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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10CFR2.790 ML20212F7871999-09-24024 September 1999 Advises That Util 990121 Application for Amend Being Treated as Withdrawn.Proposed Changes Would Have Modified Facility UFSAR Pertaining to Values for post-accident Containment Pressure Credited in Pilgrim Net Positive Head Analyses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:NRC TO UTILITY
MONTHYEARML20062E0071990-11-14014 November 1990 Forwards List of Unimplemented GSIs at Facility,Per Generic Ltr 90-04 ML20062D6651990-11-0808 November 1990 Ack Receipt of Forwarding Util Evaluation of NRC Inspector General Rept 90N-02 Re Offsite Emergency Planning ML20058G9761990-11-0707 November 1990 Forwards Safety Insp Rept 50-293/90-20 on 900816-1008 & Notice of Violation ML20058C5501990-10-26026 October 1990 Requests Written Policies & Procedures Needed for NRC Preparation for Planned fitness-for-duty Insp ML20062B4311990-10-17017 October 1990 Advises That 901012 Response to Generic Ltr 90-03 Re Vendor Interface for safety-related Components,Acceptable ML20062B7161990-10-12012 October 1990 Extends Invitation to Attend 910220-21 Util Symposium/ Workshop in King of Prussia,Pa Re Engineering Role in Plant Support.Interest to Participate,Intent to Attend & Approx Number of Representatives to Attend Requested by 901115 ML20062B6281990-10-12012 October 1990 Forwards Insp Rept 50-293/90-21 on 900905-07.Insp Conducted to Review Event of 900902-03 Which Involved Number of Component Malfunctions & Operational Complications Following Shutdown ML20059N7251990-10-0101 October 1990 Requests That Matls Listed in Encl Be Furnished to Assist Maint Program Team Insp Scheduled for 901105-16 ML20059K6901990-09-11011 September 1990 Forwards Transcript of 900906 Public Meeting in Plymouth,Ma W/State & Local Officials Re Emergency Planning.W/O Encl ML20059H5871990-09-0101 September 1990 Advises That Reactor Operator & Senior Reactor Operator Exams Scheduled for 901203.Encl Listed Ref Matl Requested ML20059J6521990-08-29029 August 1990 Forwards Safety Insp Rept 50-293/90-09 on 900806-10.No Violations Noted.Concludes That Engineering & Technical Support Organizations Continue to Provide Strong Station Support ML20059A1481990-08-17017 August 1990 Forwards 900816 Summary of 900807 Meeting Re Inservice Testing Program ML20058P0471990-08-0909 August 1990 Forwards Safety Insp Rept 50-293/90-18 on 900709-13.No Violations Noted ML20058N0401990-08-0606 August 1990 Discusses Licensee Engineering Initiatives.Power Reactor Licenses in Region 1 Should Initiate Similar Program to Provide Sharing of Info & Experiences Involving Engineering Initiatives & Solution to Problems Common to All ML20056A4801990-07-30030 July 1990 Forwards Safeguards Insp Rept 50-293/90-16 on 900625-29.No Violations Noted.One Unresolved Item Identified ML20058L7051990-07-27027 July 1990 Forwards Safety Insp Rept 50-293/90-17 on 900625-29.No Violations Noted ML20055F2461990-06-29029 June 1990 Forwards Safety Insp Rept 50-293/90-13 on 900501-0611.No Violations Noted.Repetitive Failures of Diesel Driven Fire Pump Noted,Requiring Increased Mgt Attention ML20059M8421990-06-13013 June 1990 Forwards NRC Performance Indicators for First Quarter 1990. W/O Encl ML20247R8071989-09-21021 September 1989 Forwards SALP Rept 50-293/88-99 for 880516-890630.Instances of Deviation from Approved Practices & Lack of Attention to Detail Which Led to Challenges to Plant Equipment & Personnel Noted ML20247K6661989-09-0707 September 1989 Forwards Insp Rept 50-293/89-07 on 890525-0710 & Notice of Violation ML20246K5091989-08-24024 August 1989 Accepts Summary of QA Program Description Changes for 1989, Forwarded by ML20246L7821989-08-23023 August 1989 Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $25,000.Failures to Properly Plan, Supervise & Inspect Tagout of Circuit Breakers Directly Contributed to Event ML20246D7261989-08-18018 August 1989 Submits Response to Re Plant Power Ascension Program.Util Proposal to Defer Phase 2 of Shutdown from Outside Control Room Test to Planned Fall 1989 mid-cycle Outage Accepted IR 05000293/19890071989-08-18018 August 1989 Approves Reactor Operation Up to 75% of Full Power Per Licensee Power Ascension Test Program.Nrc Findings Docketed in Insp Repts 50-293/89-07 & 50-293/89-08 & Status of Emergency Preparedness for Communities Encl ML20246J4811989-08-18018 August 1989 Clarifies NRC Position Re Definition of Extremity for Purposes