ML20065J706

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Responds to NRC Re Violations Noted in IE Insp Rept 50-293/82-12.Corrective Actions:Draft Training Plan Written,Interim Administrative Controls Re Tech Specs Implemented & Operator Requalification Program Revised
ML20065J706
Person / Time
Site: Pilgrim
Issue date: 08/27/1982
From: Harrington W
BOSTON EDISON CO.
To: Starostecki R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20065J683 List:
References
82-229, NUDOCS 8210060164
Download: ML20065J706 (2)


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s BOETON EDISDN COMPANY B00 BOYLETON STREET BOETON, MA55ACHusrns 02199 WILLIAM D. HARRINGTON

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/ , August 27, 1982 BECo Ltr. #82-229 Mr. Richard W. Starostecki, Director Division of Project and Resident Programs Region 1 U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293

References:

(a) USNRC Letter dated July 7, 1982; Inspection No. 50-293/82-12 (b) BECo Letter dated August 6, 1982; Response to Inspection No. 50-293/82-12

Subject:

Supplemental Response to I&E Inspection No. 50-293/82-12

Dear Sir:

This letter is written to clarify the information we pros'ded to you in Ref.

(b). The need for this clarification was recognized and agreed to by members of our staff during a aeeting on August 16, 1982 with the Senior Resident Inspector assigned to Pilgrim Station.

A training session was initiated for all licensed personnel to inform them of the deviation in reactor water level instruments event and to review the ap-propriate directions as delineated in Special Order 82-04. This training has been completed.

In order to prevent future violations of this nature, we have written a draft training plan which incorporates the specifics of the reactor water level di-vergence event. This training will be included in the Plant Systems Update portion of the Operator Requalification Program which will be completed by .

November 1. 1982.

The event which led to this notice of violation concerned a failure to recognize and follow a limiting condition of operation which was entered while attempting to resolve the deviation between th<s reactor water level instruments. This event and others of a similar natura, has caused us to take corrective actions which address the broader issue of adequately recognizing, interpreting and applying Technical Specifications.

We have implemented interim administrative controls which require Watch Engineer (WE) and Shift Technical Advisor (STA) concurrence on Technical Specification interpretations which allow continued operation of the unit. These controls provide escalation to higher management for those areas of disagreement.

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BOSTON EEC2N COMPANY We believe this step will resolve our concerns until completion of the following actions.

We have held discussions with consultants for the development of a Tech Spec training program for the STA's. This program is expected to be ready for imple-mentation by October 15, 1982.

The Tech Spec training provided for the WE's and the other SR0's during their requalification training will subsequently be expanded to encompass the training afforded the STA's. This training will be completed by the end of each indi-vidual's next requalification cycle. (September 1,1983)

The Operator Requalification Training Program will also be reviewed and revised as necessary to assure that the operations personnel receive adequate training concerning reactor water level anoma' .es and instrument channel logic, which includes ECCS, RPS and PCIS System lot'.c. This program assessment will be completed by January 1, 1983 and the resultant training provided during the next requalification cycle. (September 1, 1983)

We are also filling the position of Chief Operating Engineer to provide con-tinuity of direction to the operations group. We expect to have this completed by October 1, 1982.

We trust that you will find this clarification satisfactory; however, should additional information be required, please contact us.

Very truly yours, 1

Commonwealth of Massachusetts) g y) [4 County of Suffolk ) (

Then personally appeared before me William D. Harrington, who, being duly sworn, did state that he is Senior Vice President - Nuclear of Boston Edison Company, the applicant herein, 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.

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