IR 05000293/1994009
| ML20024J241 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/04/1994 |
| From: | Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Boulette E BOSTON EDISON CO. |
| References | |
| NUDOCS 9410130044 | |
| Download: ML20024J241 (3) | |
Text
?j October 4, 1994 E. Thomas Boulette, PhD Senior Vice President - Nuclear Boston Edison Company Pilgrim Nuclear Power Station
600 Rocky Hill Road i
Plymouth, Massachusetts 02360-5599
Dear Dr. Boulette:
I SUBJECT:
INSPECTION 50-293/94-09 (NOTICE OF VIOLATION)
Thank you for informing us of the corrective and preventive actions documented in your June 30, 1994 correspondence, in response to our June 2,1994 letter.
The subject violation dealt with the improper implementation of procedural controls for fire watches in the facility. We noted that you stated f
contributing causes for the violation were due to human performance (multiple
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cognitive errors during maintenance) and lack of procedural clarity / instruction. Although you do not mention it as a contributing cause
of the violation, our followup inspection will review the impact of the change
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in organizational responsibility from the contractor to the security staff just prior to this violation.
We appreciate your cooperation.
Sincerely, ORIGINAL SIGNED BY:
James C. Linville, Chief Projects Branch No. 3 Division of Reactor Projects Docket No: 50-293 cc:
L. Olivier, Vice President - Nuclear and Station Director T. Sullivan, Plant Department Manager R. Fairbank, Manager, Regulatory Affairs and Emergency Planning Department D. Tarantino, Nuclear Information Manager E. Olson, Compliance Division Manager 9410130044 941004 PDR ADOCK 05000293 l)
O PDR OFFICIAL RECORD COPY
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E. Thomas Boulette, PhD
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cc w/cy of Licensee's Response Letter:
R. Hallisey, Department of Public Health, Commonwealth of Massachusetts l
R. Adams, Department of Labor and Industries, Commonwealth of Massachusetts
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The Honorable Terese Murray The Honorable Peter V. Forman B. Abbanat, Department of Public Utilities
Chairman, Plymouth Board of Selectmen
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Chairman, Duxbury Board of Selectmen Chairman, Nuclear Matters Committee l
Plymouth Civil Defense Director i
Paul W. Gromer, Massachusetts Secretary of Energy Resources i
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Bonnie Cronin, 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
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Chairman, Citizens Urging Responsible Energy
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Public Document Room (PDR)
Local Public Document Room (LPDR)
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Nuclear Safety Information Center (NSIC)
K. Abraham, PA0 (2 copies)
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NRC Resident Inspector
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Commonwealth of Massachusetts, SLO Designee
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E. Thomas Boulette, PhD
bec w/cy of Licensee's Response Letter:
Region I Docket Room (with concurrences)
R. Conte, DRP J. Shediosky, DRP M. Oprendek, DRP W. Dean, OEDO R. Eaton, NRR W. Butler, NRR M. Shannon, ILPB
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RI; RI:D frd a v pl RI:DRP o
Macdonaid/meo Con e 3 Li i1 9/14/94
']),p l'T Lf JC q y 0FFICIAL RECORD COPY A:RP9409.ME0
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BOSTON EDISON Pdgrarn Nuclear Power Station Rocky Hdt Road Plymouth Massachusetts 02360 June 30,1994 E. T. Boulette, PhD Senior vice Presdunt - Nuclea'
BECo Ltr. #94-076 U.S.
Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 License No. DPR-35 Docket No. 50-293 Subject:
RESPONSE TO NOTICE OF VIOLATION Reference:
NRC INSPECTION REPORT NO. 50-293/94-09 Please find enclosed the response to the Notice of Violation contained in the referenced Inspection Report.
Please contact me if there are any questions regarding this response.
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E.T. Boulette, PhD Enclosure PMK/ lam /9471 Then personally appeared before me, E. T.
Boulette, who being duly sworn, did state that he is Senior Vice President - Nuclear of Boston Edison Company and that he is duly authorized to execute and file the submittal contained herein in the name and on behalf of Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.
My commission expires:
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DATE NOTARY PUBLIC' V.
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Ltr. #94-cc:
Mr. Thomas T. Martin Regional Administrator, Region I U.S.
Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr.
R.B.
Eaton Division of Reactor Projects I/II
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Office of NRR - USNRC One White Flint North-Mail Stop 14D1 11555 Rockville Pike Rockville, MD 20852 i
Senior Resident Inspector i
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ENCLOSURE
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RESPONSE TO NOTICE OF VIOLATION BOSTON EDISON COMPANY DOCKET NO. 50-293 PILGRIM NUCLEAR POWER STATION LICENSE NO. DPR-35 Notice of Violation During an NRC inspection conducted April 5, 1994 to May 9, 1994 a violation of NRC requirements was identified and documented in Inspection Report (IR) 50-293/94-09.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10CFR Part 2, Appendix C, the violation is listed below:
Technical Specification 6.8.A requires that written procedures and administrative polices be implemented that meet or exceed the requirements and recommendations of Sections 5.1 and 5.2 of ANSI 18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33.
