IR 05000293/1987034

Insp Rept 50-293/87-34 on 870804-0914.No Violations Noted. Concerns Stated.Major Areas Inspected:Plant Operations, Radiation Protection,Physical Security,Plant Events,Maint, Surveillance,Outage Activities & Repts to NRC

ML20236R612
Person / Time
Site:	Pilgrim
Issue date:	11/06/1987
From:	Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236R594	List: IR 05000293/1987034 ML20236R592
References
50-293-87-34, GL-87-03, GL-87-3, NUDOCS 8711230384
Download: ML20236R612 (17)

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U. S. NUCLEAR REGULATORY' COMMISSION

' REGION I-q Docket / Report N /87-34 Licensee: Boston Edison Company 800 Boylston Street Boston, Massachusetts. 02199 Facility: Pilgrim Nuclear Power Station Location: Plymouth, Massachusetts Dates: August 4 - September 14, 1987 Inspectors: '

M. McBride, Senior Resident' Inspector J. Lyash, Resident Inspector T. Kim, Resident Inspector L. Doerflein, Project Enginee R. Fuhrmeister, Reactor Engineer Approved By: // d'2 A. Bloughrthief, Reactor Projects Date Section 3B  ;

Areas Inspected: Routine resident inspection of plant operations, ' radiation protection, physical security, plant events, maintenance, surveillance, outage activities, and reports to the NRC. The inspection consisted of -325 hours of direct inspection by three resident and two regional inspectors. . Principle persons contacted by the inspectors are listed in Attachment Results: No violations were identifie The. inspectors- made . the following observations:

Concerns: The licensee's radiological assessor identified a locked high radiation i area door unlocked, open and apparently unguarde Similar problems with the control of high radiation areas were the subject of violations during inspections 50-293/87-03 and 50-293/87-11. The inspector stressed the need to ensure this continuing weakness is resolved at -all levels of the organization (Section 3.c). Controls implemented by a contractor radiographer were weak and immediate response by licensee field technicians to the incident was slow (Section 3.c).

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. The licensee's response to Violation 85-06-02 was reviewe Licensee justification for requesting withdrawal of. the violation was not con-sidered adequate, however corrective actions implemented subsequently

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appear to resolve the concerns raised (Section 2.0).

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l The licensee's security force responded promptly and effectively to an incident involving four individuals making an unauthorized entry into the owner controlled are Unresolved Items The inspectors will review the licensee's engineering evaluation support-ing seismic qualification of the reactor auxiliary bay and intake struc-ture (Section 3.a). The new containment spray nozzles were procured as "non-Q" component The licensee will provide the inspectors the reasons why these components were procured "non-Q" and the process that was taken to upgrade the

! components to "Q" (Section 3.b).

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TABLE OF CONTENTS Page Summa ry o f Fa c i l i ty Acti v i tie s . . . . . . . . . . . . . . . . . . . . . . . . 3

Followup on Previous Inspection Findings .......... ...

' Violations, Unresolved Items, Inspector Follow Items 3, Routine Periodic Inspections .......................... 9 - Plant Observations Plant Maintenance and Outage Activities Radiation Protection Surveillance Testing j l Review of Plant Events ................................ 13 l

, Loss of Security Area Key Control Residual Heat Removal System Pipe Corrosion Four Individuals Arrested in the Owner Controlled Area Suspected Alcohol Use by Contract Employees While On Duty Meetings ............. ................................ 15 ,

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Attachment I - Persons Contacted

