ML20207S788

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

ML20207S788
Person / Time
Site:	Pilgrim
Issue date:	03/06/1987
From:	Bissett P, Blumberg N, Marilyn Evans NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207S763	List: ML20207S762 ML20207S771 ML20207S788
References
50-293-87-04, 50-293-87-4, NUDOCS 8703200271
Download: ML20207S788 (18)

See also: IR 05000293/1987004

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U.S. NUCLEAR REGULATORY COMMISSION

, REGION I

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Report No. 50-233/87-04

Jocket'No. 50-293

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v' L'ic'et;.te No. DPR-35

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Licenge: Boston Edison Company

800 Boylston Street

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Boston, Massachusetts 02199

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FaciTfty Name: Pilgrim Nuclear Power Station

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Inspection At: Plymouth, Massachusetts

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Inspection Conducted: January 12-16, 1987

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Inspectors:,

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'N. Reactor E eer, DRS d te

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) P.1 1ssett,-Reactor Engtheer, DRS

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M. Evans, Reactor Engineer, DRS da'te

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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. 50-293/87-04.

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 interfaces.

The insyction was performed on site by three region-based inspectors.

Results: Fode violation were identified: (1) Inadequate surveillance test of

3 the gSBGT system _ (para. 3.3.1); (2) Inadequate test program procedures (para

, fi. 3.3f3, 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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.t? , , DETAILS

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e $ Persons contacted are identified in Attachment A to this report.

2.0 ' Licensee Action Concerning iPrevious Inspection Findings

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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 testing.

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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 testing.

The inspector also reviewed severa,1 completed and approved checklists for

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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 '3.1 Scope and Criteria

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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

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Pilgrim Station Technical Specifications (T.S.), Section 4,

Surveillance Tests (Ph?S) n.

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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 Plants.

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PNPS, Final Safety Analysis Report 'NSAR)

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Appropriate licenses administrative controls ~as listed in

Attachment 8 to this report.

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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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surveillances (detailed in paragraph 5),. The inspection included

review of technical specifications, test procedures, test schedules,

and interviews with licensee personnel.

3.2 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 testing.

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A master test schedule for surveillance testing was established.

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Mechanisms were established for the tracking of completed tests.

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Completed tests received proper reviews.

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Test procedures were established for surveillance tests required

by the T.S.

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Test procedures were established for each T.S. surveillance test

requirement and accomplished T.S. objectives.

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Test schedules were being adhered to, and

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Surveillance test frequencies were as specified in the T.S.

3.3 Findings

3.3.1 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 requirement.

In one instance, the test provided by the licensee appeared

to be inadequate to meet the T.S. requirements. T.S.

4.7.8.1.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 this. Failure to adequately perform this T.S.

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 objectives. Incon-

sistencies were noted and the following additional

weaknesses were observed:

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T.S. sections were poorly referenced. In many cases

the T.S. were not referenced at all or only the major

paragraphs rather than subparagraphs were referenced.

In addition, some referenced T.S. were incorrect or

incomplete in that all T.S. requirements to be

verified by the procedure were not referenced in the

procedure.

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Procedure formats varied. There were major inconsis-

tencies on how information was presented.

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Acceptance criteria were unclear. At times,

acceptance criteria did not clearly state how the T.S.

requirement was satisfied. Except as stated above

there. were no instances identified where the. actual

body of the test did not satisfy the T.S. requirement.

The licensee recognized the need to improve surveillance

test procedures. Consultants are currently rewriting

procedures; however, no commitment was given by the

licensee as to the expected completion date of this

project.

The T.S. contains contingency surveillance requirements.

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 reached. 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

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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 recommendations. 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 future.

3.3.2 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 completed.

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 detail.

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 errors.

The inspector made the following observations to the

licensee:

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There is no centralized control of surveillance

testing. Although there is a master schedule, each

group controls its own surveillance tests. However,

no group in the plant lias its own procedures for

controlling its own test program.

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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 completion. Initials are transposed as much as

3 or 4 times. After the third transposition, entries

are made to the computer. This system is prone to  !

