ML20207P865
| ML20207P865 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 01/09/1987 |
| From: | Lydon J BOSTON EDISON CO. |
| To: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 87-004, 87-4, NUDOCS 8701200345 | |
| Download: ML20207P865 (5) | |
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.asa wsw Executive Offices 800 Boylston Street Boston, Massachusetts 02199 James M. Lydon Chief Operating Officer January 9, 1987 BECO Ltr #87-004 Mr. William Kane, Director Division of Reactor Projects USNRC - Region 1 631 Park Avenue King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293
Subject:
Response to NRC Inspection Report No. 50-293/86-38
Dear Mr. Kane:
This letter is submitted in response to your letter dated December 9, 1986 which transmitted the subject inspection report. Attachment I addresses the notice of violation regarding a fire protection system drawing discrepancy and provides a description of actions taken to improve management attention to fire system operations, maintenance and training.
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Please do not hesitate to contact me directly should there be any question regarding this respo,nse.
Very truly yours, l
James M. Lydon PJH/la.
Response to Notice of Violation 2.
Response to Concern Identified in Cover Letter l
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ATTACHMENT 1 RESPONSE TO NOTICE OF VIOLATION Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 Violation as Set Forth in NRC Inspection Report No. 86-38, Appendix A Pilgrim Nuclear Power Station Operating License number DRP-35, section 3.f, Fire Protection, requires the licensee to implement the administrative controls specified in section 6 of the NRC's Fire Protection Safety Evaluation (SE), dated December 21, 1978.
Section 6 of the NRC Fire Protection SE states that quality assurance provisions will be established in accordance with the licensee's 10CFR50 Appendix B operational quality assurance program and in accordance with NRC Branch Technical Position (BTP) 9.5-1.
10CFR50 Appendix B, Criterion V, and BTP 9.5-1 Appendix A, Section C.2 require, in part, that activities be controlled by procedures and drawings Contrary to the above, as of November 11, 1986, adequate procedures and drawings had not been established for the station fire water system. At that time, the firewater system piping configuration was not accurately reflected on controlled drawing M218, revision E10, nor in system operating procedure 2.2.25, revision 16.
This resulted in inadvertent isolation of normal fire water supply sources to the site for six days.
Boston Edison Response to Violation Boston Edison Company has reviewed the subject violation and concurs that station drawing M218, revision E10, and procedure 2.2.25 revision 16 were incorrect.
In response to the violation the following corrective actions have been completed:
Provided details of the event and initial corrective action via LER 86-025 which was submitted on November 25, 1986.
Revised and issued Piping and Instrumentation Diagram M218 Sht. 2, Fire Protection System, on November 19, 1986 to resolve the drawing discrepancy described in the violation.
Corrected the bakelite labeling tags for valves T-117 and T-ll8 on November 14, 1986 to reflect the actual system configuration.
i Revised and issued procedure 2.2.25, Fire Water Supply System on December 9, 1986 to resolve the procedural discrepancy noted in the violation.
Revised and issued procedure 2.1.11, System Lineup File, on November 25.-1986 to require independent verification of fire water supply system lineup l
changes.
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v ATTACHMENT 1 (Cont'd)
Additional planned corrective action includes:
Verification that other systems with similar characteristics (diesel generator fuel oli supply and salt service water) are properly reflected on the associated piping and instrumentation diagrams. This verification is in progress and to date no other discrepancies have been identified. Completion of this tast-is expected by 2/9/87.
He believe that the above stated corrective actions will effectively preclude recurrence of a similar violation.
The date of full compliance was November 19, 1986 for the drawing discrepancy and December 9, 1986 for the procedural discrepancy.
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ATTACHMENT 2 RESPONSE TO CONCERN IDENTIFIED IN COVER LETTER TRANSMITTING INSPECTION REPORT NO. 86-38 Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 NRC Concern
"..... provide a description of those actions planned or taken to improve the management attention and the priority afforded to fire system operations and maintenance and to upgrade training for your onsite fire brigade members."
Boston Edison Response We concur that increased management attention is required to oversee fire protection system maintenance, operations, and training. As such a new management position of Fire Protection Grcup Leader was recently authorized and. filled in-December,.1986 by an experienced individual.
Previously, management oversight of fire protection activities was by a group leader who was also responsible for the areas of security, medical and industrial safety. The Fire Protection Group Leader is responsible to oversee. the fire protection program at Pilgrim Station including interface with the Operations, Maintenance and Training Groups to provide assistance and expertise on establishing priorities in these areas.
With regard to the specific items of concern identified in the inspection report the following action has been taken:
NRC Item - One of the two municipal fire hydrants could not be used as a water source (IFI86-38-03A)
Status - The hydrant repair is complete.
NRC Item - The licensee agreed to review the priorities for fire protection equipment maintenance at the exit meeting (IFI86-38-038).
Status - The backlog of fire protection : system maintenance requests have been reviewed for priority.
Results of that review include the following:
Reduced the outstanding maintenance requests (mechanical) from 142 to 24 since November 18, 1936.
Established a Fire Protection System Status Board which provides a list of key fire systems and current status for the Fire Protection Group Leader.
Supplemented the maintenance work force with contractor personnel to address backlog work items including fire protection.
NRC Item - The on shift fire brigade leader had not operated the fire truck pumping unit in several years and could not operate it during the demonstration (IFI86-38-04)
Status - Fire brigade personnel in the Operations Department have been trained on the use of the backup fire truck pumping unit.
Presently two fire truck quallfled brigade members are scheduled for each shift.
Requalification training of operations brigade members will be formally scheduled for once/ year on the pumping unit.
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.s-ATTACHMENT 2 (cont'd)
Hith regard to the broader issue of recent fire brigade training discrepancies Boston Edison has taken the following action:
Hired two contract personnel to rewrite and improve the fire brigade training program.
Recognized a need for improvement in the fire protection area and, as previously discussed, created and filled a new management position dedicated to the oversight of the fire protection program.
Planntrg to authorize a new full time position of fire brigade training instructor. A contractor is currently filling this position.
The above is representative of the action taken to date.
The details of additional corrective actions with regard to the fire brigade training issue are being developed and will be further discussed in our response to NRC Inspection Report 50-293/86-37 and at our meeting with Senior Regional Management tentatively scheduled for January 20, 1987 at Region I headquarters.
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