ML20129F813

Discusses Insp Rept 50-293/96-07 on 960708-12,22 & 26 & Forwards Nov.Nrc Concerned About Failure to Maintain Containment Integrity Under Certain Conditions & Failure to Identify Condition Sooner

ML20129F813
Person / Time
Site:	Pilgrim
Issue date:	10/21/1996
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Boulette E BOSTON EDISON CO.
Shared Package
ML20129F818	List: ML20129F813 ML20129F870
References
EA-96-271, NUDOCS 9610290217
Download: ML20129F813 (5)

See also: IR 05000293/1996007

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

REGloN I

475 ALLENDALE ROAD

i KING OF PRusstA. PENNSYLVANIA 194061415

j October 21, 1996

EA 96-271 ,

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j E. Thomas Boulette, PhD

i Senior Vice President - Nuclear

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Boston Edison Company

Pilgrim Nuclear Power Station

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600 Rocky Hill Road

j Plymouth, Massachusetts 02360-5599

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SUBJECT: NOTICE OF VIOLATION

, (NRC INSPECTION REPORT NO. 50-293/96-07)

! Dear Mr. Boulette:

This letter refers to the NRC inspection conducted from July 8 to July 12,1996, and July 22

to July 26,1996, at the Pilgrim Nuclear Power Station facility to review the circumstances

surrounding an event reported to the NRC in Licensee Event Report (LER) 96-04, dated

May 9,1996, involving the potential degradation of primary containment integrity. The

findings of the inspection were discussed with you and members of your staff during a r

telephone exit meeting on September 3,1996. In addition, the NRC inspection report was

sent to you with our letter, dated September 20,1996. On October 3,1996, a Predecisional  ;

Enforcement Conference was conducted with you and members of your staff to discuss the l

related violations, their causes, and your corrective actions. i

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Based on the information developed during the inspection, and the information provided during

the conference, and by the LER, two violations of NRC requirements were identified. The j

violations are set forth in the enclosed Notice of Violation. The first violation involved the

failure to maintain primary containment integrity in accordance with Technical Specification Section 3.7. A,in that two electrical containment penetrations were not properly protected due

to improper trip-settings of 12 electrical penetration circuit breakers. Under certain high-

impedance fault conditions during a postulated design basis accident, the trip settings, which

were too high, could allow excessive current to pass through the electrical penetration circuits,

thereby damaging the penetration seals, and causing the loss of primary containment integrity.

This condition was discovered by your staff on April 9,1996, following an investigation of a

failed drywell-unit-cooler fan motor that was powered by electrical circuits passing through

one of the two penetrations. When you discovered this condition, you declared primary l

containment inoperable and entered a 24-hour limiting condition for operation (LCO). l

The second violation involved the failure to identify and correct this condition sooner, even f(DJ

though it existed as early as 1988 (and may have existed as far back as 1972). This

constitutes a violation of 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action"

which requires, in part, that measures shall be established to assure conditions adverse to

9610290217 961021

PDR ADOCK 05000293

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Boston Edison Company 2

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{ quality are promptly identified and corrected. For example, during a self-assessment that you 1

performed in July 1991 of Pilgrim's electrical distribution system, your staff identified that  ;

l electrical penetration protection for potential electrical faults within the primary containment  ;

had not been addressed. Although your staff later performed an operability evaluation to

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address this problem, the problem was not corrected because of an incorrect assumption

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regarding thermal overload of the motor starter, as described in the Notice. Therefore, the

incorrect breaker trip-setting problem was not corrected. Later,in 1992, while performing a '

calculation for the purpose of evaluating the penetration under normal plant operation, your

j engineers noted that some of the circuits protected from overload by thermal relays were not

adequately protected from short-circuits because the settings of magnetic-trip-only breakers

l exceeded National Electric Code (NEC) limits. Your engineers failed to pursue this further, and

! did not recognize that the circuit breaker manuf acturer's technical manual required adherence

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to the NEC limits. In July 1993, your staff mischaracterized the corrective action for replacing

l the magnetic-trip-only breakers as enhancements, and therefore, the affected circuit breakers c

i were not replaced until 1996. l

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j The failure to maintain containment integrity under certain conditions, as well as the failure

to identify this condition sooner, represent significant regulatory concerns. Therefore, these

{ violations have been classified in the aggregate as a Severity Levellli problem in accordance

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j with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"

l (Enforcement Policy), NUREG-1600.