of Setting Occupational Exposure Limits.Due to Misunderstanding,No Enforcement Action Planned If Licensee Procedures Incorporated Misunderstanding ML20246G1861989-08-18018 August 1989 Approves Reactor Operation Up to 75% of Full Power Per Licensee Power Ascension Test Program.Nrc Findings Docketed in Insp Repts 50-293/89-07 & 50-293/89-08 & Status of Emergency Preparedness for Communities Encl ML20245F1781989-07-31031 July 1989 Forwards Insp Rept 50-293/89-06 on 890411-0524.No Violations Noted.Licensee Actions W/Respect to 890503 Turbine Trip/Reactor Scram Demonstrated Excellent Approach to Problem Investigation & Resolution ML20247D0181989-07-18018 July 1989 Ack Receipt of Re Response to NRC Bulletin 89-003, Inadequate Latch Engagement in Hfa Type Relays Mfg by Ge. Necessary Actions Performed to Address Issues in Bulletin ML20246N3921989-07-14014 July 1989 Forwards Safety Insp Rept 50-293/89-09 on 890619-22.No Violations Noted ML20246D4961989-07-0606 July 1989 Advises That 880713 Response to NRC Bulletin 88-004, Potential Safety-Related Pump Loss Acceptable ML20246A7561989-06-26026 June 1989 Approves Reactor Operation Up to 50% Full Power,Per Util Power Ascension Test Program & Confirmatory Action Ltr 86-10.Assessment of Licensee Readiness for Release from NRC Approval Point 3 & Related Info Encl ML20246B5961989-06-22022 June 1989 Forwards,For Info,Nrr Ack Receipt of Petition Filed by Ecology Ctr of Southern CA & Stating That Petition Being Treated Under 10CFR2.206 of Commission Regulations ML20245A5371989-06-0909 June 1989 Forwards Insp Rept 50-293/89-05 on 890311-0410.Weaknesses Noted Re Evaluation of Failure Rate & Root Causes for Failures of Airlock Doors & Interlocks ML20244C2121989-06-0707 June 1989 Responds to Util 881011 Response to Generic Ltr 87-02, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors. Implementation Schedule Contingent Upon Resolution of Procedure ML20244C2751989-06-0606 June 1989 Forwards Draft Safety Evaluation Re Plant Compliance W/ 10CFR50.62, ATWS Rule. Requests Response to NRC Concerns Re Diversity & Testability of Alternate Rod Injection & Reactor Pump Trip Sys NUREG-1275, Informs That Util Fulfilled Requirements of Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety Related Sys1989-06-0202 June 1989 Informs That Util Fulfilled Requirements of Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety Related Sys ML20247P5501989-06-0101 June 1989 Forwards Request for Addl Info on Proposed Tech Specs Change Re Visual Insp of High Energy Piping.Listed Concerns Based on Review of Bechtel Calculation 17322-S5,Rev 1 ML20247M2661989-05-26026 May 1989 Forwards Director'S Decision,Ltr of Transmittal & Fr Notice in Response to Ocre 2.206 Petition Expressing Concerns Re 880309 Power Oscillation Event at LaSalle Unit 2 & Request to Reopen Rulemaking on ATWS Issue.W/O Encls ML20246P6051989-05-15015 May 1989 Forwards Notice of Withdrawal of Application for Amend to License DPR-35.Amend Would Modify Tech Specs Re ECCS Surveillance Requirements ML20247D5481989-05-0808 May 1989 Forwards Augmented Insp Team Rept 50-293/89-80 on 890413-19 & 17-26.Team Concluded That Safety Significance of 890412 Pressurization Transient Was Minor,Though Event Raised Concerns Re Proximate Human Factors & Equipment ML20246N7951989-05-0404 May 1989 Forwards Mgt Meeting Rept 50-293/89-04 on 890328-30 W/Commonwealth of Ma & Local Officials ML20247A6911989-05-0303 May 1989 Extends Invitation to Attend Power Reactor Operator Licensing Seminar on 890531 in King of Prussia,Pa.Agenda & Info Re Lodging Arrangements Encl ML20245H8371989-04-26026 April 1989 Forwards SAIC-89/1121, In-Progress Audit Rept of Dcrdr at Boston Edison Co Pilgrim Nuclear Power Station & SAIC-89-1119, In-Progress Audit Rept for Boston Edison Co Pilgrim Nuclear Poser Station Spds ML20245H9551989-04-26026 April 1989 Forwards Insp Rept 50-293/89-01 on 890206-0310 & Notice of Violation ML20245J1441989-04-25025 April 1989 Advises That 880921 & 890302 Responses to NRC Bulletin 88-007 & Suppl 1, Power Oscillations in BWRs Meet Requirements of Both Bulletins ML20244E4611989-04-14014 April 1989 Requests Prompt Review & Reporting of Status of Implementation of TMI Action Plan Items at Facility.Printout of All TMI Items Annotated Where Tracking Sys Indicates That Implementation Not Complete Encl ML20244C2771989-04-10010 April 1989 Informs of Completion of Followup on Plant Regulatory Effectiveness Review Effort & Activities Re TAC 56995. Previous Compensatory Measures Removed as Result of Implementing Corrective Action ML20244A6931989-04-0707 April 1989 Forwards Mgt Meeting Rept 50-293/89-43 on 890309 to Discuss Util Followup Actions to 890304 Reactor Scram ML20244A6281989-04-0303 April 1989 Forwards Insp Rept 50-293/88-37 on 881227-890205.Violation Noted Re Failure to Control Locked High Radiation Area Access ML20236A8451989-03-0303 March 1989 Approves Reactor Operation Up to 25% of Full Power Per Util Power Ascension Test Program & Confirmatory Action Ltr 86-10.Urges Util to Cooperate W/Commonwealth of Ma & Local Govts to Further Improve State of Emergency Preparedness 1990-09-11
