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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10CFR2.790 ML20212F7871999-09-24024 September 1999 Advises That Util 990121 Application for Amend Being Treated as Withdrawn.Proposed Changes Would Have Modified Facility UFSAR Pertaining to Values for post-accident Containment Pressure Credited in Pilgrim Net Positive Head Analyses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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- d. fr. Victor Stello,~Jr.. 1
_ Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 License No. DPR-35 Docket No. 50-293
References:
(A) Letter V. Stello, Jr. to G. C. Andognini
, dated July 8, 1980
-(B)-Letter B. H. Grier to G. C.'Andognini dated July 9,.1980; re: Inspection 50-293/80-09
Dear Mr. Stello:
This letter.is in response'to your letter dated July 8, 1980, concerning four apparent items of non-compliance relating to the movement of irradiated fuel in the spent fuel pool at Pilgrim Nhclear Power Station on March 8,1980.
Appendix A~to'your July 8, 1980 letter, " Notice of-Violation", identified certain activities'as in apparent non-compliance with Technical Specifica-tions and station operating procedures. Our response to this Notice of Violation is submitted as Attachment A to this letter pursuant to the terms of the Notice and Section-2.201 of the NRC's " Rules of Practice" Part 2, Title 10, Code of Federal Regulations.
Appendix B to your letter, " Notice of Proposed Imposition of Civil Penalties,"
proposes to impose civil penalties in the amount of thirteen thousand dellars (13,000)'for three of-the apparent items of non-compliance identified ~in
' Appendix A. Our response.to the Notice of Proposed Imposition of Civil Penalty and our requests for mitigation land/or remission of these proposed civil penalties is submitted as Attachment B to this letter pursuant to the terms
.of the Notice and Section 2.205 of the NRC's " Rules of Practice" Part 2, Title 10,' Code:of Federal. Regulations.
Appendices C and D to your letter contain copies of correspondence between
'yourself and two Senior Reactor. Operators, Messrs. O'Rork and Alukonis, who
- are employed at Pilgrim Nuclear Power Station. Their individual replies to those letters are being provided by them under separate cover.
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BOstDN EDCCN COMPANY-Mr. Victor Stello, Jr.
- August 1, 1980 Page Two .
Your letter further expresses concern with the effectiveness of our managerial control of licensed activities, particularly in the areas of development of safety-related procedures and of controls for personnel actions related to procedure adherence, and requests that we give attention in our response to these areas of concern. Although we are not in agreement with the view expressed in your letter that there is a " chronic problem" in these areas,y especially inasmuch as the circumstances surrounding the movement of irradiated fuel, which was the basis for.the present Notice of Violation, were virtually
~
unique, we nevertheless fully share 'your concern with the proper development and implementation.of necessary procedures and will strive to improve our performance in this regard. We have, in response to this concern, initiated a full independent review of the Pilgrim Station Procedures Manual, the pur-pose being a complete modernization, stream-lining, consolidation and revision of our operating procedures. This task will specifically address the improve-ment of controls for procedural development, particularly including procedures addressing temporary off-normal situations and procedure adherence. These improvements will be incorporated in our training, supervision, inspection
-and audit functions. While we trust that these improvements will be fully responsive to the concerns you have raised, we further welcome any suggestions which you may have to offer.
Should you have any further comments or questions concerning this response, please contact us.
Very truly yours, cc: Mr. B. H. Grier '
Attachments:
(A) Response to Notice of Violation (B) Response to Notice of Proposed Imposition of Civil Penalty CERTIFIED MAIL - RETURN RECEIPT REQUESTED i
i 1
In an. effort to ascertain the validity of the assertion regarding the existence of ,
a chronic problem, we : contracted with an outside agency as well as began an inter- ,
nal investigation-to determine the enforcement history in this area both at Pilgrim Station and at other operating nuclear facilities. The results of this investiga-tion _ revealed that Pilgrim Station has, in fact, received a number of items of non-compliance relative to _a failure to follow procedures or to a lack of required procedures during its operating _ history. However, the results also showed that
' Pilgrim Station's record does not significantly differ from that of the industry
.and in'many instances.is superior.
