ML20133P466
| ML20133P466 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/18/1985 |
| From: | Harrington W BOSTON EDISON CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 85-190, NUDOCS 8511010021 | |
| Download: ML20133P466 (4) | |
Text
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t EOSTON EDISON COMPANY 500 GovLeTON Stets?
BOSTON. MASSACHUSETTe 02199 WILLIAM D. HAmplNOTON October 18, 1985 BECo Ltr. #85-190 "N"
Mr. Richard W. Starostecki, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I - 631 Park Avenuo King of Prussia, PA 19406 r
License No. DPR-35 Docket No. 50-293
Subject:
Response to Violations as Contained in NRC Inspection Report #85-21
Dear Mr. Starostocki:
This letter is in response to the violations identified during a special NRC Inspection conducted by Dr. M. McBride of your office on July 16-30, 1985 at Pilgrim Nuclear Power Station and communicated to Doston Edison Company in enclosures to the subject letter.
Our response is therefore enclosed as an attachment to this letter.
Should you have any further questions concerning these issues, please do not hesitate to contact me.
Respectfully submitted,
/
WM William D llarrington Atitachments l'
l 8511010021 851018 gDR ADOCK 05000293 l
PDR l
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16 of aa
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ATTACHNENT Violation "A" Technical Specification Limiting Condition for Operations 3.7 C.1 requires, in part, that whenever the reactor is critical, secondary containment integrity be maintained. Section 1.N of the Technical Specifications definos secondary containment integrity and requiros as one of its conditions that all automatic ventilation system isolation dampers must be operable or secured in the closed
- position, Contrary to the above, for approximately 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> betwoon 3:00 p.m.,
July 15, 1985 and 10:00 a.m.,
July 16, 1985, secondary containment inte;rity was not maintained while the reactor was critical in that automatic vencilation system isolation dampor A0-N-90 in the exhaust ventilation duct from the refueling floor was identified as open and inoperable at 3:00 p.m. on July 15, 1985, and the damper was not secured in the closed position until 10:00 a.m. on July 16, 1985.
Rosponso Cause of not performing the Tech. Spec, componsatory actiorss for approximately 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> was due to utility Maintenanco personnel error.
The error occurrod when personnel failed to report the event according to Proceduro 1.3.24 (Failure and Malfunction Roport) which would have alertad the Watch Engincor that appropriate Tech. Spec. action was nonded. The cause of the damper not fully closing was, as reported on the Maintenanco Roquest, due to slippage in the drive gears.
Immediato correctivo action to correct the condition was to close the redundant dampor and to align the drivo gears on Dampor AON-90.
Correctivo action to proclude recurrence was to counsel involved personnel in the requiromonts of Procedure 1.3.24 (Failure and Malfunction Roport),
especially the nood to issuo a F&MR as well as the Maintenanco Roquest in future failures.
This nood will be ro-omphasized in additional training which is explained in further detail in our response to Violation "C" of this letter.
Full compliance was achieved on July 11, 1985, the dato by which Maintenanco management had boon instructed on the importanco of promptly initiating r&MR's.
Violation "B" Technical Specification (T.S.) Survoillance Requirement 4.5.r.1 specifies that when one diosol gonorator is inoperablo, the romaining diosol gonorator, and all low pressure core cooling and containment cooling systems shall be tested immediately and daily thoroaf ter.
Contrary to the above, on July 23, 1905, Diosol Gonorator A was found to be inoperable because the water and sedimont content in the diosol fuel tank T-126A was in excess of the limits in Table 1 of ASTM D975-77, required core cooling subsystems, and containmont cooling subsystems woro not tostod until July 26, 1905.
Pago 1 of 3
Response
Cause of the event was an inadequato procedure and the fact that Chemistry personnel were not fully aware of the requirements of the F&MR procedure.
Procedure 7.1.36 (" Diesel Generators' Fuel Oil Sampling and Quality Analysos")
was inadequate in that it (1) did not state that the Watch Engineer must be notified if the fuel oil test results are not within specifications and (2) did not clearly requiro Chumistry personnel to file a Failure and Malfunction report if those specifications are not mot.
Immediate corrective action included counseling of the Chemistry personnel involved regarding the need to issuo F&MR's and temporarily increasing the storago tank sampling frequency from monthly to wookly (for 4 wooks).
Weekly test results since pumping water from the "A"
storage tank on 7/26/05 have been satisfactory.
Day tank test results found no wator/sodiment.
Visual inspection of the area of the tank did not identify any obvious point of entry for the wator/sodiment.
1 Corrective action to preclude recurrence is that, on 9/18/PS, procedure 7.1.36 was revised to require (1) immediato Watch Engincor notification and (2) filing of a F&NR by Chemistry personnel if the test results for the omorgoney diesel fuel oil do not mout Technical Specification acceptance critoria.
Full compliance was achieved on 9/18/85, the date upon which the subject procedural controls were put in place.
J V_lolation "C" Technical Specification 6.0.A requires, in part, that written proceduros be established, implomonted and maintaired that moot or exceed the requirements and recommendations of Section 5.1 and 5.3 of ANSI N18.7-1972 and Appendix "A" i
of NRC Regulatory Guido 1.33.
I Station proceduro 1.3.24, Failure and Malfunction Reports, Revision 11, dated l
February 6, 1985, written as required by T.S. 6.8.A states that (1) a Failure and Malfunction Report (F&MR) shall bo initiated whenover malfunctions 3
identified during surveillance testing of safety related components could l
prevent the components from fulfilling their intended functions and (2) the objective of the F&NR is to ensuro an adoquato initial review of evonts with potential safety significance.
Contrary to the above, 1.
At 3:00 p.m. on July 15, 1985, secondary containment ventilation damper AO-N-90 was identified as malfunctioning (would not fully closo) during a routino dampor surveillance inspection, and an F&MR was not initiated.
2.
On July 23, 1985, water and sodimont in excess of limits was discoverod in the T-126A diesel generator fuel oil storage tank during a monthly surveillanco test, and a F&MR was not initiated.
1 i
Pago 2 of 3 i
Responso cause of this violation is an apparent lack of understanding in the failure and malfunction process of problem identification and reporting as exhibited by certain sectors of our staff at Pilgrim Station, i
Thorofore, as correctivo action to correct the condition and to procludo recurrence, a Station-wide re-instruction on the importance of the Failure and Malfunction Report is currently baing implomonted.
The program will cover the following subjects:
Why a F&MR is required to be initiated Who is responsible for writing a F&MR r
How the form is filled out When a F&MR is required It'is anticipated that the appropriato groups will have received this training by 1/2/06.
We will havo reached full compliance on 1/2/06, the date on which the subject training is expocted to be completed.
NRC Concern The NRC concern that, Licensed Operators rely solely upon the F&MR for notification of abnormal conditions, is not shared by this Company.
Boston Edison believes an adequato level of aggressivonoss is exhibited by Licensed Operators in pursuing resolution of potential problems. However, as we have stated earlier in this responso, we ballove that a major contributor to this type of problem is a lack of understanding of the reportability process as exhibited by personnel other than in the Operations Group.
The training program outlinod in our response to Violation "C" will increaso plant workers sensitivity and reaction to situations involving potential problems.
Another important tool which operators frequently use to identify abnormal conditions is communication with personnel of other disciplinos. The training mentioned earlier in this responso will improve the frequoney and the quality of that inter-disciplinary communication.
Notwithstanding the above, the lessons learned from the above incidents and the subsequent dialoguo and training disponsed to various groups, including the licensed operators, has and will result in an increased level of employoo sensitivity to abnormal conditions and the reportability concerns which follow.
Pago 3 of 3
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