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| | number = ML20207S788 | | | number = ML20236T269 |
| | issue date = 03/06/1987 | | | issue date = 11/20/1987 |
| | title = Insp Rept 50-293/87-04 on 870112-16.Violations Noted: Inadequate Surveillance Test of Standby Gas Treatment Sys, Inadequate Test Program Procedures & Failure to Evaluate Effects of Out of Calibr Test Equipment | | | title = Ack Receipt of 870409 & 0608 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/87-04. Violation B Withdrawn Based on Results of Further Review,Per Util 870608 Request |
| | author name = Bissett P, Blumberg N, Evans M | | | author name = Johnston W |
| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | | | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| | addressee name = | | | addressee name = Bird R |
| | addressee affiliation = | | | addressee affiliation = BOSTON EDISON CO. |
| | docket = 05000293 | | | docket = 05000293 |
| | license number = | | | license number = |
| | contact person = | | | contact person = |
| | document report number = 50-293-87-04, 50-293-87-4, NUDOCS 8703200271 | | | document report number = NUDOCS 8712010103 |
| | package number = ML20207S763
| | | document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE |
| | document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | | | page count = 2 |
| | page count = 18 | |
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| | NOV 2 01987 |
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| | Docket N Boston Edison Company ATTN: Ralph G. Bird , |
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| | Senior Vice President - Nuclear 1 800 Boylston Street Boston, Massachusetts 02199 Gentlemen: |
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| | Subject: Inspection No. 50-293/87-04 l This refers to your letters dated April 9 and June, 8,1987, in response to our letter dated March 10, 198 l Thank you for informing us of those preventive and corrective actions taken for violations A, C and D as documented in your letter of April 9, 198 These actions were subsequently reviewed by us during inspections 50-293/87-37 and 50-293/87-41 and found to be sati s f actor In regard to violation B, as requested in your letter of June 8, 1987, we have withdrawn the Notice of Violation (50-293/87-04-04) based upon the results of a further review of this matter which is documented in Inspection Report 50-293/87-4 Your cooperation with us is appreciate |
| U.S. NUCLEAR REGULATORY COMMISSION
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| , REGION I
| | Sincerely, E C EI6 M. c r.t.! r William V. Johnston, Acting Director Division of Reactor Safety I |
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| | /p[$f 8712010103 871120 PDR ADOCK 05000293 G PDR |
| Report N /87-04 Jocket'No. 50-293
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| | OFFICIAL RECORD COPY RL PILGRIM 87-04 - 0001. /06/87 |
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| v' L'ic'et;.te N DPR-35
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| Licenge: Boston Edison Company 800 Boylston Street
| | Boston Edison Company 2 d |
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| Boston, Massachusetts 02199
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| | l K. P. Roberts, Nuclear Operations Manager l |
| FaciTfty Name: Pilgrim Nuclear Power Station
| | Paul Levy, Chairman, Department of Public Utilities i Chairr..an, Board of Selectmen Plymouth Civil Defense Director J. D. Keyes, Boston Edison Regulatory Affairs and Programs E. D. Robinson, Nuclear Information Manager R. N. Swanson, Nuclear Engineering Department Manager |
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| Inspection At: Plymouth, Massachusetts
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| Inspection Conducted: January 12-16, 1987
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| | The Honorable E. J. Markey Senator Edward P. Kirby The Honorable Peter V. Forman Sharon Pollard, Secretary of Energy Resources Peter W. Agnes, Assistant Secretary of Public Safety, Commonwealth of Massachusetts Rachel Shimshak, MASSPIRG Public Document Room (PDR) |
| | Local Public Document Room (LPDR) |
| | Nuclear Safety Information Center (NSIC) |
| | NRC Resident Inspector Commonwealth of Massachusetts (2) |
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| | Region I Docket Room (with concurrences) |
| | Management Assistant, DRMA (w/o encl) |
| | Section Chief, DRP R. Wessman, PM, NRR Robert J. Bores, DRSS T.Du(lt? |
| | h RI:DRS U t-RI:DRS ( |
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| | h RI:DRP Bissett Blumberg @Gaflo .GnBlough r id///87 1h/ l /87 16/h87 1D/3 /87 16/ /87 0FFICIAL RECORD COPY RL PILGRIM 87-04 - 0002. /28/87 |
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| ) P.1 1ssett,-Reactor Engtheer, DRS | | . 800 Boylston Street Boston. Massachusetts 02199 Ralph G. Bird June; 8, 1987 senior vice P esident- Nuclear BECo Ltr. '#87-98 Document Control-Desk U.S. Nuclear Regulatory Commission Washington, D..C. 20555 Docket No. 50-293 License No. DPR-35 Subject: :NRC Inspection Report 50-293/87-04 |
| , k.$AW M. Evans, Reactor Engineer, DRS da'te
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| | ' Reference': Boston Edison Company Letter Number 87-56 |
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| [ Approved by: -( $ 7 Dr. P. K. Eapen, Chief, Quality Assurance ' d4te Section, OPB, DRS Inspection Summary: Routine, Unannounced Inspection on January 12-16, 1987, Report No. 50-293/87-0 Areas Inspected: Routine unannounced inspection of licensee action on previous inspection findings, the surveillance testing program, instrument calibration, measurement and test equipment, new refueling bridge pre-operational testing and post modification surveillances, refueling bridge post modification training, surveillance testing for refueling operations and QA/QC interface The insyction was performed on site by three region-based inspector Results: Fode violation were identified: (1) Inadequate surveillance test of 3 the gSBGT system _ (para. 3.3.1); (2) Inadequate test program procedures (para
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| , f .3f3, 5.3.2 and 6.3.2); (3) Failure to evaluate the effects of out of i , calkbration test equipment (para. 5.3.1); and (4) Failure to properly implement 4 (s and maintain a test procedure (para. 6.3.2).
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| Y s :
| | ==Dear Sir:== |
| 8703200271 870399
| | Attached is Boston Edison Company's response to Notice of Violation B' |
| , PDR ADOCK 05000293 G PDR s , | | ; |
| | , contained in the subject inspection repor On May 1, 1987, Boston Edison Company management representatives met with NRC management to obtain clarification of the Notice of Violation. As a result of meeting discussions, our conclusion is that the Notice of Violation was issued-because we did not effectively communicate our programs for test control'tm the inspector. The.need for effectiveness of communication and diligence in resolving inspector concerns in'a timely manner has been re-emphasized to the appropriate members of our staf We continue to believe that our test program elements meet the applicable ANSI-and BEQAM requirements'and based upon the information presented in the attachment to this letter, request that Notice of Violation B-be withdraw Please do not hesitate to contact me directly if you have any question .G EM/la Attachment-cc: Regional Administrator, Region 1 Director, Office of Inspection U.S. Nuclear Regulatory Commission ' and * Enforcement 631 Park Avenue , U.S. Nuclear Regulatory Commission King of Prussia, PA 19406 Washington, DC 20555 Senior Resident Inspector , |
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| | | ., ATTACHMENT 1 |
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| | Notice of Violation B |
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| .t? , , DETAILS ( ) 1.0.Pehso'nsContacted e $ Persons contacted are identified in Attachment A to this repor .0 ' Licensee Action Concerning iPrevious Inspection Findings
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| .1 y (Closed) Unresolved Item (50-293/84-28-05) - licensee to develop a Modification Management. Group , Work Instruction to establish the requirements for system walkdownsiby test directors prior to turnover from construction to preoperational testin !! , | |
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| ?,The inspector reviewed and discussed with the Modification Management Group Leader Section II of "the licensee's Modification Management Work Instruction Manual which describes'the requirements for system walkdowns prior to conducting any testing iof' the modified system. -The inspector noted that a checklist was provided -in the Work Instruction Manual to
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| document the findings, exceptions and ; system status identified during the
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| turnover process and prior to the commencement of preoperational testin The inspector also reviewed severa,1 completed and approved checklists for j
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| t four (4) modifications being conduc'ted during the'present plant outage and y verified proper documentation of the system turnover prior to start of f testing. This item is closed.,
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| 3.0 SurveillanceTestingPrograrrj a
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| t ' Scope and Criteria n' , , *
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| Y The licensee's surveillance test program was re' viewed for conformance y ,', to the following requirements:
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| 10 CFR 50, Appendix'B c a c
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| Pilgrim Station Technical Specifications (T.S.), Section 4, Surveillance Tests (Ph?S) ,
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| Regulatory Guide 1.33, Quality Assurance Program (Operation)
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| ANSI- N18.7-1976, Administrative Controls and Quality Assurance
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| for; the Operational Phase of Nuclerc, Power Plant PNPS, Final Safety Analysis Report 'NSAR)
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| Appropriate licenses administrative controls ~as listed in Attachment 8 to this repor '
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| e Emphasis in this inspection was placed on programmatic aspects of the
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| . , surveillance test program. Implementation was reviewed in the areas of instrument calibration (detailed in paragraph 4) and refueling
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| | 10CFR50, Appendix B, Criterion XI, requires that test programs be' establishe BECo Quality Assurance Manual (QAM), Volume II, Section 2, Quality Assurance Program, states that the QA program conform to ANSI N18.7-1976. ANSI N18.7-1976, paragraph 5.2.19, Test' Control states in part that "A test program shall be established to assure that testing required to' demonstrate that the item will perform satisfactotfly in service is identified and documented, and that testing is q performed in accordance with written test procedures which incorporate or' reference 1 the requirements and acceptance limits...The test program shall cover all required ' |
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| | tests including.... surveillance tests and tests which-demonstrate satisfactory. |
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| surveillances (detailed in paragraph 5),. The inspection included review of technical specifications, test procedures, test schedules, and interviews with licensee personne .2 Areas-Reviewed The licensee's surveillance test program, excluding the inservice testing of pumps and valves, was reviewed to ensure the following:
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| Programs were established for the overall control of surveillance, instrument, post-maintenance, and post modification testin A master test schedule for surveillance testing was establishe Mechanisms were established for the tracking of completed test Completed tests received proper review Test procedures were established for surveillance tests required by the Test procedures were established for each T.S. surveillance test requirement and accomplished T.S. objective Test schedules were being adhered to, and
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| Surveillance test frequencies were as specified in the .3 Findings 3. The inspector used a sample of approximately 30 separate Technical Specification surveillance requirements to determine if the licensee had established procedures to implement these requirements. For each surveillance test which must be performed on a regularly scheduled basis the licensee was required to provide a test which met that surveillance requiremen In one instance, the test provided by the licensee appeared to be inadequate to meet the requirement .7.8.1.a.(4) requires that, at least once every 18 months, each branch of the standby gas treatment (SBGT) system be automatically initiated and the SBGT fans operated at 4000 CFM 10% during this initiation. The 18 month tests used by the licensee (8.M.2-1.5.8.3 and 1.5.8.4) perform automatic initiation only but do not operate the fans. The licensee stated this was done because other tests were .