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217D3951999-10-13013 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 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 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 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) ML20211H5701999-08-27027 August 1999 Forwards Insp Rept 50-293/99-04 on 990610-0725.Two Violations Identified Being Treated as non-cited Violations ML20210U7521999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opossing 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 ML20210U6691999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opposing Merger Between Bec Energy & Commonwealth Energy Systems 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 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 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 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) 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 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 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 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) ML20195K3071999-06-15015 June 1999 Forwards Safety Evaluation Granting Licensee Request to Use Guidance of GL 90-05 to Repair Flaws in ASME Class 3 Salt Svc Water Sys Piping for Plant ML20195K3851999-06-11011 June 1999 Forwards Copy of Notice of Consideration of Approval of Application Re Proposed Corporate Merger & Opportunity for Hearing.Application Seeks Approval of Proposed Indirect Transfer of FOL for Plant ML20196K9921999-06-0404 June 1999 Informs That NRC Ofc of NRR Reorganized Effective 990328.As Part of Reorganization,Division of Licensing Project Mgt Created ML20207E7351999-05-27027 May 1999 Responds to Requesting Reduction in IGSCC Insp Frequency Per GL 88-01 to Be Performed During Upcoming RFO 12.Forwards SE Re Reduction of IGSCC Insp of Category D Welds Due to Implementation of H Water Chemistry ML20207B6341999-05-26026 May 1999 Informs That Licensee 990415 Submittal Re Financial Position of Entergy Intl Ltd,Llc Will Be Marked as Proprietary & Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b) of Atomic Energy Act ML20207B7391999-05-24024 May 1999 Forwards from Kc Goss of FEMA to Cl Miller Forwarding FEMA Analysis of Prompt Alert & Notification Sys for Pilgrim Nuclear Power Station.Based on Review,No Significant Problems Exist with Alert & Notification Sys ML20207B0701999-05-24024 May 1999 Responds to Sent to Ofc of Congressional Affairs Requesting Info on Concerns Raised by One Constituent,J Riel Re Y2K Compliance of Pilgrim NPP in Plymouth,Ma ML20207C0321999-05-18018 May 1999 Forwards Fifth Rept Which Covers Month of Apr 1999. Commission Approved Transfer of TMI-1 Operating License from Gpu to Amergen & Transfer of Operating License for Pilgrim Station from Beco to Entergy Nuclear Generating Co ML20206U7501999-05-17017 May 1999 Forwards Insp Rept 50-293/99-02 on 990308-0418.Two Severity Level 4 Violations Occurred & Being Treated as NCVs ML20206M1891999-05-11011 May 1999 Forwards SE of 980826 Request to Use Guidance of GL 90-05 to Repair Flaws in ASME Class 3 Salt Svc Sys Piping for Plant ML20206E0551999-04-29029 April 1999 Discusses Bulletin 96-03 Issued on 960506 & Beco Responses ,970207,981230,990121 & 990309 for Pilgrim Npp. Determined That Actions Taken Should Minimize Potential for Clogging of ECCS Suction Strainers ML20206B3031999-04-20020 April 1999 Forwards Insp Rept 50-293/99-01 on 990125-0307.Two Violations of NRC Requirements Occurred & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy.Security Program Was Also Inspected ML20205Q9491999-04-0909 April 1999 Informs That on 990225 NRC Staff Completed PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Develop an Integrated Understanding of Safety Performance ML20205B9391999-03-24024 March 1999 Forwards Second Request for Addl