ML20011A735

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Responds to NRC Re Violations Noted in IE Insp Rept 50-293/81-16.Corrective Actions:Station Procedure Revised to Specifically Address Drilling of Fire Walls
ML20011A735
Person / Time
Site: Pilgrim
Issue date: 10/05/1981
From: Morisi A
BOSTON EDISON CO.
To: Brunner E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20011A725 List:
References
81-233, NUDOCS 8110290364
Download: ML20011A735 (3)


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'9'g BOSTON EDIBON COMPANY GENERAL. Orrects COO BOvLsTON ETREET 50STON, MASSAcHUBETTs 02199 A. V. M O RIsl MANAGER NUCLEAR OPERATIONS SUPPORT DEPARTMENT 0ctober I5,1981 BECo. Ltr. #81-233 Mr.'Eldon J. Brunner, Chief' Projects Branch #1 Division of Resident and Project Inspection 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 81-16 Reference (a) NRC Letter of August 28, 1981 to Boston Edison (BECo. Ltr. #1.81.248)

Dear Sir:

1 In the referenced letter, two items of non-compliance were identified. - The following contains Boston Edison's responses ~ to those items:

Appendix A, Item A Technical Spe.cification 3.12.F requires that a continuous fire patrol be established on at least one side of the affecter barrier within one hour of a i

j fire barrier penetration seal protecting safety related areas not being functional.

i Contrary to the above, the following are examples of fire barrier penetrations being degraded without the required continuous patrols being performed:

- At 3:00 pm on July 31, 1981, several through-wall holes of one inch and two inch diameters existed in the concrete block walls ' separating the Salt Service Water Pump Rooms.

- At 9:20 am on August 12, 1981, the fire door between the ' A' 4160V Switchgear Room and the ' A' Battery Room was held open with an electrical cord and port-able equipment cart.

Response

The imediate corrective actions taken by PNPS are documented in the inspection report detailing this item.

To preclude recurrence of violations involvirg the drilling of through-wall holes, Station Procedure 3.M.1.18, " Core Drilling", has been revised to specifically address the drilling of fire. walls.

Full compliance was achieved September 24, 1981.

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' BQ ;TQ'N EECON COMPANY Mr.. Eldon.J. Brunner, Chief October 5,1981 Page 2-In the cover letter of Reference (a), it is suggested that the second part of Appendix A, Item A is-a recurrent or uncorrected item of noncompliance.' This is not precisely : correct.

. While both items of noncompliance are similar, -the response to Violation A contained in-our letter of June 29, 1981 concerned a Security Procedure (1.11)-

involving fire doors equippedwith alarms. ~The commitment to make Security Proecedure 1.11 effective by July 30, 1981.was met.

The item of noncompliance ~ described in Reference (a) concerns a fire door that was not equipped with an alarm; hence, the required actions delineated in the Security Procedure were circumvented.

Boston Edison recognizes the importance of maintaining fire protection. For example, all three hour rated fire doors, both nuclear safety and non-nuclear safety, are marked with the appropriate warnings.

We believed that this would be an adequate action to ' obviate the type of violation that occured.

We now realize this is not the case; therefore, to preclude the recurrence of events of this nature, a Procedure is being prepared for fire doors in general. This Procedure shall address the purpose, marking, surveillance, operational requirements, and compensatory measures concerning fire doors.

Full compliance shall be~ achieved by December 1,1981.

Appendix A, Item B Technical Specification 6.4.4 states that "A retraining and replacement training program for the facility staff shall be maintained under the direction of the Nuclear Operations Manager."

The Pilgrim Nuclear Power Station Training Manual, Revision 2, Section 3.1.1; Initial Operations Group Training, requires that personnel 'qualifyiag for operator and watch positions (Nuclear Plant Operator, Nuclear Operating Supervisor, Senior Reactor Operator, Nuclear Watch Engineer...etc.) complete the (appropriate) training certification ' Form (s)'.

Section 3.1.1.4 of the Training Manual further requires that the Nuclear Training Specialist be responsible for maintaining the training record of each individual assigned to the operations group.

Contrary to the above, on July 30, 1981, the licensee was not maintaining

' training records containing all of the documentation required by the Training Manual for station personnel.

Response

The Training Group reviewed the records of all licensed operations-personnel, and all. previous training records are complete at the present time.

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Mr.* Eldon' J. Brunner, Chief.

.0ctober : 5, - 1981-Page 3 In order to prevent a recurrence of this item, a training program was conducte'd for all Training Group personnel. This training program stresses the. import-ance of compliance, record keeping and the use of the Training Manual.. All

. future Training Group personnel shall receive this training, and shall maintain

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records as instructed.

Full complinace was achieved on September 22, 1981.

~ We believe the above responses satisfactorily address the items identified :in -

the inspection.

Should you require further information concerning these responses, please contact us.

Very truly yours, gyz

' Commonwealth of Massachusetts)-

. County of Suffol k '

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Then personally appeared before me John M. Fulton, who, being duly sworn, did state that he is Project Manager - Nuclear Licensing of Boston Edison Company, the applicant herein, and that he is duly authorized to sign for A. Victor Morisi, Manager - Nuclear Operations Support and that he is duly authorized to execute and file the submittal contained herein in the name and on behalf of Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.

My Conmission expires: [p// [, /ffx/

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