ML20030B942
| ML20030B942 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 07/31/1981 |
| From: | Elsasser T, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20030B939 | List: |
| References | |
| 50-293-81-13, NUDOCS 8108250231 | |
| Download: ML20030B942 (16) | |
See also: IR 05000293/1981013
Text
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DCS 50293-810601
50293-810602
50293-810604
59293-810615
U.S. NUCL EAR REGULATORY COMMISSION
50293-810616
0FFICE OF INSPECTION AND ENFORCEMENT
50293-810617
Region I
50293-010630
Report No. 50-293/81- 13
Docket No. 50-293
License No. DPR-35
Priority
r-
Category
C
Licensee:
Boston Edison Company
800 Boylston Street
Boston, Massachusetts 02199
Facility Name:
Pilgrim Nuclear Power Station
Inspection at:
Plymouth, Massachusetts
Inspection conducted:
June 1-19, 29-30, 1981
Inspectors:
& heath
[___
19 . 19 tl -
d te tigned
hJohnsonh5enior Resident Inspector
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date signed
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date signed
N J/,//8/
Approved by:
. .
(/ dage signed
T. Elsds%r, Chief, Reactor Projects
Section No. IB. Projects Branch No. 1
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Inspection Summary:
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Inspection on June 1 19, 29-30, 1981(Report No. 50-293/81-13)
Routine unannounced safety inspection of plant operations
Areas Inspected:
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including an operational safety verification, followup on previous inspection
findings, followup on events occurring during the inspection, surveillance
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activities, maintenance activities, a review of I.E. Circulars, and a review
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of activities involving the Containment Atmosphere Control System and post LOCA
combustible gas control. The inspection involved 76 hours8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br /> by the resident
inspector.
Results:
Two items of noncompliance were identified in two areas. (Failure to
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have the required equipment operable to continuously monitor and record a radio-
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activt liquid discharge, Paragraph 3.b'(5); and failure to authorize a plant
design change, Paragraph 8.e(2)).
0108250231 810811
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JPDR ADOCK 05000293
O
Region I form 12
(Rev. April 77)
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DETAILS
1.
Persons Contacted
J. Aboltin, Sr. Reactor Engineer
R. Belanger, Q.C. Inspector
W. Deacon, Senf - Electrical Engineer
R. DeLoach, Grc
Leader - Mechanical (NED)
J. Fulton, Senior Licensing Engineer
P. F. Giardiello, Sr. Compliance Engineer
E. Graham, Sr. Plant Engineer
R.Machon,NuclearOperationsManager(PilgrimStatien)
C. Mathis, Deputy Nuclear Operations Manager
T. McLaughlin, Sr. Compliance Engineer
W. Olsen, Senior Nuclear Training Specialist
P. Smith, Chief Technical Engineer
R. Smith, Sr. Chemistry Supervisor
E. Ziemianski, Management Services Group Leader
The inspector also interviewed other members of the health physics,
operations, maintenance, security, and technical staffs.
2.
Followup on Previous Inspection Findings
.
(Closed) Unresolved (293/79-20-01): The inspector has reviewed the tagout
system with respect to effectiveness during periodic tours of the facility.
No recent examples of failure to have a required component tagged have been
identified. However, several examples of tags which were in place and which
were not entered in the Watch Engineer's Tag Log have been identified. This
was considered as an item of noncompliance as described in inspection report
no. 50-293/81-08.
This item is considered closed.
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(Closed) Deficiency (293/79-20-02); The inspector reviewed the licensee's
actions described in a letter to the NRC dated February 6,1980. The
licensee has submitted Licensee Event Reports (LER's) No.'s. 79-46, 79-52,
,
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79-53 and 79-54 for these events. The licensee has also completed a review
of previous events to the beginning of 1979 for similar reportable items.
LER's 80-74 and 80-75 were submitted completing the required actions. The
inspector has noted appropriate awareness of the necessity to report these
kinds of events to the NRC through discussions with the licensee's manage-
ment.
