ML20004G019
| ML20004G019 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/24/1981 |
| From: | Willians M Office of Nuclear Reactor Regulation |
| To: | Ippolito T Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8106260495 | |
| Download: ML20004G019 (5) | |
Text
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June 24,1981 Docket 50-293 MEMORANDUM T0: Thomas A. Ippolito, Chief Operating Reactors Branch #2 Division of Licensing FROM:
Mark H. Williams, Project Manager Operating Reactors Branch #2 Division of Licensing
SUBJECT:
Meeting Summary - June 18, 1981 meeting with the Boston Edison Company On June 18, 1981, a meeting was held with the representatives of the Boston Eu. son Company (BECo.) listed in Encl.1, regarding the past compliance of Pilgrim Nuclear Power Station Unit I with 10 CFR 50.44.
The meeting was requested by BECo.
On May 29, 1981,- BECo. identified an area of potential non-compliance with the regulation at Pilgrim I.
Subsequent findings by BECo. resulted in thejr determination that a meeting was desirable. In the meeting, BECo., stated that PilgrJm I had not been in compliance with 50.44 from the effective date of the rule to June 2,1981. This non-compliance was a result of various inEdequacies in Management Controls.
The original system which was used to meet the regulation from November 1978 to May 1980 relied on operator actions to meet the single failure criterion of GDC 41.
In June 1981, BECo. determined, as a result of an 'NRC requested review, that such operator actions could not be assured due to the postulated radiation doses in the reactor building subsequent to an accident (BEco.81-127 6/15/81). A new system, remotely operated which did meet the single failure criterion, was installed in the May 1950 outage.
Although this system was thought, by BECo., to be in service from May 1980 to June 1981, it was actually disabled during maintenance in July 1980.
The purge lines were cut and capped rather than installing elbows as originally _
specified on a BECo. design change. An investigation is underway at BECo.
to determine the manner in which the change request was altered. In addition, it was later discovered by BECo. that even if the lines had not been cut l
in July 1980, the system was still inoperable since it was valved out of l
service shortly after the May 1980 outage due to undesirable leakage.
Therefore, the unit had not been in compliance with 10 CFR 50.44 at any time in the past. The NRC request which resulted in the BECO. findings was
-a telephone request in early 1981 based on NRC letter dated October 30, 1979 which requested BECo. to provide a basis for their letter of October 19, 1979, in which BECo. claimed compliance with the 10 CFR 50.44 with existing
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b Boston Edison presented their new program to implement effective
-Management Controls for Pilgrim I (Encl. 2). The method employed by BECo. forces all work items, regardless of their initiating-circumstances (eg. NRC req't.BEco. design change, etc.) into a predetermined network. The network integrates all of the requirements of the operational, technical, and administrative disciplines of' the company, which produces the final action. BECo.
demonstrated how this future program would mitigate the possibility of future occurances similar to the 50.44 violation. BECo.~also committed to review their compliance with all post 1972 regulations which did not result in a design change at the plant. The schedule for their review would be submitted to NRC by June 26, 1981.
Subsequent to internal ~NRC discussion, BECo. was informed that the 50.44 violation would be addressed in two parts. The Office of Inspection and Enforcement, Region 1, would address the past non-compliance.
It was agreed that BECo. ap'peared to be in compliance _with the regulation since June 2,1981 by use of the new system (BECo.81-127, June 15,1981).
However, the Office of Nuclear Reactor Regulation would conduct a review of_ a detailed submittal by. BECo. to assure such compliance. That submittal would be formally requested by a NRC letter to be sent during the week of June 22, 1981.
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Mar H. Williams, Project Manager Op ating Reactors Branch #2 i
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- Pilgrim Station Manager Boston Edison. Company; RFD #1, Rocky: Hill. Road
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