Info Re GL 95-07, Pressure-Locking & Thermal-Binding of Safety-Related Power-Operated Gate Valves ML20204C7871999-03-17017 March 1999 Informs That Application Submitting Transfer of Facility Operating License & Matls License & Proposed Amend, Will Be Marked as Proprietary & Be Withheld from Public Disclosure Pursuant to 10CFR2.709(b)(5) ML20199K8321999-01-22022 January 1999 Forwards Request for Addl Info Re Transfer of Facility Operating License for Plant ML20199H5811999-01-20020 January 1999 Submits Exemption Withdrawal of 10CFR70.24(a) Re Criticality Accident Monitoring Requirements ML20198L7781998-12-22022 December 1998 Forwards Insp Rept 50-293/98-10 on 981020-1208.No Violations Noted.Nrc Regional Specialists Reviewed EP & Fire Protection Programs.Ep Program Was Found to Be Well Implemented ML20198J0891998-12-21021 December 1998 Forwards NRC Response to Me Lampert Re Transfer of Ownership of Pilgrim Station in Response to Senator Kerry Ltr Dtd 981019.NRC Will Terminate License Only When Licensee Remediates Site to Levels Specified in Regulations ML20198J1041998-12-21021 December 1998 Forwards NRC Response to Me Lampert Re Transfer of Ownership of Pilgrim Station in Response to Congressman Markey Ltr Dtd 981019.NRC Will Terminate License Only When Licensee Remediates Site to Levels Specified in Regulations ML20137T2211998-12-17017 December 1998 Responds to to Chairman Jackson Re Concerns About Possible Sale of Pilgrim Station & Waste Disposal Issues.No Application for License Received Nor Contract of Sale Between Beco & Entergy.Record Copy ML20198J1161998-12-17017 December 1998 Responds to to Chairman Jackson in Which Recipient Expressed Concern About Possible Sale of Pilgrim Station & About Waste Disposal Issues.Nrc Has Not Received Application for Transfer of License to Date ML20198P2781998-12-17017 December 1998 Final Response to FOIA Request for Documents.Forwards App a Records Being Released in Entirety.App B Records Being Withheld in Entirety (Ref FOIA Exemption 4) ML20198B2021998-12-0909 December 1998 Advises of Planned Insp Effort Resulting from Licensee Irpm Review.Details of Insp Plan for Next 6 Months & Historical Listing of Plant Issues Encl ML20197H8521998-12-0909 December 1998 Responds to Ltr Sent to Chairman SA Jackson on 981028 Re Concern That NRC Will Not Perform Environ Assessment in Connection with Consideration of Approval of Transfer of License for Plants to Permit Sale ML20196J1201998-12-0404 December 1998 Ack Receipt of 971217 & 30 & 980112,0309,0423 & 0630 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-293/97-02,50-293/97-11,50-293/97-13, 50-293/97-80 & 50-293/98-01.Actions Found Acceptable ML20196B5421998-11-24024 November 1998 Forwards Plant SRO & RO Initial Exam Rept 50-293/98-301OL During Wk of 981016-23 ML20196F7631998-11-24024 November 1998 Forwards Insp Rept 50-293/98-203 on 980928-1023.No Violations Noted.Three Issues Identified Re Containment Flooding,Surveillance Testing Criteria & Protection for RBCCW System from High Energy Line Break Inside Drywell ML20196C1191998-11-20020 November 1998 Forwards Insp Rept 50-293/98-08 on 980907-1019.No Violations Noted.During Insp Period,Chemical Decontamination of Residual Heat Removal Sys Was Well Planned & Implemented Which Reduced Radiation Doses in Heat Removal Quadrants ML20195H7361998-11-16016 November 1998 Informs of Individual Exam Results for Applicants on Initial Exam Conducted on 981016 & 981019-23 at Facility.Nine Applicants Were Administered Exam & Nine Passed.Licenses Issued & Individual Test Results Encl.Without Encl ML20155C4781998-10-29029 October 1998 Forwards RAI Re Resoultion to GL 96-06 Issues at Plant,Unit 1.Response Requested by 981130 ML20154J7881998-10-0808 October 1998 Authorizes Mb Santiago to Administer Initial Written Exams to Applicants Listed (Except Applicants Redlined), on 981016.NRC Region I Operator Licensing Staff Will Administer Operating Tests During Week of 981019 1999-09-30
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Inspection Report - Pilgrim - 1984044 |
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JUN 2 61985 Docket No. 50-293 EA 85-18 Boston Edison Company M/C Nuclear ATTN: Stephen J. Sweeney President 800 Boylston Street Boston, Massachusetts 02199 Gentlemen:
Subject: Notice of Violation (NRC Inspection Nos. 50-293/84-44 and 50-293/85-02)
Your letter of April 5,1985 (BECo Ltr No.85-068) transmitted your response to the Notice of Violation (NOV) enclosed wita our letter dated March 6, 1985.
