ML20153F210
| ML20153F210 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/16/1998 |
| From: | Conte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Olivier L BOSTON EDISON CO. |
| References | |
| 50-293-98-04, 50-293-98-4, EA-98-277, NUDOCS 9809290042 | |
| Download: ML20153F210 (3) | |
See also: IR 05000293/1998004
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September 16, 1998
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EA 98-277
Mr. Leon J. Olivier
Senior Vice President - Nuclear
BEC Energy -
Pilgrim Nuclear Power Station
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600 Rocky Hill Road
Plymouth, Massachusetts 02360-5599
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SUBJECT:
PILGRIM INSPECTION REPORT NO. 50-293/98-04(REPLY)
Dear Mr. Olivier:
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This letter refers to your August 28,1998 correspondence, in response to our notice of
violation dated August 6,1998 and our integrated inspection report dated June 29,1998.
This inspection focused on the maintenance rule baseline program (April 27,1998 to May
1,1998 onsite, and from May 4-15,1998 in-office) at the Pilgrim Nuclear Power Station,
Plymouth, Massachusetts. We have reviewed this matter in accordance with NRC
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- Inspection Manual Procedure 92902," Maintenance." We concur with your assessment of
the root causes and corrective actions as summarized below and we note a common cause
for all three violations being human error that resulted from your initial incomplete
understanding of the requirements and initial inability to remain current in evolving NRC
expectations in this area.
The first vblation involved failure to establish an unavailability performance measure for
the anticipated transient without scram (ATWS) function of the control rod drive system.
The corrective actions involved re-evaluation by your Expert Panel, and this function was
determined to be risk significant. Accordingly, unavailability criterion was established and
the bases document was revised and approved by your Expert Panel.
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The second violation involved failure to include in the scope of the Maintenance Rule
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program, the heating, ventilation and air conditioning (HVAC) system for the reactor
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building 480V switchgear environmental enclosures and for the firewater system function .
of providing a backup (and supplemental) Supply to the screenwash system. The
corrective actions involved re-evaluation by your Expert Panel, development of performance
criteria, revision of the respective bases document and approval by the Expert Panel.
The third violation involved failure to complete the periodic evaluation required to be
performed for refueling cycle 11, which ended April 1997. The corrective actions included
~ completing the (a)(3) periodic assessment for refueling cycle number 11 and a planned
revision to your program requirements that will require the (a)(3) periodic assessments to
be completed at the end of each refueling outage, not to exceed two years.
.0 0]?A
9809290042 980916
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ADOCK 05000293
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Mr. Leon J. Olivier
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The effectiveness of your corrective actions will be reviewed in a future inspection after
the completion of your comprehensive self-assessment in which you indicated is expected
to be completed by April 15,1999. We appreciate your cooperation.
Sincerely,
ORIGINAL SIGNED BY:
Richard J. Conte, Chief
Operator Licensing and
Human Performance Branch
Division of Reactor Safety
Docket No.: 50-293
License No.: DPR-35
cc w/ encl:
R. Ledgett, Executive Vice President - Operations
C. Goddard, Plant Department Manager
J. Alexander, 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
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' Chairman, Duxbury Board of Selectmen
Chairman, Nuclear Matters Committee
Plymouth Civil Defense Director
P. Gromer, Massachusetts Secretary of Energy Resources
J. Miller, Senior lasues 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
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Mr. Leon J. Olivier
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Distribution w/ encl:
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- Region 1 Docket Room (with concurrences)
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Nuclear Safety information Center (NSIC)
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PUBLIC :
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NRC Resident inspector
- J. Wiggins, DRS
L. Nicholson, DRS
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R. Conte, DRS
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J. Caruse, DRS
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C. Cow 0 l, DRP
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R. Sunmre, DRP
C. O'Daniell, DRP .
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H. M!Iler, RA/W. Axelson, DRA
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D. Holody, ORA
DRS File
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B. McCabe, OEDO
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C. Thomas, NRR (COT)
