to ULV LKG 86-157 MG Set A Breaker Failure 85-17 MG Set A Breaker Failure 85-165 MG Set A Breaker Failure 85-28 MG Set A Breaker Failure 86-177 MG Set A Standing Water 86-146 Relays Calibration overcue 86-180 Relays Out-of-Calibration 86-140 Corrosion on M0-1001-28B Disk 86-130 Corrosion on Mo-1001-28B Disk Erg Evaluation 86-092 Leaking Test Connection at Mo-1001-28B 86-085 RHR Isolation Vavles M0-1001-288 and 29B Leaking 86-017 Fuse Found (Vice Link) in M0-1009-29B indicating CKT 86-016 Fuse Found (Vice Link) in M0-1009-29A indic: ting CKT l

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