ML20114D412
| ML20114D412 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 01/09/1985 |
| From: | Harrington W BOSTON EDISON CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 85-003, 85-3, NUDOCS 8501310284 | |
| Download: ML20114D412 (3) | |
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BOSTON EDISON COMPANY B00 BovLsTON STREET BOSTON. MASSACHUSETTS 02199 W!LLIAM D. HARRINGTON January 9,1985
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BEco Ltr. #85-003 Mr. Richard W. Starostecki, Director Division of Project and Resident Programs U. S. Nuclear Regulatory Commission Region I - 631 Park Avenue King of Prussia, PA 19406
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License No. DPR-35 Docket No. 50-293
Subject:
Response to Violations as Contained in NRC Inspection Report No. 84-36
Reference:
NRC Letter to Boston Edison, dated December 10, 1984
Dear Mr. Starostecki:
This letter is in response to the Violations identified during an inspection conducted by Mr. J. Johnson and M. McBride of your office on November 1, 2, and 7, 1984 and communicated to Boston Edison Company in Appendix A of the reference.
lechnical Specification 6.8 and Regulatory Guide 1.33 require that procedures for shift turnover be implemented. Station Procedure 1.3.34,
" Conduct of Operations," Revision 4, May 31, 1983 requires that control room personnel (i.e., Nuclear Watch Engineer, Nuclear Operation Supervisor, and Nuclear Plant Operator) ensure that adequate shift turnover is given and received. Procedure 1.3.34 also requires that shift turnover sheets for the Nuclear Watch Engineer, Nuclear Operation Supervisor, and Nuclear Plant Operator (OPER38B, 38C, and 38D, respectively) be completed prior to shif t turnover to indicate bypassed or out of service equipment. This procedure requires the Nuclear Plant Operator to maintain an awareness of plant status and changes in plant conditions.
Contrary to the above, on November 1,1984, control room personnel did not ensure that adequate shift turnovers were given and received between the first (midnight to 8:00 a.m.) and second (8:00 a.m. to 4:00 p.m.) shifts.
The bypassed "B" Source Range Monitor (SRM) was not recorded on OPER38B, 38C, or 380 prior to shift turnover between the first and second shif t on November 1,1984. The Nuclear Plant Operator was not aware that the "B" SRM was bypassed. As a result, personnel on the second shift moved fuel assemblies and control rods in the reactor vessel while unaware that the "B" SRM was bypassed.
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PDR ADOCK 05000293 h
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. l g BOSTON EDISON COMPANY Mr. Richard W. Starostecki U.S. Nuclear Regulatory Commission
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January 9, 1985 Page Three Notice of Violation '8" i
Technical Specification 6.8 and Regulatory Guide 1.33 requires that procedures be implemented for refueling and core alterations. Station Procedure 4.3, " Fuel Handling," Revision 21, dated October 17, 1984 requires that during refueling the SRM's be continuously monitored from the time a fuel assembly is about to enter the core until the refueling platfom returns to the spent fuel pool.
Contrary to the above, on November 7,1984 at approximately 8:45 a.m., the SRM's were not continuously monitored while a fuel assembly was loaded j
into the core.
'. Corrective Steps Taken and the Results Achieved l
The identified violation occurred due to a misinterpretation of SRM j
monitoring requirements by the Nuchar Operating Supervisor on duty at the time. He incorrectly inferred thr' the continuous monitoring requirement of Station Procedure 4.3 could be v.
by the operator at the 905 panel r
l intermittently checking - rather thmi continuously watching - the SRM's.
Immediate corrective action was implemented when the situation was brought to the attent4n of the on-shift Watch Engineer and Chief Operating Engineer. A second operator was prneptly dispatched to the control room to ensure personnel were available to properly monitor the SRM's during further fuel loading activities and the NOS was subsequently reinstructed concerning SRM monitoring requirements.
Preventive Measures Taken to Avoid Further Violations To' preclude recurrence of_the violation,~ Boston Edison has applied I
increased management attention to control room staffing and supervision.
As noted in our response to the first violation.. either the Nuclear Operations Manager or Chief Operating Engineer is now and will continue to be present in the control room on a 24-hour basis during.important phases of the current start-up activities. Additionally, as noted above, control room staffing was reviewed by plant management to ensure that individual crews contain a mix of heavily experienced'and lesser experienced personnel.-
780ston~ Edison achieved full compliance on November 7,1984, the date on which the Nuclear Operating Supervisor was reinstructed concerning SRM
' monitoring requirecents.
'If there are any questions concerning these matters, please do not hesitate to
-contact me.
-Respectfully submitted,
^
t William D. Harrington-4 1
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BOSTON EDISON COMPANY Mr. Richard W. Starostecki U.S. Nuclear Regulatory Commission January 9,1985 Page Two Corrective Steos'Taken and Results Achieved Boston Edison suspended fuel loading upon identification of the violation. As immediate corrective action to correct the deficient condition, verbal reprimands were administered to the licensed personnel involved in the incident. They were counseled as to the need for improved observation of of f-normal conditions, for improved communications between the control room and the refuel floor, and.for compliance with Procedure 1-1.3.34.
Additionally, each operating shift was briefed on the importance of walking down the control room panels carefully during shift turnover and on the importance of the SRM's during fuel reload activities.
Boston Edison completed. corrective action by reviewing shif t turnover
. checklists.for.the Operating Supervisor and Licensed Operators to ensure that the shift turnover forms contained in Procedure 1.3.34 are adequate.
As'a result of this review, " Fuel Load Checklist" attachments were added 4
to'.the OPER 38C id OPER 380 turnover sheets via a temporary SRO change.
The added Fuei.oad Checklists are required to be performed whenever a change of operators occurs at Panel 905 during fuel loading. They require both the off-going and on-coming personnel to perform and document a check of operable equipment for fuel loading activities, indicating off-normal conditions including checks on SRM operability.
Preventive Measures Taken to Avoid Further Violations To preclude repetition of this violation, Station management reviewed the' experience of licensed control room personnel to ensure that crews are balanced and contain a mix of heavily experienced and lesser experienced personnel. We have since determined that the watches were properly L
balanced.
Additionally, Boston Edison plans to incorporate the SRO changes mentioned L
above on a permanent basis..This.will be done by 3/1/85.
Finally, as a supplemental measure to preclude recurrence during the balance of the current refueling / start-up efforts, either.the Nuclear-
- Operations Manager or Chief Operating Engineer hes been and will. continue
'to be present in the control room during critical activities on a 24-hour per day basis.
BostonL Edison achieved full compliance on November 1,1984, the date upon
. hich the appropriate personnel were counseled'and the subject checklists w
were reviewed for adequacy.
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