IR 05000293/1992027
| ML20035A053 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/15/1993 |
| From: | Bettenhausen L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Boulette E BOSTON EDISON CO. |
| References | |
| NUDOCS 9303240010 | |
| Download: ML20035A053 (3) | |
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l/AR 151993 Docket No. 50-293 Dr. E. Thomas Boulette Acting Senior Vice President-Nuclear Pilgrim Nuclear Power Station Boston Edison Company RFD #1 Rocky Hill Road Plymouth, Massachusetts 02360 t
Dear Dr. Boulette:
SUBJECT: INSPELTION NO. 50-293/92-27 This letter refers to your February 10,1993, correspondence, in response to our
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December 30,1992, letter.
Thank your for informing us of the corrective and preventive actions documented in your
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letter. These actions will be examined during a future inspection of your licensed program.
i Your cooperation with us is appreciated.
Sincerely, t
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Lee H. Bettenhausen, Chief Operations Branch Division of Reactor Safety
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OFFICIAL RECORD COPY A:RL9227.AEF l
9303240010 930315 PDR ADOCK 05000293 xi l
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Dr. E. Thomas Boulette
IMR 15 T393'
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cc:
E. Kraft, Acting Vice President, Nuclear Operations and Station Director L. Schmeling, Plant Manager V. Oheim, Manager, Regulatory Affairs and Emergency Planning Department D. Tarantino, Nuclear Information Manager N. Desmond, Compliance Division Manager-R. Hallisey, Department of Public Health, Commonwealth of Massachusetts R. Adams, Department of Labor and Industries, Commonwealth of Massachusetts The Honorable Edward M. Kennedy The Honorable John F. Kerry The Honorable Edward J. Markey The Honorable Terese Murray The Honorable Peter V. Forman B. Abbanat, Department of Public Utilities Chairman, Plymouth Board of Selectmen Chairman, Duxbury Board of Selectmen Plymouth Civil Defense Director Paul W. Gromer, Massachusetts Secretary of Energy Resources Sarah Woodhouse, Legislative Assistant A. Nogee, MASSPIRG Regional Administrator, FEMA Office of the Commissioner, Massachusetts Department of Environmental Quality Engineering Office of the Attorney General, Commonwealth of Massachusetts T. Rapone, Massachusetts Executive Office of Public Safety Chairman, Citizens Urging Responsible Energy
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Public Document Room (PDR)
Local Public Document Room (LPDR)
j Nuclear Safety Information Center (NSIC)
K. Abraham, PAO (2) All Inspection Reports (w/ copy of letter dtd February 10,1993)
NRC Resident Inspector Comtoo:r.vealth of Massachusetts, SLO Designee (w/ copy of letter dtd February 10,1993)
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OFFICIAL RECORD COPY A:RL9227.AEF i
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Dr. E. Thomas Boulette
g4g y 3 )gg3 bec:
Region I Docket Room (with concurrences)
DRS/EB SALP Coordinator J. Linville, DRP E. Kelly, DRP J. Macdonald, SRI - Pilgrim (with concurrences)
W. Butler, NRR
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R. Eaton, NRR V. McCree, OEDO DRS File
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L. Bettenhausen, DRS N. Blumberg, DRS
A. Finkel, DRS i
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e /ajk/dmg erg ausen 03/(93 03/ll/93 0318 93 OFFICIAL RECORD COPY A:RL9227.AEF
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i BOSTON EDISON
eag.m Nadem Powm Station 10 CFR 2.201 Rocky Hdt Road l
Phmouth. Massachusetts 02360
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february 10, 1993
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E. T. Boulette, PhD BECo-Ltr.93-013
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Senior Vea Presdent - Nuclear f
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U.S. Nuclear Regulatory Commission j
Attn: Document Control Desk
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-Washington, D.C. 20555 l
Docket No. 50-293 l
License No. DPR-35
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Subject:
REPLY TO NOTICE OF VIOLATION (REFERENCE NRC REGION I INSPECTION
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REPORT NO. 50-293/92-27)
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Dear Sir:
Enclosed is Boston Edison Company's reply to the Notice of Violation contained in
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the subject inspection report.
As indicated in BECo Letter No.93-009, dated
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January 25, 1993, this reply is being submitted within 30 days of receipt of the j
report.
-l Please do not hesitate to contact me if there are any questions regarding the
enclosed reply.