This item-is considered closed.
(Closed) Inspector Follow Item (293/79-20-03); During the inspection con-
ducted in December,1979 (Inspection Report No. 79-20), the Onsite Review
Committee (ORC) meeting minutes back to July, 1979 had not been approved.
The inspector reviewed the approved ORC meeting minutes on file with ORC
Secretary and with the Document Control center on June 17, 198]. The
meeting minutes reviewed included No. 79-20 (meeting date of April 25,1979)
through No. 81-39 (meeting date of May 27,1981). The inspector determined
that ORC meeting minutes were not being prepared and approved in an exr.:ditious
The inspector also noted that the licensee's QA department f.ad
manner.
identified a deficiency in this area and was following the station's progress
in preparing minutes for about 8 meetings in 1979. The inspector reviewed
station memo No. MSG 81-229, from the Management Services Group Leader to the
QA Manager,which stated that corrective actions to prepare and approve
meeting minutes No's. 79-56, and 79-60 through 79-66 had been completed.
The inspector also reviewed these completed meeting minutes and had no further
questions.
-
This item is considered closed.
(Closed) Inspector Follow Item (293/79-20-04); The inspector has reviewed
the Station Operation's Log in the control room on a daily basis.
Improv'e-
ments have been observed in the area of detail however, on several instances
following discussions with the operators on shift additional entries have
been made to the logs.
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This follow item is considered closed for. record purposes, however, reviews
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of the station logs will continue to be perfonned on a routine basis during
future inspections of the facility.
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(0 pen) Unresolved (293/79-06-03); The inspector noted that the licensee's
controlled copy of the Technical Specifications still contained the same
differences in typing as the NRC's copy (pages 206c and 206d).
It is again
noted that there is no technical difference and, although the inconsistencies
are not of themselves of concern, the method of retyping and resetting T.S.
pages (which are provided in the proper fomat for the licensee by NRR) may
cause future changes to result in deletion of requirements.
The inspector contacted the NRR Licensing Project Manager and was provided a
copy of his T.S.
An audit of this copy of the T.S. compared to the licensee's
copy will be perfomed to detemine the magnitude of the inconsistencies.
This item remains open pending completion of the comparison the licensee's
copy of the T.S. with NRR's copy, and discussions between the NRR Project
Manager and the licensee's Licensing Engineer to resolve the discrepancies.
(Closed) Infraction (293/78-16-03); The inspector reviewed the licensee's
supplemental response dated February 28, 1979 which stated that Procedure
No. 1.5.3, Maintenance Requests, would be revised to present additional
work from being done on an existing Maintenance Request without a review
by the QC department. The inspector also reviewed the current procedure
no. 1.5.3, " Maintenance Requests", Revision 13, dated May 9, 1980, which
states in section VI.C that "when it becomes apparent that the scope of
work defined on the MR is not suffkiS t to satisfactorily complete the
assignment, a new MR shall be instituted ,cith the same number and an alpha
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suffix." This requirement to initiate a new MR if the scope of work is
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expanded would ensure that the appropriate Q(. department review is performed.
,
This item is considered closed.
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3.
Operational Safety Verification
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a.
Scope and Acceptance Criteria
The inspector observed control room operations, reviewed selected logs
and records, and conducted discussions with control room operators.
The inspector verified the operability of selected emergency systems and
verified proper return to service of the affected components. Tours
of the reactor building, 4160v switchgear rooms, machine shop, conden-
sate demineralizer valve area, auxilliary bay, turbine building, intake
structure, radwaste corridor, refueling deck, and the control room
(daily)wereconducted. The inspector's observations included a review
of equipment condition (including control room annunciators), potential
fire
hazards, physical security, housekeeping, and the implementation
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of radiological controls and equipment control (tagging).
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The inspector reviewed the documentation associated with the several
liquid radioactive waste discharges, and the logs, records, and control
room instrumentation pertaining to gaseous release rates from the
station.
