ML20090K127
| ML20090K127 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/03/1984 |
| From: | Harrington W BOSTON EDISON CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20090K126 | List: |
| References | |
| NUDOCS 8405240048 | |
| Download: ML20090K127 (2) | |
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BOETON EDISON COMPANY l
800 BOYLSTON STREET BOSTON. M AssACHUSETTs 0219 9 WILLIAM D. HARRINGTON May 3,1984 BECo Ltr. #84-063
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Mr. Richard W. Starostecki, Director Division of 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 84-04
Reference:
NRC Letter to Boston Edison, dated April 3, 1984
Dear Mr. Starostecki:
This letter is in response to the violation identified during a routine safety inspection conducted by Mr. J. Johnson of your office on February 7,1984 to March 12,1984 and consnunicated to Boston Edison Company in Appendix A of the reference.
Notice of Violation (84-04-01) ll Technical Specification 6.8.A and USNRC Regulatory Guide 1.33, Section 4.j, require that procedures be established and maintained for normal operation of the containment ventilation systems.
Contrary to the above, between June 24, 1982 and February 22, 1984, procedures were not properly established and maintained for normal operation of the containment ventilation systems in that Procedure No. 2.2.70, Primary Containment Atmospheric Control, specified the normal position of two, 1-inch nitrogen block valves (H.O. 100 and H.O. 101) as L
" closed" and, if implemented, would have prevented remote operation of the post-LOCA Containment Atmospheric Dilution System.
Response
The error in the valve checklist in Procedure 2.2.70 occurred during the preparation of Revision 21 to~said procedure which was issued on June 26, 1982. However, the subject valves were in the locked open position during the operating segment of the current cycle as verified by successful performance of the Containment Atmospheric Dilution (CAD)
-System functional test on May 11, 1983 and further verified by visual observance by a licensed cperatcr and witnessed by the Resident Inspector on February 7, 1984.
8005240048 840515 PDR ADOCK 05000293 4
O PDR
W BOSTO'N E[DCN COMPANY
'Mr. Richard W. Starostecki, Director U. 5. Nuclear Regulatory Commission May 3, 1984 Page Two Upon discovery of the procedural error, our inmediate corrective action was to initiate a revision to the subject procedure to specify the correct position of the block valves (H.0. 100 and H.0. 101).
An effort is underway to make improvements to the procedure preparation and revision process including transfer of word processing to site, a streamlining of the " process," and assignment and definition of the responsibility for the proofing of procedures.
Any other discrepancies of a similar nature which may exist in safety-related procedures will be identified and corrected by two existing NRC-approved programs; namely, the Procedure Update Program (PUP) and the Program to Update Design Documents (PUDD) and by the resulting validation process. "oth of these programs, PUP and PUDD, are to be completed in October as stated in our Performance Improve-ment Program.
Full compliance was achieved with the approval and issuance of the revised procedure on February-22, 1984.
If you have any questions or need any further information on this subject, please do not hesitate to contact me.
Respectfully submitted, hl W. D. Harrington PB: caw