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E. T. Bou t
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Senior Vice President Nuclear
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Enclosure:
Reply to Notice of Violation 50-293/92-27-01
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Mr. Inomas T. Martin-l Regional Administrator, Region I l
U.S. Nuclear Regulatory Commission (
475 Allendale Rd.
King of Prussia, PA 19406 Mr. R. B. Eaton i
Div. of Reactor Projects I/II
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t Office of NRR - USNRC One White Flint North - Mail Stop 14DI 11555 Rockville Pike Rockville, MD 20852
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Sr. NRC Resident. Inspector - Pilgrim Station-l
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ENCLOSURE
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REPLY TO NOTICE OF VIOLATION 50-293/92-27-01 j
Boston Edison Company Docket No. 50-293
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Pilgrim Nuclear Power Station License No. DPR-35
i During an NRC inspection conducted from November 16-20, 1992, violations of NRC l
requirements were identified.
In accordance with the, " General Statement of Policy and
Procedures for NRC Enforcement Actions", 10 CFR Part 2, Appendix C (1990), the violations
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are listed below:
l 10 CFR 50, Appendix B, Criterion XVI, requires that measures shall be established to i
assure that conditions adverse to quality, such as failures, deficiencies, defective
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material and equipment, are promptly identified and corrected.
Boston Edison
Company (BECo) Fire Protection Program, N0P83FP1, requires that the fire protection program be periodically audited. The BECo Quality Assurance Program Sections 2.5.6, 16 and 16.2.4 require that audit deficiencies be reported to responsible management.
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Conditions adverse to quality shall be corrected and such corrective action shall be
timely.
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Contrary to the above, actions were not taken in a timely manner to correct audit
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findings and other conditions adverse to quality as evidenced by the following l
examples:
A lack of required fireproofing material on structural steel in some areas of
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the Reactor Building was identified by Quality Assurance Deficiency 1306,
October 24, 1984.
The same deficiency was also identified in Audits No. 90-l i
30, December 5,1990, and 91-45, January 9,1992. Corrective action was not
taken to repair this deficiency until November 19, 1992, after it was again
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brought to your attention during our inspection.
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In June 1988, an engineering service request (ESR 88-407) was issued i
identifying a broken sight glass on the diesel fire pump fuel oil day tank j
which was also identified in Maintenance Requests 88-33-51 and 88-33-161.
l Audit No. 90-30, December 5, 1990, further identified that the design of the
l day tank sight glass was not in accordance with the design requirements of the
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National Fire Protection Code No. 20. To date, no corrective action has been
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taken to bring the tank volume measurement system into NFPA code design.
This is a Severity Level IV Violation (Supplement 1).
REASON FOR VIOLATION i
Structural steel fire proofing material was removed / damaged in some areas of the Reactor
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Building, Vital MG Set and Switchgear Rooms during the implementation of various plant-modifications in early 1984.
Upon completion of the modifications, the fire proofing a
material was not re-applied to all of the steel beams. The application of the fire coating was a commitment in the 1978 fire protection Safety Evaluation Report (SER).
Quality Assurance Audit No. 84-27 identified this issue as a concern and documented it on j
Deficiency Report (DR) No. 1306 in October of 1984. The DR was subsequently closed during
1985 based upon completion of a portion of the corrective action.
The fire proofing had j
been reapplied to the steel in the Vital MG Set and Switchgear Rooms but not in the
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Reactor Building.
The DR was inappropriately closed; some of the steel in the Reactor l
l Building remained uncoated.
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In 1988, a Management Corrective Action Request (MCAR) was generated to document some of l
the steel in the Reactor Building was still in need of repair.
It was initially believed
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by the Appendix R Project that Engineering could perform an evaluation to demonstrate that
the steel in the uncoated condition was acceptable as is.
The barriers supported by the
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steel in question are not required for Appendix R fire area separation and do not separate
redundant trains of safe shutdown equipment.
During development cf the draft engineering
evaluation, it was recognized that the steel protection was an SER commitment; c'
consequently, the draft evaluation was never issued.
It was subsequently determined the appropriate course of action was to reapply the fire proofing to the steel. This
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conclusion was not effectively communicated to BEco management and, consequently, the repair work was not planned, tunded or implemented in a timely manner.
v Although this issue was discussed in subsequent QA Audit Reports Nos. 90-30 and 91-45, r
additional Deficiency Reports were not issued by the Quality Assurance Department since
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MCAR 88-001 remained open.
The MCAR, however, was also inappropriately closed in 1991 prior to completion of the required work.
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t The concern with the glass tube sight gage on the diesel fire pump fuel oil storage tank was also a case of miscommunication and ineffective corrective action tracking. Although the problem was documented as an observation in various QA Audit Reports, it was not
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effectively communicated to management that the design of the gage was contrary to NFPA
guidelines.