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| performed to check fan capacity. This T.S. specifically required an integrated operation, and the present test does not do thi Failure to adequately perform this surveillance is contrary to T.S. 4.7.B.1.a(4) and is considered a violation (50-293/87-04-01).
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| In the above review, the inspector observed that some procedures were unclear as to their objective Incon-sistencies were noted and the following additional weaknesses were observed:
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| T.S. sections were poorly reference In many cases the T.S. were not referenced at all or only the major paragraphs rather than subparagraphs were reference In addition, some referenced T.S. were incorrect or incomplete in that all requirements to be verified by the procedure were not referenced in the procedur Procedure formats varied. There were major inconsis-tencies on how information was presente Acceptance criteria were unclea At times, acceptance criteria did not clearly state how the requirement was satisfie Except as stated above there. were no instances identified where the. actual body of the test did not satisfy the T.S. requiremen The licensee recognized the need to improve surveillance test procedure Consultants are currently rewriting procedures; however, no commitment was given by the licensee as to the expected completion date of this projec The T.S. contains contingency surveillance requirement For example, SBGT filters must be sampled if they. are exposed to smoke, chemicals or paint fumes; the torus must be inspected if certain temperatures are reache These requirements did not appear to be in appropriate procedures (such as a precaution in the SBGT operating procedure or SBGT filter sampling procedure). The inspector expressed a concern that these requirements could be overlooked if not placed in appropriate procedures. The licensee acknowl-edged the inspectors comments; however no commitment was made to include these T.S. in procedures. The licensee further stated, that in a recent instance when a contingency occurred it was not overlooked.
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| Recently a consultant (who was hired by the licensee to
| | performance following plant maintenance and modification In addition, the BECo QAM', Section l'1, " Test Control", requires in part, that post work tests and periodic surveillance tests are performed by qualified personnel in accordance with written, approved test procedures, which identify all test prerequisites and environmental conditions which must be satisfied before-performing these tests; that Watch Engineer or his designee,' reviews and approves the' post,-work test data results; and that the N0D' Manager is responsible to assure that surveill,ance tests are performed when required, test results are evaluated, and test requirements are satisfie Contrary to the above, as of January 16, 1987, programs for performance of periodic surveillance tests and tests following performance of plant modifications or-maintenance had not been' adequately established in that there were no station administrative control procedures which addressed the following: |
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| | Overall mechanisms for control of specific test programs such as periodic surveillance tests, post maintenance tests, and post' modification tests. |
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| ensure that all T.S. surveillance tests were covered by a procedure) issued a report. This report was used by a licensee representative during this inspection to find procedures associated with each T.S. surveillance require-ment. The report pointed out problem areas to the if censee and made recommendation As of the date of this inspection, the licensee had not taken action to address the concerns of this report nor to validate the procedure vs. T.S. cross reference. At the exit interview on January 16, 1987, the licensee stated that action would be taken on this report in the near futur . Previous NRC inspections and licensee event reports have identified occasions where scheduled surveillance tests were missed. The inspector reviewed the licensee's method for scheduling tests and Procedure 1.8, " Master Surveillance Tracking Program." In addition, the inspector 4 held discussions with personnel who use, and input to, the master schedule; observed the mechanism by which tests are determined to have been complete Procedure 1.8, Revision 4, dated August 1984, appeared to be lacking in its instructions to personnel. During this inspection a planned revision, Revision 5, to 1.8 was issued which was more comprehensive in its detai Although basically acceptable, the inspector observed weaknesses in the program which could cause surveillance tests to be occasionally not performed. The mechanism for scheduling and tracking completed tests appeared to be cumbersome, inefficient and open to potential error The inspector made the following observations to the licensee:
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| There is no centralized control of surveillance testin Although there is a master schedule, each group controls its own surveillance test However, no group in the plant lias its own procedures for controlling its own test progra Although a computer controlled schedule is issued, its implementation is performed manually. Verification of completed tests is by initials on a copy of the computer schedule and depends on personnel from each section going to the Control Room Annex and initialing their completio Initials are transposed as much as 3 or 4 times. After the third transposition, entries are made to the compute This system is prone to !
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| The planning and scheduling group is informed of changes to the schedule by the groups which perform the test. If a change is not entered in the computer it could be overlooked. There is no positive feedback to the group making the change that schedule changes have been actually mad Postponed tests or tests not applicable to the current mode are left on the weekly schedule for long periods of time. This leads to clutter on the schedule and potential errors with verification of completed test Each group maintains its own completed procedure There is no routine independent review (outside tne implementing group and other than sampling by QA) that tests have actually been completed. Test planners do not see completed tests but only initials on a schedul The licensee acknowledged the inspectors comments and stated that they recognized problems with the current method of scheduling. They also indicated that action was being taken to improve the current methods of scheduling and controlling surveillance test .3.3 Except for the Master Surveillance Test Schedule procedure, there appeared to be no administrative procedures for control of test programs. While licensee representatives were able to discuss mechanisms by which they control their surveillance test programs no administrative procedures were in plac In accordance with Station Procedure 1.8, each station group has the responsibility for performing their own surveillances. The lack of test programs was also observed in the areas of I&C calibration and post-modification testin ANSI Standard 18.7-1976, Paragraph 5.2.19, requires the establishment of program procedures for the conduct and control of surveillance test programs, post-maintenance testing, and post modification testin In addition, the BECO QAM, Section 11, requires that all tests be performed by qualified personnel; that approved test procedures be established; that test procedures identify all prerequi-sites and environmental conditions; that the Watch Engineer or his designee evaluate and approve post modification and post maintenance test results; and that the N0D Manager is responsible for the evaluation and approval of periodic surveillance test results. Although there is an adminis-trative control procedure for the scheduling of periodic
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| surveillance tests and for the preparation of periodic surveillance tests, other programmatic aspects were not included in procedures. Some examples of items should have been included but were not included:
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| Mechanisms for overall control and performance of test Definition of personnel qualified to perform test Methods by which prerequisites and environmental conditions are to be determine Specifications of personnel who are designated to approve and evaluate test result Definitions of the kinds of instruments to be included in the instrument and control surveillance test progra Methods by which acceptance criteria are properly specifie Journal for post maintenance and post modification test procedure Failure to establish an overall test program Administrative Control procedure is contrary to 10 CFR 50, Appendix B, Criterion XI; ANSI N18.7-1976, paragraph 5.2.19; and BECO QAM Section 11 and is considered a violation (50-293/
| | Methods by which prerequisites and environmental conditions are to be |
| 87-04-04).
| | ! determined and examples of suc Specification of personnel who are designated to approve and evaluate test results and assure that test requirements are satisfied. |
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| 4. Instrument Calibration 4.1 Scope and Criteria Refer to paragraph .2 Program Review / Implementation The inspector held discussions with Maintenance Group personnel to evaluate those controls in place used to identify, schedule, track, perform, and document calibration activities required by Technical Specifications (T.S.). Also reviewed were those controls in place that are used during the calibration of selected instrumentation that support the performance of T.S. related surveillance The majority of instrument calibrations are performed by the Instru-ment and Controls (I&C) section. The overall performance of the site
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| | Definitions of the kinds of instruments to be included in the instrument and control surveillance progra Methods by which acceptance criteria are properly specifie Format for post maintenance and post modification test procedure his is a Severity Level IV Violatio (Supplement 1) |
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| calibration program is controlled via the Master Surveillance Track-ing Program, thus calibration activities are designated as station surveillance requirements. Scheduling of calibration activities is controlled and documented through either weekly, monthly or semi-annual surveillance test schedules. Each station group and their respective sub groups are responsible for the performance of scheduled calibrations. This includes the development and updating of the data base, the performance, documentation and subsequent revisions of completed calibration Further discussions with Compliance and Administrative Group, Project Control Group, and Maintenance sub group personnel included a review of the following:
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| Weekly and monthly surveillance test schedules
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| Semi-annual Master Surveillance Tracking Program Test List Variance Reports / Priority Notice Reports, and Various surveillance procedures used during the performance of calibrations The inspector verified that calibration methods and associated l frequencies had been established for installed instrumentation used
| | Boston Edison's program for the implementation of the " test program" as |
| , during the performance of Technical Specification required surveillances. As with Technical Specification required calibra-
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| ! tions, these installed instrument calibrations are tracked, scheduled and performed under the Master Surveillance Tracking Program. The inspector selected four surveillance requirements associated with the
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| | described in ANSI N18.7-1976/ANS3.2 consists of administrative procedures, implementing procedures, and personnel selection and training processes. The various elements of the ANSI N18.7-1976/ANS3.2 " test program" and the BECo QAM, section 11, " Test Control" have been incorporated in the procedures associated with the work activity rather than a separate test control procedure. For example, post maintenance test specification, performance and approval are contained in Nuclear Operations Department Procedure 1. " Maintenance Requests" while the format and content of procedures is specified in Nuclear Operations Department Procedure 1.3.4 " Procedures". |
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| 1) Standby Liquid Control Syst.em; 2) Standby Gas Treatment System and the 3) Fire Protection System. This selection was made in order to provide assurance that 1) installed instrumentation required to support the completion of T.S. surveillances were included in the Master Surveillance Test Schedule, 2) required frequencies had been established, and 3) calibrations were being performe From the above selected surveillance requirements, the licensee was requested to provide the appropriate surveillance procedure number which documented the calibration of associated instrumentation used during the performance of these surveillance Subsequently, the inspector reviewed the appropriate surveillance procedures which documented the performance of these calibration The inspector also observed a performance of surveillance procedure 8.M.2.-l.1 " Primary Containment Isolation System - Reactor High Pressure" calibration and 8.M.2-2.10.2-16, " Low Pressure Coolant Injection Break Detection Logic Functional Test - Division A". NRC observation of these surveillances was conducted to verify that the following was accomplishe .