'.A. Wang, NRR
R. Correia, NRR
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F. Talbot, NRR
- R. Zimmerman, ADPR, NRR
F. Davis, OGC
A. Nicosia, OGC .
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J. Lieberman, OE (OEMAIL)
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DOCDESK
. inspection Program Branch, NRR (IPAS)
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DOCUMENT NAME: G:\\OLHP\\CARUSO\\PIL9804. REP
To receive a copy of this document, indicate b @.c box: "C" = Copy without
attachment / enclosure
"E" = Copy with attach nent/ enclosure
"N" = No copy
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Boston Edloon
Pilgrim Nuclear Power Station
600 Rocky Hill Road
Plymouth, Massachusetts 02360
August 28, 1998
LJ. Olivier
BECo Ltr. #2.98.120
Senior Vice Presidect Nuclear
U.5. Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, DC 20555
Docket No 50-293
License No. DPR-35
REPLY TO THE NOTICE OF VIOLATION. DATED AUGUST 6.1998
(NRC INSPECTION REPORT NO. 50-293/98-04)
Enclosed is Boston Edison Company's reply to the Notice of Violation dated August 6,1998
(Inspection Report No. 50-293/98-04).
This letter includes the following commitments.
A comprehensive self-assessment of the effectiveness of the Maintenance Rule
improvement Program is being developed and will be performed to further ensure the
continued full compliance with the requirements of 10CFR50.65. This will be completed
by April if,1999.
Nuclear Engineering Procedure 16.03, "10 CFR 50.65 NRC Maintenar.ce Rule" will be
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revised to include the schedule for 10 CFR 50.65(a)(3) evaluation at the end of each
refueling outage, not to exceed two years. This revision will be completed by December
31,1998.
Please do not hesitate to contact me if there are any questions regarding the enclosed reply.
- 8J@
L. J. Olivier
Enclosure: Reply to the Notice of Violation
298120
WGU vlO98-04-01,04 &OS
cc:
' Mr. Alan B. Wang, Project Manager
Region I,
Project Directorate 1-3
U.S. Nuclear Regulatory Commission
Office of Nuclear Reactor Regulation
475 Allendale Road
King of Prussia, PA 19406
1 White Flint North
11555 Rockville Pike
Senior Resident inspector
Rockville, MD 208S2
Pilgrim Nuclear Power Station
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Boston Edison Company
Docket No. 50-293
Pilgrim Station
License No. DPR-35
EA 98--277
ENCLOSURE
VIOLATION: EA 98-277
A.
10 CFR 50.65(a)(1) requires, in part, that orolders of an operating license shall monitor the
performance or condition of structures, systems and components (SSCs),within the scope of the
monitoring program, as defined by 10 CFR 50.65(b), against licensee established goals, in a
manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their
intended functions. Such goals shall be established commensurate with safety and, where
practical, take into account industry-wide operating experience. When the performance or
condition of a SSC does not meet established goals, appropriate corrective action shall be taken.
10 CFR 50.65(a)(2), requires, in part, that the monitoring as specified in 10 CFR 50.65(a)(1) is not
required where it has been demonstrated that the performance or condition of a SSC is being
effectively controlled by performing appropriate preventive maintenance, such that the SSC
remains capable of performing its intended function.
Contrary to 10 CFR 50.65(a)(2), from July 10 1996 to April 27,1998, the licensee had elected not
to monitor the performance or condition of thc control rod drive system against established goals
pursuant to the requirements of Section (a)(1), and failed to demonstrate that the performance or
condition of the SSCs, within the scope of 10 CFR 50.65, had been effectively controlled by
performing appropriate preventive maintenanco pursuant to the requirements of Section (a)(2).
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Specifically, the licensee failed to establish unavailability measures for the anticipated transient
i without scram (ATWS) function of the control rod drive system. Without an unavailability
measure, the ATWS function could be out-of-service for an excessive period of time rendering it
[ incapable of performing it's intended function.
This is a Severity LevelIV violation (Supplement 1).
B.
10 CFR 50.65(b) established the scope of the monitoring program for selection of safety-related
and nonsafety-related structures, systems or componcats (SSCs) to be included within the
maintenance rule program. The monitoring program shall include, in part, non-safety related
SSCs that are relied upon to mitigate accidents or transients, or are used in the plant ernergency
operating procedures, or, or whose failure could cause a reactor scram or actuation of a safety-
related system.
