IR 05000293/1998002

Ack Receipt of 980618 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/98-02.Actions Will Be Examined During Future Insp

ML20237E772
Person / Time
Site:	Pilgrim
Issue date:	08/27/1998
From:	Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Olivier L BOSTON EDISON CO.
References
50-293-98-02, 50-293-98-2, NUDOCS 9809010164
Download: ML20237E772 (3)

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August 27,1998 Mr. Leon Senior Vice President - Nuclear

! ' BEC Energy Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, Massachusetts 02360-5599 SUBJECT: NRC INTEGRATED INSPECTION REPORT 50-293/98-02 AND NOTICE OF VIOLATION

Dear Mr. Olivier:

This letter refers your June 18,1998 correspondence responding to our May 19,1998 letter.

Thank you for informing us of the corrective and preventive actions documented in your letters. These actions will be examined during future inspections of your licensed program.

Your cooperation with us is appreciated.

Sincerely, Original Signed By:

Curtis J. Cowgill, Ill, Chief Reactor Projects Branch No. 5 Division of Reactor Projects Docket No. 50-293 cc w/o cv of Licensee Response letter:

R. Ledgett, Executive Vice President - Operations C. Goddard, Plant Department Manager J. Alexander, Regulatory Relations D. Tarantino, Nuclear Information Manager cc: w/cv of Licensee Resoonse letter R. Hallisey, Department of Public Health, Commonwealth of Massachusetts The Honorable Therese Murray The Honorable Joseph Gallitano T. MacGregor, Mass. Dept. of Public Comm. & Energy Chairman, Plymouth Board of Selectmen Chairman, Duxbury Board of Selectmen Chairman, Nuclear Matters Committee Plymouth Civil Defense Director 9809010164 980827 PDR ADOCK 05000293 G pm l f' ' D '

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Mr. Leon P. Gromer, Massachusetts Secretary of Energy Resources J. Miller, Senior issues Manager J. Fleming A. Nogee, MASSPIRG Office of the Commissioner, Massachusetts Department of Environmental Quality Engineering Office of the Attorney General, Commonwealth of Massachusetts T. Rapone, Massachusetts Executive Office of Public Safety Chairman, Citizens Urging Responsible Energy Commonwealth of Massachusetts, SLO Designee

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Mr. Leon Distribution w/cy of Licensee Response Letter:

Region i Docket Room (with concurrences)

PUBLIC Nuclear Safety Information Center (NSIC)

NRC Resident inspector H. Miller, RA/W. Axelson, DRA C. Cowgill, DRP R. Summers, DRP C. O'Daniell, DRP B. McCabe, OEDO C. Thomas, NRR (COT)

A. Wang, NRR R. Correia, NRR F. Talbot, NRR DOCDESK Inspection Program Branch, NRR (IPAS)

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DOCUMENT NAME: G:\ BRANCH 5\RPLY-LTR\PIL-RPY.898 T3 receh,e a copy of this document. Indcate in the boa: "C" = Copy without attachment / enclosure "E' = Copy with attachment / enclosure 'N' = No copy OFFICE Rl/DRP h) f h Rl/DRP / l l NAME CCowgill D f/m DATE 08/18/98 P 08/ /98 08/ /98 08/ /98 08/ /98 OFFICIAL RECORD COPY

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10 CFR 2.201

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O so. con am-> I Pilgrim Nuclear Power Station l 600 Rocky Hill Road Plymouth, Massachusetts 02360 L June 18,1998 Senior Vice President Nuclear BECo Ltr. #2.98.076 i U.S. Nuclear Regulatory Commiscion Attention: Document Control Desk i Washington, DC 20555 I Docket No. 50-293 License No. DPR-35 REPLY TO A NOTICE OF VIOLATION i

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NRC INSPECTION REPORT NO. 50-293/98-02. DATED MAY 19,1998

Enclosures 1,2 and 3 provide Boston Edison Company's reply to the Notice of Violation i contained in the subject inspection report.

I This letter includes the following commitments.

Violation 98-02-02 Core Sorav Pumo Motor (Enclosure 1):

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Appropriate design documents and maintenance instructions will be revised to provide details of the cooling coil / packing gland arrangement and incorporate necessary precautions. The revisions will be completed by September 30,1998.

Training on this issue will be developed and presented to the appropriate personnel by December 30,1998.

Violation 98-02-03 Material Condition (Enclosure 21:

The circumstances regarding this violation and management expectations concerning

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the low threshold material items will be reviewed with appropriate station personnel by September 30,1998.

Violation 98-02-07 Desian Control (Enclosure 3):

Training will be provided to engineering personnel on substitution equivalency evaluation preparation with ' an emphasis on reviewing the physical /special requirements of component replacement. This will be completed by September 30,1998.

Please do not hesitate to contact me if there are any questions regarding the enclosed reply.