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| - | | Boston Edison has reviewed the concerns of the above Notice of Violation and the requirements of AN(I N18.7-1976/ANS3.2 section 5.2.19 " Test Control" and BECo 0AM section ll, "h st Control" as implemented by currently existing procedures and policie Boston Edison believes the test.progcam, as it currently exists, is in compliance with the aforementioned ANSI and BECo QAM requirement A point by point comparison of the specific concerns expressed in the Notice of Violation with the methods currently in use to sa'. fy the concerns is presented be]o , |
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| | -- Overall mechanisms for control of specific test programs.such as periodic surveillance tests, post maintenance tests, and post modification test Nuclear Operations Department Procedure 1.8 " Master Surveillance Tracking Program" controls the performance of periodic surveillance test The associated computer program provides the mechanism for scheduling performance of periodic surveillance test . |
| | Nuclear Operations Department Procedure 1.5.3 " Maintenance Requests" controls the performance of post maintenance testing. Provisions for designation of both maintenance related and Technical Specification operability related tests are contained in this procedur Nuclear Operations Procedure 83E1 " Control of Modifications to Pilgrim Station", Nuclear Operations Procedure 83A6 " Modification Management", and Nuclear Engineering Department Procedure 3.02 " Preparation, Review, Verification, Approval and Revision of Design Documents for Plant Design Changes" control post modification test Definition of personnel qualified to perform the subject test Personnel qualified to perform surveillance and post maintenance tests are determined through the detailed evaluation of previous job experience and specific job training which is performed by the Nuclear Training Departmen This information is posted in the maintenance shop areas for use by the supervisors in charge of the work activity to assist in the assignment of individuals to the particular maintenance tas Technical Specification surveillance and operability testing is also performed by l Nuclear Plant Operators and Reactor Operators who, by virtue of the training associated with their job descri'tten's, p are qualified to perform these tests.- . |
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| Applicable surveillance procedures were approved, up-to-date, and used throughout the conduct of the surveillanc *
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| Appropriate personnel were notified prior to the start of the tes *
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| Calibrated test equipment was use Acceptance criteria were met, and if not, appropriate corrective action was take *
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| Properly specified parts and materials were identified, and Following completion of the test, systems were aligned for normal operatio During the calibration of Reactor High Pressure sensor PS-261-23A,
| | ATTACHMENT 1 (Cont.)- |
| "As-Found" values were found to be out-of-tolerance. The Barksdale Switch adjustment cover and eventually the switch cover itself, had to be removed in order for the I&C technicians to make the necessary adjustment to bring the pressure sensor within the allowable operating rang Subsequent inspection of the environmentally qualified Barksdale switch cover plate gasket indicated the need for replacemen However, the I&C technicians were unable to obtain a new gasket because none were found in stock at the site. To provide assurance that the gasket is replaced a work order was generated against the pressure switch and the surveillance is not be considered complete until the new gasket is replace .3 Findings The inspector expressed some concern over the lack of programmatic controls for controlling calibration activitie This also applies to the calibration of installed instrumentation used to support Technical Specification surveillances. Only through discussions with various site personnel, was the inspector able to ascertain how the calibration program was controlled and conducted. This is an example of lack of programmatic controls contributing to the violation identified in paragraph 3.3.3. abov . Measurement and Test Equipment (M&TE)
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| 5.1 Scope and Criteria Refer to paragraphs .2 Program Review / Implementation The inspector held discussions with individuals designated to ad-
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| | - Test. Directors. Test. Directors are individuals whose qualifications meet |
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| | -- Methods by which prerequisites and environmental conditions are to be determine Surveillance and post maintenance test procedures are written per the- , |
| | I requirements of Nuclear Operations Department Procedure 1. " Procedures". Test procedures contain a section specifying prerequisites ! |
| | and environmental conditions, if applicable, which must be satisfied prior-to initiation of the tes Preoperational. test p'rocedures are written per the requirements of the i Modification Management Work Instruction Manual, section 1 " Modifications Management Preoperational Test Procedure Development". |
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| minister and control the site's measuring and test equipment. Con-trol of this program is designated in Procedure 1.3.36, " Measurement and Test Equipment". A review of this procedure governing the con-trol of M&TE was conducted and verified to ensure that the program was being implemented as intended. This verification included a review of the followin *
| | Test procedures contain a section specifying prerequisites and |
| Calibration records
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| Toolroom controls
| | environmental conditions, if applicable, which must be satisfied prior to J initiation of the tes { |
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| | -- Specification of personnel who are anignated to approve and evaluate test resul,ts a,nd assure .that test requirements are s~atisfie , |
| Equipment master list for I&C and Station Services
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| *
| | - The individ'ual surveillance test procedures specify the persons responsible for the evaluation and approval of test results. For example, 1 the Watch Engineer evaluates and approves Technical Specification surveillance test result ]3 |
| M&TE records
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| | 'The designation of personnel who evaluate and approve post maintenance test results.is contain'ed in Nuclear Operations Department Procedure 1. " Maintenance Requests" and in the individual test procedures. For |
| Staffing A tour of the tool rooms controlled by the I&C group and the Station Services Group and discussions with tool room attendants and their supervisors was conducted to verify that the storage and issuance of M&TE were being adequately controlle .3 Findings 5. Issuance and retrieval of all M&TE is handled by the toolroom attendant M&TE was adequately controlled through the utilization of calibration logs, history records and issuance log Equipment was found to be appropriately stored and identified. M&TE was found to fall into one of the following categories:
| | ~ example, the Watch Engineer evaluates and approves Technical Specification operability test result The' designation of personnel who evaluate and approve post modification |
| *
| | . test results is contained in Nuclear Operations Procedure 83A6 |
| Out for re-calibration
| | " Modification Management" and in the individur.1 preoperational tert procedures wri_tten in accordance with the Modification Management Work Instruction Manual, section 10.0 " Modification Management Preoperational 1' |
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| | Test Procedure Development". |
| Segregated (due for re-calibration or inoperable)
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| In-use, and
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| j Restricted use 5. During the inspectors review of past calibration records, it was determined that historical use evaluations for M&TE found to be out-of-calibration was not being performed as required by ANSI 18.7, and the PNPS M&TE Procedure 1.3.3 Over 18 instances were found where these evaluations were not completed by I&C and Station Service Much of the i problem with the Station Services group is attributable to their not following through with the evaluation by not contacting various groups to which were 'ssued evaluations for corrective action. This lack of followup and interface
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| resulted in the failure of the other groups to complete the necessary action I&C attributed their failure to com-plete these evaluations to staffing problem Failure to evaluate and document the effect of out-of-calibration test equipment on previously performed tests is contrary to ANSI N 18.7-1976, paragraph 5.2.16 and is considered a violation (50-293/87-04-02).
| | -- ' Definitions of the kinds of instruments to be included in the instrument and control surveillance progra .As clarified in our meeting, the inspector's concern was calibration of non-safety related, installed instrumentation, used to measure system parameters during the' performance of system test The calibration of installed plant instrumentation required to support the performance of tests is either performed as a step in the individual test procedure or periodically as controlled by the Master Surveillance Tracking Program. |
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| No other violations or deficiencies were observe .0 Refuel Bridge Modification and Preoperational Testing 6.1 Background and Purpose of the Inspection The refueling bridge at Pilgrim Station is a rolling hoist primarily to load new fuel into the reactor and remove the old fuel during refueling outage The previous refueling bridge had a long history of both mechanical and electrical equipment failur The bridge failures during previous refueling operations had caused considerable lost outage time while repairs were being made. In addition, the frame of the refueling bridge had been deformed and the controls were outdate Because of these problems, the licensee decided to replace the existing refueling bridge with a new BWR 6 refueling bridge. Some features of this new bridge include upgraded controls and drive mechanism, improved high capacity air supply and semiautomatic contro .
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| The purpose of this inspection was to verify that adequate preopera-
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| , tional testing of the new refueling bridge would be conducted prior to the operational use of the bridg In addition, the inspector reviewed the areas of post mcdification training and surveillance testing to determine that the licensee had adequately addressed these areas in regard to the refueling bridge modificatio .2 Criteria and Documents Reviewed See paragraph 3.2 and Attachments B and .3 Scope The inspector reviewed preoperational test procedures TP86-127 and TP86-182 for the refueling bridge. These procedures were reviewed in preparation for test witnessing, for technical and administrative adequacy and to independently verify that testing satisfied regulatory guidance and licensee commitments. They were also reviewed to verify licensee review and approval, proper format, test
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| objectives, prerequisites, initial conditions, test data recording requirements and system return to norma In addition, completed portions of TP86-127 were reviewed. No refueling bridge testing was conducted during this inspectio .4 Findings During the above review, the inspector verified that the refueling bridge interlocks described in the vendor's Instruction Manual IM-01620, appeared to be adequately tested in the preoperational test procedure However, during the review of TP86-127, Section 11,
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| " Traveling Safety Control Interlock", the inspector noted discrepan-cies in the refueling bridge positions for testing conducted in Zone II (canal joining spent fuel pool to reactor cavity area) and Zone III (spent fuel pool). These interlocks are provided to eliminate the possibility of the fuel grapple running into the wal Specifically, after review of TP86-127, Attachment D, figure 1, which shows the 3 zones in which the main hoist can travel, it appeared to the inspector that bridge position numbers identified in Section II, Zone II.b and Zone III.c. were incorrec The inspector discussed this concern with the licensee test director who had performed this portion of the procedure on October 8,198 The test director stated that the refueling bridge position numbers listed in the procedure were incorrect and that at the time he conducted the test he had intended to correct the procedur Instead, he performed this section of the test using the correct bridge position numbers and signed off the steps in the procedure as complete, but failed to change the bridge position numbers in the procedure and ensure that this was properly approve This constitutes a violation of Technical Specification 6.8.A for failure to properly implement and maintain the procedure (50-293/87-04-03).
