IR 05000293/1987033: Difference between revisions

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{{Adams
{{Adams
| number = ML20196A562
| number = ML20238A790
| issue date = 01/28/1988
| issue date = 08/20/1987
| title = Ack Receipt of 871221 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/87-33
| title = Insp Rept 50-293/87-33 on 870803-07.Violations Noted.Major Areas Inspected:Post Mod Test Program Preoperational Test Procedure Review,Qa/Qc Interface w/post-mod Testing, Independent Verification & Plant Tours
| author name = Johnston W
| author name = Briggs L, Eselgroth P
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| addressee name = Bird R
| addressee name =  
| addressee affiliation = BOSTON EDISON CO.
| addressee affiliation =  
| docket = 05000293
| docket = 05000293
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = NUDOCS 8802050094
| document report number = 50-293-87-33, NUDOCS 8708310211
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| package number = ML20238A760
| page count = 3
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 6
}}
}}


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=Text=
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JAN 281988
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Docket No. 50-293
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  . Boston Edison Company ATTN: Ralph G. Bird    -
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Senior-Vice President - Nuclear 800 Boylston Street Boston, Massachusetts 02199 Gentlemen:
U.S. NUCLEAR REGULATORY COMMISSION      ,
Subject: Inspection-No. 50-293/87-33 This refers to your letter dated December 21, 1987, in response 'to our letter dated August 21, 1987.
REGION I      l Report.N /87-33
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  . Docket N License N DPR-35 Licensee: Boston Edison Company M/C Nuclear 800 Boylston Street-Boston, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station Inspection At: Plymouth, Massachusetts      .I
. Inspection Conducted: August- 3-7, 1987      1 i
j Inspectorsi ~  4M L. Briggs, laid Reactor Engineer, DRS 8 /.s70 / # 7 date Approved by: / J , 'f    82d[<f 7 P.'Eselgr ' , Chief, Test Programs Section    / ddte 08, DRS        j Inspection Summary: Inspection on August 3-7, 1987 (Inspection Report    i No. 50-293/87-33)
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Areas Inspected: Routine unannounced inspection of the licensee's post    I modification test program preoperational test procedure review, QA/QC interface with post modification testing, independent verification and plant tour Results: One violation was identified for failure to adequetely review a design package and its associated post maintenance preoperational test,     , l Paragraph !
Note: For acronyms not defined refer to NUREG-0544 " Handbook of Acronyms and l Initialisms".        j l
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8708310211 870821 PDR ADOCK 05000293 G  PDR
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Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.
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Your cooperation with us is appreciated.
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DETAILS A"
  '1.'0''PersonsContactfdc
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  * M.'Akhtar,< Modifications Management Group Leader
  * T. Beneduci, Senior Engineer, Modifications Management
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  * N. Brosee, Outage Manager-
  * R.,Grazio, FieM Engineering Sectinn Manager
  * P. Hamilton, Cortpliance Group Leader
  , ' * S, Hudson," Operations'Section Manager-
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  ' B. Lunn, Compliance Engineer
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  " J..Mattia, QA, Group Leader
  ' * A. Morisi,- @ pt and Turnover Section Mantger
  >2 l * K. Roberts, Station Nnager  i
  *.R. Schifone, QA k  NRC ,
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  *fN. Blumburg, Chief, Operational Programs'Section
  * J. Lyash, Resident Inspector The inspector also contacted other memebers of the licensee'4 QA/QC and-technical stat ;
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  * Denotes those present at the August 7, 1987, exit meetin ~
2.0' Post Modification Preoperational Testing (PMPT). Procedure Review  l 2.1 Scooe
  ./ The PMPT's and Plant Design Changes (PDC's) listed below were
" 4 a'  reviewed in preparation for test witnessin The PMPT's were j  ' reviewed for, technical and administrative adequacy and for
  . ,. f, ,  verification that testing is planned to adequately satisfy a  regulatory svidance and licensee commitment They were also
,  reviewed to vsrify licensee review and approval, proper format, test F
  ' objectives, prerequisites, initial conditions, test data recording requirements and system return to normal. The PDC's were reviewed to determine what changes were made to the associated system and to provide a bases for the determination of PMPT scope necessary to s  verify the system's modified desig 'f
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PDC 86-70, Standby Gas Treatment System Modification; j
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PDC 82-25, 011 and Vibration Alarms Modification on )
Recirculation Pump Motors;
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PDC 85-59, HPCI Exhaust Vacuum Breaker;
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TP 87-128, Pre-Operational Test of Standby Gas Treatment System Modification Per PDC 86-70, Revision 1, dated July 20, 1987; r
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Sincerely, RCRGT M. T.'.o
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William V. Johnston, Acting Director Division of Reactor Safety
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cc:
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K. P. Roberts, Nuclear Operations Manager Paul Levy, Chairman, Department of Public Utilities Chairman, Board of Selectmen Plymouth Civil Defense Director    l J. D. Keyes, Boston Edison Regulatory Affairs and Programs  l E. D. Robinson, Nuclear Information Manager  l R. N. Swanson, Nuclear Engineering Department Manager  ,
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The Honorable E. J. Markey   '
TP 86-95, Pre-Operational Test.of Oil Level and Vibration System on the Recirculation Pumps, Revision ~1, dated June 11, 1987;'and,
Senator Edward P, Kirby The Honorable Peter V. Forman Sharon Pollard, Secretary of Energy Resources  l Peter W. Agnes, Assistant Secretary of Public Safety,
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TP.87-88, HPCI. Vacuum Breaker Pre-Operational Test, Revision 0 1, (draft).
Commonwealth of Massachusetts Rachel Shimshak, MASSPIRG    y


