IR 05000293/1987004

Ack Receipt of 870409 & 0608 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/87-04. Violation B Withdrawn Based on Results of Further Review,Per Util 870608 Request

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

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NOV 2 01987

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Docket N Boston Edison Company ATTN: Ralph G. Bird ,

Senior Vice President - Nuclear 1 800 Boylston Street Boston, Massachusetts 02199 Gentlemen:

Subject: Inspection No. 50-293/87-04 l This refers to your letters dated April 9 and June, 8,1987, in response to our letter dated March 10, 198 l Thank you for informing us of those preventive and corrective actions taken for violations A, C and D as documented in your letter of April 9, 198 These actions were subsequently reviewed by us during inspections 50-293/87-37 and 50-293/87-41 and found to be sati s f actor In regard to violation B, as requested in your letter of June 8, 1987, we have withdrawn the Notice of Violation (50-293/87-04-04) based upon the results of a further review of this matter which is documented in Inspection Report 50-293/87-4 Your cooperation with us is appreciate

Sincerely, E C EI6 M. c r.t.! r William V. Johnston, Acting Director Division of Reactor Safety I

/p[$f 8712010103 871120 PDR ADOCK 05000293 G PDR

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OFFICIAL RECORD COPY RL PILGRIM 87-04 - 0001. /06/87

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Boston Edison Company 2 d

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l K. P. Roberts, Nuclear Operations Manager l

Paul Levy, Chairman, Department of Public Utilities i Chairr..an, Board of Selectmen Plymouth Civil Defense Director J. D. Keyes, Boston Edison Regulatory Affairs and Programs E. D. Robinson, Nuclear Information Manager R. N. Swanson, Nuclear Engineering Department Manager

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The Honorable E. J. Markey Senator Edward P. Kirby The Honorable Peter V. Forman Sharon Pollard, Secretary of Energy Resources Peter W. Agnes, Assistant Secretary of Public Safety, Commonwealth of Massachusetts Rachel Shimshak, MASSPIRG Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Massachusetts (2)

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Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

Section Chief, DRP R. Wessman, PM, NRR Robert J. Bores, DRSS T.Du(lt?

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h RI:DRP Bissett Blumberg @Gaflo .GnBlough r id///87 1h/ l /87 16/h87 1D/3 /87 16/ /87 0FFICIAL RECORD COPY RL PILGRIM 87-04 - 0002. /28/87

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Executive offices E ^ * :. -

. 800 Boylston Street Boston. Massachusetts 02199 Ralph G. Bird June; 8, 1987 senior vice P esident- Nuclear BECo Ltr. '#87-98 Document Control-Desk U.S. Nuclear Regulatory Commission Washington, D..C. 20555 Docket No. 50-293 License No. DPR-35 Subject: :NRC Inspection Report 50-293/87-04

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' Reference': Boston Edison Company Letter Number 87-56

Dear Sir:

Attached is Boston Edison Company's response to Notice of Violation B'

, contained in the subject inspection repor On May 1, 1987, Boston Edison Company management representatives met with NRC management to obtain clarification of the Notice of Violation. As a result of meeting discussions, our conclusion is that the Notice of Violation was issued-because we did not effectively communicate our programs for test control'tm the inspector. The.need for effectiveness of communication and diligence in resolving inspector concerns in'a timely manner has been re-emphasized to the appropriate members of our staf We continue to believe that our test program elements meet the applicable ANSI-and BEQAM requirements'and based upon the information presented in the attachment to this letter, request that Notice of Violation B-be withdraw Please do not hesitate to contact me directly if you have any question .G EM/la Attachment-cc: Regional Administrator, Region 1 Director, Office of Inspection U.S. Nuclear Regulatory Commission ' and * Enforcement 631 Park Avenue , U.S. Nuclear Regulatory Commission King of Prussia, PA 19406 Washington, DC 20555 Senior Resident Inspector ,

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., ATTACHMENT 1

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Notice of Violation B

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10CFR50, Appendix B, Criterion XI, requires that test programs be' establishe BECo Quality Assurance Manual (QAM), Volume II, Section 2, Quality Assurance Program, states that the QA program conform to ANSI N18.7-1976. ANSI N18.7-1976, paragraph 5.2.19, Test' Control states in part that "A test program shall be established to assure that testing required to' demonstrate that the item will perform satisfactotfly in service is identified and documented, and that testing is q performed in accordance with written test procedures which incorporate or' reference 1 the requirements and acceptance limits...The test program shall cover all required '

tests including.... surveillance tests and tests which-demonstrate satisfactory.

