IR 05000293/1987019

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/87-19

ML20236H871
Person / Time
Site:	Pilgrim
Issue date:	07/27/1987
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Bird R BOSTON EDISON CO.
References
NUDOCS 8708050373
Download: ML20236H871 (2)

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.o n;L. i * 1997 i

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i Docket No. 50-293 Boston Edison Company M/C Nuclear l

ATTN: Ralph G. Bird-Senior Vice President - Nuclear l 800 Boylston Street '

Boston, Massachusetts 02199

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Gentlemen:

Subject: Inspection No. 50-293-87-19  ;

This refers to your letter dated June 17, 1987, in response to our letter dated May 21, 1987.

Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of j your licensed program. i Your cgperation with us is appreciated. l T

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Sincerely,

0"icid21 Signe d By *

p(})d [', OM '

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Thomas T. Martin, Director f

, Division of Radiation Safety l

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and Safeguards cc:

l -K. P. Roberts, Station Manager l - Paul Levy, Chairman, Department of Public Utilities

- Chairman, Board of Selectmen-Plymouth Civil Defense Director

- J . D. Keye s-The Honorable E. J. Markey-Senator Edward P. Kirby-The Honorable Peter V. Forman-Sharon Pollard, Secretary of Energy Resources-Rachel Shimshak, MASSPIRG Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

-NRC Resident Inspector Commonwealth of Massachusetts (2)

0FFICIAL RECORD COPY RL PILGRIM 87-19 - 0001.0.0 07/14/87  %%

0708050373 870727 ADOCK 05000293 PDR

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JUL 2 7 1987 bec:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

Section Chief, DRP W. Raymond, SRI, Vermont Yankee T. Shedlosky, SRI, Millstone 1&2 H. Eichenholz, SRI, Yankee R. Wessman, PM, NRR PA0 (2) SALP Reports Only Robert J. Bores, DRSS I

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RI:DRSS RI:DRS N RI RI S RI.D SS LeQuia/mlb Loesch Shanbaky Bellamy Mar n 7/15'/87 7/I5/87 7/20/87 7/Lo/87 7/ /87 0FFICIAL RECORD COPY RL PILGRIM 87-19 - 0002.0.0 07/14/87

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BOSTON EDISON

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Executive Of fices 800 Boylston Street Bcston. Massachusetts 02199 Ralph G. Bird Senior Vice President - Nuc! ear June 17,1987 BECo Ltr. #87-104 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Subject: NRC Inspection Report 50-293/87-19

Dear Sir:

Attached is Boston Edison Company's response to the Notice of Violation contained in the subject inspection report.

Please do not hesitate to contact me directly if you have any questions.

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R.G. Bird BPL/la i

Attachment l cc: Regional Administrator, Region I 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, D.C. 20555 Senior Resident Inspector  !

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ATTACHMENT 1

. Boston Edison Company Docket No.'50-293 Pilgrim Nuclear Power Station License No. DPR-35 Notice of Violation Technical Specification 6.8 requires, in part, that the procedures recommended in Appendix A of Regulatory Guide 1.33 be established and implemented.

Procedure 1.3.10, Revision 16, " Key Control," requires, in part, in Section Ill.A.7, that one high-high radiation key will be kept in the Control Room in the Special Key Cabinet. Additionally, the key will be accounted' for at the beginning of each shift and an entry made in either the NOS log or Radwaste

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Log.

l Contrary to the above, on April 28, 1987, a high-high radiation key was

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located in the Watch Engineers desk rather than in the Special Key Cabinet and .)

on several occasions including April 6, April 7, and April 25, 1987, the high-high radiation key was not accounted for at the beginning of each shift.

Response .

1. Background The Notice of Violation and associated inspection report identifies a lack of procedural compliance regarding the control of radiation area keys.

Previous NRC inspections this year (87-03 and 87-11) also identified violations associated with key control. Our responses to these previous violations strengthened our procedural controls by centralizing the administrative control and responsibility for high and high-high radiation l

access control within the Radiological Section. The Nuclear Watch Engineer (NWE) retained control of two (2) high (>1 Rem /hr) radiation area 3

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access keys and one (1) high-high (>10 Rem /hr) radiation access key to be used in the case of an emergency. This procedural change became effective '

on April 20, 1987. Additional corrective actions involved communicating the need for attention to detail in procedural compliance.

l Follow-up investigation by personnel assigned to the Compliance Management Group had identified the failure to document the control room shiftly key audit on April 6, and April 7,1987 as described in this violation. These instances were described in our fesponse to Violation 87-03 as two isolated instances of non-compliance by one individual.

Although the instances of procedural non-compliance described in this violation are viewed as significant due to repetitive problems of this nature, it should be noted that a review of records from April 20 to April 29, 1987 revealed no evidence that these keys were used in an unauthorized manner.

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2. Corrective Steps Taken and Results Achieved

. Failure to document the shif tly key audit in the Nuclear Operations '

Supervisor's (NOS) log on April 6, April 7, and April 25, 1987 was a result of inattention to detail by one individual. The high-high l radiation access key found on the NWE's key ring in the hKE's desk on ]

April 28, 1987 resulted from an error by an Administrative Assistant while relabelling the keys. Relabelling of the radiation access control keys J i

was required to implement Procedure No.1.3.10, Rev.16. " Key Control". l These performance problems have been discussed with the individuals involved and the importance of attention to detail in the conduct of their responsibilities has been reemphasized. The high-high key was placed in ]

the locked key cabinet upon recognition of the problem on April 28, 1987.

Investigations have shown that the high-high rad key was located in the NWE's desk for approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Although revision No.16 to the ,

key control procedure was ef fective on April 20, 1987, the change was not '

l addressed in the Night Orders until April 29, 1987 due to an administrative error. Therefore, Operations personnel were not fully cognizant of the procedural requirements resulting in the misplaced key not being identified in the shiftly key audit. .

I Independent key control audits conducted on April 29, April 30, and I l May 22, 1987 by the Operations Section Manager and on June 8,1987 by l Compliance Management Group personnel found no procedural discrepancies.

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Continued compliance of high rad key control has also been verified by weekly inventories of the control rooms high radiation access control keys by the Radiological Section as well as the shiftly inventories of keys located in the control and health physics office by their respective ,

organizations. l I

3. Corrective Steps Taken to Prevent Future Violations The Operations Section Manager has personally discussed the requirements i

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of the key control procedure with the NWE's and NOS's to ensure their understanding. To ensure Operations personnel are aware of changing requirements the required reading system is being revised. Prior to l assuming their watch responsibilities Operations personnel will be required to acknowledge their understanding of any required reading added in their absence. Procedural changes become effective when they are received by the control room and those changes affecting operations can be entered into the required reading book at that time. Implementation of the improved required reading process is expected by June 30, 1987.

4. Date When Full Compliance Was Achieved The action required to achieve f ull compliance with Procedure No.1.3.10, Rev. 16, " Key Control", was achieved on April 29, 1987 when the new procedural requirements were addressed in the Night Orders.

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