Public Document Room (PDR)
2.2 . Discussion During the review of TP 87-128 the inspector noted several areas of the. test procedure that were either in error or. did not' appear. to verify the design of the modified system. These items were discussed with one of the licensee's senior Modifications Management Group (MMG) engineer The' engineer and licensee management agreed with the inspector that the following errors / omissions should tave been identifie Paragraphs 7.'2.5, 7.3.5 and 7.4.5 required 5 damper control switches- to be in the. auto position and their associated dampers in the open position. The associated dampers would be in the closed position with'the specified switch position and no initiation signal present, Section 7.3.8.and 7.3.8.9-did' not require verification tha't.
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Massachusetts (2)
0FFICIAL RECORD COPY RL PILGRIM 87-33 - 0001.0.0 01/11/88 .I i 8802050094 88012e PDR y0i 'I
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O ADOCK 05000293 PDR    j m -     J


Boston Edison Company  2
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Region I Docket Room (with concurrences)
valve A0N-112 closed when the 'B'. Standby' Gas Treatment System-(SBGTS)-fan tripped (per procedure). Inlet valve A0N-106 was verified as closin Paragraph 7.3.8.6 required the differential pressure across the calibrated orifice plate'(DPI-AA-32) in the 'B' SBGTS train to be recorded with the 'B' SBGTS fan in standby (off). This reading was being taken to measure 'B' train bypass flow so it could be combined with 'A' train to determine system flo Under the system conditions specified this reading would be zero  ,
Management Assistant, DRMA (w/o enc 1)
    (0) since one of the SBGTS modifications moved the upstream  i bypass flow connection such that the connection between the A  ,
Section Chief, DRP R. Wessman, PM, NRR PA0 (2) SALP Reports Only Robert J. Bores, DRSS S. J. Collins, DRP
and B SBGTS trains is now downstream (bypassing) of the   l'
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calibrated orifice plat The flow recorded on the 'A'
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calibrated orifice plant would represent full system flow ter  ,
RI:DRSh[ RI S , RS Briggs 79cb Ke ilo
the specified lineu ~ Train 'B' logic requires A0N-106 damper (inlet) to open and    '
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pick up a position limit switch which allows the 'B' SBGTS fan to start and outlet damper A0N 112 to open. This logic sequence would occur during any start of the 'B' SBGTS train and was not-   ;
1//j/88 1/2,\/88 1 88 0FFICIA RECORD COPY RL PILGRIM 87-33 - 0002.0.0 01/11/88
checked in TP 87-12 The procedure did'not verify that per design the 'B' SBGTS    i train would remain running after 20 minutes if the 'A' train
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g sosrmmsm Executive Offices 800 Boylston street Boston, Massachusetts o2199.
 
Ralph G. Bird    December 21', 1987 senior Vice President - Nucle at BECo 'Ltr. #87 202
  .U.S. Nuclear Regulatory Commission Attention: Document Control Desk Hashington, DC 20555 License No. DPR-35 Docket No. 50-293 Subject: NRC Inspection Report 50-293/87-33
 
==Dear Sir:==
Attached is a revision of Boston Edison Company's response (BECo Ltr. #87-176, October 5,1987) to the Notice of Violation contained in the subject inspection report. Our response is revised as a result of clarifications obtained during a telephone conference between Boston Edison Company and NRC representatives on November 10, 1987.
 
Subsequent to the NRC Inspection 87-33, multiple communications with the NRC inspector occurred at our request.
 
These communications were necessary because inspection. we did not effectively communicate our position during the The need for effective communication and diligence in  )
investigating the appropriate inspectors'
membersconcerns in a timely manner has been reemphasized to of our staff.
 
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Please do not hesitate to contact me directly if you have any questions.
 
