ML20203Q172
| ML20203Q172 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/02/1986 |
| From: | Harrington W BOSTON EDISON CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 86-054, 86-54, NUDOCS 8605090082 | |
| Download: ML20203Q172 (4) | |
Text
BOSTON EDiBON COMPANY B00 GovLaTON STREET BOSTON. MassAcNusETTs 02199 WILLIAM O. MARRINGTON senese vees meseseasse axnum May 2, 1986 Deco Ltr. #86 054 Richard W. Starostecki, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission 631 Park Avenue - Region 1
. King of Prussia, PA 19406 Docket No. 50-293 License No. OPR-35
Subject:
Response to Notice of Violation and Other Items as Contained in NRC Inspection Report #86-06
Dear Mr. Starostocki,
This letter is in response to the Notice of Violation and other items contained in NRC Inspection Report #86-06, conducted ' by Mr. Wenzinger and other members of your staff on February 18, 1986 to March 7, 1986, at Pilgrim Nuclear Power Station.
The response to the the notice of violation is enclosed as Attachment "A" to this letter and the response to the " Licensee Responses Items" is enclosed as Attachment "B".
If you should have further questions regarding this matter, please do not hesitate to contact me.
Sincerely.
O'Mi'd
^
W. D. Harrington Attachment 8605090002 860502 1
G O\\
ATTACHMENT A Violation Technical Specification 4.4. A.2.c requires that replacement squib charges for the standby liquid control system (SLCS) be selected from a batch that has been tested during a manual initiation of the SLCS.
Contrary to the above on April 10, 1984, replacement squib charges were installed in the SLCS from a batch that had not been tested during a manual initiation of the SLCS, BECo Response As stated in our report to the NRC (via LER 86-004-00 "SLCS declared Inoperable when SQUIB Valves not tested Insitu"), cause of this event was personnel error. The error was failure of utility personnel to follow approved procedure (8.4.6) when performing previous SLCS operability tests. Contributing to the personnel error was the fact that (1) testing of replacement charges with a remote power source had been perceived as an acceptable practice and (2) the procedure checklist, which personnel fill out during the test, does not specify that the replacement squibs be tested with the installed firing circuitry (e.g. from the control room).
Corrective action to correct the condition was that the appropriate supervisory personnel were made fully aware that the replacement batch squib valves are to be tested utilizing the installed firing circuitry.
This was done through an instructional memo issued on April 16, 1986.
Corrective action to preclude recurrence is that a procedure revision to further clarify and define the testing process will be incorporated by 6/30/86.
Full compliance was achieved on the date upon which the appropriate supervisory personnel were retrained to the testing requirement.
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ATTACHMENT B Licensee Response Item #86-06-01 Evaluate the' need to include instrument root valve positions in station procedures and drawings.
BECo Response Boston Edison agrees with the need to identify and control certain isolation and root valves and is currently developing a plan which will:
identify what instrument root and isolation valves need to be controlled
' establish how these valves will be controlled (i.e., revise drawings and procedures to allow for control).
This action plan will be submitted to Region 1 in an update letter within (60) days.
Licensee Response Item #86-06-03
- Complete labeling of station valves and components.
BECo Response Labeling of station valves and components has previously been identified as an issue by INPO and is currently being addressed by Boston Edison.
Efforts are ongoing to inspect and identify non-labeled valves and components. The inspection is proceeding by plant area and level and is approximately 20% complete.
Areas of need are being recorded and will be corrected once the total plant inspection is completed.
Our final completion dates of the above actions will be submitted to Region 1 in an update letter within (60) days.
Licensee Response Item #86-06-04 Establish a policy on allowing licensed personnel outside the plant protected area boundary while on shif t.
BECo Response Boston Edison policy is that Technical Specification required staffing levels inside the plant protected boundary will be maintained, dependent on plant operating status, This policy will be clarified and incorporated into procedure 1.3.34 (" Conduct of Operations") within (60) days from the date of this letter.
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Lic+nsm R3spons* It m #86-06-06 Investigate the cause and required corrective actions for the residual RCIC' flow indication occasionally noted af ter RCIC surveillance tests by June 1, 1986.
I BECo Response The RCIC residual flow indication issue is currently under evaluation by Boston Edison Company. Once a root cause analysis is completed, an action plan will be developed. The results of the root cause analysis and our corrective action plans (including a final completion date) will be
. submitted in an update letter to Region 1 within (60) days.
Licensee Response Item #86-06-09 Upgrade.the ALARA program, including implementat!on of ALARA procedures, earlier incorporation of ALARA planning into work planning process, and completion of an evaluation of ALARA for "A" priority RWPs.
~BECo Response The ALARA program at Pilgrim Nuclear Power Station is currently undergoing a complete upgrade under the cognizance of. the Sr. ALARA Engineer. A total of five (5) engineers (three permanent, two temporary) are assisting with the restoration of the ALARA program.
Pre-planning has been the number one concern of the ALARA group, and the pre-job review procedure is planned to be completed by May 31, 1986.
This review concerns all RWP's (with the exception of "A" priority RWP's) for work at PNPS.
A primary
-feature of the procedure is to ensure that more time is allotted for ALARA/RP review of the work so ' that more engineering controls and shielding considerations can be addressed.
A review of the RWP Procedure 6.1-022 is currently being performed by the ALARA group to address "A" priority RWP's.
This review should be completed by May 31, 1986.
Licensee Responso Item #86-06-13 Implement a baseline preventative maintenance program for 480 VAC molded case circuit breakers in motor control centers during the next refueling outage.
BECo Response The existing Preventive Maintenance Program for molded case circuit breakers is undergoing a technical review for adequacy. The Nuclear Engineering Department has been tasked with determining acceptance criteria for each breaker based on the plant's coordination studies. Once NED's evaluation is completed (expected by 8/31/86), the preventive maintenance procedure will be revised to incorporate this criteria and the technical review results.
An expanded Preventive Maintenance Program will then have been established for once/ cycle testing of an appropriate percentage of MCC molded case breakers.
The current plans are to have tested the safety-related breakers by the end of RFO #7.
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