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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N8911999-10-15015 October 1999 Forwards Rept of Changes,Tests & Experiments at Pilgrim Nuclear Power Station for Period of 970422-990621,IAW 10CFR50.59(b).List of Changes Effecting Fsar,Encl ML20217D3951999-10-13013 October 1999 Forwards Request for Addl Info Re Util 990806 Submittal on USI A-46, Implementation Methodology Used at Pilgrim Nuclear Power Station, Per GL 87-02 ML20217E1581999-10-0808 October 1999 Forwards Insp Rept 50-293/99-05 on 990726-0905.Three Violations Noted & Being Treated as Ncvs.Violations Include Failure to Assure That Design Bases Correctly Translated Into Specifications ML20217C3151999-10-0606 October 1999 Forwards Scenario Package for Pilgrim Nuclear Power Station Nrc/Fema Evaluated Exercise Scheduled for 991207.Without Encl ML20217D5591999-10-0505 October 1999 Documents Pilgrim Nuclear Power Station Five Yr Survey of Main Breakwater.Survey Has Determined That Pilgrim Main Breakwater Is Intact & Remains Adequately Constructed to Perform Designed Safety Function ML20217C8051999-10-0505 October 1999 Forwards Proprietary Results of Audiologic Evaluations for Jp Giar,License SOP-10061-3.Attachment Clearly Shows Requirements for Operator Hearing Ability Are Met. Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML20212J8301999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Integrate Performance Info & to Plan Insp Activities at Facility Over Next Six Months ML20216J9961999-09-29029 September 1999 Forwards Resume of Person Identified as Acting RPM in Licensee to NRC Re Notification That Person Named in License Condition 11 of 20-07626-02,is No Longer Employed at Pilgrim Station.Resume Withheld,Per 10CFR2.790 ML20212F7871999-09-24024 September 1999 Advises That Util 990121 Application for Amend Being Treated as Withdrawn.Proposed Changes Would Have Modified Facility UFSAR Pertaining to Values for post-accident Containment Pressure Credited in Pilgrim Net Positive Head Analyses ML20212H1381999-09-23023 September 1999 Submits Info in Support of Request Filed on 990730 to Grant one-time Exemption from 10CFR50,App E,Authorizing Biennial Full Participation Emergency Preparedness Exercise to Be Conducted in 2002 Instead of 2001 ML20212H1441999-09-23023 September 1999 Withdraws 990121 Request for License Change Re Emergency Core Cooling Sys Net Positive Suction Head,Due to Incorrect Datum Preparation ML20212C2861999-09-16016 September 1999 Forwards SER Accepting Licensee 981123 Request for Relief RR-E1,RR-E5,RR-E6 Pursuant to 10CFR50.55a(a)(3)(i) & Request for Relief RR-E2,RR-E3 & RR-E4 Pursuant to 10CFR50.55a(a)(3)(ii) ML20216F3451999-09-16016 September 1999 Forwards Summary Rept Providing Results of ISI Conducted at PNPS on-line & Refueling Outage (RFO 12) ML20216E7111999-09-0909 September 1999 Forwards License Renewal Application Including Form NRC-398 & Form NRC-396 for Jp Giar,License SOP-10061-3.Without Encls ML20216E5891999-09-0707 September 1999 Forwards Copy of Pilgrim Station Organization Structure. Encl Refelcts Changes in Upper Mgt Level Structure.Changes Were Effective 990901 ML20211M4501999-09-0303 September 1999 Informs That Pilgrim Nuclear Power Station Plans to Conduct Full Participation Emergency Preparedness Exercise with Commonwealth of Ma on 991207,IAW 10CFR50,App E,Section IV.F.2 ML20211M9161999-08-31031 August 1999 Submits Review & Correction of Info in Reactor Vessel Integrity Database (Rvid),Version 2,re Pilgrim Station ML20211J8391999-08-30030 August 1999 Forwards Rev 1 to Provisional Decommissioning Trust Agreement for Plant,Changing Portions of Agreement to Permit Up to Two Distributions & Clarify Formula for Distribution ML20211H5701999-08-27027 August 1999 Forwards Insp Rept 50-293/99-04 on 990610-0725.Two Violations Identified Being Treated as non-cited Violations ML20211C3381999-08-19019 August 1999 Provides semi-annual LTP Update,Including Schedule, Commitment Descriptions,Progress Since Last Update & Summary of Changes.Rev Bars Indicate Changes in Status Since Last Submittal ML20210U7521999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opossing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U6691999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opposing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U5761999-08-18018 August 1999 Responds to Opposing Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts. Informs That for Sale,Nrc Responsible for Only Ensuring That Entergy Technically & Financially Qualified to Operate NPP ML20210U5151999-08-17017 August 1999 Forwards Notice of Withdrawal of Application for Approval of Indirect Transfer of FOL for Pilgrim in Response to .Approval No Longer Needed Since Beco Sold Interest in Pilgrim to EOI on 990713 ML20211B3841999-08-16016 August 1999 Forwards Response to NRC Second RAI Re Pressure Locking & Thermal Binding of SR power-operated Gate Valves ML20210U4831999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data Sheets for Period of 990101-0630,per 10CFR26.71(d) ML20210S0891999-08-0909 August 1999 Forwards Amend 11 to Indemnity Agreement B-48 Signed by Boston Edison Co & Entergy Nuclear Generation Co ML20210R6251999-08-0606 August 1999 Provides Supplementary Info on USI A-46 Implementation Methodology at Pilgrim Station,To Enable NRC to Perform Evaluation & Issuance of Plant Specific SER for Plant ML20210M9411999-08-0202 August 1999 Requests That NRC Treat Pending Actions Requested by Beco Prior to 990713,as Requests Made by Entergy.Ltr Requests That Minor Administrative Changes to License Amend 182 & Associated Ser, ,reflect 990713 Transfer ML20210H8761999-07-30030 July 1999 Requests That NRC Grant Exemption from Requirements of 10CFR50,App E,Section IV F,Which Would Authorize Rescheduling of 2001 Biennial Full Participation Emergency Preparedness Exercise for Pilgrim Station to 2002 ML20210H8661999-07-29029 July 1999 Provides Revised Response to GL 96-06 & Addresses NRC Insp Concern for Containment Penetration X-12.Info Submitted to Facilitate NRC Review & Closeout of Subject GL for Plant ML20216E2321999-07-26026 July 1999 Discusses GL 92-01,rev 1,suppl 1, Rv Structural Integrity. NRC Revised Info in Rvid & Releasing as Rvid Version 2 ML20216D4131999-07-22022 July 1999 Informs That J Conlon,License OP-11040-1,terminated Employment with Beco on 990703,per 10CFR50.74.Individual Will Not Participate in Util Licensed Operator Requalification Training Program ML20210E2231999-07-20020 July 1999 Discusses Arrangements Made by Dennis & M Santiago During 990615 Telephone Conversation for NRC to Inspect Licensed Operator Requalification Program at Pilgrim During Wk of 991004 ML20210C4151999-07-19019 July 1999 Informs That Util Intends to Submit Approx Eight