ML20204J625

Notice of Violation from Insp on 850201-0304

ML20204J625
Person / Time
Site:	Pilgrim
Issue date:	04/11/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20204J618	List: IR 05000201/2003004 ML20204J613 ML20204J625
References
50-293-85-03, 50-293-85-3, NUDOCS 8504250085
Download: ML20204J625 (4)

See also: IR 05000201/2003004

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APPENDIX A

NOTICE OF VIOLATION

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Boston Edison Company Docket No. 50-293

Pilgrim Nuclear Power Station License No. DPR-35

As a result of the inspection conducted on February 1, 1985 - March 4, 1985, and

in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following

violations were identified:

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A. Technical Specification Table 4.1.1 requires the following:

1. .The average power range monitor (APRM) inoperative scram trips be func-

tionally tested prior to declaring them operable while the reactor is

in the startup mode,

2. The APRM high flux scram trips be functionally tested as soon as prac-

ticable after entering the run mode if the functional test has not been

performed within one week,

3. The APRM downscale scram trips be functionally tested prior to declaring

them operable while the reactor is in the run mode, and

4. The main turbine stop valve closure alarm be functionally tested prior

to declaring the turbine stop valve closure scram instrumentation oper-

able in the run mode with turbine first stage pressure greater than 305

psig.

Contrary to the above:

1. On December 24, 1984 and January 7, 1985, the APRM inoperative scram

trips were not functionally tested prior to declaring them operable

-while the reactor was in the startup mode. The functional test was

eventually performed on January 13, 1985.

2. On December 29, 1984, the APRM high flux scram trips were not tested as

soon as practicable after entering the run mode and the last test was

not within one week. The functional test was eventually performed on

January 4,1985.

3. On December 29, 1984 and January 9, 1985, the APRM downscale scram trips

were not functionally tested prior to declaring them operable while the

reactor was in the run mode. The functional test was eventually per-

, formed on January 13, 1985.

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Appendix A 2

4. On January 12, 1985, the stop valve closure alarm was not functionally

tested prior to declaring the turbine stop valve closure instrumentation

operable while the reactor was in the run mode and turbine first stage

pressure was greater than 305 psig. On February 9,1985, the reactor

mode was changed, and this requirement no longer applied. The test

was performed subsequently.

The above examples constitute a Severity Level IV Violation (Supplement I).

B. Technical Specification 1.0.V and Table 4.2.C require the following:

1. The APRM downscale rod block trips be functionally tested prior to de-

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claring them operable in the run mode,

2. The portion of the rod block logic system which is used in the run mode

be functionally tested prior to declaring the rod block logic system

operable in the run mode, and

3. The upscale and downscale trips for the rod block monitors be function-

ally tested and calibrated prior to declaring the monitors operable in

the run mode with reactor power greater than 30 percent.

Contrary to the above:

1. On December 29, 1984 and January 9,1985, the APRM downscale rod block

trips were not functieaally tested prior to declaring them operable in

the run mode. The test was eventually performed on January 13, 1985.

2. On December 29, 1984 and January 9, 1985, the portion of the rod block

logic system used in the run mode was not functionally tested prior to

declaring the rod block logic system operable in the run mode.

3. On January 10, 1985, the upscale and downscale trips for the rod block

monitors were not functionally tested or calibrated prior to declaring

the monitors operable in the run mode with reactor power greater than

30 percent. On February 9,1985, the requirement no longer applied.

The test and calibration were performed subsequently.

The above examples constitute a Severity Level IV Violation (Supplement I).

C. 10 CFR 50, f.ppendix B, Criterion XVI, Corrective Action, and the Boston Edison

Company Quality Assurance Manual, Sections 16 (Corrective Action) and 18

(Audits), re. quire measures be established to assure that conditions adverse

to quality are promptly identified and corrected.

Nuclear Operations Procedure N0P84A1, Nuclear Operations Surveillance Moni-

toring Report (dated September 30,1984), requires the Q.A. Manager to be re-

sponsible to assure acceptable resolution of surveillance findings and the

Department Managers and Group Leaders to be responsible to implement prompt

corrective action. Section 6.2 of this procedure requires 1) the cognizant

Group Leader to return the signed original Surveillance Finding Sheet to QA

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Appendix A 3

within five (5) working days and, 2) the ms.tter be referred to the Vice

Presidents if a solution acceptable to the QA Manager cannot be obtained

within thirty days.

Contrary to the above, on February 6,1985, conditions adverse to quality were

not promptly corrected when identified by the Nuclear Operations Surveillance

Monitoring Program. Managers and Group Leaders did not implement prompt cor-

rective action as evidenced by the fact that initial responses (Signed Sur-

veillance Finding Sheets) and corrective actions were routinely overdue. As

. of February 6,1985, corrective actions for 29 surveillance findings were

late; included were initial responses overdue for up to 221 days and correc-

tive actions overdue for up to 306 days. Examples are listed below:

Initial Corrective

Finding No. Description Response Action

84-1.4-2-3 Unapproved standby liquid control 276 days

tank heater setpoint overdue

84-1.1-14-1 Improper selection of battery

pilot cells

149 days

overdue

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84-4.2-1.1 Inadequate emergency diesel 306 days

sprinkler test overdue

84-6.1-2-1 No verification of licensed 221 days

operator education overdue

The above examples constitute a Severity Level IV Violation (Supplement I).

D. 10 CFR 50, Appendix B, Criterion VI, Document Control requires that measures

be established to control the issuance of procedures to assure that they are

used where the activity is performed.

Contrary to the above, on February 14, 1985, measures did not assure that pro-

cedures were used where the activity was performed in that procedure 8.7.2.7,

Measure Flow and Pressure Drop Across Control Room Environment System, was

performed utilizing Revision 4 instead of the correct Revision 5, approved

on July 27, 1984.

This is a Severity Level V Violation (Supnlement I).

E. Criterion XII of 10 CFR 50 Appendix B, requires that measures be established

to assure that measuring and testing devices used in activities affecting

quality are properly controlled.

Contrary to the above, on January 19, 1985, measures were not established

which assured that measuring and testing devices were properly controlled

in that digital multimeter No. I-860C which was past due for calibration

was used to check the rod block monitors during rod block monitor

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Appendix A 4

calibrations. In additien, on February 20, 1985, decade box No. IDC 6A

and frequency counter No. 134 were past due for calibration but stored

with calibrated equipment and available for use.

The above examples constitute a Severity Level V Violation (Supplement I).

Pursuant to the provision of 10 CFR 2.201, Boston Edison Company is hereby required

to submit to this office within thirty days of the date of the letter which trans-

mitted this Notice, a written statement or explanation in reply, including:

(1) the corrective steps which have been taken and the results achieved; (2) cor-

rective steps which will be taken to avoid further violations; and (3) the date

when full compliance will be achieved. Where good cause is shown, consideration

will be given to extending this response time.

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