ML19262A600
| ML19262A600 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/02/1979 |
| From: | Andognini G BOSTON EDISON CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19262A598 | List: |
| References | |
| 79-192, NUDOCS 7912070126 | |
| Download: ML19262A600 (3) | |
Text
'
?
o BOSTON EDISON COMPANY GENERAL DrrtCEs GOD SDYLSTON STREET BonTQN. MaasACNuSETTs 02199 G. CARL ANDOGNINI SUPERINTENCENT NuCLEAN QPERATIONE DEPANTNENT October 2, 1979 BECo. Ltr. #79-192 Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch Office of Inspr.ction and Enforcenent Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pa.
19406 License No. DPR-35 Docket No. 50-293 Response to IE Inspection No. 79-09
Dear Sir:
Inspection No. 79-39, dated September 10, 1979, contained three items of non-compliance.
Boston Edison Company's response to those items is presented as follows:
Item A.
Infraction Technical Specification 6.8.A states in part that:
" Written pro-cedures and Administrative policies shall be established, implemented, and maintained that meet or exceed the requirements and recommendations of... Appendix "A" of USNRC Regulatory Guide 1.33,..."
USNRC Regulatory Guide 1.33, Appendix A, requires procedures to cover the following safety-related activities:
"A.3 Equipment Control (e.g.,
locking and tagging) and D.7 Emergency Core Cooling System."
Contrary to the above, as of June 1,1979 Procedure 2.2.21, High Pressure Coolant Injection System, Revision 5 and Procedure 8.C.13, Iocked Open Locked Closed Valve Line Up Surveillance, Revision 2 did not specify that High Pressure Coolant Injection Valves 2301-74 (Turbine Exhaust to Torus Manual Block) nor the one inch manual block to 2301-VRV-9066 (Turbine Exhaust Line Vacuum Breaker) were required to be locked open as indicated on Piping and Instrumentation Drawing M-243, HPCI System Revision 15.
The two valves were open but not locked when checked on May 31, 1979.
1522 330
'2070 J[
.. B O STO N EDISON COMPANY Mr. Eldon J. Brunner, Chief October 2, 1979 Page 2
Response
Procedure 8.C.13 was updated to.ocit>Je these two valves. Appendix A (valve list) of all 2.2 procedures will be checked against the P&ID's and each will be updated as necessary. At the present time all safety systems have been checked and we are in compliance in this area.
All systems will be checked and we will be in full compliance by 6/1/80.
Item B.
Infraction 10 CFR 50, Appendix B, criterion XIV states in part:
"XIV.
INSPECTION, TEST, AND OPERATING STATUS Measures shall be established to indicate, by the use of markings such as stamps, tags, labels, routing cards, or other suitable means, the status of inspections performed upon indi-vidual items of the nuclear power plant. Measures shall also be established for indicating the operating status of structures, systems, and components of the nuclear power plant or fuel re-processing plant, such as by tagging valves and switches, to prevent inadvertent operations."
Contrary to the above, measures were not ef fective to indicate the operating status of components in that A0-5033A, the Drywell Nitrogen Addition Block Valve was indicated as Red Tagged closed from Feb. 12, 1979 under Maintenance Request 79-262 and Locked Open at the same time on May 15 and March 15, 1979.
Response
The two NP0's involved in these two incidents were admonished to be more careful in the future when filling out surveillances to assure that anything on the surveillance that is not as stated, must be flagged on the surveillance sheet and brought to the attention of the Watch Engineer. We are presently in compliance in this area.
Item C.
Infraction Technical Specification 6.8. A states in part:
" Written procedures shall be established...that meet or exceed the requirements and recom-mendations of Section.. 5.3 of ANSI N18.7-72..."
Section 5.3.4 of ANSI N18.7-72 states in part:
" General plant procedures provide in-structions for the integrated operations of the plant... details concerning specific general plant procedures are emphasized in the following sections..."
Section 5.3.4.1.(1) of ANSI N18.7-1972 states in part:
"...startup procedures shall include confirmation that...
valves are properly aligned..."
General Plant Operating Procedure 2.1.11, Section N.A.,
Revision 0 states:
" Cognizant individuals shall utilize the blank valve lineup forms (Appendix A to System Operating Procedures) for conduct of all valve lineups."
1522 331
b
,BdSTON EDISDN COMPANY Mr. Eldon J. Brunner, Chief October 2, 1979 Page 3 Contrary to the above, Appendix A to the below listed System Operating Procedures (SOP) were not established; in that confinnation that some valves were properly aligned was not incorporated into the appropriate Appendix A:
Appendix A of SCP 2.2.8, Standby AC Power System (Diesel Generators), Revision 4 did not incorporate the manual out-let valves of the A and B Emergency Diesel Generator Fuel Oil Storage Tanks.
Appendix A of SOP 2.2.2.1, High Pressure Coolant Injection Systems, Revision 5 did not incorporate the manual isolation valve asso-ciated with the Turbine Exhaust Line N2 supply or the manual isolation valve associated with VRV 9066, Turbine Exhaust Line Vacuum Breaker.
Response
Appendix A (valve list) of all 2.2 procedures will be checked against the P&ID's and each will be updated as necessary. At the present time all safety systems have been checked and we are in compliance in this area.
All systems will be checked and we will be in full compliance by 6/1/80.
We believe that this letter is responsive to your concerns.
However, should you have any questions or concerns please contact us.
Very truly yours,
~
JG.//dka:a
//
/
1522 332