Licensing Actions in FY00 & Eight in FY01,in Response to Administrative Ltr 99-02.Actions Are Not Expected to Generate Complex Reviews ML20210A9441999-07-14014 July 1999 Responds to Re Changes to Pilgrim Nuclear Power Station Physical Security Plan Identified as Issue 2,rev 14, Addendum 1,respectively.No NRC Approval Is Required IAW 10CFR54(p) ML20210F3711999-07-14014 July 1999 Informs NRC That Effective 990713,listed Pilgrim Station Security Plans Have Been Transferred from Boston Edison to Entergy & Are Still in Effect ML20209G2251999-07-0909 July 1999 Forwards Insp Rept 50-293/99-03 on 990419-0609.Five Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations,Consistent with App C. Several Individual Tagging Errors Occurred ML20209C4661999-07-0707 July 1999 Forwards SE Accepting Addendum on Proposed Change in Corporate Ownership Structure Involving Entergy Nuclear Generation Co ML20209C3851999-07-0606 July 1999 Forwards Redacted Draft of Decommissioning Trust Agreement Re Transfer of PNPS & NRC Operating License & Matls License from Boston Edison Co to Entergy Nuclear Generating Co ML20209C7761999-07-0606 July 1999 Submits Annual Summary Rept of Changes Made to QAP Description as Described in QA Manual,Vol Ii.Rept Covers Period of Jul 1998 Through June 1999.No Changes Made During Period ML20196J7251999-07-0101 July 1999 Informs of Completion of Licensing Action for GL 96-01, Testing of Safety-Related Logic Circuits, for Pilgrim Nuclear Power Station ML20209B9411999-06-30030 June 1999 Discusses Deferral of IGSCC Welds to RFO 13.Deferral of Welds to Refueling Outage 13 Does Not Impact Acceptable Level of Quality & Safety Per 10CFR50.55(a)(3)(i) Since Plant in Compliance W/Exam Percentage Requirements ML20209B9431999-06-30030 June 1999 Provides Formal Notification That Closing Date for Sale & Transfer of Pilgrim Station Scheduled to Occur on 990713. a Wang Will Be Verbally Notified of Time of Sale Closing ML20196H2381999-06-29029 June 1999 Forwards SER Denying Licensee 980820 Request for Alternative Under PRR-13,rev 2 for Use of Code Case N-522 During Pressure Testing of Containment Penetration Piping ML20209B9791999-06-29029 June 1999 Forwards Rev 13A to Pilgrims COLR for Cycle 13,IAW TS 5.6.5 Requirements.Rev 13A Provides cycle-specific Limits for Operating Pilgrim During Remainder of Cycle 13 ML20209A8761999-06-28028 June 1999 Forwards SER Authorizing Licensee 990317 Relief Request to Use ASME Code Case N-573 as Alternative to ASME Code Section XI Article IWA-4000 for Remainder of 10-year Interval Pursuant to 10CFR50.55a(a)(3)(i) ML20209A8701999-06-25025 June 1999 Responds to NRC Request for Info Re Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure for Plant,Reporting Status of Facility Y2K Readiness Encl ML20210U5901999-06-25025 June 1999 Opposes Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts.Expresses Skepticism Re Claim by Companies That Consumers Will Benefit from Proposed Consolidation & four-year Freeze in Base Rates ML20209C3431999-06-22022 June 1999 Forwards Addendum 1,Rev 14 to Pilgrim Station Security Plan,Iaw 10CFR50.54(p)(2).Changes Proposed Have Been Implemented & Constitute Increase in Plant Defense Plan Commitments.Encl Withheld,Per 10CFR73.21 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217N8911999-10-15015 October 1999 Forwards Rept of Changes,Tests & Experiments at Pilgrim Nuclear Power Station for Period of 970422-990621,IAW 10CFR50.59(b).List of Changes Effecting Fsar,Encl ML20217C3151999-10-0606 October 1999 Forwards Scenario Package for Pilgrim Nuclear Power Station Nrc/Fema Evaluated Exercise Scheduled for 991207.Without Encl ML20217C8051999-10-0505 October 1999 Forwards Proprietary Results of Audiologic Evaluations for Jp Giar,License SOP-10061-3.Attachment Clearly Shows Requirements for Operator Hearing Ability Are Met. Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML20217D5591999-10-0505 October 1999 Documents Pilgrim Nuclear Power Station Five Yr Survey of Main Breakwater.Survey Has Determined That Pilgrim Main Breakwater Is Intact & Remains Adequately Constructed to Perform Designed Safety Function ML20216J9961999-09-29029 September 1999 Forwards Resume of Person Identified as Acting RPM in Licensee to NRC Re Notification That Person Named in License Condition 11 of 20-07626-02,is No Longer Employed at Pilgrim Station.Resume Withheld,Per 10CFR2.790 ML20212H1441999-09-23023 September 1999 Withdraws 990121 Request for License Change Re Emergency Core Cooling Sys Net Positive Suction Head,Due to Incorrect Datum Preparation ML20212H1381999-09-23023 September 1999 Submits Info in Support of Request Filed on 990730 to Grant one-time Exemption from 10CFR50,App E,Authorizing Biennial Full Participation Emergency Preparedness Exercise to Be Conducted in 2002 Instead of 2001 ML20216F3451999-09-16016 September 1999 Forwards Summary Rept Providing Results of ISI Conducted at PNPS on-line & Refueling Outage (RFO 12) ML20216E7111999-09-0909 September 1999 Forwards License Renewal Application Including Form NRC-398 & Form NRC-396 for Jp Giar,License SOP-10061-3.Without Encls ML20216E5891999-09-0707 September 1999 Forwards Copy of Pilgrim Station Organization Structure. Encl Refelcts Changes in Upper Mgt Level Structure.Changes Were Effective 990901 ML20211M4501999-09-0303 September 1999 Informs That Pilgrim Nuclear Power Station Plans to Conduct Full Participation Emergency Preparedness Exercise with Commonwealth of Ma on 991207,IAW 10CFR50,App E,Section IV.F.2 ML20211M9161999-08-31031 August 1999 Submits Review & Correction of Info in Reactor Vessel Integrity Database (Rvid),Version 2,re Pilgrim Station ML20211J8391999-08-30030 August 1999 Forwards Rev 1 to Provisional Decommissioning Trust Agreement for Plant,Changing Portions of Agreement to Permit Up to Two Distributions & Clarify Formula for Distribution ML20211C3381999-08-19019 August 1999 Provides semi-annual LTP Update,Including Schedule, Commitment Descriptions,Progress Since Last Update & Summary of Changes.Rev Bars Indicate Changes in Status Since Last Submittal ML20211B3841999-08-16016 August 1999 Forwards Response to NRC Second RAI Re Pressure Locking & Thermal Binding of SR power-operated Gate Valves ML20210U4831999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data Sheets for Period of 990101-0630,per 10CFR26.71(d) ML20210S0891999-08-0909 August 1999 Forwards Amend 11 to Indemnity Agreement B-48 Signed by Boston Edison Co & Entergy Nuclear Generation Co ML20210R6251999-08-0606 August 1999 Provides Supplementary Info on USI A-46 Implementation Methodology at Pilgrim Station,To Enable NRC to Perform Evaluation & Issuance of Plant Specific SER for Plant ML20210M9411999-08-0202 August 1999 Requests That NRC Treat Pending Actions Requested by Beco Prior to 990713,as