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      .G. Bird 1 BPL/la Regional Administrator, Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Sr. Resident Inspector
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. . ATTACHMENT
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Boston Edison Company  Docket No. 50-293 Pilgrim Nuclear Power Station  License No. OPR-35 Notice of Violation 10CFR50.54 (a)(1), requires each nuclear power plant licensee subject to the Quality Assurance Criteria in 10CFR50, Appendix B, to implement pursuant to 10CFR50.34(b)(6)(ii), the quality assurance program described or referenced in the Safety Analysis Report, including changes to that report.
Boston Edison Company Quality Assurance Manual (BEQAM) Volume II implements the requirements of 10CFR50, Appendix B. BEQAM, Section 6, Document Control, requires that measures be established to assure that documents affecting quality are reviewed for adequacy and approved for release by authorized personnel.
Contrary to the above on August 6,1987, it was determined that Plant Design Change (PDC) 86-70, Standby Gas Treatment System Modification, had been reviewed, released and implemented but did not completely specify design verification testing requirements as required by BEQAM, Section,3, Paragraph 3.3.2.8., specifically electrical functional and logic testing requirements.
In addition, Temporary Procedure 87-128, Preoperational Test of Standby Gas Treatment System (SBGTS) Modification Per PDC 86-70 was reviewed, approved and released for performance on July 22, 1987 and contained several errors and did not verify all design aspects of PDC 86-70. Specifically, neither the formal l review process of PDC 86-70, nor the formal review of TP 87-128 identified the missing testing requirements of the PDC or the failure of the TP to fully l verify the SBGTS modified design. l Resoonse Discussion:
On November 10, 1987, Boston Edison Co. management personnel contacted NRC Region I management personnel via telecon to provide further explanation of the position described in our initial response to the Notice of Violation dated October 5, 1987. This dialogue enhanced our understanding of the basis for the Notice of Violation.
He concur with the inspector's general concerns regarding the adequacy of reviews and the need to more completely specify preoperational testing requirements in Plant Design Change packages. During the telephone conference, however, it was agreed that the perceived errors in TP87-128, identifled in Sections 2.2.B", 2.2.0 and 2.2.E'of the Inspection Report, were not errors. Although it was agreed that the error identified in Section 2.2.A of the inspection report would have been identified during the conduct of the test, it was also agreed that errors of this nature could be eliminated by a more thorough technical review. Agreement was not achieved regarding the perceived error identified in Section 2.2.C"of the Inspection Report, as we continue to believe that a cognizant inclusion of an unnecessary procedural step is not an error.
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ATTACHMENT 1 (Cont.)
, The errors in TP 87-128 were identified by the inspector prior to the implementation of the preoperational test. During the conduct of a preoperational test, the test is halted if a discrepancy is identified.
The discrepancy must be resolved and the procedure reviewed prior to.
continuing the test. This conservative testing philosophy, in combination with the multiple levels of review and verification associated with the plant modification process, provide assurance against the possibility of errors in the final product. However, we recognize that the propensity to rely on the process, as opposed to assuring that the job is done right at each step in the process, must be guarded against.
Cause:
The errors identified in TP87-128 were a result of a lack of a thorough technical review by independent reviewers. These reviews may have resulted from a substantial increase in individual work load in support of the plant outage. In particular, procedure reviewers are normally selected from the line organization based on their technical expertise.
These line organization reviewers have concurrent managerial and/or technical responsibilities. Although the need to take the time to do the job right the first time has been repetitively communicated by senior BECo management, a cituation of conflicting priorities may have resulted in a less thorough preoperational test review than desired.
The incomplete specification of electrical functional and logic testing requirements in PDC 86-70 resulted from a lack of procedural definition or other guidance regarding the level of detail required to be specified in a PDC. Because of this lack of guidance, the level of detail of testing requirements specified in PDC's has been inconsistent. He believe this situation developed in part because of the demonstrated ability of the Modification Management Group's personnel to prepare preoperational tests with limited direction from the Nuclear Engineering Department.
Corrective Actions Taken:
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The Nuclear Engineering Department issued Technical Quality Memo (TQM) No. 92 on August 19, 1987 to reemphasize to engineering personnel the responsibility to clearly specify testing and acceptance requirements in Plant Design Change packages.
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The Design Review Board (DRB) members have been specifically reinstructed concerning their responsibility to assure PDC packages contain complete preoperational testing requirements. The DRB members are comprised of the engineering discipline Group Leaders who are responsible for the performance of engineers performing design functions for Pilgrim Nuclear Power Station.
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Temporary Procedure (TP) 87-128 has been revised to correct the identified discrepancies. TP87-128 Revision 3 was completed on August 29, 1987.
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. ATTACHMENT 1 (Cont.)
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The Modifications Management Group of the Nuclear Operations Department has established a three man team to conduct independent reviews of the preoperational test for the duration of RF0 No. 7.
This review tean has no other concurrent responsibilities and '
provides additional assurance that the large number of modifications implemented during RF0 No.7 receive thorough reviews.
l Corrective Steps To Be Taken:      j
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As comitted in TQM No. 92, NED procedures will be revised to specify
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the level of detail required for preoperational testing requirements in PDC packages.
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p h-l had. insufficient flow or.was tripped with the 'B'. train in standby, The system is designed to trip the 'B' train after  20 minutes if sufficient flow exist The inspector discussed the above items with the licensee and reviewed the other TPs and PDCs identified in Paragraph 2.1 abov It_was. observed that the other PDCs provided a more defined level of testing requirements. PDC 86-70 did not specify any electrical or logic checks while PDC 85-59 and 82-25 did. The inspector noted that the Boston Edison Quality Assurance Manual-(BEQAM) Paragraph 3.3. and 3.3.2.8 specifically requires the cognizant design organization, in this case Boston Edison Nuclear Engineering Department (NED), to specify acceptance criteria and methods for verifying' design changes,
A process is being developed (proceduralized) to require comments from the station review of PDC packages to be collected by the  ;
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Modification Management Group and sent to the Nuclear Engineering   1 Department (NED) for disposition prior to approval by the Operations  l Review Committee. This process will provide feedback to the NED on PDCs released to the station.
such as qualification testin It was also noted that the Modifications Management Work Instruction Manual (MMWIM), dated January 12, 1987, in Section 10 requires the Maintenance Modification Group (MMG) to determine preoperational
 
