ML19262A604
| ML19262A604 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/07/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19262A598 | List: |
| References | |
| 50-293-79-09, 50-293-79-9, NUDOCS 7912070134 | |
| Download: ML19262A604 (2) | |
Text
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APPENDIX A NOTICE OF VIOLATION Boston Edison Company I Docket No. 50-293 Based or, the results of an NRC inspection conducted on May 14 to June 1, 1979, it appears that certain of your activities were not conducted in full compli-ance with the Code of Federal Regulations and yar Facility License DPR-35 as indicated below.
These are infractions.
A.
Technical Specification 6.8. A states in part that:
" Written procedures and administrative policies shall be establisned, implemented, and main-tained 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., lock-ing and tagging) and 0.7 Emergency Core Cooling System."
Contrary to the above, as of June 1, 1979 Procedure 2.2.21, High Pressure Coolant Injection System, Revision 3 and Procedure 8.c.13, Locked 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 PSing and Instrumentation Drawing M-243, HPCI System Revision 15.
The two valves were open but not locked when checked on May 31, 1979.
B.
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 mark-ings such as stamps, tags, labels, routing caras, or other suitable means, the status of inspections performed upon individual items of the nuclear power plant.
Measures shall also be established for indicating the operating status of structures, systems, and compo-nents of the nuclear power plant or fuel reprocessing plant, such as by tagging valves and switches, to prevent inadvertent operations."
Cortrary to the above, measures were not affective to indicate the operat-ing status of components in that A0-5033A, the brywell Nitrogen Addition Block valve was indicated as Red Tagged Closed from February 12, 1979 under Maintenance Request 79-262 and Locked Open at the same time on May 15 and March 15, 1979.
C.
Technical Specification 6.8.A states in part:
" Written procedures shall be established...that meet or exceed the requirements and recommendations 1522
,33-3 nuovo g
2 of Section.. 5.3 of ANSI N18.7-72...."
Section 5.3.4 of ANSI N18.7-72 states in part:
deneral plant procedures provide instructions 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...."
Gene-ral Plant Operating Procedure 2.1.11, Section N. A, Revision 0 states:
" Cognizant individuals shall utilize the blank valve lineup forms (Appen-dix A to System Operating Procedures) for conduct of all valve lineups."
Contrary to the above, Appendix A to the below listed System Operating Procedures (SOP) were not established; in that conf
- nation that some valves were properly aligned was not incorporated into the appropriate Appendix A:
Appendix A of S0P 2.2.8, Standby AC Power System (Diesel Genera-ters), Revision 4 did not incorporate the manual outlet valves of the A and B Emergency Diesel Generator fuel Oil Storage Tanks.
Appendix A of S0P 2.2.2.1, High Pressure Coolant Injection System, Revision 5 did not incorporate the manual isolation valve asso-ciated with the Turbine Exhaust Line N supply or the manual iso-2 lation valve associated with VRV 9066, Turbine Exha,;t Line vacuum breaker.
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