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DETAILS i 1.0 Summary of Facility Activities The plant was shutdown on April 12, 1986 for unscheduled maintenance. On July 25,1986, Boston Edison announced that the outage would be extended to include refueling and completion of certain modification .0 Followup on Previous Inspection Findings Violations (Closed) Violation (83-23-01), failure to test the HPCI injection check valve at the frequency specified in the IST program. This item was last updated in inspection report 50-293/86-25. During inspection 83-23 the inspector identified that testing required by the licensee's Inservice Test (IST) Program had not been implemented at the prescribed frequency for the high pressure coolant injection (HPCI) system injection check valve 2301-7. The licensee subsequently instituted testing which verifies opening of the 2301-7 valve by mechanical manipulation, with the system draine Similar testing was also initiated. for the reactor core isola-tion cooling (RCIC) injection check valve, 1301-50. The frequency of this testing was established consistent with the licensee's IST program submit-tal and applicable relief requests. The inspector also expressed concern during inspection 83-23 that HPCI check valve 2301-7 was not verified to seat on reversal of flow. In response, the licensee added tests to mech-anically verify that HPCI check valve 2301-7 and RCIC check valve 1301-50 would close. The residual heat removal (RHR) and core spray (CS) injec-tion check valves (1001-68A and B, and 1400-9A and B respectively) how-ever, were only tested in the open direction during pump flow tests. In addition the requirement to perform closing tests was not included in the licensee's IST program for any of these check valve The valves discussed above serve as isolation boundaries between high and low pressure systems. NRC Generic Letter (GL) 87-06, Periodic Verifica- '

tion of Leak Tight Integrity of Pressure Isolation Valves (PIV), states I that periodic tests of the leak tight integrity of all PIVs is necessar )

GL 87-06 requests licensees to submit a list of all PIVs and tests which verify this integrit The inspector noted that the licensee's response to GL 87-06 did not list the HPCI or RCIC injection check and gate valves and did not specify periodic leak testing for many valves which were listed. During the current outage, the licensee elected to perform appro-priate leak tests of the subject valve The inspector reviewed the. com-pleted test results and verified that adequate acceptance criteria had been specified and satisfie In addition, the licensee added this leak testing to the Master Surveillance Tracking Program (MSTP) for continued

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implementation at an interval of two years. The licensee plans to revise the Inservice Test (IST) program to include these test requirements. The licensee also stated that an updated response to GL 87-06 including the HPCI and RCIC valves and listing all appropriate tests would be submitte Based on completion of the testing during this outage, its addition to the MSTP, and the licensee's commitment to update the IST Program and their response to GL 87-06 this item is close (Closed) Violation (84-36-03), failure to continuously monitor the SRMs during refueling. This item remained open pending NRC review of the licensee's commitment to improve the shift turnover process in the control roo During this inspection period, the inspector reviewed the revised station procedure 1.3.34, Conduct of Operations, Rev.12, and associated OPER 38, Shift Turnover Checklis The inspector also observed Nuclear Operations Supervisor and Nuclear Plant Operator shift turnovers and determined that adequate transmittal of information regarding plant status and changes in plant conditions were performed. This item is close (Closed) Violation (85-06-02), failure to perform DOP testing of SBGT fol-lowing removal and reinstallation of the HEPA filters. On March 15, 1985 structural maintenance was done on the high efficiency particulate air (HEPA) filter housings of the A standby gas treatment (SBGT) train. Fol-lowing completion of the repairs, the filters were not tested with diotyl phthalate (DOP) until the concern was raised by the inspector on March 27, 198 The DOP test is required by technical specification after perform-ance of any maintenance which could affect HEPA filter bypass leakag The reactor was taken critical on March 20, 1985 and the SBGT system was considered operable by the licensee with the unit at power for seven days without performance of this test. The licensee contested the violation as documented in the response letter dated May 24, 1985, on basis that no time limitation for performance of the test was specified in the technical specification The inspector subsequently raviewed this response and concluded that this position was not appropriate since the DOP test pro-vides assurance that the system is operable after significant maintenanc Failure to perform the test for seven days resulted in the SBGT system operability status being indeterminant. Licensee management acknowledged the inspector's concern and stated during the exit interview conducted on September 17, 1987, that the philosophy regarding surveillance test impie-mentation had been altered since submission of the respons In response to the violation the licensee immediately declared the system inope:ble on Me rch 27,1985, then promptly performed the required tes Procedure 3.M.4-38, SBGT Maintenance, was subsequently (i.e., in August 1987) revised to sequence performance of the DOP testing prior to sign off of SBGT maintenance work as complete. This appears adequate to ensure the timely performance of this testing. Based on this corrective action, this item is close _ _ _ _ _ - _ _ .

