IR 05000293/1997003

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/97-03

ML20217G921
Person / Time
Site:	Pilgrim
Issue date:	10/08/1997
From:	Conte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Boulette E BOSTON EDISON CO.
References
50-293-97-03, 50-293-97-3, NUDOCS 9710140295
Download: ML20217G921 (2)

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l October 8, 1997 r Thomas Boulette, PhD 6enior Vice President Nuclear

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Boston Edison Company -

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, Massachusetts 02360 5599 SUBJECT: NRC INTEGRATED INSPECTION REPORT 50 293/97 03 AND NOTICE OF VIOLATION Dear Dr. Boulettet i

This letter refers to your August 21,1997 correspondence, in response to our July 22, 1997 letter. Thank you for informing us of the corrective and preventive actions documented in your letter.

We note that the failure to adhere to radiological control procedures resulted in'a failure to maintain a radiological control boundary. The cause, human performance, is being corrected with additional postings and heightened awareness of your staff through site communications and training.

These actions will be examined during a future inspection of your licensed program. Your coope'stion with us is appreciated.

Sincerely, Original Signed By:

Richard J. Conte, Chief Projects Branch 8 Division of Reactor Projects Docket No. 50 293 cc w/o cv of Licensee Resoonse letter:

L. Olivier, Vice President - Nuclear and Station Director C. Goddard, Plant Department Manager N. Desmond, Regulatory Relations D. Tarantino, Nuclear Information Manager H0038 \\

II!EEIIE R Rllll 9710140295 971000 f ,* A FDR O

ADOCK 05000293 PM I'

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Mr. E. Thomas Boulette, PhD 2 cc: w/cv of Licenste Response letter R. Hallisey, Department of Public Health, Commonwealth of Massachusetts j

The Honorable Theresa Murray

The Honorable Joseph Gallitano i B. Abbanat, Department of Public Utilities {

Chairman, Plymouth Board of Selectmen Chairman, Duxbury Board of Selectmen Chairman, Nuclear Matters Committee Plymouth Civil Defense Director P. Gromer, Massachusetts Secretary of Energy Resources J. Miller, Senior lasues Manager J. Fleming A. Nogee, MASSPIRG 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 Commonwealth of Massachusetts, SLO Designee

Distribution w/ermt Region i Docket hb !with concurrences)

PUBLIC

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Nuclear Safety information Center (NSIC)

NRC Resident inspector R. Conte, DRP M. Conner, DRP C. O'Daniell, DRP H. Miller, RA W. Axelson, DRA R. Eaton, NRR A. Wang, NRR K. Kennedy, OEDO R. Correia, NRR F. Talbot, NRR DOCDESK Inspection Program Branch, NRR (IPAS)

' DOCUMENT NAME: g:\ branch 8\rplyltr\pil9703.rpy

. To receive a copy of this document, ind6cate in the bos: 'c' = copy without ettechment/ enclosure 'E" = Copy with attachment / enclosure 'N' = No copy OFFICE Rl/DRP l Rl/DRP J Rl/DRP l

, , , l NAME RLaura f J/J l, EConper g}yf RCont,e ,g A DATE 10/08/97 / / JV 10/]/97' A 10/7/97 10/ /97 10/ /97

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OFFICIAL RECORD COPY

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10CFR 2.201

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Pilgten Nuc6est Power Staton Rocky Hill Road Plymouth. Massachusetts 02300 L J. Olivier y ce Pree6 dent Nucleat Operatens August 21. 1997 l end ststen oirector BECo Ltr. #2.97.085 l U.S. Nuclear Regulatory Commission

! Attention: DocumentControlDesk Washington, DC 20555 Docket No. 50 293 License No. DPR 35 SUBJECT: Rooly to Notice of Violation (Reference NRC Inspection Report 97-03)

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

The following commitments are made in this letter.

o The training program for waste control technicians will be reviewed and upgraded by December 31,1997. Training on the upgraded program will be completed by June 30,1998.

o Provide periodic refresher training to station se4 vices personnel.

o Procedure 1.4.39 will be revised by December 1997 to improve instructions to painters.

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

. v RLC/WGlJRAH/dmcN970302 ErvAosure: Reply to Notice of Violation oc: Mr. Alan B. Wang, Project Manager Project Directorate 13 Omco of Nuclear Reactor Regulation MailStop: OWF1482 U. S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rociwilie, MD 20852 g A ,

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Boston Edison Company U.S. Nuclear Regulatory Commission l

Region l I

475 Allendale Road l

King of Prussia, PA 19406 Senior Resident inspector Pilgrim Nuclear Power Station i

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i Boston Edison Company Docket No. 50 293 Pilgriin Station License No. DPR 35 ENCLOSURE Repiv to Notice of Violation 97-03-02 Violatio_D

"As a result of an inspection conducted April 29 June 24,1997, the following violation of NRC requirements was identified. in accordance with the NRC Enforcement Policy (60 FR 34381; June 30,1995), the violation is described below:

PNPS technical specification 6.11 requires that radiation protection procedures wall be adhered to for all operations involving personnel exposure. PNPS procedure 1.3.114, Conduct of Radiological Operations, Step 5.1.1.6 specifies not to move or remove any radiological postings or boundaries unless directed by radiological protection (RP) personnel to do so.