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BostDN EDCON COMPANY g
ATTACHMENT A' RESPONSE TO NOTICE OF VIOLATION Boston Edison Company Docket No. 50-293 License No. DPR-35 EA-80-38 Pursuant to Section 2.201 of the NRC's " Rules of Practice" Part 2, Title 10, Code of Federal Regulations, Boston Edison Company hereby provides its re-sponse to the " Notice of Violation" dated July 8, 1980, issued in the above-captioned docket.
Each item or.sub-item of. alleged no'n-compliance contained in the Notice of Violation will first be set forth followed by the Company's detailed response.
Item I:
Technical Specification 3.7.C.1 requires that secondary containment integrity shall be maintained whenever irradiated fuel movement is iti progress.
Contrary to the above, irradiated fuel was moved within the spent fuel pool on March 8, 1980, without assuring secondary containment integrity existed.
This is a violation. (Civil Penalty - $5,000)
Response: s Boston Edison Company admits that on March 8, 1980, contrary to Technical Specification 3.7.C.l', two irradiated fuel elements were reoriented within the spent fuel pool without assuring that secondary containment integrity existed.
The direct cause of this occurrence was the failure of the Senior Reactor
- Operator, who was -at that time supervising operations on the refueling floor preparatory to the commencement of reloading activity, to realize that second-ary containment integrity was not assured. Contributing reasons for this failure included the lack of a specific check list to address requirements for fuel movement within the spent fuel pool as opposed to movement to or from the spent fuel pool, as well as the lack of an overall station-level review priorito fuel movement activities to assure that all applicable requirements have been* fulfilled. The Company believes that corrective actions responsive to these concerns have either been implemented or are now underway. ,
The basic' procedure utilized by Boston Edison Company to assure compliance with regulatory requirements, including Technical Specification 3.7.C.1, during fuel movement operations is Procedure 4.3, " Fuel Handling". The various requirements under this Procedure, including maintenance of secondary
-containment integrity, are summarized in checklist forms which are maintained
.as attachments to Procedur,e 4.3. &1 March 8, 1980, Procedure 4.3 (Revision 16
)
of Procedure 4.3 was in effect on March 8,1980) had as attachments checklists which addressed fuel movement from the reactor vessel to the spent fuel pool
.(unloading) and fuel movement from the spent fuel pool to che reactor vessel
. (reloading); however, 'there was no distinct checklist applicable solely to fuel movement within the spent fuel pool.
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BostDN EDi[DN COMPANY l
ATTACHMENT A Page Two on March' 8,'1980, while completing final preparations on the refueling floor for reloading the reactor vessel, directions were given for two fuel elements to be reoriented within the spent fuel pool in order to facilitate the expected reloading process. Prior to such movement, the Senior Reactor Operator super-vising the fuel handling had performed a routine evaluation of the availability of systems required for fuel handling to his satisfaction and had no reason to suspect the integrity of the secondary containment. Subsequently, the two fuel elements were moved without assuring that secondary containment integrity
' existed. It should be noted in this connection that a secondary containmen-leak rate test had been satisfactorily performed in January 1980, thereby demonstrating secondary containment integrity prior to fuel unloading. Sub-sequent thereto certain maintenance work had begun which necessitated further leak rate testing.'
Immediately following recognition of this f ailure (which occurred later the same day at a meeting of the Operations Review Committee (ORC) at which time the NRC was promptly notified), all further plans for fuel handling activity were sus-pended. A secondary containment leak rate test was immediately initiated to ascertain the existence of secondary containment integrity. To provide further control of fuel handling, the fuel handling equipment was locked out of service with the key controlled by the station manager. Subsequently, Procedure 4.3 was revised to incorporate the requirement that full ORC approval must be obtained prior to any fuel movement. Finally, prior to resumption of fuel handling man-euvers, all licensed operations personnel attended a training session which detailed the event and ihe circumstances surrounding its occurrence and which stressed the importance of assuring that all fuel handling prerequisites and requirements are verified prior to fuel movement.