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Unresolved Items-(Closed) Unresolved Item (83-19-05), review the NSRAC quorum requirement and their method for reviewing safety . evaluations. During inspection-50-293/83-19 the inspector questioned the licensee's -interpretation Lof Technical Specification (TS) 6.5.1'3.6 (Quorum), and TS 6.5.13.7 '(Review)

as applied to safety. evaluation As a result of licensee ... reviews, TS 6.5.13.6 was subsequently revised. by Amendment 104 to clearly- state. that a ' '

quorum of the Nuclear Safety Review and Audit Committee (NSRAC) shall con -

sist of the Chairman and at least four members. The. NSRAC Charter is con- ,

sistent with this TS quorum requiremen Inspector followup also'noted i that NSRAC meets substantially more frequently than the technical specifi_-- l cation- requires and normal attendance at these ' meetings consistently exceeds the minimum quorum. The NSRAC charter also states that the NSRAC will independently review completed 10 CFR 50.59 safety evaluations and j their bases to verify that such actions do not constitute an unreviewed  ;

l safety questio The inspector reviewed numerous NSRAC meeting minutes

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and has attended several committee meetings. Based on these observations NSRAC appears to have satisfactorily implemented. the safety evaluation review requirement. This item is close (Closed) Unresolved Item (86-07-05), review licensee corrective actions

, to ensure proper package searche The inspector reviewed licensee

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security procedures and post. orders, and observed security personnel assignment and performance in the- fiel Based on the above it appears ,

that the licensee has establishe'd adequate personnel assignments, instruc-

tions and package search requirements for the area of concern. Routine audits of vital area access were performed by the resident inspectors to ensure that other areas were also being properly controlled. The inspec-tor had no further. questions, this. item is closed.

l~ (Closed) Unresolved Item (86-24-02), licensee to demonstrate operability of the backup scram valves each refueling outage. The inspector reviewed procedure 8.M.1-22, " Reactor Mode Switch In Shutdown", Revision 13,'and determined that the procedure was revised to include a verification that the backup scram valves vent and that the scram pilot valve air header low pressure alarm is received during the tes Procedure 8.M.1-22 -is re-quired by the Technical Specifications to be performed each refueling out- i age and has been scheduled to be performed thirty days prior to'startup

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from the current outage. The inspector had no further questions on this ite (Closed) Unresolved Item (87-01-01), review refueling bridge welding and bolting. During inspection 50-293/87-01 the inspector identified 'struc-tural steel welds on the new refueling platform, that was being prepared for initial use, which did not meet the requirements of part 3.3.1 of AWS D1.1 in that, there was excessive fitup gaps with appropriate increases in weld sizes. In addition the inspector questioned the acceptability of bolts used to anchor several cable take-up assemblies to the refueling platform. The plant design change (PDC) package for the installation of 1 - - .-___--__---_- _ _ _ *

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the refueling bridge was originally designated as non-Q. The resident inspectors questioned this designation during inspection 50-293/86-36 (Unresolved Item 86-34-02) in September 198 Subsequently, the licensee Quality Assurance Department issued Stop Work Order (SWO) '86-01 on November 21, 1986 which prohibited use of the platform for fuel movement pending resolution of this issue. The PDC was reevaluated by the licensee engineering department. The refueling platform is considered a seismic class II component which could affect the operation of seismic class I systems and therefore must be classified as Q in accordance with the i licensee's Quality Assurance Manual. The PDC was withdrawn, the seismic analysis of the refueling platform and appurtenances was reperformed, and the PDC was reissued as Q under Field Revision Notice 85-58-22 on January 9, 198 The reissued PDC contained, on Exhibit 3.02-R, page 17, l