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These reviews and observations were perfonned in order to verify con-
f
formance with the Code of Federal Regulations, the facility Technical
Specifications, and the licensee's procedures.
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b.
Findings
(1) During a tour of the control room on June 1,1981, the inspector
noted an error in the calculation of the Maximum Fraction of
Critical Power Ratio (MFCPR) performed on the daily surveillance
log sheet (OPER 09). This error was immediately corrected by the
operator on shift. The inspector verified that the corrected yalue
was within T.S. limits and had no further questions.
(2) On June 10, 1981, the inspector provided a list of control room
annunciators which were not included in the licensee's most recent
status list (that were either deactivated or continuously in the
alarm condition) to the Chief Technical Engineer and the Deputy
Nuclear Operations Manager. The inspector will follow the licensee's
progress in correcting these alanns. No items of noncompliance were
identified.
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(3) On June 18, 1981, the inspector reviewed the licensee's daily sur-
'
veillance log sheets for the period May 29, 1981 to June 17, 1981,
to determine whether the torus water level was being maintained
within the Technical Specification (T.S.) limits.
T.S. 3.7.A.1
a and b require that the torus volume be maintained between 84,000
and 94,000 cubic feet.
T.S. 3.7.A.1.m requires that the downcomer
submergence be maintained between 3.75 and 4.00 feet.
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The licensee's daily surveillance log sheet (OPER 09) requires that
the torus level be maintained between -3.5 and -6 inches (indicated).
The inspector reviewed a graph of Torus Volume vs. Indicated
Inches of Water dated March 16, 1976, and detennined that. the
range -3.5 to -6 inches (indicated) corresponded to a volume of
between 86,800 to 84,800 cubic feet. This is within the range
specified by T.S. 3.7.A.I a and b but the. inspect.or questioned the
licensee for verification that the range of -3.5 to -6 inches
was within the limits of T.S. 3.7.A.1.m for downcomer submergence.
On June 19, 1981, the licensee provided the inspector with calcula-
tions previously performed which relate a downcomer submergence
range of 3.75 feet to 4.00 feet to an indicated level range of -3
to -6 inches.
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The inspector determined that the torus level was being maintained
within the T.S. limits and had no further questions at that time.
No items of noncompliance were identified.
($) On June 3,1981, the licensee conducted a drill which exercised
a portion of the Emergency Plan. A radioactive release was simulatad
and the radiological offsite monitoring teams were called in and
sent offsite for sampling. The drill lasted from about 7:40 pm
to 9:10 pm. Several offsite agencies were contacted but the NRC
operations center was not notified. The Nuclear Operations Manager
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did contact the resident inspector at home during the drill who
in turn notified the I&E HQ Duty Officer.
Subsequently, the inspector discussed the subject of notification -
to the NRC of drills in progress with the Nuclear Operations
Manager. The licensee acknowledged the inspector's concerns and
stated that, during future drills, if any offsite involvement was
exercised, the drill scenario would include having the control
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room operator notify the NRC duty officer via the ENS phone.
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The inspector had no further questions.
(5) During a tour of the control room on June 11, 1981, the inspector
noted a log entry in the Station Operations Log that indicated that
i liquid radioactive waste discharge of the Waste Neutralizing Sump
i.ad been completed at 8:25 pm on June 9, 1981.
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The inspector discussed this discharge with the Senior Chemistry
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Supervisor and reviewed the applicable documentation to support the
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required sampling, analysis, and authorization.
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The inspector reviewed the following procedures:
7.9.5, " Waste Neutralizing Sump Discharge Procedure", Rev. 1
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7.9.2, " Liquid Radioactive Waste Discharge", Revision 10
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Procedure 7.9.5,Section V.B. requires that if the analysis of
the batch sample indicates radioactive contamination of the sump,
tnen the batch will have to be handled as a liquid radwaste dis-
charge.
