ML20133B388

Discusses Insp Rept 50-293/85-21 on 850716-30 & Forwards Notice of Violation.Violation Re Failure to Take Action to Maintain Secondary Containment Integrity Classified as Severity Level IV

ML20133B388
Person / Time
Site:	Pilgrim
Issue date:	09/20/1985
From:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Harrington W BOSTON EDISON CO.
Shared Package
ML20133B392	List: ML20133B388 ML20133B394
References
EA-85-104, NUDOCS 8510030260
Download: ML20133B388 (3)

See also: IR 05000293/1985021

Text

!

's . .

SEP 2 01985 l

. Docket No. 50-293

! License No. DPR-35

EA 85-104

Boston Edison Company M/C Nuclear

ATTN: Mr. William D. Harrington

i Senior Vice President, Nuclear

800 Boylston Street

Boston, Massachusette 02199

Gentlemen:

,

SUBJECT: NOTICE OF VIOLATION

(Inspection No. 50-293/85-21)

This refers to the special NRC inspection conducted by the NRC Resident Inspec--

tor on July 16-30, 1985, at the Pilgrim Nuclear Power Station, Plyrr.outh, Mass-

achusetts. The inspection report was forwarded to you on_ August 13, 1985. The

inspection was conducted to review the circumstances associated with two vio-

lations of NRC requirements, one of which was identified by members of your

staff and reported to the.NRC. The violations involve: (1) failure to take

action to maintain secondary containment integrity in accordance with the tech-

nical specifications upon discovery of an inoperable ventilation damper on July

-

15; and, (2). failure to perform required surveillance testing of certain sys-

tems in accordance with the technical specifications after finding an unaccept-

able water and sediment content in the fuel oil supply of one of the diesel

generators on July 23, 1985. On August 27, 1984, we held an enforcement con-

ference with you and members of your staff to discuss the apparent violations,

their causes, and your corrective actions.

The NRC is concerned that each of these violations of the technical specifica-

tions could have been prevented if the responsible plant personnel, upon dis-

covery of the abnormal condition, had promptly initiated a Failiare and Mal-

! function Report (F&MR) as required by procedure. This report is utilized to

inform the operations department of the abnormal condition to ensure a prompt

review of the safety significance of the failure or malfunction. Such com-

munication between nonlicensed personnel and the licensed operators regarding

abnormal conditions is essential to ensure that actions required by the tech-

nical specifications are promptly taken to assure the facility is operated

safely. Failure to promptly complete the F&MR constitutes a third violation-

of NRC requirements.

The NRC is also concerned-that although the F&MRs were not completed in each

case, licensed operators were informed of the abnormal conditions, either ver-

bally or through the issuance of a maintenance request. However, the oper-

ators did not independently pursue a-determination of the effect of the ab-

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OFFICIAL RECORD COPY CP NOTICE PILGRIM - 0001.0.0 1

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Boston Edison Company

M/C Nuclear 2

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normal conditions on the ability to adhere to the technical specifications.

The licensed operators apparent reliance solely upon the F&MR for notification

of abnormal conditions does not exhibit the agressiveness expected of licensed

operators in pursuing resolution of potential problems.

These violations have been classified at Severity Level IV in accordance with

the " General Statement of Policy and Procedures for Enforcement Action", 10 CFR

2, Appendix C based on the low safety significance. Nonetheless, we will '

examine closely your corrective action, and we emphasize that any similar

violation in the future may result in additional enforcement action.

Your are required to respond to the enclosed Notice and you should follow the

instructions specified therein when preparing your response. In your response,

you should address the actions taken or planned to ensure that (1) plant staff

understands the importance of initiating F&MRs and will properly initiate and

implement F&MRs in the future, and (2) licensed operators do not rely solely on

F&MRs for notification of abnormal conditions. Your written reply to this

letter and the enclosed Notice and the results of future inspections will be

considered in determining whether further enforcement action is appropriate.

In accordance with 10 CFR 2.790(a) a copy of this letter and the enclosure will

be placed in the NRC Public Document Room.

The responses directed by this letter and the enclosed Notice are not subject

to the clearance procedures of the Office of Management and Budget as required

by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely,

Orir,inal Signod 3g*

Richard W. Starostecki, Director

Division of Reactor Projects

Enclosure:

Notice of Violation

cc w/ encl:

A. V. Morisi, Manager, Nuclear Management Services Department

C. J. Mathis, Station Manager

Joanne Shotwell, As>istant Attorney General

Paul Levy, Chairman, Department of Public Utilities

W. J. Nolan, Chairmaa, Plymouth Board of Selectmen

Plymouth Civil Defense Director

Senator Edward P. Kirby

Public Document Room (PDR)

local Public Document Room (LPDR)

'

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

! Commonwealth of Massachusetts (2)

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09/20/85

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Boston Edison Company

M/C Nuclear 3 SEP 2 01985

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Section Chief, DRP

W. Raymond, SRI, Vermont Yankee

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