ML20042A345
| ML20042A345 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/04/1982 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042A342 | List: |
| References | |
| 50-293-82-04, 50-293-82-4, NUDOCS 8203230345 | |
| Download: ML20042A345 (2) | |
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APPENDIX A NOTICE OF VIOLATION Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 Based on the results of the inspection conducted on January 25-29, 1982, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified:
A.
Technical Specification 6.8.A requires that written procedures be established and implemented.
Contrary to the above, the following are examples where station procedures s operly implemented.
were not c
(1) On four occasions, October 20, 1981, and December 2, 3, 4, 1981 the licensee conducteu local leak rate tests on feedwater containment isolation valves 58 A&B with air.
This method did not conform to the water seal method prescribed and the valve lineup of procedure 8.7.1.8, revision 6, local Leak Rate Test of Feedwater Check Valves.
(2) Procedure 1.3.8, revision 25, Document Control section 4.c requires that notification be given to the Management Services Group when it is observed that a Piping and Instrumentation Diagram (P&ID) should be revised. As of January 29, 1982, this notification requirement had not been initiated by several licensee personnel who were aware of certain drawing errors since October 1981.
This is a Severity Level V violation (Supplement I of the Interim Enforcement Policy) applicable to DPR-35.
B.
10 CFR 50, Appendix B, Criterion V, states that activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances.
Technical Specification 6.8.A states, in part, that written procedures shall be established which meet or exceed the requirements and recommendations of Section 5.3 of ANSI N18.7-1972.
ANSI N18.7 section 5.3.4 states, in part, that General Plant Procedures provide instructions for integrated cperations of the plant, including startup procedures that shall include confirmation that valves are properly aligned.
OFFICIAL RECORD COPY 8203230345 820304 PDR ADOCK 05000293 G
Appendix A 2
General blant Operating Procedure 2.1.11, Revision 2, Section N.A states that valve lineup forms (Appendix A to System Operating Procedures) shall be utilized for conduct of all valve lineups.
Contrary to the above, the following are examples of drawings and procedures not appropriate to the circumstances and not meeting the requirement to confirm that valves are properly aligned.
1)
Three Piping and Instrumentation Diagrams (PI&D) did not identify thirteen test, vent, and drain (T, V&D) connections existing in safety related piping systems.
Instrument Air System drawing M-220 identifies only one header isolation valve inside the drywell when two exist. Three of these T, V&D connections are primary containment boundaries.
2)
The valve lineup check lists for the four applicable system operating procedures do not identify twenty-two valves associated with the T, V&D connections noted above; therefore their positions are not confirmed as required.
This is a Severity Level IV violation (Supplement I of Interim Enforcement Policy) applicable to DPR-35.
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) corrective 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 given to extending your response time.
The responses directed by this Notice are not subject to the clearance procedures l
of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Dated I N2
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l Thomas'T. Martin, Director I Division of Engineering and l
Technical Programs l
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0FFICIAL RECORD COPY l
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