ML20205E652
| ML20205E652 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/13/1988 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bird R BOSTON EDISON CO. |
| References | |
| EA-88-263, NUDOCS 8810270431 | |
| Download: ML20205E652 (3) | |
Text
D. C S
Senior Vice President - Nuclear Pilgrim Nuclear Power Station RFD #1 Rocky Hill Road Plymouth, Massachusetts 02320 Gentlemen:
Subject:
Exercise of Enforcement Discretion Relative to Pilgrim Fire Barrier Deficiencies This letter is sent to advise you that the NRC will exercise enforcement dis-cretion and not issue a Notice of Violation or a civil penalty concerning the extensive number of fire barrier deficiencies identified by Boston Edison Company (BECO) as part of the extensive fire barrier inspection and upgrade program during the extended outage at Pilgrim. The specific deficiencies involved multiple fire barrier penetration seals that were inoperable due to either (1) a lack of documentation verifying the adequacy of the seals, (2) material degradation of the seals, or (3) BEco's uncertainty over seal requirements.
These deficiencies were reported to the NRC in various Licensee Event Reports (LER's) and through discussions with our resident inspectors.
In response to the fire barrier penetration problems, you performed an extensive penetration seal inspection and upgrade program and identified 3900 of 5200 penetration seals which did not meet acceptance criteria. The NRC noted, in Inspection Report No. 50-293/88-19, that (1) you have repaired or reanalyzed those seals which were deficient, and (2) your fire barrier inspection and upgrade programs were reviewed and found acceptable.
Given the nature and megnitude of the fire barrier deficiencies, the NRC would normally (1) issue a violation for these deficiencies, (2) classify the deficier,cies in the aggregate &t Severity Level III in accordonce with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR 2, Appendix C (1988) (Enforcement Policy), and (3) absent any mitigating factors, assess a civil penalty. However, in accordance with the guidance set forth in Section V.G.2, of the Enforcement Policy, I have decided, after consultation with the Director of Enforcement and the Deputy Executive Director for Regional Operations, to exercise caforcement discretion and not issue a Notice of Violation or a civil penalty in this case because Pilgrim has been in an extended shutdown since April 1986 in conjunction with Confirmatory Action Letter 86-10, related to generally poor performance over a long period. During j
0FFICIAL RECORD COPY PROP ENF DISC PILGRIM - 0003.0.0 10/13/88 8810270431 681013 PDR ADOCK 05000293 O
PDC fp
Boston Edison Company 12 the shutdown, substantial improvements were made in the management and material condition of the plant, including improvements in the fire protection program which identified these deficiencies. We recognize that during the latter two-thirds of that shutdown, significant resources were devoted to identify fire protection deficiencies, and appropriate corrective measures were taken.
However, the NRC has established regu!ations in the fire protection area, as well as all other areas of plant operation, to help ensure public health and safety, and has enforcement authority available to ensure compliance with this regulation. Therefore, in the future, we continue to expect that if deficien-cies exist, they should be promptly identified, corrected, and reported to the NRC.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter will be placed in the NRC Public Document Room.
Sincerely, Original Sicned By i:nLu.;' 7. La"LL William T. Russell Regional Administrator cc:
K. Highfill, Station Director R. Anderson, Plant Manager J. Keyes, Licensing Division Manager E. Robinson, Nuclear Information Manager R. Swanson, Nuclear Engineering Department Manager The Honorable Edward J. Markey The Honorable Edward P. Kirby The Honorable Peter V. Ferman B. McIntyre, Chairman, Department of Public Utilities Chairman, Plymouth Board of Selectmen Chairman, Duxbery Board of Selectmen Plymouth Civil Defense Director P. Agnes, Assistant Secrett y of Public Safety, Commonwealth of Massachusetts S. Pollard, Massachusetts Secretary of Energy Resources R. Shimshak, MASSPIRG Public Document Room (POR) local Public Document Room (LPOR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Massachusetts (2) 0FFICIAL RECORD COPY PROP ENF DISC PILGRIM - 0004.0.0 10/13/88
e -
,7 ll $;.l ';.
Boston Edison Company 3
bec:
Region I Docket Room (with concurrences)
Management Assistant, ORMA (w/o enc 1)
W.-Russell, RA W. Kane, DRP S. Collins, DRP J..Wiggins, DRP R. Blough, ORP L. Doerflein, ORP M. Kohl, ORP B. Boger, NRR R. Wessman, NRR D. Mcdonald, NRR J. Gutierrez, RC I:D RI:E0 MC'^J'-
j DHolody RI:0RP RI:0RP RBlough/geb JWiggins 10/ /88 10/h/88 k /0
-^
10/f/88 qGyf y
R P
ORP RI:RC RI:0RA RI:RA M I OE AfD@
p T /,,
h o
ns WK Gutierrez Allan WRussell JLieberman g
D
'6 / / # 5,'
10/ /88 10/$/88 10/ /88 10/ /88 10/ /88 (10/ /88g; 5, P l*[
o 4
\\
EMS
\\
-]
0FFICIAERECORD,00P.I PROP ENF DISTPTGRIM - C005.0.0 10/13/88 kJJC9 r
p.a m oe \\*i 0 p@