Quality Control (QC) inspection requirements for all structural and non-structural field weld Acceptance criteria for the structural welds required removal of any paint and visual inspection in accordance with AWS 01.1-198 The licensee Quality Assurance Department had previously l evaluated the platform supplier's QA program for shop welding and deter-l- mined it to be acceptabl On January 7, 1987 licensee QC performed visual inspection of those welds identified as deficient by the inspecto Nonconformance Report (NCR) 87-01 was issued to document the ' finding Subsequently, the licensee performed the QC inspections specified in the upgraded PD A total of forty-three NCRs were generated to document various weld discrepancies. Of the total fifty-eight structural field welds, forty-seven failed QC inspection. All of the NCRs were evaluated, l dispositioned and closed prior to retraction of QC SWO 86-01 on l January 16, 1987. The inspector reviewed a sample of the NCR dispositions

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for adequacy. The inspector also reviewed the stress calculations for the l cable take-up assembly platforms. The calculations appeared to consider a all applied and seismic loads and demonstrated acceptable safety margin "

l The licensee revised appropriate portions of their Quality Assurance Manual and the 'Q' list to clarify quality classification requirements for modifications potentially affecting seismic class I equipmen The licensee's Design Review Board has been instructed to ensure implementa-tion of these requirement The licensee also stated that a review of ;

other modifications would be conducte This review will be performed !

consistent with the licensee's response to NRC Generic Letter 87-03, l Verification of Seismic Adequacy of Mechanical and Electrical Equipment in I Operating Reactors. Based on the above, this item is closed.

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J Inspector Follow Items (Closed) Followup Item (84-28-01), review the licensee's actions to l improve control of nonconforming materials. During a previous' inspection period, the inspector noted a weakness in control of nonconforming mate-rials as evidenced by the lack of a tag on the nonconforming valve, the lack of a Non-Conformance Report (NCR) on the pipe gouge, and the lack of administrative control in the contractor surveillance inspection report (SIR) system. This item was last reviewed in inspection report 50-293/

86-01 at which time the inspector noted that the licensee contractor dis-continued tracking items under the SIR syste The licensee initiated NCRs and Failure and Malfunction Reports (F&MR), in place of the SIRS which reduced complications in controlling nonconforming conditions. The inspector also reviewed documentation associated with the pipe gouge repair, including: the dispositioned G.E. NCR RS-003, the completed work traveler 84-400-033, the liquid penetrant examination report of the pipe repair area and no discrepancies were note During this inspection period the inspector reviewed the latest licensee program in controlling nonconforming material In March of 1987, the licensee erected a QC con-trolled area to segregate nonconforming contaminated materials in the reactor building elevation 91' along the north wall of the drywell . A l cage with wire screen mesh door, sides, and roof has been erected and i tagged "QC Hold Area for Contaminated Materials". Based on the above this item is close (Closed) Followup Item (85-28-05), follow up on the licensee's evaluation of the operability of exposed instrument lines connected to the fire water storage tanks. During a previous inspection period, the inspector ques-tioned the operability of two small exposed instrument lines connected to the fire water storage tanks. Flexible conduit originally protected the lines, but has since mostly rusted away. The instrument lines are used to sense water temperature and activate tank heaters. The licensee has since replaced the rusted flexible conduit with rigid conduit. A licensee main-l tenance engineer and the inspector examined the new conduit on August 25, l 198 The licensee also provided the inspector with vendor information I which indicated that any damage, including harsh environment, to the exposed sensing lines would result in the actuation of the heating syste The Trerice three way TC plug valves are designed to fail open on loss of service air, low temperature, and damage to the capillary tubes, to allow heating water to circulate through the heating coils of the fire water storage tank The inspector had no further questions. This item is closed.