' Contrary to the above. from July 10,1996 to April 27,1998, the licensee had failed to include in
' the scope of the Maintenance Rule program the heating, ventilation, and air conditioning system
(HVAC) for the reactor building 480V switchgear environmental enclosures, which were designed
to protect the switchgear from the consequences of high energy line breaks in the secondary
containment (failure of this system could result in loss of safety significant loads) and the firewater
system function of providing a backup (and supplemental) supply to the screenwash system
l s(failure of this system could result in a plant trip in the event of a loss of normalsystem sup
creenwash system concurrent with grass intrusion and screen clogging).
This is a Severity LevelIV violation Supplement I.
REASON FOR THE VIOLATIONS
The reason for the above violations was human error. The failure to include, as of July 10,
1996, the unavailability performance criterion for the ATWS function of CRD, the HVAC motor
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control c:nt:r enclosura function, and tha firewater system back up to ths screenwash function
in the Maintenance Rule was the result-oLoutinitiaLincomplete-understanding of the
requirements of the rule and_our_initiaLinability._to_remairLcurrenLFh_ evolving _NRC
expentations.
Itiese deficiencies were also not discovered during the overhaul of the
Maintinance Rule Program in response to OA audit 97-08 because the self-imposed,
aggressive schedule we established for the overhaul activities, in some cases, may not have
allowed sufficient engineering assessment time to identify the deficiencies. A critical self-
. assessment is now in progress to ensure our upgraded Maintenance Rule Program fully
incorporates the requirements of the rule and is complete and accurate (PR 98.0919).
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED
OA audit 97-08 was completed in September 1997 to determine the extent of compliance
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with 10 CFR 50.05. A Maintenance Rule improvement Program was developed to provide
effective corrective and preventive actions to resolve OA audit findings. A complete
overhaul of Pilgrim's Maintenance Rule Program to correct the programmatic weakness was
accomplished in May 1998 (PR 97.2869).
The ATWS function of CRD was re-evaluated by the Expert Panei and determined to be risk
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significant. An appropriate unavailability performance criterion was established for the
ATWS function of the CRD system and the CRD bases document revised and approved by
the Exped Panel on June 18,1998.
The Reactor Building 480V switchgear environmental enclosure safety-re:ated HVAC
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function and the firewater system function to provide a backup to the screenwash system
were both added to the scope of the Maintenance Rule Program. Performance criteria
were developed for these functions and the respective bases documents revised. The
Expert Panel approved the revision to the screenwash system bases document on May 8,
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1998, and the revision to the HVAC system bases document on June 29,1998.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
A comprehensive self-assessment of the effectiveness of the Maintenance Rule improvement
Program is being developed and will be performed to further ensure continued full compliance
with the requirements of 10CFR50.65. This will be completed by April 15,1999.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
Full compliance was achieved en June 29,1998.
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VIOLATION
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10 CFR 50.65(a)(3) requires, in part, that performance and condition monitoring activities and
associated goals andpreventive maintenance activities shall be evaluated at least every refueling
cycle provided the interval between evaluations does not exceed 24 months.
Contrary to the above, as of April 27,1990, the licensee had failed to complete the periodic
evaluation for the refueling cycle No.11 which ended April 1997.
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This is a Severity LevelIV violation Supplement I.
REASON FOR THE VIOLATION
-The reason for the violation was human error. The current NRC position for the completion of
the 10 CFR 50.65(a)(3) periodic assessment requirement was misinterpreted (PR 98.0919).
The extent of this problem is limited to this one incident. The next (a)(3) evaluation is due at
the end of refueling oJtage 12.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED
The periodic evaluation required by 10 CFR 65(a)(3) was completed, approved, and issued on
May 5,1998. A copy of the evaluation report was sent to the NRC's Mr. John Caruso on May 5,
1998.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
Nuclear Engineering Procedure 16.03, "10 CFR 50.65 NRC Maintenance Rule" will be revised
to include toe schedule for 10 CFR 50.65(a)(3) evaluation at the end of each refueling outage,
not to exceed two years. This revision will be completed by December 31,1998.
DATE widen FULL COMPLIANCE WILL BE ACHIEVED
Full compliance was achieved on May 5,1998, when we completed the refueling cycle No.11
evaluation.
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