In addition, although the problem was documented on an Engineering Service
Request (ESR), the condition did not receive appropriate attention.
j NFPA Code No. 20 states that means other than sight glass tubes be provided for determining the amount of fuel in a storage tank. Since the initial finding in QA Audit l
Report No. 88-42, the sight glass which is susceptible to damage had been broken several times and, therefore, was unable to provide oil level indication.
ESR No.88-407 was written to Engineering requesting a resolution of the concern. Although the ESR was
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answered indicating an alternative design was being pursued, the issue was not properly j
prioritized and the sight glass was not replaced. Although the existing installation was
l contrary to NFPA Code requirements, the condition posed no safety concern to plant (
operations. The sight glass can be salved out of service to eliminate concerns for l
breakage, leakage or rupture during a fire.
Tank level can. be verified operationally via t
Procedure 8.B.1, " Fire Pump Test", by running the diesel oil transfer pump until the tank
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high level alarm is received in the Control Room. Although this means to verify tank
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level is cumbersome, system operability was never in question. The low safety
significance combined with no operability impact also contributed to the delays in
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i resolving this concern.
In summary, both concerns were the result of ineffective implementation of the corrective l
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action process.
Although the Quality Assurance audit reports initially identified the l
issues, the DR and MCAR processes did not ensure timely corrective action was taken.
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addition, the other plant corrective action process that existed at the time, Failure and
Malfunction Reports (F&MR), was not appropriately used.
Initiation of an F&MR-in
conjunction with the other documents would have helped to ensure a more timely resolution.
The miscommunication of fire protection requirements also contributed to the delays in
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correcting these two issues.
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CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED l
i The fire proofing was reapplied to the structural steel in the Reactor Building during
December of 1992.
The work was done by an approved supplier in accordance with i
Engineering Specification No. M505, " Structural Steel Fire Proofing".
Repair work was i
inspected by the Station Fire Protection and Prevention Officer (FPPO) with satisfactory results. The SER commitment to coat structural steel in the Reactor Building with a fire i
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proof retardant is now satisfied.
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A Plant Design Change (PDC), initiated in August' of 1992, to replace the sight glass on
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the diesel fire pump day tank was issued on December 18, 1992. The new design is a float
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type level indicator that meets the NFPA requirement that sight tubes not be used. The
i PDC is scheduled for implementation when the diesel fire pump is taken out of service for j
maintenance and will be completed by March 31, 1993.
t CORRECTIVE ACTION TAKEN TO PRECLUDE RECURRENCE L
The fire protection group now reports under the Mechanical Systems Engineering Division f
(MSED) that is part of the Plant Department.
Prior to this change, the group was a j
separate division in the Plant Support Department. The reorganization will enable fire
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protection personnel to be trained as systems engineers in addition to maintaining their
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proficiency in fire protection.
This should enhance the overall fire protection program l
at Pilgrim Station as the systems engineering expertise will be more readily available to
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the fire protection personnel.
It is also believed this integration between the fire
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protection and technical divisions will improve the overall communication process with management in ensuring fire protection commitments and code requirements are satisfied.
The reorganization will also help ensure the existing internal corrective action process
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is used more effectively.
This process has undergone significant improvement at Pilgrim
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Station. The improved process called the Problem Report (PR) Program consolidated several existing corrective action tracking systems including Failure and Malfunction Reports, Potential Conditions Adverse to Quality, and Recommendations for Improvement into one
program.
This program is a closed loop tracking system and was implemented in March of l
j 1992.
Some of the highlights of the new PR Program that will help address these fire
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protection issues include the following:
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All Problem Reports undergo a formal structured screening process which
J assigns a graded significance level. A Screening Coordinator makes the j
initial assignment of significance level that is then validated by a Problem j
Assessment Committee (PAC).
PAC currently consists of the day-shift Watch
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Engineer, SR0 licensed as Chairman, and senior representatives from the QA,
j Regulatory Affairs, Radiological and Engineering Departments.
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The new Problem Report process ensures significant problems are brought to the l
attention of the Nuclear Watch Engineer (NWE). The NWE is required to review
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significant problems and formally determine system operability and provide the j
basis for that determination.
Compensatory measures including fire watches i
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Each action item assignment is required to detail the action necessary to i
respond to the assignment and the documentation necessary to support closure.
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All assigned actions are made by the PR Coordinators and validated by the
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Technical Programs Division Manager prior to assignment distribution. Closure documentation is validated by the PR coordinators to ensure adequacy.
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The Problem Report Nuclear Organization Procedure (NDP) places time limit
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requirements on evaluation completion and allows shortening of evaluation time limits to meet regulatory requirements.