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performance following plant maintenance and modification In addition, the BECo QAM', Section l'1, " Test Control", requires in part, that post work tests and periodic surveillance tests are performed by qualified personnel in accordance with written, approved test procedures, which identify all test prerequisites and environmental conditions which must be satisfied before-performing these tests; that Watch Engineer or his designee,' reviews and approves the' post,-work test data results; and that the N0D' Manager is responsible to assure that surveill,ance tests are performed when required, test results are evaluated, and test requirements are satisfie Contrary to the above, as of January 16, 1987, programs for performance of periodic surveillance tests and tests following performance of plant modifications or-maintenance had not been' adequately established in that there were no station administrative control procedures which addressed the following:

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Overall mechanisms for control of specific test programs such as periodic surveillance tests, post maintenance tests, and post' modification tests.

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Definition of personnel qualified to perform such tests.

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Methods by which prerequisites and environmental conditions are to be

! determined and examples of suc Specification of personnel who are designated to approve and evaluate test results and assure that test requirements are satisfied.

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Definitions of the kinds of instruments to be included in the instrument and control surveillance progra Methods by which acceptance criteria are properly specifie Format for post maintenance and post modification test procedure his is a Severity Level IV Violatio (Supplement 1)

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' Response

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Boston Edison's program for the implementation of the " test program" as

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described in ANSI N18.7-1976/ANS3.2 consists of administrative procedures, implementing procedures, and personnel selection and training processes. The various elements of the ANSI N18.7-1976/ANS3.2 " test program" and the BECo QAM, section 11, " Test Control" have been incorporated in the procedures associated with the work activity rather than a separate test control procedure. For example, post maintenance test specification, performance and approval are contained in Nuclear Operations Department Procedure 1. " Maintenance Requests" while the format and content of procedures is specified in Nuclear Operations Department Procedure 1.3.4 " Procedures".

Boston Edison has reviewed the concerns of the above Notice of Violation and the requirements of AN(I N18.7-1976/ANS3.2 section 5.2.19 " Test Control" and BECo 0AM section ll, "h st Control" as implemented by currently existing procedures and policie Boston Edison believes the test.progcam, as it currently exists, is in compliance with the aforementioned ANSI and BECo QAM requirement A point by point comparison of the specific concerns expressed in the Notice of Violation with the methods currently in use to sa'. fy the concerns is presented be]o ,

-- Overall mechanisms for control of specific test programs.such as periodic surveillance tests, post maintenance tests, and post modification test Nuclear Operations Department Procedure 1.8 " Master Surveillance Tracking Program" controls the performance of periodic surveillance test The associated computer program provides the mechanism for scheduling performance of periodic surveillance test .

Nuclear Operations Department Procedure 1.5.3 " Maintenance Requests" controls the performance of post maintenance testing. Provisions for designation of both maintenance related and Technical Specification operability related tests are contained in this procedur Nuclear Operations Procedure 83E1 " Control of Modifications to Pilgrim Station", Nuclear Operations Procedure 83A6 " Modification Management", and Nuclear Engineering Department Procedure 3.02 " Preparation, Review, Verification, Approval and Revision of Design Documents for Plant Design Changes" control post modification test Definition of personnel qualified to perform the subject test Personnel qualified to perform surveillance and post maintenance tests are determined through the detailed evaluation of previous job experience and specific job training which is performed by the Nuclear Training Departmen This information is posted in the maintenance shop areas for use by the supervisors in charge of the work activity to assist in the assignment of individuals to the particular maintenance tas Technical Specification surveillance and operability testing is also performed by l Nuclear Plant Operators and Reactor Operators who, by virtue of the training associated with their job descri'tten's, p are qualified to perform these tests.- .