Requests Made by Entergy.Ltr Requests That Minor Administrative Changes to License Amend 182 & Associated Ser, ,reflect 990713 Transfer ML20210H8761999-07-30030 July 1999 Requests That NRC Grant Exemption from Requirements of 10CFR50,App E,Section IV F,Which Would Authorize Rescheduling of 2001 Biennial Full Participation Emergency Preparedness Exercise for Pilgrim Station to 2002 ML20210H8661999-07-29029 July 1999 Provides Revised Response to GL 96-06 & Addresses NRC Insp Concern for Containment Penetration X-12.Info Submitted to Facilitate NRC Review & Closeout of Subject GL for Plant ML20216D4131999-07-22022 July 1999 Informs That J Conlon,License OP-11040-1,terminated Employment with Beco on 990703,per 10CFR50.74.Individual Will Not Participate in Util Licensed Operator Requalification Training Program ML20210C4151999-07-19019 July 1999 Informs That Util Intends to Submit Approx Eight Licensing Actions in FY00 & Eight in FY01,in Response to Administrative Ltr 99-02.Actions Are Not Expected to Generate Complex Reviews ML20210F3711999-07-14014 July 1999 Informs NRC That Effective 990713,listed Pilgrim Station Security Plans Have Been Transferred from Boston Edison to Entergy & Are Still in Effect ML20209C7761999-07-0606 July 1999 Submits Annual Summary Rept of Changes Made to QAP Description as Described in QA Manual,Vol Ii.Rept Covers Period of Jul 1998 Through June 1999.No Changes Made During Period ML20209C3851999-07-0606 July 1999 Forwards Redacted Draft of Decommissioning Trust Agreement Re Transfer of PNPS & NRC Operating License & Matls License from Boston Edison Co to Entergy Nuclear Generating Co ML20209B9431999-06-30030 June 1999 Provides Formal Notification That Closing Date for Sale & Transfer of Pilgrim Station Scheduled to Occur on 990713. a Wang Will Be Verbally Notified of Time of Sale Closing ML20209B9411999-06-30030 June 1999 Discusses Deferral of IGSCC Welds to RFO 13.Deferral of Welds to Refueling Outage 13 Does Not Impact Acceptable Level of Quality & Safety Per 10CFR50.55(a)(3)(i) Since Plant in Compliance W/Exam Percentage Requirements ML20209B9791999-06-29029 June 1999 Forwards Rev 13A to Pilgrims COLR for Cycle 13,IAW TS 5.6.5 Requirements.Rev 13A Provides cycle-specific Limits for Operating Pilgrim During Remainder of Cycle 13 ML20209A8701999-06-25025 June 1999 Responds to NRC Request for Info Re Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure for Plant,Reporting Status of Facility Y2K Readiness Encl ML20210U5901999-06-25025 June 1999 Opposes Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts.Expresses Skepticism Re Claim by Companies That Consumers Will Benefit from Proposed Consolidation & four-year Freeze in Base Rates ML20209C3431999-06-22022 June 1999 Forwards Addendum 1,Rev 14 to Pilgrim Station Security Plan,Iaw 10CFR50.54(p)(2).Changes Proposed Have Been Implemented & Constitute Increase in Plant Defense Plan Commitments.Encl Withheld,Per 10CFR73.21 ML20195G3721999-06-0707 June 1999 Informs That Proposed Indicators Failed QA Assessments for Digital Verification,Validation & Control of Software. Proposed Mod Can Be Completed on-line ML20195B5021999-05-27027 May 1999 Provides Suppl Info to 990203 Request of Beco That NRC Consent to Indirect Transfer of Control of Util Interest in License DPR-35.Request Described Proposed Merger of Bec Energy with Commonwealth Energy Sys ML20207D4681999-05-24024 May 1999 Provides Addl Info to That Included in Beco Ltr 98-123 Dtd 981001,addressing NRC Concerns Described in GL 96-06, Concerning Waterhammer in Reactor Bldg Closed Cooling Water Sys ML20195B9051999-05-20020 May 1999 Forwards Completed Renewal Applications for Listed Operators.Without Encls ML20206J4901999-05-0606 May 1999 Forwards Completed License Renewal Application,Including Forms NRC-398 & 396 for Sc Power,License OP-6328-3 ML20206P0711999-05-0606 May 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee, for K Walz,License SOP-10886-1.Encl Withheld IAW 10CFR2.790(a)(6) ML20206D3621999-04-27027 April 1999 Informs NRC That Final Five Sys self-assessments Required to Fulfill Commitment Made in 980828 Response to Insp Rept 50-293/98-04 Were Completed on 990422.Completion Was Delayed by High Priority Refueling Outage 12 Preparatory Work ML20205R9871999-04-21021 April 1999 Forwards Affidavit of JW Yelverton of Entergy Nuclear Generation Co Supporting Request for Withholding Info from Rept on Audit of Financial Statements for Year Ended 971231. Pages 16 & 18 of Subj Rept Also Encl ML20207B0891999-04-20020 April 1999 Forwards e-mail Message from Constituent,J Riell Re Y2K Compliance of Nuclear Power Plant in Plymouth,Massachusetts. Copy of Article Entitled Nuke Plants May Not Be Y2K Ready Also Encl ML20206A2741999-04-16016 April 1999 Dockets Encl Ltr Which Was Sent to AL Vietti-Cook Re Condition of Approval of Transfer of License & License Condition for DPR-35.Encl Resolves Issues Between Attorney General of Commonwealth of Massachusetts & Applicants ML20205P9131999-04-16016 April 1999 Submits Applicant Consent to Listed Condition of Approval of Transfer of License & License Condition for License DPR-35 & Affirmatively Request That NRC Adopt Listed Language in Order ML20205P9271999-04-16016 April 1999 Withdraws Motion for Leave to Intervene & Petition for Summary Or,In Alternative,For Hearing.Requests That NRC Adopt Condition of Approval of Transfer of License & License Condition Agreed to Beco & Entergy Nuclear Generation Co ML20205Q9231999-04-15015 April 1999 Forwards Proprietary & non-proprietary Addl Info in Support of Request to Transfer of Plant FOL & Matls License to Entergy Nuclear Generation Co.Proprietary Info Withheld,Per 10CFR2.790 ML20205P9631999-04-15015 April 1999 Provides Attachments a & B in Support of Request for Transfer of Plant Operating License & NRC Matl License from Beco to Entergy Nuclear Generation Co as Submitted in Ref 1. Info Provided in Response to Request at 990413 Meeting ML20205H9281999-04-0707 April 1999 Requests Withdrawal of Uwua Locals 369 & 387 Unions Joint Intervention in Listed Matter ML20205F3731999-04-0202 April 1999 Submits Addl Info Provided in Support of Request for Transfer of Pilgrim Nuclear Power Station Operating License & Matls License.State of Ma Order Authorizing Divestiture & Copy of Financial Arrangement Encl ML20204H3771999-03-26026 March 1999 Informs That Local 387,Utility Workers Union of America,AFL- Cio Voted to Approve New Contract with Entergy Nuclear Generation Co & Voted to Accept Boston Edison Divestiture Agreement ML20205D4231999-03-24024 March 1999 Forwards Decommissioning Funding Rept for Pilgrim Nuclear Power Station,In Accordance with 10CFR50.75(f)(1) 1999-09-09
[Table view] Category:UTILITY TO NRC
