ML20215K770
| ML20215K770 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/29/1987 |
| From: | Bird R BOSTON EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 87-066, 87-66, NUDOCS 8705110345 | |
| Download: ML20215K770 (5) | |
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BOSTONEDtSON Executive Offices 800 Boylston Street Boston. Massachusetts 02199 Ralph G. Bird Senior Vice President - Nuclear April 29,1987 BECo Ltr. #87-066 U.S. Nuclear Regulatory Commission Attn: NRC Document Control Desk Washington, DC 20555 License No. OPR-35 Docket No. 50-293
Subject:
NRC Inspection Report 50-293/87-03
References:
1.)
NRC Inspection Report 50-293/87-11 2.)
BECo Letter No.87-059
Dear Sir:
Attached is Boston Edison Company's response to the Notice of Violation issued with the subject inspection report.
Please do not hesitate to contact me directly if you have any questions.
R.G. Bird EH/la Attachment cc: Regional Administrator U.S. Nuclear. Regulatory Commission 631 Park Avenue - Region I
-King of Prussia, PA 19406 Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 Senior Resident Inspector 0"kOoh 5
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- ATTACHMENT 1 Boston Edison Company.
Docket No. 50-293~
Pilgrim Nuclear, Power Station License No. DPR-35
- Notice of' Violation A
~ Technical Specification 6.13, "High: Radiation Area"; requires in' part that
'. areas with radiation levels greater than 1,000 mres/hr be locked and the keys be maintained under the administrative control of the shift foreman or unit health physicist.
Contrary 5o_theabove,betweenDecember 19. 1986 and-January 3, 1987, a~ master "R" key which controls all locked areas in the plant.with radiation levels between.1:,000 mrem /hr and 10,000 mrem /hr was not under the administrative control of the shift foreman or unit health physicist.
Specifically, the key was removed from the control room in an unauthorized manner between December 19, 1986 and December 22. 1986 and~the licensee did not take compensatory action to restore administrative control of high radiation areas until January 3, 1987.
This is a Severity Level IV violation (Supplement IV).
Response
- 1. : Corrective Steps Taken and Results Achieved On December 22, 1986 a periodic audit, by the Nuclear Operations Supervisor, identified one master key, which allows access to. areas of the plant with radiation levels between 1,000 mrem /hr and 10,000 mrem /hr, as missing.
The Radiological Section was immediately notified and a Radiological Occurrence Report (ROR) was prepared in accordance with NOD Procedure 6.1-209.
The immediate compensatory actions (verification that 4
all~ doors were secured every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) as specified in the associated ROR, however, were not implemented. This failure to implement compensatory action was caused by insufficient communication of the task to the person responsible to perform the action. The individual responsible for the implementation of the immediate corrective action as specified in the ROR has been removed from that responsibility.
This violation was-reviewed in light of previous problems with key control 1
l for_ radiation areas, past corrective actions, and a recent violation identified in NRC Inspection Report 50-293/87-11 (ref. 1).
Our response to this recent violation, BECo Letter No.87-059 (ref. 2), specifies-corrective' actions which will centralize administrative control and responsibility for high and high-high radiation area access controllwithin j.
the Radiological Section.
A review of.the Operations Section "R" key control from February 13, 1987, the date of identification of the violation in reference 1, through April l'
15, 1987 shows continued compilance with the current "R" key control procedure with the exception of two isolated instances by one individual.
On April 15, 1987 the routine issuance of "R" keys by the Operations Section was stopped in preparation for the turnover of control of the keys to the Radiological Section. Several keys will be retained by the Watch
' Engineer for. emergency use only.
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ATTACHMENT 1 (Cont.)
2.
Corrective Steps Taken to Prevent Future Violations The corrective steps stated in reference 2 provide centralized responsibility for control of high and high-high radiation area access.
Also as stated in that letter, plant personnel have been reinformed of their responsibility to aggressively enforce procedure requirements.
3.
Date When Full Compliance Was Achieved The immediate compensatory action to restore administrative control of high. radiation areas was increased surveillance checks of those areas.
This action was initiated on January 3, 1987 and continued until new locks were installed. The procedural changes necessary to provide centralized control of high and high-high radiation area access as stated in reference 2, will be implemented prior to May 1, 1987.