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Enclosure 1: Reply to Violation 98-02-02 Enclosure 2: Reply to Violation 98-02-03 Enclosure 3: Reply to Violation 98-02-07 298076 WGU VIO98-02-02. 03 &O7 cc: Mr. Alan B. Wang, Project Manager Project Directorate I-3 Office of Nuclear Reactor Regulation USNRC, Mail Stop: OWFN 1482 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 Region I, U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident inspector Pilgrim Nuclear Power Station

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Boston Edison Company Docket No. 50-293 Pilgrim Station License No. DPR-35

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ENCLOSURE 1 l

Repiv to Violation No. 98-02-02 VIOLATION Pilgrim Technical Specifications, Section 6.8, " Procedures", requires that written procedures be implemented for activities covered by Regulatory Guide (RG) 1.33, Appendix A. RG 1.33, Appendix A, Section 9, " Procedures For Pedorming Maintenance,' requires that maintenance be performed in accordance with written-procedures or instructions that are appropriate to the circumstances. BECo procedure 1.5.20, ' Work Control Process,' step 7.4.2[5] specifies that work plan details shall be commensurate with the complexity of the task.

Contrary to the above, the work plan to replace the external cooling water flexible hoses j to the 'A' core spray pump motor was not commensurate with the complexity of the \

task. As a result, physical damage occurred to an internal upper motor cooling coil 1 resulting in significant rework and additional worker radiation exposure. {

This is a Severity LevelIV violation Supplement I.

REASON FOR THE VIOLATION I The reasons for the violation were as follows:

(1) Inadequate preparation of the work plan used to replace the external flexible hoses connected to the internal cooling coil in the "A" core spray pump motor (P-215A). I The work plan team failed to consider the need for precautions concerning the

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fragility of the internal cooling coil as referenced in GE-SIL #5 and did not recognize contingency steps might be required to attain minimum bend radius for the flexible hose.

, (2) Field personnel replacing the flexible hose also erred when, in the absence of l specific guidance, they assumed the portion of the cooling coil penetrating the motor l l housing was a slip fitting. Consequently, when the need to make an adjustment i arose that would allow attaining the minimum flex hose bend radius, the cooling coil

nipple was rotated without confirming the actual configuration. Rotating the cooling l coil caused a leak which was discovered while preparing for post work testing.

l l CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED

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The Maintenace Work Package (MWP) scope was modified, the damaged internal cooling l coil was replaced, and the post work testing was completed or' April 4,1998 (MR19800660 I

and MR19701704).

. The human performance aspects of this issue were reviewed with mechanical and electrical maintenance personnel and planners. This was completed on April 11,1998.

. The flexible hose replacement MWPs for P-215B and P-203A, B, C, and D (RHR pumps)

have been revised to include appropriate details and precautions. This was completed on April 29,1998.

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CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS (

! * Appropriate design documents and maintenance instructions (vendor manual, V-0367, "GE Induction Motors" and isometric drawing M-1004) will be revised to provide details of the cooling coil / packing gland arrangement and to incorporate necessary precautions. These changes will be completed by September 30,1998. [RC 98.2076.10 and 20]

. Training will be developed and presented to appropriate personnel by December 30,1998. I The focus of the training will be reinforcement of quality verification and validation (OV&V) l methods, communications between the various groups involved in work plan preparation l

, and performance, and reinforcement of self-checking philosophies and methodologies. (RC i 98.2076.30] -

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l DATE WHEN FULL COMPLlANCE WILL BE ACHIEVED I l Full compliance was achieved on April 29,1993, when the remaining work plans for similar

! motors were upgraded to provide sufficient details.

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Boston Edison Company Docket No. 50-293 Pilgrim Station License No. DPR-35 ENCLOSURE 2 Ren!v to Violation No. 98-02-03 )

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VIOLATION t 10 CFR 50, Appendix B, Criterion XVI, " Corrective Actions," states that, measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, defective material and equipment, and non-conformances I are promptly identified and corrected. -

i Contrary to the above, the NRC identified that appropriate measures were not being .

implemented to assure prompt identification and correction of several conditions l adverse to quality, including:

I. a broken conduit on the high pressure coolant injection system turbine that exposed and stretched electricalleads for an oil temperature alarm;

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2. a leaking instrument air line supply for valves in the spent fuelpool system; 3. an oilleak caused by a defective weld in the "A" reactor recirculation system ,

motorgenerator(MG) set oilline; l 4. excessive vibration in an oil line on the 'A' reactor recirculation set MG set caused by a loose U-bolt piping clamp; 5. loss of operating status indication light on the local electrical switchgear for the

"B' fluid drive oil pump for the 'B' reactor recirculation MG set, this condition existed for 3 days and went undetected; This is a Severity LevelIV violation (Supplement I).

REASON FOR THE VIOLATION

'The reason for the violation was failure to communicate to the plant staff expectations for prompt identification and corrective action of low threshold material deficiencies.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED

• A meeting with operations managers and all SROs was conducted on May 7,1998, to communicate raised expectations regarding prompt identification of low threshold material deficiencies. Subsequently, the number of work request tags (WRTs) written during the month of May rose dramatically. The total number of WRTs written in May 1998 was 364 which represents a 58% increase over historical monthly averages. Of these,68% were classified as low threshold.