MONTHYEARBECO-90-108, Forwards Anticipated Operator Licensing Exam Schedule Requested by Generic Ltr 90-07, Operator Licensing Natl Exam Schedule,1990-09-12012 September 1990 Forwards Anticipated Operator Licensing Exam Schedule Requested by Generic Ltr 90-07, Operator Licensing Natl Exam Schedule, ML20059D6641990-08-30030 August 1990 Forwards Revised Emergency Plan Implementing Procedures,Per 10CFR50,App E,Section V.W/O Encl ML20059D6791990-08-30030 August 1990 Notifies That Two Remaining Actions for Implementation of SPDS at Plant Complete,Per .Spds Procedures Modified,Identifying Sampling Panel C-19 Return Valves to Operator BECO-90-100, Advises That Valve MO-1001-50 Cannot Be Shown to Meet 30-day Mission for PASS in post-accident Environ Due to Elevated Radiation Dose Rates.Util Currently Developing Solution to Allow PASS to Meet 30-day Availability Requirement1990-08-27027 August 1990 Advises That Valve MO-1001-50 Cannot Be Shown to Meet 30-day Mission for PASS in post-accident Environ Due to Elevated Radiation Dose Rates.Util Currently Developing Solution to Allow PASS to Meet 30-day Availability Requirement BECO-90-102, Forwards Fitness for Duty Program Performance Data for Jan- June 19901990-08-23023 August 1990 Forwards Fitness for Duty Program Performance Data for Jan- June 1990 BECO-90-095, Informs That Kn Taylor Permanently Reassigned to Nuclear Training Dept as of 900717.Taylor Will Remain in Position Which Does Not Require License Certification1990-08-0808 August 1990 Informs That Kn Taylor Permanently Reassigned to Nuclear Training Dept as of 900717.Taylor Will Remain in Position Which Does Not Require License Certification BECO-90-092, Forwards, Decommissioning Funding Rept, Per 10CFR50.33(k) & 50.75(b)1990-07-26026 July 1990 Forwards, Decommissioning Funding Rept, Per 10CFR50.33(k) & 50.75(b) ML20044B3111990-07-11011 July 1990 Responds to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount. Corrective Actions Include Replacement of Transmitters Identified in Suspect Lots & Implementation of Surveillance Program ML20044A7891990-06-19019 June 1990 Responds to Generic Ltr 90-04, Request for Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements or Corrective Actions. Table Listing Status of Each Issue Encl ML20043D7181990-05-31031 May 1990 Advises That Response to NRC 900426 Safety Evaluation Re Util 880804 & 890619 Responses to Generic Ltr 88-01 Will Be Sent on 901115 ML20043A8211990-05-15015 May 1990 Notifies of Change of Senior Operator Status for Cj Martin, Per 10CFR50.74.CJ Martin Will No Longer Participate in Licensed Operator Requalification Training Program ML20042F2211990-05-0101 May 1990 Advises That Scheduled Completion of SPDS Human Factors Validation Activities Scheduled for 900630 & Sys Availability Test by 900731 ML20043B3881990-05-0101 May 1990 Responds to Violations Noted in Insp Rept 50-293/90-05. Corrective actions:82 Excess Flow Check Valves Installed & Operability of Valves Verified by Performing Surveillance Testing ML20012F5601990-04-0202 April 1990 Responds to Generic Ltr 89-13 Re Svc Water Sys Problems Affecting safety-related Equipment.Util Instituted Biofouling Control Program in 1982 & Program Has Been Effectively Implemented at Plant & Complies W/Generic Ltr ML20012F3631990-03-30030 March 1990 Requests Temporary Waiver of Compliance from Requirements of Tech Spec Table 3.2.C-1, APRM Upscale Rod Block in Startup & Refuel Modes to Avoid Unnecessary Delay in Critical Path Surveillance Testing ML20012C6501990-03-15015 March 1990 Responds to Generic Ltr 90-01 Re Request for Voluntary Participation in NRC Regulatory Impact Survey.Completed Questionnaire for Applicable Areas Delineated in Survey Encl ML20012D1931990-03-15015 March 1990 Forwards Proposed Scope & Objectives of Annual Exercise 90-04-B Scheduled for 900618 Per Lazarus 890609 Ltr, Emergency Exercise Objective & Scenerio Guidelines. Exercise Will Test & Evaluate Util EPIPs ML20012C7191990-03-14014 March 1990 Forwards Explanation of Errors in 890707 Application Re Corrective Action Plan & Advises That Errors Do Not Affect Technical Basis on Which Exemption Granted.Util Corrective Action Plan Remains Unchanged ML20011F5381990-02-26026 February 1990 Responds to Violations Noted in Insp Rept 50-293/89-12 on 891002-1119.Corrective Actions:On 891109,operations Personnel Directed,Via Night Orders,To Be More Diligent W/ Tagout Documentation & Boundary Tagging Clarified ML20011F2301990-02-23023 February 1990 Notifies of Change in Status of Senior Licensed Operator. DW Gerlits Terminated Senior Reactor Operator License on 900201 But Will Retain Position as Senior Sys & Safety Analysis Engineer ML20006G1411990-02-23023 February 1990 Advises That Tj Mcdonough Reassigned Effective 900126. Individual Will No Longer Participate in Licensed Operator Requalification Training Program ML20011F6521990-02-21021 February 1990 Forwards Inservice Insp Plan for 1990 mid-cycle Spring Outage for Facility.Augmented Insp Will Be Performed for Three IGSCC Category a Welds Using Guidance in Generic Ltr 88-01 & Criteria in NRC Bulletin 88-08,Suppl 3 ML20011F4481990-02-20020 February 1990 Forwards Revised Operability Evaluation of Salt Svc Water Pumps for Plant.Evaluation Concludes That Salt Svc Water Pumps Operable & Requirements of Tech Spec 3.5.B.1 for Pumps Met ML20006G0051990-02-20020 February 1990 Forwards Update to long-term Plan,In Accordance W/Section V.A of Plan for Long-Term Program. Util Implementing Plant Betterment Mods & Activities ML20011E7551990-02-0909 February 1990 Requests Temporary Relief from Tech Spec 4.7.A.2.b.1.d, Limiting Condition for Operation. ML19354E7661990-01-23023 January 1990 Responds to NRC Bulletin 89-002, Stress Corrosion Cracking of High Hardness Type 410 Stainless Steel Bolting in Anchor Darling.... Review Determined That No Subj Anchor Darling Swing Check Valves or Similar Valves Installed at Facility ML20011F4441990-01-19019 January 1990 Forwards Operability Evaluation Re Salt Svc Water Pumps P208 B,C,D & E,Per 900117 Telcon.Evaluation Concluded That Salt Svc Water Pumps P208 B,C,D & E Operable & Tech Spec 3.5.B.1 Requirements Met ML20006A0761990-01-15015 January 1990 Forwards Executed Amend 10 to Indemnity Agreement B-48 ML20006A2591990-01-15015 January 1990 Responds to Generic Ltr 89-10, Safety-Related Motor- Operated Valve Testing & Surveillance. Util Will Develop Program to Enhance Maint,Analysis & Testing Already Conducted on motor-operated Valves ML20005G7701990-01-11011 January 1990 Discusses Revised Schedule for Operability & Availability of Spds,Per 891221 Notification to Nrc.Rev Necessitated by Software Problems Affecting 891231 Schedule Projected in Util 890710 Ltr ML20005G7451990-01-11011 January 1990 Provides Bases for Environ Qualification of Instrumentation Monitoring Effluent Radioactivity & Status of Standby Power