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(Closed) Inspector Followup Item (85-30-01), licensee to correct defici-encies noted in various procedures. The inspector reviewed procedures 2.2.21, ' "Hi gh Pressure Coolant Irjection System", 2.3.2.2, " Panel 903 ,

Center Control Room", 2.2.47, "HPCI Room Cooling.and Ventilation System",

and 2.2.48, " Reactor Building Quadrants Cooling and Ventilation System",

to verify that the licensee revised the procedures as necessar The q respective procedures were revised to refer to appropriate ECCS technica specifications when redundant unit coolers are. out of service, to reflect the correct setpoint for valve MO-2301-14, and to include procedural steps ;

and an explanation for the three minute nitrogen purge of the HPCI exhaust line after a turbine shutdown. The -inspector had no further questions regarding this ite (Closed) Inspector Followup Item (85-30-08), licensee to review control ;

of instrument isolation valves. The inspector noted that this item is 1 identical to item 86-06-01. The licensee. committed to identify instru- i ment root and isolation valves and to establish how these valves will be !

controlled. Licensee actions will be reviewed in under existing item 1 86-06-0 Item 85-30-08 is administratively close <

(Closed) Inspector Followup Item (86-06-02), review licensee's evaluation of Hi/Lo annunciators. The inspector noted that the licensee implemented l

PDC 82-25 to split both recirculation pump Hi/Lo oil level alarms into I separate alarms for upper bearing high level', upper bearing low level, and '

lower bearing low level. The inspector reviewed alarm response procedures 2.3.2.5, 2.3.2.6, and 2.3.2.7, and verified the appropriate revision had been made to reflect the new alarm The inspector also noted that the licensee will address control room dual function annunciators as part of the Control Room Design Review reperformance, and that - procedure N .3.1, " General Action (Alarm Procedures)", was revised to require the operator to determine which input caused a common annunciator to alar The inspector had no further questions on this ite j (Closed) Inspector Followup Item (86-06-03), licensee to complete compo-nent labeling and establish controls to periodically review the status of component tags. The inspector noted that the licensee has completed the system walkdowns which included identification of all unlabeled or mis-labeled valves up to and including the instrument root valves. Also, the licensee has essentially completed hanging tags on those valves which were noted as not correctly labeled during the walkdown The inspector :

reviewed the valve labeling on portions of two safety related systems and '

found it adequate. The inspector also reviewed several safety system oparating procedures and verified that the revised procedures require the operator verify that valve labels are in place when performing valve line-ups. Copies of valve lineup pages identifying mis. sing valve labels are forwarded to the shift administrative assistant for tag replacement. The inspector had no further questions on this item.

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3.0 Routine Periodic Inspections The inspectors routinely toured the facility during normal and backshift hours to assess . general plant and equipment conditions, housekeeping, and )

adherence to fire protection, security and radiological control measure Inspections were conducted between midnight and six a.m. on August 31, 1987 for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and September 1,1987 for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and weekends on August-15, August 22, and September 6, 1987 for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Ongoing work activities I were monitored to verify that they were being conducted in accordance with

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approved administrative and technical procedures, and that proper communi-cations with the control room staff had been established. The inspector observed valve, instrument and electrical equipment lineups in the field to ensure that they were consistent with ' system operability requirements and operating procedure During tours of the control room the inspectors verified proper staffing, j

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access control and operator attentivenes Adherence to procedures and limiting conditions for operations were evaluate The inspectors examined equipment lineup and operability, instrument traces and status l

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of control room annunciators. Various control room logs and other avail-able licensee documentation were reviewe l The inspector observed and reviewed outage, maintenance and problem inves-tigation activities to verify compliance with regulations, procedures, codes and standards. Involvement of- QA/QC, safety tag use, personnel qualifications, fire protection precautions, retest requirements, and deportability were assesse The inspector observed tests to verify performance in accordance with approved procedures and LCO's, collection of valid test results, removal l and restoration of equipment, and deficiency review and resolutio Radiological controls were observed on a routine basis during the report-iag period. Standard industry radiological work practices, conformance to radiological control procedures and 10 CFR Part 20 requirements were observe Independent surveys of radiological, boundaries and random surveys of nonradiological points throughout the facility were taken by l the inspecto Checks were made to determine whether security conditions met regulatory requirements, the physical security plan, and approved procedures. Those checks included security staffing, protected and vital area barriers, personnel identification, access control, badging, and compensatory measures when require _ _ _ _ _ _ _ _