Notice of Violation B 10CFR50, Appendix B, Criterion XVI Corrective Action, requires that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, and deviations are promptly identified and corrected.
Station Procedure No. 1.3.24, Failure and Malfunction (F&M) Reports, Revision 14, requires that F&M Reports "e initiated whenever failures or malfunctions are identified during the sur.
11ance testing of safety-related components that could prevent the systems irom fulfilling their individual functions in their intended manner.
It further requires that an F&M Report be initiated for a malfunction of a-system installed to mitigate an accident, which may not be specifically addressed by Technical Specification.
Contrary to the above, no F&M Report had been initiated as of February 17, 1987 when, on February 5, 1987, the auto transfer of safety-related 480 VAC load center 86 failed to function properly during a routine surveillance test.
This is a Severity Level IV violation (Supplement I).
Response
1.
Corrective Steps Taken and Results Achieved The supervisor in charge of the work failed to issue a F&M Report. This individual did, however, initiate a Maintenance Request (MR) to repair the malfunctioning load center. The individual has been reinstructed in specific criteria for issuance of a F&M Report and now understands his responsibilities in this area.
This violation was reviewed in light of previous corrective actions taken for a similar violation in 1985. Station-wide instruction on the F&M Report purpose and process was implemented. Cyclic retraining in the F&M Report process is also routinely performed.
This training is considered j
adequate.
This instance is viewed as personnel error and an isolated instance in the Maintenance Section. As corrective action, the individual involved was reinstructed in the requirements for F&M Report initiation.
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i ATTACHMENT I (Cont.)
2.
Corrective Steps Taken to Avoid Further Violations A memo has been issued to all Maintenance Section personnel as required reading which reinforces the necessity of following station procedures, and specifically the F&M Report procedure.
As supplementary corrective action, the Maintenance Request procedure has been revised to add the requirement to review the requested maintenance action and ensure a F&M Report is initiated as required by the F&M Report procedure.
3.
Date When Full Compliance Has Achieved A F&M Report for the failure of load center B6 was initiated on February 17, 1987.
Notice of Violation C Technical Specification 3.12.B states that the fire suppression water system shall be operable with two fire system pumps, separate water supplies and an operable flow path.
With less than the above required equipment restore the inoperable equipment within seven days or submit a report to the Commission within thirty days outlining the plans and procedures to be used to provide for loss of redundancy in this system.
Contrary to the above, between October 1986 and January 1987 portions of the required fire suppression water system equipment were inoperable and no report was submitted to the Commission.
In addition, no plans or procedures to provide for loss of redundancy in the system had been implemented.
This is a Severity Level IV violation (Supplement 1).
Response
1.
Corrective Steps Taken and Results Achieved An evaluation of the circumstances surrounding the recent fire protection equipment failures, extended maintenance, and valving errors has been performed.
This evaluation identified the need for improvement by the Operations staff in the areas of knowledge of fire protection system Technical Specifications (TS), cognizance of fire protection equipment operational status, and the need to pre-plan for fire protection equipment unavailability.
To ensure that TS Limiting Conditions for Operation (LCO's) are included in maintenance planning and considered when equipment is removed from service for maintenance, Procedure 1.5.3 " Maintenance Requests" has been revised to explicitly require a review of the planned maintenance for applicable TS LCO's.
To enhance Operations staff cognizance of fire protection equipment operational status, a status board, maintained by the Fire Protection Group, has been placed in the Control Room.
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ATTACHMENT 1 (Cont.)
2.
Corrective Steps Taken to Prevent Future Violations To improve the Operations staff level of knowledge of fire protection system Technical Specifications, a memo on the subject will be prepared and issued as required reading.
To further ensure that compensatory action is taken in response to fire protection equipment unavailability, the existing procedures will be revised. This revision will indicate options available to restore fire protection system redundancy.
3.
Date When Full Compliance Was Achieved The Special Report required by TS 3.12.8 was issued on February 23, 1987 as BECo Letter No. 87-32.
The above referenced required reading is expected to be completed by May 1, 1987.
The procedure changes for fire protection system contingencies will be implemented by June 1, 1987.
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