ML20129F813
| 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: |
| 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
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475 ALLENDALE ROAD
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KING OF PRusstA. PENNSYLVANIA 194061415
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October 21, 1996
EA 96-271
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E. Thomas Boulette, PhD
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Senior Vice President - Nuclear
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Boston Edison Company
Pilgrim Nuclear Power Station
600 Rocky Hill Road
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Plymouth, Massachusetts 02360-5599
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SUBJECT:
(NRC INSPECTION REPORT NO. 50-293/96-07)
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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
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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
related violations, their causes, and your corrective actions.
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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
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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
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containment inoperable and entered a 24-hour limiting condition for operation (LCO).
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The second violation involved the failure to identify and correct this condition sooner, even
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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
ADOCK 05000293
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Boston Edison Company
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quality are promptly identified and corrected. For example, during a self-assessment that you
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performed in July 1991 of Pilgrim's electrical distribution system, your staff identified that
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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
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calculation for the purpose of evaluating the penetration under normal plant operation, your
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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
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exceeded National Electric Code (NEC) limits. Your engineers failed to pursue this further, and
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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
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the magnetic-trip-only breakers as enhancements, and therefore, the affected circuit breakers
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were not replaced until 1996.
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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
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violations have been classified in the aggregate as a Severity Levellli problem in accordance
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with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
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(Enforcement Policy), NUREG-1600.
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The NRC commends the technicalinquisitiveness of the electricalengineer who identified this
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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.
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Nonetheless, if similar inquisitiveness had been exhibited by your staff when opportunities
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existed in 1991,1992, and 1993, this problem could have been corrected sooner. These
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findings demonstrate the need for management taking appropriate action to assure that your
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staff in general, and your engineers in particular, are sensitive to the importance of performing
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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
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corrected.
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In accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000 is
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considered for a Severity Level til problem. Your facility has been the subject of escalated
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enforcement actions within the last 2 years (namely, a Severity Levellli violation without a
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civil penalty issued on March 3,1995, for failure to maintain containment integrity for
approximately 30 days while the reactor was critical (EA 95-010)). Therefore, the NRC
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considered whether credit was warranted for /dentification and Corrective Action in
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accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement
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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
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actions were both prompt and comprehensive once the violations were identified in 1996.
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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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Boston Edison Company
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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,
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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.
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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
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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),
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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Boston Edison Company
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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:
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PUBLIC
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JTaylor, EDO
JMilhoan, DEDR
JLieberman, OE
HMiller, RI
FDavis, OGC
FMiraglia, NRR
RZimmerman, NRR
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Enforcement Coordinators
RI, Rll, Rill, RIV
BBeecher, GPA/PA
GCaputo, 01
DBangart, OSP
HBell, OlG
EJordan, AEOD
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OE:Chron
OE:EA
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NUDOCS
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DScrenci, PAO (2)
Nuclear Safety Information Center (NSIC)
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