ML20202D244

Notice of Violation from Insp on 971111-980106.Violations Noted:Util Did Not Properly Evaluate Cause & Implement Corrective Actions to Preclude Repetition of Temporary Temp Detectors Deficiencies from Reactor Vessel Flange

ML20202D244
Person / Time
Site:	Pilgrim
Issue date:	02/06/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20202D240	List: IR 05000293/1997013 ML20202D237 ML20202D244
References
50-293-97-13, NUDOCS 9802170025
Download: ML20202D244 (2)

Text

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Enclosure 1 Notice of Violation Boston Edison Company Docket No. 50-293 Pilgrim Station License No. DPR 35 During an NRC inspection conducted on November 11,199.', through January 6,1998, violations of NRC requirements were identified, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions, NUREG 1600,the violations are listed below:

A. 10 CFR 50 Appendix E, Criterion XVI, Corrective Action, states, in part, that measures shall be established to assure that conditions adverse to quality, such as deficiencies, deviations, and non-conformances are promptly identified and corrected. The measures shall assure that the cause of the condition is determined and corrective actions taken to preclude repetition.

Procedure 1.3.121, " Problem Report Progrem," revision 3, section 6.6.3 and 6.6.4 require that corrective actions taken and/or required to correct the deficiency tJ.all be identified and corrective actions Jeveleped are adequate to prevent recurrence.

Step 6.1(1) requires that " Hardware and non-hardware (human performance, administrative controls, procedural deficiencies) related problems shall be documented on a PR. This includes failures, malfunctions, deficiencies, human errors, abnormal occurances, defective or degraded material or equipment, and non-conformances."

Contrary to the above, BECo did not properly evaluat? the ca.use and implement corrective actions to preclude repetition of the temporary temperature detectors deficiencies from the reactor vessel flange. The temperature elements moved / separated from the reactor vessel flange on three separate occasions (November 27, December 2, and December 7,1997). Tl'is degraded condition resulted in an extra plant cooldown and heatup, in addition, BECo failed to document on a problem report that two of three temporary temperature detectors, installed per temporary modification 97-29, had become disengaged from the reactor vessel flange on November 27,1997.

This is a severity Level iV Violation (Supplement 1)

8. Pilgrim Technical Specification (TS) 6.8A, Procedures, requires that procedures be implemented for activities covered under Appendix "A" of NRC Regulatory Guide 1.33. Section 9, Procedures For Performing Maintenance, of Appendix "A" requires that maintenance be properly preplanned, and be performed in accordance with written procedures or instructior.s that are appropriate to the circumstances.

Additionally, BECo procedure 1.5.20, Work Control Process, step 7.5, Task Ready Review, specifies that planners and I&C supervisors shall ensure that parts are in reserve / withdrawn for the work prior to designating a package as task ready. Step 7.5 also specifies that the work supervisor or his designee will perform a hands-on parts verification for each job.

Contrary to the above on December 20,1997, a work control planner and I&C supervisor classified a work package to replace an ATWS system electrical relay as task ready when all parts were not available. Additionally, a hands-on parts 9802170025 990206 PDR ADOCK 05000293 G PDR

2 verification was not perfuned prior to the start of work. As a result, a relay of the incorrect voltage rating was installed which overheated and resulted in an unplanned ATWS system LCO maintenance cutage.

This is a Severity Level IV violation (Supplement 1).

Pursuant to the provisions of 10 CFR 2.201, Boston Edison Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident Inspector at Pilgrim, within 30 days of the date of the letter transmitting this Notice of Violation (Violation). This reply should be clearly marked as " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that wi!! to taken to avuid further violations, and (4) the date when full compliance will be achieved, your response may reference or include previous docketed correspondence,if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or Demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time, if you contast this enforcement action, you ehould also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Because your response a a! be placed in the NRC Public Docket Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction, if personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracket-ed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you muit specifically identify the portions of your respm that you seek to have withheld and provide in detail the bases for your claim of withhoa.m ' g., explain why the disclosure of information will create an unwarranted invasion of puwasi privacy or provide the information required by 10 CFR 2.790(b) to support a request for with-holding confidential commercial or financial information), if safeguards information is necessary to provide an acceptable response, please provide tha level of protection described in 10 CFR 73.21.

Dated at King of Prussia, Pennsylvania this 6th day of February,1998 4