Thank you for providing us the corrective and preventive actions discussed in your letter. We will review the implementation of these actions during a future inspection.
In your letter, you (1) requested that Item A.1.a be eliminated as a violation or at least be reduced in Severity Level; (2) requested that the Severity Level of Items A.1.b, A.1.c, A.2 and B be reduced; and (3) disagreed with our characterization that the primary cause of the incident was a lack of radio-logical controls management oversight.
The NRC maintains that the violations were appropriately classified in the aggregate so as to focus on the underlying cause, namely, a lack of adequate oversight of radiation protection activities as evidenced by multiple and recurrent failures to adhere to procedural requirements. The NRC also main-tains that classification of this aggregate problem at Severity Level III is appropriate because the violations are associated with an event in which a substantial potential existed for an exposure in excess of the regulatory limit. This potential existed because an individual entered a tank where high radiation levels existed, in careless disregard of procedural requirements. The radiation levels inside the tank had not been predetermined and the individual was not in possession of radiation survey instrumentation to limit stay times, and licensee surveillance of this work activity was not being performed.
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As you are aware, procedural adherence in the area of radiation protection has been a continuing problem at Pilgrim over the last 18 months. In April 1984, a
$40,000 civil penalty was issued, and in November 1984, an Order Modifying License was issued, for two separate incidents involving a substantial potential for an exposure in excess of the regulatory limit because of a failure to follow procedures. In your response to the second incident, you appropriately concluded that the cause was not only a failure to follow procedures but failure to pro-vide adequate oversight to ensure procedural adherence. This latest incident, which includes additional examples of failure to adhere to procedures, further demonstrates the need for improved oversight of radiation protection activities.
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OFFICIAL RECORD COPY CP PKG PILGRIM - 0001.0.0 8507020402 850626 06/25/85 g PDR ADOCK 05000293 ,
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Boston Edison Company JUN 2 61985
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M/C Nuclear 2 We emphasize that licensees are not only responsible for development of a satisfactory radiation protection program, establishment of adequate procedures to implement the program, and training of personnel in expected performance, but are also responsible for maintaining adequate oversight of employee and contractor activities and control of this program and those of their con-tractors to assure adherence to program requirements , identification of devi-ations, and the implementation of prompt corrective actions to resolve identi-fied problems and to prevent recurrence.
In addition to the multiple examples of failure to follow procedures specified in Item A, one of the violations, Item B, involved failure to establish a proce-dure describing how to use a remote reading teledosimetry system to perform radiological monitoring of personnel working in high radiation areas. Such procedures, required by the Technical Specifications, are normally established to meet the procedure establishment requirements of Regulatory Guide 1.33 which is incorporated by reference into your Technical Specifications and would normally contain guidance as to: (1) maximum whole body radiation dose rates such a system could be used in; (2) allowable dose rate gradients the system can be used in; (3) proper positioning of the teledosimeter on an individual; (4) frequency of checking dose accumulation of the system; (5) methods of periodically verifying proper operation of the system while it is being used; (6), allowable accumulated exposure an individual could accumulate using the system as the primary real-time monitoring device and; (7) acceptable methods for notifying an individual wearing a teledosimeter that he has received his allowable exposure and is required to exit the high radiation area. This latter item is particularly important because the teledosimetry device used by Boston Edison was not an alarming dosimeter. An alarming dosimeter was required by your Technical Specifications.