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l The NRC commends the technicalinquisitiveness of the electricalengineer who identified this

4 problem in 1996 during his follow-up review of a starter problem with a drywell area cooler.  ;

If not for his inquisitiveness, this problem likely would have remained uncorrected.

j Nonetheless, if similar inquisitiveness had been exhibited by your staff when opportunities ,

j existed in 1991,1992, and 1993, this problem could have been corrected sooner. These

j findings demonstrate the need for management taking appropriate action to assure that your

4 staff in general, and your engineers in particular, are sensitive to the importance of performing i

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comprehensive evaluations whenever potential problems surf ace at the facility. Such reviews  ;

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are needed to assure that all potentially degraded features are promptly identified and i

j corrected.

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l In accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000 is  ;

[ considered for a Severity Level til problem. Your facility has been the subject of escalated j

j enforcement actions within the last 2 years (namely, a Severity Levellli violation without a '

civil penalty issued on March 3,1995, for failure to maintain containment integrity for l

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approximately 30 days while the reactor was critical (EA 95-010)). Therefore, the NRC l

considered whether credit was warranted for /dentification and Corrective Action in

i accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement

} Policy. Credit is warranted for identification since you identified the violation of Technical

, Specification Section 3.7.A. Creditis warranted for corrective action because your corrective

, actions were both prompt and comprehensive once the violations were identified in 1996.

Your corrective actions included, but were not limited to (1) immediately entering the

Technical Specification Limiting Condition of Operation; (2) correcting the trip-setting of the

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affected circuit breakers within four hours; (3) replacing all 12 magnetic-trip-only circuit

breakers with thermal-magnetic type circuit breakers; and (4) completing a root cause

evaluation, which identified additional corrective actions to be taken in the near future, namely

establishing an improved tracking mechanism for periodic Long Term Plan (LTP) review, ,

revising the calculation procedure to require verification that corrective actions are tracked,

reviewing other calculations to determine if similar conditions exist, and reviewing the

electrical engineering design guide to determine whether improvements should be made. t

Therefore, to encourage prompt and comprehensive identification and correction of violations,  :

I have been authorized, after consultation with the Director, Office of Enforcement, not to

propose a civil penalty in this case. However, significant violations in the future could result

in a civil penalty.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response, in part, to ,

determine whether further enforcement action is necessary to ensure compliance with

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regulatory requirements.  ;

in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, and

its enclosure will be placed in the NRC Public Document Room (PDR),

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Sincerel

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Hubert J. Miller

Regional Administrator

Docket No. 50-293

License No. DPR-35

Enclosure: Notice of Violation

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cc w/ encl:

L. Olivier, Vice President - Nuclear and Station Director

T. Sullivan, Plant Department Manager

N. Desmond, Regulatory Relations

D. Tarantino, Nuclear Information Manager

R. Hallisey, Department of Public Health, Commonwealth of Massachusetts

The Honorable Therese Murray

The Honorable Linda Teagan

B. Abbanat, Department of Public Utilities

Chairman, Plymouth Board of Selectmen

Chairman, Duxbury Board of Selectmen

Chairman, Nuclear Matters Committee

Plymouth Civil Defense Director

P. Gromer, Massachusetts Secretary of Energy Resources

J. Shaer, Legislative Assistant

J. Fleming

A. Nogee, MASSPIRG

Regional Administrator, FEMA

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

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Boston Edison Company

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plSTRIBUTION: l

j PUBLIC ,

SECY l

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CA j

JTaylor, EDO

JMilhoan, DEDR  !

JLieberman, OE

HMiller, RI l

FDavis, OGC  ;

FMiraglia, NRR l

RZimmerman, NRR ,

Enforcement Coordinators )

RI, Rll, Rill, RIV

BBeecher, GPA/PA  ;

GCaputo, 01 l

DBangart, OSP

HBell, OlG

EJordan, AEOD ,

OE:Chron l

OE:EA

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DCS

, NUDOCS

DScrenci, PAO (2)

Nuclear Safety Information Center (NSIC)

Te receive a copy or this document, indicate in the box: "C" = Copy without attachmenvenclosure "E" = Copy with attachment / enclosure *N' = Nop>py

0FFICE Rl/ES o/\p Rl/DRS , l6 RI:DRP n ,, Rl/RC W{pesfXG RI:fJg S/ l

NAME JJoustra/wj& W JWiggins biW; RCooper W LSm4h MPSA.-Hl0h (bf'

DATE (0/ 10/96 /d /// /96 hA t/. L/96 L i

10 /3//96 .,St.) If/Ji/96

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OFFICIAL RECORD COPY

a: PROP-PIL.rev