IR 05000293/1987004: Difference between revisions

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{{Adams
{{Adams
| 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 Violation B Withdrawn Based on Results of Further Review,Per Util 870608 Request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and found to be sati s f actor In regard to violation B, as requested in your letter of June 8, 1987, we have withdrawn the Notice of Violation (50-293/87-04-04) based upon the results of a further review of this matter which is documented in Inspection Report 50-293/87-4 Your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
 
    , 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?
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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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Inspectors:,
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     ' Reactor E eer, DRS d te
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Executive offices E ^ * :. -
  )  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
, 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).


Y s :
==Dear Sir:==
8703200271 870399
Attached is Boston Edison Company's response to Notice of Violation B'
  , PDR ADOCK 05000293 G   PDR s ,
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  , 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
  .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)
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).
 
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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Definition of personnel qualified to perform such tests.


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.


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
  ' Response
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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-
  . 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".


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
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  . 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.


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 .
The purpose of this inspection was to verify that adequate preopera-
, 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,
" 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).
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:
*
Surveillance checklists Evaluation sheets
*
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 . .
i ATTACHMENT A PERSONS CONTACTED Licensee
*M. Akhtar  Group Leader - Modifications Management
*M. Brosee  Maintenance Section Manager F. Famulari  Quality Control (QC) Group Leader D. Gerlits  Senior Nuclear Training Specialist F. Giardiello  Compliance Engineer
*E. Graham  Compliance Group Leader
*R. Grazio  Field Engineering Section Manager P. Hamilton  Compliance Engineer
*S. Hudson  Operations Section Manager G. LaFond  I&C Engineer E. Larson  Senior QA Engineer
*P. Mastrangelo  Chief Operations Engineer
*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)
S. Wollman  Principal Operations Engineer
*E. Ziemanski  Nuclear Management Services Section Manager The inspector also interviewed other licensee personnel including I&C Technician . USNRC M. McBride  Senior Resident Inspector
*J. Lyash  Resident Inspector
* 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
-- 1.3.36 Measurement and Test Equipment
~ - - 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)
-- Fuel Handling
=
 
a
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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 :. -
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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  *-
,y, ,
      ' 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,
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".


--
-- Format for post maintenance and post modification test procedures.
PNPS Procedure " Reactor Core Fuel Verification".


--
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 '
!
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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Latest revision as of 06:37, 17 December 2021

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
ML20236T269
Person / Time
Site: Pilgrim
Issue date: 11/20/1987
From: Johnston W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Bird R
BOSTON EDISON CO.
References
NUDOCS 8712010103
Download: ML20236T269 (2)
v • d • e


Text

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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

{

cc:

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)

bec:

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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L' BOSTONED60N

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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.)-

4 '6 f

. Personnel qualified to perform post modification tests are specifled as

- Test. Directors. Test. Directors are individuals whose qualifications meet

, ' ., i or exceed applicable ANSI requirements.

'

-- 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

!

'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 '

!

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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