IR 05000293/1985001

Ack Receipt of Informing NRC of Steps Taken to Correct Violation B Noted in Insp Rept 50-293/85-01. Violation a Re Number of Licensed Operators in Control Room Remains as Stated

ML20129F796
Person / Time
Site:	Pilgrim
Issue date:	07/11/1985
From:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Harrington W BOSTON EDISON CO.
References
NUDOCS 8507170462
Download: ML20129F796 (4)

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JUL 111985 Docket No.~.50-293 Boston Edison Company M/C Nuclear ATTN: Mr. William D. Harrington Senior Vice President, Nuclear 800 Boylston Street Boston, Massachusetts 02199 Gentlemen:

Subject: Inspection 50-293/85-01-This refers'to your_ letter dated March 22, 1985, in response to our letter dated February 20, 1985, which transmitted Inspection Report 50-293/85-0 Thank you for informing us of the corrective and preventive actions documented in your letter regarding Violation B. These actions will be examined during a future inspection of your licensed progra In your letter you disagree with Violation A, which dealt with the number of lic-ensed operators.that were present in the control room, and indicate that the use of the bathroom by a licensed ope ~.ator is considered acceptable without any com-pensatory measures because you believe the bathroom to be ~a part of the control roo You also indicate that it is acceptable for the licensed senior operator providing supervisory oversight in the control room to relieve a licensed operator at the reactor controls for brief periods of tim We have reviewed your response and as discussed in more detail in Enclosure 1, we reinforce our conclusion that your practices are in violation of the requirements of 10 CFR 50.54 as described in Appendix A to Inspection Report 50-293/85-0 In your letter, you stated that, based on your discussions with individuals from the Office of Nuclear Reactor Regulation, your practice is acceptable to and supported by the Division of Human Factors in that office. We have pursued this matter with responsible management in DHFS and they do not support your position. - Accordingly, you are'hereby required to respond to the violation and in respcnding to this let-ter you should follow the instructions in Appendix A to Inspection Report 85-0 The' response directed by this letter is not subject to the clearance procedures of.the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51

Sincerely, original sisned att Richard W. Starostecki, Director Division of Reactor Projects Enclosure: Detailed Basis for Violation

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A. V. Morisi, Manager, Nuclear Management Services Department C. J. Mathis, Station Manager Joanne Shotwell, Assistant Attorney General Paul Levy, Chairman, Department of Public Utilities W. J. Nolan, Chairman, Plymouth Board of Selectmen Plymouth Civil Defense Director Senator Edward P. Kirby Division of Human Factors Safety, NRR NRC Licensing Project Manager Public Document Room (PDR)

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Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Massachusetts (2)

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ENCLOSURE DETAILED BASIS FOR VIOLATION Requirement 10 CFR 50.54(m)(2)(iii) states: "When a nuclear power unit is in an operational mode other than cold shutdown or refueling, as defined by the unit's technical specifications, each licensee shall have a person holding a senior operator license for the nuclear power unit in the control room at all time In addition to this senior operator, for each fuelea nuclear power unit, a licensed operator shall be present at the controls at all times."

Example 1 Senior reactor operator (SRO) relieving the reactor operator (RO) at the control The requirement clearly states: "In addition to this senior operator..." There-fore, one SR0 may not satisfy the dual requirements of an R0/SR0 at the controls and an SR0 in the control room. Accordingly, when the SR0 relieved the R0 at the controls, these two requirements were not me e Further, the Statements of Consideration for this rule, contained in the Federal Register at 48 FR 31611 state: "The requirement for a senior operator's continuous presence in the control room would assure that: (1) a person is available who can provide the oversight function of the supervisor so that the probability of cor-rectly detecting abnormal events early enough to mitigate potential adverse con-sequences might be increased." The Statements of Consideration also state: "The requirement for an additional licensed operator for operating units is necessary so that a qualified individual will be able to provide relief for the operator at the controls. The senior operator in the control room cannot be relied on for such relief under the rule because having the senior operator perform the functions of a reactor operator, even for a limited time, would result in loss of oversight function of the supervisor which might decrease the probability of correctly de-tecting abnormal events early enough to mitigate potential adverse consequence If the senior operator in the control room was without a second licensed individual to monitor plant instrumentation and manipulate controls, the senior operator might not be able to oversee and observe other relevant plant conditions."

Example 2 SR0's use of the bathroom while one R0 remains in the control roo The requirement states that the SR0 must be in the control room at all times. In this instance, while the bathrcom is adjacent to the control room, a person in the bathroom with the door closed has ro direct visual or auditory contact with the control room panels or its annunciators. Accordingly, when the SR0 is in the bathroom, the requirement for an SR0 in the control room at all times is not me m 0FFICIAL RECORD COPY

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t Enclosure 2 Further, the Statements of Consideration for this rule state: "However, the senior operator should remain, at all times, in a position to provide prompt assistance to the reactor operators when requested. Additionally, that means that the senior operator must either (1) be in sight of or in the audible range of the reactor operators at the controls or (2) be in the audible range of the control room an-nunciators. 'This is necessary so that the senior operator's training and knowledge will be immediately available as needed."

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