ML20058G982

Notice of Violation from Insp on 900816-1008.Violation Noted:Licensee Issued Two Minor Field Rev Notices Which Affected Safety Evaluation Bases of Plant Design Change for Temporary Leak Seal Repair of Shutdown Cooling Sys Valve

ML20058G982
Person / Time
Site:	Pilgrim
Issue date:	11/07/1990
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20058G981	List: IR 05000293/1990020 ML20058G976 ML20058G982
References
50-293-90-20, NUDOCS 9011140171
Download: ML20058G982 (2)

Text

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NOTICE OF VIOLATION ,

I Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DRP-35 As a result of the inspection conducted on August 16 to October 8,1990 and in accordance  !

with the NRC Enforcement Policy (10 CFR 2 Appendix C), the following violation was identified:

10 CFR 50, Appendix B, Criterion 111 requires that, design changes, including field changes, be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original ,

design.  ;

The Boston Edison Quality Assurance Manual, Volume II, Section 3 requires that, 3 subsequent changes to an approved plant design change package are made using Field Revision Notices (FRNs). Nuclear Engineering Deparnent Procedure (NED),3.03,

" Field Revision Notices," states that: The cognizant discipliia division manager (DM) ;

or an engineer assigned by the DM review FRNs and make deerminations to whether ,

they are major or minor and safety related or non safety related. A major FRN is  :

defined as one that: (1) changes the original conceptual design or the intent of the implementation document, or (2) affects the (br,ses) on which the approved safety evaluation was made. NED 3.03 also requires that the original design change safety  !

evaluation be revised (to reflect the affect of major FRNs) and approved prior to ,

implementation.

Contrary to the above, on September 11 and September 23, the licensee issued two minor FRNs which affected the safety evaluation bases of a plant design change for -

the temporary leak seal repair of a shutdown cooling system valve. As a result, the .

appropriate safety evaluation (revision) and required approval did not occur.

This is a Severity Level IV Violation (Supplement I).  ;

Pursuant to the provisions of 10 CFR 2.201, Boston Edison Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, A'ITN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional  ;

Administrator, Region I, and a copy to the NRC Resident inspector, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be :learly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the .

corrective steps that have been taken and the results achieved, (3) the corrective steps which  ;

will be taken to avoid further violations, and (4) the date when full compliance will be achieved, if an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause  !

is shown, consideration will be given to extending the response time, s

9011140171 901107 PDR ADOCK 05000293 0 PDC

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The response directed by this Notice is not subject to the clearance procedures of the Office  :

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