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ATTACHMENT 1 (Cont.)-

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. Personnel qualified to perform post modification tests are specifled as

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

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-- Methods by which prerequisites and environmental conditions are to be determine Surveillance and post maintenance test procedures are written per the- ,

I requirements of Nuclear Operations Department Procedure 1. " Procedures". Test procedures contain a section specifying prerequisites !

and environmental conditions, if applicable, which must be satisfied prior-to initiation of the tes Preoperational. test p'rocedures are written per the requirements of the i Modification Management Work Instruction Manual, section 1 " Modifications Management Preoperational Test Procedure Development".

Test procedures contain a section specifying prerequisites and

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environmental conditions, if applicable, which must be satisfied prior to J initiation of the tes {

-- Specification of personnel who are anignated to approve and evaluate test resul,ts a,nd assure .that test requirements are s~atisfie ,

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- The individ'ual surveillance test procedures specify the persons responsible for the evaluation and approval of test results. For example, 1 the Watch Engineer evaluates and approves Technical Specification surveillance test result ]3

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'The designation of personnel who evaluate and approve post maintenance test results.is contain'ed in Nuclear Operations Department Procedure 1. " Maintenance Requests" and in the individual test procedures. For

~ example, the Watch Engineer evaluates and approves Technical Specification operability test result The' designation of personnel who evaluate and approve post modification

. test results is contained in Nuclear Operations Procedure 83A6

" Modification Management" and in the individur.1 preoperational tert procedures wri_tten in accordance with the Modification Management Work Instruction Manual, section 10.0 " Modification Management Preoperational 1'

Test Procedure Development".

-- ' Definitions of the kinds of instruments to be included in the instrument and control surveillance progra .As clarified in our meeting, the inspector's concern was calibration of non-safety related, installed instrumentation, used to measure system parameters during the' performance of system test The calibration of installed plant instrumentation required to support the performance of tests is either performed as a step in the individual test procedure or periodically as controlled by the Master Surveillance Tracking Program.

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-- Methods by which acceptance criteria are properly specifie l

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' ATTACHMENT 1-(Cont.)

b, Surveillance and post maintenance test procedures are written and approved 14: _ per the requirements of Nuclear Operations Department Procedure:1.3.4,

" Procedures". Test procedures contain a section specifying test L acceptance criteri Reference documents used in the generation of the test. procedure (i.e.-Technical Specifications, Final Safety Analysis Report, Vendor. Manuals, design documents, etc.) supply information on specific' acceptance criteri Post modification test procedures are written per the requirements of the Modification. Management Work Instruction Manual, section 1 " Modification Management Preoperational Test Procedure Development". Test procedures.contain a section specifying test acceptance criteria. The l- specific acceptance criteria for inclusion in the test procedure are developed during the portion of the design process controlled by Nuclear Engineering Department Procedure 3.02'" Preparation, Review, Verification, Approval and Revision ~of Design Documents for Plant Design Changes".

-- Format for post maintenance and post modification test procedures.

t Post maintenance test procedures are written per the requirements of . ,

. Nuclear Operations Department Procedure 1.3.4 " Procedures" which. specifies. . '

j test'proced.ure forma '

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l Post modification test procedures are written per the requirements of the'

Modification Management Work Instruction Manual, section 1 " Modifications _ Management Preoperational Test Procedure Development" which specifies test prccedure forma Boston Edison is currently' performing an extensive programmatic upgrade for the control of surveillance testing. This upgrade, scheduled for impicmentation and validation in June, 1987, will greatly ihcrease the l effectiveness of the current surveillance test progra The Master l Surveillance Tracking Program (MSTP) is being refined to; 1) provide a complete' cross reference between surveillance requirement and implementing l- surveillance test procedures, 2) provide for the scheduling of surveillance l tests which correspond to the operating condition of the plant, 3) provide the ability to schedule surveillance tests based upon plant system availability, 4) track the completion of surveillance tests in which portions of the test are completed at different points in time, and 5) provide for the designation of acceptance criteria. Most importantly, experienced technical personnel have been assigned to the administration and maintenance of the MST Thi will ensure the continuance of a high quality surveillance program under the cognizance of a single manager. Boston Edison will examine the elements of the post maintenance test program to determine which areas are in need of improvemen The program for post modification testing, as it currently e d sts, is effective and adequate To ensure that the appropriate management personnel are aware of the implementing procedures for the, various aspects"of the test program, our

"Index of Procedures Per Criteria of ANSI N18.7-1976" is being updated and will be distribute Page 4 of 4

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