As further corrective action, a new checklist which specifically addressed the movement of fuel elements within the spent fuel pool is in the process of being
' developed and is expected to be completed by September 1, 1980. In additien, the station-operator training and requalification programs are being revised to assure continual reinforcement of the concerns raised by this incident and special training sessions will be held immediately prior to the next scheduled refueling for all licensed personnel involved in fuel handling.
Item IIA:
Technical Specification 6.8.A states in part, " Written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7 - 1972 and i- Appendix "A" of USNRC Regulatory Guide 1.22....."
i 1
A. Pilgrim Nuclear Power Station (PNPS) Procedure 4.3, " Fuel Handling",
Revision 18, requires that prior to commencement of fuel handling operations, a meeting of the Operations Review Committee (ORC) shall be convened to review existing plant conditions to ensure that all requirements for fuel handling are met and, further, fuel movement may not being until the "on-duty" Watch Engineer receives approval from the ORC.
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' ATTACHMENT"A' Page-Three '-
' Contrary to the;above, on March 8, 1980, a Senior Reactor Operator undertook fuel handling operations without the consent of the Operations' Review Committee.
This-is an-infraction.- .( Civil' Penalty'- $4,000)
Response:-
' Boston. Edison Company denies that this' infraction occurred. The basis for.this
' denial-is: the ; fact that on March 8,1980, Revision ~ 16 of Procedure 4.3 was in effect rather than -Revision 18 as alleged. Revision 16 did not contain a require-ment relative to prior. review by the Operations Review Committee (ORC).~ In fact,
, the above" stated' requirement for prior ORC review and approval was instituted' on March 20, 1980,.in Revision l_7_ to. Procedure 4.3 as part of the corrective
-action in response to the subject event.
l Consequently, Boston Edison Company denies the item of non-compliance alleged in Item IIA and' requests that'the proposed-infracticn be withdrawn.
Item IIB:
B.- PNPS' Procedure 1.3.4,." Procedures", Revision 20, requires that approved
. written procedures shall be adhered to and that these procedures shall cover all normal and foreseeable off-normal conditions.
Contrary to the above,;on March 8, 1980, the output breaker controls 'f the emergency diesel ~ generator were temporarily modified to prevent automatic closure and there was no written procedure for the startup, operation and shutdown of the emergency i power source in this. condition.
- This is-an infraction.. (Civil penalty - $4,000)
Response
Boston; Edison Company' adisiits that on March 8,1980, the auto-close feature on both of the emergency.dieseligenerators were temporarily modified to. preclude a possibility of their closing on the/ bus out of: phase with the 23kV lines and that there was no written procedure for'the~startup, operation and shutdown of the generators in this condition.. It'should be noted that.this configuration existed only while the modifi-
' cation lof:the station's~345kV lines was in progress which modification was purposely e >
,f:.scheduledtobeperformed-duringtheperiodfuel'wasoutofthereactorvessel.
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.kbility.inthisLease was the ftd movemert within the spent fuel pool which was the
- subject :of Item 'I of the Notice of Violation.. This : fuel movement 'sh'ould not have -
^ 'taken. place for reasons ~already discussed in response to Item I and was clearly not-
" foreseeable"~in the context of Procedure 1.3.4. Consequently, the Company submits 7that,this was not the type of circumstance for which an approved written procedure Twas required by Procedure l.3.4.
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ATTACHMENT B RESPONSE TO NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTY
-Boston-Edison Company Docket No. 50-293 License No. DPR-35 EA-80-38 Pursuant to Section'2.205 of the NRC's " Rules of Practice", Part 2, Title 10,-
Code of Federal Regulations, Boston Edison Company hereby protests the impos-ition of civil penalties as set forth in the Notice of Proposed Imposition of Civil Penalties dated July 8,1980, issued in the above-captioned docket.