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| In addition to the concerns addressed above, the inspector discussed the control of the conduct of the preoperational tests following modifications with various licensee representatives. The inspector found that no specific programmatic procedure which list the require-ments for such items as testing holds and failure to meet acceptance criteria during conduct of the test existe The absence of a procedure to control the conduct of preoperational testing is another example of the violation discussed in paragraph 3.3.3 abov .0 Refueling Bridge Post Modification Training The inspector discussed the training of licensee personnel concerning the refueling bridge modification with two licensee training representative They explained that training includes the following:
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| An on watch discussion with each licensed and unlicensed operator on the applicability and requirements of the documents listed in Attachment D, and
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| Hands-on training in the operation of the new refueling bridge for all licensed and unlicensed operator The licensee representatives explained that the on-watch discussions have already been conducted and the hands-on training will occur after the refueling bridge preoperational testing has been completed and the system turned over to operations. In addition, they noted that after the review of the procedures listed in Attachment D, all changes to the procedures as a result of the refueling bridge modification have been discussed with the operator No deficiencies were identified with regard to the' licensee's program for refueling bridge post modification trainin .0 Surveillance Testing for Refueling Operations 8.1 Scope and Criteria The inspector reviewed Procedure 4.3, " Fuel Handling", in order to verify that the licensee had identified the surveillance testing needed to be conducted prior to and during fuel loading / unloadin The inspector noted that Procedure 4.3 included attachments which identified the requirements for either specific systems to be operable or specific surveillance test procedures to be performe The inspector compared these attachments with the Technical Speci-fication requirements for fuel loading / unloading. See Paragraph and Attachment B for requirements and inspection criteri .2 Findings The inspector noted that the Control Room high efficiency air filtration system required to be operable per T.S. 3.7.B.2 was not addressed in Procedure The inspector questioned a licensee representative concerning this ite He stated that this item had been previously identified and was to be included in the next revision of the procedur The inspector reviewed a draft copy of the procedure revision and verified that the requirement for system operability was include In addition, during review of Procedure 4.3, the inspector noted that step 18, of Attachment OPER-10 identified surveillance testing to be conducted per T.S. Table 3. note 7. Step 18 specifically references three surveillance tests to be conducted. However, the surveillances for reactor mode switch in shutdown, manual scram and scram discharge volume high level are not referenced in this ste After discussion with the licensee representative, he committed to including a reference to these
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| surveillances in step 18 of OPER-1 No violations or other deficiencies were identifie .0 Quality Assurance / Quality Control (QA/QC) Interface The Quality Assurance group is represented on-site, along with Quality Control personne Thus, these independent groups are able to actively monitor on going station activitie Discussions were held with the Senior QA Engineer to ascertain QA's involvement with the site's calibration and surveillance program. It was noted that a QA surveillance program is in place to provide QA coverage of various site activities, including the performance of calibrations and surveillances. A review of completed QA surveillances within the area of calibration and surveil-lances, performed during the past 12 months indicates that QA's participation is adequate, for present staffing level Approximately 17 QA surveillance reports were reviewed by the inspector This review included the following:
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| Surveillance checklists Evaluation sheets
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| Nonconformance reports, if applicable Trending input sheets, and Department responses, if applicabl It was noted that QA personnel were identifying problems in areas such as procedure adherence, inadequate procedure content, and usage of out-of-calibration equipment. Station response and subsequent corrective action to the items reviewed appeared to be timely as noted during the inspector's review of the QA's weekly deficiency status repor .0 Management Meetings Licensee management was informed of the scope and purpose of the inspection at an entrance interview conducted on January 12, 1987. The findings of the inspection were periodically discussed with licensee representatives during the course of the inspectio An exit interview was conducted on January 16,1987 (see Attachment A attendees) at which time the findings of the inspection were presente At no time during this inspection was written material concerning inspection findings provided to the licensee by the inspector A subsequent telephone discussion concerning clarification of the inspection findings was conducted between the inspector and Mr. E. Graham on January 21, 198 . .
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| i ATTACHMENT A PERSONS CONTACTED Licensee
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| *M. Akhtar Group Leader - Modifications Management
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| *M. Brosee Maintenance Section Manager F. Famulari Quality Control (QC) Group Leader D. Gerlits Senior Nuclear Training Specialist F. Giardiello Compliance Engineer
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| *E. Graham Compliance Group Leader
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| *R. Grazio Field Engineering Section Manager P. Hamilton Compliance Engineer
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| *S. Hudson Operations Section Manager G. LaFond I&C Engineer E. Larson Senior QA Engineer
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| *P. Mastrangelo Chief Operations Engineer
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| *L. Mcdonald Nuclear Management Service Department Group Leader M. McGuire Electrical Engineer P. Moraites Assistant Chief Maintenance Engineer S. Musial Tool Management Supervisor A. Pederson Station Manager K. Roberts Director of Outage Management C. Santora Planning Analyst R. Schifone Compliance Engineer J. Serry R. Sherry Chief Maintenance Engineer D. Sukanek Station Services Group Leader J. Thompson Training Requalification Instructor J. Vender Mechanical Engineer D. Witecki I&C Senior Engineer (Quadrex)
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| S. Wollman Principal Operations Engineer
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| *E. Ziemanski Nuclear Management Services Section Manager The inspector also interviewed other licensee personnel including I&C Technician . USNRC M. McBride Senior Resident Inspector
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| *J. Lyash Resident Inspector
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| * Denotes those present at exit intervie d'
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| ATTACHMENT B
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| ' PROCEDURES REVIEWED FOR CONTROL OF SURVEILLANCE TESTING AND CALIBRATION
| | -- Methods by which acceptance criteria are properly specifie l |
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| 1.3.4 Procedures
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| 1.3.6 Adherence to Technical Specifications
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| -- 1.3.36 Measurement and Test Equipment
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| ~ - - Master Surveillance Tracking Program
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| '1.8.2 PM Tracking Program
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| 2.1.5 Daily Surveillance Log (Technical Specifications and Regulatory Agencies)
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| -- Fuel Handling
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| L ATTACHMENT C REFERENCES REVIEWED FOR CONTROL OF MODIFICATION AND TESTING OF THE REFUELING BRIDGE
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| Pilgrim Nuclear dawer Station (PNPS), Technical Specifications
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| PNPS, Final Safety Analysis Report (FSAR)
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| Nuclear Operatio1s Procedure 83A6 (N0P83A6), Modification Management, July 31, 198 Nuclear Operations Procedure 83E1 (N0P93EI), Control of Modifications to Pilgrim Station, September 17, 198 Nuclear Operations Department, PNPS, Procedure No. TP86-127, Preoperation-al Test for Refueling Bridge, Revision 6, January 7, 198 Nuclear Operations Department, PNPS, Procedure No. TP86-182, Preoperation-al Test for Refueling Bridge / Vessel Disassembled, Revision 0, January 3, 198 Instruction Manual IM-01620, Refueling Platform BECO, Pilgrim Station, P.O. No. 68521, Volume 1 of 2, Revision 0, February 25, 198 Safety Evaluation, PNPS, No. 2044, Approved January 6, 198 Modification Management Work Instruction Manual, Approved January 12, 198 :. -
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| ATTACHMENT D PROCEDURES AND DOCUMENTS INCLUDED IN REFUELING BRIDGE POST MODIFICATION TRAINING
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| Technical Specifications 3.10 " Core Alterations", and base Technical Specifications " Reactivity Control", and base PNPS Procedure "SNM Inventory and Transfer Control".
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| PNPS Procedure " Fuel Handling".
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| PNPS Procedure 5. " Refueling Floor High Radiation".
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| | ' ATTACHMENT 1-(Cont.) |
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| -- | | b, Surveillance and post maintenance test procedures are written and approved 14: _ per the requirements of Nuclear Operations Department Procedure:1.3.4, |
| PNPS Procedure 2.2.75 " Fuel Handling and Servicing Equipment".
| | " Procedures". Test procedures contain a section specifying test L acceptance criteri Reference documents used in the generation of the test. procedure (i.e.-Technical Specifications, Final Safety Analysis Report, Vendor. Manuals, design documents, etc.) supply information on specific' acceptance criteri Post modification test procedures are written per the requirements of the Modification. Management Work Instruction Manual, section 1 " Modification Management Preoperational Test Procedure Development". Test procedures.contain a section specifying test acceptance criteria. The l- specific acceptance criteria for inclusion in the test procedure are developed during the portion of the design process controlled by Nuclear Engineering Department Procedure 3.02'" Preparation, Review, Verification, Approval and Revision ~of Design Documents for Plant Design Changes". |
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| -- | | -- Format for post maintenance and post modification test procedures. |
| PNPS Procedure " Reactor Core Fuel Verification".
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| | t Post maintenance test procedures are written per the requirements of . , |
| PNPS Procedure 8.1 " Refueling Interlocks Functional through 8.1 Tests".