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The results of the three man team's independent review of the   !
preoperational tests prepared during RF0 No. 7 will be evaluated to  I allow incorporation of lessons learned to the preoperational test review process if appropriate.
 
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Date of Full Compliance:      j Full compliance was achieved on August 29, 1987 when TP87-128 Revision 3  l was completed.
testing (POT) requirements and to prepare POTS to satisfy all aspects of required testin The inspector also observed that throughout the. entire review chain for this' PDC and TP that these deficiencies (lack of specified testing required to verify design and PMPT errors) were not identified and corrected. The licensee as part of their immediate correc+ive action statect that an independent, 3 man review group will be established, with no concurrent duties, to review PMPT's initiated for implementation during this outage .
The review of the remaining PMPT's did not'ider.tify any procedural deviations from the system design as described in the PD .3 Findings The above examples relative to PDC 86-70 and TP 87-128 constitute a violation of the requirements of 10 CFR 50 Appendix B, Criterion VI and BEQAM, Section 6, Document Control, for failure to perform an adequate review (293/87-33-01).


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3.0 QA/QC Interface with Post Modification Testing 3.1 Scope The inspector requested all QC inspection reports (QCIR) associated with PDC 86-70 (SBGTS) and 82-25 (Recirculation Pump) which were implemented under maintenance requests 87-48-12 (SBGTS) and 86-2-49    j and 86-2-50 (Recirculation Pump). The following QCIR's were      j provided the inspector. They primarily deal with the installation    of i the modifications since testing of the modifications were in the     l very early stages during this inspection,      i
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I BOSTON EDISON  \
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Ralph G. Bird  October 5, 1987 semor Vice Presioent - Nuoear BECo Ltr. #87-176 l U.S. Nuclear Regulatory Commission Attention: Document Control Desk Hashington, DC 20555 License No. DPR-35 Docket No. 50-293 Subject: NRC Inspection Report 50-293/87-33


==Dear Sir:==
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Attached is Boston Edison Company's response to the Notice of Violation contained in the subject inspection report.
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Based upon our review and investigation of the matters described in the subject inspection report, we do not believe a Violation is appropriate. The basis for this position is described in the Attachment to this letter. A meeting with the appropriate level of NRC management has been requested to allow further explanation of our position and the reasons we believe that the Notice of Violation should be withdrawn.
 
Please feel free to contact either myself or Mr. Robert Grazio (Telephone 617-747-8189) if you have any questions.
 
[R.G. Bird
    $Q BPL/la Regional Administrator, Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Sr. Resident Inspector
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ATTACHHEMI Boston Edison Company  Docket No. 50-293
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Pilgrim Nuclear Power Station  License No. DPR-35 Notice of Violatiqn 10CFR50.54 (a)(1), requires each nuclear power plant licensee subject to the Quality Assurance Criteria in 10CFR50, Appendix B, to implement pursuant to 10CFR50.34(b)(6)(ii), the quality assurance program described or referenced in the Safety Analysis Report, including changes to that report.
 
Boston Edison Company Quality Assurance Manual (BEQAM) Volume II implements the requirements of 10CFR50, Appendix B. BEQAM, Section 6, Document Control, requires that measures be established to assure that documents affecting quality are reviewed for adequacy and approved for release by authorized personnel.
 
Contrary to the above on August 6, 1987, it was determined that Plant Design Change (PDC) 86-70, Standby Gas Treatment System Modification, had been reviewed, released and implemented but did not completely specify design verification testing requirements as required by BEQAM, Section 3, Paragraph 3.3.2.8., specifically electrical functional and logic testing requirements.
 
In addition, Temporary Procedure 87-128, Preoperational Test of Standby Gas Treatment System (SBGTS) Modification Per PDC 86-70 was reviewed, approved and released for performance on July 22, 1987 and contained several errors and did l not verify all design aspects of PDC 86-70. Specifically, neither the formal review process of PDC 86-70, nor the formal review of TP 87-128 identified the missing testing requirements of the PDC or the failure of the TP to fully verify the SBGTS modified design.
 