Per Reg Guide 1.97,Rev 3 & Generic Ltr 82-33 ML20005G8061990-01-11011 January 1990 Advises That Commitment to Complete Enhancements of Control Panels as Part of Dcrdr,Per NUREG-0737,Item I.D.1 by Oct 1989 Not Met.All Three Panels at Simulator Enhanced & Installation of Revised Meter Scales in Progress ML20005F0761990-01-0404 January 1990 Forwards Revised Inservice Test Program in Response to Generic Ltr 89-04.List of Inservice Test Program Relief Requests Previously Submitted & Acceptable,Per Generic Ltr 89-04,encl ML20005E5601989-12-29029 December 1989 Certifies That Util Has Established Fitness for Duty Program That Meets Requirements of 10CFR26.Drug & Alcohol Level Screening Match Rule Imposition & Implementation Will Be Effective on 900103 ML20042D4821989-12-26026 December 1989 Responds to Violations Noted in Insp Rept 50-293/89-10. Corrective Action:Radiological Section Standing Order 89-09 Issued Allowing Only Radiological Supervisors to Exercise Locked High Radiation Area Door & Key Control ML20011D6851989-12-14014 December 1989 Forwards Response to Generic Ltr 89-21, Request for Info Re Status of Implementation of USI Requirements. ML20011D1631989-12-14014 December 1989 Forwards Pilgrim Nuclear Plant Station Final Assessment Rept, Summarizing Results of self-assessments & Evaluations Conducted Throughout Implementation of Plant Restart Plan & Power Ascension Program ML19325F2751989-11-10010 November 1989 Responds to NRC Bulletin 88-010,Suppl 1, Nonconforming Molded-Case Circuit Breakers. Util Installed H2/02 Analyzers Procured in 1980 & Therefore Exempt from Bulletin Requirements ML19327C0911989-11-0606 November 1989 Forwards Response to Suppl 3 to NRC Bulletin 88-008, Thermal Stresses in Piping Connected to Rcs. Since cyclic- Thermal Heatup/Cooldown Not Present in Piping,Failure Due to Cyclic Thermal Fatigue Will Not Occur ML19325E8581989-11-0101 November 1989 Discusses Litigation Before FERC Re Plant.Util Will Undertake Review of Matls Developed by Opposing Parties in Proceedings.Required Repts Will Be Submitted to NRC After Reportability Has Been Determined ML19325E5251989-10-27027 October 1989 Responds to Generic Ltr 88-20,Suppl 1,describing Plan for Completing Individual Plant Exam for Severe Accident Vulnerabilities.Performance of Level 1 PRA Based on Current Plant Design & Operation Intended ML19325E5661989-10-27027 October 1989 Response to Generic Ltr 89-04, Guidance on Developing Acceptable Inservice Testing Programs. Revised Inservice Testing Program Which Will Include Statement of Conformance to Technical Positions Will Be Submitted by 891215 ML19324B8191989-10-25025 October 1989 Informs That C Leonard & J Stokes Reassigned to Positions Which Do Not Require License Certification Effective 891003 & 891020,respectively ML19327B2291989-10-20020 October 1989 Responds to Generic Ltr 89-07 Re Power Reactor Safeguards Contingency Planning for Surface Vehicle Bombs.Changes Made to Contingency Plan,Per 10CFR50.54.Plan Withheld (Ref 10CFR73.21) ML19325E0981989-10-20020 October 1989 Responds to NRC Re Violations Noted in Insp Rept 50-293/89-07.Corrective Actions:Terminal Block Replaced, post-work Functional Test of Ref Temp Switches Performed & Procedure Tp 88-78 Revised to Correct Relay Numbers BECO-89-142, Responds to NRC Re Violations & Proposed Imposition of Civil Penalty from Insp Rept 50-293/89-95. Corrective Action:Two Responsible Util Operators Suspended Because Breakers Incorrectly Positioned for Test1989-09-22022 September 1989 Responds to NRC Re Violations & Proposed Imposition of Civil Penalty from Insp Rept 50-293/89-95. Corrective Action:Two Responsible Util Operators Suspended Because Breakers Incorrectly Positioned for Test BECO-89-144, Requests Interim Approval for Relief from Testing of RHR Sys Valves 63 & 64 Until Refueling Outage 8 Scheduled for 9103151989-09-22022 September 1989 Requests Interim Approval for Relief from Testing of RHR Sys Valves 63 & 64 Until Refueling Outage 8 Scheduled for 910315 BECO-89-135, Forwards Util Anticipated OL Exam Schedule,Per 890706 Generic Ltr 89-12 Request1989-09-11011 September 1989 Forwards Util Anticipated OL Exam Schedule,Per 890706 Generic Ltr 89-12 Request BECO-89-131, Forwards Tech Spec Figures 6.2-2 & 6.2-1,replacing Title of Director of Nuclear Engineering W/Title of Station Director & Adding New Title of Vice President of Nuclear Engineering1989-09-0505 September 1989 Forwards Tech Spec Figures 6.2-2 & 6.2-1,replacing Title of Director of Nuclear Engineering W/Title of Station Director & Adding New Title of Vice President of Nuclear Engineering BECO-89-129, Submits Addl Info Re 890707 Request for Exemption from Certain Containment Leakage Testing Requirements of 10CFR50. Plant mid-cycle Maint Outage,Previously Scheduled for Oct 1989,has Been Rescheduled for Spring 19901989-09-0101 September 1989 Submits Addl Info Re 890707 Request for Exemption from Certain Containment Leakage Testing Requirements of 10CFR50. Plant mid-cycle Maint Outage,Previously Scheduled for Oct 1989,has Been Rescheduled for Spring 1990 1990-09-12
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BOSTONEDISON Executive of fices 800 Boylston Street Boston, Massachusetts 02199 James M. Lydon Chief Operating Officer January 22,1987 BECo Ltr. #87- 011 k
U.S. Nuclear Regulatory Commission Attention: Document Control Desk Hashington, DC 20555 Mr. Thomas T. Martin Director, Division of Radiation Safety \
USNRC 1 631 Park Avenue King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293
Subject:
NRC Inspection Report No. 50-293/86-19
Dear Mr. Martin:
This letter is in response to your letter dated December 15, 1986 transmitting NRC Inspection Report No. 50-293/86-19.
Boston Edison was pleased to have the opportunity during this inspection to demonstrate its progress in the area of Radiological Protection improvements at Pilgrim.
He agree with the findings of the inspection team and are taking actions to improve and strengthen each specific and programmatic area. Boston Edison management will continue to place an emphasis on enhancing the communication interface between the Radiological Section and other station groups. Boston Edison management will also continue to refine the Pilgrim Station goals and performance monitoring programs in order to more explicitly define performance expectations, responsibility and accountability.
Actions in response to each specific item identified as an Inspector Follow Item in the subject inspection report are detailed in the attachment to this letter. All commitments made have an associated plan for completion, have been assigned to persons with primary responsibility for commitment implementation, and have been assigned target dates for completion, in accordance with our NRC Commitment Control Program.
