ML20082U970

Responds to NRC Re Violations Noted in IE Insp Rept 50-293/83-19.Corrective Actions:Special Order Book Review Performed,Resulting in Retirement of Invalid Special Orders.Failure & Malfunction Rept Procedure Revised

ML20082U970
Person / Time
Site:	Pilgrim
Issue date:	11/18/1983
From:	Harrington W BOSTON EDISON CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20082U963	List: ML20082U970
References
#83-288, NUDOCS 8312190239
Download: ML20082U970 (2)

Text

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4 EOSTON EDISON COMPANY 800 WovLaTON STREET EOsTON. MANSACHUSETTE D2199 wlLLIAM D. HARRINGTON

cc ... .. .. .

' November 18, 1983 .

I BECo Ltr. #83- 288 Richard W. Starostecki, Director Division'cf. Project and Resident Programs

.U. S. Nuclear Regulatory Commission Region 1

-631 Park Avenue King of Prussia, -PA 19406 License No. DPR-35 Docket No. 50-293

SUBJECT:

' INSPECTION 83-19

Reference:

NRC Letter to Boston Edison Co. dated October 27, 1983

Dear Sir:

This letter is in response 'o t two (2) violations identified during a routine safety inspection conducted by Messrs.'J. Johnson'and H. Eichenholz of your office on August 16, 1983 to October 3, 1983 and communicated to Boston

' Edison Company.in Appendix A of the reference.

Notice of Violation A. -(INC 83-19-02)-

10 CFR 50, Appendix B, Criterion'II, requires that the quality assurance program.be carried out by documented policies and procedures. The Boston Edison Quality Assurance Manual, Section 2. Revision 11, states that the quality; assurance program conforms to NRC Regulatory Guide 1.33. Revision 2.

Regulatory Guide 1.33, Revision 2, Section C.5, requires periodic review and

- updating of Special Orders..

Contrary.to the above, as of September 12, 1983, periodic review and updating

' ~of Special Orders had not:been performed. The oldest active entry was dated

~

October 8, 1981. Furthermore, the governing procedure, No. 1.3.2, Special Orders, Revision.8, did not require periodic reviews.

Response = -

The immediate corrective action taken was the performance of a Special Order Book' review'which resulted in the retirement or. updating of'those Special

- Orders which were determined-to be no longer valid or appropriate. This action was. completed'on: September 20, 1983.~

To preclude' recurrence, the_Special-Order procedure is being revised to include specific requirements re;;arding review of the Special Or' der Book.

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~ Novemberfl8, 1983 Page/2- >

Full compliance will be achieved with the issuance of the revised pro-cedure, which is scheduled to -occur onnJanuary 15, 1984.

Notice of Violation 1 B. (INC 83-19-01)_

' Technical..Specifica' tion 4.5.H. Maintenance of Filled Discharge Piping, re-'

quires that_the discharge piping of the Core Spray system be vented from Lthe high point.~:

' Contrary to the.above, as of September 28, 1983, the. discharge piping of the

. Core--Spray system was not vented from the high point, but was vented from the

~

drain valves on the piping.

Response

To' ensure compliance with the-Technical Specification section-4.5.H and station procedures, and to' preclude recurrence of. improper venting, a memorandum was issued to operating personnel'specifying that all venting of-high integrity

.pipingcfor keep-fill checks 11s to be done at the high point vents and not the

-t high point drains.

si.o ~ . Full compliance was achieved on'0ctober 14, 1983.

. Review'and Evaluation of Events

TheLreference letter to Boston Edison Company also requested details of actions cplanned to improve the review and~ evaluation of events for reportability.

cResponse

,~

Prior to the event noted in. paragraph 4.A;(4) of Inspection. Report 83-19, station personnel had performed a review of the station procedure for the' pro-

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' cessing'of Failure and Halfunction Reports and determined that a procedure change would be necessary. A revision'has been completed and was approved by

.the Operations- Review Committee on. November 9,1983 to effect .a more expe-ditious review-and evaluation of events for reportability.

'If'you have any. questions on the above responses, please direct them to the Eundersigned.

Very truly yours,.

William D. Harring on 1WDH:em f

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