| | . Nuclear Operations Department Procedure 1.3.4 " Procedures" which. specifies. . ' |
| | j test'proced.ure forma ' |
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| | l Post modification test procedures are written per the requirements of the' |
| | Modification Management Work Instruction Manual, section 1 " Modifications _ Management Preoperational Test Procedure Development" which specifies test prccedure forma Boston Edison is currently' performing an extensive programmatic upgrade for the control of surveillance testing. This upgrade, scheduled for impicmentation and validation in June, 1987, will greatly ihcrease the l effectiveness of the current surveillance test progra The Master l Surveillance Tracking Program (MSTP) is being refined to; 1) provide a complete' cross reference between surveillance requirement and implementing l- surveillance test procedures, 2) provide for the scheduling of surveillance l tests which correspond to the operating condition of the plant, 3) provide the ability to schedule surveillance tests based upon plant system availability, 4) track the completion of surveillance tests in which portions of the test are completed at different points in time, and 5) provide for the designation of acceptance criteria. Most importantly, experienced technical personnel have been assigned to the administration and maintenance of the MST Thi will ensure the continuance of a high quality surveillance program under the cognizance of a single manager. Boston Edison will examine the elements of the post maintenance test program to determine which areas are in need of improvemen The program for post modification testing, as it currently e d sts, is effective and adequate To ensure that the appropriate management personnel are aware of the implementing procedures for the, various aspects"of the test program, our |
| | "Index of Procedures Per Criteria of ANSI N18.7-1976" is being updated and will be distribute Page 4 of 4 |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N8911999-10-15015 October 1999 Forwards Rept of Changes,Tests & Experiments at Pilgrim Nuclear Power Station for Period of 970422-990621,IAW 10CFR50.59(b).List of Changes Effecting Fsar,Encl ML20217D3951999-10-13013 October 1999 Forwards Request for Addl Info Re Util 990806 Submittal on USI A-46, Implementation Methodology Used at Pilgrim Nuclear Power Station, Per GL 87-02 ML20217E1581999-10-0808 October 1999 Forwards Insp Rept 50-293/99-05 on 990726-0905.Three Violations Noted & Being Treated as Ncvs.Violations Include Failure to Assure That Design Bases Correctly Translated Into Specifications ML20217C3151999-10-0606 October 1999 Forwards Scenario Package for Pilgrim Nuclear Power Station Nrc/Fema Evaluated Exercise Scheduled for 991207.Without Encl ML20217D5591999-10-0505 October 1999 Documents Pilgrim Nuclear Power Station Five Yr Survey of Main Breakwater.Survey Has Determined That Pilgrim Main Breakwater Is Intact & Remains Adequately Constructed to Perform Designed Safety Function ML20217C8051999-10-0505 October 1999 Forwards Proprietary Results of Audiologic Evaluations for Jp Giar,License SOP-10061-3.Attachment Clearly Shows Requirements for Operator Hearing Ability Are Met. Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML20212J8301999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Integrate Performance Info & to Plan Insp Activities at Facility Over Next Six Months ML20216J9961999-09-29029 September 1999 Forwards Resume of Person Identified as Acting RPM in Licensee to NRC Re Notification That Person Named in License Condition 11 of 20-07626-02,is No Longer Employed at Pilgrim Station.Resume Withheld,Per 10CFR2.790 ML20212F7871999-09-24024 September 1999 Advises That Util 990121 Application for Amend Being Treated as Withdrawn.Proposed Changes Would Have Modified Facility UFSAR Pertaining to Values for post-accident Containment Pressure Credited in Pilgrim Net Positive Head Analyses ML20212H1381999-09-23023 September 1999 Submits Info in Support of Request Filed on 990730 to Grant one-time Exemption from 10CFR50,App E,Authorizing Biennial Full Participation Emergency Preparedness Exercise to Be Conducted in 2002 Instead of 2001 ML20212H1441999-09-23023 September 1999 Withdraws 990121 Request for License Change Re Emergency Core Cooling Sys Net Positive Suction Head,Due to Incorrect Datum Preparation ML20212C2861999-09-16016 September 1999 Forwards SER Accepting Licensee 981123 Request for Relief RR-E1,RR-E5,RR-E6 Pursuant to 10CFR50.55a(a)(3)(i) & Request for Relief RR-E2,RR-E3 & RR-E4 Pursuant to 10CFR50.55a(a)(3)(ii) ML20216F3451999-09-16016 September 1999 Forwards Summary Rept Providing Results of ISI Conducted at PNPS on-line & Refueling Outage (RFO 12) ML20216E7111999-09-0909 September 1999 Forwards License Renewal Application Including Form NRC-398 & Form NRC-396 for Jp Giar,License SOP-10061-3.Without Encls ML20216E5891999-09-0707 September 1999 Forwards Copy of Pilgrim Station Organization Structure. Encl Refelcts Changes in Upper Mgt Level Structure.Changes Were Effective 990901 ML20211M4501999-09-0303 September 1999 Informs That Pilgrim Nuclear Power Station Plans to Conduct Full Participation Emergency Preparedness Exercise with Commonwealth of Ma on 991207,IAW 10CFR50,App E,Section IV.F.2 ML20211M9161999-08-31031 August 1999 Submits Review & Correction of Info in Reactor Vessel Integrity Database (Rvid),Version 2,re Pilgrim Station ML20211J8391999-08-30030 August 1999 Forwards Rev 1 to Provisional Decommissioning Trust Agreement for Plant,Changing Portions of Agreement to Permit Up to Two Distributions & Clarify Formula for Distribution ML20211H5701999-08-27027 August 1999 Forwards Insp Rept 50-293/99-04 on 990610-0725.Two Violations Identified Being Treated as non-cited Violations ML20211C3381999-08-19019 August 1999 Provides semi-annual LTP Update,Including Schedule, Commitment Descriptions,Progress Since Last Update & Summary of Changes.Rev Bars Indicate Changes in Status Since Last Submittal ML20210U7521999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opossing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U6691999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opposing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U5761999-08-18018 August 1999 Responds to Opposing Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts. Informs That for Sale,Nrc Responsible for Only Ensuring That Entergy Technically & Financially Qualified to Operate NPP ML20210U5151999-08-17017 August 1999 Forwards Notice of Withdrawal of Application for Approval of Indirect Transfer of FOL for Pilgrim in Response to .Approval No Longer Needed Since Beco Sold Interest in Pilgrim to EOI on 990713 ML20211B3841999-08-16016 August 1999 Forwards Response to NRC Second RAI Re Pressure Locking & Thermal Binding of SR power-operated Gate Valves ML20210U4831999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data Sheets for Period of 990101-0630,per 10CFR26.71(d) ML20210S0891999-08-0909 August 1999 Forwards Amend 11 to Indemnity Agreement B-48 Signed by Boston Edison Co & Entergy Nuclear Generation Co ML20210R6251999-08-0606 August 1999 Provides Supplementary Info on USI A-46 Implementation Methodology at Pilgrim Station,To Enable NRC to Perform Evaluation & Issuance of Plant Specific SER for Plant ML20210M9411999-08-0202 August 1999 Requests That NRC Treat Pending Actions Requested by Beco Prior to 990713,as Requests Made by Entergy.Ltr Requests That Minor Administrative Changes to License Amend 182 & Associated Ser, ,reflect 990713 Transfer ML20210H8761999-07-30030 July 1999 Requests That NRC Grant Exemption from Requirements of 10CFR50,App E,Section IV F,Which Would Authorize Rescheduling of 2001 Biennial Full Participation Emergency Preparedness Exercise for Pilgrim Station to 2002 ML20210H8661999-07-29029 July 1999 Provides Revised Response to GL 96-06 & Addresses NRC Insp Concern for Containment Penetration X-12.Info Submitted to Facilitate NRC Review & Closeout of Subject GL for Plant ML20216E2321999-07-26026 July 1999 Discusses GL 92-01,rev 1,suppl 1, Rv Structural Integrity. NRC Revised Info in Rvid & Releasing as Rvid Version 2 ML20216D4131999-07-22022 July 1999 Informs That J Conlon,License OP-11040-1,terminated Employment with Beco on 990703,per 10CFR50.74.Individual Will Not Participate in Util Licensed Operator Requalification Training Program ML20210E2231999-07-20020 July 1999 Discusses Arrangements Made by Dennis & M Santiago During 990615 Telephone Conversation for NRC to Inspect Licensed Operator Requalification Program at Pilgrim During Wk of 991004 ML20210C4151999-07-19019 July 1999 Informs That Util Intends to Submit Approx Eight Licensing Actions in FY00 & Eight in FY01,in Response to Administrative Ltr 99-02.Actions Are Not Expected to Generate Complex Reviews ML20210A9441999-07-14014 July 1999 Responds to Re Changes to Pilgrim Nuclear Power Station Physical Security Plan Identified as Issue 2,rev 14, Addendum 1,respectively.No NRC Approval Is Required IAW 10CFR54(p) ML20210F3711999-07-14014 July 1999 Informs NRC That Effective 990713,listed Pilgrim Station Security Plans Have Been Transferred from Boston Edison to Entergy & Are Still in Effect ML20209G2251999-07-0909 July 1999 Forwards Insp Rept 50-293/99-03 on 990419-0609.Five Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations,Consistent with App C. Several Individual Tagging Errors Occurred ML20209C4661999-07-0707 July 1999 Forwards SE Accepting Addendum on Proposed Change in Corporate Ownership Structure Involving Entergy Nuclear Generation Co ML20209C3851999-07-0606 July 1999 Forwards Redacted Draft of Decommissioning Trust Agreement Re Transfer of PNPS & NRC Operating License & Matls License from Boston Edison Co to Entergy Nuclear Generating Co ML20209C7761999-07-0606 July 1999 Submits Annual Summary Rept of Changes Made to QAP Description as Described in QA Manual,Vol Ii.Rept Covers Period of Jul 1998 Through June 1999.No Changes Made During Period ML20196J7251999-07-0101 July 1999 Informs of Completion of Licensing Action for GL 96-01, Testing of Safety-Related Logic Circuits, for Pilgrim Nuclear Power Station ML20209B9411999-06-30030 June 1999 Discusses Deferral of IGSCC Welds to RFO 13.Deferral of Welds to Refueling Outage 13 Does Not Impact Acceptable Level of Quality & Safety Per 10CFR50.55(a)(3)(i) Since Plant in Compliance W/Exam Percentage Requirements ML20209B9431999-06-30030 June 1999 Provides Formal Notification That Closing Date for Sale & Transfer of Pilgrim Station Scheduled to Occur on 990713. a Wang Will Be Verbally Notified of Time of Sale Closing ML20196H2381999-06-29029 June 1999 Forwards SER Denying Licensee 980820 Request for Alternative Under PRR-13,rev 2 for Use of Code Case N-522 During Pressure Testing of Containment Penetration Piping ML20209B9791999-06-29029 June 1999 Forwards Rev 13A to Pilgrims COLR for Cycle 13,IAW TS 5.6.5 Requirements.Rev 13A Provides cycle-specific Limits for Operating Pilgrim During Remainder of Cycle 13 ML20209A8761999-06-28028 June 1999 Forwards SER Authorizing Licensee 990317 Relief Request to Use ASME Code Case N-573 as Alternative to ASME Code Section XI Article IWA-4000 for Remainder of 10-year Interval Pursuant to 10CFR50.55a(a)(3)(i) ML20209A8701999-06-25025 June 1999 Responds to NRC Request for Info Re Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure for Plant,Reporting Status of Facility Y2K Readiness Encl ML20210U5901999-06-25025 June 1999 Opposes Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts.Expresses Skepticism Re Claim by Companies That Consumers Will Benefit from Proposed Consolidation & four-year Freeze in Base Rates ML20209C3431999-06-22022 June 1999 Forwards Addendum 1,Rev 14 to Pilgrim Station Security Plan,Iaw 10CFR50.54(p)(2).Changes Proposed Have Been Implemented & Constitute Increase in Plant Defense Plan Commitments.Encl Withheld,Per 10CFR73.21 1999-09-09