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. The status of the five examples included in the violation is as follows:

HPCI loose conduit: MR19800702 was initiated. A system outage is needed for repair.

Instrument air leak: MR19800709 was initiated and will be completed by June 26,1998.

Recire Pump 'A' oil leak: MR19702768 was initiated. A system outage is needed for repair.

Recirc MG Set B fluid drive oil pump indicating light: Corrected Recirc MG Set A loose pipe clamp: Corrected

. A series of plant walk-downs to identify low threshold material conditions not yet captured in the work control process was initiated. Cross functional teams were assembled and assigned specific areas of the plant to walkdown. These ' walk-downs provided an-opportunity to mentor key personnel in the identification of low threshold material deficiencies. This effort is complete.

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. The following interim measures were implemented on May 11,1998:  !

I A temporary team comprised of an SRO, maintenance, planning, and station services i personnel, as needed, was formed to identify and systematically correct low priority material deficiencies in the plant. This will help minimize the backlog of low threshold material deficiencies.

The existing 12 week maintenance schedule was changed to a 13 week schedule.

This extra week will be dedicated to correcting minor maintenance items to help minimize the backlog of low threshold material deficiencies.

CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Management expectations concerning low threshold material deficiencies will be reviewed with appropriate station personnel by September 30,1998. [RC 98.2076.40} The effectiveness of this training will be determined via the PNPS self assessment process. [RC98.2076.50]

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED 4 Full compliance will be achieved on September 30, 1998, following completion of station personnel training on plant management expectations concerning prompt identification of low threshold material deficiencies in the plant.

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Boston Edison Company Docket No. 50-293 Pilgrim Station License No. DPR-35 I

ENCLOSURE 3 Reply to Violation No. 98-02-07 VIOLATION 10 CFR 50, Appendix B, Criterion Ill, * Design Control," states that measure shall be established to assure that the design basis of components are correctly translated into l

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procedures and instructions. These measures shallinclude provisions to assure that l appropriate quality standards are specified and included in design documents and that-deviations from such documents are controlled.

Contrary to the above, the design basis of a component was not correctly translatedinto procedures in that Field Revision Notice 94-02-27, which installed the new "A" salt '

service water pump motor, did not address the unique configuration of the pump

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pedestal (weld pads). As a result, the pump motor shaft failed twice in 1997 due to misalignment of the pump and motor.

REASON FOR THE VIOLATION l The cause of the violation was human error while performing Substitution Equivalency Evaluation (SEE) 464, in that the actual configuration of a "A" SSW pump motor and pedestal i was not recognized. This error led to motor misalignment and subsequent motor drive shaft I failures. (PR 98.1083)

SEE 464 was prepared on April 8,1992, with generic applicability to all service water pump motors. In accordance with the SEE procedure, NESG 3.16, " Substitution Equivalency Evaluation", applicable procedures and all interface drawings are to be reviewed during the development of a SEE. However, drawing M8-27 " Service Water Pump (P-208A-E) Motor Base", was not reviewed or referenced as part of SEE 464. This drawing documented the l unique motor base configuration for pump P-208A. l l

In 1994, a work package was prepared to replace the motor P-208A using SEE 464. I Subsequently, the work package made no reference to the motor base drawing, M8-27. As '

such, the drive shaft was installed without recognizing the unique configuration of the P-208A motor base. The shaft was replaced as part of normal maintenance in March 1996. Some shaft misalignment likely resulted.

l The P-208A drive shaft failed on August 26,1997, after eighteen months in service. The failed shaft was removed and replaced on August 27,1997. A second shaft failure occurred on the same pump on October 19,1997. While investigating the second shaft failure (PR 97.9533) , .

the gap between the motor and the motor base was discovered that had resulted in excessive i shaft misalignment in summary, the design basis of the SSW pump pedestal was not correctly translated into the work package due to the error of omitting drawing M8-27 from SEE 464.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED e The motor base for pump P-208A has been returned to its original configuration, and drawing M8-27 has been revised to show the motor base for P-208A in its original configuration. This was completed on June 9,1998.

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! . The pump general maintenance procedure 3.M.4-14.2, " Salt Service Water Pumps: Routine l Maintenance", was revised on May 4,1998, to incorporate the pump motor alignment l checks.

l e The electrical engineering department manager discussed this issue with the personnel involved in the preparation of SEE 464.

CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Training will be provided to engineering personnel regarding preparation of SEES for generic

, applications. The training will emphasize the need to review all affected design documents so l unique component configurations can be assessed. This will be completed by September 30,-

1998. [RC 98.2076.60]

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

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Full compliance was achieved on June 9,1998, after the P-208A motor base was restored to its original configuration and design documents were revised to properly reflect the base motor configuration.

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