ML20148K461

Responds to Violations Noted in Insp Rept 50-293/87-50. Corrective Actions:After Relays in Panel Became Deenergized, Further Work Panel Suspended & Control Room Notified & Addl Work Controls Established

ML20148K461
Person / Time
Site:	Pilgrim
Issue date:	03/24/1988
From:	Bird R BOSTON EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
88-058, 88-58, NUDOCS 8803310165
Download: ML20148K461 (7)

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hi sosnweasou Pilgrim Nuclear Power Station Rocky Hnl Road Plymouth, Massachusetts 02360 h 4, 88 se o Vce Pre ident-Nuclear U.S. Nuclear Regulatory Commission Attn: Document Control Desk Hashington, DC 20555 Docket No. 50-293 License No. OPR-35

Subject:

NRC Inspection Report 50-293/87-50

Dear Sir:

Attached are Boston Edison Company's responses to the Notices of Violation contained in the subject inspection eport.

Please do not hesitate to contact me directly if you have any questions.

iY BPL/bl Attachment I: Response to Violation A Attachment II: Response to Violation B Attachment III: Response to Violation C CC:

Mr. Hilliam Russell Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Rd.

King of Prussia, PA 19406 Sr. Resident Inspector - Pilgrim Station Ok 8803310165 880324 PDR ADOCK 05000293 {

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ATTACHMENT I Resoonse to Violation "A" (87-50-07)

Boston Edison Company Docket No. 50-293 I Pilgrim Nuclear Power Station License N0. DPR-35 l 1

Notice of Violation "A" Technical Specification 6.8.A requires that written procedures be established and implemented that meet the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1972.

ANSI N18.7-1972 Section 5.1 states that maintenance which can affect the performance of safety-related equipment shall be properly preplanned and performed in accordance with written procedures. Section 5.3 requires that the procedure shall be sufficiently detailed for c qualified individual to perform the required function without direct supervision, and that special attention shall be given to restoration of norma 1 conditions.

Contrary to the above on November 24, 1987, replacement of safety-related relay coil 16A-K55 in the primary containment isolation system was initiated without proper preplanning and without a sufficiently detailed written procedure. In addition measures were not established to ensure restoration of normal conditionc. No step-by-step procedure for isolation and removal of the relay coil, and for verification and independent verification of restoration was used. As a result, replacement of the relay coil caused several unanticipated engineered safety feature actuations.

Response to Notice of Violation "A" CM!1ft:

The root cause of this event was inadequate administrative controls for replacement of the relay coil. No specific precautions or guidance on the arrangement of neutral leads (neutral leads of the relay coils are connected in series) was provided by the Maintenance Request work package.

An oversight by the contractor supervisor responsible for the relay replacement alto contributed to the event. Although the appropriate drawings were reviewed, i:he supervisor did not recognize the impact of removing the neutral lead from the neutral string.

Additionally, the Maintenance Request was assigned a 'UE' (unplanned emergency) priority. The sense of urgency communicated by the assigned priority may have contributed to the event.

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Attachment I (cont.)

i Corrective Steos Taken and Results Achieved:

After the relays in the panel became de-energized, further work in the panel was suspended and the Control Room was notified.

Concurrently, annunciations in the Control Room prom >ted investigations for cause. The continuity of the neutn 1 circuit was re-established using a spare contact on relay 16A-K55. The isolation logic was reset allowing reestablishment of shutdown cooling.

Prior to resuming work in the panel, additional work controls were estabiished using the Maintenance Summary and Control (MSC) form.

The HSC specified additional reviews, installation of jumpers in the neutral string, tagging and verification of jumpers.

The contractor supervisor and the utility supervisor responsible for the work were cautioned on.the level of review necessary for work on logic relays.

A night order was issued on November 25, 1987 requiring notification to the Maintenance Section Manager of priority 'A' or 'UE' Haintenance Request.

On December 12, 1987 a night order was issued describing actions to be taken for work activities having the potential for causing inadvertent actuation or isolation of a safety system.

Licensee Event Report 50-293/87-016-00 "Unplanned Actuations of Primary Containment, Secondary Containment and Standby Gas Treatment Systems" was submitted describing this event on December 23, 1987.

Corrective Steos Which Hill be Taken to Avoid Further Violations:

The Haintenance Summary and Control process will be restuctured to include the capability to sequence specific sections of a maintenance activity.

Engineering Service Request #88-156 was initiated to evaluate the feasibility of achieving design improvement to neutral circuits.

In response to the recurrence of unplanned ESF actuations an interdisciplinary task force has been chartered to evaluate recent ESF actuations, determine the underlying causes, and recommend corrective actions to avoid future events.

Date of Full Como11ance:

Full compliance was achieved on November 25, 1987 when additional work controls were established using the MSC form to allow replacement of the relay coil without further incident. Corrective actions to prevent unplanned ESF actuations continue.

Safety Consecuences:

This event posed no threat to the public health and safety or to plant operation.