Specifically, Appendix A.1.1 to USNRC Regulatory Guide 1.33 provides that administrative procedures should be established to implement plant fire protection programs.
Pilgrim Nuclear Power Station Procedure 8.B.14,
" Fire Protection Limiting Conditions for Operation and Compensatory Measure Fire Watch Requirements," Sections 7.1.1 and 7.1.2 direct that when confronted with a fire barrier in a degraded or inoperable condition, review Final Safety Analysis Report (FSAR) Section 10.8, and within one hour establish the appropriate fire watch.
Contrary to the above, on May 5, 1994, the inspector observed two fire doors in the salt service water rooms located within the intake structure that had been blocked in the open position in excess of one hour without proper fire watches being established.
Additionally, subsequent to this occurrence, the licensee identified several other instances in which fire watches were not established as required when fire doors were found or made to be inoperable or when a vehicle was parked in the reactor building trucklock.
This is a Severity Level IV violation (Supplement I).
Reason for the Violation This violation was caused by two factors:
(1) human performance, and (2) lack of procedural clarity / instruction detailing where compensatory measures are required.
In the case of the two fire doors in the salt service water rooms being blocked open, personnel did not identify the requirements concerning compensatory measures to be taken when fire barriers are breached.
This aspect of the violation was due to human j
performance.
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The several instances we identified of cases when fire watches
were not properly established was due to a lack of procedural clarity / instruction.
Specifically, the procedures did not contain a comprehensive definition of what constitutes a blocked i
open door, and did not contain a comprehensive list of fire / smoke
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doors in the plant identifying the necessary compensatory actions (hourly or continuous fire watch) to aid in the identification / assignment of a fire watch.
The failure to post a fire watch while a vehicle was parked in the reactor building trucklock resulted from a lack of clear procedural instruction that (1) the vehicle itself
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(unloaded / empty) is a transient combustible and (2) the reactor building inner trucklock door is not considered a fire barrier.
Corrective Stens Taken and Results Achieved Our immediate corrective action was to close the subject fire doors or post fire watches.
A fire watch was posted for the vehicle parked in the trucklock.
On May 10, 1994 the Maintenance Section discussed the incident to reinforce the importance and nature of fire protection requirements.
Mechanical Maintenance
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Supervisors have been counseled on their responsibility to ensure fire watches are in place whenever a Fire Door is blocced open.
Clarification was made not to assume a security guard in the area
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satisfies the requirement for a fire watch.
Guidance was
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provided to craft personnel and their supervisors on fire door requirements.
Security personnel were briefed on the incident
and reviewed the specific requirements of their responsibility as fire watches.
Other actions taken include: (1) a Nuclear Organization, "For Your Information", newsletter was issued on May 16, 1994 to
reinforce fire door requirements (Pilgrim's General Employee Training (GET) addresses fire doors and contains questions to i
ensure personnel are aware of fire door requirements);
(2) a portion of the May 26, 1994 Monthly Plant Safety meeting discussed the topic of fire doors, and provided better definition on what constitutes blocking open a door.
We have placed warning signs in the reactor and turbine building trucklocks that specifically communicate the need to establish fire protection compensatory measures prior to bringing in I
vehicle (s) and other combustibles.
The'radwaste trucklock is exempted from similar requirements because it has full fire suppression and detection systems.
A Fire Protection representative now attends the daily 0715 production meeting to provide increased fire protection involvement in the day's scheduled activities and to allow the representative to be aware of any activities having the potential for impacting the fire protection program or implementation of program required actions.
No further violations have been identified since these immediate corrective steps have been implemented.
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PROCEDURAL CHANGES MADE TO PRECLUDE FURTHER VIOLATIONS
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Procedure 8.B.14 (Rev. 17), " Fire Protection Limiting Conditions for Operation and Compensatory Measure Fire Watch Requirements",
has been revised to provide:
A comprehensive, stand alone matrix of fire doors / smoke
doors and a related listing of LCO and compensatory measure fire watch requirements should such a door be disabled or blocked open.
A definition of what constitutes a " blocked open" door.
- Specific requirements for fire watches for motor vehicles
entering the Process Buildings and/or trucklocks.
Procedure 1.4.3 (Rev. 19),
" Combustible Controls for PNPS", has been revised to include specific requirements for combustible permits for all motor vehicles entering the Process Buildings.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Our immediate corrective actions have achieved full compliance.
The changes to Procedures 8.B.14 and 1.4.3 were approved June 23, 1994.
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