, transposition errors. l

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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 made.

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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 tests.

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Each group maintains its own completed procedures.

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

schedule.

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 tests.

3.3.3 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 place. 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 testing.

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 testing. 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

tests.

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Definition of personnel qualified to perform tests.

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Methods by which prerequisites and environmental

conditions are to be determined.

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Specifications of personnel who are designated to

approve and evaluate test results.

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Definitions of the kinds of instruments to be included

in the instrument and control surveillance test

program.

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Methods by which acceptance criteria are properly

specified.

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Journal for post maintenance and post modification

test procedures.

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/

87-04-04).

4. Instrument Calibration

4.1 Scope and Criteria

Refer to paragraph 3.1.

4.2 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 surveillances.

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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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 calibrations.

Further discussions with Compliance and Administrative Group, Project

Control Group, and Maintenance sub group personnel included a review

of the following:

Weekly and monthly surveillance test schedules

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

, during the performance of Technical Specification required

surveillances. As with Technical Specification required calibra-

! 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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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 performed. 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 surveillances. Subsequently, the inspector

reviewed the appropriate surveillance procedures which documented the

performance of these calibrations.

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 accomplished.

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Applicable surveillance procedures were approved, up-to-date,

and used throughout the conduct of the surveillance.

Appropriate personnel were notified prior to the start of the

test.

Calibrated test equipment was used.

Acceptance criteria were met, and if not, appropriate corrective

action was taken.

Properly specified parts and materials were identified, and

Following completion of the test, systems were aligned for

normal operation.

During the calibration of Reactor High Pressure sensor PS-261-23A,

"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 range. Subsequent inspection of the environmentally

qualified Barksdale switch cover plate gasket indicated the need for

replacement. 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 replaced.

4.3 Findings

The inspector expressed some concern over the lack of programmatic

controls for controlling calibration activities. 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. above.

5. Measurement and Test Equipment (M&TE)

5.1 Scope and Criteria

Refer to paragraphs 3.1.

5.2 Program Review / Implementation

The inspector held discussions with individuals designated to ad-

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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 following.

Calibration records

Toolroom controls

Equipment master list for I&C and Station Services

M&TE records

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 controlled.

5.3 Findings

5.3.1 Issuance and retrieval of all M&TE is handled by the

toolroom attendants. M&TE was adequately controlled

through the utilization of calibration logs, history

records and issuance logs. Equipment was found to be

appropriately stored and identified. M&TE was found to

fall into one of the following categories:

Out for re-calibration

Segregated (due for re-calibration or inoperable)

In-use, and

j Restricted use

5.3.2 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 1.3.36.

Over 18 instances were found where these evaluations were

not completed by I&C and Station Services. 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 actions. I&C attributed their failure to com-

plete these evaluations to staffing problems.

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).

No other violations or deficiencies were observed.

6.0 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 outages.

The previous refueling bridge had a long history of both mechanical

and electrical equipment failure. 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 outdated.

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

control. .

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 bridge. 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 modification.

6.2 Criteria and Documents Reviewed

See paragraph 3.2 and Attachments B and C.

6.3 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 normal. In addition, completed

portions of TP86-127 were reviewed. No refueling bridge testing was

conducted during this inspection.

6.4 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

procedures. 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 wall.

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 incorrect.

The inspector discussed this concern with the licensee test director

who had performed this portion of the procedure on October 8,1986.

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 procedure.

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 approved. 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 existed. The absence of a

procedure to control the conduct of preoperational testing is another

example of the violation discussed in paragraph 3.3.3 above.

7.0 Refueling Bridge Post Modification Training

The inspector discussed the training of licensee personnel concerning the

refueling bridge modification with two licensee training representatives.

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 operators.

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

operators.

No deficiencies were identified with regard to the' licensee's program for

refueling bridge post modification training.

8.0 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 / unloading.

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 performed.

The inspector compared these attachments with the Technical Speci-

fication requirements for fuel loading / unloading. See Paragraph 3.1

and Attachment B for requirements and inspection criteria.