8702020682 8701 P ama Osm g2 q,
Mr. Thomas T. Martin Page 2 Please do not hesitate to contact me directly should there be any questions regarding these matters.
Very truly yours, James M. Lydon xc: Dr. M. McBride EM/la Attachment
ATTACHMENT RESPONSE TO INSPECTION REPORT 50-293/86-19 Item 50-293/86-19-01 The documentation of management oversight and control of the radiation protection program has improved. Radiation protection Program procedures and staffing has been upgraded. However, the following significant program weaknesses were brought to the licensee's attention as areas needing improvement:
NRC:
Communications and working relationships between the Radiation Protection Section and other station sections, particularly the Operations Section, needs improvement. This continues to degrade morale with potential impact on operational and radiological safety.
The licensee is acutely aware of this problem and is taking steps to address it.
BOSTON EDISON RESPONSE:
The issue of communications and working relationships among the Radiological Section and other station groups is a matter of acute concern to all management at PNPS. In an effort to improve this relationship we have and will continue to stress the need for frequent, complete and candid information exchange and open discussion of information between all groups.
Recent initiatives have been taken by the operations department to improve the interface with the Radiological Section. The Radiological Section Manager believes that communications have improved as a result of this cooperative effort.
He will stress the need for consistency in conservatively applying both Health Physics and ALARA requirements while being helpful and supportive of efforts to operate and maintain the plant. Since some of the friction appears to result from a belief that adherence to Health Physics requirements is solely l the interest and responsibility of the Radiological Section, each section i manager and the Station Manager are making a positive and aggressive effort to l instill in all employees recognition that each individual is personally l responsible for adherence to good radiological practices. All levels of I management are making efforts to dispell the perception that Health Physics personnel are " policemen" and are encouraging that they be viewed as members of the work team with special skills to enhance work safety. All levels of management have notified their personnel that adherence to good radiological practices is of paramount importance to every section manager not only the radiological section.
l '
NRC:
i The station and section goals program needs upgrading. The current l performance monitoring program does not stress accountability when goals are not achieved. Also, some important parameters do not have accompanying goals. For example, of six radiological controls parameters included in the performance monitoring report, only two have accompanying goals. In addition, of twenty-four parameters tracked in the monthly Radiological Occurrence Report summary, none have accompanying goals. Also some important parameters are not provided to senior management as a performance indicator (e.g. total station area contaminated).
Page 1 of 13
BECO:
To stress accountability, annual personnel performance reivews will contain an assessment of an individual's performance in the area of ALARA.
The performance monitoring program has recently been expanded to include many more parameters and goals where appropriate. Of the six existing radiological parameters, goals will be estabitshed where appropriate. For example goals would not establish for total number of RHPs since this is contingent upon the ,
amount of work being performed. However, goals have been established for total number of RORs.
The information provided to management has been expanded to include items like the amount and degree of contaminated area in the station.
NRC:
Aggressive management action is needed to substantially reduce the number of Radiological Occurrences at the station. Recurrent problems continue to be identified by the Radiological Occurrence Report Program.
BECO:
Increased emphasis and management attention is being directed toward worker compilance with radiological requirements which will reduce the number of ROR's.
NRC:
The Licensee has completed a review of the Radiation Protection Plan and Radioactive Material Control Plan to ensure that appropriate implementing procedures are in place. Some procedural deficiencies were identified. The licensee should ensure all necessary procedures to implement the plans are established and implemented on a timely basis.
BECO:
As part of our Backlog Project we have assigned tasks to review safety evaluations related to onsite storage to ensure that the bases for all procedures have been accurately reflected in the procedures. The principal procedure has been modified to require review of temporary storage areas by fire protection personnel. Although considerable progress has been made in the upgrade of vital procedures, the Radiological Section intends to continue to revise and improve all procedures to ensure compliance and consistency with the Radiation Protection Plan and Radioactive Material Control Plan as part of the Backlog Project.
NRC:
A RIP audit was conducted by the Radiological Oversight Committee and by a contractor. Appropriate milestones should be established for completion of corrective actions for weaknesses identified in both assessments.
BECO:
Each item identified in the RIP implementation audit conducted by our contractor has been scheduled and assigned for action and resolution. Many of these items have already been completed. The remainder are currently scheduled to be completed during the current outage.
Page 2 of 13
' Item 50-293/86-19-02 Although the organization was found to be upgraded, the following items for improvement were identified:
NRC:
The current Radiation Protection Organization is not consistent with that depicted in Technical Specifications. The Technical Specifications should be updated to: 1) depict the correct organization and 2) clearly identify the Regulatory Guide 1.8 qualified Radiation Protection Manager (or equivalent title).
6 BECO:
A proposed Technical Specification change has been prepared which will depict the current Radiation Protection Organization and designate the PNPS position corresponding to the position of Radiation Protection Manager as defined in Reg. Guide 1.8.
NRC:
- Olscussions with cognizant radiation protection personnel indicate that during outage conditions, the section directly reports to the Outage Manager and administratively reports to the Station Manager. This arrangement is not provided for or described in Technical Specifications.
BECO:
1 Boston Edison Licensing Group is evaluating the need to change the Technical Specifications.
NRC:
The Radiation Protection Plan does not describe functional responsibilities for all Radiation Protection Supervisors. The Plan serves as the primary program description document and should be updated to reflect radiation protection supervisor responsibilities.
BECO:
The Radiation Protection Plan will be revised to describe the functional responsibilities of all Radiation Protection Supervisors during the current outage.
NRC:
Responsibilities in the area of radioactive and contaminated material handling need upgrading and distribution to all station sections involved with radioactive material handling, processing and storing. Consideration should be given to establishing a radioactive waste handling, processing and shipping group.
BECO:
The procedure on Radioactive Material Control has been distributed as required reading to all station groups.
A consolidated Radioactive Waste Group has been authorized and is in the process of being staffed. This group will be responsible for all waste generation, processing, packaging and shipping activities.
Page 3 of 13
NRC:
An individual with experience in internal dosimetry should be obtained.
Otherwise the individual supervising the internal dosimetry program should be provided additional training. The current individuals supervising this area have limited experience in internal dosimetry.
BECO:
The newly hired Senior Supervising Engineer, Dosimetry and Respiratory Protection reported to work on 12-29-86. This individual has experience in internal dosimetry and will have available to her the services of a Certified Health Physicist with substantial training and experience in internal dostmetry. Additionally, an internal dosimetry course is being administered to approximately 20 members of the Radiological Section.
NRC:
The Senior Radiological Engineer - ALARA position is vacant. This position should be filled in a timely manner by a qua11 fled individual.
BECO:
He are currently searching for and interviewing candidates for the position of Senior ALARA Engineer. Every reasonable effort will be made to hire a qualified individual as expeditiously as possible.
E:
Personnel are being moved to other positions in the radiation protection technical support area. Movement of personnel in this area should be finalized in a timely manner in order to stabilize and provide consistent oversight of technical support functional area responsibilities.
BECO:
We are in the process of optimizing the assignment of personnel in order to focus management oversight and technical competence in those areas which require the greatest improvement. We will make every reasonable effort to formalize these adjustments promptly. He believe that the present organization is adequate to meet the needs of PNPS for the foreseeable future and we expect to stabilize its structure within the next 2 months.