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Resoonse Boston Edison believes that Plant Design Change (PDC) 86-70 and Temporary Procedure (TP) 87-128 were prepared, reviewed, approved, released and implemented in compliance with the requirements of 10 CFR Part 50, Appendix B and the Boston Edison Quality Assurance Manual (BEQAM). He have, however, implemented actions described at the end of this response to further strengthen the PDC testing process.
 
Discussion:
The subject Notice of Violation identifies three issues as follows:
1. PDC 86-70 did not completely specify design verification testing requirements as required by BEQAM, Section 3, Paragraph 3.3.2.8, specifically, electrical functional and logic testing requirements.
 
2. TP 87-128 contained several errors and did not verify all design aspects of PDC 86-70.


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i 3.2 Discussion
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ATTACHMENT (Centd
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3. The review requirements of 10CFR50, Appendix B and SE0AM Volume II, Section 6, Document Control were not fully implemented as
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evidenced by issue (1) and (2) above.
 
The balance of this discussion is formatted to address each of these issues.
 
Issue 1 - Design Verification Requirements:
Qualification testing is one of the BEQAM approved methods for performing design verification, but was not chosen for PDC 86-70.
 
Instead, PDC 86-70 was verified using the design review method as permitted by the BEQAM.
 
The PDC received multiple levels of review and approval including independent, interdisciplinary and Quality Assurance Department reviews and approvals. In addition, calculations were made and independently reviewed to support the design. The multiple reviews and calculations verified the adequacy of the design and satisfied the requirements of BEQAM Paragraph 3.3.2.8. The reviews and calculations are documented in the PDC package. Qualification testing was not used as a verification method for this PDC.
 
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Our plant design change procedures require that preoperational test requirements and acceptance criteria are specified in the PDC. The preoperational test TP 87-128 was prepared to verify the functions of the SBGTS for the different modes of operation. The requirements of Section 3.3.2.8 of the BEQAM do not apply to TP 87-128 since it is not a design verification test.
 
Section 10.4.2.27 of the work instruction for PDC 86-70 specifies the testing requirements for the logic portion of the PDC and identifies the required calibrations. Sections 10.5.19 and 11.4 of the work instruction specified the acceptance tests required for electrical equipment. The level of detail specified in these sections of the PDC was adequate to assure that the SBGTS functions were verified.
:1 Issue 2 - Alleged Errors Our responses to the specific discrepancies identified in Section 2.2 of the Inspection Report follow.
 
Section 2.2.A states,
  "Paragraphs 7.2.5, 7.3.5 and 7.4.5 required 5 damper control switches to be in the auto position and their associated dampers in the open position. The associated dampers would be in the closed position with the specified switch position and no initiation signal present."
 
Response:
Although the procedure was in error as stated the errors would have been identified during the conduct of the test as follows:
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If the dampers were wired correctly, discrepancies between the observed damper positions and the damper positions specified in TP 87-128 would have been apparent.
 
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ATTACHMENT (Cont.)
 
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Only two of the five dampers were affected by the modi fication. If those two dampers affected by the
QCIR 87-048-12A, Instrument Calibration (SBGTS) performed July 22, The QC inspector witnessed calibration of 2 separate
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modification were wired incorrectly, a discrepancy between the modified dampers and non-modified dampers would have been apparent.
1987 instrument loops being performed in accordance with an approved  )
 
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procedure and also verified calibration status of all test equipment being use No deficiencies were noted by the QC inspecto QCIR 87-980, verification of correct installation of switch 42.1426-CS (SBGTS B train fan) performed August 2,1987. The QC inspector observed that the switch was installed in accordance with the PD )
In either case, TP 87-128 specified the correct damper positions in Attachment E, Steps El thru E20. Therefore, if the discrepancies had not been previously identified, they would have been identified in these steps.
 
Procedure 1.3.4 "Procedures" defines the process by which procedures are revised when errors are identified. Prior to completion of the test, the discrepancy would have been resolved and TP 87-128 would have been corrected.
 
Section 2.2.8 states,
"Section 7.3.8 and 7.3.8.9 did not require verification that valve AON-112 closed when the 'B' Standby Gas Treatment System (SBGTS) fan tripped (per procedure). Inlet valve A0N-106 was verified as closing."
 
Response:
A0N-112 was verified to close during previous steps in the procedure which tested major portions of the circuit. Steps 7.3.8 and 7.3.8.9 tested discrete portions of the circuit that feed the previously tested A0N-112 circuit. Those portions of the circuit were verified to be functional by these steps. This overlapping test method adequately demonstrates functionality of the subject valve.
 
Section 2.2.C states,
"Paragraph 7.3.8.6 required the differential pressure across the calibrated perforated plate (DPI-AA-32) in the 'B' SBGTS train to be recorded with the 'B' SBGTS in standby (off). This reading was being taken to measure 'B' train bypass flow so it could be combined with 'A' train to determine system flow.
 