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Section VII of procedure 7.9.5 further states that if the result of
the gross count indicates radioactive contamination of the batch,
the batch is to be treated as a liquid radwaste release and handled
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according to~ procedure 7.9.2.
The inspector noted that procedure 7.9.5 addresses controls to
ensure that requirements pertain;ng to pH and suspended solids
are met prior to release. The neutralizing sump is not designed to
be a radioactive waste tank but is a tank to collect acid and
caustic waste from the Water Treatment System
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The inspector reviewed the Waste Neutralizing Sump Discharge Pemit
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(Fonn CH-IlB) initiated for this discharge which indicated that
the gross count was greater that the (3 sigma) limit for designating
,
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it non-radioactive. The insrector also reviewed the completed
Liquid Radwaste Discharge Permit (Fonn CH-11.A) No. 81-70 which
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is required by Procedure No. 7.9.2.
The inspector noted that the
Discharge Permit (CH-ll.A) was complete with sample result data,
total dilution ratio, maximum discharge fiow rate, specified dis-
charge flowrate, Watch Engineer authorization, start and stop times
and total volume and curies discharged. The sections for process
radiation
monitor (PRM)tripsetpointswasmarkednotapplicable
because the discharge of the neutralizing sump is not tied into the
normal radwaste system, cannot be pumped through the PRM and auto-
matic closing valves, and is discharged through a separate line
directly to the discharge canal.
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The inspector stated that, although the documentation reviewed
indicated that the release was within the limits of T.S. Section
3.8.A.1 (10 CFR 20, Appendix B, for unrestricted areas), the re-
lease did not meet the requirements of T.S. Sections 3.8.A.4.b
through 3.8.A.4.d.
These Sections require that during the release
of radioactive wastes, the following conditions shall be met:
.
the gross 3ctivity monitor and recorder on the radwaste effluent
line shall ne operable; the effluent control monitor shall be set -
to alarm and automatically close the waste discharge valve prior
to exceeding the limits specified in 3.8.A.1 above; and, the
liquid waste activity and flow rate shall be continuously monitoid
and recorded during release.
The licensee acknowledged the inspector's statements and stated
that this area had previously been reviewed at the station and
it was detemined that the intent of the T.S. 3.8.A.4 was met
because the batch discharged was adequately sampled and analyzed,
and that, since there were no other radioactive tanks that input
to the neutralizing sump (other than the source of this discharge -
salt water collected in the RBCCW atxilliary bay sump and pumped
up to the neutralizing sump), there would be no cdditioC radio-
active liquid discharged that had not been properly analyzed and
authorized.
The inspector acknowledged the licensee's' comments and stated that
if the licensee could not adhere to the requirements of the facility
T.S. in this area that proposed T.S. Changes should be properly
prepared, justified, and submitted to the NRC:NRR ior approval.
The radioactive liquid discharge of the waste neutralizing sump
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on June 9,-1981 without the required equipment operable to con-
tinuously monitor and control the release is considered an item '
of noncompliance (50-293/81-13-01).
t.
Followup on Events Occurring During the Inspection
Loss of Shutdown Transfomer on June 4,1981
a.
At 3:12 pm on June 4,1981, the station experienced a loss of power
to the shutdown transfomer from the offsite 23 kv power line. No
plant transient resulted and the power was restored at 3:43 am on
June 6, 1981. The inspector verified that the requirements of T.S.
Section 3.9.B.1 were met (both 345 kv offsite power lines, the main
transfomer, startup transfomer, both EDG's and both Emergency 4160V
No items of non-
busses were operable) and had no further questions.
compliance were identified.
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b.
Control Rod No. 30-51 drifted in on June 16, 1981
On June 16, 1981, control rod no. 30-51 dr ifted in from position 48
to position 00. The cause was determined to be a blown fuse on the
power supply to one of the control rod's two scram pilot solenoid
valves. The inspectcr verified that Procedure No. 2.4.3, " Rod Drift",
Revision 6, was followed and the control rod was withdrawn to the
normal position. At 11:27 June 16, 1981 the faulty fuse was re-
placed and normal operation of the control rod observed. Control rod no.
