ML19352A828
| ML19352A828 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/26/1981 |
| From: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19352A827 | List: |
| References | |
| 50-293-81-02, 50-293-81-2, NUDOCS 8106020189 | |
| Download: ML19352A828 (4) | |
Text
.
/
APPENDIX A NOTICE OF VI0t WON Eoston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 As a result of the inspection conducted on Jtnuary 5-30, 1981, and in accord-ance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified.
A.
Technical Specification 4.2.G states that " surveillance for instrumentation which initiates Recirculation Pump Trip and Alternate Rod Insertion shall be as specified in Table 4.2-G".
Table 4.2-G requires a daily instrument check, a monthly functional test, and a trip unit calibra-tion once per 3 months.
Contrary to the abovs, on January 7, 1981, the facility was operating at full po e-and :.11 of the required instrument checks, functional tests, rad trip unit calibrations for both the reactor high pressure and rea'. tor low-low water level instruments, which initiate Recir,ulation Pump Trip and Alternate Rod Insertion, had not been per'ormed.
This is a Severity Level IV Violation (Supplement I.D.).
B.
Technical Specification 6.8.A required that " procedures be established, implemented, and maintained that meet or exceed the requirements and recommendations of Sections 5.1, 5.3 of ANSI N18.7-72 and Appendix A of USNRC Regulatory Guide 1.33 "... Section 5.3.9 of ANSI N18.7-1972 requires that procedures be provided to ensure that material associated with safety related structures or systems are properly stored and controlled.
Regulatory Guide 1.33, Appendix A, Section 1.h.,
includes procedures for log entries, record retention, and procedure review; and Section 7.2 includes procedures for discharging !iquid rad-waste effluents.
Station proceou a 1.4.9, Revision 5, " Storage, Handling, and Disposal of Sodium centaborate,"Section III, states in part that Borax will be stored in the station warehouse... containers shall be kept sealed.
Contrary to the above, on January 9,1981, a partially used container of Borax was unsealed and stored on the 91 foot elevation of the Reactor Building under a stairway near the Standby
!.iquid Control System.
B108020@O
Appendix A 2
Station procedure 1.3.7, Revision 17, " Records,"Section III.A.1.a.
requires the off going Watch Engineer to summarize the overall operation of the plant during his watch in the Station Operations Log.
Contrary to the above, on January 13, 1981, a summary of the overall operation of the plant was not being entered in the Station Operations Log at the end of each shift.
Station Procedure 7.9.2, Revision 9, " Liquid Radioactive Waste Discharge,"Section VIII.B, requires the Watch Engineer to personally supervise the lineup of valves for the tank to be discharged, check off such verification on the liquid radwaste discharge permit, and in addition, to sign form OPER-28, " Liquid Radwaste Release Valve Lineup Check."
Contrary to the above, the OPER-28 valve lineup check sheet used for a radioactive liquid discharge of the
'C' monitor tank on January 20, 1981 was not signed by the Watch. Engineer prior to the discharge.
These three failures to implement station procedures are a Severity Level.VI Violat, ion (Supplement I.F.).
C.
10 CFR 50, Appendix B, VI, Document Control, states in part that,
" Measures shall be established to ccatrol the issuance of documents s'ch as... procedures... including changes thereto, which prescribe all activities affecting quality.
These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed."
Boston Edison Co. QA Manual, Volume II, Operation of Nuclear Power plants, Section 5 (revised August 6,1979) requires that station quality assurance program related procedures be sub-mitted to the QA Manager for review end approval, to be subsequently.eviewed and approved by the Station Manager or his designated alternate.
Station Procedure 1.3.4, Revision 21, " Procedures,"Section III.D.,
states that each proceuure title page contains a space for the signature of the QA Manager when applicable.
Contrary to the above, on January 23, 1981, seven Station QA Program related procedure revisions had been approved and distributed for use at the Station without being approved by the QA Manager.
I
.-w
.x x
Appendix A -
3 L
Station' Procedure 1.3.8, Revision 24, " Document Control,"
Section III.A., states that controlled copies of selected
~
volumes and individual procedures are maintained in accordance l
with Attachment 1.3.8 A-1..3.8 A-1 refers to-.3.8.E-1 for a list of additional controlled copies of Volume 2.2 procedures which are to be provided spectfically to the Radwaste Control room operator.
Contrary 'to-the above, on January 21, 1981, nine of eleven of the required procedures held.and used by the Radwaste Control Room operator
[
had been superceded by: subsequent revisions.
6 These; failures to properly control the station procedures are a-Severity Level VI Violation-(Supplement I.F.).
I D.
Technical Specification 6.8.A requires that " procedures be established, implemented, and maintained that meet or exceed the requirements and
.i recommendations of... USNRC. Regulatory Guide 1.33..." Regulatory Guide'l.33, Appendix A,-Section 5, includes procedures for alarm annunciators.
[
i Station-procedure 2.3.1, Revision 3, " General Action (Alarm Procedures),"
l Section III, states that a nuisance or malfunctioning alarm may be silenced by pulling the alarm card, provided that a yellow tag
' s placed on the annunciator window with the following information:
}
i date, maintenance request number, and Watch Engineer's name. An entry 4
in the Control Room Log 1ndicating this action is also required.
l Section III further states than an erratic alarm because of operation P
at the setpoint does not require a maintenance request number, but f
is required to be replaced when the parameter is no longer on the alarm i
setpoint.
.An entry in the-Control Room Log Book is required any time these actions take place.
F Contrary to the above, on January 14, 1981, there were twenty-two control room annunciator _ panel alarms silenced with their cards pulled with no evidence.of log' entries being made in the Control Room Log Book.
Sixteen of these had no maintenance request number entered on the yellow tag attached to the alarm window.
This is.a Severity Level VI Violation (Supplement _I.F.).
Pursuant'to the provisions'o' 10 CFR 2.201, Boston Edison Company is hereby 4
required to submit to this office within twenty-f,1ve days of the date 4
i r
I
i-
' Appendix A 4
of this Notice,'a written statemert.:r explanation in reply including the corrective steps which have been takan and results achieved; correc-L tive steps which will tue taken to avoid further violations; and the date when full compliance will be achieved.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
6W Dated
- _- __ q Eld 6n J. Brunner, Chief Projects Branch No. 1, Division of Resident and Project Inspection j