Under the system conditions specified this reading would be zero (0) since one of the SBGTS modifications moved the upstream i bypass flow connection such that the connection between the A l and B SBGTS trains is now downstream (bypassing) of the l calibrated orifice plate. The flow recorded on the 'A' i calibrated orifice plate would represent full system flow for the specified lineup."  J l
Response:    j Recording flow through the standby train of the SBGTS was recognized as not being required in the draft review of the procedure. It was determined that the reading should be left in the procedure based on the following:
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Analysis of the data can be used to show no flow through the standby train when there should be no flow. This would reflect the integrity of the standby train inlet damper.
QCIR 87-14, Surveillance of the drilling of anchor bolt holes for hangers on the 41 foot 6 inch elevation of the reactor building, performed on January 6, 198 No discrepancies were observed by the QC inspecto QCIR's 87-75 and 87-81 concerned the witnessing of cables being pulled into the cable spreading room and into the control roo They were performed on January 27 and 28, 1987. No discrepancies were observed by the QC inspecto .3 Findings No violations were identified in the above revie .0 Independent Verification During the review discussed in Paragraph 2.2 the inspector independently calculated the various voltages required to give the desired vibration readings during the recirculation pump vibration monitor calibration check in TP 86-95. The inspectors calculations agreed with those contained in the procedur .0 Plant Tours The inspector toured various areas of the facility to assess plant and equipment conditions including cleanliness, fire hazards and work in progres No unacceptable conditions were observe .0 Exit Interview At the conclusion of the site inspection, on August 7, 1987, an exit interview was conducted with the licensee's senior site representatives (denoted iri Section 1). The findings were identified and inspection items were discusse _____-  __ -


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ATTACHMENT (Cont.)
 
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Reading standby train flow is of no consequence to the test performance or results.
 
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Section 2.2.0 states,
  "Train 'B' logic requires AON-106 damper (inlet) to open and pick up a position limit switch which allows the 'B' SBGTS fan to start and outlet damper A0N-112 to open. This logic sequence would occur during any start of the 'B' SBGTS train and was not checked in TP 87-128."
 
Response:
Although the logic sequence was not verified, the component functions were verified to occur. The actuation logic for this series of functions is as follows. A0N-106 opens which operates a limit switch starting the fan. A contact on the fan motor starter relay causes AON-il2 to open. This sequence was modified by the design. However, numerous independent wiring errors in several locations would be required for the components to function in other than the desired sequence. Design verification and construction verification, including QC verification of the as-built versus design configuration, provided assurance that the system wiring was correct.
 
Verification of the logic sequence was considered redundant.
 
Section 2.2.E states,
  "The procedure did not verify that per design the 'B' S8GTS train would remain running after 20 minutes if the 'A' train had insufficient flow or was tripped with the 'B' train in standby.
 
The system is designed to trip the 'B' train after 20 minutes if sufficient flow exists."
 
Response:    .
The design sequence of operation following auto initiation of the SBGTS is as follows:
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Both 'A' and 'B' SBGTS trains start.
 
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After 20 minutes of operation the standby ('B') train shutsdown, i
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If insufficient flow or no flow (' A' SBGT fan tripped) is !
sensed, the standby ('B') train reinitiates after a 10 l second time delay and locks in for a continuous run. !
Section 7.3 of TP 87-128 properly demonstrated these functions.
 
This was discussed in detail with the inspector subsequent to the inspection. l Issue 3 - Review Requirements:    '
10CFR50 Appendix B. Criterion VI and BEQAM Section 6, require that i document control measures be established to control issue and i revision of documents which prescribe activities affecting quality. l These measures assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel.
 
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ATTACHMENT (Cont.)  ;
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Both PDC 86-70 and TP 87-128 were reviewed and approved in accordance with approved BECO procedures. These procedures require multiple
, reviews and approvals that were fully documented in TP 87-128 and PDC 86-70. Based upon our response contained herein, we.believe that adequate reviews of both FCC 86-70 and TP B7-128 were performed.


Additional Actions:  ,
At no time during this inspection was written material provided to the licensee by the inspector. Based on the NRC Region I review of this report and discussions held with licensae representatives during this inspection, it was determined that this report does not contain information subject to 10 CFR 2.790 restriction x l
The following additional actions have been taken or are planned to further strengthen the PDC process:
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As immediate action the Nuclear Engineering Department issued Technical Quality Memo No. 92 on August 19, 1987, to reemphasize to engineering personnel the responsibility to clearly specify testing and acceptance requirements, in Plant Design Change packages. As committed in memo No. 92 NED procedures applicable to design verification testing will be revised to-clarify existing requirements.


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Temporary Procedure (TP) 87-128 has been revised to correct the identified discrepancies. TP 87-128 Revision 3 was completed on
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i August 29, 1987.
 