Contrary to the above, on June 2,1997, a sti.t'on services department worker tied open the

, boilur room door which forms part of the radiological controlled area and this action was not

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directed by RP personnel.

This is a Severity Level IV violation (Supplement IV)."

, REASON FOR THE VIOLATION

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The reason for the violation was determined to be human performance caused by non-com_oliance with procedure 1,3.114. The waste control technician (WCT) who had been working in the boiler room area tied open the door to allow the floor to dry after cleaning without considering radiation protection ramifications. The existing radiologie,al controlled area (RCA) sign remained on the reverse side of the door but could not be read when the door was tied open. The orocedure requised the WCT to inform the radiation protection personnel before keeping the door tied open; however, the WCT was unaware of the requirement to seek permission from the RP personnel and the irnpact of keeping the door npen.

in addition, the NRC identified other events in the inspection report that we reviewed for possible common cause contributors. During RFO#11 (April 1997), a salt service water pump became inoperable when the electrical breaker that powers the pump motor was inadvertently bumped open during a cleaning activity in the auxiliary bay where the breaker is located. On July 19,1995, a plant tmnsient from 100% to 70% (rapid downpower) occurred when the tube oil sightg' ass on the "6" seawate" pump motor became inverted during a cleaning and painting activity. The oil drained from the sightglass and resulted in scoring of the motor bearing. The transient was caused by contract painters. In 1995, action wac taken to require workers, specifically painters, to hold a daily briefing with the Nuclear Watch Engineer to discuss the areas to be worked and the precautions necessary to prevent future damage or impact on plant equipment. Although th action was taken, the requirement was not proceduralized.

Their have been no further known occurrences involving painters.

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Our assessment of the above events indicated a we kness in the waste control technician training program and painting instructions for contractor painte More specifically, the current training activities do not result in a satisfactory awareness ( 4 W mpact that casual errors can have on plant operation during station services activities.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The following corrective steps were taken to resolve the boiler room door event.

. The door was immediately restored to its proper closed configuration, and the event was discussed with the individual involved.

• Areas in the plant having the potential to repeat this type event were evaluated, and a second set of postings (inside the door) were added in the following areas:

- Boiler Room door to outside

- Mahup demineralizer door to outside

- Augmented Off-Gas building door to outside

- Outside Retube building door to outside.

The above postings were completed on June 6,1997.

. Notices about radiological postings and boundaries were displayed on the station video news system (TargetVision) for employee awareness throughout the nuclear organization.

. An employee information notice ("FYl") was published on Ane 13,1997. The focus of this FYi was to remind the employees of the importance of not blocking or moving any postings and barriers located in and around the plant that are placed for radiological, security, and safety requirements.

. A discussion of the event was included in the monthly nuclear organization safety meeting information packages used for the June 18,1997, meeting.

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. The event was discussed with all WCTs. Also, industry and plant events were reviewed with WCT personnel, and their input for improvement was obtained. These actions were completed by June 27,1997.

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QORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The WCT training program is intended to include plant impact training to highlight the various ways that plant equipment could adversely be impacted during station services activities (e.g.,

having the potential for a plant transient). The WCT training program will be improved as follows:

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. The intermediate training objective is to review and upgrade the training program to include l l problem report trends, day-to. day job activities, potential plant impact, and WCT personnel input. The uograde to the training program will be completed by December 31, 1997, Updated training for WCT personnel addressing the potential for adverse plant impact

.during routine and nonroutine station services activities will be conducted by June 30, 1998, e The long term training objective is to incorporate periodic refresher training on an annual basis (or more frequently if indicated by future assessment) to maintain proficiency on procedural requirements and potential plant impact for routine and nonroutine activities that pertain to station services activities. The program is subject to updates on a continuing basis, if warranted, based on worker or management level assessments.

To improve upon the instructions for painters, procedura 1.4.39, " Control of Ps.:nting in the Reactor Bul6deg," will be revised to include indoctrinetion on potential plant impact for routine and nonroutine activities that pertain to station services activities. The revised procedure 1.4.39 will be implemented by December 1997.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on June 2,1997, when the boiler room door was closed to allow proper viewing olthe RCA posting.

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