At the time of this event, Boston Edison had in place a procedure which clearly described methodology for performing radiation monitoring in high radiation areas. Your procedures required that this monitoring be performed by a radio-logical controls technician with a survey meter at a frequency specified on the Radiation Work Permit. No other procedures were established which described an alternate methodology for performing monitoring of personnel working in high
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Our review of the circumstances surrounding Item B found that a contractor
- Radiological Controls Supervisor elected, on his own initiative, to eliminate the procedurally described high radiation area monitoring requirements incor-
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porated into the RWP used for sludge lancing, and use an alternate methodology (i.e. the teledosimetry system). This action by the contractor supervisor reduced the quality of the high radiation area controls established for sludge lancing because: (1) although a procedure was in place which described set-up of the teledosimetry system, no procedure guidance was in place explaining how to use the device for actual monitoring of personnel working in high radiation areas, and (2) periodic visual oversight of an individual working independently
, in a high radiation area was no longer being performed.
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OFFICIAL RECORD COPY CP PKG PILGRIM - 0001.0.1 06/25/85
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- ' JUN 2 61985 M/C Nuclear 3 The violations discussed above, some of which occurred over several days, demonstrate that at the time of the incident, both workers and supervisors violated radiological control program procedure requirements and no effective management control system was in place to readily identify these violations and initiate appropriate, timely, and comprehensive corrective action. These items further demonstrate the importance of improved oversight of radiation protection activities.
If you have any additional questions or comments, please contact me. No reply to this letter is required. Your cooperation with us is appreciated.
Sincerely, Origi'nal signed by Tho=as E. Murley Thomas E. Murley Regional Administrator CC:
A. V. Morisi, Manager, Nuclear Management Services Department C. J. Mathis, Station Manager Joanne Shotwell, Assistant Attorney General Paul Levy, Chairman, Department of Public Utilities W. J. Nolan, Chairman, 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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BDBTON EDISON COMPANV Ea!Etif tst Orricts too Sortstow StacEr BOSTQh,M AssACHUEETTS 07199 STEPHEN J SWECNEY pat &tDTNT Cseirr sat ufws OFFICf's April 5,1985 BEco. Ltr. #65-068 Dr. Thomas E. Murley Regional Administrator U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA. 19406 License No. DPR-35 Docket No. 50-293 Re: Notice of Violation INRC InsDection Nos. 50-293/B4-44 and 85-02 )
Dear Dr. Marley:
This letter is in response to the above Notice of Violation concerning a radiological incident which occurred at Pilgrim Station on December 17, 1984.
The Notice of Violation was communicated to Boston Edison Company with your letter dated March 6,1985.
j Boston Edison's detailed response to the Notice of Violation is contained in f the Attachment to this letter. As President and Chief Executive Officer I want to assure you that Boston Edison acknowledges the seriousness of the incident giving rise to the Notice of Violation andAt is the firmly committed same time, as to maintaining a strong radiological safety program.
amplified in the Attachment, we believe that the circumstances surrounding the violation make the categorization of the violation as Severity Level III_
inappropriate._and we therefore respectfully request that you consider assigning these violations to a lower Severity Level. We stress that the "C" primary cause of the major incident involving the individual entering the
! monitor tank without proper authorization was the willful disregard of j
instructions by that individual.
In addition, Boston Edison wishes to take exception to the statement contained in your letter that lack of_ adequate health physics management oversig~ht the crimarv cause of the incident.
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' ' human and financial resources to developing and implementing an extensive multi-deparunental Radiological Improvement Program (RIP) to address previously identified programmatic deficiencies on a long-term basis prior to Until full implementation of the RIP can be achieved, an
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the end of 1985.
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Dr. Thomas E. Murley
. Aprl) 5, 1985 Page Two Interim Program (IP) has been initiated to strengthen radiological controls in the interim period. The decision to make such extensive comitments was made_
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prior to the "C" monitor tank incident. J e beTreV rthit osr long term comitments as evidenced in the RIP as well as the corrective and preventive
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measures discussed in the Attachment which were enacted imediately following the "C" nonitor tank incident reflect the seriousness of Boston Edison's consnitment to radiation safety.
Should you have any questions or concerns regarding this response, please do not hasitate to call upon either myself or Mr. Harrington, our Senior Vice President - Nuclear.
Very truly yours, i ,
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Comonwealth of Massachusetts County of Suffolk Then personally appeared before me Stephen J. Sweeney who, being duly sworn, did state that he is President and Chief Executive Officer of the Boston Edison Company, the applicant herein, and that he is duly authorized to execute and file the submittal contained herein in the name and on behalf of the Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.
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ATTACHMENT , Page 1 of 4
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!htsponse to Notice of Violation ~
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(NRC InsDection Mos. 50-293/84-44 and 85-02)
Notice of Violation "A" ,2 Technical Specification 6.11 requires that radiation protection procedures be adhered to for all operations involving personnel radiation exposure.
