ML20004B050

Responds to NRC 810326 Ltr Re Violations Noted in IE Insp Rept 50-293/81-02.Corrective Actions:Surveillances Performed & Periodic Testing Requirement Added to Surveillance Program

ML20004B050
Person / Time
Site:	Pilgrim
Issue date:	04/27/1981
From:	Morisi A BOSTON EDISON CO.
To:	Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20004B048	List: ML20004B050
References
81-90, NUDOCS 8105270157
Download: ML20004B050 (5)

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E S S T.N. MAS SA.M u g.TTg Q 21 $ g A. V. M O RISI MANAGER NUCLEAR QPERAT10NS SUPPORT DEPARTMENT April 27,1981 BICo. Ltr. #81-90 Mr. Eldon J. Brunner, Chief Projects Branch #1 Division of Resident and Project Inspection U.S. Nuclear Regulatory Connission 631 Park Avenuo King of Prussia, PA. 19406 License No. DPR-35 Docket No. 50-293 1

Resoonse to IE Insoection #81-02

Dear Sir:

IE Inspection No. 81-02 dated March 26, 1981 contained four items of non-compliance. ,

Boston Edison Company's response to the inspection recort is presented below.

Notice of Violation 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 calibration once per 3 months.

Contrary to the above, on January 7,1981, the facility was operating at full l

power and all of the required instrument checks, functional tests, and trio

! unit calibrations for both the reactor high pressure and reactor low-low water level instrumtnts, which initiate Recirculation Pump Trip and Alternate Rod Insertion, had not been perfonned.

Resoonse l

To resolve this violation the required surveillances were performed and their i periodic testing requirement added to the -tation's surveillance program. A daily instrument check, PNPS pmcedure number 2.1.15, is perfonned by station operating personnel and functional and calibration tests, procedure numbers 8.M.1-29 and 8.M.1-30 were performed and are periodically scheduled for cer-formance by I&C personnel . Full compliance with this item has been achieved.

l f Notice of Violation B Technical Specification 6.8.A regt. ired that " procedures be established, imple-mented, and maintained that meet or exceed the requirements and recommendations of Sections 5.1, 5.3 of ANSI N18.7-72 and A-nendix A of USNRC Ragulatory Guide 1.33 ".. . Section 5.3.9 of ANSI N18.7-1973 requires that procedures be orovided l

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COCTck Eo CON COMPANY

!1r. Eldon J. Brunner, Chief April 27,1981 Page 2 to ensure that material associated with safety related u:ructures or systems are properly stored and controlled. Regulatory Guide 1.33, Aopendix A, Sec-tion 1.h., includes procedures for log entries, record retention, and pro-cedure review; and Section 7.2 includes procedures for discharging liquid radwaste effluents.

B.1 Station procedures 1.4.9, Revision 5, "Sto" age, Handling and Disposal of Sodium Pentaborate,"Section III, states in oart that Borax will be stored in the station warehouse ... containers shall be kept sealed.

Contrary to the above, on Januar/ 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 Liquid Control System.

Resoonse B.1 To prevent improper storage and handling of partially used containers of Borax and boric acid powders, station procedure 1.4.9 has been revised.

j The procedure revision permits the storace of these cartially used containers .

' in the SBLC area with the Senior Chemical Engineer's permission.

This definition of authority and the chemical engineer's review should ensure that adequate safeguards exist to prevent these chemicals from being a hazard.

Full co'mpliance to this item was achieved by the issuance of Revision 6 to

! procedure 1.4.9 on February 4,1981. .

B.2 Station procedure 1.3.7, Revision 17, " Records ,"Section III. A.1.a, requires the off-going Watch Engineer to sumarize the overall opera-tion of the plant during his watch in the Station Operations Loo.

Contrary to the above, on January 13, 1981, a sumary of the overall operation of the olant was not being entered in the Station Goerations Log at the end of each shift.

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Resoonse B.2 The requirement to sumarize the overall ooeration is redundant to the ongoing log kept during the watch and will therefore be deleted from procedure 1.3.7.

Until the procedure can be revised, instructions have been given to the Watch l Engineers to revie.1 the procedure and comply. The procedure will be revised by June 1,1981.

B.3 Station Procedure 7.9.2, Revision 9, " Liquid Radioactive Waste Discharae,"

Section VIII.B, requires the Watch Engineer to personally suoervise the i lineup of valves for the tank to be discharged, check off such verifica-tion on the liquid radwasts discharge permit, and in addition, to sign i

form OPER-28, " Liquid Radwaste Release Valve Lineup Check."

Contrary to the above, the OPER-28 valve lineuo check sheet used for a radioactive liquid discharge of tne 'C' monitor tank on January 20, 1981 was not signed by the Watch Engireer prior to the discharge.