30-51 is located on the edge of the core and its drifting in while
at power had minimal affect on the power distribution.
No items of noncompliance were identifed.
c.
'B' Channel Rod Block Monitor (RBM) Inoperable
At 3:31 pm on June 16, 1981, the 'B' RBM was declared inoperable.
The inspector verified the operability of the 'A' channel and the com-
pletion of Procedure No. 8.M.2-3.2.1 " Rod Block Monitor Inoperable",
Revision 0, on June 16, 1981 for channel A (T.S. Table 3.2.C allows
operation for 7 days with only one trip system).
Repairs were completed
,
to a faulty flow converter and the 'B' channel was declared operable
following testing at 1:45 am on June 17, 1981.
No items of noncompliance were identified.
d.
Drywell 'Jnidentified Leakage Greater than 5 GPM
At 1:40 pm on June 21, 1981, the licensee observed a drywell floor sump
leakage rate of 6.24 gpm (T.S. limit is 5 gpm). An orderly shutdown
was commenced in accordance with T.S. 3.6.C.3 and the NRC was notified-
via the ENS phone. The licensee adjusted recirculation pump seal flow
and electrically backseated the cleanup system inboard isolation valve
(No.1201-2). At 10:12 pm on June 21, 1981, the drywell unidentified
leakage rate was measured at 4.16 gpm, routine power operations were
resumed r.d the NRC was again notified via the ENS phone.
.
No items of noncompliance were identified.
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S.
Surveillance Activites
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The inspector reviewed the licensee's actions associated with surveillance
testing in order to verify that the testing was performed in accordance
with station procedures and met the Technical Specification limiting con-
ditions for operation.
Portions of the following tests were observed / reviewed:
s
'B' Containment Cooling Loop operability tests (RHR, RBCCW, and Service
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Water Systems) prior to removing thE 'A' RBCCW heat exchanger from
service on June 1,1981.
'A. Loop Service Water Pump operability tests following return to
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service of the 'A' RBCCW heat exchanger at 5:40 am on June 2, 1981.
'D' Salt Service Water Pump inoperable on June 3,1981; Redundant
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cooling loop operability surveillance testing prior to removing from
service for motor bearing replacement and post maintenance testing
prior to declaring operable.
'E' Salt Service Water Pump inoperable on June 9,1981; Redundant cool-
--
ing loop operability surveillance testing prior to removing from service
for discharge check valve repairs and post maintenance testing prior
to declaring operable at 4:00 pm on June 11, 1981.
-- Shutdown Transformer inoperable on June 4,1981; Redundant equipment
testing (both EDG's).
'B' Rod Block Monitor (RBM) Inoperable on June 16, 1981; Redundant
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equipment testing (channel 'A'
RBM).
No items of noncompliance were identified during this review of surveillance
activities.
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6.
Maintenance Activities
The inspector reviewed maintenance items in order to verify that the
activities were conducted in accordance with the licensee's procedures,
the facility Technical Specifications and the Code of Federal Regulations.
The inspector verified for selected items that the activity was properly
authorized, and that appropriate radiological controls, equipment control
tagging, and fire protection were being implemented.
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The items / documents reviewed are listed below:
-- Maintenance Request (MR) No. 81-30-11; inspect and clean 'A'
heat exchanger.
MR No. 81-29-10, 81-29-11 ('D' Service Water Pump (' bearings and dis-
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charge check valve repairs) and MR No. 81-29-12
Pump discharge check valve repair).
The inspector also reviewed the material certifications and associated
receipt inspection reports for these items (Material Receipt Inspection
Report (MRIR) No's.77-036, 80-1074,81-566, 81-130,81-110, and 81-101).
