IR 05000293/1998004

Discusses Insp Rept 50-293/98-04 on 980427-0515 & Forwards Notice of Violation Re Failure to Properly Implement Maint Rule

ML20237A299
Person / Time
Site:	Pilgrim
Issue date:	08/06/1998
From:	Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Olivier L BOSTON EDISON CO.
Shared Package
ML20237A301	List: IR 05000293/1998004 ML20237A303
References
50-293-98-04, 50-293-98-4, EA-98-277, NUDOCS 9808130253
Download: ML20237A299 (4)

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l August 6, 1998

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l EA 98-277 Mr. Leon i Senior Vice President - Nuclear BEC Energy Pilgrim Nuclear Power Station 600 Rocky Hill Road l Plymouth, Massachusetts 02360-5599 l

SUBJECT: NOTICE OF VIOLATION AND EXERCISE OF ENFORCEMENT D!SCRETION (NRC INSPECTION REPORT NO. 50-293/98-04)

Dear Mr. Olivier:

This letter refers to the NRC inspection conducted at the Pilgrim Nuclear Power Station from April 27,1998 to May 1,1998 (onsite), and from May 4-15,1998 (in-office). The purpose of the inspection was to review Pilgrim's maintenance rule implementation in

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accordance with 10 CFR 50.65. During the inspection, apparent violations were identified related to the failure to properly implement the maintenance rule. The findings of the l Inspection were discussed with members of your staff at the conclusion of the onsite inspection on May 1,1998, and the inspection report addressing these issues was ser;t to j you on June 29,1998. Our letter indicated that we were still making a decision on enforcement matters and the purpose of this letter is to provide you with the results of our

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deliberations.

- Based on the results of this inspection, the NRC has determined that violations of NRC requirements occurred._ Three of these violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding them are described in detail in the

! subject inspection report. The violations involved: (1) f ailure to demonstrate effective preventive maintenance as required by 10 CFR 50.65 (a)(2) because you did not establish

an unavailability performance measure for the anticipated transient without scram (ATWS)

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function of the control rod drive system; (2) failure to include in the scope of the

< . Maintenance Rule program, as required by 10 CFR 50.65(b), the heating, ventilation and air ( conditioning (HVAC) system for the reactor building 480V switchgear environmental i enclosures and for the firewater system function of providing a backup (and supplemental)

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supply to the screenwash system; and (3) failure to complete the periodic evaluation required to be performed for refueling cycle 11, which ended April 1997, as required by 10 CFR 50.65 (a)(3). The violations were identified by the NRC and have been categorized l individually at Severity Level IV in accordance with the " General Statement of Policy and Ij Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, Revision 1, /

May 1998.

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O Mr. Leon Further, during your self-assessment of your maintenance rule program, you identified significant performance weaknesses and inadequacies which indicated an apparent organizational ineffectiveness in implementing the maintenance rule. The identified deficiencies included examples of failure to demonstrate effective preventive maintenance and failure to include structures, systems and components (SSCs)in the ccope of the maintenance rule program, as well as failure to place systems into an (a)(1) status in a timely manner when it was evident that preventive maintenance was not effective. For example, you identified that the feedwater system and the primary containment system were not placed into an (a)(1) status in May 1997 and July 1996, respectively, it was apparent that your organization was not in compliance with the maintenance rule as of July 10,1996 when the rule became effective. The NRC recognizes that considerable progress was made in the months prior to the subject inspection. Nonetheless, these violations collectively represented an initial programmatic breakdown in the development and implementation of the Rule.

These violations were considered for escalated enforcement action in accordance with the Enforcement Policy; however, after consultation with the Director, Office of Enforcement, and the Regional Administrator, I have been authorized to not issue a Notice of Violation and not propose a civil penalty (for the violations identified by your organization) in accordance with the provisions provided in Section Vll.B.6 of the Enforcement Policy. The decision to exercise discretion was made in consideration of the facts that: (1) your self-assessment identified the deficiencies in your maintenance rule program; (2) your corrective actions to address the weaknesses were reasonably prompt and comprehensive after identification; and (3) there was no actual adverse impact on system performance as a result of the deficiencies in your program. At the time of the inspection, your maintenance rule program and implementation were in compliance with 10 CFR 50.65 with some exceptions as noted above. Although the NRC identified several violations during the inspection, these deficiencies were not indicative of a continuing programmatic breakdown.

Rather, it appeared that you had not had a chance to review your corrective actions for effectiveness.

You are required to respond to this letter and should follow the instructions in the enclosed Notice. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Room (PDR).

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9-Mr. Leon Your cooperation with us is appreciated.

Sincerely, ORIGINAL SIGNED BY: .l

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James T. Wiggins, Director i Division of Reactor Safety.

Docket No.: 50-293

- License No.: DPR-35 Enclosure: Notice of Violation cc w/ encl:

R. Ledgett, Executive Vice President - Operations C. Goddard, Plant Department Manager . l N. Desmond, Regulatory Relations D. Tarantino, Nuclear Information Manager R. Hallisey, Department of Public Health, Commonwealth of Massachusetts The Honorable Therese Murray The Honorable Joseph Gallitano T. MacGregor, Mass. Dept. of Public Comm. & Energy

' Chairman, Plymouth Board of Selectmen Chairman, Duxbury Board of Selectmen Chairman, Nuclear Matters Cornmittee Plymouth Civil Defense Director P. Gromer, Massachusetts Secretary of Energy Resources J. Miller, Senior issues Manager J. Fleming A. Nogee,' MASSPIRG Office of the Commissioner, Massachusetts Department of Environmental Quality Engineering Office of the Attorney General,' Commonwealth of Massachusetts T. Rapone, Massachusetts Executive Office of Public Safety .

Chairman, Citizens Urging Responsible Energy Commonwealth of Massachusetts, SLO Designee L

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!- Notice of Violation 4  !

Distribution w/ encl:

Region i Docket Room (with concurrences)

Nuclear Safety information Center (NSIC)

PUBLIC NRC Resident inspector J. Wiggins, DRS L. Nicholson, DRS R. Conte, DRS J. Caruso, DRS  ;

C. Cowgil, DRP R. Summers, DRP C. O'Daniell, DRP 1 H. Miller, RA/W. Axelson, DRA I OE (2)

D. Holody, ORA DRS File j Distribution w/enci (VIA E-MAIL):

B. McCabe, OEDO C. Thomas, NRR (COT)

A. Wang, NRR R. Correia, NRR F. Talbot, NRR R. Zimmerman, ADPR, NRR F. Davis, OGC A. Nicosia, OGC J. Lieberman, OE (OEMAIL)

DOCDESK inspection Program Branch, NRR (IPAS)

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I DOCUMENT NAME: G:\OLHP\CARUSO\PROPILR1.MR

. To receive a copy of this document, indicate in the box: "C" = Copy without

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attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy OFFICE Rl/ ORA Rl/DRS [t OE l Rl/DRP /p l Rl/DRS [

NAME TW er 'JCarusQ' 74 MS s CCowgill/CRehb JWiggins V

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