ML20128N797

Responds to NRC Re Violations Noted in Insp Rept 50-293/85-06.Corrective Actions:Lprm Switch 44-13A Placed in Bypass Position Upon Discovery of Incorrect Switch Position.Attention to Procedures Emphasized

ML20128N797
Person / Time
Site:	Pilgrim
Issue date:	05/24/1985
From:	Harrington W BOSTON EDISON CO.
To:	Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
85-096, 85-96, NUDOCS 8506030387
Download: ML20128N797 (2)

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- BOSTON EDISON COMPANY

,a 300 BOVLaTON STREET '

BOSTON, MASSACNUSETTS D2199 i W LLIAM O. MAR 20NeTON

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May 24,1985 BECo Ltr. #85-096

'Mr.fEdwa d C."Wenzinger,. Chief

, Projects: Branch No,'~3 U.S." Nuclear. Regulatory Commission .

Region I:- 631 Park' Avenue.

Ning of Prussia,:PA- -19406 License No. DPR-35 r,: Docket No. 50-293

Subject:

Response'to Violations as Contained in

- NRC Inspection Report- No. 85 a  :

Reference:

NRC Letter to Boston Edison, dated April 25, 1985

Dear Mr; Wenzinger:

This^~1etter is in response to the violations identified during an inspection conducted by Messrs. J. Johnson and M.~ McBride of your office during the period-March 5,.1985 to April 1, 1985 and communicated to Boston Edison-Company in Appendix AJof the reforence.

,: Notice of Violation "A"

. Technical Specification'l.0.V and Table 4.1.-2 require that the local power range monitors (LPRM)'be calibrated. prior to being declared operable if a calibration during the previous surveillance interval has.been waived.

Contrary to the above,-'between March 22 and 23, 1985,-the 44-13A LPRM was declared operable without a prior calibration. The LPRM calibration during the previous surveillance interval had been waived.

. Response

. Upon further investigation of the incident, it was concluded that between l March 22:and March 25, 1985, the switch for the 44-13A LPRM was

' inadvertently moved from the " Bypass" position to the " Operable"

' - position. This was done_during'the weekly performance of the APRM.

. functional' test. -We consider this to be an isolated case of an individual's' failure to follow procedure.

JThe corrective stop taken to' correct the condition is that upon discovery

.of the incorrect switch position, the switch was placed back in the

'" Bypass" position.

..8506030387 850524 PDR ADOCK 05000293

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. [BOSTONEDISONCOMPANY-Mr.: Edward C. Wenzinger U.S. Nuclear Regulatory Commission May 24 -1985 Page Two

-The corrective step taken to prevent further violations is that a memo was issued to Control Room personnel describing this incident and reminding them of the importance to adhere to procedures.

Full. compliance was achieved on March 27, 1985, the date on which the LPRM

, switch ~was moved back to the " Bypass"l position.

Notice of Violation "B"

~ Technical Specification 4.7.B.b.1 requires that in--place cold dioctyl phthalate

, _(DOP) testing be performed on the high efficiency particulate air (HEPA) filter banks in the standby gas. treatment system if structural maintenance is done on the HEPA filter. system housings.which could affect bypass leakage.

Contrary to the above, on March 15, 1985 no DOP testing was' performed on the "A" train of the standby gas treatment system following the removal and re-installation of-HEPA filter banks in that-train (a structural maintenance activity that could affect bypass leakage).

iResponse-Boston Edison' denies the contention that we were in violation of Technical Specification 4.7.B b.1, which requires DOP testing'be performed on the HEPA filters after (either) (1) replacement of the HEPA filter bank or (2) (subsequent to) any structural maintenance on the HEPA filter system housing which could affect the-HEPA filter bank bypass leakage. The subject section of the Technical Specifications does not state any specific time constraints within which the DOP test should be performed. Nevertheless, we admit'a' procedural weakness in that the testing had not been done in a timely manner.

Upon the Inspector bringing the situation to our attention and as corrective action to' correct the condition, a successful DOP test of "A"' train was conducted on March 27,~1985.

Corrective action to preclude recurrence is that in order to assure more timely testing and improved controls for_ future situations in which maintenance on the subject systems would constitute a potential to affect bypass leakage, Procedure-3.M.4-38, "SBGT Maintenance," will be revised to sequence, in-a more timely manner,' the necessary post-work testing requirements.

. If you have any further questions, please do not hesitate to contact me.

Respectfully submitted,

)

W. D. Harrington

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