Item 50-293/86-19 Licensee personnel indicated that the following matters would be reviewed:
E:
i The inspector noted that the board used for posting of notices to workers (as required by 10CFR 19.11) at the main control point was not in a location conspicuous to individuals entering the controlled area using the access route
! from the Administration building. The licensee stated that the board had been recently moved during facility modifications and would be relocated to a more conspicuous location.
' BECO:
i l The board used for posting of notices to workers at the main control point has i been relocated. It is now located in the New Administration Building, i immediately next to the doorway providing access to the controlled area.
Page 4 of 13 l
NRC:
Inspector noted discrepancies between the qualification requirements specified
, in the training manual and those in the individual position descriptions. The position description for the chief radiological engineer is not consistent with the qualification description in the training manual. Also, an apprentice radiation protection technician is not described in the training manual.
BECO:
The qualification listed in the individual position descriptions are generally more stingent and more recent than those in the training manual. The training manual will be updated as part of the Backlog Project.
N,RQ:
The training manual, section 3.5.4, describes the qualification prerequisites for entry level. Paragraph 3.5.4.1 states that all HP technicians hired into the Boston Edison Company will meet the ANSI N18.1 requirements. The description as to what Boston Edison considers adequate to meet the training and experience requirements is not consistent with ANSI N18.1.
BECO:
The training manual.Section 3.5.4, will be revised if necessary to reflect the description of training and experience requirements of ANSI N18.1 by 4/1/86.
Item'50-293/86-19-04 The following program weaknesses were discussed with licensee's management for appropriate action:
NRC:
Communication between the RP group and operations and maintenance groups is vital for the proper operation of a RWP control system. The frequent use of Priority "A" RWPs, the large number of RWPs requested and approved that do not get worked, and the failure to notify the RP group when work is complete, indicated communication problems and a lack of a strong management oversight to ensure efficient and safe conduct of radiological operations.
BECO:
As previously stated in response to Item 50-293/86-19-01, communications and working relationships among the Radiation Protection Section and other station groups is a matter of acute concern. In an effort to improve the efficiency of the RWP system, we will continue to stress the need for frequent, complete and candid exchange of perceived problems and possible solutions. RWP usage rates are now trended and lists of those persons not using RWPs, once issued, is presented to station management for remedial action.
Station management is strongly committed to a work management system, incorporating the RWP process in work planning and performance. Full implementation of this system is expected to achieve among other objectives, an increase in the efficiency of implementation of the RWP system.
Page 5 of 13
Itea 50-293/86-19-05 Licensee personnel indicated the following matter would be reviewed:
NRC:
Review of the 1986 RORs indicated a recurring problem with maintaining LHRA access points locked. The gate to the RWCU pump room found unlocked in this inspection had been previously found unlocked and unguarded by an NRC inspector this year. Repeat occurrences of the N.W. gate on the 51' level of the Turbine Building being found unlatched were also noted. These occurrences indicate that the licensee's systems for diagnosing a root cause, necessary for proper corrective action, needs improving. In discussions with RP supervision the licensee indicated they would investigate whether they had a generic problem with the LHRA mechantsms.
BECO:
4 The recurring issue of unlocked high radiation area doors will be corrected by
- 1) improving the system for identifying individual (s) by name who have possession of high radiation keys and 2) employing disciplinary action (s) where necessary to increase individuals' appreciation for the importance of key control and locked high radiation area doors. These actions are presently in progress. We have also instituted the practice of auditing LHRA every four hours to ensure that all areas are properly controlled.
NRC:
During the review of the keys controlled by the operations group, the inspector interviewed one watch engineer / shift supervisor, a senior reactor operator and the technical assistant involved in LHRA key issuance. The watch engineer interviewed displayed a lack of knowledge of the control and issuance procedures of the keys administratively under his control. A review of the key issuance log did not indicate that any key was issued to unauthorized personnel.
BECO:
A recent policy has been issued by the Operations Section Manager to clarify the Watch Engineers' responsibilities in the matter of high radiation area key control.
NRC:
Controlling procedure 6.1-012 does not reflect the requirements for entry into high radiation areas specified in TS 6.13.1. This procedure leads the reader to believe that continuously indicating radiation monitoring devices are only l required for entrance into areas of greater than 10,000mR/hr contrary to the TS (which require them in areas of 100 mR/hr or greater). Although these requirements are listed in the RWP issuance procedure (No. 6.1-022) referenced in 6.1-012, this may lead to some confusion with plant personnel. During GET
! for initial access to the plant, the NRC inspectors were told by the instructor that having a continuously indicating monitor was in fact not required unless entering an area of greater than 10,000 mR/hr.
I BECO:
Both the procedure in question and the GET course will be corrected to accurately reflect Technical Specification Requirements.
Page 6 of 13
itel 50-293/86-19-06 The following matters and concerns were discussed with the licensee during the inspection and the licensee indicated that they are being addressed:
NRC:
Completion of dosimetry procedure revisions and implementation.
Complete development and implementation of the new dosimetry training program.
Completion of personnel dosimetry staffing (2 additional staff members).
Complete resolution of outstanding technical issues as discussed above.
Complete arrangement to perform offsite irradiation of TLD dosimeters for use in QA/QC.
BECO:
All of the five items are scheduled to be completed prior to 3/31/87.
Item 50-293/86-19-07 The licensee indicated the following matters would be reviewed:
NRC:
The licensee had established a procedure for in vitro monitoring for internal exposure controls. However, specific instructions for obtaining fecal samples, and the appropriate analyses for certain isotopes such as transuranics had not been developed at the time of the inspection.
BECO:
Necessary procedures for in vitro monitoring are scheduled to be developed and implemented during the current outage. These procedures will provide the necessary detail.
NRC:
The establishment of procedures for comparison of air sample results, whole body count data and respiratory protection would be considered.
BECO:
i Procedures for comparison of air sample results and whole body count data are being prepared and are scheduled to be implemented during the current outage.
NRC:
The appropriate guides and standards for determination of intake of radioactive material have not been referenced in procedures.
BECO:
The appropriate references have been incorporated into the procedure.
Page 7 of 13
Ite7 50-293/86-19-08 NRC:
The routine plant radiation, contamination and airborne radioactivity surveillance program is adequate. However, the program procedures do not provide guidance for modifying the program as a result of changes to the radiological environment (e.g. modification of surveillance program following leaking fuel or high coolant activity).
BECO:
The procedures are scheduled to be improved to provide guidance for modifying the program when warranted by extraordinary situations by 2-15-87.
Item 50-293/86-19-09 The ALARA program contains the following weaknesses:
NRC:
Need for improving inter- and intra- departmental working relationships and communication.
BECO:
Boston Edison management is continuing to provide emphasis on inter- and intra-departmental working relationships and communication through various initiatives. Examples of these initiatives are:
1.) The recent restructuring of daily morning inter-departmental meetings.
2.) The recent designation of the Station Manager as chairman of the ALARA Committee.
NRC:
Lack of effective meetings by the ALARA Oversight Committee, and too few meetings by the ALARA Committee.