MR No. 81-9-23; Remove four one-inch pipe caps and install piping per
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Field Revision Notice 80-21-22 (Containment Atmosphere Control System -
Nitrogenmakeuplines). The inspector also reviewed the valve lineup
and local leak rate testing of the two one inch manual isolation valves
to the drywell and torus to ensure primary containment integrity during
this modification to the nitrogen supply piping. The completed MR in-
dicated that a QC Inspection Report No. I-81-9-23 had been performed,
post maintenance leak rate testing performed in accordance with pro-
cedure 8.7.1.5, a piping weld air leak test and dye penetrant test com-
pleted at 5 pm on June 2, 1981. The MR was signed off as complete and
returning the nitrogen supply system to service at 8:20 on June 3, 1981.
M.R. No. 81-3-45; Control Rod No. 02-31 drive water filter replacement.
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M.R. No. 81-45-107; 'B' RBM flow converter replacement.
No items of lioncompliance were identified during this review of maintenance
activities.
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7.
I.E. Circular Followup
.
The inspector reviewed the licensee's actions in response to the I.E.
Circulars listed below to determine whether the appropriate concerns were
adequately addres' sed if applicable to the station.
IEC 80-02. Nuclear Power Plant Staff Working Hours; The NRC has clarified
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its position on shift manning and overtime and has included this area
in the T.M.I. Task Action Plan, NUREG 0737, as item I.A.l.3.
The licensee has established an overtime policy for licensed control
room operators in response to this item and the inspector has observed
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implementation of this policy.
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This Circular is considered closed. Further inspection effort concern-
ing staff working hours will be tracked with respect to the T.M.I. Task
Action Plan.
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IEC 80-08, BWR Technical Specification Inconsistency - RPS Response
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Time; The inspector noted that Amendment 42 to the T.S. issued in
May, 1980, corrected the RPS response time to 50 miliseconds. The
inspector also reviewed the licensee's system operating procedure
No. 2.2.79, " Reactor Protection System", and periodic surveillance test
procedures (No's. 8M.3.11.1 through 8.M.3.11.4) and determined that the
correct RPS response time limit of 50 miliseconds was addressed.
This Circular is considered closed.
No items of noncompliance were identified.
8.
Post Accident Combustible Gas Control
Summary of Previous Compliance with 10 CFR 50.44
a.
On June 16,1981,'the licensee issued a prompt report (LER
81-021/0lX-0) which sumarized the conclusions in a letter sent to
NRR dated June 15, 1981. The licensee detemined that the analysis
previously used to demonstrate compliance with 10 CFR 50.44 under-
estimated the upper limit dose rates in the reactor building following
a postulated accident. Compliance with 10 CFR 50, Appendix A, GDC 41,
would not have been assured by relying on operator action as previously
assumed. The licensee also reported that portions of the one inch
redundant nitrogen purge lines installed during the January-May,1980
refueling outage (to alleviate the concerns for operator action) had
been out of service from July,1980 until June 3,1981.
b.
Background (March. 1979 to May, 1981)
.
In a letter dated March 14, 1979, NRR requested that the licensee
submit a schedule for the installation and testing of a Containment
Atmosphere Dilution (CAD) system.
In a letter dated June 6,1973, the
licensee infonned NRR that a CAD system was not planned and that a
hydrogen recombination system was under evaluation. Additionally, in
a letter dated October 19, 1979, the licensee infortned NRR that the
present station design complies with 10 CFR 50.44 with existing equip-
ment.
In a letter dated October 30, 1979, NRR requested additional information
from Boston Edison Co. in order to review the basis for the licensee's
conclusion that existing equipment was satisfactory to demonstrate com-
pliance with 10 CFR 50.44.
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To meet the requirements of 10 CFR 50.44, and the Tfil lessons
Learned Recommendations, the licensee installed redundant nitrogen
purge and vent lines for both the drywell and torus during the
January-May, 1980 refueling outage (Plant Design Change Requests
PDCR 80-03, and 80-21).
