ML20065J725

Responds to NRC Re Violations Noted in IE Insp Rept 50-293/82-12.Corrective Actions:Addl Operator Training Implemented & Reactor Water Level Divergence Issue Incorporated Into Operator Requalification Program

ML20065J725
Person / Time
Site:	Pilgrim
Issue date:	08/06/1982
From:	Harrington W BOSTON EDISON CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20065J683	List: ML20065J706 ML20065J725
References
82-206, NUDOCS 8210060180
Download: ML20065J725 (4)

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BOSTON E' DIS O N COMPANY 800 BovLaTON STREET BOETON MABBACHUBETTs 02199 WILUAM O. HAR RINGTON August 6, 1982 BECo Ltr. #82-206 m

Mr. Richard W. Starostecki, Director Division of Project and Resident Programs Region I U.S. Nuclear Regulatory Cc mnission 631 Park Avenue

• King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293 Reference (A): NRC letter of July 7, 1982 from Mr. R. W. Starostecki to Mr. W. D. Harrington (BEco. Ltr. #1.82.192)

Subject:

IE Inspection 82-12

Dear Sir:

This responds to a violation identifed in a routine safety inspection conducted April 5-May 9, 1982 at the Pilgrim Nuclear Power Station and transmitted to us in Reference (A).

The response to the specific natice of violation (INC 82-12-01) is contained in the attachment to this letter.

A substantial review of this event was performed, which included corporate involvement. Although the elements of a corrective action plan had been initiated, we have now determined that the investigation into the most probable cause was not satisfactorily concluded prior to implementation, nor did it consider whether a causal relationship exists between this and other events, which would indicate a broader issue. Therefore, we will continue to investigate this issue and develop a corrective action plan accordingly.

As part of our corrective action, we will include additional Operator training to ensure their familiarity with multiple Technical Specification situations which may apply during certain operational circumstances and additional training to ensure operator familiarity with reactor protection system logic.

13210060180 820930 .

~PDR ADOCK 05000293  ;

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i. COOTON EDCON CEMPANY Mr. Richard W. Starostecki, Director August 6, 1982 Page Two i

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We believe this response satisfactorily addresses the item identified in Reference (A). Should you require further information concerning this

, response, please contact us.

4 Very truly yours,  ;

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Commonwealth of Massachusetts) I County of Suffolk )

Then personally appeared before me William D. Harrington, who, being duly sworn, did state that he is Sr. 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 Edi;on Company and that the statements in said submittal are true to the best of his knowledge and belief.

My Commission expires: g 6 / q j/ j _

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i attachment

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' Attachment to BECo Ltr. #82-It'/,

ATTACHMENT Violation Appendix A (Inc 82-12-01)

Technical Specification.3.1.1 requires complete insertion of all control rods within four hours when both trip systems have less than two operable reactor low water level instrument channels.

Contrary to the above, on March 29, 1982, complete insertion of all control rods was not performed within four hours of having less than two operable reactor low water level instrument channels in both trip systems.

This is a Severity Level IV violation (Supplement I).

Response

Our immediate corrective action was to iasue Special Order 82-04, " Directions following Deviation Between Reactor Water Level Instruments " and to conduct training for all on-watch personnel regarding this issue. This training is scheduled for completion by September 1, 1982.

To preclude recurrence, the subject reactor water level divergence issue will be incorporated into the Operator Requalification Program, which is scheduled to begin on September 7, 1982, at which time, full compliance shall be achieved.

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