The basis for this protest for each.of the three items of alleged non-compliance for which civil penalties have been proposed is set forth below.
Item I:
That section of Attachment A containing the Company's ." Response" to Item I (i.e. .pp.1&2) . is hereby incorporated by reference herein.
As admitted in the " Response" irradiated fuel was moved within the spent fuel pool on March 8,1980, without assuring secondary containment integrity. While Boston Edison Company admits being thereby in non-compliance with the Technical Specification, it is submitted that the circumstances surrounding the event ,
make the imposition of a civil penalty inappropriate.
In particular, reference is made to the Commission's " Criteria for Determining Enforcement Action" dated December 31, 1974. The Company submits that the event.in question is much more nearly described by the criteria for which it is stated that " generally a ' notice of violation' may be considered sufficient enforcement" as opposed to the criteria listed as causing a civil penalty to be "the appropriate enforcement action." With respect to the Notice of Violation criteria, the. Company would note that the events underlying this item of non-compliance were.almost unique and could hardly be termed repeated or chronic.
The violation was readily correctable and, in fact, appropriate corrective action was promptly undertaken. Furthermore, the Company does not believe that the incident could_be fairly characterized as constituting an "immediate or serious' threat to health, safety, the environment or the common defense and security." With respect to the civil penalty criteria, it is similarly urged that~they cannot fairly be deemed descriptive of this item of non-compliance.
Consequently, it is respectfully requested that the proposed civil penalty of
, ' $5,000 be withdrawn or, in the alternative, that it be reduced or mitigated.
Item IIA:
l That portion of Attachment A containing the Company's " Response" to Item IIA (i.e. , pp. '2) is hereby incorporated by reference herein.
As indicated in the " Response" the procedural requirement for ORC review and approval prior to fuel handling was not-in effect at the time of the event.
Therefore, inasmuch'as there was no non-co=pliance, we respectfully request that the proposed civil. penalty of $4,000 be withdrawn.
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- ATTACHMENT B Page Two Item IIB:
~
That portion of Attachment A containing the Company's " Response" to Item IIB
'(i.e. pp. 3) is hereby incorporated by reference herein.
- As admitted in the Response" on approved written procedure had not been implemented to specifically address the special alignment of the emergency power supply. The Company submits, however, that it is highly questionable whether Procedure 1.3.4 required a formal written procedure in this unique and non-foreseeable situation. Even if this should be considered a technical violation though the Company believes that a civil penalty is inappropriate under the Commission's " Criteria for Determining Enforcement Action." In particular, the Company points out that it had recognized the uniqueness of the situation presented by the special alignment of the diesel generators and, further, that all operations personnel were made cognizant of the alignment and instructed as to the single manual action required by them to load the generators to the buses in the event of an auto start. All other facets of the operation of the emergency diesel generators were .: overed by existing procedures. It is clear that at no time was there an, immediate or serious threat and the matter was quickly remedied when the improper fuel handling activities ceased.
Therefore, it is respectfully requested that the civil penalty of $4,000 be withdrawn or in the alternative that it be reduced or mitigated.
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. .BDaTON Ell'Z N COMPANY ATTACHMENT A Page Four Even if thic should be deemed a situation where an approved written procedure were required by Procedure 1.3.4, it is submitted that the full intent of the written procedure requirement was met and adequate procedural steps had been established and communicated to operating personnel to assure emergency power source availability during this period despite the absence of an approved written procedure. It is the Company's firm belief that although an approved written procedure had not been specifically created to address the special diesel generator alignment, the techniques actually employed demonstrate a reasonable and operationally sound approach.
All control room licensed operators had been informed of the special diesel alignment ,' and they were cognizant of the actions required by them should an auto start of the emergency diesel generator occur. If the emergency diesel generators had started while so aligned, the control room licensed operator had the following actions to perform:
A. Visually t 'termine that the 23kV brea'kers had all opened. (The indica-i tion is on tanel C-3 in the main control room).
l E. Manually close the "D" feed breaker once the emergency diesel generators reached full speed.