Precedure 6.1-022, " Radiation Work Femits (RWP)," states in Section V. A.
that it is the responsibility of the first~line supervisor and the individuals working for the supervisor under the control of an RWP to follow all instructions on the RWP.
Procedure 6.1-022, also states in Section C.7 that all RWPs for work in high radiation areas must specify constant or periodic surveillance and that the surveillance frequency must be specified on the RWP. This surveillance is to be perfomed by a technician with a survey meter.
Procedure 6.1-022, states in section c.10 that an RWP revision sheet be .
completed if for any reason it becomes necessary to change RWP requirements or instructions, m
Contrary to the above:
1. On December 17, 1984, certain instructions specified in RWP No.
B4-3057, dated November 19, 1984, were not followed, as evidenced below; a. RWP Ho. 84-3057, prohibited entry into the 'C' Monitor Tank without HP supervisory approval.
~ However, at about 2:00 p.m., an individual who perfomed work under RWP 84-3057 entered the 'C' Monitor Tank without HP supervisory approval.
I b. RWP Ho. 84-3057 specified the perfomance of high radiation area surveillance at a frequency of every half-hour.
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However, between 10:00 a.m. and 3:20 p.m., no high radiation area surveillance by a technician with a survey rneter was perfomed.
c. RWP Ho. S4-3057 also required that a breathir.g zone air (BIA)
sampler be provided to each person during sluege-lancing operation.
However, between 2:30 p.m. and 3:20 p.m., an individual perfomed sludge-lancing of the 'C' monitor tank under the coverage of RWP Ho. 84-3057, and no BIA was provided to the individual, nor were other air samplers present in the area.
2. On or about December 14, 1984, a change was made to RWP No. 84-3057 deleting the need to perform periodic surveys every one-half hour in the area of the monitor tanks, and a revision sheet showing the change was not cocpleted. The RWP was used for several days to provide radiological controls for sludge-lancing of the 'C' monitor tank, and the surveys specified in the RWP were not trade.
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ATTACHMENT Page 2 of 4
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. ' Resconse to Violation "A" Boston Edison believes that Violatlon "A" should be considered in two separate parts: Item 1.a which directly involved the unauthorized entry of the individual into the 'C" monitor tank and Items 1.b,1.c and 2 which involved failures to follow proper procedures with respect to Radiation Work Permits. With respect to Item 1.4 the seriousness of the incident is acknowledged, but it is not clear what Boston Edison could have done to prevent the incident. We do not believe therefore that Item 1.a should be considered a violation, or in any event, we do not believe it should be categorized as a violation of Severity level III categorization. With respect to the remaining items we admit that these were indeed violations, however we do not believe that they Were by themselves of Severity Level III category. In each of Item 1.b, 1.c and 2 the specific change to the RWP would have been acceptable, if properly made. Thus, although it is clear tL.r. proper procedures should have been folicwed and the RWP should have been evised in writing rather than orally, we do not believe that
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there was ever a " substantial potential for an exposure or release in excess of 10 CFR 20" from the improper oral amendments to the RWP in ,
question. Consequently, we respectfully request a lower categorization of Severity Level for the subject incident. Following is specific infomation on the causes of each item and the correction actions which have been taken or are planned:
It has been established that in the case of Item la, the contractor
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employee who entered the tank was fully aware that he was not allowed to do so by procedure. However, he took deliberate actions, such as removing his headset and teledosimetry, 50 that the health physics technicians and the foreman who were monitoring him from outside the area would not know he was entering the tank.
In response to items 1.b end 2, health physics technicians discontinued the periodic surveillances required by the RWP based upon verbal instructions from a contra: tor Radiological Group supervisor. Tne supervisor perceived use of the teledosilretry system as the equivalent of perforcing the surveillances. Due to administrative oversight, the I contractor supervisor neither infomed Boston Edison Radiological Group i supervision of this change, nor did be revise the RWP appropriately.
Concerning item 1.c, a breathing zone air sar.pler was not provided to the individuals perfoming sludge-lancing because the health physics i technician on duty concluded that an air sampler was not necessary based l upon the type of wark being perfomed and en the results of an air sample ;
collected that morning during the perfomance of similar work. This
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decision was also discussed with and verbally approved by the contractor Radiological Group supervisor. Due to administrative oversight, the RWP was not appropriately revised.
