ML20135G435

Responds to Violations & Deviations Noted in Insp Rept 50-293/85-17.Corrective Actions:Procedures 8.C.14 & 8.C.16 Revised to Include F-to-C Conversion Chart & Surveillance Procedure Re Stroke Time Corrected

ML20135G435
Person / Time
Site:	Pilgrim
Issue date:	09/04/1985
From:	Harrington W BOSTON EDISON CO.
To:	Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
85-161, NUDOCS 8509190083
Download: ML20135G435 (6)

Text

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BOSTON E01 BON COMPANY B00 BOvteTON STREET B onTON. M ASS ACHUS ETTs 0 219 9 WILLIAM D. HARRINGTON esmoon veas omseseau, a=='=*= September 4, 1985 DECO Ltr. #85- 161 Mr. Edward C. Wenzinger, Chief Projects Branch No. 3 Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I - 631 Park Avenue King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293_

Subject:

Response to Violations and a Deviation as Contained in NRC Inspection Rpt. No. 85-17

Dear Mr. Wenzinger:

This letter is in response to the Violations and Devint. ion identified during an inspection conducted by Mr. J. Johnson and Dr. M. PlcBride of your office on June 13-July 15, 1985 at Pilgrim Nuclear Power Station and communicated to Boston Edison Company in Appendices A and B of the subject letter.

Our response is therefore enclosed as an attachment to this letter.

Should you have any further questions concerning these issues, please do not hesitate to contact me.

Respectfully submitted, 6

• William D. Harrington P Attachment

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PD G

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ATTACHP9ENT VIOLATION "A" Technical Specification 6.8 requires in part that procedures be established, implemented and maintained that meet or exceed the requirements of Section 5.1 of ANSI N18.7-1972. Section 5.1 of ANSI N18.7-1972 requires that procedures be instituted for surveillance testing. In addition, Technical Specification 4.9.A.2 requires that pilot cells in the station batteries be tested for specific gravity, voltage, and temperature at a frequency of once-per-week.

Contrary to the above, on June 2, 1985, procedures were not established and maintained for surveillance testing of the station 250 V battery. As

' a result, pilot cell specific gravity, voltage, and temperature were not tested between May 26, 1985 and June 9, 1985. In addition, portions of surveillance test Procedure No. 8.C.14 for the station batteries were not implemented on the following occasions:

On June 9 and 23, 1985, battery temperatures above procedural acceptance criteria were logged and accepted without recognizing that acceptance criteria were exceeded, therefore, no followup actions were taken.

-- On June 9, 1985, voltage levels for the D17-125V and DIO-250V distribution buses were not logged on the procedural check list as required by the procedure.

On July 9, 1985, the voltage level for the D17-125V distribution bus was incorrectly entered on the procedural check list.

On July 6 and 13, 1985, battery cells in the 125V (B) and 250V station batteries with the lowest specific gravities were not chosen pilot cells for testing as required by the procedure.

RESPONSE

A majority of the above-listed errors were caused by a clerical error in which one of the table values in Procedure 8.C.14 was copied wrong while drafting a new revision to that procedure. Instead of copying the 250V value, 24V was inadvertently entered.

The Operations Group's administrative assistants are responsible for this transcribing and subsequent review for any errors and should have picked up the error. In the vast majority of cases, the quality of their review is thorough and adequately precludes transcribing errors early enough in the procedure change process. The problem was further compounded by the operator '(implementor of the surveillance) correcting the error with a pencil, but not following up with an immediate SRO change.

The problem involving the lowest specific gravity pilot cells not being chosen was also a clerical oversight on the part of the administrative assistants. In Boston Edison's perception, these two instances of clerical error, although significant, were isolated and not reflective of any programmatic weaknesses.

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Therefore, as immediate corrective action to correct the condition, the following steps were taken:

Operations Group personnel involved in the incidents were verbally counselled to (1) follow surveillance requirements more closely, and (2) after manually correcting any errors they may find in a procedure, to consider it their personal responsibility to follow up their actions (within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />), with an SRO change so that the errors found becomo permanently rectified.

The batteries in question were subsequently re-tested and found to be within acceptable limits.

An SRO procedure change was immediately implemented to Procedure 8.C.14 (" Weekly Pilot Coll. . . Check") upon the inspector bringing it to our attention. The procedure has since been permanently revised (on 7/31/85) to require testing of the 250V battery.