All other facets of control during startup, operation and shutdown of the emergency power source were unchanged and required no special instruction. Further, a description of the alignment and a schematic diagram was maintained with the applitable maintenance request in the main control room and the maintenance re-quest had been approved by members of the Operations Review Committee (ORC).
The modification itself was scheduled when the operability requirements for the emergency diesel generator would be least impacted. The emergency diesel generator had also satisfactorily passed the operability surveillance test prior to beginning the 345kV modification.
It is submitted that the intent of the requirement for approved procedures addressing I all special or off-normal conditions is to assure that the appropriate individuals are cognizant of the existence of special conditions and to provide any needed specific guidance to them so they may continue to operate that system in a safe l
and reliable manner. It is Boston Edison Company's position that the actions which were implemented, though not an " approved written procedure" satisfied the intent of such a procedure and ensured the continued safe cperation of the emergency diesel generator. Therefore, it is requested that this infraction be withdrawn.
l Icem IIC:
C. PNPS Procedure 1.3.7, " Records", Revision 17, requires the Operating Super-visor and Control Room Operator to log in the Station Operations Log a minute-by-minute account of the operation of the plant, and that this should include everything that is happening in the plant.
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ATTACHMENT A-
. .Page Five
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' Contrary to' the :above, the movement of irradiated fuel in the spent fuel pool, nthe violation ofLTechnical Specification 3.7.C.1 and the notification of NRC of.the' incident were not logged in the Station Operations Log.on March 8, 1980.
Thisjid a' deficiency'. (No Civil Penalty)
Response
Boston Edison Company admits that the three specified items were not logged in the Station Operations Log on March 8, 1980.
The Company-submits that the failure to log these three items in the Station Operations Log resulted from a difference of interpretation of the requirements of Procedure 1.3.7 ' and should not be considered to be in non-compliance with that' Procedure.
With. respect to the failure to log the movement of irradiated fuel in the spent fuel pool on March 8,1980, it should be pointed out that, due to the complexity and numbar.of. tasks and.on-going activities in the plant during a refueling out-
-age, Pilgrim Station maintains an additional operations log during refueling outages - the Refueling Floor Supervisor's/ Coordinator's Log. The practice of keeping this additional log was initiated during Refuel 2 in 1975, and has been utilized during'each subsequent refueling outage including the one occurring in 1980. This log is maintained in the main control room and an account of all licensed refueling floor activitfes is documented in this log by the individuals super-vising activities on the refueling floor. A review of this log revealed that on March 8,1980, the movement of irradiated fuel in the spent fuel pool, was logged by the Senior Reactor Operator in charge of the refueling floor as re-quired. Although we believe this practice fully satisfied the intent of Procedure 1.3.'7, in order to expressly delineate the practice of, utilizing
'this additional log during refueling outages, Procedure No.1.3.7, " Records",
will~be revised to explicitly reference the refueling log. It is expected that this revision will be implemented by September 1, 1980.
-With respect to the violation of Technical Specification 3.7.C.1 and the subsequent notification of the NRC, it is submitted that the failure to' log these items is based upon a differing interpretation of wnat constitutes " operations of the plant."
On Saturday, , March 8,1980, the Operations Review Committee (ORC) met to evaluate
.the fuel movement incident. It was during this meeting that the determination was made that. Technical-Specification 3.7.C.1 had, in fact, been violated and that the event should be promptly reported. The NRC was immediately notified by a member: of the ORC from an administration building office. There was not control room involvement in the ascertainment of the technical specification violation and the subsequent telephone report to the NRC. Though the control room was notified by the 9KC of the results of the meeting ' and the notification to the NRC, these events were1oot construed as being part of the " operations of the plant"
-and as'such, were not entered into the control room Station Operations Log.
It is the Company's position therefore that classifying the failure to log these items in the Station Operations Log as a deficiency is unwarranted.
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