ML20070D802
| ML20070D802 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/15/1982 |
| From: | Harrington W BOSTON EDISON CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20070D801 | List: |
| References | |
| 82-248, NUDOCS 8212150224 | |
| Download: ML20070D802 (7) | |
Text
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EOSTON EDISON COMPANY 800 movLaTON 5tattT EOSTON. MoSSACHUSETTs 02199 witJ. LAM O. HAR RINC. TON g.emson wees pasessent NYCLEAA September 15, 1982 BECo. Ltr. #82-248 Mr. Richar6 W. Starostecki, Director Division ot' Project and Resident Programs Region I U.S. Nuclear Regulatory Commission 631 Park /. venue King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293 Response to Inspection 50-293/82-19 Ref:
IE Inspection 50-293/82-19, dated August 16, 1982 (BECo. Ltr. #1.82.249)
Dear Sir:
This submittal addresses the concerns identified in Inspection 50-293/82-19.
Violation A (50-293/82-19-01)
Technical Specification 6.8.D requires that written procedures to implement the Fire Protection Program be established, implemented and maintained.
Station Procedure No. 8.B.17, Inspection of Fire Doors and Dampers, Revision 0, states that "... breaching of a fire door or damper at PNPS requires the permis-sion of the Watch Engineer and the establishment of a documented fire patrol".
Contrary to the above, on June 24, 1982, fire door number 153 in the Radwaste/
Cortrol Building was found blocked open without the permission of the Watch Engineer or the establishment of a documented fire (at
Response
With regard to the fire door (#153) which was found blocked open, the following corrective steps have been completed.
1.
The Watch Engineer unblocked the fire door and returned it to the closed position.
2.
The door's locking mechanism was repaired.
3.
The Nuclear Operations Manager instructed the department heads to reiterate the requirement to their personnel about not blocking open fire doors.
8212150224 821210 PDR ADOCK 05000293 O
CDCTCN EDCON COMPANY Mr. Richard W. Starostecki, Director September 15, 1982 Page 2 As a result of an informal survey, it has been concluded that the current wording on the fire doors ("Do Not Block") is subject to misinterpretation and may have been a contributing factor in previous occurrences in which unattended fire doors were found blocked open.
To prevent this potential confusion, we intend to clarify the wording on three-hour rated fire doors to say "Do Not Block Open".
This will be completed by November 1,1982.
As a further corrective action to preclude future violations, we intend to supplement our General Employee Training (GET) by providing an additional handout and by adding specific questions to the associated quiz relating to fire protection requirements.
Full compliance will be achieved by November 12, 1982.
Violation B (50-293/82-19-02)
Technical Specification 6.8.D requires that written procedures to implement the Fire Protection Program be established, implemented and maintained, Station Procedure No.1.4.3, Storage of Flammable, Combustible Materials and Transient Combustibles Control, Revision 10, requires that combustibles be controlled within safety related areas to keep combustible loading within acceptable limits.
Contrary to the above, on June 29, 1982, the Safety Related Fan Room No. 2 on the 51' elevation of the Radwaste and Control Building was found to have transient combus-tibles moved into the area without exercising adequate controls to assure that combustible loading would be within acceptable limits.
1
Response
Our imediate corrective action was to relocate the anti-contamination clothing area to a non-safety related area.
This was completed on June 30, 1982.
With regard to the movement of transient combustibles at PNPS, we wish to make you aware that pre-move combustible loading evaluations are not always required either per Procedure 1.4.3, " Storage of Flammable Combustible Materials and Transient Combustibles Control or the PNPS Fire Protection Plan." Procedure 1.4.3 will be clarified to reflect the circumstances in which a combustible loading evaluation would be needed.
It is considered neither practical nor realistic to expect that every activity, especially those not specifically involved with the maintenance or modification processes, will be preceded by a combustible loading evaluation.
Notwithstanding the above, our routine (monthly) inspections should have identified this violation as a potential problem which would have resulted in either an acceptable loading evaluation (based on analysis) or appropriate corrective actions.
l To preclude recurrence of this type event, we intend to develop a set of check-l lists for the safety related areas identified in the Fire Protection System Review APCSB 9.5-1 Docket No. 50-293 March 1, 1977, and incorporate these checklists into a surveillance procedure. These checklists will be designed to ensure that key parameters, including combustible loadings, are considered for applicability when the surveillance procedure is performed. This procedure shall be implemented by November 12, 1982.
