ML20083B377
| ML20083B377 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/17/1991 |
| From: | Gina Davis BOSTON EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 91-121, NUDOCS 9109250062 | |
| Download: ML20083B377 (5) | |
Text
_ _ _ _ _ _ _ _ _
10 CFR 2.201 BOSTON EDISON Pagom Nuclear Power Staton Rocky Hdt Road h mouth, Massachusetts 02300 i
George W. Davis s ner vie re oent - Nuoe.,
September 17, 1991 BECo,tr. 91 121 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Hashington, D.C.
20555 Docket No. 50-293 Litense No. DPR-35
SUBJECT:
REPLY TO NOTICE OF VIOLATION (REFERENCE NRC REGION 1 INSPEC110N REPORT NO. 50-293/91-20)
Dear Sir:
Enclosed is Boston Edison Company's reply to the Notice of Violation contained in the subject inspection report.
Please do not hesitate to contact me if there are any questions regarding the enclosed reply.
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. Page 1 LMC10SUEE RELL1030HCLOF V10LAH08 Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station
!icense N".
OPR-35 As a result of the inspectio-
.,ucted at Pilgrim Nuclear Fower Station from July 29, 1991 through August 2, 1991 and in accordance with the NRC Enforcement Policy (10CfR2, Appendix C), the following Violation was identified:
M011CLOLY10Lal10N The Pilgrim Nuclear Power Station Physical Security Plan, dated November 23, 1988, Revision 8, Section 6.1, st u s, in part, that areas within the Protected Area, the perimeter and isolation zones are illuminated to a minimum of 0.2 foot-cantiles roa:ured at ground level.
In addition, Section 4.1.1, R,..ision 5, of the Pilgrim Nuclear Power Station Security Procedure, " Security Patrols and Equipment Inspections" states, in part, that security lighting shall be verified during hours of darkness.
,S.:nkc Discrepancies sha^
be rept ted to the Officer-In-Charge (0IC) who will tT" ensure compensator,, measures are initiated, the BECo Security Shift NE Supervisor (SSS) is notifled, and proper entries are made in the Daily 1 f_
Security Activity Report.
Section 5.5, Revision 19, of the Pilgrim Nuclear Power Station Security Procedure, " Loss or egradation of Perimeter / Protected Area lighting System' states, in part, tL c when Protected Area lights are inoperative, the OIC shall be immediately notified of the lighting loss and location.
If, in the judgment of the OIC, lighting levels fa'.1 belos 0.2 foot-candles, the OIC i
shali initiate compensatory measures.
Cantiary to the above, on July 31, 1991, at approximately 4:00 a.m., while conductiny a lighting survey, three areas were identified Ly the inspectors
<hich did not satisfy the minimal lighting requirenu..t (i.e., 0.2 font-candles measured at ground level) and for whit-no compensatory measures had been implemented. The specific areas were: (1) under an E. H. Hines office trailer adjacent to the H.P. Building; (2) under the connecting structure between two office trailers in the vicinity of the H.P. Building; and (3) Ur. der the connecting structure between two office trailers adjacent to the Administrative Building.
This 1: a Severity Level IV Violation (Supplement III).
DACEGROMQ On July 31, 1991, a Protected Area (PA) and isolation zone lighting survey was conducted from approximately 4:00 a.m. to 6:00 a.m.
Dering the survey, three areas were identified that were not tiluminated to the level of 0.2 foot-ccodles as specified in the Security Plan.
Two of the areas were undet connecting structure < between two office trailers and the third areh was under a partially skirted trailer for which lighting was installed but not energized.
4 Page 2 BCELLl03011CE_0F V10lHl0H (CONTINUED)
Security force members (SfHs) who conduct PA patrols are provided with a log sheet that identifies areas having lighting deficiencies (e.g. burned out bulbs). To compensate for lighting deficiencies, the SfHs are required to tour and inspect those areas while conducting their rounds. All lighting deficiencies identified by the SfHs and not identified on the log sheets must be reported to the OIC for evaluation and, if needed, compensatory action.
A review of the security patrol log sheets indicated that none of the three areas identified wert. noted on the log sheets and, therefore, no compensatory measures had been implemented.
The inspectors Jetermined that the failure to maintain the lighting in the three areas within-the specified levels, as committed in the Security Plan, represented a violation of NRC requirements.
C0!LRLCTIVE ACTION 'AKEN AND RESULTS ACillEVID Immediate corrective actions were taken that restored the lighting level in two of the three identified areas to e level equal to, or greater than 0.2 foot-candle measured horizontally at ground !evel.
They are respectively in the area under the E.H. Hines office trailer adjacent to the H.P Building and under the connecting structure between two office trailers adjacent to the Old Administration building.
The third arec which consisted of the l
connecting structure between two office trailers in the vicinity of the H P.
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Building was physically enclosed to preclude access by an individual and the need for lighting. A subsequent lighting survey of the Protected Area and Isolatior Zone was conducted and no further deficiencies were identified that had not been previously identified and documented.
CORRECJ1VE ACTION TAKEN TO PRECLUDE RECURREECE To preclude recurrence of similar Violations, Boston Edison impiemented additional actions that include the following:
Revision of Station Instruction SI-SC.1215 " Identification of Protected a
Area Lighting Loss" to provide improved guidance for the detection and l
reporting of lighting deficic*s and implementation of propei compensatory measures, when required.
Improvements incorporated into SI-SC.1215 include:
Expanded clarification of responsibilities foi key SFNs.
Additional examples of areas where SFHs should be particularly cognizant for possible -lighting deficiencies.
l Improved guidance on acHons to be taken by SFHs upon notification of a lighth g loss / deficiency.
Improved lighting survey maps and cher.klists.
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Page 3 Additional guidance for performing lighting surveys.
Revision 2 of Procedure SI-SC.1215 was issued on September 13, 1991.
Enhancement of the training lesson plan SP-PTL-01 and crucial tasks to provide the SFHs with a better understanding of lighting requirements and potential deficiencies, Revision 2 of Lesson Plan SP-PTL-01 was issued on September 6, 1991.
Additional training of the security shif t supervisors on the use of light meters was accomplished on August 5, 1991.
DAJE HHEN FULL COMPLIbEL HAS ACtj][ YID full compliance was achieved on July 31, 1991 when immediate action was taken that :estored the lighting level in two of three identified areas to a level equal to, or greater than 0.2 foot-candle measured at ground level and installation of a physical barrier at the third identiftad area, t