8.2 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 4.3. The inspector questioned a licensee

representative concerning this item. He stated that this item had

been previously identified and was to be included in the next

revision of the procedure. The inspector reviewed a draft copy of

the procedure revision and verified that the requirement for system

operability was included. 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 3.1.1.

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 step. After discussion with the licensee

representative, he committed to including a reference to these

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surveillances in step 18 of OPER-10. No violations or other

deficiencies were identified.

9.0 Quality Assurance / Quality Control (QA/QC) Interface

The Quality Assurance group is represented on-site, along with Quality

Control personnel. Thus, these independent groups are able to actively

monitor on going station activities. 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 levels.

Approximately 17 QA surveillance reports were reviewed by the inspectors.

This review included the following:

Surveillance checklists

Evaluation sheets

Nonconformance reports, if applicable

Trending input sheets, and

Department responses, if applicable.

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 report.

10.0 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 inspection. An exit interview

was conducted on January 16,1987 (see Attachment A attendees) at which

time the findings of the inspection were presented.

At no time during this inspection was written material concerning

inspection findings provided to the licensee by the inspectors.

A subsequent telephone discussion concerning clarification of the

inspection findings was conducted between the inspector and Mr. E. Graham

on January 21, 1987.

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ATTACHMENT A

PERSONS CONTACTED

1. 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

Technicians.

2. USNRC

M. McBride Senior Resident Inspector

• J. Lyash Resident Inspector

• Denotes those present at exit interview.

d'

'

t+

ATTACHMENT B

' PROCEDURES REVIEWED FOR CONTROL OF

SURVEILLANCE TESTING AND CALIBRATION

--

1.3.4 Procedures

--

1.3.6 Adherence to Technical Specifications -- 1.3.36 Measurement and Test Equipment

~ - -

1.8 Master Surveillance Tracking Program

--

'1.8.2 PM Tracking Program

--

2.1.5 Daily Surveillance Log (Technical Specifications and Regulatory

Agencies)

--

4.3 Fuel Handling

=

a

.

L

ATTACHMENT C

REFERENCES REVIEWED FOR CONTROL OF

MODIFICATION AND TESTING OF THE

REFUELING BRIDGE

--

Pilgrim Nuclear dawer Station (PNPS), Technical Specifications

--

PNPS, Final Safety Analysis Report (FSAR)

--

Nuclear Operatio1s Procedure 83A6 (N0P83A6), Modification Management,

July 31, 1984.

--

Nuclear Operations Procedure 83E1 (N0P93EI), Control of Modifications to

Pilgrim Station, September 17, 1986.

--

Nuclear Operations Department, PNPS, Procedure No. TP86-127, Preoperation-

al Test for Refueling Bridge, Revision 6, January 7, 1987.

--

Nuclear Operations Department, PNPS, Procedure No. TP86-182, Preoperation-

al Test for Refueling Bridge / Vessel Disassembled, Revision 0, January 3,

1987.

--

Instruction Manual IM-01620, Refueling Platform BECO, Pilgrim Station,

P.O. No. 68521, Volume 1 of 2, Revision 0, February 25, 1986.

--

Safety Evaluation, PNPS, No. 2044, Approved January 6, 1987.

--

Modification Management Work Instruction Manual, Approved January 12,

1987.

1

. -

ATTACHMENT D

PROCEDURES AND DOCUMENTS INCLUDED

IN REFUELING BRIDGE POST MODIFICATION TRAINING

---

Technical Specifications 3.10 " Core Alterations", and bases.

--

Technical Specifications 3.3 " Reactivity Control", and bases.

--

PNPS Procedure 4.0 "SNM Inventory and Transfer Control".

--

PNPS Procedure 4.3 " Fuel Handling".

--

PNPS Procedure 5.4.2 " Refueling Floor High Radiation".

--

PNPS Procedure 2.2.75 " Fuel Handling and Servicing

Equipment".

--

PNPS Procedure 4.5 " Reactor Core Fuel Verification".

--

PNPS Procedure 8.10.1 " Refueling Interlocks Functional

through 8.10.6 Tests".