Full compliance will be achieved by November 12,1982; L
r BOLTON EDCN COMPANY Mr. Richard W. Starostecki, Director September 15, 1982 Page 3 Violation C (50-293/82-19-04) 10 CFR 50, Appendix B, Criterion III, requires that applicable design bases be correctly translated into drawings.
A design basis for Plant Design Change Request (PDCR) No. 81-22 and the supporting Safety Evaluation No.1157, dated May 21, 1981, specified that the proposed torus dewatering isolation valve be nonnally locked closed.
Contrary to the above, on June 25, 1982, a design basis for PDCR 81-22 was not correctly translated into two controlled drawings, (1) Piping and Instrumenta-tion Drawing (P&ID) M245, Rev. E2, Design Revision A, issued for construction, and, (2) P&ID M245 Drawing Change Approval No. 5, issued based upon an as-built walkdown, in that the nonnal position of the proposed torus dewatering isolation valve was not shown as locked closed.
Response
Our corrective action was to issue DCN 81-22-01 to P&ID M245 on June 28, 1982 to properly reflect existing piping configuration. Although the Piping and Instrument Drawing M245, Rev. 2, Design Revision A issued for construction was incorrect, the "as built" verification portion of the PDCR closeout process identified and corrected this error. The "as-built" drawir.g currently on file shows the correct designator for this valve.
To preclude recurrence of this type event, BECo. will review and revise Procedure HED 6.02 to require that " locked" designators ' ' addressed. This revision will be completed by December 1,1982.
In addition, the Deputy Nuclear Engineering Manager has reinforced the requirement to cognizant engineering personnel that greater attention to detail must be demonstrated during the PDCR preparation and review process.
Full compliance will be achieved by December 1,1982.
Violation D (50-293/82-19-05) 10 CFR 50.59(a) states that changes in procedures as described in the safety analysis report can be made without prior Commission approval, if the proposed change does not involve an t.nreviewed safety cuestion.
10 CFR 50.59(b) requires that a written safety evaluation be performed which prevides the basis for the detennination that the change does not involve an unreviewed safety question.
FSAR, Section 13.6.2, specifies that station operation will be conducted in accorJance with the power operations procedures that include detailed check-lists for all major systems to ensure that all necessary equipment is functioning and in the proper mode for startup.
Station Systems Operating Procedure No. 2.2.22, Reactor Core Isolation Cooling, provides in Appendix A, a valve checklist.
Contrary to the above, on May 19, 1982 a change was made in the nonnal position of the torus dewatering valve specified in Appendix A to Procedure No. 2.2.22 without Commission approval and without performing an adequate safety evaluation which provided the basis for whether an unreviewed safety question was involved.
ED3 TON E! CON C2MPANY Mr. Richard W. Starostecki, Director September 10, 1982 Page 4
Response
The corrective action we have taken was to review Procedse 2.2.22 in its entirety.
A Procedure Change Notice has been issued to correct this error.
In this case, the procedure status of the above mentioned valve will be changed back from the closed position to the correct, locked-closed position.
Since the valve was locked in the closed position, no change to the configura-tion cf the plant was required.
The most likely cause of the change in status from locked-closed to closed, as listed in Procedure 2.2.22, Rev. 14, can be attributed to an administrative error ocurring during an extensive procedure update:, resulting from plant walkdowns and general procedure improvements.
To preclude recurrence of this type of violation, a memo (MSG 82-933) has been distributed to management personnel involved in the procedure change process.
The memo outlines and re-emphasizes the concept that greater attention to detail must be demonstrated when a procedure is revised.
Full compliance of the above mentioned actions will be completed by October 1,1982.
Violation E (50-293/82-19-06)
Technical Specification 6.8.D requires that written procedures to implement the Fire Protection Program be established, implemented and maintained.
Station Procedure No. 8.B.17, Inspection of Fire Doors and Dampers, Revision 0, requires that fire door No. 4 in the Turbine Building be monitored by the Access Control System.
Contrary to the above, fire door number 4 in the Turbine Building was unmonitored by the Access Control System from June 8, 1982 to July 1, 1982.
l
Response
This violation was immediately corrected at the time of its identification by switching the alarm mode to " secure" from " access".
To preclude recurrence and ensure the continued monitoring of this and other alarmed fire doors, close supervision of the system was immediately established.
This control consisted of periodic checks of the mode of each fite zone.
Security Memo No. S-82-79 has been issued to reinforce this control. This memo j
has been reviewed by the console operators and security supervisors The contents i
of this memo will be incorporated in Station Security Procedure B.93.
The following is a list of planned changes.
1.
Each fire zone will be identified.
2.