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The Problem Report Process provides several checks and balances to ensure
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action completion. The most effective is the " Notice" process. This process,
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similar to the Master Surveillance Tracking Program (MSTP) Notice process, provides automatic notification to Coordinators and action owners when certain i
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milestones are reached. The " ALERT NOTICE" is issued one day after the I
action's due date. The " FAILURE-TO-COMPLY NOTICE" is issued every day after j
an action has passed its dead date.
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All change requests that revise due dates, assigned work scope, or ownership
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rust be approved by the owner's section manager. These section manager
approved change requests are validated via a formal file review for acceptability by the PR Coordinator.
Other checks and balances include issuing a monthly PR status report that p
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includes the number of open and past due items. The report is distributed to
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senior management and is part of an on-going effort to reduce the number of
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open items and to minimize the time taken to implement corrective actions.
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Outstanding fire protection issues were reviewed to ensure they were properly captured on
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the appropriate corrective action document.
Several prs were initiated as a result of
this review. Future fire protection problems including hardware deficiencies, failure to
fulfill regulatory commitments and other system abnormalities will be documented and l
processed using the PR Program. This will better ensure work is properly prioritized,
planned and implemented in a timely manner.
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f The Quality Assurance Department's DR process has also undergone significant revision i
since the subject deficiency was identified.
In early 1992, the DR process was revised to f
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assign deficiency " levels" to help focus appropriate management attention to more significant deficiencies based on safety significance, regulatory compliance, etc.
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Concurrent with this change, documentation requirements were strengthened to require more i
thorough documentation for the basis of DR closure by the QA Engineer. These changes were
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recently reviewed with applicable department personnel.
The MCAR process is also being i
revised to strengthen the closecut requirements and increase the level of management i
attention required for each MCAR. A Problem Report was written (PR 93.0069) to document
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that MCAR 88-001 closecut was inappropriate.
In addition to these programmatic changes, QA audits of the corrective action program have
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included reviews of closed DRs and MCARs to verify that closecut was appropriate.
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review of closed DRs has indicated the inappropriate closecut of the subject DR (1306) was
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an isolated occurrence. This conclusion is further supported by the results of QA l
Surveillances and DR process reviews conducted during the annual Combined Utility l
Assessment Team (LUAT) audits. Also, as a result of deficiencies identified during the
1989 Corrective Action Audit, a review was conducted of all closed MCARs existing at that
time. This review resulted in the reopening of several closed MCARs. MCARs that were l
closed between 1989 and present were also reviewed with no other inappropriate closecuts j
identified. We are confident the ongoing internal reviews in conjunction with the
programmatic changes discussed above will further enhance the effectiveness of the j
existing QA corrective action processes.
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We recognize recent findings may suggest existing corrective action processes are not
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always ensuring timely corrective action. Ongoing enhancements to the Problem Report
Program as well as recent changes to existing QA processes will improve the timeliness of l
corrective action implementation at Pilgrim Station. Although considerable progress has l
been made with the implementation of the new PR Program, additional efforts are still j
warranted. Management has a heightened awareness and increased sensitivity to the
timeliness issue and we are continuing to monitor progress in this area.
i One recent improvement includes establishing goals for the average age of open Problem
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Report evaluations and corrective action items to be more consistent with INP0 Good Practices. These goals are being incorporated into the Goals and Objectives of applicable i
Departments and should help to maintain the proper focus on closing out issues. Also, the l
average age of open issues has been steadily declining over the past six months. Average.
age of open issues is included in the PR status report which is distributed to senior
management on a monthly basis.
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Senior management is also requesting each Department review outstanding issues to ensure J
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they are captured on the appropriate corrective action document. A review of outstanding
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L prs is also planned..This review will focus on open significance level 1 prs and those corrective action documents that were converted into prs when the new Problem Report l
Program was implemented in March of 1992. The review will include the following:
Open significance level 1 prs will be reviewed to ensure action plans are
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commensurate with safety significance.
This review will be completed by M,ay j
31, 1993.
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Corrective action documents converted into prs will be reviewed to ensure
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appropriate assignment of significance level and to ensure action plans are commensurate with safety significance. These documents are being selected for
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review because they may not have been subjected to the same level of screening l
as prs written under the new system.
This review will be_done in two phases l
with those greater than 2 years in age expected to be completed by May 31,
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1993, and remaining prs by August 31, 1993.
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We are also establishing a task force chartered to make additional recommendations to
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senior management to address the timeliness of corrective action issue. The task force l
i will meet periodically with management, and a final report containing recommendations is expected before restarting from refueling outage No. 9, scheduled to begin in April of 1993.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
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The structural steel fire proofing was reapplied on December 31, 1992.
The new diesel
fire pump day tank level indicator will be installed during the diesel fire pump system j
l outage and will be completed by March 31, 1993.
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