ML20236F111
| ML20236F111 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/26/1987 |
| From: | Bird R BOSTON EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 87-167, NUDOCS 8710300148 | |
| Download: ML20236F111 (4) | |
Text
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_ g, is mosm asm Executive Offices a
i 800 Boylston street Boston, Massachusetts 02199
- Ralph G. Bird
('
senior Vice President - Nuclear October 26, 1987 BECo Ltr. #87 167 U.S. Nuclear Regulatory Commission i
Attn: Document Control Desk
- Washington, DC 20555 License No. DPR-35 Docket No. 50-293 l
Subject:
NRC Inspection Report No. 50-293/87-36
Dear Sir:
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Attached is Boston Edison Company's response to the Notice of Violation l
contained in the subject inspection report.
Please contact me directly if you have any questions on _this response.
t
.G.
B~rd Attachment cc: Regional. Administrator U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Sr. Resident Inspector i
l 93-PDFt
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ATTACHMENT I Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. OPR-35 Notice of Violation:
10CFR50, Appendix B, Criterion XI, states in part, " Test results shall be... evaluated to assure that test requirements have been satisfied."
10CFR50, Appendix B, Criterion XVI, states in part, " measures shall be established to assure that...nonconformances are promptly identified and corrected."
Contrary to the above, as of August 27, 1987, post maintenance test results that failed to meet acceptance criteria had not been adequately evaluated. As a result of the inadequate evaluations, these unsatisfactory test results were not identified and subsequently corrected.
Two instances were noted where completed test results of 480 volts (MR No.86-273) and 520 volts (MR No.
86-14-25) had exceeded the acceptance criteria of 460 volts specified in Procedure No. 3.M.4-10, Attachment C, Revision 6.
Both test results had been accepted as satisfactorily completed following a supervisory and a Quality Control review on April 10, 1986 and August 15, 1987, respectively.
This is a Severity Level IV violation (Supplement I) applicable to DPR-35.
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Response
1.
Summary:
Boston Edison concurs with the facts stated in the Notice of Violation.
The fundamental violation was personnel failing to identify discrepancies between acceptance criteria and recorded test results as required by Procedure 3.M.4-10.
Corrective action has been taken to resolve that problem as described in Section 4 of this letter.
Based on a review of the facts of the violation Boston Edison requests the Severity Level be changed from IV to V.
10CFR Part 2 Appendix C states that Severity Level V violations, "have minor safety or environmental l
significance".
He consider this violation to meet that criterion since an evaluation has concluded that the motors would not be adversely affected by the observed elevated voltages.
A discussion of the pertinent technical details is provided below to support our position.
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ATTACHMENT I (Cont.)
2.
Discussion:
Elevated AC voltages have negligible effect on motor RPM and therefore will not significantly affect valve stroke time.
Elevated voltages (i.e.
approximately 520 volts) increase motor heating but do not exceed the motor's temperature rise capability / rating due to the short operating time.
During a previous outage, prior to the subject work being performed, an informal assessment of the discrepancy between nameplate voltage (460V) and actual bus voltage had been performed on a generic basis.
This informal assessment was performed by a senior Boston Edison electrical engineer and recently was confirmed by the Nuclear Engineering Department by memo dated October 21, 1987.
The subject Procedure, No. 3.M.4-10 " Valve Maintenance" was not being used to demonstrate valve operability, therefore valve operability was not compromised by this error. A separate operating procedure was used to confirm valve operability.
This violation therefore meets the criterion for severity Level V.
3.
Cause:
Personnel failed to identify a discrepancy between the stated " Acceptance Criteria" and the recorded test results.
This violation was caused by personnel 1) failing to follow procedures and 2) relying upon a previous informal evaluation which concluded that voltages up to 520 volts were 4
acceptable.
i In retrospect, the procedure should have either been revised to delete I
voltage as an acceptance criteria or the discrepancy evaluated each time Procedure 3.M.4-10 was used, j
4.
Corrective Actions Taken to Avoid Future Violations and Results Achieved:
The Quality Control and Maintenance personnel involved in the violation were counseled on the importance of procedural adherence.
The Operations QC Group Leader conducted a training session of QC personnel on August 28, 1987 and reinforced their responsibility to question and document discrepancies between identified " Acceptance Criteria" and recorded test data.
The QC Group Leader also issued a l
change to the " Quality Control Inspection" procedure to include the attachment of the acceptance criteria to the quality control inspection report to facilitate independent review. Additionally, previous uses of Procedure 3.H.4-10 from January 1987 to the present have been reviewed.
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Discrepancies have been documented and resolved.
j The Chief Maintenance Engineer took prompt action to revise procedure 1
3.M.4-10 (Rev. 8 issued August 21, 1987) to address the immediate concern of the voltage data and its intended use.
This change deleted voltage as an acceptance criteria but retained the requirement to record voltage at the MCC.
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ATTACHMENT I (Cont.)'
On August 28, 1987, the-Senior Vice President, Nuclear emphasized to site
. personnel at an "All Hands" meeting the importance of procedural adherence. He also noted that if a procedure cannot be followed as written then work should be stopped and the procedure corrected. On September 9,'1987, a brief summary of the "All Hands" meeting was posted on the bulletin boards throughout the site.
This recent emphasis, as well as continuing training and implementation of the formal Plant Management Monitoring Program are expected to lessen the likelihood of future violations.
5.
Date of Full Compliance:
Full compliance was achieved on August 21, 1987 when procedure 3.M.4-10 was revised. Additionally, the QC effort to review previous uses of Procedure 3.M.4-10, from January 1987 to the present, was concluded on 1
October 21, 1987.
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