The procedure will specify that each zone be maintained in " Secure Mode".
3.
Upon change of mode, an appropriate message will be entered via the console to the access command " Comment" field.
i COSTON E2 CON COMPANY Mr. Richard W. Starostecki, Director September 15, 1982 Page 5 4.
Each change of shift will require verification that each zone is in the
" Secure" mode or verification that other compensatory measures are in affect.
The measures incorporated into this procedure will preclude occurrences of this type in the future.
This procedure revision and associated training will be completed by November 1, 1982.
Full compliance will be achieved by November 1, 1982.
Notice of Deviation (50-293/82-19-08)
Based on the results of an NRC inspection conduct =d during the period June 14 -
August 1,1982, it appears that one of your activities was not conducted in conformance with your comitment to the Comission as indicated below:
In your letter to the Comission dated February 27, 1978 (BECo. letter No. 78-35) regarding fire protection, you listed fire doors that were normally locked or alarmed and stated that other fire door assemblies within a single fire zone will be placed under administrative control and inspected periodically to ensure they are in the proper position.
"These fire door assemblies will be added to the Watch Engineer's daily inspection tour."
Contrary to the above, the referenced fire doors which are not normally r 'cked or alarmed, had not been added to the Watch Engineer's daily inspection t Jr by July 12, 1982.
Response
With regards to the identified deviation, it is apparent that there occurred a failure to properly translate the comitment into an appropriate action.
The commitment to inspect fire doors which are not locked and not alarmed on a daily basis has been added to Station Procedure 2.1.16, OPER 08.
We believe that the recent implementation of the Nuclear Organization Commitment Control System will preclude recurrence of items of this type. Full compliance has been achieved.
Supplemental Response to Item of Non-Compliance 82-04-03 An exhaustive review of the circumstances surrounding the failure to fully correct the identified items in IE Report 82-04 and IE Report 82-19 has not identified a conclusive reason or reasons which could explain the breakdown of management controls which resulted in ineffective followup corrective actions. This review did identify several factors which, when considered in total, contributed to the overall problem.
I
BQ3 TON EDCON COMPANY Mr. Richard W. Starostecki, Director September 15, 1982 Page 6 An extensive system walkdown and verification project prior to startup from the 1981 Refueling Outage generated a large number of relatively minor deviations (primarily test, vent, and drain connections) for which corrective actions were initiated. This large effort may have tended to dilute the effectiveness of the actions taken in response to IE Report 82-04.
Miscommunication of project objectives to the personnel involved in the system walkdowns and document upgrade processes, and inadequacies in the audit-able trail concerned with checking the results are also believed to be contributing factors. We believe that the above mentioned factors were most likely responsible for the recurrence of this problem.
To preclude recurrence of ineffective followup corrective actions, each' ins'tance must be assessed independently.
In this case, additional emphasis will be placed on tighter control of the in-process documentation.
For efforts of this type, more detailed planning will be established at the inception of a project, which will ensure high quality results. The need for a single authority to coordin-ate multi-disciplined projects of this type will be ascertained so that effec-tive project scoping, implementation, and closeout will be attained.
To correct the specific discrepancies identified in IE Report 82-04 and IE Report 82-19, a plan will be developed to resolve the deviations between 1.) the sketches associated with Procedure 8.7.1.5, " Local Leak Rate Testing of Primary Containment Penetrations and Isolation Valves", 2.) the system P&ID's which were subjected to a walkdown just prior to restart from the 1981 Refueling Outage, and 3.) the valve lineup check lists associated with the system procedures. The plan will focus on the LLRT sketches as the lead document against which the others will be compared. Our basic approach will be to identify the deviations which represent conflicts between the documents and then resolve them accordingly.
The primary results exlected from this effort are agreement between the LLRT sketches, and key P&ID's, valve lineup check-lists, and Procedure 8.C.13.
Please be aware that this action is not intended to supersede any actions committed in our Performance Improvement Plan.
Full compliance is contingent upon determining the scope of the number of deviations identified and the resulting efforts of disposition. The plan, detailing our comitments and the associated schedule will be provided by l
October 15, 1982.
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BA; TON EDCON COMPANY Mr. Richard W. Starostecki September 15, 1982 Page 7 Also, we wish to thank you for the one (1) day extension granted by telecon with your Mr. Eldon Brunner.
We believe this submittal satisfactorily responds to the issues identified in IE Inspection 82-19.
Should you require any further information concerning this response after reviewing it, please contact us.
Very truly yours, i
5
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IIYh It 0/
Commonwealth of Massachusetts)
County of Suffolk
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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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