ML20041D362

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Notice of Violation from Insp on 811130-1204
ML20041D362
Person / Time
Site: Pilgrim
Issue date: 02/16/1982
From: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20041D355 List:
References
50-293-81-36, NUDOCS 8203050263
Download: ML20041D362 (3)


Text

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Appendix A Notice of Violation Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 Plymouth, Massachusetts As a result of an inspection conducted at Pilgrim Nuclear Power Station on November 30 - December 4, 1981, and in accordance with Interim Enforcement j

Policy, 45 FR 66754 (October /, 1980), the following violations were identified:

A.

Technical Specification 6.8.A states that policies shall be established that meet or exceed the requirements of Section 5.1 of ANSI N18.7-4 1972.

ANSI N18.7-1972, Paragraph 5.1.7, states in part "... Provisions shall be made for performing scheduled surveillance testing.

Such provisions shall include the establishment of a master surveillance schedule reflecting the status of all planned in plant surveillance testing...".

Contrary to the above, as of December 4, 1981, a master surveillance scheduled for planned in plant surveillance testing had not been established.

This is a Severity Level VI violation - Supplement I.

B.

Technical Specification 6.8.A states that written procedures and administrative policies shall be established and implemented.

Station Procedure 1.3.6, " Adherence To Tec;..ical Specifications",

paragraph II, states in part, "... Amendments to (the Facility Operating License) will be promptly processed to ensure _that controlled copies of the Technical Specifications utilized for reference reflect

-the stations latest commitments...".

Contrary to the above, on December 3,1981, the controlled copy of the Technical Specifications maintained in Control Room did not properly reflect the latest status of Technical Specification amendments in i

that:

l License Amendment 49,- received by the Station during October,1981, had not yet been posted.

(

Licensee Amendment 50 had been placed in front of the Technical

[

Specification,-but had not been posted as a page for page replace-ment as required by the Amendment instructions.

- 8203050263 B2o216' 0FFICIAL RECORD COPY PDR ADOCK 05000293 0

PM

~ Appendix A 2

One page of' Amendment 38 was posted to the Technical Specification without removing the page being replaced.

This is a Severity Level VI Violation - Supplement I.

C.

10 CFR 50, Appendix 8, Criterion II, requires that suitable environ-mental conditions be established for activities affecting quality and that adequate cleanliness be maintained.

The Boston Edison Quality Assurance Manual (BEQAM) paragraphs 2.2.2.11 and 2.2.2.12 requires conformance with Regulatory Guide 1.33 - 1978, "QA Program Requirements (Operation)" and Regulatory Guide 1.39 -1977,

" Housekeeping Requirements for Water - Cooled Nuclear Power Plants".

These regulatory guides, in turn. require conformance to ANSI N18.7 -

1976Property "ANSI code" (as page type) with input value "ANSI N18.7 -</br></br>1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., "... Quality Assurance for the Operational Phase of Nuclear Power Plants"; ANSI N45.2.3 - 1973, " Housekeeping During the Construction Phase of Nuclear Power Plants"; and ANSI N45.2.1 - 1973, " Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants" as they are applicable to the operational phase of nuclear power plants. ANSI N45.2.3 requires that housekeeping I

zones, protection methods for open systems, housekeeping records and personnel training be established, and delineated in procedures. ANSI N45.2.1 requires that procedures be established for cleaning or verifying cleanness of components / systems.

Contrary to the above, as of December 4, 1981, neither programs nor procedures have been established which conform to the above standards in that:

Station Procedure 1.4.6, " Housekeeping", did not establish housekeeping zones, methods for protecting open quality systems, maintaining housekeeping records, or means of. training personnel; and No procedures have been established for cleaning or verifying cleanness of quality systems or components.

This is a Severity Level V Violation - Supplement I.

Pursuant to the provisions of 10 CFR 2.201, Boston Edison Company is hereby required to submit to this office, within thirty days of the date of this notice, a written statement or explanation in reply, including:

(1) the corrective steps which have been taken and the results achieved; (2) correct-ive steps which will be taken to avoid further violations; and (3) 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. Where good cause is shown, consideration will be siven to extending your response time.

. Appendix A 3

The responses directed by this notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

'U 6 $2 j,gg g Dated Thomas T. Martin, Director Division of Engineering and Technical Inspection