IR 05000293/1993012

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/93-12

ML20057A591
Person / Time
Site:	Pilgrim
Issue date:	08/31/1993
From:	Joyner J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Boulette E BOSTON EDISON CO.
References
NUDOCS 9309150015
Download: ML20057A591 (3)

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l Docket No. 50-293 E. Thomas Boulette, PhD Senior Vice President - Nuclear Boston Edison Company i Pilgrim Nuclear Power Station l Rocky Hill Road j Plymouth, Massachusetts 02360 l

Dear Dr. Boulette:

l Subject: Inspection No. 50-293/93-12 This letter refers to your August 13, 1993 correspondence, in response to our July 15, 1993 letter.

Thank you for informing us of the corrective and preventive actions documented in your let'er.

l These actions will be examined during a fu"x inspection of your licensed program.

Your cooperation with us is appreciated.  ;

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Sincerely, j

Original Signed By:

James H. Joyner James H. Joyner, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards l

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OFFICIAL RECORD COPY G:PILG9312.RL August 30,1993 .g m

9309150015 930831 PDR ADOCK 05000293 /

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Boston Edison Company 2 cc:

E. Kraft, Vice President, Nuclear Operations and Station Director L. Schmeling, Plant Department 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, I2gislative Assistant A. Nogee, MASSPIRG Regional Administrator, FEMA Office of the Commissioner, Massachusetts Depanment 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 Public Document Room (PDR)

local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Massachusetts, SLO Designee OFFICIAL RECORD COPY G:PILG9312.RL August 30,1993

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Boston Edison Company 3 j bec: '

] Region I Docket Room (with concurrences)

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bec (VIA E-MAIL): i 1 W. Butler, NRR R. Eaton, NRR  !

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10 CFR 2.201

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I E. T. Boulette. PhD Senio' vce besioent - Nudeaf

August 13, 1993 BECo Ltr. 93- 101 l U.S. Nuclear Regulatory Commission

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Attn: Document Control Desk Washington, D.C. 20555

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I Docket No. 50-293 License No. DPR-35

l l SUBJECT: REPLY TO NOTICE OF VIOLATION (REFERENCE NRC REGION I INSPECTION REPORT NO. 50-293/93-12)

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

Please do not hesitate to contact me if there are any questions regarding the enclosed reply.

h,YOLdth E.T. Boulette, PhD RLC/bal Enclosure: Reply to Notice of Violation cc: Mr. Thomas T. Martin Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Rd.

King of Prussia, PA 19406 Mr. R. B. Eaton Div. of Reactor Projects I/II Office of NRR - USNRC One White Flint North - Mail Stop 14D1 11555 Rockville Pike Rockville, MD 20852 Sr. NRC Resident Inspector - Pilgrim Station hh$W

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ENCLOSURE

REPLY TO NOTICE OF VIOLATION Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Sir. n License No. DPR-35 As a result of the inspection conducted at Pilgrim Nuclear Power Station from June 14. 1993 through June 18, 1993 and in accordance with the NRC Enforcement Policy (10CFR2, Appendix C), the following Violation was identified:

NOTICE OF VIOLATION The Pilgrim Nuclear Power Station Physical Security Plan, dated December 22, 1992, ISSUE 2, Revision 11, Section 6.1, states, in part, that areas within the Protected

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Area, the Perimeter and Isolation Zones are illuminated to a minimum of 0.2 foot-candles measured at ground level. Additionally, Section 6.1, states, in part, that approved procedures are developed to provide direction for compensatory measures during periods of lighting loss and for obtaining maintenance support to return the lighting system to normal operation.

In addition, Section 6.2, Revision 2, of Station Instruction SI-SC.1215,

" Identification of Protected Area Lighting Loss", states, in part, at least once every seven days, the OIC (Officer-In-Charge) will initiate a lighting survey of Perimeter and Protected Area Lighting. The results will be documented on the Weekly Lighting Survey Map. Section 6.3, of Station Instruction SI-SC.1215, also states, l in part, on a bi-monthly basis, not to exceed 60 days, I&C Technician (s) and the BSSS (BECo Security Shift Supervisor) shall conduct a lighting survey of the Perimeter and Protected Area Lighting. The survey will be performed by use of a '

calibrated light meter and all darkened areas of the Protected Area and Isolation Zone (s) will be selected and tested. ,

Contrary to the above, on June 15, 1993, the inspector determined that, while the l OIC had performed a lighting survey at least once every seven days, it was performed

with a light meter that had never been calibrated since it was purchased by the security department in excess of two years ago. Additionally, one of the I&C department's light meters was sent for calibration in December 1992 and the other,

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on March 31, 1993; neither had been returned by June 15, 1993. Therefore, the required bi-monthly lighting survey could not have been conducted during the period, April 1- June 15, 1993, a period exceeding 60 days.

This is a Severity Level IV Violation (Supplement III).

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REASON FOR VIOLATION

The cause of the violation was improper tracking and performance of the lighting  !

surveys during the cited time period. In addition, a failure to control the time table for calibrating the light meters resulted in both meters being off-site at the same time for calibration.

Also, the Security Shift Supervisor failed to alert the Security Operations Manager of the light meter unavailability and the missed surveillance.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED A lighting survey was accomplished with a calibrated light meter by an Instrumentation and Control (I&C) technician on June 17, 1993. There were no lighting deficiencies noted during the survey.

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ENCLOSURE

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REPLY TO NOTICE OF VIOLATION (CONTINUED)

CORRECTIVE ACTION TAKEN TO PRECLUDE RECURRENCE The lighting survey required by Station Instruction 51-5C.1215 was added to the Master Surveillance Tracking Program (MSTP) on June 16, 1993. The program ensures the appropriate level of management attention is devoted to surveillance activities.

In the event that a surveillance is not performed on the specified Due Date, +#

ALERT NOTICE is issued notifying the responsible owner. A PRIORITY NOTICE is issued to the owner on the day of the Dead Date. If the surveillance is not performed by the Dead Date, a FAILURE NOTICE is issued to the owner. This failure to perform the surveillance would be followed up by the issuance of a Problem Report. Calibration of the light meters are now staggered and tracked to ensure a calibrated, operational light meter is available to support performance of all required lighting surveys.

The Security Section Manager counselled the Boston Edison Shift Supervisor regarding his actions, indicating procedural noncompliance would not be tolerated. He also conducted a meeting with all Boston Edison Shift Super'risors stressing the importance of procedural adherence.

On August 5,1993, a Nuclear Security Section Self Assessment Manual was issued.

This inspection manual provides for individual audits on specific areas (Protected Area Lighting, etc.) within the Security Section. It will provide the Pilgrim Station Security organization with consistent oversight of the Security Force requirements, objectives, and will also identify areas in need of improvement.

In addition, the Security Section Manager will request an independent evaluation of the process from the Boston Edison Quality Assurance Department.

The light meter previously used by Security personnel is being calibrated and, when returned, will provide a third light meter for use if necessary. This instrument will also be added to the Measurement and Test Equipment (M&TE) list.

Other Security Preventive Maintenance and Surveillance Procedures will be reviewed to identify any additional procedures that should be tracked by the MSTP. This review is expected to be complete by October 14, 1993.

DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved on June 17, 1993 when the lighting survey was completed with a calibrated light meter and no degraded areas due to insufficient lighting were found.

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