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The Modifications Management Group of the Nuclear Operations Department has established a three man team to conduct independent reviews of the preoperational tests for the duration of RF0-7. This team provides additional assurance that the large number of modifications implemented during RF0 No. 7 receive a thorough review for preoperational testing requirements.
 
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Revision as of 02:11, 24 January 2021

Insp Rept 50-293/87-33 on 870803-07.Violations Noted.Major Areas Inspected:Post Mod Test Program Preoperational Test Procedure Review,Qa/Qc Interface w/post-mod Testing, Independent Verification & Plant Tours
ML20238A790
Person / Time
Site: Pilgrim
Issue date: 08/20/1987
From: Briggs L, Eselgroth P
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20238A760 List:
References
50-293-87-33, NUDOCS 8708310211
Download: ML20238A790 (6)
v • d • e


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U.S. NUCLEAR REGULATORY COMMISSION ,

REGION I l Report.N /87-33

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. Docket N License N DPR-35 Licensee: Boston Edison Company M/C Nuclear 800 Boylston Street-Boston, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station Inspection At: Plymouth, Massachusetts .I

. Inspection Conducted: August- 3-7, 1987 1 i

j Inspectorsi ~ 4M L. Briggs, laid Reactor Engineer, DRS 8 /.s70 / # 7 date Approved by: / J , 'f 82d[<f 7 P.'Eselgr ' , Chief, Test Programs Section / ddte 08, DRS j Inspection Summary: Inspection on August 3-7, 1987 (Inspection Report i No. 50-293/87-33)

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Areas Inspected: Routine unannounced inspection of the licensee's post I modification test program preoperational test procedure review, QA/QC interface with post modification testing, independent verification and plant tour Results: One violation was identified for failure to adequetely review a design package and its associated post maintenance preoperational test, , l Paragraph !

Note: For acronyms not defined refer to NUREG-0544 " Handbook of Acronyms and l Initialisms". j l

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8708310211 870821 PDR ADOCK 05000293 G PDR

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DETAILS A"

'1.'0PersonsContactfdc

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  • M.'Akhtar,< Modifications Management Group Leader
  • T. Beneduci, Senior Engineer, Modifications Management

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  • N. Brosee, Outage Manager-
  • R.,Grazio, FieM Engineering Sectinn Manager
  • P. Hamilton, Cortpliance Group Leader

, ' * S, Hudson," Operations'Section Manager-

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' B. Lunn, Compliance Engineer

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" J..Mattia, QA, Group Leader

' * A. Morisi,- @ pt and Turnover Section Mantger

>2 l * K. Roberts, Station Nnager i

  • .R. Schifone, QA k NRC ,

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  • fN. Blumburg, Chief, Operational Programs'Section
  • J. Lyash, Resident Inspector The inspector also contacted other memebers of the licensee'4 QA/QC and-technical stat ;

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  • Denotes those present at the August 7, 1987, exit meetin ~

2.0' Post Modification Preoperational Testing (PMPT). Procedure Review l 2.1 Scooe

./ The PMPT's and Plant Design Changes (PDC's) listed below were

" 4 a' reviewed in preparation for test witnessin The PMPT's were j ' reviewed for, technical and administrative adequacy and for

. ,. f, , verification that testing is planned to adequately satisfy a regulatory svidance and licensee commitment They were also

, reviewed to vsrify licensee review and approval, proper format, test F

' objectives, prerequisites, initial conditions, test data recording requirements and system return to normal. The PDC's were reviewed to determine what changes were made to the associated system and to provide a bases for the determination of PMPT scope necessary to s verify the system's modified desig 'f

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PDC 86-70, Standby Gas Treatment System Modification; j

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PDC 82-25, 011 and Vibration Alarms Modification on )

Recirculation Pump Motors;

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PDC 85-59, HPCI Exhaust Vacuum Breaker;

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TP 87-128, Pre-Operational Test of Standby Gas Treatment System Modification Per PDC 86-70, Revision 1, dated July 20, 1987; r

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TP 86-95, Pre-Operational Test.of Oil Level and Vibration System on the Recirculation Pumps, Revision ~1, dated June 11, 1987;'and,

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TP.87-88, HPCI. Vacuum Breaker Pre-Operational Test, Revision 0 1, (draft).

2.2 . Discussion During the review of TP 87-128 the inspector noted several areas of the. test procedure that were either in error or. did not' appear. to verify the design of the modified system. These items were discussed with one of the licensee's senior Modifications Management Group (MMG) engineer The' engineer and licensee management agreed with the inspector that the following errors / omissions should tave been identifie Paragraphs 7.'2.5, 7.3.5 and 7.4.5 required 5 damper control switches- to be in the. auto position and their associated dampers in the open position. The associated dampers would be in the closed position with'the specified switch position and no initiation signal present, Section 7.3.8.and 7.3.8.9-did' not require verification tha't.