After being informed of the incident on December 17, 1994, Boston Edison
! management inrediately suspended monitor tank desludging work and initiated an investigation into the circumstances surrounding the l
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incident. Subsequently, the individual who willfully violated the RWP and
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the procedure by entering the tank had his employment terminated at
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Pilgrim Station. Additionally, two television _ cameras were installed in the monitor tank area allowino constant visual surveillance of the
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oTerret4ertTThe Ndfation protecfien technicians stationed outside th^e
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Boston Edison and contractor techni'cians were reinstructed verbally and in writing of the importance of following procedures and the consequences of failing to do so. Also, the contractor Radiological Group supervisor and four contractor technicians involved in the incident were given written reprier. ands. Other individuals working on the desludging operation were also reinstructed on the procedures to be followed during this project.
Finally, the remainder of the monitor tank desludging was perfomed under the purview of Boston Edison (rather than contractor) Radiological Group supervisors and technicians. .
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Full compliance with respect to ,1.hese piolations w a achieved pricr to the resumption of work on the "C" monitoritank on 1/8/8S. -
BostonEdisonhaslessenedthe.discrefianaryauthorityallowedcontractor '
health physics personnel by revising the Station procedure governing Radiation Work Permits so that only Boston Edison supervisory personnel are permitted to revise the requirements of a Radiation Work Permit.
Additionally, the Vice President-Nuclear Operations reinforced, via memorandum to Station personnel, the policy that failure to follow procedures would not be tolerated by Boston Edison. Finally, it should be noted that on January 17, 1985, an Internal Review Program of work in progress was initiated with the use of an independent auditor.
In addition to the preceding corrective actions we would also point out that Boston Edison has undertaken an extensive Radiological Improvement Program (RIP) to address programatic deficiencies on a long-tem basis.
Included within RIP is a complete analysis, and overhaul where necessary, of Radiation Work Fermits and the controlling procedure. Upon completion of the RIP at the end of 1985 Boston Edison would expect to have impleeented a comprehensive approach to assuring that all RWP-controlled work is conducted in a safe manner.
Notice of Violation "B" Technical Specification 6.8 requires that procedures be established, implemented, and maintained that meet or exceed the requirements of Appendix "A" of USHRC Regulatory Guide 1.33, November 1972. This
! Regulatory Guide recomends in Appendix A, Section 6.5, that procedures for restrictions and activities in High Radiaticn Areas and for surveys and monitoring be established.
Contrary to the above, on December 17, 1984, a remote reading teledosimetry system was used for purposes of surveying, monitoring, and restricting activities during sludge-lancing of the 'C' monitor tank, and no procedures detailing use of this device for this purpose had been established.
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- .Resconse to Violation "B" The RWP controlling the job required high radiation area surveillances at half-hour intervals. As noted in cur response to Violation "A" above, the surveillances were discontinued when a contractor Radiological Group supervisor infomed the health physics technician covering the job that using the teledosimetry system was equivalent. The contractor supervisor failed to inform Boston Edison supervision of his actions and also failed to appropriately revise the RWP to adFess use of the teledosimetry for this purpose. Note that a Station fOcedure governing teladosimetry usage existed at t59 time of the incident ' Boston Edison admits that the job-specific RWP should have refere ced this procedure if the teledosimetry was to to used in this manner. However, we stress that this violation does not represent a f ai/ure to establish procedures as required by the Technical Specification and Regulatory Guide 1.33 which you cited.
As with Violation "A", although i is edmitted that there"B" was a violation should not of proper RWP procedure, it is s itted that Violation have been characterized as Sever y Leyl III because there was not a '
substantial potential for an exposcr4}r release in excess of 10 CFR 20". As with Violation "A" we Qeref respectfully request a lower categoritationofSeverityLeveffort, subject incident. c
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As noted in our response to ViglationhA", upon being infomed of the the desludging operations monitortankincident.BostonjlEdisonsuspendedto investigate the situatio being used in lieu of performing the required surveillances, Boston Edison issued supervision instructions to cease this practice. Additionally, as noted earlier, the contractor supervisor received a written reprimand and Station personnel were inforced by memorandum from the Vice President-Nuclear Operations that failure to folicw procedures would not be tolerated.
Full compliance was achieved prior to recommencement of the work on 1/8/85 when the use of the teledesimetry system in lieu of perfoming the required surveillances was discontinued.
As noted earlier in this response, the Station procedure governing RWP's
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' has been revised to restrict - to Boston Edison supervisory personnel alone - the authority to revise RWP requirements. Also, as discussed above, an Internal Review Program has been initiated, providing Boston Edisen Radiological Group management with an additional means of assuring adherence to procedures. In acdition, and as further corrective action,
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- we would again point to the Radiological Improvement Program (RIP) which Boston Edison is in the process of implementing and which we believe will
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ccnstitute an effective icng-range approach to problems in the radiological safety area.
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