BECO:
Improvement in the effectiveness of the meetings of the ALARA Committee is evolutionary in nature and is expected to increase as more meetings are held i
and meeting agenda more clearly defined. The recent designation of the l Station Manager as chairman of the ALARA Committee and future consolidation I with the ALARA Oversight Committee is expected to both improve the I effectiveness of this committee and improve inter-departmental communications and effectiveness of the ALARA program. Monthly meetings of the ALARA Committee are planned for the future.
NRC:
Need for challenging section goals and additional initiatives for dose reduction, and vigorous program followup and implementation to achieve these goals.
Page 8 of 13 l
i l
,q - ,.- - -- - - - - , -
1ECO:
Challenging exposure goals for the various station organization sections have been established by the Radiation Protection organization working closely with the individual sections. Progress toward these exposure goals is tracked by the Radiation Protection organization and reported to the various sections and BECo management.
NRC:
Need for complete development and/or implementation of procedures.
BECO:
Progress toward development and implementation of procedures is continuing, as before, with the highest priority <
Item 50-293/86-19-10 The reviews of this area indicated the licensee has substantially improved his oversight and control of radioactive and contaminated material. Instances of improper storage, spillage or identification of unexpected contamination of normally non-contaminated areas are addressed via the radiological occurrence report system. Despite these improvements, weaknesses in some aspects of the program were identified. The licensee indicated the following matters would be reviewed:
NRC:
An unapproved, unreviewed instruction is being used by maintenance personnel to provide guidance for decontamination and storage of contaminated tools.
Licensee personnel indicated the instruction will be reviewed and its information will be incorporated into the Radioactive and Contaminated Material Control Program.
BECO:
The Maintenance Section plans to formalize the instructions used for tool control and decontamination.
MC:
The current radioactive and contaminated material storage program does not contain adequate provisions to ensure that the types and quantities of material stored comply with the limitations imposed by applicable safety evaluations. Licensee personnel indicated that provisions would be included in applicable procedures to ensure that the types and quantitles of material stored are within applicable safety evaluations.
Page 9 of 13
. a BECO:
Applicable safety evaluations will be reviewed to determine what limits on the quantitles of stored radioactive material is appropriate for each permanent storage area of the plant. Existing procedures will be modified to require that estimates of the total activity of each. component will be made to insure compliance with storage limits. Limits and components will be considered which present a safety hazard due to accidental fire or similar circumstances. This review and applicable procedure changes is scheduled to be completed during the current outage.
NRC:
It is not apparent that procedures for establishment of new radioactive and contaminated material storage areas provide for all applicable safety reviews (e.g. seismic loading, fire protection) prior to establishment of the area.
Licensee personnel indicated the procedures for establishment of new storage locations would be reviewed to ensure that all applicable reviews are performed consistent with NRC guidance (e.g. Generic Letter 81-38).
BECO:
The requirement for a fire protection review has already been incorporated into the applicable procedures. The need for review for seismic or floor loading concerns will be evaluated. This evaluation is scheduled to be completed during the current outage.
NRC:
All procedures for receipt of radioactive material did not ensure that appropriate surveys required by 10 CFR 20 would be performed within the time constraints specified therein. Licensee personnel indicated security procedures would be revised to ensure radiation protection personnel are notified of receipt of radioactive material in a timely fashion to allow them to perform package surveys within 10CFR20 time constraints.
BECO:
Security procedure 2.01 is now being revised to require timely notification of a Health Physics Supervisor whenever radioactive material arrives at any gate. -
NRC:
Procedures for release of material offsite do not discuss loose or fixed alpha contamination, surveys of inaccessible areas, types of alternative surveys for "non-routine" material released (e.g. soll) off. site; or lower limits of detection for this non-routine material.
Page 10 of 13 l
i l
'"BECO:
i This procedure has been modified to address these concerns. The issue of de-minimus measurements as they apoly to the release of " clean" or
" contaminated" material such as dirt has not yet been resolved.
NRC:
Procedures for " direct frisk" of material do not take into consideration mixtures of beta-gamma nuclides and counting efficiencies to be realized for variations in mixtures.
BECO:
Our procedures have already been modified to specify that any activity of any and all nuclides that result in greater than 100 cpm above background is unacceptable for release.
NRC:
Procedures for counting alpha contamination smears do not address self-absorption corrections.
BECO:
We have developed a basis for an alpha self absorption factor of 1.5 and are including the factor in the appropriate procedures. These procedures are scheduled to be revised during the current outage.
Item 50-293/86-19-11 The following were considered minimally acceptable. However, the licensee indicated that they will be re;iewed for possible improvement:
NRC:
Adequacy of the activities of the well and open calibrators to cover the full range of instrument calibrations.
BECO:
We have ordered a new high range calibrator to permit calibration of the upper ranges of all instruments. He expect del.tvery of this unit within the next 3 months.
NRC:
Adequacy of the method of using the well calibrator to calibrate instruments considering scattered radiation.
BECO:
The accuracy of the existing calibrator will be determined by using an NBS traceable device.
Based on the results of this determination we will evaluate the need for a free air calibrator. He expect to complete this evaluation by 1-31-87.
Page 11 of 13
'NRC:
Adequacy of the calibration facility, or room, to house higher activity sources if the current sources are upgraded.
BECO:
The adequacy of the temporary calibration facility to house high activity sources will also be determined by 2-28-87.
Item 50-293/86-19-12 The following areas were considered minimally acceptable. However, the licensee indicated that they will be reviewed for possible improvement:
NRC:
Improvements in current QA/QC practices.
BECO:
He are presently reviewing current QA/QC practices as part of the Backlog Project.
NRC:
Improvements in supervisory review of counting laboratory data, particularly daily QA data.
BECO:
Supervisory review of counting laboratory data has been improved and will continue to receive close attention.
NRC:
Need for additional counting equipment.
BECO:
With the help of an INPO assistance visit we have determined the need for additional counting equipment. He are currently soliciting proposals for a low background alpha - beta counting system. No additional equipment is presently anticipated.
NRC:
Development of a technical bases manual or document to record the technical bases for certain practices, such as for example the choice of quality control chart limits, methods of calculating LLD or MDA, specification of the conditions under which the LLD and MDA are used, and so on.
BECO:
All of this information will be incorporated into existing procedures.
Revision of these procedures is expected to be performed during the current outage.
Page 12 of 13
" Item 50-293/86-19-13 The following program areas which need improvements were discussed with licensee personnel. The licensee indicated these would be reviewed:
NRC:
The licensee currently only has one size mask for respiratory protection.
Therefore, there will be some individuals who will not fit properly in the standard respirator facepiece. The licensee is considering purchase of additional respirator facepiece sizes to accommodate personnel with large or small faces to ensure proper respirator fit. Personnel who cannot be fit are not permitted to wear respirators.
BECO:
l' The final evaluation on the practicability and effectiveness of using different size respirators will be completed by 1/31/87.
NRC:
Respirators were stored more than two respirators high, and respirator head straps were pulled over the faceplete visor for storage. These two practices have been found to potentially deform the sealing surfaces of the respirator faceplece. The licensee stated that these two practices will be discontinued and respirator training will be revised to instruct workers on donning of respirators without pulling headstraps over the facepiece.
BECO:
The practice of stacking respirator more than two high and pulling head straps over the facepiece has been discontinued. Respirator training will be revised to instruct workers on donning of respirators without pulling head harness straps over the facepiece by 1/31/87.
Page 13 of 13
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