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) Plant Observations l

FSAR Section 12.2 defines class I:as those structures, equipment,.and i components whose failure or malfunction might cause or increase the j severity of an accident. This category includes equipment required I for safe shutdown and isolation of the reacto Class II is defined l as those structures, equipment and components which are important to j reactor operation. but are not essential for preventing or mitigating P the consequences of accidents. The FSAR also states that Class II designated structures and equipment 'shall not degrade the integrity of any structures and equipment designated Class Designated as-Class I are the high pressure coolant injection system (HPCI), resi-dual heat removal system (RHR), reactor building closed cooling water system (RBCCW) serving Class I equipment, salt service water' system (SSWS) serving Class I equipment and the intake structure housing th salt service water system. Included on the list as Class II struc-i tures are the reactor building auxiliary bay and the intake and dis-charge structures, except areas housing or supporting Class I l equipment.

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The inspectors questioned licensee engineering personnel on the l acceptability of placement of Class I equipment such as HPCI, RHR, SSWS and RBCCW in the Class II reactor building auxiliary bay. The i licensee stated that an analysis and' evaluation of the above ground portion of the auxiliary bay was initiated during 1986 after person-nel in the licensee's electrical engineering group identified several i safety-related conduit routed therei Safety related conduit were also identified in the Class II portions of the intake structure, and  ;

a similar evaluation initiate The licensee expects to complete these evaluations by the end of September, -1987. The inspector also questioned the classification of the balow grade portion of the  ;

auxiliary bay. Licensee engineering personnel committed to research the design basis of the below ground portions of the auxiliary bay and establish its classification. It appears that the housing of this Class I equipment in Class II structures originated during

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initial construction. During field walkdowns however, the inspector noted that a portion of the safety related conduit routed through these areas was installed more recentl The inspector questioned the licensee regarding this recent installation and the adequacy of the design . process which allowed i This issue remains unresolved pending licensee response to this question and completion of the referenced analysis (87-34-01).

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il Plant Maintenance and Outage Activities l Containment Spray Nozzle Discrepancies During implementation of a planned system modification, the licensee discovered discrepancies in the newly. installed primary containment spray nozzles. As part of a modification to optimize the system. flow j rate and spray pattern, the licensee had just replaced the existing nozzles with an improved design which have a single fogjet por I During a post installation system walkdown, the licensee had dis-covered three nozzles with double fogjet port The new nozzles were . initially procured as "non-Q" cnmponents and l then subsequently upgraded to "Q". No initial receipt inspection was ;

conducted on the nozzles as they were procured "non-Q". The inspec- j j

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tor raised the following questions: 1) why were these components procured "non-Q", 2) what process was taken to. Upgrade these compo-nents to "Q" and 3) why were the discrepancies not identified during !

installatio This issue remains unresolved pending pending licensee's response to the inspectors questions (50-293/87-34-02).

c. Radiation Protection

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On August 14, 1987 during preparation for performance of radio-graphy in the B residual heat removal (RHR) pump room, adequate steps to ensure that personnel had been evacuated were not take In preparation for performance of the radiography by a contractor a paperwork review of radiation work permits (RWPs)

outstanding in the areas impacted was conducted. This review failed to identify the presence of two pipefitters in the. torus room adjacent to the B RHR pump room. No tour to visually '

verify that the areas had been cleared was perfor_med . The radiographer was given permission to proceed. Subsequently, but before actual commencement of the radiography, the two pipe fitters were observed exiting the area. The radiographer was told to hold for a short period and then allowed to continu The radiographer was not made aware of the incident by his assistant until after the activity was complete. Similarly the radiation protection (RP) technicians involved did not . inform the on-duty RP supervisor until after completion of the I activit When appraised of tne incident the RP supervisor promptly notified RP managemint and all radiography was sus-pended pending investigatio _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ -

