ML20137G936
| ML20137G936 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/15/1985 |
| From: | Harrington W BOSTON EDISON CO. |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 85-205, NUDOCS 8512020284 | |
| Download: ML20137G936 (2) | |
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a BOSTON EOlsON COMPANY B00 BOYLsTON STREET BOSTON, M AssACHusETTs 02199 WILLIAM D. H ARRINGTO N tesesse wiss passiesset November 15 1985 6sie DECO Ltr, #85 205 Edward C. Wenzinger, Chief Projects Branch No. 3 Division of Reactor Projects U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 License No. DPR-35 Docket No. 50-29,3_
Subject:
Response to Violation 85-26-05 as Contained 1*i NRC Inspection Report 85-26
Dear Mr. Wenzinger:
This letter is in response to the subject violation contained in NRC Inspection Report 85-26, conducted by Dr. M. McBride of your office on August 20, 1985 to September 23, 1985 at Pilgrim Nuclear Power Station.
The subject violation and Boston Edison's response is enclosed as on attachment to this letter.
If you should have any further questions regarding this matter, please do not hesitate to contact me.
Very truly yours,
{] I (1/b1'Y h J
W. D. Harrington Attachment
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ATTACHMENT VIOLATION 10 CFR 50 Appendix B, Criterion XVI, " Corrective Actions", requires that conditions adverse to quality be promptly identified and corrected.
Proceduro No. 1.3.34,
" Conduct of Operations", requires in part that the Plant Manager authorize overtime involving safety related activities when work timos exceed twenty-four hours in a forty-eight-hour period or seventy-two hours in a seven-day period.
The lack of a program to implement overtime authorization requirements fer licensed reactor oporators who work more than twenty-four hours in a forty-eight-hour petivu was identified during NRC Inspection No. 50-293/85-01 in January, 1985.
In addition, the failure to authorl/o a licensed reactor operator to work more than seventy-two hours in a seven-day period was identified by the licensoo in July, 1985.
Contrary to the above, following NRC inspection No. 50-293/85-01 in January, 1985 and following identification of unauthorized overtime in July 1985, the licensoo did not take corrective action to ensure that overtime for licensed reactor operators was subsequently authorized in accordance with the requirements of Proceduro No. 1.3.34.
Failure to properly authorize licensed reactor operator overtime is a condition adverse to quality.
As a result of the lack of licensoo corrective action, operators worked unauthorized overtime as follows:
a.
From June 15, 1985 to September 14, 1985 there were 29 instances when licensed reactor operators worked more than twenty-four hours in a forty-eight-hour period without authorization from the Plant Manager.
The maximum number of hours worked was 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br />.
b.
From August 18, 1985 to September 7, 1985, there were six instances when licensed reactor operators worked more than sovonty-two hours in a sevon-day period without authorization from the Plant Manager.
The maximum hours worked was 87 hours0.00101 days <br />0.0242 hours <br />1.438492e-4 weeks <br />3.31035e-5 months <br />.
RESPONRE The Watch Engineers have primary responsibility for ensuring that the Plant Manager's approval is secured in casos as mentioned in the subject violation.
After receiving the subject violation, all Watch Engineers were counseled concerning the above examples of unauthorized overtime. They woro reminded of the regulatory concerns and the requiiements involved. We are confident that this corrective action (1) has clovated their attention to this matter, and (2) will onsure adhorance to the requirements of procedure 1.3.34 " Conduct of Operations." An audit of overtime worked was conducted on November 1, 1985 to ensure adherence to the requirements, and full compliance was verified.
Additionally, administrative controls have been improved so that the person responsible for hiring for overtime will have adequato information available to make the correct hiring selections that are in compliance with Procedure 1.3.34.
Root cause of this problem is a shortage of licensed operators.
Boston Edison Company, in order to ameliorato this condition, has authorized ten additional operator positions for Pilgrim Station.
The Company is now actively recruiting for those positions.
Ultimately, increasing the complement of licensed operators will significantly reduce the nood for excess overtime worked by licensed roactor operators.
Full compliance was achieved on November 1, 1985, the date upon which the above audit was conducted to verify that the proper authorizations for overtime were being secured.
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