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{QLTON EDCON COMPANY j Mr. Eldon J. Brunner, Chief April 27,1981 Page 3 Response B.3 This violation occurred because OPER-28 is not a cart of procedure 7.9.2 and the procedure which addresses the OPER-28 #".1.17) does not sticulate the same requirements for the Watch Engineer as 7.9.2. Instructions were given to the Watch Engineers to review the re uirements for the OPER 28. This con-

flict in procedures will be revised by June 1,1981.

?btice of Violation C 10 CFR 50, Appendix B, VI, Document Control, states in part that " Measures

shall be established to control the issuance of documents such as ... crocedures

... 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 oersonnel and are distributed to and used at the location where the prescribed activity is performed."

C.1 Boston Edison Company QA Manual, Volume II, Operation of Nuclear Power Plants, Section 5 (revised August 6,1979) requires that station quality assurance program related procedures be submitted to the QA Manager for review and approval, to be subsequently reviewed and aoproved by the Station Manager or his designated alternate.

Station Procedure 1.3.4, Revision 21, " Procedures,"Section III.D., states that each procedure 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 aooroved and distributed for use at the Sta-tion without being approved by the QA Manager.

Resconse C.1 To prevent a recurrence of this event, the particular procedures which require QA department review have been highlighted in the station's procedure status

, log book; in addition, Q.A. identified orocedures, which are crocessed through the word processing system, have been updated to require the Q.A. Manager's -

review. 1 Immediate corrective action was initiated for these procedures by issuing the procedures, replete with the latest revisions to Q.A. for review and acoroval.

Q A. has reviewed these procedures and submitted recommendations for their revision. These recommendations are being reviewed.

Full compliance to this item of non-compliance will be achieved by June 1, 1981 C.2 Station Procedure 1.3.8, Revision 24, " Document Control, "Section III.A. ,

states that controlled copies of selected volumes and individua*. procedures are maintained in accordance with Attachment 1.3.8A-1. Attachment 1.3.8A-1

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icacN E2 CON COMPANY itr. Eldon J. Brunner, Chief April 27,1981 Page 4 refers to Attachment 1.3.8E-1 for a list of additional controlled copies of Volume 2.2 procedures which are to be provided specifically 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 suoerceded by subsequent revisions.

Response C.2 l

i Upon notification from the on-site inspector of this deficiency, the specified procedures were immediately replaced with current revisions.

l Controls have been implemented and personnel assigned to maintain PNPS radwaste procedures. The Records Center has been assigned the rescon-sibility of transmitting the latest revisions to holders of controlled radwaste procedures. A closed loop transmittal system verifies receipt and disposition of these revisions. The control room clerk will update the applicable radwaste procedures, complete the transmittal form, and l return it to the Records Center.

Full compliance with this item of non-compliance has been achieved.

Motice of Violation D Technical Specification S.8. A requires that " procedures be established, l

implemented, and maintained that meet or exceed the reauirements and l

reconinendations of . . . USNRC Regulatory Guide 1.33 ..." Regulatory Guide l 1.33, Appendix A, Section 5, includes procedures for alarm annunciators.

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! Station Procecure 2.3.1, Revision 3, " General Action ( Alarm Procedures)",

Section III, states that a nuisance or malfunctioning alarm may be silenced

! by pulling the alarm card, provided that a yellow tag is placed on the an-nunciator window with the following informi2 tion; date, maintenance request number, and Watch Engineer's name. An entry in the Control Room Log indica-ting this action is also required.Section III further states that an erratic alarm because of operation at the setpoirit does not require a maintenance re-quest number but is required to be replaced when the carameter is no longer on the alarm setpoint. An entry in the Control Room Log Book is required any time these actions take place.

1 Ccntrary 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

! maintanance request number entered on the yellow tag attached to the alarm window.

Response

Efforts have been instituted to correct the pulled annunciator alanns through the i1R and PDCR processes. In addition, station procedure 1.3.18 will be l revised to include listing of annunciators that have been silenced, the reason

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! why they have been silenced, and corrective action taken. This revision will be completed by June 1,1981.

a c::x c'N Eos :ON COMPANY Mr. Eldon J. Brunner, Chief April 27,1981 Page 5 Inspection Response Sununary Boston Edison Company has initiated the following action orograms to preclude reoccurrance of incidents of this nature:

Quality Assurance will implement their formal surveillance inspection function (mini-audits); areas to be inspected at least bi-monthly will include Criteria

II, V, VI, and XI of 10 CFR 50, Appendix B.

To be fully implemented by June 30, 1981.

In addition, comprehensive Quality Assurance audits in these areas will be preformed, on an annual basis, as required by BECo's Quality Assurance Manual.

To be fully implemented by December 31, 1981.

We are confident that the above stated corrective measures and planned actions are responsive to your concerns. Should you require any additional information, please do not hesitate to contact us.

Very truly yours ,

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