In early 1981, telephone conversations occurred between NRR and
Boston Edison management concerning the final resolution of the
containment atmosphere control issue. As a result, the licensee's
corporate engineering department was requested to provide a de-
tailed analysis which would answer the concerns in NRR's letter
of October 30, 1979.
Licensee's Identification of Problem and Imediate Corrective
c.
Actions (May 27, 1981 to June 10, 1981)
In support of the corporate engineering department's analysis, station
personnel performed an inspection of the nitrogen purge system. Un
May 27,1981, it was identified that the two one inch nitrogen purge
supply branch lines were capped rendering the system inoperative.
Preliminary investigation by the licensee revealed the following
sequence of events which led to this unauthorized modification.
,
A design change (Field Revision Notice FRN 81-21-21 dated July 21,
1980) had been issued to the PDCR 80-21 Package which authorized
the removal of a check valve from each of the two nitrogen branch
supply lines and required that the check valves be replaced with
appropriate sections of piping in order to retain system integrity.
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Maintenance Request MR 80-468, dated July 21, 1980 was issued to
implen*nt this modification. However, the section of MR 80-468
which documents the work actually performed indicates that on July
23-24, 1980, the two check valves were removed and the lines capped
as per FRN 80-21-20, Option No.1.
Further investigation revealed that an unrelated authorized version
of FRN 80-21-20 had been previously approved on July 1,1980 and
was issued by Document Control in order to update a Sketch (SK5 Rev.
I
J) to the PDCR 80-21 package. This sketch update was completely
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unrelated to the check valve removal modification.
It was further
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determined that there existed an unauthorized FRN 80-21-20 which had
l
not been issued by Document Control and which was similiar to FRN
l
80-21-21 with two exceptions: first, the FRN number had been
!
changed from 80-21-21 to 80-21-20 and second, the addition of an
option, " Note (l) Field may cut pipe and install SW pipe cap to
sui t. . . " It was the implementation of this option of an unapproved
FRN 80-21-20 which resulted in the disabling of the accident nitrogen
l
purge system.
,
l
l
-
14
The licensee has initiated an investigation to determine the cause
of this unauthorized design change.
On May 28, 1981, the Nuclear Operations Manager informed the inspector
of the licensee's identification of the two capped nitrogen supply
lines.
The licensee stated that actions would be initiated to
imediately return this portion of the nitrogen supply system to
service. On May 29,1981, the inspector discussed the licensee's .
plans with station management personnel and recommended that the
licensee's licensing staff inform the NRR Project Manager concerning
system status.
The inspector questioned the licensee concerning the status of primary
containment integrity in July,1980 (when the two check valves were
cut out cf the newly installed nitrogen supply lines), the current
status cf primary containment integrity, and the capability to return
the recundant lines to service while the plant was operating.
The
inspector determined from a review of records
md system drawings that
primary containment integrity was maintained during the removal of the
check valves on July 23, 1980 (MR 80-468).
The one inch manual root
valves were red tagged closed and had been previously included as
boundary valves during local leak rate testing.
The inspector also
determined that primary containment integrity had been maintained
since July 23, 1980 because the piping had been terminated with a
welded pipe cap connection, and that the system could be returned
to service with the plant operating.
The licensee stated that repairs
were expected to be completed by June 2,1981.
The inspector reviewed Maintenance Request No. 81-9-23 completed at
8:20 am on June 3,1981, which documented the removal of the one inch
pipe caps and reinstallation of piping sections in accordance with
,
l
PDCR FRN 81-21-22.
The inspector also reviewed results of local leak
l
rate testing conducted between June 1-2, 1981, on the two one inch
root valves used as isolations and the four down stream solenoid
I
valves (A0 5087 A&B, and A0 5088 A&B).
!
On June 10, 1981, during a telephone conversation between the
i
licensee's corporate management and NRR management the licensee
stated that the analysis to demonstrate previous compliance with 10 CFR 50.44 was not complete. Additional time was necessary to per-
l
form detailed dose rate calculations in the reactor building.
requested that the licensee's analysis be submitted no later
than June 15, 1981.