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l The licensee later conducted interviews with all involved per-sonnel and reviewed the applicable. procedures to determine their adequacy. This evaluation and licensee corrective actions' are documented under Radiological Occurrence- Report (ROR) 87-08-14-0939. The immediate actions taken by the licensee appear

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were discussed by the licensee with an NRC: Region I radiation protection specialist inspector, and a copy of the ROR package -

was forwarded to Region I for revie The inspectors had no further question i

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On September 2, 1987 at 10:00 a.m., the licensee's Independent j Radiological Assessor observed that the locked high radiation i door to the radwaste truck lock from the old machine shop was I unlocked, open and apparently unguarded. The door had been propped open to allow power cables to be . routed through the opening. .The key to the area had been signed out by radiation j protection personnel at 0931, and returned at 0935. Control of the door was transferred to operations at that tim No indi- j vidual however, was dedicated to control the doo Instead individuals working in the area assumed this re spon si bil i t At the time of the ' licensee assessor's observation the workers i had exited and proceeded to an adjoining area. They stated that

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visual contact with the door was maintained at all time Licensee surveys indicate that the area was not required to be i locked at the time of the incident because dose rates did not  !

exceed 1 R/hr. The intent of the licensee's procedure for con- )

trolling entrances to high radiation areas requires the door to 1 be locked or guarded. Assignment of individuals' working within the area does not meet this intent. The licensee's procedure for high radiation area key control specifically forbids prop-  !

ping the door open under any circumstance. These procedure {

violations were identified by the licensee during the followup )

investigation for radiological occurrence report 87_-09-02-100 j Problems with the control of high radiation area keys were the subject of violations during inspections 50-293/87-03 and 50-293/87-11. In this instance, a senior staff level individual found and reported the proble The probable cause of this event is lack of lower level staff sensitivity to the issue.

l The inspector stressed the need to resolve these weaknesses at I all levels of the organizatio This was discussed with licen-see management during the inspectors exit interview. Effective- 1 ness of licensee corrective measures to upgrade control of high

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radiation doors will continue to be escalated by NR l i

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.. Surveillance Testing The inspector performed NRC: Region I Temporary Instruction 87-04, Bypass of Non-Essential Diesel Generator Trips. This temporary instruction was initiated due to the discovery that a non-emergency diesel generator protective trip was not bypassed on a loss of = off-site power at another facilit At Pilgrim, emergency start of the diesels is initiated either by a loss of coolant accident signal from core spray or residual heat removal, or by a loss of offsite power signal. Emergency start disables the following trips of the diesel

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Crankcase Vacuum )

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Any of these trips will energize the engine shutdown relay (SDR). ]

The trip bypass function is accomplished by using a contact from the i emergency start relay in series with the coil for the shutdown relay

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which precludes energization of the SDR. This function is tested every six months during performance of procedure 8.M.2-2.10.8.3, Diesel Generator A Initiation by Core Spray Logic, and 8.M.2-2.10, 8.4, Diesel Generator B Initiation by Core Spray Logi Those trips which remain in effect after an emergency start are:

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Overspeed Trip

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Manual Emergency Stop

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Generator Breaker Lockout (initiated by phase overcurrent or j differential current relaying)

The electrical protective relays initiating a generator output breaker lockout are calibrated each refueling outage. The inspector had no further question .0 Review of plant Events l

The inspectors followed up on events occurring during the period to deter-mine if licensee response was thorough and effective. Independent reviews of the events were conducted to verify the accuracy and completeness of licensee informatio ._ __ _ - _ - -

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. Loss cf Security Area Key Control On August 3, 1987, licensee security . supervision learned that a security guard had lost a set of security keys during a routine site tou Security compensatory measures were initiated. The licensee informed the NRC of the lost keys via the Emergency Notification