-- on 8/21/85, an instructional memorandum was issued to all Operations Group personnel which mentioned the details of the violation and required that any person who discovers an error or omission in surveillances or procedures will take immediate actions to ensure that an SRO procedure change is initiated to permanently correct the problem.

As corrective action to preclude recurrence, Procedure 8.C.14 and Procedure 8.C.16 (" Quarterly Battery cell Surveillance Check Sheet") were revised to include a Fahrenheit-to-Centigrade Conversion Chart. This guidance will satisfactorily preclude recurrence of any temperature conversion-related confusion.

Full compliance was roached on 7/31/85, the date upon which Procedure 8.C.14 was revised to reflect the 250V battery on the surveillance.

VIOLATION "B" Technical Specification 6.8 requires in part that procedures be implemented which meet or exceed the requirements of Appendix "A" of USNRC Regulatory Guide 1.33. Regulatory Guide 1.33 requires that procedures for radiation work permits be instituted. Procedure No. 6.1-022, " Radiation Work Permit", requires in part that both a comprehensive radiation survey frequency and a high radiation area surveillance frequency be specified on work permits. In addition, Technical Specification 6.13 requires that high radiation area surveillance frequencies be entered on radiation work permits, if individuals in high radiation areas are not provided with either a continuously indicating radiation instrument or an integrating, alarming dosimeter.

Contrary to the above, on July 3, 1985, radiation work permits wnich required periodic radiation surveillance for high radiation areas did not specify high radiation area surveillance frequencies.

Pago 2 of 5

RESPONSE

As immediate corrective action, on 7/3/85, Boston Edison revised all open RWP's augmenting periodic surveillance coverage with more specific instructions such as "once-per-shift" frequency. The need to indicate specific surveillance frequencies on RWP's was also reiterated to Health Physics technicians on July 12, 1985.

As corrective action to preclude recurrence, the Health Physics supervisors responsible for approving RWP's were re-instructed of the requirement that it be specifically stated - in the "Romarks" section of the RWP - what the surveillance frequencies are or will be, prior to approving that RWP.

As further corrective action to preclude recurrence, the RWP form will be redesigned, by December 1, 1985, to better address the area of specifying frequencies.

Full compliance was reached on July 3, 1985, the date upon which Health Physics reviewed and revised RWP surveillance coverage requirements, as appropriate.

DEVIATION As a result of the inspection conducted on June 13, 1985 - July 15, 1985, and in accordance with the NRC Enforcement Policy, 10 CFR Part 2, Appendix C, 49 FR 8583 (March 8, 1984), the following deviation was identified:

The Inservice Testing Program (ISI) submitted to the NRC in a letter dated April 13, 1979 required that the setpoint on a vacuum relief valve, VRV-9066, in the high pressure coolant injection (HPCI) system, be tested every five years. The licensee committed to implement this program on August 1, 1979.

The second lO-year IST program submitted to the NRC in a letter dated July 11, 1983, which the licensee committed to implement in the third quarter of 1983, as revised in a letter dated February 14, 1984, required that the following tests be conducted quarterly:

System Valve Test HPCI 2301-0 Stroke time to close position VRV-9066 Stroke test to open position Diesel Oil Transfer 1 in. No. 223 Stroke to close position (2 valves)

Foot-Val A and D Stroke to close position Contrary to the above, on June 24, 1985, the VRV-9066, 2301-0, No. 223, and Foot-Val A and D valves had not been tested in the manner indicated.

RESPONSE

HPCI Valve 2301-8 The surveillance procedure for HPCI Valve 2301-8 stroke time to the closed position has been corrected to require the stroke closure test. This action is complete and procedure was approved by ORC at its Meeting #85-84 on 8/21/05.

The stroke time to close position of the subject valve was successfully performed on 8/28/85.

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HPCI V cuum Reliaf V'Iv3 9066 The two examples of deviations related to testing the one inch HPCI Vacuum Relief Valve, VRV-9066, were identified by the licensee, Boston Edison, in response to the NRC Resident Inspector's inquiry on HPCI Valve 2301-8.