Following this discussion, the licensee in-
formed the inspector that corporate management had initiated an in-
dependent investigation to determine the cause of the unauthorized
maintenance that had rendered the system inoperative as of July,
1980.
1
~
_ _ _ _ _ _ _ _
15
d.
Results of Licen.;ee's Analysis / Conclusions / Reports (June 15, 1981
to June 30,1981)
On June 15, 1981, the licensee completed a review of the analysis to
evaluate previous compliance with 10 CFR 50.44, and sent a letter
(BECo letter No.81-127) to NRR sumarizing the basis for the con-
clusions that previous compliance could not be assured.
The licensee
stated that the calculated upper limit dose rates may preclude per-
sonnal access for extended periods of time projected necessary to
perform equipment maintenance and assure that the single failure
criterion is satisfied.
The licensee further stated that "...Conse-
quently, compliance with 10 CFR 50, Appendix A, GDC 41, based on
local operator action cannot be assured...".
On June 16, 1981, following discussions with the inspector, the licensee
submitted a prompt report (LER No. 81-21/0lX-0) to the NRC describing
the results of this recent analysis as detailed in the June 15, 1981
letter to NRR.
On June 18, 1981, a meeting was held at NRC headquaters with Boston
Edison Co., NRR, and IE management personnel to discuss compliance
with 10 CFR 50.44. The licensee stated the station had not been in
compliance with 10 CFR 50.44 from the effective date of the rule
(November,1978) to June 2,1981.
The original system which was con-
sidered to meet the regulation from November,1978 to May,1980, re-
lied on operator actions to meet the single failure criterion of
GDC 41, and such operator actions could not be assured due to postu-
lated post accident dose rates in the reactor building. A new re-
motely operated system with redundant supply and exhaust lines which
would meet the single failure criterion was installed in the May,
1980 outage. Although intended to be inservice from !!ay,1980 to
June,1981, the nitrogen supply section of this new system war
rendered inoperative in July 1980 as a result.of the unauthorized
modifications which has been previously describad in this report.
The licensee has initiated an investigation to detennine the cause
of this unauthorized change. The licensee also stated that even if
the unauthorized modifications.had not occurred, local operator action
in the reactor building would have been required to operate the new
redundant supply lines because the one inch block valves to the
drywell and torus were normally closed. The system operating pro-
cedure No. 2.2.70 has since been revised to require these two
block valves to be normally open.
During the June 18, 1981 meeting, the licensee's management discussed
their proposed program to improve the management control of all work
i tems.
The licensee also comitted to review their compliance with
all post 1972 regulations which did not result in plant design changes.
The results of this review will be submitted to NRR.
. - . -
.e,
16
In a letter from NRR to the licensee dated June 26, 1981, the results
of the June 18, 1981 meeting were summarized and the licensee was
also requested to provide detailed information to enable NRR to evalu-
ate present compliance with 10 CFR 50.44 as it pertains to the
currently installed system.
Licensee Event Report No. 81-023/03L-0 was issued on June 24, 1981
to report operation in an allowable degraded mode with respect to .
TS 3.7.D.2.
The plant was in this degraded mode while returning the
redundant nitrogen supply lines to service on June 1-3, 1981.
e.
Findings
(1)
The findings relating to previous compliance with 10 CFR 50.44
will be discussed in a separate report.
(2)
Unauthorized Modification
The unauthorized modification to the two one inch nitrogen
supply lines on July 23, 1980, performed under Maintenance
Request No.80-468, is considered an item of noncompliance
(50-293/81-13-02).
9.
Unresolved Item
Areas for which more information is required to determine acceptability
are considered unresolved. Unresolved items are discussed in Paragraph
2.
10. Exit Interview
At periodic intervals during the course of the inspection, meetings were
held with senior facility management to discuss the inspection scope and
findings.
_ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ .