ML20054G167

Responds to NRC 820505 Ltr Re Violations Noted in IE Insp Rept 50-293/82-10.Corrective Actions:Change to Isolation for Maint Request 81-11-16 Issued & Maint Supervisors Counseled on Importance of Following Procedures

ML20054G167
Person / Time
Site:	Pilgrim
Issue date:	06/02/1982
From:	Harrington W BOSTON EDISON CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20054G160	List: IR 05000293/1982010 ML20054G167
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.2, TASK-TM NUDOCS 8206210199
Download: ML20054G167 (3)

Text

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e 305 TON EDISON COMPANY 800 BOYLsTON STRtrr EOmTON, MAssACHUerns 02199 WILLIAM D. HARRlNGTON esmies wees passessuv munsaa June 2,1982 BECo. Ltr. #82-155 l

Mr. Richard W. Starostecki, Director Division of Project and Resident Programs Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA. 19406 License No. DPR-35 Docket No. 50-293 Response to Inspection 50-293/82-10

Reference:

(A) NRC Letter dated May 5, 1982, IE Inspection 82-10 i

Dear Sir:

This responds to an item of violation and an item of deviation contained in Reference (A), the results of routine safety inspection conducted March 1 -

Arpil 4,1982 at Pilgrim Nuclear Power Station.

Appendix A, Notice of Violation Technical Specification 6.8.a requires that written procedures and administrative l policies shall be established that meet or exceed the requirements and recommenda-l tions of Appendix "A" of USNRC Regulatory Guide 1.33. Regulatory Guide 1.33 re-quires administrative procedures for Equipment Control (e.g. locking and tagging).

Station Procedure 1.4.5, "PNPS Tagging Procedure", Revision 8,Section II. A.1 prohibits the operation of a device with a red tag attached.

Contrary to the above, on March 16, 1982, Standby Liquid Control System valve No. 1101-22, which was required to be tagged in the closed position to satisfy system isolation for a different maintenance action, was disassembled and in the process of repair with the valve internals (disc, stem, bonnet and hardwheel) removed from the valve body and the red tag requiring that the valve remain in the closed position still attached the the handwheel.

This is a Severity Level V Violation (Supplement 1).

8206210199 820615 PDR ADOCK 05000293 G PDR

s CD TON E*D CO N COMPANY Mr. Richard W. Starostecki, Director June 2, 1982 Page 2 Response to Appendix A, Notice of Violation (INC 82-10-03)

As noted in the test of Inspection 82-10, our immediate corrective action was to issue a change to the isolstion for Maintenance Request (MR) 81-11-16, thereby satisfying the isolation requirements of the MR.

The disassembly of the valve occured when a mechanic working two maintenance requests (MR) for the same system noted that even though the subject valve was tagged for one MR, he was " covered" by the tagging for the other and did not return to the control room and have the isolation for the valve in question changed. This is not acceptable IAW Station Procedure 1.4.5, but a safety hazard did not exist and the health and safety of the public was not jeopardized.

The Chief Maintenance Engineer counseled the maintenance supervisors and requested that they councel the mechanics on the importance of following procedures on March 29, 1982 and again on June 1, 1982.

The event was discussed and the Chief Maintenance Engineer stated that the "short-cuts" that evolved this event are not to be taken, and that personnel safety and procedural compliance are mandatory in all cases.

Full compliance has been achieved.

A_ppendix B, Notice of Deviation NUREG 0737 dated October 31, 1980, Item II.B.2, describes the NRC position regarding actions to be taken to assure personnel access to vital plant equipment / areas under post accident radiological conditions. In your submittals to the Commission, Boston Edison Company (BECo) described several design changes that would be completed to meet the requirements of Item II.B.2, including the installation of remote controls for the Reactor Building Truck Air Lock inner door. By letter 82-24 dated January 25, 1982, BECo reported that actions taken for the Truck Lock Door portion of Item II.B.2 were complete.

Contrary to the above, our inspection on March 1,1982, determined that BECo actions to complete the Truck Lock Door design change were incomplete. Although a remote control panel for the Truck Lock had been installed and proven operable by functional testing on May 27, 1981, as of March 1,1982, the design change package had not been turned over from the construction group; keys to open the panel and operate the en-closed key-lock switch were not under Operations Department control; and, training on the panel and its use had not been completed.

Response to Appendix B, Notice of Deviation (INC 82-10-09)

The installation, as discussed in the text of Inspection 82-10, was physically complete, that is, the equipment was in place. Operations personnel, however, had not been supplied with the necessuy keys. In reviewina the evolution which led to this situation, we found that the functional test had been completed by the Construction Management Group (CMG) on May 27, 1981, but that the subsequent test by Operations had not been completed, causing a delay in final acceptance.

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CD TON EDCON COMPANY Mr. Richard W. Starostecki, Director June 2, 1982 Page 3 Our immediate corrective steps, as described in the inspection, were to replace the lock, issue new keys to.the Control Room, and, on March 2,1982, to install bakelite tags which contained operating instructions on the panel. This action allowed use of the modification by Operations personnel.

The evolution of this event began prior to our developing plans and procedures, as part of the 1981 Refueling Outage, to ensure that plant design changes are properly translated into procedures , drawings and training programs, as appropriate, in a timely manner. We believe the development of that modification management process will preclude recurrence.

Full compliance has been achieved.

We believe this submittal satisfactnrily addresses the items identified in Inspection 82-10. Should you require any further information concernino this response, please contact us.

Very truly yours, Commonwealth of flassachusetts)

County of Suffolk )

Then personally appeared before me William D. Harrington, who, being duly sworn, did state that he is senior Vice President - Nuclear of Boston Edison Company, the apolicant herein, and that he is duly authorized to execute and file the submittal contained herein in the name and on behalf of Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.

!!y Commission expires: [ u g ggg' .2 /, /988 Notar. Public

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