ML20137F236
| ML20137F236 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/15/1985 |
| From: | Harrington W BOSTON EDISON CO. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 85-152, NUDOCS 8508260176 | |
| Download: ML20137F236 (4) | |
Text
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l BOSTON EDISON COMPANY 800 WOvLsTON STREET l
BOSTON, M AaBACHuSETTis 02199 l
WILLIAM O. HARRINGTON l
August 15, 1985 w...........
i BECo Ltr. #85-152
=. uaa Mr. Thomas T. Martin, Director Division of Reactor-Safety and Safeguards U.S. Nuclear Regulatory Commission
' Region I - 631 Park Avenue King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293
Subject:
Response to Violation and Deviation as
. Contained in Inspection Report 85-13
References:
NRC Ltr to Boston Edison, dtd. July 16, 1985 Dear Mr. Martin This letter is in response to the-Violation and Deviation identified during a routine radiological safety inspection conducted by Mr. R. L. Nimitz of your office on May 20-24, 1985 and communicated to Boston Edison Company in Appendices (A) and (B) of the reference.
Notice of Violation (Appendix A)
Technical Specification 6.8 requires that written procedures and administrative policies be established, implemented and maintained, that meet or exceed the requirements and recommendations of Appendix ' A' of Regulatory Guide 1.33, 1972. This regulatory guide recommends, in part, that procedures for procedure review and approval be prepared. Station approved procedure 1.3.4, " Procedures," requires in Section III.A that approved written procedures be adhered to by all station personnel.
Procedure 1.3.4, Revision 27, specifies, in part, in Section C.3, that the Operations Review Committee (ORC) indicate its approval of a procedure to be included in Category Three Group procedures.
Contrary to the above, as of May 23, 1985, two procedures, FP-OP-OO7-442 and FP-OP-OO8-442, used to provide guidance for cutting of control rod blades and LPRMs, were not presented to ORC for l
approval as Category Three Group procedures. As a result, the ORC did not indicate. its approval of the procedures for use as Category Three i
Group procedures.
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- BOSTON EDISON COMPANY Mr. Thomas T. Martin U.S. Nuclear Regulatory Commission August 15, 1985 Page Two Procedure No. 3.M.1-19, Revision 1, " Spent Fuel Pool Cleaning,"
specifies in Section IV, that the obtaining of a valid Maintenance Request (MR) is a prerequisite for procedure use.
Contrary to the above, as of May 23, 1985, procedure No. 3.M.1-19 was used to provide general guidance for cutting of control rod blades and LPRMs in the spent fuel pool, but ne valid Maintenance Request was in effect.
Response
The cause of the subject violation was an isolated case of an error in judgment on the part of the project manager who (1) incorrectly concluded.
that ORC approval was not required for the two subject procedures, and (2) failed to issue a Maintenance Request for the fuel pool cleanup task.
On May 23, 1985, work associated with the spent fuel pool cleanup was stopped. Prior to restarting work, the following corrective steps were taken:
Chem-Nuclear Procedures FP-OP-008-442 and FP-OP-007-442 were approved by the ORC as Category Three procedures in accordance with PNPS Procedure 1.3.4.
Procedures associated with the spent fuel pool cleanup were reviewed for consistency and adequacy and changed as appropriate.
A Maintenance Request was issued for spent fuel cleanup.
Personnel (BECo and Contractors) directly involved in the fuel pool cleanup reviewed all procedures associated with the project.
Pre-shift briefings with BECo and Contractor personnel were initiated and will continue prior to each shift.
The corrective steps listed above were completed and work was started again on the fuel pool cleanup project on May 28, 1985. The above actions satisfactorily corrected the deficient condition. To preclude future violations, the project manager was counseled to pay closer attention to procedural requirements particula,ly during unusual evolutions such as the fuel pool cleanup.
Full compliance was therefore achieved on May 28, 1985, the date on which corrective actions were completed.
Notice of Deviation (Appendix B)
As a result of the inspection conducted on May 20-24, 1985, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following deviation was identified:
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- BOSTON EDISON COMPANY Mr. Thomas T. Martin U.S. Nuclear Regul'atory Commission August 15 1985 Page Three IE Bulletin 80-10 requires, in part, that:
- 1) a review of facility design and operation be performed to identify systems that are considered as nonradioactive, but could possibly become contaminated through interfaces with contaminated systems; 2) a routine sampling / analysis or monitoring program be established for these systems in order to promptly identify any contaminating events which could lead to unmonitored, uncontrolled, liquid or gaseous releases to the environment, including releases to on-site leaching fields and; 3) the specifics of these reviews be documented and made available to the NRC for review during future on-site inspection efforts.
In particular, special consideration was to be given to the instrument air system and the sanitary waste system. The licensee's response to this Bulletin indicated that the above was implemented.
Contrary to the above, as of May 24, 1985:
- 1) the instrument air system' and sanitary waste system had not been reviewed to determine if these systems could becomo contaminated through interfaces with contaminated systems; 2) no routine sampling / analysis or monitoring program (as appropriate) was established in order to promptly identify any contaminating events which could lead to unmonitored/ uncontrolled releases from these systems; and 3) no specifics relative to the above were documented and made available to the NRC.
Response
After discussion of the subject issues at the 5/24/85 exit meeting, Boston Edison took the following corrective steps:
On 5/24/85, a Special Instruction was issued to the~ Chemistry technicians, providing them specific instructions for analysis and reporting of results of-normally clean systems if found to be radioactive.
On 5/28/85, a memorandum was issued to the Nuclear Watch Engineers referencing the requirements of the Bulletin and providing specific instructions for action when a normally clean system is found to be contaminated.
As corrective action to avoid further deviations, the Engineering Department has been requested to perform an evaluation of facility design and operation, which will include the instrument air and sanitary waste systems. The results of that evaluation will be factored into existing Station procedures and/or Work Instructions, as necessary.
Full compliance was reached on May 28, 1985, the date on which both the Chemistry technicians and the Nuclear Watch Engineers were provided adequate guidance for action when a normally non-radioactive system becomes contaminated.
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' BOSTON EDISON COMPANY
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Mr. Thomas T. Martin U.S. Nuclear Regulatory Commission August 15, 1985 Page Four NRC Concerns To addresa Mr. Nimitz' concerns as stated on Page (1) of the referenced letter, we would like to emphasize that, although a Maintenance Request was not generated in accordance with the prerequisite requirements of Procedure 3.M.1-19 (" Spent Fuel Pool Cleaning"), we maintained adequate communications and ensured adequate radiological protection of the workers involved through numerous Radiation Work Permits and constant HP coverage of fuel pool cleaning tasks. We have conducted a root cause as,alysis and have determined that not filling out a Maintenance Request was an isolated instance of failure to follow procedures on the part of the project manager.
As mentioned earlier in this report, he has since been counseled on the importance of following Station procedures.
Additionally, in order to ensure improved oversight of ongoing radiological work, the Contractor On-Site Assessor has been requested in his reviews to ensure personnel are using appropriately reviewed procedures and are knowledgeable in procedural requirements.
We weuld also like to correct what appears to be a misconception as reflected on Page 8 of the Inspection Report. The two vendor procedures used to control cutting work contained no specific radiological controls, but provided basic work instructions for the Chem-Nuclear personnel involved in the activities.
Neither of the procedures required sign-offs by licensee radiological control technicians.
Rather, the technicians stated in the procedure are those of the vendor, Chem-Nuclear.
If there are any questions concerning these matters, please do not hesitate to contact me.
Respectfully submitted, W. D. Harrington k