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• l AIJACMiENT II Resoonse to Violation "B" (87-50-04)

Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 Notice of Violation "B" l Technical Specification 6.11 requires that procedures for personnel radiation protection be prepared and adhered to for all operations involving personnel radiation exposure. Station Radiation Protection Procedure 6.1-022, "Issue, Use and Termination of Radiation Work Permits (RHP)," states in part that entry into areas having whole body radiation levels equal to or greater than 100 mrem per hour (high radiation area) requires a RHP.

Contrary to the above, on November 14, 1987, a radioactive waste worker was found inside a posted High Radiation area adjacent to the chemical waste tanks, without the required RHP, required anti-contamination clothing and required health physics coverage.

Resoonse to Notice of Violation "B" CM10:

The failure to use the Radiation Work Permit (RHP) for picking up contaminated trash from high radiation areas resulted from ineffective communications between the involved Radioactive Haste Handler and the Health Physics Technician. The Radioactive Haste Handler misunderstood the health physics instructions in part because previous instructions were inconsistent. At times Health Physics personnel had permitted access beyond the high radiation area posting, using the RHP for areas less than 100mr/hr when (1) visual contact could be maintained, and (2) the actual whole body dose rate was verified to be less than 100mr/hr.

Corrective Steos Taken Including Steos Taken to Avoid Further Violations:

A review of RHP entries made by the Radioactive Haste Handlers for the period of January 1, 1987 to November 15, 1987 was performed. One Hundred Twenty Five (125) high radiation area entries were documented by the RHPs indicating proper RHP usage. Interviews with the Radioactive Haste Handlers determined that the problem involving failure to sign in on the correct RHP occurred on a few occasions, howevar, it was not a wide spread problem.

The involved Radioactive Haste Handler was suspended without pay. Upon his return to work, the individual was reapprised of the seriousness of the RHP infraction, retrained on the requirements of the waste handling RHPs and proper handling of contaminated materials.

On November 16, 1987, a meeting was conducted with the Radioactive Haste Handlers. The topics discussed included:

A. Adherence to procedures.

B. The importance of fully understanding the RHP briefing.

C. Maintaining good Health Physics work practices.

D. The relationship of the topics listed to the Station's Operating License.

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Attachment II (cont.)

It was emphasized that violations of procedure, RHP briefing, or good health physics practices would not be tolerated.

The Radiation Protection Technicians were instructed that entry to a posted high radiation area required a high radiation area RHP, even if the actual whole body dose rate was verified to be less than 100 mr/hr.

Date of Full Comoliance:

Full compliance was achieved on November 24, 1987 when the waste handler exited the high radiation area. The corrective actions taken to avoid further violations of RHP requirements by Radioactive Haste Handlers were completed on November 16, 1987.

Safety Conseauences:

No adverse safety consequences resulted from the event. The Radioactive Haste Handler's net dose was documented on the RHP as zero. No spread of contamination to clean areas or personnel was identified.

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ATTACHHENT III' Resoonse to Violation "C" (87-50-05)

Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 Notice of Violation "C" Technical Specification 6.6 states that for each ceportable event the Commission shall be notified pursuant to the requirements of 10 CFR 50.72.

10 CFR 50.72 (b)(2) states that the licensee shall notify the NRC within four hours of any event or condition that results in manual or automatic actuation of any Engineered Safety Feature.

Contrary to the above on November 23 and again on November 24, 1987, automatic agtuations of the primary containment isolation system, an engineered safety feature, resulting in isolation of the reactor water cleanup system occurred and were not reported to the NRC within four hours.

Resoonse to Notice of Violation "C" CAUSE:

Failure to report in accordance with the requirements of 10CFR 50.72 resulted from a lack of complete understanding of these requirements. In particular, the involved personnel did not '"11y understand to what extent actuations of only portions of a safety system are reportable.

Corrective Steos T. ken and Results Achieved:

The NRC was notified of the events via the Emergency Notification System on November 24, 1987.

A memorandum OPS87-948 was issued on November 25, 1987 to the Nuclear Hatch Engineers, Nuclear Operations Supervisors, and Shift Technical Advisors. This memo provided clarification of the 10CFR 50.72 requirements for reporting Engineered Safety Feature (ESF) actuations and included select pages from NUREG 1022, supplement I.

A copy of NUREG 1022 and NUREG 1022 Supplement I have been made available in the Control Room for reference.

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Attachment III (cont.)

Corrective Steos to be Taken to Avoid Further Violations:

- A list of Pilgrim specific ESFs is being prepared and will be proceduralized.

- The 10CFR 50.72 reporting requirements will be discussed during the next annual requalification program for Licensed Operators.

Date of Full Comoliance:

Full compliance with the requirements of 10CFR50.72 was achieved on November 24, 1987 when the NRC was notified via the Emergency Notification System.

Safety Conseauences:

No adverse safety impact resulted from the violation of 10CFR 50.72 requirements.

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