[Table view] Category:NRC TO UTILITY
MONTHYEARML20062E0071990-11-14014 November 1990 Forwards List of Unimplemented GSIs at Facility,Per Generic Ltr 90-04 ML20062D6651990-11-0808 November 1990 Ack Receipt of Forwarding Util Evaluation of NRC Inspector General Rept 90N-02 Re Offsite Emergency Planning ML20058G9761990-11-0707 November 1990 Forwards Safety Insp Rept 50-293/90-20 on 900816-1008 & Notice of Violation ML20058C5501990-10-26026 October 1990 Requests Written Policies & Procedures Needed for NRC Preparation for Planned fitness-for-duty Insp ML20062B4311990-10-17017 October 1990 Advises That 901012 Response to Generic Ltr 90-03 Re Vendor Interface for safety-related Components,Acceptable ML20062B7161990-10-12012 October 1990 Extends Invitation to Attend 910220-21 Util Symposium/ Workshop in King of Prussia,Pa Re Engineering Role in Plant Support.Interest to Participate,Intent to Attend & Approx Number of Representatives to Attend Requested by 901115 ML20062B6281990-10-12012 October 1990 Forwards Insp Rept 50-293/90-21 on 900905-07.Insp Conducted to Review Event of 900902-03 Which Involved Number of Component Malfunctions & Operational Complications Following Shutdown ML20059N7251990-10-0101 October 1990 Requests That Matls Listed in Encl Be Furnished to Assist Maint Program Team Insp Scheduled for 901105-16 ML20059K6901990-09-11011 September 1990 Forwards Transcript of 900906 Public Meeting in Plymouth,Ma W/State & Local Officials Re Emergency Planning.W/O Encl ML20059H5871990-09-0101 September 1990 Advises That Reactor Operator & Senior Reactor Operator Exams Scheduled for 901203.Encl Listed Ref Matl Requested ML20059J6521990-08-29029 August 1990 Forwards Safety Insp Rept 50-293/90-09 on 900806-10.No Violations Noted.Concludes That Engineering & Technical Support Organizations Continue to Provide Strong Station Support ML20059A1481990-08-17017 August 1990 Forwards 900816 Summary of 900807 Meeting Re Inservice Testing Program ML20058P0471990-08-0909 August 1990 Forwards Safety Insp Rept 50-293/90-18 on 900709-13.No Violations Noted ML20058N0401990-08-0606 August 1990 Discusses Licensee Engineering Initiatives.Power Reactor Licenses in Region 1 Should Initiate Similar Program to Provide Sharing of Info & Experiences Involving Engineering Initiatives & Solution to Problems Common to All ML20056A4801990-07-30030 July 1990 Forwards Safeguards Insp Rept 50-293/90-16 on 900625-29.No Violations Noted.One Unresolved Item Identified ML20058L7051990-07-27027 July 1990 Forwards Safety Insp Rept 50-293/90-17 on 900625-29.No Violations Noted ML20055F2461990-06-29029 June 1990 Forwards Safety Insp Rept 50-293/90-13 on 900501-0611.No Violations Noted.Repetitive Failures of Diesel Driven Fire Pump Noted,Requiring Increased Mgt Attention ML20059M8421990-06-13013 June 1990 Forwards NRC Performance Indicators for First Quarter 1990. W/O Encl ML20247R8071989-09-21021 September 1989 Forwards SALP Rept 50-293/88-99 for 880516-890630.Instances of Deviation from Approved Practices & Lack of Attention to Detail Which Led to Challenges to Plant Equipment & Personnel Noted ML20247K6661989-09-0707 September 1989 Forwards Insp Rept 50-293/89-07 on 890525-0710 & Notice of Violation ML20246K5091989-08-24024 August 1989 Accepts Summary of QA Program Description Changes for 1989, Forwarded by ML20246L7821989-08-23023 August 1989 Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $25,000.Failures to Properly Plan, Supervise & Inspect Tagout of Circuit Breakers Directly Contributed to Event ML20246D7261989-08-18018 August 1989 Submits Response to Re Plant Power Ascension Program.Util Proposal to Defer Phase 2 of Shutdown from Outside Control Room Test to Planned Fall 1989 mid-cycle Outage Accepted IR 05000293/19890071989-08-18018 August 1989 Approves Reactor Operation Up to 75% of Full Power Per Licensee Power Ascension Test Program.Nrc Findings Docketed in Insp Repts 50-293/89-07 & 50-293/89-08 & Status of Emergency Preparedness for Communities Encl ML20246J4811989-08-18018 August 1989 Clarifies NRC Position Re Definition of Extremity for Purposes of Setting Occupational Exposure Limits.Due to Misunderstanding,No Enforcement Action Planned If Licensee Procedures Incorporated Misunderstanding ML20246G1861989-08-18018 August 1989 Approves Reactor Operation Up to 75% of Full Power Per Licensee Power Ascension Test Program.Nrc Findings Docketed in Insp Repts 50-293/89-07 & 50-293/89-08 & Status of Emergency Preparedness for Communities Encl ML20245F1781989-07-31031 July 1989 Forwards Insp Rept 50-293/89-06 on 890411-0524.No Violations Noted.Licensee Actions W/Respect to 890503 Turbine Trip/Reactor Scram Demonstrated Excellent Approach to Problem Investigation & Resolution ML20247D0181989-07-18018 July 1989 Ack Receipt of Re Response to NRC Bulletin 89-003, Inadequate Latch Engagement in Hfa Type Relays Mfg by Ge. Necessary Actions Performed to Address Issues in Bulletin ML20246N3921989-07-14014 July 1989 Forwards Safety Insp Rept 50-293/89-09 on 890619-22.No Violations Noted ML20246D4961989-07-0606 July 1989 Advises That 880713 Response to NRC Bulletin 88-004, Potential Safety-Related Pump Loss Acceptable ML20246A7561989-06-26026 June 1989 Approves Reactor Operation Up to 50% Full Power,Per Util Power Ascension Test Program & Confirmatory Action Ltr 86-10.Assessment of Licensee Readiness for Release from NRC Approval Point 3 & Related Info Encl ML20246B5961989-06-22022 June 1989 Forwards,For Info,Nrr Ack Receipt of Petition Filed by Ecology Ctr of Southern CA & Stating That Petition Being Treated Under 10CFR2.206 of Commission Regulations ML20245A5371989-06-0909 June 1989 Forwards Insp Rept 50-293/89-05 on 890311-0410.Weaknesses Noted Re Evaluation of Failure Rate & Root Causes for Failures of Airlock Doors & Interlocks ML20244C2121989-06-0707 June 1989 Responds to Util 881011 Response to Generic Ltr 87-02, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors. Implementation Schedule Contingent Upon Resolution of Procedure ML20244C2751989-06-0606 June 1989 Forwards Draft Safety Evaluation Re Plant Compliance W/ 10CFR50.62, ATWS Rule. Requests Response to NRC Concerns Re Diversity & Testability of Alternate Rod Injection & Reactor Pump Trip Sys NUREG-1275, Informs That Util Fulfilled Requirements of Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety Related Sys1989-06-0202 June 1989 Informs That Util Fulfilled Requirements of Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety Related Sys ML20247P5501989-06-0101 June 1989 Forwards Request for Addl Info on Proposed Tech Specs Change Re Visual Insp of High Energy Piping.Listed Concerns Based on Review of Bechtel Calculation 17322-S5,Rev 1 ML20247M2661989-05-26026 May 1989 Forwards Director'S Decision,Ltr of Transmittal & Fr Notice in Response to Ocre 2.206 Petition Expressing Concerns Re 880309 Power Oscillation Event at LaSalle Unit 2 & Request to Reopen Rulemaking on ATWS Issue.W/O Encls ML20246P6051989-05-15015 May 1989 Forwards Notice of Withdrawal of Application for Amend to License DPR-35.Amend Would Modify Tech Specs Re ECCS Surveillance Requirements ML20247D5481989-05-0808 May 1989 Forwards Augmented Insp Team Rept 50-293/89-80 on 890413-19 & 17-26.Team Concluded That Safety Significance of 890412 Pressurization Transient Was Minor,Though Event Raised Concerns Re Proximate Human Factors & Equipment ML20246N7951989-05-0404 May 1989 Forwards Mgt Meeting Rept 50-293/89-04 on 890328-30 W/Commonwealth of Ma & Local Officials ML20247A6911989-05-0303 May 1989 Extends Invitation to Attend Power Reactor Operator Licensing Seminar on 890531 in King of Prussia,Pa.Agenda & Info Re Lodging Arrangements Encl ML20245H8371989-04-26026 April 1989 Forwards SAIC-89/1121, In-Progress Audit Rept of Dcrdr at Boston Edison Co Pilgrim Nuclear Power Station & SAIC-89-1119, In-Progress Audit Rept for Boston Edison Co Pilgrim Nuclear Poser Station Spds ML20245H9551989-04-26026 April 1989 Forwards Insp Rept 50-293/89-01 on 890206-0310 & Notice of Violation ML20245J1441989-04-25025 April 1989 Advises That 880921 & 890302 Responses to NRC Bulletin 88-007 & Suppl 1, Power Oscillations in BWRs Meet Requirements of Both Bulletins ML20244E4611989-04-14014 April 1989 Requests Prompt Review & Reporting of Status of Implementation of TMI Action Plan Items at Facility.Printout of All TMI Items Annotated Where Tracking Sys Indicates That Implementation Not Complete Encl ML20244C2771989-04-10010 April 1989 Informs of Completion of Followup on Plant Regulatory Effectiveness Review Effort & Activities Re TAC 56995. Previous Compensatory Measures Removed as Result of Implementing Corrective Action ML20244A6931989-04-0707 April 1989 Forwards Mgt Meeting Rept 50-293/89-43 on 890309 to Discuss Util Followup Actions to 890304 Reactor Scram ML20244A6281989-04-0303 April 1989 Forwards Insp Rept 50-293/88-37 on 881227-890205.Violation Noted Re Failure to Control Locked High Radiation Area Access ML20236A8451989-03-0303 March 1989 Approves Reactor Operation Up to 25% of Full Power Per Util Power Ascension Test Program & Confirmatory Action Ltr 86-10.Urges Util to Cooperate W/Commonwealth of Ma & Local Govts to Further Improve State of Emergency Preparedness 1990-09-11