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valve A0N-112 closed when the 'B'. Standby' Gas Treatment System-(SBGTS)-fan tripped (per procedure). Inlet valve A0N-106 was verified as closin Paragraph 7.3.8.6 required the differential pressure across the calibrated orifice plate'(DPI-AA-32) in the 'B' SBGTS train to be recorded with the 'B' SBGTS fan in standby (off). This reading was being taken to measure 'B' train bypass flow so it could be combined with 'A' train to determine system flo Under the system conditions specified this reading would be zero ,

(0) since one of the SBGTS modifications moved the upstream i bypass flow connection such that the connection between the A ,

and B SBGTS trains is now downstream (bypassing) of the l'

calibrated orifice plat The flow recorded on the 'A'

calibrated orifice plant would represent full system flow ter ,

the specified lineu ~ Train 'B' logic requires A0N-106 damper (inlet) to open and '

pick up a position limit switch which allows the 'B' SBGTS fan to start and outlet damper A0N 112 to open. This logic sequence would occur during any start of the 'B' SBGTS train and was not-  ;

checked in TP 87-12 The procedure did'not verify that per design the 'B' SBGTS i train would remain running after 20 minutes if the 'A' train

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p h-l had. insufficient flow or.was tripped with the 'B'. train in standby, The system is designed to trip the 'B' train after 20 minutes if sufficient flow exist The inspector discussed the above items with the licensee and reviewed the other TPs and PDCs identified in Paragraph 2.1 abov It_was. observed that the other PDCs provided a more defined level of testing requirements. PDC 86-70 did not specify any electrical or logic checks while PDC 85-59 and 82-25 did. The inspector noted that the Boston Edison Quality Assurance Manual-(BEQAM) Paragraph 3.3. and 3.3.2.8 specifically requires the cognizant design organization, in this case Boston Edison Nuclear Engineering Department (NED), to specify acceptance criteria and methods for verifying' design changes,

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such as qualification testin It was also noted that the Modifications Management Work Instruction Manual (MMWIM), dated January 12, 1987, in Section 10 requires the Maintenance Modification Group (MMG) to determine preoperational

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testing (POT) requirements and to prepare POTS to satisfy all aspects of required testin The inspector also observed that throughout the. entire review chain for this' PDC and TP that these deficiencies (lack of specified testing required to verify design and PMPT errors) were not identified and corrected. The licensee as part of their immediate correc+ive action statect that an independent, 3 man review group will be established, with no concurrent duties, to review PMPT's initiated for implementation during this outage .

The review of the remaining PMPT's did not'ider.tify any procedural deviations from the system design as described in the PD .3 Findings The above examples relative to PDC 86-70 and TP 87-128 constitute a violation of the requirements of 10 CFR 50 Appendix B, Criterion VI and BEQAM, Section 6, Document Control, for failure to perform an adequate review (293/87-33-01).

3.0 QA/QC Interface with Post Modification Testing 3.1 Scope The inspector requested all QC inspection reports (QCIR) associated with PDC 86-70 (SBGTS) and 82-25 (Recirculation Pump) which were implemented under maintenance requests 87-48-12 (SBGTS) and 86-2-49 j and 86-2-50 (Recirculation Pump). The following QCIR's were j provided the inspector. They primarily deal with the installation of i the modifications since testing of the modifications were in the l very early stages during this inspection, i

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QCIR 87-048-12A, Instrument Calibration (SBGTS) performed July 22, The QC inspector witnessed calibration of 2 separate

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1987 instrument loops being performed in accordance with an approved )

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procedure and also verified calibration status of all test equipment being use No deficiencies were noted by the QC inspecto QCIR 87-980, verification of correct installation of switch 42.1426-CS (SBGTS B train fan) performed August 2,1987. The QC inspector observed that the switch was installed in accordance with the PD )

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QCIR 87-14, Surveillance of the drilling of anchor bolt holes for hangers on the 41 foot 6 inch elevation of the reactor building, performed on January 6, 198 No discrepancies were observed by the QC inspecto QCIR's 87-75 and 87-81 concerned the witnessing of cables being pulled into the cable spreading room and into the control roo They were performed on January 27 and 28, 1987. No discrepancies were observed by the QC inspecto .3 Findings No violations were identified in the above revie .0 Independent Verification During the review discussed in Paragraph 2.2 the inspector independently calculated the various voltages required to give the desired vibration readings during the recirculation pump vibration monitor calibration check in TP 86-95. The inspectors calculations agreed with those contained in the procedur .0 Plant Tours The inspector toured various areas of the facility to assess plant and equipment conditions including cleanliness, fire hazards and work in progres No unacceptable conditions were observe .0 Exit Interview At the conclusion of the site inspection, on August 7, 1987, an exit interview was conducted with the licensee's senior site representatives (denoted iri Section 1). The findings were identified and inspection items were discusse _____- __ -

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At no time during this inspection was written material provided to the licensee by the inspector. Based on the NRC Region I review of this report and discussions held with licensae representatives during this inspection, it was determined that this report does not contain information subject to 10 CFR 2.790 restriction x l

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