The first deviation involves the failure to test the setpoint of this vacuum relief valvo, whose test is to be performed once every five years and should have been completed prior to August 1, 1984. The second deviation involves the lack of documented stroke test to the open position which is to be conducted quarterly per the IST program.

The circumstances which resulted in the deviation are as follows.

An attempt was made to setpoint test VRV-9066 during the 1984 outage (RFO #6) Field test teams determined that due to the welded-in configuration and vacuum relief function, the valve was not testable by available methods and criteria. A request for Engineering services was made to evaluate modifying the piping configuration, to provide a flanged connection so that VRV-9066 could be bench tested, or, alternatively, to replace VRV-9066 with a new, testable valve. Due to the lead time associated with the modification hardware, it was not practical to implement the modification during RFO #6, and, instead, it was targeted for RFO #7, It should be noted, however, that during RFO #6, VRV-9066 was successfully pressure tested by a Class 2 system hydrostatic test to ensure the pressure retaining function of this relief valvo. This test gave assurance that the relief valve did not compromise the pressure boundary of the HPCI exhaust line.

In parallel with these activities, additional problems, documented in Licensee Reports LER 85-008 and 85-012 (corcerning HPCI exhaust line water hammer events) have caused us to reassess, from a broader perspective, the vacuum relief capability of the HPCI exhaust line. It is our present judgment that this review will likely make the 1-inch vacuum relief valve obsolete, and instead a substantial redesign and upgrading in vacuum relief capacity will be employed. Ultimately, corrective action for testing the vacuum relief function of HPCI should be incorporated into the modification to the exhaust line. Implementation of any such modification will be scheduled per DECO's Long Term Plan; a feasible schedule for implementing such a modification is RFO #7, It is also our engineering judgment that the function and setpoint of the existing 1-inch valve is a relatively minor contributor to the dynamics experienced in the HPCI exhaust line.

With respect to the second deviation concerning quarterly testing, the IST program's testing approach to VRV-9066 for quarterly operability was to determine that the valve relieved vacuum in the exhaust line unless a problem became evident. In other words, if HPCI successfully operated and met its system flow rate and discharge pressure requirement. , the VRV was considered successfully tested. With the problems in the exhaust line that became evident in 1985, this approach can no longer be considered valid.

Therefore, based on our recent experiences, it is now our position that .

stroke testing to the open position for VRV-9066 is not practical. We intend to prepare a relief request to the Inservice Test Program and submit it by September 30, 1985.

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Foot Valves A and B The function of the foot valvo is to prevent draining of the pump suction line to the underground storage tank. This keeps the pump primed. If the foot valve were to fail, the pump would have to evacuate air in the line before delivering fuel oil. Past surveillance test practice has had this feature incorporated into it by observing successful operation of the diesel oil transfer pump. Therefore, it has been determined that this approach can be used to satisfy the IST commitment for both foot valves. Observing operability of the transfer pump also proves operability of the foot valves in question. A procedure revision has been initiated to clarify the operability of the foot valve in both the opening and the closing functions.

Df.esel Oil Transfer Check Valves (1 in No. 223)

The function of the pump discharge check valve (s) (1 in., No. 223) is to prevent back flow through an idle diesel fuel oil transfer pump if the two pumps are cross-connected. There is a provision to allow supply of fuel oil to either day tank A or B or fire pump day tank from either transfer pump (as an operator convenience), via a manual valve which is normally closed (Valve 1-1/2 in., No. 325).

Therefore, it has been determined that the discharge check valves are for operator convenience, and the closure test requirement will be deleted from the test program. Support of this conclusion is that given the scenario that one of the fuel oil transfer pumps was used to fill both day tanks, the foot valve, which is tested for closure function, would ensure delivery of oil to the day tanks. Use of the cross-connect valve is procedurally controlled and valve alignment requires it to be normally closed.

Testing for opening function of the check valve will continue as it has been by verifying that the transfer pump will deliver fuel oil to the day tank.

A relief request to the Inservice Test program will be submitted with our revised submittal presently scheduled for September 30, 1985.

To avoid further deviations in the IST Program, Boston Edison plans to take the following corrective steps:

- Within 120 days of the above-mentioned relief requests, affected in,plementing procedures will have been revised and put in place.

- An audit of these procedures against our program commitments will be conducted by our Quality Assurance Department to ensure compliance.

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