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217D3951999-10-13013 October 1999 Forwards Request for Addl Info Re Util 990806 Submittal on USI A-46, Implementation Methodology Used at Pilgrim Nuclear Power Station, Per GL 87-02 ML20217E1581999-10-0808 October 1999 Forwards Insp Rept 50-293/99-05 on 990726-0905.Three Violations Noted & Being Treated as Ncvs.Violations Include Failure to Assure That Design Bases Correctly Translated Into Specifications ML20212J8301999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Integrate Performance Info & to Plan Insp Activities at Facility Over Next Six Months ML20212F7871999-09-24024 September 1999 Advises That Util 990121 Application for Amend Being Treated as Withdrawn.Proposed Changes Would Have Modified Facility UFSAR Pertaining to Values for post-accident Containment Pressure Credited in Pilgrim Net Positive Head Analyses ML20212C2861999-09-16016 September 1999 Forwards SER Accepting Licensee 981123 Request for Relief RR-E1,RR-E5,RR-E6 Pursuant to 10CFR50.55a(a)(3)(i) & Request for Relief RR-E2,RR-E3 & RR-E4 Pursuant to 10CFR50.55a(a)(3)(ii) ML20211H5701999-08-27027 August 1999 Forwards Insp Rept 50-293/99-04 on 990610-0725.Two Violations Identified Being Treated as non-cited Violations ML20210U7521999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opossing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U5761999-08-18018 August 1999 Responds to Opposing Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts. Informs That for Sale,Nrc Responsible for Only Ensuring That Entergy Technically & Financially Qualified to Operate NPP ML20210U6691999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opposing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U5151999-08-17017 August 1999 Forwards Notice of Withdrawal of Application for Approval of Indirect Transfer of FOL for Pilgrim in Response to .Approval No Longer Needed Since Beco Sold Interest in Pilgrim to EOI on 990713 ML20216E2321999-07-26026 July 1999 Discusses GL 92-01,rev 1,suppl 1, Rv Structural Integrity. NRC Revised Info in Rvid & Releasing as Rvid Version 2 ML20210E2231999-07-20020 July 1999 Discusses Arrangements Made by Dennis & M Santiago During 990615 Telephone Conversation for NRC to Inspect Licensed Operator Requalification Program at Pilgrim During Wk of 991004 ML20210A9441999-07-14014 July 1999 Responds to Re Changes to Pilgrim Nuclear Power Station Physical Security Plan Identified as Issue 2,rev 14, Addendum 1,respectively.No NRC Approval Is Required IAW 10CFR54(p) ML20209G2251999-07-0909 July 1999 Forwards Insp Rept 50-293/99-03 on 990419-0609.Five Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations,Consistent with App C. Several Individual Tagging Errors Occurred ML20209C4661999-07-0707 July 1999 Forwards SE Accepting Addendum on Proposed Change in Corporate Ownership Structure Involving Entergy Nuclear Generation Co ML20196J7251999-07-0101 July 1999 Informs of Completion of Licensing Action for GL 96-01, Testing of Safety-Related Logic Circuits, for Pilgrim Nuclear Power Station ML20196H2381999-06-29029 June 1999 Forwards SER Denying Licensee 980820 Request for Alternative Under PRR-13,rev 2 for Use of Code Case N-522 During Pressure Testing of Containment Penetration Piping ML20209A8761999-06-28028 June 1999 Forwards SER Authorizing Licensee 990317 Relief Request to Use ASME Code Case N-573 as Alternative to ASME Code Section XI Article IWA-4000 for Remainder of 10-year Interval Pursuant to 10CFR50.55a(a)(3)(i) ML20195K3071999-06-15015 June 1999 Forwards Safety Evaluation Granting Licensee Request to Use Guidance of GL 90-05 to Repair Flaws in ASME Class 3 Salt Svc Water Sys Piping for Plant ML20195K3851999-06-11011 June 1999 Forwards Copy of Notice of Consideration of Approval of Application Re Proposed Corporate Merger & Opportunity for Hearing.Application Seeks Approval of Proposed Indirect Transfer of FOL for Plant ML20196K9921999-06-0404 June 1999 Informs That NRC Ofc of NRR Reorganized Effective 990328.As Part of Reorganization,Division of Licensing Project Mgt Created ML20207E7351999-05-27027 May 1999 Responds to Requesting Reduction in IGSCC Insp Frequency Per GL 88-01 to Be Performed During Upcoming RFO 12.Forwards SE Re Reduction of IGSCC Insp of Category D Welds Due to Implementation of H Water Chemistry ML20207B6341999-05-26026 May 1999 Informs That Licensee 990415 Submittal Re Financial Position of Entergy Intl Ltd,Llc Will Be Marked as Proprietary & Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b) of Atomic Energy Act ML20207B7391999-05-24024 May 1999 Forwards from Kc Goss of FEMA to Cl Miller Forwarding FEMA Analysis of Prompt Alert & Notification Sys for Pilgrim Nuclear Power Station.Based on Review,No Significant Problems Exist with Alert & Notification Sys ML20207B0701999-05-24024 May 1999 Responds to Sent to Ofc of Congressional Affairs Requesting Info on Concerns Raised by One Constituent,J Riel Re Y2K Compliance of Pilgrim NPP in Plymouth,Ma ML20207C0321999-05-18018 May 1999 Forwards Fifth Rept Which Covers Month of Apr 1999. Commission Approved Transfer of TMI-1 Operating License from Gpu to Amergen & Transfer of Operating License for Pilgrim Station from Beco to Entergy Nuclear Generating Co ML20206U7501999-05-17017 May 1999 Forwards Insp Rept 50-293/99-02 on 990308-0418.Two Severity Level 4 Violations Occurred & Being Treated as NCVs ML20206M1891999-05-11011 May 1999 Forwards SE of 980826 Request to Use Guidance of GL 90-05 to Repair Flaws in ASME Class 3 Salt Svc Sys Piping for Plant ML20206E0551999-04-29029 April 1999 Discusses Bulletin 96-03 Issued on 960506 & Beco Responses ,970207,981230,990121 & 990309 for Pilgrim Npp. Determined That Actions Taken Should Minimize Potential for Clogging of ECCS Suction Strainers ML20206B3031999-04-20020 April 1999 Forwards Insp Rept 50-293/99-01 on 990125-0307.Two Violations of NRC Requirements Occurred & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy.Security Program Was Also Inspected ML20205Q9491999-04-0909 April 1999 Informs That on 990225 NRC Staff Completed PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Develop an Integrated Understanding of Safety Performance ML20205B9391999-03-24024 March 1999 Forwards Second Request for Addl Info Re GL 95-07, Pressure-Locking & Thermal-Binding of Safety-Related Power-Operated Gate Valves ML20204C7871999-03-17017 March 1999 Informs That Application Submitting Transfer of Facility Operating License & Matls License & Proposed Amend, Will Be Marked as Proprietary & Be Withheld from Public Disclosure Pursuant to 10CFR2.709(b)(5) ML20199K8321999-01-22022 January 1999 Forwards Request for Addl Info Re Transfer of Facility Operating License for Plant ML20199H5811999-01-20020 January 1999 Submits Exemption Withdrawal of 10CFR70.24(a) Re Criticality Accident Monitoring Requirements ML20198L7781998-12-22022 December 1998 Forwards Insp Rept 50-293/98-10 on 981020-1208.No Violations Noted.Nrc Regional Specialists Reviewed EP & Fire Protection Programs.Ep Program Was Found to Be Well Implemented ML20198J0891998-12-21021 December 1998 Forwards NRC Response to Me Lampert Re Transfer of Ownership of Pilgrim Station in Response to Senator Kerry Ltr Dtd 981019.NRC Will Terminate License Only When Licensee Remediates Site to Levels Specified in Regulations ML20198J1041998-12-21021 December 1998 Forwards NRC Response to Me Lampert Re Transfer of Ownership of Pilgrim Station in Response to Congressman Markey Ltr Dtd 981019.NRC Will Terminate License Only When Licensee Remediates Site to Levels Specified in Regulations ML20137T2211998-12-17017 December 1998 Responds to to Chairman Jackson Re Concerns About Possible Sale of Pilgrim Station & Waste Disposal Issues.No Application for License Received Nor Contract of Sale Between Beco & Entergy.Record Copy ML20198J1161998-12-17017 December 1998 Responds to to Chairman Jackson in Which Recipient Expressed Concern About Possible Sale of Pilgrim Station & About Waste Disposal Issues.Nrc Has Not Received Application for Transfer of License to Date ML20198P2781998-12-17017 December 1998 Final Response to FOIA Request for Documents.Forwards App a Records Being Released in Entirety.App B Records Being Withheld in Entirety (Ref FOIA Exemption 4) ML20198B2021998-12-0909 December 1998 Advises of Planned Insp Effort Resulting from Licensee Irpm Review.Details of Insp Plan for Next 6 Months & Historical Listing of Plant Issues Encl ML20197H8521998-12-0909 December 1998 Responds to Ltr Sent to Chairman SA Jackson on 981028 Re Concern That NRC Will Not Perform Environ Assessment in Connection with Consideration of Approval of Transfer of License for Plants to Permit Sale ML20196J1201998-12-0404 December 1998 Ack Receipt of 971217 & 30 & 980112,0309,0423 & 0630 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-293/97-02,50-293/97-11,50-293/97-13, 50-293/97-80 & 50-293/98-01.Actions Found Acceptable ML20196B5421998-11-24024 November 1998 Forwards Plant SRO & RO Initial Exam Rept 50-293/98-301OL During Wk of 981016-23 ML20196F7631998-11-24024 November 1998 Forwards Insp Rept 50-293/98-203 on 980928-1023.No Violations Noted.Three Issues Identified Re Containment Flooding,Surveillance Testing Criteria & Protection for RBCCW System from High Energy Line Break Inside Drywell ML20196C1191998-11-20020 November 1998 Forwards Insp Rept 50-293/98-08 on 980907-1019.No Violations Noted.During Insp Period,Chemical Decontamination of Residual Heat Removal Sys Was Well Planned & Implemented Which Reduced Radiation Doses in Heat Removal Quadrants ML20195H7361998-11-16016 November 1998 Informs of Individual Exam Results for Applicants on Initial Exam Conducted on 981016 & 981019-23 at Facility.Nine Applicants Were Administered Exam & Nine Passed.Licenses Issued & Individual Test Results Encl.Without Encl ML20155C4781998-10-29029 October 1998 Forwards RAI Re Resoultion to GL 96-06 Issues at Plant,Unit 1.Response Requested by 981130 ML20154J7881998-10-0808 October 1998 Authorizes Mb Santiago to Administer Initial Written Exams to Applicants Listed (Except Applicants Redlined), on 981016.NRC Region I Operator Licensing Staff Will Administer Operating Tests During Week of 981019 1999-09-30
[Table view] |
Inspection Report - Pilgrim - 1987004 |
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NOV 2 01987
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Docket N Boston Edison Company ATTN: Ralph G. Bird ,
Senior Vice President - Nuclear 1 800 Boylston Street Boston, Massachusetts 02199 Gentlemen:
Subject: Inspection No. 50-293/87-04 l This refers to your letters dated April 9 and June, 8,1987, in response to our letter dated March 10, 198 l Thank you for informing us of those preventive and corrective actions taken for violations A, C and D as documented in your letter of April 9, 198 These actions were subsequently reviewed by us during inspections 50-293/87-37 and 50-293/87-41 and found to be sati s f actor In regard to violation B, as requested in your letter of June 8, 1987, we have withdrawn the Notice of Violation (50-293/87-04-04) based upon the results of a further review of this matter which is documented in Inspection Report 50-293/87-4 Your cooperation with us is appreciate
Sincerely, E C EI6 M. c r.t.! r William V. Johnston, Acting Director Division of Reactor Safety I
/p[$f 8712010103 871120 PDR ADOCK 05000293 G PDR
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OFFICIAL RECORD COPY RL PILGRIM 87-04 - 0001. /06/87
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Boston Edison Company 2 d
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l K. P. Roberts, Nuclear Operations Manager l
Paul Levy, Chairman, Department of Public Utilities i Chairr..an, Board of Selectmen Plymouth Civil Defense Director J. D. Keyes, Boston Edison Regulatory Affairs and Programs E. D. Robinson, Nuclear Information Manager R. N. Swanson, Nuclear Engineering Department Manager
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The Honorable E. J. Markey Senator Edward P. Kirby The Honorable Peter V. Forman Sharon Pollard, Secretary of Energy Resources Peter W. Agnes, Assistant Secretary of Public Safety, Commonwealth of Massachusetts Rachel Shimshak, MASSPIRG Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Massachusetts (2)
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Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
Section Chief, DRP R. Wessman, PM, NRR Robert J. Bores, DRSS T.Du(lt?