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System (ENS) at 0018 on August 4. Several hours later, on August 4, 1987, the keys were found and turned over to security supervision by a licensee maintenance employee who stated that he had found the unmarked key ring earlier in the day. The licensee informed the NRC via ENS at 0417 on August 4 that all keys had been' accounted for, and ]

that the previously -instituted compensatory measures were withdraw Preliminary discussions regarding this incident were held with the licensee during an enforcement conference held in Region I on September 9, 198 Residual Heat Removal pipe Corrosion On August 20, 1987, the licensee reported to the NRC that an inser-vice inspection of pipe welds revealed pitting corrosion in the pipe base metal of the A RHR heat exchanger inlet piping. The portion of I the piping was subsequently flapped to allow ultrasonic testing (UT) J thickness measurements. The deepest pits were measured and it was determined that some of the areas on the base metal had a wall thick- 1 ness less than the prescribed minimum. The licensee's initial root

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cause analysis determined that the pitting corrosion was the result '

l of a prior heat exchanger flange leak and the entrapment of water in

) the piping insulatio This item was reviewed by a regional

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specialist inspector as documented in the inspection report (50-293/

I 87-37) and remains unresolved (50-293/87-37-01) pending NRC review of j l the licensee's formal root cause analysis and an engineering evalua- l tion on the extent of the proble Four Individuals Arrested in the Owner Controlled Area L

At approximately 9:30 pm on September 5, 1987, a patrol guard observed a person in the owner controlled area adjacent to the pro-tected area barrier. A security response team was dispatched to investigate and apprehended four males,17-20 years of age, possess-  !

ing a camera and binoculars. They were arrested by a member of the security organization empowered by the Town of Plymouth, Massachusetts,  !

l with arrest authorit The Plymouth Police Department was notified l and took custody of the individuals. They were subsequently charged l

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with trespassin The area in which the four were apprehended was searched for further contraband at approximately 10:00 pm on September 5, and again at 7:30 am on September 6, 1987, with negative results. During a . third search of a wider area, at approximately

, 3:30 pm on September 6,1987, a small bag containing a . towel, a 24

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foot length of knotted rope and some twine was found. The persons arrested for trespassing stated they just wanted to look around and take some pictures. ..There was no indication that the protected area perimeter barrier had been breached by the individuals. NRC: Region I l

notified the FBI and the Commonwealth of Massachusett Suspected Alcohol Use by Contract Employees l

On September 5,1987, three contract health physics technicians were escorted offsite and were relieved of their duties as they were sus-pected of being under the influence of alcoho The three contrac-tors had just returned from their meal break offsite when the licen-see's onshif t health physics supervisor detected a strong odor of alcohol from the individuals. Their employment was subsequently terminated following a licensee investigation. The licensee's review of personel records revealed that there was no indication of previous alcohol related problem .0 Meetings At periodic intervals during the course of the inspection period, meetings were held with senior facility management to discuss the inspection scope and preliminary findings of the resident inspectors. An exit interview was held with the station manager and other senior licensee representa-l tives on September 17, 1987. No written material was given- to the licen-l see that was not previously available to the publi On August 18, 1987 and September 3,1987, several NRC senior managers and the NRR licenseing Project Manager met with the resident staff onsite to discuss inspection resources and scheduling. The licensee made a brief presentation to the group on their proposed restart and power ascension

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progra On September 9, 1987, an enforcement conference was held at the NRC Region I offices in King of Prussia, PA to discuss the violations identified in l' security inspection 50-293/87-3 The details of the meeting will be l documented in the meeting minutes.

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Attachme.t I to Inspection Report 50-293/87-34 Persons Contacted R. Bird, Senior Vice President - Nuclear

• K. Roberts, Station Manager D. Swanson, Nuclear Engineering Department Manager N. Brosee, Outage Manager J. Jens,. Radiological Section Head N. Gannon, Chief Radiological Engineer J. 5 eery, Technical Section Head P. Mastrangelo, Chief Operating Engineer R. Sherry, Chief Maintenance Engineer C. Higgins, Security Group Leader F. Wozniak, Fire Protection Group Leader

• Senior licensee manager present at the exit interview.

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