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h RI:DRP Bissett Blumberg @Gaflo .GnBlough r id///87 1h/ l /87 16/h87 1D/3 /87 16/ /87 0FFICIAL RECORD COPY RL PILGRIM 87-04 - 0002. /28/87
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Executive offices E ^ * :. -
. 800 Boylston Street Boston. Massachusetts 02199 Ralph G. Bird June; 8, 1987 senior vice P esident- Nuclear BECo Ltr. '#87-98 Document Control-Desk U.S. Nuclear Regulatory Commission Washington, D..C. 20555 Docket No. 50-293 License No. DPR-35 Subject: :NRC Inspection Report 50-293/87-04
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' Reference': Boston Edison Company Letter Number 87-56
Dear Sir:
Attached is Boston Edison Company's response to Notice of Violation B'
, contained in the subject inspection repor On May 1, 1987, Boston Edison Company management representatives met with NRC management to obtain clarification of the Notice of Violation. As a result of meeting discussions, our conclusion is that the Notice of Violation was issued-because we did not effectively communicate our programs for test control'tm the inspector. The.need for effectiveness of communication and diligence in resolving inspector concerns in'a timely manner has been re-emphasized to the appropriate members of our staf We continue to believe that our test program elements meet the applicable ANSI-and BEQAM requirements'and based upon the information presented in the attachment to this letter, request that Notice of Violation B-be withdraw Please do not hesitate to contact me directly if you have any question .G EM/la Attachment-cc: Regional Administrator, Region 1 Director, Office of Inspection U.S. Nuclear Regulatory Commission ' and * Enforcement 631 Park Avenue , U.S. Nuclear Regulatory Commission King of Prussia, PA 19406 Washington, DC 20555 Senior Resident Inspector ,
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., ATTACHMENT 1
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Notice of Violation B
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10CFR50, Appendix B, Criterion XI, requires that test programs be' establishe BECo Quality Assurance Manual (QAM), Volume II, Section 2, Quality Assurance Program, states that the QA program conform to ANSI N18.7-1976. ANSI N18.7-1976, paragraph 5.2.19, Test' Control states in part that "A test program shall be established to assure that testing required to' demonstrate that the item will perform satisfactotfly in service is identified and documented, and that testing is q performed in accordance with written test procedures which incorporate or' reference 1 the requirements and acceptance limits...The test program shall cover all required '
tests including.... surveillance tests and tests which-demonstrate satisfactory.
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performance following plant maintenance and modification In addition, the BECo QAM', Section l'1, " Test Control", requires in part, that post work tests and periodic surveillance tests are performed by qualified personnel in accordance with written, approved test procedures, which identify all test prerequisites and environmental conditions which must be satisfied before-performing these tests; that Watch Engineer or his designee,' reviews and approves the' post,-work test data results; and that the N0D' Manager is responsible to assure that surveill,ance tests are performed when required, test results are evaluated, and test requirements are satisfie Contrary to the above, as of January 16, 1987, programs for performance of periodic surveillance tests and tests following performance of plant modifications or-maintenance had not been' adequately established in that there were no station administrative control procedures which addressed the following:
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Overall mechanisms for control of specific test programs such as periodic surveillance tests, post maintenance tests, and post' modification tests.
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Definition of personnel qualified to perform such tests.
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Methods by which prerequisites and environmental conditions are to be
! determined and examples of suc Specification of personnel who are designated to approve and evaluate test results and assure that test requirements are satisfied.
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Definitions of the kinds of instruments to be included in the instrument and control surveillance progra Methods by which acceptance criteria are properly specifie Format for post maintenance and post modification test procedure his is a Severity Level IV Violatio (Supplement 1)
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' Response
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Boston Edison's program for the implementation of the " test program" as
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described in ANSI N18.7-1976/ANS3.2 consists of administrative procedures, implementing procedures, and personnel selection and training processes. The various elements of the ANSI N18.7-1976/ANS3.2 " test program" and the BECo QAM, section 11, " Test Control" have been incorporated in the procedures associated with the work activity rather than a separate test control procedure. For example, post maintenance test specification, performance and approval are contained in Nuclear Operations Department Procedure 1. " Maintenance Requests" while the format and content of procedures is specified in Nuclear Operations Department Procedure 1.3.4 " Procedures".
Boston Edison has reviewed the concerns of the above Notice of Violation and the requirements of AN(I N18.7-1976/ANS3.2 section 5.2.19 " Test Control" and BECo 0AM section ll, "h st Control" as implemented by currently existing procedures and policie Boston Edison believes the test.progcam, as it currently exists, is in compliance with the aforementioned ANSI and BECo QAM requirement A point by point comparison of the specific concerns expressed in the Notice of Violation with the methods currently in use to sa'. fy the concerns is presented be]o ,
-- Overall mechanisms for control of specific test programs.such as periodic surveillance tests, post maintenance tests, and post modification test Nuclear Operations Department Procedure 1.8 " Master Surveillance Tracking Program" controls the performance of periodic surveillance test The associated computer program provides the mechanism for scheduling performance of periodic surveillance test .
Nuclear Operations Department Procedure 1.5.3 " Maintenance Requests" controls the performance of post maintenance testing. Provisions for designation of both maintenance related and Technical Specification operability related tests are contained in this procedur Nuclear Operations Procedure 83E1 " Control of Modifications to Pilgrim Station", Nuclear Operations Procedure 83A6 " Modification Management", and Nuclear Engineering Department Procedure 3.02 " Preparation, Review, Verification, Approval and Revision of Design Documents for Plant Design Changes" control post modification test Definition of personnel qualified to perform the subject test Personnel qualified to perform surveillance and post maintenance tests are determined through the detailed evaluation of previous job experience and specific job training which is performed by the Nuclear Training Departmen This information is posted in the maintenance shop areas for use by the supervisors in charge of the work activity to assist in the assignment of individuals to the particular maintenance tas Technical Specification surveillance and operability testing is also performed by l Nuclear Plant Operators and Reactor Operators who, by virtue of the training associated with their job descri'tten's, p are qualified to perform these tests.- .
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ATTACHMENT 1 (Cont.)-
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. Personnel qualified to perform post modification tests are specifled as
- Test. Directors. Test. Directors are individuals whose qualifications meet
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-- Methods by which prerequisites and environmental conditions are to be determine Surveillance and post maintenance test procedures are written per the- ,
I requirements of Nuclear Operations Department Procedure 1. " Procedures". Test procedures contain a section specifying prerequisites !
and environmental conditions, if applicable, which must be satisfied prior-to initiation of the tes Preoperational. test p'rocedures are written per the requirements of the i Modification Management Work Instruction Manual, section 1 " Modifications Management Preoperational Test Procedure Development".
Test procedures contain a section specifying prerequisites and
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environmental conditions, if applicable, which must be satisfied prior to J initiation of the tes {
-- Specification of personnel who are anignated to approve and evaluate test resul,ts a,nd assure .that test requirements are s~atisfie ,
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- The individ'ual surveillance test procedures specify the persons responsible for the evaluation and approval of test results. For example, 1 the Watch Engineer evaluates and approves Technical Specification surveillance test result ]3
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'The designation of personnel who evaluate and approve post maintenance test results.is contain'ed in Nuclear Operations Department Procedure 1. " Maintenance Requests" and in the individual test procedures. For
~ example, the Watch Engineer evaluates and approves Technical Specification operability test result The' designation of personnel who evaluate and approve post modification
. test results is contained in Nuclear Operations Procedure 83A6
" Modification Management" and in the individur.1 preoperational tert procedures wri_tten in accordance with the Modification Management Work Instruction Manual, section 10.0 " Modification Management Preoperational 1'
Test Procedure Development".
-- ' Definitions of the kinds of instruments to be included in the instrument and control surveillance progra .As clarified in our meeting, the inspector's concern was calibration of non-safety related, installed instrumentation, used to measure system parameters during the' performance of system test The calibration of installed plant instrumentation required to support the performance of tests is either performed as a step in the individual test procedure or periodically as controlled by the Master Surveillance Tracking Program.
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-- Methods by which acceptance criteria are properly specifie l
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' ATTACHMENT 1-(Cont.)
b, Surveillance and post maintenance test procedures are written and approved 14: _ per the requirements of Nuclear Operations Department Procedure:1.3.4,
" Procedures". Test procedures contain a section specifying test L acceptance criteri Reference documents used in the generation of the test. procedure (i.e.-Technical Specifications, Final Safety Analysis Report, Vendor. Manuals, design documents, etc.) supply information on specific' acceptance criteri Post modification test procedures are written per the requirements of the Modification. Management Work Instruction Manual, section 1 " Modification Management Preoperational Test Procedure Development". Test procedures.contain a section specifying test acceptance criteria. The l- specific acceptance criteria for inclusion in the test procedure are developed during the portion of the design process controlled by Nuclear Engineering Department Procedure 3.02'" Preparation, Review, Verification, Approval and Revision ~of Design Documents for Plant Design Changes".
-- Format for post maintenance and post modification test procedures.
t Post maintenance test procedures are written per the requirements of . ,
. Nuclear Operations Department Procedure 1.3.4 " Procedures" which. specifies. . '
j test'proced.ure forma '
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l Post modification test procedures are written per the requirements of the'
Modification Management Work Instruction Manual, section 1 " Modifications _ Management Preoperational Test Procedure Development" which specifies test prccedure forma Boston Edison is currently' performing an extensive programmatic upgrade for the control of surveillance testing. This upgrade, scheduled for impicmentation and validation in June, 1987, will greatly ihcrease the l effectiveness of the current surveillance test progra The Master l Surveillance Tracking Program (MSTP) is being refined to; 1) provide a complete' cross reference between surveillance requirement and implementing l- surveillance test procedures, 2) provide for the scheduling of surveillance l tests which correspond to the operating condition of the plant, 3) provide the ability to schedule surveillance tests based upon plant system availability, 4) track the completion of surveillance tests in which portions of the test are completed at different points in time, and 5) provide for the designation of acceptance criteria. Most importantly, experienced technical personnel have been assigned to the administration and maintenance of the MST Thi will ensure the continuance of a high quality surveillance program under the cognizance of a single manager. Boston Edison will examine the elements of the post maintenance test program to determine which areas are in need of improvemen The program for post modification testing, as it currently e d sts, is effective and adequate To ensure that the appropriate management personnel are aware of the implementing procedures for the, various aspects"of the test program, our
"Index of Procedures Per Criteria of ANSI N18.7-1976" is being updated and will be distribute Page 4 of 4
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